ML20058B305

SALP Rept 50-289/89-99 for 890116-900515

ML20058B305
Person / Time
Site:	Crane
Issue date:	10/09/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058B281	List: ML20058B278 ML20058B305
References
50-289-89-99-01, 50-289-89-99-1, NUDOCS 9010300088
Download: ML20058B305 (37)

See also: IR 05000289/1989099

Text

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ENCLOSURE 1

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U. S. NUCLEAR REGULATORY COMMISSION

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REGION I

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SYSTEMATIC ASSESSMENT OF-LICENSEE PERFORMANCE

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FINAL REPORT

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REPORT 50-289/89-99

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GENERAL PUBLIC UTILITIES NVCLEAR CORPORATION

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'THREE MILE ISLAND, UNIT 1

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. ASSESSMENT PERIOD: January 16, 1989 - May 15, 1990

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BOARD MEETING _DATE:> July 10, 1990

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TABLE OF CONTENTS

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INTRODUCTION

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II . . SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . .

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II.A

Overview . . . . . . . . . . . . . . . . . . .

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II.B

Facility Performance Analysis Summary

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III. PERFORMANCE ANALYSIS', . . . . . . . . . . . . . . . . .

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III.A'

Plant Operations

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!!!.B

Radiological Controls

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III.C' Maintenance / Surveillance . . . . . . . . . . .

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-111.0 . Emergency Preparedness . . . . . . . . . . . .

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Security . . . . . . ... . . . . . . . . . . .

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III.F

Engineering / Technical Support

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III'G

Safety Assessment / Quality Verification . . . .

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. SUPPORTING DATA AND SUMMARIES

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A.1L Licensee Activities

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A.2.' Direct 1 Inspection and Review Activities:

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50/$-2

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Criteria . .~... ... . . . . . . . . . .:... . . . .-. .

50/5-2

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' Unplanned- Shutdowns, Plant Trips -and- Forced Outages

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' Enforcement. Activities-

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Inspection Hour' Summary . . . . ._, . . .:. . . ...

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'SD/S-5

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Licensed Event Report Causal Analysis =

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INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) is an integrated

NRC staff effort to collect the available observations and data on a

periodic basis and to evaluate licensee performance based upon this

information.

SALP is supplemental to normal regulatory processes used to

ensure compliance with NRC rules and regulations.

SALP is intended to be

sufficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful guidance to the licensee management

to promote quality and safety of plant operation.

An NRC SAlp Board, composed of the staff members listed below, met on

July 3D,1990, to review the collection of performance observations and data to

assess the licensee performance in accordance with the guidance in NRC

Manual' Chapter 0516, " Systematic Assessment of Licensee Performance." A

summary of the guidance and evaluation criteria is provided in Section B

in the Supporting Data of this report.

The Board's findings and

recommendations were forwarded to the NRC Regional Administrator for

approval and issuance.

This report is the NRC's assessment of the licersee's safety performance

at-the Three Mile Island Nuclear Station, Unit 1, for the period of

January 16, 1989, to May 15, 1990..

The SALP Board was composed of the following:

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Board Chairman

M. Hodges, Director, Division of Reactor Safety (DRS)

' Board Members

M. Knapp, Director, Division of Radiation Safety and Safeguards

(DRSS)

E. Wenringer, Chief, Projects Branch No. 4. Division of-Reactor Projects

.(DRP) -

J. Stolz, Director, Project Directorate I-4, Office of Nuclear

Reactor Regulation (NRR)

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W. Ruland, Chief, Reactor Projects Section.48, DRP

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R.: Hernan, Project Manager, NRR

F.- Young, Senior Resident Inspector, TMI, DRP

J. Ourr, Chief, Engineering Branch, DRS (part time)

W..Johnston, Deputy Director, DRS (part time)

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Other Attendees

J. Wiggins,' Deputy Director, DRP'

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M. Case, Operations Engineer, Performance & Quality Evaluation Branch,

NRR

P. Ray Operations Engineer, Performance & Quality Evaluation-Branch,

NRR

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P. Esc 1groth, Chief PWR Section, DRS

T. Moslak, Resident Inspector, TMI, DRP

D. Johnson, Resident Inspector TMI, DRP

D. Beaulieu, Resident Inspector, TMI, DRP

R. Skokowski, Summer Intern, DRS

D. Bessette, Acting Chief, Operational Programs Section, DRS

R. Bores, Chief, Effluents Radiation Protection Section, DRSS

"

R. Nimitz, Senior Radiation Specialist, DRSS

E. Fox, Senior Emergency preparedness Specialist, DRSS

C. Conklin, Senior Emergency Preparedness Specialist, ERC, DRSS

M. Channa1, DRS

H. Gregg, Senior Reactor Engineer, DRS/EB

II. SUMMARY OF RESULTS

. . .

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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

performance activities.

The operations staff was expanded to provide more

than adequate staffing and additional personnel to enhance outage control

activities.

The plant operations department continued to exhibit a professional, safe

approach to operating the plant at power and during a refueling outage.

Operators performed well on the licensed operator requalification 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.

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

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.several year effort.- Engineering support for the most recent outage was

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well coordinated and effective.

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In summary, the licensee continues to have policies and procedures in

place to effectively and safely operate and maintain the plant. Good

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 Areaj

Period

period

Trend

Plant Operations

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fladiological Controls

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Maintenance / Surveillance

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Emergency Preparedness

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Security-

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Engineering / Technical

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Support

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Safety Assessment /

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Quality Verification

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• From November 1, 1987 to January 15, 1989

"From January 16, 1989 to May 15, 1990

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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%)

'1.

Analysis

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The previous SALP rating in this area was Category-1.

Significant

. strengths 11dentified 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 licensee has continued to operate the.

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plant in a safe manner and has achieved an excellent operating

record.

The number of control room operators exceeded technical

specif.ication plant staffing requirements,

No plant trips during

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oower operation occurred due to operator error.

Operator vigilance

during steady-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

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operations, a professional decorum was maintained in the control room

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and distractions to the operators were kept to a minimum.

Shift

supervisors effectively 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 senio- reactor

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operator (SRO) to perform complex surveillance testing wh'en f power.

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The use of a knowledgeable team to perform complicated surveillances

was particularly effective in reducing the burden on the normal shift.

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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 electrohydraulic control system.

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the BR refueling outage, a licensed operator caused a second reactor

trip during zero power physics testing. With the trip point reduced

to 0.5*. power during startup, the reactor operator moved control rods

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without closely monitoring power. The ensuing power increase caused

the scram, These events were of minor safety significance and did not

indicate any adverse performance trend.

Site senior management's involvement in plant operations was readily

evident.

Such involvement was apparent by the routine presence of

senior managers in the plant at daily planning meetings. Management

encouraged workers, at all levals, to identify equipment or procedur-

al problems or potential problems that could affect plant safety.

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' Performance standards were effectively set for all staff. Procedures

required management to review logs and notifications. Management

backshift tours and incident response were also formalized. Opera-

tions Management urged establishment of a task force to evaluate

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plant upsets caused by aging components in the integrated control

system (ICS),

Several hardware improvements have been made to the

system as a result of this task' force.

In the long term, TM1 is

planning installation of an Advanced Control System.

