ML20149J219
| ML20149J219 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/11/1988 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| Shared Package | |
| ML20149J223 | List: |
| References | |
| NUDOCS 8802220316 | |
| Download: ML20149J219 (3) | |
See also: IR 05000289/1986098
Text
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FEB 11 1988
Docket No. 50-289
GPU Nuclear Corporation
ATTN: Mr. H. D. Hukill
Director, IMI-1
P. O._ Box 480
Middletown, PA~ 17057-
Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report No.
50-289/86-98
-The NRC Region I SALP Board conducted a review on December 8, 1987, and evaluated
the performance of activities associated with the Three Mile Island (Unit 1) Nuc-
lear Generating Station. The results of this assessment are documented in the
enclosed SALP report, which covers the period November 1, 1986, to October 31, 1987.
We will contact you shortly to schedule a meeting to discuss the report.
At the meeting, you should be prepared to discuss our assessment and any plans you
may have to improve performance further. Any comments you may have regarding our
report may be discussed at the meeting. Additionally, you may provide written
comments within twenty days after the meeting.
Your cooperation is appreciated.
Sincerely,
original Signed By
GIII ": T. T/i 3;LL
William T. Russell
Regional Administrator
Enclosure: NRC Region I SALP Report 50-298/86-98
8002220316 800
209
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OFFICIAL RECORD COPY
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T. G. Broughton, Operations and Maintenance Director, TMI-1
C. 'W. Smyth, Manager, TMI-1 Licensing
R. J. McGoey, Manager, PWR Licensing.
Ernest L. Blake, Jr. , Esquire
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
Commissioner Carr
Commissioner Rogers
K. Abraham, PA0, RI (14 copies)
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
TMI Alert
Susquehanna Valley Alliance
bec w/ encl:
Region I Docket Room (with concurrences)
W. D. Travers, Director, TMI-2 Cleanup Projects Directorate
J. Goldberg, OELD:HQ
J. Taylor, DEDO
J. Lieberman, OE
W. Russell, RI
T. Martin, RI
W. Johnston, RI
D. Holody, RI
Management Assistant, DRMA (w/o encl)
DRP Section Chief
R. J. Bores, DRSS
SALP Board Meeting Attendees
R. Brady, RI
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R. J. McGoey, Manager, PWR Licensing
Ernest L. Blake, Jr., Esquire
Chairman Zech
Commissioner Roberts
Commissioner Bernthal
Commissioner Carr
Commissioner Rogers
K. Abraham, PAO, RI (14 copies)
Public Document Room (PDR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
TMI Alert
Susquehanna Valley Alliance
bec w/ enc 1:
Region I Docket Room (with concurrences)
W. D. Travers, Director, TMI-2 Cleanup Projects Directorate
J. Goldberg, OELD:HQ
J. Taylor, DEDO
J. Lieberman, OE
W. Russell, RI
T. Martin, RI
W. Johnston, RI
D. Holody, RI
Management Assistant, ORMA (w/o encl)
DRP Section Chief
R. J. Bores, DRSS
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ENCLOSURE
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-289/86-98
GPU NUCLEAR
THREE MILE ISLAND, UNIT 1
NOVEMBER 1, 1986 - OCTOBER 31, 1987
8802220326 Beg 2gg9
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TABLE OF CONTENTS
PAGE
I.
Introduction.........................................................
1
II. Criteria. ......................... .................................
2
III. Prior Assessments....................................................
5
IV. S u mm a ry o f R e s u l t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
7
A.
Overall
Summary.................................................
7
B.
Background......................................................
8
C.
Facility Performance Analysis
Summary...........................
10
D.
Unplanned Shutdowns, Plant Trips, and Forced Outages............
11
V.
Performance Analysis.............
......... .........................
12
A.
Plant Operations.................
..............................
12
B.
Radiological
Controls...........................................
16
C.
Maintenance..........................
..........................
19
D.
Surveillance.
22
..................................................
E.
Fire
Protection.................................................
25
F.
27
....................................
G.
Security and Safeguards.........................................
29
H.
0utages.........................................................
3?
I.
Licensing Activities............................................
36
J.
Engineering Support.............................................
39
K.
Training and Qualification
Effectiveness........................
43
L.
Assurance of Quality..........
46
..... ............. .... ..... ..
VI.
Supporting Data and Summaries..........................
.............
51
A.
Investigations and Allegations
Review...........................
51
B.
Escalated Enforcement Actions..............
....................
51
C.
Licensee Conferences Held During Appraisal
Period...............
51
D.
Licensee Event Reports and Other Events.........................
52
E.
Licensing Activities....... ....................................
53
TABLES
Table 1 - Inspection Report Activities
Table 2 - Inspection Hours Summary
Table 3 - Enforcement Summary
Table 4 - Licensee Event Reports
i
s
.
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an inte-
grated NRC staff effort to collect available observations and data on a peri-
odic basis and to evaluate licensee performance based upon this information.
The SALP program is supplemental to normal regulatory processes used to ensure
compliance with NRC rules and regulations.
The SALP program is intended to
be sufficiently diagnostic to provide meaningful guidance to the licensee's
management to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on December
8, 1987, to review the collection of performance observations and data and
to assess licensee performance in accordance with the guidance in NRC Manual
Chapter 0516, "Systematic Assessment of Licensee Performance." A summary of
the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety perform-
ance at Three Mile Island, Unit 1 for the period November 1, 1986, through
October 31, 1987.
The SALP Board was comprised of the following:
Chairman
W. Kane, Director, Division of Reactor Projects (DRP), Region I (RI)
Members
T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS), RI
J. Stolz, Director, Project Directorate I-4, Office of Nuclear Reactor
Regulation (NRR)
L. Bettenhausen, Chief, Reactor Projects Branch No. 1, RI
P. Eapen, Chief, Engineering Branch, Division of Reactor Safety (DRS), RI
C. Cowgill, Chief, Reactor Projects Section No. 1A, RI
G. Edison, Operating Reactors Project Manager (TMI-1), NRR
R. Conte, Senior Resident Inspector (TMI-1), DRP, RI
Other Attendees (Non Voting)
W. Baunack, Project Engineer, DRP, RI
H. Bicehouse, DRSS, RI
D. Johnson, Resident Inspector (TMI-1), DRP, RI
R. Keller, Chief, Pressurized Water Reactor Section, DRS, RI
A. Krasopoulos, DRS, RI
W. Lazarus, Chief, Emergency Preparedness Section, DRSS, RI
T. Moslak, Resident Inspector (TMI-2), DRP, RI
W. Pasiack, Chief, Effluents Radiation Protection Section, DRSS, RI
S. Peleschak, Reactor Engineer, DRP, RI
M. Shanbaky, Chief, Facilities Radiation Projection Section, DRSS, RI
G. Smith, DRSS, RI
T. Weadock, DRSS, RI
1
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2
a
I
II. CRITERIA
A.
General
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, pre-operational, or
operational phase.
Functional areas normally represent areas significant
to nuclear safety and the environment. Some functional areas may not
be assessed because of little or no licensee activities or lack of mean-
ingful observations.
Special areas may be added to highlight significant
observations.
One or more of the following evaluation criteria were used to assess
each functional area.
1.
Fianagement involvement and control in assuring quality.
!
2.
Approach to the resolution of technical issues from a safety stand-
!
point.
3.
Responsiveness to NRC initiatives.
l
4.
Enforcement history.
l
5.
Operational and construction events (including response to, analyses
of, and corrective actions for).
6.
Staffing (including management).
7.
Training mod qualification effectiveness.
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories.
The definitions
of these performance categories are:
Category 1.
Licensee management attention and involvement are aggressive
i
and oriented toward nuclear safety; licensee resources are ample and
l
effectively used so that a high level of performance with respect to
~
operational safety and construction quality is being achieved.
Reduced
NRC attention may be appropriate.
I
Category 2.
Licensee management attention and involvement are evident
'
and are concerned with nuclear safety; licensee resources are adequate
and are reasonably effective so that satisfactory performance with re-
spect to operational safety and construction quality is being achieved.
NRC attention should be maintained at normal levels.
i
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a
Category 3.
Licensee management attention or involvemert is acceptable
and considers nuclear safety, but weaknesses are evident, licensee re-
sources appear to be-strained or not effectively used so that minimally
satisfactory performance with respect to operational safety and con-
struction quality is being achieved.
Both NRC and licensee attention
should be increased.
The SALP Board may determine to include an appraisal of the performance
trend of a functional area.
Normally, this performance trend is only
used where both a definite trend of performance is discernible to the
Board and the Board believes that continuation of the trend may result
in a change of performance level.
Improving (declining) trend is defined
as: licensee performance wa's determined to be improving (declining) near
the close of the assessment period.
B.
Explanation of Functional Areas
Since the SALP process started for TMI-1, the Engineering Support func-
tional area (current title) has evolved as the staff started to focus
a number of inspections into this important licensee activity.
In the
earlier SALP reports, this area was termed "Design, Engineering, and
Modifications," and then called "Technical Support." The Institute of
Nuclear Power Operation (INPO) has a broad view of the Technical Support
area and includes such functional areas as surveillance and maintenance
work, along with other NRC termed functional areas. To eliminate con-
fusion and to more clearly define the activities in the subject func-
tional area, Technical Support was changed to Engineering Support.
Engineering Support includes all activities of an engineering nature be-
.
yond those provided by the operating organization professional technical
l
personnel in support of operating activities.
This includes design con-
trol, review, analysis, and audit (non-QA) of nuclear plant operations.
Modification control and test is considered implementation of the design
product, and it is addressed in the "Outage" functional area.
The various aspects of the "Training and Qualification Effectiveness"
l
I
functional area are considered and discussed as an integral part of other
functional areas and the respective inspection hours have been included
in each of the other functional areas.
Consequently, the discussion in
Section V.K is a synopsis of the assessment related to the training con-
,
i
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ducted in other functional areas.
Training effectiveness has been meas-
'
ured primarily by observed performance of licensee personnel and, to a
lesser degree, by a review of the program adequacy. Thus, the discussion
addresses the training attributes and weaknesses as noted throughout all
functional areas and the effect that these have on the overall safe
operation of the plant.
__
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-. . - -
-
.,
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. - _ . _ - .
_
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4
4
Likewise, management involvement and control in assuring quality con-
tinues to be an evaluation criterion for each functional area.
The
various aspects of the programs to assure quality have been considered
and discussed as an integral part of each functional area and the re-
spective inspectiun hours are included in each one.
Consequently, the
discussion in Section V.L is a synopsis of the assessments relating to
the quality of work conducted in other areas.
I
.
..
T
5
.
III. PRIOR ASSESSMENTS
This was the fourth assessment in the 25-month period since TMI-1 Restart
. authorization. The first assessment (termed "interim") covered the first
three months of operations and it focused on the startup and test program as
it interfaced with operations. The second assessment (termed "SALP I")
covered the first seven months of operations as directed by the Commission
and it included a one month outage related to steam generator repair. The
third assessment (termed "SALP II") covered the subsequent six months a'so
as directed by the Commission, and it assessed a period covering full power
operations.
This fourth assessment was the first twelve-month SALP since
restart and it included the first refueling outage (five months) since TMI-1
Restart.
For the SALP I/II period, there were 9,059 inspection hours, compared to 4,966
,
during this fourth assessment.
The reduction in hours reflects the overall
positive results of FALP I/II periods in that NRC staff had a high level of
confidence in licensee performance in order to reduce the substantial and
special attention given to this licensee during the first thirteen months of
operations. A relatively high level of attention was maintained, however,
with the assignment of four resident inspectors and completion of selected
programmatic reviews left over from the SALP II period, as reflected in the
relatively high inspection hours for this assessment. The level of attention
was maintained due to TMI-l's unique design in Region I and some unexpected
weaknesses identified during the SALP I/II period.
Also, comparing the two periods, SALP I/II versus this assessment, the in-
spector-identified violation rate remains essentially the same and relatively
low, approximately two violations per 1,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> of inspection.
Further,
the number of LER's remained relatively low, probably due to the licensee's
customized (in distinction to the more restrictive standard) technical speci-
fications.
With respect to performance, the SALP I/II period found that TMI-I was oper-
ated safely with a generally strong orientation toward nuclear safety / safe-
'
guards and radiation protection.
The notable characteristic was the overall
high competence of licensee personnel with respect to their high qualification
levels and knowledge of plant design / system status. This reflected positively
on the licensee's substantial training programs.
The material condition of
the plant was quite good and, in general, worker attitudes were noted to be
overall positive.
There were minor lapses in worker attentiveness early in
the startup period while working in safety-related areas.
This combination
of personnel and good material condition of the plant seemed to be the major
contributors toward the relatively good operating record for the plant during
that first year of operations.
However, weaknesses were identified.
Despite generally well established programs, implementation of these programs,
i
at times, was deficient.
Problems seemed to be oriented around control of
the human element; namely, personnel error or personnel producing deficient
(in part) procedures.
Personnel performance notably trended downward, es-
Y
._
.
6
-
.
pecially during periods of schedular pressure which seemed to be excessively
applied at the middle management level in the' interest of production. Also,
at times, technical and/or supervisory review lacked thoroughness and in-
quisitiveness in the area ~ of design or for problems / events not making the
reportability threshold.
Performance here also trended downward during
schedular pressure periods.
It~was noted that during the SALP II period,
these review functions were not excessively challenged because of the good
operating record of the plant.
'
Finally, during SALP I/II, it was noted that many oversight groups had the
necessary expertise to aggressively identify problems, but licensee management
apparently was less aggressive in prioritizing and effectively resolving the
root causes of the issues identified.
Escalation of issues to higher manage-
ment seemed to be weak.
A number of licensee initiatives in the area of
problem identification were noteworthy, however.
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.
.
IV.
SUMMARY OF'RESULTS
A.
