ML20155G850
| ML20155G850 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 05/06/1982 |
| From: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| To: | Starostecki R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20151G994 | List: |
| References | |
| NUDOCS 8806200117 | |
| Download: ML20155G850 (18) | |
Text
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, . ENCLOSURE 3 QPU Nuclear y gf 100 Interpace Parkway Parsippany, New Jersey 07054 201 263 6500 TELEX 136-482 Writer's Direct Dial Number: ,
May 6, 1982 Mr. Richard Starostecki, Director Division of Project and Resident Programs U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Starostecki:
Subject:
Oyster Creek Nuclear Generating Station Docket No. 50-219 Systematic Assessment of Licensee Performance (SALP)
Your letter of April 7, 1982 provided, for our review and response, a draf t Systematic Assessuent of Licensee Performance (SALP) report concerning activities conducted at the Oyster Creek Nuclear Generating Station for the period November 1, 1980 through October 31, 1981. Attachment I to this letter '
provides our responses to the maintenance and surveillance areas which were classified as areas of weakness.
In addition to our specific responses concerning those two areas, we. are taking this opportunity to provide comments on the other areas which were l evaluated. The additional comments, also contained in Attachment I, are I
provided to help meet the SALP objective of furthering NRC's understanding in how the licensee management directs, guides, and provioes resources for l assuring plant safety. '
1 Very :ruly yours, 8906200117 88061029 Philip R l
DR ADOCK 050 Executiv/' Clark e Vice President '
GPU Nuclear Corporation ec: Mr. Ronald C. Haynes, Administrator Region I U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 }
NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, NJ 08731
' 3
ATTACHFENT I
Subject:
Responses and Comments to the NRC Systematic Assessment of Licensee Performance (JALP) l Evaluation Period: November 1, 1980 Through October 31, 1981 :
Summary of NRC Evaluation:
FUNCTIONAL AREAS OYSTER CREEK NUCLEAR CENERATING STATION l
CATECORY CATEGORY CATEGORY ,
1 2 3 j
- 1. Plant Operationis X
- 2. Radiological Controls X
- 3. Maintenance X
- 4. Surveillance (Including Inservice and Preoperational Testing) X l 5. Fire Protection and Housekeeping X
- 6. Emergency Preparedness 'I l 7. Security & Safeguards X
- 8. Re fueling X
- 9. Licensing Activities X Category Definitions:
l Category 1: Reduced NRC attention may be appropriate. Licer.see management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of parformance with respect to operational safety or construction is being cchieved.
Category 2: NRC attention should be maintained at normal levels. Licensee management attention and involvement are evident and are concerned with nuclear l 'sefety; licensee resources are adequate and are reasonably effective such that l satisfactory performance with respect to operational safety or construction is boing achieved.
Category 3: Both NRC and licensee attention should be increased. Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appeared strained or not offectively ured such that minimally satisfactory performance with respect to operational safety and construction is being achieved.
1 Page 2
'1. Plant Operations - NRC Evaluation 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 adherence to management controls procedures at the lower management and supervisory levels, and in the area of meeting commitments to the NRC. ,An improving trend waa notad as licensee management responded in a positive manner to address the identified weaknesses.
- This ares 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 viola
- ions. 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 prucedures. Two Severity Level IV
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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 lef t open. Failure to report an unplanned radioactive release and inadequate corrective action on recurrent pills of radioactive liquid resulted in two Severity Level IV violations. One Severity Level 11 violation involving vacuum breaker blockage was indicative of inadequate controls over activities affecting plant operations, and sometimes inadequate tours of the plant by operations personnel. 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 mansgement involvement in this area. The licensee has implemented a Nuclear Assurance Department Operations Support
. Program. The program involves the assignment of an Assistant to the Plant Operations Director and' Shif t Assistants who are tasked with reviewing plant operations and ' making recommendations fcr improvement in the areas of procedural adequacy, procedural adherence, and control of activities that have an impact on operations. Also, corporate management has issued [
policy statements stressing verbatim compliance with operating procedures .
and has begun vigorously enforcing the policy.
