IR 05000219/1992099
| ML20059K362 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 01/26/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20059K349 | List: |
| References | |
| 50-219-92-99, NUDOCS 9402020051 | |
| Download: ML20059K362 (7) | |
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SALP REPORT - OYSTER CREEK 50-219/92-99
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BACKGROUND The SALP Board convened on December 22,1993, to assess the nuclear safety performance of Oyster Creek for the period July 19,1992, to December 11, 1993. The Board was conducted pursuant to NRC Management Directive (MD) 8.6 (see NRC Administrative Notice 93-02). Board members were Richard W. Cooper (Board Chairman), Director, Division of Reactor Projects, NRC Region I (RI); M. Wayne Hodges, Director, Division of Reactor Safety, NRC RI; Susan F. Shankman, Deputy Director, Division of Radiation Safety and Safeguards, NRC RI; and John F. Stolz, Director, Project Directorate. I-4, NRC Office of Nuclear Reactor Regulation. The Board developed this assessment for approval of the Region I Administrator.
The performance category ratings and the assessment functional areas used below are defined and described in NRC MD 8.6, " Systematic Assessment of Licensee Performance (SALP)."
II.
PERFORMANCE ANALYSIS - PLANT OPERATIONS Plant operations was rated a SALP Category 2 in the previous SALP period. Performance was characterized by good response to operating challenges by a professional and knowledgeable staff. In addition, improvements in procedures and equipment control contributed to overall improvements in plant operation. However, management oversight and reinforcement of performance standards was ineffective in reducing the number of significant operator errors.
During this SALP period, operators continued their strong performance in responding to plant challenges and controlling planned activities. Among noteworthy examples were operator performance during the integrated plant startup from the 14R refueling outage,
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operator response to two scrams that occurred early in the assessment period, and response
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to reactor recirculation flow-induced transients that occurred late in the assessment period.
Although troubleshooting activities by operators have not resulted in unexpected challenges to plant equipment or systems, the continued lack of a written plan and risk assessment for troubleshooting by operators increases the potential for losing control of the activity and could result in an undesirable system configuration or unexpected plant transient.
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Licensed and non-licensed operator training programs, which contributed to maintaining the strong command and control noted above, were excellent, and were strengthened by the use of the plant-specific simulator that was installed and certified during this SALP period. The licensee's initiative to upgrade emergency operating procedures (EOPs) significantly
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improved their quality.
Operators continued to exhibit a good questioning attitude that succeeded in mitigating or preventing problems. Noteworthy examples included the improved approach to operator rounds and logkeeping, as well as the request by control room staff for implementation of 9402020051 940126 PDR ADOCK 05000219 i
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administrative controls to maintain positive control of a fire pump battery charger for replacement of a non-safety-related relay during component troubleshooting.
Operations and all other plant departments were significantly challenged during the 14R refueling outage because of the many significant plant modifications and otherjobs that required specialized system configurations. Operators effectively controlled outage work and ensured that activities were performed within the bounds of the shutdown risk management plan. As a result, the outage was conducted in a safe and exemplary fashion.
The licensee continued to staff the control room beyond staffing levels required by the Technical Specifications. Improved management oversight and communication of performance expectations to operators were effective in reducing the number and significance of personnel errors. However, early in the SALP period, an error made by an operations
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engineer while developing a temporary procedure change resulted in a significant event involving degraded core cooling that led to an undetected heatup of the reactor to above 212"F without primary containment established.
Notwithstanding Operations Department Management's communication of performance expectations, instances of a lack of specific guidance to operators led to inconsistent or inappropriate application of technical specification requirements that occurred throughout the assessment period. The most significant example involved the lack of an effective operability /reportability assessment process, with the functions fragmented and not well defined. This problem contributed to a delay in the reportability determination for 4.16kV bus undervoltage relays, as well as an improper operability determination relative to the average power range monitors (APRMs) on discovery of a failure to conduct weekly surveillance tests. Management attention is needed to better define the operability process at Oyster Creek, and particularly to define the roles and responsibilities of the Engineering and Operations Departments in making operability determinations.
