ML20133G691
| ML20133G691 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 09/30/1985 |
| From: | Fischer S, Green H, Hendrie J MISSISSIPPI POWER & LIGHT CO. |
| To: | |
| Shared Package | |
| ML20133G668 | List: |
| References | |
| TAC-59910, NUDOCS 8510160083 | |
| Download: ML20133G691 (26) | |
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GRAND GULF NUCLEAR STATION UNIT 1 i
POST WARRANTY RUN i
I OPERATIONAL READINESS REVIEW SEPTEMBER 1985 k
i i
Performed by: MP&L SRC Special i
' Subcommittee for Review of Plant Operational Readiness J
Members:
Mr. H. J. Green - Chairman Dr. S. R. Fischer Dr. J. M. Hendrie 1
Dr. D. W. Jones Dr. F.~E. Tate i
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't REPORT OF THE SAFETY REVIEW COMMITTEE SPECIAL SUBCOMMITTEE FOR REVIEW OF PLANT OPERATIONAL READINESS I.
Introduction This report documents the review and evaluation performed by the SRC Special Subcommittee for Review of Plant Operational Readiness following completion of the 100-hour warranty run.
The post warranty run readiness review is a requirement of paragraph 2.C. (4) of the Grand Gulf operating license.
The subcommittee was appointed on November 20, 1984. The members, since that date, independently and periodically visited the plant interviewing i
people, reviewing documents and observing activities in progress. This effort culminated with a concentrated effort beginning August 27, 1985 and concluded with the issuance of this report.
The subcommittee's conclusions and recommendations are based on findings resulting from interviews, observations, discussions and where necessary reviews of pertinent documents. While not necessarily all inclusive, to the best of our knowledge and belief they are correct and appropriate.
In the course of our evaluation we formulated a number of recommendations. These are not requirements to be met for continued operation, but are suggestions which, if adopted, should result in improved plant operation. The subcommittee, in the course of its investigation, reviewed the resolution of comments and recommendations contained in the 50 Percent Power Operational Readiness Review Report.
Results of this review are presented in Section III of this report. The subcommittee concludes that, observing normal procedural controls, plant and personnel are ready to continue with commercial operation.
II.
Review and Evaluation (i) Status and Readiness of The Plant and Systems Needed to Support Intended Modes of Operation and/or Testing.
a.
Introduction With successful completion of the Power Ascension Program and Warranty Run, the unit is scheduled to be on line until early October 1985 at which time the Fall Outage is scheduled to begin and last an estimated seven weeks. Upon completion of this. outage, the unit is again scheduled to operate continuously until the First Refueling Outage which could start as early as April 4, 1986 or as late as October 10, 1986 based on load factors of-0.90 to 0.50 respectively.
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The Fall Outage is necessary in order to perform the cold shutdown surveillances necessary to permit unrestricted operation until October 10, 1986, the late start date of the First Refueling Outage.
The outage is also required to support completion of NUREG 0588 commitments for the safety relief valve (SRV) solenoids.
The scope of the Fall Outage includes a number of items that were commitments for the First Refueling Outage. This allows substantial savings in the First Refueling Outage and will have minimal impact on the Fall Outage duration. The Fall Outage appears to be well planned and the outage work list has been essentially frozen since May 24, 1985. One of the items scheduled to be accomplished during the Fall Outage is induction heat stress improvement (IHSI) on the recirculation piping welds.
The plant and supporting staff demonstrated the ability to work together as a team in a commendable effort during an outage to repair the main condenser February 13 to March 28, 1985. The outage was unscheduled and occurred unexpectedly.
Within a few dsys after the forced shutdown, a schedule had been developed which not only provided for repair of the main condenser but included accomplishment of a significant portion of the activities previously planned for an expected outage later in the spring.
(This scheduled outage became unnecessary in view of the work done while the condenser repairs were being carried out.) The outage went well. All work was accomplished to the highest standards and the outage was completed ahead of schedule. This flexibility and the ability to get things done in an expeditious and competent manner reflect well on the management and supervisory ability of the staff.
Primary water chemistry has been held not only within the license limits but within the tighter GE limits. The radwaste operation, once a subject of doubt, has functioned well and radwaste and bulk water handling matters have not interfered with or limited plant operation.
The subcommittee is pleased to note the continued improvement in plant appearance. Plant management has, since our last review, pressed forward and made steady progress in improved labeling, painting and cleanup.
In the course of its review, the subcommittee recognized several uncorrected conditions which have the potential for adversely affecting planc availability and/or load factor.
The following are examples:
One item concerns cooling tower capacity. Analysis of performance data indicates that the tower as constructed is not capable of removing the plant's full design heat rejection J09 MISC 85090513 - 2
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i load. Because of this, the plant is not able to operate efficiently at high power levels during the summer months.
The Plant Service Water System contains deficiencies which are being addressed but still may adversely affect plant reliability. Water quality is generally poor leading to fouling of heat exchange and other surfaces, pump wear has been excessive, and the control system has proven to be unreliable and can be adversely affected by weather conditions. A fourth well is under construction to increase the volume of water available and thus improve flexibility and a
reliability.
Another potential problem area is the chillers in the Auxiliary Building' Chilled Water System. The three installed 800 ton compressors experience frequent failures. The vendor i
is no longer in business, so spare parts are-difficult to obtain. The two compressors from Unit 2 are being utilized as available spares permitting continued operation.
Another deficiency stems from a chronic leakage problem at the flanges of the feedwater flow venturi. Over 12 man-rem have been received in attempts to stop the leakage. This amounts to approximately 35% of the total plant exposure to date.
All of these deficiencies are recognized and both interim and longer term efforts are underway to solve the problems.
