Text

Insp Rept 50-289/98-07 on 980920-1031.No Violations Noted. Major Areas Inspected:Licensee Operations,Engineering,Maint & Plant Support,Including Results of Insps by Regional Inspector Re Emergency Preparedness & Radiological Controls
	ML20196J151
Person / Time
Site:	Crane
Issue date:	12/03/1998
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20196J140	List: IR 05000289/1998007; ML20196J134;
References
	50-289-98-07, 50-289-98-7, NUDOCS 9812090270
	Download: ML20196J151 (49)
	v • d • e

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i U.S. NUCLEAR REGULATORY COMMISSION REGION 1-c 1.

Docket No.

50-289 License No.

DPR-50 Report No.

98-07 Licensee: GPU Nuclear, Inc. (GPUN) ~ Facility: Three Mile Island Station, Unit 1 Location: P. O. Box 480-Middletown, PA 17057 Dates: September 20 through Octooer 31,1998 Inspectors: Wayne L. Schmidt, Senior Resident inspector Craig W. Smith, Resident inspector Joseph E. Carrasco, Engineering Inspector, DRS Douglas A. Dempsey, Reactor Engineer, DRS William A. Maier, Emergency Preparedness Specialist, DRS John R. McFadden, Radiation Specialist, DRS ' Laurie A. Peluso, Radiation Physicist, DRS Approved by: Peter W. Eselgroth, Chief Projects Branch No. '7 Division of Reactor Projects 9812090270 981203 POR ADOCK 05000289 G PDR ,.

EXECUTIVE SUMMARY Three Mile Island Nuclear Power Station Report No. 50-289/98-07 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a six-week period of resident inspection; in addition, it includes the results of announced inspections by regional inspectors concerning emergency preparedness, radiological environmental monitoring, and radiological controls.

GPU Nuclear, Inc. (GPUN) operated Three Mile Island Unit 1 at 100% reactor power i throughout the inspection period.

) _QR?EstiRRE The control room staff operated the unit safely and responded well to several minor equipmerit issues. (Section 01) Plant operators responded well to a failed second stage feedwater heater relief valve.

Operations management and system engineering supported the operating crew wellin developing a plan to address a failed open feedwater heater relief valve. (Section 01,1) , Operators performed well during periodic full stroke testing of the turbine valves. (Section - 04.1) Maintenanga GPUN performed well during observed maintenance activities on a nuclear river water pump and on a reactor building hydrogen recombiner. Mechanical and electrical personnel conducted these activities well, followed approved procedure, and documented as-found conditions accordingly. Supervisor involvement was very good during these two jobs.

(Section M2) Observed surveillance tests were conducted properly including reactor protection testing and control rod drive breaker logic testing. (Section M2) GPUN identified, monitored, and put in place plans to improve the performance of structures, systems, and components that needed enhanced attention in their maintenance rule program. (Section M2.1) Enaineerina - GPUN took action to address concerns over the use of an unapproved acceptance criteria for dispositioning some eddy current indications in the Cycle 11 once through steam-generator (OTSG) inspections. Namely, a technical specification change request was

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submitted and approved to allow the use of a length-based repair criteria for inside diameter inter-granular attack indications during Cycle 12 OTSG inspections. Subsequent to the Cycle 12 inspections, GPUN submitted a report to the NRC outlining the resultr, of the OTSG inspections and providing an assessment of OTSG tube integrity for the c6 ration of Cycle 12 operation. (Section E8.1) GPUN properly reported the conditions of potentially overpressurized isolated piping following a loss of coolant accident, via LER 97-001-00. GPUN determined that while the identified piping sections would be pressurized above the original design limits the piping, based on additional analysis allowed by ASME Section ill, Appendix F, would not fail.

However, during the 12R refueling outage GPUN installed small relief valves on these lines to limit pressurization and thus stresses above design limits. Based on direct observations these relief valves would prevent overpressurization of the identified isolated lines.

(Section E8.5) Plant Support Emeraency Preparedness,, GPUM followed NRC regulations in implementing the reviewed changes to the emergency , plan implementing procedures. None of the changes decreased the effectiveness of the , approved emergency plan, and thus did not require prior NRC approval. (Section P3) The overall performance in the September 30,1998, drill demonstrated the onsite emergency plan was adequate and the licensee was capable of effectively implementing it.

One amcise weakness was noted due to the failure to complete offsite notifications within the15 minute time requirement for both the Alert and Site Area Emergency

declarations. The critiques, conducted immediately following the drill and in a formal presentation on October 2,1998, were candid, organized, and an accurate appraisal of drill performance. (Section P4) Radioloaical Controls: GPUN implemented effective applied radiological controls at Unit 1. Access controls to rad lologically controlled areas were effective, and appropriate occupational exposure monitoring devices were provided and used. Personnel occupational exposure was maintained within applicable regulatory limits and as low as reasonably achievable. The radiation work permit program was properly implemented. (Section R1.1) GPUN implemented overall effective surveys, monitoring, and control of radioactive materials and contamination. Health Physics technicians conducted proper surveys and properly documented survey results. Radiological housekeeping conditions were noted to be generally good. Personnel and area contamination rates were tracked and trended. In general, the surveys, monitoring, and controls were implemented with calibrated and properly used devices. (Section R1.2) GPUN implemented an overall effective program to maintain occupational radiation ' exposure as low as reasonably achievable (ALARA). The monthly Station Health Physics

- - - . _ _ _ _ Awareness Committee meetings provided coordination of ALARA efforts. The pre-job ALARA review and the pre-job briefing meeting for Radiation Work Permit No. 157866 (diving evolution in the spent fuel pool) were detailed and extensive. (Section R1.3) l GPUN demonstrated effective radiation protection self-identification and corrective action i processes. Quality Assurance (QA) audits, monitoring reports, corporate assessments, and i self-assessments continued to be effective in identifying, at a low threshold, deficiencies and improvement opportunities. Corrective actions were implemented for findings.

j (Section R7) Radioloaical Environmental Monitorina: Overall, the licensee effectively maintained and carried out the radiological environmental monitoring program in accordance with regulatory requirements. Groundwater tritium ' monitoring was comprehensive and effective. (Section R2.1) The licensee effectively maintained and implemented a meteorological monitoring program , following regulatory requirements, including effective calibration methodology. (Section ' R2.2) GPUN's self-identification and corrective action processes in the area of radiation protection were effective. NSA audits, monitoring reports, corporate assessments, and

self-assessments continued to be effective in identifying, at a low threshold, deficiencies ' and improvement opportunities. Corrective actions were implemented for findings.

(Section R7) The audits and self assessments were of sufficient depth to assess the implementation of the radiological environmental monitoring program and the meteorological monitoring program. (Section R7.1) The environmental laboratory continued to implernent effective quality a.ssurance/ quality control programs for the radiological environmenntal monitoring program samples, and continued to provide effective validation of analytical results. The programs are capable of l ensuring independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample media. (Section R7.2) iv !

.- - .- . .. -, . .-. _- - . [ i - , TABLE OF CONTENTS . EX EC UTIV E S U M M A R Y.............................................. ii - i.

TA B LE O F C O NTENTS............................................... v , a l 1. Operations .....................................................1 k '

Conduct of Operations.................................... 1 01.1-Failed Feedwater Heater Relief Valve..................... 1

Operator Knowledge and Performance......................... 2 04.1 Operator Performance During Turbine Valve Testing.......... 2 . , i 11. M a int e n a n c e................................................... 2 i M2 Maintenance and Material Condition of Facilities and Equipment....... 2 ' M2.1 Maintenance Rule Monthly Report....................... 2 l

111. E n g i n e e ri n g................................................... 3

, E8 Miscellaneous Engineering issues............................. 3 j ! E8.1 (Closed) Unresolved item 50-289/95 13-01................ 3

I . E8.2 (Closed) Escalated Enforcement items 95-238/01013......... 4

1 E8.3 (Closed) Followup ltem 5 0-2 8 9 /9 6-0 8-02.................. 6 E8.4 (Closed) Unresolved item 50-289/97-07-01................ 7 i j E8.5 (Closed) Licensee Event Report 9 7-001 -00................. 7 ' E8.6 (Closed) Violation 50-2 7 8/97-10-01...................... 8 m l IV. Plant Support .................................................9 P3 Emergency Preparedness Procedures and Documentation............ 9 P4 Staff Knowledge and Performance in Emergency Preparedness........ 9 , P8 Miscellaneous Emergency Preparedness issues.................. 11 P8.1 (Closed) Escalated Enforcement item 97-127/04013......... 11 , i P8.2 (Closed) Escalated Enforcement item 97-127/04023........ 11

P8.3 (Closed) Violation 50-28 9/97-04-01.................... 1 1 P8.4 (Closed) Inspector Followup item 50-289/97-04-02..........

