ML20098B143

Provides Response to SALP Evaluation,Per 950901 Request. Attachment 1 Provides Response to Recent SALP Evaluation

ML20098B143
Person / Time
Site:	Oyster Creek
Issue date:	09/27/1995
From:	J. J. Barton GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C321-95-2291, NUDOCS 9510020254
Download: ML20098B143 (18)

Text

- _ _

GPU Nuclear Corporation Nuclear  :::em:r>=

Forked River, New Jersey 08731-0388 609 971-4000 Writer's Direct Dial Number:

September 27,1995 C321-95-2291 Document Control Desk U. S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406-1415

SUBJECT:

Oyster Creek Nuclear Generating Station Docket 50-219 Response to SALP Evaluation As requested by your correspondence of September 1,1995, Attachment I provides the response to our recent SALP evaluation. We value your perspective in the identification of areas where further improvements can be made. In the following discussion we have addressed those areas in detail.

GPU Nuclear is in agreement with your assessment in all functional areas except the Plant Support area, specifically Radiological Controls. Although we are pleased that NRC has acknowledged steady improvement in exposure reduction our continued aggressive approach toward reducing the in-plr.nt source term should also be recognized. We provide additional information on Radiological Controls programs and improvements herein as well. In addition, GPU Nuclear would welcome the opportunity to meet with the staff to present Oyster Creek's specific challenges and to detail our progress in reducing in-plant source term.

Additionally, as discussed at the meeting your assessment contained two areas which we would like to clarify for the record:

1) in the cover letter the statement, "... critical omissions in management oversight and control of the modifications of the Emergency Diesel Generators and the Station Blackout Combustion Turbines contributed to their subsequent inoperability," is in error. Although we did consider the combustion turbines to be inoperable at no time was either diesel renerator inoperable when declared to be operable.

020061  ;

GPU Nuclear Corporation is a subsidiary of General Pubhc Utihties Corporation

/fD s j

9510020254 950927 PDR ADOCK 05000219 j i

_ _ _ _ _ _ _ _ _ _ _ _ Fal ____M -

Response to SALP Evaluation C321-9,5-2291 Page 2 l

2) In the area of Maintenance the statement, "A second challenge was a plant  !

shutdown and declaration of an Unusual Event that resulted from work performed outside the scope of the controllingjob order," is in error. This challenge relates to excessive nitrogen leakage through V-27-1 and 2 which resulted in the initiation of a shutdown, however, the shutdown was not completed.

As expressed at the meeting held August 24, 1995, we appreciated your presentation and favorable comments held in a public forum and welcome the opportunity to meet with you in the near future. Should you have any questions or comments, please feel free to contact me directly.

Very t ly yours, (

[ _-

Joh n J. Bartd n Vi .c President & Director .

ster Creek Nuclear Generating Station JJB/BDE/gl cc: Administrator, Region I OCNGS Senior Resident Inspector OCNGS NRC Senior Pmject Manager i

t

{

ATTACHMENT I RESPONSE TO SALP EVALUATION 1

i

OPERATIONS 1

GPU Nuclear is in agreement with the assessment in this area. Much work has been done to improve performance in this area during the SALP period as recognized in the assessment. It is also recognized that several significant operator errors have occurred. In order to address these issues, several actions aimed at human performance improvement have been taken. These actions include:

• Renewed emphasis on self-checking (skill based errors) and the requirement for

. a visible delay / pause before completing the action step.

• In an effort to promote improvements in individual shift performance, each crew has revised their individual Shift Improvement Plan. These plans have been merged into an Operations-wide document.

Specincally with regard to weak management control of Station Blackout (SBO) Combustion Turbines (CT's), the following actions were taken:

1. _ A System Performance Team (SPT) has been formed. This team consists of a SBO system engineer, a Control Room Group Shift Supervisor, and a JCP&L site

engineer who is responsible for the combustion turbine. The team meets quarterly to discuss ongoing system issues as well as all SBO system modifications affecting the operability of the CT's.

2. The responsibility of the GPU Nuclear System Engineer regarding the SBO equipment under JCP&L jurisdiction is included in the document known as "ClariGcation of Responsibilities between Jersey Central Power & Light and GPU Nuclear Corporation." The following agreements are included in the document which is periodically reviewed by all parties:

The GPU Nuclear SBO System Engineer will be notined of proposed design changes to the FRCTs which potentially affect operability.

The GPU Nuclear SBO System Engineer will provide concurrence for detailed design engineering for modifications to the FRCTs which affect operability.