In summary, performance improvements in the plant operations area were noted throughout the SALP period, but particularly within the last six months of the period. Plant challenges were aggressively and conservatively addressed during periods of plant operation, as well as during the particularly challenging 14R refueling outage. However, the licensee must ensure appropriate and consistent operability determinations are made by more rigorously defining the process and the roles of the Operations and Engineering Departments. In addition, management needs to provide greater administrative controls for operators who control troubleshooting activities.
The plant operations area is rated Category 2.
III.
PERFORMANCE ANALYSIS - ENGINEERING During the previous SALP period, engineering was rated Category 2. The in-house development of modifications was a noted achievement. There was a proactive approach to preparation and release of modification packages. Improvements were noted in root-cause
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analysis and communication with other organizations. Engineering strengths were observed in the support of the electrical distribution system inspection, and weaknesses were observed in support of motor-operated valve activities. Engineering support of licensing activities was generally good and the technical capability of the engineering staff was a strength.
During this SALP period, design modifications were well planned and the licensee demonstrated good management oversight. Examples include: (1) modification of the drywell to reduce the potential for corrosion (sandbed removal); (2) station blackout modifications; (3) deletion of containment spray automatic start logic; (4) isolation condenser piping stress improvements; and (5) service water piping repair. Modification documents were well prepared and complete and included good safety evaluations and 50.59 reviews.
There was generally good communication between the onsite and offsite engineering staffs.
The recently developed onsite system engineering organization was responsive to operations and maintenance activ.ities and was considered a strength.
Engineering analyses were excellent. The evaluation of damage to a reverse-powered emergency diesel generator (EDG) was very thorough. There were good analyses in the evaluation and trending of degraded control rod drive pump performance. Licensing submittals and presentations were of high technical quality. Amendment requests, such as for the reduction in drywell pressure and changing the trip logic for the low condenser vacuum scram, were of high quality and seldom required requests for additional information.
The presentation to the staff on the drywell corrosion mitigation program and the core spray sparger crack were very detailed and complete.
There was good engineering support of maintenance and operations. This was exhibited in the inspection and repair of the EDG cooling fan and in troubleshooting failure of an EDG to start. There was strong engineering support in the repair of the EDG fuel oil transfer leaks and turbine electrohydraulic pressure regulator. System engineering adequately coordinated and executed troubleshooting activities and no specific problems resulted. However, no formal guidance or administrative controls exist for the conduct of troubleshooting by system engineering personnel.
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Emphasis was directed at valw testing and erosion / corrosion programs by adding more permanent corporate technical fuietions staff to support these programs. The installation in the control room panel of plug-in juicper terminal blocks enhanced the implementation of
emergency operating procedures.
In some instances, safety evaluations were incomplete, as were some responses to industry notices. Safety evaluations were lacking or incomplete for the following: the impact of defeating automatic recirculation pump trip when performing a temporary modification; soil grout injection for underground service water leak repair did not evaluate the seismic effect on buried pipe and nearby components; and, responses to industry experience on Potter &
Brumfield relays and on Agastat relays were incomplete. Timeliness of corporate engineering inputs for operability /reportability determinations was a concern. This timeliness problem appears to result from a lack of a formal, well-understood process for identifying operability /reportability needs in emerging engineering issues.
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In summary, engineering was approached with a strong safety ethic. Design modifications were well planned and executed, and there was strong management oversight. Engineering analyses were excellent. There was good engineering support of operations and maintenance.
However, there were instances of incomplete safety evaluations and incomplete response to industry notices. Timeliness of corporate engineering input to operability /reportability issues is a concern.
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The engineering area is rated Category 1.
IV.
PERFORMANCE ANALYSIS - MAINTENANCE
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During the previous SALP period, maintenance was rated Category 2. The maintenance had been generally effective, but efforts were primarily reactive. The material condition of the plant had improved, but equipment challenges indicated weaknesses in the implementation of a long-term improvement program. Surveillance was particularly well controlled and conducted. Additional attention to detail was needed to prevent occasional errors in surveillance performance. Work planning and scheduling improved, in part due to the
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continued improvement in communications between maintenance and other onsite organizations.