P8.5 (Closed) Inspector Followup Item 50-289/97-08-02.......... 12 R1 Radiological Protection and Chemistry (RP&C) Controls............ 12 R1.1 Radiological Controls-External and Internal Exposure......... 12 R1.2 Radiological Controls-Radioactive Materials, Contamination, Surveys, and Monitoring ....................................14 R1.3 Radiological Controls-As Low As Reasonably Achievable...... 16 R2.1 Implementation of the Radiological Environmental Monitoring Program ..............................................17 R2.2 Meteorological Monitoring Program..................... 18 R6 Radiological Protection and Chemistry Organization and Administration. 19 R7 Ous!ity Assurance in Radiological Protection and Chemistry Activities.. 19 R7.1 Guality Assurance Audit Program ......................20 R7.2 Quality Assurance of Analytical Measurements............. 20 V. Management Meeting s........................................... 21 v

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. . ..- _ _ _ -. _ -.. _ - _ .. _ _.... _ _.... . _ _... _ _ _ _ _... _. _ _.. _.. _ _ X1 Exit Meeting Summ ary................................... 21 X2 Engineering Management Meeting........................d.. 21' INSPECTION PROCEDURES USED..................................... 22 ITEMS OPENED, CLOSED AND DISCUSSED.............................. 23 LIST OF ACRONYM S U SED.......................................... 24

ATTA C H M E NT 1................................................. 2 6 ATTAC H M E NT 2................................................. 2 7 i i i ! i

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Report Details ! ,

j Summary of Plant Status ! , i GPU Nuclear, Inc. (GPUN) operated Three Mile Island Unit 1 (TMI) at 100% reactor power ! throughout the inspection penod.

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l. Operations ' . t j

Conduct of Operations (71707) l , i The control room staff operated the unit safely and responded well to several minor equipment issues including a minor emergency diesel generator (EDG) issue and a failed , feedwater heater relief valve.

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01.1 Eailed Feedwater Heater Relief Valve l

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Insoection Scooe (71707)

t - j On October 19,1998, the inspectors observed operations personnel response to a + )_ failed extraction steam relief valve (HV-V-13A) on de shell side of the "A" second

$ stage high pressure feedwater heater (FW-J-1 A).

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, b.

Observations and Findino,g ., a { l Control room operators took prompt action to reduce reactor power in response to l ' the event and prevented exceeding core thermallimits. The event occurred during j off-normal work hours. Plant management and support staff responded quickly and ' provided appropriate recommendations to the operating crew. The failed relief valve l , was gagged shut. A temporary modification was prepared to cross connect the '

relief valve from the "B" second stage high pressure feedwater heater (FW-J-18) l and provide over pressure protection to FW-J-1 A. The plant was returned to 100%

j power later that day.

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Conclusions )

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Plant operators responded well to a failed second stage feedwater heater relief

valve. Operations management and system engineering supported the operating ! crew wellin developing a plan to address a failed open feedwater heater relief valve.

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Operator Knowledge and Performance - , t 04.1 Operator Performance Durina Turbine Valve Testina ' I a.

Inspection Scope (71707) I l The inspector observed operator performance during full stroke turbine valve testing ' in accordance with GPUN Operating Procedure 1106-1," Turbine Generator," ! Appendix C, " Valve Testing - Main Turbine."

I b.

Observations and Findinas Operators performed well during the testing. Operations management was present in the control room during the test and the operating crew exercised good control of the evolution. Communications between test personnel in the control room and the field were professional and aided in the safe conduct of the test. The procedure l was well written and provided sufficient detail, with appropriate precautions, notes, and cautions.

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Conclusions Operators performed well during periodic full stroke testing of the turbine valves.

l I II. Maintenance [ i M2 Maintenance and Material Condition of Facilities and Equipment (62707,61726) GPUN performed well during observed maintenance activities on a nuclear river i water pump and on a reactor building hydrogen recombiner. Mechanical and electrical personnel conducted these activities well, followed approved procedures, and documented as-found conditions accordingly. Supervisor involvement was very j good during these two jobs.

t Observed surveillance tests were conducted properly including reactor protection , testing and control rod drive breaker logic testing.

l ) M2.1 Maintenance Rufe Monthly Report , i i a.

Insoection Scope (62707) ' I l

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l-The inspector reviewed the September 1998 maintenance rule monthly report to , l assess GPUN's implementation of 10 CFR 50.65, " Requirements for Monitoring the j !- Effectiveness of Maintenance at Nuclear Power Plants",(the maintenance rule).

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Observations and Findinas i As of September 1998, GPUN was monitoring the performance of nine structures, systems, and components (SSCs) under paragraph 50.65 (a)(1) of the maintenance , rule. In May 1998, GPUN added six of these SSCs to this list following redefinition ' of the methodology for assessing system performance. The new methodology assessed SSC performance on a more detailed level, based on system functions.

The SSCs being monitored under paragraph 50.65 (a)(1) of the maintenance rule were: 480 Volt Auxiliary System

High Pressure injection / Makeup and Purification

Auxiliary and Fuel Handling Building Heating and Ventilation

Secondary Services River Water

Reactor Building Spray

Control Rod Drive Mechanism

Integrated Control System

Low Pressure injection / Decay Heat Removal

Decay Heat River Water

The inspector found appropriate system performance goal setting and corrective action plans documented in the corrective action program (CAP) for each of the SSCs in category a(1).

c.

Conclusion GPUN identified, monitored, and put in place plans to improve the performance of SSCs that needed enhanced attention in their maintenance rule program.

Ill. Enaineerina E8 Mi cellaneous Engineering issues (92903) E8.1 (Closed) Unresolved item 50-289/95-13-01: Once Throuah Steam Generator Inservice insoection Activities a.

Insoection Scoce (92903) NRC Inspection Report (IR) 95-13, dated December 14,1995, addressed GPUN's practice of using a voltage-based criteria for dispositioning some once through steam generator (OTSG) tube eddy current indications in the Cycle 11 refueling outage. At the time, the Technical Specifications (TSs) referenced only a percent through wall acceptance criteria for dispositioning eddy current indications. The inspector questioned whether the use of a voltage-based acceptance criteria required prior NRC review and approval. Following the Cycle 11 OTSG inspections, GPUN met several times with NRC staff members from the Office of Nuclear Reactor Regulation (NRR) to discuss the use of an alternate repair criteria for inside diameter (ID) inter-granular attack (IGA) indication b.

Observations and Findinas A number of variables complicate the ability to accurately size the depth of OTSG tube service induced IGA degradation with eddy current inspection techniques, making accurate dispositioning of tubes using a depth-based criteria difficult.

However, eddy current techniques can be used to reasonably estimate the length of such indications. In a TS change request dated August 12,1997, GPUN proposed using a length-based criteria for dispositioning ID IGA indications.

On October 16,1997, the NRC staff issued a TS amendment allowing use of the length-based repair criteria for ID IGA indications for Cycle 12 operation only. The TS amendment required that GPUN demonstrate the structuralintegrity of the tubes to be left in service with known IGA defects based on the length-based repair criteria. These requirements included in-situ pressure testing of the most significantly degraded tubes and an assessment of the growth of any ID IGA defects during Cycle 12.

GPUN implemented the TS amendment during the Fall 1997 refueling outage.

GPUN submitted a report, dated January 12,1998, to the NRC, which included a summary of the extent of the OTSG inspections, the location and eddy current characteristics for each indication of an imperfection, and an assessment of OTSG tube integrity for the duration of Cycle 12 operation. The NRC staff had no comments on the report.

The inspector closed this item since the NRR staff accepted GPUN's methodology of using eddy current testing to identify OTSG tube ID IGA defects combined with the use of length-based acceptance criteria. While this failure to disposition OTSG indications as required was a violation of TSs, this f ailure constitutes a violation of minor significance and is not subject to formal enforcement action.

c.

Conclusions GPUN took action to address concerns over the use of an unapproved acceptance criteria for dispositioning some eddy current indications in the Cycle 11 OTSG inspections. Namely, a TS change request was submitted and approved to allow the use of a length-based repair criteria for ID IGA indications during Cycle 12 OTSG inspections. Subsequent to the Cycle 12 inspections, GPUN submitted a report to the NRC outlining the results of the OTSG inspections and providing an assessment of OTSG tube integrity for the duration of Cycle 12 operation.

E8.2 (Closed) Escalated Enforcement items 95-238/01013: Failure to Adeauately control a Modification to Reactor Coolant System Drain Pinina and 95-238/02014: Failure to Perform an Evaluation to Demonstrate the Adecuacy of Reactor Coolant System Drain Pipina Suncorts The inspector reviewed the GPUN corrective actions for two escalated enforcement items (Eels),01013 and 02014, from enforcement action (EA) 95-238, initially described in IR 95-16. Both violations concerned design control and corrective

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i actions regarding reactor coolant system (RCS) drain piping. The inspector reviewed the GPUN letter dated April 10,1996,in response to the violations. The inspector reviewed key aspects of GPUN calculation No. C-1101-566-5320-006, i Revision 2, which analyzed the support configuration, configuration change

document No. T1-CCD-128205-00,and work package No. 780965, which installed . the modified configuration.

O_1.,013: GPUN had developed a modification because of a 1990 structural analysis that , showed that the RCS drain pipes were over-stressed due to an improper support configuration. However, GPUN had not carried out the modification as of i

September 1995. GPUN stated that the violation occurred because no formal J tracking system captured the 1990 modification and the staff failed to followup on l the action.

i i ' To address this portion of the violation, GPUN carried out another series of stress analyses and possible design changes to the RCS drain line supports that satisfied i ' the design code, United States Standard B31.1-1967, Power Piping (B31.1-1967.)

