IR 05000219/1987034

Insp Rept 50-219/87-34 on 871019-22.No Violation Noted.Major Areas Inspected:Followup on Corrective Actions Following 870911 Event Re Requirement to Have Two Recirculation Loops in Full Open Position

ML20149D330
Person / Time
Site:	Oyster Creek
Issue date:	12/21/1987
From:	Cowgill C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20149D319	List: IR 05000219/1987034 ML20149D315
References
50-219-87-34, NUDOCS 8801120278
Download: ML20149D330 (12)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N Docket N License N OPR-15 Priority - Ca tegory C Licensee: GPU Nuclear Corporation P.O. Box 388 Forked River, New Jersey 03731 Facility Name: Oyster Creek Nuclear Generating Station Inspection Conducted: October 19-22, 1987 Participating Inspectors: D. J. Florek M. G. Evans D. K. Allsopp Approved By: I

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C. J.(Cowg1(11h Chief l(- 2/ l 9 b' 7 date'

Reactor Prb4dcts Section 1A, DRP Inspection Summary:

Inspections were commenced on October 19, at the corporate offices, and completed on October 22 at the site. The inspections were performed to follow-up on corrective actions following an evint on September 11, 1987 where in a condition requiring at least two recirculation loops to be in the full ;

open position was not me Results:

No violations were identifie l

l 8801120278 871228 PDR ADOCK 05000219 0 DCD

., o Details 1.0 Overview On September 11, 1987, maintenance activities in progress at the plant led to the violation of Technical Specification Safety Limit 2.1.E. in that fewer than two set of recirculation loop valves were not fully open for a short period of time as required by the limit. For details of this event see Inspection Report No. 50-219/87-2 The purpose of this inspection was to ascertain that the corrective actions performed by the licensee, in response to this safety limit violation, were adequat .0 Policies and Procedures regarding Integrity and Procedure Adherenc .1 Discussion The inspector reviewed corporate policies, site policies, letters, procedures, human relation publications, and interviewed maintenance personnel, Group Shift Supervisors, and reactor operators to deter-mine that standards for integrity and procedure adherence had existed and the personnel were aware of these standard The inspector obtained information of the corporate policies based on an inspection conducted at the corporate offices on October 19 and 20, 1987. Based on information provided at the corporate offices the inspector obtained additional information at the site and conducted interviews with five maintenance personnel (foremen, job coordinator, and supervisors), two on-shift Group Shif t Supervisors, three on-shif t reactor operators, and one operations staff person with a reactor operators license to ascertain whether these individuals were aware of these policie The documents reviewed indicated that GPUN has had policies concern- )

ing the integrity of the employees at Oyster Creek. The policies have been reinforced by memos from upper management to the employee A specific seminar on the legal responsibilities of licensed

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operate s was given to the licensad operators during the 87-1 Re-qualification Cycle which also reinforced the integrity and account- ;

ability of the actions of the licensed operators. The licensee also j has a vehicle in the Employee Assistance Program wherein if an l employee experiences a condition that may impact on his ability to l function he may seek help. Based on the discussions with the persons l interviewed, the individuals were clearly aware of their respon- I sibilities and the high standards that they must achieve. They acknowledged that they have received reinforcement on these policies '

periodically in discussions and from receipt of memos from site and ;

corporcte managamen ;

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A similar conclusion exists for the awareness of the need ta adhere to procedures. Oyster Creek has repeatedly reinforced the need fo employees to adhere to procedures. Administrative procedures require that operations personnel adhere to procedures and follow-up memos to  ;

various plant events reiterated the need for following. procedure *

Training in administrative-procedures adherence was conducted with the operators during the period May to July, 198 The person '

interviewed were aware of the need.to folicw procedures and knew that procedures could be changed if-needed to accomplish a specific tas :

They also indicated that they did not receive supervisory pressure.to l ignore the procedure to get a job done in order to meet.a schedul :

In fact, they indicated _the opposite was the cas !

i 2.2 Review of GPUN Attitude Analysis and Balancing of Shift Strengths  !

i 2. GPUN Employee Attitude Survey j In April 1937, the licensee announced to the employees at  !