Modifications which may affect the operability of the FRCTs shall be post-modification tested by JCP&L. GPU Nuclear Start-Up & Test engineers will review the procedure prior to implementation and will then

review the results of the post-modi 0 cation testing or will personally witness post-modincation testing and provide written concurrence that SBO capability is unaffected.

- A'ITACHMENT I - Response to SALP Evaluation

'. C321-9,5-2291 Page 2 I I Additionally, the GPU Nuclear SBO System Engineer will review the results of post-modification testing or personally witness post-modification testing and provide written concurmnce that the SBO capability is unaffected.

3. A Plant Support Engineering task Action Item is Generated per GPU Nuclear procedures to document the review and approval of the CT modifications. This

task is closed only after approval by systems supervisor and the manager. A Safety / Environmental Determination and 50.59 review is completed per GPU Nuclear procedures, as necessary.

1 MAINTENANCE

- GPU Nuclear is in agreement with the assessment in this area. As noted in the assessment, several instances where communication failures, breakdowns in the control of maintenance or

- weak supervisory oversight and technical support resulted in plant chal l engesht atd etracted from

- overall performance. These challenges and those actions taken to prevent recurrence are described below. )

. CHALLENGE:

1 1 During the process of draining 1-1 and 1-2 Containment Spray Heat Exchangers (tube i l

. side) in preparation for cleaning, it was noted that Maintenance Department individuals '

operated a system without pmper operating instmetions. The root cause was failure to

{ follow the procedure and perform procedure steps correctly in completing the work.

i Specific actions taken as a result were as follows:

• The evolution was stopped, valve V-3-936 was verified closed and the hoses were disconnected. Secondary containment integrity was re-established.  ;

A tagout was issued for both System 1 and 2 drain modifications. This prevented the use of these systems without proper instructions.

The turnover process was implemented for the remainder of System 1 and all of System 2. The lack of operating instructions was identified as a discrepancy.

Operating Procedures were revised to include specific operating directions.

• Additional training was conducted for Maintenance personnel on the need to 9

follow established Procedures for the contml of plant equipment. This training  !

emphasized that installed plant equipment is not to be operated by Maintenance ,

Personnel without proper instruction and/or direction. Also, Maintenance  !

Supervision was given tmining on the Plant Configuration Change Control i Process.

ATTACHMENT I -_ Response to SALP Evaluation C321-9,5-2291 Page 3

• The event critique was required reading for all Operations Personnel to communicate the need to follow the requirements of Procedure 124 in controlling the use of plant equipment not turned over and the need to assure appropriate instmetions are utilized to operate plant equipment.

CHALLENGE:

It was determined that leakage through V-27-1 and 2 was the cause for excessive make-up of nitrogen to the drywell. An immediate maintenance job order authorized the investigation and mpair. The actuator arm adjustment on both valves was found to be incorrect. This resulted in the valves being partially open which degraded primary containment. The root cause was inappropriate actions resulting in a failure to comply with procedural mquirements. Contributing factors to the event were inadequate work instructions and lack of communications. Corrective actions consisted of the following:

• The Plant Maintenance Director emphasized, in writing, to all Maintenance personnel and all Site Services personnel the administrative requirements concerning revisions of Job Orders. The Preventive Maintenance Job Orders for 15R were reviewed for adequacy of the post-maintenance tests.

• Plant Maintenance management interviewed Mechanical Maintenance supervisors and the bargaining unit personnel involved in the event to clarify their understanding of requirements related to the use of and adherence to PM job orders. A sampling of personnel other than those involved in the event were also interviewed to better understand the departmental position relating to changes and scope of work.

• Senior maintenance management met with all maintenance production supervisors to reaffirm management's expectations regarding procedural compliance and personal accountability.

• A letter was issued to all maintenance personnel highlighting the subject event and Lessons Izarned. Additionally, management's expectations for procedure use/ adherence and change in scope were re-emphasized.

• Use/ adherence and change in scope training was given to all first line supervisors and job coordinators.

Use/ adherence and change in scope training was incorpomted into cyclic tmining.

PM Task 390M was revised to provide enhancements addressing preferred valve positions, tagout needs, and precautions / limitations concerning actuator arm adjustments.

