ML20151K590
| ML20151K590 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 12/12/1984 |
| From: | Congel F Office of Nuclear Reactor Regulation |
| To: | Muller D Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20151G994 | List: |
| References | |
| NUDOCS 8501070426 | |
| Download: ML20151K590 (9) | |
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9,, UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION B rj wAsmNGTON, D C.20555
\*****/ DEC 121984 MEMORANDUM FOR . Daniel R. Muller, Assistant Director for Radiation Protection, DSI .
FROM: Frank J. Congel, Chief
. Radiological Assessment Branch, DSI
SUBJECT:
LWR OCCUPATIONAL DOSE DATA FOR 1983 Attached is a compilation and analysis of occupational radiation doses reportedfrom75lightwatermoderatednuclearreactors(LWRs)forthe year 1983. The infonnation in this memorandum was derived from reperts submitted to the 'Comission in accordance with 10 CFR Part 20.407. Only onepressurizedwaterreactor(PWR),Sequoyah2,completeditsfirstfull year of comercial operation in 1983 and is included in this year's sum-mary for the first time (indicated in Table 1 by an 'N)). In addition, this sumary includes four units (Dresden 1, Humboldt Bay, Indian Point 1, and Three Mile Island 2) that are currently shutdown for an indefinite period of time. These units have been retained in this sumary since they are still licensed and dose is still accumulated to maintain them.
The total collective dose for all LWRs in 1983 was 56,471 person-rems.
This number is eight percent higher than the 1982 total of 52,190 person-rems,andisthehighestannualLWRtotaldosetodate(theprevious high total was 54,142 person-rems in 1981). The average dose per unit for LWRs in 1983 was 753 person-rems per unit, well above the 1982 average of 705 person-rems per unit, but still below the highest recorded averege of 791 person-rems per unit in 1980. The increash in the average dose per unit in 1983 ends a two year decline of this value for LWRs.
In 1983 the average dose for PWR units was 592 person-rems, a two percent increase from the 1982 average of 578 person-rems. The number of PWRs in this year's compilatio: increased from 48 to 49. The average boiling water reactor (BWR) dose of 1,056 person-rems per unit in 1983 was 12 percent
' higher than the 1982 BWR average of 940 person-rems. The number of BWRs remained the same in 1983 at 26 units. The attached exposure compilation table (Table 1) presents a breakdown of the person-rems received at each of the LWRs which had completed at least one full year of comercial operation by the end of 1983. The exposure figures listed in Table I were derived from data submitted by the licensees in response to the require-ments of 10 CFR Part 20.407 and plant technical specifications (the plant technical specifications require that only personnel receiving greater than 100 are be listed--these data are shown in parentheses in Table 1). The i
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D. Muller -i. DEC 121984 figures quoted above and used in the attached figures are from the 10 CFR Part 20.407 data.-
Figure 1 shows the total average yearly person-rem figures for BWRs, PWRs, and LWRs for the years 1969-1983. For the tenth consecutive year, the everage exposure for BWRs has remained higher than the average yearly PWR exposure. Figure 2 shows the total number of operating reactors and the total collective LWR dose per year plotted for the years 1969-1983.
Figure 3 provides a graphic comparison of the annual occupational exposure per unit, for each BWR, for the three year period from 1981 to 1983. Four BWR units--Brunswick I and II, Oyster Creek, and Vermont Yankee--had doses which exceeded 1500 person-rems in 1983. Although these four units repre-sented only 15 percent of the BWRs operating in 1983, they contributed over one fourth (7259 person-rems) of the total BWR exposure in 1983.
Major maintenance jobs which were large contributors to BWR doses in 1983 included inspection and repair of primary piping and pipe welds,and Mark I torus modifications.
Figures 4a and 4b provide a crmparison of occupational exposures per unit for PWRs for the three year turiod from 1981-1983. In 1983, seven PWR units--Haddam Neck, Millstone Pt. II, Surry I and II, St. Lucie I, and Turkey Pt. III and IV--all had doses which exceeded 1200 person-rems.
These seven units, while comprising only 14 percent of the PWRs operating in 1983, contributed over 35 percent (10370 person-rems) of the total PWR exposure in 1983. Steam generator maintenance and repair continued to be a major source of personnel exposure at PWRs in 1983. Another major l source of exposures at PWRs was maintenance on reactor vessel internals, l such as core barrel and core thermal shield repair, and feedwater nozzle l replacement.
This infomation was compiled by C. Hinson, RPS/RAB.
Frank J. Co el, Chie Radiological Assessment Branch Division of Systems Integration Enclosure As Stated cc: See next page.
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Docket No. 50-219 JUL 2 01983 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 Forked River, New Jersey 08731 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP) Report and.your letter dated June 17, 1983 This refers to the SALP for the Oyster Creek Nuclear Generating Station conducted by this office on April 19, 1983 and discussed with your staff at a meeting on May 12, 1983. A list of attendees at the meeting is presented in Enclosure 1. The NRC Region I SALP Report is attached as Enclosure 2. Tnis report evaluates the l4 i
period February 1, 1982 through January 31, 1983 and any significant findings from the three iaonth gap from the previous assessment period. Our letter dated April 29, 1983 which forwarded the SALP Report, and your letter dated June 17, 1983, which provides your actions and coments regarding the SALP Report, are attached d as Enclosures 3 and 4.
Overall, your perfonnance in the operation of the facility was found acceptable.
During the meeting of May 12, 1983, we discussed our assessment of your regulatory perfonnance in each of nine functional areas. Some of your coments at the meet-ing and in your June 17, 1983 letter address improvements in the backlog of items needing Plant Operations Review Comittee attention, fonnalization of administra-tive procedures governing interfaces between divisions, improvements in the radio-chemistry program, steps to improve quality of work and knowledge of maintenance department personnel, and improvement in procedures and administrative control of the integrated leak rate test. We believe your actions to be responsive and will improve future perfonnance.
With regard to the statement in your June 17, 1983 letter .'hich points out a de-sign error as opposed to procedural inadequacies during the integrated leak rate test caused radioactive contamination of a portion of the reactor building service air system, we agree and have modified our report to correct the error.
In addition, as noted at the meeting, we concur that deficiencies in your radio-chemistry program were identified in two functional areas of the report. To cor-rect this we have amended Pages 7, 8, and 10 of our report. The emended pages are inserted preceding the original pages of the report.
In accordance with 10 CFR 2.790(a), a copy of this letter and its enclnsures sill be placed in the NRC Public Document Room, n,si n r o '
- u np t MffWl
. GPU Nuclear Corporation 2 JUL 2 0 G33 No reply to this letter is required.
Your actions in response to the NRC System-atic tions.Assessment of Licentee Performance will be reviewed during future NRC insp We believe that our May 12, 1983 meeting was beneficial and improved mutual under standing of your activities and our regulatory program.
is appreciated. Your cooperation with us Sincerely,
/W .
Thomas E. Murley ~
Regional Administrator
Enclosures:
- 1. SALP Management Meeting Attendees
- 2. -
NRC Region I SALP, GPU Nuclear Corporation Oyster Creek Nuclear Generating Station 3.
- 4. NRC Letter, R. W. Starostecki to P. B. Fiedler dated April 29, 1983 GPU Nuclear CtJrporation Response Letter, P. B. Fiedler to R. W.
Starostecki dated June 17, 1983 cc w/encls:
M. Laggart, Licenting Supervisor J. Knubel, BWR Licensing Manager Public Document Room (PDR) local Pubc Cocument Room (LPDR)
Nuclear Safety Infonnation Center (NSIC)
NRC Resident Inspector St ..te of New Jersey bec w/encis:
R;gion I Docket Room (with concurrences) '
Senior Operations Officer (w/o encis)
DPRP Section Chief i K. Abraham (2 copies) l i
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ENCLOSURE 1 U.S. NUCLEAR REGULATORY COMMISSION SALP MANAGEMENT MEETING ATTENDEES Licensee: GPU Nuclear Corporation Facility: Oyster Creek Nuclear Generating Station Meeting At: Forked River, New Jersey Meeting Conducted: May 12, 1983 Licensee Attendees M. Budaj, Manager, Plans and Programs J. T. Carroll, Director, Startup and Test P. k. Clark, Executive Vice President, GPU Nuclear Corp.
R. D. Fenton, Oyster Creek Emergency Preparedness Manager '
P. Fiedler, Vice President and Director, Oyster Creek E. J. Growney, Safety Review Manager R. W. Heward, Vice President - Radiolo ical and Environmental Control D. Klucsik Manager, Comunication Service, Oyster Creek' J. Knubel, Manager, BWR Licensing M. Laggart, Oyster Creek Licensing Manager R. L. Long, Vice President, Nuclear Assurance
- J. P. Maloney, Manager, Plant Material F. F. Manganaro, Vice President and Director, Maintenance and Construction R. S. Markowski, QA Oyster Creek Audit Manager F. J. Maughan, Plant Security Supervisor, Oyster Creek W. J. Smith, Plant Engineering Director J. L. Sullivan, Plant Operations Director J. R. Thorpe, Director, Licensing and Regulatory Affairs C. R. Tracy, Manager, Oyster Creek QA M00/0PS D. W. Turner, Manager, Radiological Controls NRC Attendees R. R. Bellamy, Chief, Radiological Protection Branch, Division of Engineering and Technical Programs E. L. Conner, Chief, Reactor Projects Section 38 DPRP C. J. Cowgill, Senior Resident Inspector, Oyster Creek D. Crutchfield, Chief, Operating Reactors Branch #5, Division of Licensing, NRR R. R. Keimig, Chief, Projects Brsnch f3, Division of Project and Resident Programs J. J. Lombardo, Licensing Project Manager, Operating Reactors Branch #5, Division of Licensing, NRR R. W. Starostecki, Director,' Division of Project and Resident Programs (DPRP)
L E. Tripp, Chief, Reactor Projects Section 3A, DPRP d
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Enclosure 2 i
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<l U.S. NUCLEAR REGut.ATORY COMMISSION I
REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE GPU NUCLEAR CORPCRATION OYSTER CREEK NUCLEAR GENERATING STATION APRIL 19, 1983 e*
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- i INTRODUCTION
- ~
- a. Purpose and Oy w /few p i /
i The Systematic Assessment of Licer.sa ?arformance (SALP) is an integrated NRC staff effort to ecileet the available observations on an annual bast observations w'3 and evaluate licehsed performance based on those f th the objectives of haphoving the NRC Regulatory Program and licensee performance.
The asseument period is February 1,19,82 through January 31, 1983.
This ass,essment., however, contains pertinent observations and NRC and iteensee activities through February 1983.
The prior 15 ALP assessment period was November 1,1980 - October 31, 1981. Sibnf ficant findings of this assessment and the period between the previous assessment and this assessment are provided it, the apriicable Performance Analysis Functional Areas (Section IV).
Evaluation criteria used during this assessment n e discussed in Section IU. Each criterion was applied using the "Attribute: for Assessment of Licensee Performance" contained in NRC Manual Chapter 0516.
- b. SALP Board Members: R. W. Starostecki, Director, Division of Project
, and Resident Programs R. R. Keimig, Chief, Projects Branch No. 2, 1
Division of Project and Resident Programs
\ R. R. Bellamy, Chief, Radiological Protection Branch, Division of Engineering and Technical Programs L. E. Tripp, Chief, Reactor Projects Section 2A, Division of Project and Resident Programs J. J. Lombardo, Licensing Project Manager, Operating Reactors Branch No. 5, Division of Licensing, Office of NRR C. J. Cowgill, Senior Resident Inspector, Oyster
- 1 Creek Nuclear Cenerating Station Other /btendees
- J. A. Thomas, Resident Reactor Inspector, Oyster
- p. l Creek Nuclear Generating Station
/
- c. Backoround (1) Licensee Activitier:
4 At the beginning of the assusment period, the facility had been in cold shutdown since December 9. 2381 to investigate the failuro of
.an isolation condenser valve. The valve failure was caused by stem nut crackfog and stem damage resulting from the practice of
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electrically'backseating the valve to prevent packing ieakage.
Other valves with Limitorque Operators that had been frequently backseated were found to have similar damage and were repaired.
\ Valve rep. airs were completed by the end of January 1982, but the plant remained shutdown to replace leaking coolers on the diesel generators and to complete surveillances which Technical Specifications required to be done each refueling outage (but at intervals of no more than 20 months).
The licensee satisfactorily 4empleted an annual emergency plan exercise on March 16, 1982. Ghe exercise was observed by teams from NRC and FEMA. ' ,,
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e, The plant began o;perating on .b;ril12, 1982 but scrammed on April 13 when operator errer' caused inadvertent closure of, the Main Steam Isolation Valves. The plant was restarted that day,,however, a controlled shutdown waz perfomed the following day to repair steam leaks on a ma a steam reheater pressure regulating' valve. Operation resumed on April 15, but the c4 actor scrammed on April 17, 1982 when a flooded offgas delay pipe caused a loss of condenser vacuum. The plant was resta.-ted on April 18 and operated at 60 to 70 percent power, limited by one of three condensate pumps being out of se rvice.
/
The plant cdtfnued to operate at reduced power until shutdown on May 23, 1982 to repair a steam leak on a steam reheater manway cover gasket. Operation limited to 60 - 70 percent power was resumed on May 27. /
The plant scramed aftpr a high reactor water level turbine trip on June 4, 1982, while attempting to fill the reactor wrter cleanup system. The plant.wi,s restarted on June 5, with all three condensate pumps available for operation. However, the plant, remained at a reduced power of about 80 percent because of fu'el depletion. The plant continued to operate in "coastdown."
The plant was shutdown on August 13, 1982 to investigate the ceuse of high differential pressure'across the salt water side of the containment spray heat exchangers. Extreme fouling by marine life debris was found on the tube sheets of all four heat exchangers.
The heat exchangers were cleaned and the plant went back on line at reduced power on August 29.
The licensee underwent an audit by the Institute of Nucleal-power Operations (INPO) between October 25 and November 4, >
1S82. NRC (Region I) representatives did not attend the INp0 debriefing and a report of their findings was not yet issued at ,
the time of this assessment. s
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On November 24, 1982, high seal cavity temperature caused l
by pump seal degradation forced the removal of the 'A' reactor recirculation pump from service. Continued leakage of the seal forced a reactor shutdown on December 10 to replace the seal.
Restart was begun on December 13 with all five recirculation pumps operating normally. During startup, a high flux scram occurred while in the intermediate range. During restart from the trip, the reactor was manually scrammed when water hammer occurred in the feed water piping. On December 18, 1982, the reactor again scrammed due to low reactor water level caused by valve oscillations when placing the reactor water cleanup system in service. Power operation was resumed on December 21, 1982.
On December 21, 1982, operator error caused initiation of the
! containment spray system. One pump ran for about 30 seconds injecting cooling water into the drywell air space. Electrical l checks of components in the drywell showed no abnormalities ar.d l power operation continued.
At the end of the assessment period, the facility was operating at about 50 percent power in coastdown with an 11 month refueling outage scheduled to begin in mid-February 1983.
(2) Inspection Activities One NRC resident inspector was assigned to the site for the entire assessment period. A senior resident inspector was assigned periodically from April through July 1982, and permanently from August through the end of the assessment period.
Total NRC Inspection Hours: 2435 (Resident and region based).
Distribution of inspection hours is shown in Table 3.
A tabulation of inspection activities is shown in Table 4, and a tabulation of enforcement data is shown in Attachment 1.
An emergency response appraisal team inspection was conducted in January 1982 prior to the beginning of the assessment period, and a team evaluation of the licensee's annual emergency drill was performed in March 1982.
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TABLE OF CONTENTS P_agg I. Introduction 1 II. Summ'ary*of Results 4
III. Criteria 5 IV. Performance Analysis '6
- 1. Plant Operations 6
- 2. Radiological Controls 9
- 3. Maintenance 11
- 4. Surveillance 13
- 5. Fire Protection 15
- 6. Emergency Preparedness 16
- 7. Security and Safeguards 17
- 8. Refueling 18
- 9. Licensing Activities 20 V. Supporting Data and Summaries 21 i
l 1. Licensee Event Report Tabulation and Causal Analysis 21
- 2. Investigation Activities 22
- 3. Escalated Enforcement Actions 22
- 4. Management Conferences During the Assessment Period 22 TABLES 1
Table 1 - Tabular Listing of LERs by Functional Area 23 Table 2 - Violations 24 l
Table 3 - Inspection Hours Summary 25 Table 4 - Inspection Activities 26 ATTACHMENTS -
tachment 1 - Enforcement Data 29 I I l
4 II.
SUMMARY
OF RESULTS OYSTER CREEK NUCLEAR GENERATING STATION FUNCTIONAL AREAS CATEGORY CATEGORY '
CATEGORY l 2 3
- 1. Plant Operations X
- 2. Radiological Controls
- Radiological Protection *
- Radioactive Waste Management
- Transportation
- Effluent Control and Monitoring X
- 3. Maintenance X t
- 4. Surveillance (Including Inservice and Preoperational Testing) X Fire Protection and Housekeeping X
- 6. Emergency Preparedness X 1
e i 7. Security and Safeguards X
- 8. Refueling / Outage Activities X
- 9. Licensing Activities X t
. 5 181. CRITERIA The following performance aspects were reviewed in each area:
- 1. Management involvement in assuring quality.
- 2. Resolving technical issues from a safety viewpoint.
- 3. Responsiveness to NRC initiatives.
- 4. Enforcement h: story.
- 5. Reporting and analysis of reportable events.
- 6. Staffing (including management).
- 7. Training effectiveness and qualification.
To provide a consistent evaluation, attributes relating each aspect to the characteristics of Category 1, 2, and 3 performance were applied as discussed in NRC Manual Chapter 0516, Part II and Table 1.
The SALP Board conclusions were categorized as follows:
Category 1: Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a
- high level of performance with respect to operational safety is being hieved.
l Category 2:
NRC attention should be maintained at normal levels.
l Licensee management attention and involvement in nuclear safety are evident; licensee resources are adequate and reasonably effective such that satisfactory performance with respect to operational safety is being i
achieved.
Category 3:
Both NRC and licensee attention should be increased.
Licensee management attention'cr involvement is acceptable and considers i
I nuclear safety, but weaknesses are evident; licensee resources appear strained or not effectively used such that minimally satisfactory performance with respect to operational safety is being achieved.
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w ..a.w,, - - - - - , .,.,-,,-,,.,-,-,-,n-e-, ,c,.,-- , -, ,,.e- . _ ,,--n-. ,,--,.,e ,,,_-,, , w....-,,_ , - - --. , ,-- - -
g IV. PERFORMANCE ANALYSIS
- 1. Plant Operations (407)
' Analysis of this area includes dire:t observation of plant operational activities and operational support activities. The operations area was under continual review by the resident inspectors supplemented by region-based inspectors. Inspections examined compliance with license and procedural requirements, design changes and modifications, training, housekeeping, quality assurance, audits, corrective action systems, safety review committees, and reporting systems.
Ouring the assessment period, improvement was noted in the area of operator awareness of plant conditions, knowledge of technical specifications, and operators' attention to detail. In general, operator response to transient and abnormal conditions was good. However, when other than normal system alignments did not require immediate operator action, operators were sometimes not fully aware of all the potential safety concerns and did not always aggressively pursue correction of the problems that caused the unusual alignment. There were deficiencies noted in the adequacy and formality of control room shift turnovers, but observations later in the assessment period indicated significant improvement.
A main steam isolation valve closure scram and an inadvertent containment spray actuation were caused by operator error resulting from i
inattention to activities in progress. Both events were caused by the same operator and are not indicative of a general carelessness by licensed operators. The licensee's corrective actions in these events appears to-have been adequate. Five licensee event reports involved personnel errors by licensed operators, however, the nature of the events were such that
{ none were significant nor indicative of adverse trends in this area. In l fact, improvements in operator technical knowledge and more management ;
attention to prevention of operator error have been noted. Frequent '
management presence in the control room has been noted. Operations l
management frequently observes and participates in routine shift
' turnovers, providing for prompt management review of operating logs, instrument recorder traces and discussion of plant status with operators.
Fewer incidents involving procedure violations have occurred at compared to the last assessmont period. This is the result of enforcement of the management policy of verbatim compliance with written procedures, and a vigorous program of review and revision of procedures.
Two improper releases of radioactive liquids to the environment during this assessment period are attributable to personnel error. One involved an unplanned unmonitnred release when contaminated water was drained from a service air system. The drain path was thought to go to a waste collection system when in fact it went to a storm drain system. An improperly monitored release occurred when, during a planned release of '
treated liquid to the environment, the record set of laboratory samples ,
was drawn from the wrcng tank.
7 AMENDED The Plant Operations Review Comittee (PORC) has been generally effective in reviewing safety issues. However, the large backlog of items needing PORC review has caused significant delays in issuance of many revised procedures.
The licensee is attempting to correct this by using alternate PORC members, while maintaining proper comittee quorum, to conduct daily PORC meetings.
The large backlog is partially the result of the extensive program of proce-dure review and upgrade and the large number of modifications and design change packages requiring review prior to the scheduled refueling outage.
The large number of procedure revisions has been necessitated in part by the licensee's increased emphasis on verbatim compliance and efforts to clarify the often cumbersome and difficult to follow operating procedures. i An inspection conducted early in the assessment period identified deficien-cies in the area of control of design changes and modifications. Many nec-essary administrative procedures for control of the development of design change packages, control of documents, turnover of systems, and update of drawings and system procedures had not been issued. The licensee is under-going major reorganization in the Maintenance and Construction and Techni-cal Functions Divisions, and as a result, the necessary interfaces betweert the various corporate divisions and plant staff had not been fonnalized in administrative procedures. A followup inspection later in the assessment period noted significant improvement in that the Maintenance and Construc-tion Work Management System Manual was issued to provide the necessary ad-ministrative controls in the areas of maintenance, design changes, and mod-ifications. Senior management attention to the problem areas was evident and progress toward establishing an acceptable program by the 1983 outage appears adequate.
