ML20154Q363
| ML20154Q363 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 03/17/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20154Q361 | List: |
| References | |
| 50-289-85-98, NUDOCS 8603210139 | |
| Download: ML20154Q363 (38) | |
See also: IR 05000289/1985098
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U. S. NUCLEAR REGULATORY COMMISSION
RCGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-289/85-98
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION
THREE MILE ISLAND NUCLEAR GENERATING STATION UNIT ONE
ASSESSMENT PERIOD: SEPTEMBER 16, 1985 - JANUARY 10, 1986
BOARD MEETING DATE: JANUARY 24, 1986
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TABLE OF CONTENTS
Page
I. INTRODUCTION
A. Purpose and Overview. . .............. I
B. SALP Board Members ................ 2
C. Background. . . . . . . . . . . . . . . . . . . . . 3
II. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . 6
III. SUMMARY OF RESULTS
A. Facility Performance. . . . . . . . . . . . . . . . 8
B. Overview. ........ ............. 9
IV. PERFORMANCE ANALYSIS
A. Plant Operations. . . . . . . . . . . . . . . . . . 11
B. Radiological Controls . . . . . . . . . . . . . . . 14
C. Maintenance . . . . . . . . . . . ......... 16
D. Surveillance Testing. . . . . . . . . . . . . . . . 19
E. Startup Testing . . . . . . . . . . . . . . . . . . 21
F. Training and Qualification Effectiveness ..... 24
G. Assurance of Quality. . .............. 26
V. SUPPORTING DATA AND SUMMARIES
A. Investigations and Allegations Review . ...... 28
B. Escalated Enforcement Actions . . . . . . . . . . . 28
C. Management Conferences. . . . . . . . . . . . . . . 28
D. Licensee Event Reports. . . . . . . . . . . . . . . 28
E. Reactor Trips / Forced Outages ........... 29
F. Planned / Unplanned Releases. . . . . . . . . . . . . 29
TABLES
Table 1 - Inspection Report Activities . . . . . . . . . . . . . T1-1
Table 2 - Inspection Hours Summary . .............. T2-1
Table 3 - Enforcement Summary. ................. T3-1
Table 4 - Enforcement Data . . . . . . . . . . . . . . . . . . . T4-1
Table 5 - Unplanned Reactor Trips and Snutdowns ........ T5-1
Table 6 - Radiological Effluent Releases . . . . . . . . . . . . T6-1
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I. INTRODUCTION
1 A. Purpose and Overview
j The Systematic Assessment of Licensee Performance (SALP) is an inte-
i grated NRC staff effort to collect available observations and data on
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a periodic basis to evaluate licensee performance. The SALP process
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is supplemental to the normal inspection processes used to ensure
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compliance with NRC rules and regulations. It is intended to be suf-
ficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's man-
agement in order to improve the quality and safety of plant opera-
I tions and modifications.
This SALP is termed an interim SALP in that it covers the period from
i a few weeks prior to criticality to several days after the completion
of the power escalation program. The purposes of this interim SALP
i are (1) to assist in the preparation for the first of two Commission-
directed performance appraisal team (PAT) inspections, (2) to verify
performance during the transition from a long-term shutdown condition
) to commercial power operation, and (3) to determine the allocation of
1 NRC resources for future inspections.
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An NRC SALP Board, comprised of the staff members listed in Section B,
met on January 24, 1986, to review the collection of performance
observations and data to assess the licensee's performance in accor-
I dance with the guidance in NRC Manual Chapter 0516, " Systematic
Assessment of Licensee Performance." A summary of the guidance and
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evaluation criteria is provided in Section II of this report.
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This report is the SALP Board's assessment of the licensee's
, performance at TMI-1 Nuclear Generating Station for the period
September 16, 1985, through January 10, 1986. The summary findings
! and totals reflect a relatively short period compared to the normal
assessment period which is at least 12 months.
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- B. SALP Board Members
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Chairman
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R. Starostecki, Director, Division of Reactor Projects
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Members
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! R. Bellamy, Chief, Radiation Protection Branch, DRSS (Part Time)
! L. Bettenhausen, Chief, Operations Branch, DRS
l R. Blough, Chief, Reactor Projects Section No. IA, DRP l
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R. Conte, TMI-1 Senior Resident Inspector
S. Ebneter, Director, DRS (Part Time)
4 W. Kane, Deputy Director, DRP
H. Kister, Chief, Projects Branch No. 1, DRP (Part Time)
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P. McKee, Chief, Operating Reactor Programs Branch, Division of
a Inspection Programs, IE
. J. Thoma, TMI-1 Operating Reactors Project Manager, Project
Directorate No. 6
Other Attendees
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N. Blumberg, Lead Reactor Engineer, DRS (Part Time)
, R. Urban, Reactor Engineer, RPS 1A, DRP (Part Time)
i R. Weller, Section Leader, Project Directorate No. 6
F. Young, TMI-1 Resident Inspector
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C. Background
1. Licensee Activities
The major milestones of the licensee's power escalation program
along with completion dates are listed in Figure 1. This sched-
ule was proposed by the licensee and agreed to by the NRC staff.
The licensee completed its program within a few days of the plan- ;
ned schedule. The program included six NRC Region I hold points.
The assessment period began with the plant in hot shutdown. The
reactor was taken critical on October 3, 1985, for natural cir-
culation testing and other low power tests. On October 9, 1985,
the main generator was placed on-line.
Between October 13 and 18, 1985, the turbine was taken off-line
several times with the reactor at low power to repair weld fail-
ures on drain lines from steam inlet piping to the main turbine.
On October 19, 1985, a test of the reactor trip on loss of main
i feedwater was initiated from 40 percent power and a subsequent
natural circulation test was completed. The reactor was re-
started and the main turbine generator placed on-line on
October 23, 1985, then taken to 48 percent power.
The reactor was then operated at 48 percent power for operator
training and steam generator leakage monitoring. Between
November 24, 1985, and December 27, 1985, the licensee completed
additional planned steady-state power operation at 75 percent
power. On December 27, 1985, the NRC released the licensee to
take the plant to_ full power. However, the maximum achievable
power was limited due to secondary side fouling of the steam
generator, which caused higher than expected steam generator
water levels. Even after raising the steam generator water
level limit, as has been done at other B&W plants which experi-
enced the same problem, the licensee was able to achieve only
88 percent of full power.
On January 2,1986, the licensee satisfactorily completed the
final power ascension tests -- reactor trip on turbine trip and
EFW initiation on loss of reactor coolant pumps. After the
planned January 2 trip and an unplanned trip during start-up on
January 4, the steam generator fouling was apparently alleviated '
and the plant reached full power.
During the above period, two unplanned reactor trips occurred:
on December 1, 1985, from 75 percent power, as discussed above,
and on January 4,1986, from 22 percent power. The first
occurred because of a main generator breaker trip due to a mal-
function in a main electrical generator protection relay. The 1
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other occurred because of another secondary plant malfunction
that caused a high level in a moisture separator which resulted
in a turbine-to-reactor trip.
