ML20082D623

% Power Operational Readiness Review

ML20082D623
Person / Time
Site:	Grand Gulf
Issue date:	11/30/1983
From:	MISSISSIPPI POWER & LIGHT CO.
To:
Shared Package
ML20082D612	List: AECM-83-0746, Forwards Grand Gulf Nuclear Station Unit 1 5% Power Operational Readiness Review, Per License Condition 2.C.(3) ML20082D623
References
TAC-56594, NUDOCS 8311220486
Download: ML20082D623 (60)

Text

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.g Attachment to AECM-83/0746 GRAND GULF NUCLEAR STATION UNIT 1 5% POWER OPERATIONAL READINESS REVIEW NOVEMBER, 1983

. Performed by: MP&L SRC Special Subcommittee for Review of Plant Operational Readiness.

Current Members.

Mr. J. F. Groves - Chairman Dr. S. R. Fischer Dr. J. M. Hendrie j Dr. D. W. Jones

-, Mr. T. F. Plunkett Dr. F. E. Tate, Consultant V

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PREFACE The Mississippi Power and Light Co. Corporate Safety Review Committee (SRC) Special Subcommittee for Review of Plant Operational Readiness performed a review of the Grand Gulf Nuclear Station (GGNS) Unit 1 operations prior to the plant proceeding with startup testing beyond 5% power. This review was performed at the request of the SRC chairman in order to fulfill the requirements of the GGNS Operating License Condition 2.C.(3). The results of the review are documented in this report.

The conclusions and recommendations presented ir the report reflect the results of Subcommittee interviews, observations, discussions, and document reviews performed during the October 12, 1983, to November 4,1983, timeframe. The conclusions and recommendations are in the Subcommittee's judgement, correct and appropriate, and are based on the collective knowledge and experience of the Subcommittee members.

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TABLE OF CONTENTS, Section Page I. Status and Readiness of the Plant and Systems Needed to Support Intended Modes of Operation and/or Testing. I-1 II. Readiness of Personnel to Conduct Intended Operation and Testing. II-1 III. Morale and Attitudes of Plant Personnel that Have a Bearing on Safe Plant Operation. III-1 IV. Past Performance in Plant Operations and Adherence to Procedures and Administrative Control s. IV-1 V. Changes in Current Organization With Regard to Experience and Qualifications of Plant Management and Supervisory Personnel Since V-1 Last Evaluation.

VI. Results and Effectiveness of PSRC VI-1 VII. Status of the Plant as Compared to other BWR Startups Based on the Subcommittee's Knowledge and Experience. VII-1

I. STATUS AND READINESS OF THE PL :.T AND SYSTEMS NEEDED TO SUPPORT INTENDED MODES OF OPERATION AND/0R TESTING A. Walk-Thru Inspection of the Plant An inspection of the turbine building, auxiliary building, and  ;

containment was conducted by members of the Special Subcommittee. '

i Housekeeping, but for a few minor exceptions, is judged adequate for power ascension beyond 5% power. Boards, panels and cabinets were orderly and free of combustibles and other foreign material.

4 Observations were as follows:

o Readiness for radiological protection requirements appeared good throughout the plant. Monitors were in place and operative. Radiation protection personnel appeared knowledgeable in their work.

Access control areas were properly arranged and Grand Gulf personnel appeared adequately trained in access control procedures. Doors leading to areas of exposure were properly marked and controlled.

Key card access points have been changed to effect better control of passageways leading from the turbine building to the control building to force personnel to exit through the passageway at the Health Physics station for proper monitoring. The few radiation areas that presently exist were properly posted and controlled, o No fire or industrial safety hazards were noted.

Fire hoses and extinguishers were in pl ace and I-1

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appeared to be well maintained. A few isolated instances were observed where the monthly inspection had not been initialed a few months back, but on balance the fire protection equipment was in good shape and receiving regul ar attention.

o Work activities in progress appeared to be performed under controlled conditions. Good safety practices appeared in use except for the wearing of hard hats. If hard hats are required, pl ant personnel should be required to wear them.

o Preservation of the systems and equipment appears adequate, but could be substantially better. The most significant shortcomings are in the exposed carbon steel piping and other unpainted surfaces, especially in the auxiliary building. The rusted parts and other unpainted surfaces will be more difficult to maintain than well-coated surfaces.

From both contamination control and corrosion protection standpoints, an effort should be made to paint exposed piping, walls, floors, etc.

o Except for some of the lower elevations, plant components and piping were not labeled as to the I-2 A

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system, direction of flow, etc. The Special Subcomittee recommends that a concerted effort be made to label piping and components.

o Numer9us tags were reviewed. Except for two construction tags dated in 1978, all tags appeared val id. It was obvious that an effort had been made to clear construction / jurisdictional tags. The plant tagout procedure appears adequate.

o Most instrumentation had calibration stickers.

Many calibration stickers were checked and this instrumentation was within its calibration period.

Some instruments did not have calibraticn stickers.

The Special Subcommittee did not determine dether the stickers were missing or whether stickers were not appropriate or not needed for these instruments.

Overall, the plant appeared in good condition and ready for power ascension.

B. Control Room Considerable time was spent in the control room. The Special Subcommittee's observations are as follows:

All personnel were conducting themselves in a businesslike manner. Annunciators were promptly responded to. The lines of authority were clear and ware being respected.

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The status of Technical Specification-rel ated equipment is kept in a notebook. The status is not visibly available to the control room staff. A Status Board was available but it appeared not to be in use.

The general appearance of the control room could only be described as cluttered. Prints, drawings, procedures and miscellaneous pieces of paper were scattered. Other items included a rain jacket on the floor, vacuum cleaner tube, and nuts and bolts.

Housekeeping practices need considerable improvement.

Control room access does not appear to be adequately restricted. Strong efforts need to be made to reduce through-flow traffic and to restrict entry to only those personnel needing access.

i The Special Subcommittee recomends that improvements in control room appearance and housekeeping and a concerted effort to control access to the control room be made prior to exceeding 5%

power.

l C. System Transfers and Preop Test Exceptions Preoperational test results and system transfers are processed as summarized below.

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In an effort to best use the manpower available and expedite startup of the plant, several months prior to initial fuel loading MP&L, with NRC concurrence, elected to conduct preoperational test-ing and transfer of systems from the Startup organization to Plant Staff in two stages, Phase I and Phase II.

Phase I consisted of those systems essential for safe fuel loading and open vessel testing plus certain other systems as a matter of convenience. Phase II consisted of the remaining systems.

The intent was to permit initial fuel loading and low power startup testing to progress concurrently with the preoperational testing and transfer of the Phase II systems. Since preoperational testing and transfer of the Phase I systems were included in the operational readiness review conducted by the Special Subcommittee prior to initial fuel loading; this review for proceeding beyond 5% power, except for Phase I preoperational testing open items, has focused primarily on Phase II systems.

Upon completion of preoperational testing of a system, a transfer package containing the complett d test procedure with filled-in in data sheets, a release to plant staff form, a retest log, open and closed retest forms, and a list of open items, if any, j is routed through appropriate individuals and groups for signature, i

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Outstanding test exceptions are identified on the preop test signature page for ready recognition.

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The preoperational test results are submitted by the Test Supervisor through a Group Leader, through the Bechtel Project Startup Engineer and the General Electric (GE) Site Operations Manager if applicable, through MP&L Plant Quality, through the MP&L Startup Supervisor to the Plant Manager. Signature by these individuals or group representatives certifies approval and acceptance of the test results.

The Release of Systems to Plant Staff form bears the following signatures certifying concurrence: Startup Superintendent; Operations Superintendent; Technical Superintendent; and Pl ant Quality Superintendent. System receipt is certified by tha signatures of the Manager, Nuclear Plant Engineering and the Nuclear Plant Manager. Safety-related system transfers are reviewed by the PSRC and the chairman's signature certifies PSRC approval.