Oyster Creek that a survey of attitudes of all system i employees would be conducted. The survey would identify  ;

what the personnel at Oyster Creek felt, what was done l right, and what areas could be strengthened. The results  !

of the survey would be provided to the employees along with  ;

the assessment of what will be done to improve those  !

conditions that the employees identified as. concerns. The l survey was broadly based in the areas under investigation  !

with over 150 questions asked. Topics surveyed included ,

safety perspective and organizational performanc l In August 1987, the results of the survey were presented to the licensee management and the Office of the President of  :

GPU In September, a brief summary c f results were pro- i vided to the employees. The licensee is in the process of  ;

addressing the concerns of the survey and developing  ;

feedback to the employee This will be in the form of  !

what was identified, what the organization can do, what is i 4 still being worked upon, and what can't be done and wh j Management support in using the survey results to improve '

the performance of Oyster Creek was evident. The Director *

of Oyster Creek was tasked with chairing a group to resolve  ;

the concerns that were of a generic nature. Lower level l managers were tasked with assuring that the concerns identified at a specific group level were also addresse Utilization of personnel within the work group was  ;

encouraged to address the concerns identifie '

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2.2.2 Teamwork and Leadership -Training

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Over the past 18 months the licensee has attempted to ,

improve the-teamwork =and leadership aspect of the persons 't involved with Oyster Creek. A major effort recently .

developed included seminars conducted withL nearly 250

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Oyster Creek managers and supervisors based on a program developed by an outside consultant. -The licensee has used i the consultant to develop the necessary skills within the organization _to pursue the. teamwork and leadership ;

training. As reported in prior inspections an improvement i in teamwork was noticed after this training was provide i This program has the support of corporate management with -l

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reinforcement aspects included within the program. This -!

includes receiving copies of a newsletter, "Team Talk", I plus rescheduling of the program one month and one year [

after the seminar was conducted. Based on discussions with *

Senior Site Management, the licensee is continuing to apply .!

the concepts of the teamwork and leadership programs in the organization and assessing new methods to apply the program concepts at Oyster Creek. This is an ongoing activit .?.3 Balancing of Shift Strengths After the September 11 safety limit violation at Oyster Creek, the licensee instituted an assessment of the operating crews from a teamwork and leadership perspective attempting to balance the shift strengths. Mary of th skills developed from the teamwork and leadership training were utilized in this assessment. The licensee utilized corporate staff under corporate vice presidential' direction including its staff behavioral scientist in the development of this assessment. The assessment was based on interviews with individuals from a broad spectrum of work groups interfacing with the shift crew The persons utilized for these inputs for the most part did receive the teamwork'and leadership training and thus were quite familiar with the concepts that tha interviewers were probing. The licensee systematically analyzed the data obtained and developed conclusions and recommendations. These conclusions and recommendations were forwarded to sen;or management on site to assess. The recommendations and conclusions are being utilized by senior site management as one of the inputs in the strengthening of the operating tea . --~ .-. ... . .. .. _ _

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2.3 Findings No unacceptable conditions were iden'tified. . The licensee corrective -

actions regarding-Integrity and Procedure Adherence policies and procedures, were found to be adequat The inspector reviewed the licensee's methodology, as well as, the conclusions and recommendation The methodology was able to assess the operating crew strengths and can be effectively. utilized as one tool to assist management in the strengthening of the operating tea .0 Plant Procedure Review and Revision Efforts 3.1 Liscussion The inspector reviewed the licensee's corrective actions, regarding the recirculation loop availability Safety Limit Violation.(SLV),

committed to in GPU Nuclear letter from P. Clark, President, GPU Nuclear to Dr. T. Murley, Director, Office of Nuclear Reactor Regulation, dated September 20, 198 .2 Procedure Review and Revision The inspector discussed the licensee's plant procedure review and revision efforts regarding the SLV with a licensee representativ The representative stated that a review of all plant procedures, to determine if adequate statementa are present which warn the operator of the SL, is in progress. He stated that review of operating procedures specifically affecting reactor recirculation pump operation has been complete Changes have been made to the following procedures:

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Procedure Number 301, Nuclear' Steam Supply System, Revision 40, Effective dated 10/8/8 Procedure Number 305, Shutdown Cooling System Operation, Revision 32,. Effective date 10/8/8 Procedure Number 2000-RAP-3024.01, Nuclear Steam Supply System Annuciator Response Procedures, Revision 23, Effective date 10/8/8 The inspector reviewed these procedures and noted that appropriate changes were instituted regarding placement of cautions which warn of the SL. In addition, the inspector noted that changes were also made to procedure numbers 301 and 305 regarding operation of recirculation loop valves; changing of recirculation ficw; and securing of the final two recirculation pumps in off-normal plant condition <.