The design evaluations showed that rather than strengthening the existing piping supports, GPUN should design new supports for both loops. The inspector found the calculation of the piping support modification to reduce the thermal over-stress ! condition in the piping to be acceptable. The inspector verified that: ' GPUN carried out the support modifications, according to the configuration

! control document.

Modification documents contained sufficient detail, precise instructions, and

well-defined scope.

j Adequate control of design interfaces and coordination among participating i

design organizations were used.

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Another aspect involved an error in the GPUN evaluation of a crack in the RCS dram l line following identification by GPUN during the refueling cycle 11 outage in 1995.

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This error had resulted in underestimating the stress in the pipe. The revised ) analysis showed thermal stresses approximately 40% above the allowable specified I in the design code. GPUN attributed this pipe stress underestimation to a personnel

error in the calculation.

. The inspector veri'ied that GPUN had counseled the preparer and the reviewer of i this stress calculation. The verifier was temporarily suspended from performing

verifications until GPUN retrained him on the enhanced design verification l procedure. Further, the inspector verified that GPUN reviewed and revised the pertinent procedures to correct programmatic issues that may have contributed to the calculation and verification errors.

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In terms of training, the inspector reviewed " Engineering Personnel Training," No.

10.1.20. This document was revised and enhanced to add this lesson learned. The , l inspector found this document to be an excellent training tool to prevent errors such - .,

as this one. Further, the inspector verified that records showed that 113 individuals successfully completed this training.

The inspector found GPUN's assessment and the response acceptable and closed this violation.

02014: GFON had improperly resolved design problems upon identifying a distorted support on the RCS drain lines. GPUN did not adequately evaluate the piping and associated supports. Further, GPUN structural analysis of the drain lines showed that the configuration of the supports did not allow the pipe to expand under , thermalloading. Consequently, stress levels in the drain piping exceeded the i allowable stress values of the design code (B31.1-1967). To address this over-stress, GPUN had used a later code, American Society of Mechanical Engineers (ASME) Code, Section Ill, subsection NB-3653, but the analysis did not incorporate all related requirements established in the Section 111 of the ASME Code. The violation involved a 1990 pipe stress calculation and a 1989 and 1990 support inspection and evaluation.

Regarding the 1990 pipe stress calculation, GPUN addressed inconsistent uses of codes by establishing measures for proper code application or a rigorous code reconciliation. The inspector verified that these measures were in place in " Engineering Standard" No. ES-001. Also, the inspector confirmed that upon the completion of the recommended modifications to the RCS drain line, the pipe stress was within design code B31.1-1967 allowable limits.

Regarding the 1989 and 1990 pipe support inspection and evaluation, upon identifying the bent support, GPUN had not properly followed up. To address this part of the violation, GPUN revised the entire corrective action process to ensure that upon identifying deficiencies (e.g., hardware or software), the responsible individual must enter the deficiency (as-found condition) in the corrective action process to ensure tracking to a satisfactory completion.

The inspector found GPUN assessment and the response acceptable and closed this violation.

E8.3 (Closed) Followuo item 50-289/96-08-02: Leak Testina of Pressure Isolation Valves The inspector identified 18 pressure isolation valves in the decay heat removal, makeup and purification, and reactor coolant systems that were not individually leakage rate tested as Category A valves in the TMI-1 Inservice Test (IST) Program.

Alternate tests methods for the valves were discussed in GPUN's response to Generic Letter (GL) 87-06, " Periodic Verification of Leak Tight integrity of Pressure isolation Valves," including: (1) current TS and inservice functional tests, (2) daily RCS leakage rate calculations, (3) monitoring of plant operational parameters, and (4) pressure isolation valve maintenance histor.. _ - - !

In a task interface agreement (TIA) dated November 26,1996, NRC Region I requested the NRR staff to determine whether the 18 valves are subject to leakage testing in accordance with the IST requirements of 10 CFR 50.55a and the ASME i Operations and Maintenance Standards, Part 10, as referenced by the 1989 Edition ' of the Boiler and Pressure Vessel Code. NRR responded to the TIA on February 20,1997. NRC staff review of the test requirements for non-Event V pressure isolation valves was conducted under Generic Safety issue (GSI) 105, , "Intersystem Loss-of-Coolant Accidents (LOCAs) for Light-Water Reactors," and j documented in NUREG-1463," Regulatory Analysis for the Resolution of Generic - Safety issue 105." The NRC concluded that there was insufficient basis to impose generic leakage testing requirements for these types of non-Event V isolation valves. In addition, according to the Individual Plant Examination (IPE) for TMI 1, the risk significance of interfacing system loss of coolant accidents is relatively low, ' approximately 9.2E-7/ year or 2.2% of the total core damage frequency.

Based on the NRC's resolution of GSI-105, the IPE results for interf acing system LOCAs at TMi-1, and the licensee's current surveillance and maintenance practices, , the inspector concluded that the 18 pressure isolation valves at TMI-1 do not need i to be individually leakage rate tested in the IST program.

E8.4 (Closed) Unresolved item 50-289/97-07-01: Pressure Lockina and Thermal i Bindinas of Safetv-related Gated Valves i When this item was opened, the licensee had not completed its evaluation of j safety-related motor-operated gate valves for susceptibility to pressure locking and i thermal binding. The licensee since completed its evaluations and documented the results and proposed corrective actions in response to GL 95-07, " Pressure Locking and Thermal Binding of Safety-Related Power-Operated Gate Valves." Final review of this issue at TMI, including the need for any further licensee activities, was documented in a safety evaluation report on January 22,1998, on GL 95-07 issued i by the NRR staff.

l , E8.5 (Closed) Licensee Event Report 97-001-00: Potential Overoressurization of Isolated i Pioina Followina an Accident

a.

Inspection Scoce The NRC issued GL 96-06, dated September 30,1996, to address, in part, the possible overpressurization of isolated piping runs that penetrated the containment, due to thermal expansion of trapped water following a LOCA.

The inspectors reviewed the GPUN licensee event report (LER), 97-001-00, issued on February 17,1997, to document the identification of several piping runs that could be overpressurized. The inspectors also reviewed several subsequent GPUN GL 96-06 responses and walked down the completed modifications.

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b.

Observations, Findinas and Conclusion GPUN properly reported the conditions of potentially overpressurized isolated piping following a LOCA, via LER 97-001-00. GPUN determined that while the identified piping sections would be pressurized above the original design limits the piping, based on additional analysis allowed by ASME Section Ill, Appendix F, would not f ail. However, during the 12R refueling outage GPUN installed small relief valves on these lines to limit pressurization and thus stresses above design limits. Based on direct observations these relief valves would prevent overpressurization of the identified isolated lines.

E8.6 ! Closed) Violation 50-278/97-10-01: Failure to Review and Document Reactor Buildina Cooler Testina and Unresolved item 50-278/97-10-03: Review of Reactor Buildina Cooler Confiauration a.

Insoection Scope The NRC issued GL 96-06, dated September 30,1996, to address, in part, the t possibility of damage to reactor building emergency cooler (RBEC) water piping due - to voiding and subsequent water hammer, all following a design basis LOCA.

In IR 97-10, the inspectors identified several issues with the RBECs; first, the licensee isolated the RBECs from the normal nuclear service closed cooling (NS) water pressurization source without completing a safety evaluation, and second, that the licensee had not translated the design basis need for the NS pressurization into the operating procedures for the RBECs.

b.

Observations, Findinas and Conclusions GPUN acted accordingly to identify and address problems with the control of troubleshooting and design basis information. In their response dated March 30, 1998, GPUN clarified the circumstances that lead to closure of the RBEC outlet - valves and isolation of the coolers for approximately seven hours in November 1997. Corrective actions taken which were reviewed by the inspectors included: Enhanced operator guidance for the conduct of troubleshooting and the use

of procedures. This guidance ensures that troubleshooting activities are properly reviewed by senior licensed operator and a special test procedure developed and reviewed if the activities are difficult or cannot be conducted i using previously approved plant procedures.

Enhanced guidance for review of design basis information following .

modification or changes to system design operating requirements and the related actual plant operation requirements.

Based on these corrective actions, the inspectors closed violation 97-10-0 In their September 30,1998, response to an NRR GL 96-06 request for additional information, GPUN stated that additional calculations had been completed to ensure that voiding of the RBEC water piping did not cause water hammer damage to the piping. GPUN also stated that they had completed this evaluation with the NS cross tie closed. Based on this statement and on the continuing review of the adequacy of GPUN's GL96-06 response by NRR the Unresolved item 97-10-03 was closed.

IV. Plant Support P3 Emergency Preparedness Procedures and Documentation a.

Insoection Scope (82701) The inspector reviewed recent changes made to the emergency plan implementing procedures (EPIPs) to determine if these changes were made in accordance with NRC regulations. He performed this review both onsite and in the NRC Regional office. The inspector discussed some of the changes with the emergency preparedness (EP) staff to determine better if these changes constituted a decrease of effectiveness of the approved onsite emergency plan. A list of the changes reviewed is included as Attachment 1 to this report.

b.

Observations. Findinas and Conclusions GPUN followed NRC regulations in implementing the reviewed changes to the EPIPs.

None of the changes decreased the effectiveness of the approved emergency plan, and thus did not require prior NRC approval.

P4 Staff Knowledge and Performance in Emergency Preparedness a.

