IR 05000289/1989099
| ML20058M388 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 08/03/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058M382 | List: |
| References | |
| 50-289-89-99, NUDOCS 9008100096 | |
| Download: ML20058M388 (26) | |
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~ ASSESSMENT PERIODi(JanuaryJ16J1989 t May 15,!1990:
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TABLE'0F-SUMMARY OF RESULTS A.
Overview The licensee's overall performance during this SALP, period was outstanding.
Only-one reactor trip occurred at power and the licensee established;new
.
records'for continuous operation at power and capacity factor for the 1989
' calendar year, This was due to an absence of major equipment problems,
-
and an. operating staff that responded to plant transient precursors quick-
'['
ly~enough-to prevent adverse consequences.
Integrated control system
. upgrades;also enhanced the. ability of operators to respond to plant.tran-
,
'
sients.
Improvement was noted in the conduct of maintenance planning and i
performance activities. -The operations' staff 4was expanded to provide more
"
than? adequate staffing and additional personnel to enhance outage control
'
. ac tivi ties'.
The plant operations department continued to exhibit a professional, safe approach to operating the plant at. power and during a refueling outage.
- 0perators performed well on the licensed operator req'ualification exam.
Management resolution of significant issues was' accomplished.in a timely
,
. '+
manner.
The plant material organization, now fully staffed, also performed well.
Significant. improvements were made in planning, scheduling and control-
'
'
ling maintenance activities.
The plant material assessment group con-tributed several new initiatives to the preventive maintenance effort.
- cl The radiological controls, emergency preparedness and security organiza-
'
tions continued to perform at previous superior levels with well staffed, effective programs.
Licensee performance in the engineering and technical support area was improved.
Initiatives from the B&W Safety Performance Improvement Program were virtually all implemented or evaluations completed, to resolve this several year effort.
Engineering support for the most recent outage was well' coordinated and effective.
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In summary, the 1icensee con'tinues to have policies.and procedures in place to effectively and safely operate and maintain' the plant. Good
.j management. involvement was evident in:all phases of plant-operation.
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Initiatives have-been taken to improve plant procedures and accomplish
-modifications!to enhance plant safety.
!
. B '.
Facility; Performance Analysis Summary
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'-
- Rating
- Rating.
'Last This
Functional-Areas Period Period Trend i
Plant Operations 1-
-
Radiological: Controls
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I
!
Maintenance / Surveillance
1
-
Emergency. Preparedness
1
.
]
-
Security
1
-
Engineering / Technical
1
-
-
Support
.
' Safety Assessment /'
1
-
Quality Verification-
- From Novemtier 1,.1987.to January 15, 1989
- * From ~ Jan ua ry 16, 1989 to~May 15, 1990 h
..
III. PERFORMANCE ~ ANALYSIS-A.
-Plant-Operations (1993 hours0.0231 days <br />0.554 hours <br />0.0033 weeks <br />7.583365e-4 months <br />, 54%)-
g l1.
Analysis The previous SALP rating in this area was Category 1.
Significant strengths identified in this functional : area included experienced.
-highly professional operators; a strong,' effective operator training program; and a strong corporate and site management leadership.
During this SALP period, the licensec has continued to operate the plant in a safe manner and' has achieved an excellent operating record..The number of control room operators exceeded technical specification plant staffing requirements. No plant trips during power operation occurred due to operator error. Operator vigilance during.steaoy-state operations and in response to plant transients was excellent. Operating crews consistently demonstrated a detailed knowledge of plant design, procedural requirements, and system
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modifications associated with equipment operation. During power operations,:a professional decorum was maintained in the control' room and distractions-to the' operators were kept to a minimum.
Shift supervisorsJeffectively managed' plant activities and provided de-
' tailed briefings' to relief crews.
The licensee frequently uses a dedicated crew =of operators under the supervision of a senior reactor operator'(SRO)~ to perform complex surveillance _ testing wnen at power'-
.
The use of,a= knowledgeable team to perform complicated surveillances
. I was particularl.y-. effective in reducing the burden'on'the normal shift.
'
- Two unplanned reactor. trips occurred during the assessment period.
'
'One reactor trip at full power occurred, when a component failed in'
the main turbine' generator's electrohydrauiic control system. After
,
the 8R refueling outage, a licensed cperator caused a'second reactor.
I tri'p during zero power physics testing. With the trip point reduced j
to 0.50 power during startup, the' reactor operator mo'ved control rods
without closely monitoring power.
The ensuing power increase caused
.
the scram. These events were of-minor safety significance and did nott
]
indicate.any adverse performance trend.
i Site senior management's-involvement in plant operatio_ns was readily
>
evident. _Such involvement was apparent by the routine presence of
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1 senior managers in the plant at daily planning meetings. Management
{
encouraged workers.. at all levels, to identify equipmeat.or procedur-
'
Lal problems.or. potential problems that could affect plant safety.
l Performance stand.rds were effectively set for'all staff.
Procedures-
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required management 'to review logs and notifications.
Management backshift-tours and incident response were also.fermalized.
Opera-tions Management' urged establishment of a task force to evaluate plant upsets caused _by aging components in;the integrated control system (ICS);
Several hardware improvementsthave-been made to the.
o systemtas a result' of this task force.
In the long term, TMI will be the pilot plant for the installation of an advanced control system.
Management's. resolution of the few' operational problems has been y
almost always conservative and timely.
,
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- Licensee management incorporated lessons learned from past outages to improve coordir,ation activities for the 8R refueling outage.
Included
,
in these initiatives were detailed integrated work schedules using a
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-computerized work control system; tracking plant equipment configura--
j tions that affect operations by plant conditions; adding shift outage
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advisor positions and instituting a Shift Supervisor's Coordination s
Action List.
These changes were ef fective' in completing outage
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related activities safely and minimizing communication problems between t e various working groups.
This corrected a problem found during the last assessment period, f
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-sistently alignedLin accordance with operational procedures-The
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1The-licensee improved' procedure, adherence..SafetyLsystems were con-
.
licensee acknowledged a programmatic deficiency in assuring compli-ar.ce with administrative procedures during~the last SALP meeting.-
- Based on an? internal task force ~ recommendation,.the licensee made
'
broad changes:to improve ~ administrative procedure compliance.