This program has resulted in many improved procedures, improved procecceal adherence, improved operation awareness and understanding of plant activities, impreved followup of operations identified maintenance .
l concerns, and improved operator morale. The program has relieved some management and supervisory personnel of administrative burdens, allowing .
more timely and thorough reviews of activities.
Page 3 i
The development of a "programs and controls" group has improved the scheduling and prioritization of work activities and the soordination between maintenance and operations.
Some problems still exist with operator k,nowledge of regulatory requirements. These problems are evidenced by the following: '
(1) Failure to recognize malfunction of a TIP in-shield limit switch as a degradation of containment intgrity.
(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.
Conclusion _
Category 2 -
. Board Recommendations -
. Hone . _ . _ . . . . . _ . -.
CPU Nuclear Corporation Comments: ..
' 5 The third paragraph in the above evaluation references a Nuclear Assurance Department Operations Support Program. This is a misnomer. The comment is made in order to avoid confusion between activities conducted by our Nuclear Assurance division and this program. l l The program consisted of temporarily assigning experienced personnel, from other divisions within GPUNC, including the Nuclear Assurance Division, to aid in the site specific activities of the Operations, Maintenance and
, Plant Engineering departments of the Oyster Creek Division. These l specific assignments were made on a temporary basis to fill vacant i positions. At the present time, the temporarily assigned personnel have rcturned to their respective divisions. Continuity of the program will be based on an overall evaluation of the program and permanent personnel have been placed in many positions. I With regard to the statement in the last paragraph of the evaluation that some problems still exist with operator knowledge of regulatory requirements, a comprehensive formal refresher training program has been ,
developed for Operations Shift Supervisors in the area of Technical l Specification and regulatory requirements. The results achieved by a program of this nature would not be observable in the short term, but are e expected to result in improvements in this area.
. I
Page 4 20 Radiological controls - NRC Evaluation .
The previous assessment period identified several areas of major concern.
Programmatic problems included inadequate staf fing, use of personnel not
- meeting ANSI N18.1-1971 standards, procedures inconsistent with Technical Specifications, and poor control in the area of transportation of radioac tive waste. Nineteen violations were identified and one civil penalty was assessed for inadequate radiation 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, f increase the s'ize and quality of the radiation protection staff, and '
implement organizational changes to put direct management attention in the areas of radwaste 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 ef fluent monitoring and control. In addition, one regional office evaluation.of a State of Nevada burial site inspection, and one investigation of NAC-lE 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 c radioactive waste transportation, two Severity Level IV's associated with { ,
control of high radiation area access, and two Severi'ty Level V's associated with dosimetry issue procedures and control of procedure changes were identified. These items were not repetitive or indicative of prograsaatic breakdowns. Corrective actions were timely.
l Two licensee event reports identified unmonitored uncontrolled liquid ,
I releases. Four operations related event reports identified failures to >
monitor gaseous effluents due to sample system breakdowns. The events were properly classified and reported. }
l f Management involvement in this area is evidenced by the major reoganization of the radwaste management program and generally well -
! defined procedures. However, lack of formal approval of Radiation Control j 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 radiological engineering reviews show evidence of adequate planning and technically sound approaches to problems.
Conclusion -
Category 2 !
Board Recommendations -
None k -
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Page $ i t
CPU Nuclear Corporation Comments:
i The radiological Field Operations Training Program, referred to in the i fourth persgraph, has now been submitted for NRC review and approval. As (
you are aware, until NRC approves this program, each member of the !
radiation protection organization, for which there is a comparable ,
, position described in ANSI N18.1-1971, meets or exceeds the minimum qualifications specified therein.
i
- 3. Maintenance - NRC Evaluation: ;
, 8 Three inspections during the previous assessment period identified no violations. Three of four maintenance related event reports involved
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personnel error. The assessment concluded that the licensee had a viable maintenance program with no major programmatic weaknesses.