A spot check of eleven packages selected at random and discussions with the responsible supervisor indicate that very few exceptions were initiated for the Phase II systems.

The Special Subcomittee noted that C88 (Startup testing instrumentation and GETAR checkout, BOP vibration and thermal l expansion) is listed as a 5% power item. This is tracked as part of power ascension in that test instrumentation is covered in prerequisites of individual startup tests and BOP thermal expansion and vibration are accomplished in conjunction with the power escension program at the various power level test conditions. l l

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l All the Phase II test exceptions and retests (except C88) have been reviewed by the PSRC and are in for final signature by the PSRC Chairman and Plant Manager.

There were several outstanding preoperational test exceptions for Phase I systems at the time of initial fuel loading. To guard against over1 coking outstanding Phase I test exceptions, they were '

carried as open items on the plant's Master Punchlist.

Discussion with the responsible supervisor and spot checks of the- paperwork indicated all the Phase I preop test exceptions but four (which lack only PSRC review and Plant Manager approval) had been satisfactorily resolved or transferred to the Startup Test Program.

The Special Subcommittee recommends that the outstanding reviews and approval signatures for both the Phase I and Phase II exceptions be completed before going above 5% power.

D. Dispositioning of Master Punchlist Items In addition to the Phase I preop test exceptions, the Master Punchlist contained all the outstanding open work items at the time of initial fuel loading. At that time the Plant Safety Review Comittee (PSRC) reviewed the punchlist and provided justification for fuel loading and low-power testing with the open items remaining i

at initial fuel loading.

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The Master Punchlist was dispositioned in a planned manner around the end of 1982 (last issue dated 12/16/82). The method used was to go through the master punch 11st i tem-by-i tem and mark completed those items determined to be completed. The remaining items were then transferred to the computerized logs of other established tracking systems such as for the Design Change Packages (DCP), Maintenance Work Orders (MWO), etc.

On December 29, 1982, an Outage Work Review Board was estab-lished which consisted of the Assistant Vice President, Nuclear, the Plant Manager, the Manager of Nuclear Plant Engineering, the Techni-cal Superintendent, and the Operations Superintendent. The purpose of this was to set priorities and control the scope of the outage work which was then thought to be continuing through January and February 1983. (Modifications to the drywell cooling system shown to be necessary by deficiencies during non-nuclear heatup, review and rewrite of the surveillance procedures and processing related Technical Specification changes, plus numerous other * <ek activities to clear up inadequacies and to minimize the first refueling outage and improve plant availability actually extended the outage to late September,1983. )

The Board reviewed all outstanding work of significance and assigned a priority rank to each item according to specific definitions. The priorities, ranked in importance from 1 through 5, ranged from items which, if not corrected, would cause violation of a Technical Specification or license commitment, a forced shutdown I-8

or a safety hazard, to items of routine work. Tne work force resources were concentrated on Priority 1 ad 2 items.

Work items to be added to or deleted from the outage were presented to the Board for review by the responsible engineer from Technical , Startup, Nuclear Plant Enginering, or Licensing, as applicable. Since the outage lasted considerably longer than the expected two months, the formal meetings with all principals present were discontinued, but the method of the Plant Manager reviewing 4

work to be performed with the " systems" engineers and other involved manager,s and superintendents continued to function throughout the outage.

There is presently a rel atively large backlog of work activities which have not yet been authorized for work. These have been assigned priorities as previously described and, where necessary, milestones have been set for accomplishment. The bulk of these activities are classified as priorities 3, 4 and 5. The Plant Manager is confident that those items necessary for the short-term I

can be performed while the plant is operating or during scheduled outages without significantly impacting startup test activities.

The Special Subcomittee concl udes that al though some work activities may impact startup, there will be no degradation of safety if manpower limitations are imposed and abided by.

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E. Radwaste The Radwaste Supervisor has been in his job since December 1982. He was formally a Mechanical Maintenance Supervisor. His radwaste experience is limited to Grand Gul f and a visit to Brunswick Plant. His previous mechanical maintenance experience is currently proving to be a plus as the radwaste equipment is now being brought on-line. However, his lack of previous radwaste experience is not a positive factor. To overcome this, an experienced consultant is presently assigned to assist the Radwute Supervisor. This consultant should be retained to assist until such time as the Radwaste Supervisor is self-suffkhnt.

Radwaste Operators are presently on a rotating five shift basis with two operators per shift. Performance of the radwaste operation should be carefully observed throughout startup testing to ensure that staffing is adequate to perform the required tasks. The five shift rotation is in place to allow for training one shift every fifth week. This training has not yet started. Emphasis on Radwaste Operator training needs to be improved. There appears to l

j be reasonable confidence in the procedures to operate the radwaste equipment.

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The FUNDA filters (large precott filters) in the floor drain and equipment radwaste systems have operational problems dich must be addressed. Their operational history to date has been very poor and spare parts are hard to obtain. Although operation above 5% is acceptable with these filters, a decision as to their future should be made before exceeding 50% power.

The Special Subcommittee made a limited inspection of the radwaste handling facilities. Radwaste handling areas are being repainted on a selective basis as manpower is avail able. The previous wall coating is flaking away, due to incompatible materials used in successive layers, and has to be completely stripped and a thin layer of the wall surface removed to prepare for recoating.

The areas most likely to become contaminated are being repainted first, with other radwaste building areas to follow een painting crews are available.

The originally-planned drumming facility for wet solid radwaste has been abandoned as unworkable. Large radwaste liners will be filled directly from the waste holding tanks and other sources and eventually removed from the site. Chem-Nuclear is supplying the liners. The new system appears workable and should be adequate for the early operating years of the plant. An overhead crane, built to handle concrete-loaded 55-gallon drums, is undersized for the 12-ton Chem-Nucl ear liners. It should be modified, so that the full capacity of the liners can be used.

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A neber of design changes need to be made in the wet solids 4

handling systems before any appreciable buildup of radioactivity )

occurs. The changes will be more difficult to make after the systems are contaminated. One of these changes involves routing

- various radwastes such as the condensate demineralizer spent resins directly to the Chem-Nuclear liners rather than into the limited-volme waste holding tanks. Another involves moving the liquid decant pumps and waste monitoring pumps, and other components that must be maintained such as valves, from just under the waste holding tanks to a shielded location. Their present locations make them nearly impossible to maintain. These and other design changes are underway or are pl anned. It is importan+. that changes, essential for the operability of the radwaste systems, be completed before radiation levels in the radwaste cells become appreciable, i

F. Diesel Generators Because of concerns expressed industry-wide and locally regarding reliability of diesel generators (DGs) and, in particular, Transamerica Delaval diesels, the Special Subcommittee reviewed the status and performance of the GGNS DGs.

1 On September 7, 1983, prior to comencing this operational readiness review and imediately after a fuel oil fire damaged the Division I DG, the Chairman of the corporate Safety Review Committee (SRC) initiated a review of the DG activities. Specifically, at that point in time he asked this Special Subcommittee to look at DG testing and apprise him of the following:

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(1) What testing remained yet to be done on each of '

the three DGs. l (2) What retesting was planned following restoration of Division I DG fire damage.

(3) What additional testing or other actions the Subcomittee recomended to improve DG reliability The Special Subcomittee's response to the numbered items, as documented in the Subcomittee's Memo to the SRC Chairman, was as follows:

Item 1: Testing Yet To Be Done Plant management informed us that all tests in the 18-month surveillance procedure had been satisfactorily completed for Diviskas II and III DGs and no further testing except routine periodies was planned.

For Division I DG, all tests of the 18-month surveillance procedure had been completed prior to the fire except Test 7, LOP and LOCA after 24 Hours at 100% Load. Thus by the test program, Test 7 for Division I DG was the only outstanding test yet to be performed on any of the three DGs prior to criticality.