Overall Summary
The licensee continues to operate TMI-1 in a safe manner. Across all
functional areas, programs are well established and generally strong,
coupled with substantial personnel resources who are highly knowledgeable
,
and appropriately trained. However, program implementation is sometimes
weak.
Certain deficiencies, although identified, remain uncorrected as
long-term problem resolution continues.
During the period, the operating record at the facility was good. Sta-
tion personnel are professional and take pride in their performance.
The material condition of the plant is good and is a direct result of
licensee efforts in the Maintenance and Surveillance areas.
Engineering
support is also notable in providing new systems or modified systems that
did not adversely impact operations significantly during the period.
'
However, a good portion of the operating events were due to personnel
error, which 7"e preventable since they are primarily due to failures
to follow procedures.
Individual procedural step inadequacies continue
to be noted, and contributed to certain events.
The corporate-based
'
technical and safety review program has weakened because of program
changes using a methodology unreviewed and unapproved by NRC staff.
Strong programs exist in the site Emergency Preparedness and Radiological
Controls areas. However, the failure to correct long standing problems
in these areas indicates a decreasing trend which if uncorrected could
r
result in an overall decrease in performance.
Corrective action systems
are available and are improving, self-assessments in the Security area
remains a strength.
However, in the Engineering Support area, perform-
ance remains inconsistent indicating more attention is required.
Improvements have occurred in the area of outage planning, coupled with
a strong modification control program.
The licensee effectively converts
regulatory requirements into site implementation either by plant modifi-
,
cation or software changes. However, there is a heavy reliance on the
test program to identify installation errors.
Further, certain designs /
installations unnecessarily challenge operators because of weak engineer-
i
ing support.
In some cases, this involves an incomplete consideration
in the design process for human factors. This apparent deficiency in
technical approach appears also in the licensing area. Weak engineering
support continues to be noted in the environmental qualifications and
fire protection areas.
Schedular pressures continue to negatively in-
fluence the interfaces between operations and other groups, such as test
j-
personnel or engineers.
The various review groups, both required by NRC or by licensee initiative,
have the required expertise to identify substantive issues.
However,
-
upper management is struggling with developing viable solutions to cor-
rect continuing inconsistent performance. A notable asset it the quality
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6
assurance department, but the process for escalation of issues was im-
proved only recently as a result of NRC staff enforcement issues in the
, environmental qualifications area.
B.
Background
1.
-Licensee Activities
At the beginning of this SALP period, the licensee started their
first refueling outage since March 1979, which was scheduled for
"
about five months. The critical path work included final upgrade
of the emergency feedwater system to safety grade (installation of
the Heat Sink Protection System (HSPS)) and upgrades to the fire
protection area to meet 10 CFR 50 Appendix R.
Other routine major
work completed in that outage were a containment integrated leak
rate test, refueling, and emergency diesel generator overhauls.
i
Other significant work completed was the Engineered Safety Features
fuel handling building ventilation system (to support refueling)
and replacement of both letdown coolers. The outage was completed
on schedule.
Upon return to power operation in late March 1987, the plant was
limited in power output due to reaching high water level limits in
1
the Once-Through Steam Generators (OTSG's). This is termed "power
'
level limited" and is a generic power generation problem with the
Babcock and Wilcox (B&W) designed steam generators.
The high level
limits are reached because of corrosion product buildup in the
secondary side of the OTSG's which interfere with primary-to-
secondary heat transfer.
As a short-term measure to increase power output, the licensee con-
ducted a planned turbine-to-reactor trip on May 1, 1987, in order
to redistribute the corrosion products interfering with feedwater
flow in the OTSG. However, upon return to power, an unplanned trip
occurred on May 2, 1987.
The planned +. rip was successful in per-
'
mitting the plant to return to full power operation.
Excessive letdown cooler leakage into the closed-cycle cooling sys-
tem was detected on May 14, 1987, and it progressively got worse,
affecting both coolers.
The licensee decided to conduct an outege
to replace both coolers (June 12-24, 1987). During the shutdown
of June 11, 1987, an unplanned reactor trip occurred.
The outage
was planned for four weeks but was ccmpleted in two weeks.
Since the return to power operations in late June 1987, there was
one additional unplanned trip on September 18, 1987. A minor power
,
reduction for a few days also occurred to correct secondary plant
problems.
_
_
_ ._.
. - . .
.
9
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During current power operations, the licensee continues to make'
progress on Regulatory Guide (RG) 1.97 instrument work'in order to
shorten the next refueling outage. This outage is currently sched-
uled for July 1,1988, and is to .last approximately two to. three
months.
License amendments to support the above-noted modifications were
also issued during this period. An amendment of significance was
the NRC staff approval in September 1987 of the licensee's corporate
reorganization.
2.
Inspection Activities
Resident inspector assignments varied between two and four personnel
assigned during the period.
In addition numerous specialist in-
spections were conducted.
During this period, the following major
team inspections occurred:
in November 1986 and October 1987, annual emergency prepared-
--
ness exercise observations to assess licensee ability to pro-
tect public health and safety in case of an emergency;
in December 1986, an Appendix R inspection to assess licensee
--
compliance with the fire protection rule 10 CFR 50 Appendix
j
R;
1.
in January 1987, an Environmental Qualification (EQ) inspection
--
i
to assess compliance with rule 10 CFR 50.49.
i
in February 1987, a Readiness Assessment Team (RAT) Inspection
--
to assess licensee preparations for Cycle 6 startup.
Significant NRC staff effort also occurred as followup on the
numerous open issues identified during NRC-directed Performance
Appraisal Team / Systematic Assessment of Licensee Performance (PAT /
SALP) processes of 1986, especially in the areas of Technical Sup-
port and Technical and Safety review.
,
l-
This was a twelve-month SALP period which involved 4966 inspection
hours.
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C.
Facility Performance Analysis Summary *
Functional Area
!.ast Period
This Period
Plant Operations
2
2
Radiological Controls
1
1
Maintenance
1
1
Surveillance
1
1
Fire Protection
N/A
2
1
1
-
Security and Safeguards
2
1
Outages
N/A
2
Licensing Activities
1
2
Engineering Support
2
2
Training and Qualifi-
1
1
cation Effectiveness
Assurance of Quality
2
2
- No significant trends were discernible to the Board.
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11
4
0.
Unplanned Shutdowns, Plant Trips, and Forced Outages
Power
Root
Functional
Date
level
Description
Cause
Area
5/1/87
100%
Turbine-to-reactor Design - need for
N/A
trip for steam
an effective sys-
generator fouling
stem for removal
problem.
of fouling
material.
5/2/87
90%
Reactor trip on
Personnel - inat-
Surveillance
loss of feedwater
tention to verif y-
4
due to operator
ing action of
error during heat
aligning non-tested
balance calibration power range input
(LER 87-02).
to the Integrated
Control System (ICS).
6/12/87
11%
Reactor trip on
Personnel - inat-
Operations
high RCS pressure
tention to control
due to lors of FW
parameters in
in manual mode
in manual feedwater
(LER 87-06).
control.
6/12/87
N/A
Forced outage for
Tube failure under N/A
letd wn cooler
investigation.
rra, cement.
6/23/87
N/A
Rea. tor protection Personnel inatten- Operations
system (RPS) actu- tention to control
ation on high pres parameters.
sure in shutdown
bypass mode (LER
87-07).
9/16/87 100%
Turbine-to-reactor Component malfunc- N/A
trip due to high
tion.
level in plant mois-
ture separator -
control valve mal-
function (LER 87-08)
NOTE:
The root cause in the table is the opinion of the SALP Board based
on the inspector (s) description of the event and may, in certain
instances, differ from the LER.
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ii
V.
' PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
During the previous assessment period, the SALP Board found that
operational activities were oriented towards nuclear safety but
were not always fully conservative. Adequate resources were avail-
able to er.sure safe operation.
Control room operators exhibited
good overall kaowledge and command of evolutions.
Review groups
were utilized to identify problems but were less effective in caus-
ing changes to resolve noted problems.
Some personnel errors were
noted in that operations were conducted from memory or without
rigorous use of procedures.
' In addition to the routine inspections by the resident inspectors,
the inspection effort included a readiness assessment team inspec-
tion prior to startup from the Cycle 6 refueling outage (6R).
Con-
tinuous backshift inspection coverage was provided during transition
pcriods into and out of outages by the resident offica.
The control room environment continued to be oriented toward safe
operation of the plant.
The control room environment is generally
quiet, professional, and controlled.
Access to the control room
proper aren was rigorously controlled.
Distracting activities, such
as radios, were not permitted and this policy was strictly imple-
rns ated .
Control room operations pre-shif t briefings of all shif t
personnel continued to aid in effective sn'ift communication.
Rou-
tine activities were carried out with few problems.
Overall, operations department organization and planning positively
contributed to the successful conduct of both routine evolutions
and off-normal situations. Operations department management input
into scheduling shutdown and startup activities, along with alloca-
tion of resources, has permitted these complex activities to be
carried out with relatively few problems. As an example, the
planned reactor trip on May 1, 1987, was accomplished without major
problems.
Preplanning, which included briefings and additional
personnel, provided assurance that necessary plant systems were
availcbie and the evolution resulted in an expected plant response.
Further, recent testing of ventilation systems to justify Appendix
R exemption requests was completed without any adverse impact on
safe pisnt operations. Generally, safety evaluations in accordance
with 10 CFR 50.59 for these evolutions have been more complete and
thorough than in past assessment periods.
However, preplanning becomes a problem at times when schedular
pressure heightens.
Several operational interface problems occurred
,
during startup from 6R, which resulted from poor cornmunications and
_____-
--_
.-
1
13
,
the fast pace of activities.
For example, thor _e was an inadvertent
-
injection of feedwater into a steam generator because of simultane-
ous preoperational testing and feedwater heating / cleanup.
Further,
4
'
a HSPS steam generator level indicator alignment problem confused
operators on initial operation of tha steam generator for the Cycle
6 startup.
These events unnecessarily challengd operators in the
performance of their duties during mode transition periods.
Operator response to off-rormal events continued to be oriented
toward nuclear safety.
The operators were generally conservative
in these events as identified =In their response to the above-noted
challenges.
Contributing factors appeared to be their substantial
experience a+, TMI-1 specific design and the high quality of training
provided by the licensee. >For example, training for major modifi-
cations (HSPS'and Appendix R), which were installed during the re-
-
fueling outage, was extensive and it aided in operator response to
related system off-normal events. The licensee prepared the opera-
f
tors reasonably well for Cycle 6 startup as evidcreed by the rela-
tively smooth transition from cold shutdown to p?wer operations.
In other cases, there were lapses in operator conservatism. Opera-
ter impromptu action to protect against the loss of a vital bus
~
,
disrepted the conduct of a test for one emergency d'esel generator.
No adversity to safety resulted because v thest. lap es in operator
perfo*mance which usually was of high. quality.
Management resolution of problems and anomalous conditior;s that occur
is generally accomplished with an attitude toward safety. The post-
'
trip review process that has been exercised on several occasions
,
during t.his period has proven to be an effective tool in evaluating
the trip and resolving any associated problems. Plant startups
3
after the trips have been accenplished without ropstitive problems.
The backshift management tours are an initiative to focus attention
,
,
'
on routine operations.
Overall, management was substantially in-
volved in all facets of plant operations and especially in the pro"
cess of post-trip recovery.
For example, this has resulted in an
improved performance in logkeeping practices, especially for re-
cording minor event details.
Howevy,'self-evaluation of these less significant problems appears
i
to be waak, as discussed below.
These problems are not formally
'
]
evaluated by the Plant Incident Report (PIR) system. An example
-
of this occurred during post-trip recovery actions when an OTSG
'
level transmitter malfunctioned and operators reduced OTSG 1evel
to the' point at which there was an emergency HSPS logic initiation.
As permitted by technical specifications, the auto start function
of the emergency feedwater pump had been defeated, so no plant
'
transient cccurred.
Earlier evaluation of this anomaly would have
,
resulted in a more timely detection of the malfunctioning detector
i
i
--
-
-
.- . -._.
-
, , - -
-- .
- - .
- -,,
.
, , . . .
,
n
..
14
Q
'
,
x.
,
prior to plant startup instead of several days after startup.
Op-
portunities for operational program enhancements are lost because
of a lack of critical review of minor events.
'Although the number of reported events in this area is small , a few
!
I
~
problems have occurred with operators due to personnel errors.
Re-
view of LER's and internal events indicates that a majority of these
b
events are due to personnel error and/or procedure inadequacies.
,
Procedure nonadherences were a leading contributor to personnel
'
,
error events. -During major plant transitions, the pace of activi-
ties also seems to be a contributing cause.
The r amber and significance of procedure adherence problems appeared
to have decreased in this area during this SALP period, but minor
problems persisted. The most significant of these events was an
inspection finding during the draining of OTSG's for chemistry con-
-trol and when to use nitrogen overpressure.
During this transition
period, operators failed to follow procedures rigorously because
I
they were confused on which section of the procedure was to be used.
This problem was corrected by shift supervision with no adverse
effect on the plant.
Counseling or additional training on some
complex, non-routine evolutions has been the preferred corrective
.
actior,, rather than making procedure enhancements or creating new
procedures (see also Assurance of Quality).
The licensee completed implementation of the Independent Verifica-
>
tion Program (IVP) during this SALP period.
The additional emphasis
on re-evaluating their IVP activities was accomplished due to addi-
,
^
tional NRC staff concerns about the program after the IVP issue was
initially resolved in 1983. The programs for verifying correct
operating activities have been tentatively reviawea by NRC staff
as acceptable. A weakness exists in that IVP applies only to a
special subset of safety-related equipment,
,
However, IVP program implementation has, in general, been quite good
with no events occurring that involve major safety significance.
Operations performance problems with respect to verifying correct
.
activities cannot be correlated to IVP weaknesses.
They seem to
!
1
be due to poor attention to detail; failure to follow administrative
controls; poor technical and safety reviews; and, perhaps, poor
training in the area of system classification (see Assurance of
Quality).