The annual emergency preparedness exercise was completed satis-
factorily on November 20, 1985. Also, the licensee completed
construction of a new annex to the training building which,
among other support functions, will house the plant-specific
simulator scheduled for delivery in June 1986.
2. Inspection Activities
In May 1985, Region I established the TMI-I Restart Staff organ-
ization to provide an intensive review of licensee activities
using an augmented shift coverage plan. This organization
continued to function from that time through delays in restart
authorization and through the licensee's power escalation
testing (PET) program. There was a high level of Region I
management involvement including the Deputy Director, Division
of Reactor Projects, who served as TMI-1 Restart Director on
site.
Because of his knowledge of the TMI-1 plant and experience with
the TMI-1 restart process, the senior resident inspector was
designated TMI-1 Restart Manager and assigned the responsibility
to manage inspection activities. Shift inspectors, experienced
in B&W plant operations, included resident / project engineers
from Region I, other regions, the NRC training center, and NRC
contractors. Shift inspector activities ranged from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />
per day to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day, depending on the pace of licensee
activities. The resident inspector and Region I inspectors
conducted follow-up reviews of a programmatic nature in response
to shift inspector concerns. As time permitted, they condu:ted
reviews of equipment operability and of the technical adequacy
of selected procedures. Region-based specialist reviews also
occurred in the areas of radiation protection, training,
engineering support, security, and emergency preparedness.
To provide additional technical expertise and experience with
the fMI-1 restart, the former senior resident inspector for
TMI-1 was assigned as a technical assistant to the TMI-1 Restart
Director.
A total of 3936 inspection hours were expended during the period
(shift inspector coverage was approximately 40% of that total)
with a distribution in the appraisal functional areas as shown
in Table 2. The inspection hours occurred during a 17-week
period which converts to 232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br /> / week or approximately 12,000
hours annually. Summaries of inspection activities and identi-
fled violations are tabulated in Tables 1 and 4 respectively.
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This report also discusses " Training and Qualification Effec-
tiveness" and " Assurance of Quality" as separate functional
areas. Although these topics, in themselves, are assessed in
the other functional areas through their use as criteria, the
two areas provide a synopsis. For example, quality assurance
effectiveness has been assessed on a day-to-day basis by resi-
dent inspectors and as an integral aspect of specialist inspec-
tions. Although quality work is the responsibility of every
employee, one of the management tools to measure this effec-
tiveness is reliance on quality assurance inspections and audits.
Other major factors that influence quality, such as involvement
of first-line supervision, safety committees, and worker attitudes,
are discussed in each area.
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II. CRITERIA
Licensee performance was assessed in selected functional areas significant
to nuclear safety and the environment. Assessment areas were selected
based on facility status (i.e., restart testing phase) and, for this in-
terim SALP, NRC inspection program focus. Consequently, this interim SALP
does not include certain typical SALP functional areas, such as emergency
preparedness, security and safeguards, fire protection, technical support,
and licensing. These will be addressed in the next SALP.
One or more of the following evaluation criteria were used to assess each
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functional area:
1. Management involvement and control in assuring quality
2. Approach to resolution of technical issues from a safety standpoint
3. Responsiveness to NRC initiatives
4. Enforcement history
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5. Report and analysis of reportable events
6. Staffing (including management)
7. Training effectiveness and qualification
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1. Reduced NRC attention may be appropriate. Licensee manage-
ment attention and involvement are aggressive and oriented toward nuclear
safety; licensee resources are ample and effectively used so that a high
level of performance with respect to operational safety or construction is
being achieved.
The NRC attention recommendation may not be consistent with the above
categories for a given SALP rating in a specific functional area.
This is because of unique aspects of TMI-1 and because of public sen-
sitivity to operational activities at the facility to which the NRC
staff must be prepared to respond.
Category 2. NRC attention should be maintained at normal levels. Licensee
mar.agement attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and reasonably effective
so that satisfactory performance with respect to operational safety or
construction is being achieved.
Category 3. Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear
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safety, but weaknesses are evident; licensee resources appear to be
strained or not effectively used so that minimally satisfactory perfor-
mance with respect to operational safety or construction is being
achieved.
Normally, the SALP Board assesses each functional area to compare the
licensee's performance during the last quarter of the assessment period
to that during the entire period in order to determine the recent trend
for each functional area. Because of the short period covered by this
SALP, the trend categories are not addressed, however, perceptible changes
in performance in the last month of the period are addressed in the
functional areas.
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III. SUMMARY OF RESULTS
A. Facility Performance (September 16, 1985 - January 10,1986)
Category
Functional Area This Period
1. Plant Operations 2
2. Radiological Controls 1
3. Maintenance 2
4. Surveillance Testing 1
5. Startup Testing 1
6. Training and Qualification 1
Effectiveness
7. Assurance of Quality 1
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B. Overview
Overall, licensee management prepared their operators and the plant
well for restart in light of the long shutdown. Licensed operators
conducted themselves competently and exhibited a detailed knowledge
of the facility design and plant status. They demonstrated their
skills especially well in operating the integrated control system in
the manual mode. Despite signs of inexperience, non-licensed person-
nel also performed well. No plant trips occurred due to personnel
error, but workers in safety-related spaces were not always careful
in working around the equipment; this had the potential to cause
safety system challenges. A strong training program contributed to
the overall good results in operator performance.
Plant equipment was in good material condition and it reflected a
strong preventive and corrective maintenance program applied during
the long shutdown. The startup group assured that the numerous re-
start modifications were adequately tested to minimize operational
problems during power ascension. Plant maintenance adequately
maintained equipment subsequent to plant turnover. Very little
safety-related equipment needed repairs during the startup test
program.
In general, procedures were adequate but, in certain instances, prob-
lems with individual procedure steps challenged personnel in the prop-
er implementation of the procedures. Even though a strong procedure
control policy exists, apparently not all workers understand their
responsibilities when procedures cannot be followed.
To varying degrees, the oversight review groups performed adequately.
However, it appears that certain important findings by review groups
were not effectively acted on by licensee management.
The radiological controls program continued to be implemented effec-
tively during power operation. The unplanned radiological releases
that occurred were due to poor work planning, not radiological plan-
ning.
The surveillance and startup test programs were strong, involved com-
petent and dedicated personnel, and complemented each other in the
restart. The power escalation program was slow and deliberate, and
was effective in providing familiarization training for operators.
It was also effective in identifying and correcting overall system
integration problems.
The assessment covered a period of intense NRC staff review during
transition from a long shutdown to commercial power operation.
Licensee personnel attentiveness to the plant was probably heightened
by these circumstances. Although many of the licensee's programs are
strong, continued good nuclear safety performance will result only
with effective program implementation and sustained personnel
attentiveness and involvement.