During the current assessment period, one region based inspection and routine inspection by the resident inspector identified no violations. In
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an effor.t .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'4pparent understaffing in maintenance 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.
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 i because.of incomplete maintenance modifications which did not include I permanen; removal of abandoned components, or the need for further engineering review.
The preventive maintenance program is being expanded and crews dedicated specifically to preventive maintenance are being formed. This program .
. presently involves primarily instrumentation and lubrication. Maintenance recor.ds are reviewed by a preventive maintenance engineer who is developing mschinary history records, but this program has not yet been developed to the point that maintenance trend analysis can be performed.
In addition to marginal maintenance history records, the availability of current equipment data is a weakness. Controlled files of equipment data
'vich 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 building to suppression chamber air operate,d vacuum breakers were replaced with valves made by a dif ferent manufacturer in 1979.
- - - - - - - . - - - - - - - - - - _ - _ _ - - - - - , , , -, , , , , ,- , - - , ,r
Page 6 The licensee's response to NRC initiatives is sometimes delayed. For example, corrective actions on a 1977 IE Circular relating to fuse coordination in Standby Liquid Control system Squib firing circuits, a '
1979 IE Circular relating to defective diesel fire pump starting contractors, and a 1979 IE Circular on Limitorque valve operator locking devices were not completed until the NRC~ expressed concern for lack of responsiveness.
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. 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 involving improper assesmbly and testing of a torus vacuum breaker ,
valve was discovered. The action resulted in one torus vacuum breaker !
being inoperable for 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 l maintenance activities is necessary. .
. The licensee has implemented a program of increased management involvement -
[
in maintenance activities.
In addition, recent staffing c1anges which have placed individuals with extensive maintenance background in ( i upper-level management positions have resulted in an improving trend in this area. ,
,- t r
Conclusion -
Category 3 Board Recommendations -
Increased inspection effort by the resident inspector. I i
i I
l i GPU Nuclear Corporation Comments::
The eval'uation period (November 1,1980 through October 31, 7981) coincides with the reorganization of our Maintenance Department in September 1980 and as cuch, covers a transition period. Current activities now meet most of the goals of the reorganization and satisfactorily address many of the concerns of the above evaluation.
The following paragraphs provide examples of how the reorganization has
- ef fected pos'itive changes which, toward the end of the evaluation period l and subsequent thereto, have become clear
l l C -
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e- i.- > - - --.m
d Page 7 The second paragraph of the ev 11uation contains the statement ". . . there is a lack of corporate and plat.t management involvement in P.he review and l prioritization of outstanding maintenance items ...". Procedure No. 105 ,
"Conduct of Maintenance" ensures '. hat management reviews and prioritizes -
each job order. The prioritization of job orders has been in af feet since January of 1981 and consists of assigning one of four priorities. "Urgent
. 1" is the most immediate p'riority and indicates that work should be started within one day. This priority includes emergency maintenance -
initiated by the Group Shif t Supervisor and other work considered likely to cause any of the following conditions within three days: }
- 1. Personnel injury ,
i
- 2. Significantly increased contamination or radiation hazard ,
._ 3. .
.. Unplanned, uncontrolled release of radioactive material to the environment in excess of normal release rates l
- 4. Significant dau ge t.o safety-related equipment needed for safe plant shutdown
. J. _ Violation of Technical Specifications _ _
__ _ ,. j
- 6. Inunediate plant shutdown or load reduction The remaining three categories involve problems of a leuser severity and guidance is given in the procedure for assigning priorities.
The second paragraph also refers to "... an apparent understaffing in maintenance departments ...". We have increased our first line supervisor to worker ratio. Currently, our average ratio is one supervisor per ten ,
to twelve workers. The key maintenance positions are now filled and :
implementation of che desired program is being effected. We believe that our present emphasis on more effective use of supervision, emphasizing supervisor presence on the job site and better olanning, in addition to
'the improved supervisor to worker ratio, wi?,1 help effect the desired improvements.