Management's

resolution of the few operational problems has been almost always

conservative and timely.

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Licensee management incorporated lessons: learned from past outages to

improve coordination-activities for the 8R refueling outage.

Included

in these initiatives were detailed integrated work schedules using a

computerized work. control system; tracking plant equipment configura-

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tions that affect operations by plant conditions; adding shift outage

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advisor positions and instituting-a Shift Supervisor's Coordination

Action List.

These changes were effective in completing outage

related activities safely and minimizing communication problems

between the various working groups. This corrected a problem found

during the last assessment period.

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The licensee improved procedure adherence.

Safety systems were con-

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sistently aligned in accordance with operational procedures.

The

licensee acknowledged a programmatic deficiency in assuring compli-

ance 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

changes included removing redundant administrative requir'emerts, en-

hancing the biennial procedure review process, improving training,

and 6ssuring that pre-job briefings occur.

The licensed operator training and qualification process was accept-

able as demonstrated by initial examination results of twelve reactor

operator applicants. Three failed the written exam and two failed

the operating exam. The failures revealed no programmatic weaknesses

with the licensed operator training program.

Nineteen of twenty

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. operators who took the NRC administered requalification exam passed.

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- The operations staff had an excellent understanding of both the B&W

Owner's Group recommendations for preparing the Emergency Operating

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Procedures (EOP) and incorporating the TMI-1 plant specific excep-

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tions.into the E0Ps. The operators demonstrated that they can suc-

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cessfully implement the E0Ps.

Overall, a disciplined, well trained staff operated the unit with.few

transients throughout the period. Management took action to correct

those problems identified during the previous $ ALP.

A timely approach

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.to reso v ng issues was evident.

Results of licensed operator exams

were adequate.

2.

Conclusion

. Category - 1

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Board Recommendation

Li ensee: None

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NRC:

None

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B.

Radiological Controls (211 hours0.00244 days <br />0.0586 hours <br />3.488757e-4 weeks <br />8.02855e-5 months <br />, 6'4)

1.

Analysis

The previous SALP report rated Radiological Controls as Category 1.

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Strengths included management involvement in daily activities, good

quality assurance audits, highly qualified staff, a well managed

support program, good access control, and an effective as low as

reasonably achievable (ALARA) program. Minor weaknesses included

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Slowness in updating surveys in some areas of the plant and some

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lapses in proper outage planning, specifically in connection with

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scaffold erection.

Radiological Controls

The strengths observed during the previous SALP period continued to

be strengths durin0 the current SALP period.

In adoition, 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 staff.

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

addition to fully using the available staff, 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 controls.

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Management has demonstrated a willingness to go beyond the minimum

program requirements to ensure high ouality 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

above 1 man-rem instead of 5 man-rem.

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-Attention to detail was lacking in some observed situations.

For

example, improper placement of dosimetry was observed once, and some

inconsistent postings marking a high radiation area were also ob-

served.

The radiological implications of these specific instances

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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

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removing protective clothing was improved by the use of a continuous

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video display placed at the dressout area to show the workers the

proper techniques. Two way radios were also effectively used during

the last outage by health physics supervisors and by technicians

covering important jobs.

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All important positions in the radiological controls organization on

site were fully staffed during this assessment period. The staff was

highly qualified.

To maintain a well qualified staf f, criteria were

developed that specify the type and amount of experience acceptable

for hiring a senior health physics technician. The training program

centinues to be effective as shown by the high quality performance at

al' levels of the radiation protection organization, th0 small number

of violations and issues identified by the NRC and the lack of signi-

incant operational events.

Performance in maintaining exposure ALARA continues as a program

strength. The weakness noted during the last SAlp period with scaf-

folding has been corrected, and additional efforts to reduce dose

have been made.

For example, laser video disc displays are being

used ef fectively during pre-job briefings to show workers job loca-

tions and access routes.

Industry experience was used to plan high

exposure jobs. The ongoing cobalt reduction program helped minimize

' plant radioactivity in the primary systems at a minim .i level. Goals

set during this atrossment period have been realistic but challeng-

ing, and the cumulative exposure for the 1989 non-outage year was

significantly below the goal .

Cumulative worker exposure fnr the

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station also continues to be relatively low by current industry per-

formance.

Radwaste, Transportation, Effluents and Radiological Environmental

Monitoring

During the previous assessment period, excellence in the effluents

controls program and in the training of radwaste personnel was noted.

During the current assessment' period, inspections of the licensee's

Radwaste, Transportation, Effluents and Radiological :nvironmental-

Monitoring Programs (RFMP).were conducted.

Thelicencee's'QualityAssurance/QualityControlf(QA/QC) programs

remain 5 Jng with the scope and technical' depth of audits within the

radwaste, effluents and REMP being excellent. The QC program for the-

meteorological tower and Environmental Radiation Laboratory (ERL)

. instrumentation continues to be strong as indicated by the high avail-

ability of these systems and the high quality results produced.

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The licensee continues to aggressively attempt to resolve technical

issues, as shown by-its. preparation for the startup of the evaporator

system to be used 1.o process Unit 2 Accident Generated Water. The

licensee has conducted extensive testing for tritium in environmental

media, and has proposed to increase the sampling frequencies when the

evaporetor comes on line.

In addition, the licensee undertook an-

extensive evaluation of its condenser offgas iodine sampling in re-

sponse to an' NRC inspection which had been conducted at the end of-

the previous assessment period.

The licensee continues to have few operational events in the radwaste

processing and transportation area.

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Staffing levels and training of personnel, especially in the radwaste

area, continue to 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

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lack of significant operational events.

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In summary, the radiological controls program, including rad aste,

transportation, and REMP, remains strong and effective in all areas

assessed. Strengths noted during the previous assessment period con-

tinue to be strengths, and the weaknesses previously noted were cor-

rected. Weaknesses observed' during this period were minor and did

not detract from the overall high quality of the program.

2.

Conclusion

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Category - 1

3.

Board Recommendation

Licensee: None

NRC:

None

C.

Maintenance / Surveillance (756 hourt, 21%)

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1.

Analysis

During the last SALP period, no major programmatic problems were

noted.

The effectiveness of.the newly restructured maintenance or-

ganization remained to be realizeJ. Some weaknesses were noted in

specific job planning, failure to follow administrative controls,

increased personnel errors, and deficiancies in chemistry laboratory

operations. A Category 2 rating was assigned to the maintenance /

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surveillance combined area.

During this assessment, NRC perspective was provided by routine

inspections by resident inspectors, specialist inspections, and the

completion of a maintenance team inspection.

Maintenance

- Maintenance was generally perivrmed in a controlled manner, in ac-

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cordance with. procedures and was adequately supervised.

Controls

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have been established to ensure maintenance tasks were appropriately-

planned, prioritized, and scheduled.

Realistic maintenance backlog

goals have been established and the backlog was maintained below

these goals.

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The effectiveness of th'e new plant materiel organization was e dent

during this evaluation period.

The new organization was full

staffed

and several benefits have been realized.

The creation of tt

plant-

materiel assessment group has allowed experienced mainten

ce per-

sonnel, not associated with day-to-day maintenance activ ies, to

more deeply assess and improve the maintenance program.

