ML20197A877
| ML20197A877 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 02/26/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20197A880 | List: |
| References | |
| 50-289-98-99, NUDOCS 9803100017 | |
| Download: ML20197A877 (7) | |
See also: IR 05000289/1998099
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ENCLOSURE 1
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
THREE MILE ISLAND UNIT 1
Report No. 50 289/98 99
1.
BACKGROUND
The SALP Board convened on February 5,1998, to assess the nuclear safety performance
of Three Mile Island Unit 1 for the period from August 5,1996, through Jarsuary 24,1998.
The Board was conducted pursuant to NRC Management Directive (MD) 8.6 (see NRC
Administrative Letter 93 20). The Board members were Charles W. Hehl (Board
Chairman), Director, Division of Reactor Projects, Region I (RI), Larry E. Nicholson, Deputy
Director, Division of Reactor Safety, Bl, and Cecil O. Thomas Jr., Director, Projects
Directorate 1-3, Office of Nuclear Reactor Regulation. The Board developed this
assessment for the approval of the Region i Administrator.
The performance ratings and the functional areas used below are described in NRC MD
8,6, " Systematic Assessment of Licensee Performance (SALP)."
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PERFORMANCE ANALYSIS - OPERATIONS
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Overall Three Mile Island Unit 1 (TMI) plant operation was excellent over this period.
Operations management continued to provide extensiva oversight of control room
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activities, which iesulted in a very good level of safe'.y performance. The operations staff
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conduct of norma ~ r:tivities and response to the infrequent plant transients and equipment
problems were excellst GPU took effective actions to address previous issues with the
control of equipment and human errors. - However, on occasion the operators did not
rigorously fellow approved procedures. The licensed operator requalificatlan program
remained a strength. The standing review committees functioned well and the corrective
actions systems generally improved. However, improvements were needed in the conduct,
tracking, and oversight of the corrective action process (CAP).
Licensed operators performed routine activities very well and did not initiate any plant
transients. Shift management and operators displayed excellent control over plant
activities during unit shutdowns, startups, and planned on-line maintenance. The control
room annunciator panels were routinely maintained clear of alarm annunciators. The
operators' response to the reactor trip and loss of offsite power in June 1997 was
excellent. Effective corrective actions prevented recurrence of previously identified
problems such as the failure to enter Technical Specification (TS) limiting conditions for
operations when equipment problems occurred. Human errors were reduced, indicating the
effectiveness of severallicensee initiatives in this area. Operators' procedure use during
routine and planned evolutions was generally good. However, on occasion, when faced
with unfamiliar conditions, the shift crews did not follow procedures or used a procedure
that did nct meet the intent of the performed activity. Most noteworthy, during the
refueling outage a shift supervisor directed the use of a water flow path that was not
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authorized by operations management for the given plant conditions. This resulted in a
faster than desired reactor coolant system fill rate and the spilling of water from the control
rod drive mechanism vents.
Plant management continued extensive involvement with the operation of TMI. Routine
management meetings effectively evaluated equipment problems and established priorities.
The daily meetings focused on safe plant operation and kept the operating crews aware of
the risks of conducting on-line maintenance. The operating crews were provided risk
analysis for sensitive planned maintenance activities. However, on one occasion,
mcnagement did not demonstrate a good safety perspective by the decision to lower
reactor coolant water level to the mid loop condition, for an extended period, with only one
active means of decoy heat removal operable and available. This was in contrast to
management's normally conservative decisions regarding plant activities.
The licensed operator requalification program continued to be a strength. Management
involvement in the conduct of simulator activitiet was extensive and showed a
commitment to consistent crew performance.
The plant review group, the group offsite review board, and the other oversight
committees generally performed wellin the review and identification of possible plant and
personnel performance issues. The licensee corrective action process has generally
improved the identification and assessment of adverse conditions since its introduction in
March 1997. However, the increasing backlog of open issues combined with an
inconsistent tracking and escalation process warrant management's continued attention.
The Operations area was rated Category 1.
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111.
