ML20197H324
| ML20197H324 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 04/21/1986 |
| From: | Hukill H GENERAL PUBLIC UTILITIES CORP. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML20197H314 | List: |
| References | |
| 5211-86-2068, NUDOCS 8605190135 | |
| Download: ML20197H324 (3) | |
Text
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____m.s c.
... mem GPU Nuclear Corporation PU luclear
- ,or g r 8o Middletown, Pennsylvania 17057-0191 717 944 7621 TELEX 84 2386 Writer's Direct Dial Nurnber
April 21, 1986 5211-86-2068 Dr. Thomas E. Murley Region I, Regional Administrator U.S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19405
Dear Dr. '4urley:
Three Mile Island Huclear Station Unit.1 (TMI-l)
Operating License No. DPR-50 Docket No. 50-289 GPUH Response to the TMI-l Restart SALP Report This letter provides GPUN's comments on the March 17, 1986 SALP Report as clarified by our meeting with you on March 31, 1986.
We are pleased that the report and your comments during the meeting conclude that the TMI-l restart was safe and well controlled.
Our responses to previous inspection reports (IR 85-22, 25, 27 and 30) address the roo t causes of specific items identified in the SALP Report.
Those re spo nses are not repeated here.
There were however three general issucs i de nti fied in the report.
These issues relate to Use and Quality of Procedures, Use of Oversight Group Findings, and Technical Support.
A discussion of these items is attached which includes appropriate actions taken or planned to irnprove our performance.
We believe the SALP process is an overall useful process in that it provides a ddi tio nal diverse insight into the quality of our activities.
Sincerely, H. D. Hukill Director, TMI-l HDH/CWS/spb Attachment
%f G
GPU Nuclear Corporation is a subsidiary of the General Public Utilities Corporation
l I.
Use and Quality of Procedures THI-l uses over 2500 procedures, most of which were revised and upgraded j
duri ng the 6-1/2 year shutdown.
Specifically, we believe our ATOG procedures were a major improveme nt.
GPUN did anticipate that some minor procedure problems would surface during the restart as more and i
nore of the procedures were used under nornul opera tional conditions.
Indeed some problems were noted both by the NRC and by GPUN.
The problems identified were generally minor and caused no safety problems.
i While we have made major improvements in our procedures, we believe additional improvement can be achieved.
To this end, and as a result of the procedural problems identified, GPllH has completed or will complete i
the following items:
1.
the TMI-l Director has discussed procedural compliance and the need to i de ntify required cha nges with all Plant Operations and
!'aintenance personnel,
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procedure complia nce and identifying needed cha nges have been discussed at the TMI-l Managers Meeting,
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3 procedural guidance has been issued to clarify which circumstances require written procedures, 4.
various nemos have been issued to document the above items, 5
at the request of the TMI-l Di rector, OA specifically monitored procedJra l compliance and reported its results, (This monitoring is co nti nui ng. )
6 a large number of PCPs have been processed to correct problems icentified during the startup that had not been turned in during the startup (these had been saved up by individuals we believe to avoid disrupting the restart program with minor items),
7 the discussions for itens 1 and 2 above have included work habits such as housekeeping and using sensitive equipnnnt in lieu of 1 Wers ne scaf folding, 4
the 'lanagers conductino off-shift tours and the OA shif t monitors have been reques ted to emphasize procedural complia nce and work
- habits, 9.
fi nally, a corporate Task Force has been established to review the safety related procedures and their implementation in all divisions.
l 1
II.
Use of Oversight Group Findings The SALP Report at page 12 identifies three items.
Each item is discussed below:
A.
Disposition of NSCC Recommendations The SALP Report indicated that " Board dispositions for some NSCC recommenda tions were not clear".
The following is provi ded to clarify handling of NSCC recommendations.
NSCC is composed of three outside members of the GPUN Board of Directors.
MSCC members as such attend the monthly Board metings and report on their activities.
In accordance with its charter, the NSCC provides to the Board a
semi-annual report.
This report includes any recommenda tions.
The report's recommenda tions are formally responded to by the President GPUN.
The NSCC evaluates those responses and in subsequent reports provides the results of these assessments.
At the direction of the GPUN Board these NSCC reports are provided fornally to the NRC.
B.
Management
Response
to QA Assessments Regarding Procedure Implementation Problems i-discussed at the SALP tleeting, QA assessment reports indicated minor procedural implementation problems.
We consider our procedure systen to be sound and effective if properly i na c ted.
Management did respond to QA assessments and emphasized procedural compliance and the need to ensure procedures are up-to-date; however, it is apparent that stronger and more forceful actions were needed to prevent recurrence of these problems.
Significant ma nagement attention has been focused in this area as indicated in Item I, above.
C.
10SRG Recommendations This item arises from a memorandum written by an 10SP,G staff member to his Manager on September 5,
1984.