Improvements

included a new lubrication program, completion of sev al reliability

centered maintenance (RCM) system evaluations, and

ditional effort

on root cause analysis. The new and expanded mate al planning organi-

zation centributed to the timely completion of t

8R outage.

The licensee started a major effort to more ef ectively plan main-

tenance activities and ensure that administr- ive procedures were

followed.

This resulted in improved mainty'.ance.

Maintenance

organization and planning are now strong (oints in the overall

license

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The pla

nce pro-

cedures

aintenance

procedu

ent organi-

zation

REPLACED BY PAGE 9a

engineering

input h

increase

their u

The pla

nstituted a

program

ns of speci-

fic pla

e spot or

incorpo

the plant

preservation (paint 1 g) work list.

Previous problems in identifying

minor material dis epancies have been corrected.

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The maintenance eam inspection reviewed 43 specific aspects of the

maintenance pr gram.

The team concluded that 35 of those aspects

were well do mented and functioning well. The team identified six

specific we nesses that needed improvement.

There were specific

,"

instances

f incomplete documentation associated with tagouts, com-

pleted w rk packages, and control of contractors.

In addition, the

contro

on vendor manuals, as well as hoisting and test equipment,

need mprovement. Several vendor manuals were not controlled in the

ven r-document control program.

The program for hoisting and test

e ipment was'not well controlled.

Post maintenance testing was not

ways specified or adequately documented.

In general, the examples.

of lack of documentation and administrative controls were effectively

overcome by a capable staff, appropriate management attention and

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excellent implementation of work activities.

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An effective Maintenance training program was in place. A six shift

rotation schedule allowed adequate time for conducting training. A

Veutudteo maintenance training staff and facility has been established

=and training facilities such as mock-up and training aids are being

upgraded.

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The effectiveness of the new plant materiel organization was evident

during this evaluation period.

The new organization was fully staffed

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

more deeply assess and improve the maintenance program.

Impovements

included a new lubrication program, completion of several' re'iability

. centered maintenance (RCM) system evaluations, and additioral effort

on root cause analysis.

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.

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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 organi-

zation was dedicated to this effort.

Vendor guidance and engineering

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-

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fic plant areas.

Minor di>crepancies'were corrected on the spot or

incorporated 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

.were well documented and functioning well.

In the remaining eight

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aspects, the team identified six specific weaknesses that needed

improvement. There were specific instances of incomplete documenta-

tion-associated with tagouts, completed work packages, and control of

contractors.

In addition, the controls on vendor manuals, as well as

- hoisting and test equipment, need improvement.

Several vendor manuals

were not controlled in the vendor document control program. The pro-

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gram for.. hoisting and test equipment was not well controlled.

Post

maintenance testing was not always specified or adequately documented.

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- In general, the examples of lack of documentation and administrative

controls;were effectively overcome by a capable staff, appropriate

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management attention and excellent implementation of work activities.

An effective Maintenance training program was in place.

A six shift

rotation' schedule allowed adequate time for conducting training. A

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dedicated maintenance training staff and facility has been established

and training facilities such as mock-up and training aids are being

upgraded.

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Surveillance

The overall surveillance program continued to be properly impi

mented.

Surveillances were performed on schedule, adequately

ocu-

mented and testing deficiencies were properly resolved. On minor

problem occurred when the licensee identified that a surve

lance for

a process liquid effluent monitor had not been completed s required

by technical specifications.

This was duc to inadequat engineering /

licensing interface dur.ing completion of a modificatio, to the sys-

tem.

Three violations were identified during survei .ance testing

activities of which one was cited.

Two violations oncerned testing

of engineered safeguards systems and were a combi

tion of personnel

errors caused by inadequate procedures and lack f operator knowledge.

The violations involved inadvertent engineered .afeguards features

and reactor protection system actuations.

Th

licensee upgraded

these -

ite poten-

tial et

lem.

Genera ~

lished

safely

jentified in

the vii

incies.

REPLACED BY PAGE 10a

The in:

Sufficient

manager

activities.

Licenst

In sumt

trformed

well at

aograms in

place s

ate.

Pre-

vious prootems in the are of acministrative procedure acnerence and

,

specific job planning h e been corrected.

However, administrative-

'

controls in the arcas

f post maintenance testing and hoisting / test

equipment need some

..provement.

2.

Conclusion

Category - 1

3.

Board

commendation

'

Licensee: None

NRC:

one

'

D.

Eme gency preparedness _(124 hours0.00144 days <br />0.0344 hours <br />2.050265e-4 weeks <br />4.7182e-5 months <br />, 3%)

,

,

Analysis

.

During the previous SALP period, this area was rated Category 1.

The

licensee had developed and maintained a strong emergency preparedness

n

program. No exercise weaknesses were identified.

[

__ _.

._

_

_

__

nJ

'.

.

10a

.

Surveillance

The overall surveillance program continued to be properly imple-

mented.

Surveillances were performed on schedule, adequately docu-

mented and testing deficiencies were properly resolved. One minor

problem occurred when the licensee identified that a surveillance for

a process liquid ef fluent monitor had not been completed as required

by technical specifications.

This was due to inadequate engineering /

licensing interface during completion of a modification to the sys-

tem.

Three violations were identified during surveillance testing

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 /

technician knowledge.

The violations involved inadvertent engineered

safeguards features and reactor protection system actuations.

The

licensee upgraded these specific types of surveillance procedures to

eliminate potential confusion. This was effective in resolving the

problem.

Generally, performance of surveillance testing was accom-

plished safely, and the specific procedure / performance problems

identified in the violations were not indicative of programmatic

deficiencies.

The' inservice. inspection program met program objectives.

Sufficient

management involvement existed to properly control vendor activities.

Licensee and vendor staffing was ample.

,

In summary, maintenance and surveillance activities are performed

well and have a high degree of management involvement,

Programs in

place were effective and procedure reviews have been adequate.

Pre-

vious problems in the area of administrative procedure adherence and

specific job planning have been corrected. However, administrative

controls in the' areas of post maintenance testing and hoisting / test

equipment need some improvement.

2.

Conclusion

Category - 1

3.

Board Recommendation

Licensee: None

,

NRC:

None

B

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 the-previous SALP period, this area was rated Category 1.

The

licensee had developed.and maintained a strong emergency preparedness

program. No exercise weaknesses were identified.

'

!

i

.

.

-,

'o

.

11

.

No deficien:ies in the emergency plan were identified.

Upper mana e-

ment was routinely involved in emergency preparedness activities.

Management involvement and control in assuring emergency prep edness

program Quality was effective and extensive.

Station manage

main-

tained emergency response organization position qualificati n, re-

viewed and approved plan and procedure changes, participa

'd in

drills and exercises and resolved audit issues.

To dete mine if

quality was achieved, an extensive audit was conducted y the li-

censee's OA Department and reviewed by senior managem nt.

Audit team

memoers were well qualified for the task.

The audi

report found

that an effective emergency program had been devel ped and was being

maintained.

Additionally, licensee management c tinued their in-

volvement in the off-site emergency preparednes program.

Two staff

members were dedicated to off-site emergency

eparedness.

There

were fr

ensee also

provide

veness of

this tr

rgency

Managen

the exer-

cise.

specifica-

tions.