During the month of July 1985, the first month of commercial operation, the plant achieved an availability of 95.8%, a capacity factor of 78.3%, and a 4.3% forced outage rate.
For August, the second montt. of commercial operation, the availability and capacity factors were 87.0% and 78.0%
respectively.
i Management continues to demonstrate a keen interest in providing timely and prudent decisions related to operational and equipment problems, and the plant and systems are in a high state of readiness to support continued operation.
(ii) Readiness of Personnel to Conduct Intended Operation and Testing a.
Staffing The subcommittee examined the staffing of the plant and support organizations. 'Since the startup tests have been completed and the plant declared in commercial operation as of July 1, 1985, the subcommittee's attention was directed at staffing levels to support long-term normal operation.
The plant staff has been at 689 budgeted positions through the first half of 1985, which is slightly (5 positions) larger than the 1984 authorized strength. In August 1985 an additional 34 positions were authorized, bringing the plant J09 MISC 85090513 - 3 l-
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staff to 723 budgeted positions. The 34 additional positions are for local entry level trainees in the health physics (12),
radiation chemistry (6), instrumentation and control (10), and computer sections (6).
The MP&L employee on-board strength stood at 632 as of August 26, 1985 with a number of offers outstanding and being considered. The remaining open positions are filled, except for the 34 new trainee positions, by consultants and contractor staff.
As detailed later, a number of changes in MP&L personcel policy have contributed to the succesa of current recruiting and retention efforts. These include better communication and understanding between the MP&L personnel department and the nuclear organization, development of an improved employee appraisal system, improved position description and rating processes, and improved ability of the Company to offer competitive, employee benefits and compensation. A new, continuing education program that is fitted to nuclear work force need and is compatible with work schedules should contribute to retention of key employees. The overall nuclear work force turnover rate was about 12% in 1984; it projects to 8 to 10% for 1985.
The Operations group is adequately staffed with licensed personnel. The plant is operating on five shifts, with two SR0s (Shift Superintendent, Shift Supervisor) on each shift and with three additional SR0s in the group management (Operations Superintendent, Operations Assistant, and Operations Training Assistant), for a total of 13 SR0s. Tre additional SR0s are expected to be licensed in the near future, provided the NRC accepts the control room experience levels of the two candidates, which are slightly below the 4-year requirement for SRO licensing at operating plants.
If accepted, this will bring the SRO total to a level to support 6 shift operation. In February 1986 one more SRO is expected to be licensed, which would give the Operations group 16 SR0s, enough to manage the group, man 6 shifts, and have 1 extra SRO to fill in for people during absences. The SRO training pipeline for Operations is full, with an adequate field of candidates among the RO license holders (Nuclear Operators-A).
There are also 4 licensed SR0s in the Training group and people in the pipeline to increase this number.
At present there are 15 R0s in the Operations group, on 5 shifts. A new group of R0s is expected to be licensed in the near future and all of these will be assigned to Operations.
The addition will support 6-shift operation, with 3 R0s on each shift. This is in excess of the minimum RO staffing specified in the license (2 R0s per shift), but is the preferred manning level. The subcommittee agrees that 3 R0s per. shift is a preferred number and should be an objective for normal long-term operation; however, the licensed manning level of 2 R0s per shif t is adequate for safe operation and is acceptable when conditions require it.
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After mid-1986, licensed manpower projections show 2 extra Ros (a total of 20) and after early 1987, 6 extra R0s (a total of
- 24) in the Operations group. The extra R0a are needed to help cover during absences and especially to provide slotn For people in SRO training. This keeps the SRO pipeline full on a continuing basis. The R0 pipeline, in turn, is kept full by drawing candidates for RO training from a 34-person group of Nuclear Operators-b (non-licensed control room operators).
The B operators are obtained from the Auxiliary Operators-Nuclear group (28 people) and the A0-Ns are supplied from a 16 person operator trainee group. Vigorous recruiting and the desirability of operator positions has kept this array of operator groups essentially fully staffed and promises to continue to do so.
The subcommittee believes that licensed personnel staffing of the plant is in excellent shape and that management plans will keep it that way.
The change to 6-shift operation is a progressive one, in line with industry and i
INPO-recommended good practice. Working conditions and compensation are adequate to retain the staff. The licensed group has been exceptionally stable over the past two years.
The non-licensed shift positions, Nuclear Operator-B (NOB),
Auxiliary Operator-Nuclear (AON), Shift Technical Advisors (STA), and Production Aides are adequately covered. As noted, the NOB and AON groups are large and will support 6-shift operation. The STA and Production Aide groups may need another person or two to assure coverage and backup for the long term.
The plant staff groups supporting operation.are generally staffed at an adequate level, although selected increases in budgeted position numbers may be necessary to permit replacement of contractors now doing essential jobs. A case in point is the Mechanical Maintenance Section, which is essentially fully staffed in budgeted positions (89) but has 20-odd contractor people working in the section on a full-time basis. Even at that, the Mechanical Section's apparent workload exceeds the present work force capability by a substantial factor if all originally planned preventive maintenance, in-service inspection, and other work are included in the tally. The section management is re-evaluating preventive maintenance schedules and finding that reductions in workload are possible while still maintaining the essential elements of the program.
In past reports, the subcommittee has urged the Company to recruit and train permanent MP&L employees for the nuclear workforce in order to reduce dependence on consultants and contractors. Good progress has been made in that direction and there is now underway a strong effort to replace contractors by the end of 1985. The subcommittee has noted the progress and the present program with approval. There will probably continue to be some special areas for which the retention of experienced contractor personnel is essential, J09 MISC 85090513 - 5 l
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and in which recruitment of the requisite expertise as permanent MP&L staff is impractical over the nevt few years.
