ML20086M381
| ML20086M381 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 12/03/1991 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| C311-91-2144, NUDOCS 9112170386 | |
| Download: ML20086M381 (18) | |
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GPU Nuclear Corporation e
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One Upper Pond Road
- 1 Parsippany, New Jersey 07054 201 316-7000 TELEX 130 482 Wntern Direct Del Nurcer (717) 948-8005 December 3, 1991 C311-91-2144 1
Mr. Thomas T. Martin Region I, Regional Administrator U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406
Dear Mr. Martin:
Subject:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. OPR-50 Docket No. 50-289 Systematic Assessment of Licensee Performance (SALP) i 1991 GPU Nuclear Status Report
Reference:
(1) NRC letter dated October 9,1990, T.T. Martin to H.D. Hukill,
" Systematic Assessment of Licensee Performance (SALP) Final Report Number 50-289/89-99 (2) NRC. inspection Report Numbers 50-289/91-08 and 50-320/91-05 dated May 24, 1991 The purpose of this letter is to provide the status of actions taken since the mid SALP review at Region I offices on May 9, 1991. The last SALP report is contained in Reference 1 and a review of the mid SALP meeting is contained in Reference 2.
GPU Nuclear believes the mid SALP review was mutually beneficial to the NRC and GPU Nuclear and that there is no need to re-examine the items addressed in that review.
Accordingly, Attachment 1 provides the status of the actions taken since that meeting. We hope this proves helpful and would be pleased to answer any questions you might have.
9112170386 911203
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PDR GPU Nuclear Corporation is a subsca y of General Pubhc UMtes Corpore:on
'C311-91-2144 Page,2 Since our meet'ng we have safely conipleted tha 9R Outage. We believe the quality of work was good and are pleased with the total low radiation exposure to personnel.
GPU Nuclear is conenitted to continued upgrade and improverrent of performance in all areas. We judge the actioris taken or underway to be consistent with that objective and reflect our commitment of raanagement and resources to achieve the desired continued improvements in TM1-1 activities.
We look forward to a constructive dialogue following receipt of the 93 P report.
Sincerely,
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,, ~. - L-c2;vw P. R. Clark President RDW Attachments cc: TMl-1 Project Manager
- 4kC Resident inspector IMI Document Control Desk
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GPU NUCLEAR THREE MILE ISLAND UNIT 1 UPDATE ON SALP STATUS
'T.T. Martin Attachment
- C3t h912144
, Page1 FUNCTIONAL AREA: P1 ANT OPERATIONS GENERAL OVERVIEW On July 24,1991, a low pressure reactor trip occurred with post trip response nonnal.
e The reactor trip was documented in Licensee Event Report (LER)91-002. During the unplanned shutdown, the plant took the opportunity to perform corrective maintenance, which lasted approximately two days, in order to improve the material condition of the plant. Activities performed included:
Repair of an instrument fitting leak on the secondary side of the "A" OTSG. This resulted in a reduction of secondary system leakage into the reactor building by
-1500 gallons per day.
Plugging of several feedwater heater tube leaks which reduced heater leakage by
~1500 gallons per minute.
Restart of the unit occurred on July 26, 1991. The unit remained on-line for the remainder of Cycle 8.
On September 27, 1991, the unit was shutdown for the 9R Refueling Outage. While shutdown activities were in progress, the reactor tripped from 13% power on high RCS pressure during a turbine generator valve testing sequence. This event is described in LER 91-003.
OUTAGE MANAGEMENT A refueling outage of 49 days duration was completed on November 15, 1991. Activities that contributed to the success of this outage included:
Formal assessments of Nuclear Safety Risk and Environmental Assessment were performed prior to the outav,e in order to minimize the potential for shutdown events which could threaten fuel cooling or the environment.
Experience and " lessons-learned" from past outages were applied during this outage and were effective in preventing reoccurrence of previous outage events (e.g., loss o^ decay heat, radioactive liquid spills).