A'ITACHMENT I - Response to SALP Evaluation

AT.TACHMENT I - Response to SALP Evaluation

~

4 C321-95-2291 Page 4 i CHALLENGE:

c A third challenge was a reactor trip signal while shutdown during post-maintenance testing of the newly installed digital Reactor Recirculation Flow Control System, which was the result of weak supervisory oversight and technical support of the testing. >

A recirculation flow transient was experienced during 15R when the I&C technicians were performing troubleshooting in the newly installed digital Feedwater Control System.-

As a result of this transient, it was identified that I&C technicians required additional training on the new control system and that a maintenance procedure was needed in order to control any troubleshooting performed on this system. Additionally, plant management imposed an administrative requirement that either the system engineer or maintenance tminer directly supervise all troubleshooting activities until this procedure was developed and issued.

l As identified in the assessment, GPU Nuclear concurs that control over transient and loose maintenance equipment located near safety-related components was weak. The following actions were taken:

'

• All maintenance production supervision were sensitized as to the need to comply  ;

with the Rolling Stock requirements.

• The rolling stock issue was incorporated into the Management Off-Shift Tour Program and the Management Observation Tour Program in an effort to draw attention to and address this concern.

Finally, in the Maintenance area a concern was expressed regarding limited oversight of contractors specifically with regard to the core shroud inspections during 15R. It is agreed that

oversight of contractor work is necessary to assure a qualityjob. In general, however, the level of oversight provided is proportional to the complexity of thejob, the historical work quality of j the vendor and the vendor's performance during the job. It is not appropriate or cost effective

to assign staff to provide full-time oversight to watch vendors perform inspections unless serious problems exist or there is reason to believe there are problems with the vendor's ability to t perform in accordance with requirements. However, it is necessary to keep close account of all

, vendors on a daily basis, to monitor the progress of the work, understand problems that have i- occurred and review their results for accuracy and completeness. -

The lack of direct oversight provided to the vendor in performance of the automated Ultrasonic 4

examination of the Reactor Vessel Nozzles was a decision made prior to the outage. This i examination was fully automatui and computer controlled. The procedure and critical parameters were reviewed prior to the outage and approved by GPU Nuclear, and in the case '

4 of these examinations, were modeled at EPRI to ensure the vendor's procedure was accurate.

The data and scan coverage was reviewed by GPU Nuclear to ensure the analysis was complete.

Therefore, it was not necessary to monitor the examination on a daily basis. GPU Nuclear continues to believe that our level of overview was appropriate for the activity being performed.

4

. 1 R

ATTACHMENT I ~ Response to SALP Evahttion C321-95-2291 - j Page 5 i

1 1

4 1 ENGINEERING GPU Nuclear concurs with the assessment in this area.- We acknowledge and share your concern P. regarding control of the modifications for the Emergency Diesel Generators (EDG). Specific actions taken to address this event were discussed during the subsequent enforcement conference _ l as well as in GPU Nuclear's response to the Notice of Violation and will not be repeated here.

! It'should.be noted, however, that at no time was either diesel generator. inoperable when declared to be operable. The diesels were not considered operable until after they had completed a . all required operability testing. Furthermore, there have been no EDG operability issues during Cycle 15 nelated to the 15R modification work.

l With regarti to the biofouling of the Service Water System, modifications were made to the '

Emergency Service Water systems during the 14R outage to reroute the chlorination point closer to the intake. This modification was not effective in preventing biofouling due to poor l

i performanx of the chlorination system. Following the biofouling events in the summer of 1994, additional modifications and changes were implemented to prevent future recurrences. These changes included the installation of a more reliable chlorination injection system, installation of l inspection ports to allow early detection of mussel growth, environmental permit changes to

' allow continuous chlorination in order to improve chlorination effectiveness, and adjustment to

.the surveillance program to monitor pipe differential pressure. As a result of these initiatives, i there have been no observations of ESW system biofouling during the summer of 1995.

4 PMNT SUPPORT

l

< GPU Nuclear agrees with the assessment in the area of Emergency Planning and Security-f however, in the area of Radiological Controls our assessment differs from that presented in the SALP report. In the Security section of Plant Support, we have taken the following actions to

address training and repetitive lighting weaknesses.

l

• The Security training lesson plan has been revised to add more detail in the area )

of physical " Pat Down" searches. I

- I

' l

• Annual security officer proficiency tests have been revised to include enhancements made to lesson plans.

• The use of " Pat Down" searches have been minimized through the use of hand held metal detectors.

New " Walk-Through" metal detectors have been purchased and are installed.