PERFORMANCE ANAL.YSIS - MAINTENANCE
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Excellent plant material condition, very few equipment failures ud consistently good
squipment response were noted this period. GPU appropriately applied resources to
resolve several important issues. The control of work activities both during operation and
shutdown was very good. Management and supervision continued to have a strong field
presence. However. a relatively small number of rework problems resulted in the increases
in shutdown and operational risk. The TMI staff conducted surveillance activities very well,
including inservice inspection activities. However, there were a few missed surveillances
due to inservice test program problems.
The excellent plant condition resulted from good management coordination and
implementation of the maintenance program. There was only one automatic reactor trip,
few challenges to safety systems, no indicated fuelleaks, and essentially zero primary to
secondary leakage. When the infrequent plant upset conditions occurred, the equipment
responded as designed and did not complicate the operators' restoration. An example was
the excellent equipment response to the June 1997, reactor trip and loss of offsite power.
Management continued to provide the resources needed to ensure a high level of plant
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equipment performance. Examples noted were the control rod drive thermal barrier
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replacement, main generator stator bar replacement / rewind, 'B' decay heat removal pump
replacement, high pressure injection thermal sleeve crack repair, and the 100% steam
generator tube eddy current testing.
Management and supervision involvement and oversight c,f maintenance activities,
including the refueling activities, continued as a program strength. Proper management of
non-outage work requests and control room deficiencies led to low backlogs. On-line
maintenance equipment outages were well-planned, coordinated, and controlled. Excellent
human performance during these work activities resulted in no challenges to plant
operation. For potentially challenging activities, a detailed written risk evaluation and
prescribed manual actions were prepared to minimize risk,
The experienced work force and good maintenance procedure use resulted in few rework
items. However, maintenance related difficulties in the 'A' decay heat removal pump seal
replacement impacted the plant shutdown risk during the 1997 refueling outage and the
improperly wired power operated relief valve (PORV) affected operational risk during the
19951997 operating cycle. The PORV wiring problem, which occurred in 1995,
highlighted some problems in the post-maintenance testing process, workers' questioning
attitude, and self checking. The liceme did a thorough rcot cause analysis which
generated comprehensive corrective , 4 o :o address these issues.
The licensee's Nuclear Safety Assessment Group completed a comprehensive post-
maintenance testing review prior to the re-start from the 1997 refueling outage. The
quality verification group continued to perform objective assessments of maintenance
activities that resulted in personnel performance and program improvements.
Good surveillance test performance contributed to the safe and reliable operation of plant
equipment. There were no significant errors during the performance of surveillance testing
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or adverse plant responses. A more consistent use of self checking practices was noted
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during field observations. Outage inservice inspection was well planned and accomplished.
The Maintenance area was rated Category 1.
IV.
PERFORMANCE ANALYSIS - ENGINEERING
Performance in the engineering area was mixed. Significant problems were identified in a
number of engineering program areas. Examples included problems with the Inservice
Testing (IST) and Motor Operated Valve (MOV) programs, the Quality Classification List
(OCL) Process, and Technical Support. Adverse findings associated with engineering
performance, which were previously identified by the licensee's oversight groups, were not
addressed effectively, and did not resolve the programmatic conclusions eventually found
by the NRC. In contrast, system engineering provided generally good support to address
emergent issues. The procurement engineering program was excellent and had good
management oversight.
A lack of effective management involvement and oversight contributed to numerous
problems with engineering programs. Important check valves were omitted from the IST
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program, the MOV program was not adequately completed within the required time, and
significant errors were made in the OCL process that resulted in the improper downgrading
of safety related equipment. Some key engineering procedures were nnt in the safety
review process nor were they followed during the downgrading of safety related
components. Management failed to effectively establish, communicate, and enforce
adequate engineering standards and provided poor oversight to correcting problems
identified through Quality Assurance audito. As a result of the problems noted above, GPU
conducted a thorough Engineering Corrective Action Program Assessment Team (ECAPAT)
review, which confirmed inadequate management involvement as an underlying root cause.