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Item 2: Retesting Following Fire Damage Restoration Retest plans following fire damage restoration were to repeat tests 2, 3, 6, 7 and possibly 4 of the 18-month surveillance procedure for Division I DG only since fire damage was confined to the Division I DG area and no interacting features or logic of the other DGs were involved.

The basic plan was to accomplish the restoration work by use of MW0s in which retests for the component being replaced or restored would be specified. Replacement instruments and pressure switches would be calibrated and then tested in their loops. The preoperational test procedures were to be reviewed to ensure no important feature was overlooked in the retest effort.

Upon completion of restoration, and following post maintenance functional checks, the selected tests of the 18-month surveillance procedure identified above would be performed.

Item 3: Additional Recommendations The Subcommittee recommends the following as a minimum:

a) Full restoration of the Division I DG should be completed and the entire 18-month I-14

surveillance procedure, 06-0P-lP75-R-0003, should be rerun prior to next i criticality.

b) The root cause of the fuel line failure should be identified and appropriate corrective action, i.e., addition of pipe ,

supports, piping material changes, fitting changes, etc., should be taken.

c) Inspect Divisions I, II and III DGs for piping arrangements and connections similar to that which failed and apply corrective measures as necessary.

4 d) To further increase confidence that the DGs will perform their intended safety function, prior to exceeding 5% reactor power ,

Division I, II, and III DGs should each be run under close scrutiny for the equivalent of one week (168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />) at greater than 50%

load.

e) Develop a short- and long-term vibration monitoring program for Divisions I and II DGs to identify any existing problems and to I-15 4

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improve detection of component or primary equipment degradation before fail ures occur, f) Establish a preventive maintenance program based on comprehensive review of root causes of previous failures at GGNS and throughout the industry. In particular, the probic-ms with Delaval DGs at the Shoreham Station should be reviewed and measures taken as necessary to assure that these problems are not present or are corrected at GGNS. In view of the cracking of crankshafts of the Shoreham diesel engines, a careful review of design differences and fabrication and opera-tional histories of the Shoreham cnd GGNS engines should be made to determine whether similar f1aws might be present in the GGNS engines. For long-term assurance of the integrity of the GGNS crankshafts, considera-tion should be given to performing dye l penetrant, ul trasonic, or other nonde-

, structive inspections of the crankshafts at some time before the start of the second fuel cycle.

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g) Develop a closer working relationship with Delaval and consult with them with respect to modifications to prevent recurrence of equip-ment problems experienced at GGNS and throughout the industry. One of the areas that should receive special attention is a long-term program foi upgrading Del aval-suppl ied, engine-ass' fated piping, tubing, fittings, and welding to a higher level of quality, in view of the safety importance of the DGs.

h) To reduce the possibility of personnel error, increased emphasis on pre-action pl anning sessions for the persons involved are recom-mended for planned operational and mainten-ance activities. The trend of personnel error should be closely monitored and addf-tional training be provided as indicated by the trend and analysis of events.

l The above recommendations together with appli-cable recomendations from responsible individuals in the line organization should be incorporated into a comprehensive DG reliability improvement program. The program should be developed and implemented on a high priority

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basis. Progress should be monitored regularly to assure improved DG performance.

Although additional information is becoming available almost daily, the Subcomittee believes the findings and recommendations were valid at the time they were promulgated, and that they are still valid today.

In addition, MP&L has recently hosted an industry-wide informa-tion meeting on DG reliability and related problems. Interest and attendance were reported to have been good, but no major new infor-mation to alleviate the concern for DG reliability was revealed.

An extensive internal report on the GGNS DG's has been prepared by MP&L. This report delineates design criteria, preoperational and operational history, reliability enhancements and industry compar-isons. The information from this report has been summarized in MP&L's letter (AECM-83/0653 dated October 19, 1983) to the Nuclear Regulatory Comission Office of Nuclear Reactor Regulation. The report identifies design similarities and differences t.etween the GGNS and Shoreham DGs.

l Although the root cause of the crankshaft failures at Shoreham is not known because the failure analysis is incomplete at this time, MP&L believes there is reasonable assurance that the GGNS Delaval crankshafts will not fail in a mode similar to that i

experienced by Shoreham and that the engines will continue to operate as designed.

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n-The Special Subcommittee concurs with MP&L's finding and concludes that, when those items recomended for completion by the Subcommittee in its special report are completed, the plant can be operated to the next Subcomittee evaluation point (50% power).

G. Agastat Relays i

While conducting the 18-month DG surveillance tests, several Agastat relays failed to perform their intended function.

Failure mode testing and reliability analysis were coopera-tively performed by MP&L,. Amerace Corporation (the manufacturer) and General Electric (the supplier) to detennine the root cause of the failures.

It has been determined that the failures were due to service aging of normally energized relays in a mild environment in combina-tion with mechanical configuration and tolerances of the internal parts specific to pre-August 1977 relays. The calculated service life, based on test data, for these Agastat GP Series relays in a continuous operating mode (normally energized) is 4.5 years. The calculated service life for normally non-energized relays is greater than 40 years. GE recommends replacement of normally energized 4 relays at GGNS over the next two years.

MP&L has determined by inspection the location of all the safety-related GP Series relays. MP&L will replace, as required, affected Agastat GP Series relays with relays which are of a 1-19

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different design. MP&L plans to implement a more aggressive schedule than that proposed by GE. Replacement of the safety-rel ated Agastat relays which are normally ener., 'd is expected to be completed den the electrical divisions are out of service during the Battery Surveillances in the spring of 1984.  !

l The Subcomittee concludes that the actions taken and committed to by MP&L will be adequate to ensure satisfactory performance of the systems controlled by Agastat relays.

H. Intergranular Stress Corrosion Cracking (IGSCC)

There are 24 welds located on the reactor recirculation system piping which are susceptible to intergranular stress corrosion cracking unless mitigating action is taken. MP&L has formally comitted to performing mitigating techniques on the IGSCC susceptible welds by the first refueling outage. Al though not

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absolutely certain, it is possible that some irreversible damage may occur to these welds during the first fuel cycle. MP&L has advised the NRC of their intent to implement the mitigating action during an outage in the March-April 1984 timeframe, subject to the

.s uncertainties of the startup test program.

.; The Subcommittee believes the planned action is adequate to s limit IGSCC in the susceptible welds. MP&L is encouraged to implement the mitigating measures as soon as practical.

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I. ITE Breaker Trip Units Failures have occured in the solid state trip devices on the ITE electrical bregkers throughout the industry. Failure of the I trip unit may produce spurious trips of the breaker or may prevent the breaker from tripping at all.

GGNS Unit 1 had 59 of these trip units in safety-related appli-cations. Presently all have been changed out with an improved design except 10 which are utilized in applications such that it is

, impractical to change them out while operating the reactor.

1 The PSRC reviewed this situation in a meeting on October 18, 1983, and concluded that in view of the redundancy of equipment and the overlapping of protected zones, it would be satisfactory to continue with low power testing, but that the 10 remaining trip units should be changed out before operating above 5% power.

f The Special Subcommittee concurs with the PSRC decision.

J. Conclusions The Special Subcommittee concludes that when the items identified for completion prior to going above 5% power are j finished, the plant and systems will be ready to support startup I

i testing to the next evaluation point at 50% power.