It was occasioned by a corpora te-wi de assessment of verification procedures performed by HSAD/IOSRG at the request of the Office of the President.
The memo represented the personal opinion of this IOSRG staff menber.
After some consultation and reflection the IOSPG Manager rejected the recomnendations contained in the memorandum.
The recommendation was not distributed by the 10SRG for further action and it remained a piece of internal IOSRG correspondence.
III. Technical Support The Restart effort placed a heavy burden on the Plant Engineering staff.
This, with the need to explain engineering technical decisions to various company and NRC oversight groups, stretched this technical support to its limits.
Decisions had to be made concerning the priority of each issue and the depth of documentation appropriate to be developed in the near term.
We believe that the on-site engineering and technical support is a dequa te, however, we consider tha t greater use of the available of f-si te technical support is also necessa ry.
GPUN will re-emphasize the need to more fully utilize Technical Functions off-site resou rce s.
s
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U. S. NUCLEAR REGULATORY COMMISSION j
REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-289/85-98 GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION j
l THREE MILE ISLA!G NUCLEAR GENERATING STATION UNIT ONE ASSESSMENT PERIOD:
SEPTEMBER 16, 1985 - JANUARY 10, 1986 BOARD MEETING DATE: JANUARY 24, 1986 r, -
6&W I) L
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TABLE OF CONTENTS Page 1.
INTRODUCTION A.
Purpose and Overview.
1 B.
SALP Board Members 2
C.
Background.
3 6
II.
CRITERIA III.
SUMMARY
OF RESULTS A.
Facility Performance.
8 9
B.
Overview.
IV.
PERFORMANCE ANALYSIS-A.
Plant Operations.
11 B.
Radiological Controls 14 C.
Maintenance.
16 0.
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.
Plannec/ Unplanned Releases...
29 TABLES i
l Table I - Inspection Report Activities T1-1 i
Table 2 - Inspecti.on Hours Summary T2-1 Table 3 - Enforcement Summary.
T3-I Table 4 - Enforcement Data.
T4-1 Table 5 - Unplanned Reactor Trips and Snutdowns T5-1 Table 6 - Radiological Effluent Releases.....
T6-1
1 I.
INTRODUCTION A.
Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an inte-grated NRC staff effort to collect available observations and data on a periodic basis to evaluate licensee performante.
The SALP process is supplemental to the normal inspection processes used to ensure 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-tions and modifications.
This SALP is termed an interim SALP in that it covers the period from a few weeks prior to criticality to several days af ter the completion of the power escalation program.
The purposes of this interim SALP 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 f rom a long-term shutdown condition to commercial power operation, and (3) to determine the allocation of NRC rescurces for future inspections.
An NRC SALP Board, comprised of the staff members listed in Section B, met on January 24, 1986, to review the collection of performance ocservations and data to assess the licensee's performance in accor-dance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's performance at TMI-l Nuclear Generating Staticn 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 wnich is at least 12 months.
2 B.
_S_F_ ? Eoard Members Cnairman R. Starcstecki, Director, Division of Reactor Projects Members R. Bellamy, Chief, Radiation Protection Branch, DRSS (Part Time)
L. Bettenhausen, Chief, Operations Branch, DRS R. Blough, Chief, Reactor Projects Section No. lA, DRP R. Conte, TMI-1 Senior Resident Inspector S. Ebneter, Director, DRS (Part Time)
W. Kane, Deputy Director, DRP H. Kister, Chief, Projects 3 ranch No. 1, DRP (Part Time)
P. McKee, Cnief, Operating Reactor Programs Branch, Division of Inspection Programs, IE J. Thoma, TMI-1 Operating Reactors Project Manager, Project Directorate No. 6 j
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Otner Attendees N. Elumberg, Lead Reactor Engineer, DRS (Part Time)
R. Urban, Reactor Engineer, RPS 1A, DRP (Part Time)
R. Weller. Section Leader, Project Directorate No. 6 F. Young, TMI-l Resident Inspector
3 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 0ctober 19, 1985, a test of the reactor trip on loss of main-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-liat 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. Betwcen-November 24, 1935, 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 powe'r. 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 tne same problem, the licensee was able to achieve only 88 percent of full power.
On January 2,1936, 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, twc 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 elect-ical generator protection relay.
The-i 1
2
1 i
4 i-other occurred because of arcther 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-1 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
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testing (PET) program. There was a high level of Region I
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management involvement including the Deputy Director, Division of Reactor Projects, who served as TMI-1 Restart Director on site.
1 Eecause of his knowledge of the TMI-1 plant _and experience with i
the TMI-1 restart process, the senior resident inspector was
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designated TMI-1 Restart Manager and assigned the responsibility to manage inspection activities.
Shift inspectors, experienced I
in B&W plant operations, included resident / project engineers I
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 /> 4
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 i
conducted follow up reviews of a programmatic nature in response l
to shift inspector concerns. As time permitted, they conducted reviews of ecuipment operability and of the technical adequacy cf selected procedures.