Based on recommendations from the Independent Onsite Safety Review Group (IOSRG),
e guidelines were established for control of the individual work hours during the outage.
These guidelines applied not only to personnel :nvolved in safety related work but to all outage workers, supervisors and individuals providing direct support for work.
'T.T. Martin Attachment C31b912144 Page 2 FUNCTIONAL AREA: PLANT OPERATIONS (Cont'd)
The use of an integrated schedule plus application of specific outage modifications (e.g.,
e cold leg dams) developed during previous outages were effective this outage in allowing activitics to be performed in parallel without adversely affecting safety and within guidelines for manpower and control of work hours.
Preparation of work and systems was done in a controlled manner (e.g., Reactor Vessel (RV) draining with good plant control and coordination).
OUTAGE ACTIVITIES The following is a highlight of activities performed during the 9R Outage:
The entire core was offloaded for RV inservice inspection activities. Inservice inspection of the RV welds was conducted and the RV was found to be in excellent condition, Disassembly, inspection, and reassembly of the turbine generator was cornpleted. A major e
overhaul of the High Pressure (IIP) and Low Pressure (LP)"A" turbine r.nd the excitor were performed. This included:
A complete steam path realignment of the HP and LP "A" turbine.
Weld repair of the HP ist stage nozzles to repair solid particle erosion damage.
Resizing of valves on the fourth stage extraction lines to allow TM1 to take only one LP string out of service while maintaining the associated high pressure feedwater heater string in service. This allows higher power levels to be achieved when dealing with feedwater heater tube leaks in the LP string.
Identification and implementation of changes to the turbine control system to minimize the probability of a plant trip being induced by the turbine control system.
Reactor Coolant pump - is were inspected. Two pumps had the seals cleaned and reinstalled and the other two pumps had the seals replaced. All four pumps now have silica nitride seals.
Steam Generator Activities l
Chemical cleaning of the "A" and "B" Once Through Steam Generators (OTSGs) was e
performed. Approximately 3000 lbs of ferrous oxide material was removed from each OTSG, and low corrosion was observed.
I
'T.T. M:rtin Attachment
- C311-912144
. Page 3 FUNCTIONAL AREA: PULNT OPERATIONS (Cont'd)
One (1) tube was plugged in the "A" OTSG and two (2) tubes were plugged in the "B" OTSG. Currently there are 1258 plugged tubes in the "A" OTSG and 372 plugged tubes in the "2 OTSO.
125 sleeves were installed in the upper tubesheets of each generator to reduce the e
likelihood of tube failure from high cycle fatigue in the lane wedge region.
15 B&W plugs were replaced in the upper tube sheet due to eddy current indications in e
the plugs.
in the lower tubesheets, a backup rolled plug was installed to prevent leakage from 30 of e
the explosive plugs (27 in "A" OTSG and 3 in "B" OTSG). A marual welded plug was installed to repair a leaking Westinghouse rolled plug in the "A" OTSG.
Significant effort was spent to identify the small primary to secondary leakage. We believe fixing the leaking plugs will significantly reduce the primary to secondary leakage in Cycle 9.
The 9R Outage findings of lower tubecheet plug leakage and the absence of tube leakage e
confirmed the basis presented in Technical Specification Change Request No. 210 (License Amendment No.163) which raised the license administrative primary to secondary leakage limit for the final few months of cycle 8 operation.
Outage Modifications The following is a highlight of modifications performed during the 9R Outage:
&nicipagd Transient Without Scram (ATWS) modifications.
In order to meet the requirements of 10 CFR 50.62, the following modifications were performed:
Installation of ATWS Mitigation System Actuation Circuitry which automatically initiates emergency feedwater and trips the turbine.