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II. READINESS OF PERSONNEL TO CONDUCT INTENDED OPERATION AND TESTING A. Interviews With Plant Staff Representatives The Special Subcommittee interviewed a number of individuals from various levels of the Plant Staff as part of its inquiry into readi-ness of personnel for operation and testing above 5% power and to provide a basis for evaluating personnel morale and attitudes. The interviewees included the Plant Manager; Plant Quality Superintendent; the Assistant Plant Managers; the Operations Superintendent; Technical Superintendent; Maintenance Superintendent; first line Supervisors in the maintenance organization from the Instrumentation and Control Group, the Electrical Group, and Mechanical Group; three Shift Super-intendents; three Shift Supervisors; three A Operators; three B Operators, a Shift Technical Advisor, and one of the BWR-experienced Shift Advisors who is presently a consultant to the Operations s

Superintendent. (The Subcommittee had discussions with many other

_ plant staff and other MP&L people on assorted subjects: the interviews cited here were those for the particular purpose of assessing personnel readiness, morale, and attitudes.)

The interviews indicate that plant staff members are confident of their ability to operate the plant safely and are ready, and in most cases eager, to continue the startup beyond the five percent power level . Those feelings are reflected at all levels of the plant j staff.

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l There seem to be several reasons for those feelings of confidence and readiness to proceed with the startup. The first is that the great majority of plant staff members, particularly the operations group, have been working toward this point in the startup for a long time. The extended shutdown after initial criticality has provided more than a year for operations personnel to consolidate their under-standing of plant equipment, systems, and procedures.

The second reason is the relatively smooth progress of operation and testing during nuclear heatup since the restart in late September.

'here have been some equipment problems and a number of changes and adjustments found necessary in operating and surveillance proceduru.

These have been dealt with in a competent manner and the operations and testing have gone forward at or a little faster than the scheduled ,

rate. The successful operating experience in the restart has rein-forced the plant staff's confidence in its ability to operate the plant and in its readiness to continue the startup. The successful operation to date also indicates that changes in plant equipment, systems, and procedures made over the extended shutdown are being assimilated successfully by the plant staff.

The third reason is that startup testing and training evolutions <

are being carried out at a deliberate and considered pace. The opera-tions and maintenance staff members interviewed all felt that testing was proceeding at a comfortable speed, with adequate time for careful

! consideration of plant conditions, the next steps to be made, surveil-l l

lances and other work being carried out at the time. Maintaining an unhurried pace in the startup has been an important element in the 11-2

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successful operation to date and is especially important in view of the lack of experience of the plant staff in BWR commercial operation.

While conducting these interviews, the Special Subcommittee became aware of indications that discrepancies might exist in the processing of certain aspects of the operator's basic training (Qual card signoffs) and license applications. The Special Subcommittee members brought the matter to the attention of the Plant Manager and MP&L's executive management and suggested that:

1) W&L conduct an investigation to determine whether or not significant discrepancies existed, and

2) MP&L prepare and implement (if necessary based on the findings) a plan for recovering from the training short-fall s.

MP&L immediately named an investigating team and initiated an investigation which was begun the next day.

4 Because of this new investigation and other reviews and

evaluations pending and in progress, the Special Subcommittee did not l

directly pursue the training matter further, choosing rather to base corrective action recommendations on the outcome of the l

l investigations.

The Special Subcommittee recommends that, when the investigations l are complete, any supplemental training required to correct training l

qualification shortfalls be implemented on a case-by-case basis for individuals. The matter should be fully resolved before progressing above 51 power.

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B. Shift Organization The plant is currently operating on a four-shift basis because the number of licensed people has been marginal to support five-shift operation. The four Senior Reactor Operators awaiting issuance of their licenses will bring the SR0 list to 16 and provide a sufficient cadre of SR0's for five-shift operation, training, and operations management. . The change to five shift operation, which is really necessary for long-term maintenance of a proper level of training and

, requalification work should be accomplished early in November.

l The shift crews generally prefer stability in shift assignments so that they get to know each other and can feel confident in working together. Additionally, shift stability tends to foster team spirit and camaraderie. The reassignments to form five shifts from the present four will cause a temporary unwelcome perturbation. The present schedule for the change will allow the five new shifts adequate time for shaking down and the shift members to adjust to one another before continuing the startup beyond 5%. The company and plant management have declared an intention to try to maintain the stability of shift crews after the change to five shifts.

For reasons that are not clear to the Special Subcommittee, there seem to be difficulties in establishing the Shift Clerk position as a regular 198L shift job. The job is now covered by contractor person-nel . These difficulties should be attended to promptly. The Shift Clerk serves an important function by keeping the Shift Superintendent free to concentrate his attention on plant operation. The Shift Clerk 11-4

t position was' committed to by N&L in the Operations Enhancement Pro-gram, presented in March,1983. Full implementation of that commit-ment should have been possible by now.

Shift crews are adequately manned and meet 10CFR50.54 paragraph M criteria. On the 5-shift rotation, the standard shift manning will include a Shift Superintendent and a Shift Supervisor (both SR0's),

two licensed Reactor Operators, three non- licensed Nuclear Operators, i

two Auxiliary Operators, a Shift Clerk, a Shift Technical Advisor who is a graduate engineer, and a Shift Advisor who has previous licensed experience in commercial BWR operation. Under the shift team concept, the Shift Technical Advisor and Shift Advisor would be permanently assigned to a particular shift crew and rotate out for training with them. The Shift Clerks should also be permanently assigned to each shift crew, rather than rotating among the various shifts. These changes should enhance the team feeling of the shift crews.

• Each shift unit also has a radiation protection representative and maintenance supervisors and craftsmen assigned from the Instrumen-tation and Control, Electrical, and Mechanical Sections. The avail-ability of maintenance personnel on the back shifts, in particular, should be an asset in dealing rapidly with equipment problems. In addition, during the startup period, a startup engineering unit is present on each shift. This consists of one MP&L Startup Test Engineer and two General Electric engineers: one, the Startup Test and Operations Engineer; and the other the Test, Design, and Analysis Engineer.

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., m.___ _ . . . - ,, _ _ . _ . . _ , , _ , _ . ___,_.._.,_._r . . ~ . . _ - . _ , _ . _ _ _ , , . , , _ . . _ , _ , . , , . . . _ _ _ . . . _ . . , _ . . _ _ , , , , _ . _ . . . . _ _ _ _ , _ _ _ _ , . _ _______,,___

C.. Shift Staffing and Experience The training " pipeline" that supplies licensed personnel has several classes in progress and seems capable of maintaining the licensed personnel staff at adequate levels. The recent addition of four SRO's marks a substantial improvement in the number of licensed personnel and the prospects for the future are encouraging.

i The staffing levels for non-licensed groups appear generally adequate although there are some areas that plant management will have to watch with particular care. One of these areas is the maintenance group, particularly in the electrical and mechanical sections.

Staffing may not be adequate to keep up with all maintenance

activities over the long term. At the moment, preventive maintenance is not being carried out in all areas at a rate appropriate for long-term operation. That is a result of attending first to required surveillances and next to work on essential design change packages and then to the corrective maintenance associated with starting up of plant systems. Also, there has been a natural reluctance on the part of Operations in the early days of the startup to have equipment removed from service and activities going on in the plant that may

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limit operational flexibility or distract attention from the primary job of startup testing. These conditions should change, as the startup is completed, and a more normal ratio of preventive to corrective maintenance work is established. That should also allow a reduction in the backlog of maintenance work- orders, now approximately 1200 in number. If the backlog of maintenance work of all kinds does II-6

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not show signs of decreasing in the next six months, increases in maintenance group staffing should be considered or other measures taken to assure that essential maintenance tasks are being done in a timely manner.

Operations staff personnel have assorted nuclear Navy experience and some experience from jobs at commercial nuclear plants. No one on the Operations staff has been previously licensed on any commercial (PWR or BWR) nuclear plant. To provide on-shift commercial operating experience, MP&L, per the GGNS Operating License, has hired a group of

., previously licensed experienced BWR SR0s to act as on-shift advisors.

