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s CD Report No. 219/70-8 January 13, 1971 DIVISION '0F COMPLIANCE INSPECTION OF MANAGEMENT SYSTEMS l
l JERSEY CENTRAL POWER AND LIGHT COMPANY (0YSTER CREEK)
Docket No. 50-219 Inspection Conducted:
October 13-16, 1970 October 28-29, 1970 November 5-6, 1970 i-9604170066 960213 PDR FOIA
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o TABLE OF CONTENTS P.*R*.
A.
B a ck g ro un d...................................................
1 B.
Objectives...................................................
1 C.
Planning and Organization....................................
1 i
D.
Utilisation of Manpower......................................
2 E.
Principal Persons Contacted..................................
2 F.
C on c l us io ns..................................................
3 G.
Ins p ec t ion Res ul ts...........................................
3-24 1.
Inspection at Sit 0.......................................
3-15 a.
Problem Identification In Review of Plant 3
Operation and Testing................................
b.
Review and Evaluation of Identified Probleme Including Follow-up Act1on...........................
5
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c.
Availability and Utilisation of Techni'al Support c
i Personne1............................................
6 d.
Perfornance of the Plant Operating Review i
i Committes (P0?.C).....................................
6 e.
Performanca of the General Office Review Bosrd (0025)
An Viewed f rom Site Inspection..............
8 f.
Licensee's Review and Evaluation of Problane at Other Reactors, Including Follow-up Action...........
8 g.
Present Status, Plans, and Criteria R21sted to Plant Staffing.......................................
9 h.
Implementation of Operator Retrcining Progree.......
10L 1.
Reviaw and Approval of Facility Changas in accordence with AEC 3agulatione (10 CFR 50.59).................
10
- j. Systems for Assurina Adequa:y of Facility Procedures and for ths Trcining of Personnsi in t hes e P ro c e darsa.................................. 11
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TABLE OF CONTENTS (cont'd) f.sgi k.
Systou for Assuring Implementation of Required surveillance Tes t P rogram............................
12 1.
Administretive Controls Relating to Plant Maintenanc2..........................................
13 m.
Management Direction and Support - As Viewed f rom S it a Ins pec t io n.................................
13
- n. - Sn.::ary Faecing with Site Management.................
14 2.
In=pection at Management 0ffices.........................
15-21 a.
.Managem2n Eeview of Plant 0psration.................
15 b.
Technical Support cf I'lant Operation by C?U..........
17 c.
Perforr.ance of the GOL3..............................
19 d.
Licenses's Ravin and Evcluction of Problems at Other Raactors, Includi 2g Pollow-up Action...........
^21
- e. ' Iianage:mnt Diroc': ion r.nd Support Relating to Plant Operatior........................................
21 3.
Scnxry I:ieting with compar.y Prssident...................
22
'!. Summary Lis ting of IInj e r Usakn3ce cs..........................
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The~ Division of Cocpliance conducted a special inspection of the manage-ment'o'ystems employed by the Jersey Central Power and Light Cospany (JC) to obtain information on the adequacy of these systems to acsure the safa op3 ration of their Oyster Creek boiling water reactor facility.
The inspection, which is in addition to the Division of Compliance's normal inspection program, was conducted because of recent problemb l
experienced at op3 rating reactors that can be attributed to lack of management attention. This licensee was selected for the first inspec-tion of this type because of their past performanca record and to assess the action taken by JC management in response to Complianco's enforce-ment letter dated September 9,1970.
j Similar inopections of this type are planned fo'r other operating pa:fer reactor facilities.
B.
Objectivas The primary objective of the inspection was to obtain information regardinC tha imples:entation and effectiveness of the management cystsac eeployed by JC for their Oyster Creek facility to ensure cocplianca uith their license and for auditing and evaluating the eefety of operations.
4 A secondary objective use to determine the need for broedening the scope of the Compliancs inspection program at other operating power 3
reactor fccilities.
i C.
Plannint ced Craanist. tion The incpection team was composed of three senior Compliance inspectora:
Mr. R. T. Carlson, Senior Reactor Inspector, C0:1 Hr. J. G. Keppler, Senior Reactor Inspectica Specialict, C0 llQ Mr. F. J. Nolan, Senior Reactor Inspection Specialist, CO:HQ 1
' The major f aatures of tha inspection were as follows:
1.
The inspection keyed on unnagement systems relating to nuclecr sa fety.
2.
The inspection recognised that some of the areas inspected had l
been reviewsd, st least in part, during the courso of thz noraci l
CD inspection pro 3rc.a.
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The inspection effort recognised that absolute standards do not l
exist at this time for evaluating asnagement's performance.
4.
The inspection findings were based on extensive interviews.with cognisant representatives of JC and General Public Utilitiac (G?U),
supplemented by a review of pertinent documentation. As a further 4
check, cpecific examples were selected and "welked throuth" in ords: to test the effectiveness of these managen, ant cyster.3.
'Intervious conducted within the operating organisation or.coopassed
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. all levels of responsibility from the equipment operctor to ths Corocny President.
4 5.
The pertinent inspection findings have been discussed with licensee uanagement representatives.-
C.
Utilisation of Manpower The inspection team spent 11 man-daye on-site and five can-dsys at ths acnacensat/angineering; offices in Parsippany, New Jersey. Follocin the inspection, a summary meeting was held with Mr. R. 7. Bovicr, President, JC, at his office in Morristown, New Jersey. *:he inepac-tion *ca conducted between October 13 and November 6, 1973.
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E.