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i Technical Support
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Technical support staffing was ample v'ith definite signs of both cor-
! porate and site engineering presence ara involvement in plant activi-
ties. In general, management exhibitew conservatism when faced with
- technical problems and, overall, technical support by licensee per-
- sonnel was adequate but not aggressive. When technical problems
could not be resolved immediately, appropriate interim measures were
provided to assure nuclear safety, such as with the relief / safety
valve problems associated with both the steam generators and the
turbine-driven emergency feedwater pump steam inlet piping. In
- certain instances, however, appropriate measures or investigations
were established only after prodding by NRC staff. Further, licensee
review of certain problems or events could have been more thorough
j and complete. Apparently, engineering personnel and management were .
not always sufficiently inquisitive to assure a complete understand-
ing of problems. In certain instances, especially during meetings
on the sixth and final NRC hold point, there was an apparent attitude
of shortsighted analysis of events. Upon final resolution, no
unreviewed safety questions were identified, and ultimately, the
licensee competently resolved the technical problems.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations (974 hours0.0113 days <br />0.271 hours <br />0.00161 weeks <br />3.70607e-4 months <br />, 25%)
Analysis
The licensee displayed excellent overall control of the plant. Li-
censed shift personnel were professional and competent in handling
routine evolutions and tests and were especially skillful in operat-
ing the integrated control system. Further, operators performed well
and demonstrated a safety conscious attitude during unexpected
events, such as the two unplanned reactor trips. The operators
showed a high level of knowledge and the ability to use that knowledge
in operating the plant safely. Shift turnovers were thorough and
professional. The shift technical advisor was integrated into plant
operations, especially in the evaluation of individual parameter
trends and of plant transients. Licensee management instilled a team
concept in the shift organization. Operations management insisted on
a quiet, professional control room atmosphere. Resources were well
managed to avoid excessive operator overtime while optimizing perfor-
mance and training benefits of the test program. The licensee made
effective use of pre-briefings for special evolutions and tests and
was responsive to NRC comments for improving the briefings. Licensee
management asserted their pre:ence and involvement during the dayshift
as well as backshifts. In summary, noteworthy performance by licensed
operators, supervisors, and coerations management resulted in excel-
lent overall plant control.
Administrative controls, procedures, and procedural adherence are
generally strong, but exceptions have been noted that require
licensee management attention. Administrative controls for TMI-1 are
well established and they reflect a strong commitment to meeting re-
quirements to assure nuclear safety. These procedures also include
licensee initiatives beyond regulatory requirements. However, cer-
tain equipment control administrative procedures are inconsistent
with each other and with sub-tier documents with respect to indepen-
dent verification of equipment control measures as described in
NUREG-0737, TMI Task Action Plan Item I.C.6. Some of these proce-
dures impose independent verification for less than the full
safety grade scope of equipment to which it is intended to apply.
Although most licensee personnel exhibited respect for administrative
controls and attention to detail in implementing procedures, a sig-
, nificant number of exceptions were noted. These included three cases
(two of which involved safety-related equipment) of conducting activ-
ities without a procedure, several minor examples of failure to ad-
here to procedures, and several other examples where personnel worked
, around obvious procedure errors rather thar stopping implementation
to obtain procedure change approval. There were also cases where a
more conservative approach was needed in implementing equipment con-
trol (tagout) measures. In two cases, reliance on minimal isolation
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barriers for maintenance work resulted in small releases of
radioactivity when single isolation points leaked. Management atten-
tion is needed to ensure that all personnel properly and conserva-
tively implement administrative and procedural controls. Also, some
upgrading of the quality of reviews of routine system operating and
test procedures may be warranted to foster worker respect for proce-
dures. This is highlighted by the fact that where procedures have
received extra attention, they are generally of good quality and are
strictly followed. Examples include safety system valve lineups and
major tests.
There was a definite presence and attentiveness on the part of vari-
ous over sight groups. The Nuclear Safety and Compliance Committee
(NSCC) performeo well. They scheduled their reviews and were able to
implement their plans well. Their reviews were thorough. The NSCC
staff has a high level of experience and good channels of communica-
tions to the board of directors. The Quality Assurance (QA) depart-
ment's presence on site was strong. This was exemplified by their
use of shift monitors, a unique and important licensee initiative.
The presence of experienced (formerly licensed) operations personnel
in the QA department enhances performance and credibility. Some
problems were noted with the Independent On-Site Safety Review Group
(IOSRG), including (1) failure to follow its own procedures and (2)
lack of a systematic approach and sufficient depth in procedure re-
view. Overall, the oversight groups provide potentially beneficial
insights, but the degree to which the licensee uses the information
is unclear. For example:
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Board dispositions for some NSCC recommendations were not clear;
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Management did not respond effectively to QA assessments regard-
ing procedure implementation problems; and,
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IOSRG discovery of a part of the independent verification prob-
lems did not lead to comprehensive resolution of
inconsistencies.
In general, management exhibited conservatism when faced with techni-
cal problems and, overall, licensee technical support was adequate
but not aggressive. When technical problems could not be resolved
immediately, appropriate interim measures were provided to assure
nuclear safety, such as with the relief / safety valves problem for
steam generators and the emergency feedwater pump steam inlet piping.
In certain instances, however, these measures were established only
after prodding by NRC staff. Further, licensee review of certain
problems or events could have been more thorough and complete. Exam-
ples included review of an RPS breaker malfunction, evaluation of
letdown cooler leakage, and evaluation of decay heat system pressure
indicator discrepancies. In general, corrective action was timely,
but there were exceptions. For example, had a more aggressive ap-
proach been taken toward ventilation system balancing, noble gas
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contamination incidents might have been precluded or ninimized. Oth-
er functional areas describe related instances of poor technical sup-
port, most notably reflected in "Furmanite" repair jobs. Apparently,
engineering personnel and management were not sufficiently inquisi-
tive to assure a complete understanding of certain problems, espe-
cially when a short-term, multi-disciplined review was needed. Upon
final resolution, no unreviewed safety questions were identified and, i
ultimately, the licensee competently resolved the technical problems.
In summary, licensee management. prepared the plant and their opera-
tors well for restart. For the most part, procedures were techni-
cally adequate but individual procedure step inadequacies challenged
personnel in strictly adhering to those procedures. In general,
there is respect for procedure adherence, but there were too many
instances where personnel either did not follow or sidestepped a
procedure step. It appears that in certain instances, personnel
understanding of the licensee's strong procedural control policies
are not well understood. To varying degrees, the oversight review
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groups are performing adequately; however, some important findings
were not acted on effectively by licensee management. Overall
licensee performance in this area was effective and well oriented
toward nuclear safety.
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Conclusion
Category 2
Recommendation
Licensee: Discuss at the SALP meeting (1) licensee actions to im-
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prove the technical support area, (2) measures to instill in all
workers appropriate attention to operations phase administrative con-
trols, and (3) licensee measures to ensure optimal benefits from
oversight group findings.
. NRC: PAT I should review extensively the licensee's independent
technical and safety review process; by PAT II, an assessment
- should be made of the licensee's plant safety review processes; in
particular, the reliance on individual reviews as contrasted with
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interdisciplinary committee reviews.