Installation of a Diverse Scram System which trips the reactor if the Reactor Pressure System (RPS) fails.
j
'T.T. Martin Attachment l
' C3119) 2144 Page 4 FUNCTIONAL AREA: PLANT OPERATIONS (Cont'd)
Upgrade Reactor Coelant Pun 1p (RCP) lube Oil System.
e This modification was performed because the RCP lube oil system high/ low level alarm pressure switches were unreliable, and continuing oil leaks were experienced. The scope of work completed during the 9R Outage included:
Replacement of high/ low level alarm pressure switches on all eight reservoirs with external standpipes containing level indication float switches.
Installation of readout electronics and cabling for the new float switches in the control building including a tie-in to the plant computer.
Replacement of local fill pi;Iing and level sight gauges on all four reservoirs and connection to the remote fill system.
Station Blackout (,EBO) Medificatiom In order to comply with 10 CFR 50.63, a TMI 2 diesel generator was converted for use as a dedicated SBO diesel for TMI-1. The majority of the above work was performed during the ramp up period preceding the outage. However, to ensure full compliance with testing requirements, critical path outage activities at the end of the outage were delayed one half to one day to facilitate inspection and testing.
Operational Improvements EFW Au12-11RLt ES Test Lights e
As a result of presions ESAS inadvertent actuations, an ESAS testbutton was added in the Control Room. This modification also installed ES test lights in the Emergency Feedwater (EFW) pump auto-start circuits to provide for verification of ES contact operation.
Rgaetor Building Preservation Reactor Building preservation performed during the 9R Outage included recoating piping and components in the Nuclear Services Closed Cooling Water System, RB Emergency Cooling Water Systern, and the RB Industrial Cooling System.
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'T.T. Martin Attachment j
C31b912144
. Page 5 FUNCTIONAL AREA: P1 ANT OPEl(ATIONS (Cont'd)
Thermocmtple (T/C) Cable llGlKancli e
All 52 incore detectors were replaced during the 9R Outage. Each detector includes one T/C. Sixteen (16) of these T/Cs are part of the Backup Incore Readout System and perform the safety-related function of detecting inadequate core cooling.
RCS Shutdown Len! Monitoring This modification installed a second, independent means of monitoring the RCS level during shutdown as committed in GPU Nuclear's response to NRC Generic Ixtter 3817,
' Loss of Decay lleat Removal."
e Control Room Alarm Enhanecnen15 The purpose of this modification was to facilitate quicker and more effective response to alarms, therefore minimizing plant trips and enhancing protection of plant equipment and personnel. The scope of this modification included:
18 new alarms addeo to the overhead panels.
34 alarms combined into 11 new alarms, each trouping requiring the same basic operator action.
22 alarms were removed from the main annunoator panel and added to the plant
- computer, RCP 1A/D arid Main Steam (MS) Line Hartgenfermanent Platfenns e
The purpose of this modification was to allow access to the RCP lower motor bearings and coupling areas and selected MS line hangers. These platforms greatly improve access and personnel safety and reduce personnel exposure.
OPERATOR EXAM RESULTS During this SALP period the TMI licensed operator requalification and training program was evaluated by the NRC and was rated as satisfactory. At three separate times during the SALP period, the NRC administered initial and requalification examinations to a total of 21 operators.
All 21 operators successfully passed the examinations. Two of the operators initially failed a portion of the requalification examination but subsequently passed a NRC administered exam at a later date. No programmatic weaknesses of the programs were identified.
'T.T. Ma rtin Attachment C311912144 Page 6 FUNCTIONAL AREA: RADIOLOGICAL CONTROLS l
Control of airborne radiciodine inside containment during the 9R Outage was the most e
successful to date. This improvement was due to a purge system modification, procedure i
control, planning, and inter department communication. The methodology has been added to punchlist tracking for future outages.
In order to improve overall radiological controls and work practices for the 9R Outage e
workforce, over 800 individuals attended the advanced radiation worker training j
(approximatel; 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> in length) in addition to the standard radiation worker training.
This course focused on practical factors, including the use of realistic mockups.