REPLACED BY PAGE 11a

Sound r

ment

period,

censee,

working

tegrated

into th

adio net-

work.

ergency

Operati

also been

responsive in resoiving p niems witn inadvertent sounding of the

Alert and Notification 5 stem sirens.

Siren decoders have been re-

wired to reduce the nu er of inaevertent siren soundings.

The licensee respon d to one actual event during-the assessment

period. This even involved a small steam = generator tube leak under

power ascension

nditions. Approved-procedures were correctly fol-

, lowed. Althoug not required, the-licensee dispatched monitoring

teams, calcul

ed projected doses-using worst case scenarios and

monitored of site readings.

In addition, the Commonwealth of

Pennsylvani

and county officials were voluntarily notified. A sub-

sequent r iew of this event,. initiated internally by the licensee,

revealed that their procedures lacked the analytical capability to

immedi

ely and-accurately quantify a small primary leak rate. The

licen ee declared an Unusual Event (UE).a day late for this event

whe they found through detailed calculations, that the actual leak

ra e required a UE declaration. This report showed a willingness by

. nagement-to ensure complete adherence to the Emergency Plan.

,

'.4,

4

Il a

4

No deficiencies in the emergency plan were identified.

Upper manage-

ment was routinely involved in emergency preparedness activities.

Management involvement and control in assuring emergency preparedness

program quality was effective and extensive.

Station managers main-

tained emergency response organization position qualification, re-

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-

censee's OA Department and teviewed by senior management.

Audit team

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 in-

volvement in the off-site emergency preparedness program.

Two staff

members were dedicated to off-site emergency preparedness.

There

were f requent meetings with government of ficials. The licensee also

provided training for off-site emergency workers.

Effectiveness of

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.

Sound resolution of technical issues continued this assessment

<

period.

Due to past communication system failures, the licensee,

working with the Commonwealth of Pennsylvania, has been integrated

into the Pennsylvania Emergency Management Agency (PEMA) radio net-

work.

This radio system links the licensee to the PEMA Emergency

Operations Center (EOC) and county E0Cs.

The licensee has also been

responsive in resolving problems with inadvertent sounding of the

Alert and Notification System sirens.

Siren decoders have been re-

wired to reduce tha 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 internally 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) the following day for this

event lwhen they found through detailed calculations, that the actual

leak rate required a UE declaration. This report showed a willing-

ness by management to ensure complete adherence to the Emergency-

Plan.

,

,

,

.

12

'.

Staffing of the emergency preparedness program was stable at all

levels and the staff was well qualified to maintain an effective

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

organization was fully staffed and the Technical Support Center staff

was increased to provide for a more effective engineering capability

on-site.

A very effective emergency preparedness training program was developed and

maintained by the plant training department.

The effectiveness of this

training was demonstrated by the performance of licensee personnel during

the full participation exercise.

The basis for the training was clearly

described in the Training and Education Department Manual which delineates

policy, specifies the training matrix, lists course content, and states

requalification policy. Training is practical in nature and was correctly

based on job analysis.

Engineers were given training in accident analysis.

The realism of this training has been enhanced by the utilization of a

computer program which models six different accidents.

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

resolved.

The Emergency Preparedness Program staff was stable and well

qualified'to maintain an effective program.

Training was well developed

and effective as demonstrated by exercise performance.

A very good

working relationship was maintained with the Commonwealth, county and

local governments.

2.

Conclusion

Category.- 1

3.

Board Recommendation

Licensee:

None

NRC: None

E.

Security (86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br />, 2ff)

1.

Analysis

During the previous assessment period, the licensee's performance was

rated as a Category 1, based on a very effective and_ performance

oriented security program. Management attention to and support of

the program were clearly evident.

No major reg'latory issues were

u

identified.

.

- .,

- .,

13

.

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

period. One violation was identified in this functional area during

this assessment period, (failure of the medical department to pro-

perly perform proper visual acuity tests for two security decartment

personnel).

The licensee took timely and effective actio'n t! correct

? w problem, identify the root cause and strengthen procedures to

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 to be

completed very early in the next assessment period.

The allocation

of the resources to upgrade equipment was evidence of management

support for an effective security program.

' ' '

,

Corporate security management continued to be actively involved in

site security program matters.

This involvement included site

visits by the corporate staff to provide assistance, program ap-

praisals, and direct support in the budgeting and planning process

affecting program modifications and upgrades.

Site and corporate

'

security management personnel also remained active in the Region 1

Nuclear Security Association and other organizations engaged in

nuclear plant security matters.

This demonstrated program support

from upper level management.

'

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 members contributed to

the effectiveness of audit. However, the NRC found that the auditors

were denied access-to source- medical documentation for members of the

security organization.

This resulted in the only violation during

this assessment period.

When the problem was identified to 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 actions on findings and recommendations

identified during the audit and self-assessments were prompt and

effective with appropriate follow-up to ensure their proper imple-

mentation. The comprehensive quality assurance 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.

L

4

.

. --.

,

3

<

,

[

t

"

14-

L.

The licensee submitted one security event report in a accordance with

NRC requirements during this assessment period.

The event was the

result of human error.

The licensee properly reported the event to

the NRC and the documentation was sufficiently comprehensive to per-

mit NRC analysis without the need for additional information.

The

licensee's event reporting procedures were consistent with regulatory

requirements and implemented by knowledgeable personnel.

Because of

this event and other minor human errors, the licensee implemented a

program to formally critique all human errors with the people in-

volved.

This is followed bv an independent review and the identifi-

cation-of lessons learned from the event.

This was further evidence

of-the. implementation of an effective security program,

c

Staffing of the security force was consistent with program needs, as

(R

evidenced by the minimal use of overtime.

Members of the security

force exhibited a professional appearance, good morale and demeanor.

The turnover rate remained very low.

The train'ing and requalification program was administrated by a full

time instructor from the Training Department who conducted all class-

room training.

All practical-training was conducted by five members

of the security department. The training and requalification program

was revised during this assessment period to. improve continuity so

that all required training was completed in a single block instead of

.

in a fragmented manner.

The effectiveness of the training program

'

was shown-by-the small number of personnel errors that occurred dur-

.ing the assessment _ period.

, ..

In summary, the licensee's_ hardware improvements and strong personnel

practices provided for a strong security program. . Effective audits

!

'

and strong corporate support made 'a positive cor.tribution.

l

2 =.

LConclusion

u

.

' Category 1-

3.

Board Recommendation

> Licensee: . None

'

'

-NRC: None

..

1

F.

Engineering /Techn. 11 Support (419. hours,11%)

'

'

,

~1..) Analysis'

l

-

During the previous. assessment period, the licensee's performance in

.

this' functional area'was rated Category 2: ' Improving. There were

noted_ improvements-in prioritizing work assignments, training for

safety reviews,_and. control of_ modifications.

,

_

Initiative was evident

,

.

(

'

,

b

y

l'

_

. . ,

.

..

l

15

i

I

.

!

in the program planning for design bases documents and safety system

i

functional inspections.

Support of operations was generally thorough

i

and effective; however, there was indication that improvements cobld

i

be made in several activities such as support data for the diesel

generator load calculation, and in planning post modification func-

tional acceptability verification of several design changes.