Compensation for the lack of BWR operating experience on the MP&L Operations staff is provided in part by the presence of the experi-enced Shift Advisors, in part by the knowledge of the plant possessed by the MP&L licensed and unlicensed operator personnel, and in part by 1

the careful and deliberate pace of the startup schedule. The Special

S'2bcommittee believes that the use of the experienced shift advisors coupled with the paced startup schedule and operator knowledge of the plant compensates for the lack of commercial experience and, l therefore, the plant staff is ready to proceed with the startup program. The good operating experience since the restart supports this view. A corollary is that it will be important that the rest of the startup schedule, from the 5% level on to full power, be carried out in a careful, deliberate, and unhurried manner.

I D. Utilization of BWR Shift Advisors l The BWR-experienced Shift Advisors seem to be utilized in a II-7

reasonable way. During the extended outage, the Shift Advisors tended

to work more as technical assistants to the Shift Superintendents in

processing maintenance work orders, design change packages, etc., than as operations advisors. Since the restart that situation has changed and the Shift Advisors are once more back in the control room during significant evolutions, observing the progress of the testing, responding with advice to the shift crew when asked, and offering suggestions and cautions as their experience may indicate. The Shift Superintendents and Shift Supervisors use the available BWR experience of the Shift Advisors by noting their cautions and suggestions and by asking for advice when they feel they need it. There is no indication that the Shift Superintendents and Supervisors are becoming overly dependent on the Shift. Advisors, or lack confidence in their own knowledge of the plant and procedures. Some additional directions are being issued by plant management on the role and use of the Shift Advisors to clarify further the function. Even without this guidance, the Special Subcommittee believes that the Shift Advisors are being utilized in a reasonable way thus far.

( E. Summary l The Subcommittee concludes, from its interviews and associated j discussions and in view of the good operating record since the restart; that, contingent on satisfactory completion of any required j supplemental training resulting from the previously noted investi-l gation, the plant staff is ready and able to conduct the intended l

l- operation and testing of the unit through the next phases of the startup. Plant staff members are confident of their ability to l

11-8 l

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operate the plant safely and are ready to move on to the next phase of the startup. Although the Special Subcommittee did not formally examine individuals as to their knowledge of the plant, based on the Subcommittee's observation of activities in progress and on performance to date, the Operations staff is adequately prepared and appears to have an adequate knowledge of plant systems and procedures.

The Operations staff has obtained a reasonable amount of experience in operating the plant systems in various preoperational checkout and testing modes and in the startup to date through 5% power. The plant Operations staff lacks commercial BWR experience, but experienced Shift Advisors are on duty as part of each Shift Team. Shift manpower levels are adequate. MP&L and General Electric Startup Engineers are assigned to each operating shift and, together with the Shift Technical Advisor, form a cadre of graduate engineering expertise on each shift. The Special Subcommittee recommends that the five shift

rew rotation be implemented prior to continuing with the plant startup beyond 5% power. The Special Subcommittee also notes that the startup is being carried out in a deliberate and unhurried manner and recommends that the schedule on through commercial operation proceed in similar fashion.

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II-9

III. MORALE AND ATTITUDES OF PLANT PERSONNEL THAT HAVE A BEARING ON SAFE PLANT OPERATION The interviews carried out by the Special Subcommittee in connection l with its investigation of the readiness of personnel to conduct intended operations and testing (Part II) also provided a basis for assessing the morale and attitudes of plant staff as related to safe operation. In brief, morale is good to excellent at the upper levels of plant management and seems to decrease monotonically to no better than average, or a little worse, among rank and file licensed and unlicensed nuclear and auxiliary operators. Attitudes towards safety are much more uniform with all ranks clearly intent on maintaining safety and adhering to plant procedures and confident of their ability to do so.

Delays in achieving the startup of the plant have caused disappoint-ment and frustration. At the same time a great deal of work was scheduled to be completed and a high level of effort was required. A consulting psychologist was employed to talk regularly with the management and supervisory personnel and make suggestions on ways to keep people involved l and reasonably content. Employee meetings were held by management to '

foster communication and understanding. In -addition, monthly management seminars were held to assist managers with techniques to reduce the effects of stress and improve their management of time. Other seminars were directed at motivational methods and the improvement of communication skills.

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Morale in the working ranks seems to have improved somewhat with the restart and with the good operating experience accrued to date. There is some prospect that it should continue to improve in the future as some of the conditions that have depressed people's feelings are ameliorated.

Plant staff still shows the scars of heavy overtime for extended 5

periods that was required to complete the recent outage and prepare for restart. The overtime situation has improved but the operating staff is still close to Technical Specification overtime limits because the four-shift operation leads to such things as the annually-required fire brigade J

training being carried out on what amounts to an overtime basis. Other training also appears as overtime in a four-shift configuration. Even the Special Subcommittee interviews added to the overtime burden of the

! operating staff since these had to be carried out off-shift. The conversion to five-shift operation should be a considerable help in getting the overtime situation under control and reducing the depressing effect of excessive overtime on people's states of mind.

I Another aspect of the five-shift operation that should be an aid to morale is the stability that is expected in the shift team concept now accepted by plant and corporate management. In the past there has been substantial shuffling of shift personnel in order to make up the required crew strengths. The limited number of licensed operators, both SRO and RO, has worked to make the licensed personnel group particularly vulner-able to such shuffling. The operators clearly prefer stable team situa-tions where they can come to know one another, one another's strengths and weaknesses, and the ways of working of the Shift Supervisor and Super-intendent.

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The level of cooperation and connunication among departments of the plant (notably Operations, Maintenance and Security) was reported to have improved -significantly in the past year. Shift turnover meetings include 1

representatives from departments which are involved in the work being

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scheduled. This approach has resulted in a team effort toward accomplish-ing desired goals and has helped boost morale as well as improve l scheduling of time.

l Some problems with plant procedures are noted in Part IV of this re-port, notably with the speed and efficiency with which requested procedure changes are converted to Temporary Change Notices (TCNs) and subsequently, the rate at which TCNs are incorporated into procedure revisions. Both these aspects are an irritant to the operators and improvements would improve morale.

Union negotiations have been in progress recently. There do not seem l to be any particularly difficult points as regards nuclear plant staff in the negotiations this year but the mere fact that negotiations are going

. on seems to sensitize all groups in ways that are not especially helpful to morale.

The most serious factor affecting morale at the present time seems to be the questions raised about training records and Operator Qualification i Cards. Most of the operators do not seem to have much admiration for the l-Training Department anyway, feel!ng that they (the operators) have acquired their knowledge of the plant and the procedures and Technical Specifications more through their own efforts, and almost in spite of Training, rather than due to any great help from Training. Now they find l that their training records and license applicetions, as compiled by Training, have some irregularities and they may hr.e to do some remedial training and checkouts.

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9 It is nst surprising that many of the operators are upset over the matter. Nor is morale helped much by the impending NRC investigation about which rumors of subpoenas and lie detector tests are circuliting through the Operations staff. Some of the operators are not happy with the adequacy of training they have received on design changes carried out during the recent extended outage and on such general background matters as reading electrical drawings.

i Improvement in the training situation has been underway for some time. The near-term measures have involved bringing in experienced BWR operators (SR0s) from a contractor as instructors. These people, however, have experience on older BWRs: the BWR-6 systems of Grand Gulf are, in part, new to them and they lack detailed knowledge of the plant, the pro-cedures, and the Technical Specifications. That has not endeared them to the MP&L operators, who know the plant and the procedures well, although the operators do appreciate the new instructors' problems in attempting to simultaneously learn the plant and procedures and also instruct. The situation should improve substantially as the new instructors complete t

their own training exercises and become SRO-certified on Grand Gulf. Some immediate help is forthcoming with the prospective transfer of one MF&L SR0 from Operations to Training to take charge of operator training. For

the long term, manning the Training Department with shift-experienced SR0s from the MP&L Operations staff is the preferred and proper way to achieve a fully competent and respected training operation.