Early in the assessment period, some deficiencies were noted involving fail-ure to follow equipment control procedures and inadequacies in the equip-ment control procedures. With assistance from a management consultant, the licensee revised the procedures to provide better control of equipment tag-ging, jumpering, and lifting of electrical leads. The program changes were major and required fonnal training of operations penonnel. The new program ,
was implemented late in the assessn:ent period and appears to have corrected ,
the previous deficiencies. i Responsibility for licensee's radiochbmistry program was placed under the cog-nizance of the operations department during the assessment period. There were significant deficiencies identified that are discussed in section two, page
- 10. Licensee made several personnel changes within the c?partment and improve-ment was noted at the end of the period.
l
7 .
The Plant Operations Review Committee (PORC) has been generally effective in reviewing safety issues. However, the large backlog of items needing PORC review has caused significant delays in issuance of marty revised procedures. The licensee is attempting to correct this by using alternate PORC members, while maintaining proper committee quorum, to conduct daily PORC meetings. The large backlog is partially the result of the extensive program of procedure review and upgrade and the large number of modifications and design change packages requiring review prior i to the scheduled refueling outage. The large number of procedure l
revisions has been necessitated in part by the licensee's increased
' emphasis on verbatim compliance and efforts to clarify the often cumbersome and difficult to follow operating procedures.
l An inspection conducted early in the assessment period identified deficiencies in the area of control of design changes and modifications.
l Many necessary administrative procedures for control of the development of design change packages, control of documents, turnover of systems, and i update of drawings and system procedures had not been issued. The licensee was undergoing major reorganization in the Maintenance and Construction and Technical Functions Divisions, and as a result, the necessary interfaces between the various corporate divisions and plant staff had not been formalized in administrative procedures. A followup inspection later in the assessment period noted significant improvement in that the Maintenance and Construction Work Management System Manual was issued to provide the necessary administrative controls in the areas of maintenance, design changes, and modifications. Senior management attention to the problem areas was evident and progress toward establishing an acceptable program by the 1983 outage appears adequate.
Early in the assessment period, some deficiencies were noted involving failure to follow equipment control procedures and inadequacies in the equipment control procedures. With assistance from a management ,
consultant, the licensee revised the procedures to provida better control of equipment tagging, jumpering, and lifting of electrical leads. The program changes were major and required formal training of operations personnel. The new program was implemented late in the assessment period and appears to have corrected the previous deficiencies.
Significant deficiencies were found in the licensee's radiochemistry program which is under the cognizance of the operations department. They involved inadequate procedures, improper control and calibration of counting equipment, and improper review of procedures. Most of the deficiencies had been previously identified by the . licensee's internal hudits and were the result of inadequate management review of and involvement in the radiochemistry program. The licensee has begun a program to upgrade the training and qualification of the chemistry technicians and supervisors, to increase the size of the staff, and to
.,.-,,,--.c. .-_-,,......_ .,_ _,-..__ - -...,.._ _ _ ,_ ..--.._ . _,..__._-.. . . _ _ - _ _ _ _ _
8 AMENDED The plant engineering staff appears to be capable of providing adequate oper-ational support to the facility. Improvement has been noted in the plant /
corporate engineering interface which provides better onsite outage planning and coordination. In the past, followup analysis of plant events was fre-quently delayed. However, recent plant events and transients have received a prompt, coordinated effort between plant engineering, technical functions, and plant operations to perform in-depth analysis of the events and accurate, timely assessments of the consequences. Of particular note were the plant responses to a reactor feed system water hammer event, a high worth control rod withdrawal event, and the assessment of the radiological consequences of a leakage from the radwaste system waste surge tank. ,The technical content of Licensee Event Reports is generally excellent. although reports are not always timely. The cause of many events is frequently coded as "other," how-ever, the narrative description of the cause is generally accurate and in-dicative of a thorough review. The analysis of the event and corrective actions are generally indicative of a sound, technical approach to safety issues.
During this assessment period, general improvement was noted in management control and review of most operations functions and in licensed operator per-formance. However, the occurrences of unmonitored releases, the significant breakdowr. of management controls in the radiochemistry program, the large backlog of PORC review items, and deficiencies in the design change and modification programs indicate needed management attention to effect improve-ments.
Conclusion - Category 2 l
l Board Recommendations - Maintain inspection coverage consistent with program requirements for a plant in a refueling outage.
1 l
l l
8 provide more in-depth management review of the daily radiochemistry activities. Improvement has been noted in this area.
The plant engineering staff appears to be capable of providing adequate operational support to the facility. Improvement has been noted in the plant / corporate planning engineering interface which provides better onsite outage and coordination. In the past, followup analysis of plant events was frequently delayed. However, recent plant events and transients have received a prompt, coordinated effort between plant engineering, technical functions, and plant operations to perform in-depth analysis of the events and accurate, timely assessments of the consequences. Of particular note were the plant responses to a rea: tor feed system water hammer event, a high worth control rod withdrawal event, and the assessment of the radiological consequences of a leakage from the radwaste system waste surge tank. The technical content of 1.icensee Event Reports is generally excellent, although reports are not always timely.
The cause of many events is frequently coded as "other,"
however, the narrative description of the cause is generally accurate and indicative of a thorough review. The analysis of the event and corrective actions are generally indicative of a sound, technical approach to safety issues.
During this assessment period, general improvement was noted in management control and review of most operations functions and in licensed operator performance.
However, the occurrences of unmonitored releases, the significant breakdown of management controls in the radiochemistry 1
program, the large backlog of PORC review items, and deficiencies in the design change and modification programs indicate needed management attention to effect improvements.
Conclusion - Category 2 Board Recommendations - Maintain inspection coverage consistent with program requirements for a plant in a refueling outage.
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9
- 2. Radioloofcal Controls (14%)
Evaluation in this area included monthly rev!ew of selected program areas by the resident inspectors and six inspections by region based inspectors of the radiation protection progra.n, radioactive waste management, shipping, radioactive effluent c.onitoring, and radiochemistry program.
The licensee has developed a strong management organization in the radiological controls department with multiple levels of supervision and a viable reporting structure. The licensee's radiation protection staff is supplemented by contractor personnel with the two groups well integrated at both the technician and supervisory levels. Health Physics (HP) technicians are required to complete formal qualification programs which include both classroom and on-the-job training with written and oral board exams prior to performing responsible plant related duties. Improved General Employee Training programs have increaseo the plant and contractor l employees' general knowledge and awareness of radiological conditions in the plant and the requirements of the radiation protection program. Procedural requirements are generally well defined and understood, and the radiological precautions written l
into other Plant operating, maintenance, and special installation procedures are indicative of thorcugh review by the radioisgi o!
engineering group.
Response to noted deficiencies was generally prompt and appropriate. A violation for inadequate drywell access controls l
resulting in workers being locked in the drywell was corrected by issuance of a new temporary procedure shortly after identification l of the violation. ;
l Recent reorganizations in the areas of radioactive waste management !
l and waste shipping have resulted in a strong management i organization. The licensee has pursued a vigorous waste reduction program and has grsatly reduced the volume of treated water released to the environment. Reviews of the waste shipping program indicate strict management control of shipping activities.
Weaknesses were noted in the areas of radiological effluent '
monitoring and in the radiochemistry program. Four licensee event reports were submitted on unmonitored liquid releases. Two releases i were the result of equipment failure. One. release was the result of contaminated water being drained into a storm sewer system by mistake and one improperly monitored release resulted when monitoring samples were taken from the wrong location. One violation was the failure to collect proper environmental air samples and one violation was the failure to perform adequate gamma spectroscopy measurements '
of effluent sampl.es when the laboratory equipment was not properly l .-.
. . . . . . . . . . . .. v 10 AMENDED calibrated. In general, the licensee's actions after an unmonitored release were good. They included collection and analysis of appropriate environmen-tal samples to adequately assess the environmental and safety impact. None of the releases resulted in allowable limits being exceeded.
Major programatic weaknesses in the radiochemistry program were indicative of a general breakdown in the management controls. No central responsibil-ity was assigned for management of the site chemistry program. As a result, procedures were poorly implemented and many were inadequate, procedures were improperly reviewed, analytical results were not reviewed and analyzed for trends, and radiochemstry laboratory equipment was poorly maintained and contmiled. Most deficiencies in this area were also noted by the licensee's i
intamal audits and a vigorous corrective action program is in progress.
The deficiencies in calibration and control of radiochemistry laboratory
( equipment resulted in erroneous calculations in the envimnmental effluent l monitoring program for about one year.
Licensee has begun a program to upgrade the training and qualification of the chemistry technicians and to increase the size of the staff and to provide more in-depth management review of the daily radiochemistry activities. Im-provement has been noted in this area.
Conclusion - Category 2
- Board Recomendations - Resident Inspectors should review the licensee's cor-rective actions in the radiochemistry program with a followup independent l measurements inspection by region based inspectors prior to the end of the l 1983 refueling outage.
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, 10 calibrated. In general, the licensee's actions ' after an unmonitored release were good. They included collection and analysis of appropriate environmental samples to adequately assess the environmental and safety impact. None of the releases resulted in allowable li.mits being exceeded.
- Major programmatic weaknesses in the radiochemistry program were indicative of a general breakdown in the management controls. No central responsibility was assigned for management of the site chemistry program. As a result, procedures were poorly implemented and many were inadequate, procedures were improperly reviewed, -
a.nalytical results were not reviewed and analyzed for trends, and radiochemistry laboratory equipme'nt was poorly maintained and controlled. Most deficiencies in this area were also noted by the licensee's internal audits and a vigorous corrective action program is in pro.gress. The deficiencies in calibration and control of radiochemistry laboratory equipment resulted in erroneous calculations in the environmental effluent monitoring program for about one year.
Conclusion - Category 2 Board Recommendations - Resident Inspectors should review the licensee's corrective actions in the radiochemistry program with a followup independent measurements inspection by region based inspectors prior to the end of the 1983 refueling outage.
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- 3. Maintenance (9%)
This area was under review by the resident inspectors throughout the assessment period. In addition, two inspections by region-based inspectors examined the maintenance organization and staffing.
A major reorganization of the maintenance department occurred in early October,1982. All corrective maintenance is now performed by the Maintenance and Construction (MC) Division under the Vice l
President, Maintenance and Construction, and all corrective maintenance personnel including supervision report to that division. The plant maintenance manager provides plant review and
! approval of all work assigned to MC. Interfaces between the plant staff and MC are provided in the plant conduct of maintenance procedure. Additional changes to the organization will occur when l an amendment is issued to formalize the reorganization in the Technical Specifications. Procedures to fully implement the new program are under development. The revised organization has provided for higher level management review of maintenance activities, with difficulties in divisional interfacas being resolved at the Vice President level, when necessary. However, I review of ths organization and dis:ussions with plant personnel have i
indicated that there is still some confusion with respect to i organizctional interfaces. Early in the reorganization phase, many individuals indicated that they were unaware of what their duties and responsibilities would be in the new organization. Observation of daily maintenance planning meetings also indicate the need for further definition of responsibilities and divisional interfaces.
Consolidation of the plant maintenance and MC supervisory staffs i has provided increased manpower in the maintenance area with a
! current supe-visor to worker ratio of about 1 to 10. The licensee intends to increase the staff further to attain an average supervisor to worker ratio of about 1 to 8. However, there are still indications of weaknesses in the first line supervision of maintenance crews. A violation occurred during this assessment period when the emergency diesel oil heaters were scured improperly during maintenance. The particular procedural violation had become routine maintenance practice approved and encouraged by the first '
l line supervisor. In addition, there are indications of a lack of adequate direct field observation and verification of work i
activities by first line supervision.
Improvement has been made in this area since the last SALP assessment period. The maintenance staff includes full time schedulers who are experienced in most aspects of corrective maintenance. The schedulers I
review priorities, availability of material, and manpower needs, and coordinate with maintenance and plant supervision to schedule individual ,
I tasks. .
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= . _ . .
12 .
Schedulers frequently review outstanding work orders in an effort to reduce the maintenance back log. Dlant administrative procedures give clearly stated guidelines for assignment of work order priorities, and new work orders as well as tasks in progress are reviewed daily by senior plant management.
Revised procedures now give specific requirements for cancellation of work orders, which occurs only rarely, and only after obtaining concurrence of the initiating department supervisor. Availability of ;
current equipment data and' technical manuals has improved. Some trending of corrective maintenance is now performed and improvements '
have been made in machinery history records. Future reorganizations are planned to further improve maintenance history records with the formation of a plant materiel group.
Although significant improvement has been made in the general management control and review of maintenance functions, frequent rework of some jobs indicates there may be a need to improve the general quality of work and knowledge of maintenance mechanics.
Near the end of the assessment period, tha licensee began a program of formal classroom instructions for maintenance personnel.
Improvements in this area are expected as the outage progresses.
There is evidence of management involvement and control in assuring quality in preventive maintenance. There is a full time dedicated manager with a staff to supervise and schedule. About thirty persons are assigned to perform preventive maintenance and surveillance on electrical, mechanical, instrument control and fire protection
- systems. presently, all scheduling of preventive maintenance is done manually, but the licensee intends to computerize scheduling and recording in the future. A program of trend analysis of ,
preventive maintenance and surveillance results has been started and will be expanded in the future.
Conclusion - Category 2 '
l Board Recommendations - None.
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_ _ . . , . . . . - . . . - . _ . . , _ . - - - _ . _ _ . . . . _ - - - ~ ~ _ . _ , _ . . _ _ . - . _ _ _ . . _ _ _ . _ - _ _ . . . _ _ . _ _ . . , _ _ - _ _ . . - - . _ _ _ . . _ - - - .
. .c. .. .r.a a . a 13
- 4. Surveillance (10%)
This area was under review by the resident inspectors throughout the assessme' period. One inspection of the containment leak rate test program was conducted by region-based inspectors.
Adequate management control and review of routine technical specification related surveillance programs exist. A master i surveillance listing has been prepared which incorporates all surveillances requirsd by technical specifications. An annual master i schedule is prepared and is updated when technical specification amendments change surveillance requirements. previous problems existed which involved failure to modify surveillance schedules and procedures as technical specification changes were issued. Increased management review of surveillance programs and regulatory changes have resulted in improved performance in this area. No similar problems have occurred during this assessment period.
l Routine surveillance testing has generally been performed properly t
and on time with no violations 4.nd only two licensee event reports
! resulting from missed surveillances.
l l The review of surveillance test results has improved. First line i supervisors are now responsible for the first level of review and greater management level attention is given to review and evaluation of test results. The licensee's "deviation report" system provides for prompt identification and followup evaluation of deficiencies ,
ider.tified during surveillance testing. '
Licensee's followup review process for surveillance tests has improved in that anomalous test retults have been identified and reported which were not identified in the initial review. Although some improvement in the initial review has been noted, additional effort to strengthen that process is required. I Seven of the fourteen licensee event reports relating to l surveillance involved setpoint drift of safety related sensors.
This has been a recurring problem and has received considerable management attention. Modifications are scheduled for the next
! refueling outage to correct this problem.
Although the conduct of the routine surveillance program is adequate, significant deficiencies existed in the performance of containment leak rate testing program. Violations for inadequate implementation of leak rate test procedures and observed inadequacies in the general control and coordination of the leak test program indicated a major l breakdown of the management control and review of this program.
There was little evidence of prior planning for the leak test program l
conducted in Marc.h and April of 1982. NRC review of the test program
y.1 - , _ . . .
4 14 AMENDED found frequently procedural violations, improper evaluation of test results, and indications that the personnel perfonning the tests lacked familiarity with the regulatory requirements relating to primary containment leak test-ing. Procedural inadequacies resulting from design and evaluation deficien- ;
l .
cies resulted in radioactive contamination of the reactor building service air system. Also, testing found an improperly assembled valve that had re-mained in an ino>erable condition since the 1980 refueling outage. The im-proper assembly 1ad gone undetected until early 1982 because of procedural inadequacies in the leak test program. The licensee has comitted to re-vise the affected procedures prior to using them again.
Inadecuate prior planning for the leak rata test program was due, in part, to sucden unforeseen schedule changes. Operational problems forced a plant shutdown in December 1981 which lasted for three months. As a result, the licensee rescheduled the planned refueling outage for early 1983. The schedule change.resulted in the required containment leak rate testing being due prior to the refueling, so the licensee elected to perfom the testing prior to plant startup. This allowed very little time for procedure re-views, training of technialans and other prior planning. In addition, the testing was >erformed by a group of inexperienced personnel who were unfam-iliar with t1e procedural and administrative recuirements of the program.
Observation of local ieak rate testing perfonnec since the end of this assessment period has noted cignificant improvements in this area.
In the previous assessment period, a weakness was identified in management of the controls in the IST program in that connitznents made in April 1981 were not met and no followup or notification was provided to the NRC. Dur-ing this assessment period, the licensee revised his connitment dates for some of the items identified in the 1981 letter. As of the end of this assessment period, the administrative procedure for control of the IST pro-gram has not been implemented, indicating that management controls require further strengthening. One possible cause for continued problems in this area is that there have teen three IST coordinators in the past 3 years.
Conclusion - Category 2 Board Recomendations - Inspect the primary containment leak rate test program during leak rate testing at the end of the 1983 refueling outage.
..._.. . . ~
. 14 found frequent procedural violations, improper evaluation of test results, and indications that the personnel performing the tests lacked familiarity with the regulatory requirements relating to primary containment leak testing, procedural inadequacias during the Integr3ted Leak Rate Test resulted in a valving error that caused radioactive contamination of a portion of the reactor building service air system. Also, testing found an improperly assembled valve that had remained in an inoperable condition since the 1980 refueling outage. The improper assembly had gone undetected until early 1982 because of procedural inadequacies in the leak test program.
The licensee has committed to revise the affected procedures prior to using them again.
Inadequate prior planning for the leak rate test program was due, in part, to sudden unforeseen schedule changes. Operational problems forced a plant shutdown in Decemoer 1981 which lasted for three months. As a result, the licensee rescheduled the planned refueling outage for early 1983. The schedule change resulted in the required containment leak rate testing being due prior to the refueling, so the licensee elected to perform the testing prior to plant sta rtup. This allowed very little time for procedure reviews, training of technicians and other prior planning. In addition, the testing was performed by a group of inexperienced personnel who were unfamiliar with the procedural and administrative requirements of i the program. Observation of local leak rate testing performed since '
l the end of this assessment period has noted significant improvements L
in this area.
9 In the previous assessment period, a weakness was identified in management of the controls in the IST program in that commitments I made in April 1981 were not met and no followup or notification was provided to the NRC. During this assessment period, the licensee revised his commitment dates for meeting some of the items identified in the 1981 letter. As of the end of this assessment period, the administrative procedure for control of the IST program has not been implemented, indicating that management controls require further strengthening. One possible cause for continued problems in this area is that there $ts been three IST ceordinators l
in the past 3 years. ~-
Conclusion - Category 2 i
Board Recommendations - Inspect the primary containment leak rate test program during leak rate testing at the end of the 1983 refueling outage.
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A mminandademanhammwt.c. -
i 15
- 5. Fire Protection and Housekeeping (4%)
One fire protection program inspection was conducted by a region based inspector during this assessment period. Fire protection and housekeeping were under continual review by the resident inspectors.
A full time Fire Protection Mana* g er is assigned to the facility with sufficient staff resources to carry out all Fire Protection Program functions. Portions of the fire protection staff have been recently reassigned to the preventive maintenance department to provide for a centralized control of preventive maintenance including maintenance and inspection of fire protection equipment. This also frees the Fire Protection Manager from supervisory activities and allows more direct management level programmatic review and analysis. A coherent and effective training program has been established and assures that all operating shifts have a fully trained fire brigade.
The licensee's submittal made in accordance with 10 CFR 50 Appendix R indicated an adequate understanding of the technical and safety issues and a sound approach to resolution of the issues. The licensee has requested exemptions to some requirements of 10 CFR 50 Appendix R. These exemptions are currently under NRC review. One Licensee Event Report in the Fire Protection area involved an activation of the fire suppression system and the resulting wetdown of safety related electric equipant.
I Similar events had occurred during the previous assessment period which decastrated inadequacies in the original fire protection safety eva.luati on . The licensee performed an extensive survey of plant systems and conducted a program of waterproofing electrical components and l installation of drip shields over safety related motors and motor control I centers. At the time of the event during this assessment period, the i drip shield installation was complete, but the installation of terminal box gaskets and conduit sealing devices was not complete. The licensee performed a revaluation of the water tight integrity of safety related equipment and accelerated the waterproofing program in the plant.
The licensee has made significant ' improvements in the area of housekeeping, as a result of increased management attention which included periodic housekeeping inspections by plant management staff.
General cleanliness of the plant has improved as clean up crews continually remove trash and debris before it builds up to significant levels. However, further improvements can be made by improving the attitude of general plant workers toward housekeeping. Radiological housekeeping conditions are generally acceptable. The licensee has made some reduction in the number of contaminated and high radiation areas but l further reduction is still needed. i l
i Conclusion - Category 2 l Board Recommendat. ions - None.
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- 1 16
- 6. Emergency Preparedness (10%)
Analysis in this area is based on observation by an NRC Team of the annual emergency preparedness exercise which is designed to demonstrate all facets of the emergency plan, and on periodic observation by the resident inspectors of plant training exercises.
During the annual exercise on March 16, 1982, the Itcensee demenstrated an adequate capability to deal with a plant emergency.
A number of deficiencies, most of which were also identified by the licensee, were noted in the areas of information flow, dose assessment, offsite radiological surveys, data display, personnel training, and communications. Resident inspector observations indicated that significant improvement has been made in overall site readiness prior to the exercise. Continued senior level management attention to emergene) planning is evident with a full time manager assigned at the site with a significant support staff of emergency planning specialists. The licensee has also maintained a viable active duty rorcer of qualified emergency response personnel. The licensee has also maintained adequate shift coverage to ensure that all emergency plan esquire.ments for non-licensed onshift personnel were met. Emergency plan training is an integral part of operator qualification and requalification training, and quarterly full scale emergency plan training drills are cunducted on site.