Y

• Periodic monitoring indicates that corrective actions have been successful.

r

1 Attachment I - Response to SALP Evaluation

! C321-95-2291 Page 6 1

Extensive actions have been taken to resolve the repetitive lighting discrepancies. These actions i should assure lighting levels are continuously maintained.

• "Relamping" has been added to weekly maintenance schedule.

$

• Twenty-eight (28) trailers and one (1) building have been removed from the protected area.

• Extensive trimming has been accomplished on shmbbery inside the protected area.

• Five (5) modifications have been installed to eliminate temporary lighting with at least three (3) more planned for 1995.

• Specific accountability for lighting of the protected area has been given to three

' (3) additional Security Department personnel.

• A System Performance Team conducts a bi-monthly protected area lighting walk downs.

In the area of Radiological Controls GPU Nuclear was pleased ihat the Nuclear Regulatory Commission has noted steady improvement in exposure reduction. It is recognized that Oyster

! Creek continues to be challenged by a high in-plant source term. This has, in fact, been the topic of several discussions with the NRC staff. GPU Nuclear has and will continue to reduce the source term, through a variety of reduction efforts, to as low as reasonably achievable.

Through a continuous long term effort, the three year rolling average has decreased

dramatically. This continuous improvement since 1988 is shown in Figure 1.

OYSTER CREEK DOSE TRENDS 3 YEAR ROLLING AVERAGE 2000 2

• 1500 ------ ------- - - - - - - - - - - -

8E 1 E+idllllilii

+ + + ++ + + 9 4 9 9 5 9 44 4 9 4 + 4 4 +,#

FNEMNG YEAft rsvuent Mgure 1: Three Year Rolling Average

W Attachment I - Response to SALP Evaluation j C321-9.5-2291 Page 7 M

The dose performance in 1995 is expected to be the lowest dose since 1970, the first full year

, of operation. Figure 2 shows the Annual Dose Trends. The expected 1995 dose of 95 rem or less is similar to many, newer BWR plants for operating periods.

j i

, OYSTER CREEK DOSE HISTORY l ANNUAL DOSE 1

2600 aces ---_----------- ------ ---

3 _________ __. .__ ._ ____--__

9 isoo gicoo ____ _ __

a a.

soo --- -

i o =In m

• j eN%NM% M ' M M M YEAR

! esrusse Figure 2 Dose by Year i The continuous dose reduction results achieved are reflected in monthly dose totals as well.

! Dose per month in the operating cycle, as well as dose and duration of outages, has shown a continuous impmvement during the last several years as shown in Figures 3 and 4.

OYSTER CREEK MONTHLY DOSE l

20 ._______________________ l l

15 -- - - - - - - - - - - - - ---------

10 -- --- ---

---

g---

5 - - - - - - - --- - - - --

1982 1983 1994 1996

• YEAR

. as or em Figure 3: Monthly Dose by Year

Attachment I - Response to SALP Evaluation C321-95-2291 Page 8 OYSTER CREEK RECENT OUTAGE RESULTS 5000 1000

_________________ .oo a ._______________ noe g ._______________ 7ae o g3aoa soa soo g l

• 2000- ------------- 400 .

o . __________ 3 g s o.:r.

1000- --------

200 0

rr/###/

OtrTAGE

' ESTIMATE Figure 4: Outage Dose / Duration

)

l These dramatic reductions in exposure are attributable to both exposure control programs and I significant reduction in the source term. Over the last few years, we have conducted two chemical decontaminations of the major recirculation piping and approximately 45 % of the total CoS9 input into the reactor water system has been eliminated. Efforts have included plant design modifications, operational changes, target of opponunity stellite removal, and special maintenance activities specifically to remove stellite. Panicular attention has been paid to the l control of Hydrogen Water Chemistry (HWC) to minimize recontamination of the reactor  !

recirculation system piping by reducing relocation of the Co60 that is present. Due to this  !

effort, there has been no major increase in recirculation piping dose rates attributable to hydrogen chemistry. Based on the most recent data available, from the 15R outage, drywell ,

I dose rates are stable and may in fact be decreasing, which can be attributed to Co59 reduction effons and HWC control.

Attachment I - Response to SALP Evaluation

. C321-95-2291 Page 9 Some of the major CoS9 and Co60 mmoval efforts to date and those expected in the near future am enumerated in Table 1. The Co60 reduction results are illustrated in Figure 5. During the time period between Cycle 11 and Cycle 15 there has been a 30% reduction due to component replacement and a 16% reduction due to condensate polisher improvements. Dose avoidance and Co60 removal is a continuing process. Numerous projects have involved major shielding efforts, decontamination, source removal, and source avoidance as delineated in Table 2.

