ML20077Q588
| ML20077Q588 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/14/1991 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| C321-91-2218, NUDOCS 9108220012 | |
| Download: ML20077Q588 (5) | |
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GPU Nuclear Corporation a Nuclear
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201-310-7000 TE LE X 136-482 August 14, 1991wnter s orect 0:ai Number C321-91-2218 U.S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555
Dear Sir:
Subject:
Oyster Creek Nuclear Generating Station Docket 50-219 System Assessment of Licensee Performance (SALP) Response (90 39)
We have reviewed the SALP report in detail and appreciate your recognition of improvements in addition to your identification of areas where improvements can be made, in general we have no disagreement with the report's content, conclusions and recommendations.
The enclosure provides our response to the report and, in particular, the recommendations made. As discussed during the SALP meeting, we have contacted the NRC reviewers in the area of Security to obtain clarification of the basis for the SALP conclusions.
Our response under the security heading of the enclosure reflects our review of the SALP report and our understanding of the issues following communication with the NRC staff.
Of particular note both in the SALP report and in the Diagnostic Evaluation Team Report is the area of work practices. We concur that overall improvement in this area is needed.
To this end, management intends (through meetings and/or committees) to seek worker and supervisor participation to fully identify problem areas and to implement lasting solutions.
As stated in the radiological controls section of the enclosure, this approach has been very successful in developing needed improvements.
If you should have any questions or desire additional information regarding our response, please contact Mr. George Busch, Manager DC Licensing at 609-971-4643.
l Very truly yours,
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0h<Ad P.R. Clark President PRC/BDEM:jc Enclosure cc:
Administrator, Region 1 i
l Senior NRC Resident Inspector Oyster Creek NRC Project Manager
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9109220012 910814 PDR ADOCK 05000219
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GPU Nuclear Corporation is a subsid6ary of General Pubhc Utikties Corporation I
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i Enclosure 5
Response to and Comments on the Preliminary NRC SALP Report P1 ant.0pfrations GPUN concurs with the conclusions of the SALP report and will continue to seek excellence in plant operations.
The SALP report included one recommendation in the Plant Operations area as follows:
l Recommendationt "GPUN should assure continued improvements in the licensed operator training and requalification program, and, in particular, they should take action to correct the high failure rate for SRO candidates on NRC i
initial examinations."
I The failures referred to occurred early in the SALP period, in order to address these concerns, which are shared by GPUN, the following actions have j
been taken:
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In the past year simulator training for initial and license i
upgrade candidates at the 9 Mile Nuclear facility has been t
lengthened by an additional week.
Initial license candidates t
L received three weeks of training and license upgrade candidates received two weeks of training.
2.
Practice walkarour.ds have been increased from two to a minimum of
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three. A member of the Operations management staff is now includ-ed in this process in order to further examine and enhance the i
supervisory skills of the candidates, j
3.
Additional use of the basic principles trainer simulator and photographic mockup of the control room has been added in the final phases of the program.
4.
Practice walkarounds now exercise a candidate in the roles of GSS and CR0 during any part of a given scenario.
This technique of random role swapping will minimize candidate confusion during the l
NRC walkaround and further enhance trainee mastery of a given transient.
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e Upon receipt of the Oyster Creek plant referenced simulator, additional I
simulator training time in excess of current requirements will be provided.
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2-Radioloaical Controls GPU Nuclear recognizes the need to enhance individual worker adherence to radiological work practices and procedures, in order to strengthen the l
radiological controls program in this area the Plant Director is planning a series of meetings with groups of plant workers to discuss this area of plant performance and to seek worker level input for improvement of our radiological work practices.
This approach has proved successful with regard to industrial safety as well as other initiatives. Additionally, plant management is taking a more active role in observing and instructing workers in proper work practices.
The approach utilized will be to closely observe work in progress in the radiologically controlled areas &nd " coach" workers as appropriate.
It is anticipated that such involvement of all levels of GPU Nuclear personnel j
will lead to further lasting improvement in this area,
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Maintenance and Surveillance GPU Nuclear concurs with the SALP assessment in this area which among other i
things re-emphasizes the conclusions of the Diagnostic Evaluation Team (DET) with respect to material condition. GPU Nuclear concurs with the i
recommendation stated in the Maintenance and Surveillance section of the SALP l
report as follows:
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Recommendation:
"GPUN should establish an effective program to address the need to-improve and maintain the plant materiel condition".
In order to implement maintenar.ce actions for the Preventive Maintenance i
Program additional resources have been committed from departments outside of Maintenance.