_

Inspections performed by region based personnel, the resident in-

I

spectors, and evaluations from headquarters staff provided the bases

'

for the current assessment.

l

!

During this SALP period, the licensee has completed several major

modifications in which effective engineering was evident. The Heat

Sink Protection System upgrade improved the logic and electrical

j

supply for emergency and main feedwater (FW) system isolation and

i

control. All 32 FW Flows nozzles were replaced in both SGs. A Cold

i

'

-

'

Leg Nozzle Dam installation was engineered to enable SG work during

~

reactor flood-up conditions.

Two new state-of-the-art electropol-

ished FW Flow Venturi replacements were installed and tested. All the

above effcrts were well planned with in-depth engineering involvement

l

and direction and were good engineering accomplishments.

!

Numerous other smaller modifications were performed during the 8R

,

outage. __These included upgrade of the Reactor Coolant Pump Lube 011

i

System upper reservoirs, Reactor Building Maintenance Platforms,

!

" Gaseous Chlorine System replacement, the initial phase of the Instru-

ment Air System upgrade, and the. Radiation Monitoring System pump

replacements.

In each of these modifications, the engineering was

l

thorough with clearly written installation specifications, safety

evaluations, work descriptions, and testing requirements. Good in-

terface between site and corpoiate engineering was evident during the

I

daily outage status meetings and engineering support contributed to a

.!

successful outage and timely modification completions.

"

Engineering's support of site operations by plant and corporate

,

engineering was evident during the activitics related to high SG

l

leve_1 and reduced power due to corrosion. build-up on the SG tubes.

i

This was an example of good communications and teamwork.

Plans for

l

chemical cleaning of the SGs'was assigned a high priority and cor-

l.

porate engineering has draf ted details _ for the work.

1

Plant engineering activities in support'of operation and maintenance-

was viewed as a strength.

Initiatives were taken in the valve _ pack-

1

ing upgrade program to eliminate asbestos: and use live load packing,

j

Recent efforts to develop a split mechanical pump seal to allow main-

~

tenance without removing bearings showed a high level-of engineering-

involvement and expertise. The control rod drive mechanism (CRDM)

1

gasket and split nut ring replacements were well coordinated by en-

gineering.

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

i

n

.

I

,

a

7

'

't

,

16

.

in the resolution of an inaccurate reactor pressure boundary leak

rate.

This required flow indicator relocation, piping reconfigur -

tion, and valve replacement.

Plant engineering support of the

tube and tube plug eddy current testing was adequate and a con erva-

tive approach was taken to remove defective plugs.

Ultrasoni test-

ing of the new and reused fuel and the recaging of one asse, ly re-

sulted ir. a core reload free of defects.

A revies of the licensee's involvement,in and implement

ion of the

'

B&W 0.:.er

Group Safety and Performance Improvement Pr gram (SPIP)

found corporate and site management committed to and 'ery active in

j

the program.

The licensee's engineering staff was xtremely know-

)

ledgeable of the issues, recommendations received ppropriate priori-

t12ation, and good engineering analyses supporte each recommendation.

The licensee has made an aggressive effort to i

rove plant safety as

a result of the SPIP program and at the end of this assessment period,

only 3 out 222 recommendations remained to b

implemented.

The plant and corporate engineerino staff esponded to the SG tube

I

leak shut

ident in

the aggre

and per-

form nect

repriate

commitmer

ving.

In

addition,

and an

exigent i

REPLACED BY PAGE 16a

d had

,

good engi

>

The'Corpc

ms for

Design Ba

nspec-

tions (55

r the

Reactor E

aste

. systems,

r Distri-

!

bution were well pertor ed and meaningful findings.resulted from each

.

project.

The license s action item tracking and updating of the

documents .. ave been ystematic and contributed to the program.

Future DBD plans w e aggressive and included five DBDs and one SSFI

.to be performed i

1990.

Several proble areas- noted during the assessment period included the

!

,J

high backlog-

site engineering evaluation requests and a large

number of F1

d Change Notices and Requests associated with modifi-

<

cation pro cts. Each of the problems was being appropriately ad-

'

dressed.

Wi thin he context of finding problems, the licensee's self-

asses ent of. technical support performed in 1989 and updated in

Jan ry 1990 was beneficial in pointing to areas needing improvement.

Ba d on the licensee's ability to find and take immediate corrective

!

a

ions for eacn problem, engineering management was committed to

i

ontinued improvement.

The majority of the self-assessment action -

items have been completed.

4

1

o

a

t

,

26 a

,

in the. resolution of an inaccurate reactor pressure boundary leak

rate.

This required flow indicator relocation, piping reconfigura-

tion, 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-

ing of the new and reused fuel and the recaging of one assembly re-

suited in a core reload free of defects.

A review of the licensee's involvement in an:' mplementation of the

B&W Owners Group Safety and Performance Impr:,ement Program (SPIP)

found corporate and site management committed to and very act1ve in

the program.

The licensee's engineering staff was extremely know-

ledgeable of the issues, recommendations received appropriate priori-

tization, and good engineering anal.,les supported each recommendation.

The licensee has made an aggressive effort to improve plant safety as

a result of the SPIP program and at the end of this assessment period,

only 3 out 222 recommendations remained to be implemented. Of the

original 222 items, 41 were not implemented based on technical

,

review or inapplicability.

The plant and corporate engineering staff responded-to the SG tube

leak shutdown of March 6, 1990.

Engineering tu mwork was evident in

the aggressive effort to find the leak, de%rmine its cause and per-

form necessary corrective action.

The licensee has made appropriate

l

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 Corporate Engineering and Design Department pilot. programs for

Design Bases Documents (DBDs) and Safety System Functional Inspec-

tions (SSFIs) have been successful.

The 1989 DBD reviews for the

Reactor Building-Emergency. Cooling Water and the Liqui.d Radwaste

systems, and the SSFIs on 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

to be performed in 1990.

>

Several problem areas noted during the assessment period included the

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.

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

items have been completed.

~_

%

.

i

'

17

p-

o

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.

The backlog of items assigned to the corporate technical functions

organization had a sizeable reduction in this assessment period.

The

licensee's new graphical backlog format presents a clear picture of

the number of items and the chronology and age group of the item.

The backlog tracking system was updated monthly and was a good manage-

ment tool.

The licensee's engineering groups were adequately staffed with suf-

ficient personnel of all engineering disciplines.

There was little

L

use of contract engineers other than in outage activities; however,

contracts were in place to provide-architect engineer and NSSS vendor

support when needed.

The licensee is supportive of industry stand-

ards group, owners group, and professional society participation.

The rotational assignments of engineering management and engineers

between corporate and site continued to be beneficial.

Training of

new engineers included one year of formal training and one year on-

site.

A training programs also existed for the experienced engineers.

After a detailed engineering evaluation of the alternatives to deal

with steam generator fouling, the licensee elected to manually trip

.he reactor to redistribute the corrosion products causing the foul-

-ing.

The long term solution to the problem is chemical cleaning of

toe steam generator secondary side. Manually tripping the reactor

fcr this purpose unnecessarily challenges safety systems.

However,

ttere are also 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

rufueling 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 drawing improvements.

The staff was technically competent and

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 protoction up-

grade, and the DBD program have been proactive. ' Problem areas have

been' minimal and of minor safety significance.