The aim of the contractor reduction effort now in progress should be to increase MP&L staf f capability aa nuch as possible through recruitment and training and to reduce dependence on contractors to a reaconable minimum.
The addition of trainee positions in the Health Physics (HP),
Radwaste/ Chemistry, Instrumentation and Control (I6C), and computer areas will be of considerable help in maintaining full staffing levels in these groups. These are discipline areas in which national rceruitment continues to be competitive and personnel in these areas are less likely to stay permanently on the staff. Use of the new trainee positions for local entry level people should, over time, provide a lasting solution to this problem.
At the time of the 50% power operational readiness review, the subcommittee noted a difficulty in filling the Plant Chemist slot.
It still is a difficulty, which suggests a re-evalua-tion of the position rating to be sure that the level of expertise and experience needed in the job is properly reflected in what the Company is offering qualified candidates.
Supporting groups in the nuclear area outside the plant staff include engineering, outage planning, quality assurance, licensing and safety, and nuclear support. Nuclear Plant Engineering (NPE) is actively recruiting engineers to replace about 27 contractor engineers working in the group. NPE will continue to use Bechtel, or other engineering firms, as a backup resource to absorb the peaks in workload cycles. With that provision, NPE appears to be staffed to provide essential services to the plant.
Quality Assurance has been expanded to incorporate the Plant Quality group and has an authorized strength of 65.
It is essentially fully staffed with MP&L people (60 positions now filled and offers out or accepted on the balance.) The workload is substantial and handling it with the authorized workforce depends on timely completion of a program of transferring quality assurance paperwork from hand preparation and maintenance to a computer-based system. Also, new responsibilities in providing nondestructive examination capability (via contractors) for inservice inspection are being given to QA. Assuming an appropriate staffing increment for these added responsibilities, and successful completion of the computer-based system, the QA staff level should be adequate.
Overall, the subcommittee finds that staffing levels in these essential supporting groups appear to be adequate for l
operation of the plant.
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b.
Training and Experience The experience level of plant staff and support groups has increased substantin11y since the 50% power operational readiness review. The stattup tests have been completed through 100% power, *he major transient tests completed, the warranty run completed, and two months of commercial operation accomplished. Plant availability has been good since the declaration of commercial operation, attesting to the ability of plant staff to keep the unit operating.
In view of the completion of startup testing, the BWR-experienced shift advisor function was discontinued on August 1, 1985. This function, which served a useful purpose in terms of backup experience availability (as well as meeting NRC requirements) in earlier days, had reached a point in recent months where it was little needed. This was to be expected as MP&L shift managers became more experienced. The subcommittee believes that the plant staff has adequate experience to carry forward with normal power generating operation.
Progress noted in the subcommittee's previous report in improving training programs has continued. The generally poor opinion of training held several years ago throughout the operations staff has changed to one of general approval.
The presence of licensed SR0s in charge of operations training and the improved plant-specific knowledge of contractor instructors have contributed to that change, as have the general upgrading of the Training group and training programs.
The Company has just submitted the operator training and requalification programs (SRO, RO, and non-licensed nuclear operator) to INPO for accreditation. The remaining programs are scheduled to follow.
The new training facilities and the control room simulator continue to be major assets in the training program.
Managers, supervisory personnel and operators are being given short courses, appropriately modified for each group, in Kepner-Tregoe decision analysis theory and practice. The aim is to instill a basis for disciplined problem analysis and decision making among key plant staff.
The Quality Assurance group is working toward anticipated INP0 accreditation of training programs for quality control and quality assurance. A qualified individual has been brought into the QA group to carry out development of the training modules and to work with Training to get them in place.
Health Physics training has been upgraded and a formal course established following some suggestions from a recent INPO assistance visit in that area. Members of the HP staff have been sent to Oak Ridge National Laboratory for refresher and professional improvement training and tests have been used to indicate needed additions or modifications to the HP qualification program.
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8 c.
Ability to Operate Plant The p1Ent staff has demonstrated the ability to operate the plant safely and the other nuclear department organizations have shown that they can support plant operation. Performance through the startup period and recent commercial operation has been generally good although there is room for improvement.
The Technical Support and Maintenance groups have shown ingenuity and an ability to move rapidly in dealing with plant equipment problems. The recent changeouts of a circulating water pump motor and the Division III emergency generator were major equipment replacements done quickly and ef ficiently.
Materials handling, under Mcidtenance, is being reorganized into an integrated materials management system.
On the administrative support side of plant staff, Training is now doing an effective job and is improving.
Security has always been a strong element of plant staff. The Office Services droup, once a bottleneck in procedure changes, is functioning effectively. Records management has been consolidated under new leadership and is performing well.
The supporting organizations outside the plant staff can support full power operation, but there is room for improvement in some areas and strengthening these organiza-tions for the long term is indicated. NPE appears to have a very heavy workload, due to outage, safety and licensing tasks, such that it appears unable to muster adequate forces for a concerted attack on such general plant problems as the too-frequent feedwater and condensate malfunctions and the nagging problem of reactor water cleanup system isolations.
These have been pointed out by NPE's independent safety engineering group but remain unsolved at this late stage.
There is also a need for increased sensitivity in NPE to plant operating conditions and limitations. The latter circum-stance, which is not unique to NPE, would be considerably improved if there were NPE engineers who could be trained on the plant by taking the SRO course. Communication between NPE and the plant has improved over recent months, but further improvement is needed.
The QA group and the Jackson-based support groups would also benefit by having SRO-trained people. QA had an SRO but lost the individual to the Training group because of inability to recognize his newly acquired credentials in terms of compensation. It is the subcommittee's understanding that such recognition can be accorded certified individuals in organizations other than plant staff when management determines that such skills are necessary to the organization's mission.
This provision of the Company's personnel policy should be exercised on behalf of the supporting organizations.