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B. Radiological Controls (244 hours0.00282 days <br />0.0678 hours <br />4.034392e-4 weeks <br />9.2842e-5 months <br />, 6%)
Analysis
The licensee's radiation protection program continued to be well de-
fined by clear policies and directives. Startup inspections indicat-
ed that the licensee satisfactorily implemented the radiation
protection program in accordance with regulatory requirements. An
adequate staff was available to carry out the program, and the per-
sonnel involved were well qualified and capable of performing satis-
f actorily in their assigned areas of responsibility. A formalized
training program for the radiation protection staff continued to be
implemented and provided sufficient technical and practical instruc-
tions to assure competence in the o ganization.
! Adequate management review and oversight are consistently evident as
demonstrated by their awareness of daily activities, the establish-
ment of effective inter-departmental communications and cooperation.
The quality assurance department has a lead monitor in this area
for oversight of radiological control activities. The radiation
protection management staff takes the initiative in improving and
enhancing radiological control practices and procedures. For example,
(1) the licensee's radiological staff initiated the iavestigation of
- noble gas migration pathways in the auxiliary and fuel handling build-
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ings, and consequently effected corrective measures to better control
airborne activity in the facility; (2) both health physics-field
operations and radiological engineering groups perform frequent
! planned inspections and audits of radiologically controlled areas,
I work activities, policies and procedures to assure quality perform-
ance; and (3) all anomalous occurrences that have the potential to
affect exposures to workers or the general public are aggressively
reviewed and evaluated to ascertain causal factors, corrective
measures, and dose effects. Additionally, radiological controls
awareness meetings are held monthly by the radiation protection,
maintenance, and operation departments to exchange information and
resolve concerns pertaining to radiological work, practices, and pol-
icies. These meetings are also attended by representatives from the
bargaining unit, the Vice President and Director of TMI-1, and con-
cerned workers.
The licensee generally exhibits good radiological control practices
and they implement a very thorough radiation worker training program
in an effort to ensure that radiation workers are aware of radiolog-
ical safety procedures and are able to implement them competently.
The TMI-1 Restart Staff noted that the licensee consistently demon-
strated a strong commitment to ALARA. During radiological work
performed in this assessment period, the licensee used ALARA
engineering practices, job planning, and worker training to reduce
personnel exposure.
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l Effective programs relative to radioactive waste management, effluent
monitoring, and control and transportation of radioactive materials
were implemented and maintained. Effective quality control measures
are embodied in laboratory procedures and practices. The licensee's
i performance in this area was consistent with regulatory requirements.
In general the licensee's performance during various operations and
- maintenance activities involving high levels of-radioactivity demon-
- strated reasonable planning and preparation, good procedure develop-
ment and/or use, and the establishment of appropriate radiological
- controls. However, there were examples where better planning could
have prevented releases of radioactivity and the contamination of
workers. For example, the work on the waste gas compressor resulted
in a release because a check valve was relied upon to isolate the
, waste gas header (see Functional Area A, Plant Operations). Other
similar instances were noted which related to poor work planning,
although not specifically poor radiological planning. Licensee re-
view of the above events was thorough with extensive use of the radi-
,
ological awareness report and investigative reports.
'
In summary, the licensee was able to demonstrate that program ele-
ments continued to be effectively implemented during power operations,
and the licensee adequately trained and qualified personnel responsi-
l ble for implementation of the radiological control program. Implemen-
tation problems were not due to programmatic weaknesses but were
,
related to poor individual worker performance or inadequate support
l from other departments such as operations or engineering. The
<
licensee's program in this area is technically sound.
Conclusion
i
i Category I
! Recommendations
None
j
,
4
i
.
. - _ - . . - - - -_. _ . - - . - - - . _. . . . - - , - .. - . -
_ ___ _
_ ._ .
.
.
16
C. Maintenance (288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br />, 7%)
Analysis
The maintenance organization was staffed with knowledgeable and
skilled personnel to support the required maintenance activities to
maintain safety-related equipment in a proper condition. When
maintenance-related work was identified by operations, the mainte-
nance department was aggressive in scheduling and completing the work
based on the priority assigned by management. Managerial involvement
on a daily basis in supervising, tracking, identifying and resolving
problems resulted in a high level of plant operational readiness.
A continued positive management initiative was that of permanently
j assigning maintenance personnel to one of the six rotating shifts.
j This reduced the typical power plant peaks of high maintenance
j activity during the dayshift. It also allowed the maintenance
,
department to schedule and perform corrective maintenance on vital
i
equipment as problems developed. Placing a portion of maintenance
l personnel on shift work did, however, dilute the experience level in
'
the I&C area. This dilution of experience in the I&C area caused
minor operational problems which resulted in delays in retests until
supervision arrived on site. The electrical and mechanical main-
tenance experience remained at a high level. The collective know-
4
ledge of the maintenance department was sufficient to resolve equip-
,
ment problems. In addition, maintenance personnel appeared to be
highly motivated and supportive of management.
Administrative controls in the area are adequate and properly imple-
mented along with maintenance procedures. The staff identified a
minor drawing control violation with respect to posted drawings in-
side control room cabinets. This was uncharacteristic of the
licensee's drawing control program. Another instance was noted where
individuals failed to follow a maintenance procedure and this result-
ed in the loss of a safety-related electrical bus. The individuals
involved were disciplined for failing to cooperate in the licensee's
review of this event. I&C personnel were involved to a limited ex-
tent in the procedure implementation problems addressed in other
sections.
During this assessment period, several major safety-related systems
were reviewed closely by inspectors to determine overall reliability.
and operability of the equipment. Emphasis was placed on preventive,
'
as well as corrective maintenance by management in response to plant
restart. Preventive maintenance procedures appropriately reflected
vendor technical manual recommendations. Safety-related equipment was
.found to be in good material condition. Machinery history and mainte-
nance records reflected proper documentation (consistent with restart
hearing board requirements) and this resulted in development of a
useful historicci data base on plant equipment. Records and field
observations reflected the involvement of the QA department in as-
suring operability of safety-related equipment.
-
. _ . -
.
.
17
No instances were noted of inoperability or poor testing because of
maintenance procedures. However, certain maintenance procedures
lacked specificity and clarity associated with the recording and/or
evaluation of as-found conditions. This lack of clarity has forced
maintenance personnel, independent of plant engineering, to evaluate
and determine the operability of equipment in the field with limited
guidance. This has pointed out a need for enhanced procedure review
and approval and better technical support on the evaluation of
as-found conditions.
Maintenance personnel, in particular, and other groups of personnel
doing work in safety-related spaces, were somewhat insensitive to the
! change to an operating mode. In certain instances, personnel contin-
ued their working habits as though the plant was in a shutdown condi-
tion. As a result, a violation occurred on unsecured scaffolding
!
that in a seismic event may have jeopardized the ability of the die-
1
sel generator to function. Other potentially adverse conditions oc-
l curred..the most significant of which was the inadvertent tripping of
i the emergency feed pump during scaffold construction, causing the
J pump to be inoperable for several hours. The day-to-day approach and
i
attitudes of non-operations personnel was changing but not completely
corrected by the end of the period.