The last sentence in the second paragraph states "There is ca,.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." There are a large i number of outstanding work orders, many as a result of our increased i efforts to identify what work needs to be accomplished. However, as '
identified above, all job orders are prioritized according to specified criteria and the majority of outstanding job orders are in the minor category.
. N .. . ..
Page 8 With regard to job orders being closed out inappropriately, Procedure 105 currently requires that a job order may only be cancelled by the applicable Maintenance Supervisor after obtaining concurrence of the initiating department supervisor. The procedure also identifies when temporary repairs are effected or further modification to the existing
... system is required, the temporary repair job. order may be closed out. A new job order is initiated for execution when materials and/or the modification package is available.
With regard to the large number of long-standing lif ted leads and jumpers referted to in the third paragraoh, we have recently completed a review of and dispositioned.all lifted leads and jumpers where possible. The unresolved remaining items have been identified and are being referred to engineering for permanent resolution. ,
. __._ _ .The fourth paragraph in the evaluation discusses the preventative maintenance program. We fee,1 this area has been greatly imptoved, since reorganization in September 1980. The present program includes electrical, mechanical, instrumentation and lubrication ac tivities.
Maintenance history cards are now updated whenever corrective or preventative maintenance is performed. Although past history of
_ maintenance may, in some cases, be unretrievable, current practices will ensure that future trend analysis will be achievable. (
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Our re'sponsiveness to NRC initiatives is now coordinated through the ;
Licensing Department. Each item is assigned to the cognizant department and tracked by a formal program until completion of the assignment is effected. Outstanding items are brought to the attention of upper management and a summary report is provided to the Office of the President on a monthly basis. The current program should help ensure that events
- such as the examples cited in the evaluation will not be of a recurrent nature.
With regard to control of contractor activities, our corrective actions, as you are aware, are described in our response to the Notice of Violation The controls imposed have had a positive effect dated September 21, 1981.
, in that potential problems are identified and corrected prior to conducting work activities. -
l l
l 4. Surveillance - NRC Evaluation l During the previous assessment period, six routine unannounced inspections '
i by region based inspectors, one Performance Appraisal Branch Inspection l and routine inspection by the resident inspec.cor identified three violations. The licensee had failed to perform surveillances on three occasions.
(
1
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3 Page 9 During the current assessment period, two region bas 1d inspections, one regional based team inspection, and routine resident reviews identified ;
eight violations. The violations involved f ailure to conduct Technical Specification and ASME Section XI testing, inaccurate calibration, calibration and testing witho'ut 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 program to meet the requirements of ASME code Section XI by. January 1,1982. j After the assessment period, region based inspectors found that the licensee had not completed all corrective action, in that a program for
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valve testing was not fully implemented. The licensee has since submitted l a revised completion schedule to NRC:RI. The licensee stated that ;
operational commitments and manpower shortages were the reasons for not meeting the commitments. The high number of violations and the failure to meet commitment dates without notification, indicate weakness in licensee .
... management control in this. area. , , , , . , , . _,
j 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 surveillances, int particular ,
a Severity Level IV violation involving f ailure to survey Emergency Service Water pumps following unacceptable surveillanca on redundant pumps, indicate a need for more management attention in review of i surveillance programs and assuring unambiguous acceptance criteria.
This need is further amplified by a violation that occurred after the assessment period. Three successiva failures of an isdlation condenser valve during operability testing followed by two successful o >erations of, the valve, with no followup investigation to determine the ca sse of the failures, was interpreted by a member of the management staff as ,
acceptable component performance. -
Conclusion -
Category 3 ,
l Board Recommendations -
None GPU Nuclear Corporation Comments: .