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9 d.
Summary The subcommittee concludes that staffing in all essential groups is adequate for full power operation. Plant staff training and experience are good, and the staff is able to operate the plant safely and competently for commercial operation. The supporting organizations should be strengthened but are able in their present states to support full power operation.
(iii) Morale and Attitudes of Plant Personnel That Have a Bearing on Safe Plant Operation It is apparent to the subcommittee from the interviewa conducted in connection with its reviews that morale among all levels of plant personnel has improved steadily over the past two years.
This improvement is based on many factors, not the least of which is the pride and satisfaction of having completed the power ascension program and achieving commercial operating status.
A morale factor mentioned in the 50 Percent Power Operational Readiness Review Report was concern about certain Company personnel policies primarily related to compensation and benefits.
During the past year, the MP&L Personnel Department has been reorganized and seven new professionals have been brought into the Department. The Nuclear Human Resources Manager was hired and in the reorganization became Employment Manager for the entire Company with suf ficient resources to devote a majority of his time and effort to supporting hiring and developing effective personnel policies and programs for the Auclear Production Department. All exempt positions have been re-evaluated and many have been upgraded with accompanying salary increases.
Extensive effort has gone into industry surveys designed to guarantee that MP&L employees are compensated at a level that is comparable to the industry. Managers report that hiring has become significantly easier. The consensus appears to be thar Company management is giving strong support to improving the quality of life of employees.
Stabilization of plant programs has resulted in greater clarity of direction for plant personnel, and as a consequence, increased job satisfaction and a decrease in tension and stress. A program for releasing two or three supervisors, superintendents or managers at a time to attend SRO training has improved prospects for career progress. The Company has recently made a new commitment to providing continuing education courses leading to a Bachelor's degree in Nuclear Operations. This program has evoked consider-able enthusiasm from individuals with whom the subcommittee talked.
The turnover rste of plant employees is projected to be somewhat lower for 1985 than for 1984. Only one licensed operator has resigned since the 50 percent power operational readiness review was conducted last November.
In some departments there has been J09 MISC 85090513 - 9
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e 10 zero turnover during 1985. These data suggest increased job satisfaction and improvement in morale.
It appears that the problems MP&L and its sister companies are encountering in securing rate increases to pay for Grand Gulf.may 4
constitute the single most negative morale factor. Managers reported some reluctance on the part of outside candidates for employment to accept job offers based on their concern for the Company's financial situation. This issue could have significant influence on morale if the situation worsens. A related concern is the unpopular image of Grand Gulf projected by the media and state officials involved in rate matters. Employees are constantly bombarded by negative attitudes and their morale is certain to be affected. The Company has been forced to cut some costs, but executives have clearly stated their commitment not to cut costs in the Nuclear Production Department in any way that-could possibly affect safe operation _of Grand Gulf.
i Overall, it is the conclusion of the subcommittee that morale remains quite high and that many positive factors exist which predict a continued high level. There is nothing in this area to preclude the continued safe operation of the plant.
(iv) Past Performance in Plant Operation and Adherence to Procedures and Administrative Controls a.
Introduction Plant staff performance in plant operations and adherence to procedures and administrative controls was evaluated by reviewing various plant documents coupled with in-depth interviews of key plant staff personnel. The focus is on i
events and activities since the subcommittee's last review.
Since exceeding 50% power, the overall performance of the plant staff has been above average. Throughout this period, i
the plant level administrative and procedural programs have continued to be refined and have achieved a level of maturity such that most plant staff personnel now feel comfortable with the overall program and have confidence in their ability to perform in a proper manner.
The overall management philosophy continues to be conservative with proper. emphasis on safety. Resolution of problems has been appropriate and timely. As operations have matured, management has developed and implemented a performance monitoring program which focuses on overall Nuclear' Production
-Department goals. Plant supervisors are. aware of-the plant goals and are monitoring their activities accordingly.
The confidence of plant' personnel in their ability to operate the plant safely has increased as a result of continued successful testing and good operational performance. The ability of operations personnel to be responsive and to. deal l
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11 effectively with events that have the potential to scram the plant has been demonstrated by the proper handling of recent events such as the loss of feed flow signal, the partial and total loss of the plant service water system and the failure of a circulating water pump motor. To improve overall plant operations, management is continuing with the self-monitoring
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program which is coordinated by the Technical Assistant to the General Manager. Assignments are made on a monthly basis for i
supervisory personnel to observe various activities. This program has identified potential problems and has helped to improve management understanding of and involvement in plant operations.
The overall scheduling and coordination of daily and outage activities has continued to improve. The daily work planning meeting is well run and appears effective in coordinating work and informing personnel of plant work status.
i b.
Adherence to Procedures / Administrative Controls i
Plant staff familiarity with and confidence in plant procedures have improved with continued successful plant operation. Although there continue to be some personnel i
errors, there is a determination on the part of plant staff to follow procedures precisely and to deal with any needed adjustments or changes in routine in accordance with the l
established temporary change notice (TCN) procedures. The procedures themselves, and associated administrative rules and practices, have been worked over and used enough so that'there l
are substantially fewer problem spots than was the case a year 1
or so ago. As problems come to light, they are corrected. A 1
case in point is the current modification, clarification, and improvement in the daily logging procedure. Some difficulties in these records, due in good part to the cumbersomeness and I
inscrutability of the old forms, was uncovered by QA in an audit. The resulting corrective action request triggered a thorough review and revision of the procedure by Operations.
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I The number of outstanding TCNs has increased since the subcommittee's last review due in part to an increase in TCNs I
during the spring condenser repair outage and the delay in l
processing of TCNs due to the transition from Lanier to IBM word processing equipment. With the completion of the transition, the number of TCNs is expected to be reduced, although during the Fall Outage a number of new TCNs will be
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l generated. To upgrade the quality of procedures, enhance their readability and to reduce errors, two Technical Proofreaders have been hired to review all procedure revisions.