_ _ . _ _ . . .

1

1

- . ,

.

.

18

2.

Conclusion

Category - 1

3.

Board Recommendation

Licensee: None

"

NRC:

None

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%)

1.

Analysis

This area received a Category 2 rating in the last assessment period.

Strengths identified included Quality Assurance Department (QAD)

'"

oversight activities, initiatives taken by the licensee to enhance

performance in this area, and the quality of Licensee Event Reports

(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).

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

Action Plan Items. Also, during this period, the licensee submitted

its responses to the ATWS Rule (10 CFR 50.62) and the Station Black-

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 exception to a staff interpretation regarding

pwer supply independence. The licensee's Station Blackout submittal

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 bulletins, 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-

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 satisfactory by the staff. To enhance communications with

the staff and understanding of the issues, the licensee _ met approxi-

mately once per month during this period with the NRC to discuss

licensing issues and inspection open items.

'

':

.

.,

19

Review of licensee performance in identifying and evaluating plant

deficiencies concerning safety indicated two noteworthy examples.

During an audit of Fairbanks Morse, an emergency diesel generator

vendor, the licensee found deficiencies in the vendor's spare parts

procurement program.

The licensee contacted other utilities through

the Fairbanks Morse Owners Group to alert them of potential :roblems.

Following issuance of an information notice by the NRC, the 'icensee

inspected their containment emergency sump screens and founo gaps in

the screens as a result of a 1983 modification.

The gaps could have

allowed solid material to enter the ECCS pump suction lines during an

accident.

The condition was identified and corrected by the licensee.

The NRC approved Revisior 2 of the licensee's Operational Quality

Assurance (00A) 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-

ment period. One purpose of this review was to verify conformance

with the revised 00A 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

the part of the audit team and a commitment by licensee management to

' identify and correct problems that could adversely af fect quality.

For example, an audit pursued some important points regarding poten-

tial failure modes of a Powdex bypass valve that had apparently not

been considered 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

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

the end of the last SALP period and after NRC approval of Revision 2

to the 00A 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-

erally improved.

However, in some cases, the rationale used by the

reviewer:to answer questions on the. screening form was still not in

';

suffic'ient detail to allow an independent reviewer to understand the

thought processes (including which adverse operation may, result from

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 is necessary.

__

- - _ -

_

._

___

.

_ _ _

ga s.:

.<

.

20

.

.

,

Although some improvement has.been noted in followup and documenta-

i

tion of events of a minor nature (e.g. , those not requiring an LER or

1

incident report), the licensee occasionally failed to document their

,

investigation of such events.

The quality of Licensee Event Reports (LERs) continued to be nigh

>

during this period.

LER 90-005 covering the March 6, 1990, steam

generator tube leak was particularly well written and understandable.

,

The licensee has demonstrated safety initiative by instituting a

number of improvements dealing with plant design.

For example,

Safety System Functional Inspections (SSFIs) have been performed on

the liquid radwaste and emergency AC power systems and more SSFIs are

'

-planned. .Several system modifications have been made as a result of

recommendati:.7s in-the TMI-1 Probabilistic Risk Assessment.

For-

example,.two small diesel generators-were installed to provide backup

'"

'

power to the switchyard air compressors and. breaker heaters.

The

power supply for the "B" High Pressure Injection Pump Lube Oil Pump

was modified to improve reliability of that pump.

In addition, a

-task force was organized to search for modifications that would im-

prove the rel1 ability of the Integrated Control System.

,

In. summary, the licensee had policies, procedures and practices in

place to effectively. identify, evaluate, and correct problems poten-

'

tially affectirg plant safety and quality. Management involvement.

'from the highest levels down, was apparent in the daily operation of-

the facility.

The Quality Assurance Department continued to be an

effective-part of-this effort and was recognized as such by manage-

i

ment._ Improvement has been noted in weak areas identified in pre-

'

vious SALP reports. 'The licensee has also taken' aggressive action to

make. improvements in plant. procedures and system design, including a.

number of plant modifications during the 8R refueling outage.

2.'

Conclusion

'

Category - 1

,

.3.

Board Recommendation

.

Licensee: None

NRC: -None-

,

m

'l~

, .

b

4

>

4

5

)

r

nW

a

y;,.

_

_

_

,

,

.

-

N

$

f

.

.

Supp0RTING DATA AND SUMMARY

A,3

Licensee Activities

~ ; ring this period, the licensee operated TMI-1 essentially at .ull

wer, except for a refueling outage and three unrlanned shu owns

as noted in Section C (Forced Outages and Plant Transients)

This

reflected two transition periods between power operations nd hot (or

cold) shutdown.

A scheduled sixty-four day refueling outage started J nuary 5.1990,

and the licensee completed it about three days earl , Ma 'or

safety-related work completed during the refuelin outage was:

1.

OTSG tube 'tddy Current Testing and tube /pl

repair work,

2.

Seal replacements on all fuer Reactor Coo ant Ivmps.

3.

Reactor Building Integrated Leak Rate T

t.

4

Ultrasonic testing of all fuel assembi,res for fuel leakage.

At the

! department

at TMI-

.I Department.

Four ma

n the following

functio

stion, planning

and sch

REPLACED BY PAGE S-la

Also du

ate

reorgan

cDerati

A.2 Direct

Four NRc resiuent in vu svi > nei e o , . 3. .e . .. .... ..

s...I-1 and 2)

throughout most of

e assessment period.

Total NRC inspection effort-

was 3691. hours (2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per year).

See-Section E for functional area

expenditures.

Special team

spections were: Maintenance Team Inspection (89-80);

Emergency 0 rating Procedure Inspection and Emergency Preparedness

Exercise

-81).

,

- The Off ce of Nuclear Reactor Regulation (NRR) sent a' team to audit

the 1

ensee's implementation of. Safety Parameters Improvement Program

(SP

,

.

&W.

..

' [ln

"*

-;

-e.

S-la

.

SUPPORTING DATA AND SUMMARY

A.1 Licensee Activities

1

During this period, the licensee operated TMI-1 essentially at full

power, except for a refueling outage and three unplanned shutdowns

as noted in Section C (Forced Outages and Plant Transients). Thir

reflected two transition periods between power operations and hot (or

,

cold) shutdown.

i

A scheduled sixty-one day refueling outage started January 5, 1990, and

the_ licensee completed it three days early. Major safety-related work-

completed during the refueling outage was:

1.

OTSG tube Eddy Current Testing and tube / plug repair work.

2.

Seal replacements on all four Reactor Coolant Pumps.

-"

'

-

3.

Reactor Building-Integrated Leak Rate Test.

4. -V1trasonic= testing of all fuel assemblies for fuel leakage.

'At the beginning of this period, the licensee's maintenance department

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

functions; corrective and preventive maintenance imp _lementation, planning-

m

and scheduling, material assessment and administration.

<

-

Also*during this period,-the licensee implemented a corporate

reorganization.

This reorganization did not affect plant

.- ope ra t ion s ..

,

'

A.2 Direct Inspection and Daview Activities

Four NRC resident-inspectors were assigned.to the site-(TMI-1 and 2)

'throughout most of the assessment period.

