IR 05000289/1985097

Revised SALP Insp Rept 50-289/85-97 for 850916-860430

ML20211G426
Person / Time
Site:	Crane
Issue date:	10/24/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20211G422	List: IR 05000289/1985097 ML20211G417
References
50-289-85-97, NUDOCS 8611040004
Download: ML20211G426 (60)

Text

a

.

Enclosura 4

.

L U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-289/85-97 GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION THREE MILE ISLAND NUCLEAR GENERATING STATION ASSESSMENT PERIOD:

SEPTEMBER I6, 1985 - APRIL 30, 1986 BOARD MEETING OATE: June 6, 1986 (

8611040004 861024 PDR ADOCK 05000289

.

G PDR

. - -

- _ _ _ _ _ _ _

-

.

.

.

.

l t

SUMMARY OF RESULTS A.

Facility Performance Interim Recent SALP SALP I Trend Functional Area (9/16/85-1/10/86) (9/16/85-4/30/86) (Last 1-2 Mos.)

1.

Plant Operations

2 Consistent 2.

Radiological Controls

1 Declining 3.

Maintenance

2 Consistent 4.

Surveillance Testing

1 Consistent-5.

Startup Testing

1 NA 6.

Emergency Preparedness Note 1

Consistent 7.

Security and Safeguards Note 1

Consistent

.

8.

Technical Support Note 1

Consistent

'

9.

Training and Qualifi-

1 Consistent

'

cation Effectiveness 10.

Assurance of Quality

2 Consistent

.

11.

Licensing Note 1

Consistent Note 1:

This functional area was not assessed as a specific area in the interim SALR.

B.

Overview

"

Overall, the licensee continued to operate TMI-1 in a competent and-safe manner.

Clear and well defined programs are in place which provide the necessary direction and guidance for assuring that the various functions are integrated and controlled.

Licensed operator performance continued at a high level.

Some problems were identified with non-licensed staff training. Although control room operators performed well, a number of events and violations were attributable to personnel error.

In some cases this was aggravated by procedural deficiencies.

The concern in the interim SALP regarding an apparent general disregard of workers for equipment protection in the operating spaces was not observed during this period indicating (

that the licensee's corrective actions have been effective.

Plant equipment remained in good material condition evidencing a generally strong and aggressive preventive and corrective maintenance program, t

_.

.

,

.-

-

_ _ - - _ _ _ _ _ - _ -.

'

.

.

t

'

Six unplanned reactor trips and shutdowns occurred during this period, five of which were attributed to secondary plant problems.

Unnecessary challenges to safety systems and operators continues to be a concern. More attention to preventive maintenance and in some instances secondary plant design could result in fewer failures of susceptible balance of olant features that result in challenges to the reactor protection system.

Althougn technical support for startup activities was good, increased attention to the overall technical support area is warranted. As previously mentioned, programs are strong but implementation is lack-

ing. A number of examples of improperly prepared / installed modifi-cations reflected the lack of a thorough design review both at the peer / supervisor level and at the regulatory-mandated technical review level.

This was further supported by problems observed by licensee-initiated review groups subsequent to the normal review process.

A recurring ' theme in a few areas is the staff's observation that some activities are performed in a hurried manner to meet schedules and that this sometimes results in problems.

For example, some unplanned exposures and radiological releases are attributed to the higher pace of activities.

In this regard the SALP Board attributes this partially to a conflict between upper management's expressed goals for achieving-a high level of performance and middle management's emphasis on meeting schedules. We believe that this conflict has not yet been effectively dealt with and is responsible for many of the problems discussed in this SALP.

Similarly, the degree of supervisory _ oversight in the review of routine procedures and their implementation was found to be lacking.

!

i l

i

,

<

.

__

. _ _.

_

_

-_

_

_..

.-

._

___

. _

<

.

..

(

IV.

PERFORMANCE ANALYSIS A.

Plant Operations (3528 hours0.0408 days <br />0.98 hours <br />0.00583 weeks <br />0.00134 months <br />, 54%)

The interim SALP period rated the licensee's performance as Category 2.

The NRC found the licensee displayed excellent overall control of the plant; management established their presence and involvement during all shifts; and, management exhibited conservatism in resolving technical issues in an adequate, but not aggressive, manner.

Implementation of procedures for significant evolutions was

<

adequate.

For the most part, procedures were technically sound but, individual procedure step inadequacies challenged personnel in strictly' adhering to those' procedures for routine activities.

'

Lic~ensed operator performance. continued to be oriented toward

nuclear safety. Operators conducted themselves in a professional manner.

Shift turnovers and pre-briefings for major evolutions were thorough and detailed.

Depth of knowledge of plant. anomalies,

,

current plant conditions, and on going evolutions by operating crews I

was excellent.

This is partially attributed to. licensee training of operators.

In general, the licensed operators' positive attitude toward operating the plant in a safe manner is one of the major factors in contributing to good performance of the pisnt.

Licensee personnel maintain the control room and conduct related to

.

business in a manner to avoid disruptive activities and to present a

'

posture of overall control of operations. Operations staff is

,

segregated from otner personnel by an entrance barrier made up by a panel, bookcases, and an entrance gate.

Routine business and requests, including pre-shift briefings, are conducted across that bookcase section to avoid unnecessary. personnel in the control room proper

,

i area.

No radios, televisions, and unrelated reading material are f

permitted; and, for the most part notebooks,' procedures, and manuals are properly stored. A dress code continues to be implemented. Main control board overhead annunicators that are normally lighted are

i relatively few and the licensee has' administrative controls to track

'

alarms that periodically change status or come on and stay lighted beyond one shift. With additional effort by licensee technical sup-port personnel, a condition where no anunciators are routinely lit ~1s achievable. Overall, a professional atmosphere is maintained in the control room.

i Despite upper management directives to adhere to procedures, a proce-

dure adherence problem persists and it is related to attention to detail ir, complying with procedures. Moreover, it also appears to j.

be precipitated by middle. management attempting to maintain schedules of activities and their ineffectiveness in communicating the expressed upper management intention in this area.

In several instances during

the startup from the ECT outage, inattention to detail and communi-i '

cation problems along with the fast pace of activities led to

'

improper procedure implementation.

Exam;;es include:

no

,

'

-

.~

--

., - -

, _. - - =..+

- - -,,. -,..,.

,

,n,

-

-

_, - - - -

--

.

.

(

shift SRO in control room for 1/4 hour with the plant above 200 F; improper deboration valve alignment; and failure to properly respond to a waste gas first alarm (alert) during.a routine' gas release.

In other minor cases:

completed procedures requiring steps to be signed

off or initialed as being completed were not done; out-of-specifica-tion log readings continued for long periods of time; and some opera-ting crews performed only minimum documentation of plant evolutions, plant anomalies, or surveillance / maintenance activities in their logs (representing minimal compliance with related administrative controls on logs and record-keeping).

From a control viewpoint, the two management directives to meet schedules and adhere to procedures can coexist. Overall, control of special evolutions and testing has been quite good; but, in several operational instances, as noted above, dealing with routine activi-ties, licensee personnel (from management down to the worker) have

,

not properly implemented procedures.

This demonstrates that the conflict between the expressed procedure adherence policy and the

,

desire to meet established schedules has not yet been effectively

"

resolved.

Technical adequacy of station procedures was sufficient; however,

!

some weaknesses continued to be noted.

For example, a reactor trip was partially attributed to weak procedures associated with the main turbine lube oil system.

Lifting of a relief valve during a plant

degasification evolution demonstrated the need for a clearer proce-

!

dure. The QA monitoring of plant operations on all shifts aided the licensee in identifying these plant operational problems.

,

An assessment of the licensee's safety and technical reviews organi-ration found the system was operating in accordance with the mecha-

'

nism stated in the technical specifications.

Each department thus achieves this requirement independently in diverse ways using differ-ent procedures and initiatives.

Because of this independence, many overview / analysis report's on the procedure review process are diverse and for the most part, they are not diagnostic with respect to the nature of problems in the program. As a result cognizant vice pres-idents are missing the opportunity to assess problem areas and take appropriate corrective action. An exception to this is in the Nuclear Assurance Department, where reports do lean toward evaluative summaries i

for these reports.

,

J The plant is generally kept clean and free of transient combustibles.

Daily involvement by management has been aggressive with respect to fire prevention and housekeeping as evidenced by their frequent tours, including a daily backshift tour. However, a poor. practice permitted fire service water to be routinely used as a source of back-flushing water for other systems and equipment on a continuing basis which had-the potential for degrading the fire service water (

.

.

-

.. - _

-

.-

.

.

_ -.

.

-

.

-

,

,

.

REVISED f~

11C r

-system.

Further, with respect to fire protection training.and prac-

!

tices, the licensee program meets the minimum. requirements but, in

!

some instances, it lacks thoroughness in implementation to assure meaningful training.

!

Licensee Event Reports (LERs) from TMI-1 are generally reported with-in the required time period following the occurrence.. Reporting is accurate and appropriate corrective action generally is planned or taken.

,

!

The four unplanned reactor trips from power operation, which occurred i

in the 7-month report period, equates to a rate of approximately seven trips per year.

Several reactor trips were.the result of turbine i

or generator problems with the protection systems responding as expected.

Additional management attention is warranted in reducing secondary plant upsets during startup and routine operations.

~

}

Overall, the licensee's programs are strong in the area of adminis-trative controls and licensed operator performance.

For the most j

part, procedures were tecnnically adequate but individual procedure

.

step inadequacies persist. The licensee continued to experience

}

difficulty in providing the proper balance between schedular consid-erations and the expressed policy on procedure adherence. This was

particularly evident when middle managers inserted themselves directly

'.

and accelerated the pace of work activities.