These resources, along with existing maintenance resources, will be assigned responsibility by Plant Maintenance Management to prescribe maintenance plans for plant components utilizing existing failure trend data, NPRDS/CFAR data, vendor recommendations, and good engineering judgment.
This process will closely follow the guidelines set forth by the LOSMP Program.
Additionally for those RCM analyses completed and ready for implementation, recommendations made on the components being addressed will be considered in the development of maintenance plans. The products of this effort will be the definition of preventive maintenance requirements, writing of work instructions, and planning and scheduling of the activities.
This effort should make more effective use of our Failure Trend Program in prioritizing the equipment needing attention, utilizing vendor and operating experience where applicable, and start implementation and scheduling of maintenance tasks to address the need for increasing the scope and effectiveness of our Preventive Maintenance Program.
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While the attention to the Preventive Maintenance Program is one piece of the total program to address the materiel condition of Oyster Creek, there still j
remains the need to maintain an overall view of the materiel condition outside of what would be considered in the Preventive Maintenance Program. This requires a realignment of functional responsibility and greater coordination with engineering expertise. Plant Maintenance is the holder of the Materiel Condition issues List previously held by Plant Materiel.
This list, along with the recommendations from the MPR Consulting Firm Materiel Condition
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Study, are being utilized to initiate long-term actions necessary to address j
existing and potential materiel condition concerns, items from this liiting are be being consolidated with the System Status Matrices as they art developed by the Engineering Department system engineer.
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These actions with the utilization of existing processes by which work gets j
identified, budgeted, planned, and scheduled will provide the necessary level of attention to the materiel condition question for Oyster Creek.
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i Several improvements in the area of security were evident during the period, as acknowledged in the SALP report.
There were no reportable security events; i
a significant improvement over the previous period when three events were reported.
Better pre-outage planning efforts averted potential security vulnerabilities and minimized the need for overtime by the guard force.
The
. training and qualification program was considered very effective as evidenced j
by the minimal number of personnel errors, none of which required NRC notifi-cation.
Additional improvements include the repositioning of certain CCTV cameras and the addition of new monitors in the alarm stations.
This has enhanced the intrusion detection and assessment capability.
In addition, tighter administrative controls were imposed on personnel access to vital areas.
It was noted in the report that the security force exhibited a comprehensive
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knowledge of their duties and responsibilities and good morale.
Also, our i
actions taken on fitness-for-duty issues were considered aggressive, reflect-ing our resolve to maintain an alcohol and drug free work place.
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We believe the above performance reflects a very effective security program.
A high level of security ef fectiveness was maintained during the period despite the challenges presented by a major refueling outage.
Weaknesses j
identified during the period were generally described as " minor" by the NRC t
and were subsequently resolved in followup inspections.
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The report notes that corrective actions were often unduly delayed when
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departments outside security were involved.
Recently, a new system was instituted which gives security supervisors the ability to input work requests directly into the computer tracking system.
This new capability eliminates i
much of the review / approval process for routine maintenance tasks and should i
i help to achieve timely action in the future, i
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4 The SALP report notes that some training opportunities were not effectively utilized due to a "very limited security training staff". We agree that some training opportunities were missed. We do not agree that the reason was "very limited security training staff."
In addition to the one full time security instructor noted in the report, there are five personnel in the security and training departments who can be made available to instruct in those areas for which they are qualified on an as-needed basis, for firearms training, there are two New Jersey State qualified range masters and seven qualified range instructors.
In addition, as of July 25, 1991, security instructors are participating in contingency drills.
This will increase the efficiency by which feedback from such sessions is incorporated into the security training program.
GPU Nuclear maintains an effective security program and will continue to search for ways to improve through our self assessment program, management oversight, participation in industry group activities, and continuing dialogue with NRC staff.
Enaineerina/ Tech SuDParl GPU Nuclear concurs with the SALP assessment in this area.
The sal.P report as well as the DE1 report and several inspection reports have recognized a number of improvement initiatives which have led to improved performance.
Several of these are the establishment of senior Technical functions Manager at the site, implementation of the system engineer concept both at the site and corporate headquarters, and improved interdivisional communications.
As recognized by GPU Nuclear and the NRC staff, the major challenge in this area is improving root cause determination techniques and performance. To this end, a root cause standard has been developed and evaluated through applications to specific circumstances.
The root cause standard has proven to be a valuable tool to assure proper reviews and root cause determinations are made. The standard is now being proceduralizert for use.
it is expected this effort will result in improved root cause determinations commensurate with the event consequences.
Therefore, corrective actions will be focused on prevention of recurrence thereby continually improving performance.
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