!
1
In summary, management involvement has been evident in all areas
of operations, especially as evidenced by continuing backshift tours.
Some improvement in this area has been noted. Guidance and direc-
tion for complex evolutions are substantial.
Experienced licensed
operators, functioning in a positive control room environment, con-
i
tinue to react well to abnormal situations. This reflects positively
l
on the quality of training provided by the licensee.
The post-trip
'
,
A
h'
. _ _ _ _
.
15
.
review process is strong and is a positive aspect of overall plant
operations.
However, opportunities for operational enhancements
are missed because minor events are overlooked. The interface and
cooperation between operations and engineering or test personnel
weakens under schedular pressures.
2.
Conclusion
Category 2.
3.
Recommendations
None.
l
l
!
l
,
I
_ _ _ _ - _ - _ _
_ _ _ _ _ -
.
,
16
4
B.
Radiological Controls
!
!
1.
Analysis
During the previous assessment, the licensee's radiological controls
program had no significant deficiencies.
In addition to routine resident coverage, three inspections were
conducted by region-based radiation specialists during the current
period; two covered in plant radiological safety and one reviewed
the licensee's water chemistry control program. One violation re-
lated to in plant radiological safety was identified.
Areas of previously noted strong program performance remained con-
sistent and effective during the current period. A well qualified
supervisory staff provided an appropriate level of oversight for
on going radiological activities.
Effective radiation worker and
technician training programs continue to be implemented. The lic-
ensee's multi-level radiological controls audit program, featuring
independent review by Quality Assurance (QA) and Radiological Engi-
neering, provided technically sound and timely assessments.
Adequate facilities and equipment were available to support the pro-
gram.
Routine surveys were effectively performed and aided in the
prompt identification of secondary-side contamination and of an in-
advertent transfer of RCS water to the borated water storage tank.
Appropriate follow-up was taken to insure radiological postings and
controls reflected the newly-identified conditions.
Clear procedures and policies are in place and, with isolated ex-
ceptions, strong procedural compliance was routine noted.
Radiological sctivities during the 6R outage were well controlled
,
in which significant planning was noted.
In general, the overall
pace of activities was unhurried and resulted in minimizing radio-
logical concerns noted during the previous outage.
Radiation Work
Permits (RWP's) contained appropriate controls and workers appeared
well briefed.
Area posting and contamination control were generally effective;
however, a concern with high radiation area (HRA) posting was iden-
tified.
This has been an area of recurring deficiency for the lic-
ensee; aggressive corrective actions have been taken but have not
been completely effective in sensitizing workers to posting require-
ments in this area.
Several deficiencies in radiological controls were noted during
routine radwaste operations. A failure by the licensee to ade-
quately evaluate the scope of work and the resulting high potential
for airborne radioactivity resulted in the unplanned intake of
_ _ _ - _ _ _ _ _ _ .
_ . - _
_ _ _ _ _
___
_
._.
_
_ _
___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
%
.
17
,
i
,
'
radioactive material by. personnel working in the letdown filter
cubicle. The pace of activities was a contributing factor. This
cubicle is a known highly contaminated area.
.
Licensee corrective actions in response to an earlier _ similar event
in the same cubicle were not effective in preventing the above re-
'
currence.
The licensee's evaluation and corrective actions gene-
rated in response to the second event, however, were noted to be
comprehensive and identified both personnel and design deficiencies
which are being addressed.
Site and corporate management appeared
'
to be somewhat inattentive to the radiological control problems in
the letdown filter cubicle.
The licensee's ALARA (as low as reasonably' achievable) program ex-
hibited effective performance during the current period.
Realistic
annual and outage exposure goals were developed. A significant
scope of work activities was undertaken in the 6R outage, including
refueling, steam generator eddy-current testing, and letdown cooler
replacement.
Pre-work ALARA planning was initiated early and ALARA
'
reviews were comprehensive and well documented. The licensee im-
piemented vario;s exposure reduction techniques for the outage,
including primary system clean-up, flushing of hot spots, extensive
!
use of temporary shielding, and delay of primary system breach, by
t
scheduling integrated leak rate testing (ILRT) at the onset of the
outage. The licensee also routinely performs effective pre work
'
briefings and utilizes engineering and contamination controls.
,
Accruing exposure and work status was closely monitored by the ALARA
i
sta.ff during the outage.
ALARA efforts were effective in bringing outage exposure to 30 per-
cent under the outage goal which was primarily due to reduction of
anticipated dose rates. Significant effort was expended debriefing
personnel after the outage to ensure all outage "lessons learned"
were captured and communicated to the Radiological Controls staff.
.
Licensee exposure for the assessment period totaled approximately
213 person-rem for 1986 and 148 person-rem for the first eleven
!
months of 1987.
These exposure values compare favorable with in-
L
dustry pressurized water reactor annual averages (approximately 400
[
person-rem / year).
'
Review of the water chemistry control program indicated a strong
corporate commitment to and support for this area.
The organization
.,!
was clearly defined and well staffed,
Positions were defined and
l
interfaces with the corporate staff were well established. Good
'
'
communication of chemistry data trends was noted to occur at criti-
cal levels within the plant organization. Appropriate action was
j
taken on out-of-specification chemical parameters.
In-line instru-
l
mentation and sampling was adequate for corrosion and impurity in-
f
I
'
i
i
'
i
.-
_ __
. . . _ . . . - . , _,_ .
, , - _
_ . _ -
_
_
.m .
_ _ _ . _ _ - . _ - ,
-
.
- _ _ _ _ _ _ _ _ _ _ _ _ _ - _
.
18
.
gress monitoring.
Special attention is paid to maintenance proce-
dures and the investigation of situations where action levels are
exceeded for chemical parameters.
The overall evaluation of this
area is that the chemistry program effectively supports plant
operations.
In summary, the licensee's radiological controls program exhibited
generally strong, consistent performance in the radiological safety
and water chemistry control areas. Deficiencies in radiological
safety were noted; however, they do not appear indicative of pro-
grammatic weaknesses and the overall program remains effective.
Management inattentiveness to radiological control problems in the
letdown filter cubicle appeared to be an isolated case.
2.
Conclusion
Category 1.
3.
hcommendations
None.
.
_ _ _ _ _ _ _ _ _ _ _ .
.
19
.
C.
Maintenance
1.
Analysis
The previous SALP rated the licensee's performance in maintenance
activities as being well controlled.
The organization, scheduling,
and staffing of maintenance activities continued to have a positive
effect on plant operations.
No major maintenance-related plant
problems occurred as maintenance personnel exhibited increased
awareness of their effect on an operating plant. Weaknesses were
identified in th) areas of planning, internal event review, and EQ
implementation on prior SALP's.
During this assessment, routine resident inspection activities on
maintenance activities were supplemented by a region-based review
of the maintenance program.
The maintenance area was also examined
as part of the Readiness Assessment Team (RAT) inspection prior to
startup from the 6R refueling outage.
During this assessment period, major maintenance activities occurred
during the 6R outage which involved complex activities requiring
good coordination utilizing strict radiological control and good
inter-departmental interface communication.
The OTSG eddy current
testing and tube removal were properly accomplished in accordance
with requirements. Good vendor support occurred both in the field
and at the laboratory. Overall, performance in the tube plugging /
removal evolution was ratisfactory and accomplished on schedule.
However, vendor communication problems occurred for the major emer-
gency diesel generator (EDG) maintenance accomplished during the
outage. Maintenance activities using poor vender guidance resulted
in damage to the "1A" EDG.
The vendor had recommended some minor
engine modifications and adjustments and, apparently, this guidance
was not subjected to a thorough technical and safety (T&S) review.
Some of these critical adjustments / modifications, when combined with
the installation of new engine components, resulted in the damage.
This required a second engine overhaul with major parts replacement.
Licensee communication with the vendor seemed to be the primary
cause of this particular problem, along with poor T&S review.
The
potential existed for common mode failure as similar modifications
were to be made to both EDG's. The conditions causing the engine
failure were eventually corrected and factored into the "1B" over-
haul. Overall, it appears that the outage maintenance was conducive
,
to the good operating record, since only one unplanned trip in Sep-
tember 1987 resulted from maintenance activities.
Further, the
conduct of maintenance during power operations did not adversely
affect plant operations.
. - - .
_- - _ _ .
.
20
.
The environmental qualification (EQ) review verified that safety-
related electrical equipment was being properly maintained in ac-
cordance with appropriate EQ requirements.
An administrative problem with the final closecut of job tickets
was identified during a review of post-letdown cooler replacement
outage work documents.
Final closecut of the job ticket documents,
reflecting final testing and operations acceptance of the component,
had not occurred up to three to four months after the outage.
The
question of equipment operability certification and restoration to
normal was raised, but other management control systems were found
to verify component operability.
This delay in final job ticket
processing did not adversely affect the status of the individual
component / system operability processing.
Management involvement in maintenance activities continued to be
substantial. The QA/QC coverage was also substantial and the back-
log of safety-related maintenance items was relatively small. As
an example, both decay heat removal / low pressure injection loops
were successfully worked in three day mini-outages to resolve minor
leaks / problems and accomplish preventive maintenance. No adverse
impact on plant operation resulted from this activity.
The organizational structure of the maintenance department has re-
cently been changed to orient the on-site activities to a higher
t
level of "materiel control" and to be in line with other corporate
maintenance organizations. A new area of this organization will
trend maintenance activities with the intent of predicting component
end of serviceable life so that these components can be replaced
prior to failure.
This is viewed as a positive step in the overall
conduct of maintenance.
One violation occurred due to maintenance activities and one LER
resulted from maintenance activities.
The violation involved a
procedure weakness and a technician being unaware of the safety
impact of his actions with lif ting leads on a safety system. The
LER involved auto start of a diesel due to a construction defi-
ciency with a relay cover. Although these events were isolated
incidents in this area, other functional areas address training
deficiencies, personnel errors, and procedure step inadequacies.
Corrective actions were appropriate (see Training and Assurance of
Quality).
In summary, the various groups within the maintenance department
are adequately staffed.
Maintenance supervisory personnel are
knowledgeable of on going activities and have effectively maintained
control of scheduled activities throughout this period.
Communica-
tion and coordination between maintenance and other groups, such
as operations, appeared to be more effective despite isolated lapses
in the area of vendor interface. No plant trips or significant
I
f
.
21
.
operational problems occurred as the result of maintenance activi-
ties.
The maintenance department continues to be a positive in-
fluence on overall plant performance.
2.
Conclusion
Category 1.
3.
Recommendations
None.
_ _ _ _ _ _ _ _ _
.
22
.
D.
Surveillance Testing
1.
Analysis
During the previous SALP period, the licensee's surveillance program
was considered a strength.
The program was adequate and properly
implemented.
Failure to provide specific commitments and schedules
in the licensing area adversely affected the insarvice testing area.
Procedures for accomplishing surveillances remained adequate.
During this assessment period, inspection activities in the sur-
veillance area consisted of normal resident review of on going sur-
veillance activities. Also, programmatic reviews of inservice in-
spection and testing areas were conducted.
The surveillance area
was also reviewed in detail during the Readiness Assessment Team
(RAT) inspaction conducted prior to startup from the 6R outage.
Additionally, the containment integrated leak rate test (CILRT) was
monitored and evaluated.
Inservice inspection (ISI) activities were satisfactory. The lic-
ensee's program for determining pipe wall thinning from the erosion /
corrosion process was acceptable and resulted in several components
being removed and replaced due to significant degradation well in
advance of an NRC bulletin on the matter.
The methodology of selec-
tion / detection, the equipment used, and the knowledgeable personnel
conducting the examination process was viewed as a strength of the
ISI program.
The inservice testing (IST) program was adequately implemented.
The program implementation was reviewed and it was determined to
be in conformance with regulatory requirements.
The lack of a
trending program for acceptable results represented a weakness in
the Engineering Support area for the program in that only unsatis-
factory results were reviewed by engineering. With the issuance
of the NRR safety evaluation for this program, the licensee initi-
ated actions to assure modifications are installed within schedular
commitments.
Outage-related surveillances were conducted properly and were well
controlled.
For those conducted during the mode transition periods,
additional shifts and/or personnel were used to allow the on-shift
operators to coricentrate on plant status and core heat removal.
Also noteworthy was the containment integrated leak rate test (CILRT)
in that it was an "as-found" test in which repairs did not precede
the test.
Good administrative controls were used for the test and
test-related activities.
The test procedure was properly imple-
mented or changed appropriately.
Duties and responsibilities of
test personnel were clearly defined and well understood by personnel.
A good interface existed between operations and test personnel and
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
_ _ _ _
l
..
I
23
i
. '
there was substantial QA and management involvement in the test.
- These positive attributes were similarly noted for other major plant
,
testing.
,
Although the "as-found" CILRT failed, adequate corrective actions
4
were taken.
The related LER identified that the previous local leak
rate test procedure did not identify _this leakage because of a test
,
l
methodology different from the CILRT. Although procedures were up-
graded, this procedure deficiency was reflective of a procedure
adequacy problem (see Assurance of-Quality).
The use of a surveillance matrix on the power escalation test pro-
gram schedule (start-up pre requisite document) resulted in a smooth
,
transition from outage activities to puwer operation.
No incomplete
,
actions in the surveillance area was noted. The pre-operational
and start-up test programs complement the surveillance test area,
t
Operability reviews of safety-related systems revealed that sur-
l
veillance testing was accomplished in an adequate and timely manner.
.
The exception and deficiency (E&D) process for noting unsatisfa. tory
l
,
data or procedure problems was properly and effectively implemented.
The E&D's were integrated into the refueling outage startup prere-
,
'
quisite list.
Problem resolution using this system was effective
,
in resolving issues as they occurred and this additional site man-
agement oversight resulted in greater assurance that the large num-
!
.
ber of surveillances needed prior to 6R startup were completed
'!
j
satisfactorily,
!