I Housekeeping and fire protection measures remained consistent with
the previous high standards implemented during the long shutdown.
Extensive use of absorbent material to collect oil drippings was used
and contaminated drainage was directed to floor drains using tygon
tubing. However, certain areas of the turbine building were not re-
flective of those cleanliness standards that were applied to safety-
related areas. No fire hazards were created in the turbine building;
by the end of the period, conditions improved substantially in that
building.
Sufficient technical support was provided to maintenance and good
communication existed between this department and plant engineering.
There was consistent evidence of engineering evaluations in mainte-
nance packages. There was, however, incomplete support for " Fur-
manite" repair to leaking flanges and valves. The licensee started
work during the 40% trip outage without considering the stress
induced by this process on the flange bolts. Another example was the
poor control of the amount of Furmanite for repeat injections evi-
denced during the full power trip outage. As a result, an OTSG level
instrument root valve clogged during the injection process and the
material was later blown into the OTSG. Further, no consideration
was given to the effects of the material in the OTSG until questioning
by the NRC staff occurred. Upon complete review of these problems,
no unreviewed safety questions were identified by the licensee.
These examples reflect a need for licensee management to assure a
more inquisitive evaluation of plant problems.
.. . . . . .. - _ . _ _ - - - _ .__ _- - . - _ - . .. ..- . - - _ - -
.
i
^
.
j 18
4
i
Overall, the maintenance program is properly established, implement-
ed, and adequately staffed. Management involvement at all levels is
evident. Equipment and plant material condition are well maintained i
i and in a condition that supported unit startup. The QA department is
- very active in this area. Personnel attitude toward work in the
spaces still reflects attitudes associated with a plant in cold shut-
- down; however, it has not as yet had an adverse effect on plant
- safety.
4
l Conclusion
!
) Category 2
Recommendations
None
i
,
,
I {
!
.
1
i
!
l
i
i
)
i
i
I
l
1
l
t
1
l
!
l
!
!
i
_ . _ ._ _ _ _ _ . .
-
!
i
.
19
- D. Surveillance Testing (252 hours0.00292 days <br />0.07 hours <br />4.166667e-4 weeks <br />9.5886e-5 months <br />, 7%)
Analysis
During this inspection there was a high level of NRC inspection cov-
erage in this area as evidenced by inspection report documentation of
all or portions of over sixty surveillance tests. This included all
types of surveillances, including maintenance, operations, radiolog-
ical controls, and instrument and control surveillance. In addition,
the data and calculations of numerous other surveillance tests were
reviewed.
The licensee has a strong administrative program which assures that
tests are conducted at the specified frequency. The overall adminis-
trative program was properly implemented except for minor problems.
A computerized scheduling system was used for the surveillance test
program. Accordingly, surveillance tests were effectively integrated
.
'
with routine plant operations and well coordinated with operations
department activities. Surveillance procedures, with a few minor
exceptions, were properly implemented. Surveillance tests required
. by the technical specifications were conducted at the specified fre-
! quency with one exception. A fire surveillance was missed for sever-
1
al days due to the improper issuance of a procedure change. This
j violation of requirements was considered minor.
During this inspection period, NRC staff performed an extensive re-
view of safety-related equipment operability regarding the following
components: the makeup pumps, decay heat pumps, and the diesel gen-
erators. The review included operating procedures, technical speci-
fication compliance, inservice testing, preventive maintenance,
maintenance history, and surveillance testing. Applicable surveil-
lance tests were found to be technically adequate in that they met
all applicable NRC requirements. Surveillance test procedures, along
with maintenance procedures and post-maintenance testing, provided
adequate assurance that the selected safety-related compcnents were
operable when called upon.
Surveillance procedures were properly followed. Tests were performed
in a deliberate manner ensuring that each step was completed prior to
proceeding to the next step.
'
Records were well kept. For a surveillance test of frequency of
ninety days or longer, a hard copy record of the last completed test
was maintained in the control room. Once a test was completed, the
newer test was placed in the file and the older test was sent to
plant records for microfilming. This system enabled technicians or
operators good access to the most recently completed tests, if neces-
sary. In addition, extensive test records were reviewed by NRC and
found to be complete with one exception, discussed below.
i
!
l
l
._ .. , - . - . _ . - .-, . , . - - -- .. -. - . - _ -
-. .- _. .. . _ - - ._ ._
.
20
Of particular concern during this period were the circumstances that
developed during and after a routine surveillance test of the
pressurizer power operated relief valve (PORV). The issues of con-
cern included: (1) a routine test that could not be completed be-
cause a portion of the test was not conducted correctly, (2) the
>
unnecessary creation of both a deficiency sheet and an exception L
sheet as a result of that test and, subsequently, throwing tnese
'
sheets away and (3) the confusing documentation used to substantiate
the shift supervisor's determination of operability of the PORV.
There was prompt involvement by senior management in the retest when
'
operability questions arose. However, the NRC staff's early involve-
ment in this process led to discovery of the exception and deficiency
sheets that had been thrown away and the identification of the poor
,
'
instructions for handling exceptions and deficiencies. This records
handling problem was considered uncharacteristic of the licensee's
records management program. It did point out a need for additional
attention to detail on the part of licensee personnel in handling
these particular records. Further, the licensee's review and approv-
al process could have developed better instructions for the handling
of test problems.
Although other mistakes were made by personnel, in general, licensee
supervision caught them before any adverse condition resulted. A
number of examples were noted in which supervision or senior personin
nel corrected errors made by junior personnel. This was especially
evident in the I&C area. Because of supervisory presence, corrective
actions were appropriate to satisfactorily complete tests and avoid
challenges to safety systems.
Staffing was ample in this area along with good interdepartment in-
terfacing. A specially assigned staff representing the maintenance
and operations department assured overall good coordination of sur- .
veillance test implementation and records. Personnel, in general,
'
were qualified to perform surveillances but as noted above, some in-
experience was evidenced by a few individuals. None of the unplanned
reactor trips during this period were caused by surveillance tests.
Overall, the licensee has a strong surveillance program. Management
and QA department involvement in this area is evident. The problems
observed were few in number and did not adversely affect plant safe-
ty. The licensee safely conducts surveillance tests during plant
1 operations.
l Conclusion
!
i
Category 1
Recommendations
None
_ _
_ _ _ _ _ . - . , . . _ _ . , , _ _
. _ , _ , . . - -- . . _ _ _
- . . . - - . .- _- . . -. -- . . - . - . - . .
-
.
1
.