Principal Persons Contacted Jersey Central Power and Light Company i
Mr. R. 7. Bovier, President Mr. E. H. Sims, Vice President, Production Department
!!r. I. L. Finfrock, Jr., Manager, Nuclear Generating Statione Mr. T. J. McCluskey, Station Superintendent Mr. D. A. Ross, Technical' Supervisor Mr. J. T. Carroll, Operations Supervisor Mr. E. Riggle, Maintenance Supervisor j
Mr. J. T. Sullivan, Assistant Technical Engineer j
Mr. D. E. Kaulback, Radiation Protection Supervisor jl Mr. R. Pelrine, Chemical Supervisor Mr. R. McKeon, Shift Fore.aan Mr. N. W. Cole, Shift Foreman 4
General Public Utilities Corporation Mr. W. Verrochi, Vice President, Design and Construction Civision
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Mr. W. H. Hirst, Manager of Projects and Chairman of OL3 Mr. B. G. Avers, Quality Assurance Manager i
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o Genersi Public Utilities Corporation (cont'd)
Mr. D. E. Hetrick, Manager, Plant Operations and Testing, and I
Vice Chairman of GORE Mr. J. Thorpe, Manager, Safety and Licensing F.
Conclusions 1
The results of this inspection of management systems indicate to the-Division'of Compliance that:
1.
The management reorganisation with JC, which took effect in April 1970, has resulted in active and knowledgeable participation in pie:t - problems by licensee management.
2.
Whereas increased management attention was being devoted at Oyster Creek to improve the safety of operations and the noncompliance record for.this facility, additional efforts are naedad by JO to stabilise and thereby strengthen the onsite operating organiza-tion and to improve observed weaknesses in the parforcance of the reactor safety committees.
3.
The racognized need for a change in Compliance's inspection 'af fort and incraesed emphasis in the areas of managecent syst as es th:y relata to the safety of operations uns demonstratsd.-
G.
Inspection Issults The eignificant findings obtained from thic inspection of menassmant systems are given below. Organization chcres depicting the Cycter Creek plant organization and the acnagement cracnisetion ns it functionally relater to ths Oyster Creek facility cr: providad ca enclosures 1 and 2 to this report.
i 1.
Inspection at Site i
a.
Problem Identification in Review of Plant-Operation and Tes tina (1)
Interviews stith Messrs. McCluskey, Carroll, Rock, cnd Riggla indicated there was close coordination of thsir 2
activities in. tha day-to-dcy operation of tbs facility; however, the abesnee of documentation conce::aing t'm handling of spacific problems traesd' by tha ir:psetion tocc was considered es being reflective of a hi;h deseos of informality.
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j General Public Utilities Corporation (cont'd)
Mr. D. E. Hetrick, Manager, Plant. Operations and Testing, and Vice Chairman of GORB Mr. J. Thorpe, Manager, Safety and Licensing F.
Conclusions j
The results of this inspection of management systems indicate to the 1
Division of Compliance that:
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1.
The management reorganization with JC, which took effect in April 1970, has resulted in active and knowledgeable participation in plant problems by licensee management.
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2.
Whereas increased management attention was being devoted at Oyster Creek to improve the safety of operations and the noncompliance 2
record for this facility, additional efforts are needed by JC to stabilize and thereby strengthen the onsite operating organiza-tion and to improve observed weaknesses in the performance of the reactor safety committees.
3.
The recognized need for a change in Compliance's inspection effort and increased emphasis in,the areas of management systems as they
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relate to the safety of operations was demonstrated.-
j G.
Inspection Results The significant findings obtained from thie inspection of management 1
i systems are given below. Organization charts depicting the Oyster j
Creek plant organization and the management organization as it functionally relates to the Oyster Creek facility are provided as enclosures 1 and 2 to this report.
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1, Inspection at Site a.
Problem Identification in Review of Plant Operation and 1
Testinn i
(1)
Interviews with Messrs. McCluskey, Carroll, Ross, and Riggle indicated there was close coordination of their activities in the day-to-day operation of the facility; however, the abssace of docssmentation concerning the handling of specific problems tracsd by the inspection team was considered as being reflective of a hish degree
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of informality.
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1 (2) There was evidence to show that c working systam anisted in the day-to-day op3rctions at ' Oyster Crsok for the identification of problems in the Oparatiorm Supervisor's areas of raoponsibility. Extensive records vers bein-maintained end revierred. These records este noted to receive at least two layers of review. Although the syston for identification of problems was found to be effective tu j
areas tantod, at least one icportant instcuce was obccrved uhers the cossunication of problems to tha cppropricts levels of acnagement above che Operation Cupcrvisor use inadaquata (i.e., a problem uith high ox/g:n cor. tant in the drywcil).
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(3) Similar observations waro cads concerning erob1:3 identifi-cctics with raepect to ths Tschnical Supervisor'a creca of repoccibility (core phyoice, cociant chenictry, radiclogi-cal enfaty)'; however, daily logo were not reutinely raviewed by the Technical Supervisor. First line supervisors usre hald responcibla for informing the Technical Supervisor of detected problas=. Ons notraorthy and favorable obee.rvation j
uns that the Tschnicc1 Stnervisor was parcenally nsintainias d
and roccrding dets on savsral cafsty rslated parcusterm to neaitor for tronde and long tsrn offects.
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'(4) /. discarnible lech of edzinietret'iv3 crgenizatien va observad in the Maintenance Suparvisor'e arena of re: pone j
s ibility. The inspection tsam found no evidence of c l
vorhing nyetes ralating to ths ravira of osintaatsco cetivitisc and equipment perfortanca, theraby reicin3 c,usstione as to the ciasly idaatificceion of problems in these arsac.
(5) Mr. McCluck:y, Ste ion tuperintendsat, was in Wsshincten, D.C. ou cot;cny businese for the mejerity of the sito 1
inopsetion. B: sed on intervisas uith the senior staff, the innpsetors concludad thet the Station Suparintendent main:ctuad serv:111ancs of ths dcy-to-day operationa y
primarily by meanc of vorbal briafings from the senior staff.
He, in turn, ic responsible for the further ra;vix>
of these problems and communicctions of same, as appro-priate, to highar management.
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asvie f and Evcitetion of Identified Prob 13mc Ireluding Follo s up Action (1) Dapendini; on the nature of the prcbisz id2ntifiad: the inspectors found that problars pesa thecugh ons or core etegna of ir.forcal revic r enrouta to recairing pe cible fortt.cl concidaration. The licaness tekncvladasG chat j
filterina action was inharsr.t in thic proccea.