There are prospects for improvement in all of the various adverse-to-morale factors currently influencing the operators and; on balance, the operators seem to be bearing up rather well. Performance does not seem to be much affected. The positive effects of having the plant in operation at long last and of successful accomplishment of the startup tests and evolutions are most important to morale. Continuing on with the startup l

III-4

program and bringing the secondary plant into operation will be a major step forward in this regard.

The Special Subcomittee concludes that morale and attitudes of plant personnel, as regards safe operation, are sufficiently good for continuation of the startup program beyond the 5% power level. As noted, morale is not high among rank and file personnel, but has iraproved with the operation to date and should improve substantially after resolution of the training record problems and with continuation of the startup. Most important to the Subcommittee's conclusion is the finding of a uniformly positive attitude on the part of the plant staff toward safety and adherence to procedures.

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IV. PAST PERFORMANCE IN PLANT OPERATIONS AND ADHERENCE TO PROCEDURES AND ADMINISTRATIVE CONTROLS Plant staff performance with respect to plant operations and adher-ence to procedural administrative controls was evaluated. Emphasis was placed on evaluating personnel procedural adherence problems as opposed to equipment related problems which are reported in Material Nonconformance Reports. Specific attent'on was addressed to the control of surveillance testing and temporary alterations. Past performance on procedure adherence was reviewed and trended by evaluating Incident Reports (irs),

Plant Quality Deficiency Reports (PQDRs), Corrective Action Requests (CARS), and NRC violations.

A. Surveillance Test Procedures Following discussions with the NRC about problems associated with the surveillance test requirements specified in the Techraical Specifications and the issuance of NRC's Confirmation of Action-letter on October 20, 1982, a Surveillance Review Program was insti-tuted. A Surveillance Review Team consisting of a group avereging 20 to 25 engineers (peak staffing approached 50) was esteb11shed in November, 1982. The review program provided a detailed technical 1

review of all Technical Specification surveillance requirements and their implementing plant surveillance procedures.

The review process identified 160 surveillance procedures which were found to have technical inadequacies either in the procedures or in the surveillance requirements of the Technical Specifications.

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The surveillance tests covered by this group of 160 p*ocedures were rerun prior to the September 25, 1983 criticality.

At the request of the Chairman of the MP&L Corporate Safety Review Comittee, the Subcommittee for Review of Plant Operational Readiness reviewed the surveillance procedure rewrite effort. This review was performed during the June - August,1983 timeframe.

The Subcomittee found that a thorough review had been con-ducted by a qualified team to insure that Technical Specification surveillance requirements were properly covered in plant surveil-lance procedures.

B. Surveillance Test Performance The Technical Specification surveillance testing program was reviewed with respect to test scheduling, handling surveillances during mode changes, failed surveillance tracking and test result review.

The Maintenance Planning and Scheduling System (MPSS) is the overall plant system for scheduling and tracking surveillance tests.

However, due to a lack of confidence in the new computerized MPSS system, each department currently also tracks their specific surveillances manually. The manual tracking provides an excellent cross-check of the MPSS. Although MPSS is slowly building credi-bility among the plant staff, it is an off-line system which does IV-2

not have real-time interaction capability. It would be desirable to make 195S an on-line system to make it responsive to plant staff's needs.

The involvement of shift supervision (i.e., Shift Superinten-dent and Shift Supervisor) in surveillance testing is satisfactory.

They are provided a saily schedule from the MPSS and are responsible for release of equipment for performance of surveillance testing.

Each department has a surveillance test completion review pro-cess in place. However, the fact that some test results go through the review process with failed results being approved as satisfac-tory indicates the system is not foolproof. Test data sheets that were reviewed did have acceptance criteria listed that could be compared to actual test results.

The Plant Quality organization does not play a major role in the surveillance test program. They have minimal hold / witness points in the surveillance procedures and do not review the normal i

or routine surveillances prior to the completed test results being placed in the vault. Surveillances that are performed as a result of maintenance work are reviewed by Plant Quality.

i The Surveillance Group, which operates the MPSS, does a 10%

review of surveillance test results. The review is primarily a review of proper test data sheet completion and is not a review of actual test results versus acceptance criteria.  !

IV-3 t

The review of test results from a technical basis ends with the department's review. There is no independent review of test results versus acceptance criteria outside the department responsible for performing the test. The test results review process could be strengthened. This has to start with the individual performing the test being charged with verifying that the results are satisfactory.

The accompanying department reviews must be thorough. "aring power ascension testing, the Special Subcomittee recomends that an independent group be assigned the responsibility to review a portion of the surveillance test results to ensure acceptance criteria are met.

Overall, the Special Subcommittee feels that the Plant Staff clearly understands the importance of proper and timely completion of Technical Specification surveillance testing and its relation to plant safety.

C. Temporary Alterations

. Temporary alterations (TAs) were being used during the preop-erational test program to document changes required during perfor-mance of tests. The use of TAs, in this fashion, resulted in a large number of TAs generated. Also, the procedure governing use of i TAs had undergone numerous revisions resulting in plant staff and i

startup test personnel lacking proper knowledge to ensure adherence to the TA procedure.

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A review of the Quality Assurance (QA) involvement in assessing proper use of TAs identified a number of formal audits performed since fuel loeding. To improve procedure adherence, a commitment was made by plant management that two successive monthly audits of TAs must be performed and have no findings. This commitment was met in January 1983. An additional audit performed in May, 1983 indicated that improved performance in the use of TAs was sustained.

Presently, there are 59 TAs open. A subcommittee of the PSRC is doing a re-review of the 50.59 safety evaluations on the open TAs. Considerable improvement has been made in the processing of TAs. The general philosophy appears to be to incorporate alterations in approved procedures as opposed to using TAs. This philosophy should be encouraged. Additionally, the Subcommittee recommends that the ongoing review of the existing 50.59 evaluations on outstanding TAs be completed prior to exceeding 5% power.

D. Adherence to Procedures t

Plant Staff performance with respect to procedural adherence since receipt of the Operating License was assessed by reviewing Incident Reports (irs), Corrective Action Requests (CARS), Plant i

9 IV-5

Quality Deficiency Reports (PQDRs), and NRC violations as described in Inspection Reports. The results of this evaluation indicate a downward trend in the number of reported procedural violations since fuel loading.

After the issuance of the low power license, there was a signi-ficant increase in the ntnber of procedure adherence violations.

This increase was attributed to:

1) Lack of awareness by plant personnel of all administra-tive procedures affecting their job, and

2) Perception by plant personnel that management was more concerned with meeting schedules than compliance with procedures.

An Enforcement Conference on adherence to procedures was held on January 17, 1983. At this conference, MP&L presented a program to improve procedure compliance. An analysis of procedural adher-ence problems by MP&L at that time indicated 60% of the procedure violations were personnel errors and 40% were the resul t of technical inadequacies in the procedure itself.

To clarify any misconception by Plant Staff about the need to comply with procedures, on January 31, 1983, MP&L President D. C.

Lutken addressed the GGNS Staff and indicated that "Our primary emphasis is regulatory compliance and procedure adherence."

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After Mr. Lutken's speech, management controls were established to reduce procedure violations. These controls included:

1) Periodically advising all Nuclear Production Department personnel of the necessity for following and adhering I to procedures.

2) Revising personnel performance evaluation procedures and forms to include procedure adherence.

3) Providing guidelines for the use of progressive disci-plinary action to control procedure adherence.

4) A review by MP&L management of significant instances of non-adherences to procedures.

5) Ensuring that procedural violations are investigated and appropriate action taken.

Other actions taken included the development and implementation of a program to train personnel on relevant administrative level procedures and to conduct a review of administrative procedures to assure they are realistic, effective and reflect requirements.