Licensee management

'

needs to review their routine conduct of~ operations to see if. competing

.

factors are precluding the achievement of the goal to adhere to I

procedures.

!

Conclusion

,

i Category 2, Consistent i

Recommendations

'

,

Licensee: See text and summary of Section IV.J, Management

- Assurance of Quality.

'

!

$.

!

I i

i

.

___

._.

.

.

.

.

i system.

Further, with respect to fire protection training and prac-

tices, the licensee program meets the minimum requirements but, in

!

some instances, it lacks thoroughness in implementation to assure meaningful training.

The quality of training during fire drills was noted to be limited due to the large number of participants which resulted in a lack of realism in the training.

Licensee Event Reports (LERs) from TMI-l are generally reported with-L in the required time period following the occurrence.

Reporting is accurate and appropriate corrective action generally is planned or taken.

The four unplanned reactor trips from power operation, which occurred in the 7-month report period, equates to a rate of approximately seven trips per year.

Several reactor trips were the result of turbine l-or generator problems with the protection systems responding as expected.

Additional management attention is warranted in reducing secondary

,

i pl.at upsets during startup and routine operations.

'

Overall, the licensee's programs are strong in the area of adminis-j

!

trative controls and licensed operator performance.

For the most part, procedures were tecnnically adequate but individual procedure

-

step inadequacies persist.

The licensee continued to exoerience difficulty in proviaing the proper balance between schedular consid-

'

'

erations and the expressed policy on procedure adherence.

This was particularly evident when middle managers inserted themselves directly

j and accelerated the pace of work activities.

Licensee management needs to review their routine conouct of operations to see if competing j

factors are precluding the achievement of the goal to adhere to procedures,

'

i Conclusion Category 2, Consistent

>

Recommendations Licensee:

See text and summary of Section IV.J, Management l

Assurance of Quality.

l

!

i

!

(.

,

i

1-m

,

-

-,

,,. -. - -

-.,,

,

-,

---

.e.,

--,--

-

-

.-v..-

-

, -,

.

REVISED

'

.

12C

.

B.

Radiological Controls (389 hours0.0045 days <br />0.108 hours <br />6.431878e-4 weeks <br />1.480145e-4 months <br />, 6%)

Analysis During the interim SAlp period, the licensee's performance in this area was Category 1.

Program elements were noted to be sound and thorough. Minor problems were identified in the area of radiological work planning where better planning could have prevented releases of radioactivity ar.d personnel contamination.

Problems of this type continue and are discussed in this section.

The licensee's radiation protection organization contains sufficient technical expertise and an appropriate level of staffing to adequate-ly implement the program. Thorough and well-defined radiation worker and radiological controls technician training programs are in place and are effectively implemented by the licensee. An additional cyclic training program is provided for radiation protection techni-cians and would appear to establish a method for communicating recent procedural modifications to the technicians.

However, lapses in communication of recent procedural changes do occur.

For example, a change in licensee policy regarding dosimeter placement inside anti-contamination clothing when face shields were worn was observed to be neither clearly understood nor uniformly implemented in the field.

• Internal audits by the Radiological Controls Department of the radiation protection program were conducted as required and appeared to be of ade-quate technical depth and scope. Although the overall audit plan in this area is formalized and carried out in accordance with a schedule, no tracking system is in place to ensure all individual program elements within.

this area are periodically reviewed.

Well-defined procedures are established to control radiation protec-tion program activities.

Radiation protection personnel appeared familiar with and conversant on all procedural requirements.

The licensee typically demonstrates a strong commitment to ALARA and planning for the radiological aspects of the March 1986 steam genera-tor outage was initiated in a timely manner. Judicious scheduling of technician training and qualification boards allowed the licensee to effectively staff outage operations without reliance on a large contractor HP technician work force.

The licensee's use of the radiation work permit (RWP) system to control radiological work activities was generally very effective.

Pre-job surveys were always taken and were of appropriate scope for evaluating radiological hazards. No violations of RWP requirements were noted during this assessment. However, there was an instance

-

.

.

i B.

Radiolecical Controls (389 hours0.0045 days <br />0.108 hours <br />6.431878e-4 weeks <br />1.480145e-4 months <br />, 6%)

Analy si s During the interim SALP period, the licensee's performance in this area was Category 1.

Program elements were noted to be sound and thorough. Minor problems were identified in the area of radiological work planning where better planning could have prevented releases of radioactivity and personnel contamination.

Problems of this type continue and are discussed in this section.

The licensee's radiation protection organization contains sufficient technical expertise and an appropriate level of staffing to adequate-ly implement the program.

Thorough and well-defined radiation worker and radiological controls technician training programs are in place and are effectively implemented by the licensee. An additional cyclic training program is provided for radiation protection techni-cians and would appear to establish a method for communicating recent procedural modifications to the technicians.

However, lapses in communication of recent procedural changes do occur.

For example, a change in licensee policy regarding dosimeter placement inside anti-contamination clothing when face shields were worn was. observed to be neither clearly understood nor uniformly implemented in the field.

Audits by QA of the radiation protection program were conducted as required and appeared to be of adequate technical depth and scope.

Although the overall audit plan in this area is formalized and carried out in accordance with a schedule, no tracking system is in place to ensure all individual program elements within this area are periodically reviewed.

Well-defined procedures are established to control radiation protec-tion program activities.

Radiation protection personnel appeared familiar with and conversant on all procedural requirements.

The licensee typically demonstrates a strong commitment to ALARA and planning for the radiological aspects of the March 1986-steam genera-tor outage was initiated in a timely manner. Judicious scheduling of technician training and qualification boards allowed the licensee to effectively staff outage operations without reliance on a large contractor HP technician work force.

The licensee's use of the radiation work permit (RWP) system to control radiological work activities was generally very effective.

Pre-job surveys were always taken and were of appropriate scope for evaluating radiological hazards. No violations of RWP requirements

,

were noted during this assessment.

However, there was an instance (

'

,

.

.

. _.

-.

_

_. -

-

-

.

.

i when middle management became intimately involved in steam' generator ECT work setup and this resu'ted in their' personal contamination.

Poor communication and weak RWP extremity protection requirements were contributing factors to these events.

Housekeeping and radiological posting in the work areas reflects a management commitment to keeping workers well informed as to radio-logical conditions. Survey information is prominently displayed at the HP control point and at the access to cells and cubicles. _The licensee has been responsive in implementing NRC guidance to limit posting to the appropriate area surrounding the radioactive source, rather than simply posting large areas-at the doorways. The licensee has also implemented a system to serialize all posted " hot spots" to allow tracking and re-surveying by the HP staff. However, inatten-tion to detail on the part of personnel was the root cause of a violation which was a failure'to prcperly post a radiation area.

Overall, a programmatic problem does not appear to exist in this area.

The recent steam generator eddy current testing performed during March and April represented the licensee's first post-critical outage work in several years. During this outage, a failure to perform timely-surveys for airborne radioiodine during steam generator operations led to a late identification of reactor building airborne radiciodine.

This resulted in the unplanned uptake of radiciodine by a substantial number of workers.

Communication problems between shifts and staff preoccupation with a concurrent noble gas problem aggravated the delay in the licensee's identification of, and response tc, the radiciodine.

Licensee corrective action, once the situation was identified, was appropriate and mitigated further consequences. _ Additionally, licen-see staff contained suf ficient technical expertise for performing followup whole body counting and dose assessment.

Licensee response towards both NRC and licensee-identified deficien-cies is timely and thorough.

Additi6nally, the radiological controls

-

organization often takes the initiative in identifying engineering or design deficiencies which may adversely affect radiological condi--

tions.

For example, the radiological staff initiated an investiga-tion of sampling and floor drain flow paths in the auxiliary and fuel

,

handling buildings which were contributing to a noble gas airborne problem in those buildings.

One inspection of licensee radioactive waste organization and trans-portation activities was conducted during this assessment period.

Organizational structure and staffing of the Unit I radwaste group appeared adequate to support the group's activities. Generally, training for the radwaste group appeared to be timely and comprehen-sive with one exception.

Specifically, a radwaste supervisor did not

'

k

.

/

n x),,

.

,

.

,

i

'

,

t receive the biennial retraining as required by licensee commitments.

A review of licensee audits of the radioactive waste management area indictedthatappr6ppiqteprogramelementswereaudited.

The licensee has a well-organized and smoothly-functioning effluent monitoring and control program, Licensee documentation of effluent

, releases was found to be thorough and compi,ete.

Effluent monitors were; calibrated at a frequency more conservative than.tF3 technical specification requirement. An LER received during this a.2essment per.iod transmitted notification of the isolation of the condenser offgas radiation monitor during power operation.

This inadvertent

~

isolation was promptly discovered by the licensee and adequate corrective actions have been taken.

• The licensee's organizational structure, with direct reporting to the Vice President, Radiological and Environmental Controls, provides for added measures of independence.

Quality assurance and audit activi-ties were conducted as required and licensee response to identified deficiencies was timely.

In general, procedures were technically adequate.

However, implementation problems did occur. Although certain pre-job planning efforts and job performance could have been enhanced by better communications and less direct middle' management involvement, jobs involving significant radiciogical hazards were conducted in a safe manner and they were oriented toward ALARA'.

y

Conclusion Category 1, Declining Recommendations None

s

'

_,

.

.

.

.

.

.

_..,

. _..

.

.

-

i C.

Maintenance (426 hours0.00493 days <br />0.118 hours <br />7.043651e-4 weeks <br />1.62093e-4 months <br />, 7%)

Analysis The interim SALP rated the licensee's performance as Category 2.