3.3 Training of Operators on SLV and Procedure Changes The inspector discussed the supplemental training of shift operators regarding the SLV with a representative of the licensee's training department. He stated that training consisted of both classroom lecture and simulator training on the Basic Principles Trainer (BPT). The inspector reviewed the lesson plans for the SLV training and held discussions with several shift operators who had re:eived the trainin The inspector verified that the training included discussion of the May 2, 1979 and September 11, 1987 events at Oyster Creek; discussion of procedural limitations on recirculation loop availability and their basis; discussion of control room indications applicable to the September 11, 1987 SLV; review of changes made to reactor recirculation operating procedures; and discussion of the importance of adherence to procedures. In addition a memorandum from the training department to all licensed operators dated October 19, 1987 identified the significant procedural changes made as a result of the SL The inspector verified that 23 of 29 shift operators had received the required training prior to the completion of the inspectio ,

In a follow-up phone conversation with a licensee representative en October 29, 1987, the inspector verified that one of the remainir.g six operators received the training on that da .4 Findings No unacceptable conditions were identifie The licensee corrective actions, regarding procedure and revisions and training of shift operators, were found to be adequat P 4. Training Regarding Limitorque Operation ano Backseating and Maintenance Controls Limitorque Operation and Backseating Details The licensee has implemented the following training to satisfy restart commitments anc to improve specific skills in the mainten- '

ance, operation, and engineering department Subject Training For 1) Safety Limit Violation Lessons Learned Operations 2) Basic Principles Trainer Scenario Operations

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3) Detailed Characteristics of Limitorque Operations, Operation Maintenance, Engineering 4) Tagging and Switching Procedure Operations, Maintenance, Engineering 5) Valve Backseatiag Procedure Operations, Maintenance, Engineering 6) Station Critique of Safety Limit Violation Operations, Maintenance, Engineering <

7) Edwin H. Stier Safety Limit Inspection Operations, Maintenance, Engineering 8) Procedure Compliance Requirement Operations, Maintenance, Eg,ineering The training on lessons learned from the safety limit violation is being conducted by the manager 4 plant operation. A;l other training topics are being conducteo by training center instructors with exception of

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the station critique and Edwin H. Stier investigation which are required reading. An examir . tion to test training ef fectiveness is administered at the conclusion of each training session. The inspector held discussions with a training instructor and reviewed the training session handout and examinatio The training sessions appear to have been both detailed in scope and effectively conducte The following is a status of colpleted training for the operations, maintenance, and engineering department The licensee's intentions are to have completed licensed operator t;aining prior to restart or have deficient individuals taken off the watchbill until their training 1:; ,

complete. The maintenance department has sent all 58 area supervisors, group supervisors, job coordinators, and planners to the above specified l training. The engineering departient bas sent 10 of 14 selected spare l part engineers, operation engineer;, electricil engineers, aiid mechanical ;

engineers to the above specified tr ining. The remaining four engineers ;

were scheduled to complete training during the week of October 26, 198 ;

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Several procedure modifications have been or will be implemented to simplify or clarify procedure requirements. The "Generic Repack Procedure for the use of Chesterton St/le 5300 and Style One (1)

Packing" has been revised to include the necessary pre autions and limitations to perform the repacking with the valve on its badm This procedure references the appropriate backseating pr % re The station's existing backzeating procedure and standing order 33 will be combined into a single plant operations series procedure by the end of Decemoer, 198 In conclusion, all restart commitments in this area have been satisfied with the exception of the completion of limitorque operation trainir.g by the operation and engineering department .2 Control of Maintenance A: tivi +1es The licensee has implemented several improvements in the maintenance area to meet restart commitments and to enhance control of mainten-ance activitie The maintenance organization has been reorganized from an area responsibility to a discipline responsibility concept to improve communication and control. Maintenance management is planning to conduct internal training to stress the importance of proce6 ural compliance, shift turnover, and maintenance tagging responsibilities. This training is scheduled to be completed prior to plant restart, however, had not started as of October 23, 198 The maintenance department has issued a policy statement delineating interim controls to be used to assure adequate communications and transfer of job control between maintenance supervisors during shift turnove The maintenance department ;us implemented an interim job turnover document to improve management control of jobs in progress during shift turnover. A detailed turnover procedure and document is being developed and is scheduled for completion by the end of December, 198 To improve coordination between departments during outages, the station has implemented a shift management meeting between the group shift supervisor, the group radiation control shift supervisor, and the maintenance superviso The station administrative procedures for control of maintenance, conduct of operation, and equipment control have been modified to clarify the operations and maintenance interface responsibilities. Training on ,

these procedure modifications is being conducted during the required !

training on Limitorque operation and backseating sessions discussed j in paragraph 1. This training also discussed an interim revision to 1 the switching and tagging procedure which delineates specific l operations and maintenance responsibilities during maintenance. A l complete revision to the switching and tagging procedure is in l progress with an expected completion date of December, 198 The i station critique of the safety limit violation is required reading ;

for maintenance production personnel, planners, licensed operators, I and equipment operator I

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In conclusion, all restart commitments in this area have been satisfied with the exception of the internal maintenance training on procedural compliance, shift turnover, and maintenance tagging responsibilitie .3 Findings No unacceptable conditions were identified. The licensee corrective actions, regarding training for limitorque operation and backsaating and maintenance controls, were found to be adequat .0 Exit Meeting The inspectors briefed licensee management at the exit meeting on October 22, 1987 on the findings. No written material was provided to the licensee by the NRC during this inspection. There was no indication by the li:ensee thar, any proprietary information was involved in this inspe:' . io Licensee Corrections Actions were discussed in a licensee letter dated September 20, 1987 and a letter dated September 22, 1987, as well as in Licensee Event Report 87-03 .