These l
,
changes included 1 removing redundant. administrative requirements, en*
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hancing the biennial procedure review process, improving training,.
L and assuring that pre-job briefings occur.
The' licensed operator training and qualification-process was accept-able ;s demonstrated by initial examination results of twelve reactor
~
operator applicants.
Three f ailed the written' exam and two failed the operating' exam.
The failures revealed-no programmatic weaknesses
,lwith the licensed-operato, training program.
Nineteen of. twenty
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operatorsLwho'took the NRC administered requalification exam passed.
The operations' staff had an excel'ent understanding of both the B&W 0wner!s Group recommendations for preparing the Emergency Operating.
.
' Procedures (EOP) and incorporating the TMI-l plant specific excep--
~tions into the4E0Ps.
The operators-demonstrated that they can suc-
ces'sfully implement the E0Ps-t
.
Overall, a dis:1plined, well trained staff operated the unit with 'few J
transients throughout the period. Management.took action'to-correct those problems identified-during the previous SALP. A timely approach to resolving 11. sues was' evident. -Results of licensed operator exams were adequate.
2.-
' Conclusien
' Category - 1.
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'3.
Board Recommendation-Licensee:
None j
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NRC: None s
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B.
Radiological Controls (211' hours,6%)
1...
Analysis
,
q The previous SALP report rated Radiological Controls as Category 1.
.,
Strengths included' management involvement in daily activities, good'
j quality assurance. audits, highly qualified staff, a well managed
'
support program, good access control,tand an effective as low as
!
' reasonably achievable (ALARA) program. Minor weaknesses included
. slowness in updating surveys in some areas of the plant and some
.
lapses-in proper outage planning, specifically in connection with i
scaffold erection.
'
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Radiological Controls
.The' strengths observed during the previous SALP period continued to-
_i be strengths _during the current SALP period.
In addition, the weak-
,
nesses'.previously noted have been corrected.
Management involvement'
and commitment to proper radiological controls practices-and ALARA continue as program, strengths.
There have also been efforts to in--
crease awareness of radiological controls in all site staf f. 'Toward -
this end,.the use of auxiliary operators and chemistry technicians to assist the health physics staff at the access control points-and the counting room during outages, was instituted during this period.
In
,
adottion to fully using the available staf f, non-health physics per-
-sonnel were acquainted with the details of daily health physics activi-ties to develop an. appreciation of the effort needed to implement-
~
proper. radiological cont'rols.
LManagement'has demonstrated'a willingness to go beyond the minimum
,
program requirements to ensure high quality performance. 'Although
the internal assessment program requires a four year assessment cycle to audit all-aspects of the program, the cycle.was completed in two years. ALARA reviews.were being performed for jobs with ' estimates i
above 1 man-rem instead of 5. man-rem.
Attention to detail was' lacking'in some observed situations.
For
,
example, improper placement of dosimetry was observed once, and some D
inconsistent postings marking a.high radiation area were also ob-served.
The radiological implications of these specific instances were minor and were not indicative of overall program quality. 'The radiological controls staff has also continued to identify problems and to develop solutions. The worker's proficiency in donning and removing protective clothing was improved by the use of a continuous video display placed at the dressout area to show the workers the l
proper. techniques.
Two-way radi_os were also ef fectively used during the last outage by health physics supervisors and by technicians covering important jobs.
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-A11fimportant' positions'in the radiological controls organization on yy
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site were fully-scaffed during this assessment period. The. staff was
' highly qualified.
To maintain a well. qualified staff, criteria were 1 4
develo' ped.that specify the type and amount of expericnce acceptable
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'for hiring a senior health physics technician. The training program
'
continues,to be effective as shown by the_high quality performance at.
all levels of_ the radiation. protection organization, the smallL number -
W of? violations and issues identified by the NRC and the lack of signi-ficant operational events.
Perform ~ance in maintaining. exposure ALARA continues as a program
'
,y strength. The weakness noted during the last.SALP period with scaf-
' *'
fold _ing has been corrected, and additional--efforts to reduce dose -
n thave been made.
For example, laser video disc displays are being
- used: effectively during pre-job briefings to show workers job loca-
'tions and' access routes.
Industry experience _was used to plan high
.
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t eexposure jobs. The ongoing cobalt reduction program helped minimize
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plant radioactivity in 'the primary sy. ems at a minimum level.
Goals -
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' set <during this assessment period have been realistic' butzchalleng-i J
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ing, and. the cumulative exposure for the 1989 non-outage ' year was
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significantly below the goal.
Cumulative ~ worker exposure for the
'
station also-continues.to be relatively low by current industry per-
,
Lformance.
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-Radwaste, Transportation, Effluents and Radiological Environmental
[
a Monitoring N'
9, Y During the previous assessment period, excellence in the effluents
'
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L controls: program and in the training of radwaste personnel was noted.
'@_
During the current assessment period, inspections of the 'ticensee's
{f;.
-Radwaste, Transportation, Effluents and_ Radiological Environmental Monitoring Programs-(REMP) were conducted.
'
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..The licensee's Quality Assurance / Quality Control (QA/QC)-programs y
,
T'n remain strong with the' scope and technical depth of audits within the
'
g" -E radwaste, ef fluents and REMP being excellent. The QC program for the
'h meteorological tower and Environmental Radiation Laboratory (ERL)-
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instrumentation continues to be strong as indicated by the high avail-
,
,
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ability of these-systems and the high' quality results produced, j
The licensee continues to aggressively attempt to resolve technical-
,
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issues,-as shown by its preparation for the startup of.the evaporator
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system to be used to process Unit 2 Accident Generated Water. The y
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licensee has conducted extensive testing for tritium in' environmental ph g media, and has proposed to increase the sampling frequencies when the 6$
evaporator comes on line.
In addition, the licensee undertook an G
extensive evaluation of its condenser offgas iodine sampling in re-fy sponse to an NRC inspection which had been conducted at the end of a
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the previous assessment period.