1 i Several violations that are referenced in the above evaluation inv.olved a ,
failure to comply with the surveillance requiremener of recently approved l Technical Specification changes. Our practice had been that follow-up to Technical Specification changes, such as the draf ting of procedures, was ,
not initiated until after NRC had approved the change. At present, the Surveillance Testing Program is administered by the Plant Engineering Department and compliance to Technical Specifications is accomplished through the maintenance of the surveillance testing schedule and implementing procedures.
Page 10 To improve the implementation of Technical Specification changes, Plant Engineering will review all pending Technical Specification Change Requests and assure that all aspects relative to the specific ci,anges are prepared in anticipation of approval. Once approved, the draft procedures will be reviewed again for changes, which may havs occurred due to NRC review, and cycled through our internal cycle for final approval and implementation. Under this program, a change to Technical Specifications should be implemented within 30 days after issuance.
As you are aware, the common NRC practice of making Technical ,
Specification changes "ef fective upon date of issuance" has been addressed by us in previous correspondence as being impractical to implement. We request that all changes to Technical Specifications become effective 30 ,
days after receipt by the licensee unless requested otherwise.
t In addition to the above planned actions, Plant Engineering has instituted training in the area of Technical Specifications. All engineering personnel will be required to attend. The classroom instruction will be presented by the BWR Licensing Manager and is scheduled to be conducted during May of 1982. i An integrated training program ic being developed to educate each member of the Plant Engineering staf f with regard to general BWR knowledge.
Specific system responsibility will be assigned to individuals who will be expected to acquire knowledge comparable to operations personnel for the systems assigned to them. This is expected to raise the overall system level knowledge with regard to plant operations to a level considerably higher than before. Training in the specific system areas is expected to g begin in July of 1982.
We feel the violations referenced in the evaluation regarding the Emergency Service Water Pumps and the Isolation Condenser Valve do not indicate a programmatic weakness in the surveillance program. The !'
decision to declare the Emergency Service Water Pumps operable was based on previous knowledge and experience of system performance. Management's decision was bas 2d on knowledge chaq should.have been incorporated into the procedure; however, in absence of procedure criteria, the pump should have been declared inoperable. With regard to the Isolation Condenser valve operability, the cause can be attributed to poor judgement. This event has been discussed with plant operations personnel and management direction to make such judgement conservatively from a safety standpoint has been reemphasized. ;
i
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Page 11
- 5. Fire Protection and Housekeeping - NRC Evaluation .
I Three inspections by region based inspectors and one Performance Appraisal
- Branch inspection during the previous assessment period identified no major programmatic weaknesses. Two violations were identified involving storage of combustible material in safety related areas.
During this assessment period, 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 in a degraded condition. ,
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 l barriers. ,
There were considerable problems causing delays i .... installation and testing of a storage tank and pumping system to . > vide an alternate I source of water to the fire protection system.
l 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 I
waterproof and protect electrical components. .
i Housekeeping has improved during this assessment period as a result of more management attention. Radiological housekeeping conditions are l generally acceptable with no significant NRC inspection findings in this t
area. Poor general plant cleanliness and appearance; however, continues to reflect poor plant staf f attitudes and lack of professionalism / pride.
An improving trend has been noted as a result of increased management
- attention.
l l Conclusion -
Category 2*
Board Recommendations -
none
! *This rating is assigned without regard to the licensee's position on 10 CFR 50, Appendix R provisions.
i 1
l ,
_ . _ _ . ~ . . _ , _ _ _ _._ _ _ __
_____A,
Page 12 GPU Nuclear Corporation Comments:
As a result of increased management attention in the area of housekeeping, we feel there has recently been considerable improvements in plant cleanliness and appearance. We feel the continued emphasis will elevate the pride of the entire plant staff.