Independent neutron dose and spectral measurements were performed in Cycle 8 by e
Batelle Pacific Northwest Laboratories. Evaluation of the final report is underway to j
assess any changes necessary to the dosimetry program, GPU Nuclear's TLD dosimetry program for measurement of personnel dose was o
accredited by the National Voluntary Laboratory Accreditation Program (NVLAP). The program implementation and quality control remains one of the best in the nuclear induary.
During the latter part of Cycle 8, filter pore size reduction of most make-up and purification filters was effected The trending of this source term reduction technique will continue for future cycles / outages, Efforts remain in place to reduce skin and clothing contaminations.
During the e
9R Outage, steps to reduce skin contaminations were not as effective as desired.
However, due to additional training and changes in the protective clothing program, the number of clothing contaminations has been greatly reduced compared to previous outages.
Radiological Controls efforts to reduce person-rem exposures during the 9R Outage were very successful. Total person-rem was 200 as compared to the goal of 280 person-rem.
Additionally, the highest exposure to en individual (i.e.,1.24 person-rem) was less than the projected goal ',i.e., < l.3 person-rem). Contributing to the low total person dose were:
Shorter outage - 49 days vs. 56 days (8R)
Advanced radiation worker training Integrated Schedule i
Good hot particle control (e.g., increased use of automated whole body friskers) l Performed high risk (industry overexposure) jobs successfully 52 incores replaced 2 unplanned spent fuel pool dives e
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. 'T.Tr Martin Attachment -
C31b9.12144 -
Page 7 -
FUNCTIONAL AREA: RADIOLOGICAL CONTROLS (Cont'd)
" ROGER" robotics used in all four OTSG channel heads Good planning / communications between Radiologleal Controls and the plant:
Fuel Transfer Canal (UTC) Draindown/ cleanup e
_ RCS inventory control e-e Airborne radiciodine controlin the RB FUNCTIONAL AREA: MAINTENANCE / SURVEILLANCE Plant Materiel has been effective in maintaining the plant on line and keeping the plant systems in an effective operating condition. During Cycle 8 the plant operated 542 days out of 555 days (13 da"s off-line and 12 days at reduced power).
Emphasis continues to shift from Corrective Maintenance (CM) to Preventive Maintenance
- (PM). Total failure types for all syste_ms is on a downward trend and has decreased since the beginning of 1990. In the valve repacking effort, a total of 2447 valves have been repacked including 530 during the 9R Outage. During 10R Outage,800 valves are scheduled to be repacked, completing the repack program for the high pressure systems in addition, a total of 231 valves were replaced during the 7R,8R, and 9R Outages.
- The Maintenance Team Inspection (November 1989) had identified six weaknesses. TMl has continued to address these items and only_one item has remaining work to be completed. That
- weakness involved periodic procedure reviews associated with slings and. hoisting equipment
. controls. LTMI incorporated the corrective action for this weakness into the maintenance.
procedure upgrade program.
- The Maintenance Procedure Upgrade Program was implemented following the issuance of a Maintenance Procedure Writers Guide and the training of maintenance supervisors who are-originators or owners of maintenance procedures. This program has raised the quality level of the TMI 1 maintenance procedures. Positive feedback on this program has been received from
~INPO, the NRC and the GPUN Quality Assurance personnel. QA personnel have contributed to this higher quality plateau through their reviews and interface with procedure writers. The :
T process is currently being reviewed to ensure that it includes a method for. continued improvement in quality, particularly for those procedures where the tasks are complex and/or are infrequently performed.- A more efficient approach to accomplishing the biennial review of maintenance as well as other plant procedures is the goal of this process review.
'T.T. Martin Attachment
' C3119.12144 Page 8 FUNCTIONAL AREA: MAINTENANCE / SURVEILLANCE (Cont'd)
The Reliability Centered Maintenance (RCM) program is continuing to be addressed. In the MID SALP meeting in May 1991, it v.as reported that nine systems were evaluated. Work is continuing or, two more systems.