Regi or.-ba set.pecialist reviews also occurred in the areas of raciation protection, training, engineering support, security, and emergency preparedness.
To provide additional technical expertise and experience with the TMI-1 restart, the former senior resident inspector for TMI-1 was assigned as a technical assistant to the TMI-1 Restart l
Director.
i
-A total of 3936 inspection hours were expended during the period (shift inspector coverage was approximately 40% of.that total)
I with a distributior in the appraisal functional areas as shown in Table 2..
The inspection hours occurred 'during a 17 week i
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 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> annually.
Summaries of inspection activities and identi-i fied violations a-e tabulatec in Tables 1'and 4 respectively.
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h---------i-----
5 This report also' discusses " Training and Qualification Effec-1 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.
~
_y 6
II.
--. CRITERIA Licenseeperformancewasasseshedin 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 wilkhe addressed in the next SALP.
One or more af the following evaluation criteria were used to assess each functional aPea:
1.
Management involvement and control in assuring quality 2.
Approach to reiolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4
Enforcement history
(
5.
Repor; and analysis of reportable events f
6.
Staffing (including management) 7.
Training ef fectiveness and qualification Basec upon the SALP Ecard assessment, each functional area evaluated is classif.ied into one of three performance' categories.
T,he definitions of i
tnese performance categories are:
Catecory 1.
Reduced NRC attention may be appropriate.
Licensee manage-
' i~tentien and involvement are aggressive and oriented toward nuclear Feet a
safety; liiensee resourcos are amole and effectively used so that a high
, '. e s.ei of es #ce ance i th espect to operational safety or construction is teirg acn:e.ec.
Tne 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 dnique aspects of TMI-1 and because of public sen-sttivity to operational activities at the facility to which the NRC staff must be prepared to respond.
Catecorjy 2.
NRC attention should be maintained at normal levels. Licensee nanagenent attention and involvement are evident and are concerned with nuc' lear sa fety; licersee resources are adequate and reasonably effective s
satisf actory performance with respect to operational safety or so tnat constru: tion is being achieved.
l Cateaorv_d Beth NRC and l'c=nsee attention should be increasec. Licensee I
manager.; attention or invebJerent is acceptable and considers nuclear h
S m
e
~
7 safety, but weaknesses are evident; iirensee resources appear tc be strained or not effectively used so that minimally satisfactory perfcr-mance with respect to operational safety or construction is being achieved.
Normally, the SALP Board assesses each functional area to compare tne 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-mor.th of the period are addressed in the functional areas.
8 III. SU.YMARY OF RESULTS A.
Facility Performance (September 16,19S5 - January 10, 1956)
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
9 B.
Overview Overall, licensee management prepared their operators and the plant well for restart in light of the long shutdown.
Licensea operators conducted themselves competently and exhibited a detailed knowledge of the facility design and plant status, lhey 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..
- q, 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 imolementation of tne procedures.
Even though a strong procedure control policy exists, apparently not all workers understand their responsiciiities when procedures cannot De followed.
To varying cegrees. the oversight review groups performed adequately.
However, it apoears that certain important findings by review groups were r.at effectively acted on by licensee management.
l The radiological centrois program continued to be implemented effec-tively dur*"; ; _ e. + - oceration.
7ne urplannec radiological releases that c.:;.--ed we e c.e to ; eor wori p'a-ring, ret adiological plan-ning.
The surveillance and startup test programs were strong, involved com-peter.: anc cedicated persennel, 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 ef fective in icentifying and correcting overall system integratier. problems.
]
The assessmert covered a period of intense NRC staff review during trarsition f rom a long shutdown to commercial power operation.
Licensee personnel attentiveness to the plant was probably heightened by these circumstantes.
Although many of the licensee's programs are s
ong, cortinuer g: 3c r; clear safety performance will result only tr.effe:tive pragram imolementaticr anc sustained personnel a:
attentiveness and invo'..e ent.
10 Technical Support Technical support staffing was ample with definite signs of both cor-porate and site engineering presence and involvement in plant activi-ties.
In general, management exhibited conservatism when faced with technical problems and, overall, technical support by licensee per-sonnel was adequate cut 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-criven 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 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 unreviewec safety cuestions were identified, and ultimately, the licensee competently resolved the technical problems.
)
]
9
11 1
IV.
PERFORMANCE ANAL SIS A.
Plant Operations (974 hours0.0113 days <br />0.271 hours <br />0.00161 weeks <br />3.70607e-4 months <br />, 25%)
i j
Analysis i
The licensee displayed excellent overall control of the plant.
Li-i l
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 i
1-trends and of plant transients.
Licensee management instilled a team j
concept in the shift organization.
Operations management insisted on j
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 orogram.
The licensee made effective use of pre-briefings for special evolutions and tests and was resconsive to NRC comments for improving the briefings.