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The number of LERs generated to date in 1985 is below that l
generated in a comparable period.in previous years. Based on 29 issued thus far in 1985, the plant goal of less than 48 is
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achievable. This compares with 61 issued in all of 1984. The J09 MISC 85090513 - 11
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e' 12 number of LERs attributable to personnel errors is steadily decreasing, reflecting improved operations.
Reviews of other plant nonconformance indicators such as Incident Reports (irs), Material Non-Conformance Reports (MNCRs), and Plant Quality Deficiency Reports (PQDRs) do not appear to yield noticeable unexplainable trends. Open MNCRs appear to be remaining at a constant level. The number of PQDRs, which generally reflect administrative non-conformances, exhibits an overall decline.
The Company has been cited by the NRC for a number of severe violations since the subcommittee's last review. They relate to conditions which occurred and were corrected prior to receipt of the Full Power Operating License.
Several recent violations reflect issues related to independent verification activities. Recognition of the significance of this problem prompted the General Manager to issue supplemental instructions to all plant supervisory people, designating independent verficiation practices at GGNS.
Additionally, a review of independent verification practices at Middle South Utilities (MSU) nuclear units, including GGNS, is being performed under the direction of the MSU Nuclear Oversight Committee.
Another recurring problem which was reflected in several LERs was a failure by operations personnel to recognize entry into a limiting condition for operation. Management, recognizing the problems primarily involved non-routine surveillances, took appropriate corrective action. A review of all non-scheduled surveillance requirements was performed to clearly identify action triggers and related variable surveillances.
c.
Plant Operations Startup testing was completed and the plant declared commercial on 7/1/85. Fifty-six startup test exceptions remain to be resolved. The major open items involve steam condensing mode testing. During final phases of the startup program, to ensure overall operations were conducted in an efficient manner, management implemented a daily duty roster with senior plant supervisory personnel on shift to provide 24-hour coverage to resolve problems.
The number of unplanned scrams that GGNS has encountered is comparable in number to those encountered during other recent BWR startups. A large fraction of the scrams is attributable to feedwater and condensate problems encountered and subse-quently resolved during startup testing. Results of startup tests demonstrate that the reactor and the plant, in general, respond to anticipated operational occurrences in a stable manner.
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O 13 Plant water chemistry has been within specifications at all times. Daily isotopic analyses of water samples using an ion chromatograph are made to provide effective trending.
The number of outstanding temporary alterations (TA) has increased since the subcommittee's last review. On a monthly basis management reviews each open TA.
Operations estimates that about 3/4 of the TAs will be resolved by design changes which have been included in the plant annual operating plan (AOP). These design changes will be implemented subject to priority and scheduling.
To date, plant personnel exposure has been minimal. This reflects, in part, the uncontaminated cindition of the plant.
After a recent event, where employees did receive unnecessary exposure, management initiated aggressive action to prevent recurrence and to strengthen the radiation control program.
d.
Maintenance Overall maintenance activities appear to be proceeding well.
Work performed in radiation areas has proceeded well, with a low accumulated dose despite completing considerable work and the continuing leakage problem with the feedwater venturi flanges. A backlog of preventive maintenance (PM) activities continues for Mechanical Maintenance although the number has been reduced substantially. Most of these overdue PM procedures have been performed at least once whereas at the time of the subcommittee's last review numerous PMs had never been performed. Instrumentation and Control (I&C) and Electrical PMs are current. The corrective maintenance backlog has slowly increased during the startup program reflecting, in part, plant system modifications / improvements identified as a result of testing. As the plant begins more routine operation, this backlog is expected to be reduced.
Over 40% of the maintenance backlog consists of 16C items. To improve effectiveness of work activities in the event of a forced or unplanned outage, the Maintenance Planning Scheduling System (MPSS) software has been modified. Thus if a forced outage occurs, maintenance can obtain a prioritized list of work compatible with the anticipated scope and duration of the outage.
The measuring and test equipment facilities, the machine shop and the hot machine shop are all well equipped and functioning satisfactorily to support continued plant operation. A restructuring of the materials management function should provide long term support to plant maintenance activities.
Management's attention has been called to a possible shortage of warehouse space needed to support the planned work activities for the First Refueling Outage. The Materials Section is in the process of implementing a computerized inventory management system. The new Plant Outage group should help to improve planning of plant design changes J09 MISC 85090513 - 13
a 14 scheduled for planned outages. Management is currently investigating various approaches to integrate this outage function with normal plant staff responsibilities.
e.
Summary The past performance of plant staff with respect to plant operations and adherence to procedures and administrative controls has been satisfactory and clearly demonstrates readiness to proceed with routine full power operation.
(v) Changes in Current Organization with Regard to Experience and Qualifications of Plant Supervisory Personnel Since the Last Evaluation The following summarizes the changes in organization with regard to experience and qualifications of plant supervisory personnel since the subcomaittee's last evaluation.
a.
Vice President-Nuclear Operations The nuclear experience level of the MP&L managerial team was significantly strengthened by the addition of a Vice President for Nuclear Operations. This individual has a degree in Engineering Physics and 13 years experience in the management of a commercial nuclear power plant. He is directly responsible for nuclear production, licensing and safety.
b.
Plant Management Plant management consists of a General Manager and Managers for Plant Operations, Plant Maintenance and Plant Support. A new manager for Plant Operations was appointed February 1, 1985. The change resulted frem an automobile accident in which the previous manager was seriously injured.