The emergency plan and procedures continue to be adequate and shift personnel have maintained familiarity with tha. The inspectors noted, however, that some procedures are cumbersome and difficult to follow. The Itcensee has indicated that they are planning to revise the emergency procedures to streamline them.
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i l
The licensee was issued a Notice of Violation for fai1ure to complete -
! the public notification system by February 1,1982. Installation was !
completed on March 5, 1982. The ifcensee had instituted compensatory '
measures in the interim and 45 of 46 planned strens were installed before March 1.
I i
' Prior to the assessment period, an Emergency Preparedness Implementation appraisal was conducted which identified a number of findings including i
the need for improvements in support facilities, personnel training, '
offsite dose assessment, procedural development, and post accident reactor coolant sampling capabilities. NRC staff has met with the
! licensee and is in the process of resolving the post accident sampling issus.
Conclusiog - Category 2 Board Recommendations - None. '
! 4
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- 7. Security and Safeguards (8%)
Ouring the assessment period, there were three unannounced physical security inspections and one material control and accounting inspection conducted by region-based inspectors, and continuous inspections by the Resident Inspectors. Three minor procedural viciations were timelywere identified and the licensee's corrective actions and appropriate. The licensee was effective in maintaining overall security program per formance and management support of site security activities was evidenced by the purchase of -
new explosives detectors, the assignment of professional training instructors to the security program, and the purchase of an improved computerized access control software program scheduled for installetion in March 1983.
In preparation for the forthcoming refueling outage, licensee management has augmented security staff with contractor personnel.
These personnel are currently undergoing training to qualify to supplement the existing guard force. The Site Security Supervisor resigned in January 1983. A qualified replacement was selected from l
l within Department.
the company with no lapse in the supervision of the Security NRC inspection findings were corrected quickly, and actions to prevent recurrence proved adequate. There have been no repeat yiolations.
During this assessment period, the licensee submitted 11 Security Event Reports. The majority of these reports resulted from ,
computerized access control system failures. The impact of these i events was minimized because of timely and effective compensatory l
measures. The licensee intends to modify existing software to reduce or eliminate this problem, as noted above.
All security personnel appeared to be knowledgeable of their assigned duties. The Guard Training and Qualification Program is progressing on schedule, and the program is well defined and implemented by experienced personnel.
Conclusion - Category 1 Board Recommendations - Maintain rurmal inspection coverage.
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- 8. Refuelino and Major Outage Activities (5%)
There were no refueling outages during this assessment period, however, there were several short maintenance outages and considerable planning efforts in preparation for the 1983 refueling outage.
Considerable improvement was noted in scheduling and coordination of outage activities. The Programs and Controls department whose manager reports directly to the Vice President and Director, Oyster Creek, has been expanded and now includes a full time staff of schedulers and planners. This department oversees all outage planning at the site and coordinates site planning activities with the Technical Functions and Maintenance and Construction Divisions planning and scheduling activities. The department has effectively planned short outages with scheduling activities generally addressing key outage and sutage recovery items. During forced shutdowns that occurred during the assessment period, the Programs and Controls Department was able to quickly develop schedules that not only allow prompt completion of the critical repairs but also allowed the plant to capitalize on the down time to complete other maintenance activities.
More direct management attention to review of contractor work activities has resulted in some improvement in the control of these activities. Operations supervision is now required to survey work areas accompanied by contractor supervision, prior to the start of work, to assure that contractor activities will not impair plant operation.
Observation of contractor activities has indicated that I
I contractor personnel are now more aware of radiological working conditions and requirements, as well as the general plant administrative procedures for conduct of work activities.
Significant deficiencies were noted early in the assessment period with the coordination and control of design change and modification activities. As discussed in section IV.1 of this report, the licensee has made progress toward correction of these deficiencies.
Although recent organizational changes have been made to provide an integrated and improved system of controls for work being done in the plant, the organization is still evolving with some problems with organizational interface remaining. The 1983 refueling outage schedule has been changed several times. The refueling was originally scheduled for late 1981. After several reschedulings, the outage actually began February 11, 1983. Most of the delays were the result of operational problems throughout the fuel cycle which prevented the licensee from achieving the intended fuel burnup. However, other delays were the result of the licensee's ,
realization that the staff was not prepared to effectively manage an outage of the intended scope.
. .,. . e. t-~-- ......o-.. .
19 The licensee has well staffed corporate and plant engineering groups. However, the coordination between the groups with respect to outage planning is an area needing improvement. At the end of the assessment period the full scope of the 1983 outage had not been finalized, and many scheduled outage jobs had not been reviewed for availability or procurement of needed material.
Previous deficiences were noted with coordination of system turnover after modification, training of operators on modifications, and upd'ites of system drawings and procedures. Recent changes in the organization and administrative programs should provide for more formal and effective control in this area. The effectiveness of these programs will be assessed as the outage progresses.
Conclusion - Category 2 Board Recommendations - Because of the extensive outage activities scheduled, a region based Readiness Assessment Team inspection should be performed prior to completion of pre-operational testing.
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- 9. Licensing Evaluation in this area is based on review of the licensee's activities in the Systematic Evaluation Program (SEP), Fire Protection review, Core Spray Effectiveness review, Three Mile Island Task Action Plan (NUREG 0737) responses, development of Radiological Effluent Technical Specifications (RETS), and Operator Licensing.
The licensee generally places adequate canagement attention and involvetaent in licensing activities with decision making at a level that ensure adequate management review. The licensee demonstrates a clear understanDe of the issues and conservatism when safety concerns ve 1,1vcived but, at times, attempts to meet only the minimum requirements.
While the licenses provides generally sound and acceptable resolutions to the issues, frequent time extensions are required.
Considerable E C effort and repeated submittals are needed to l
adequately cover the material to be reviewed. This was particularly evident with the Fire Protection and RETS submittals. The timeliness of responses was poor in the previous assessment period and continues at about the same pace with a two to three month time delay being the norm. Marginal staffing, particularly in the light of the SEP requirements levied on the licensee, may have contributed
! to these delays. When the SEP is completed, adequate manpower should be available to perform in a timely manner. ,
Three sets of operator license examinations were conducted during the appraisal period. Overall, five out of six reactor operators
) and four out of eight senior reactor operators passed the i examination. There has been some indication of a lack of adequate i
screening of applicants ' prior to recommending them for an examination. Four SRO candidates failed the licensing examination with low overall scores. One candidate has since passed the examination. Licensee management has taken steps to identify and correct these deficiencies, nowever, there has not been an adequate number of examinations to evaluate the effectiveness of this action.
Conclusion - Category 2 Board Recommendations - None.
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a.r/h":. . A 21 V. SUPPORTING OATA AND SUMMARIES
- 1. Licensee Event Reports Tabular Listing Unit 1 Type of Events:
A. Personnel Error 11 B. Design / Mfg /Constr/ Install. 2 C. External Cause 0 O. Defective Procedures 6 E. Component Failures 19 X. Other 25 TOTAL 63 Licensee Event Reports Reviewed Unit 1:
Reports 82-01 through 82-61, 82-63, 82-64 Causal Analysis
- a. 8 LER's resulted from instrument drift causing safety system actuation sensors to have setpoints outside of the specified range. This is a recurrent problem which the licensee plans to .
l correct during the 1983 refueling outage by modification of the affected instruments. The LER's in this group are: 82-01, 82-03, 82-07, 82-15, 82-17, 82-24, 89,-29, and 82-56. ;
- b. 4 LER's reported loss of stack gas monitoring resulting from i electrical trips of the sample pumps. The licensee plans to l upgrade the stack gas monitoring system during the 1983 i refueling outage. LER's in this group are: 82-30, 82-41, 82-44, and 82-55.
- c. 3 LER's involved missed surveillances. They were: 82-08, 82-38, and 82-63.
- d. 3 LER's involved degraded offgas isolation capability due to control problems with valve V-7-31. LER's in this group are:
82-15, 82-35, and 82-61,
- e. 3 LER's reported failure of valves to pass the containment local leak rate test. They were: 82-14, 82-19, and 82-20.
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- 2. Investigation Activities: None
- 3. Escalated Enforcement Actions
- a. Cffil Penalties
$40,000 proposed December 1982 for violations involving failure to declare one Isolation Condenser inoperable and improper maintenance and testing on a Torus Vacuum Breaker,
- b. Orders April 30, 1982, order to all Licensees modifying 10 CFR 50.48 rule effective date.
- c. Confirmatory Action letters Confirmatory action letter dated February 18, 1982 regarding deficiencies in emergency preparedness identified in the January 1982 appraisal.
- 4. Management Conferences April 16, 1982 Onsite to discuss Cycle II SALP May 4, 1982 Region I to discuss violations involving failure to declare Isolation Condenser inoperable and improper maintenance and testing on torus vacuum breaker.
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- i TABLE 1
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TABUI.AR LISTING OF LERs BY FUNCTIONAL A.2EA 1
@JERCREEKNUCLEARGENERATINGSTATICH s
\
Area Number /Cause Code Total
- 1. Plant Operations 6/A 1/0 1/E 2/X 10
- 2. Radiological Contro7s 1/E 1 i
- 3. Maintenance / 4/A '
2/8 1/0 ' 15/E 15/X 37
- 4. Surveillance 1/A 4/0 2/E 7/X 14 -
- 5. Fire Protection 1/X 1 ,
1
- 6. Emergency Preparednes_s
\
Security and Safeguards _
1
- 8. Refueling _
- 9. Licensing Activities '
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- 10. Other \
,2-l 3 TOTAL 63 i
Cause Codes: A - Personnai Error 8 , Design, Manufacturing, Construction, or Installation Error \
C - External Cause 0.- Defective Procedures
, E - Component Failure X - Other
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V_If,M[',~lCNS (2/1/82 - 1/31/83) s' ! t OYSTER CREEK NUCLEAR GENERATING STATION - .
A. Number and Severity ^ Level of ' Violations Severity Level I O f
Severity Level II O Severity Level III 2 Severity Level IV 13 Severit 7 Sever!t/yLevelV Level VI 3 Tot.l.1 25 B. V olations Vs. Functidaal Area Severity Levels
,fNCTIONALAREAS I II III IV V VI
- 1. Plant Operation.s
~
7 2 2
- 2. Radiological Controls _
1_ 1 ,
- 3. Maintenance , 1 1 i
- 4. Surveillance 4 1
- 5. Fire Protection
- 6. Emergency Preparedness }'
_ 1
- 7. Security & Safeguards _ 1 2
- 8. Refueling .
r j ...
- 9. '
Licensing Activities
- 1 Totals 0 0 2 13 7 3 Totsi Violations = 25 l'
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,i j 25 TABLE 3 INSPECTION H00R'S
SUMMARY
(2/1/82 - 1/3i 3,1 OYSTER CREEK NUCLEAR GENERATING Sl TION Hours % OF TIME
- 1. Plant Operations
_ _ , 971 40 2 Radiological Controls 331 14
- 3. Maintenance _ ?.13 .
9
- 4. Surveillance 259
. 10 __,
\
- 5. Fire Protection / Housekeeping / 97 '
4 S. Emergency Preparedness 247
_,_ 10
. Security and Safeguards __ 197 8
- 8. Refueling 120 5
,_ 9. Licensing No Data Available Total 2435 .
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. TA8LE 4 INSPECTION REPORT ACTIVITIES OYSTER CREEK NUCLEAR GENERATING STATION February 1,1982 - January 31, 1983 9 port No. and Inspection I
Jsuection Dates Hours Inspector Areas Inspected 82-02 36* Resident 1/4/82-3/1/82 Routine Resident Safety Inspection 82-03 32 Resident-1/2/82-4/5/82 Routine Resident Safety Inspection 82-04 246 NRC Team Emergency Preparedness and Observation i/15/82-3/17/82 a'nd Resident of Annual Emergency Exercise 82-05 50 Specialist Design Changes and Modifications
- /8/82-2/19/82 82-06 118 Specialist
/17/82-4/6/82 Containment Penetration Leakage Test Program and Observation of Primary Containment Integrated Leak Tes*
32-07 38 Specialist
!/o/82-4/2/82 Fire Protection / Prevention Program l
82-08 22 Resident Review of Improper Assembly of a
,/2/82-3/17/82 1
Reactor Building To Suppression Chamber Vacuum Breaker 82-09 80 Resident Routine Resident Safety Inspection
/6/82-5/3/82 i
/12/ -
15/82
- "" **""I*#
82-11 9 Specialist 4/8/82 Review of Radioactive Contamination of Service Air Piping 82-12 10 ---
Management Meeting to Discuss SALP 4/16/82 Conclusions L 82-13 30 ---
l 5/4/82 Enforcement Confe -..- to Discuss Findings of Inspe;:'Ns 81-21 and 82-08 l
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- Inclu, des only those inspection hours after February 1,1982 '
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_ TABLE 4 (Continued) iF t No. and Inspection Ir..,4ction Dates Hours Inspector Areas Inspected 82-14 63 Specialist
- 5/17/82-5/21/82 Physical Security 82-15 36 Specialist Training
-5/24/82-5/28/82 82-16 66 Resident
.5/4/82-6/1/82 Routine Resident Safety Inspection 82-17 115 Resident 5/2/82-7/5/82 Routine Resident Safety Inspection 82-18 83 Resident 7/6/82-8/2/82 Routine Resident Safety Inspection 82-19 60 Specialist 1/2/82-8/6/82 Radiation Protection 82-20 131 Resident 1/3/82-9/7/82 Routine Resident Safety Inspection 32-21 158 Specialist
- , 82-9/3/82 Quality Assurance Program, Design Change and Modification Program, Offsite Support Staff 82-22 212 Resident
/8/82-10/6/82 Routine Resident Safety Inspection 82-23 56 Specialist
/14/82-9/17/82 Environmental Monitoring Program 82-24 80 Specialist Independent Measurements and Radio
/27/82-10/8/82 Chemistry Program 82-25 169 Resident ; Routine Resident Safety Inspection 0/7/82-11/11/82 82-26 52 Specialist Physical Security 0/12/82-10/15/82 82-27 22 Specialist Special Nuclear Material Control and 0/20/82-10/22/82 Accounting 82-28 37 Specialist Radiation Protection 1/9/82-11/16/82 -
32-29 234 Resident Routine Resident Safety Inspection 1/12/82-12/31/82
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.-.1 TABLE 4 (Continued) k 't No. and Inspection
- _ : tion Dates Hours Inspector Areas Inspected 83-01 128 Resident
./1/83-1/31/83 Routine Resident Safety Inspection 83-02 35 Specialist
'./16/83-1/20/83 Radiation Protection, Followup of Allegation of Lost Neutron Source 0
0 0
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29 ATTACHMENT 1 ENFORCEMENT DATA OYSTER CREEK NUCLEAR GENERATING STATION February 1, 1982 - January 31, 1983
- NSPECTION JUMBER SUBJECT REO. SEV. AREA 82-02 Sdrye11 lance controls did not appropriately 10 CFR 50 IV 4 protect. safety features from adverse environ- Appendix 8 mental conditions .
82-02 Failure to follow procedures for vital area T.S. V 7 access control l
l 82-02 Failure to control vital area keys in accord- T.S. IV 7 l ance with procedures 82-05 Administrative procedures were not implemented 10 CFR 50 VI 1 l for performance of design changes and modift- ,,.pendix B l cations
!82-05 Report of facility changes was not submitted 10 CFR 50.59 VI 9 fcr calendar year 1980 82-05 Followup action to audits was not taken 10 CFR 50 VI 1 82-06 No LER was submitted to report identified T.S. IV 4 !'
primary containment degradation 82-06 Procedures were not properly implemented during T.S. IV % ;
perfomance of containment leak rate testing 82-08 Failure to maintain containment integrity and T.S. III 3 vacuum breaksr operability when valve mis-assembly went undetected ,
82-17 Radioactive liquid was released and was not T.S. IV 1 continuously monitored 82-18 Failure to follow procedures to protect safety T.S. IV 4 features from adverse environment 82-18 Procedures as implemented did not adequately T.S. IV 1 confirm system realignment l
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ATTACHMENT 1(Cont _inuedl NSocCTION 11 SUBJECT REQ. SEV. AREA 82-20 Failure to follow equipment control procedures T.S. V 3 when diesel oil heaters were secured 82-20 Procedures were inadequate to assure proper T.S. IV 2 control of a lacked high radietton area 82-22 Isolation Condenser isolation systems were not T.S. IV 1 fully operable wher. open isolation valves were electrically defeated 82-23 Environmental air particulate samples were not T.S. V 2 collected at the proper frequency 82-23 Environmental thermal monitoring system T.S. V 4 calibrations did not include sensor calibration 82-24 Failure .to make adequate gamma spectroscopy 10 CFR 20 IV 1 measurements of effluent samples -
,82-24 Failure to implement chemical and radio- T.S. IV 1 chemical control procedures
'5 Radlochemistry procedures used by contractor T.S. V 1 l and vendor laboratories were not reviewed and
. approved as required.
82-24 Procedures for calibration and operation of a T.S. V 1 gamma spectrometer were not reviewed and approved 82-25 Failure to follow visitor escort procedures T.S. V 7 82-29 Failure to conduct a proper shift turnover T.S. IV 1 82-29 Rod Worth Minimizer procedures were inadequate T.S. IV 1 l
to insure verific-tion of rod withdrawal sequences 482-36
- Failure to demonstrate that administrative 10 CFR 50 III 6
) and physical mears were established to alert Appendix E l
the public within the plume exposure pathway This enforcement action issued by letter dated February 12, 1982 l from Director, Office of Inspection and Enforcement to GPU Nuclear Corporation ,
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, UNITE 3 STATES Enclosure 3 NUC1. EAR REGULATORY COMMisslON E e REGION l
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APR 2 91983 -
Docket No. 50-219 GPU Nuclea: Corporation A1TN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P.O. Box 388 Forked River, New Jersey 08731 Gentleman; i
Subject:
Systematic Assessment of Licensee Performance (SALP)
The NRC Region I SALP Board conducted a review on April 19, 1983 to assess the performance of activities associated with the Oystar Creek Nuclear Generating Station. The results of this assessment are documented in the enclosed SALP Board Report. A meeting has been scheduled for 1:00 p.m.,
May 12, 1983, at the station to provide a forum for candid discussions re-lating to the performance assessment.
You also should be prepared to discuss any plans to improve perfomance.
Any coments you have regarding the board report may be discussed at this l meeting. Additionally, you are requested to provide written coments within 20 days of the meeting.
Following the meeting and receipt of your written coments, the enclosed I report, your rt.sponse, and a sumary of our findings and planned actions .
will. be placed in the NRC Public Document Rocr.i.
l l
Your cooperation is appreciated. '
Sincerely,
[
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, Richar . Starostec 1, SALP Board Chaiman Director, Division of Project and Resident Programs
Enclosure:
As Stated
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, GPU Nuclear Corporation '
APR 2 91983 Enclosure 3 cc w/ enclosure:
- P. Clark Executive Vice President. GPU Nuclear Corporation
! NRC Resident Inspector l
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Enclosure 4 GPU Huclear y gg P.O. Box 388 ,
Forked River. New Jersey 08731 609 693-6000 Writer's Direct Dial Number.
June 17, 1983 Mr. Richard W. Starostecki, SAIP Board Chairman Director, Division of Prnject and Resident Programs f U. S. Nuclear Regulatory Commission Region I i 631 Park Avenue
- l King of Prussia, PA 19406
Dear Mr. Starostecki:
Subj ect: Oyster Creek Nuclear Generating Station Doeket No. 50-219 Systematic Assessment of Licensee Performance (SALP) i Your letter of April 29, 1983, provided the results of the SALP Board's essessment. In response to your letter and the follow-up meeting of May 12, 1983, ,
where discussions took place regarding the assessment, we submit the following comments in the areas of Plant Operations, Maintenance, and Surveillances.
PLANT OPERATIONS l
l Three areas identified in the assessment of Plant Operations warrant comments in i crder to provide additional information regardin8 our progress to date. j As identified in dhe assessment, there did exist a backlog of items needing Plant j Operations Review Committee (PORC) attention. The backlog was in fact due to the ;
i large number of modifications scheduled for the refueling outage and our procedure t upgrade program. That backlog has now been eliminated. I With regard to control of design changes and modifications, the assessment pointed l cut that we were undergoing a major reorganization in the Maintenance and Construction and Technical Func tions Divisions; and as a result, the necessary l interfaces between various corporate divisions and the plant staf f had not been formalized in administrative procedures. Management attention in this area snabled us to formalize the controls necessary prior to the start of our refueling ou tag e. The procedural systems are now in place and functioning. .
Wa recognized in early 1982 that our radiochemistry program needed upgrading. At that time we catablished both short and long tern goals to upgrade our program and the goals we established for 1982, were realized. Significa nt technical expertise '
hcs been added to our staf f and operational chemistry functions have been transferred to our Plant Operations Department. In addition, technical expertise v ey'c&10
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.s Enclosure 4 Mr. Ri chard W. St a ro st e cki, Page 2 SAU Board Chairman and assistance from corporate headquarters is now being integrated into our progra m. A Chemistry technician training program is now in ef fect which includes o minimum of 240 hours0.00278 days <br />0.0667 hours <br />3.968254e-4 weeks <br />9.132e-5 months <br /> / year of formal training. New laboratory equipment has been purchased and a new laboratory will be constructed during this current outage.
Negotiations are currently underway with the Union (IBEW) to upgrade entry level requirements for Chemistry Technicians as well as annual requalification for Chemistry. Te chnicians. Continued improvements during 1983 will be realized.
MAINTENANCE W2 believe we have obtained our maintenance goals and objectives set forth in our !
SALP response of last year. The major reorganization of our Maintenance and Construction Division has been e!!ected which resulted in firmly establishing our i Work Management System for corrective maintenace and all modification work.
There is a need to improve the quality of work and knowledge of our maintenance i' psrsonnel, and our ef forts will be directed in this area. We intend to upgrade our training programs with more emphasis on work related activities. A training conter for maintenance personnel is nearing completion which will allow a greater portion of time to be devoted to hands on training rather than just lectures. In cddition, our second line supervisors will take an active part in the training pro ce s s . Training conducted by our most experienced personnel on plant spe cific equipment will lessen the amount of rework now required.