Licensee i
management asserted their presence and involvement during.the dayshift as well as backshifts.
In summary, noteworthy performance by licensed operators, supervisors, anc operations management resulted in excel-lent overall plant control.
l 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 tney reflect a strong commitment to meeting re-quirements to assure nuclear safety.
These procedures also include 3
licensee initiatives beyond regulatory requirements. However, cer-tain e;;icrent centrol adeinistrative procedures are inconsistent efth each other anc with suo-tier cocaments with respect to indepen-l cent verification of equipment control measures as described in NUREG-0737, TMI Task Action Plan Item I.C.6.
Some of these proce-i 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 1
i 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-l ities without a procedare, several minor examples of failure to ad-l j
here to procedures, and-several;other examples where personnel worked around obvious procedure errors rather than stopping implementation I
to' obtain procedure change approval.
There were also cases where a -
more conservative approach was~needed.in implementing equipment con-n.
(t=ccut) measures.
In two cases, reliance on minimal isolation' i
i.
12 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 rcspect for proce-dures. This is highlighted by the fact that where procedures have received extra attention, they are generally of good quality and are i
strictly followed.
Examples include safety system valve lineups and major tests.
There was a definite presence and attentiveness on the part of vari-ous oversight groups.
The Nuclear Safety and Compliance Committee (NSCC) performed 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 theTP use of shift monitors, a unique and important licensee initiative.
The presence of experienced (formerly licensed) operations personnel in the QA cepartment enhances perfcrmance and credibility.
Some problems were noted with the Independent On-Site Safety Review Group (IOSRG), including (1) failure to follow its cwn 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 cegree to which the licensee uses the information is unclear.
For example:
Board dispositions for some NSCC recommendations were not clear; Management did not respond effectively to OA assessments regard-ing procedure implementation problems; and, 10SRG discovery of a part of the indeoendent verification prob-lems did not lead tc ccrprenersive resclution of incarsiste cies.
In general, management exhibited conservatism when facec with*techni-cal problems and, overall, licensee technical support was adequate but not aggress,ive. 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 af ter prodding by NRC staff.
Further, licensee review of certain problems or events could have beer. more thorough and ccaplete.
Exam-pies included review of an RPS breaker malfun: tion, evaluation of letdown cooler leakage, and evaluation of cecay heat system pressure indicator discrepancies.
In general, corrective action was timely, act trere w+re e>:epticas.
For example, had a r.:-e aggressive ap-prod;h teen taler tcwa-c ver.t. ;ation system balancing, noble gas
13 contamination incidents might have been precluded or minimized. Oth-er functional areas describe related instances of poor tecnnical 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 wnen a short-term, multi-disciplined review was needed.
Upon final resolution, no unreviewed safety questions were identified and, 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 groups are performing adequately; nowever, some important findings were not acted on ef fectively by licensee management.
Overall 11censee performance in this area was effective and well oriented toward nuclear safety.
Cenciusion Category 2 Recommendation Licensee: Discuss at the SALP meeting (1) licensee actions to im-prove the technical support area, (2) measures to instill in all wor + s accropriate attention to operations phase acministrative con-trols, and (3) licensee measures to ensure optimal benefits from oversign: group findings.
NRC:
?AT : s~~'c review extensively the litersee's independent technical anc satety review process; by PAT II, an assessment shoald be race of the licensee's plant safety review processes; in pa rti cul a r, tne reliance on individual reviews as contrasted with interdi sci;1i ta ry committee reviews.
-n
14 E.
Radiolooical Controls (244 hours0.00282 days <br />0.0678 hours <br />4.034392e-4 weeks <br />9.2842e-5 months <br />, 6*J)
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-factorily 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 organization.
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 cuality assurance department has a lead monitor in this area for oversight of radiological control activities.
The radiation prutettiun management staff takes tne in1tlative in improving and enhancing radiological control practices and procedures.
For example, (1) the licensee's radiological staff initiated the i.1vestigatior of noble gas migration pathways in the auxiliary and fuel handling build-ings, and consecuently effected corrective measures to better control airborne activity in the facility; (2) both health physics-field operations and radiological engineering groups cerform frequent planned inspections anc audits of radiologically controlied areas, 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 reviewec and evaluated to ascertain causal f actors, corrective measures, and dose effects. Additionally, radiological controls awareness reetings are held monthly by the radiation protection, airtena :e, anc o;e-at:cr cesartments to exchange information and rescive conce ns pertairirg to radiological work, cractices, and pol-icies.
Inese meetings are also attended by representatives from the bargaining enit the Vice President and Director of TMI-1, and con-cerned workers.
The licensee generally exhibits good radiological control practicas and tney implement a very thorough radiation worker training pregram in an effort to ensure that radiation workers are aware of radiolog-ical safety procedures and are able to implement them competently.
The TMI-I Restcrt 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
- <':: ro
- rposure
15 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 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.