(2) Tne dster.tination of the need for outsida tschnical easistance in the recolution of idantified pro ~0lamo in sc.ada by the Station Superintendent cad /or :wicor: of his senier staff.
Inspection findin3s noted ths tha u:iliza-tion of out:61de aseistance uc7 or nay not bo :tand13d through written correspondence.
3 (3) The revier.7 cud evaluation of ;robismo brought to the st:entien of the senior staff for conaidsrctien tra not doctnented. Mr. Nc01uckey decida: r$sther the rretlem.
warrants forac1 cencidsrction by t'ta 20EC. Our inspection findinsa indicatsd a po antici existo fer e.atterc :o raceivt. only infornal considwation in incte.nci: ti.wto fornal concidarction by ths 102C, pr ca, es7 t a in ordar.
Yna inopsetoca noted seisral instancss uhsra, in thair j uc'cn:at, ch:".s rea ths c:aa (s.g., tha Sciaion to con-tinua operation :sithout.ths TIP syctau; probism ancoun-terad tfith th: dryus11 oxygen enclysse).
(4) The icote claim.ffcent jrobicus rara fetad to heva rees1*?s3 review and evs.ict. tion by ch: PC?.0 ths G'i.C, and tho LE0; 3
ce cypropric:st in cecordanca uith ths requirsnnte of tha Technieni Opscific:tionc.
(5) Ca t'..oco probin_n trhers folle t-up actiots urn rc:otraenhd, tha fo11errins yt.c noted:
(s) 7er thocs prfalat: that rero not doct=2nted, varifi-ention of follow-up cetion aise tsas not doc =: canted.
(4) Yho fallcr-up cetion on thoas c:: tere ravic :d for.cc117 'ay tha PCR0 has ;enere117 b:.an varified inforac11y; however, etops have racontly basa initisted by the Station Superintendsnt to for~
acli 2 thia verification procaac.
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(c) The follow-up action on matters reviewed formally by the GORB, although more formal than that implied
- in G.I.b.(5)(b) above, has not been consistent.
4 Here, also, steps have recently been taken by the GORB to tighten up in this area.
c.
Availability and Utilisation of Technical Support Personnel (1)
Interviews with the Station Superintendent and his senior staff indicated that authority has been delegated to these people by upper management for the unlimited utilization of consultants in support of plant operation.
(2)
It was noted that there continues.to be considerable reliance placed upon GE primarily outstanding contrac-tural matters; however, consultants have been and are being utilised in a nisaber of areas related to the safety of plant opard. tion.
(3)
Based on discussions with senior plant personnel, it was concluded that the role of GPU in the technical support of the Oyster Creek facility is limited. The indications
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were that the major problem is that, with few exceptions, the people within the GPU support group lack familiarity with the plant and are therefore not in a position to contribute ef fectively. To the extent this subject could be reviewed at the site, the observations made in this area were in contrast to the statements made in Amend-ment 52, page 16, to the Facility Description and Safety Analysis Report. This reference states' in part that:
"This group gives direct technical assistance and guidance to the operating staffs once the stations go into operation."
d.
Performance of the PORC (1) The membership of the PORC is as follows:
Mr. T. J. McCluskey, Station Superintendent (Chairman)
Mr. D. A. Ross, Technical Supervisor Mr. J. Carroll, Operations Supervisor Mr. E. Riggle, Maintenance Supervisor Mr. D. E. Hetrick, Manager of Plant Operations and Testing, GPU, (GORB Member)
Mr. D. Rees. Oyster Creek Project Manager, GPU (OORB Member).
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(2)
Facility records indica:6 that there had been 66.PORC meetings as of the time of the inspection.
Twenty-two of the meetings were held 'during calender year 1970.
i (3) The inspection findings indicate that the more signifi-cant problems have received formal review by the PORC,
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however, a check by the inspectors of some 10 items i
designated as requiring follow-up action indicated that there was no formal system to assure follow-up of these l
items. Although the majority of the items were found to l
have been given proper attention, two of them, both of which required action on the part of the Maintenance Supervisor, had not been completed satisfactorily. As previously stated, action has since been taken by the 4
PORC to formalise verification of matters identified for follow-up.
(4) One responsibility of the PORC, as defined in the Technical Specifications, is to " review plant operations to detect potential safety hasards." This requirement
-i is quite general and while the inspections found the PORC to be reviewing the more significant problems, there have been some instances noted where, in the judgment of the inspectors, these matters did not receive formal review by the PORC (e.g., operation of the reactor with-out the TIP system; test failures with the diesel generator and 125 V d-c batteries). This matter had been pursued l
previously by CO with the licensee with some improvements noted.
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.i (5) Sixteen PORC meetings have been held between the time of l
the previous site inspection and this special inspection.
l One or both 00RB acabers were in attendance at only four I
of the 16 meetings (at a fifth meeting, one member was contacted by telephone).
It should be noted that poor attendance at the PORC meetings by the 00RB representa-I tives has been a recurring problem.
(6) A review of the PORC meeting minutes showed them to be consistently lacking in sufficient detail to permit the GORB to determine whether matters reviewed by the PORC involved unreviewed safety questions.
In addition, the J
inspectors had some reservations as to whether all matters reviewed by the PORC were identified in the meeting minutes.
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(7) One area was identified wheroin it ucs not clear that the licenses was meeting fully the intent of the Tech-nical specifications, i.e., with regard to the respon-sibility of the PORC to investigate all reportad instances of violations of the Technical Specifications.
Review in this area was not completed during this inspection. This matter has been identified for follow-up by the assigned inspector.
- . Performanca of the GORE - as Viewed from Site Inspection (1)
It was recognised at the outset of this inspection that the primary review of the GORB performance would be made se the management offices. However, one important observation made at the site in a concern that the GOR 2 may not be getting the complets picture on the ocfsty of operatione for their consideration due to the incomplete-ness of the PORC documentation. This concern was ampli-fied by the poor attendanco record of the assigned GORB 4
members at the PORC meetings.
f.
Licensee's Review and Evaluation of Problems at Othse Reactorc, l
Includina Follow-up Action (1) There was no effective systen evident for incorporatin; lessons learned from experiences at other reactor facilicies into the operations at Oyster Croeh.