I SURVEILLANCES The assessment states, "Procedural inadequacies during the Integrated Leak Rate Test resulted in a valving error that caused radioactive contamination of a l portion of the reactor building service air system." The statement is incorrect ,
in that it was not a valving error, but a design er' ror which caused contamination ,
l of the service air system. i !
With regard to the intergrated leak rate test, the procedural deficiencies noted i in the assessment have been corrected by thorough procedure review and revisions. !
In addition, our Startup and Test Department will assist in the next integrated Isak rate test which is scheduled prior to startup f rom our current outage. I The administrative control procedure for the IST program was approved in January {
of 1983 and became ef fective in February. i i
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w Enclosure 4
. . Mr. Ri chard W. St a ro st e cki, p g, 3 SAL" Board Chairman Dialogue provided by the SALP process enables both the NRC and the Licensee to better focus on those areas in need of management attention. If there are any questions regarding our comments please contact me or Mr. Michael Laggart of my staf f at (609) 971-4643.
Very truly yours, 7 _ IV Peter B. Fiedler Vice President and Director Oyster Creek PBF:jal ec: NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731 i
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Enclosure 3 i
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, . Jul 101964 llo. 50-219 GPU leuclear Corporation ATTN: lir. P. 8. Fleider Vice President and Director Oyster Creek Nuclear Generating Station P. O. Box 388 ]
Forked River, New Jersey 08731 :
Gentlemen:
Subject:
Systematic Assessment of Licensee Performarce (SALP); Report No. 50-219/84-19 The IEC Region I SALP Board has reviewed and evaluated the performance activities of the Oyster Creek Nuclear Generating Station for the period Februa y 1,1983 to April 31,1984. The results are contained in the enclosed report dated June 21, 1984. A meeting to discuss this assessment has been tentatively scheduled for July 16, 1984. The meeting will be held in Forked River, New Jersey near the plant.
The SALP Board concluded that satisfactory or higher levels of performance occurred in all functional areas. It was noted that steady or improved performance had oc-curred in functional areas with the exception of Security, Outage Technical Support (special assessment area), and Licensing. In the Security area performance had substantia 11y degraded during the first half of the assessment period. However, improvement was noted in the second half af ter staf fing changes we-e implemented.
With regard to the Outage Technical Support and Licessing assessments, although satisfactory performance was assessed, we are concerned with corporate engineering support provided to the plant in that a number of problems associated with design control, engineering support, and timeliness of responses were noted. Stellar problems were noted in the earlier assessment for Three Island Unit No. 1. If uncorrected, these problems could potentially lead to a further degradation in your overall performance. You should be prepared to discuss your efforts to in-prove the corporate engineering support functions at the meeting.
We had noted improved performance in your 1983 emergency drill over the previous year's drill. However,.we do not believe this improving trend was continued into the May 10,1984 drill . Although this latest drill is outside the assessment period, we would like you to be prepared to discuss any improvements you plan for future drills.
The meeting is intended to be a dialogue wherein any comments you may have regard-ing our report may be discussed. Written responses addressing the above areas are requested within 30 days of the meeting.
a ,=
OFFICIAL RECORD COPY 50-2195 ALP 84 - 0001.0.0 06/07/84 i
,'l
i JUL 10154 I GPU Nuclear Corporation 2 l f
Your cooperation is gpreciated.
i Sincerely,
- 03M WI 4.
- .ed Re g Richard W. Starostecki, SALP Board Chairman Olvision of Project and Resident Programs
Enclosure:
As Stated cc w/ enc 15: .
BWR Licensing S Aager Licensing Manacer, Oyster Creek Public Document Room (POR)
Local Public Document Roor I'.PDR)
Nuclear Safety Informatie- - ter (NSIC)
NRC Resident Inspector State of New Jersey bec w/ enc 1:
Region I Docket Room (with concurrences)
Senior Operations Officer (wie encis)
DPRP Section Chief SALP Board Members hRC Resident Inspector, TMI-;
1 RI:DPRP PRP RI:
Cowg!11/meo ner Star st ki 6/15/84 g ]
OFFICIAL RECORD COPY 50-2195YLP84-0001.1.0 06/07/84
\
O Report No. 50-219/84-19 U. S. NUCLEAR REGULATORY C0 m IS$10N REGION I SYSTEMATIC ASSESSMENT OF LICEt4SEE PERFORMANCE GPU NUCLEAR CORPORATION
'v5TER CREEK NUCLEAR GENERATING STATION JUNE 21, 1984 l
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4 TABLE OF CONTENTS PAGE 1.0 I n t rod uc t i o n . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . !! !~
2.0 S umma ry o f R e s u l t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 3.0 Criteria.......................................................... 5 4.0 P e r f o rse n c e As41 y s i s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 41 21 ant Operations..... ...................................... 6 4.2 Radiologfcal Controls........................................ 9 4.3 Ma i r. t e n a ec e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12 4.4 S u ri e 1 1 1 a n c e . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14 4.5 Fi re Pretection . . . . . . . . ............ ...................... 15 4.6 E me r g e n e , P r e p a r e d n e s s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16 4.7 S ecu r i ty a n d S a f e g u a rd s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 4.8 O u ta g e T ec h n i c a l S u p p o r t . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 4.9 Li ce n s i ng Ac t i v i t i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 0 5.0 S u p po rt i n g Da ta a n d t amma r i e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 5.1 Licensee, Event Report Tabulation and Causa? Analysi s. . . . . . . . 21 5.2 Investigation Activities.................................... 21 5.3 E scal a tec En f orcement Acti v i ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21 5.4 Managemeet Conferences During the Assessment Period. . . . . . . . . 22 TABLES Table 1 -
Tabula- Li sting of LERs by Functional Area. . . . . . . . . . . . . . . . 23 Table 2 -
LER S unna ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 4 Table 3 -
Violations...................................... .. ...... 26 Table 4 - In s pe cti o n Hou r s S umma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 7 Table 5 -
Inspecti on Report Ac ti vi ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28 Table 6 -
En f o rceme n t Da te . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 31 o
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1.0 INTRODUCTION
1.1 Purpose and Overvie_w The Systematic Assessment of Licensee Performance (SALP) is an inte-grated NR; staff effort to collect the available observations on an
! annual basis and evaluate licensee performance based on those observa-I tions with the objectives of improving the NRC Regulatory Program and l Licensee performance.
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The assessment period is February 1,1953 to April 30, 1984.
1.2 SALP Board Members: R. Starostecki, Director, Division of Project and Resident Programs +
R. Vollmer, Directer, Division of Engineering, NRR R. Bellamy, Chief, Radiological Protection Eranch, Division of Engireering and Technical Programs.
S. Ebneter, Chief. Engineering Programs Branch, Division of Engireering and Technical Programs.
J. Joyner, Chief, haclear Materials and Safeguards Branch, DETP F. Miraglia, Assistant Director for Safety Assessment, Division of Licensing, NRR J. Lombarco, Licersing Project Manager, Operating Reactor Branch No. 5, Division of Licensing, Office of NRR E. Conner, Section Chief, Section 3B, Division of Project and Resicent Programs C. Cowgill, Senior Resident Inspector, Oyster Creek Nuclear Generating Station.
I Other Attencees:
J. Wechselberger, Resident Inspector, Oyster Creek Nuclear Generating Station.
1.3 Background
(1) Licensee Activities j At the beginning of the assessment period, the f acility was oper-ating at 239 MWe with load limitec by core reactivity. The reat-tor was shutdown February 12, 1983 for the plannec 1983 refueling and maintenance outage and has remained shutdown for this outage during the entire assessment period.
During the outage, 75 major modifications were scheduled for ac-complishment. As of the end of the evaluation ceriod, over $000 individual maintenance activities have been completed. Some of the significant modifications and repair activities completed were:
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- Repair of cracks in recirculation valve discs;
- Recirculation pu-o seal replacement;
- Feedwater systee valve repairs;
- Reactor Protection System HFA relay replacement;
- Scram discharge volume modifications;
- lestallation of plant computer and emergency response f acility data system;
- Construction of si t e buildino for Technical Support Center;
- Torus modificati:ns and painting;
- Installation of : cst accident sampling system and chemistry laboratory espansien;
- Intermediate range monitor range expansion (10 ranges);
- Addition of new cable spreading room; and
- Turbine inspection.
The litersee inspect or- of the : ore spray sparger and vessel annu-i lus was completed in
- arch 1933. The reactor re:irculation picing was completed during tne month of July 1983. No cracking identified in either system.
The licensee satisfactorily completed an annual emergency plan exercise on May 24, 1933. The esercise was observed by a Region I inspection team.
On June 6,1983, an uausual event was declared when a chlorine leak occurred in the plant's chlorination system. The leak was isolated in eleven minutes. Tne unusual event was terminated following the satisfactory accountacility of station personnel.
l A fire occurred in the step down transformer for substation bus "A" l on November 14, 1983. This resulted in a complete loss of off site powe r. The fire brigade and local fire companies responded. The potential transformer was replaced and the electric plant was placed l
in a normal shutdown lineup.
i An Intermediate Range Monitor (IRM) dry tube was discovered to be cracked in February. Aoditional inspection found a total of 8 dry tubes (71RM and 1 SRM) to be cracked. The facility has formulated replacement plans to be conducted prior to restart.
Twenty-seven crack in ications have been found in the condensate and steam lines outsice the dyrwell for the two isolation conden-sers. An inspection of the piping was conducted Dy the licensee as a result of discovering a leak in a condensate line during a syster hydrostatic test. The licensee repair plans include pipe replacement and weld overlaying. These repairs will be completed prior to plant restart.
3 (2) Inspection Activities A Senior Resident Inspector was assigned to the site for the entire assessment period. A second Resident Inspector was on site from February 1 to September 1, 1983 and since January 1, 1984.
Two team inspections were performed during the evaluation period, One team reviewed licensee actions in response to two consultant reports (BETA and RHR) and the 1992 INPO evaluation. A second team evaluated readiness for operations following the long refueling and maintenan:e outage. This team reviewed the modification process used to control outage work.
The total hRC Regior I inspection hours (resident and region-based) for this assessment sciod is 3,643 hours0.00744 days <br />0.179 hours <br />0.00106 weeks <br />2.446615e-4 months <br />.
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. 4 2.0 5lM4ARY OF RESULTS I
OYSTER CREEK NUCLEAR GENERATI C STATION FUNCTIONAL AREAS CATEZRY CATE W Y CATEGORY I 2 3
- 1. Plant Operations and Outage Ccetrol I
- 2. Radiological Controls
- Radiation Protection
- Radioactive haste Manageeent
- Transportation
- Ef fluent Control and Moritoring
- 3. Maintenance X
- 4. Surveillance (inclucing lesenice and Preeperationa' Testing) a
- 5. Fire Protection anc houseseecing X
- 6. Emergency Prepareoness X
- 7. Security and Safeguards X
- 8. Outage Technical Support X
- 9. Licensing Activities X Overall Assessmen_t This assessment is based on licensee pe-formance during an extended refueling and modification outage. Major efforts were expanded by t:e licensee to upgrade plant equipment as well as perform modificatica.s te plant systems. During the outage, about 75 modifications and over 5000 co rective maintenance items were performed j in addition to required testing and inspection. Many nonroutine evolutions were
, ) performed and evaluation of these evolutions showed involvement by all site or-
! cally competent manner.
I In the area of Design Control a number of interface problems between the licensee and contract architect engineers were identified tnat had the potential for final designs to be inadequate. Additionally, constructability eviews during design needs improvement.
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Overall, the licensee is devoting constoerable resources to improve performance l ; in all areas evaluated. Continuea sanagement attention to icentifying and cor-
' I recting weaknesses is apparent. Managecent convr.itment to safety is evident f rom
, j commitment to training and high reparc for st*ingent p-ccedural adnerence.
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5 3.0 CRITEkla The following performance aspects were reviewed in each area:
Management involvement in assuring quality.
Resolving technical issues from a safety viewpoint
- Responsiveness to NRC initiatives.
- Enforcement history.
- Reporting and analysis of reportable eserts.
- Staf fing (including management).
- Training ef fectiveness and qualificatica.
To provide a consistent evaluation of lice-see performance, attr butes relat-ing each aspect to the characteristics of "ategory 1, 2, and 3 performance were applied as discussed in NRC Han.al Cta:ter 0516, Part 11 and Table 1.
The SA'D
. Roard conclusions were categorize: as follows: ,
C.ategory 1: 9 educed NRC attention may be arcropriate. Licensee management attention and involvement are aggressive a9: oriented to*ard nuclear safety; licensee rescueces are atole and effectively used such that a high level of performance witn respect to operatioral sc'et) i s being acnieved.
Category 2: NRC attention should be maintaired at normai levels. Licensee
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management attention and involvement in na:Iear safety are ?vident; licensee resources are adequate and reasonably ef fe:tive sucn that satisf actory per-formance with respect to operational safets is being achieved.
Ca,teg0r) 3: Both NRC and licensee attentice should be increased. Licensee management attention or involvement is acce: table and consioers nuclear safety, but weaknesses are evident; licenset resources appear strained or not effectively used such that minimally satisfactory perforr.ance with re-spect to operational safety is Deing achievec.
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. 6 4.0 PERFORMANCE ANALYS15 4.1 PlantOperationsardOutageControl(2y.J This assessment is basec on inspection of piant operation a:tivities by the resident 1.spe: tors anc region based inspectors. The inspectors re-viewed complian:e with techaical specification requirements, training requirements, cuality assurance audits. corre:tive action systems, safety review comrittee actions, and reportirg system cortrols.
Management cortrol of the outage t,hroug30ut this assessnient has been very good. There was co-tinued evidence of manageeent involve-e-t in cally plant activities 'n:lucing caily conteci rocs tours by operatiers anc support group manacers, daily meetings involiing operations, maintenance, and engineerirg decaetment represertatives, and publicatio cf clanned a:tivities (t ee cay periods). Obse .atier f shif t tu nc.ers inoicate:
tnat even duri g re-iods of relatively los c:erational acti,'ty snif t turnovers were sn:-:,agn. cccorenensive an: professional. A: itionally, site quality assvar:e reviewed all ongoing a:tivities in t9e cperations areas.
The licensee u s we'l established policies g:<erning plant operations.
These policies were wicely cistributed and generally well vacerstood by plant operators ar: supervisors. Managecents approach to a:tivities was generally conservative and strongly safety criented. '
Control of outage activities was enhanced by the issuance of a daily plan of activities and close cuoroination of the various departments a:tivities by a caily ostage meeting. Senior management involvement was evider.t in this precess through the ap:roval of all daily activity plans.
Altnough overall control of activities was a:ceptable there were sigri-ficant interfa:e probless early in the outage including, ir some cases, inadecuate jot plarning. Coordiration improved as the outage progressed but interf acing between departments co-tinued to be one of the most significant o6tage problees. However, no resultant safety problems were identified.
Many operatior.al 4:tivities conducted during the assessment period were in support of sajoe outage activities. In 00st cases, these activities wre nonroutine and were governed by soecial procedures written speci-fically for stat a:tivity. Exa ples irclude reactor vessel craining and refilling, anc refue'ing the reactor vessel e 'h the suppressier pool empty. The procecue es were conservative, ha: received thor:vgr manage-ment review aed rec.f ree the performan:e cf cerio:ic manage ert checks at critical stages. The licensee performed a fonsal refuelirg certifi-cation prior te start of rea: tor vessei refueling. The inseector's re-view cf this certif t:ation showeo it t? be comprenensive arc properly reviewec by tN licenst- g
7 Control of refueling activities has been good. Core off load was ob-served by the NRC and procedures were judged tc be comprehensive and conservative. The inspector observed good supervisory control. Obser-vations of new fuel inspections showed that persons performing the in-spections were thoruugh, knowledgeable and conservative. One problex l associated with fuel movement occurred when a fuel bundle was dropped ,
a few feet to the bottom of the fuel storage pool rack. Licensee cor- '
rective actions included placing a camera on the fueling grapple to ir-sure proper latching of the bundles. The inspection of fuel loading activities showed that personnel were well trainec and properly super-vised.
Tne licensee's response to abnormal conditions has been excellent. Early in the assessment period a chiorine leak resultec ir ceclaration of ar unusual event. Operator and station management response was prompt and thorough. In November. tring a less of of f site po er, the licensee's response decorstrated fir sa'ety orientation and senior management involvement in site problems.
The Plant Operations Review Conmittee has been effective in reviewing safety issues. During the previous assessment period, a large backlog of items needing review was identified. The litersee augmented the re-view committee and conducted cally reviews until the backlog was recuted.
Recent changes to the technical specificat ons i have changed the review process and should help reduce future problems in this area. An adt.1-tional technical specification change, involving the requirement to re-view temporary procedure changes within 14 days will reavire continued licensee attention since cignificartly more time than this has been re-quired in some cases.
Licensee prosedural control is acceptable. Inspector reviews showec that procedures are generally technically adequate and are capable of being performed as written. Scee triceouacies have been identified by both licensee and hRC inspections involving missing valves in system valve checkoff lists. The missing valves were principally vent and drain
<alves. The licensee had, prior to NRC identification vf the above problem, initiated a complete review of plant systems to verify accu-racy of system ccmponents and drawings. This program includes verifying
. its built conditions for both rechanical and electrical systems and the-w erecting system checkoff lists. The program is scheduled to be com-pleted by February 1955. One problem remains with regard to .entral control and accountability of temporary changes to procedures. Currert p*ocedures recuire that a log of te:nporary e.*aages that are also to be made a permanent change be maint4 iced in the control room. The ins;ec-tcr found no sethod of assuring that such temporary changes are cair-teined in a central location. Management attention to solve this prob-let was requested at tne exit reeting.
Si'.e En'g'ineering suoport was well organi:ed anc aceovately staffes.
E:sineering recuests, f ron otner groups were p ioriti:ed anc tracked.
8 The inspector found that engineering eval .ations were thorough and in most cases timely. Corporate plant engineering interf aces appear ade-quate but still require more coordinatioe. The technical content of Ltcensee Event Reports (LER) continues te be excellent with good narra-tive descriptions, documentation of cause oescriptions, and root cause dete rmina tion s . Corrective actions are c:asidered appropriate and well described. Timeliness of LER's continues to be a probler. A number of LE4s have been subettted late and in som+ :ases, entende: periods of time pats before the decisio- is made that ar -.ent is reportaole. Manage-ment attention to improve timeliness is re:essary.
Site training programs for general escloyee access, operator training ano er.gineering personnel were well esta:iished programs. The licensee excended consicerable ef f ort to upgrade a'l of the above programs. In particular site engineering personnel r(:eived sigrificant system train-ing. Also, operator recua'ificatior tra - ag has been utgraded as a
-esult of the poor resu'ts achieved on t - rost recent 1*:ensee annual requalification examination.
Operator training for initial NRC license + examinations has improved with 13 of 15 candidates for RO or SRC 1 :emses passing caring the re-porting period. NR examiners have bee especially impressed with some SRO candicate performances on oral exam.1 ations. Teese examples demon-strate streng management support and atte-tion to trainirg and qualifi-
' Cation.
Stamary During this assessment period, continued improvemert has been observed in management control ana review of operations function and site train-ing activities. Substantial improvement Pas been r:ted in the cheeistry area. Control of teeperary changes and timeliness of cvent reporting continues to be a problem.
Conclusion Category 1 Board Recommendations l Owe to the length of the current outage, tSe Board recot ends aug*f.nt inspection coverage during plant startup. Maintair 16 b:gr ccverage foe about 4 weeks after f t3rtup. Reture to r:real coverage af ter that time.
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4.2 Radiological Controls (9'.)
There were seven routine inspect'ons by radiation protection specialists during the assessment period. The Resident Inspectors on a continuing basis reviewed selected program areas. Two severity V violations were identifie0. one in effigent eenitoring and one involving transportation.
A contin.,trg trend of imprcver+nt in the overall radiation safety pro-gram was noted this period. Significant improvements have been noted in plant chemistry.
i 4.2.1 Radiatfor Pretection The licensees perforinan:e during the refueling outage has been
- comencable. For irstan
- es, the use of a specially cesigned
. containments to enclose conta'ninated ccmpoaents on the refuel-irg ficor greatly ivoroved cc trinatiot control alle.ing ac-g cess into this a ea in street :lotaes. A training pregram has Deen develope: fcr workers wn:, install these containments as
- well as for persenrel wne work inside the enclosures. Similar uses of containments during roatine operation has allowed a grac;al redu
- tior cf the savare foctage of contaminated area in the plant.
1 Cl canagers witnin the Raciological Controls (RC) Department
- a e permanent GPUN employees. Contractor oersonnel are used f or a limited nutbee of technician ano technician supervisor positions. Jo
- descriptions aad delineation of responsibili-I ties is clear. The organization has been stable with minimal turnover and no recrgani:ation. Within the RC Department the j responsiveness to hRC iritiatives has been prompt and thorough.
l The Operational Health Physics technicians play a key role in the control of work during the outage. Their excellent per-i l fomance is the resalt of extensive training and qualification l
provided on tne site. Each technician must complete a pro-gram that is similar to a licensed position, i.e., classroom instruction, practical f actors, written exams, oral exams and j esperience pre equisites.
I Radiological engineering reviews all "unusual incioents" (In-ternal report of events involving radiological controls ). Each l l Incident repe-t resslution receives senior level management Concurrence. E"f trCement of radiological controls is strict l and violatic 5 usua'ly result in strong disciplinary action.
j ine inspectors founc that the training of Support Technicians, tn'>se whc perform w ole oody counts, issue dosimetry, and test l j re s::' ra tc r users, was n:t forr:alized. Tne licensee nas susse-l csertly ce.E'; ped a program a d standarci:ed it throsghout the l l GLU\ system.
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10 Several minor problers were neted with radiation protection procedures, inese findings were considered to be isolated and not indicative of a prog ammatic problems.