During this SALP period, the licensee demonstrated a strong overall safety perspective and strong management involvement and oversight. Solid critiques were used to drive procedural adherence and accountability of personnel. Management was aggressively involved in resolving safety concerns related to the removal of sand from the drywell and in the valve maintenance and overhaul project. There was good first-line supervisor involvement in the oversight of work.
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Maintenance support of management initiatives related to plant risk produced concrete and measurable improvements to safety and plant reliability. The shutdown risk management program was a strength in that both planning and outage control were well defined in a safety context. Information on plant risk management had been widely disseminated to all outage work groups in the daily outage status report. The lessons learned from work progress and field changes for the modification of EDO 1 were used to facilitate work on EDG 2.
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There was a general improvement in preventive maintenance (PM) through the creation of the Component Maintenance Team, a group responsible for long-term upgrades to the PM program and for making significant changes to existing PM tasks. Although in an early stage of implementation, improvements were already observed from this program and more are expected from the continuing management presence. Corrective maintenance efforts, including troubleshooting, were well coordinated, planned, and executed. For example, the electrical maintenance activities in the energized 4.16 kV switchgear were well planned and executed; maintenance personnel promptly identified and repaired leaking seals on the secondary containment railroad bay door and personnel air lock; during APRM troubleshooting, the instrument and control technician used appropriate vendor manuals and surveillance procedures to adjust and check the APRM response - the job order contained the necessary instructions and the work was well coordinated with control room operators.
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A number of weaknesses in surveillance procedures resulted in inadequate testing, plant transients, and unacceptable plant conditions. Core spray surveillance did not address the requirement to reduce average planar linear heat generation rate (APLHGR) to less than 90 percent when one core spray system was inoperable. Average power range monitor (APRM)
high-level clamping at 115.7-percent power at 100-percent and greater flows had not been surveillance checked for 23 years; high-level clamping had been adjusted once in 1987. The reactor vessel was unintentionally rapidly depressurized during a required leak rate test of the vessel due to a procedural inadequacy.
Programmatic weaknesses were noted in surveillance testing; these are of concern because of their potential effect on safety equipment. The licensee routinely performed smveillance tests on systems without declaring the systems inoperable during the tests. During a turbine load reject scram test, the licensee temporarily secured the test for more than three hours and resumed testing on the following shift. The logs stated that the system was returned to normal and that the surveillance would continue on the next shift; however, the surveillance contained no documentation of the temporary stoppage and there was no documentation to support the required independent verifications for the interim system restoration. In addition, there was no documentation of the re-verification of prerequisites or permission to resume the surveillance.
In summary, the licensee demonstrated a strong safety perspective and management involvement in maintenance ectivities. There was measurable improvement in preventive and corrective maintenance activities. However, weaknesses in surveillance procedures and programmatic weaknesses in the surveillance program are cause for concern.
The maintenance area is rated Category 2.
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i V.
PERFORMANCE ANALYSIS - PLANT SUPPORT I
i The previous SALP period had no plant support functional category. In this SALP period,
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this functional area covers three areas (radiological controls, emergency preparedness, and security) that had been rated separately in the previous SALP, as well as all activities related to plant support, such as chemistry, fire protection, and housekeeping.
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Radiological controls was previously rated as Category 2 because the licensee had maintained a well-staffed radiological controls organization with excellent radiation protection training.
Further, an improving trend was noted in adherence to procedures and the practices of radiation workers. The licensee conducted effective radiological environmental monitoring, effluent control, and confirmatory measurement programs with a weakness noted in calibration procedures for effluent monitors, b
During this SALP period, the radiological controls program continued to be well staffed.
The radwaste organization, particularly, was well staffed with well-qualified individuals.
The training program for those individuals responsible for certifying the adequacy of radioactive waste materials shipments was excellen.
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Despite system design-based difficulties in developing representative scaling factors (used to account for radionuclides not detected by gamma spectral analysis), good compensatory i
measures were taken by the licensee. Further, significant improvements were made to the licensee's air-sample and swipe-sample counting facilities.