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ni The licensee continues to have few operational events in the radwaste a
. processing and transportation area.
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Staffing leve W and training of personnel, especially in the radwaste
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r area', continue no be a-licensee strength. Appropriate expertise was available:within the radwaste, effluents and REMP staff, The train-
.
,
ing program.for radwaste and transportation personnel continues to
[
make a positive contribution to this program area, as shown by the-r lack of significant operational events.
In summary,: the radiological controls program, including:radwaste,
'
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transportation, and REMP, remains strong and effective in'all areas.
- assessed.< Strengths noted during the previous assessment period con-
,
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._tinue to-be strengths, Land the weaknesses previously noted.were cor-
- i'
Erected.
Weaknesses observed during this period:were minor and did
not detract from the overall high quality of the program, i
2.
Conclusion Jf a
Category - 1.
13.
Boa'rd Recomniendation Licensee:
None
,
- NRC ': None
'
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C.
Maintenance / Surveillance '(756 hours0.00875 days <br />0.21 hours <br />0.00125 weeks <br />2.87658e-4 months <br />, 21%)
l '.
JAnalysis
!
During;the:last SALP period, no-major programmatic problems were
!
noted.
The ef fectiveness of the newly restructured maintenance or-
ganization. remained to be realized.
Some weaknesses were noted in
specific job-pianning,-failure to follow administrative controls,
,
' increased personnel errors, and deficiencies in chemistry laboratory
"
operations. A Category 2-rating wasLassigned to.the-maintenance /
surveillance combined area.
w-During this assessment,-NRC perspective was provided by routine
,
inspections by resident inspectors, specialist' inspections, and the c
completion of a maintenance team inspection.
Maintenance l
Maintenance was generally performed in a controlled manner, in ac-cordance with procedures and was adequately supervised.
Controls
', '
have been established to ensure maintenance tasks were-appropriately planned, prioritized, and scheduled.
Realistic maintenance backlog
'
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goals have been established and the backlog was maintained below
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1 The effectiveness of th'e new plant materiel organization.was. evident'
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during this evaluation period.
The new organization was fully staffed
-;
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b and several_ benefits have been realized.
The creation of the plant-
[
materiel assessment group has allowed experienced maintenance per-
-sonnel, not associated with day-to-day maintenance activities, to
'
n more deeply assess and improve.the maintenance program.
Improvements
'~
included.a new lubrication program, completion of several reliability centered maintenance (RCM) system evaluations, and additional effort on root cause analysi_s..The new and expanded material' planning organi-zation' contributed to-the. timely completion of'the 8R outage.
'
The licensee started a major effort to more effectively plan main-
-
tenance activities and ensure that administrative procedures were followed.
This resulted in improved maintenance.
Maintenance organization and planning are now strong points in the overall
' licensee effort to operate the plant safely.
'
The plant materiel organization has implemented a maintenance pro-
- cedures writers guide and continues a general upgrade of maintenance-
,
procedures. One individual in-the licensee safety assessment orgri-M zation was' dedicated to this effort.
Vendor guidance and engine.;
input has been incorporated into the revised procedures to increase their usefulness.
The plant material. condition was good.
The licensee has instituted a program of senior operations / maintenance personnel walkdowns.of-speci-fic plant areas. Minor discrepancies were corrected on the spot or
,
1ncorporated into other specific tracking vehicles such as the plant preservation.(painting) work list.
Previous problems in identifying minor material discrepancies have been corrected.
'
'
The maintenance team inspection reviewed 43 specific aspects of the maintenance program.
The team concluded that 35 of those aspects e-were well documented and functioning well. The team identified six-specific weaknesses that needed improvement.
There were specific instances of incomplete documentation associated with tagouts, com-pleted work packages, and control of contractors.
In addition, the controls on vendor manuals, Is well as hoisting and test equipment, need improvement. Several vendor manuals were not controlled in the vendor document control program. The program for hoisting and test equipment was not well controlled.
Post maintenance testing was not always specified.or adequately documented.
In general, the examples
- of lack'of documentation and administrative controls were effectively
,
overcome by a capab_le staff, appropriate management attention and excellent implementation of work activities.
!
An effective Maintenance training program was in place.
A six shift rotation schedule allowed adequate t.ime for conducting training. A dedicated maintenance training staf f and facility has been established and training facilities such as mock-up and training aids are being y
upgraded.
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Surveillance l
_ The overall-surveillance program continued to-be: properly imple-
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.mented. /Surve111ances were performed on schedule, adequately.docu-
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.
'.
. mented and testing! deficiencies were properly = resolved. One minor problem occurred when the licensee identified that a surveillance for
!
a process l liquid effluent monitor.had not been completed as required by. technicaltspecifications. -This was due.to inadequate engineering /
-
licensingiinterface dur.ing completion of a modification to the sys--
t-tem. Three violations were identified during surveillance testing ij
. activities of which one was cited.
Two violations concerned testing
.
of engineered safeguards systems and were a combination of personnel
errors caused'by inadequate procedures and lack of' operator knowledge.
M
.
The violations involved inadvertent engineered safeguards features
and reactor protection system actuations. The licensee upgraded w
these" specific' types of surveillance procedures to eliminate poten--
tial confusion..This was effective.in resolving the problem.
g Generally, performance of surveillance testing was accomplished j
safely,- and the specific procedure / performance problems' identified in
'I the violations were not. indicative of programmatic deficiencies.
.4 The: inservice inspection program met program objectives.
Sufficient managem involvement existed.to properly control vendor-activities.
Licensee and vendor staffing was ampie.
' l
tin summary,.maintenanct.
survei.llance activities are perforhied
s well and-have a high (,,ree of management involvement.
Programs in place-were effective and procedure: reviews have been adequate, Pre-a vious problems-in the area-of administrative procedure adherence and-
~
, specific job planning, ave been corrected.
However,-administrative econtrols in the areas of post-maintenance testing and hoisting / test a
. equipment.need some improvement.
'
2.
Conclusion o
Category - l'
,
3.
Board' Recommendation i
Licensee: None
r
.