,
'
One reactor trip occurred due to surveillance activities and was
i
described in an LER. Another LER dealt with the incorrect perfor-
!
i
mance of a surveillance test resulting in the discharge of a waste
i
evaporator condensate storage tank (WECST) with the automatic ter-
i
mination function being bypassed.
Both of these were attributable
!
to a personnel error.
However, corrective actions included proce-
!
dure enhancements (see Assurance of Quality section).
i
!
,
i
One violation was noted in the surveillance area during the RAT in-
i
spection. This was a procedure adherence problem due to the cali-
bration procedure not being upgraded to the actual methodology used
'
for instrument loop calibrations (see Assurance of Quality).
[
,
t
!
In summary, the surveillance testing area continued to be a strength
i
in the licensee system for ensuring the operability of safety-
f
related equipment.
Previous concerns over licensing impact on the
'
IST program have been resolved with the issuance of a final NRC
,
i
safety evaluation report on the second ten year IST program.
Re-
i
i
solution of technical problems is complete and adequate. Conserva-
l
tive action is taken for surveillance test deficiencies.
Procedure
'
_
use has been generally good with a few exceptions of minor nonad-
[
'
herences or personnel error,
t
!
i
!
i
!
'
--
- _ . _ . -.
. _ _ _ _
.
24
.
2.
Conclusion
Category 1.
3.
Recommendations
None.
l
e
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l
..
- _ _ _ _ _ - _ _ _ _ _ _ _ _
25
E.
F_ ire Protection
1.
Analysis
The previous SALP period did not specifically evaluate this area.
For that period, fire protection activities were included primarily
in the maintenance area. The findings of the SALP were, overall,
positive with no implementation problems identified.
This assessment is based on the following: (1) region-based Appendix
R team inspections; and, (2) resident inspector focus on program
implementation in addition to routine monthly reviews.
Management's involvement in the Appendix R compliance effort was
evident.
Upper level management paid considerable attention to the
,
progress of the Appendix R inspection and they made commitments to
satisfy NRC concerns raised during the inspection. The licensee,
through the use of an experienced consultant and corporate-based
engineering personnel, developed a fire hazard analysis that was
thorough and easily understood.
The response to NRC concerns was adequate. Many issues were dis-
cussed with the licensee, researched by the licensee, and ultimately
resolved to the NRC's satisfaction.
A substantial amount of work was properly completed to assure com-
pliance with 10 CFR 50 Appendix R.
Licensee management recognized
well before the refueling outage that the fire protection system
upgrades were a critical path for Cycle 6 startup.
Planning started
sufficiently earlier, but poor engineering support (untimely engi-
neering work / incomplete or inadequate initial reviews) appeared to
be a contributing factor to poor performance in the Appendix R as-
pects of fire protection area as noted below.
As an example of poor engineering support, there was an "eleventh
hour" change from a maximum of thirty minutes to ten minutes re-
quired to restore reactor coolant pump (RCP) seal thermal barrier
cooling and seal injection for a design basis fire and this resulted
in a last minute exemption request before Cycle 6 startup. Also,
engineering review failed to identify the need to install emergency
lighting and this resulted in a violation.
An LER resulted because
of an inadequate fire barrier review.
Further, vendor re-review
of Appendix R work has identified significant previous oversights
for unprotected cables in areas covered and not covered by a fire
watch.
It is noteworthy that this review is occurring and the lic-
ensee is keeping the NRC informed as significant deficiencies are
identified. However, the above-noted deficiencies collectively
reflect adversely on corporate management's ability to rigorously
direct and control the engineering support work for this area.
.
e
-
..
!
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26
O
P
h
l
In fact, there appears to be signs that previously identified per-
i
formance problems in the environmental qualification area may be
occurring in the fire protection area.
These negative elements are:
inadequate reviews, delays in meeting requirements, and apparent
lack of understanding of requirements in this specialized area,
,
This situation was similar to a condition identified in the EQ area
noted in previous SALP reports.
!
l
Generally, the fire protection program at THI-1 continues to be
properly implemented.
Housekeeping is acceptable and control of
transient combustibles is generally not a problem, Unacceptable
housekeeping conditions were noted in the auxiliary building just
prior to Cycle 6 startup, but management was responsive and cor-
rected the problem within a week after restart.
These conditions
resulted from the temporary storage of outage-related transient
equipment taken out of safety-related areas to support restart.
-
Also, fire protection engineer weekly walkdowns of the plant spaces
identified some minor discrepancies, but they were promptly cor-
,
rected.
The inspectors noted proper implementation of this program.
'
.
Although a number of outstanding inspection findings in the fire
l
l
protection area were identified in the last SALP period, the licen-
.
i
,
see was generally responsive toward the satisfactory resolution of
related issues.
The inspector noted that some items could have been
',
precluded, in part, had better communications occurred between re-
spective organization representatives and, in part, if licensee
-
personnel would have given a more complete initial review of the
issues.
t
i
Licensee provided training for operators in this area appeared to
l
be well thought out and substantial as evidenced by the remote
shutdown panel test.
Previously identified fire brigade training
I
problems were also resolved.
In summary, the fire protection program is well established and it
appears to be properly implemented.
Isolated lapses in the high
'
level of performance in the housekeeping area occurred, but manage-
ment was responsive by providing adequate corrective action. Ap-
pendix R deficiencies appear to be due to weak engineering support.
However, a substantial amount of Appendix R work was satisfactorily
completed and properly tested.
2.
Conclusion
Category 2.
.
3.
Recommendations
See Engineering Support,
r
I
_
-
- .
.
- .
- -
.
- -
-
_ _ _ _ _ _ .
-_ __
,
.
27
]
)
F.
i
1.
Analysis
,
1
During the previous assessment period, the licensee's program was
'
considered a strength in this area. With the implementation of the
i
first consolidated GPU Nuclear Emergency Plan for all three nuclear
!
units, an effective emergency preparedness program was noted along
with excellent performance during the annual exercise.
'
During this assessment period, an Unusual Event was declared, and
l
there were:
two failures of the primary emergency communications
'
system; a full participation exercise [ Federal Emergency Management
Agency (FEMA) observed); a partial participation exercise observed
(observed by NRC); and, a routine inspection.
Further, Revision
-
1 to the consolidated GPU Nuclear Emergency Plan for both GPU sites
was submitted.
'
,
The primary emergency communications system failed on Saturday, May
)
9, 1987, when all twenty-three dedicated emergency phone lines, in-
cluding NRC's Emergency Notification System (ENS) plus commercial
phone lines, were inoperative.
The shift supervisor promptly de-
l
clared an Unusual Event in accordance with implementing procedures
L
and used the alternate (back-up) microwave system.
The NRC was
,
contacted, but notification could not be made to the Pennsylvania
!
l
Emergency Management Agency (PEMA) and the Dauphin County Emergency
i
Operations Center until three hours later when partial phone service
was restored. The failure was due to a malfunction in Bell of
Pennsylvania's Harrisburg central offices phone system. Calls with-
in and to and from the Harrisburg area were not possible.
Off-duty
GPU personnel assigned to the TMI initial and support emergency re-
!
sponse organizations could not have been called to report in on May
.
l
9, 1987, since their pagers are activated via the Bell telephone
f
'
system. GPU Nuclear recognizes a need to upgrade the alternate
system and is working with the PEMA to do this, stressing communi-
l
cation system diversity. This failure was beyond any anticipated
by the emergency plan; however, licensee response to this low prob-
ability event was very good, which demonstrated that the operations
t
and emergency response personnel are well trained and knowledgeable,
j
,
i
A second failure of lesser magnitude took place on Thursday, May
l
13, 1987, when an off-site construction crew cut all phone lines
i
between TMI and Harrisburg.
This event did not warrant the declara-
!
tion of an Unusual Event.
The alternate microwave system was again
!
placed in service.
PEMA, the five surrounding counties, and the
[
NRC were promptly notified.
Phone service was restored in nine hours,
t
!
'
During the routine safety inspection, all program activities re-
viewed met regulatory requirements with one minor exception. A
!
Notice of Violation was issued for failure to supply a procedure
'
l
l
!
.
.
.
-
-
-
- _ .__ - -. _
.
28
.
revision to the NRC within thirty days of such changes, as required.
All other procedure changes were appropriately incorporated into
procedures and were reviewed, approved, and distributed in accord-
ance with regulatory criteria.
Observation of the full and partial participation exercises indi-
cated licensee actions were timely and adequate to provide protec-
tive measures for the radiological health and safety of the public.
Although exercise performance was adequate, two weaknesses were
identified.
The first a.ea involved a weakness in the ability of
the Technical Support Center to analyze plant conditions and provide
answers to technical questions asked by the control room and Emer-
gency Operations Facility. The second involved slowness in acti-
vating the Parsippany Technical Functions Center.
Both of these
weaknesses had been noted to some extent in previous exercises.
Although these weaknesses are not considered major, it appears that
management has nut provided sufficient attention to this area.
In summary, the licensee has committed sufficient resources and
developed supporting policies for Emergency Preparedness.
The ef-
forts expended in the TMI-1 Emergency Preparedness Program exceed
regulatory requirements.
In general, correction of identified de-
ficiencies has been good; however, a declining trend was noticeable
in light of the above-noted repetitive deficiencies.
2.
Conclusion
,
'
Category 1.
3.
Recommendations
None.
I
M
f
I
l
r
I
1
k
.
_ - _ _ _ _ _ _ _ _ _ _
.
29
.
G.
Security and Safeguards
1.
Analysis
During the previous SALP, the licensee's performance in this area
was Category 2.
This rating was influenced by a long-standing issue
involving the perimeter intrusion detection system and the Regula-
tory Effectiveness Review (RER) identified program vulnerabilities.
During this assessment period, one routine and one special unan-
nounced chysical security inspection were performed by region-based
inspectors; and routine inspections by the resident inspectors con-
tinued throughout the period.
No violations were identified.
The licensee :ommitted to have the issue involving the perimeter
intrusion detection system (PIDS) resolved by December 1987. A new
PID was installed and operational on August 19, 1987.
The resolu-
tion of this long-standing issue approximately four and half months
before the committed date is indicative of the licensee's desire
to implement an effective program.
Most of the RER findings were
addressed prior to the issuance of the final report of the RER
findings in January 1987. The licensee responded to the remaining
RER findings in May 1987.
Corporate security management continued to be actively involved in
all site security program matters.
This involvement included visits
to the site by the corporate staff to provide assistance, program
appraisals, and direct support in the budgeting and planning pro-
cesses affecting program modifications and upgrades.
Security man-
agement personnel are also actively involved in the Region I Nuclear
Security Association and other industry groups engaged in ruclear
plant security matters.
This demonstrates program support from
upper level management.
The licensee's self-inspection techniques, which are independent
of the NRC's required annual security program audit, were again an
effective method of providing oversight of the implementation of
l
l
the security program.
The self-inspection teams are composed of
experienced security management personnel from corporate headquar-
ters and TMI-2 and Oyster Creek.
The findings of the self-inspec-
tions are reviewed at the security corporate level and are forwarded
to site security management for actions.
This initiative is indica-
l
tive of the licensee's desire to implement an effective security
program and has contributed to the licensee's excellent enforcement
'
history during the evaluation period.
l
Tne annual audit of the security program, performed by the 11cen-
see's quality assurance group, was extremely comprehensive in scope
and depth.
Audit reports are distributed to appropriate management
I
&
-
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
.
30
!
!
.
!
!
personnel for review and action, as necessary.
Corrective actions
on deficiencies identified were prompt and effective with adequate
follow-up to ensure their proper implementation.
.
The licensee submitted no security event reports to the NRC during
i
l
the assessment period.
Review of the licensee's event reporting
procedures found them consistent with the NRC's regulation (10 CFR 73.71) and implemented by personnel knowledgeable of the reporting
,
]
requirements.
Staffing of the licensee's security organization is adequate.
De-
fective security equipment is repaired in a timely. manner, thus
minimizing the need for compensatory security posts and overtime.
.
The security officer training and requalification program is well
!
developed and administered by two full time instructors.
In addi-
tion to initial and requalification training, self-initiated on-
the-job performance evaluations are conducted which measure the
,
retention and proficiency of individuals with regard to general and
i
specific security program requirements. This initiative is further
evidence of the licensee's desire to implement an effective program.
A programmatic problem was identified in the maintenance of training
,
records.
In transferring the source training documents from paper
files to microfiche files, the licensee created an extremely cum-
!
bersome system of filing and retrieving training documentation.
'.
During a routine inspection, the licensee was unable to provide
source training documents to the inspectors in a timely manner,
j
The nature of the system is such that there is a potential for the
>
{
licensee to overlook required training for individual members of
!
!
the security force.
This system was scheduled for internal QA audit
l
in October 1987, as part of the annual security program audit.
"
i
During this assessment period, review of the licensee's security
-
I
maintenance program revealed that a dedicated technician with
I
authority to obtain assistance from other qualified technicians has
j
been assigned to security equipment. The result is a maintenance
J
and testing program that is very responsive to any equipment mal-
J
functions, thereby minimizing system degradation and the need for
j
manpower intensive and prolonged use of compensatory measures.
,
Security facilities and spaces were adequate and well maintained.
Records, except for the aforementioned source training records, were
]
readily retrievable, complete, and centrally located for ease of
use,
,
1
I
!
l
l
J
,
I
i
1
l
-
_ _ _ _ - _ -
_
_.
_.
.
.
. . _ _ _ .
. _ - _ _ - _ _ _ _ _ , _ _ _ _ _ _ _ _ _ _ - _ _ .
..
31
l
.
!
Members of the security force exhibited excellent appearance and
[
morale and a professional demeanor. The turnover rate among members
of the security organization remains very low and those that do
leave are generally promoted to-other positions within the licen-
see's organization.
Ouring this assessment period, the licensee submitted three revi-
,
sions to the security plan in accordance with the provisions of 10 CFR 50.54(p), one revision to the security plan under the provisions
of 10 CFR 50.90, and provided its response to the miscellaneous
i
amendments to 10 CFR 73.55, codified by the NRC in August, 1986.