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Enclosure I Documents on Integrity Assessment Corporate Policy 1000-POL-1000.02 Quality of Work Policy, Revision 0 dated 12/1/86 1000-POL-1020.01 Use of Ombudsman Function for Resolving Nuclear or Rad Safety Concerns, Revision 2, dated 5/3/82 1000-POL-1740.01 Employee Contact with Regulatory Agencies, Revision 0 dated 11/18/82 1000-POL-2002.00 Standards of Conduct, Revision 0 dated 5/15/86 ;

1000-POL-2200.01 Human Resources Policy, Revision 0 dated 5/20/86 GPUN Vision and Value Statements provided to Employees 5-6/87

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Corporate Procedure and Plans 1000-ADM-1218.01 GPUN Policy, Plan and Frocedure System, Revision 2 dated 5/1/86 1000-ADM-2002.04 Employee Fitness for Outy Procedure / Drug and Alcohol, Revision 0 dated 5/5/86 1000-ADM-2130.01 Disciplinary Guidelines, Pevision 0 dated 5/2/86 1000-PLN-2504.01 Employee Assistance Program Plan i Letters and Memoranda ,

R. Arnold to GPUN Employees, Interim Policy on Assignment of Employees whil3 Questioning Their Performance or Conduct are Being Resolved, dated t 9/27/83 ' . lark to GPUN Employees Assigned to Nuclear Facilities, Meeting Responsibilities, dated 12/8/83 P. Clark to GPUN Employees Engaged in Nuclear Activities, Some Implications of the Indictcent of Metropolitan Edison Company for Pre-accident Activities at TMI-2, dated 2/27/84

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P. Clark to P. Fiedler et al, Support of GPUN Corporate Objective 11, dated 7/30/87 P. Fiedler to All Oyster Creek Employees, Retention of Data, dated 7/25/86 J. Sullisan to All Department Managers, Control Room Professional Dress, dated 2/27/87 P. Fiedler and P. Clark to Oyster Creek Group Shift Supervisors, Command Responsibilities, dated 3/5/87 Director R&EC Division to All R&EC Division Employees, Integrity and Discipline, dated 5/15/87 Director MCF and MCF Director Oyster Creek to All Department Employees, Integrity and Discipline dated 6/23/87 Oyster Creek Station Instruction 2000-POL-2000.01 Policy Statements-Personnel, Revision 1 dated 9/1/86 (Compendium of policy statements at Oyster Creek)

Documents Relating To Procedure Adherence Procedures 106 Conduct of Operations, Revision 45 dated 8/13/87 107 Procedure Control, Revision 37 dated 8/14/87 Letters and Memoranda J. Sullivan to All Operations Department Personnel, Procedure Compliance dated 11/23/83 J. Sullivan to All Operations Personnel, Outage Completion dated 3/16/84 J. Sullivan and R. McKeon to CRos, EDs, GOSs, GSSs, OSAs, Operations Staff, Procedure Doficiencies During Load Test Surveillance dated 5/16/84 J. Sullivan to All Operations Personnel, Conduct of Activities, dated 8/23/84 P. Fiedler to OC Department Heads, Outage Completion, dated 8/24/84 J. Sullivan to Equipment Operators, Equipment Operator Tours / Turnovers dated 4/17/86 .

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P. Clark to P. Fiedler et al, Support of GPUN Corporate Objective 11, dated 7/30/84 P. Fiedler to All Oyster Creek Employees, Retention of Data, dated 7/25/86 J. Sullivan to All Department Managers, Control Roem Professional Dress, dated 2/27/87 Other Documents Related to the Issues of Procedure Adherence and Integrity General Employee Training Information Revision 3 dated 2/16/87 '

GPUN Oyster Creek Rules and Regulations Supplement to JCP&L General Rules dated 5/83 Oyster Creek Newsletter "The Power Line" Issues dated 5/1/87, 5/29/87, 8/28/87, 9/17/87 and 9/25/87 '

Parsippany Newsletter "Parisppany Nuclear Update 3 Issues dated 5/18/87, 5/29/87, 8/21/87, 9/4/87 and 9/14/87 J. Sullivan to All Operations Personnel, Outage Responsibilities dated 6/9/86 J. Sullivan to All Operations Personnel, Oyster Creek Operations dated 5/22/87

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