NRC:
None i
D.
Emergency Preparedness (124 hours0.00144 days <br />0.0344 hours <br />2.050265e-4 weeks <br />4.7182e-5 months <br />, 3%)
"
1.
Analysis
,.
During th'e previous SALP period, this area was rated Category 1.
The H
licensee had developed and maintained a strong emergency preparedness program.
No exercise weaknesses were identified.
l.
. i jt t
k
.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ -
- _ _ _ _ _
.
' '
[
- .
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"
'
g
,
b
-
i
!~
No deficiencies in the emergency plan wtre identified.
Upper manage-
-ment was routinely involved in emergency preparedness activities.
0 Management' involvement and control in assuring emergency preparedness program quality was effective and extensive.
Station managers main-'
tained emergency response organization position qualificaticr.. ree viewed and approved plan and procedure changes, participated in drills and exercises and resolved audit issues.
To determine if quality was achieved, an extensive audit was conducted by the li-
,
O censee's QA Department and reviewed by senior Lanagerrent.
Audit tea n members were well qualified for the task. The audit report found that an effective emergency program had been developed and was being
maintained. Additionally, licensee management continued their b-volvement in the off-site emergency preparedness program.
Two staff members were dedicated to off-site emergency preparedness.
There were frequent meetings with government officials.
The licensee also provided training for.off-site emergency workers.
Effectiveness of C
this training was demonstrated by the positive Federal Emergency Management Agency (FEMA) evaluation of performance during the exer-cise, The availability of the siren system exceeded FEMA specifica-tions, f
Sound resolution of technical issues continued this assessment period.
Due to past communication system failures, the licensee, working with the Commonwealth of Pennsylvania, has beer. integrated into the Pennsylvania Emergency Managernent Agency (PEMA) radio net-work. This radio system links the licensee to the PEMA Emergency Operations Center (EOC) and county EOCs.
The licensee has also been responsive in resolving problems with inadvertent sounding of the Alert and kotification System sirens.
Siren decocers have been re-wired to reduce the number of inadvertent siren soundings.
The licensee responded to one actual event during the assessment period.
This event involved a small steam generator tube leak under power ascension conditions, Approved procedures were correctly fol-lowed. Although not required, the licensee dispatched monitoring teams, calculated projected doses using worst case scenarios and monitored off-site readings.
In addition, the Commonwealth of Pennsylvania and county officials were voluntarily notified.
A sub-sequent review of this event, initiated iriternally by the licensee, revealed that their procedures lacked the analytical capability to immediately and accurately quantify a small primary leak rate. The licensee declared an Unusual Event (UE) a day late for this event when they found through detailed calculations, that the actual leak rate required a UE declaration. This report showed a willingness by management to ensure complete adherence to the Emergency Plan.
m
'
__
______ _ ___ _ ______ _ ___ _ ___ ___
_ __ _ _ _ _ _ _
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.
Staffing'of the emergen.cy prepareJness program was stable at all
'
"
J
' levels and the staff was well qualified to maintain an effective
.
t 0..
' emergency preparedness' program.
Emergency preparedness policies and-procedures were clearly delineated ~in GPU Nuclear Administrative Processes and the GPU Nuclear Emergency Plan.
The emergency response.
L organization was fully staffed and the Technical Support Center staff
~
was increased to provide for a more effective engineering capability on-site, A very ef fective emergency preparedness training program wts developed and j
,
p
' maintained by the plant training department.
The effectiveress of this l
L.
training was demonstrated by the performance of licensee personnel during
'
W-
.the full participation exercise.
The basis for the training was clearly i
described in the Training and Education Department Manual which delineate-lL policy, specifies the training matrix, lists course content, and states i
.
.
- ,
requalification policy. Training is practical in nature and was correctly based on job analysis.
Engineers were given training in accident analysis.
..
The realism.of th.s training has been enhsnced by the utilization of a
-
computer program which models six different accidents.
i
~
.
In summary, the licensee maintains a strong and effective emergency preparedness program. Management remains very involved with a
,
-
demonstrated commitment-to quality.
Technical issues were.promptly f
. resolved.
The Emergency Preparedness Program staff was stable and well
,
qualified to maintain an effective program. Training was well developed l
and effective as demonstrated by exercise performance. A very good working relationship was maintained with the Commonwealth, county and i
4 cal governments.
j 2.
Conclusion
Category-- 1
.
,
.!
"J.
Board Recommendation l
Licensee:
None-NRC:
None a
E.
Security (86 hourt 2%)
c.
'
1.
Analysis
,
-
-
i During the' previous assessment period, the licensee's performance was s
rated as a Category 1, based on a very effective and performance
-
.
oriented security program. Management attention to and support of
'
i the program were clearly evident.
No major regulatory issues were identified.
.
e
.
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.
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.
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During this assessment period, there was one routine unannounced security inspection performed by region-based inspectors.
Routine inspections by the resident inspectors continued throughout the
-
.
W period. One violation was identified in this functional area during this assessment period.. (failure of the medical departmnt to pro-i a
perly perform proper visual acuity tests for two security department b
personnel).
The licensee took timely and effective action to correct (
the, problem, identify the root cause and strengthen procedures to p
prevent recurrence.
'
~During this assessment, the licensee began a major equipment upgrade to replace access control hardware and the security computers with
,
,
!
state-of-the-art. equipment.
This upgrade program was scheduled ta be
"
completed my early in the next assessment period.
The allocahon of th resources to upgr&de equipment was evidence of management
,
support for an effective security program.
Corporate security management continued to be actively involved in L
site security program matters.
This involvement included site-
-
visits by the corporate staff to provide assistance, program co-praisals, and direct Jupport in the budgeting and planning process L,
affecti_ng program modifications and upgrades.
Site and corporate security management personnel also remained active in the Region I Nuclear Security Association and other organizations engaged in nuclear plant security matters.
This demonstrated program support-g
_
from upper level management.