As the system evaluations are completed, the recommendations of the evaluations are :mplemented in the existing Preventative Maintenance Program (PM) as appropriate. These evaluations provide additional technical basis of the PM program. During the 9R Outage, the RCM cvaluators were reassigned as job coordinators and are resuming their evaluation process upon completion of their outage responsibilities.
FUNCTIONAL AREA: EMERGENCY PREPAREDNESS The 1991 full scale, unannounced Annual Exercise was conducted after hours on June 26,1991. No violations or exerc se *veaknesses were identified.1lowever, a number of areas for improvement were reported and Emergency Preparedness is dispositioning all items.
A routine unannounced NRC Inspection took place the week of July 15,1991. No violations were identified. One concern was raised that the on shift Emergency Directors are tested on General Emergency cla:sification and the PAR logic diagram via e able top exercise only once a year during a.mual training.
Consequer**
number of General Emergency shift drills nre being developed for impleme
, in 1992, e
The T.
. ADS computer data link was satisfactorily tested on August 21,1991.
Instruc s < for the initiation of the system during emergencies have been procedurahzed.
The appropriate personnel were subsequently briefed and implementation of the synem was completed October 4,1991, Revision 6 of the Corporate Emergency Plan was completed on September 30, o
199L The most significant change consisted of mode (plant conditions) applicability statements for the Emergency Action Levels (EALs). Although this revision does not reduce the effectiveness of the Plan, in accordance with previous requests from NRC Region 1, the Plan has been submitted for NRC approval prior to implementation. The Commonwealth of Pennsylvania has concurred with this revision. GPU Nuclear made a presentation to NRC Region I personnel and j
repiesentative from PA and NJ to address the specific changes made to the Emergency Plan.
A new Emergency Director (ED)/ Emergency Support Director (ESD) Systems and Accident Mitigation course was developed and implemented in 199L Additionally, numerous personnel were qualified as ESD, ED, ED Assistant, Operations Support Center (OSC) Coordinator, and OSC Coordinator Assistants.
~,
S T.T. Martin -
Attachment
' C3114.12144
. Page 9 i
FUNCMONAL AREA: EMERGENCY PREPAREDNESS (Cont'd)
-A prompt ratification siren system upgrade program to enhance the reliability of the systerr was completed in June of 1991, GPUN-sponsored Offsite-Emergency worker training attendance is up e
approximately 45% In addition, there has been an increase in state support in the area of offsite hospital and ambulance training, off site emergency worker training, and involvement in Emergency Preparedness exercises.
I GPUN produced and distributed to all risk municipalities a VCR tape addressing personnel dos! metry. The tape can be used to brief emergency workers during emergencies and as a refresher training program throughout the year.
j Also during this period, a number of Emergency Facility upgrades were completed.
e Theyl included the Emergency Support Director Data Display System at the EOF, installation of uninterruptable power supplies for at vital Emergency Facill:y -
computers not on vital power, and Einergency Plan Implementing Procedure " user friendliness" upgrades.
A comprehensive information briefing program describing the restart from the 9R Outage wasl presented to local, county, and state officials. This briefing, a joint effort by the Emergency Preparedness and Communications Departments, explained how abnormal conditions would be classified and communicated.
FUNCTIONAL AREA: SECURITY
_ In the mid-SALP review, GPU Nuclear indicated that the new Secondary Perimeter Intrusion L Detection System was scheduled for installation during the third quarter 199L This system has been ins'.Jed and is operati_onal Additionally, the mid SALP review stated that three (3)
~
surveillance cameras were scheduled for installation during the third quarter 1991. One ~(1)
- camera has been installed to enhance the coverage of the east isolation zone of the Protected Area (PA); boundary; the remaining cameras are scheduled to be installed to enhance the coverage of the west isolation zone during Cycle 9.
Replacement of temporary lighting with permanent lighting in the PA is scheduled for Cycle 9.
Additionally, the TMI Processing Center (PC) has been modified to enhance personnel ingress -
and egress. Further renovation of the PC is scheduled to be completed during Cycle 9.