OCNGS Co40 SOURCES M

g. ._____________________

go - ____________.________

o ,. . ____ ____ ._______ _

O "

a to - _--- -___- ____ -

s . ____ ____ ___ _

/, /////// (

• /////// / #/

Figure 5: Co60 Source Reduction 1

1

Attachment I - Rcsponse to SALP Evaluation C321-95-2291 J Page 10 l

TABLE 1 l Source Term Reduction OUTAGE / CYCLE MAJOR CoS9 AND Co60 REMOVAL EFFORTS 10R Stainless Steel Feedwater Regulator Valve Plugs Were installed llR Chemical Decontamination of Recirculation System was performed Cleaned Main Condensers (Reduces Feedwater Iron) 12R 16 Non-Stellite Control Cell Blades Were Installed Stainless Steel Feedwater Minimum Flow Valve Was lastalled Cycle 12 Modified 16 Spare Contro! Blades to Remove Stellite Modified 4 Spare Recirculation Isolation Valves to Remove Stellite 13R Performed Reactor Water Cleanup System & Recirculation System Chemical Decontamination 9 Non-Stellite Control Cell Blades Were Installed Temporary Cavity Filtration System Was Utilized Replaced Isolation Condenser Valves with Lower Stellite Valves Non-Stellite Last Stage Blades Installed on "B" Low Pressure Turbine ,

Non-Stellite Feedwater Regulator Block Valves Were Installed Cycle 13 Condensate Air Drag Valve Installed 14R "JO Backwash" Modification to Improve Condensate Polisher Cleaning Last Stage Blades On "A" Low Pressure Turbine Replaced with Non-Stellite Materials Performed Modified " Soft Shutdown" Used Temp Cavity Filtration Cycle 14 Evaluated Higher Flow Operation on RWCU - Determined It to Be Valuable to Maximize Cleanup Flow During Power or HWC Changes Low Cross Link Resins in Condensate Polisherr (One of the First Plants to Do So, Feedwater Iron Reduced to ~1 ppb)

Implemented HWC Control Process to Minimize Recirculation System Co60 Buildup 15R Temporary Cavity Filtration Augmented with Skimmer Maximized RWCU During Shutdown 8 Non-Stellite Non-Control Cell Blades Were Installed Stainless Steel Internals in RWCU Pressure Control Valves Cleaned Hotwells Retained ' Aged' Resins in Condensate Demineralizers Cycle 15 Joint Radiological Controls / Maintenance Valve Repair Training lacluding CoS9 Input Minimization / Foreign Material Exclusion New Replacement Low Pressure Turbine to be Procured - No Stellite on Erosion l Shields  !

16R Evaluating 'NOREM' for MSIVs (Not Yet Used in Industry) l 28 Non-Stellite Control Blades to be Installed Evaluating Accelerated Control Blade Replacement Replacement of Last Stage Blades on "C" Low Pressure Turbine Planned l Evaluating in-Vessel Vacuuming to remove silt / fines during fuel movement