Insoection Scope (82301) The inspector observed the onsite performance during the EP drill conducted on September 30,1998. The inspector observed a portion of the activities conducted in the emergency control center (ECC), the technical support center (TSC) and the emergency operations facility (EOF). He also observed the formal critique of the drill, conducted on October 2,1998. This drillinvolved activation and operation of the major onsite emergency response resources and involved limited participation by offsite agencies. The agencies affiliated with the Commonwealth of Pennsylvania provided representation to the EOF.

b.

Observations and Findinas Activities in the ECC went well with one exception. Offsite agency notifications for both the Alert and Site Area Emergency declarations were not completed within the 15 minute time limit specified in procedures and NRC regulations. The notifications were completed in 18 minutes for both event declarations. The licensee's preliminary investigation of these late notifications revealed complex causes, but

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training inadequacy was a contributing factor. This failure to complete the offsite

agency notifications within the 15 minute time requirement constituted an exercise , > ] weakness, requiring corrective action. This issue has been classified as an inspector followup item, and the NRC willinspect impbmentation and adequacy of

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corrective actions at a later date. (IFl 50-289/98-07-01)

' i , j The licensee has experienced difficulties, in the past, in accomplishing notification to offsite agencies within 15 minutes of the declaration of an emergency event.

, i These ptoblems have occurred during drills and exercises as well as during an actual

emergency event notification in June 1997. The latter occurrence resulted in the i

issuance of a Notice of Violation (NOV) (IR 97-06).

' l The licensee determined the root cause to be related to qualification of the communicators making the telephone calls. Hardware issues that contributed to the ! proble n were also cited. The licensee took action in response to the NOV to >

i correct the problem, including the installation of a computer system that i j automatically delivers a predefined event notification form with up-to-the-minute

supporting data and standardized event descriptions. This eliminated some of the overhead burden previously experienced in generating the information manually.

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These predefined event notifications are printed out for immediate telefax ' l transmission to the offsite agencies in an attempt to assure the information is delivered in a timely fashion without the delays occasionally caused by manual generation and oral telephone transmission.

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Following the September 30,1998, drill, the licensee verified that some of the j offsite agencies had received the fax transmission of the event declarations within ] 15 minutes even though they had not received the oral report within that time. The I licensee _ believes the delays in telephonic oral delivery were caused by unfamiliarity

with the new event notification delivery system. The licensee considers this

l problem to be worthy of correction action and intends to supplement the training of ~ j emergency response personnel in order to overcome this problem.

l l ' Despite this discrepancy, all activities in the ECC were well-performed. Plant

conditions and transients were accurately and quickly recognized and diagnosed.

' Both event declarations were accurate and reasonably timely. ECC management i showed appropriate concern for protection of onsite personnel during the " l progression of the drill. Communications within the ECC were accurate, concise, i and followed management expectations. Dose assessment activities in the ECC j were orderly and gave reliable results for the scenario expectations.

i

The inspector observed activities in the TSC only to a limited extent at the end of ' the scenario. Performance in the TSC, as observed, was effective.

- r . Activities in the EOF were very well performed. The inspector noted that the . radiological assessment staff generally provided accurate dose projections for the ,

scenario parameters. The Emergency Support Director (ESD),in charge of overall EOF response, exhibited superior command and control of the facility. A conference , of the ESD staff was characterized by good information flow, free expression of [ -

!

. -we 4r -, -,,- - -

-

opinions, and solicitation of input from all available sources, including offsite agency representatives. Interaction with the offsite agency representatives was very good; much improved over the March 1997 exercise performance.

The critique, conducted on October 2,1998, was characterized by candid evaluations and preliminary analysis of causes of unfavorable performance. The debrief conducted immediately following the drill at the EOF was also characterized by an organized approach to honest evaluation of performance by the responders.

There was good feedback between drill participants and observers at this debrief.

c.

Conclusions The overall performance in the September 30,1998, drill demonstrated the onsite emergency plan was adequate and that the licensee was capable of effectively implementing it. One exercise weakness was noted due to the failure to complete offsite notifications within the15 minute time requirement for both the Alert and Site Area Emergency declarations. The critiques, conducted immediately following the drill and in a formal presentation on October 2,1998, were candid, organized, and an accurate appraisal of drill performance.

P8 Miscellaneous Emergency Preparedness issues (92904) ' P8.1 (Closed) Escalated Enforcement item 97-127/04013: Failure to Recoanize and Classify a General Emeraency This item was opened based on performance in the March 5,1997, biennial exercise. Programmatic corrective actions and a successful remedial exercise were inspected and documented in IR 97-04. These actions and the inspection occurred prior to issue of this escalated enforcement item. Performance in the September 30,1998, drill did not indicate a recurrence of the weakness; therefore, this item is being administratively closed.

P8.2 (Closed) Escalated Enforcement item 97-127/04023: Failure to Assess the Need for a PAR Beyond the 10 Mile EPZ This item was also opened based on performance in the March 5,1997 biennial exercise. Programmatic corrective actions and a successful remedial exercise were inspected and documented in inspection report 50-289/97-04. These actions and the inspection occurred prior to issue of this escalated enforcement item.

Performance in the September 30,1998, drill did not indicate a recurrence of the weakness; therefore, this item is being administratively closed.

P8.3 (Closed) Violation 50-289/97-04-01: Lack of Comouter Code Documentation and Procedures for Dose Assessment j Corrective actions for this item were discussed in IR 97-08. The remaining corrective actions as discussed in that inspection report included the development of a user's manual for the computer-generated dose assessment models, the

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_ _. _ _ -._.._._._ _. _ _ _ __. i !

documentation of the manual radiological assessment code and completion of ' training in the user's guides and updated codes. These items were completed in , March,1998; therefore, this item is closed.

! !

P8.4 (Closed) Insoector Followuo item 50-289/97-04-02: Additional Guidance Needed for Once Throuah Steam Generator Leakrate Calculation Tool , ! This item also was reviewed in IR 97-08 and corrective actions taken to the date of

that report are described therein. The remaining action to be completed was

training fo' the radiological assessment personnel in the vanous emergency

response positions. This training was completed and its results documented. This ' item is therefore closed.

P8.5 (Closed) Inspector Followuo item 50-289/97-08-02: Review of lmolementation of l Emeraency Preoaredness Self-assessment Proaram i ! The EP staff had implemented the site-wide self-assessment procedure and had f completed a benchmarking effort against two other utilities. A schedule of self-i assessments was developed for the current calendar year. The inspector verified i the incorporation of scveral of the findings of the self-assessment effort into the various EPIPs. The program was being effectively implemented, so that this item is , closed.

l R1 Radiological Protection and Chemistry (RP&C) Controls (71750)

! R 1.1 Radioloaical Controls-External and Internal Exoosure ' I a.

insoection Scooe (83750)

The inspector evaluated the effectiveness of selected aspects of the applied i radiological controls program. The evaluation included a selective review of the

adequacy and implementation of the following radiological controls program l elements.

l Access Controls to Radiologically Controlled Areas (RCA) l - Use and Adequacy of Personnel Occupational Exposure Monitoring Devices - Maintenance of Personnel Occupational Radiation Exposures (External and - internal) Within Applicable Regulatory Limits and As Low As Reasonably Achievable (ALARA)

' Implementation of the Radiation Work Permit (RWP) Program including the - Effectiveness of Work Planning Operation and Maintenance of a National Voluntary Laboratory Accreditation ! - Program (NVLAP)-accredited Personnel Dosimetry Program

Operation and Maintenance of a Whole-body-counting Program ' - The inspector evaluated GPUN's performance in the above selected areas via observation of activities, tours of the RCA, discussions with cognizant personnel, ) > t

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. review of historical documentation, and review and evaluation of applicable station procedures.

b.

Observations and Findinas GPUN implemented effective access controls to the RCA including use of RWPs, bar code readers, and computerized log-in activated by a personal electronic dosimeter.

No access control deficiencies were identified.

Appropriate personnel monitoring devices for access to the RCA were supplied and used. Thermoluminescent dosimeters (TLDs) and personnel alarming dosimeters were observed to be properly worn to measure external dose. Access controls for high radiation areas (HRAs) were effective, and radiological postings and labels throughout the areas toured provided additional administrative controls and information to the worker. Radiological surveys were also available in-plant.

GPUN maintained personnel occupational radiation exposures (external and internal) within applicable regulatory limits and ALARA. A review of historical personnel exposure data for 1998 (as of mid-October 1998), identified that individual exposure results for total effective dose equivalent (TEDE), lens of the eye dose equivalent (LDE), and shallow-dose equivalent (SDE) were well below regulatory requirements. Further, the maximum individual committed effective dose equivalent (CEDE) for any one individual was well within applicable limits. The occupational exposure of declared pregnant women and the dose to the embryo / fetus were controlled in accordance with 10 CFR 20.1208.

A selective review of the planning and early implementation for RWP No. 157866, to be used for spent fuel pool diving operations (cable drive modification and miscellaneous underwater maintenance), found the permit and current work . preparations to be detailed and extensive.

GPUN operated and maintained a NVLAP-accredited personnel dosimetry program which used TLDs. The program was well organized and implemented by ) knowledgeable, experienced, and dedicated personnel. Proper system performance j was demonstrated, in part, by the use and trending of daily quality control measures and by semi-annualindependent quality assurance testing.