4.2.2 Radioactive Wage Nnagement Examination of the licensee's plans for implementation of land
- disposal of rc3ioactive waste regulation 5 indicat(d that the licensee has a clear understa* ding of the recuirements of the new regulatory requirements (
- 0 CFR 61). The licensees im-pienentation was timely and t+chnically sound.
4.2.3 Transportation
' The licensee has implemented a strong radioactive transport management organization. Pro:edures clearly define rescensi-bilities anc a.,thorities of tee Nnager-Rad aste Operations
' and the Rac=&ste Shipping Sucervisor. In aadition, tne re-sponsibilities of other support groups are specified.
One transportation violation was identified involving failure
' to verify that the drain line and accesh plugs of a shipping cask were appropriately pluggec and sealed prior to transport.
The licensee ime; ate!y obta'ned confirmation that the pack-age drain line and access plugs had been in compliance and implemented coerective actions to assure that future snipments
- would be in compliance. This violation was not constoered indicative of programmatic defects.
A defined program of comprehersive training to key personnel involved in the transfer, packaging and transport of radioac-I tivt material is implemented as required. The review of the program indicates that the licensee is implementing a gener-ally adequate and effective Radioactive Transportation Program.
4.2.4 Ef fluent Monitoring and Contrels Compared to the last assessmert, the radio chemistry program has significantly improved. A new chemistry manager has been onsite for the entire evaluaticn period. Several additional persons have been added to the chemistry staff that have sig-nificant experience in radio chemistry. Daring this period, the licensee has revised all reocedures and adoed internal laboratory QC controls. Significant improvements have been made in chemistry training an: qualification. The licensee is constructing a new chemistry laboratory that should be in operation by 0:.taber 1, 1984 On a quarterly basis, chemis-try management now internally audits its own program in addi-tion to the ncrmal Quality Assurance division audits.
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On two occaW.ns, required umpling was not performed due to g the controlling procedure f#iling to identify all Technical
\ Specification required analyses. This was juriged to be an i isotated instance in an otherwise excellent program. There were five Licensee Event Reports (LER) concerning failure of the Starccy Gas Treatment System ($GTS). Two failures were the resi.lt of design deficiency, ore involved broken equipment,
' orie involved improper post-maintenance testing and one failure inv;1ved a trip of one train of the SGTS sample pump while the otbe- train was inoperable. Increaso$ attentior should be i given to the overall integrity of the SGTS.
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An LER was issued to report a January 19B3 mq1 function of a Chentcal Waste Storage Tark level instrumentation which caused i
an onmonitored release of radioac'.tve water outside the New l
Rac.aste Builcing. Tre corrective actions', inc?uding periodic
- test ng, seer adequate to prevent recorrence(
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3 An ceerall irorovement in the management of the raa' wane area j inckdtng che .istry was observed. New personnel have been hirec to fill vacancies. There is adecuate staff with clearly d.W eeated responsibilities, hecessary data was available for
,' eva ation of the program. Corrective actions, where necessary,
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were timely and acceptable. This was also observed in the l
i tra':Dertatic'. area during the November inspection. The lic-s e. net is attecating to incrove the program ant: correct deft-CiefCles.
Conciusion lI
', Cate;ory 1 Bosed Recommeeda_tions
! ; Following restart from the current refueling ouuge, return i to routine inspection. ,
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-! 12 4.3 Maintenance ($
Inspection of mainter.ance activities caring the outage consists of re-
\ views by the resideats primarily of Inspection, overhaul and general i\- improvement of the plant. Two specialtst inspections reviewed mainten-3 ance activities when the refueling outage wat just beginning. In addi-i tion, this area was reviewed daring a team inspection late in the evalu-4 tion period.
l Maintenance at Oyster Creek is performed by the Maintenance and Con-
} struction (hi&C) Division which reports to a vice president at the cor-8 po ate office. All maintenan:e person el report to that division. Main-tenance is requested by tre Plant Division and reviewed for necessity and consistency by the piant Materiel cepartment. This provices plant i operations oriented revie., a: proval, anc control of maintenance acti-vities and schedules. The organi:stic al structure with its many inter-3 faces requires close cocrdination betweer plant c;erations, plant engi-neering and maintenance and o nstructio.. Wntle some improvements have been made to improve con unications at the organizational interfaces, continual improvement in this area is secessary.
Administrative controls over esintenan:e were well established anc con-
, tain provisions for prio itiration deoe".cing on the activities cot. plex-ity and urgency. Priorities were init illy assignec by the initiator but j were reviewed by both Flant Operation, and Plant Materiel management.
This assures proper pricriti:ation and planning. In addition, the lic-
, ensee establish" a pro:edure for performance ana control of urgent work,
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10entified during of f-normal nours. Daily maetings we e conducted during i
the current refueling outage with both maintenance and representatives from all site organizations to coordinate activities. These meetings r
Jppear to be beneficial in keeping management appraised of on going work. Procurement of safety related equips.ent was well controlled and documented. One minor wichtion regarding chemistry resins was identi-Vied but is not conside&O indicative of a program breakdown. Although procurement is acceptable, po current component level quality classifi-cation list exists. A licensee group has been formed to resolve this probles. Continued management attention in this area was evident by the numerous levels of review by both plant engineering and quality assur-ance.
Preventive maintenance (PM) is controlled by a separate group within Plan +. Materiel Department. Actinistrative controls are well defined and nrovide acceptable controls for the conduct of the program. The program is scheduled on troth a yearly a :: weekly basis. NRC review identified that the schedules are come etwnsive, reviewed frequently, and accurately reflect the status of tw PM program. Checklists were i technically accurate and periodically c dated to reflect new informa-t tion. PM tasks were performec by a decicated group of technicians ro-tated periodically detai'ed from the KLC Department. One area associ-ated with preventive maintenance requires some increased attention
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When performing presentive mair tenance work when engineering evaluation was required, plant engireering work requests were initiated to obtain that information, kR' obsersations indicate trat once the information was requested, there was litt!e followup by plant materiel to ensure timely response. This needs continued management attention.
There was evidence of routine involvement by OA in maintenance activities througn po".t mainterarce quaIity reviews, quality control holc and wit-ness points of wor 6 ir progeess, quality assuri. ace department observa-tions of various mairtenance activities.
The Piant Materiel Ocpa-ttent reviews all comp'eted r.aintenance work packages and has begun a treet analysis progran. An initial review was performec by electrical maintenr.9ce. Their ren'ew was thorouga and had substantive recornme cations fcr improvements. .NRC review incicates that recomendations eac been app epriately ar ed u::n. This was resitive e* ice 9:e Of litersets aggress:ve approach to 5::ving problems. Further tuprovemerts will b+ mace whc the review process is expanced to fDeChan-ical systems, inc re a s i9; serior nanagement in.alverrent in the recom-eended corrective a:tions is expected.
Five LER's, associated 'th eit..rical breaker raintenance prcelems, appear to be a tclative. hign riumaer for this ' unction. This cata in-cicates tne need fc- ad' ;ioral licensee attention in this area. An-other LER involved 'denti'ication of problems m'th torque switch sett' ings on limitcrque salves. Tris problem, identified by licensee per-sonrel, was based c infervration t eceived at a raintenance conf erence.
Identification of tris peoDi m demonstrates sot.r.d technical analysis
, and aggressive corrective a .. Additionally, the licensee has in-formed other uti . ities of in. Istentially generic nature of tne problem prior to issuance cf NR.C docie. .s. \
. Conclusion I '
Category 2 i
Board Recommendatic-s hone.
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l 4.4 Surveillance Q5'.)
This assessment is based on inspections of the surveillance program by the resident inspectors and by region based inspectors (four inspections of 151 activities).
The licensee cc strc'.s the routine surveillance test program through is- l suance of annual master surveillance test sched. ales. They have admini- !
strative controls in place to modify surveillance tests as required by plant conditions and changes to Technical Specifications. Management <
involvement in review of both test schedules and test results is evident. I During this mluation period, one problem was identified regarding ac- '
ceptance criteria for a fire pure. Licensee manacement used this oppor- ;
tunity to review all surveillance tests to ensve technical aceauacy and l compliance with Technical Spe:ifications. The inspector found surveil- I lance procedures t :hnically adecuate, tests coacucted on tir'? and re-suits receive procer reviews. The plant engineering :taf f, responsible for maintaining status of co. :lete surveillances, fell oehind in record kee;ing. This was corrected by reassigning reviews and increasing senior management review. Additionally, the licensea foresees signifi-cant improvements when the plan to computerize the surveillance test program is completed.
Successful accomplishment of the leak rate testing prograrr had been a problem in the previous assessment. Tnspector review during this perled indicates significant improvecent. Observations indicate that test procedures have been reviewed anc upgraded and the personnel performing tests were knowledgeable of test requirements. Review of the completed test results was per formed timely and thoroughly.
Management oversight of the Inservice Inspection and Inservice Test pro-grams appears strong. Administrative controls were found to be well developed including scheduli.,g of activities and assigning proper au-thority and responsibility for program accomplishments. Appropriate feedback mechanisms were in in place to monitor program performance.
Appropriate QA interf aces were evident and technician training was good.
During this outage, significant inservice testing and inspection has been conducted as discussed further in Section 4.8.
Conclusion Category 1 (ardRecommendation None.
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1 4.5 Fire Protection and Housekeeping (2_.5*.)
The assessment of performance in the fire protection and housekeeping areas are based on inspections by the resident inspectors.
Site fire protection activities are supervised by a full-tin'e assigned i indivicaal with responsibility fcr overall program accomplishment. A
- dedicated staff is assigned to tenduct preventhe maintenance and sur-l veillance testing Of fire fightirg equip,ent to er.sure centralized con-trol of these activities.
The licensee has established a comprehensive fire protection training progra n. A review of this progran identified implementation problems re-garding lecture attendance and timely makeup of missed lectures by the fire brigade mecers. Licensee corrective action for this problem in-cluded requiring all brigade pernnnel to attenc scheduled or makeup lect. es cnd to take eraminations to ensure that training was acequate.
! There has been ceasicerable effort by both NRC and the licensee to at-l 1 teept to resolve issues involvec with fire protection regulations (10 CFR 50, Appendix 4). Currectly, the licensee has requested 19 technical
, exemptuns and 13 sche 0Jlar exemptions to these requirements. These requests are presently under review by NRR.
( The lichisee has continuer exe-t sign 11icant mcnagement atter. tion to
- ! housekeeping during this a. e ssment period with the plant in a major l! refueling and modifica 'on o.tage. Routine tours are made bv senior station management to mentify ard correct housekeeping problems. When
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conditions became degraded, canacement has taken aggressive action to
- improve housekeeping including one occasion when all outage related work i was stopped for three days to perfortn plant cleanup. Although continued i emphasis is placed on housekeeping, general worker attitude .n this area 1 reeains somewhat low.
Radiological housekeeping was viewed to be adequatc considering the ac-tivity in the plant. Continued attention to contamination control is evidenced by the ef ferts to decor.taminate areas as soon as practicable af ter completion of activities causing the area contamination. There remains certain contaminatec and high radiation areas that require con-tinued attention.
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1 16 4.6 Emergency Preparedness (18*.)
Analysis in this area is based on observation of the Annual Dercise by I the NRC team, three followup inspections by region based ins:ectors, and observations of plant trainir.g exercises by tre resident instectors.
During the annual exercise on May 10, 1933, the licensee dem:-strated adequate capability to perforin a complicated simulated plant emergency.
Although NRC observation of this esercise idertified that a 5.bstantial
! improvement was made over the 1932 exercise, a number of def ciencies o
' (most of wnicn were also icentified by t'.e licensee) were ncied in oper-etional assessment, training, scenario preparation, informat on flow, dose assessmeat, 4nd radiation protecticn evaluation. Conti'aed senior level management attention to emergency planning is evident tr. that a
' full time manager is assigned at the site with sufficient sta'f support.
Licensee maintains a tnree se: tion emergency response otati: anc con-ducts ceriodic shi't and site drilis to maintain personnel p ficiency 4 between annual exercises. During this evaluation period, spe:ific
, j training was conducted for senior level unage-s in accident assessment.
1 The energency plan and proceda es continue to be adequate. '.icensee has put forth a large ef fort.to resised emergen:y proceaures to stream-
- j line them. One example is a rocesed shif t of classificatio of emer-
' gency to sym;: tom based approach to conferrt witt emerger:y operating procedures used by Operations Department perse- el.
A nunber of items remain open (principally asse:iated with L:st Accident
)! ' Sampling Systems) f rom the energency appraisal conducted in ~anuary, 1982. Licensee progress towards correction of the remaining items is sa ti s f actory. During this assessment, the licensee cocr.itte: to c.7m-plete the post-accident sampling system prior to October of 1984 Ad-l ditionally, a new Technical Support Center is Deing constructed and will I be available about September 1,1954.
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The improved performance noted in 1983 over tFe 1982 drill was not con-tinued in the licensee's performancc of the May 10, 1964 e x e-c i se . Al-though outside this assessment period, deficiencies in commu-ication, EOF environmental data coordinatier and presertation, and 11:ensee/ex-j ternal agency interfaces were noted.
Conclu_sion Category 2 Boa rd .(ecomenda t io_n 1
None.
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.' 17 i
4.7 Securit>andSafegua+s(1.5'.)
One regional physical g-otection nsee: tion and r:stine residert inspec-tions du-ing the first ralf of the assessment perted identifiec a total of sia p ysical securit3 violatiets (i :luding oae Severity Level 111 violatio- for which a s'vil penalty was assessed). The violat' ors and 1
cther de.iations reflected a lac 6 o* a:ecuate ma agement attertion to impleme tation of se:ur'ty progra* re:.irements a c first line suservi-sory pe 'orrance. Tne reed f or "creasec ma9 age +r.t attentior. :: ore-paratior for the maj0r n:dificatSr. 4: refueling cutage work cas: led with a adeginal audit /s. veillante p-o;-am in the physical setw .ty area may have contributec te the progru 's oegracatio . An enforceme ; con-ference was held in April 1933 tc ciscwr s the prcblem. The lice see's correcti.e actior:, =*.ict inclodec a e: gani:atic+ of onsite a-d cor-porate se:urity manage. Tent to ef fect *;-e direct management in.:'vetent in the r-ogram and a- i roved Qxiity assurance a. iting prog a- it the
' securit) a ca, was reci:t anc aprea-s t- base Dee effective. Sussecuent routine -esicent ins;ections anc a reg cnal physt:ai security nspection
- icentifiec no violat ters durteg t e se
- ca.d half c' the assessme .t period.
However, a deviatio t r:- the lice .see's consitme-t to correct oae of I
the pre. ous violaticns by July I's3 r .as cited ir August 1983, ine cor-rective action was comp'eted late- that month.
The t asainq and qualification Or:gra resulted ir a satisfactc y level of job haowledge and ac*erence tc cro:edures in m:st cases. It is well definec 490 carried out by cedicatec gersonnel. The security fo :e staf fin; level was acec. ate throLr.nout the perioc, especially consider-ing the i9 crease in the rormal wt-k force as a result of the 0.tage.
The posit ion of $1te Se:urity Surerv'so*, which 6.ac been fillec in about l
.tanaary 1953, was lef t sacant in July 1983 by the ceath of the in:um-bent. T*.e position was again fil'ed tr Septembe 1983 by a ve y qual-
]
d'ied and esperienced irdividaal. This is indicative of the li:ensee's resolve to irprove the' perf ormatce ir this area.
I Analyses and reperting cf ever.ts are complete anc prompt as are correc-teve act+ons. Sever. event reports were submittee during the assessment
< p'ri od .
Corclusion Categor) 2 Board R*:o-egnd,atio s 1
40'.e .
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1 IB 4.3 OutageTechnicalSuppoltj.24*.)
Assessment in this area is based on region based and reside-t inscector review of outage work and a tsar. inspection of the licensee's modifica-tion process, performed at the end of the assetsment period.
During this outage, significa t inservice testing and irscectien has been conducted. Licer.see managete't atten'. inn in this peograr was evicert as demonstrated by corporate recsalification of all cortract cerscnnel used to perform testing and use of liceesee personnel tc su:<rvise and perform final reviews of test cata. The overall perforra ce of irservice
- testing was satisfactory.
The licensee performed NDE testing on recirculation syste c'cing for intergranular stress corrosio* cracking. During Region ' re.'en of tnis testieg, a number of problems with licensee's pletting a*d e.aluatior of test data was found. Additio' 411y, tne testing was re t ao+.;uate to ceterrine whetner any crackir; was preser.t. Af ter conversat: ens and reetings between NRC and Seni:r Manageren., the licensee f.erfcemed ad-dittoSal data evaluation and testing. ho crack indications were iden-tified during tnese activities. Late in the period, sirilar NCE testing on isolation condenser piping was performed. WRC revie. cf test results
- identified substantial improve ent in data reduction anc ev.s.ation.
! Major modifications were made during the outage te ungrac. 57.n design and meet new regulatory requirements. Several modificatier > zh as i coeplete replacement of all cce. trol rooe alarm panels were rstallec to I
aic operator performance. NR* review of ' t?enste control c' the modi-fication process has shown a conservative approach tc the .esolution of technical issues. Administrative controls associated w'th eccification, corsteaction, testing, and plant staff acceptance are good.
l The licensee's system for implementation of plarned modifications is a$eauate. Modifications installation is performed under the control of Maintenance and Construction Olvision (M&C). Significant pcetions of the work is then performed by contract organizations. Appreoriate QC hold and witness points are irserted in installation proced. es and quality assurance observation of activities in progress are routinely observed. Inspector observations did, however, identify probiens asso-l ciated with construction in the areas of procecare change comtrol, weld-ing, and hanger installation associated with Appendia J anc Scras Dis-chan ge Volume Modifications. Licensee resolution of these coscerns is not complete at the end of tris assessment period.
Altnoagh general control of tae modification process has been acceptable, a nuncer of problems associated with design cortrol of modifications has beer. osserved. The licensee's Technical runctions Division 945 rot al-I ways advised contractor architect engireers of changes to p-ce:se modi-fications being designed by t-e contractor. TF+ s led to scoe inadecuate review of oesign changes. In scoe cases enanges were race t: cortractor
. - . - - - _ - - - -r .._. . . . - _ . _ _ _ _ _ _ - . . . _ , _ . , , , . _ _ _ . _ _ _ , . . , , _ , ... _ ,_,_ _ _ , _ =_.__ ___., ~ ..,.. _ __ ______ -__.-. _ _. .
19 design packages without review by the original designer. The licensee initiated a review by corporate QA, at NRC request, to oetermine if out- l age modifications meet design criteria. The results of this review will I be evaluated by W;C Region I in the near future. Additionally, during '
installation, several modifications required a significant number of design changes. Exa ples included Appendix J modifications and the scram discharge volume modifications. Ir ore cases, a task force was formed to review and solve associated problems with installation. TF ?se prob-lems, in many cases were the result of poor constructability reviews b)
Technical Functio-s. Additionally, the licensee did not have a limit on the number of cesign changes that could be made prior to revising the original design occurent. Although no installation errces have been identified as a result, the potential for installation errors exists.
Con:lusion .
Category 2 Bpard Recommendations The licensee shon id be requested to address the interf a:e problems that exist between the licensee and contract engineers pe.foer.ing design work.
Inspection of foIIowup corrective actions should be plarned. g
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20 4.9 Licensing Evaluation in this area is based on review of the licensee's activities in the area of methodology and Cycle 10 reload, Radiological Effluent Technical Speci fications (RE'S), Core $5. . v Effectiveness, NUREG-3737 responses, Systematic Evaluation Prtsrar (SEF), fire protection review, valve operability, and equipment c alificatien.
The licensee's performance and sar.agenert carabilities were generally adequate. The licensee and his cc-tractors uve dem:9strated good work-ing knowledge of regulatory regaieeeents ano exceliert levels of tech-nical competen:e. Management atte-tion anc irvolvemert with specific matters of safety is evident, liceesee reso6*ces are acequate although staf fing in various areas should be imp-oved, and satisfa: tory perfor-sance with respect to operational safety is being achieved.
While the liceesee provides generally soJnd aed accertable rescit. tion to the licensing issues, f recue9t entensions of time are requirec. Con-siderable NRC ef fort and repeated su:cittals are neeced to adecuately cover the mata-ial to be reviewed. The time'iness of responses was poor with two or tr. ee month time delay in resporses being the norm. These probless were especially noted in submittals for SEP, RETS, NUREG-0737 TS, and fire protection topics.
Conclusion Category 2 Board Recommendations The licensee should be requested te address tre adequacy of the corporate engineering suoport providec to t?w plant it regards to the content and timeliness of licensing submittals. An adverse trend has been noted, particularly in the areas of SEP and fire prctection topics.
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21 P
5,0 SUPPORTING DATA AND SU*. ARIES 5.1 Licensee Evert Reports Tabular Listing Licensee Event Reports Type of Events:
A. Personnel Errer 5 B. Desi gn /Ma n./ Con st . /In s t al l . 7 C. External Cause 0 D. Defective Frocedure 2 E. Componer.t Failure 6 X. Other __7 TOTAL 27 Licensee Event keports Revie ea: 83-01 through 63-26 and 64-01, 02 and 05 excluding Security Event Reoorts.
Causal Analysis:
Four sets cf com on mode events were identified:
- a. LER's 83-7. 83-15, 83-25 and 83-26 toentified events in which incorre:t or inadecuate ;rccedures cortributed to the event.
- b. LER's 83-10, 83-12, and E3-14 involvec cesign deficiencies. Two LER's icentified deficiencies with the standby 3as treatment sys-tee,
- c. LER's 2' t, 83-8, 83-15, 83-20 and 84-2 involved electrical breaker mainten; e problems.
- d. LER's S3-6, 83-7, 63-13, 93-11, and 83-14 pertained to the standby gas treatment system. These can be further classified as follows; 2 LER's involved design deficiencies and 2 LER's involved sensing Ifne failures. The relatively large runber of problems identified in standoy gas treatment may indicate the need for a complete sys-tes review.