Attachmcat I - Response to SALP Evaluation C3'21-95-2291 Page11 TABLE 2 Dose Reduction Initiatives LOCATION PROJECT OUTAGF 14R Began i od 15R Began 09/94 Turbine Building Combined Intercept / Reheat Valve Shields 15R Evaluating Similar High Pressure Turbine Shields Cycle 15 Front Standard Shadow Shielding 15R Heat Resistant Pan / Tilt / Zoom Cameras in the Condenser Bay 15R Evaluating Additional Cameras for Condenser Bay 16R Locked the Turbine Floor to Minimize Dose Cycle 15 Moved Plant Staff Out of an Office With Higher Than Normal Background Cycle 15 Flushed Radwaste Return to Condensate Pipe Cycle 14 Shield is Designed and Approved for Radwaste Return Pipe Cycle 15 Shielding Planned on Condensate Transfer Piping Cycle 15 Water Usage Tracking by Plant Analysis Helps Eliminate Condenser Bay Tours Cycle 15 Eliminated Routine Condenser Bay Tours Cycle 15 Added Permanent Scaffold to Reduce Scaffold Construction Dose Ongoi g A Specialized Portable Man-Lift was Obtained Which Eliminates Some Need for Cycle 15 Dose-Intensive Scaffold Construction in the Condenser Bay Rexctor Building Hydrolased Floor Drains, Underway Again Cycle 14/15 Decontaminated the Reactor Bldg. Equipment Drain Tank (RBEDT) Cycle 14 Shielded Portions of Drains Systems Cycle 14 Performed Robotic Inspection of Filter Sludge Tank Cubicle Cycle 15 Hydrolased Fuel Pool Coolers Cycle 14 Flushed RWCU Filter /Demineralizers Drains Cycle 15 Decontaminated the RWCU Valve Gallery Cycle 15 Flushed RWCU Pipe in Valve Gallery 15R Eliminated Reactor Cavity Coating in 15R and Future Outages 15R Removed the Reactor Cavity Grating Which Was a High Radiation Source 14R Added Second Temporary Cavity Filtration System 15R Wet Lift Equipment & Detensioning Carousel 14R Cut Out & Replaced Hot Spot in Drains Systems Cycle 14 Cut Out of HCU Drain Headers Approved / Planned / Scheduled Cycle 15 Evaluated Operator Tour Dose Sources - Actions Planned Cycle 15 Shielding Under Reactor Bldg. Equipment Drain Tank Cycle 15 Replaced Reactor Water Cleanup (RWCU) Valve Nest Plug With a Plug Easier to 15R Handle Redwaste Building Desludged Three (3) Tanks & Several Feet of Pipe & Shielded Pipe to Support Cycle 14 HPT-IB Relining Filter Sludge / Waste Chemical Filter Bypass Modification Cycle 14 Rebuilt /Rescreened Waste Chemical Fihers Cycle 14/ Cycle 15 Waste Chemical Demineralizers Repiped to Be in Series Cycle 15 Destudged Four (4) Sumps Cycle 14/ Cycle 15 Hydrolased Floor Drain Systems Cycle 14/ Cycle 15 Decontaminated Pump Rooms, Valve Galleries, & Floor Drains Cycle 14/ Cycle 15 Replaced / Upgraded Motors on Filter Sludge Pumps Cycle 15 Changed Filter Pre-Coat Material Cycle 15 Hydrolasing of Tanks & Pumps Allowed Removal of LHRA Controls from Portions Cycle 14 c,f Old Radwaste Radwaste Dismantlement Removed Unused Components Cycle 14 Extensive Use of Hydrolasing & Shielding for Fuel Pool Filter Septa Replacement Cycle 14 Shielded Liner Fill Batch Tank Cycle 14 Remote Liner Capping Tool Cycle 14 Waste Chemical Tank Side Mi -r Modification Cycle 14

TABLE 2 Dose Reduction Initiatives I.f) CATION PROJECT OUTAGE 14R Began 11/92 15R Began 09/94 Drywell Used Encapsulant on Contaminated Insulation 15R Modified Recirculation Fans to Direct Drive 15R Used Remote / Automated Tooling for Weld Inspections 15R Used Remote / Automated Equipment for Mechanical Stress Improvement 15R Reduced Scope for Safety Valve Exchange by Changing the Testing Protocol 15R Added to Thickness of Lead in Shadow Shields on Recirculation Pipe 15R v Added Multiple Shields for Recirculation Pump Repairs 15R improved Surface Decontamination 15R Modified 1-8 Sump Cover to Provide More Shielding & Support Additional Shielding 15R Installed Modification to Support Shadow Shielding ou Bottom Head Drain 15R Installed Long-Term Neutron Monitors to Evaluate Elimination of the BioShield 15R Doors Installed Quick Disconnect Modification on 1-8 Sump Pumps 15R Additional Shielding on Head Drain Pipe ISR Cameras Installed to Monitor Work ISR Permanent Scaffolding has been Added to Reduce Construction Dose with More Ongoing Being Evaluated Evaluating Use of Special Portable Man-Lift to Reduce Scaffolding Dose Cycle 15 General Actions Implemented a Dose Reductbn Tracking System Cycle 15 Implemented the Automated Access Control System with Electronic Dosimetry Cycle 14 Integrated the RWP Into the Maintenance Job Order Cycle 15 Operations Department Implemented a Condenser Bay Performance Team to Improve Cycle 15 Equipment Performance & Thereby Reduce On-Line Maintenance HWC Control Optimization Cycle 14 Continued Contaminated Area Reductions On-Going Significant Reduction in Radwaste Volume 15R/ Cycle 15 Used CO: Decontaminate System - Very Cost & Dose Effective Radwaste Volume 15R Reduction An EPRI Waste Minimization Study was Performed Cycle 14 Operations Department Initiated Condenser Bay Performance Team Cycle 15 Engineering Department Developed Several Modifications That Significantly Cycle 14/ Cycle 15 Improved Radwaste Processing & Reduced Dose Rates in the Radwaste System The Source Term Reduction Committee has identified & is Tracking the Overall Ongoing Source Term Reduction Process at the Plant The Radiological improvement Committee includes Management & Labor in a Single Ongoing Group Which Meets Monthly to Exchange Ideas & Implement Actions Maintenance has Implemented a Long Term On Line Maintenance Window Cycle 15 Approach to Scheduling Which has Greatly Improved the Ability of the Radiological Controls Department to Interface with Maintenance and be Pro-Active in Support Actively Reviewing Zn injection Cycle 15 RCFO Manager is Chairman of the BWROG ALARA Committee Over the Last Two Years Improvements in the Coordination Effort for Work in Ongoing Steam Affected Areas has Reduced the Dose from N16 Significantly. Work is EfTectively Prioritized and Diverted to Power Reductions, Unscheduled Outages, or HWC OOS Windows The Collective Dose Overview Group Includes Senior GPU Nuclear Management and Meets Annually to Review and Provide Guidance On the Overall ALARA Program A Site Visit by EPRI to Review and Discuss the Source Term Reduction Program Cycle 15 has been Requested