21
l E. Startup Testing (561 hours0.00649 days <br />0.156 hours <br />9.275794e-4 weeks <br />2.134605e-4 months <br />, 14*4)
4 During this SALP period, the licensee performed an extensive power
escalation test program over a three-month period. This program was
successfully completed with only minor performance problems noted.
l Testing was performed at predetermined power levels from 0 to 100
i percent power for both transient and steady-state conditions and in-
! cluded tests of reactor physics performance, natural circulation,
l integrated control system, feedwater system, errergency feedwater sys-
tem, plant performance during reactor trips, and measurements of re-
actor coolant system and steam generator leakage. NRC inspectors
witnessed all scheduled plant transients and portions of selected
~
steady-state tests, and reviewed all licensee test data and resolu-
tions to all test exceptions and deficiencies.
Overall test performance by licensee personnel, including plant oper-
- ators, reactor engineers, test engineers, and supporting personnel
from the headquarters safety analysis group, was very good. Opera-
tors always remained in control of the plant during special and in-
- tensive test periods. The reactor engineering group, which performed
- the physic testing, was well prepared in this aspect of the startup
'
,
test program. The licensee assured that ample supporting specialists
from the fuel vendor and corporate fuel groups were present. In
i addition, innovative software programs were employed to monitor and
predict core status on a real time basis. With proper interfacing
with the licensed operators, this resulted in tests being completed
in an effective and well-controlled manner. Although reactor engi-
neers initially were aggressive in their requests to operators to
establish plant test conditions, plant operators were always in
( control of plant operations.
J
j The startup test engineers had the largest portion of the program;
i
directing test evolutions from natural circulation testing through
the final reactor trip at 88 percent power, to subsequent steady-
- state testing at 100 percent power. Except for the first part of the
- natural circulation test, plant testing was well-coordinated with
good interface with the plant operators. Data were properly taken,
- i
data stations were adequately manned, and data reduction was per-
formed properly. Test exceptions and deficiencies (E&Ds) were pro-
perly resolved and all data along with test problems were reviewed by
,
the Test Acceptance Group in formal meetings conducted periodically
during each test phase. In spite of some minor delays during the
,
program, all testing was completed within the scheduled time frame of
the test program.
I The extensive pre-test training of reactor engineering and test engi-
- neering personnel was evident in the overall lack of personnel prob-
- 1 ems during test performance. Test briefings for major evolutions
!
were thorough and extensive. Problems noted during earlier tests,
- where applicable, were factored into briefings for later tests.
j Quality assurance involvement in startup testing was extensive in
!
!
i
I
,, .,___, ,, _ _ _ . _ . . , _ _
__ _ . __ _ __ _ - . _ _ _ . _ _ _ - . _ ._ _
_ _ . =_ -. _- . . . - . - . . - .- - - -- -
1 .
.
22
that QA monitors were on shift for all testing. In addition, QA had
prepared a detailed test monitoring plan and documentation of QA mon-
itoring activities was comprehensive. Licensee management attention
and involvement were very evident in that top management was present
and witnessed major test evolutions and power escalations.
Generally, in handling technical problems, licensee management did
exhibit conservatism. During the initial startup, licensee manage-
ment ordered the reactor to be stabilized high in the source range
until one of the two instrument channels for the intermediate range
neutron power was fixed. While performing an all-rods-out boron mea-
surement test during zero power physics testing, too much boron was
added to the reactor causing suberiticality. This " boron overshoot"
condition was promptly noted and the reactor engineers and operators
displayed a cautious approach in the boron dilution needed to correct
the problem. The licensee was responsive to staff concerns on the
emergency feedwater system turbine relief valve inadvertent actuation
'
problem and to the interaction problem between the steam generator
safety valves and the turbine bypass valves. ' Adequate interim
corrective action in terms of procedural guidance was provided to the
operators for both of these technical problems. Overall, licensee
management competently resolved their technical problems.
. Based on staff review, the startup test procedures were comprehensive
!
and accomplished the desired test objectives with some minor problems
as discussed below. Procedures were followed completely during the
test. All test data reviewed by the NRC staff were correct, and E&Ds
,
were properly resolved.
Notwithstanding the positive aspects of the test program, some
problems with procedures and personnel were observed. During the
.
first part of natural circulation testing, test engineers did not.
, appear to be fully organized. This problem was recognized by manage-
ment and was quickly corrected. The test could have been better
planned to instruct the operators how to recover from the unique plant
conditions. As a result, at initial restoration of forced circulation
1
'
flow, a steam generator safety valve lifted. Other procedure defi-
ciencies were noted with respect to clarity of instructions. Test
! management took corrective actions to improve these situations. At
j
4
the conclusion of the test program following the reactor trip at 88
percent power, one further test deficiency was noted in that the
, reactor trip test failed to document the reset function of the let-
'
down isolation valve MU-V3 following the reactor trip. The adequacy
of MU-V3 to open after a trip was subsequently demonstrated through a
separate retest after NRC staff prodding on the issue.
i
In summary, the licensee performed very well during the TMI-1 restart
startup testing program. Aggressive management attention and involve-
ment at the upper and middle management levels contributed to the
, 1
l
l
!
l
- ..
. ._
. - . . ,- - . - - - . . . --
.
23
effective program. The startup program was effective in identifying
equipment problems, especially from the viewpoint of integrated
system operations. The test program was thoroughly planned, accom-
plished on a realistic schedule, and provided ample time for operator
training and familiarization. Licensee initiatives having generic
B&W applicability in this area were noteworthy. Although they
constituted unique tests, more comprehensive reviews should have
been considered by the licensee before implementation.
Conclusion
Category 1
Recommendations
None
. _ - - - -- ,_
- . - - ._ _ _ . - _. . - - - -
i .
'
a
.
1 24
F. Training and Qualification Effectiveness (NA)
Analysis
i
The various aspects of this functional area have been considered and
discussed as an integral part of the other functional areas and the
respective inspection hours have been incorporated into the respec-
tive functional areas. Consequently, this discussion is a synopsis
of the assessments conducted in other areas. Training effectiveness
, is measured primarily by the observed performance of licensee per-
sonnel and, to a lesser degree, as a review of program adequacy.
This discussion addresses three principal areas: licensed operator
training, non-licensed staff training, and the status of INp0
training accreditation.
The training department was staffed with knowledgeable and experi-
enced personnel. The lesson plans, specialized manuals and courses,
hands-on experience, and/or extensive use of simulator and basic
principles simulator training provided meaningful and practical
training not only to licensed operators but also to other operator
technical personnel. This was evident in the performance of new
4
'
candidates for operator licenses. All candidates for licenses or
instructor certifications passed. They included four SRO candidates,
one RO candidate (on retake), and one instruction certification can-
didate.
! As noted in the plant operations section, observations of licensed
operator personnel by shift inspectors produced a good deal of infor-
l
mation relative to their level of knowledge and performance skills.
The results of that review were favorable. The special interviews and
discussions on shift confirmed a high level of knowledge of facility
i design with only minor weaknesses observed. Operators were well pre-
!
pared for restart and demonstrated especially strong skills in manip-
ulating the integrated control system in the manual mode. The
training for the non-licensed staff consisted of both formal and
, on-the-job training. Based on NRC observations, this program was
also effective in producing performance-oriented personnel similar to
! the licensed operator program. During the implementation of work
, activities, in general, non-licensed personnel were appropriately
- knowledgeable in the requirements of the procedures and plant design.