Overall performance of maintenance activities was good and reflected a safety conscious mode of operation.

Problem areas existing during this period were a general overall lack of awareness concerning the fact that the plant was now in an operating mode which requires greater sensitivity to adverse work in safety-related areas.

Engi-neering support / coordination was also a weak area, along with proper job planning, incorporating operations and radiological control input to assist safe accomplishment of maintenance activities.

Many positive elements of the maintenance program noted in the interim SALp continued to be exhibited.

The same level of knowledge, staffing, scheduling, and completion of work items was maintained.

Management concern and participation continued to be evident.

The

corrective maintenance trending report developed every three months was used to identify problem areas on a system and component basis.

Severa.1 problems continued to be exhibited and were specifically identified by the PAT ir.spection.

One problem was adequacy of procedures and practices related to the emergency feedwater system.

The procedure for repacking the EFW pumps was generic and not specif-ic enough to resolve special problems with the particular character-istics of these pumps.

This apparently contributed to a failure of a pump packing gland during post-maintenance testing.

There was a lack of preventive maintenance on check valves for the EFW instrument air system. Another problem dealt with the adjustment of limit switches and torque switches on motor-operatec valves (MOVs). The specific switch settings were not always defined or documented, and changes were not always reviewed for impact on valve operation. An aggressive effort was exerted during the ECT outage for the motor-operated valve testing program and it has resolved a majority of problems with switch settings.

The continuation of the program for all safety-related valves, other than those identified in Bulletin 85-03, is desirable and is planned for future outages. Overall, maintenance procedures are adequate, but these examples point out a continuing need for attention to detail in the procedure review process.

Maintenance conducted during the eddy current outage was an ambitious effort to work on several existing problems, along with the major effort of steam generator tube examination.

Effective control of

+

vendor activities was exhibited during the eddy current activities.

The testing was accomplished with " state of the art" equipment and applicable requirements were followed.

Tne EFW flow nozzle thermal sleeve cracking problem and associated extensive activities that were

,

..

_

_

_

_

_ _. _ _

_

._-

_ _

-

.

__

_

'

,/

.

%

,

,

'

/

[

f t

)

not initially' planned were completed in/a safe manner, although formal

.

evaluation of-the nozzle failure method 6 yet to be resolved.

For

'

j these major evolutions', procedures were properly implemented.

!

.

.

The safety-related systems reviewed by NRC during this assessment i

'

period continued to evidence the effects of good preventive and

.

i

/

corrective maintenance. Of particular interest was the replacement

of the "A" vital battery bank - a modification conducted by the i

maintenancedepartmentinaccordancewiththelicensee'smodification control program.

The procedures used for this. effort reflected current industry standards for station storagenbatteries procurement and installation.

Testing confirmed that the battery replacement was t

accomplished satisfactorily with no major maintgnance problems

,

'

evidenced in the testing and checkout process (see Surveillance section on the adecuacy of periodic testing of battery banks).

'

However, several instances were noted in.which minor plant modifica-tions were conaucted using the maintenanceLmechanism without-proper

,

j review and approval in accordance with the modification control program.

{

In addition to PAT I findings in this area, the most notable incident was the licensee discovery that the high voltage power supp'y, for a

!

channel of nuclear source range instrumentation was not connected to

'

the detector during deboraticn to criticality. This was directly related to a technician switching cable connectors in a containment

,

'

penetration in accordance with an outdated controlled drawing.

The penetration configuration was changed based on previous maintenance work which did not use the established modification control program.

Basec on previous SALP findings, these improper minor modifications

are repetitive.

Enhanced management attention to this area is w stranted.

l Maintenance personnel appear to have'shown increased sensitivity to existing plant conditions when planning and conducting maintenance

,

activities.

No plant trips or major equipment damage have occurred as a direct result of maintenance activities during this assessment t

period. However, certain secondary plant. transients / trips could be related to maintenance practices. A number of instances continued to indicate poor maintenance planning with respect to radiologically controlled system work.

'

,

a Engineering and technical support was evaluated as a problem area in the interim SALP period. The licensee is working on corrective

'

actions, but problems continue to occur.

It was not apparent that a formal evaluation on the EFW nozzle cracking would be conducted.

.

.Also. NRC staff questioning apparently caused organizational review

'

of the leakage associated with Decay Heat System check valves. On the other hand, for significant or visible issues, such as the diesel blower problem and the steam generator tube plugging, effective actions

)

.

were planned and implemented by the licensee.

{

!

t,

,

s

.

_,- -..

,

-

-

.. -

-

2.

-..

.

.-

.

... _

_

_. _.

. _.

_

_ _ _.

_

._

__

__. _ _. -. _

.

..

__

_

_ _

_..

.

a i

l

$

Housekeeping activities continued to be a strong point in maintenance

!

activities.

No problems were identified in routine activities or

!

during the extensive eddy current outage activities. No fire hazards

'

were observed during these intensive work activities.

'

'

Overall, the maintenance program is properly established, imple-

.

mented, and staffed. However, several instances reflect weak implementation despite management involvement.

Personnel attitudes

relevant to respect for plant equipment appear to be improving.

The ability to control extensive maintenance activities in short outage i

situations and react to changing problem areas was evidenced in this t

period. Procedure adequacy and technical support problems continue to be noted.

'

Conclusion

,

Category 2, Consistent

'

Recommendations Licensee:

See text and summary of Section IV.J. Management Assurance of Quality.

'

[

i i

j

,

.

k

.

d

'

,-

.--.--,n.,

n

.

+,.

u,.,,..

.

,

,,-,wg.,.

,

a g,-

.

.

1 D.

Surveillance Testing (339 hours0.00392 days <br />0.0942 hours <br />5.605159e-4 weeks <br />1.289895e-4 months <br />, 5%)

Analysis The interim SALP rated the licensee's performance as Category 1.

This was due to a strong surveillance program with quality assurance (QA) involvement, ample staffing, well-kept records, and proper procedure adnerence. Minor problems that surfaced were few and did not adversely affect plant safety.

The licensee continued to properly implement their surveillance program throughout the assessment period. The computerized scheduling system continues to be used effectively to ensure that surveillance tests are accomplished in a timely manner with minimal effort on plant operations.

Surveillance procedures were followed,

,

l personnel were knowledgeable, and problems were documented.

However,

I a missed surveillance on a fire door in the diesel generator building resulted from a poorly coordinated review / approval of averal sur-veillance procedure revisions.

,

l

!

With respect to proper problem ide'1tification and documentation, poor

uncerstanding by personnel of the proper use of exception and defic-

!

iency (ELD) forms persisted.

The interim SALP identified poor hand-

]

ling of the Power Operated Relief Valve (PORV) E&D's. During this per'od, weekly and monthly surveillance for the new "A" battery bank were incomplete because personnel thought ali fluid leve's had to be at a specific mark (high level indicater) for corrected specific gravity. With the incomplete cata, personnel classified tne problem

'

only as an " exception." This precluded operations department review of the anomaly.

Technical support personnel were slow to respond to correct "the deficiency." Subsequently, tne results of a review by the licensee indicated that level correction was not needed and the battery bank was operable.

However, the problem reiterated another example of weak technical support and the need for plant wide training in the use of the new E&D system.

In general, technically-adequate surveillance procedures were noted during NRC review of the RB spray system, containment local leak rate tests, station batteries tests, and emergency feedwater system tests.

However, certain weaknesses were noted. The PAT I identified that emergency feedwater pump discharge check valves were not being tested for proper seating and ability to prevent back flow because the test lineup isolated the idle pump check valves from pressure when the other pumps were being tested.

During this appraisal period the "A" battery bank was replaced.

Although periodic surveillance testing requires a capacity test in accordance with Technical Specifications, tne licensee did not propose to conduct future periodic duty testing'after conducting one

,

l such test.

-

.-

-

_.-- --

.

.

.

-

-.

. _ _

.

.

-

-

_

.

REVISED

,

19 C Latest industry standards suggest such testing and in light of the apparently early end of life for the previously installed battery bank, such a practice seems appropriate.

The licensee is not specifically required to follow this edition of the standard but this incident reflects either (1) a lack of awareness / understanding of current industry standards or (2) a lack of initiative to adopt industry practices beyond those imposed by NRC. Although'an isolated event, it does adversely reflect on the licensee's commitment to excellence.

Overall, the surveillance program is adequate and is aggressively implemented. Additional training is needed in the proper processing of test problems.

The above-noted procedural weaknesses warrant.

further licensee management attention with respect to overall adequacy of the licensee's review process.

,

Conclusion

"

Category 1, Consistent Recommendation Licensee:

See text and summary of Section IV.J. Management Assurance of Quality.

NRC: Assure that existing periodic surveillance tests are sufficient in the long term to measure battery reliability.

i

.-_

,

.

.

- -

- -

_-

-.

.-

-..

--..

.

. -

-.

_ -

.--..

-.. -.

'

.

.

3 Latest industry standards suggest such testing and in light of the apparently early end of life for the previously installed battery

'

'.

bank, such a practice seems appropriate. The licensee is not specifically required to' follow this edition of the standard but this incident reflects either (1) a lack of awareness / understanding t

of current industry standards or (2) a lack of initiative to adopt industry practices beyond those imposed by NRC. Although an isolated event, it does adversely reflect on the licensee's commitment to excellence.

.

!

Overall, the surveillance program is adecuate and is aggressively

implemented. Additional training is neeaed in the proper processing

.

of test problems. The above-noted procedural weaknesses warrant

'

further licensee management attention with respect to overall i

adequacy of the licensee's review process.