In thic ragarf questions were asked of a number of personnel at all lerals within the site organisation regarding the recent ec:tr -
l-rences at Dresden 2, Humboldt Eay and LACBWR.* All personnel interviewed were awars of the Drasden 2 ccc:r-rence. This particular incident did receive spacini attention by management with respect to its applice -
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'oility to Oyster Creek.
In contrast, not all of enecc l
people were cognisant of the experience et Hueboldt Eny i
and no one was cuara of the occurrence at LACBWK.
Furthermore, several recent failures experienced uit:4 i
engineered safety features at Dresden 2 were generally f
unknoUA.
acr3susn 2 - Depressurisation Incident, Juna 5,1970 Hunbcidt Say - Loss of Off aits Power, July 17, 1970 LACBUa - Dapressurisation Incident, May'15,1970 F
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s (2) Discussions with members of the senior staff indicated that a number of mechanisms are utilised to learn of pertinent experiences at other facilities. These include:
Mr. Rees, and his various channels of i
communication with other facilities and attendance at pertinent professional meetings (IEEE, EEI, etc.);
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Atomic Energy Clearing House publications; tenthly reports that are exchanged with some of the other 1
utilities; matters brought to JC's attention through G3 or JC's consultants; information provided by Co:pliance; and Reactor Operating Experience reporte (11r. McCluskey stated that, in his view, the latter would be of greater benefit if they were issued more timely). While a number of cources of information hcvs been utilised, the efforto being expanded in this regard vero considered by the inspectors to be ineffec-tiva for the most part (based on item C.1.f.(1) above) in that they were uncoordinated and with no organized I
approach tiith respect to translation of follow-up actions applicable to the Oyster Creek operation.
3 Present Statua, Plans and Criteria P. elated to Plant Staffing j
(1) Discussicas tsith the Station Superintendent and his senior staff indicated that there has been a change in ths think-ing of upper nanagement with regard to their understanding of the staffing needs peculiar to a nuclear power facility' va a conventional power plant.
In the judgment of the inspectors, this change in thinking has been motivated at least in part by the discussions held at the March 25, 1970 meeting between JC and the AEC, (2) In regard to icon (1), changas mado to data include tho follorings (a) The addition of 2 associato ongineers and 1 staff enginser to ths Tochnical Supervisor'o staff.
However, it ic noted that the position of Technien1 Engineer 1 otill vacant.
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(b) 'Iha addition of 1 staff engin?ar to tha C;nratSat Supervisor's secff for the purpoca of ot crmoic3 the'overall surveillanco testing progrec.
(c) Tne addition of two Assistant Tachniciars to cort..
both the Radiation Protection Sttparvicar.cd tha
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1 Chemical Supervisor. Alco ons Instrtament and l
Control Technician has been added.
l (d) An increase in the numbers of people in the operating organisation to allou reorganising froct 4 to 5 shift coverage following training and a
j operator licensing as appropriato. This move is l
expected to be completed prior to the end of 1970.
(3) The discussions also revealed plans to further augment j
the plant staff. This, at least in pcrt, in to serve tha futura staffing needs at Forhed P.iver Unit 1.
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licansee emphasised the intent to avoid the problema onparianced in the staffing of Oystor Creek.
(4) Hertofore, the actual assign:nnt of rseponsibilities to the senior members of the plant staff did act coincide f
well sith the job dercriptions provided in the liceast l
spplicction. Thio has been con: pounded by ths nuaScr cf personnal changes made in thoco positions cince the j
issuance of the operating license. The inspectora notsl that improvement has been made in this ragord, i.o., d.o i
individual staff job descriptions havs bscoes more' i
definitiva; however, further improvenant van focad to be in order.
h.
Implementation of Operator Retrainina Progren (1) A formalised personnsi competenes cad esercinic;; program had not boon 1:::plemented at the tics of tho inspsetion.*
A retraining progran plan had been drcf tsd sr.d tics t:nder review by licensee management. Irplansate:: ion of the retraining program uns scheduled to atart Ssfero ths ead of ths year, concurrent with the c=pansion of tho opsrc~
ting staff to five shif tc.
'Iha assignsd esector in=pector j
will follow-up on thic matter.
1.
Eavisf and Approval of Facility Channes in Accordtzeca td.$ A3C-Rsaulations (10 CFR 50.59) l
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date which involved c changs to the fccility froc tSct (1)
Relatively few facility codification: hs' boca cada to
- The licensee's letter to D3L on this subject, dated April 3. ".970, estimated this program will begin in 1970.
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described in the Final Safety Analysis Report (FSAR).
Host of the changes that had been made were initiated l
by C3.
(2)
It was found that substantive changes to plant systems were being reviewed by the 00RB in becordance with Technical Specification requirements.
i (3) Although an improved awareness had been exhibited by the licenses to satisfy the requirements of 10 CFR 50.59, I
the documentation relating to the safety evaluation of these changes, in some cases, was found by the inspectors i
to be marginally acceptable.
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- j. Systems for Assuring the Adequacy of Facility Procedures and for the Training of Personnel in these Procedures t
(1). The inspectors found that the licenses has a system which, i
when fully implemented, should assure the adequacy of the facility procedures on a _ continuing basis. The system includes the assignment of responsibilities to individual senior members of the plant staff. The shortcomings noted in this program at the time of the inspection were an i
follows:
(a) Each senior staff merher assigns priority to his responsibilities in this area depending on how well he is "on top of his job," e.g., essentially no action has been taken with regard t'o procedures assigned the Maintenance Supervisor.
~(b) The PORC has been reviewing and approving procedures as required; however, they were currently backlogged with a considerable number of proposed procedure changes that had been processed to the point requir-ing their review and approval.
(c) A time interval ~ for periodic review of procedures had not been established.
(d) Not all procedures have been tested, including many in the maintenance area. Many of these procedures will be tested during the initial refueling outage.