Experienced personnel provided adequate guidance to less experienced
j personnel.
I
No plant trips occurred due to personnel error. However, inspectors
saw a persistent problem with workers in various plant areas having
the potential to cause a trip or a challenge to a safety-related
system. Personnel (licensed operators included) were also involved
in the problem with the proper implementation of administrative
,
'
controls for procedure implementation. There seemed to be a dis-
connect between the well-stated management policies in these areas
l and the understanding of those policies by certain individuals.
!
.
!
!
- _ . _ _ _ . __ __. - __ __. . _ _ . _ _ _ _ __
.
.
25
Even with the corrective action initiated before the end of the power
escalation program, licensee management had not completely reached
all plant workers and corrective action is not yet complete.
The licensee received training program accreditation from INPO in the
following Jive areas: control room operators; senior reactor opera-
tors; shift technical advisors; auxiliary operators; and radiological
control tecnnicians.
In summary, the licensee's training program is effective and is ori-
ented toward improving on-the-job performance. The program has the
support and commitment of management. The QA department is actively
involved in training. In general, personnel are knowledgeable of
work and procedural requirements, and conduct activities with care.
When faced with problems, personnel take conservative measures and
seek help.
Conclusion
Category 1 (based on functional areas addressed)
Recommendations
None
.
-
---.. . - . - . - _.-. - .
- -
!
.
26
.
'
G. Assurance of Quality (NA)
.
The variou aspects of quality assurance program requirements have
been considered and discussed as an integral part of each functional
area and the respective inspection hours are included in each one.
Consequently, this discussion is a synopsis of the assessments
conducted in those areas.
The quality assurance department continued their aggressive involve-
ment in oversight activities. This was reflected in their unique
three levels of review along with a substantial resource initiative
--24-hour QA shift monitors. Licensee management continued their
orientation in staffing the department with experienced personnel
along with providing career enhancement positions for licensed (or
formerly licensed) TMI-1 operators. This had the added benefit for
,
licensee management of enhancing the operational expertise of the QA
i department to fulfill its responsibilities in the oversight of
"
operations.
There was a definite QA presence and involvement in the various fac-
ets of field activities. The monitoring level of review was effective
in identifying the procedure implementation problems later noted by
- the NRC staff. As a result of successful monitoring, the audit group
! more effectively used their time in reviewing programs and program
l implementation. However, licensee management apparently did not
!
effectively respond to the QA department for the procedure implemen-
l tation problem, which was highlighted in the QA department's annual
effectiveness review.
.
'
In summary, there was management and quality assurance (QA) depart-
ment presence and involvement in all facets of activities at the site,
i Licensee management may need to provide additional attention to the
QA department's effectiveness reviews.
- Conclusion
- Category 1 (based on the functional areas addressed)
i
4
a
?
!
l
l
.l
Y
s-m- . - -, ,- _ , -. ,,, _ , , , , , . y.,__m. --. 3 . r_. e , , - --. . ,, .-~
_ _.
.
4
27
Recommendation
Licensee: None
NRC: PAT look at the effectiveness of the QA review process.
i
!
- . - . ..- -- -
. - . - - , .
.. _ . . - _ _ _ - .
.
.
28
V. Supporting Data and Summaries
A. Investigations and Allegations Review
There are no open investigations for TMI-1. The investigation on the
environmental equipment quali'ication apparent material false state-
ments was completed during this period and it is being reviewed by
Region I staff.
There were no allegations received during this assessment period.
B. Escalated Enforcement Actions
None
C. Management Conferences
None
D. Licensee Event Reports
Only three licensee event reports were submitted during this period.
They are listed below instead of being tabulated in a separate table.
--
LER 85-002, dated October 3, 1985, for the manual reactor trip
(from hot shutdown condition) that occurred on September 7,
1985, due to operator action in response to a fire in the rod
control system. The root cause was an equipment / component mal-
function (re: PLANT OPERATIONS AREA).
--
LER 85-003, dated December 31, 1985, for the reactor trip from
75 percent power that occurred on December 1, 1985, due to a
proximate cause of high pressure in the RCS. The root cause was
an equipment / component malfunct'on with a main generator relay
that caused a main turbine rejection which caused.the transient
in the RCS (re: PLANT OPERATIONS AREA).
--
LER 85-004, dated December 26, 1985, for inoperable fire barri-
ers found on November 26, 1985, to a makeup pump cubicle without
a fire watch during modification work. This was due to person-
nel error (re: PLANT OPERATIONS AREA).
In summary, all LERs were listed in the plant operations area; two
with component failure causes and one with a personnel error cause.
No casual link can be inferred among the three LERs. However, LER
85-003 and an LER to be submitted outside this assessmer.t period re-
flects a possible need for improvement in the design of. secondary
trip function logic in which a one-out-of-one malfunction caused a tran-
sient on the RCS.
... -- . , . - .- . ._ . .. . . _ - - . -.
.
!
-
!
- 29
1
i
5 LER 85-004 was indicative of the worker in the spaces problem identi-
l fied in the maintenance area.
J
i E. Reactor Trips / Forced Outages
i T3ble 5 reflects the unplanned reactor trips and reactor shutdowns
i
along with root causes. Also, the main turbine was taken off-line
i with the reactor critical at low power during October 13-18, 1985,
j for turbine steam inlet drain line repairs, as discussed in paragraph
I.C.I.
5
The following reactor trips that occurred during this period were
'
planned per the licensee' test program: 2
--
October 15, 1985, Manual PLANNED in accordance with
startup test procedures
--
October 21, 1985, Loss of PLANNED in accordance with
Feedwater power escalation procedures
].
--
January 2,1986, Turbine Trip PLANNED in accordance with
power escalation procedures
! F. Planned / Unplanned Releases
, Table 6 is a summary of the more significant unplanned releases for
j the period, along with a summary of the routine releases from the
plant on a monthly basis. No regulatory limits were violated.
!
I
i
,
t
e
i
E
9
I
!
l
<
i
,
._. _
. _ . . .-_ ._
.
.
T1-1
1
- TABLE 1
INSPECTION REPORT ACTIVITIES
,
TMI-1 NUCLEAR GENERATING STATION
REPORT NO./ PERIOD AREAS
'
AREA INSPECTED INSPECTOR TYPE HOURS INSPECTED
.
85-22 '
SHIFT 683 Power Operations
9/16/85-10/11/85 RESIDENT / PROJECT Startup Testing
STARTUP TESTING
ENGINEERING SPECIALIST
- 85-24 SHIFT 369 Power Operations
- 10/11-18/85 RESIDENT / PROJECT
'
Startup Testing
i STARTUP TEST Licensed Operator
4
RADIATION SPECIALIST Training
Radiological .