!

}

Conclusion Category 1, Consistent

]

Recommendation I

i Licensee:

See text and summary of Section IV.J Management Assurance of Quality.

,

i

f E

't w

y

,-y,-

,

y m--u y m-i, -

w -

a-

-

- - - - -. - -

r

-

- - - - a

>-,

,m.

~.

--

,

.

REVISED

.

20 C E.

Startup Testing (561 hours0.00649 days <br />0.156 hours <br />9.275794e-4 weeks <br />2.134605e-4 months <br />, 9".)

This area was evaluated in the interim SALP (see attached) and the startup testing program was completed on January 10, 1986.

Conclusion Category 1 Recommendations Licensee - none

.

.

,

.

.

E.

Startup Testing (561' hours, 9'.)

This area was evaluated in the interim SALP (see atta.ched) and the startup testing program was completed on January 10, 1986.

Conclusion Category 1 Recommendations Licensee - none NRC - Assure that existing periodic surveillance tests are sufficient in the long term to measure battery reliability.

l

.

.

-

.

.

.

>

F.

Emercency Precaredness (242 hours0.0028 days <br />0.0672 hours <br />4.001323e-4 weeks <br />9.2081e-5 months <br />, 4*.)

This area was not addressed in the interim SALP.

During the prior assessment period (February 1,1984 - January 31, 1985), no signifi-cant weaknesses were identified and this area was rated Category 1.

During this assessment period, a full scale emergency exercise, which included NRC participation, was held on November 20, 1985.. The licen-see's execution and participation in the exercise demonstrated thorough planning and a strong commitment to emergency preparedness.

Examples i

of thoroughly planned activities observed by NRC team members included timely staff briefings in each emergency response facility, adequate

,

j interface with NRC Incident Response Team members, and demonstration i

by emergency personnel of familiarity with emergency duties and use i

of Emergency Plan Implementing. Procedures (EPIPs). The licensee's I

performance demonstrated that it could implemen.t the emergency pl,an

and EPIPs in a manner that would adequately provide protective measures

for the health and safety of the public.

Minor weaknesses noted included a large number of personnel in the control room, information flow, and development of protective action recommendations.

Positive i

'

corrective action by management from the previous drill was noted

'

where a weakness was identified.

For example, significant items observed in the 1984 exercise did not recur.

Licensee management is taking the initiative in this are1 to further improve their emergency response capabilities.

Radiological control personnel in the control room perform dose assessment and in plant health physics functions.

Inis results in a larger number of people with an attendant increase in background noise level.. Consequently dose assessment information in the E0F is obtained from a communicator and this arrangement is not as effective in supporting the emergency support director in the EOF once it has been activated.

Similarly, in plant health physics functions need to be communicated to the Operational Support Center where workers are dispatched to deal with problems in the plant. Although no specific deficiencies can be directly associated with this arrangement, experience at other sites shows performance can be enhanced with alternative options.

'

The licensee took the initiative by consolidating the three unit emergency plans (TMI-1, TMI-2, and Oyster Creek) -into one corporate.

plan. This consolidation is to help standardize approaches at all three plants. Another noteworthy initiative was the licensee permit -

ting the local area fire fighters to use their " burn building" for training.

This and other licensee support of these local companies-has made a positive contribution to local fire fighter preparedness

to support an emergency at TMI.

I

'

.

_

.

..

_

_

.

.

In summary, the licensee performs well in the emergency prepared-ness area and continues to successfully demonstrate this during crills and annual exercises.

Conclusion Category 1, Consistent Recommendations Licensee:

Assess the effectiveness of dose assessment and in plant healtn pnysics functions in emergencies aealing with longer term scenarios where the EOF and OSC are fully operational.

-

.

.

G.

Security and Safecuards (79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br />, 1%)

Analysis-This area was not assessed separately in the interim SALP. The previous SALP period (February 1,1984 - January 31,1985) rated the licensee performance as Category 1.

No major security program issues were identified.

During this assessment period, one unannounced physical protection inspection was performed by a region-based security inspector.

Routine resident inspections continued tnroughout the assessment period.

Corporate management's interest in the program was exhibited by the continued involvement of the Director of Security in the day-to-day security activities on site. That involvement appears to have further opened communication channels between site and corporate management and has resulted in increased appreciation by corporate management of program needs. Monthly meetings held on site between corporate and site security management continue to enhance the

~

program by cemonstrating strong corporate support for the program and by allo.ing potential problens to be surfaced and resolved before they can have an adverse impact.

Onsite security management is competent and knowledgeable of the requirements and objectives of nuclear plant security.

They are also effective in directing the program.

Staffing of the program is adeauate and management remains attentive to human factors.

This is evidencec by tne continued high morale and professionalism of members of the security force and the stability in the force.

Further, the training and qualification /requalification program continues to be managed by a competent staff whose sole responsibility is training.

Few personnel errors were attributable to the security force during the assessment period. However, security personnel apparently were not aggressive in enforcing badge controls (as discussed later in this section) -- training on program / policy changes needs strengthening.

Training facilities are well maintained and indicative of the imoortance management places on security force training.

The licensee's security audit program, which consists of an annual corporate audit and quarterly audits by site personnel, is well planned and comprehensive. Audit reports are disseminated to appro-priate levels of. management and are generally promptly responded to with effective actions. A recent licensee initiative, involving

- semi-annual self-inspections conducted in conjunction with security personnel from the licensee's Oyster Creek facility to review and compare program implementation, is further evidence of a positive management attitude toward the security.crcgram.

It also provides

- - -

...

.

.

for an exchange of experiences and problem solving between the facilities.

This program appears to be effective in providing yet another perspective concerning program implementation.

While correction of problems identified by NRC staff was generally adequate, some problems were noted during this period.

Safeguards licensing issues, e.g., perimeter intru'sion detection system (PIDS),

remained outstanding for about two years despite on going dialogue with NRC staff. The staff's frestration in resolving these issues resulted in a letter to the licensee in March 1986, identifying those

'

issues which were still outstanding. Management attention is required l

to resolve these long-standing issues.

Further, a security badge

'

control violation resulted because of ineffective licensee corrective action subsequent to an NRC staff concern regarding personnel not effectively controlling their badges and key cards.

Initially,

security implementing procedures were weak in this area. After the procedures were strengthened, personnel failed to properly implement

l these procedures and licensee management was lax in enforcing them.

"

Wnen brought to their attention, licensee management exhibited a lack l

cf uncerstanding cf the issue and refuted the violation by expressing

!

apoarent futility in how to avoid future violations.

Based on.sub-sequent discussions with licensee representatives and on actual cbservations in the plant, it now appears that effective correctiv?

actions have been taken.

In summary, the licensee has a well-established program and, in

_ general, it is properly implemented.

Dasitive measures should be taken to resolve the PIDS deficiencies.

,

Conclusion Category 2, Consistent Recommendations None

,

,

(.

.

.-

.

.

H.

Technical Support (127 hours0.00147 days <br />0.0353 hours <br />2.099868e-4 weeks <br />4.83235e-5 months <br />, 2%

not including PAT inspection)

Analysis The interim SALP did not specifically evaluate this functional area because of the operational / test emphasis for that period.

However, comments were made in each of the functional areas with a conclusion in the overview section.

Technical support was considered adequate but not aggressive.

Specifically, licensee engineering personnel and management demonstrated an apparent lack of inquisitiveness for a complete understanding of technical problems.

In their response to that SALP, licensee management claimed that this was due to the heavy burden on their engineering staff from ouestions by oversight groups, including NRC staff, but they committed to enhance their attention to-this area.

.

For the remainder of the SALP period, some improvements were noted out problems continued to be exhioited in otner areas (see mainte-nance and surveillance sections). However, as found by PAT I, there does appear to be a problem, despite a well-established program, with the thoroughness and completeness of design reviews for engineering plant modifications.

Inis leaos NRC staff to believe that the symptoms manifestad during restart by licensee engireering personnel and management were indicative of a more fundamental problem as addressed later in this section.

The licensee's modification control prcgram is well established.

The Technical Functions procedures are quite oetailed; and they are organized well enough to give personnel a good understanding of what the system is and what their responsibilities are.

This system brought on a marked improvement in the cuality of the licensee's safety evaluations.

The program is in piace to assure that safety grade design criteria are applied to plant modifications.

However, for various reasons, full implementation of the program has not been achieved.

The PAT I identified a number of examples where modifications or temporary modifications were improperly prepared and/or installed.

They included:

lack of 10 CFR 50.59 evaluation for temporary shield-ing installation; lack of thorough and complete review to assure EFW 2-hour backup air supply bottles met single failure criteria;. lack of thorough and complete review to assure cycle 6 remote shutdown panel and safety grade signal conditioning cabinet met electrical isolation criteria; weak documentation of design input and lack'of documenta-tion to support design assumptions and calculations; lack of complete design verification; and, inconsistent and outdated drawings avail-able for design and operational use.

Some of these issues are examples of failure to properly implement tne licensee modification-control program procedures. These findings demonstrated that i

-..

-

.

.

.-

licensee personnel, including first-line supervisors, and the independent technical and safety review process were not sufficiently thorough and comprehensive in performing their activities and lacked the attention to detail in properly following procedures.

The environmental qualification area is another example of poor engineering project implementation.

The PAT-I identified that the licensee did not complete a review, specific for TMI-1, for use of a certain cable type in safety-related applications.

Further, NRC staff questioning identified.another cable type (different vendor)

that was not included in the TMI-1 plant-specific file.