That response is under NRR review.
Two 10 CFR 50.54(p) revisions
,
resolved NRC comments resulting from revisions submitted in the
'
prior SALP period.
The third is currently under review.
The 10 CFR 50.90 revision is also currently under review and involves the
,
consolidation of the TMI-1 and TMI-2 security forces. The quality
'
.
of the revisions was acceptable and these revisions provided suffi-
cient detail to describe the changes.
The licensee has continued
,
I
to upgrade the security program and revise program plans consistent
with current operations and requirements and, as noted previously,
o
resolved a long-standing safeguards licensing issue ahead of
l
schedule.
'
,
]i
In summary, the licensee continues to implement a very effective
security program that goes beyond mere compliance with regulatory
I
requirements and security plan commitments, such as noted in their
i
i
self-assessment techniques. The initiatives undertaken by the
licensee are indicative of the licensee's intention to implement
l
,
a high quality security program.
2.
Conclusion
I
i
Category 1.
3.
Recommendations
,
None.
I
]f
.
,
!
J
'
e
i
i
1
I
,
]
!
J
J
5
4
!
l
,
, ,, , - -
- ,
- - _ , , . . - . - - . - - - - - . .
- - - - . -
--
<,rerm-,-
- -e
~
w-
- - ---
erm1
- - --- -- - - - -
-
---
.
.
32
.
H.
Outages
1.
Analysis
The previous SALP period did not specifically evaluate this area.
For that period, outage-related activities were included in Engi-
neering Support area (previously termed "Technical Support").
The
findings of the SALP were, overall, positive.
The licensee was
adequately prepared for the then upcoming refueling outage.
Some
engineering delays were evident.
This assessment is based on the following:
substantial resident
and region-based inspections during the refueling outage and Cycle
6 startup; a Readiness Assessment Team inspection; and, twenty-four
hour resident coverage of the transitional periods in between the
two outages and power operations.
The licensee demonstrated an ability to realistically schedule their
outages considering the planned work.
The refueling cutage was
completed essentially on schedule and the letdown cooler outage
ahead of schedule. A number of contingencies were factored into
these schedules; these contingencies were not realized for the let-
down cooler replacement outage.
Contributing factors to this
scheduling ability were frequent and routine site / corporate staff
meetings and a staff dedicated to long-range planning.
The licensee
recently further enhanced this aspect with a reorganization to con-
solidate planning, licensing, and safety review under one corporate
vice president.
The ALARA and radwaste generation considerations
were factored into this planning, along with contingencies for un-
expected problems.
New initiatives were also included, such as for
recommendations as a result of the Babcock & Wilcox (B&W) designed
reactor reassessment. Overall, substantial management attention
and involvement in this area has produced positive results.
The licensee intentionally delayed the four-week refueling evolution
to prevent interference with other reactor building work, such as
the containment leak rate test.
Refueling procedures were well
written and thorough for controlling necessary fuel movements and
verifications.
Staffing was ample and personnel from operations
and oversight organizations exhibited a well qualified and trained
attitude when performing activities that had not been accomplished
since 1978-79.
The licensee also used the most experienced senior
reactor operators (SRO's), including the Plant Operations Director,
to provide twenty-four hour overview coverage of refueling activi-
ties.
In addition, operations QA monitors provided twenty-four hour
coverage.
The licensee had its site personnel well prepared for
this somewhat unique activity with respect to procedures, training,
and staffing.
1
_ _ _ _ _ _ _ _ - _ _ _
_ _ -
h
I
.
33
'
'
i
,
Implementation of fuel movement was proper and in accordance with-
.;
procedures. Site management was frequently observed in the plant
'
and as part of deliberations on technical problems with refueling.
-
They also interfaced with the QA department to assure proper imple-
i
mentation.
In addition QA conducted a special audit to verify
proper positioning of fuel assemblies. When problems in the house-
keeping area occurred, site management was responsive to correct
the situation. Overall, refueling was conducted in a safe manner
and in accordance with regulatory requirements.
i
The quality and control of the workmanship during the outages were
!
generally acceptable.
Inspections confirmed that required modifi-
l
cation installations were in accordance with essential design ele-
l
ments and regulatory requirements.
Examples included the new fuel
,
handling building ventilation system, the new Heat Sink Protection
t
System (HSPS - safety grade initiation and control system for emer-
gency feedsater system (EFW)), and control building ventilation
'
system modifications. This was attributable to good verbal and
formal communications between the licensing, engineering support,
'
and construction groups. However, there were some problems that
.
resulted in significant events, some of which were reportable, as
[
addressed below.
,
o
Installation errors did occur; and, in most cases, they were iden-
t
tified by test activities.
Some resulted in significant events
!
during the refueling outage. Three LER's, one violation, and a
number of inspection findings in this area indicated that these
,
errors were a result of: (1) poor work instructions, such as unclear
i
drawings reflecting, in part, weak engineering support; and,
(2) personnel errors primarily due to inattention to detail and,
!
to a lesser extent, to failure to follow work instructions.
The
!
most significant of these events which reflects all of these causes
was the incomplete Appendix R wiring work on the "18" emergency
,
diesel generator, failure of test personnel to identify the incom-
plete work prior to diesel functional testing, and repeated operator
attempts to synchronize the diesel generator output breaker for
-
functional testing despite repeated excitation circuit trips and
L
no control room voltage indication. Although the licensee identi-
l
fied and corrected these problems primarily through the test program,
they do reflect poorly on the adequacy of supervisory direction and
l
.
1
control.
Review of these events revealed no programmatic deficien-
)
cies.
!
The test program was adequate in that it detected work installation
errors. Test personnel were knowledgeable of plant design and their
[
duties.
Substantial training occurred for the remote shutdown panel
i
,
.
test, along with HSPS modifications. The licensee was responsive
'
to NRC concerns to conduct a functional test of the remote shutdown
'
panels. The tie-in system adequately enntrolled the transition from
l
i
[
!
t
i
f
-
-
- -.-,,
.--- ~ -.
. . . . -
- . -
-
- ..
.
.
.
. - - .
_________ -_
_
i
!
i
34
,
construction to tast to operations despite implementation problems.
'
The licensee initiative of a company wide startup prerequisite list
provided an added measure of plant / system readiness for startup.
However, there were deficiencies noted. Static zero shift alignment
for HSPS level transmitters was not done in plant and resulted in
.
operator confusion during Cycle 6 startup boil-down of the OTSG's.
[
Other examples included an inadvertent feedwater (FW) injection to
'
a steam generator (SG) during HSPS testing and FW heating / cleanup.
Schodular pressures were noted to influence these activities.
'
The Cycle 6 startup physics tests were performed in accordance with
approved test procedures by highly qualified personnel. Test re-
!
sults were properly evaluated.
Information derived from the test
results, such as the power imbalance detector correlation test, was
quickly disseminated to the appropriate groups. Records were well
prepared, complete, and readily retrievable.
Staffing was observed
i
to be ample and reactor engineers involved in these tests were found
i
to be knowledgeable in their assigned areas.
Excellent support from
i
the headquarters fuel design group and fuel vendor (B&W) was also
'!
evident.
This resulted in efficient and timely test data reduction
l
and evaluation.
,
,
Modified or new systems remained operable and in good working order
-
throughout power operations.
For example, there were no inadvertent
HSPS/EFW actuation during power operations, nor were there inad-
vertent engineered safeguards (ES) or EFW actuations during post-
trip recovery periods. Modification and testing activities con-
l
tinued through power operations without any significant plant up-
!
sets. This record reflected the high quality coordination of a
[
number of groups sorking closely together.
The QA activities in this area included procedure resiew, test wit-
nessing, and test results review.
The QA monitoring program for
l
all outage activities was thorough and comprehensive.
In summary, outage planning had dedicated resources, provided for
contingencies, and reflected initiatives for improvement.
Refueling
was well controlled.
In general, there was high quality and control
i
l
of workmanship during the outages; but problems existed, and there
I
was apparently heavy reliance on the test program to identify these
,
problems. This reliance reflects a lack of defense in depth to
j
,
assure that modification installation errors are not carried through
~
1
the test program with adverse results on operations. Operations-
'
test interface problems occurred when schedular pressures increased,
The startup physics program was well established and adequately
l
i
1
implemented.
Substantial QA/QC and management attention and in-
[
!
volvement were noted in this aren.
>
l
i
i
f
6
l
t
t
)
!
o
-_ .
. _ _ _ _ _ , _ . . _ . .
_ _ _ _ _ _ _ . . _ _ , _ _ _ _ _ . _ _ _ _ _ . _ _ . - _ . _ _ _ _ _ _ . . , _ . - . , , _ _ _
_
1
I
i
.
&
35
.
i
2,
Conclusion
'
Category 2.
3.
Recommendations
'
None.
l
,
s
i
I
{
i
I
I
i
I
t
L
>
I
i
,
f
f
1
Y
I
4
!
,
!
,
4
t
f
l
l
<
b
i
!
r
-. . ,- , -.. - ...-. - -- - . - ..- . ... . -
. - .
. - .
. . . . . ~ . . . - _ . - - . . . - - - - . - . . .
. - . .
- _ _ _ _ _ _ _ _
.
36
4
I.
Licensing Activities
1.
Analysis
During the previous SALP period, the licensee was rated as Category
1 with the trend declining in this functional area.
During the current SALP period, fifty-two licensing actions were
under review. Of these, thirty were completed.
The majority of
these were complex and difficult.
Twenty-two licensing actions
remained open at the end of the SALP period.
The significant licensing actions completed in the SALP rating
period include the following:
reactor coolant pumps trip review;
RG 1.07 requirements for instrumentation (a few remaining open
items); NVREG 0737, Item II.E.1.2, long-term EFW items; reload
amendment; Appendix R Exemption Review; certain Salem ATWS (Antici-
pated Transient Without Scram) items; review of RCS high pressure
reactor trip setpoint; resolution of asymmetric loss of coolant
actuation (LOCA)/ multi plant action item 0-10; and, revised steam
safety valve operability requirements.
The licensee has shown evidence of prior planning and assignment
of priorities.
This has been demonstrated in the good working re-
lationship between the former and present NRC project managers and
the licensee.
This is also shown in the licensee's excellent re-
sponse to the Safety Issues Management System (SIMS), and, at tce
NRC project manager's suggestion, the maintenance of a priority l!st
for licensing actions.
The licensee has continued to demonstrate an active role in licens-
ing-related activities.
Management involvement has been especially
evident where issues such as steam generator tube corrosion and
power reduction due to steam generator fouling have potential for
extended shutdowns.
The licensee has demonstrated an understanding of the technical
,
l
issues involved in licensing actions and has grrerally proposed
technically adequate and timely resolutions to these issues. Man-
agement attention and involvement has generally been good, showing
prior planning and assignment of priorities. An exception has been
the fire protection issue.
In mid-1982, the licensee proposed a
course of action to satisfy Appendix R, which the staff described
as acceptable in a Safety Evaluation Report.
Since that time, the
licensee has changed course repeatedly, preferring a less conserva-
tive approach and causing delays in resolving the fire protection
issue.
In late 1986, the staff denied certain proposed exemptions
for protecting heating, ventilation, and air conditioning (HVAC)
related systems. By February / March 1987, the licensee was ready
for restart but had made little apparent progress to resolve the
O
37
,
1
staff's stated concerns in previously denying the exemption requests.
This caused considerable last minute review activity for the staff
,
and resulted in exemptions based on fire watches to resolve the
problem.
There was a clear understanding with the licensee that
the fire watches were a "short term" expedient.
However, alterna-
tive codifications to permit removal of the fire watches were not
proposed at the end of the period. The less conservative route of
trying to show by analysis that fire damage will not occur has been
chosen and delays in meeting Appendix R are continuing.
Some improvement has been noted in timeliness of submittals.
How-
ever, delays were experienced in submitting an amendment proposed
to update pressure-temperature limits to account for irradiation
effects on the reactor vessel through ten effective full power years,
i
This required the NRC staff to imtrediately review the submittal
because the plant would have had to shut down or violate the exist-
ing technical specification limits in about two and a half months
from the time the submittal was received.
Other licensing issues
which could have been dealt with better were: (1) the reorganization
of the Radiological Controls Department, which required repeated
submittals to correct minor oversights; and, (2) the chlorine de-
tection system technical specifications for which inadequate justi-
fication was proposed to meet RG 1.95.
These aclays appear to be
attributable to the engineering support staff.
The licensee has been responsive to NRR in meeting on an approxi-
mately monthly basis to discuss all active licensing actions in-
cluding their priorities and future submittals.
These meetings were
well conducted, well prepared for, and helpful in resolving the
issues.
The licensee has been responsive to NRR initiatives.
The quality
of its "no significant hazards consideration" analysei has improved.
'
For one issue, the proposal of revised technical specifications for
radiological ef fluent treatment systems (RETS), a revised submittal
was received because the staff had concerns about the "no signifi-
cant hazards" evaluation. Although the "no significut hazards"
evaluation was improved from the original submittal, it was still
insuf ficient in that a meeting was required to clarify significance.
Also, several items in that submittal were improperly characterized
as administrative in nature. This problem was cated in the previous
SALP report, but it was only partially corrected.
On other issues, the licensee has responded promptly to several
surveys from the staff dur.ng the reporting period.
This >1s par-
ticularly evident in the licensee's response to the staff's request
for SIMS information.
Also, in response to the staff's initiative
,
in Generic Letter 85-07, the licensee submitted its integrated
living schedule in July 1987,
I
!
!
.
38
.
With regard to reporting of operational events, the Licensee Event
Reports (LER's) appear to be thorough and adequate. With few ex-
ceptions, LER submittals are made on a timely basis and contain
detailed information on the event description and evaluation.
For
one issue, the reportability of inadvertent actuations of the EFW
system, the licensee's approach was less than satisfactory, but it
has improved.