The previous manager was assigned as a Technical Assistant to the General Manager, thereby retaining his experience and expertise. The Manager, Plant Support has recently entered SRO training and was replaced by his Technical Assistant, who has just completed SRO training.
c.
Plant Operations In addition to the new Manager, Plant Operations, a new Technical Assistant was appointed. This individual had previously been Technical Support Superintendent and has just completed SRO training. The incumbent Technical Support Superintendent entered SRO training and was replaced by the Startup Supervisor. These changes reflect normal personnel movement in the operations organization and management's continuing effort to improve the plant specific knowledge of supervisory personnel.
In addition, a new Chemistry / Radiation Control Superintendent was appointed and a HP Supervisor was J09 MISC 85090513 - 14
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15 added to each shift. All changes maintained or improved the capability of the operations group.
1 d.
Plant Support A new position of Plant Controller, with responsibilities for budgeting, cost controls and accounting has been established.
A Records Section was organized with approximately 49 positions and an experienced superint'endent was recruited to manage the new section.
e.
Plant Maintenance Early in the year, the Plant Scheduling Superintendent resigned and was replaced by a degreed engineer. The Mechanical Superintendent was assigned to outage planning and replaced by an individual with extensive Navy experience.
I A new Materials Section is being proposed, to include materials engineering, inventory control, stores, and materials coordination. The section will be managed by a superintendent and three supervisors.
f.
Quality Assurance Since the last review, an organizational change has placed all quality assurance and quality control personnel under a common i
Director. Previously, quality control was under the General t
Manager. The Director, Quality Assurance reports to the Senior Vice President, Nuclear. Recent changes in supervisory positions have added over 20 years experience at the supervisory level. The educational level of the management and supervisory staff is about the same but several management and supervisory staff members have gone through BWR systems training to strengthen their overall understanding of the plant.
g.
Nuclear Engineering and Construction i
The Managers of Nuclear Plant Engineering and Plant Outages, who report to the Director - Nuclear Engineering and Con-struction, are both new to their positions. The Manager, Nuclear Plant Engineering has a Bachelor of Science in Mechanical Engineering and 19 years of experience.
The Plant Outage Sertion is a new group which was formed during a Nuclear Proiuction Department reorganization that occurred in the sprit g of 1984. The new Manager of Plant Outages was previously the Plant Mechanical Maintenance Superintendent and has an engineering degree and 12 years of relevant experience.
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Personnel The position of Manager, Nuclear Human Resource reporting to the Senior Vice President, Nuclear was changed to that of Employment Manager for all of MP&L. The functions of the Nuclear Human Resources position were all transferred to the new position. The Administrative Supervisor, with respon-sibility for plant staff recruiting and previously reporting directly to the General Manager, now reports to the Employment Manager.
This restructuring of the nuclear human resource function was undertaken to be more responsive to needs at the Grand Gulf Plant. Personnel policy changes which have been made include revision of wage and salary scales, review of benefit package, establishing a position evaluation committee, performance appraisal system and a career promotion path.
The subcommittee concludes that the managerial and supervisory changes which have taken place since our last review are positive and should result in continuing performance improvement.
(vi) Results and Effectiveness of PSRC The Plant Safety Review Committee (PSRC) appears to be conducting credible document reviews consistent with their administrative commitments and the plant technical specifications. Meetings attended by subcommittee members were well run with minimal interruptions. Member participation and involvement was at a professional level. Document reviews were thorough with members placing proper emphasis on safety concerns. The backlog of review documents has been essentially eliminated reflecting the readiness of the PSRC to proceed with routine operations. Meeting minutes generally documented the important elements of discussion items.
A sampling of attendance at PSRC meetings since March 1985 indicated that about one-half the meetings were quorum only, that is only five permanent members or alternates were present.
However, in approximately 60% of all meetings, at least five permanent members were in attendance. Most meetings are chaired by the PSRC Chairman. Members, except for the Technical Support Superintendent and I&C Superintendent, routinely arrange, in their absence, for their alternates to attend.
Administrative controls appear to have been implemented to ensure that routine document reviews are scheduled and performed in a timely manner, thus avoiding backlogs. Subcommittees have been used to perform document reviews when document backlogs developed.
Major review activities continue to focus on plant level administrative procedure changes, startup test procedure changes, review of safety evaluations for design changes, and reviews of-plant non-conformances.
J09 MISC 85090513 - 16
17 Routine review documents are not always routed to members early enough to allow sufficient review time and preparation prior to meetings. During meetings, sometimes several activities are occurring simultaneously, i.e. documents routed for member review concurrent with a verbal discussion of other items. On a weekly basis new incident reports and non-conformance reports are discussed with the PSRC. The PSRC appears to be making appropriate use of special subcommittees to address specific items of concern uuch as ALARA, Inservice Inspection (ISI), maintenance activities in high radiation areas, and control of vendor manuals.
When complex items or questions are raised during a meeting, the PSRC Secretary attempts to call appropriate individuals on plant staff or NPE to ensure that informed, knowledgeable pereonnel are available to answer questions or address PSRC concerns on design changes or changes to the plant operating license.
A training manual has been developed to inform PSRC members of their individual and collective responsibilities. The manual includes governing documents and the Kemeny THI report. The manual does not appear to be administratively controlled to keep its contents current and to ensure timely distribution to all new members. Although there is no requirement for a training manual, it is a good idea and should provide useful guidance to members.
The PSRC has functioned well over the past year handling a large workload resulting from startup activities combined with normal Technical Specification responsibilities. With the completion of startup testing, the onset of commercial operation, and the improved structure of PSRC meetings, the impact of PSRC activities on member supervisory responsibilities should be reduced. As operations stabilize and mature the PSRC should place more emphasis on a broad overview of plant operations to ensure monitoring of longer term trends as well as day-to-day operations.