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' i (2) The requalification of personnel relating to approved changes in facility procedures consists primarily in the routing of the procedure to the pertinent personnal t
for their review. A special form has been provided for this purpose which the individual initials to signify having read the revised procedure. ' This system does
. not assure complete understanding of the change or its basis, nor does it assure that the individual has in i
fact even read the procedure. The inspectors acknoul-odged that there are inherent difficulties in the 1
periodic assembling of operating personnel frot) cil four shifts for group discussions on recent proceduto revisions; howevor,. the need to devclop a more effective manns of requalifying personnel was apperant.
j h.
System for Assuring Implementation of Required Surveillanco Tact Program l
(1) At the ctart of the inspection, Mr. McCluskey revietof, nith tha' inspectors the corrective actions that had been taken by JC to improvo their performance record at Oyster Creek. Mr. McCluskey noted at this time that the one craa where corrective measures had not been impic-mented fully was the area of surveillance testing. N CO inspection confirmed the presence of continuing
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deficiencies in this area (discussed in C0 Report No. 219/70-7).
(2) 'Ihe responsibility for asruring adequate implementation of the surveillance testing program had been divided between operations, engineering and maintenance.
Mr. McCluskey stated that, in his view, this divided responsibility had contributed significantly to the previously identified inadequacica in their program f y
and that responsibility for surveillance testing was to be delegated solely to operatione in November 1970.
Furthermore, Mr. McCluskey stated that a staff engineer position had been created uithin the operations group, and that this individual.was to be aesigned full timo in the area of surveillance testing and would have the responsibility for carrying out the required program.
1,) Se,veral items of noncompliance with Technical Specifications require-4 ments in this area had been detected during previous CD inopections.
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(3) Surveillance test results are reviewed at the Instrument Foreman and Shift Foreman level, and are not routinely reviewed by the senior staff. Furthermore, it was noted that the system for maintaining and reviewing surveillance test results does not permit easy evaluation of changes or a
trends.
1.
Administrative Controls Relating to Plant Maintenance
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(1) The principal means employed by the. licenses to control i
plant maintenance work is a job order permit. These permits may be initiated by almost anyone within the plant organisation but all job orders ars processed through the operating organisation and require formal l
approval by the Operations Supervisor.
It was noted that the permit requires a determination of whether the
. work will affect Limiting conditions for operation.
i (2) The inspectors' revieu indicated that all important work was being handled by this mechanism. Houover, it was noted that a potencial existed for some work of a minor nature to be performed without the use of a vork permit.
(3) An audit of the job order file and other maintenance records by the inspectors revealed the following weakness es i.
(a) Not all completed job orders had boca signed by all responcible individuals as required.
(b) The synten for maintaining and revietting maintent.nca test records fails to allou a determination of lect-term trende regarding equipment performance.
m.
Management Direction and Support - as Viewed from Site
[
Inspection (1)
In response to a direct question, the inspectore ucra informed by Mr. McClushey thct managercent directivse relating to the operation of Oyster Creek aro prite.rily verbal.
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(2) Mr. McClushey noted that he to in daily connunication u'.th l
Mr. Finfrock and othars ca en ::are reinting to ths oporn -
l-tion of the plant.
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(3). Ifhen questioned regarding what specific direction he i
received as a result of the March 25, 1970 meeting i
between JC and the AgC, Mr. McCluskey stated that j
l subsequently Mr. Bovier held a meeting of pertinent management personnel at which Mr. McCluskey was present.
i l
Mr. McCluskey stated that ~at this meeting he was instrue::ed to (a) improve the company image with the AEC and to 4
(b) add depth and operating experience to the plant staff.
j n.
Summary Meetina with Site Management s
A summary maating was held by Messrs. Carlson and Keppler with 4
j Messrs. McCluskey, Ross, Carroll and Riggle at the conclusion of the site inspection on October 16, 1970. The objectives of the inspection including the related planning and organiza-tion, as discussed in Sections B and C of this report, wara 1-reiterated.
The major findings and observations reported in Sections G.1.a.
through m. were reviewed.
In addition, the following generci observations were made by the inspectors i
(1) The plant had been in operation for 18 months; however, l
JC was still organising their staf f and systems which should have been fully in effect prior to plant startup.
The surveillance testing program and maintenance program l
uere cited as specific examples of the latter.
Mr. McCluskey acknowledged this but pointed out that the problem was not a result of inadequate efforts by JC to augment the staf f or to upgrade their programs at Oyster Creek. He stated that significant ef forts were being expended by JC management to complete the staff at the l
facility.
(2) Although evidence was noted of positive steps taken by JC to improve their performance at Oyster Creek, the inspectors stated that they questioned whether what JC has done is sufficiently adequate and timely when con-i sidered in light of recent experiences at operating BWR facilities. Mr. McCluskey stated that he heard the comments but had no specific r.asponse. He indicated that the comments made by the inspectors would be taken under t
consideration.-
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(3) Contributing to the concerns stated above is a relatively high degree of informality or looseness sensed in the j
operating organisation. Mr. McCluskey stated that JC l
considered a certain amount of informality desirable and that they were opposed to operation by committee. He added that he did not feel the degree of informality was excessive; however, in view of the inspectors' comments and certain examples. cited in this regard, Mr. McCluskey indicated that further consideration would be given to this concern.
1 2.
Inspection at Mansassent Offices a.
Manamsment saview of Plant Ooeration (1) On March 25, 1970, a meeting was held by senior representa-tives of the AEC with the President of JC to review
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regulatory's concerns regarding the conduct of oper'stions at Oyster Creek. Subsequent to this meeting, several j
important organizational changes were effected. Th.es e are as follows:
(a)
Mr. J. Logan, Vice President, chose the option of early retirement.
(b) On April 28, 1970, Mr. R. H. Sims, Vice President, assumed the responsibility for operation of the
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Company's Production Department. In this position t
Mr. Sims has overall responsibility for JC's opera-ting power plants.
j (c)
Mr. G. H. Ritter, Vice President and former Director i
of the GPU Nuclear Power Activities Group, has been i
assigned new responsibilities unrelated to the i
Company's operating nuclear activities.