Initially, the licensee resisted reporting those
actuations (in distinction to logi; actuations) on the basis that
the F.FW is not described as an engineered safeguards feature in *.he
Final Safety Analysis Report (FSAR).
However, in the staff's view,
that approach was not consistent with the intent of the regulation
for reporting.
The licensee has now agreed to report such events.
In summary, the licensee's performance for the licensing activity
was generally found to be acceptable. Management attention and
involvement was generally good, showing prior planning and assign-
ment of priorities.
The submittals have demonstrated an understand-
ing of the issues and have generally been technically adequate and
timely.
The technical approach to the resolution of issues is
sometimes not as conservative as it should be or somewhat short-
sighted.
Staffing levels and quality of staff are, therefore, ade-
quate.
Staffing in the licensing area is especially strong with
approximately ten personnel evenly divided between headquarters and
the site.
2.
Conclusion
l
Category 2.
3.
Recommendations
j
None.
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,
!
.
.
!
39
,
J.
Engineering Support
1.
Analysis
The last SALP continued to note a well established modification
control program with improvements noted, in part, due to an exten-
,
sive NRC inspection related to TMI-1 restart.
In certain instances,
'
procedures lacked clarity and definitiveness, putting an undue bur-
den on personnel.
Implementation problems persisted, especially
,
'
in the area of drawing control and environmental qualification.
Support for routine operational problems appeared to be appropriate,
'
'
but, again, this function was not severely taxed because of the good
o p rating record at TMI-1 during that last period. The SALP Board
recommended that the licensee conduct a self-analysis for this area
to determine the causes for inconsistent performance and that an
'
NRC team inspection complete a similar review.
l
This assessment is based on the following: substantial resident and
region-based inspection during the Cycle 6 refueling and startup
!
period; a Cycle 6 startup Readiness Assessment Team (RAT) inspection,
focusing on the design of the HSPS; resident inspections at the
corporate office; and, Appendix R and EQ team inspections.
I
During this assessment period, the licensee was generally responsive
!
I
to the last SALP and, in particular, to the above-noted board re-
commendation.
Specifically, the licensee started the "technical
!
support" self-assessment.
In their SALP response, they also com-
j
mitted to initiate an audit-type review by Technical Functions on
l
implementation of the replacement-in-kind parts program.
Licensee
-
l
plans in this area appeared to be adequate, but a target completion
date appears to be well into the next SALP period for both actions.
Definitive and appropriate corrective actions, along with completion
dates, were not specifically formulated and completed to reverse
continued inconsistent performance aspects noted below.
Overall, Technical and Safety (T&S) review of modifications was
adequate, but technical deficiencies continued to be noted.
Safety
evaluations were reasonably thorough and, in some instances, quite
extensive.
This was a direct result of substantial controls estab-
lished by procedures at the Technical Func', ions level.
However,
revisions to SE's did net have documented 10 CFR 50.59 evaluations.
Further, despite a substantial safety evaluation (SE) on HSPS, the
l
'
OTSG water level design incorporated at least two blind channels
in the control room.
This necessitated only weekly channel checks
(in lieu of shift or ciaily) because test and measuring equipment
was needed for four channel comparisons. Also, the procured water
level transmitters appear to have a high failure rate and an align-
ment shift problem which recuired several transmitter replacements.
The licensee was actively reviewing Operations' concerns on HSPS
for proper resolution.
For this problem, schedular pressures did
i
j
-
-
--
-
_
_
_
_
-.
-_ _- _ _ _ _ _ _ _ _ _ - _
-_ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ -
.
40
-
.
not permit operations feedback f.u engineering in time to enhance
HSPS design. As an additional exaaple, the re?ctor water level
'
design has a single failure susceptibility, appseently to alleviate
concerns for too many instruments in the control roem. This indi-
cates that the licensee's technical approach in the design area,
at times, is shortsighted in that all factors, such as ha,an and
safety factors are not fully considered a1d properly evaluated.
.
>
Similarly, T&S review of technical problems was adequate, but docu-
centation deficiencies continued to be noted. Corporate and site
engineering effectively resolved the performance problems noted in
a previous SALP on the steam generator safety valves and steam
admission relief valves for the emergency feedwater pump. Also,
these engineering groups were actively pursuing resolution of the
steam generator fouling problem and strongly supported the refueling
and startup physics test effort.
Licensee review (by internal
memorandum) of the apparent OTSG boil-dry event at Cycle 6 startup
due to water level alignment shif t was very thorough and extensive.
However, licensee documentation of tne reYiew of the early criti-
cality event was fragmented becaus9 it was not consolidated under
<
the T&S review process.
In fact, a number of technical problems
are routinely resolved and then documented by internal memoranda
in lieu of a rigorous use of the T&S process.
Technical review deficiencies continued to be noted in the other
areas, such as design control, drawing control
EQ, and fire pro-
tection areas.
This has resulted in four of ten violations and it
has contributed to one additional violation, two of ten LER's and
several other internally reported events or inspection findings.
Poor work instruction / drawings were contributing factors in the wire
'
eiror problems addressed in the outage functional area.
Despite
substantial licensee attention to the drawing control area, per-
sistent deficiencies raise concern on the attention to detail of
personnel working in this area. Deficiencies in the EQ area are
addressed below and deficiencies in the the fire protection area
are addressed in the fire protection section.
It is apparent that the licensee has not allocated sufficient tina
and effort to correct past deficiencies in the EQ program documen-
.
tation.
Deficiencies in technical EQ documentation are repetitive.
l
Specifically, the EQ files lacked sufficient information necessary
i
to support equipment qualification. These deficiencies led to the
licensee having to perform additional testing of quality materials
i
as a result of an NRC evaluation performed during the period.
Lic-
i
ensee response to the identified deficiencies was prompt and effec-
tive; and, although cognizant licensee personnel were generally
"
knowledgeable of E0 issues, the failure to correct past deficiencies
4
- . _ . -
,
.
,,
_
.
_-
.
.
<(
\\
-
r
41
,
.
persisted. This'ih irdicative of a lack of attention to. detail on
the part of engineering personnel and a weakness in effective cor-
porate ma.1agement oversight of the program.
The shortdomings identified in-this functional area appear to be
due to personnel error relited to por attention to detail and a
lack of effective rupervisory review to compensate for such errors.
-
However, despite these. weaknesses,'both formal and informal com-
munications appear to have improved between engineering support-
~
group and site ope' rations staffs. As noted in the outage area,
installed rnodifications were in essential conformance with design
and regulatu y requirements.
Project status meetings enhanced
j
verbal com wnication in the long-range planning and status area.
Although minoq lapses were noted, the organization appears to be
effective,in translating design requirements into installation and
test actNitieq.
Technical Functions Division oversees the shift technical advisors
(STA's) and plant analysis groups, both corporate and site based.
The STA t.as been functionally integrated into the shift operations
despite a technical riporting chain that is corporate based.
The
STA's routinely trend parameters / prob!ws and are usually very
knowledgeable about plant design and status.
During major manual
mode contro! ev61utions, such as during plant startups/ shutdowns,
the STA provides a supportive role to assure uperator awareness that
the controlling parameter is reaching lin',ts.
The plant analysis
section is also supportive by its periodic reports and active par-
ticipation in the post-trip review process.
Overall, the STA and
analysis personnel have been effectively integrated into plant
operations.
In summary, engineering groups were substanticily challenged with
the two outages during this period.
Overall, these groups were
supportive of operations in resolving certain technical problems.
However, inconsistent performance continued to be noted in the areas
of design and drawing control, fire protection, environmental quali-
fication and safety review.
The licensee's technical approach at
times appeared to be shortsighted in not.considering all factors
in problem resolution.
Site and/or operational feedback on certain
designs was not effective due to schedular pressures. The corporate
,
l
organization appears to be effective in translating design require-
ments into installation and test n tivities despite minor communi-
cation lapses.
Overall, plant analysis support groups were effec-
tive in support of opet r ions. Although the licensee's technical
support reassesstent is incomplete, some signs of improvement were
'
noted.
'
-
. .
_
.
. . .
_-__
. .
. -
.
'
.-s,
.
42
.
2.
Conclusion
Category 2.
3.
Reconmer.dation s
Licensee: Revisit current corrective action plans for the technical
support reassessment to assure that the underlying causes of the
technical review deficiencies in such areas as fire protection,
environmental qualification, and other regulatory-required modifi-
cations are identified for effective resolution.
NRC: None.
l
l
,
t
_ _ _ _ _ -
._
,
.
43
.
K.
Training and Qualification Effectiveness
.
1.
Analysis
During the previous assessment, the licensee's training programs
appeared to be very effective and performance oriented despite
isolated lapses in conservatism with respect to operator performance.
Personnel were knowledgeable of plant design and status.
Poor
engineer training or poor maintenance training in the equipment
qualificatior. (EQ) area appeared to have contributed, in part, to
poor performance in the engineering support and maintenance areas,
respectively.
Licensee management continued to be supportive of
the training programs which appeared to be contributing to overall
safe plant operations.
This assessment is based on the examination of four senior reactor
operator (SRO) license candidates, routine review of operator per-
formance by the resident inspectors, and review of the requalifica-
tion program.
The requalification process was further evaluated
using a trial program in which NRC questions were substituted in
the licensee exam in selected areas.
The training program evalu-
ation by INP0 was completed and fully accredited in December 1986.
The four SRO candidates examined during the period were well pre-
pared for the licensing examination.
The one failure was in the
'
simulator portion of the examination and the individual passed the
retake portion of the examination later in the assessment period.
!
No major weaknesses were identified during this examination.
The
'
initial license training program continued to provide license can-
didates with the E,quisite knowledge and skills to assume licensed
operstor duties.
The requalification program was adequate, but minor weaknesses were
noted.
One of the licensee's requalification examinations contained
a large majority of recall-type questions in lieu of analysis-type
questions. When candidates were re-examined with the substitute
NRC exam, using more analysis-tyoe questions, the results were less
satisfactory. All candidates had satisfactory results on two other
exams that were reviewed.
Also, the oral and simulator examinations
were adetuately conducted.
The scenarios were detailed and key
points for evaluation were identified.
The operations department
and upper management were an integral part of the requalification
evaluation process. However, for both oral and simulator examina-
tions, a currently licensed SRO was examined at an R0 level.
For
the simulator exam, team performance was documented rather than
individual performance.
The licensee took adequate corrective
action to resolve these concerns.
Overall, the requalification
program was judged to be adequately implemented.
.
44
.
The plant specific simulator continued to be an integral part of
the training program for both initial training classes, requalifi-
cation classes, and non-licensed operator training, including
training .for engineers. The basic principles training was also
effectively used.
A tracking system was in effect to follow plant
modifications. The simulator is about two years behind current
modi fication s.
Although the simulator still had some problems to
be resolved, the functional and physical facility was acceptable.
These programs are supplemented by specialized training for new
system modifications involving handout material, classroom session,
and in plant walkthrough. As an example, the training for the HSPS
and remote shutdown panel was substantial and beneficial. Operator
response to HSPS level problems was good and the cooldown from out-
side the control room went smoothly without major performance prob-
lems. All plant modifications have at least a training handout
prepared by operations engineers.
Overall, the licensee uses good
initiatives and communication methods to translate new system or
design change information into training elements.
Operators cont'nued to exhibit detailed knowledge of plant design
and to demonstrate specialized skills for plant transient maneuver-
ing, especially with the integrated contrcl system (ICS) in the
manual mode. Overall, response to events or trips was quite good
despite isolated errors which were distributed over the entire
assessment period.
None of the reactor trips that occurred during
this period could be directly correlated to operator training de-
ficiencies.
Examples were:
(1) not manually tripping the reactor
during one automatic trip; and, (2) lack of awareness on the unique
aspects of controllers for EFW control valves during the May planned
trip. Although additional training was used as corrective action,
in part, for personnel errors, the training program does not seem
to be a source of the problems, especially in the area of procedure
nonadherences (see Assurance of Quality section).
Similarly, a number of other functional areas have quality training
,
programs; such as, radiological control, security, emergency pre-
,
paredness, and maintenance, which recently enhanced EQ training.
However, it appears that, when new programs are initiated, training
plans are not well established.
For example, the licensee under-
estimated the training and/or guidance nee 6d for the new technical
and safety review process. Additionally, a violation could be
attributed to inadequate training on the independent verification
,
requirements for lifted leads on important-to-safety (ITS) systems.
It had, as an underlying cause, poor understanding of safety system
classification and the applicability of the independent verification
program on the part of individuals.
Further, although the licensee
changed the ITS classification to "regulatory required", it is
likely that licensee personnel do not understand the concept which
!
.
,
.
45
.
now has a new label.
It appears that site and corporate management
does not provide sufficient time for thorough review and assessment
of change impact prior to implementation.
The procedure adequacy problems does not appear to be directly re-
lated to poor training. With respect to initial procedure / revision
review, personnel are capable of doing a thorough and comprehensive
review, but poor guidance and schedular pressures seem to adversely
affect performance.
Likewise, with respect to biennial review,
personnel are similarly capable, especially with excellent guidance
for review; but, workload appears to cause errors to be made (see
Assurance of Quality).
- '
Poor performance in specialized areas, such as EQ and fire protec-
tion, appears to be due to lack of time and thoroughness for engi-
neering support review and, to a lesser extent, on personnel under-
standing of applicable design basis cnd/or regulatory requirements.
No direct correlation to training can be made.
In summary, mat,y training programs were considered strengths and
were oriented toward good performance in the interest of nuclear
and radiation safety / safeguards.
Isolated weaknesses were noted,
but the licensee was responsive toward strengthening those areas.
The personnel errors and procedure adequacy problem did not appear
to be directly correlatable to weaknesses in the training area.
It appears that, when new programs are initiated, training plans
are not well formulated.
2.
Conclusion
Category 1.
i
3.