.

GPUN operated and maintained two whole-body counters, one for screening and j one for investigations. Both whole-body counters were currently calibrated for ' ' energy and efficiency in accordance with procedures. Daily, weekly, and monthly quality control checks were performed and documented to verify acceptable operational status of the two counters.

c.

Conclusions GPUN implemented effective applied radiological controls at Unit 1. Access i controls to the RCA were effective. Appropriate occupational exposure monitoring ) devices were provided and used. Personnel occupational exposure was maintained -. -_.

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! within applicable regulatory limits and ALARA. The RWP program was properly

implemented for control of radiological work.

R1.2 Radioloaical Controls-Radioactive Materials. Contamination. Survevs. and Monitorina ' a.

Inspection Scope (83750-01.)

, , The inspector evaluated the effectiveness of the surveys, monitoring and control of radioactive materials and contamination. The evaluation included a selective review ! of the adequacy and effectiveness of the following radioactive material and

contamination control program elements: r Surveys and Monitoring of Radioactive Material and Contamination - j the Calibration Status of Survey and Monitoring Equipment . - the Proper Use of Personal Contamination Monitors and Friskers - the Adequacy of Surveys During Work That involved Changing Exposure i - Conditions ,

the Tracking of Personnel Contamination Events and Goals, - ' . The inspector evaluated performance in the above selected areas via observation of , activities, tours of the RCA, discussions with cognizant personnel, review of historical documentation, and review and evaluation of applicable station i procedures.

' b.

Observations and Findinas - GPUN implemented a generally effective radioactive material and contamination ! control program. Personnel contamination monitors (friskers) and radiation survey ! meters exhibited current calibration stickers and were appropriately used by i' personnel exiting areas (e.g., whole body contamination monitors at the RCA exit).

Health physics (HP) technicians conducted routine periodic area surveys for i radiation and contamination and airborne radioactivity surveys in a capable and j effective manner. Survey records contained appropriate radiological information.

Radiological housekeeping conditions in the auxiliary, fuel handling, and turbine buildings were generally good. Radioactive material and radioactive waste were clearly labeled, segregated, and stored in an orderly manner.

! Goals to assist in monitoring and tracking the effectiveness of personnel and area contaminations continued to be maintained and used to gauge the overall effectiveness of the station's programs.

During a review of calibration procedures and records, Procedure 6610-PMi-4221.01," Calibration of Ludlum Portable Scaler Model 2000," was examined. This scaler in conjunction with a Geiger-Mueller (GM) pancake detector was the current - equipment configuration in use in the HP counting facility for making gross beta measurements. The procedure addressed checks for discriminator setting, high voltage setting, timer and multiplier positions, background counts, and source

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l , National institute for Standards and Technology (NIST)-traceable counts. An initial calibration involved 10 source counts and a Chi-Square test. A periodic calibration (every six months) involved a verification that the current first source count fell within +/- two sigma of the average of the 10 counts obtained at the previous i calibration. If the count fell within + /- two sigma, nine further counts were ! performed. A Chi-Square test was also performed. The average count and the +/- two sigma values were recorded.

l However, the procedure did not address the comparison of the decay-corrected disintegration rate of the standard source with the observed count rate of the standard source and the determination of counting efficiency (counts per disintegration) for initial or periodic calibrations. Thus, the calibration procedure did not provide a process for directly demonstrating calibration and instrument efficiency, but rather effected a method to demonstrate quality control and verification of proper instrument functioning. Additionally, the procedure required that a current periodic calibration compare the current source count to the previous periodic source count, not to the original source count. This resulted in a current source count being compared to a indefinite standard.

l Technical Specification 6.11, Radiation Protection Program, requires that procedures for personnel radiation protection shall be prepared consistent with the requirements of 10 CFR 20 and shall be approved, maintained, and adhered to for all operations involving personnel radiation exposure.

10 CFR 20.1501 requires that instruments and equipment used for quantitative radiation measurements are calibrated periodically for the radiation measured.

Upon identification of this observation by the NRC on October 29,1998, GPUN's Manager of Radiological Engineering assessed the condition and took actions to i revise the procedure, prior to next use, to include a more direct demonstration that the instrument was effectively calibrated. Additionally, GPUN reviewed the calibration data for all the Ludlum 2OOO/GM pancake detector combinations currently in use. Calculations of current counting efficiency were made for each.

Each of these currently-calculated counting efficiencies fell within +/- 10 percent of the calculated average counting efficiency, demonstrating that the affected instruments were effectively producing accurate results. GPUN determined that the currently-calculated average counting efficiency (+ /- 10 percent) justified the default counting efficiency which had been used based on a previously documented technical study by GPUN. The documented default value was determined to conservatively estimate any measured activity based on the isotupic mix determined in the plant. Additionally, GPUN initiated actions to review and revise, as necessary, the calibration procedure for other radiological monitoring instruments.

While GPUN's instrument Procedure 6610-PMI-4221.01 did not clearly demonstrate a process that directly verified and validated instrument efficiency, subsequent confirmatory evaluation demonstrated that the instruments were producing accurate and acceptable measurements of radioactivity. Accordingly, this deficiency

constitutes a violation of minor significance and is not subject to formal enforcement action in accordance with Section IV of the NRC Enforcement Policy.

c.

Conclusions GPUN implemented overall effective surveys, monitoring, and control of radioactive materials and contamination. HP technicians performed proper surveys, and properly documented survey results. Radiological housekeeping conditions were generally good. Personnel and area contamination rates were tracked and trended.

In general, radiological surveys, monitoring, and controls were implemented with calibrated and properly used devices.

R1.3 Radioloaical Controls-As Low As Reasonably Achievable a.

inspection Scop _e (83750) The inspector evaluated the effectiveness of the licensee's program to maintain occupational radiation exposure ALARA. The evaluation included a selective review of the adequacy and effectiveness of the following ALARA program elements: the monthly Station HP Awareness Committee meeting minutes - the monthly HP status reports (Monthly Highlights) - the pre-job ALARA review and pre-job meeting for RWP No. 157866 - The inspector evaluated GPUN's performance in the above selected areas via observation of activities, tours of the RCA, discussions with cognizant personnel, review of historical documentation, and review and evaluation of applicable station procedures.

b.

Observations and Findinas GPUN implemented an overall effective program to maintain occupation exposure ALARA. The Station HP Awareness Committee meetings provided a mechanism for review and coordination of ALARA issues by representatives from the different station organizations. This group was supplemented by an ALARA Working Group and a Radwaste Reduction Working Group.

The pre-job ALARA review for RWP No. 157866 (spent fuel pool diving evolution) was detailed and thorough, and the pre-job briefing meeting for this RWP was well-conducted with roles and responsibilities clearly established. The briefing agenda included detailed discussion of industrial safety and recent events, radiological safety, the ALARA review and radiological survey information, the station diving procedure, work sequencing, and equipment status.

Progress on annual goals for person-rem, maximum individual exposure, skin contaminations, and contaminated areas was tracked and reviewed on a periodic basis. Current actual data versus projected data showed good progress on these goal l

c.

Conclusions GPUN impl'mented an overall effective program to maintain occupational radiation exposure ALARA. The monthly Station HP Awareness Committee meetings provided coordination of ALARA efforts. The pre-job ALARA review and the pre-job briefing meeting for RWP No. 157866 (diving evolution in the spent fuel pool) were detailed and extensive.

R2.1 Imolementation of the Radioloaical Environmental Monitorina Proaram a.

Inspection Scope (84750) The following areas of the radiological environmental monitoring program (REMP) were assessed and reviewed: (1) selected sampling locations and stations; (2) selected REMP procedures; (3) 1998 environmental sample analytical results; (4) groundwater tritium monitoring; (5) Land Use Census results; and (6) 1997 Annual REMP report.

b.

Observations and Findinas Several environmental monitoring stations were examined. The air samplers, water compositors, and TLDs were placed at the locations designated in the Offsite Dose Calculation Manual (ODCM). The air sampling equipment and water compositors were operable from January 1997 to October 1998, as evidenced by the sample logs and sample analysis results. Milk and food products were collected from the locations specified in the ODCM.

The analytical results of the environmental samples were reviewed from January to October 1998. Analyses were performed by the licensee's Environmental l Radiological Laboratory with the exception of the environmental TLDs. The TLD's continue to be analyzed by site personnel. The data indicate that the environmental samples were collected and analyzed at the frequencies required in the ODCM. The licensee met the environmental lower limits of detection (LLD).

The licensee continues to monitor groundwater tritium concentrations from the onsite wells and compare the concentrations to tritium concentrations from the REMP water sampling locations. Analytical data from January-October 1998 indicated that tritium is detectable above background levels at the discharge i location and at the REMP sampling station J1-2 just downstream at the mixing zone l but not in any of the drinking water or other indicator REMP locations. These results are published in the annual environmental monitoring reports. The dose to the public was lower than regulatory requirements and in ODCM conformance.

j The annual Land Use Census was performed in 1997 and 1998, during the growing season, as required by the ODCM. A thorough land use survey, including a i resident, garden, and milk animal census and a collection of broadleaf vegetation I was performed. No significant changes were made to the REMP program as a result of the census.

l

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The 1997 Annual Radiological Environmental Monitoring Report included results of the environmental monitoring program, program changes, land use census, and interlaboratory comparison program, as required by TS. The reports provided a comprehensive summary of the results of the REMP around the site and met TS reporting requirements.

c.