Discussions with plant staff during this operational readiness assessment indicated a strong desire on their part to ensure that procedures are adhered to. However, there continue to be minor but nagging problems with the procedures, in particular, with the efficiency of the process for amending them. Many of the surveil-lance procedures for the unit are new revisions produced in the IV-7 l

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surveillance review program of the past year. There are inevitably corrections that must be made to them as experience indicates particular surveillance steps have to be carried out in a manner different from the new procedure. In the operating procedures and maintenance operating instructions, needs for various changes and corrections are identified as the startup program goes on and testing and plant evolutions are made.

The Temporary Change Notices (TCNs) by which these corrections are executed are requested by plant staff personnel who identify a difficulty with a procedure as written. After review and approval, a TCN to a procedure is issued to holders of each of the controlled sets of procedures. This process does not always take place as expeditiously as operators would like and sometimes results in no TCN being issued, or a mis-distribution that leaves one of the controlled procedure copies without the issued TCN for a time until the error is caught.

There is a problem also with getting the TCNs processed into revisions of the procedures and the revised procedures reissued to the operating groups and other holders of controlled copies. There are currently approximately 600 TCNs that are being processed or are l awaiting processing into revised procedures.

l The bulk of these TCNs are in surveillance procedures and maintenance operating instructions. About 100 TCNs (of the 600) l

! IV-8

are older than the 90 days prescribed by plant administrative procedures as the time within which a TCN must be absorbed into a procedure revision. Strong efforts are underway and must continue to eliminate this backlog of overaged TCNs by mid-November.

4 Some procedures may have as many as 5 TCNs appended to them, which makes them more difficult to follow and understand. The procedures are useable with TCNs attached, but are not as convenient as procedures free of added documents.

As the startup program goes on and new procedures are exer-cised, particularly in putting the secondary side of the plant into operation, there are bound to be additional requests for changes in 1 the procedures. The Special Subcomittee recomends that plant management keep a careful watch on the rate of processing of TCNs to see that the situation is progressively improving rather than getting worse.

The problems cited with the plant procedures are by no means disabling and do not imply any loss of safety. This point was made by some operations staff members who were particularly critical of l

! the procedures situation. However, it is clear that both operator l

morale and convenience of operation would be benefited by more l

expeditious processing of requests for TCNs in the first place and of incorporating TCNs into revised procedures in the second place.

IV-9 l

An attempt to assess recent procedural violation trends was made by evaluating all irs written in the June - September, 1983 time frame. This review identified 13 possible violations which amounted to about 3% of the total irs written during the period.

A review of the 13 procedural violations produced no specific pattern as to the cause. It was noted that all irs are given a thorough and independent review by Nuclear Plant Engineering personnel. The resul ts of these reviews are given wide 6

distribution.

The Special Subcomittee recommends that MP&L management continue to stress procedure adherence. Also, to ensure procedures have the confidence of plant personnel, a dedicated effort to incorporate temporary changes into procedures in a timely manner is needed.

Finally, in discussions with plant personnel, there appeared to

, be some confusion as to what document to use to report a procedural violation (i.e., IR or PQDR). The Special Subcommittee recommends that consideration be given to utilization of a single reporting system.

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4 V. CHANGES IN CURRENT ORGANIZATION WITH REGARD TO EXPERIENCE AMD QUALIFICA-TIONS OF PLANT MANAGEMENT AND SUPERVISORY PERSONNEL SINCE LAST EVALUATION The Special Subcommittee's review focused on changes in organiza-tional structure and qualifications of personnel that could impact the safe operation of the plant.

A. Organizational Structure The offsite organization and GGNS-1 Unit organization, as pre-i sented in the Technical Specifications, have been modified since fuel load. Minor restructuring in the Nuclear Services Organization has occurred; the Manager of Safety and Licensing position was I

eliminated and the positions Manager of Nuclear Safety and Compliance and Manager of Nuclear Licensing were created. The functional responsibilities of the individuals in these new positions remains essentially the same as that prior to restructuring.

The GGNS-1 Unit organizational structure has been changed significantly in the past month. Figure 1 presents the current plant staff organization. The new organization employs three Assistant Plant Managers (APM) to carry the workload previously

} performed by a single APM and the Nuclear Support Manager. Three major functional areas instead of two reduces the span of control of )

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' the APM's as well as providing additional opportunities for devel- '

opment and preparation for higher management positions. This new arrangement allows one APM to focus on unit operations a~nd technical support activities; a seco:d APM to focus on plant maintenance and outage planning; and a third APM to handle support functions V-1

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including training, security, office services, compifance and accounting. The new plant organization recognizes the importance of the maintenance function now that the plant is shifting from a i

construction to an operating mode. Additionally, the new organiza- j

., . tion reduces the administrative burden on the APMs and allows them more time to focus on plant operational activities. The reorgani-zation created several new positions including Technical Assistants for the APM-Operations and APM-Maintenance. The Special

! Subcommittee noted that this new plant organization is similar to that employed at other utilities ar.d believes that it should be very effective at GGNS.

B.- Management / Supervisory Changes Senior Vice President - Nuclear - Mr. J. B. Richard's appoint-

- ment to this position has had and should continue to have a positive impact on GGNS. Mr. Richard has extensive Naval Nuclear and management experience that is needed by senior MP&L management.

This personnel. change should strengthen MP&L's Nuclear Management team and should facilitate infonnation transfer and promote timely problem resolution by providing an effective communication path to MP&L Senior Management and the MP&L, Middle South Energy. Inc.

In addition, Mr.

(MSEI) and Middle South Utilities (MSU) Boards.

Richard's familiarity with Middle South Services, his previous responsibilities as INPO Point of Contact for MSU and his knowledge of the MSU sister nuclear units and staffs should allow him to draw on outside technical or operational support, if required.

Assistant Plant Manager - Support - Mr. J. Cross was hired in early 1983 to replace the previous APM - Nuc' ear, who resigned.

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I The previous Manager had 13 years BWR experience (10 years with GE).

Mr. Cross has about 14 years of commercial nuclear plant experience, ,

l primarily. on PWRs. He has considerable experience in dealing with regulatory agencies as a responsible nuclear plant line manager.

Prior to accepting his current position, he had been Assistant Plant Superintendent at both Watts Bar and Sequoyah Nuclear Plants. The addition of Mr. Cross, despite his limited experience with BWRs, has helped to improve the GGNS Plant management team.

Assistant Plant Manager - Maintenance - Mr. C. R. Hutchinson, who previously had been the GGNS Nuclear Support Manager, assumed this position within the new plant organization. Mr. Hutchinson has over 15 years of relevant nuclear experience and has been with MP&L for 10 years. Mr. Hutchinson's strong points are his knowledge of the plant and an awareness of the strengths and weaknesses of the plant staff.

Assistant Plant Manager - Support -

Mr. J. Yel verton, who 4

previously was the GGNS Nuclear Site Q/A Manager, was recently appointed to this new position. Mr. Yelverton's 4 years previous experience in Site QA has enabled him to become intimately familiar with plant personnel. Mr. Yelverton's managemeni, expertise coupled with his 13 years of quality assurance background should enable him to perform effectively in this position.

Operations Superintendent - Mr. R. G. Keeton was promoted from Shift Superintendent to - Operations Superintendent. The previous Operations Superintendent had had substantial commercial nuclear operating experience. Mr. Keeton has a solid educational background V-3

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(MS Physics), over 5 years Navy Nuclear experience, and two years as Shift Superintendent.

Maintenance Superintendent - Mr. F. H. Walsh was promoted from Maintenance Engineering Supervisor to Maintenance Superintendent to replace Mr. J. R. Elms who was appointed Technical Assistant to the ,

APM - Maintenance. These personnel changes are f elt to strengthen the overall maintenance organization by making better uses of individual strengths. Mr. Elms who is strong technically can now focus on technical issues and Mr. Walsh can provide overall management to the Maintenance Section.