Recommendations
Licensee: Re-evaluate the proportion of recall-type versus analysis-
type questions used in licensed operator requalification exams.
NRC: None
l
l
!
l
,
l
!
!
.
-
.
_ _ _ _ _ _ -
_ _ _ _ _ _
_
.
46
.
L.
Assurance of Quality
1.
Analysis
The previous assessment noted that individual procedural step in-
adequacies and procedural nonadherences did not adversely affect
safety, but they continued to be too numerous and too significant
to be considered isolated cases.
These problems were due to per-
sonnel error or inattention to detail and due, in part, to middle
management efforts to excel and meet schedules. The technical and
safety (T&S) review program had weak guidance and, in certain in-
stances, poor implementation. Also, the program was changed in that
requirements were relaxed making it questionable that the program
met applicable requirements'for procedure changes.
In certain in-
stances, corrective actions were weak and/or excessively delayed.
.
Collegial review and other licensee initiatives were apparently
needed to compensate for the above-noted weaknesses.
The prior SALP
board provided two recommendations: (1) continue efforts in correc-
tion of the procedure adherence and procedure adequacy problems;
and, (2) independently meet with NRC staff on the T&S review program
and Procedure Compliance Task Group (PCTG).
In general, worker attitudes are oriented toward nuclear safety as
a result of licensee training, but they falter at times during im-
plementation. The board's review of events identified that the
underlying causes for the majority of events due to personnel error
are varied.
They are: (1) failure to follow procedures due to a
cognitive error or due to failing to properly change the procedure
when needed; (2) inattention to detail such as failure to verify
correct action; and, (3) attempted implementation of an administra-
tive control (procedure) or controlling procedure from memory.
The
leading cause of personnel error is procedure nonadherence.
The
long-term actions of the PCTG involving programmatic changes con-
tinued to be worked on by the licensee and these will be extended
into the next SALP period.
Inspections noted skeptical improvements
in this area, such as with licensee performance during transition
into and out of the letdown cooler outage.
However, problems per-
sisted as manifested by the QA and NRC inspection findings. Many
of the causes may be related solely to individual worker poor at-
titudes, but there are signs that first-line supervision and, per-
haps, middle management has not done enough to instill a sense of
quality in individual worker attitudes.
Supervisory failures at
this level may be negative attitudes or inaction to reverse negative
trends. Apparently, the licensee has recognized this problem and
they have initiated an INP0 sponsored program for self-evaluation
in the area of personnel error.
e - -_-_
_
__
.
47
_.
Further, impromptu decisions to_ side-step procedure step 'inadequa-
t
cies or non-applicability without formal review of procedure changes
L
(the graded approach) contributes'to the procedure nonadherence
problem.
There is evidence that licensee upper management uninten-
tionally condones this apparent middle management policy as evi-
denced by the' licensee's response to a failure to follow an alarm
response procedure violation, which was identified in the last SALP
period.
This managerial attitude has not,' as yet, created a safety
problem.
Similarly, individual procedural step inadequacies continued to be
noted and are not totally correlatable to poor worker attitudes.
Since 1979, the facility procedures have been through at least three
biennial reviews; yet, significant discrepancies or inconsistencies
continue to be noted, especially with procedures that are routinely
used.
It is clear that: (1) personnel performance to take the in-
itiative to change or improve procedures is not at as high a level
as it should be; (2) despite an up-to-date biennial review status,
the quality of such reviws (possibly because of the required two-
year schedule) is lacking contrary.to the detailed administrative
controls for such reviews; and, (3) technical reviews on new proce-
dures/ procedure changes are not as thorough as they should be in
assuring other facility procedures do not become outdated by the
apparent isolated action of a new procedure or a procedure revision.
Here, again, there are signs that first-line supervision and middle
management were responsible for poor results.
The daily activities
and production schedules appeared to be easy distractions from the
seemingly unproductive attention to the long lasting quality of
procedures that can be effectively implemented.
The outage and engineering support functional areas reflect a well
established modification control program. A high level of perform-
ance, overall, is achieved in this area because of: (1) good outage
planning at all managerial levels; (2) good middle level management
of personnel for special evolutions, tests, or situations; (3) en-
hancement of formal and informal communications between site and
corporate groups; and (4) utilization of upper management initi-
atives to assure overall control of the outage and system readiness
for startup, as in the use of startup prerequisite lists.
The re-
'
cent corporate reorganization should also enhance this area. How-
ever, poor direction and control by first-line supervisors and
middle management resulted in: (1) significant errors that have
occurred during outage work and (2) poor communications in the ven-
dor interface area.
Further, there were signs that upper management
was inattentive to the adequacy of design to practically and real-
i
istically support operations in performing their complex duties
i
along with meeting safety requirements.
l
l
!
l
_
t
48
.-
The NRC staff issued a violation on the failure to properly document
T&S reviews in accordance with 10 CFR 50.59 requirements.
Licensee
response to the violation indicated their failure to fully under-
stand the staff's position on the matter with respect to revising
important-to-safety (ITS) procedures.
The relatively good perform-
ance for SE's in the facility modification area is due, in part,
to both steps in the licensee's two-step process (safety determina-
tion (SD) and safety evaluation (SE)) being used. That same level
of consistent performance does not occur for changes to ITS proce-
dures because only the SD, in general, would be used.
Inspections
also noted several instances of unclear guidance in the T&S corpor-
ate procedure, which the licensee is attempting to resolve. The
new process was adapted from an industry methodology that was unre-
viewed and unapproved by NRC staff, as yet.
A higher level of performance was noted by the TMI-1 Division which,
in general, still uses the 50 and SE for ITS procedure changes until
the apparent impasse with NRC staff is resolved. However, site
forms provide little room for narrative justification, which, gene-
,
rally, are squeezed in a corner of the form, giving an unprofes-
sional appearance. Other examples were noted which indicated that
the unified T&S review concept is not well understood, nor is it
rigorously implemented (see Engineering Support Section). Also,
the licensee reorganized in June 1987 without using this process
to justify whether or not a technical specification change was
needed.
The licensee acknowledged that better training could have
occurred before implementation of the new T&S process. However,
it appears that the root cause of poor performance in this area was
due to program weaknesses created by the change in methodology.
The three levels of QA continue to be rigorously implemented (con-
trol, monitoring, and audits).
The control and monitoring functions
have been implemented on a twenty-four hour basis in support of
outage or operations work.
The Quality Deficiency Reporting (QOR)
system appears to be an effective tool to gauge performance, such
as for the procedure adherence and adequacy problems. Audits con-
tinued to be thorough and extensive using innovative ideas and
techniques. The "escalation of issues" procedures was enhanced,
but its effectiveness remains to be determined.
There is a substantial upper management involvement in site and
licensing activities, both at the corporate and site managerial
levels. The daily planning meetings usually have representatives
from the various corporate-based organizations assigned to the site
in addition to intra-division departments at TMI-1. This contri-
butes to good communications, especially as noted during post-outage
i
startups.
In particular, back shift tours reflect management's
'
involvement, such as its use when the TMI-2 sleeping operator alle-
gation arose. Also, this level of management rigorously uses the
prerequisite list for outage startups as documentation to complement
'
.
L
.
_
_
. .__
_ . - - _ - _
__ _
.
..
_ . , -
.
a
49
6
verbal communications on a daily basis.
It was noted that this
initiative may be overemphasized since a number of refueling job
ticket packages were still "administratively open" well after the
refueling outage was over.
The other performance elements noted
herein also reflect upper management's involvement to control acti-
vities and to take appropriate corrective action for problems as
they arise. However, the poor performance problems noted above also
indicate that the effectiveness of management's involvement remains
to be realized.
There are signs that performance problems that have plagued the EQ
area have crept into the fire protection area.
Substantial manage-
ment attention appears to be lacking in the fire protection area.
Oversight personnel and/or groups continue to implement regulatory
requirements and/or implement licensee initiatives.
The T&S process
was separately addressed above. Most notable licensee initiatives
are: Plant Review Group; General Office Review Board; and, Board
of Director, Nuclear Safety and Compliance Committee.
Their reviews,
along with regulatory-required reviews continue to be effective in
problem identification, especially in light of the available exper-
tise and they do generate upper management involvement on these
problems.
However, in light of persistent performance problems
noted herein, there appears to be weak attentiveness by upper man-
l
agement to selected facets of operation; in particular, problem
solving.
,
In summary, performance has been good but longstanding performance
problems persist in the areas of procedure adequacy and implementa-
.
tion, engineerirg support, or technical and safety review while
'
licensee middle and upper management continues to work on resolving
these problems. These problems are not solely correlatable to poor
worker attitudes, but there are signs that first-line supervisors
and middle management continue to negatively affect performance in
this area by not reversing negative trends. Middle and upper cor-
porate/ site management involvement is substantial; but, at times,
attentiveness and/or attitude toward problems appears to be weak.
Regulatory-required and licensee-initiative reviews collectively
appear to be effective in problem identification, but the effective-
ness of upper management's involvement in specific problem solving
remains to be realized, such as for the procedure nonadherence
[
,
problem. Although being assessed by the licensee, personnel errors
may be related to poor management attitudes or weak programs in
t
addition to the poor quality of individual performance.
,
<
,
,
,
- - . , - . - . . . - . - , - . -
e.
---
- . , , - - ,
.,
, . , _ . . .
.
50
6
2.
Conclusion
Category 2.
3.
Recommendations
None.
_ _ _
..
.
-
.- - - .
__
.-
51
e
VI. SUPPORTING DATA AND SUMMARIES
,
A.
Investigations and Allegations Review
There are no open investigations for TMI-1. An ongoing investigation
concerning operator sleeping at TMI-2 is still being pursued, but the
implications at TMI-1 were evaluated and the issue closed (NRC Inspection
Report No. 50-289/87-13).
An allegation concerning the qualifications of signal persons for the
reactor building crane was reviewed and not substantiated during this
SALP period (see NRC Inspection Report No. 50-289/87-19). An allegation
dealing with reactor fuel "candling" effect was also unsubstantiated and
closed during this period.
'
B.
Escalated Enforcement Actions
There were no escalated enforcement actions,
a
C.
Licensee Meetings Held During Appraisal Period
The following management meetings were held:
.
--
On December 4, 1986, an enforcement conference with Region I to
discuss the findings of an investigation concerning deficiencies
-
identified in the environmental qualification (EQ) program previous
to this SALP period.
On February 12, 1987, a management meeting with Region I to discuss
--
the implementation of the licensee's new technical and safety review
process. Also, the results of the licensee's task force designed
to resolve procedure adherence were reviewed.
On February 24, 1987, the last SALP period management meeting was
--
conducted.
'
On March 10, 1987, a management meeting with Region I to discuss
--
'
,
the EQ inspection team findings.
!
On July 13, 1987, a management meeting with Region I to discuss the
--
implications of the TMI-2 sleeping allegation on TMI-1 (see also
NRC Inspection Report No. 50-289/87-13).
On September 10, 1987, a management meeting with Region I to discuss
--
licensee methodology and resolution of logs error analysis in the
EQ area.
,
l
4
i
b
i
_
_
_
, _ _ - . _ , _ _ . .
_ - - - - -
. _ - -
- - - -
- -
-
52
6
The following licensing meetings were held with the licensee during the
period:
4
On November 13, 1986 to discuss Appendix R issues.
--
On December 1, 1986 to discuss steam generator tubes plugging cri-
--
teria.
--
On December 3, 1986 to discuss SALP II Board meeting.
On February 5, 1987 to discuss an Appendix R exemption requests.
--
--
On May 21, 1987 to discuss steam generator tube tests.
On July 16, 1987 to meet new management and discuss reorganization.
--
.
On August 24, 1987 to discuss radiological effluent treatment sys-
--
tems.
On September 9, 1987 to. discuss Safety Issues Management System
2
--
(SIMS).
On September 10, 1987 to discuss Appendix R.
--
'
D.
licensee Event Reports and Other Events
'
,
The last SALP period (six months) had five LER's of which two were due
to personnel error.
For this one year period, eight of ten Licensee
Event Reports (LER's) (Table 4) were due to personnel error and procedure
,
deficiencies.
No conclusion can be drawn by this. However, for this
period, inspectors reviewed a non-duplicate event listing involving
,
violations (Table 3), LER's (Table 4) and other licensee internal plant
i
incident reports (five events).
The number of these events were rela-
tively small; but, again, a substantial majority are due to human ele-
ments of personnel error and/or procedure deficiencies. Of the subset,
,
many were attributed by the licensee to be personnel error, but further
'
review of corrective action revealed that, in addition to personnel
,
'
counseling, corrective actions were oriented toward procedure enhance-
ments.
In fact, some of these events could have had their roots in
procedure deficiencies.
The majority of the personnel errors are directly correlated to failure
I
to follow procedures.
Personnel error, along with the six procedure
adherence and adequacy problems, is addressed in assurance of quality
section.
,
i
i
_.
.
__.
,
,
..
- . -
-- . - _ - _ _ _ - - . . , _ - _ _ _ ,
. . - . . .
1
.
53
o
E.
Licensing Activities
1.
Reliefs Granted
IST 2nd 10-Year Interval - 3/19/87
ASME Code 1, 2, 3 - 3/20/87
2.
Exemptions Granted
Section III.G.2, 3 and J of Appendix R - 12/30/86
Section III.G 2, of Appendix R - 3/19/87
3.
Licensee Amendments Issued
. Amendment
Title
Date
122
ESF Filtration System
12/12/86
123
Testing Silcon Controlled Rectifiers
12/16/86
124
EFW System
3/9/87
125
3/9/87
126
Cycle 6 Reload
3/20/87
127
Fire Detection System
3/31/87
128
Organizational Titles and Operator License
5/13/87
for Shift Personnel
129
Reporting Requirements
5/14/87
130
New Condenser Vent Stack Iodine Sampler
6/8/87
131
Organizational Reporting Structure for
8/14/87
Radiological and Environmental Department
132
Functional Responsibilities in GPUN
9/1/87
Corporate Organization
133
Main Steam Safety Valves Minimum of Two
10/15/87
.