J The'NRC-required annual audit of the security program, performed by the licensee's quality assurance group, was comprehensive in scope and depth. A thorough understanding and appreciation for nuclear plant security objectives by the audit team raembers contributed to the effectiveness of audit. However, the N9C found that the auditors were denied access to source medical documentation for members of the security organization. This resulted in the only violatian during
.this assessment period. When the problem was identified tL upper level management, prompt, effective and appropriate corrective action was taken.- The responsiveness.of management to resolve the problem was considered a strength.
In addition to the NRC-required audit, the licensee also continued to conduct self-assessments of.the pro-gram utilizing experienced security management personnel from corpor-
!
.
ate headquarters, Corrective act4ns on findings and recommendations identified during the audit ind self-assessments were prompt and-effective with appropriate folivw-up to ensure their proper imple-
"
mentation.
The comprehensive quality sssurance audit and the self-
- .
assessments were major factors in the licensee's excellent perform-ance and were further indications of the licensee's commitment to
,
implementing an effective security program.
'
,.
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The licensee submitted one security event report in a accordance with NRC: requirements during this assessment period The event was-the
,
E result of human' error.
The licensee properly reported the event tu-the NRC and the documentation was sufficiently comprehensive to per-I.
_
mit1NRC analysis without the need for additional information.
The licensee's event reporting procedures were consistent with regulatory
b requirements and implemented by knowledgeable personnel Because of E
this event and other minor human errors,.the licensee implemented a
. program to formally cr'tique all human errors with the people in-
'
volved., This is followed by an independent review and the identif1-
,I cation of lessons learned from the event.
This was further evidence
[,
l of the-implementation of an effective security program, m-Staffing o' the security force was consistent with program needs,- as evidenced oy the minimal use of overtime.
Members of the security force exh.oited a professional appearance, good morale and demeanor.
.Thu turncver rate remained very low.
.The training and recualiitcation program was administrated by a' full time inst m or from the Training Department who conducted all class-room tr:.1t.ing. All practical training was cor-1ucted by five members
.
'of'tbi security department. The training and requalification program L,
. was revised during, this assessment period to improve continuity so tbt all. required training was completed in a single block instead of.
O a fragmented manner.
The effectiveness of the training program o
'
was shown by the smail: number of personnel errors that occurred dur-ing the assessment period.
In summary,.thr licensee's hardware improvements and strong personnel practices provided for a strong security program., Effective audits and' strong corporate' support aade a positive contribution.
i 2..
Conclusign Category 1 3.
Board Recommendation Licensee:
None NRC: None
'
. F.
Engineering / Technical Support (419 hours0.00485 days <br />0.116 hours <br />6.92791e-4 weeks <br />1.594295e-4 months <br />,.11%)
1.
Analysis luring the previous assessment period, the licensee's performance in
.his functional area was rated Category 2, Improving. There were
- soted improvement, in prioritizing work assignments, training for safety reviews, and control of modifications.
Initiative was evident
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.
_ _.
_
_ _ _ _ _ _ _
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,
h4 in the program planning for design bases documents and safety system P4-functional inspections.
Support of operations was generally thorough i
T
.and effective;.however, there was indication that improvements could
,
'
.be made in several activities such as. support data for the diesel p,*1,
'yeneratoriload calculation, and in. planning post modificaticn func-
,
p t nnal acceptability verification of several design changes; y
qm Q
In vections~ performed by region. based personnel, the resident in-
A spettors, and evaluations from headqua.rters staff provided the bases-
for the current assessment.
i
.
f Dt. ring this SALP. period, the licensee has completed several major
"
f modifications in which effe-tive engineering was evident. The Heat
Sink Protection System ' upgrade improved the logic and electrical
'
m U
supply for emergency and main feedwater (FW) system isolation and l
[
control. All 32 FW Flows nozzles were replaced in both,SGs. A Cold
'
'
leg Nozzle Dam'insta11ation was engineered to enable SG work during reactor flood-up conditions.
Two new state-of-the-art electroon!-
ished FW Flow Venturi replacements were installed and tested. All-the
above ef forts were 'we11 ' planned witi, in-depth engineering involvement l
and direction und were good engineering accomplishments.
!
Numerous other smaller modifications were performed during the 8R I
outage.
These included upgrade of the Reactor Coolant Pump-Lube Oil System upper reservoirs, Reactor Building Maintenance Platforms,
>
Gaseous Chlorine System replacement, the inh;al phase of the Instru-
. ment Air System upgrade, and the Radiation Monitoring System pump replacements.
In each of these modifications, the engineering was t
thorough with clearly written installation specifications, safety.
,
- evaluations, work descriptions, and testing requirements. Good in-
terface between site and corporate engineering was evident during the l
. daily outage status meetings and engineering support contributed to a successful. outage and timely modification. completions.
l.
Engineering's-support of site operations by plant and corporate
)
engineering was evident during the activities related to high SG
'
1evel and reduced power due to corrosion build-up on the SG tubes.
.This was an example cf ' good communications and teamwork.' Plans for
' chemical cleaning of the SGs was assigned a high priority and cor-
'
potate engineering has drafted' details for the work.
'
Plant engineering activities in support of operation and maintenance was viewed as a strength.
InMiatives were taken in the valve pack-
~
ing upgrade program to eliminate asbestos and use live load packing.
Recent efforts to develop a split mechanical pump seal to allow main-tenance without removing bearings showed a high level of engineering i
involvement and expertise. -The control rod drive mechanism (CRDM)
gasket and split nut ring replacements were well coordinated by en-gi nee ri ng".
A large task force of site and corporate engineers was used.
This required effective engineering interface with operations and maintenance.
Sound engineering determinations were demonstrated f
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'
.
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,
.
-
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.
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,
,
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'
in the resolution of an inaccurate reactor pressure boundary leak
'
rate. 'This required. flow indicator relocation, piping reconfigura-
!:
tio'n, and valve replacement.
Plant engineering support of the SG tube-and tube plug eddy current-testing was adequate and a conserva-
'
>
tive approach was taken to remove defective plugs.
Ultrasonic test-1[
ing of the new and reused fuel and the recaging of one assembly re-sulted in a core reload free of defects.