i

• Attachment I - Response to SALP Evaluation C321-95-2291 Page 13

. Oyster Creek implemented the revised 10CFR20 as requimd January 1,1994. Subsequent inspections indicated that implementation was complete and appropriate. Oyster Creek's implementation philosophy was conservative and thorough and has been recognized as a strength.

Inspections by NRC staff, both by residents and regional specialists have not resulted in any cited violations of regulatory requirements during the SALP period. Other amas ofimprovement include:

Labor and Management are meeting periodically to improve Radiological ,

Controls / Maintenance interface; Only 2 Radiological Incidence Reports (RIRs) in 1995, only 4 in 15R, both significant decreases; Locked High Radiation Area (LHRA) control among industry best, one in each of last two SALP periods, 26 months between events; ALARA coordination process continues to improve working relationship between Planning and Radiological Controls; Numerous reinforcements on cobalt control: Tech Functions conducted Co59 Reduction training, Spare Parts Engineering issued a Standing Order on Cobalt reduction, conducted combined Radiological Contmis/ Maintenance training, included stellite information in GMS2 component database; RWP has been simplified to include standardized protective clothing sets.

Two weaknesses were identified in inspection reports during the period. One was related to a procedural weakness where a task which was not expected to exceed the ALARA review criteria did, in fact, exceed the criteria as the task progressed. The task did not subsequently have a complete, documented Radiological Engineering Review, although the engineer was maintaining day to day contact and awareness of the task and implemented additional dose reduction actions during the course of the task. Procedural requirements have been changed to explicitly describe the documentation expectations in such situations.

The second weakness was related to moving installed lead shielding in the drywell. During the last outage, a new method of shielding control was implemented in order to allow shielding to be more efficiently used and to reduce the dose required for shielding relocation. It was known in advance that shielding installations would interfere with required pipe inspections. The shielding was designed for and intended to be moved by the inspection crews as needed, however, on several occasions when the shielding was moved the mquired notification to the Radiological Controls Department was overlooked. This problem was self-identified and corrected as the outage progmssed. As we continue to place shielding in more locations within the drywell, interference with work and incmased need for efficient control will continue. A '

primary lesson learned from this experience is to develop a mom effective control method while still providing some flexibility for the inspection requirements during the next outage. ,

~

Attachment I - Response to SALP Evaluation l C321-95-2291 Page 14 The following four graphs depict the improving trends Oyster Creek has achieved in the areas .

of contaminated area recovery (Figure 6), skin contamination rate (figure 7), clothing )

j contamination rate (figure 8), and reduction of radwaste volume (Figure 9). Skin and clothing l contamination rate results for 1995 are significantly lower and are the lowest rates achieved since such data has been trended starting in 1988.

i I

(

I OYSTER CREEK OYSTER CREEK CONTAMINATED AREAS SKIN CONTAMINATION RATE m n g o. ____________________

["

- - - - - - - ~ ~ - - - ~ ~ ~ - -

) I. ._______ __________ )

d. . _ _ _ _____ .___ ge- - -----------

sa ma

) jm. - . _ - ____ y, _ _ ____ _ _

8aan -

.. ___ g

[

4,l 2

l,._____J___,_

! ////////////// E WEAN 10N 114 12M 13A 1.A 1SH i

Figure 6: Contaminated Ana Mgure 7: Skin Contaminations OYSTER CREEK SOLID RADIOACTIVE WASTE CLOTHING CONTAMINATloN RATE TWO YEAR ROLUNG AVERAGE n .

j 3 ,,_ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . __. _ _ _ _ _ _ _ _ _ _ _ _ _ .

s i .

j la_

U

[...