Effluent Control l
85-25 SHIFT 352 Plant Operations
'
10/18-25/85 RESIDENT / PROJECT Startup Testing
STARTUP TEST
^
85-26 SHIFT 501 Plant Operations
10/25-11/12/85 RESIDENT / PROJECT Startup Testing
,
RADIATION SPECIALIST Radiological
Effluent Control
3
85-27 SHIFT 603- '
Plant Operations
,
11/12-27/85 RESIDENT / PROJECT Startup Testing
STARTUP TESTING Radwaste Management
i 85-28 SHIFT 540 Plant Operations
11/27-12/13/85 RESIDENT / PROJECT . Startup Testing
STARTUP TEST Radiological
RADIATION SPECIALIST Effluent Control
85-30 SHIFT 858 Plant Operations
12/13/85-1/10/86 RESIDENT / PROJECT Startup Testing ,
STARTUP TEST Radiation Protec-
RADIATION SPECIALIST tion
ENGINEERING SPECIALIST
,
I
h
,
$
_ . , , _ _ ,__._ __ _.,m, _,,, , y. , . .
._c, , _ , _ _ _ ,p,y, , p,, m. ,. , , , my, _ , _ , _ , . , , , . , , . , , , , , , , , , , . , , _ _ , v. , , , , _ ,,y_y.,.s
.
.
T2-1
TABLE 2
INSPECTION HOURS SUMMARY (9/16/85 - 1/10/86)
TMI-1 NUCLEAR GENERATOR STATION
HOURS % OF TIME
Plant Operations 974 25
(Shift Inspection Hours) 1617 41
Radiological Controls 244 6
Maintenance 288 7
Su-veillance Testing 252 7
Startup Testing 561 14
Training and Qualification Effectiveness (included in above)
Assurance of Quality (included in above)
Total 3936 100
.
.
T3-1
TABLE 3
ENFORCEMENT SUMMARY (9/16/85 - 1/10/86)
TMI-1 NUCLEAR GENERATING STATION
A. Number and Severity Level of Violations
Severity Levet IV 6
Deviations -
Total 7
B. Violations vs. Functional Area
Functional Area Severity Levels
I II III IV V Dev Total
Plant Operations 4 4
Radiological Controls
Maintenance 1 1 2
Surveillance Testing 1 1
Startup Testing
Training and Qualification
Effectiveness
Assurance of Quality
Totals 6 1 7
_ _ _ _
.
.
.
T4-1
TABLE 4
ENFORCEMENT DATA
TMI-1 NUCLEAR GENERATING STATION
Inspection Inspection Severity Functional
Report No. Date Level Area Violation
85-22 9/16-10/11/85 IV Maintenance Failure to
properly control
scaffolding in
safety-related
areas
85-25 10/18-25/85 V Maintenance Failure to
properly control
drawings inside
control room elec-
trical cabinets
85-27 11/12-27/85 IV Plant Failure to
Operations establish or
properly change
procedures for
safety-related
activities
85-27 11/12-27/85 IV Plant Failure to
Operations completely review
for adequacy proce-
dures for indepen-
dent verification
of safety-related
activities
85-27 11/12-27/85 IV Plant Failure to
Operations properly implement
technical specifi-
cations and related
administrative con-
trol for indepen-
dent onsite safety
review group
(10SRG) activities
.
.
T4-2
TABLE 4 (Continued)
Inspection Inspection Severity Functional
Report No. Date Level Area Violation
85-27 11/12-27/85 IV Security Failure to
(Plant properly implement
Operations) security personnel
badge identifica-
tion control
measures
65-30 12/13/85 IV Fire Failure to
Protection properly inspect
(Surveillance) a fire door on
the specified
frequency
,
~+ w
_ .._ _ _ ______ _ _ _ _ _ - . .. .. . ._. _ . . .
. ,
'
i
.
. T5-1
I
i
i
i
TABLE 5
4
UNPLANNED REACTOR TF.IPS
1
,
AND
l '
SHUTDOWNS
q
Unolanned Reactor Trips
Date Description Root Cause
4
i
December 1, 1985, The high RCS pressure resulted Secondary plant trans-
High RCS Pressure due to a load rejection with. ient due to electrical
i '
the tripping of the main grid transient
generator breaker. An over-
i excitation protective relay
malfunctioned when a regional
"
, grid voltage transient coupled
l '
with a relay setpoint drift
occurred
I
j January 4, 1986, The turbine trip resulted Fandom equipment mal-
l Turbine Trip because of an abnormal high runction in the'second-
level in one of six moisture ary plant
i separators due to a level
'
controller malfunction in
the feedwater heater drain '
collection tank
Unplanned Shutdowns
None
i
i
i
i
i
j
a
j
$
i
--
vv.,,... . - . , _ , , . , , . . . . - . , ..m. .. ._.m..__..~,,,_m_, ,._, - ,,,,,,. ...,, ... _ ,.. _,, ,- .._ _ . . ,, -
, , , , . , , . - ,
. . ._ - - _
. . . . - . - . . . . . - . .__ . .
,
!
! T6-1
1 .
I
i
TABLE 6
i
RADIOLOGICAL EFFLUENT RELEASES
,
j Anomalous Occurrences Resulting in Off-Site Releases of Noble Gases
I '
'
% of Technical
l Specifications
! Component Release Activity Quarterly
,
Date Involved Point Released (Ci) Duration Limit, Gamma
10/21/85 Reactor Trip Main Steam 1.07E-6 10 sec 3.8 E-8
'
at 40% Relief Valves
(MSRV)
- 10/28/85 Makeup Pump Station Vent 0.7 42 min 0.0015
4
t
(SV)
l 11/2/86 Reactor SV 1.05 75 min 0.027
. Coolant
) Evaporator
i
l 11/19- Main Steam MSRV 1.6 E-7 5 sec 3.48 E-0
l 20/85 Valve Testing
j 12/1/85 Reactor Trip MSRV 7.32 E-6 7 min 1.5 E-7
j at 75%
! 12/17/85 Waste Gas SV 1.4 54 min 0.001
! Compressor
j 12/30/85 Makeup Pump SV 46.3 274 min 0.07
4
,
Normal Operating Releases - Predominantly Noble Gases
j October 0.15 (0.02% 0.00132
>
particulates)
'
i
i November 18.8 (0.0003% tritium) 0.02
December 5.29 0.0076
Normal Operating Releases - Liquid - Predominantly Tritium
'
October 1.0 (0.03% non-tritium)
November 1.19 (0.01% non-tritium)
[ December 5.99 (4.4 E-3% non-tritium)
!
i
! I
i-
I
r,-w,-c y.,,p,p,,-.-r-r 3-,,.v---.--e,--- -v. ~~--.r- -,y-ny.-y..-~,,,.-.m.-.-.< --,----,,.w.w.c,,., ,_,.--,cwn-r,y,-~,.,-emw.r_ -=-r+-wms-w -n-+eceo- --- r--w-*~ese,=-