(d) Freviously, Mr. G. Kalcee, as Manager of Generating i
Stations, had responsibility for both nuclear and conventional plants. On April 23, 1970, Mr.'I. R.
Pinfrock was named Manager of Nuclear Generating l
stations, and Mr. Kalcec was named Manager of j
Conventional Generating Stations.
(e) A number of additions to the plant staff were made.
(See Section P.1 3).
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'(2) Mr. Finfrock is intended to be the focal point within JC management for handling important matters related to j
Oyster Creek. He told the inspectors that when Mr. Bovier a
appointed him to this position he was verbally instructed l
to give priority to strengthaning the Oyster Creek opera-ting and support function organisations and to improve d
j JC's image with the ABC.
(3) Discussions with Er. Finfrock indicated that he is in daily telephone communications with Mr. McCluskey con-carning the' status of the plant and current problems, and that he has been spending one day each week at the plant. In addition, it was learned that he has routine docessated communications from the site that include e daily plant operations summary, a monthly operations statistical report, abnormal occurrence reports, minutss of telecons with the ABC, and PORC meeting minutes.
Furthermore, Mr. Finfrock has instnacted plant management to inform him of any problem related to th facility 4
license or any problem affecting plant capability.
Mr. Finfrock estitisted that presently over 90 percent of his time was being applied in support of the Oyster Creek facility and that within the next year he expected to add an assistant and four staff engineers. Based on discus-siens of-several actual and potential problems at Oyster l
Casek, theJytoaa r.oncluded that Mr. Finfroch had established of factive administrative controls for main-taining close surveillance of the operating program.
Notwithstanding, the inspectors noted one instance whsre Mr. Finfrock was not aware of a significant safety i
l related problemi 1.e., one of several occasions where high oxygen concentrations within the drywell were experienced during operation.
l (4) Mr. Sims does not have a nuclear background or previous nuclear experience; however, he appeared to have an active interest in the Oyster Creek facility and is j
kept informed of significant developments daily through j
i Mr. Finfrock. In addition, Mr. Sims stated that he visits the site on a monthly basis to get first-hand knowledge with respect to reactor operations and signi-ficant problems being encountered.
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oignificant davslopments at Oyster Creek and that he had been requected, follotting the March 25 meeting with the t.RC, to ha kept inforned on important matters.
1 (6)- Disetmeions trith Hessrs. Sims and Finfrock and a review l
of specific doctsnantation revealed that memoranda are properod by plant personnel and distributed to management summarising partinent information relating to all Compli-ance intpcetions and telephone inquiries.
In response to questions concerning what feedback JO management had received relating to the sito portion of this inspection, 3
Mr. Fiu,froch stated that tuo memoranda had been written i
stannarizing partinent questions and observations made by l
the inspector and that these uere distributed to all 3
senior uenc3amant representatives including Mr. Kuhns, 1
l Presidant of GPU, at his request. The inspectors revictred thers mmoranda uith Mr. Finfrock and found then te be cer:prehensivo and rassonably accurato.
b.
Technical Supr, ort of Pitnt Operation by GPU (1) Based on information provided in Ansadment 52 to the FDSAn plus ths improacion communicated to regulatory repracontativen during vcrious pro-licensing meetings (atter.ded by the inspectors) the inspectors wira of the i
vie:J that GPU t?ould bo participating " heavily" in support of the day-to 4ay operations at Oyster Creek, i
(2) In vie:s of the above, tha inspectors diocussed trich Mr. Fiufrock ths inage thay hed received from sonier site porconnel to the effect that the rolo that GPU tino playing in suppcrt of Cynter Creak uns limited.
Hr. Finfrock oxpressed some surprise in this regard and indicated that GPU vas and had boon involved in n number l
of imports.nc espacts of plant operation (e.g., fuoi i
management, control rod drive modification, evaluation of isolation condenser trip point setting). Although 11r. Finfroch's rsmarks indicated that GPU was involvae' to a greater extant than ths inspectors had t'hought, i
based on the site inspection, this involvsment t*ao ctill short of what the inspectors had expoeted to see.
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4 (3)
Interviews with Messrs. Varrochi and Finfrock indicated that the functions and personnel of the former GPU i
Nuclear Power Activities Group have been absorbed within -
l the newly-formed GPU Service Company. This technical support function is assigned within the Design and l
Construction Division under Afr. Verrochi. Mr. Verrochi conveyed to the inspectors the impression that only a musil portion of the Division's effort had been placed on technical support to date and most of this had been in the areas of design and construction; however, he l
added that personnel were available for technical support of the Oyster Creek facility, when needed, and that he had instructed his Division managers to provide assistance to Mr. Finfrock in any voy they could. Mr. Verrochi also pointed out that, in recognition of GPU's current coenit-i monts in the nuclear field, an operations. planning unit had been established within his Division. This unit, which is headed by Mr. Hatrick, 'will also have responsi-j bility within GPU for fo11otting reactor operations at Oyater Creek on a routine basis.
l (4) The inspectors met with Mr. Avars to discuss the role that he, an Manager of Quality Assurance, has with respect to maintenance or planned modifications at j
Oyster Creek including specifically the applicability of the AsC's 10 Quality Assurance Criteria (10 CFR 50, tppendix B). Mr. Avsrs stated that his group would be I
involved in the in-service inspection progran scheduled
. to be performed during the first refueling outago, but that he had no responsibility for quality asouranca as i
it pertains to plant modifications or routine naintenance at Oyster Creek. The inspectors notod that the quality i
Assurance group was not involved in the proposed modif',-
i-cations to the scram reset circuitry. In response te questiono from the inspectors, Mr. Avero niso stated that his group haa no responsibility for updating plent system drawingo. This indicated lack of automatic involvement.
j at Oyster Creek on the part of the Quality Ascurance group was discussed Uith MR. Finfrock. Mr. Finfrock appeared e
surprised and said that he elaarly undoratood that the Quality Accurence group uould be actively involved at Oyster Crsoh. He ctated thr.t ho uould.discuse tho enttar uith Mr. Avers to clear ray oisu'.dcretandin3n.