The subcommittee recognizes that improvements in PSRC administrative functions have taken place and that periodic self appraisals are occurring which should further improve PSRC effectiveners.
In summary, the subcommittee concludes that the PSRC is functioning satisfactorily and is providing thorough reviews of scheduled documents, placing proper emphasis on safety concerns.
(vii) Status of Plant as Compared to Other BWR Startups Based on the Subcommittee Knowledge and Experience The subcommittee considers Grand Gulf Nuclear Station, when compared to other BWR startups, to be average or above. One evidence of this is the availability, capacity factor and forced outage rates attained in the two months which have elapsed since the unit was declared commercial. We view this as a favorable indicator of the plant's ability to perform in a safe and reliable manner.
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18 Comparisons were made of test program durations and the number of scrams experienced during the test program between Grand Gulf and other BWR units having recent startups. The results appear on the attached tables. Each of the units used in the comparison was the first BWR unit to start up at its plant site.
As indicated, the startup program of Grand Gulf was longer than that of the other units used in the comparison.
For the most part, schedule losses occurred a day or two at a time.
In a number of instances this was due to the conservative approach of plant management in placing equipment in service for the first time.
Feedwater heaters are an example.
In other instances, such as following the unexpected tripping of the condensate pumps, delays were due to the plant's thorough investigation of and resolution of the cause of the event.
. Typically in any startup there are two or three major equipment-caused delays; Grand Gulf was no exception. One eleven-day outage occurred while in Test Condition 2 due to a condenser tube leak and to correct a design omission concerning double fuse protection for electrical penetrations. Test Condition 3 was interrupted by a 46-day outage to correct structural defects in the main condenser. These deficiencies have been corrected and proof tested in subsequent operation.
On July 1, 1985, the 54th day of Test Condition 6, Grand Gulf Nuclear Station was declared commercial. From then on the test program was substantially delayed due to system requirements for i
generation.
i As the scram comparison table indicates, the number of unplanned scrams encountered by GGNS during the startup period was comparable to the number experienced by other recent BWR plants in startup.
The subcommittee found the staffing level of the plant and supporting organizations compared favorably with that of other recent plants at this same phase in their operational evolution.
The level of competence of the personnel, the training programs, and the pipelines established to fill out the staff replacing contractors and losses due to attrition are above the norm, as is the stability of the operating staff. We consider the operating staff to be exceptionally well-disciplined and expect this to i
reflect favorably La future operations.
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COMPARISON OF STARTUP PROGRAM DURATIONS GGNS GGNS TEST AS SCHEDULED ACTUAL KU0SHENG WPPSS SUSQUEHANNA LASALLE CONDITION DURATION (DAYS)
DURATION 1
2 1
1 TC-1 25 49 34 26 38 45 TC-2 33 77 30 68 29 29 TC-3 42 98 45 69 25 160 h
TC-4/5 20 9
15 14 7
8 TC-6 67 100 90 42 64 87 overall Totals 187 333 214 219 163 329 J09 MISC 85081604 - 1
O SCRAM
SUMMARY
OF RECENT PLANT START-UPS BY TEST CONDITION PLANT TC-1 TC-2 TC-3 TC-4/5 TC-6 TOTAL GGNS 2 (0) 6 (2) 8 (1) 6 (2) 22 (5)
Kuosheng I 6 (1) 5 (1) 10 (1) 1 7 (2) 28 (5)
WFPSS 2 5 (1) 6 (1) 8 (1) 2 (0) 5 (2) 26 (5)
Susquehanna I 3 (1) 3 (1) 1 (1) 1 2 (1)*
10 (4)
LaSalle I 2 (1) 6 (1) 15 (1) 7 (2) 30 (5)
() Planned Scram Incomplete Number J09 MISC 85091203 - 1
19 III. Resolution of Comments and Recommendations Contained in the 50 Percent Power Operational Readiness Review Report This section summarizes the status of Plant Staff actions taken in response to the subcommittee's recommendations generated at the time of the 50% Power Operational Readiness Review. All recommendations received appropriate consideration.
(1)
REC 0KHENDATION:
For long-term operation we recommend that aggressive action be taken to make the RHR steam condensing mode available for the operator.
STATUS:
Licensing of the steam condensing mode of RHR is proceeding through normal channels. The need for this alternative method for decay heat removal is not as pressing as was originally anticipated.
In July 1985 the NRC requested additional information to support MP&L's licensing request and MP&L is currently gathering this information for submittal.
(2)
RECOMMENDATION:
Concerning the Loss of Offsite Power Test (LOP),
we recommend detailed planning to ensure that this test will provide widespread training for operators, that adequate personnel are on shift at the time of the test and that actions are preplanned in the event that the LOP test does not proceed as expected.
STATUS:
The Loss of Offsite Power Test was successfully completed in January 1985 as part of TC-2.
Available operations personnel participated in the test as suggested by the subcommittee's recommendation.
(3/4) RECOMMENDATION:
Improve the documentation of PSRC meetings by providing more of the important elements of reviews conducted. Encourage complete member attendance at PSRC meetings.
STATUS:
The new Chemistry / Radiation Control Superintendent regularly attends PSRC meetings.
Documentation of meeting minutes generally reflects the key elements of discussion items.
As part of the plant self monitoring program, an assessment of PSRC activities was made on 3/14/85 by the Technical Assistant to the General Manager. Actions taken in response to that assessment include more formal control of meetings, improved overall attendance by primary members, improvements to meeting documentation, and fewer telecon meetings.
JO9 MISC 85090513 - 19
e 20 (5)
RECOMMENDATION: Consideration should be given to establishing a group of dedicated radwaste workers to process, package and ship radwaste.