A program to expand the evaluation scope and implement corrective actions was ongoing
as the period ended.
Design control weaknesses were identified with calculations. Nonconservative inputs and
assumptions were used in the analysis to support Emergency Core Cooling System (ECCS)
switchover to the reactor building sump under post accident conditions. As a result, the
ECCS was found to be inoperable. Calculations were informally addressed in docume'its
such as memoranda, technical data reports, ano plant / engineering evaluations that did not
comply with established engineering procedures. Circuit breaker testing (IEEE standards)
for certain molded case circuit breakers was not performed, and there were numerous
discrepancies noted in the Final Safety Analysis Report (FSAR), drawings, design basis
documents, and procedures. In additicn, a previously identified unreviewed safety
question regarding the net positive suction head for decay heat removal and building spray
pumps was not addressed in a timely manner. The quality of engineering / licensing
packages submitted to the NRC was mixed. While the submittals were generally timely,
they usually required additional information and were sometimes technically weak.
In contrast, strengths were observed in system engineering and with the procurement
program. System engineers addressed emergent issuer well, including providing prompt
support for operability determinations. Equipment was maintained well, with prompt
attention to resolve identified safety issues. Identification of improperly wired PORV issue
was the result of diligent review and questioning by an engineer. The procurement
engineering documents provided clear descriptions of each procurement item.
The engineering area is rated Category 3
V.
PERFORMANCE ANALYSIS PLANT SUPPORT
Performance in the plant support functional area resulted in a good level of safety
performance. Overall performance in iadiological controls was effective; however, !ssues
regarding high radiation area controls and contamination control persisted. Emergency
preparedness exercise performance results continued to be mixed. Overall performance in
the security program improved, especially in the area of problem identification and
resolution.
Overall performance in radiological controls was effectiva. Activities involving ALARA,
radioactive waste management and transportation, radiological effluents, and
environmental monitoring were implemented well, especially ALARA planning for high dose
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evolutions. However, some performance problems occurred, especially during the refueling
outage. inadequate procedural guidance and supervisory involvement, coupled 19f1 an
unanticipated contamination level environment, contributed to a significant hot particle skin
contamination.- High radiation area control issues arose early and late in this cycle, and
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were repetitive from the last cycle. Weaknesses in the establishment and maintenance of
containinated areas and in the radiological survey program were identified.
Performance in the emergency preparedness program area was mixed. Although good
program content was noted, implementation in the March 1997 exercise was poor.
Exercise performance weaknesses included a failure to recognize and classify a General
Emergency condition. Ineffective management attention and involvement to the EP area
contributed to this poor exercise performance. A remedial emergency preparedness (EP)
exercise was required. Improvement was noted in performance during the remedial
exercise.
The security program was effectively implemented with continued strong management
support as evidenced by upgrades and enhancements to the program. The controls for
identifying, resolving, and preventing security program problems were effective.
An effective fire protection and prevention program continued to be implemented as
evidenced by routine observations by inspectors. The problems with emergency lighting,
identified during the previous cycle, were corrected.
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Housekeeping was generally good. However, a period of poor housekeeping occurred
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during the refueling outage, involving miscellaneous debris on the floors in the reactor
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building. There was improvement near the end of this cycle.
The Plant Support area was rated a Category 2.
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Enclosure 2
THREE MILE ISLAND SALP 12 MONTH
INSPECTION PLAN
INSPECTION
TITLE / PROGRAM AREA
PLANNED
TYPE INSPECTION
DATES
COMMENTS
Solid Radioactive Waste Management and
4/20/98
Core Inspection
Transportation of Radioactive Materials
Maintenance Rule Inspection
5/18/98
Core inspection
Physical Security Program
6/15/98
Core Inspection
Engineering Followup
6/15/98
Regional Initiative
Legend:
IP - Inspection Procedure
T1 - Temporary Instruction
Core Inspection
- Minimum NRC Inspection Program (mandatory at all plants)
RegionalInitiative - Additional Inspection Effort Planned by Region i
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