5 j j ,._ __ __ _ _ _ _ _ _ _ _ _ _ _ . g... __. __ __ _ _ _ _ _ . .

[. _ ._ __ ._ _. _ _ _ . . . . ___ __ __ __ _

i an inn un on . un

== ".=~ma == ...

OUTAGE VEARS l l l l

l .

i Figure 8: Clothing Contaminations Figure 9: Radioactive Waste Volume l.

1

1 A;tachment I - Response to SALP Evaluation . j

. C321-95-2291  ;

Page 15  !

Use of the emerging computer and remote technologies can reduce dose and improve efficiency

, and performance. Oyster Creek is implementing automation where appropriate to again reduce a- dose and improve worker performance. Examples of this technology initiated during this SALP

. period include:

The Radiological Work Permit (RWP) has been incorporated into the maintenance job

) order; l

i.

• Automated Access Control simplifies access while providing an Electronic Self-Reading Dosimeter (ESRD) with RWP specific setpoints to each individual;

• Dose reduction tracking system provides a means to catalog, track and record effectively 2 dose reduction innovations;  ;

i Expanded use of permanent video cameras in the Condenser Bay and Drywell planned for fuel pool cooling; l

Company owns remote surveillance and decontamination capable robots which were used for " Exclusion Area" inspection of Filter Sludge Tank Room; l

• Use of digital images provides rapid exchange of information between engineering groups to assess shielding applications;

• The GPU Nuclear Robotics Committee reviews robotics and remote technology applications for in-plant use and maintains industry contact to remain current with applications of the technology; i

'

• New On-Line Maintenance Window Process provides significant improvement in lead time for Radiological Controls' input.

SUMMARY

4 4

GPU Nuclear is committed to continuous improvement in all aspects of operation. The SALP

, report identifies a number of areas for improvement and initiatives have been taken to address these specific areas as well as the broader implications involving programmade improvements.

For example, in the Maintenance area procedural improvements were made ic :cesponse to the con',ainment integrity issue as well as providing additional training to personnel at various levels 4

regarding overall work performance standards. In the current SALP period, we are focusing our attention in the areas of human performance related errors, first-line supervisor development,

' i management oversight and communication. In Engineering, as a result of. process reengineering efforts, the modification process has been substantially improved to be more effective and more i timely in affecting plant improvements. Operations has made significant progress in improvmg ,

i i

t

. . _ = . . ._ _ . . _ . - . _.

' Aftachment I - Response to SALP Evaluation .

• C321'-95-2291 Page 16

. personnel performance. All departments have made personnel performance improvement a high i- priority for continued attention.

. ~

As part of the continuous improvement in radiological protection at Oyster Creel. , attention has focused on a number of areas which contribute to increasing effectiveness of tne program. In addition to the reductions in total dose commitment through effective internal and external dose control, improving individual radiological worker practices / performance reduces the challenge to the program and saves dose. Preventing release of radioactive material from the plant is a focus of the program, with a very low incidence rate of finding radioactive material outside of j the Radiologically Controlled Area (RCA), and no recent events outside the plant protected area.

. Using an INPO accredited training and qualification processes, use of industry events for lessons

learned, and self-identification of problems with timely followup have all contributed to program -

l . improvement.

GPU Nuclear is aware, as discussed during several prior meetings with NRC staff members, that l

Oyster Creek presents a number of unique source term challenges as a result of the plant design.

l Among the more formidable of these challenges are: one drywell hatch where other plants have two or three, three main drywell levels where other plants have four or five, five recirculation loops with lower flow rates, an unenclosed / unshielded drywell equipment drain tank, and a weld 1 inspection scope about double that of other plants. Despite these challenges sustained, continuous performance in reducing radiation exposure demonstrates the effectiveness of the .

source term reduction efforts as well as dose minimization to keep exposures ALARA. The

information provided with regard to source reduction, dose reduction, and radiological controls cover a five year period during which these indicators have continuously trended downward.

l t

i j 1

I i l I

l

,