'T.T. Martin Attachment C31) 9,102144 l' age 10 FUNCTIONAL AFEA: ENGINEE"INGfl'ECIINICAL SUPPORT Plant Engineerirg and Technical Functions continued to support the Unit's operation on a daily basis. Through the SALP period, Plant Engineering and Technical Functions have completed significant work efforts. These include:
Plant Engineering and Technical Functions provided engineering support and calculations e
in establishing the allowable sealleakoff rate and other key operating parameters of the Reactor Coolant Pump Seals. This also involved coordination with other engineering and operating groups within GPUN and with the equipment vendor, Plant Engineering completed engineering for replacement of the Loose Parts / Neutron e
Noise Monitoring System with a new digital system, which is scheduled for installation in early 1992.
Actions are underway to increase the Plant Engineering Procurement Engineering team from 3 to 7 staff members. This is expected to occur in the first quarter of 1992. The goalis to meet the June 30,1992 objectives of the Comprehensive Procurement Initiative, Plant Engineering is continuing efforts to minimize the Plant Engineering backlog. The e
Plant Engineering backlog is currently at an acceptable level and iepresents a justifiable workload. The Plant Engineering backlog has been reduced by about 67% in the past 18 months.
Using in-house resources, the diesel generator loading and voltage drops were modelled e
using the Dapper Computer Proyam to confirm that GPU Nuclear satisfies the electrical design basis. This will enable GPU Nuclear to more rapidly resolve future inquiries concerning this issue.
in order to reduce exposure during the 9R Outage, the technical support groups planned e
for and participated in the implementation of early boration during cooldown to reduce RCS radiation fields. In addition, a chemistry program was implemented using higher lithium and pH limits in the reactor coolant system to minimize corrosion products.
Technical Functions along with Plant Engineering performed a correlation of the iron concentration in final feed to the fouling rate in the steam generators and established an objective of maintaining iron less than 1 ppb in order to minimize steam generator fouling in the future years; thus the time interval when chemical cleaning will be required again has been extended.
Technical Functions conmieted the design basis differential pressure calculations for all e
safety related motor operated valves, per Generic Letter 89-10. Testing on 40% of the valves was completed in the 9R Outage.
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' T.T, htriin Attachment
' CJ1,19.12144 Page 11 FUNCTIONAL AREA: ENGINEERING /TECilNICAL SUPPORT (Cont'd)
Technical Functions continued the Design Basis Document Program with DBDs being e
prepared for Reactor Building Spray, LPl/ Decay Heat, Rad Monitor System, Main Feedwater/ Condensate, and the Instrument Air System, Technical Functions, with support from the Plant Materiel Department, comple'ed a e
detailed vib..ition analysis of the main turbine generator exciter and identified the root cause of the high vibrations. This enabled appropriate corrective actions to be applied during the 9R Outage to both correct foundation deficiencies in the exciter and the coupling deficiencies between the exciter and the main turbine.
The Probabilistic Hisk Assessment Study (PRA) completed in 1987 was updated in 1991 e
to include plant configuration changes and modify reliability data based on actual plant performance.
During Cycle 8 and the 9R Outage, the final three open recommendations for the B&W Owners Group Safety and Performance Improvement Program (SPIP) were implemented.
These involved improvements to the Integrated Control Systems, Instrument Air System and Control Rod Annunciator System, Fiant Engineering along with Technical Functions provided timely and efficient support in preparation for and throughout the 9R Outage.
Several large, highly visible tasks in addition to those mentioned previously, and supported by Plant Engineering and Technical Functions were:
(1)
Located and repaired leaking OTSG tubes (leaking plugs) resulting in reduction of primary to se andary leakage from 0.100 gpm at enil of Cycle 8 (last cycle) to
<0.001 gpt, a beginning of Cyc!: 4 (2)
CRDM gasket replacement with gaskets ofimproved design and material. Total of 34 out of 69 have improved gasket material.