Chemistry and Radiation Control Superintendent - Mr. M. C.

Williams has recently been hired to fill this position which had been vacant. The previous Superintendent, who had approximately 15 years of nuclear experience resigned. In the interim, until Mr.

Williams starts work, Mr. R. Brown the Plant Chemist is acting in this position. Mr. Williams appears well qualified for the position having 10 years of nuclear experience, including the start-up of two units and 7 years of full power operation.

Nuclear Site 0/A Manager - Mr. S. Feith was promoted from l Operations Quality Assurance Supervisor to Nuclear Site Q/A Manger when Mr. J. Yelverton was promoted to APM - Support. Mr. Feith has over 13 years nuclear utility experience including over 7 years in nuclear quality assurance and appears well qualified for his new job.

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Plant Compliance Superintendent - Mr. L. Daughtery, with 14 years Navy nuclear experience plus four years in the GGNS Plant Quality Control Section was appointed to and appears to be well qualified for this position. The need for this position was estab-lished during the development of the Operations Enhancement Pro-gram.

Industrial Safety Co-ordinator - Mr. F. Barron was hired in early 1983 to fill this new position. Mr. Barron has an MS in Industrial Hygiene plus several years of relevant experience in the Petro-chemical industry.

Radwaste Supervisor -

Mr. M. Michalski was promoted from Mechanical Maintenance Supervisor to Radwaste Supervisor when the previous Supervisor resigned. Mr. Michalski has approximately 15 years of construction support work experience as a mechanic and foreman. His mechanical maintenance experience is proving to be a plus as radwaste systems, which are composed mostly of mechanical equipment, are now being brought on-line. He lacks previous radwaste experience outside of a visit to Brunswick. His predecessor had 8 years of Naval nuclear and 9 years of nuclear plant support work experience.

Operation Training Supervisor - This position is presently vacant. The previous Supervisor, a licensed SR0 with about 10 years experier.ce, recently resigned. Efforts are underway to promote a Shift Superintendent from Operations into this position.

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l C. Summary The Special Subcommittee feels that the new plant organiza-tional structure should be effective and enables plant management to focus on three key areas essential for a well run plant - Opera-tions, Maintenance and Support. From a management, supervisory and teamwork viewpoint, personnel changes occurring since fuel load are, in general, seen as an improvement. However, through these personnel changes, the plant staff has suffered a net loss of commercial BWR operating experience. Evidence of promotions from within the organization provides incentives for plant staff. Where the management or supervisors lack sufficient experience, the Special Subcommittee, consistent with the GGNS Operating License, recommends the use of experienced consultants to assist in those areas. The use of shift consul tants to assist the Operations Superintendent is essential. In s'milar fashion the use of a consul tant for the duration of startup to assist the Radwaste Supervisor is recommended. Finally, plant management must look toward and effectively utilize their experienced personnel during this crucial phase of power ascension testing.

l V-6

VI. RESULTS AND EFFECTIVENESS OF PSRC To assess the effectiveness of the PSRC, the Special Subcommittee undertook several activities. Plant Administrative Procedure 01-S-01-11 was reviewed to identify PSRC responsibilities and to verify that requirements in Section 6 of the Technical Specifications were addressed.

The most recent Q/A audit of PSRC activities was reviewed. The audit t

addressed administrative responsibilities of the PSRC and was based on a ,

review of PSRC minutes of meetings 10/83 through 47/83. The audit did not thoroughly address PSRC technical review responsibilities and commitments as delineated in the governing procedure. In addition, to further assess PSRC effectiveness, a PSRC meeting was attended.

PSRC meeting minutt s 1/83 through 205/83 were reviewed to determine if PSRC activities were being performed in a manner consistent with procedures. The PSRC was observed to be effective and thorough in reviewing material that was submitted to them. Reviews were not always timely and backlogs periodically developed. To ease the burden on the total PSRC membership, routine document reviews are handled by dividing the PSRC into two committees: one operations-oriented PSRC that is chaired by the Assistant Plant Manager - Operations and a second maintenance-oriented PSRC that is chaired by the Assistant Plant Manager

- Maintenance. This process, although not spelled out specifically by procedure, makes efficient use of plant staff personnel and expertise to handle routine pa perwork. The entire PSRC meets to handle items considered to be of major significance. This two-committee structure should be evaluated by MP&L management to ensure that adequate i nter-VI-1

. e disciplinary reviews are being performed. If it is then decided to continue the arrangement permanently, the PSRC charter should be amended accordingly to provide fomal recognition and authorization.

The Special Subcoamittee noted that the PSRC does not appear to be carrying out reviews of all items as identified in its governing procedure. These and other Subcommittee observations are summarized below.

a) Documents and safety-related events requiring PSRC I

attention are not being consistently reviewed.

b) Document reviews are not always timely.

c) Administrative responsibilities are not being handled effectively.

The performance of the PSRC and the resul ts of the Special Subcommittee review of PSRC activities were discussed with the PSRC Chairman. He acknowledged the discrepancies noted above and indicated he

,ould take appropriate action. Subsequently, the PSRC Chaiman indicated i he had written a Plant Quality Deficiency Report (PQDR) and had initiated corrective action.

The PSRC plays a major role in assuring the safe operation of the

< plant, not only by reviewing administrative procc(ures and changes to the operating license and Technical Specifications, but also by reviewing startup test procedures and results. To evaluate and ensure the readiness of the plant to proceed with power ascension and startup testing, the PSRC VI-2 i.

must review and approve all test results and exceptions before changing power plateaus.

In summary, despite the PSRC shortcomings noted above, the Special Subconnittee feels that the PSRC is functioning satisfactorily and is providing thorough reviews of scheduled documents placing proper emphasis on safety concerns. The corrective actions being taken by the PSRC Chairman should further enhance PSRC effectiveness by ensuring that all documents requiring PSRC attention are reviewed by the PSRC in a tircTy '

manner.

VI-3

-VII. STATUS OF THE PLANT AS COMPARED TO OTHER BWR STARTUPS BASED ON THE SUBCOMITTEES KNOWLEDGE AND EXPERIENCE The Special Subcommittee feels that the material condition of the plant is as good as or better than most other plants prior to exceeding 5%

power. The material condition of the plant is considerably better than the average pre-TMI plant at a similar point. A continuing emphasis .by plant management on plant cleaniness, equipment preservation, component labeling, and painting is essential.

Based on formal and informal interviews of plant staff personnel the Special Subtommittee feels that the staff is prepared to proceed with power ascension testing above 5% power, provided the testing pace allows adequate time for pre-test evaluations and procedure reviews, simulations of planned evolutions using the simulator, and power ascension tcst result reviews.

The plant staff has performed well to the present point in the nuclear heatup phase of the startup schedule. Assuming that performance continues through the balance of the heatup phase and after the training shortfalls are resolved, the Special Subcommittee believes that it is very desirable to get on with the next phases of the startup, in particular to begin to exercise the secondary plant. Startup testing and plant evolutions at power levels up to 50%, with the turbine rolling and synchronized to the grid, will exercise the balance of the plant to show equipment problems in the secondary plant, changes needed in procedures, and will provide the next measure of the ability of the plant staff. The VII-1

o i Special Subcommittee believes that plant staff is ready to take that step and that it is desirable to move forward in deliberate fashion to that next stage of the startup. The Special Subcommittee notes that the conditions of the Unit 1 License require a repetition of this review before exceeding the 50% power level.

The plant has adequate procedures to control operations and mainte-nance activities. Management and staff will have to continue with their ongoing efforts to assure procedure adherence, encourage meticulous attention to details, and instill positive attitudes emphasizing thorough-ness in all work activities.

4 VII-2

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