Conclusion Overall, the licensee effectively maintained and implemented a REMP in accordance with regulatory requirements. Groundwater tritium monitoring was comprehensive and effective.

R2.2 Meteoroloaical Monitorina Proaram a.

Inspection Scope 184750) The following areas of the Meteorological Monitoring Program (MMP) were assessed ) and reviewed: (1) calibration procedures and methodology; (2) calibration results; (3) site operations logs and action reports; (4) functional checks; and (5) j maintenance records, b.

Observations and Findinas ! The Instrument and Controls (l&C) Special Projects group is responsible for performing maintenance and annual calibrations. Execution of functional checks, maintenance, and calibrations was performed according to the procedure. The calibration results were within the acceptance criteria. The meteorological instrumentation on the tower and the readout devices located in the control room, TSC, and equipment room at the base of the tower were operable.

A review was conducted of the calibration methodology of the meteorological instrumentation. The inspector observed certain aspects of the calibration process.

j The licensee performs electronic alignments for the wind speed, wind direction, and

l temperature sensors and performs a single point channel calibration of the wind direction and temperature channels to verify the accuracy of the system, with the exception of the wind speed sensor. The licensee immediately performed a single point check of the sensors and verified that the wind sensor compared well with a calibrated anemometer. The licensee included a step in the procedure to perform this calibration check. The licensee demonstrated good performance in this area and the methodology was determined to be appropriate.

! c.

Conclusion The licensee effectively maintained and implemented a meteorological monitoring ' i program in accordance with regulatory requirements. The licensee's performance regarding the calibration methodology was effective.

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, R6 Radiological Protection and Chemistry Organization and Administration f A review was conducted of the organization and the responsibilities relative to '

oversight of the REMP and MMP. Environmental Affairs continues to have the ' responsibility to implement the REMP and l&C continues to have responsibility for

calibration and maintenance of the meteorological monitoring equipment.

Environmental Affairs was moved from the corporate office to the site as of January 1998. There were no changes in the oversight of the REMP and MMP.

, R7 Quality Assurance in Radiological Protection and Chemistry Activities !

: .

. ' a.

Inspection Scope (83750) . The inspector evaluated the effectiveness of the self-identification and corrective - - action processes. The evaluation included a selective review of the adequacy and effectiveness of the following program elements and documents: i Corporate Audit by Nuclear Safety Assessment (NSA) - , - Corporate Monitoring Reports i ' ' Independent Assessment - NVLAP Audit - Self-assessments - ' CAP Entries l - The inspector evaluated GPUN's performance in the above area via observation of < activities, tours of the RCA, discussions with cognizant personnel, review of applicable documentation, and review and evaluation of applicable station procedures.

b.

Observations and Findinas GPUN implemented an overall effective self-identification and corrective action program in the area of radiologica: controls. The scope and depth of Radiological Control Audit S-TMI-98-09 was extensive and reviewed the program for strengths and weaknesses. The audit found that the Radiological Controls program was implemented satisfactorily and identified two deficiencies which met the threshold j for entry into the corrective action program. Several NSA monitoring reports were examined which addressed radiological controls during plant tours and during a reactor building entry. The monitoring activities were well planned and detailed findings were documented. Several minor deficiencies were identified which did not meet the threshold for entry into the corrective action program. These deficiencies were either corrected on the spot or referred to appropriate supervision for immediate corrective action. An independent assessment of the radiation protection program content and implementation included outside consultants. This assessment concluded that the program met federal requirements and industry standards, and

strengths and recommendations for improvement were identified. The NVLAP audit j found that the personnel TLD processing program was satisfactorily maintained and implemented. Prompt corrective action was taken for the two identified minor i

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deficiencies. Self-assessments by the Radiological Controls organization addressed control of radioactive material, review of 1997 contamination events, respirator fit testing, minimization of mixed waste, TLD processing, RCA exit monitoring, and radiological surveys. Overall, the self-assessments evidenced effective efforts to identify procedural compliance, strengths, and weaknesses. Strengths, " recommendations, minor deficiencies, and five CAP items were documented.

c.

Conclusions , , i GPUN's self-identification and corrective action processes in the area of radiation

protection were effective. NSA audits, monitoring reports, corporate assessments, and se!f-assessments continued to be effective in identifying, at a low threshold, deficiencies and improvement opportunities. Corrective actions were implemented for findings.

. R7.1 Quality Assurance Audit Proaram '

a.

Inspection Scoce (84750) , ! j The licensee's audit of the REMP and MMP was evaluated through a review of ' (1) the quality assurance audit report, and (2) the self-assessments.

b.

Observations and Cor.clusions

1 The audits and self-assessments were detailed in scope and effectively assessed the REMP and MMP. Performance of the audit and self-assessments was good, in that l

specific REMP and MMP activities were directly observed and timely feedback j regarding performance of the activity was provided. The audits provided an effective assessment of the programs.

c.

Conclusion

The audits and self assessments were of sufficient depth to assess the implementation of the REMP and MMP.

f R7.2 Quality Assurance of Analvtical Measurements

a.

Insoection Scoce (84750)

The following aspects of the Quality Assurance (QA)/ Quality Control (OC) program of the contract laboratory, Environmental Radiological Laboratory (ERL), for the ' period of August 1997 to October 1998 were reviewed: (1) the results of the internal QC program, including efficiency and resolution checks, daily instrument energy checks, control charts of instrument performance, and routine calibrations; and (2) the results of the QA program, including the Interlaboratory Comparison , (cross-check) Program.

, ! -

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b.

Observations and Findinas < . The QA/QC program for analyses of REMP samples is conducted by the GPUN ERL.

The ERL has interlaboratory and intralaboratory OC programs. The QC program ) consisted of measurements of blind duplicate, spike, and split samples. The laboratory continued to participate in the Environmental Protection Agency Cross-

l

Check Program and the Interlaboratory Comparison Program provided by a vendor ' laboratory (Analytics, Inc.). The ERL published a Quality Assurance report semi-annually. Comparisons of QC data listed in the semi-annual Quality Assurance , reports were within the ERL's acceptance criteria.

The QA officer at the laboratory conducted independent audits of laboratory l operations. Program self-assessments were performed by the laboratory manager.

The audits and assessments were methodical and provided insight for improvement where needed.

! c.

Conclusion

i The environmentallaboratory continued to implement effective QA/QC programs for j the REMP samples, and continued to provide effective validation of analytical results. The programs are capable of ensuring independent checks on the precision and accuracy of the measurements of radioactive materials in environmental sample media.

, i

V. Manaaement Meetinas X1 Exit Meeting Summary

i The inspector presented the inspection results to members of the licensee - management at the conclusion of the inspection on November 12,1998. The j licensee acknowledged the findings presented, i X2 Engineering Management Meeting

! On October 23,1998, GPUN engineering management met with NRC Region l management in the Region I office to discuss the progress in improving engineering performance. A copy of the GPUN handout from that meeting is Attachment 2 to ' this report.

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i INSPECTION PROCEDURES USED IP61726 Surveillance Observation IP62707 Maintenance Observation I IP71707 Plant Operations ' IP71750 Plant Support l IP82301 Evaluation of Exercises for Power Reactors IP82701 ' Operational Status of the Emergency Preparedness Program l lP83750 Occupational Radiation Exposure -, IP84750 Radioactive Waste Treatment, and Effluent and Environmental Monitoring j ' IP92903 Followup - Engineering IP92904 Followup - Plant Support i .

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23 ITEMS OPENED, CLOSED A.ND DISCUSSED Opened:

, " 98-07-01 IFl Exercise Weakness - Failure to notify offsite agencies within ' 15 minutes.

Qlosed: ' 95-13-01 URI Once Through Steam Generator Inservice Inspection Activities 95-238/01013 eel Failure to Adequately control a Modification to Reactor Coolant System Drain Piping 95-238/02014 eel Failure to Perform an Evaluation to Demonstrate the Adequacy of Reactor Coolant System Drain Piping Supports 96-08-02 IFl Leak Testing of Pressure Isolation Valves 97-001-00 LER Potential Over-pressurization of isolated Piping Following an Accident 97-04-01 VIO Lack of Computer Code Documentation and Procedures for , Dose Assessment - 97-04-02 IFl Additional Guidance Necessary for Once Through Steam Generator Leakrate Calculation Tool 97-07-01 URI Pressure Locking and Thermal Bindings of Safety-related Gated Valves , 97-08-02 IFl Review of implementation of Emergency Preparedness Self-

assessment Program j 97-10-01 VIO Failure to Review and Document Reactor Building Cooler

. Testing

97-10-03 URI Review of Reactor Building Cooler Configuration ' 97-127/04013 eel Failure to recognize and classify a General Emergency condition 97-127/04023 eel Failure to assess need for PAR beyond 10 mile EPZ Discussed: !