~A review of the licensee's involvement,in and implementation of the B&W Owners Group Safety and Performance Improvement Program (SPIP)
.
found corporate and site management committed to.and very active in the program. The licensee's engineering staff was extremely know-
"'T
.ledgeable of.the issues, recommendations received appropriate priori-tization, and good engineering analyses supported each recommendation.
The licensee.has made an aggressive effort to improve plant safety as-La result of the SPIP program and at the end of this assessment period, only 3 out 222 recommendations remained to be implemented.
L The plant and corporate engineering staff responded to the SG tube leak shutdown of March 6, 1990.
Engineering teamwork was evident in the aggressive effort to find the leak, determine its cause and per-
'
form necessary corrective action.
The licensee has made appropriate commitments to evaluate preventive actions such as tube sleeving.
In addition, the licensee's request for a waiver of compliance and an exigent Technical Specification change were very detailed'and had good engineering bases.
The Corpo-ate Engineering and Design Department pilot programs for
<
Design Bases Documents (DBDs) and Safety System Functional Inspec-
.tions (SSFIs) heve been successful.
The 1989 DBD reviews for the Reactor Building tL&rgency Cooling Water and the Liquid Radwaste systems, and the SSFIs en Liquid Radwaste and Emergency' Power.Distri-bution were well performed and meaningful findings resulted from each project..The licensee's action item tracking and updating of the documents have been systematic and contributed to the program.
Future DBD plans were aggressive and included five DBDs and one SSFI E
to be performed in 1990.-
.
Several problem areas noted during the assessment period included the o
high backlog of site engineering evaluation requests and a large number of Field Change Notices and Requests associated with modifi-cation projects. Each of the problems was being appropriately ad-dressed.
- 4=
Within the context of finding problems, the licensee's self-assessment of technical support performed in 1989 and updated in January 1990 was beneficial in pointing to areas needing improvement.
,
Based on the licensee's ability to find and take immediate corrective
'
actions for each problem, engineering management was committed to continued improvement.
The majority of the self-assessment action-L items have been comoleted.
!
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K
N The drawing legibility program to improve'500 drawings'that was initiated in 1989 has been completed using in-house resources.
The other activity. associated with this program, that of replacing 25,000
,
!
circuit schedule hard copy drawings with a computer data base was a comprehensive in-house undertaking-and a notable system improvement.
v L
The backlog of items assigned to the corporate technical functions organization had a sizeable reduction in this essessment period.
The
'
licensee's new graphical backlog forma.t presents a clear picture of I'
_the number of. items and the chronology and age group of the item.
.
f-The! backlog tracking system was updated monthly and was a good manage-W ment tool.
'
The lice see's engineering groups were adequately staffed with suf-ficient ; trsonnel of'all engineering disciplines.
There was little use of c(' tract engineers other than in outage activities;- however, contracts fere in place to provide architect engineer and NSSS vendor support wl,<n needed.
The licensee is supportive of industry stand-p'
ards group, owners group, and professional society participation,
'
The rotational assignments of engineering management and engineers between corporate and site continued to be benefiaial.
Training of new engineers included one year of formal trainir,3 and one year on-site. A training programs also existed for the experienced engineers.
1:
'
After a detailed engineering evaluation of the alternatives to deal
,
with -steam generator-fouling, the licensee elected to manually trip the reactor to redistribute-the corrosion products causing the foul-ing.
The long term solution to the problem is chemical cleaning of
,
the-steam generator secondary side. Manually tripping the reactor-for this purpose unnecessarily challenges safety systems. However, there are aho technical reasons for minimizing plant cooldowns and heatups such as would be necessary for chemical cleaning. The li-censee has committed to chemical cleaning during the next scheduled refueling outage.
,
In summary, plant and corporate engineering have provided quality support for TMI-1 operations.
Engineering involvement was evident in
,
the modifications and in the problem solving responses to plant events.
-Good engineering initiatives were evident in the FW flow venturi
testing, valve packing upgrade, CRDM flange inspections, mechanical
. pump seals, SPIP program, self-assessment improvements, DBD format, and c'rawing improvements.
The staff was technically competent and k'
productive, and there was good teamwork within the organization.
!
Management was supportive of engineering and resource commitments for FW flow nozzle replacements, main FW venturi replacement, instrument air. upgrade, fuel leakage testing, and the heat sink protection up-
>
grade and the DBD program have been proactive.
Problem areas have
'
been minimal and of minor safety significance.
,
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.
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.
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.
.
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Conclusion
'
Cat'egory - 1 i
g n
.
3.
Board Recommendation
..
?, i licensee: None h
~NRC:
Nonc
'
.
w
.
U,.
G.
Safety Assessment / Quality Verification (102 hours0.00118 days <br />0.0283 hours <br />1.686508e-4 weeks <br />3.8811e-5 months <br />, 3%)
i h7,w
,
1.
Analysis
,
,
LE
,
\\.
This area received a Category 2 riting in the last assessment period.
?
^"
P Strengths identified included Quality Assuran:e Department (QAD)
oversight activities, initiatives taken by the licensee to enhance performance in this area, and the_ quality of Licensee Event Reports-K (LERs). Weaknesses were identified in the areas of 10 CFR 50.59
,
reviews of procedures, plant events caused by procedural inadequa-
-
'.
-cies, and investigation of plant events below the threshold of those
-
,
requiring an LER or Plant Incident Report (PIR).
,.
i The number of active licensing actions at any given time during the last two SALP periods has remained relatively constant at about 25,
which is below that of most other plants.
During this SALP period,
-
,
20 licensing actions were completed, including four license amend-
,
ments, three reliefs or exemptions, and-the last two remaining TMI i
Action Plan Items. Also, during this period, the licensee submitted
its responses to the ATWS Rule (10 CFR 50.62) and the Station Blaen-
,
out Rule (10 CFR 50.63).
The licensee was not as expeditious as,most other B&W licensees in submitting a final design document for the
ATWS Rule and took exceotion to a staff interpretation regarding power supply independence.
The licensee's Station Blackout obmittal
>
,
was timely, fully met the requirements of the rule and resulted in the first Station Blackout SER issued by the NRC.