5.2 Investigatter Activities:
hoce.
5.3 Escalated En'ecce eat Actie s:
- a. Civil Penalties - (83-07) 543,000: for s'olations of the physical se:urity plar..
- b. Orders: None.
22
- c. Confirmatory Action Letters: None
5.4 danagementConferences
Enforcement meeting - 4/18/83: regarding physical security plan violations.
SALP seetir.g (5/12/83): meeting to discuss Cycle 2 SALP performance.
,re--eew--+-s-- , ww .e--
23 .
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1 TABLE 1 1
TABULAR LISTING _Of LERs BY FUNCTIONAL AREA E
OYSTER CR_E_EK NILEAR GENERATING STATION AREA NUMBER /CAUSE CODE TOTAL Fra t Operation and Outage Control 2A IB-~ 2E 5 Radiological Controls 10 1 Maintenance 2A IB IE 3X 7 S.rve111ance 3B ID 2E 4X 10 Fire Protection Energency Preparedness Security and S.feguards Ostage Technica Surnort 1A IB 2 L' censing Activities Other IB IE 2 Total 27 Cause Codes: A - Personnel Crror 8 - Design, Manufacturing, Construction or Installation Error C - External Cause D - Defective Protecares E - Component Failure X - Other l
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24 TABLE 2 LER SUyMARY OYSTER CDEEK FEBRRARY 1, 1953 to APRIL 30, 1954 LER NUw3ER
SUMMARY
DES?RIDT:'N 83-03/03L During the perferrance of maintenance on two "A" control rod drive pump, a vent line was broken. This resulted in tne wet-down cf a core spray camp and the inadvertent tripping of the "B" c:ntrol rod dris e pump. Tne "E" pump was immediately restarted.
83-04/03L Cent-ci rod drive pump circuit breaker failure to operate.
83-05/03L Three high drywell pressure switenes tripped at a value greater tnan specified.
83-06/03L Low flow switch for standby g&s treatment system fan failed preventing system valves from closing.
i 83-07/03L Standby gas system declared inoperable due to plugging of HEPA filter. Identified during surveillance testing.
83-07/03X-1 Subsequent evaluation of LER 83-07/03L revealed an improperly I
installed pitot tube on flow sensing line.
l 83-08/03L Core spray booster pump was found to be inoperable due to installation of an incorrect undervoltage trip coil.
83-09/01T Main steam isolation valves A and B failed to meet local irak rate test acceptance criteria.
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83-10/01T Discovery of a design deficiency in the standby gas treatment I system which prevented inlet and outlet valves from closing l when the fan breaker is racked out.
83-11/03L Standby gas treatment system flow switch failed due to a damaged sensing line.
83-12/01T Violation of secondary containment due to trunnion room door being open identified during refueling surveillance check-off.
83-13/01T Violation of secondary containment due to both doors of a reactor building personnel access airlock being open forssp-proxirately 30 seconds.
mm --wr' ---e - --
25 LER NtMBER
SUMMARY
DESCRIPTION 83-14/01T Discovery of a design deficiency in the standby gas treatrent systes. Heating coils for both trains supplied power from same emergency bus.
83-15/03L Failure of a reactor building cicsed cocling water circuit b*eaker due tc improper performance of maintenance which in-capacitated ar undervoltage trip device.
83-16 Not issued.
83-17/OlP Destgr. deficiercy in both diesel generator timing relays.
83-18/03L Rea: tor buildirg isolation valve failed to close due to air operator dirt blockage.
83-19/03L Reactor builoing isolation valve failed to close due to air operator pisto.. break.
83-20/03L Failure of service water pump circuit breakee due to a burr on the trip latch.
83-21/03L Failure of power feed from emergency diesel geperator due to ground fault or power feed.
83-22/03L Two mechanical snubbers found to be inoperable during :esting.
C3-23 Not issued.
83-24/01T Limitorque motor operator torque switch settings below orig-inal settings.
83-25/03L Six maintenance and two surveillance procedures did not i specify verifying excess flow cFeck valves open.
l 83-26/01T Fuel pool cooling heat exchancers no longer meet seismic re-quirveents due to addition of lead for shielding.84-001 Diesel fuel oil level less than technical specification re-cuired level.84-002 Failure of circuit breaker undervoltage trip devices.84-005 A through-wall cract was discovered on the isolation conden-ser piping during a system hydrostatic test.
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26 TAS. E 3 V:0LATIONS (21/83-1/30/84)
OYSTERCREEKNUCLEARGENEi3TINGSTATION A. Number and Severi_tylevel t of Violations
- 1. Severity Level Severity Level I C Severity Level II O Severity Level III 1 Severity Level IV 13 Severity Level V _5 TOTAL 19 B. Violations vs. Fu9ttleral Area Severity Levels FUNCTIONAL AREAS I I'l f i f -~~ IV~~ V Plant Operations s Radiological Controls 2 Maintenance 1 Surveillance 1 1 Fire Protection 1 Emergency Preparedness Security and Safeguards 1 6 1 Refueling Outage 4 1 Licensing Activities , __ _
TO'ALS 1 13 5 TOTAL VIOLATIONS: 19 s.
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'l TABLE 4 INSPECTION HOURS SU*%RY (2/1/83-4/30/84)
OYSTER CREEK NUCLEAR GE%ERATING STATIOk HOURS i 0.E_T!ME Plant Operations 757 21 Radiological Controls 325 9 Maintenance 307 9 Survelliance 535 ;5 Fire Protection /dousekeeping 90 2.5 Emergency Preparedness 640 5 Security and Safeguards .
59 1.5 Refueling 933 24 Licensing No data available TCTAL 3646
28 TABLE _5 INSPECTION REPORT ACTIVITIES OYSTCR CREEK NUCLEAR GENERATING STATION REPORT NO. AND INSPECTION DATES INSFEC'OR AREA l'.5PECTED 83-03 2/7/83-2/18/83 Specia ist Energer:y Preparedness Items 83-04 2/1/83-3/7/83 Residerts Routine Resioent Inspe: tion 83-05 2/14-18,3'l-4, 3/24,3/28,1983 Specialist ISI Activities 83-06 2/22/83-Z/25/83 Specalist Maintenance, surveillance calibration activi-ties.
83-07 3/14/83-3/17/83 Specialist Se:urity Plan and Implee.enting Procedares 83-08 3/8/83-4/4/83 Residerts Routine Resident Inspection 83-09 3/16/83-3/18/83 Specialist Public Prompt Notification System 83-10 4/6/83-4/8/83 Specialist Implementation of radiation protection program ;
83-11 4/5/83-5/2/83 Resident Routine Resident Inspection 83-12 4/18/83 Specialist Enforcement Conference Physical Security Pro-gram l 83-13
! 5/11/83-5/12/83 Specialist Design review of plant shielding l
l 83-14 5/3/83-6/8/83 Residents Routine Resioent Inspection t
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29 REPORT NO. AND INSPECT!0h DATES INSPECTOR AREAS __!.NSPECTED 83-15 5/23/83-5/25/83 NRC Team and Emergency Preparedness Inspection Residents 83-16 8/23/83-8/26/83 Specialist Secu 'ty System Power Supply / Training' Security 83-17 6/9/83-7/13/83 Resioents Routine Resident Inspection 83-18 7/11/83-7/15/83 Speciali st Effluent control and Radioactive Waste program 83-19 7/12/83-7/15/83 Specialist Stress corrosion cracking and welding activi-ties 83-20 7/14/83-8/17/83 Residents Routine Resident Inspection 83-21 7/19,25,26/83 Specialist Ultrasonic data during weld examinations 83-22 8/18/83-9/21/83 Residents Routine Resident Inspection 83-23 9/22/83-11/7/83 Resident Routine Resident Inspection 83-24 10/12,17-21,27/83 Specialist Review of QA Program, QC Sury, drawings, pro-cedures, instructions and work observ.
t 83-25
. 10/17/83-10/21/83 Specialist Licensee's radiation protection and effluent control program 83-26 11/7/83-12/31/81 Resident Routire Resident Inspection 83-27 11/29/83-12/2/83 Specialist Trans. activities - radioactive waste mgmt programs 83-28 12/12-15/83 Specialist Racioactive waste prograe
30 REPORT NO. AND INSPECTION DATES INSPECT 0$ AREASINSDEC'Ep 84-01 1/1-1/13/84 Resident Routine 84-02 1/16-20/84 Specialist Licensee's radiation protectier program.
84-03 2/1-3/15/84 Resident Routine 84- 04 2/7-10/84 Specialist Licensee's irservice inspection program.
84-05 2/2;-24/83 Specialist Emergency pre:areaness items 84-06 3/12-16/84 Resident / Licensee's crganization and program implemen-Specialist tation in maintenance, training and procedu-(RHR/ BETA ral controls.
. Tena Inspec) 84-07 3/9-10/84 Specialist / Inspection of acti.ities associated with torus Resident shell thickress 84-08 3/7/84 Specialist Radiological control incident review.
84-09 3/26-30/S4; 4/2-3/84 Residents / Readiness Assessment Team Inspection of sodi-l Specialist fications, evaluating the design, construc-tion / installation, inspection, testing and acceptance for operation modifications.
84-10 3/16-4/30/84 Resider.t/ Routine resicent inspection and specialist Specialist review of isolation condenser cracks.
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31 TABLE 6 ENFORCEMENT DATA OYSTER CREEK NUCLEAR GENERATING STATION INSPECTION NUMBER SUBJECT REQ. SEV. AREA 83-04 Failure tc X-ray or physically search Provisional IV 7 hand carrier package brought through operating a protected .rea cortal. license DPR-16 83-04 Failure to ersure continuous surveil- Tech Spec IV 7 of an escorted person. 6.8.1 83-04 Failure to ensure material int.ortant 10CFR50 IV 3 to safety and traceable quality assur-ance doewaentation.
83-07 Failure to notify the commission of a Accepted III 7 change tc the security pl& ; failure Security to maintain an effective protected area Plan barrier; failure to record intrusion a l a rm s .-
83-07 Failure to observe an isolationzone Accepted IV 7 with CCTV Security Plan 83-07 Failure to guard and control access to Accepted IV 7 vital areas. Security Plan 83-07 Failure to maintain a protected area Accepted V 7 barrier height. Security Plan.
83-08 Violation of physical security plan. Provisional IV 7 operating license DPR-16.
83-20 Failure of an individual to properly Tech. Spec V 2 use protective clothing. 6.8.1 1
st
)
l 32 INSPECTION NUMBER SUBJECT REQ. SEV. AREA 83-20 Violation of physical security plar Provi sional IV 7 operating license DPR-16 83-23 Failure to provide hourly fire watch Te:h Spec IV 5 while the fire door between tne diesel generator bays were fouled.
83-24 Failure to translate design basis items 100FR50 V 8 into specifications, crawings, proce-dures and instructions.
83-25 Failure to analy:e a monthly liouid Tech Spec V 4 effluent discharge catch for tritium. 4.6.B.2.C 83-26 Failure of a surveillance procedure to Tech Spec IV 4 to identify the development of an in- 6.6.1 adequate pump head pressure.
83-27 Failure to verify drain line and access 100FR71.12 V 2 s
plugs were properly sealed prior to transport.
84-09 Failure to review design chai.ge rompen- 10CFR50 IV 8 surate with original design; f ailure to APP B incorporate design changes anc regula-tery requirements into specification, drawings, procedures and instructions.
84-09 Failure to prescribe and accomplish 100FR50 IV 8 quality installations. APP B 84-09 Failurt to adequately control design 10CFR50 IV 8 inforestion. APP B 84-09 Failure of QC inspections to verify 10CFR50 IV 8 conformance of construction activities. APD B D.EVIATION 83-16 Failure to meet a commitment to the commission concerning physical security.
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s iso UNITED STATES p
+ ug\ NUCLEAR REGUL.ATOHY COMMISslON g
7j nEoiou i 431 PARK AVENUE g
d, KING OF PRUS$1 A, PENNSYLV ANI A 19404 !
JUN 161982 ,
Docket No. 50-219 GPU Nuclear Corporation MTH: Mr. P. R. Clark l Vice President - Nuclear l 100 Interpace Parkway Parsippany, New Jersey 07054 Gentlemen:
l
Subject:
SystematicAssessmentofLicenseePerformance(SALP)and <
Management Meeting 50-219/82-12 ;
This refers to the SALP for the Oyster Creek Nuclear Generating Station, conducted by this office on March 29, 1982 and discussed with you and your I staff at the subject meeting on April 16, 1982. The report of our meeting is attached as Enclosure 1. The NRC Region I SALP Report is attached as Enclosure 2 and covers the period November 1,1980 - October 31, 1981. Your letter dated May 6,1982;which we requested provided coments and comitments for perfonnance improvements and is attached as Enclosure 3.
Overall, we find that your perfonnance of licensed activities generally is acceptable and directed toward safe facility operation. Your perfonnance in l
i the areas of maintenance and surveillance was found to be in need of increased NRC and GPU Nuclear Corporation management attention. .
In our meeting of April 16, we discussed our assessment of your regulatory j perfonnence in these areas, yourcomments on the SALP Program and assessment, I
and the actions that you are taking to improve your perfonnance. We have also l
reviewed your letter of May 6, and detennined that your actions to improve per-fonnance in these amas needing attention are responsive. We consider that our meeting was beneficial and improved mutual understanding of your activities and our regulatory program. Based on your coninents during our meeting and your May 6 htter, we have found that no changes to our assessment are necessary and therefore we have not supplemented our report. We have, however, made minor editorial and typographical corrections that did not affect our assess-ment or conclusions. In addition, we made the corrections in evalue. tion sections 1 (Plant Operations) and 6 (Emergency Preparedness) conceming the title of the Nuclear Assurance Department Operations Support Program and the installation dates for the Public Notification System sirens, which you bmught to our attention in your May 6, 1982 letter.
enD e edt^
Wyio 4.4.f / GO 1
F dPU Nuclear Corporation JUN 161982 As Region I does not presently control the issuance of Technical Specification changes, your request that these changes become effective 30 days after receipt by the licensee, rather than upon date of issuance, has been brought to the attention of Oyster Creek Licensing Project Manager in the Office of Nuclear Reactor Regulation, Division of Licensing.
In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures will be placed in the NRC Public Document Room. No reply to this letter is required. Your actions in response to the NRC Systematic Assessment of Licensee l Perfonnance will be reviewed during future inspections of your licensed activities.
Your cooperation is appreciated.
Sincerely, l
I 0, y,: o l Ronald C. Haynes l
Regional Administrator j
Enclosures:
- 1. NRC Region I Meeting Report 50-219/82-12
- 2. NRC Region I Systematic Assessment of Licensee Perfonnance, Oyster Creek Nuclear Generatin 29,1982
- 3. GPU Nuclear Corporation Letter, P. R. Clark (g Station, MarchGPU) to R. C. Haynes (NRC Region I), Response to Systematic Assessment of Liceneee Perfonnance, May 6,1982 l
I cc w/ enc 1:
1 M. Laggart, Licensing Supervisor i J. Knubel, BWR Licensing Manager
- Local Public Document Room l
l Public Document Room (PDR) (LPDR) (
Nuclear Safety Infonnation Center NSIC)
NRC Resident Inspector l State of New Jersey i bec w/ enc 1:
l Region I Docket Room (with concurrences)
Chief, Operational Support Section (w/o encis)
L. Tripp R. Xeimig l
' DPRP Re R.
R.L.C. Spessar Lewis,Direc dDirector{or D$RP,gionIIRebVTP ion III J. E. Gagliard Region IV IEol l J. L. Crews, D rector,Acting director, Region, V DRRRP&EP, J Lombardo, D J.d/
D dent Sites A _yster / Creek LPM, NRR ^^
1
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. ENCLOSUcE 1 U.S. NUCLEAR REGULAT0hY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-219/82-12 Docket No. 50-219 ,
License No. DPR-16 Priority -- Category --
Licensee: GPU Nuclear Corporation P.O. Box 388 Forked River, New Jersey i
Facility Name: Oyster Creek Nuclear Generating Station Meeting at: Forked River, New Jersey
( l Meeting conducted: April 16, 1982 NRC Personnel: em J' fu "
i U. AC.Jhom@ Resident 4f)spector date signed Approved by: #<.4A< # -
$~ ds'//2 -
l L. Mrip6) Chief, Reac%r Projects date signed !'
l Section 2A i Meeting Sumary:
l Meeting on April 16, 1982 (Meeting Report No. 50-219/82-12)_
l Scope: Special management meeting to discuss the results of the NRC Region I I
assessment of the licensee's perfonnance from November 1,1980 to October 31, 1981, as part of the NRC's Systematic Assessment of Licensee Perfonnance (SALP) :
program. Areas addressed included: Plant Operations, Radiological Controls, !
Maintenance, Surveillance, Fire Protection, Emergency Preparedness, Security and Safeguards, Refueling, and Licensing activities. i Results: A sumary of the NRC licensee perfonnance assessment was presented. No new enforcement actions were identified. i 1
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. l s DETAILS
- 1. Licensee Attendees H. Budaj, Manager, Special Projects J. Carroll, Jr. , Director, Station Operations i, P. Clark, Executive Vice President R. Fenton, Supervisor Emergency Preparedness K. Fickeissen, Plant Engineering Director '
P. Fiedler Vice President and Director, Oyster Creek J. Frew, Plant Maintenance D. Gaines, Manager, Plant Administration ;
W. Garvey, Manager, Plant Administration D. Grace, Manager, Oyster Creek Engineering Projects D. Klucsik, Comunications I, J. Knubel, BWR Licensing Manager M. Laggart, Licensing Supervisor !
i J. Maloney, Manager, Plant Maintenance R. Markowski, Site Audit Manager J. Riggar, Security Supervisor J. Sullivan, Jr., Plant Operations Director +
C. Tracy, Manager, Quality Assurance, Mod / Ops ,
D. Turner, Manager, Radiological Controls
- 2. MRC Attendees J. Allan, Deputy Regional Adninistrator, Region I C. Cowgill, Senior Resident Inspector, Peach Bottom R. Keimig, Chief, Reactor Projects Branch 2, Division of Project and Resident Programs, Regfon I r J. Lombardo, Licensing Project Manager, NRR .
I R. Starostecki, Director, Division of Project and Resident Programs, (DPRP), Region I J. Thomas, Resident Inspector, Oyster Creek .
L. Tripp, Chief, Reactor Projects Section 2A, DPRP ;
- 3. Discussion A brief summary of the Systematic Assessment of Licensee Perfomance (SALP) '
program was presented to explain the basis and purpose of the program. ;
The NRC Region I assessment was discussed, including the assessment period, evaluation topics and methods, and assessment results. The itcensee dis-cussed actions taken and planned to continue perfomance improvements and address weaknesses.
The SALP assessment report and your May 6, 1982 letter which we requested in
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our April 7,1982 letter in response to that report is also enclosed with '
this transmittal. .
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ENCLOSURE 2 U. S. NUCLEAR REGULATORY COMMISSION I REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE GPU NUCLEAR CORPORATION OYSTER CREEK NUCLEAR GENERATING STATION March 29, 1982 I
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i TABLE OF CONTENTS l
Page j I. Introduction 1 II. Summary of Results 4 III. Criteria 5 IV. Performance Analysis 6
- 1. Plant Operations 6
- 2. Radiological Controls 8
- 3. Maintenance 9
- 4. Surveillance 11
- 5. Fire Protection 12
- 6. Emergency Preparedness 13
- 7. Security and Safeguards 14
- 8. Refueling 15
- 9. Licensing Activities 17 V. Supporting Data and Summaries 18 -
- 1. Licensee Event Report Tabulation and Causal Analysis 18
- 2. Investigation Activities 19
- 3. Escalated Enforcement Actions 19
- 4. Managemer.1 Conferences During the Assessment Period 20 TABLES Table 1 - Tabular Listing of LERs by Functional Area 21 Table 2 - LER Synopsis 22 i
Table 3 - Inspection Hours Summary 28 i
Table 4 - Inspection Activities 29 72o14 5 - Violations: Severity Levels and Functional Areas 31 l
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I. INTRODUCTION 5l
- a. Purpose and Overview l The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect the available observations on an annual basis and evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and Licensee performance.
The assessment period is Novem'oer 1,1980 through October'31,1981. ,
This assessment, however, contains pertinent observationt and NRC and licensee activities through thrch,1982. Future assdssment' periods will be adjusted to provide mnre timely NRC assessment and ,
I reporting.
i The prior SALP assessment period was August 1,1979 - July 31,1980. !
Significant findings of that assessment and the period between that assessment and thi!, assessment, are provided in the applicable Performance Analysis Functional Areas (Section IV). l l
Evaluation criteria used during this assessment are discussed in l Sedicn III below. Each criterion was applied using the "Attributes l' for Assessment of Licensee Performance" contained in NRC Manual Chapter 0516. i i
- b. SALP Attendees: R. W. I Starostecki, Director, Division of Project and Resident Programs J. H. Joyner, Chief, Technical Programs Branch, j Oivision of Engineering and Technical Programs ',
W. G. Martin, Chief, Operations Support Section, Division of Emergency Preparedness and 0 s Operational Support R.'R. Keimig, Chief, Reactor Projects Branch Not2, Division of Pro',ect and Resident Programs l L. E. Tripp, Chief, Reactnr Projects Section ik. !
l 2A, Division of Project and Resident Prcgras i i J. J. Lombardo, Licensing Project Manager, '
l Operating Reactors Branch No. 5, NRR l J. A. Tht' mas, Resident Inspector, Oyster Creek l Nuclear Generating Station l
Other NRC Attendees: E. J. Bri.nner, Chief, Reactor Projects Branch Oivision of Project and Resident No.
Prca,r 1,kms C. J. Cowgill, Senior Resident Inspector, Peach Bottom Atrmic Power Station s L t
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- c. Background (1) Licensee Activities ;
At the beginning of the assessment period, the facility was l operating at about 95 percent power having 4 tarted up from a
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l seven-month-long major refueling outage on July 19, 1980.