None ! ' t b > -

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LIST OF ACRONYMS USED ALARA As Low As Reasonably Achievable ASME American Society of Mechanical Engineers CAP Corrective Action Program CEDE Committed Effective Dose Equivalent EA Enforcement Action ECC Emergency Control Center EDG Emergency Diesel Generator eel Escalated Enforcement item EOF Emergency Operation Facility EP Emergency Preparedness EPIP Emergency Plan implementing Procedure EPZ Emergency Planning Zone ' ERL Environmental Radiological Laboratory ESD Emergency Support Director GL Generic Letter GM Geiger-Mueller GPUN GPU Nuclear, Inc.

GSI Generic Safety issue HP Health Physics HRA High Radiation Area I&C Instrument and Control ID inside Diameter IGA Inter-Granular Attack IPE Individual Plant Evaluation IR

Inspection Report

IST Inservice Test LDE Lens of the Eye Dose Equivalent , LER Licensee Event Report LLD Lower Limit of Detection LOCA Loss-of-Coolant Accident MMP Meteorological Monitoring Program

NIST National Institute for Standards and Technology i NOV Notice of Violation NRC Nuclear Regulatory Commission j NRR Office of Nuclear Reactor Regulation NS Nuclear Service Closed Cooling NSA Nuclear Safety Assessment NVLAP National Voluntary Laboratory Accreditation Program ODCM Offsite Dose Calculation Manual OTSG Once Through Steam Generator j QA Quality Assurance QC Quality Control RBEC Reactor Building Emergency Cooler RCA Radiologically Controlled Areas RCS Reactor Coolant System REMP Radiological Environmental Monitoring Program i

, .,

25 RP&C- Radiological Protection and Chemistry RWP Radiation Work Permit SDE' Shallow Dose Equivalent Si international System .SSCs Structures, Systems, and Components TEDE Total Effective Dose Equivalent .TIA . Task interface Agreernent TLD Thermoluminescent Dosimeter TMl Three Mile Island Unit 1 TS Technical Specification TSC Technical Support Center . , .

ATTACHMENT 1 Emergency Response Plan and Implementing Procedure Changes Reviewed DOCUMENT DOCUMENT TITLE REVISION NO(S). EPIP-TMI.02 Emergency Direction

EPIP-TMI.03 Emergency Notifications and CallOuts TCNs 97- 138,159 Revs. 23,24 EPIP-TMI.06 Additional Assistance and Notification

EPlP-TMI.07 Activation of the RAC

EPIP-TMl.10 Onsite/Offsite Radiological / Environmental Monitoring

EPIP-TMI.19 Emergency Dosimetry / Security Badge issuance

EPIP-TMI.27 Emergency Operations Facility

EPIP-TMI.28 Activation of the Technical Support Center

EPIP-TMI.29 OSC Operations

' EPIP-TMI.36 Emergency Assembly and Site Evacuation 9,10 TEP-ADM- Maintaining Emergency Preparedness

1300.01 TEP-ADM- Emergency Preparedness Training

' 1300.02 TEP-ADM- Administration of the TMI initial Response and Emergency TCN 98- 1300.04 Support Organization Duty Roster

Rev.3 TEP-ADM- Emergency Equipment Readiness

1300.05 6610-PLN- Emergency Dose Calculation Manual TCNs 98- 4200.02 13,30,

Revs. 7,8

.

27 l ATTACHMENT 2 GPUN Handout from October 23,1998 Engineering Meeting in NRC Region l l

! l l ! . i ,

. . I'[, hik-hkk .h b ' ' ' N? h $ ' - [ ' k . ss ,, h ' ' V Q y.i .yd-h 3; Update on GPU'50$ieai'~ ~~" - improvement Initiatives in . . . . Response to ECAPAT October 23,1998

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. . . i ! ! I r i L ! A e n d,a,__MWi!%_!h&%3fikJss_ 9- m _ ,_ _ . _ .. 9" D @fy* I

.. RW4eeMWW*

- I .

I ! Findings and issues . t

b Actions Underway j . ! - Corrective Action Process (CAP) - Culture

1 - Process !mprovements - Work Management Systems . Results I f ' ! I I

i i ! l

l

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_. _- - _ - ' . . ! i Findings / ssues

~ __, gym,, %,,,,, . F ! !

i Significant long standing weaknesses identified during l ' ECAPAT review of Corrective Action System Effectiveness ,

- . Issues identified but not corrected .

. Escalation Process ineffective j i . Multiple corrective action systems l . Misinterpretations of performance based QA . Culture resistant to critical oversight ! l ., . i

( .. . _ .. . ...~.......... .. i -

_ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ [ - - i Findings / issues J fcont'dl ! ~, _,_ gggggy gg - . _;. ~ , ' Significant long standing weaknesses identified in Engineering processes.during 1996 and 1997 inspections . . Quality Classification of Components (QCL) . Calculation Control { . Setpoint Control j = FSAR/ Design Basis Conformance Inservice Test Program (IST) i . . Motoe Operated Valves (MOV) internal reviews identified the potential for similar problems in other programt j Equipment Qualification Program (EQ) l . Fuse and Electrical Load Control . . OTSG Program Management * Core Design Control * { .

performance pro'olems not observed in these processes

{

l

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_ . . Findings / Issues fcont'd'l ,, 2. ggggggg . ._ =,m, Root Causes . Fragmented Process Ownership (no-one clearly accountable;l . Inadequate resources applied . Management expectations not clearly established and communicated . Management oversight and involvement insufficient to know problems existed . Unresponsive to critical oversight . Overly defensive

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

. , Actions U nde, rwa _ua,,f}Q,_vstmcm.+nq7 < _ w gu em nwa=a-,;pem,iryun4M4 be;ujQ;g . ... m ?v: g;;ga pgy m pa i L

. i i

Corrective Action Process (CAP) i ! . Established single, low threshold system . . Management review of CAPS j . Improved escalation process j . Graded approach to root cause analysis i . Trending and tracking capabilities . Expectations for use established and reinforced

-.. .. -.. . - -.. .-.- . ---.--- . .. ... . -. -. .. - - - . -

_ _ _ _ _ l

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. Expectations established on use of CAP for resolving ' issues

. Expectations established and communicated on l Procedure Compliance to Engineering I EP-100;l . Expectations established on Leadership, Organizational, and Technical Excellence i . Conflict resolution workshops held for Engineering and i NSA personnel = Engineering management more informed of issues j through Engineering review meetings j . Self Assessment process well established I; vertical shce j assessment methodology under development;l . Promote open dialogue with NRC, GORB, and other

assessors i l \\

i ! i

_ _ _ _ _. _, i f i i t Actions Underway ' - ._ J; cont'd;y %,,,m,5%:m,a;na,:w. _ em m w; me -,

,. m . ! Process improvements Process owners assigned for Key Engineering Processes . Established process improvement methodology l . ! Review Change Train Assess l , , , Process Procedures Users Effectiveness { a

. QCL process mapped, procedures revised, personnel retrained, components reclassified, staffing augmented. Status: completed . Calculation control process mapped, procedures revised, j personnel retrained, calculation database developed. Status: ' target 5/99 l . Setpoint control process mapped, procedures revised, personnel l retrained, setpoint upgrades in progress. Status: target 2/99 l MOV program /IST program upgrades. Status: completed l . !

l I ! , f - . . - . . - --- -. - - - -- - - . - - - - - - - - - - - - - _

_ _ - _ _ _ -

Actions Underway Jc.ont g g p gy yg, g z ,, ( Process improvements (cont'd) l ' = Electrical load and fuse control process mapped, ' procedures revised. Status: completed . FSAR upgrades in progress. TMI focused on Chapter 14 (accidents and transients); OC focused on Safety Systems, HVAC, Decommissioning support systems. Status: target TMI 3/99, OC 6/99 . EQ Self Assessment. Status: In Progress (OC issue) . Core design procedures (SOER 96-01). Status: Completed . OTSG Program Plan development . Lessons learned applied to Maintenance Rule implementation l i ! ! - - . .. .- - . .

. . . - - O h j Actions Underway (cont'd)

ggggg _ ,,,_ , Work Management System . Engineering Task Tracking System (ETTS) implemented in

first quarter 1998. ' . Work prioritization system implemented in May 1998. ! . Engineering Measures implemented in March 1998

' (staffing, productivity, culture). t > . ETTS viewed as an asset by most engineers and j managers. !

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l ! ! i . . - - - - a -a m----+- - ' - -

- _ _ _ _.. _ _ _ _ _. _ _ _ _ _ _.. _ . i , Results econtd>_my , ggy_ ,.

- . - .. . , I i CAP Broad based acceptance of new process . Increased use of CAPS . implementation effectiveness included as part of every = NSA audit NSA audit of CAP in Nov.,10SRG assessment of CAP in . " I Dec. Culture ' t NSA more challenging

. increased receptivity to critical oversight by Engmeermg t e Self Identification of improvement opportunities through

. self assessment program ! ECAPAT type assessment performed of O&M (OMPAT) l . concluded that resistance to critical oversight was not l present l

i

l - - . .

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

. . i &

Results, ec_ont d, . ggggy .- - . _, _ i Process Improvements

Process improvements implemented for all major j e processes j Self assessments performed on EQ, QCL, and. Calculation l . Control Processes. - Major programmatic weaknesses fixed. Details of implementation still a concern (e.g., using wrong revision of procedures, missing

signatures, page numbering, etc). l - Current self assessment methodologies weak on vertical slice ! assessments (EQ self assessment failed to uncover a major weakness at OC). j . Additional Self assessments planned for EQ,Setpoint, Electrical Load Control, and Calculation Control Programs. l t . Engineering Work Management System (ETTS) yielding improved timeliness in engineering deliverables

l !