(3)
Erosion / corrosion pipe inspections - Utilized EPRI Checmate and ChecNDE programs for inspection of 122 components in the 9R Outage.
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'T.T. Martin Attachment C31).9.12144 Page 12 I'UNCTIONAL AltEA: ENGINEEltlNG/TECilNICAL SUPPORT (Cont'd)
(4)
Tested the Electric ilydraulic Control (EllC) system for noise which caused a previous turbhe valve transient. Pr wided corrective changes including time delay in Control isolatin Valve (CIV) fast. lose circuit. rewiring of speed signal shields and addition of surge suppression to tcat relap/ motors.
(5)
Expanded the vibration monitoring program with the installation of vibration detectors on the first four main turbine bearings and both generator bearings.
(6)
Installed a 300 point digital Data.\\cquisition System to monitor the Integrated Control System. The new system will provide electronic drift information for the preventive malatenance program as well as expanded transient malysis capability.
Several not so visible.
t important, tasks completed in the 9R Outage were:
(1)
'pleted a building addition which was successfully u. sed to process craft mnelin/out of the Reactor Building. This freed space in the plant for normal i
a..
plant personnel access / activities. Additional space aided rad monitoring of personnel and equipment (2)
Replaced fire detection instruments with qualified devices more suitable to the operating environment within the TMI 1 Reactor Building secondary sh!cids. This change should improve operating reliability and availability of a fire detection system during future operating cycles.
(3)
OT3G Skin Valve / Fitting Integrity Upgrade. During the 9R Outage we completed the modification project which involved the following items:
Replaced all 600# design bolted bonnet instrurnent root /
e drain / vent valves on the OTSG secondary side vith 1700#
design bonnelless design valves.
Seal welded or fillet welded all instrument tubing connections at the new OTSG instrument root valves where there were previously pipe threads.
These modifications will enhance the post accident and normal operating condition leak tightness of the OTSG's and will help to prevent recurrence of historic atmospheric in leakage problems during the periodic Reactor Building Integrated Ixak Rate Testing.
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- T,T. Martis Attechment C31.1912144 Page 13 k
L FUNCTIONAL AREA: ENGINEERING /rECilNICAL SUPPORT (Cont'd)
(4)
Feedwater (FW) lleater inspections extensive inspections including eddy current and pressure tests on FW heaters to increase heater reliability and tube integrity.
Maintenance included stabilizing and plugging.
(5) -Reactor Building Sump llatch redesigned hatch to improve sump accessibility for cleaning and blank flange instrallation. Redesign will hnprove personnel safety and reduce man rem exposure for work.
(6) ' Designed Reactor Vessel stud racks to allow cleaning of studs outside of Reactor Building. Man rem exposure was reduced from 21/2R to 100mR.
(7)
Standardized Contalument Penetration Test Connections Completed installation of most of the new CIV test con: lections to prepare for performance of a combined ILRT/LLRT in 10R refueling and to greatly simplify normal local Leak Rate
- Testing for many of the previously difficult to test CIV's.
FUNCTIONAL' AREA: SAFE'lY ASSESSMENT /QUALI'lY VERIFlCATION The Safety Issues Assessment Process (SIAP) review group consists of senior managers e
form the TMI 1, Technical Functions, and Corporate Services divisions and is coordinated by the ISR c'epartment. The issues evaluated by this group include generic industry issues as wc!! as TMI specific issues. The group has met several times since the last SALP to -
i evaluate issues on the be. sis of potential to enhance nuclear safety.
e There have been several strengths noted by the TM1 Quality Assurance Department in the Quality Verification area during the period. These include:
l A. Corrective Action Program.
Corporate procedure 1000 ADM 7216.01, "GPUN Corrective Action Program Processes," has been to be issued effective December 31,~ 1991. This procedure identifies GPU Nuclear's Program for implementing 10 CFR 50 Appendix.B,.