Plant output was limited by maximum differential pressure across the condensate demineralizers. The licensee was unable i to perform the needed de:Vneralizer regenerations because of the inability to process De resulting radioactive liquid waste.
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The plant was shut down on November 21, 1980 to repair a leaking feedwater heater and a feedwater systed check valve. Power operation was resumed on December 12, 1980, but at a reduced capacity due to condensate demineralizer differentidi pressure considerations. Power was further reduced later in the month to remove some demineralizers frous service to perform regenerations.
Full power was achieved on January 26, 1981.
f Power wap reduced periodically during February, 1981 to repair circulating water intake screens and salt water leaks in the main condensers. Power was limited to about 90 percent in ,
March'due to demineralizer capacity. A five day shutdown began on March 12, 1981 to repair steam leaks in the condenser bay and condenser salt water leaks. A seven day shutdown began on March 28, 1981 when primary system leak rate increased due to a leaking recirculation pump seal and a leaking drywell air ,
cooler.
Power operation resumed on April 2,\1981, but power was reduced to about 70 percent when a feedwater, heater string was removed from service due to heater leaks.
A scheduled maintenance shutdown b9gan on April 17, 1981 and lasted until May 28, 1981. The maintenance included general plant maintenance, feedwater heater repairs, installation of i environmentally qualified limitohtue ' valve operators in the drywell, and modifications to c.sma% ment isolation valve r control circuits.
During rettart 6n May 29, the reactor tripped on low water level caused by a bypass valve transient. Restart was accomplished the following day but full power was not achieved until June 11, 1981 because of condenser salt water leaks.
Power was reduced on June 18 due to inability to maintain condenser vacuum. It was further reduced on J v e 23 when a feedwater heater string was removed from servica for leak (
repairs. The plat
- tripped on June 26, 1961 due to low condenser i
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vacuum and was restarted on June 30 after repairs to the steatr,$
jet air ejector system.
Throughout the month of July the plant operated at reduced power due to degraded condenser vacuum. A shutdown began on August 11, 1981 to correct an increasing primary leak rate and to investigate the degraded vacuum condition. Startup was delayed by sudden tube failures in two of three shutdown cooling heat exchangers on August 26 and 27, 1981. The plant remained in cold shutdown using alternate means of decay heat removal until restart on October 15, 1981.
The plant tripped on October 19, 1981 when a main steam is'olation valve was inadvertently closed during surveillance testing.
- Restart was accomplished on October 19 but a shutdown was initiated on October 21, 1981 when a ec,duit, attached to the outside wai- of the reactor building, collapsed breaking several instrument control cables and causing closure of the off gas isolation valve. Restart was conducted on October 22 but another shutdown began on October 30 to repair a leaking manway I l cover on a main steam system reheater, ,
l Restart was commenced on November 2, but full power was not '
achieved until November 11, 1981 due to malfunctions of the !
j Traversing Incore probe system. i On December 9, 1981, the facility was shut down to repair ,
limitorque valve operators damaged by a practice of "backseating" l the valves to stop packing leaks. Startup has been delayed by l bearing failures in the reactor water cleanup system auxiliary l pump, control rod drive hydraulic pump failures, diesel generator l air cooler tube leaks, and main steam isolation valve leaks.
l The plant remains in cold shutdown pending satisfactory completion of primary containment integrated leak tests.
(2) h m etion Activities l l Oric NRC resident inspector was onsite for the entire appraisal !
period.
l Total NRC Inspection Hours: 2062 (Resident and region based).
Distribution of inspection hours is shown on Table 3.
A tabulation of inspection activities is shown in Table 4, and i a tabulation of vio'.ations is shown in Table 5.
One inspection was conducted by the State of Nevada resident inspector at the Beatty waste burial site.
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4 II.
SUMMARY
OF RESULTS OYSTER CREEK NUCLEAR GENERATING STATION FUNCTIONAL AREAS CATEGORY CATEGORY CATEGORY 1 2 3
- 1. Plant Operations X
- 2. Radiological Controls .
o Radiation Protection o Radioactive Waste Management o Transportation o Effluent Control and Monitoring X
- 3. Maintenance X
- 4. Surveillance (Including Inservice and Preoperational Testing) X l
S. Fire Protection and Housekeeping X l
- 7. Security & Safeguards X 1
- 8. Refueling X f
- 9. Licensing Activities X i
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III. CRITERIA The following evaluation criteria were applied to each functional area: '
- 1. Management involvement in assuring quality.
- 2. Approach to resolution of technical issues from a safety standpoint.
- 3. Responsiveness to NRC initiatives.
- 4. Enforcement history.
- 5. Reporting and analysis of reportable events.
- 6. Staffing (including management).
- 7. Training effectiveness and qualification.
To provide consistent evaluation of licensee performance, attributes associated with each criterion and describing the characteristics applicable ,
to Category 1, 2, and 3 performance were applied as discussed in NRC Manual Chapter 0516, Part II and Table 1. ,
j The SALP Board conclusions were categorized as folicws:
Category 1:
Reduced NRC attention may be appropriate. Licensee management I attention and involvement are aggressive and oriented toward nuclear l safety; licensee resources are ample and effectively used such that a ,
high level of performance with respect to operational safety or construction is being achieved. -
Category 2: NRC attention should be maintained at normal levels. Licensee l management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or i' construction is being achieved.
Category 3: Both NRC and licensee attention should be increased. Licensee l management attention or involvement is acceptable and considers nuclear ;
safety, but weaknesses are evident; licensee resources appeared strained or not effectively used such that minimally satisfactory performance with respect to operational safety and construction is being achieved R
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IV. PERFORMANCE ANALYSIS plant Operations i 1.
During the previous assessment period, (August 1, 1979 - July 31, 1980), several violations were identified involving procedural inadequacies, inadequate mechanisms for issuance of management instructions, and failure to follow procedures. Of particular importance was an incident involving failure to remove control rod interlock bypass jumpers prior to completion of control cell fuel reload. Programmatic weaknesses were identified in the area of i adherence to management controls procedures at the lower management and supervisory levels, and in the area of meeting commitments to t the NRC. An improving trend was noted as licensee management responded l in a positive manner to address the identified weaknesses.
This area was under continuing review by the resident inspector for '
the current (November 1, 1980 - October 31,1981) assessment period.
Twelve operations related violations were identified. Failure to follow procedures resulted in four Severity Level V violations.
Inadequacies in the area of administrative controls resulted in one Severity Level V violation when PORC meeting reports were not properly ;
distributed, and two Severity Level VI violations involving failure to properly review or revise operating and surveillance procedures.
t Two Severity Leve.1 IV violations were identified involving failure '
to recognize a containment integrity violation when an isolation valve failed during testing, and recurrent violations of technical specifications when containment spray compartment water tight doors were left open. Failure to report an unplanned radioactive release l and inadequate corrective action on recurrent spills of radioactive liquid resulted in two Severity Level IV violations. One Severity Level II violation involving vacuum breaker blockage was indicative i of inadequate controls over activities affecting plant operations, I l and sometimes inadequate tours of the plant by operations personnel. l Thirty-two licensee event reports were related to the operations -
area. Reports were generally timely and accurately identified the causes and corrective actions needed.
Improvements have been noted in management involvement in this area.
The licensee has implemented an Operations Support Program. The .
l program involves the assignment of an Assistant to the Plant Operations Director, Shift Assistants, and members of the Nuclear Assurance Division who are tasked with reviewing plant operations and making .
l recommendations for improvement in the areas of procedural adequacy, [
- procedural adherence, and control of activities that have an impact l on operations. Also, corporate management has issued policy statements .
! stressing verbatim compliance with operating procedures and has l begun vigorously enforcing the policy.
( l This orogram ha: resulted in many improved procedures, improved w l l
l procedural adherence, improved operator awareness and understanding I
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7 of plant activities, improved followup of operations identified maintenance concerns, and improved operator morale. The program has relieved some management and supervisory personnel of administrative i burdens, allowing more timely and thorough reviews of activities.
The development of a "programs and controls" group has improved the scheduling and prioritization of work activities and the coordination between maintenance and operations.
Some problems still exist wi+1 cc;rator knowledge of regulatory requirements. These probleas are evidenced by.the following: ,
(1) Failure to recognize malfunction of a TIP in-shield limit switch as a degradation of containment integrity. ,
(2) Failure to recognize failure of a reactor building ventilation isolation valve as a degradation of containment integrity.
(3) Interpretation of exceeding a peaking factor limit during a ,
power transient as a "Safety Limit Violation." ;
Licensee corrective and preventive actions have been generally acceptable and indicative of a responsiveness to NRC concerns, i
Conclusion -
Category 2 Board Recommendations -
None 8
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- 2. Radiological Controls The previous assessment period identified several areas of major concern. Programmatic problems included inadequate staffing, use of personnel not meeting ANSI N18.1-1971 standards, procedures inconsistent with Technical Specifications, and poor control in the area of ;
transportation of radioactive waste. Nineteen violations were identified and one civil penalty was assessed for inadequate radiation I work permit procedures. An improving trend was noted in the latter '
part of the assessment period when action was taken to upgrade the radiation protection training program, increase the size and quality of the radiation protection staff, and implement organizational changes to put direct management attention in the areas of radwaste l operations and shipping.
During the current assessment period, four inspections were performed by region based inspectors in the area of radiological controls.
One included a review of the radwaste management program and two included review of effluent monitoring and control. In addition, one regional office evaluation of a State of Nevada burial site inspection, and one investigation of NAC-1E shipping cask event were conducted. Selected activities in this area were under continuous review by the resident inspector. Six violations, two Severity /^
Level III's associated with radioactive waste transportation, two I Severity Level IV's associated with control of high radiation area access, and two Severity Level V's associated with dosimetry issue procedures and control of procedure changes were identified. These items were not repetitive or indicative of programmatic breakdowns.
Corrective actions were timely.
Two licensee event reports identified unmonitored uncontrolled liquid releases. Four operations related event reports identified failures to monitor gaseous effluents due to sample system breakdowns.
The events were properly classified and reported.
Management involvement in this area is evidenced by the major reorganiz: tion of the radwaste management program and generally well defined procedures. Hewever, lack of formal approval of Radiation Control Technician training program remains a long-standing issue. ,
The General Employee Training Program contributes to fair adherence to procedures and minor numbers of personnel errors. The plant staffing appears to be adequate and the radic1ogical engineering reviews show evidence of adequate planning and technic:dly stund approaches to problems.
Conclusion -
Category 2 Board Recommendations -
None t
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- 3. Wintenance 4 Three taspections during the previous assessment period identified no violations. Three of four maintenance related event reports involved personnel error. The assessment concluded that the licensee had a viable maintenance prognm with no major programmatic weaknesses.
During the current assessment period, one region based inspection and routine inspection by the resident inspector identified ao violations. In an effort to improve the maintenance program, the licensee has assigned a full time preventive maintenance manager and a full time corrective maintenance manager reporting to the plant ~
maintenance manager. This has placed increased management attention on the control of maintenance activities; however, there is a lack of corporate and plant management involvement in the review and prioritization of outstanding maintenance items and an apparent :
understaffing in maintenar.ce departments. There is a large backlog of outstanding work orders and frequent instances where job orders are closed out when only temporary repairs are completed, or where job orders considered to be of minor importance are cancelled. l In addition to a backlog of maintenance orders, there is a large number of long-standing lifted leads and jumpers. These have not been closed because of incomplete maintenance modifications which did not include permanent removal of abandoned components, or the l need for further engineering review.
The, preventive maintenance program is being expanded and crews dedicated specifically to preventive maintenance are being formed. i This program presently involves primarily instrumentation and lubrication.
Maintenance records are reviewed by a preventive maintenance engineer who is developing machinery history records, but this program has not yet been developed to the point that maintenance trend analysis i can be performed.
In addition to marginal maintenance history records, the availability of current equipe3nt data is a weakness. Controlleci files of equipment data with component model and serial numbers, parts lists, and engineering drawings are not always up to date. For example, the controlled valve list does not reflect the fact that the reactor bJilding to suppression chi.mber air operated vacuum breakers were !
rtplaced with valves made by a different manufacturer in 1979.
11e licensee's response to NRC initiatives is sometimes delayed.
F2r example, corrective actions on a 1977 IE Circular relating to fise coordination in Standby Liquid Control system Squib firing c ucuits, a 1979 IE Circular relating to defective diesel fire pump l stacting contactors, and a 1979 IE Circular on Limitorque valve
, operator locking devices were not completed until the NRC expressed .
concert for lack of responsiv? ness. j I
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An event during the assessment period involving blockage of torus vacuum breaker valves by contractor erected scaffolding resulted in a Severity Level II violation and assessment of a civil penalty. L Another event involved an unmonitored airborne release of radioactive material from the radwaste building ventilation system. These !
events are indicative of inadequate control of contractor work.
After the assessment period, an event invniving improper assembly ,
and testing of a torus vacuum breaker va <e was discovered. The action resulted in one torus vacuum breaker being inoperable for i about 18 months during reactor operation. This event, which is still under review by the NRC, indicates that a strengthening of management control and procedural control over maintenance activities is necessary.
The licensee has implemented a program of increased management involvement in maintenance activities. In addition, recent staffing changes which have placed individuals with extensive maintenance background in upper-level management positions have resulted in an improving trend in this area.
Conclusion -
Category 3 Board Recommendations -
Increased inspection effort by the resident inspector. (
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- 4. Surveillance Ouring the previous assessnent period, six routine unannounced inspections by region based inspectors, one Performance Appraisal '
Branch Inspection and routine inspection by the resident inspector identified three violations. The licensee had failed to perform surveillances on three occasions.
During the current assessment period, two region based inspections, one regional basad team inspection, and routine resident reviews identified eight violations. The violations involved failure to ,
conduct Technical Specification and ASME Section XI testing, inaccurate -
calibration, calibr& tion and testing without procedure, and inadequate calibration data and procedural changes. ;
Corrective action was agreed to in an Immediate Action Letter dated i April 8, 1981. The licensee agreed to upgrade his inservice test
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program to meet the requirements of ASME code Section XI by January 1, 1982. Af ter the assessment period, region based ins;,ectors found that the licensee had not completed all corrective action, in that a l program for valve testing was not fully implemented. The licensee ,
has since submitted a revised completion schedule to NRC:RI. The l licensee stated that operational commitments and manpower shortages I were the reasons for not meeting the commitments; The high number -
of violations and the failure to meet commitment dates without i l
notification, indicate weakness in licensee management control in this area.
The'large number of event reports resulting from instrument drift and the long standing nature of this issue indicates a need for high level management involvement in this area to achieve technically acceptable resolution. Violations resulting from missed survetilances, in particular a Severity Level IV violation involving failure to i survey Emergency Service Water pumps following unacceptable surveillance !
on redundant pumps, indicate a need for more management attention in review of surveillance programs and assuring unambiguous acceptance criteria.
l This need is further amplified by a violation that occurred after ,
the assessment period. Three successive failures of an isolation ;
condenser valve during operability testing folicwed by two successful operations of the valve, with no followup investigation to determine the cause of the failures, was interpreted by a member of the managernent staff as acceptable component performance.
l Conclusion -
Category 3 1
Board Recornendations -
None
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- 5. Fire protection and Housekeeping Three inspections by region based inspectors and one Performance Appraisal Branch inspection during the previous assessment period f identified no major programmatic weaknesses. Two violations were identified involving storage of combustible material in safety '
related areas.
During this assessment perica, general fire protection activities and housekeeping were under continuous review by the resident inspector.
No programmatic inspections were performed. No violations in this !
area have been identified. Two Licensee Event Reports were submitted; one, the result of mechanical failure of a fire hydrant, the other involving personnel error when a cable penetration barrier was found l in a degraded condition.
j Management involvement in this area is evident by the assignment of a full time fire protection engineer, recent procedural revisions to '
provide better control of combustible material, and improved surveillance of fire barriers.
There were considerable problems causing delays in the installation and testing of a storage tank and pumping system to provide an -
alternate source of water to the fire protection system. (
Several recent events involving wetting and ultimate impairment of safety related electrical equipment have demonstrated inadequacies in the original fire protection safety evaluation. High level management attention to this problem since the end of the assessment period has resulted in an extensive survey of plant systems and a program to waterproof and protect electrical components.
Housekeeping has improved during this assessment period as a result of more management attention. Radiological housekeeping condittoas are generally acceptable with no significant NRC inspection findings ,
in this area. Poor general plant cleanliness and appearance, however, .'
continues to reflect poor plant staff attitudes and lack of pro- l fessionslism/ pride. An improving trend b a been noted as a result of increased management attention.
Conclusion -
Category 2*
Board Recommendations -
None e
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- This rating is assigned without regard to the licensee's position [ ,
on 10 CFR 50, Appendix R provisions. \._ i
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- 6. Emergency preparedness No programmatic inspections were conducted in this area during the i previous assessment period.
During the current assessment period, an emergency preparedness drill was observed by the resident inspector. The drill indicated weaknesses in the licensee's ability to implement the previsions of a revised emergency plan issued about one week prior to the drill. -
The licensee recognized the deficiencies which were also identified by several internal audits. An intensive upgrade program, which g included significant increases in emergency planning staff, further emergency plan and procedure reviews, and intensive training, was begun.
An NRC team appraisal of emergency preparedness was conducted in January 1982 after the end of the assessment period. The appraisal identified l
, significant weaknesses requiring corrective actions. These weaknesses included: required upgrading of emergency response facilities; improved i capability for post accident sampling of stack effluent, reactor l coolant, and contaicment atmosphere; emergency procedure improvement; l and better definitions of the training program for emergency response personnel. The licensee's proposed corrective actions were discussed in a Confirmatory Action Letter dated February 18, 1982.
An NRC team observation of a major emergency preparedness exercise was conducted in March 1982. This observation determined that the licensee had demonstrated the capability to implement the provisions I of the emergency plan to adequately protect the public health and safety during an accident, nowever, areas for improvement were noted and discussed with the licensee.
The licensee failed to meet the February 1,1982 deadline for installation j of a Public Notification System and was issued a teverity Level III Notice of Violation. Forty five warning sirens were installed ,
and tested by February 26, 1982. The final siren was installed and tested on March 5, 1982.
Conclusion -
Category 2*
Board Recommendations -
None
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- This categorization has been assigned on the bases of additional information developed after the assessment period and without regard to resolution of the outstanding issue of the Confirmatory Action Letter of February 18, 1982.
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- 7. Security and Safeguards Ouring the previous assessment period, two routine inspections by ,'
i region based inspectors, routine review of selected areas by the ,
resident inspector, and one inspection by the Performance Appraisal !
Branch identified no violations or evidence of programmatic weaknesses.
During one inspection, allegations by a former security watchman, which had been published in a local newspaper, were reviewed but li could not be substantiated.
During the assessment period, two routine inspections by region based inspectors identified 7 violations. Six Severity Level IV violations were identified involving failure to secure a vital area barrier, use of improper identification badges, failure to conduct key audits, failure to perform explosives detector performance tests, inadequate lighting in two areas, and failure to retain certain records. Licensee's corrective action on these items, which were identified in one inspection, were discussed in a management meeting during this assessment period. One Severity Level V violation '
involving failure to properly control a vehicle within the protected area was identified in a subsequent inspection. The large number of violations are not indicative of major programmatic breakdowns. An inspection conducted since the end of the assessment period (December 7 7-11,1981) identified no similar problems. Management attention is demonstrated by the prompt action to correct and prevent recurrence of the identified problems. Site management is generally responsive to security program requirements. Required reviews, audits and records are generally complete and show involvement by Corporate management. The security organization is well staffed with well defined responsibilities and adequately trained personnel. Procedural adherence is good with infrequent personnel errors.
Conclusion -
Category 2 Board Recommendations -
None I
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- 8. Refueling and Major Outage Activities During the previous assessment period, one region based inspection and frequent resident inspector reviews of refueling and outage activities identified two violations involving procedural inadequacies and procedural adherence. One of the violations involved a major breakdown of administration controls causing failure to remove control rod interlock bypass jumpers prior tu control cell fuel reload. This violation received high level management attention by the corporate General Office Review Board and the Independent Safety Review Group.
During the current assessment period, one region based inspection of i post refueling testing and reload analysis was conducted. No violations were identified.
One scheduled and frequent unscheduled maintenance outages occurred during the assessment period. Considerable improvements in scheduling and coordination of outage activities were noted. This is due ,
primarily to the assignment of a full-time Programs and Controls Manager who oversees outage planning. Scheduling activities generally addressed key outage and outage recovery items. ,
Some problems in the area of control of contractor work were noted !
as evidenced by one violation involving blocking of torus vacuum i breakers by contrt.ctor erected scaffolding and an event involving an airborne release of radioactive material from the radwaste building ventilation system.
One region based inspection conducted after the assessment period, !
identified some weaknesses in the area of control of design changes and modifications. These findings, which are under review by NRC management, indicated that the management of the design changes and modification program is very fragmented with poor central control l and review. Many procedures for the program are in draft form and ,
many are still being prepared.
Training on modifications completed during outages is sometimes delayed until just prior to startup, and drawing revisions are sometimes delayed. This, together with insufficient management ,
involvement in design change program, results in an occasional lack !
of coordination between engineering, construction, and operations staff during turnover of systems to operations control and in occasionally late implementation of revised procedures.
The licensee has a well staffed corporate technical engineering j group. This group is still gaining site specific familiarity resulting in considerable relience on contractors for engineering support.
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Conclusion -
Category 2 Board Recommendations -
In light of the planned extended '
outage involving numerous and diverse modifications, increased inspection activity should be devoted to outage '
activities particularly during the early portion of the outage.
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- 9. Licensing Activities No specific assessment of licensing activities was performed during i the prior assessment period; pertinent issues were included in other functional areas.
Licensing activities during the current asseement period included miscellar.eous Technical Specification changes, a review of TMI Task Action Plan items, a major license amendment changing the license to GPU Nuclear Corporation, and replacement core spray sparger design.