Substantia-I tion of terminal block qualification was weak in that comparative samples were not available for traceability. markings and similarity of kind markings.

The results of a walkdown inspection by the licensee further disclosed that the Reactor Building fan motor power cable qualification could not be substantiated. This resulted in a delay to the startup from the ECT outage because of last minute work to replace the connectors. Once the connectors were replaced, QA identified a need for rework in that splicing material conditions were not within the bounds of the qualified splice.

Errors were made in the establishment of the TMI-I EQ file due, in part, to a lack of a thorough ar.c comprehensive independent review.

The under-lying causes of these problems appear to have been a lack of under-standing of the equipment qualification process and the need for technically conprehensive reviews.

These problems also affect performance in the licensing area in that they lead to errors in information presented to-NRC staff in licensing correspondence.

Exarples include:

non-EQ equipment for emergency feedwater system (EFW); single failut e susceptibility of the EFW instrument air syste ; and lack of electrical isolation between a safety grade signal conditioning cabinets and control room panels.

On the other hand, for startup activities there was good technical support to the site.

Several initiatives were exhibited as noted in the performance of generically applicable special natural circulation testing.

Site staffing from the corporate engineering division has increased and is taking on more responsibility for processing minor modifications.

l

.-

,

_.

.

-

_

..-

.

.

1

During the recent outage werk, licensee management involvement was adequate in maintaining positive control of all work being performed.

This was exhibited in the unplanned outage for main condenser work in February 1986.

Further, to alleviate the administrative burden on the licensed operating crew during the ECT outage, the licensee assigned an offshift qualified senior reactor operator (SRO) to coordinate the work associated with different jobs.

Prior to the outage,~ equipment to support major tasks was prepositioned to aid in the work starting smoothly, Pre-briefing and discussions between major departments were performed to assist in keeping all responsible departments abreast of the work.

However, as the pace of activity increased, such as the transition from operations to outage work, or during plant startup, these communication links between departments weakened.

This contributed to tne RB iodine buildup event and OTSG worker contamination event during initial set up of OTSG ECT condi-tions.

Overall, the licensee adequately controls modification work in the plant. Major startup activities were well supported at the site and corporate level. The modification control program is well defined, but implementation needs improvement.

Corrective actions for these problems have been weak and a significant increase in management attention to this area is warranted.

Conciusion Category 3, Consistent Recommencations Licensee:

In light of recurring problems in the e~nvironmental cualification

(EQ) area,. assess the adequacy of or the need for better accountability

on specific engineering projects, such as EQ.

Conduct a critical evaluation of the design review process with emphasis on the role of peer review adequacy and first.line supervisory oversight.

NRC:

Conduct team inspections of the off-site engineering efforts with particular emphasis on preparations / modifications planned for the forthcoming refueling outage.

T

_ _., _

v

.

-

.-.

..-

_.

.

.

.

I.

Trainine and Qualification Effectiveness Analysis During this assessment period, training and qualification effective-

.

ness has been considered as a separate functional area. However, the various aspects have been considered and discussed,as an integral part of other functional areas and the respective inspection hours have been included in each one.

Consequently, this discussion is a synopsis of the assessments.related to training conducted in other areas.

Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review c' program adequacy. The discussion below addresses three principal areas:

licensed operator training, non-licensed staff training, and status of.INPO training accreditation.

The interim SALP noted licensee performance as a Category I and noted a' strong licensee commitment to licensed operator and certain non-

~

licensed operator training areas that resulted in an: effective train-ing program for startup. These program areas were oriented toward improving on-the-job performance.

In general, personnel were know-ledgeable of plant design features and status and they conducted activities with care during special testing and major evolutions.

There was a problem of workers in various plant areas having the potential to cause a safety-system challenge in that the workers were not sufficiently careful when working around plant equipment.

Inex-perience was noted, especially among non-licensed personnel, but it-was compensated for by enhanced supervisory attention.

During the remainder of the SALP I period, personnel enhanced their experience. level curing continuous power operations and during tran-sition periods at the.beginning and end of outage.

Reportable events attributed to personnel errors remained relatively few; and, for those that did occur, no significant safety concerns were raised.

No additional examples were noted of workers not having respect for i

equipment in safety-related areas which could cause a challenge to a safety system (i.e.,

the " worker in. the spaces" issue). This.indi-i cated that the licensee's corrective actions of personnel counselling (plant wide) were apparently effective in enhancing performance.

There were two plant trips partly related to personnel error, however they were due to the way secondary plant equipment was' operated and unrelated to the " worker in the spaces" issue.

The PAT I inspection confirmed the positive elements of the licensee's training program noted in the interim SALP. The team found a high level of management commitment and involvement in-licensed operator and certain nonlicensed operator training programs i

at TMI-1.

For example,. senior plant management regularly participated in Babcock and Wilcox simulator training in order to monitor and evaluate shift performance in.non-routine evolutions and

-

_

__

,

_ - _ _

.

REVISED o

29 C emergency situations.

Training in this area was given the highest priority by plant and corporate managers and supervisors. Generally, policies and procedures were clearly written, broadly disseminated and well understood by all.

Maintenance training was considered especially strong, well con-ceived, and well implemented. Maintenance personnel typically attended one week of classroom training during each six week rotation cycle.

The training covers industry experience, administrative procedures, and craf t-specific areas.

Some problems with regard to procedure implementation for routine activities continued to persist.

This was originally attributed to individual procedure step inadequacies.

However, the PAT I and other inspection findings identified a number of examples of licensee personnel not properly implementing procedures, most notably in the modification control area, both at the corporate and site levels.

The PAT also found that some design packages cid not meet safety.

grade criteria and that some corporate engineering personnel were not knowledgeable in recoros retrieval system use. The effectiveness of training in this area warrants further review by the licensee.

Fire brigade training meets minimum requirements; but lacks realism.

In contrast to the licensed /nonlicensed training area, licensee management's attitude appears to be more oriented toward minimum regulatory requirements.than toward connitting to excellence. How-ever, licensee initiatives outside of regulatory commitments; e.g.,

burn building training, help to compensate for this shortcoming.

The licensee has received training program accreditation from INPO in the following five areas: control room operators; senior reactor operators; shift technical advisors; auxiliary operators; and radio-logical control technicians.

All five SRO and five R0 candidates for operator licenses passed the NRC license examinations.

No licensed operator training program-matic weaknesses were identified.

Some practical weaknesses were uncovered however, such as, tne candidate familiarity with the use of the plant computers and various data plots.

In summary, the licensed operator training program for startup and subsequent operation was effective and performance oriented.

Experi-ence is being gained with continued full power operations and person-nel errors remain relatively few.

The licensee was responsive to certain training needs; such as, for the " workers in the spaces" issue.

The licensee demonstrates a poor attitude with respect to fire brigade training.

Site and corporate engineering training may need enhancement.

Licensee management should direct its attention to training effectiveness on the procedure adnerence issue.

.

-

-

-

_

._ - - - -

.

.

i emergency situations.

Training in this area was given the highest priority by plant and corporate managers and supervisors. Generally, policies and procedures were clearly written, broadly disseminated

.

and well understood by all.

.

Maintenance training was considered especially strong, well con-ceived, and well implemented. Maintenance personnel typically attended one week of classroom training during each six-week rotation cycle. The training covers industry experience, administrative procedures, and craft-specific areas.

Some problems with regard to procedure implementation for routine activities continued to persist. This was originally attributed to individual procedure step inadequacies.

However, the PAT I and other inspection findings identified a number of examples of licensee personnel not properly implementing procedures, most notably in the modification control area, both at the corporate and site levels.

The PAT also found that some design packages did not meet safety-grade criteria and that some corporate engineering personnel were not knowledgeable in recoros retrieval system use.

The effectiveness of training in tnis area warrants further review by the licensee.

I Fire brigade training meets minimum requirements; but lacks realism

'

due to the large number of brigade members.

In. contrast to the i

licensed /nonlicensed training area, licensee management's attitude appears to be more oriented toward minimum regulatory requirements than toward committing to excellence.

H0 wever, licensee initiatives outsice of regulatory commitments; e.g., ourn building training, help to compensate for this shortcoming.

The licensee nas received training program accreditation from INPO in the following five areas:

control room operators; senior reactor

,

operators; shift technical advisors; auxiliary operators; and radio-

logical control technicians.

All five SRO and five RO candidates for operator licenses passed the NRC license examinations.

No licensed operator training program-matic weaknesses were identified.

Some practical weaknesses were uncovered however, such as, the candidate familiarity with the use of the plant computers and various data plots.

In summary, the licensed operator. training program for startup' and subsequent operation was effective and performance oriented.

Experi-ence is being gained with continued full power operations and person-nel errors remain relatively few. The licensee was responsive to certain training needs; such as, for the " workers in the spaces" issue.

The' licensee demonstrates a poor attitude with respect to fire brigade training.

Site and corporate engineering training may need enhancement.

Licensee management should direct its attention to training effectiveness on the procedure adnerence issue.

y.i

-

r-

- - - -

-

--,TT

-

.

.

.

,

Conclusion Category 1, Consistent Recommendations None

.

,

..

..

.

f

.

i'

J.

Assurance of Quality Management involvement and control in assuring quality is being con-sidered as a separate functional area for_ this assessment period.

However, the various aspects of the programs to assure quality have been considered and discussed as an. integral part of each functional

>

I area and the respective inspection hours are included in each one, j

Consequently, this discussion is a synopsis of the assessments relating to the quality of work conducted in other areas. It should be emphasized that this function area evaluates management assurance of ouality; and, as such, is much broader than merely an assessment of QA/QC department performance.