Good results have been achieved by the licensee's program to keep radioactive exposure "as low as reasonably achievable (ALARA)." Painting of the bare concrete surfaces throughout the station was designed to reduce radioactive waste / materials and facilitate more efficient decontamination efforts. A greater amount of shielding was used in the drywell during 14R, and senior management provided the Radiological Controls Department with a dedicated
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window in the outage to emplace drywell shielding before the start of significant work activities. The licensee's efforts in preparation for, coordination, and control of the 14R refueling outage activities were good. Also, several modifications were made in 14R which produced ALARA benefits. For example, a modification to the condensate resin system was made to allow backwashing, thereby improving iron and cobalt removal in feedwater. Also, a new rigging crane was acquired for the removal of Electromatic relief valves (EMRVs) and safety relief valves (SRVs), thereby eliminating the need for one rigging crew when
conducting such work. In summary, the licensee's ALARA program was commensurate with the licensee's source term, and some aspects of the program were considered outstanding.
However, the mechanism for initiating ALARA reviews was of significant concern and contributed to the problems related to the work in the fill aisle of the new radwaste building in May 1993, Many of the issues highlighted by these problems involved inadequate instructions in radiological procedures being performed by workers and failure to review the work being performed in a highly contaminated area to ensure that radiation exposures were maintained ALARA.
Other weaknesses in the radiological control program involved inadequacies in access controls, improper high radiation area (HRA) barrier restoration and setup, and poor
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adherence to HRA controls. Further, inadequacies were noted in the preparation of some shipments off site in that gas generation problems were identified for two shipments of filter sludge water. Review of the licensee's handling of root-cause analysis and resolution of
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discrepancies indicated that, in some cases, the licensee was not aggressive in determining the root cause and, in other cases, discrepancies were not resolved in a timely manner.
The licensee's effluent and environmental monitoring programs continued to be effective.
However, the licensee failed to document the required biennial review of meteorological monitoring instrument calibration procedures, and several monitors were out of service for extended periods of time.
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Security was rated Category 2 in the previous SA'LP report because of a generally effective program with some weaknesses, especially in maintenance support. During this SALP period, the security program at Oyster Creek continued to adequately adhere to all aspects of the licensee's security plan. New cameras, fiberoptic cable, and new monitors were added to improve the assessment system. An operational safeguards response evaluation (OSRE) that
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was conducted at the station from July 12 through July 15, 1993, found the licensee's capability to respond to an external threat generally sound. The evaluation raised several issues, including problems during some threat scenarios in the protection strategy for certain critical equipment sets. The licensee responded to all issues raised and identified corrective actions for their resolution. The effectiveness of these actions was yet to be fully assessed.
Maintenance support for security, identified as a weakness during the previous SALP period, improved during this SALP period.
During the previous SALP period, emergency preparedness was rated Category I because of strengths in management, innovative staff, and good working relationships with offsite agencies. Training and performance during four actual events and the annual exercise further
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demonstrated the superior qualities of the program. Inadequate maintenance and testing of the ventilation system in the Technical Support Center, identified as a weakness, was corrected during this SALP period. During this SALP period, the effectiveness of the
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emergency preparedness program was evidenced by excellent exercise performance, i
including excellent command and control in all facilities and innovative Operational Support Center staff approach to repair activities. The licensee continued excellent relationships with such offsite organizations as State and county authorities.~ Further, the licensee provided offsite emergency worker training.
Overall, housekeeping and the fire protection program were superior. The fire training
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school was a strong element of the fire protection program with well-developed courses and inclusion of offsite responders. A minor weakness identified during the period was inappropriate storage of trash and tools. However, the licensee responded quickly to resolve this concern.
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In summary, the licensee's efforts resulted in good plant support with superior performance in the emergency preparedness program as a notable highlight. The fire protection program continued to be well implemented. Security remained adequate. Areas for improved performance were noted in the radiological controls program and in implementation of the effluent and environmental monitoring program.
The plant support area is rated Category 2.
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