STATUS A proposal has been submitted to senior MP&L management to establish a Radwaste Supervisor reporting to the Chemistry / Radiation Control Superintendent. A group of dedicated workers /
laborers and Health Physicists would report to the Radwaste Supervisor. This group would be responsible for processing, packaging and shipping of all low level radwaste.
(6)
RECOMMENDATION: In order to facilitate the sorting and shipping of dry active radwaste, consideration should be given to construction of a staging facility.
STATUS:
The design specifications for a Radwaste Staging Facility have been developed and issued for bid.
(7)
RECOMMENDATION: Develop and implement a plant water management program to decrease the quantity of make-up water and releases.
STATUS:
A water management program has been developed and trending of discharges commenced on 7/1/85.
In spite of the requirement to drain the condenser hotwells following the tube leaks and shell cracking, the water management program appears to be working well with minimal discharges.
(8)
RECOMMENDATION: A review of the policy allowing food and drinks in the Control Room should be performed.
STATUS:
Management reviewed the subcommittee's suggestion and concluded that allowing food and drinks in the Control Room under controlled conditions is not detrimental to safety or inconsistent with the practices at other facilities. The present policy at GGNS tends to minimize absences away from the Control Room to obtain these items.
(9)
RECOMMENDATION: To reduce the number of instances of " Failure to Follow Administrative Controls" as indicated by noncomformances on PQDRs, periodic training or refamiliarization with Plant Administrative Controls should be improved particularly for maintenance personnel.
Items such as: how to obtain tools / equipment; obtaining warehouse items; processing MW0s; requesting tagging; procedure approvals, etc. need to be well i
understood by all maintenance personnel.
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STATUS:
Section level required reading programs have been revised to include applicable procedures for review on an annual basis. PQDRs involving instances of " failure to follow procedures" are reviewed by Section Superintendents and with affected section personnel.
(10)
RECOMMENDATION: The need for the Requirement Procedure Tracking System (RPTS) should be evaluated.
If the need for RPTS is present, then such a system should be implemented in a timely manner, STATUS:
The need for the Requirement Procedure Tracking System (RPTS) was evaluated and a consensus reached that the system was necessary. The system is expected to be current by 12/31/85.
(11)
RECOMMENDATION: Consider the merits of establishing system engineers. Each system would be assigned to an engineer charged with overall responsibility for the system. He should know the design, performance, the required PMs, operating procedures, etc., and should look for long-term improvements.
STATUS:
Senior management has chosen not to implement a system engineering philosophy along the lines i
originally comtemplated by the subcommittee. The responsibility for system engineering was assigned to plant staff by Senior management.
i The philosophy being employed at GGNS involves the assignment of system engineers in the plant i
staff maintenance engineering department. These individuals are " hands on" operationally oriented engineers who closely follow system performance.
Supplementing these system engineers are technical support results engineers who trend system performance and surveillance results and the discipline design engineers within NPE.
This approach, provided regular communication between all parties occurs, should meet the intent of the subcommittee's recommendation.
(12)
RECOMMENDATION: Trending of nonconformances has improved; however, a more integrated approach looking at root causes of significant irs, PQDRs, MNCRs, and CARS is suggested. A process to provide feedback on trends to management should be strengthened.
STATUS:
Management assigned this task to the Quality Assurance organization. QA is in the process of implementing an integrated root cause program for handling nonconformance issues which could prove very effective.
In addition, management recently J09 MISC 85090513 - 21 r
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implemented performance monitoring activities to provide timely indicators of performance. The Plant Staff Compliance group monitors irs, LERs and NRC items to ensure root cause determination.
The Operating Analysis Section generates a monthly report providing a summary of plant operations and an overview of significant nonconformances.
IV.
Recommendations (1)
Conditions that have the potential for adversely affecting plant operation should be corrected in a timely manner. The subcommittee recognizes that management is aware of these deficiences and is attempting to address these items on an interim and long-term basis; however, the subcommittee urges continued l
management attention to bring these issues to resolution. These conditions include but are not limited to:
(a) Insufficient heat removal capacity of the cooling tower.
i (b) Plant Service Water System deficiencies including poor water
]
quality, excessive pump wear, and unreliable control system.
l (c) Frequent f ailure of the Auxiliary Building Chilled Water i
System.
j (d) Chronic leakage problems at feedwater flow venturi flanges.
l.
(e) RWCU isolations (2)
Re-evaluate and bring into agreement the workload and staffing level of the Mechanical Maintenance Section.
i (3)- Prudence and caution in the replacement of contractor personnel with permanent MP&L employees is recommended. The subcommittee supports the contractor reduction effort, but recognizes that for special areas, retention of experienced contractor personnel or consultants is essential.
(4)
Due to the continuing problems in filling the Plant Chemist position, a re-evaluation of this position to ensure that the position description, experience level requirements, and salary are consistent and competitive.
4 (5)
Management should continue to carefully trend TCNs to ensure their timely incorporation into plant procedures.
(6)
Efforts need to be taken to ensure that plant temporary alterations, which are in fact permanent changes, are properly implemented in a timely manner as design changes.
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- 4 23 (7)
Additional efforts should be undertaken to increase the plant system specific knowledge level of NPE and QA personnel by sending selected engineers through SRO or STA training.
(8)
The NPE workload should be carefully evaluated to ensure that sufficient time and manpower are available to address plant operational or design conditions which are impacting or have the potential to impact plant availability or capacity.
(9)
The MP&L personnel policy should be appropriately exercised to recognize and ensure retention of SRO or STA GGNS-trained individuals in non-operating organizations.
(10)
The Subcommittee supports management's effort to achieve six shift operations. To this end, the Subcommittee recommends that MP&L pursue interim relief from the 4-year control room experience requirement for new hot license SR0s.
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