,

The interim SALP rated licensee performance as a Category 1.

It noted an aggressive management and quality assurance department (QAD) presence and involvement in site activities.

However, manage-ment attention to the QAD effectiveness reviews was questioned in light of.the procedure adequacy and implementation problems that persisted.

The procedure implementation problem appears now to involve more than individual procedure step inacequacies challenging people toward proper implementation.

Considering the interim SALP results, recent inspection findings, and PAT I findings in the modification control

'

area, this problem is symptomatic of an apparent corporate and site level problem in fully adhering to proceoures for routine activities.

It appears that personnel rely on memory er rush to meet schedules to complete action items without referral to tne appropriate licensee procedures.

Indirectly middle management appears to be adversely affecting performance on properly implementing procedures by their aggressive attitude toward schedule acnerence. -In this regard, indications are that management has not followed through to assure that-their procedure adherence goals are being achieved.

Overall general plant operation procedures and safety system opera-tional procedures are adequate. However, many other important to safety procedures have individual step inadecuacies, a persistent

'

problem identified throughout the SALP I period. These instances of

,

procedure inadequacy are too numerous to be considered an isolated problem and they indicate a lack of attention to detail on the part of individual reviewers along with poor supervisory oversight of the procedure review process. Compounding this problem is the lack of diagnosis in the analysis reports on the review process which are

'

submitted to the cognizant vice presidents.

Licensee initiatives are needed to improve required review process.

The quality assurance (QA) department is well staffed and is focused on enhancing operational experience.

The QA program employs many initiatives to uncover problems'in programs or program implementation.

l Other oversight groups employ substantially experienced personnel who

,

'

o

.

,

appear to be effective in their problem identification reviews.

How-ever, for problems not directly af fecting plant operations, licensee management is not effectively using these assets.

For example, pro-cedure adherence and drawing control problems are long-standing issues at TMI.

Licensee corrective actions were ineffective in this area.

Furthermore, QAD apparently has been unable to assure appro-priate corrective action.

In addition to examples noted above, EQ problems and the lack of a component level quality classification list were issues that QAD did not escalate within the licensee organization in a timely and effective matter to assure licensee management took appropriate corrective action before they became issues with NRC staff.

Also in some instances, personnel and management lacked initiative toward effective corrective action without oversight pressure.

Examples include slow action to resolve instrument anomaly problems.

In regard to a violation for failure to establish procedures the licensee-exhibited poor understanding of related management assurance requirements.

In summary, strong quality assurance and oversight review pro-grams employing unique techniques are in place.

Nonetheless, line organizational management needs to more effectively use these assets.

Improved personnel and management attitude toward proper procedure implementation is warranted.

Conclusion Category 2, Consistent Recommendations Licensee:

Establish and enforce a policy that can be understood by mid-level managers and workers to ensure procedural adherence and resolve the

perception that schedules are of a higher priority.

Reassess the process used for assuring individual procedures are technically adequate and complete.

In particular, assess the relative roles of peer review and management oversight in procedure reviews and changes.

Assess the need for better indoctrination and/or training for individuals associated with engineering design work and design change control.

(

.

..

(

K.

Licensing Analysis This area was not addressed in the interim SALP.

In the previous SALP evaluation for this area (February 1,1984, to January 31, 1985), the licensee received a Category 2 rating.

In that SALP report, we noted that management involvement was above average for significant matters which could affect plant restart. But there were other areas where management involvement and control appeared _to be lacking, particularly in areas of less significance to restart.

The licensee has been very aggretsive in meeting with NRR on a monthly casis to discuss all active licersing issues.

Priorities of review are discussed. As expected, the higher priority reviews are proceeding in an efficient manner.

But anctner result of these meetings is that the lower priority reviews 6re proceeding more smoothly than before and are being completed. Another-aspect of these meetings is that future licensee submittals are discussed along with their priority.

There was one notable breakdown in communication.

Specifically, a 10 CFR 50 Appendix H time extension reouest on analyzing reactor vessel surveillance capsules was not suomitted in a timely fashion.

Although the specific issue involved had a low safety significance from a regulatory viewpoint, the request should have been submitted ea rl i e r.

Since this is the only notable exception found to date, tnis incident was not considered to be representative of the licensee's performance.

The licensee's understanding of the technical issues has generally

been good and the proposed resolutions have been generally con-servative and sound. There are occasional differences between the NRC and licensee on how to proceed on a technical issue, but, in general, when these differences occur, the licensee has a reasonable technical basis for their decision.

However, in view of the findings under the Technical Support / Outage Management section of this SALP, questions are raised on the underlying basis of licensee submittals.

Resolving the concerns in the Technical Support section will. resolve

.these questions.

In the last SALP appraisal on licensing activities (prior to restart), the licensee was requested to improve their No Significant Hazards Determination (NSHD) submitted with each technical specifica-tion change request (TSCR).

The licensee has shown considerable improvement in this area. The best examples are contained in TSCR 14S and TSCR 153, involving extensive reviews of steam generator repair criteria.

Even on less extensive TSCRs, the licensee is

,

providing a more meaningful technical analysis for the NSHD.

j i

l l

!

.

.

.

.

i The licensee has an effective system for tracking and responding to NRC requests.

It is evident in the monthly meetings between NRR and the licensee that management attention is focused on meeting sched-ules.

Rescheduling of lower priority work is done in a conscious, controlled manner.

Licensee staff was sufficient to support startup and operation and to adequately support completion of a number of older licensing actions.

Additionally, the licensee has been very responsive to requests for information on a short notice for such items as congressional inquiry and internal NRC surveys of plant status.

In summary, the licensee's performance has improved in the licensing area. Older licensing issues are being resolved and the licensee is trying to minimize the backlog of licensing' actions.

The licensee's significant hazards determination evaluations have improved. ~This

>

functional area will require continuous diligence on-the licensee's part to maintain the observed level of improvement.

Conclusion Category 1, Consistent Recommendations None

?

i l

i

,

_. - -

-.

r

_

_

_

,

w

-,

y

.

.

V.

SUPPORTING DATA AND SUMMARIES A.

Investigations and Allegations Review There are no open investigations for TMI-1. The investigation on the environmental equipment qualification apparent material false state-ment was completed during.this period and it is being reviewed by IE and Region I staff.

Two allegations were received outside the interim SALP period. One dealt with concerns on the design adequacy of certain restart and post-restart modifications.

The allegation was reviewed in NRC Inspection 50-289/86-06 and it was not substantiated. An unresolved item was identified for the licensee to define a thermal transient on nozzles for cold water injections to high temperature systems.

The other allegation dealt with a concern on the potential for rect iti-cality during post-engineered safety feature actuation situations.

This is currently.under review by Region I.

B.

Escalation Enforcement Actions None C.

Management Conferences There were three management conferences during this period.

On December 17, 1985, NRC management (Region I and NRR) met with the licensee at the site to discuss the status of the power escalation program and various related technical problems identified during the startup process. On March 31, 1986, NRC management (Region I and NRR) met with licensee management in the Region I, King or Prussia, Pennsylvania, to discuss the interim SALP issued on March 13, 1986.

On April 18, 1986, NRC management (Region I, IE_and NRR) met with licensee management at the site to discuss technical issues on the licensee's environmental qualification program,-specifically for TMI-1 but also applicable to Oyster Creek.

D.

Licensee Event Reports In reference to Table 5, six Licensee Event Reports (LERs) were due to personnel error, three were due to component failure / malfunction, and one was due to a system design error on the two-hour backup air supply for the EFW system (which has as a root cause, personnel error).

No causal link can be inferred among the ten LERs. Although the population of 10 LERs is small, there was a relatively large number i

of these attributable to personnel error.

'

\\

.

!

,

._.

,

-

.

.

!

E.

Reactor Trips / Forced Outaaes Table 6 represents the unplanned reactor trips and unplanned outages along with root causes. Also, the main turbine was taken off line

"

with the reactor critical at low power during October 13-18, 1985, and April 24-25, 1986, for turbine steam inlet drain line repairs.

The following reactor trips and outages, which occurred during this period, were planned in accordance with the licensee's test program or regulatory requirements.

October 15, 1985, Manual PLANNED trip in accordance with

--

startup test procedures October 21, 1986, Loss of PLANNED trip in accordance with

--

Feedwater power escalation procedures

--

January 2, 1986, Turbine PLANNED trip in accordance with Trip power escalation procedures

--

March 21-April 21, 1986, PLANNED outage in accordance with Outage license conditions issued as a result of steam. generator tube-repair hearing

,

,

\\

..

,..

.

.

T1-1

'

TABLE 1 INSPECTION. REPORT ACTIVITIES TMI-1 NUCLEAR GENERATING STATION REPORT / DATES INSPECTION TYPE HOURS ACTIVITY 85-22 SHIFT 683 Power Operations 9/16/85-10/11/85 RESIDENT / PROJECT Startup Testing.

STARTUP TESTING ENGINEERING SPECIALIST 85-23 EMERGENCY PREPAREDNESS 242 Annual Emergency 11/19/85-11/21/85 SPECIALIST Exercise RESIDENT / PROJECT i

85-24 SHIFT 369 Power Operations 10/11-18/85 RESIDENT / PROJECT Startup Testing STARTUP TEST Licensed Operator

.

RADIATION SPECIALIST Training

Radiological Effluent Control 85-25 SHIFT 352 Plant Operations 10/18-25/85 RESIDENT / PROJECT Startup Testing STARTUP TEST 85-26

.