Criteria 16, Corrective Action Requirements. Compliance with this procedure will enable the efficient implementation of measures to rectify conditions adverse to quality or necessary to preclude repetition. The procedure identifies those programs
~
that are considered to be *significant deficiency reporting prograrns" and provides for lower tier programs to evaluate deficiencies and escalate significant deficiencies in the identified programs.
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- ", ' T T. M:rtia Attachment j
C31,1412144
. Page 14 FUNCTIONAL AltEAt SAFE'IY ASSESSMENT /QUAlflY VEltlFICATION (Cont'd)
II. Plant Operations.
Enhancements to the Mixed Waste Program have helped ensure segregation of waste to prevent the problems of mixed hazardous waste.
C. Quality Verification.
There has been a low number of outstanding, long term noterial deficiencies this
- period, e
SUMMARY
OF LOW TilitESilOLD EVENTS l
Operations routinely produces a Monthly Significant Events lleport. The items detailed
)
in this report consist of Shift Foreman, Control floom Operator, and Shift Technical Advisor logbook entries, along with other departmental input, such as the Plant Operations Director's daily notes. Input to the report is provided by the IOSRG, OA, and PRG sections. Ileginning in February,1991, the report has included a section which designates some events as low threshold events. These low threshold events may not be captured in other reporting or follow up review programs, due to the limited adverse impact on plant safety or long term continued operation. Ilowever, such events may warrant some additional follow up by the Plant Review Group (PRG) or other departments.
The PRG reviews these r ports in a multidiscipline forum on a monthly basis to determine whether addi:lonal follow-up or review is warranted. The reports include equipment problems, personnelinju,ies or near misses, and other events which rise above the level of routine occurrences. As of the end of Septem'oer 1991,33 low threshold events have been designated and revie.ved. One of these events, involving switch centacts which required cleaning, was determined to warrant additional follow up action to reduce the probability of further problems. Action was assigned to an engineering group for evaluation.
- T.T. htartia Attachment C31.1412144 Page 15 FUNC110NAL AREAt SAFE 1Y ASSESSh1ENT/QUAIJIY VERIFICATION (Cont'd) e PROGRAhtS FOR EhtPLOYEE DEVELOPh1ENT AND OWNERSillP Shiftworker Drot>o,t Program This program allows shiftworkers relief from shiftwork for a mmimum of 12 weeks, during which the individual maintains all required job qualifications. His timeframe allows the individual to perform duties not normally assigned (e.g., plant preservation, writing maintenance procedures).
GPU Nuclear believes that this program exposes individuals to a broader scope of plant duties and instills a sense of participation and ownership in the individual.
- During the last operating cycle, construction projects (e.g., Instrument Air upgrades, installation of maintenance nlatforms) were accomplished by the maintenance work force as opposed to contractor personnel, j
Cross training of personnel was exploited during the 9R Outage. For example, an operations shift foreman was assigned to the hiaintenance Department, chemistry technicians were assigned to Radiological Controls for laboratory duties, and 17 Auxiliary Operators were assigned to the hiaintenance Department.
COhiPARISON OF SR AND 9R REFUELING OUTAGES Several infrequently performed evolutions lead to reportable events during the 9R i
Outage. Although the number of these reportable events was higher than the operating cycle, it was similar to the 8R Outage in January h! arch 1990. Fewer problems were expected in the 9R Outage based on a better planned and scheduled outage and the i
corrective actions taken as a result of problems in past outages. The evaluation of the 9R Outage events has identified some common causes in the procedure and personnel areas.
In particular we recognize the need to perform a more critical review of procedures governing infrequently performed evolutions, including those which have been successfully performed in the past. The program to improve performance will include l
emphasis on the responsibility of operators and technicians to understand the evolutions before conducting them, and a multidisciplinary review of infrequently performed procedures by a team of users, technical content experts and experts in the human factors aspects of procedures.
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In addition, although there have been few operating cycle errors which have adversely affected plant operations, we are evaluating methods of further reducing the number of human errors. This willinclude the development and implementation of a self checking program for workers and supervisors using f-dustry developed guidelines.
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