- 6. Emergency Preparedness - NRC Evaluation No programmatic inspections uere conducted in' this area during the '
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 provisions 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 included significant increases in emergency planning staff, further emergency plan and procedure reviews, /~
and intensive training, was begun. I i
An NRC team appraisal of emergency preparedness was conducted in January t 1982 af ter the end of the assessment period. The appraisal identified i significant weaknesses requiring corrective actions. These weaknesses included: required upgrading of emergency response facilities; improved ,
capability for post accident sampling of stack effluent, reactor coolant, and containment atmosphere; emergency procedure improvement; and better definitions of the training pr> gram for emergency response personnel. The licensee's proposed corrective actions were discussed in a Confirmatory Action Letter dated February 18, 1982. i An NRC team observation of a major emergency preparedness exercise was conducted in March 1982. This observation detecmined that the licensee had demonstrated the capability to implement the provisions of the emergency plan to adequately protect the public health and safety during an accident, however, areas for improvement were noted and discussed with the licensee.
The licensee failed to meet the February 1, 1982 deadline for installation of a Public Notification System and was issued a Severity Level III Notice f Forty-five warning sirens wert ir. stalled and tested by of Violation.
March 5,1982. The final siren was installed and tested on March 11, 1981. I Y. ~
1
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Page 13 Conclusion -
Category 2 Board Recommendations -
None
' ' ~
'Erhis categorizalion has been assigned on the bases of additional i in[gts.aqion developed.,after t.he, assessment period and without~ regard ' ~~"
to resolution of the outstanding issue of the Confirmatory' Action )
Letter of February 18, 1982.
GPU Nuclear Corporation Comments:
- '~
The last paragraph in the above evaluation contains two minor errors concerning the installation dates of our warning sirens. As we indicated in the response to the Notice of Violation, forty-five (45) warning sirens vere installed and tested by February 26, 1982. The final stren was ~
installed and tested on March 5,1982. Since the SALP evaluation, we note
~~ ~~
that NRC, by their letter of April 28, 1982, has evaluated our overall response to this matter and advised us that' they plan no further action.
- 7. Security and Safeguards - NRC Evaluation ,
During the previous assessment period, two routine inspect. ions by region based inspectors, routine review of selected areas by the resident inspector, and one inspection by the Performance Apprais.a1 branch identified no violations or evidence of programmatic wtsknesses. During one inspection, allegations by a former security watchman, which had been published in a local newspaper, were reviewed but could not be substantiated.
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During the assessment period, two routine insp9etions 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.
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i Page 14 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 br,eakdowns. An inspection conducted since the end of the assessment period (December 7-il, L981) identified no similar problems.
Management attention is demonstrated by the prompt action to correct and prevent recurrence of the identified problems. Site manaFement is generally responsive to security program requirements. Pequired reviews,
' ~ ~ ~
audits and records are generally complete and show invo'.vement by Corporate management. The security organization is ' ell staffed with well defined responsibilicies and adequately trained personnel. Procedural' adherence is good with infrequent personnel errors. , ,
Conclusion -
Category 2 Board Recommendations -
None CPU Nuclear Cot 7 oration Comments: . . . . q l
None.
[
1 l
r ,
j S. Refueling and Major Outage Activities - NRC Evaluation ,
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 ada.in i s tr a t.8on controls causing failure to remove control rod interlock bypass jump 0rs prior to contro! cell fuel reload. This violation received high le,el management attention by the corporate General Of fice Review ~
Board and the Independent Safety Review Group.
1 l
During the current assessment period, one region based inspection of post l refueling testing and reload analysis was conducted. No violations were identified.
One scheduled and frequent unscheduled maintenance outages occurred during i the assessment period. Considerable improvements in scheduling and coordination of outage activities were noted. This is due primarily to l
the assignment of a full-time Programs and Controls Manager who oversees outage planning. Scheduling activities generally addressed key outage and ,
outage recovery items. ( s. ,
l l
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Page 16 A completed modification, under this program, will be accepted based on the completion of preestablished conditions. The conditions specified for each modification will be formulated at a planning meeting after construction activities have been authorized. Preestablished conditions being addressed include:
- 1. Training completed for operations personnel concerning the installed modification
- 2. All applicable operating procedures revised
- 3. Required spare pu ts identified
- 4. Preventative Maintenance Procedures written and Preventative
- Maintenance schedule updated '.