SHIFT 501 Plant Operations 10/25-11/12/85 RESIDENT / PROJECT Startup Testing RADIATION SPECIALIST Radiological Effluent Control 85-27 SHIFT 603 Plant Operations 11/12-27/85 RESIDENT / PROJECT Startup Testing STARTUP TESTING Radwaste Manage-ment'

85-28 SHIFT

.

540 Plant Operations 11/27-12/13/85 RESIDENT / PROJECT Startup Testing STARTUP TEST Radiological RADIATION SPECIALIST Effluent Control 85-30

.

SHIFT 888 Plant Operations 12/13/85-1/10/86 RESIDENT / PROJECT Startup. Testing STARTUP TEST Radiation Protec-RADIATION SPECIALIST tion

.

ENGINEERING SPECIALIST

>

..

.__

.

.

-

,.

-.

.

_..

_

-

_

-..

.

-

. _..

.-.

.

.

i T1-2 TABLE 1 (Continued)

>

86-01 SHIFT 388 Plant Operations

1/10/86-2/7/86 RESIDENT / PROJECT Shutdown /Startup f

RADIATION SPECIALIST Activities

SECURITY SPECIALIST Radiological

'

FIRE PROTECTION SPECIALIST Effluent Control Security Program Fire Protection 86-02 RESIDENT / PROJECT 273 Plant Operations

'2/7/86-3/7/86 RADIATION SPECIALIST New Fuel Receipt Radiation Protec-tion

!

86-03 SAFETY SYSTEM 770

.EFW Operational

3/3/36-3/27/86 FUNCTIONAL INSPECTION Readiness and BY THE PERFORMANCE Functional APPRAISAL TEAM (PAT)

Assessment

'

86-04 SAFETY SPECIALIST

Performance of 4/23/86 GPU Employee

!

86-05 RE3IDENT 440 Plant Operations

!

3/7/86-4/11/86 FIRE PROTECTION Fire Protection

!

SPECIALIST

RADIATION SPECIALIST Radiation Protec-ENGINEERING SPECIALIST tion

,

,

86-06 RESIDENT / PROJECT 374 Plant Operations 4/11/86-5/16/86 RADIATION SPECIALIST and Startup

-

ENGINEERING SPECIALIST Transportation i

86-07 OPERATOR LICENSING Operator-Licensing

EXAMINER Examinations

.

• Not Tabulated

i

,\\

l t

- _.,

.,

,.. _. _ _ _ -

_

_

.

. _,

,

, _,

. _..

_

_

_

.-

.

'

,

L

.

.

s

'

.

i

'

T2-1 TABLE 2 INSPECT 10N' HOURS _ SUMMARY (9/16/85 - 4/30/86)'+

TMI-1 NUCLEAR GENERATOR STATION

,.,

INTERIM TOTAL

% OF TIME SALP HOURS TOTAL HOURS

• Plant Operations 974 3528-

(shift inspection hours)

(1617)

~

Radiological Controls 244 389

• Maintenance

-

288

'426

_

.;

• Surveillance Testing 252 339

i Startup Testing

561 561

!

Emergency Preparedness

'

NA 242

Security and Safeguards NA

.

1

• Technical Support NA 127

• Training and Qualification (included'in above)

Effectiveness-t

%

.

• Assurance of Quality (included in above)

,

Licensing NA'

NA NA

• PAT Hours NA 770

.12 Total 3936 6461 NA - Not Appl 1

• PAT - Performacable -

nce Appraisal Team hobrs'are included in the total but have not been broken down into individual functional areas.

+ Includes IR 86-06 Inspection'to 5/16/86

'

-

,,

--

I (

\\

,

- -. -,

,-

-

c

-

-

n

-,

. - -

-.

.. -...

.

-.

.

..

. -. _

.

.

- -.

. -.

_.

'

.

l

,

l T3-1 i

i.

TABLE 3 ENFORCEMENT SUMMARY (9/16/85 - 4/30/86)

TMI-1 NUCLEAR GENERATING STATION I

!

I A.

Number and Severity Level of Violations

!

~

i Severity Level I

-

Severity Level II

-

. Severity Level III

-

Severity Level IV

Severity Level V

,

i

{

Total

B '.

Deviation:

1 in Radiological Control (Transportation) Area C.

Violations vs. Functional Area t

Functional Area

,_ Severity Levels ___

I

111 IV V

Total

!

I

Plant Operations

5 i

Radiological Controls

2

!

Maintenance

1 2-l Surveillance Testing

1

,

Startup Testing

' Emergency Preparedness J.

Security and Safeguards

1 j

Technical Support Training and Qualification

Effectiveness Assurance of Quality

i Totals

1

,

't

)

!

1

-

i

--~...-.a

--.

.-

.,,.--.

-.

. _. -..,, -

,

,

_

.

.

-

.

.

.c

._~

,

2 (

\\

.

i s

,

Ti-1

.

TABLE 4

,

ENFORCEMENT DATA

,

TMI-I NUCLEAR GENERATING STATION Inspection Inspection Severity Functional Report No.

Date Level Area Violation

.: L p

A.

Violations

"

85-22 9/16-10/11/85 IV Maintenance Failure to

properly control scaffolding in

,

safety-related

-

-

areas E5-25 10/15-25/65 V

Maintenance Failure to properly control drawings inside

,

control room'elec-trical cabinets

85-27 11/12-27/85 IV Plant Failure to Operations establish or i-properly change

procedures for safety-related activities 85-27 11/12-27/85 IV Plant Failure to Operat'ons completely review

.

for adequacy pro-cedures for inde-pendent verifica-i tion of safety-related

,

activities 85-27 11/12-27/85 IV Plant Failure to a

Operations properly implement technical specifi-i cations and relat-ed administrative control for inde-

pendent on-site

safety review group (IOSRG)

activities

,

!

I

-

,

.

.

-.

__

_

_

.__

_. _ _ _ _ _ _ _ - _ _ _ _ _

.

.

T4-2 TABLE 4 (Continued)

Inspection Inspection Severity Functional Report No.

Date Level Area Violation 85-27 11/12-27/85 IV Security Failure to properly implement security personnel badge identifica-tion control measures 85-30 12/13/85 IV Surveillance Failure to properly inspect a fire door on the specified frequency i

86-01 1/10/85-2/7/86 IV Plant Failure of fire Operations brigade members to respond to a drill wearing respira-tory protection apparatus 86-05 3/7/86-4/11/86 IV Radiological Failure to perform Controls timely evaluation of airborne radio-iodine in the reactor building 86-05 3/7/86-4/11/86 IV Radiological Failure to con-Controls spicuously post-radiation caution

signs at a radia-

' tion area acces-sible to personnel

,

86-06 4/11/86-5/16/86 IV Plant Failure to imple-Operations ment,.in part,

,

important to safety procedures during startup

,

t

_ _.

.. -.

-

. _ _

_

__

-_

_

_

.

.

i

!

i l

T4-3 TABLE 4 (Continued)

Inspection Inspection Severity Functional Report No.

Date Level Area Violation B.

Deviation 86-06 4/11/86-5/16/86 NA Radiological Failure to meet a commitment to re-train a radwaste supervisor bienni-ally C.

Other Violations By letter dated January 25, 1986, the NRC staff issued a Notice of Violation as a result of NRC investigations into management issues related

to TMI-1 restart.

Specifically, the violation dealt with only the TMI-1 reactor coolan-t system (RCS) leak rate for which the licensee nad taken sufficient corrective and preventive action (see below).

No response was required for the Notice of Violation. Other violations may be issued when.

<

the staff completes its review of those investigations an'd management issues.

'

The below-listed violations do not relate to licensee performance during the SALP I period, since they involve plant ' activities between April 1978

,

,

'

and September 1979.

--

Failure to adequately :ontrol the RCS leakrate by having a deficient surveillance procedure and by not properly implementing that procedure.

--

Failure to maintain records of the RCS leakrate for invalid tests.

Failure to properly identify and correct malfunctions and

--

deficiencies in a makeup tank equipment configuration.

These violations relate to the Plant Operation and/or_ Surveillance area.

Collectively, they were classified as a Severity Level III Violation.

_..

. _ _

_

_

___

_

. _ _

__

-

.__. _.----__

e

<

-

.

'

,

T5-1 TABLE 5 LER SYNOPSIS - 9/16/86 - 4/30/86 THREE MILE ISLAND - UNIT 1 i

LER Number Summary Description

,

j 85-02 Manual reactor trip due to response to a fire in the rod -

control system.

Root cause:

Equipment / component mal-i function i

85-03 Reactor trip due to a malfunction of a main generator relay that caused a main turbine rejection which caused a RCS tran-i

{

sient.

Root cause:

Equipment / component malfunction 85-04 Inoperable fire barrier to'a make-up pump cubicle without a i

fire watch during modification work.

Root cause: Personnel l

error 86-01 Inoperable pressurizer spray line snubber was found while plant

was in hot standby condition.

The snubber was found unpinned at one end.

Root cause:

Personnel error 86-02 Reactor trip following a main turbine trip due to high moisture separator level. A faulty valve controller in.the heater

'

drains flow path caused the high separator level.

Root cause:

Equipment / component malfunction 86-03 Incorrect position of a jumper internal to an undervoltage relay associated with the. shunt trip feature for a control rod drive trip breaker rendering one-of-four RPS channels out of service.

Root cause:

Personnel error 86-04 Isolation of condenser offgas radiation monitor RM-A-5L in violation of technical specification.

Improper valve alignment caused the isolation.

Root cause:

Personnel error 86-05 Fire door C310 was found inoperable due to excess door-to-floor-clearance and a continuous fire watch was not' posted within an i

hour of occurrence as required by technical specification.