6
TABLE 1
INSPECTION REPORT ACTIVITIES
REPORT /
INSPECTOR /
DATES
TYPE
HOURS
AREAS INSPECTED
86-20
SPECIALIST /
89
ANNUAL EMERGENCY PREPAREDNESS EXERCISE
11/4-6/86
RESIDENT
86-21
RESIDENT /
498
REVIEW 0F POWER (PWR) AND COLD SHUTDOWN
10/31-12/5/86 SPECIALIST
(50) OPERATIONS (OPS), RELATED RADIOLOGICAL
CONTROLS, OUTAGE STARTUP ACTIVITIES, OUTAGE
SURVEILLANCE (SUR), COLD WEATHER PREPARA-
TIONS, FIRE PROTECTION
86-22
RESIDENT /
270
REVIEW 0F OUTAGE ACTIVITIES INCLUDING
12/5/86-1/9/87 SPECIALIST
REFUELING PREPS, ISI WORK, AND PWR OPS
CHEMISTRY CONTROL, MODIFICATIONS REVIEW
86-23
SPECIALIST
172
10 CFR 50 APPENDIX R, FIRE PROTECTION
12/15-19/86
REVIEW
86-24
SPECIALIST
6
ENFORCEMENT CONFERENCE ON PAST ENVIRON-
12/4/86
MENTAL QUALIFICATION (EQ) ISSUES
87-01
SPECIALIST
302
EQ QUALIFICATION PROGRAM REVIEW
1/12-21/87
87-02
RESIDENT /
243
REVIEW 0F OUTAGE ACTIVITIES, DIESEL GENE-
1/9-2/6/87
SPECIALIST
RATOR REPAIR, MODIFICATIONS FOR STARTUP,
SUR PROGRAM
87-03
SPECIALIST
- 266
FOUR SRO EXAMINATIONS - THREE OF FOUR
3/2-6/87
PASSED
87-04
RESIDENT
4
MANAGEMENT MEETING ON LICENSEE'S NEW TECH-
2/12-18/87
NICAL AND SAFETY REVIEW PROCESS AND PROCE-
DURE IMPLEMENTATION ISSUES
87-05
RESIDENT
169
OUTAGE ACTIVITIES, ELECTRICAL EVENTS, FIRE
2/6-3/6/87
PROTECTION UPGRADES, DIESEL GENERATOR
REPAIR / TESTING
87-06
RESIDENT /
459
SPECIAL INSPECTION TO ASSESS LICENSEE
2/17-3/3/87
SPECIALIST
READINESS FOR CYCLE 6 STARTUP
87-07
SPECIALIST
- 160
REQUALIFICATION PROGRAM REVIEW AND OPERATOR
2/20-3/12/87
LICENSING REQUAL EXAMINATIONS
l
T-1-1
.
.
-
,
-
.w
Table 1
.
REPORT /
INSPECTOR /
DATES
TYPE
HOURS
AREAS INSPECTED
87-08
RESIDENT
13
REVIEW 0F PERFORMANCE APPRAISAL TEAM (PAT)
5/13-6/16/87
II FINDINGS PRIMARILY IN THE AREA 0F TECH-
NICAL AND SAFETY REVIEW - OTHER PROCEDURE
CONTROL ISSUES
87-09
RESIDENT /
800
TRANSITION FROM COLD SHUTDOWN TO PWR OPS,
3/6-4/24/87
SPECIALIST
STARTUP READINESS, EQUIPMENT PROBLEMS,
STARTUP TESTING, SURVEILLANCES, REPORTS
87-10
RESIDENT
248
ROUTINE PWR OPS - OPERABILITY REVIEWS,
4/24-5/29/87
REACTOR PHYSICS DATA, MODIFICATIONS, SAFETY
VALVE REPAIR, REACTOR TRIPS, VENDOR INTER-
-
FACE, PAST FINDINGS
87-11
RESIDENT
210
ROUTINE PWR OPS, REACTOR TRIP AND OTHER
5/29-7/9/87
EVENTS, EQUIPMENT OPERABILITY, FIRE PRO-
TECTION PROGRAM IMPLEMENTATION
87-12
SPECIALIST
- 58
OPERATOR LICENSING EXAMINATION - 1/1 SRO
6/29/87
PASSED
87-13
RESIDENT /
253
ROUTINE PWR OPS AND OPERABILITY REVIEW,
7/9-9/4/87
SPECIALIST
TMI-2 SLEEPING ALLEGATION, MAINTENANCE (MNT)
PROGRAM, RCITS MOD, SALP RESPONSE, AND
OUTSTANDING ITEMS (01) FOLLOW-UP
87-14
SPECIALIST
84
ANNUAL EMERGENCY PREPAREDNESS PROGRAM AND
7/20-24 -
IMPLEMENTATION REVIEW ALONG WITH OI FOL-
8/12-13/87
LOWUP
87-15
SPECIALIST
102
SECURITY PROGRAM AND IMPLEMENTATION
.'
8/10-14/87
87-16
SPECIALIST /
200
ANNUAL EMERGENCY PREPAREDNESS EXERCISE
10/23/87
RESIDENT
10/20/87
87-17
RESIDENT
142
ROUTINE PWR OPS, OPERABILITY REVIEW, DIESEL
9/4-10/2/87
CONTROL LOGIC, REACTOR TRIP, PLANT STARTUP,
RAD MONITOR OPERABILITY, LER'S (LICENSEE
EVENT REPORTS)
87-18
SPECIALIST
50
CALIBRATION PROGRAM AND FOLLOWUP TO OI'S
9/14-25/87
T-1-2
,
.
_
. ..
. - - .
.
Table 1
O
REPORT /
INSPECTOR /
DATES
TYPE
HOURS
AREAS INSPECTED
87-19
RESIDENT
160
ROUTINE PWR OPS, MNT, SUR, INOPERABLE
10/2-31/87
DIESELS, INDEPENDENT VERIFICATION, CONTROL
ROOM ENVIRONMENT, STORAGE OF TRANSIENT
EQUIPMENT, CORPORATE INSPECTION, ALLEGA-
TION 01, TECHNICAL & SAFETY REVIEW
87-20
SPECIALIST
8
CALIBRATION PROGRAM AND OI FOLLOWUP
9/14-24/87
<
- Includes licensed operator examination preparation and documentation time in
addition to actual examination time.
T-1-3
_
_ _ _ _ _ _ _ _ _ _ _ _
.
e
TABLE 2
INSPECTION HOURS SUMMARY
ACTUAL
PERCENT
1.
PLANT OPERATIONS
1433
29
2.
RADIOLOGICAL CONTR0'_S
246
5
3.
MAINTENANCE
424
9
4.
SURVEILLANCE
465
9
5.
FIRE PROTECTION
440
9
6.
373
7
1
7.
SECURITY AND SAFEGUARDS
194
4
8.
OUTAGES
419
8
9.
LICENSING ACTIVITIES
N/A
N/A
10.
ENGINEERING SUPPORT
972
20
11.
TRAINING AND QUALIFICATION
N/A
N/A
-
EFFECTIVENESS
12. ASSURANCE OF QUALITY
N/A
N/A
TOTALS
4966
100
i
T-2-1
_ _ _ _ _ _ _ _
s
%
TABLE 3
ENFORCEMENT SUMMARY
A.
Violations Versus Functional Area by Severity Level
SEVFRITY LEVEL
FUNCTIONAL AREA
V
IV
III
II
I
TOTAL
PLANT OPERATIONS
0
RADIOLOGICAL CONTROLS
1
1
MAINTENANCE
1
1
SURVEILLANCE
1
1
FIRE PROTECTION
1
1
1
1
SECURITY /SAFEGUAROS
0
OUTAGES
1
1
LICENSING ACTIVITY
0
ENGINEERING SUPPORT
3
3
T&Q EFFECTIVENESS
0
QUALITY ASSURANCE
1
1
_
_
_
_
_
TOTALS
1
9
0
0
0
10
T-3-1
l
, ------__ _ ---.
h
/
Table 3
e
.
B.
Violation Summary
INSPECTION
SEVERITY FUNCTIONAL
REPORT /DATE
REQUIREMENT
LEVEL
AREA
BRIEF DESCRIPTION
289/86-23
5
FIRE PROT./ FAILURE TO INSTALL EMERGENCY
APP R SEC.III
ENG. SUPP.
LIGHTS IN THE CONTROL ROOM
289/86-24
4
ENG. SUPP.
FAILURE TO TAKE TIMELY AND ADE-
APP B
QUATE CORRECTIVE ACTION ON
CRIT. XVI
ENVIRONMENTAL QUALIFICATION (EQ)
PROGRAM DEFICIENCIES
289/87-01
4
0UTAGE/ENG.
FAILURE TO FOLLOW VENDOR IN-
APP B
SUPP.
STRUCTIONS FOR SEISMIC MOUNTING
CRIT. V
0F RCS PRESSURE INSTRUMENTATION
289/87-06
4
ENG. SUPP.
FAILURE TO DESIGN REVIEW AND
APP B
APPROVE AN HSPS CALCULATION BY
CRIT. III
VEND 0R
289/87-06
4
SURVEILLANCE FAILURE TO PROPERLY FOLLOW CALI-
BRATION PROCEDURE FOR REACTOR
BUILDING PRESSURE INSTRUMENTATION
,
,
289/87-08
4
ASSURANCE OF FAILURE TO PROPERLY 00CUMENT
QUALITY
SAFETY REVIEWS
289/87-09
4
RAD-CHEM
FAILURE TO SURVEY FOR WORK IN
(B)
LETDOWN PREFILTER CUBICLE
r
289/87-09
4
ENG. SUPP.
FAILURE TO ADEQUATELY DESIGN
APP B
REVIEW PRESSURIZER INSULATION
CRIT. III
SUPPORT PLATFORM
,
!
289/87-14
4
EMERG. PREP. FAILURE TO PROPERLY CLASSIFY AND
APP E
AND SEND TO NRC AN EMERGENCY
'
ITEM 5
PLAN IMPLEMENTING PROCEDURE
289/87-19
5
MAINTENANCE FAILURE TO FOLLOW PROCEDURE ON
LIFTED LEAD AND INDEPENDENT
t
VERIFICATION
T-3-2
i
P'
,
1
-
-
\\
c
TABLE 4
LICENSEE EVENT REPORTS
A.
LER By Functional Area
NUMBER BY CAUSE CODE
FUNCTIONAL AREA
A
B
C
D
E
TOTAL
PLANT OPERATIONS
3
1
4
RADIOLOGICAL CONTROLS
0
MAINTENANCE
0
SURVEILLANCE
2
1
3
FIRE PROTECTION
0
O
SECURITY AND SAFEGUARDS
0
OUTAGES
1*
1*
1*
3
'
LICENSING ACTIVITIES
0
ENGINEERING SUPPORT
0
TRAINING AND QUALIFICATION
0
EFFECTIVENESS
ASSURANCE OF QUALITY
0
_
_
_
6
1
0
2
1
10
- Involves other functional areas, but event occurred during outage activities.
Cause Codes
A - Personnel Error
8 - Design, Manufacture, Fabrication
C - External
D - Procedure Inadequacy
E - Component Failure / Malfunction
T-4-1
\\
'
e
- .'
Table 4-
3
B.
LER SYNOPSIS
FUNCTIONAL
CAUSE
LER NUMBER
SUMMARY
AREA
CODE
86-13
REACTOR BUILDING LEAK TEST FAILED DUE
SURVEILLANCE /
0
TO PENETRATION PRESSURE VALVE LEAKAGE
ENG. SUPPORT
NOT DETECTED DURING PREVIOUS LOCAL
I
LEAK RATE TESTS
87-01
AUTO START OF A DIESEL DUE TO DEFEC-
OUTAGE (MODIFI- D
TIVE WORK INSTRUCTION
ICATION)/ENG.
SUPPORT
87-02
DIESEL GENERATOR AUTO START DURING
OUTAGE
B
l
ADJUSTMENT OF RELAY COVER DUE TO IM-
(MAINTENANCE)
PROPERLY "0RESSE0" WIRING WHICH DID NOT
ALLOW FOR COMPLETE FIT OF RELAY COVER
87-03
FIRE BARRIER PENETRATION SEAL NOT IN-
OUTAGE (FIRE
A
[
STALLED DUE TO ENGINEERING SUPPORT PER- PROTECTION -
'
SONNEL OVERSIGHT
SURVEILLANCE)
87-04
REACTOR TRIP ON HIGH PRESSURE DUE TO
SURVEILLANCE
A
OPERATOR FAILURE TO VERIFY ACTION
DURING HEAT BALANCE SURVEILLANCE
87-05
MISSED SAMPLE PRIOR TO INDUSTRIAL WASTE OPERATIONS
A
FILTERING SYSTEM RELEASE DUE TO FAILURE
TO FOLLOW PROCEDURES
87-06
REACTOR TRIP ON HIGH RCS PRESSURE DUE
OPERATIONS
A
TO OPERATOR ERROR ON MANUAL FEE 0 WATER
CONTROL OURING LOW POWER OPERATIONS
87-07
INADVERTENT REACTOR PROTECTION SYSTEM
OPERATIONS
A
ACTUATION DUE TO COGNITIVE ERROR IN
PERSONNEL NOT READING THE MOST CON-
SERVATIVE PRESSURE INSTRUMENT WHEN
COMING OUT OF SHUTDOWN BYPASS
87-08
REACTOR TRIP FROM TURBINE TRIP DUE TO
OPERATIONS
E
EQUIPMENT MALFUNCTION IN A MOISTURE
SEPARATOR LEVEL CONTROL VALVE
87-09
EFFLUENT RADIATION MONITOR INTERLOCK
SURVEILLANCE
A
DEFEATED OURING RELEASE DUE TO FAILING
TO FOLLOW PROCEDURES
T-4-2
i