1 In summary, the licensee was able to demonstrate that program ele-ments continued to be effectively implemented during power operations, anc the licensee acequateb trainec and qualified perscnnel responsi-ble for implementation of the radiological control program Implemen-tation oroblems were not due to programmatic weaknesses but were related to poor individual worker performance or inadequate support from other departrents such as operations or engineering. The licensee's program in tnis area is tecnnically sound.
Conclusior j
Category 1 Recommerdatio,s h o r,e
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 assigning maintenance personnel to one of the six rotating shifts.
This reouced the typical power plant peaks of high maintenance activity during the dayshift.
It also allowed the maintenance department to schedule and perform corrective maintenance on vital equipment as problems developed.
Placing a portion of maintenance personnel on shift work did, however, dilute the experience level in the I&C area.
This dilution Of exoerience in the I&C area caused minor operational problems which resulted in delays in retests until suoervision arrived on site.
The electrical and techanical main-tenance experience remained at a high level.
The collective know-ledge of the maintenance department was sufficient to resolve equip-ment probiems.
In addition, maintenance personnei 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 indi vidua's failed to follow a mairtenance procedure and this result-ed in tne loss cf a safet3-related elect-ical bas. Ine indivicaals invcived were ci ciplinec tc-fail'ng to cecrerate in the licensee's i
s review of this event.
I&C personnel were involved to a limited ex-tent in tne procedure implemer.tation problems addressed in other sections.
During this assessment period, several major safety-related systems were reviewed closely by irspectors to determine overall reliability and operability of the equipment.
Emphasis was placed on preventive, as well as corrective naintenance by management in response to plant restart.
Preventive maintenance procedures appropriately reflected vencer te:hrical manual recommencations. Safety-related equipment was f ounc to be in gooc material condition. Machinery history and mainte-nance records reflecteo procer documentation (consistent with restart hearing board requirements) and this resulted in development of a l
useful rist rical data base on plant equipment.
Records and field cDservaticr.s reflecte: the invaivement of the QA department in as-suring operabili t:, Of safety-related equipment.
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~ - - - - - - - - - - - - - - - - - - - - - - - - - - ' - - - - ' - - - - - - ^ ^ - - -
i 1
17 q
No instances were noted of inoperability or poor testing because of i
maintenance procedures.
However, certain maintenance procedures lacked specificity and clarity associated with the recording and/or i
evaluation of as-found conditions.
This lack of clarity has forced j
maintenance personnel, independent of plant engineering, to evaluate i
and determine the operability of equipment in the. field with limited i
guidance.
This has pointed out a need for enhanced procedure review i
and approval and better technical support on the evaluation of j
as-found conditions.
Maintenance personnel, in particular, and other groups of personnel doing work in safety related spaces, were somewhat insensitive to the I
change to an operating node.
In certain instances, personnel contin-ued their working habits as though the plant was in a shutdown condi-l 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-curred, the most significant of which was the inadvertent tripping of the emergency feed pump during scaffold construction, causing the pump to be inoperable for several hours.
The day-to-day approach and 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 implerrented 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-i 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.
1 Sufficient technical support was provided to maintenance and good
}
communicat4cn existed between tnis department.and plant engineering.
There was consistent evicence of engineering evaluations in mainte-J nance packages.. There was, however, incomplete support for " Fur-4 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.Fu'rmanite for repeat injections evi-denced during the full power trip outage. As a result, an OTSG level I-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 1
by the f% staff occurred.
Upon ccmpiete review of these problems, i
no unreviewed safety questions were identified by the licensee.
j These examples reflect a need for licensee management to assure a
]
more inquisitive evaluation of plant problems, i
i 1
1 1
18 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 and in a condition that supported unit sta-tup.
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.
Conclusion Category 2 Recommendations None i
o 19 D.
Sa vtillance Testine (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-eraga 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 p rog ram..
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-al days due tc the impro;ec issuance of a procedure change.
This violation of requirements was considered minor.
0;-ir.g thi s ir:pection period, N' C staf f perf ormed an extensive re-view of safety related equipment operability regarding the following components:
tne makeup pumps, decay heat pumps, and the diesei gen-erators.
The review included operating procedures, technical speci-fication compliance, inservice testing, preventive maintenance, maintenarce history, and surveillance testing. Applicable surveil-lance tests were founc to be technically adequate in that they met all applicable NRC reauirenents.
Surveillance test procedures, alcrg with maintenance procecures and post-maintenance testing, provided
= cs 3:e assu-u :e trat :. selected safety related componert were
~ a: > e <
- a e: upon.
Su veills :e procedures were prererly followed.
Tests were performed in a deiinerate nanne e.suring that each step was completec prior to proceeding to tne next step.
i Recercs were well kept.
For a surveillance test of frequency of ninety days or longer, a hard copy record of the last completed test was mairtaiced in tne control roc-Once a test was completed, the newe-test was placed in the file and the older te.t was sent to piant records for rJcrofilning.