Total NRC. inspection effort

was 3691 hour0.0427 days <br />1.025 hours <br />0.0061 weeks <br />0.0014 months <br />s:(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

-

'

expenditures.-

Special' team inspections were: Maintenance Team Inspection (89-80);-

!

,

JEmergency Operating-Procedure Inspection-and-Emergency Preparedness

'

Exercise (89-81).

'

,

y.

The Office of Nuclear Reactor Regulation (NRR) sent'a team to. audit-

.~the licensee's implementation of Safety Parameters _ Improvement Program-

'

'

(SPIP).

t

3;

1

,

,f 5

?ff. - $,

,

,

,

.', w 1

.

S-2

'

,

B.

Criteria.

Licensee performance is assessed in selected functional areas,

depending on whether the facility is in a construction, preoperational

or operating phase.

Each functional area normally represents areas

significant to nuclear safety and environment, and area normally

programmatic areas.

Special areas may be added to highlight

significant observations.

One or more of the following evaluation criteria was used to assess each

functional area.

4

m

' 1.

Management involvement and control in assuring quality.

.

2.

Approach to resolution of technical issues from a safety, standpoint.

3.

En f orcement - hi story.

-4.

Responsiveness to NRC initiatives

5.-

Reporting and analysis of reportable events.

.

6.

. Staffing (including management).

7.

Training and qualification effectiveness.

. Based upon the SALP Board' assessment, each functional area evaluated

is classified into one of three performance categories.

The definitions

'

of these performance categories are:

Category 1:

Reduced NRC attention may be appropriate.

Licensee

management attention and involvement are aggressive and oriented

-

toward nuclear safety;-licensee resources are ample and effectively

used so that a high level of performance with respect to operational

safety;is being achieved.

Category 2: NRC attention should.be maintained-at normal levels.

Licensee management attention'and involvement are evident and are

concerned with nuclear safety;

licensee resources are adequate-

and reasonably 1 effective so thatl satisfactory performance with.

respect to operationalLsafety,is'being achieved.

Category 3: .Both.NRC and; licensee attention-should-be increased.

i

Licensee management attention or involvement is acceptable and.

considers nuclear, safety but weaknesses aresevident; licensee-

minimally? satisfactory performance with: respect to ' operational

safety;is~being achieved.

'

'

-The=SALP Board may assessLa functional area by' examining the licensee's

performance during;the entire period in' order to determine the recent

-

,

trendt The' performance trendfis intended to predict. licensee performance

during the next assessment period. The.SALP trend c'ategories are as

'follows:

i

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>

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!

$'

i

b

__

_ _ _ _ _ _ _ _

74 .,

.

,

S3

.

The trend,- if used, is defined as:

Improving:

Licensee performance was determined _to be improving near

'

the close of assessment period.

,

.

Declining: -Licensee performance was determined to be declining near

the close of the assessment-period and the licensee had not taken

meaningful steps to address this pattern.

-

C.

Unplanned Shutdowns, Plant Trips and Forced Outages

,

1.

On November 29, 1989, the reactor tripped from 100*; power due

to a -loose wire in the electrohydraulic control system.

POWER LEVEL

ROOT CAUSE

FUNCTIONAL AREA

-

100%

Random Equipment Failure

None

'

v'

2.

.On March 4, 1990, the reactor tripped following completion of

physics acceptance testing while the operator moved control

rods without closely monitoring power.

a

POWER LEVEL

ROOT CAUSE.

FUNCTIONAL AREA

-Intermediate

Ooerator Error

Operations

>'

Range

'

3,

On March 6, 1990, the reactor was manually shutdown due to a

. tube leak in the

'A" steam generator.

i

.

p0WER L VEL

R001' CAUSE1

FUNCTIONAL AREA

s

, 'k' '-

75%-

Equiprant Failure

Engineering and Technical

~

Support' ~

D.-

Enforcement Activity

No'. of Violations'in Each severity Level

_ Functional Area

-V

IV:

III-

II

I

Total'

. ,

1

s

-

..

_

1.

1-.

A. -Plant 0perations_

e

LB. ' Radiological Controls

1

1

'

e

,

'

'

C.

Maintenance / Surveillance

4

4:

,

.

'/ D .

Emergency Preparedness-

'

"

1

E.,' Security-

.

2

2=

l

F.

Engineering / Technical

1-

1

l

Support'

__

'

.

.GL Safety) Assessment / Quality-

' Verification-

,

,

' Total-

9

9

-

'

4

,

,

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d

. _ _ _ _

.

v

< 4- w ,, ,

-

,

1

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1

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s. 4

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,

!

'

E'. - -Inspection Hour Summary

(

Actual

Annualized

, Percent

Plant Operations

1993

1594

54

-Radiological Controls

211

169

6

.

Maintenance / Surveillance 756

601

21

f

-Emergency Preparedness

124

99

3

.

t

Security'

86

68

2

5

o

Engineering / Technical.

419

335

11

-

,

1 Support

Safety l Asse5sment/ Quality:102

81

3

Verification.

.

'

W'

Total

- 3691

2952

100

'

F.' Licensee Event Report Causal Analysis

'

Numu

y Caese-Code

1

A

B

C

E

E

X-

Total

.

_

" Unit-1-

Plarit" Operations

1

,'

' Maintenance / Surveillance

~2

2'

4

<

Radiological Controls

..

2

1

3'

'

' Engineering / Technical Support-

1

1-

1

4" ~ , ' Safety! Assessment / Quality-

!

-

Verification

'

'

<Lunitf1 Total.

4

1-

0-

1

2

-- 0

8

, iCa'OseTCodes

/ , 'PersonnellError-

4

A

'

' , , ' ' iB'

Design,; Manufacturing.cConstruction

-

,

,

.

or Installation: Error

1

<t

Xi)

JC) LExternal Cause:

-0-

,

&

1

-D$ :DefectiveiProcedures-

1

i

LE! 1. Component Failure.

2

1

'

!X

Other:

0-

,

,

S0ilySightlLicenseelEventL Reports were submitted during' this period. No

'

'

H

< meaningful. causal links;were'noted.

"

<

<

>

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,

.

'

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,

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.

_

- .

- - .

.-

.

Ue

'

ENCLOSURE 2

'

.

GPU Nuclear Corporation

NucIear

o ~ e- -

Persippany, New Jersey 07054

201 316-7000

TELEX 136 482

Augu s t 30, 199pde4 Deect Dial Nurnw

C311-90-2116

U.S. Nuclear Regulatory Commission

Document Control Desk

Washington, DC 20555

Centlement

Three Mile Island Nuclear Station Unit 1,

(TMI-1)

Operating License No. DPR-50

Docket No. 50-289

GPUN Response to SALP 89-99

l

l

On August 3, 1990, the NRC issuad the Systematic Assessment of

Licensee Performance (SALP) Report for Three Mile Island, Unit 1.

A meeting to discuss this report was held at the Three Mile Island

l

Training Center on August 13, 1990. The attachment to this letter

l

provides the GPUN written comments on the SALP Report.

l<

'

We appreciate the opportunity to review the SALP Report with you and

provide our comments. We continue to believe that this dialogue is

the most meaningful portion of the SALP process.

...,

GPUN is pleased that the NRC recognizes the high standards of

performance of THI-l in the various SALP areas. We shall continue to

I

direct our emphasis toward operating TMI in a safe and efficient

(

manner, and toward making further improvements.