' - - -. -. - - - . - - - - -. - - - - - - -. . - - -

__-_____ ____________ . . !

- Ot.h e,r E n h a n_ce,,m,,,e,,n,N4$YS[[4,3he t,s , ~ - - _, _. ., .. - . thhhhhhbikipi@dA$@Mdf nAS* k >I@h. kh f$fhhb hN [ ' c;;; i f f ! Continual Safety Assessment Process . NSA process that facilitates the timely identification and focus on " key safety" and regulatory issues Nuclear Safety Oversight Committee i . Appointed by GPUN president - Independently assesses j the long term effectiveness of the nuclear safety oversight j process throughout GPUN ! I General Office Review Board j . Improvement plan implemented to improve its . , effectiveness l

! l

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! I Engineering processes have been remediated and . processes improved j . i Cultural changes implemented to sustain the . improvements made i , ' , ,

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. . . Culture and Values No. Recommendation i 1 Actions ; Status (See Legend Below)

Establish and communicate management 1. Communicate expectations to all Engincenng disision personnel CA&EVC expectations regarding accountability to comply 2. Issue " Conduct of Engineering" procedure CA&EVC with procedures 3. Revise GET training to incorporate management expectations regarding procedure compliance and include in 1997 ESP training. CA&EVC 4. Perform NSA mrrsight to determine level of understanding of procedure compliance requirements CA&EVC

Clarify expectations on resolving and escalating 1. Interim guidance issued by the President, GPU Nuclear and the VP, CA&EVC quality deficiencies Engineering 2. A 100% rcsiew of all outstanding QDRs and significant DVRs has been CA&EVC completed to ensure that all have been properly escalated. 3. Explicitly incorporate escalation into the CAP system and the DVR system CA&EVC ~ 7 Re-visit and clarify " Teamwork and Leadership" 1. Conduct team-building workshops with NSA and Engineering. CA&EVP training in regards to the potential misinterpretation or misapplication of principles. 2. Review Ops and Maint. at both TMI and OC to determine if similar problems CA&EVC exist in O&M and to what extent. E Emphasize management's responsibilitics and I. Establish and communicate expectations /responsibilitics CA&EVC expectations for conflict resolution 2. Conduct focus groups / workshops. NSA to pilot effort. CA&EVC 3. Implement conflict resolution workshops CA&EVP 4. Questions specific to the level of acceptance of NSA guidance currently CAVP present within the organization will be added to and upcoming " Safety Culture Suncy." A followup survey will be administered during 1999. At that time, the need for future survcvs will be assessed.

Clarify perfonnance-based Quality Assurance 1. Clarify the working definition of performance-based QA CA&EVC l 2. Communicate the working definition of performance-based QA CA&EVC

Establish expectations on the fonn, content, use. Implement specific near-term improvements in the CAP /DVR systems CA&EVC review / approvals, ownership and oversight of corrective action systems Legend , CA&EVC: Corrective Action & Effectiveness Verification Completed or not applicable to TMI CA&EVP: Corrective Action completed & Effectiveness Verification Pending CAVP: Corrective Action Verification Pending, effectiveness to be completed at that time i

I . . . . . .. __ - . . -- . -

. Management Systems No. Recommendation. Actions Status (See Legend on Page 1) Engineering

Map the Quality Classification For items, a comprehensive process map for the old process and recommended new CA&EVP Process process has been developed. For Activities, a detailed review was conducted of QA Plan activitics associated with items and it was determined that they are adequately addressed by current procedures with some corrective actions recommended.

Revise EP-0l I for the Rev. 5 of EP-011 issued classification of equipment. Further revision of EP-011 in progress CA&EVC Develop a new procedure for the A new procedure is not required for activities. classification of activities.

Develop a Temporary Change TAP-001, Rev. 8, approved 9/25/97, describes new Engineering Division Temporary CA&EVP Process for Engineering Change (TCN) process. Procedures

Develop basis for confidence in De sampling program has been completed for both TMI and Oyster Creek. The CA&EVC the original Quality Classification results are documented in TDR -1225. He conclusion is that while errors in the QCL Process data base were found,the sampling provided high confidence that the original classification process was sound

Develop indicators and trend it was determined that the best approach is to perform an annual self assessment of CA&EVP performance for the QCL process 'he QCL Process using standard guidelines. OC and TMI Configuration Maintenance has entered a task in ETFS to schedule the next self assessment. 05crsight

Improve GORB activities Develop GORB process improvements activities. CAVP Implement process improvement activities

Improve planning for and response Our plan is to continue to Audit one of the sites (OC or TMI) each year along with CA&EVC to CMAP audits corporate. We believe that we get better focus, breath and depth from the audit team with this approach.

Better integrate the activities of the We have decided to control all internal audits from the sites and not out of corporate. CA&EVP TMI, OC and Corporate NSA We will use some of the corporate vendor audit personnel to support and possibly lead groups some internal audits but as stated above, the audit will be based out of the sites. We have decided to use interdisciplinarv audit teams on at least some selected audits.

Implement a common, high The new company wide corrective action procedure and it will be implemented on CA&EVC volume. Iow threshold corrective April 1,1998. action system

Impose a time requirement for the De Nuclear Safety Assessment Audit Program, has been revised to reflect a target CA&EVP completion ofISRs of audit reports date of 60 days aller Audit Report issuance to perform a safety review.

- - - - .

-- -- , .. Job Skills / Organization

No.

1. Recommendation ? A

Actions)

) Status (See Legend

- . .:: on'Page '1) - Engineering

Staff the QCL process with proper 1. Interim action has been taken to ensure adequate stafTfor CA&EVC number of qualified people based on the current work load. QCL process map 2. Process mapping and draft procedure revision complete. CA&EVC Stafling evaluation for the QCL process at TMI has been completed and the final recommendations for increased staff is incorporated with the Oyster Creek stafling conclusions, to be addressed through management channels.-

Conduct training on the overall QCL Training on EP-011 revision 6 was held for TMI Engineering CA&EVC process departments that will be involved in Quality Classification on 3/18,3/23 and 3/25. Those departments that are users of the QCL information were issued a training notice via lotus notes on the changes to the procedures and screens. Oversight ' -

Select a permanent NSA Director Selection made. Selection to be announced subsequent to NRC CA&EVC action on proposed OQA Plan change.

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

- - - - . -_ _- - - - _ -- - - - -- . .. -. - - - - . Information Systems ,

No.

~ _ Recommendation ;: - F Actions' States (See Legend Jon' Page 1)" ~ Engineering and Licensing

Compile the licensing basis requirements 1. FSARs for Oyster Creek and TMI have been put into' Lotus CA&EVC in an accessible database to support the Notes databases. QCL determinations 2. Information-Only copies of the Technical Specifications for CA&EVC both Oyster Creek and TMI have been put into Lotus Notes databases. 3. A database containing licensing basis documents for both OC CA&EVP

and TMI has been developed and placed into a Lotus Notes database. The database is called the "NS & L Home Page" and is located on Notes Server 4/GPU/Regulato.nsf. 4. Based on the current direction taken with respect to OC, the CAVP compilation of a regulatory correspondence database for all incoming and outgoing regulatory correspondence from 1984 to present has been determined to no longer be appropriate. The resources assigned to this efTort have been assigned other duties consistent with site management needs. The correspondence is still available for manual search. ,

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

_ - _ . _ - - - - - .. . Other Program Assessments . No.- 1 Recommendation. L Actions 1 - Status (See Legend- - on Page 1)'

Perform assessments on a priority basis of 5 1. Assess the efTectiveness of the changes made to the Corrective CA&EVC listed programs and processes Action Process : NSA performed Audit S-COM-98-01. Based on CAVP the initial implementation of the CAP program, NSA found that the CAP met all the requirements of 10CFR50, APP B. The CAP was generally being effectively implemented. 2. Setpoint Control: Self assessment CC-MO-97-12-E420 was issued CA&EVC on 12/16/97. 3. Safety Determination and Review: The assessments have been CA&EVC performed and reports have been issued which contain recommendations to address the identified weaknesses and to improve overall effectiveness of process implementation. 4. EQ Program: Self assessment ES-PA-97-006 was issued on CA&EVP .1/16/98. L 5. Emergency Planning Program: An assessment was made on the TMI CA&EVP Emergency Preparedness Program. Detailed results of assessment documented in CAP Corrective Action T1997-0568-57.

Assemble a complete list of existing 1. Two lists developed: 1) all of the Regulatory Mandated Programs CA&EVC regulatory mandated programs and screen for GPUN is committed to, and 2) a "small" version of the Engineering further assessment Division important Issues Listing 2. Screening of the existing regulatory mandated programs was CA&EVC reported in memo E430-98-006, dated 2/11/98. 3. G.R. Skillman and John Fornicola completed the review and CA&EVC identified six areas which warranted additional review-completed or CAVP tracked by CAP. f

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v t e Inspection Report - Crane - 1998007
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \| 25 \|
1998 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 7(0) 8(0) 9(0) 99(0) 9(0) Security Operator Exams 301(0) Emergency Planning Other

IR 05000289/1998007

Text

Inspection Report

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