Overall, the-in-
'
formation submitted by the licensee relative to license amendments
'
and'new rules was consistently timely, complete and of high quality.
The'20 completed licensing actions mentioned above included licensee responses to seven NRC generic letters, six NRC bulletin =, and three
,
NRC initiatives to improve Technical Specifications.
One of the most safety significant of these was Generic Letter.88-17, =" Loss of Decay Heat Removal".
The licensee's action in. response to this generic letter was particularly thorough and implementation of the short-term
'
actions has been verified by inspection to be appropriate and respon-
-l sive. 'Overall, the licensee responded to all NRC safety initiatives
-
responsibly during this period by submitting information and action plans that needed no clarification and were readily able to be evalu-
.ated as satisf actory by the staff.
To enhance communications with.
-
l the staff and understanding of the issues, the licensee met approxi-
mately once per month during this period with the NRC to discuss i
licensing issues and inspection open items.
i
-
%X
.
,
~
'
U J.
E.
.
>
19 Review of licensee performance in identifying and evaluating plant
.
deficiencies concerning safety indicated twn noteworthy examples.-
During an oudit of Fairbanks Morse, an emergency diesel generator
-
vendor, the licensee found deficiencies in the vendor's spare parts procuremerit program.
The licensee contacted other utilities through
,
s.
the Fairbank: Morse Owners Group to alert them of potential problems, i
Following issuance of an information notice by the NRC, the licensee
inspected their containment emergency sump screens and found gaps in
,
the screens as a result of a 1983 modi.fication.. The gaps could have allowed solid material to enter the FCCS pump suction lines during an
..
1.ccident.
The condition was identified and corrected iay the licensee.
,
The NRC appreved Revision 2 of the licensee's Operational Quality Ass.urance (( iA) Plan on February 7,1989.
This revision was fairly
.;
,
extensive and emphasized, among other things, a commitment to a performance-based quality assurance (QA) audit program.
The staff
>
reviewed'several licensee QA audit reports issued during this assess-i-ment' period.
One purpose of this review was to verify conformance with the-revised 0QA Plan and to make a qualitative assessment of the
.
effectiveness of the 00A audit program. The audits dealt 'with a wide
'
.
.
diversity of subjects. All reports contained one or more "recommen-dations" and most of the reports also contained " findings" that re-quired development of corrective actions by responsible departments.
The detail contained in audit reports reflected a notable effort on
'i the part of the audit team and a commitment by licensee management to
'
identify and correct problems that could adversely affect quality.
For example, an audit pursued some important points regarding poten-
!
tial fai1% modes of a Powdex bypass valve that had apparently not
'
been t.ons'iwred during review of system design' requirements and veri-
[
fication of the as-built configuration.
The audit of Maintenance, Construction and facilities identified six findings that required I
'a corrective action and two recommendations.
The licensee QA audit
,
reports were consistent with the licensee's 00A Program and reflected
an aggressive management attitude towards assuring quality.
Past SALP reports have noted concerns in the area of licensee reviews of plant procedure changes in accordance with 10 CFR 50.59. After i
,
the end of the last SALP period and after NRC approval of Revision 2 r
to the OQA. Program' the licensee implemented a revision to the safety
,
. review procedure.
The staff reviewed several of the procedure chan-ges' processed under the revised process to determine if there have been improvements in safety evaluations.
This review indicated that personnel performing procedure review functions were familiar with-appropriate site procedures and consistently filled out a Safety
'
Determination screening form.
The quality of these reviews has gen-
-l erally improved.
However, in some cases, the rationale used b/ the
. reviewer to answer questions on the screening form was stili not in j
sufficient detail to allow an independent reviewer to understand the thought processes (including which adverse operation may result from i
the change) and reach the same conclusion as the initial reviewer regarding whether or not a formal 10 CFR 50.59 review of a procedure revision it. necessary.
,
-'
,..
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~Although some improveme'nt has been noted in followup and documenta-
@ f'
. tion of events of a minor nature (e.g., those not, requiring an LER or
_.
f incident report), the licensee occasionally-failed to document their p f,
'
investigation of such events.
mvi, i< '
The queiity of Licensee Event Reports (LERs) continued to be high.
M@- '
ducitig this period.
LER 90-005-covering the March 6,' 1990, steam w
generator tube 1.eak was particularly well written and understandable, i w:
O@hf f'
The licensee has demonstrated safety initiative by. instituting a number of %provements dealing with plant design.
For example, T.
Safety, System Functional Inspections (SSFIs) have been performed on F7 the 11guld radwaste and emergency AC power systems and more SSFIs are E'l planned, Several' system modifications have been.made as a result of recommendations in the TMI-1.Probabilistic Risk Assessment.
For
,y example, two'small diesel generators were installed to provide backup i
powertto the switchyard air compressors and breaker heaters.
The
>
W,#y power supply for the "B" High Pressure Injection Pump Lube Oil Pump was. modified to improve reliability of that pump.
In addition, a 4,
task force was organized to-search for modifications that would im-M, prove the relidility of the Integrated Control System.
y U l. * '
In summary. the-licensee had policies, procedures and practices in
@
place to effectively identify, evaluate, and correct problems poten-
'
tially affecting plant safety.and quality.
Management involvement, 3 3 jk o from the highest levels down, was apparent in the daily operation of
"
the-facility, The Quality Assurance Department continued to be an.
n effective part of this effort and was recognized'as'such by manage-ment.
Improvement has,been noted in weak-areas identified in pre-f.. f
_vious~SALP reports.. The licensee basiaiso taken aggressive action.to make improvements in plant procedures and' system design, including a'
-
W number of plant modifications during the SR refueling outage, u
h l2.
Conclusion h
Catego_ry - 1
[t, 3.
Board Recommendation Licensee: None NRC:
None
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SUPPORTING DATA AND SUMMARY
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- A.1 Licensee Activities
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l During this' period, the licensee operated TMI-1 essentially at full
Jpower, except for a refueling outage and.three unplanned shutdowns i
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as'noted in Section.C (Forced Outages and Plant Transients). This
reflected two transition periods between power operations and hot (or.