This system enabled technicians or operators good access to the most recently completed tests, if neces-sary.
In aadition, extensive test records were reviewed by NRC and found to be complete witn one exception, discussed below.
O
20 Of particular concern during this period were the circumstances that ceveloped during and af ter 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 sheet as a result of that test and, subsequently, throwing these 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 bandling 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 supervisicn caught them before any adverse condition resulted. A number of examples were noted in which supervision or senior person-nel corrected errors made by Junior personnel.
This was especially evioent in tne 1&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 cocedination of sur-veillance test implementation and records. Personnel, in general, were quali'ied te rerform surveillances but as noted above, snme in-exce-ience was e.icenced cy a few individ;als.
None of the uncianned reactor trips durir; inis ceriod were causec 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 numcer and did not adversely af fect plant safe-ty.
The licensee safely' conducts surveillance tests during plant operations.
Conclusion Category 1 Recommendations Hare
21 E.
_Startup Testinc (561 hours0.00649 days <br />0.156 hours <br />9.275794e-4 weeks <br />2.134605e-4 months <br />,14*e)
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.
Testing was performed at predetermined power levels from 0 to 100 percent power for both transient and steady-state conditions and in-cluded tests of reactor physics performance, natural circulation, integrated control system, feedwater system, emergency 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 I
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 addition, innovative software programs were employed to monitor and predict core status on a real time basis. With proper interfacing witn the licensec operators, this resulteo in tests being completed j
in an effective and well-controlled manner. Although reactor engi-neers initially were aggressive in tneir requests to operators to a
establish plant test conditions, plant operators were always in control of plant operations.
ine startup test engineers had the largest portion of the program; directing test evolutions from natural circulation testing through the final reactor trip at 88 percent power, to subsequent steady-state tastinp at 100 percer.t poacr.
Except for the first part of the nats-ai c'r:alation test. glant testing was well-coordinated with good interf ace with the plant operators.
Data were properly taken, data stations were adequately manned, and data reduction was per-
'ormed 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 pericdically 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.
Tne extensise pre-test training of reactor engineering and test engi-neering personnel was evident in the overall lack of personnel prob-lems during test performance.
'est briefings for major evolutions were thorough and extensive.
Problems noted during earlier tests, where applicable. were factored into briefings for later tests.
Caalit> assurarce 'nvol.ement in startup testing was extensive in
1 22 l
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 Doron mea-surement test during zero power physics testing, too much baron was added to the reactor causing subcriticality.
This " boron overshoot" l
condition was promptly noted and the reactor engineers and operators l
displayed a cautious approach in the boron dilution needed to correct l
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 l
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.
i Based on staff review, the startup test procedures were comprehensive l
and acconolished 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.
l Notwithstanding the positive aspects of the test program, some problems with procedures and personnel were observed. During the I
first part of natural circulation testing, test engineers did not I
apoear to be fully organized.
This problem was recognized by manage-ent and was ouickly corrected.
The test could have been better o;annec tc instruct tne operators now to recover from the unique plant
]
cunditions.
As a result, at initial restoration of forced circulation l
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 i
the conclusion of the test program following the reactor trip at 88 cercent power, one further test deficiency was noted in that the I
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-V2 to open af ter a trip was subsequently demcnstrated through a separate retest af ter NRC staf f prodding on the issue.
In summary, the licensee performed very well during the TMI-1 restart startup testing program.
Aggressive management attention and involve-l ment at the upper and middle management levels contributed to the I
1 I
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-l plished on a realistic schedule, and provided ample time for operator l
training and familiarization.
Licensee initiatives having generic i
B&W applicability in this area were noteworthy. Although they ccnstituted unique tests, more comprehensive reviews should have been considered by the licensee before implementation, l
l Conclusion i
l Category 1 l
Recommendations l
None l
l l
l l
24 1
I F.
Traininc ard Qualification Effectiveness (NA)
Analysis l
The various aspects of this functional area have been considered and j
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.
l This discussion addresses three principal areas:
licensed operator j
training, non-licensed staff training, and the status of INPO training accreditation.
The training department was staffed with knowledgeable and experi-enced personnel.
The lesson plans, speciali:eo manuals and coursm.
bands-cr experience, and/or extensive use of simulator and bas;;
principles simulater training provided meaningful and practical training not only to licensed operators but also to other oper m tecnnical personnel.
Inis was evident in the performance of new candidates for operator licenses.
Ali candidates for licenses or instructor certificatiens passed.
They included four SRO candid a e,
one RO candidate (on retake), and one instruction certification car-didate.
As noted in the plant operations section, observations of licensc<l operator personnel by snif t inspectors produced a good deal. of infor-i mation relative to their level of jnowledge and performance skills.
l The results of that review were' favorable. The special interviews and discussions on shift confirmed a high level of knowledge of facility design with only minor weaknesses observed.