CPUN also encourages the NRC to continue to conduct mid-SALP-cycle

l.

review meetings. We found this' review to be a meaningful exchange of

l

information and feedback.

l

Sincerely,

'

d

P. R. QJark

President and CEO

l-

PRC/DVH/spb 2116

cc: M .. Martin

R. Hernan

F. Young

GPU Nuclear Corporation is a subsidiary of General Public Utilities Corporation

(q Q A M A A **L2 l.

mQ

ny'f7 7 /

,

,

._

.

.

-

1*

.-

ATTACKMENT TO C311-90-2116

GPUN RESPONSE to SALP REPORT 89-99

The following comments are provided for purposes of clarification

or accuracy:

Plant coerationg

The SALP Report states that TMI will be the B&WOG pilot plant for

the installation of an advanced control system.

The lead plant

has not yet been determined.

At this time, TMI does not expect

to be the lead plant but will be closely involved in the overall

effort in this area.

Maintenance /Surveillanet

Maintenance backlog goals have been established and the plant is

working to keep the backlog below these goals.

Normally the

backlog has been within these limits but some exceptions have

occurred.

During the maintenance team inspection and in the subsequent

inspection report there were several areas identified for TM1-1

improvement including six specific weaknesses.

However, the SALP

refers to 43 specific areas of the maintenance program which were

reviewed and 35 which were found to be well documented and

functioning well. GPUN cannot specifically identify these 43

. areas or the 8 areas where we may have been experiencing

problems. We are continuing to address the comments including

the specific weeknesses identified by the maintenance team

inspection report.

. . ,

In the surveillance discussion, the SALP Report indicates two

violations were caused by inadequate procedures and lack of

operator knowledge.

In one case the violation resulted from lack

of " technician" knowledge.

Emeroency Precaredness

The SALP Report stated that GPUN was a day late in declaring an

Unusual Event for the steam generator tube leak incident.

In

f act, GPUN did not' declare- an UnusualLEvent but did make an ENS

notification. The notification was made in accordance with

210CFR50.72 (b)(1)(1)(a)1for a-plant shutdown as required by the

. plant's Technical Specifications.

In our notification we stated

that'had the leak rate been known to be greater than one gpm,

an

Unusual Event would have been declared in accordance with the

Emergency Plan.

-1-

n

6

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

. _ . . -

-

. .-

-.

.1

1

ATi,6CHMENT TO C311-90-2116

Enoineerino/ Technical SuoDort

The CPUN SPIP effort has involved reviewing the 222 SPIP

recommendations. At this time three of the recommendations are

in the implementation phase, while the othere were dispositioned

as: Implemented (178), Rejected (9) based on Technical Review; or

Not-applicable (32).

Sueoortino Data and Summary

The 8R outage was a echeduled sixty one day outage which

completed three days early.

..,

l

l'

l-

L

l-

-2-

..

.__

_

-.

_-

-

1 .,, *

.

ENCLOSURE 3

LIST OF ATrfNDEES

'IMI-

SAIP MANAGEMENT MEETING

AU3UST 13, 1990

GPU Nuclear Corporation

R. L. Ing, Dir. , Corp. Services, ions ard Maintenance, 'IMI-1

'IMI-2

T. G. Broughton Director, Operat

H. O. Hukill, D1 rector, 'IMI-1

P. R. Clark, President, GPON

I. R. Finfrock, Director, Site Services

M. K. Past, GPLN Nuclear Security Director

R. P. Shaw, Radoon Director, 'IMI

G. R. Skillman, Plant Dyineering Director, 'IMI

R. T. Glaviano, Mgr. Technical Functions, 'IMI

R. E. Rogan, Director, 'IMI Licensing

O. J. Shalikashvili, Manager, Plant Training, 'IMI

G. J. Sinonetti,icensing Dgineer, 'IMI-1

Jr., Dnergency Preparedness Mgr, 'IMI

D. V. Hassler, L

C. W. Smyth, Licensing Manager, 'IMI

E. J.. Seltgyder, Site Services, 'IMI

D. W. Myers, Director, Admin and Finance, 'IMI

J. C. Fornicola, Manager, QA, 'IMI

J. L. Sullivan, Director, Indepe.uhl Safety Review, 'IMI

l

P. S. Walsh, 'IWchnical functions Site Director, 'IMI

G. J. Giangi, Mgr.,ications, GPU-

Corp. Ehma w s'y Prep.

M. C. Wells, Cmmun

L

J. F. Stacey, Site h ity Mgr.1stant

'IMI

L

P. F. Ahern, NSCN, Sr. Staff Ass

U.S. Nuclear Regulatory cannission

l

D. P. Beaulieu, Resident Inspector

i

D. M. Johnson, Resident Inspector

J. T.1 Stolz, PIVject Director

C. W. Hehl,. Director, [EP

R. W. Hernan, NRR, PDI-4

M. W. Hodges, Director, IRS

o

W. H. Rulard, Section 011ef, DRP

R. M. Morris, Intern

Other Attenders

R. C. Cook, Pennsylvania DER /BRP

- .

-

-

.

-

- .

..

.

. - .

._ __ _

_ _ _ _

_

..

s4 s

.

,

DKIDSURE 4

SAIP BOARD REKRT IRRATA SHEET

Page

Line

Now Reads

Should Read

4

32-33

In the long tezu, TMI

In the long term, TMI

will be the pilot plant

is planning installation

for the installation of

of an Mvanced Control

an Mvanoal cantrol

Systan

Systan

Basis: Mditional information provided by the licensee noted that 7MI nar not

be the lead plant for installation of the (Ics) Mvanced control System

Page

Line

Now Reads

Should Read

9

33-34

The team identified

In the remaining eignt

six specific weaknesses,

aspects, the team

that naariai improvement,

identified six specific

h that needed

inprovement.

Basis: The six weaknesses were not directly related to the remaining elaht

aspects but conocrned itens that ctm W individual aspect areas of

on.

Page

Line

Now Reads

Should Read

10

13

..and lack of operator

...and lack of

icowledge.

operator / technician

knowledge.

Basis: The two violations involved a licensed operator error in one case arrl

a maintenance technician error in the other.

'Page

Line

Now Reads

Should Read

11

43-

... declared an Unusual

. . .rianlanad an Urmsual

Event (UE) a day late

Event (UE) the following

i

for thj.s event...

day for this event. . .

Basis: The UE was not reported late - but rather was delayed pendirrJ

licensee calculation of an accurate leak rate.

.

-

-

-

-

..

..

1

• , so o

1

l

l

Pago

Lino

Now Heads

Should Raad

j

16

17

...inplemented.

. . . inplanented. Of the

original 222 items, 41 wtro

not inplemented bascd on

technical review or

inapplicability.

Basiu

Additional Licensee infornetion clarified the actual number of

reocrmondations that were implemented.

1%go

Line

Now Roads

thould Road

SD/S-1

9

... sixty-four day...

. . . sixty-ono day. . .

fD/S-1

10

. . . it about three. . .

...it three...

Basis: 'Itm Licensoo noted that the outage was initially scheduled for

sixty-ono days and was cartpleted three days early.

i

1

l

l

l

l

!

l

l