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Performance of the CORB 1
l (1) The men'oership of the 00RB is as followst
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i i-e.r. U. H. Hirst, Hansger of Projects, GPU (Chairman) j Mr. D. E. Hatrick, Manager of Plant Operations and e
Testing, GPU (Vice-Chairman) '
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Dr. T. M. Snyder, General Electric Company Dr. W. A. Sutherland, General Electric Company Mr. U. W. Lowe, Pickard, Love and Associates i
Mr. D. R. Rees, Project Manager - Oyster Creek, GPU l
j Mr. I. R. Pinfrock, Manager, Nuclear Generating Stetions, JC (non-vot'ing member)
Mr. J. Thorpe, Safety and Licensing, GPU i
i (2) ' Pacility records indicate that there had been 19 GORB -
meetings as of the time of the inspection,16 of which
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were held subsequent to the issuance of the operating i
license on April 9, 1969. All members have had a good j
attendance record at meetings. A review of the more i
recent meeting minutes by the inspectors indicated that matters scheduled for review at meetings were receiving adequate attention by the 00RB.
(3) Mr. Hirst told the inspectors that although Abnormal Occurrence Reports and Scram Reports are supplied to him, 1
not all are routinely distributed to all GORB members; however, he indicated that he saw to it that the impor-tant or.as were forwarded to each member.
(4)
In view of the lack of detail provided in the PORC meeting minutes and the poor attendance record of the two musigned j
GORD memb'rs at the PORC meetings, the inspectors inquired as to other means being utilised by the 00RB to learn of l
important events relating to Oyster Creek. Mr. Finfrock stated that he has daily comunications with Nesaro.11strick, Thorpe, and Rees concerning plant oport-p.
tions. - Also, Mr. Retrick indicated that he has frequent telephone contacts with ' site' personnel to supplement his knowledge.
It was learned that this supplementary infost -
nation is not provided routinely to the "outside" menbsts of the GORB. The inspectore questioned that this approach would appear to constitute en informal review of sofoty related matters by a partial committee as compcred to tho intended mors formal revieu by the full ecamittee..
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Messrs Finfrock and Katrick acknowledged that a certain
- amount of filtering is inherent in this approach but j
that they felt that all important matters were being l
brought to the attention of the full couaittee.
(5) The ' initial revisi of GORB related correspondence revealed some missing meeting minutes. Furthermore, there appeared to be a lach of written reports-to.the Company President of reported instances of violations of the Technical j
Specifications, as required by the Technical Specifications.
During this initial review, Mr. Hirst was out of town. The inspectors est with Mr. Hirst on N3vember 6 and asked to see the GORB files. Mr. Hirst, af ter considerable effort, was unable to produce the desired documents. This matter has been identified for follou-up by the assigned inspector.
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(6) The inspectors interviewed Mr. Hirst for approximately one j
hour. It wasn't long into this interview before it became readily apparent to the inspectors that Mr. Hirst's involve-i ment, as Chairman of 00RB, tras superficial..Furthermore, Mr. Hirst's understanding of his role as Chairman o.f GORB j
and the role of GORB, per se, appeared to fall short.of that intended by the Technical Specificatione. Thsan i
usctors have also been identified for follow-up by the escissed inspector.
1 l
(7) The quarterly audita of plant. operations required by the Tochnical Specifications have not been performed by GORB,
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l but rather have been performed by the GPU Quality Assurance l
group. The GORB membars select the areas to be audited and at least one of the GORD members-is assigned to the audit team. The 00RB cleo has roquested recently the GPU - QA i
audit group to verify complation of matters identified by i
the GORB for fo110'f-up, in an attempt to formalise j
verification of thess mattero. An internal audit report j
l 1s written follouing each audit t1hich provides pertinent findings and recommendations for corrective actions required. s record of action tahon, and final signoff by the QA engineer. A roviou of the audit rocords by the
'j inspectors indicated that the scopo of the atu'its tras i
quito narrow (e.g., ons audit covsrsd a review of cur -
i veillance records for Limiting Safety System Sotpointo another covered logged operating data portsining to Limiting Conditions of Operatioc) and that the audita generally covered one day.
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d.
Licensei's Review and Evaluation of Problems at Other Reactors.
Includina Follow-up Action i
i (1) In view of the information learned at the site and reported in paragraph 6.13. of this report, the inspectors questioned management representatives whether any organised approach had been developed en their part for learning of problems at other facilities and reviewing their applicability to Oyster Creek. Masers. Finfrock and Hatrick indicated that they and Mr. Rees have all tried to provide assistance in this regard but acknowledged that there was oo focal point for assuring the adequate attention and related action regarding problems.
In subsequent discussions Messrs. sins and Finfrock stated that JC would initiate action to utilise more fully the mechanisms available to them in this regard.
a.
Hansaament Direction and Support Balating to Plant Operations.
(1) It was apparent to the inspectors that upper management became norm inwolved with respect to activities at Oyster Creek following the March 25, 1970, meeting between the AEC and Mr. Bovier. The evidence of this involvement is reflected in the following:
(a) The already accomplished augmentation of the plant staff and the further changes (Paragraph G.1.g.).
(b) Creation of the position of Manager, Nuclear Genera-ting Stations and filling the position with an individual (Mr. Finfrock) vbo had considerable knowledge of Oyster Creek (Paragraph G.2.a.).
)
(c) Assigning an individual (Mr. Hetrick) with concider-able knowledge of Oyster Creek'as Vice Chairman of GORB (Paragraph G.2.c.).
(d) Daily briefings on Oyster Creek at the Vice President level (Paragraph G.2.a.).
(a) Notification of the Company President of important matters relating to operations at Oyster Creek (Parnaraph G.2.a.).
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Summary Meetina with Company President l-1 j
A summary meeting was held by Messrs. Carlson and Keppler with' J
Mr. Bovier at the conclusion of the inspection on November 6,1970.
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Messrs. Sims and Finfrock also participated in the meeting. The
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objectives of the inspection, including the related planning and
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organisation, as discussed in Sections B and C of this report, j
were reiterated. The following additional introductory remarks were made by the inspectors i'
a.