Operators were well pre-i pared for restart ar.d demonstrated especially strong skills in manip-ulating the integrated cor. trol system in the manual mode.
The training for the rcr.-licersed staff consisted of both formal and on-the-job trairing.
Based on NRC observations, this program was also ef fective in produ::ing 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.
l Experierced personnel provided adequate guidance to less experienced personnel.
l No plant trips occurred due to personnel error.
However, inspectors saw a persistent problem with workers in various plant areas having i
tne potential to cause a trip or a challenge to a safety related I
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 wel'-stateo management policies in these areas and the understanding c' inose policies by certain individuals.
25 Even with the corrective action initiated before the end of the power escalation program, licensee Tanagement 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 five areas: control room operators; senior reactor opera-tors; shift technical advisors; auxiliary operators; and radiological control technicians.
In summary, the licensee's training program is effective and is ori-ented toward improving on-the-job performance.
The program has the j
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 l
seek help.
1 Conclusion l
Category 1 (based on functional areas acdreu ed)
Recommendations None l
l 6
1 l
i I
i 4
i
~
1 l
26 l
G.
Assurance of Quality (NA)
T" various aspects of quality assurance program requirements have been consiaered and discussed as an integral part of each functional i
area and the respective inspection hours are included in each one.
Consequently, this discussion is a synopsis of the assessments conducted in those areas.
l The quality assurance department continued their aggressive involve-ment in oversight activities.
This was reflected in their unique l
three levels of review along with a substantial resource initiative l
--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-l operators.
This had the added benefit for licensee nanagement of enhancing the operational expertise of the QA l
department to fulfill its responsibilities in the oversight of operations.
i Tnere wat a cefinite CA presence and involvement in the various fac-ets of field activities.
The monitoring level of review was effective in icentifying 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 progren implemectation.
However, licensee management apoarently did not ef fectively respond to the QA department for the procedure imph m n-tation troblem, which was highlighted in the 0A department's annual effectiveness review.
I r. sammary, tnere was management and quality assurance (QA) depart-ment presence and involvement in all facets of activities at the site.
Licensee management may need to provide additional attention tn the OA department's effectiveness reviews.
Co :?n :n Category 1 (based or the functional areas addressed) 9 l
L
27 Recommendation Licensee:
None NRC:
PAT look at the effectiveness of the QA review process.
9 e
O 9
w
28 V.
Supportinc Data and Summaries A.
Investigations an_d Allegati_ons Review Tnere are no open investigations for TMI-1.
The investigation en the environmental equipment qualification 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.
8.
Escalated Enforcement Actions None C.
Manaaerent Conferences None D.
Licensee Event Reports Only three licensee event reports were submitted during this period.
They are listed belos instead of being tabulated in a separate table.
LER 85-C02, dated October 3. 1995, for the manual reactor trip (from hot shutdonn condition) that occurred on September 7 1985, due to operator action in response to a firo 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 hign pressure in the RCS.
The root cause was an equipment / component malfunction with a main generator relay that caused a mair tu-bi:e reje: tion which caused the transient in :ne RCS (re:
FLANT ODERATICN5 AREA).
LER 85-004, dated December 26, 1935, 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 assessment 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.
= _ _ -
m 29 LER 85-004 was indicative of the worker in the spaces problem identi-fied in the maintenance area.
E.
Reactor Trips / Forced Outages Table 5 reflects the unplanned reactor trips and reactor shutdowns along with root causes. Also, the main turbine was taken off-line with the reactor critical at low power during October 13-18, 1985, for turbine steam inlet drain line repairs, as discussed in paragraph I.C.1.
The following reactor trips that occurred during this period were planned per the licensee' test program:
October 15, 1935, Manual PLANNED in accordance with startup test procedures October 21, 1985, Loss of PLANNED in accordance with Feedwater power escalation procedures January 2,1936. Turbine T rip PLANNED in accordance with power escalation procedures F.
Planned / Unplanned Releases Iable 6 is a summary of the t.are significant unpianned releases for the period, along with a summary of the routine releases from the plant or. a montnly casis.
No regulatory limits were violatea.
S u
O T1-1
?