The licensee's performance and management capabilities were generally adequate; however, the timeliness of responses has been poor with a two to three month time delay being the norm. Details of submittals ;
are usually coordinated with the staff beforehand to establish requirements and clarity, and are generally good quality. However, some submittals relative to the Systematic Evaluation Program (SEP) l and the TMI Task Action Plan (NUREG-0737) were not always complete and resulted in frequent requests by NRC for additional information.
The licensee and his contractors have demonstrated adequate working l knowledge of regulatory requirements and excellent levels of technical competence. The licensee's staffing is generally adequate, but in view of planned modifications and possible SEP upgrade requirements, may require increases.
Conclusion -
Category 2 Board Recommendations -
None I
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V. SUPp0RTING DATA AND SUMMARIES
- 1. Licensee Event Reports !
Tabular Listing Type of Evencs: '
A. Personnel Error 8 ,
B. Design / Man./Constr./ Install. 6 C. External Cause O D. Defective Procedure 6 i E. Component Failure 34 X. Other 16 Total 70 Licensee Event Reports Reviewed:
l Report No. 80-49/01P through 81-55/03L i Causal Analysis Seven sets of common mode events were identified:
- a. LERs 80-50/3L, 80-52/3L, 80-55/3L, 80-56/3L, 80-57/3L, 80-60/3L, 80-63/3L, 81-01/3L, 81-06/3L, 81-10/3L, 81-11/3L, 81-12/3L.
l 81-13/3L, 81-15/3L, 81-21/3L, 81-26/3L, 81-40/3L, 81-49/3L, 81-51/3L, and 81-54/3L identified events in which surveillance testing found safety related instrument setpoints out of spec-ification due to setpoint drift.
- b. LERs 80-51/3L, 80-59/3L, 81-19/3L, 81-24/3L, and 81-32/3L I involved missed surveillance tests caused by inadequate procedures !
[ (3 LERs) or personnel error (2 LERs).
- c. LERs 80-53/3L, 80-54/3L, 80-62/3L, and 81-29/3L are events in which Control Rod Drive Hydraulic Pump failures caused (3 LERs) !
or contributed (1 LER) to the event, j i d. LDS 80-58/3L, 80-61/3L, 81-09/3L, and 81-46/3L identified l events in which hydraulic snubbers were found to be inoperable during s eveillance testing.
I e. LERs 81-02/3L, 81-41/IP, 81-42/IP, and 81-43/!P involved failure i to continuously monitor the plant stack effluent activity due l
[
to failures of the sample system pumps, i
l f. LERs 81-07/3L and 81-37/3L reported incidents where the containment l
spray compartment water tight doors were left open.
(
- g. LERs 81-22/IP, 51-25/IP, 81-27/3L, 81-30/IP, 81-33/IP, 81-48/3L, c
and 81-52/3L reported events where containment integrity was 1 l
19 violated or degraded due to personnel error (3 LERs) or valve failure (4 LERs).
- 2. Investigation Activities An investigation was conducted between October 6, 1980, and January 14, 1981 of the circumstances surrounding the transportation and use of shipping cask Model NFS-4, Serial NAC-1E, from the time it was shipped from Haddam, Connecticut, May 1, 1980, until it arrived at Camp Pendleton, California August 20, 1980. The cask arrived at Oyster Creek July 23, 1980 and was shipped from the site on August i 15, 1980. No items of noncompliance were identified against this license.
- 3. Escalated Enforcement Actions
- a. Civil penalties A civil penalty of $80,000 was assessed on August 21, 1981 for violation of Technical Specification Limiting Condition for Operation when one reactor building to suppression chamber vacuum breaker in each line was prevented from opening by contractor ere'cted scaffolding,
- b. Orders Order Modifying License dated January 9,1981 requiring an
, , automatic system to initiate control rod insertion on low
Order Modifying License dated January 13, 1981 requiring assessment of suppression pool hydrodynamic loads and modifications to assure conformance with the criteria in NUREG-0661 Appendix A.
(Issued to all licensees with Mark I Containments).
Order Modifying License dated March 24, 1981 extending the deadline date of the January 13, 1981 order.
l Order Modifying License dated April 20, 1981 Implementing Technical Specifications on leak testing of certain motor operated valves. (Issued to all licensees with Event V isolation valve configurations within the boundary of high pressure to low pressure piping).
I Order Modifying License dated July 7,1981 confirming licensee commitments for TMI related requirrments contained in NUREG-0737.
(Issued to all licensees).
e.
20
- c. Immediate Action Letters IAL 80-20 dated April 8, 1981 confirming actions to be taken to I implement a pump and valve test program conforming to Section XI of the ASME Boiler and Pressure Vessel Code.
- 4. Management Conferences Held During the Assessment Period Management Meeting at the Region I office on January 14, 1981 to discuss the Physical Security Program and the violations identified during Physical Security Inspection 50-219/80-36. (Meeting No.
l 50-219/81-02).
t, I
I i
6 l
I f
5
21 i
i TABLE I TABULAR LISTING OF LERs BY FUNCTIONAL AREA OYSTER CREEK NUCLEAR GENERATING STATION l
Area Number /Cause Code Total
- 1. Plant Operations 5/A, 4/B, 3/0, 17/E, 3/X 32
- 2. Radiological Controls 1/0, 1/E 2
- 3. Maintenance 3/E 3
- 4. Surveillance 2/A, 2/B, 1/0, 13/E, 13/X 31
- 5. Fire Protection 1/A, 1/E 2
- 6. Emergency Preparedness None *
- 7. Security and Safeguards None .
- 8. Refueling None
- 9. Licensing Activities None !
~
TOTAL 70 Cause Codes: A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause O - Defective Procedures E - Component Failure X - Other l
m
t e a 22 TABLE 2 OYSTER CREEK NUCLEAR GENERATING STATION !
LER SYNOPSIS I
NOVEMBER 1, 1980 - OCTOBER 31, 1981
- LER Number Type Summary Description '
i 80-49/01P 24 Hour Degradation of the reactor coolant pressure boundary when the Isolation Condenser vent isolation valves failed to close.
80-50/03L 30 Day Containmcnt Spray System high drywell pressure switches IP-15A, IP-158, IP-15C and IP-150 tripped at a value greater than that specified.
80-51/03L 30 Day The required daily surveillance for APLHGR, LHGR, and MCPR was not performed.
- 80-52/03L 30 Day Reactor triple low water level indicator .
switches RE-18A and RE-180 both tripped at values higher than specified. (
80-53/03L 30 Day Operation in a degraded mode when CRD pumps were removed from service to repair leaks.
80-54/03L 30 Day Core Spray System I removed from service to inspect motors wetted by CRD pump leaks.
80-55/03L 30 Day Core Spray High Drywell Pressure Switches tripped at values higher 'than specified.
80-56/03L 30 Day Main Steam Line High Flow Pressure Switches tripped at values greater than specified.
80-57/03L 30 Day Containment Spray System High Drywell Pressure Switches tripped at values greater than specified.
80-58/03L 30 Day Two Hydraulic Snubbers failed to lock up during functional testing.
80-59/03L 30 Day Diesel Generator Battery and Main Station Battery Monthly Surveillance not performed as required.
80-60/03L 30 Day Isolation Condenser Pipe Break Sensors ( ,
tripped at values greater than specified. J i
23 Table 2 (Con'd) 4 LER Number Type Summary Description 80-61/03L 30 Day Three Hydraulic Snubbers failed to lock up i during functional testing.
80-62/03L 30 Day Operation in a degraded m2,de when CRDH Pump
'A' failed in service.
80-63/03L 30 Day Reactor Triple Low Water Level Switch tripped at a value greater than specified.
81-01/03L 30 Day Containment Spray High Drywell Pressure Switch tripped at higher value than required.
81-02/03L 30 Day Stack gas activity not continuously monitored i due to sample pump failure, i 81-03/03L 30 Day Fire Hydrant number 2 declared inoperable out to a frozen barrel.
82-04/01P 24 Hour Load on Emergency Diesels could exceed rated load on design basis accident.
81-05/03L 30 Day Emergency service water pump 528 failed to I demonstrate operability during testing.
81-06/03L , 30 Day Reactor Tri,,le Low Level Switch tripped at value less conservative than required.
81-07/03L 30 Day Violation of Tech Spec 3.4.E when the NE Containment Spray Water Tight Door was found open.
81-08/03L 30 Day Water seeped through the west wall of NRW Building following flooding of chem waste tank vaults.
81-d3/03L 30 Day Hydraulic Snubber 23/3 found leaking oil and failed subsequent test.
81-10/03L 30 Day MSL High Radiation Monitor RN068 tripped at
, a value higher than specified.
81-11/03L 30 Day Iso-Condenser Isolation' Pipe Break Sensor 181182 tripped at value greater than specified.
t ,
l
24 Table 2 (Con'd)
LER Number h Summary Description 81-12/03L 30 Day EMRV high pressure sensors 1A83C and 1A83E i set points exceeded tech spec limit.
81-13/03L 30 Day Core Spray High Drywell Pressure Sensor RV46B tripped at a value higher than specified.
81-14/01P 24 Hour Primary containment atmosphere not reduced to less than 5% oxygen within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of !
startup.
81-15/03L 30 Day Main Steam Line High Flow Sensors RE22F and RE22G tripped at values higher than specified.
l 81-16/03L 30 Day Failure of packing in valve V-2-88 resulted in an unmonitored release of radioactive water.
81-17/03L 30 Day Containment Spray System I inoperable due to loss of suction on ESW pumps when water f' level dropped at intake structure. \
81-18/01P 24 Hour Reactor building to suppression chamber vacuum breakers prevented from opening.
81-19/03L 30 Day During normal shutdown IRM Calibration was
[-
not performed as required.
81-20/03L 30 Day Water level in B Iso-Condenser less than specified due to instrument error. '
81-21/03L 30 Day Reactor high pressure sensors RE-03B, C, O trip settings higher than specified.
- I 81-22/01P 24 Hour Violation of containment when both personnel access airlock doors were open on the NE airlock.
81-23/03L 30 Day Tech Spec LCO exceeded when drywell Torus DP was not within specified limits.
81-24/03L 30 Day Emergency service water pumps found to be inoperable and required operability check of redundant pumps was not performed as specified,
.i
a 25 Table 2 (Con'd) l 9
i LER Number Type Summary Description i j 81-25/01P 24 Hour Violation of Secondary Containment Integrity when both railroad airlock doors were opened, j; 81-26/03L 30 Ocy Iso-Condenser initiation pressure switch !
REISA tripped at a value higher than -
specified.
I 81-27/03L 30 Day Operation in a degraded mode when Number 2 TIP Ball Valve failed to close automatically.
l 81-28/03L 30 Day Unmonitored release through new radwaste building ventilation ductwork.
81-29/03L 30 Day Operation in a degraded mode when CRDH Pump 'B' motor bearing failed in service.
81-30/01P 24 Hour Violation of Secondary Containment when exhaust valve V28-22 failed to close.
81-31/03L 30 Day Operation in a degraded mode when the 'B' EMRV failed to open during testing.
81-32/03L 30 Day Monthly channel checks of the accident monitoring instrumentation were not performed.
81-33/01P 24 Hour Secondary Containment Integrity was violated when both NW airlock doors were found open.
81-34/03L 30 Day Violation of Tech Spec when the peaking factor was 110% of the allowable limit.
81-35/03L 30 Day Violation of Tech Spec when a degraded i I
fire barrier was discovered and no fire watch was established.
81-36/03L 30 Day Reactor Water level Instrumentation for one channel in both RPS Systems were inoperable. ,
l 81-37/03L 30 Day Violation of Tech Specs when SE containment spray compartment door was found open.
t 26 Table 2 (Con'd)
LER Number Type Summary Description 81-38/03L 30 Day Tube rupture in A and C Shutdown Cooling i Heat Exchanger while in cold shutdown. ,
81-39/03L 30 Day Unmonitored release of radioactive water due to RBCCW heat exchanger tube failure.
81-40/03L 30 Day EMRV High Pressure Sensors IA83B and C setpoints exceeded specified value.
81-41/01P 24 Hour Stack Gas Activity was not continuously f monitored due to trip of the 'A' Sample ,
Pump. !
81-42/01P 24 Hour Stack Gas Activity was not continuously monitored due to trip of the 'B' Sample ,
Pump.
81-43/01P 24 Hour .
Stack Gas Activity was not continuously monitored due to air in-leakage at Sample Pump inlet.
81-44/03L 30 Day Standby Gas Treatment Fan 1-8 was removed l from service for corrective maintenance.
81-45/03L 30 Cay Iso-Condenser valve V-14-32 failed during performance of routine surveillance test. i 81-46/03L 30 Day Three hydraulic snubbers in the shutdown f cooling system failed during functional testing. i 81-47/03L 30 Day Diesel Generator number 1 failed to achieve '
peak load during surveillance testing.
81-48/03L 30 Day Degradation of primary containment integrity when RWCU Isolation Valvo V-16 .' failed to f close.
81-49/03L 30 Day Containment Spray High Drywell Pressure Switches IP-15A and C tripped at values greater than specified, 81-50/03L 30 Day Operation in a degraded mode when core spray ka pump pressure switch RV-29C failed to reset at the specified value.
27 Table 2 (Con'd) ;
I I
LER Number Type Summary Description ,
51/03L 30 Day Electromatic relief valve high pressure sensor IA83E setpoint exceeded the specified value.
81-52/03L 30 Day Operating in a degraded mode when the in-shield limit switch for No. 2 TIP machine failed preventing ball valve from automatically -
closing.
81-53/03L 30 Day Ability of offgas system to automatically l.
isolate was lost for 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> due to broken ,
power cable. !
81-54/03L 30 Day Main Steam Line Low Pressure Sensor RE 23D tripped at pressure lower than limi.t specified in the Tech Specification. i -
81-55/03L 30 Day Acoustic Monitoring System (AMS) for safety and relief valve position indication found to have two channels that provided no or low response.
i
r- ., 1 l
28 TABLE 3 INSPECTION HOURS
SUMMARY
(11/1/80 - 10/31/81)
OYSTER CREEK NUCLEAR GENERATING STATION HOURS % OF TIME
- 1. Plant Operations 1053 51 ,
- 2. Radiological Controls 223 11
- 3. Maintenance 128 6
- 4. Surveillance 201 10
- 5. Fire Protection 85 4
- 6. Emergency Preparedness 20 1
- 7. Security and Safeguards 202 10 -
- 8. Refueling 46 2
- 9. Licensing Activitives No Data Available I
- 10. Other 104* 5 g
- Total 2062 100% !
I 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br /> of region based investigation in response to a radioactively f 4
contaminated spent fuel shipping cask. }
Allocations of inspection hours vs, Functional Areas are approximations based on inspection report data. ;
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g TABLE 4 INSPECTION [REPORTACTIVITIES OYSTER CREER NUCLF.AR GENERATING-STATION REPORT INSPECTOR -
AREAS INSPECTED 80-33 Resident Routine 80-34 Specialist Past-Refueling Testing 80-35 Resident i Routine I.
80-36 Specialist physical Security l 80-57 Specialist Transportation 80-38 Investigator Shipping Cask Contamination
\ / 4 81-01 Re . dent 'Ro, utin s j l !
81-02 ---
,4!anage 4 hent Meeting '
i i if 81-03 Resident :Noutine l 81-04 .
Specialist Radiation Protection i
81-05 Specialist Surveillance, Calibration 81-06 Resident Routine 81-07 Specialist In-Service Inspection 81-08 Specialist In-Service Testing, Quality Assurance, Design Changes,
! Maintenanc.e
,/,. s 81-09 Specialist Radiatioi Protectior
- i 81-10 Resident Routine i 81-11 Resident Routine \
81-12 Resident Routine Ii 81-13 Specialist Physical Security t
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/
- ['l
, 3, _
j .. , .
i l
30 i l
, Table 4 (Con'td)
- t REPORT INSPECTOR AREAS INSPECTED 81-14 Resident sRo'utine 81-15 Specialist R6diation frotection 81-16 Resident Routine g 81-17 Resident ShutdownCoolingNeatExchanger Failure 81-18 Resident Routine 81-19 Resident Routine 81-20 Specialist ' Independent Measurements (f
\'
I i
4 l 4 l #
-1 f j
( .
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1 31 l t
t TABLE 5 ,
VIOLATIONS (11/1/80 - 10/31/81) l OYSTER CREEK NUCLEAR GENERATING STATION .
I A. Number and Severity Level of Violations
- 1. Severity Level Severity Level I 0 l' Severity Level II 1 Severity Level III 2 l Severity Level IV 16 i Severity Level V 13 i serity Level VI 3 Total 35 B. i 'ons Vs. Functional Area Severity Levels FUNCTIONAL AREAS I II III IV V VI 1- Plant Operations 1 4 5 2
- 2. Radiological Controls 2 2 2
~
- 3. Maintenance 2
- 4. Surveillance 4 3 1 l
- 5. Fire Protection
- 6. Emergency Prept.edness
! 7. Security & Safeguards 6 1
.P, . Refueling 1
- 9. Licensing Activities l
l Totals 1 2 16 13 3 Total Violation = 35 l
l l
l I
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i 32 Table 5 (Con't)
TABLE 5 ENFORCEMENT DATA OYSTER CREEK NUCLEAR GENERATING STATION November 1, 1980 - October 31, 1981 Inspection laspection Number Date Subject ,, Req. Sev. Area 80-36 12/13-19/80 Failure to secure vital area barriers PSP .IV 7
, 80-36 12/13-19/80 Use of improper I.D. badge PSP IV 7 80-36 12/13-19/80 Failure to conduct protected area key PSP IV 7 audit and failure to change safe combinations 80-36 12/13-19/80 Explosives detector performance tests PSP IV 7 were net conducted 80-36 12/13-19/80 Inadequate lighting at locations in PSP IV the protected area 7(,
l 80-36 12/13-19/80 Failure to retain certain records as PSP IV 7 l required l
l 80-37 12/3'0/80 LSA radioactive material was delivered 49CFR III 2 l to a carrier for transport in a package 173 l that was not a strong, tight package l
80-37 12/30/80 LSA radioactive material was delivered 49CFR III 2 to a carrier for transport without 173 properly describing the physical form of the material in the shipping papers 81-01 1/5-31/81 Annunciator and Alarm procedures was TS V 1 l not followed l
81-03 2/2-28/81 Failure to follow dosimetry issue TS V 2 procedures l l
b 33 Table 5 (Con't) l t
Inspection Inspection Number Date Sebject Req. Sev. Area 81-04 3/2-681 Administrative Control requirements fcr TS V 2 procedure changes were not followed 81-05 3/9-13/81 Test gauges used for safety related AppB V 4 calibrations are not of acceptable '
accuracy or readability for the calibrations being performed ,
l 81-05 3/9-13/81 Calibrations are performed on safety TS V 4 related instruments without using i approved procedures, and diesel I generator KW and KVAR meters and fire ;
pump RPM meters are not beirg calibrated
}
81-05 3/9-13/81 Failure to test valves as required by AppB V 4 i the inservice test program 81-05 3/9-13/81 PORC meeting minutes are not being TS V 1 distributed to the ISRG and GORB as required by T.S.6.5.4.1 c1-05 3/9-13/81 Annual reviews of operating procedures TS VI 1 l
were not performed 81-05 3/9-13/81 Calibration data was omitted from TS VI 4 instrument history cards and had not j received supervisory review .
1 l 81-05 3/9-13/81 The core spray pump test procedure was TS VI 1 ,
i not revised to reflect that the fill i pumps no longer operate automatically }
81-06 3/1-31/81 Safety related material was purchased AppB V 3 on requisition 61619 without OQA ,
review '
, i I 81-08 3/30-4/3/81 Pump operability tests were not performed AppB IV 4 l in accordance with Section XI of the l ASME B&PV Code l 81-08 3/30-4/3/81 Handling, Storage, and preservation AppB V 3 of materials and equipment to prevent damage or deterioration, and the l cleanliness of the level B storage area were not in conformance with l
l l
e . . _ . . _
h 34 Table 5 (Con't) l Inspection Inspection l Nuxber Date Subject Reo. Sev. Area I 81-10 4/1-30/81 One reactor building to suppression TS II 1 chamber vacuum breaker in each line was rendered inoperable by the placement of contractor erected scaffold 81-10 4/1-30/81 Corrective action has been ineffective AppB IV 1 in correcting conditions adverse to quality which present the potentiel for the release of radioactive material from the condensate transfer pump building 81-11 5/1-30/81 Geveral electrical jumpers were found ' '; V 1 improperly installed or disconnected 81-12 6/1-30/81 The required daily surveillance was TS IV 4 not performed on emergency service water pumps when the redundant pumps were inoperable t
l 81-12 6/1-30/81 A high radiation area was not locked TS IV 2 or guarded to prevent unauthorized entry l 81-13 6/8 .12/81 A vehicle in the protected area was PSP V 7 l left unlocked, unattended with the keys in the ignition l 81-14 7/1-30/81 Secondary containment integrity was not TS IV 1 i maintained as required when valve V-28-22 l was inoperable and not secured in the closed position 81-14 7/1-30/81 Instrument channel checks of the accident TS IV 4 monitoring instrunients were not performed
! monthly from May 8,1981 to July 13, 1981 81-14 7/1-30/81 The southeast containment spray pump TS IV 1 compartinent water tight door was lef t open in violation of technical specification }
i 1
l L _.
35 Table 5 (Con't)
Inspection Inspection Number Date Subject Req. Sev. Area j 81-16 8/4-9/14/81 Personnel entered a high radiation TS IV 2 -
area without proper radiation dose rate monitoring equipment 81-16 8/4-9/14/81 Failure to follow procedures during TS V 1 performance of surveillance test 81-17 8/27-10/19/81 Failure to report an unplanned, 10CFR IV 1 uncontrolled radioactive liquid release 50,72
.81-18 9/15-10/5/81 Failure to follow procedures for conduct TS V 1 of shift turnover 81-18 9/15-10/5/81 Failure to implement test procedures with AppB IV 4 adequate acceptance criteria for the station batteries
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