Oyster Creek had not been singled out for this' inspection and l-similar audits were being planned of other licensees.
l b.
This meeting was being held with Mr. Bovier because the j
inspectors had noted his personal involvement with Oyster Creek and thought that he would be interested in the inspec-i tors findings.
1 j
c.
The areas of inspection were subjective with no standard of comparison. In this regard, the assessment was said to be incomplete; i.e., it would be continuing as it encompassed other licensees.
d.
The inspectors commented on Compliance's favorable reaction to l
JC's response to the enforcement letter of September 9,1970.
Mr. Bovier expressed pleasure at hearing this and stated that JC had made a particular effort to be responsive to the concerns of Compliance..
The inspectors then proceeded to discuss the significant inspection 4
nbservations in a chronological sequence. These are as follows:
. The inspectors told Mr. Bovier that they were aware of the a.
existence and content of minutes that had been prepared by i
Messrs. McCluskey and Ross following the site inspection and j
which had been distributed to management, including himself.
The inspectors acknowledged that these minutes were compre-i hensive and reasonably accurate and,' therefore, they would defer further discussions on the site-related findings unless 1-Mr. Bovier desired further clarification.' Mr. Bovier stated I
he felt that he had a clear understanding of Compliance's findings and observations. from the site and that he did not j
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require additional clarification of these matters.
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With respect to the inspection se JC's management offices, 5
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the observations made were presented in summary form as
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follows:
(1) n a inspec*. ors stated they had a favorable reaction I
regarding the current organisation, particularly the performance of those responsible for the operations functions within annagement. The inspectors added that this, in their judgement, represented a measurable improvement over previous observations made in'connec-
. tion with Oyster Creek; however, it was pointed out that the changes made were relatively recent and that
'l observations over a longer period of time would be necessary to determine the true effectiveness of these l
changes.
l Mr. Bovier stated that he believed Jersey Central was now on top of their responsibilities and that they had no intentions of relaxing management's involvement at l
Oyster Creek. He' indicated that he would continue to l
.look forward to Compliance's comments on their performance with the passing of time.
(2) The observed contrast between the technical support actually being provided by GPU and the role that ths I
inspectors understood would be served by GPU was l
identified.
i he inspectors pointed out that they did not knotr how to l
handle this matter at this time.
l Mr. Bovier offered no position regarding the observa-l tions made by the inspectors.
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(3) Se inspectors discussed their views on the performance of the GORB. H e inspectors pointed out that the off-l site safety committee was considered by the AEC to be an important management tool and, based on observations i
made during the inspection, that JC annagement was not deriving fully all the benefits that they could from the l
00RB. Specific concerns ' discussed included the followingt
-(a) ne shallowness of the audits - the inspectors emphasised their personal experiences in this regard.
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(b) The observed shortcomings with respect to the channels of communication available to the GORB; e
1.e., PORC meeting minutes; GORB member participa-'
I tion in PORC meetings; the potential for the GORB to be an "in-house" committee.
(c) The lack of objective evidence regarding the required formal communications between the GORB chairman and Mr. Bovier.
The inspectors informed Mr. Bovier that follow-up inspections of the GORB performance would be made by the assigned in-spector.
Mr. Bovier stated that prompt action would be taken to improve the PORC minutes and the participation by GORB members at scheduled PORC meetings. He also stated that steps would be taken to strengthen the audits performed at Oyster Creek.
While Mr. Bovier made no specific commitments concerning the inspectors negative observations relating to the overall performance of the GORB, he indicated his intentions to look into the operations of the GORB.
(4) 2ne inspectors noted that many problems were being experienced at operating power reactors that could have applicability to Oyster Creek.
In this regard, the inspectors summarized their negative findings, both at the sits and within management, and stressed the importance of having an organized approach for evalu-ating and following-up problems at other facilities.
Mr. Bovier indicated that JC would reexamine their past practices and take the necessary steps to assure that lessons learned at other reactors are properly incor-porated at Oyster Creek.
c.
The inspectors stated that although, based on this inspec-tion, they had concluded that JC had initiated positive corrective measures to improve their performance at Oyster Creek and that while measurable progress had been realized, continued close attention by management appeared warranted.
i Mr. Bovier thanked the inspectors for their frank appraisal' and stated that efforts would not be relaxed in their endeavor to improve their performance.
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Suasary 1.istina of Major Weaknesses 1.
Weaknesses existed in the administration of the maintenance group operation (Paragraphs G.1.a, G.1.j, and G.1.1) 2.
The role of the GPU support group at Dyster Creek was limited (Paragraphs G.1.c and G.2.b).
3.
Weaknesses existed in the performance of the PORC (Paragraph G.I.d).
l 4.
Weaknesses existed in the performance of the GORB (including specifically the audit function)(Paragraphs G.1.a. and G.2.c).
5.
No effective system existed for incorporating lessons learned from experiences at other reactors (Paragraphs G.1.f. and G.2.d).
1 6.
Corrective measures in the area of surveillance testing had still not been fully implemented (Paragraph G.1.k.).
3 f
Enclosures:
1.
Oyster Creek Plant Organization 2.
Oyster Creek Management Organization 4
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l OYSTER CREEK PLANT ORGANIZATION Plant Superintendent.
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T. J. McCLUSKEY q
Operations Supervisor Maintenance Supervisor J. T. CARRG1 E. RIGGLE I
Shift Foreman Technical Supervisor (1 per shift)
D. A. ROSS Control Boom Operators b
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(2 per shift) t
' 'O' Radiation & Chemical Technical Engineers Supervisors Equipment Operators (2 per shift) i s
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I OYSTER CREEK MANAGE E NT ORGANIZATION President
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R. F. BOVIER c.
1 T-4 GORB
~'. H. HIRST, CHAIIBdAN Vice Pasident
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____i R. H. SDIS I
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s GHJ MIR - Nuclear Generating Stations
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I. R. FINFROCK j
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Oyster Creek l
Station Superintendent T. J. McCLUSEEY 1
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