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A; cold) shutdown, i
L A scheduled sixty-four day refueling outage started January 5,1990,
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F and the licensee completed it about three days early. Major
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safety-related work completed'during the refueling outage was:
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OTSG tube Eddy Current Testing and tube / plug repair work, f
2. - Seal replacements on al1. four Reactor Coolant Pumps.
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Reactor Building Integrated Leak Rate Test.
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4.- Ultrasonic testing of.all fuel assemblies for fuel leakage.
p-At the beginning of this period, the licensee's maintenance department
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at.TMI-1 was in the process of reorganizing into,a Material Department.
Four major groups in this department were formed to perform the following l
functions; corrective and preventive maintenance implementation, planning
and. scheduling, material' assessment'and administration.
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Also-during this ' period, the licensee implemented a corporate reorganization. This reorganization did not affeet plant i
operations.
' Al2 Direct inspection:and Review Activities
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.Four NRC resident inspectors were assigned to'the site (TMI-1 and 2)
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throsghout most of the assessment period. Total _NRC inspection effort
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was 3691 hours0.0427 days <br />1.025 hours <br />0.0061 weeks <br />0.0014 months <br /> (2952 hours0.0342 days <br />0.82 hours <br />0.00488 weeks <br />0.00112 months <br /> per year).
See Section-E for functional' area'
l expenditures.
Special: team inspections were: Maintenance Team : Inspection (89-80);
I Emergency Operating Procedure Inspection and Emergency Preparedness Exercise-(89-81).
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The-Office of Nuclear Reactor Regulation (NRR) sent a team to audit-i the licensee's implementation of Safety Parameters Improvement Program
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(SPIP).
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B.
Criteria
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t Licensee performance is assessed in selected functional areas,
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depending on whether the facility is in a construction, preoperational
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or operating phase. -Each functional area normally represents-areas
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significant to nuclear safety and environment, and area normally
[y programmatic areas.
Special areas may be added to highlight
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significant observations.
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L One or more of the following evaluation criteria was used to assess each
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functional area.
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1, Management in'volvement_and control in assuring quality.
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Approach to resolution of technical issues from a safety, standpoint.
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Enforcement history.
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Responsiveness to NRC initiatives
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Reporting and analysis of reportable events.
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Staffing (including management),
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Training-and qualification effectiveness.
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Based upon the SALP Board' assessment, each functional area evaluated f
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is classified into one of-three performance categories.
The definitions
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of.these performance categories are:
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0 Category 1:' Reduced NRC-attention may be appropriate.
Licensee
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management attention and' involvement are aggressive and oriented
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toward nuclear safety; licensee resources are ample and effectively
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used so that a high level of performance with respect to operational
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safety is being achieved.
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Category 2: NRC at'tention should be maintained at normal levels,
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Licensee management attention and involvement are evident and r
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concerned with nuclear? safety; -licensee resources are adequa;
.and reasonably effective so that satisfactory performance with respect to operational safety is.being achieved.
~ Category 3:
Both NRC;and licensee attention should be increased.
Licensee management. attention or involvement is acceptable and
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considers nuclear safety but weaknesses are evident; licensee
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minimally satisfactory performance with respect to' operational
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-safety is being achieved.
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,The.SALP Board may assess a functional area by examining the licensee's performance during the entire period -in order to determine the recent trend. The performance trend is intended to predict licensee performance during-the next assessment period.
The SAlp trend categories are as follows:
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The trend, if used cis defined as:
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Improving: 3 Licensee performance was determined-to be improving near-l
..the close of assessment period.
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Decliningi1 'Lihensee performance was determined to be declining;near;
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the close af Ti.c
- essment period and the licensee had not taken
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meaningful stepsi.to address this pattern.
j C.-
Unplanned Shutdowns' Plant Trips and Forced Outages
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'1.s 'On November 29, 1989, the reactor tripped.from 100% pcwer due l
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.to a loose wire in the electrohydraulic control system.
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q POWER' LEVEL ROOT CAUSE'
FUNCTIONAL AREA
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100%
Random Equipment Failure None t
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On March 4, 1990, the-reactor' tripped following completion of l
physics acceptance testing while the operator coved contiol
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s rods without closely mo-nitoring power.
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.. POWER LEVEL.
ROOT CAUSE FUNCTIONAL AREA l
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Intermedia te..
Operator Error Operations-Range
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On March 6, 1990, the reactor was manually shutdown due to a tube leak:in the "A" steam generator.
l x :.J POWER LEVEL ROOT'CAUSE
, FUNCTIONAL AREA:
75%
Equipment Failure Engineering and Technical
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Support e
D.'
l Enforcement Activity
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No.'of Violations in Each Severity Level _
Functional ~ Area.
V IV III II I
Total
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Plant Operations
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Radiological Con.trols 1-
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C.
Maintenance / Surveillance
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. D.- Emergency, Preparedness
E. -. Security-
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F. Engineering / Technical
1 Support
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- Safety Assessment / Quality
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Verification.
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E.
-Inspection Hour Summary
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Actua l--
-Annualized
. Percent 1'
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'I Plant' Operations 1993 11594'
r Radiological.Controis-211 169
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' Maintenance / Surveillance' 756--
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E'mergency Preparedness-124'
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-SeciMty
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- ,I Engineering /Techrleal 419 335 11-
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Support'
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' Safety 1 Assessment / Quality 102
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Total 3691 2952 100
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l F. Licensee Event' Report Causal: Analysis _
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Number by Cause Code
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D E'
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. Total
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j Plant Operations _.
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- Maintenance / Surveillance =
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-Radiological 1 Controls-
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Engineering / Technical. Support
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Safety' Assessment / Quality
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J. Unit-1- Total
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- Cause Codes.
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LA (Personnel-Error
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Design, Nanufacturing. Construction
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' orJ installation' Error
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. C: External Cause
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D : Defective Procedures
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- Ea -Component Failure:
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. Only eight Licensee Event _ Reports were submitted during 'his period.
No
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Lmeaningful'causalilinks were noted.
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