Root cause:

Personnel error 86-06 Reactor trip following a main turbine trip due to a low.

pressure spike in the turbine lube oil system caused by valving in a standby lube oil cooler that was not fully pressurized.

Root cause:

Personnel error and pro'cedure inadequacy

.

'

.

r

-

.r

-

-

.,.,. _,

,-

.,

.-.

,.

_

e

-~

,

.

T5-2 86-07 The Performance Appraisal Team (PAT) found that the installed two-hour backup air supply does not meet single failure crite-ria.

The original system design verification did not identify this discrepancy in the final design.

Root cause:

Engineering design

• /V

-..

.-__

..._.- - ----

-

.

.

.

,

l

i T6-1 TABLE 6

,

UNPLANNED REACTOR TRIPS AND SHUTDOWNS (9/16/86 - 4/30/86)

DATE DESCRIPTION CAUSE Unplanned Reactor Trip Sianals/ Power Level

<

' December 1, 1985, The high RCS pressure resulted Load dispatcher High RCS Pressure / due to a load rejection with allowed grid voltage to from 75% power the_ tripping of the main drift up coupled with a generator breaker due to an relay setpoint drift

.

overexcitation protective relay malfunction coupled with relay setpoint drift during a regional

,

grid voltage transient January 4, 1986, The turbine trip resulted from Equipment malfunction

.

i Turbine Trip /

an abnormal high level in one in the secondary

from 22% power of six moisture separators due plant - level controller to a level controller malfunction in the'feedwater heater drain collection tank March 15, 1986 The turbine trip resulted Personnel error coupled Turbine Trip /

from an abnormal low turbine with weak operating from 100% power lube oil pressure caused by procedure

,

valving in a standby lube oil cooler that was not fully

pressurized April 21, 1986 The reactor tripped after all Equipment malfunction-Failure of "D" four reactor coolant pumps in the electrical (vital) bus tripped following loss of one supply system coupled supply breaker /

(of two) 4160 volt vital buses with weak operating reactor sub-and all three 4160 volt non-procedur e s critical vital buses

.

- - -

,_

y w

- - -

r

,

re

-

, - -

-

c

-

rv,

_ _

_._

-

__

_

_

_

_

.

.

.

i'

T6-2 TABLE 6 (Continued)

,

Date Description Root Cause April 23, 1986 High RCS pressure resulted Feedwater transient due High RCS Pressure / from a main feedwater (FW)

to operations personnel from 9% power transient in which the error turbine-driven FW pump decreased speed during the transfer of steam supply from the auxiliary system to the main steam system Unplanned Shutdowns / Duration

,

January 27, 1986 Due to a 20 MW reduction 1.n Secondary plant fabri-Steam Line electrical output first-cation defect which Bellows Leak /

observed on January 17, the occurred during initial

One week licensee shut down and in-construction welding

'

spected the main condenser

,

for extraction steam expansion bellows leakage

-

.

it

!

i

!

l

!

I i

!'

.

.

-.

. - _ - -,. _ _.

....

.. -

_

,

,

_..,. - -. _. ___ -

-

,

.

T7-1 TABLE 7 LICENSING ACTIONS ACTIONS NUMBERS NRR/ Licensee Meetings

NRR Site Visits

Commission Briefings - One by the

Licensee Schedule Extensions Granted -

Appendix J (LLRT)

Appendix H (Surveillance Capsule)

Reliefs Granted

Exemptions Granted Appendix J (LLRT)

Appendix H (Surveillance Capsule)

Licensee Amendments Issues

Emergency Technical Specificatic.'

-

Changes Issues Orders Issued None

Q REVISED

.

l T8-1

,

TABLE 8 RADIOLOGICAL EFFLUENT RELEASES Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee

'

Reported)

% of Technical Specifications Component Release Activity Quarterly

~

Date Involved Point Released (Ci)

_ Limit, Gamma _

10/21/85 Reactor Trip Main Steam 1.07 E-6 3.8 E-8 at 40%

Relief Valves

!

(MSRV)

10/28/85 Makeup Pump Station Vent 0.7 0.0015 (SV)

i 11/2/85 Reactor SV 1.05 1.09 E-3 Coolant Evaporator 11/19-Main Steam MSRV 1.6 E-7 3.48 E-9 20/85 Valve Testing

-

12/1/85 Reactor Trip MSRV 7.32 E-6 1.5 E-7 a t 75?.

12/17/85 Waste Gas SV 1.4 0.001 Compressor I

12/30/85 Makeup Pump SV 46.3 0.07 l

1/2/86 Reactor Trip MSRV 1.22 E-5 2.3 E-7

!

at 88%

.

1/4/86 Reactor Trip MSRV 2.14 E-5 3.06 E-7 at 22%

1/9/86 RCLD Gas SV 1.6E-1 8.34 E-5 Sample 1/9/86 Flush of SV 2.76 2.22 E-3

,

MU-V-129A f

f

$

-

,

.

..

.

--.

.

.

.

.,..

. - -

-..-

_... _

_

.

_

_ _ _. _

.,

.

a

.

.

t T8-1

.

TABLE 8 RADIOLOGICAL EFFLUENT RELEASES

,

i

!

Non-Routine Events Resultino in Off-Site Releases of Noble Gases (Licensee i

Reported)

% of Technical

.

Specifications Component Release Activity Quarterly-

!

_

Date Involved-point Released (C1).

_ Limit, Gamma _

10/21/85 Reactor Trip Main Steam 1.07 E-6 3.8 E-8 at 40%

Relief Valves (MSRV)

10/28/85 Makeup Pump Station Vent 0.7 0.0015 (SV)

11/2/85 Reactor SV

'I.05 0.025

'

Coolant

~

Evaporator

11/19-Main Steam MSRV 1.6 E-7 3.48 E-9

20/85 Valve Testing

!

12/1/85 Reactor Trip MSRV 7.32 E-6 1.5 E-7 l

at 75%

12/17/85 Waste Gas SV 1.4 0.001 Compressor 12/30/85 Makeup Pump SV 46.3 0.07

-

1/2/86 Reactor Trip MSRV 1.22 E-5 2.3 E-7 at 88%

1/4/86 Reactor Trip MSRV 2.14 E-5 3.06 E-7

,

at 22%

j 1/9/86 RCLD Gas SV 1.6E-1 8.34 E-5 Sample

1/9/86 Flush of SV 2.76 2.22 E-3 MJ-V-129A

,

!

!

!

l'

!

-

_

_

. -. - -

.

. -. _,. _..

_..

_, _

....

,.,

.

-

_. _.... _

. -.

.

._

o REVISED

,

i

TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES 1/28/86 DH-V-578 SV 3.96 2.0 E-3 Spill 2/13/86 AHC-14C SV 6.5 E-1 3.3 E-4 Fan ~ Shutdown 2/13/86 Drain Trap SV 1.5 1.16 E-3

,

Chem Lab Sample Sink

~

2/24/86 CA-V-2 SV 11.6 6.44 E-3 Leakage

!

2/24/86 CA-V-2 SV 2.79 1.91 E-3 Repair l

3/4/86 Waste Gas SV 1.47-7.7 E-4 Comoressor

l 3/15/86 Reactor Trip MSRV 3.7 E-5 7.86 E-7 j

from 100%

i

~

3/22/86 CA-V-5 SV 14.8 8.54 E-3 Relief Lift

,

Total Operating Gaseous Releases - Predominately Noble Gas

,

j Non Routine Batch

% of Tech. Spec.

Continuous (from above (Waste Gas Qtrly. Limit,

.

(RM-A-5/8)

Table)

Tanks)

Gamma October 3.66 E-2 27.8 1.18 E-1

.0642

~

November 14.1 1.05 4.63

.0216 December 20.1 49.6 5.05

.0966

..

i January 68.0 6.87 184 0.1634

February 174.0 16.6 426'

O.28 March 128.0 16.3 686 0.528

j'

-

_

_

.

.

_.

..

__

___.._ _,

-

.

.

.

- -

_

.

a

.

.

..

--

.

-

.-...-.

..

-4 L

o i

TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES 1/28/86 DH-V-57B SV 3.96 2.0 E-3 Spill

'

2/13/86 AHC-14C SV 6.5 E-1-3.3 E-4

,

Fan Shutdown

>

2/13/86 Drain Trap SV 1.5 1.16 E-9 Chem Lab Sample Sink

,

2/24/86 CA-V-2 SV 11.6 6.44 E-9 Leakage

'

2/24/86 CA-V-2 SV.

2.79 1.91 E-3 Repair

!

3/4/86 Waste Gas SV 1.47 7.7 E-4 l

Comoressor 3/15/86 Reactor Trip MSRV 3.7 E-5-7.86 E-7 from 100%

3/22/86 CA-V-5 SV 14.8 8.54 E-3 Relief Lift Normal (Routine / Continuous) Operatino Releases - Predominantly Noble Gas 1l

% of Technical Specification

Activity Released (Ci)

Quarterly Limit, Gamma

'

October 0.15 1.32 E-3 November 18.8 2.0 E-2

$

December 5.29 7.6 E-3

'

January 262 2.78 E-1

.

February 1150 1.23 E-0

'

March 830 8.8 E-1

i

2 I

'I

,,

,

.

..m

.- -.,...

_

. _ - _ _.,

...-.-.--,..._.,-_...r._,

~ _. _.,,,

_ _

m

-..,., _.... -

-7,7

a

.

T8-3 TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES Normal (Routine) Operating Releases - Liquid - Predominantly Tritium Activity Date Released (Ci)

October 1.0 November 1.19 December 5.99 January 24.1 February 26.3 Mr.rch 17.6

,

I i

_