- 5. All applicable drawings revised
- 6. Surveillance procedures and the Master Surveillance schedule revised I The interfacing departments or divisions assigned responsibility for completion of the preestablished conditions will meet formally to verify
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and sign-of f that the modification can be put into service, f'i The following departments will be involved as appropriate:
- 1. Plant Operations -
Oyster Creek Division
- 2. Plant Maintenance -
Oyster Creek Division
- 3. Plant Engineering -
Oyster Creek Division
- 4. Project Engineering -
Tschnical Functions
- 5. Start-Up and Test -
Technical Functions
- 6. Maintenance and Construction -
Maintenance and Construction
- 7. Training and Quality Control -
Nuclear Assurance Division
- 8. Configuration Control -
Technical Functions Procedure No. 124 "System / Equipment Turnover After Modification" is presently being reviewed and revised to address the above progr:m.
Additional procedures, if deemed necessary, will be developed.
In addition to this program, Plant Engineering will assign an engineer as the "plant contcc t" for each modification authorized through the Technical Functions division. The intention of the plant contact is to provide l Plant Engineering awareness and follow-up of the modification such that appropriate documents, i.e., operations, maintenance, and surveillance procedures, vendor's manuals spare parts list, etc., are in the development stage as the mod i fication is progressing.
( .
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Some problems in the area of control of contractor work were noted as evidenced by one violation involving blocking of torus vacuum breakers by contracter erected scaffolding and an event involving an airborne release of radioactive material from the radwaste building ventilation system.
---One-region based inspec tion conducted af ter the asessment. 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 th,e design changes and modification program _.is very_fpagmented_ with, poor central, control and review. Many ,, . _ ,
procedures for the program are in draft form and many are still being prepared.
Training on modifice.tions completed during outages is sometimes delayed until just prior to startup, and drawing revisions are sometimes delayed.
Thi s, together with insuf ficient management involvement in design change pro gram, results in an occasional lack of coordination between engineering, construction, and operations staf f during turnover of systems to 1perations control and in occasionally late implementation of revised
. pro:edures. - -- .
~~~ 'The TTc'ehsee has a well sisf fed corporate technical engineering' group.
This group is still gaining site specific familiarity resulting in
. considerable reliance on contractors for engineering support. -
Conclusion -
Category 2 , af Bo ard~Re commend a tions -
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.
GPU Nuclear Corporation Comments We have had under development since early 1981, an integrated and improved system of controls for work being done in the plant. Improvements have been and are being implemented on an individual basis. The improved system is scheduled to be in ef fect prior to the upcoming outage. The system will require a formal turnover to plant operations of all newly installed modifications.
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- 9. Licensing Activities - NRC Evaluation No specific assessment of licensing activities was performed during the prior assessment period; pertinent issues were included in other functional areas.
Licensing activities during the current assessment period included l miscellaneous Technical Specification changes, a review of TMI Task Action Plan itcas, 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) and the TMI Task Action Plan (NUREG-0737) were not always complete and resulted in frequent i requests by NRC for additional information. The licensee and his i contractors have demonstrated adequate working knowledge of regulatory l requirements and excellent level of technical competence. The licensee's j staffing is generally adequate, but in view of planned modifications and possible SEP upgrade requirements, may require increases.
Conclusion -
Category 2
., JI Board Recommendations -
None P CPU Nuclear Corporation Comments: '
The third paragraph of the evaluation states, ". . . the timeliness of responses has been poor .. .". While there have been cases where our response has been later than requested, we believe that a large factor in this has been the volume of ruquests and NRC's practice of setting unrealistic response dates. Requests made for information frequently require complex studies or analyses to be performed before an adequate response can be prepared, reviewed, and approved by upper management. We will continue to respond in a timely manner and to formally request I extensions where appropriate.
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