TABLE 1 INSPECTION REPORT ACTIVITIES i
TMI-1 NUCLEAR GENERATING STATION i
REPORT NO./ PERIOD AREAS AREA INSDECTED INSPECTOR TYPE HOURS INSPECTED i
85-22 SHIFT 683 Power Operations 9/16/S5-10/11/S5 RESIDENT / PROJECT Startup Testing STARTUP TESTING ENGINEERING SPECIALIST 85-24 SHIFT 369 Power Operations j
10/11-18/85 RESIDENT / PROJECT Startup Testing STARTUP TEST Licensed Operator RADIATION SPECIALIST Training i
j Radiological l
Effluent Control i
j 85-25 SHIFT 352 Plant Operations 10/IE-25/35 RESIDENT / PROJECT Startup Testing STARTUP IEST i
~
E5-26 SHIFT 501 Plant Operations 10/25-11/12/E5 RESIDENT / PROJECT Startup Testing RADIATION SPECIALIST Radiological i
Effluent Control 85-27 SHIFT 603 Plant Operations 11/12-27/85 RESIDENT / PROJECT Startup Testing STARTUP TESTING Radwaste Management 55-25 SHIFT 540 Plar: Operations 11/27-12 13/55 RESIDENT / PROJECT 5tartup Testing i
STARTUP TEST Radiological RADIATION SPECIALIST Effluent Control
(
ea-30 SHIFT 888 Plant Operations i
12/13/85-1/10/86 RESIDENT / PROJECT Startup Testing STARTUP TEST Radiation Protec-RADIATION SPECIALIST tion ENGINEERING SPECIA.IST l
1 T2-1 TABLE 2 INSPECTION HOUR 5
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 Cor.trols 244 6
Maintenance 288 7
Surveillance Testing 252 7
j Startup Testing 561 14 j
Training anc gaalitication Effectiveness (included in above)
Assu-at:e of 0;a'ity (included ir above)
To t.i i 3936 100 4
~
l r-T3-1 TABLE 3 ENFORCEMENT
SUMMARY
(9/16/85 - 1/10/86) l l
TMI-1 NUCLEAR GENERATING STATION l
A.
Number and Severity Level of Violat' ions l
~'
Severity Level II Severity Level III
~
Deviations Total 7
B.
Violations vs. Functional Area Functional Area Severity Levels 1
II III IV V
Dev Total Plant Operations 4
4 Radiological Controls Maintenance 1
1 2
Surveillance Testing I
1 Startup Testing Training and Qualification Effectiveness Assurance of 0;ality ictals 6
1 7
.,1
\\
r 4
n.
T4-1 TABLE _4 ENFORCEMENT DATA TMI-1 NUCLEAR GENERATING STATION Inspe: tion 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 cabinet s 85-27 11/12-27/E5 IV Diant Failure to Operations establish or properly change precedures 'n-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-j dent onsite safety review group (IOSRG) activities
=
w s.
.(
T4-2 TABLE 4 (Continued)
Inspection Irispect ion Severity Functional Report No.
Date Level Area Violation l
85-27 11/12-27/85 IV Security Failure to (Plant properly implement Operations) security personnel badge identifica-tion control measures 85-30 12/13/85 IV Fire Failure to Protection properly inspect (Surveillance) a fire door on the specified frequency s
F m
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w r
e r
e T5-1 TABLE 5 UNPLANNED REACTOR TRIPS A.!LD SHUTDOWNS Unclanned Reactor Trips Date Description Root Cause December 1, 1985, The high RCS pressure resulted Secondary plant trans-High RCS Pressure due to a load rejection with ient due to electrical the tripping of the main grid transient generator breaker. An over-excitation protective relay malfunctioned when a regional grid voltage transient coupled with a relay setpoint drif t occurred January 4,1986, The turbine trip resulted Random equipment mal-Turbine Trip because of an abnormal high function in the second-level in one of six moisture ary plant separators due to a level controller malfunction in the feedwater heater drain collection tank Unplanned Shutdowns None
REVISED PAGE T6-j f
TABLE 6 RADIOLOGICAL EFFLUENT RELEASES Anomalous Occurrences Resulting in Off-Site Releases of Noble Gases
% of Technical Specifications Component Release Activity Quarterly Date Involved Point Released (Ci)
Du_r_a t i on 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 Fump Station Vent 0.7 42 min 0.0015 (SV) 11/2/86 Reactor SV 1.05 75 min 0.001 Coolant Evaporator 11/15-Main Steam MSRV 1.6 E-7 5 sec 3.49E-9 20/85 Valve Testing 12/1/85 Reactor Trip MSRV 7.32 E-6 7 min 1.5 E-7 at 75%
12/17/85 Waste Gas SV 1.4 54 min 0.001 Compressor 12/30/E5 Mateup Fump SV 46.3 274 min 0.07 Normal Ore-atina Releases - C-edo-ina :lv Noble Gases October 0.15 (0.02%
0.00132 particulates)
November 18.8 (0.0003% tritium) 0.02 December 5.29 0.0076 flormal Operat'ec Releases - Licuid - Predominantly Tritium October 1.0 (0.03*. non-tritium)
November 1.19 (0. rl", non-tri tium)
Decem3er 5.99 (4.4 E-3*. non-tritium)
9 T6-1 0
4 TABLE 6 RADIOLOGICAL EFFLUENT RELEASES Anomalous Occurrences Resulting in Off-Site Releases of Noble Gases
% of Technical Specifications Component Release Activity Quarterly Date Involved Point Released _(C.i)
Dura _ tion Limit. Gamma 10/21/85 Reactor Trip Main Steam 1.07E-6 10 sec 3.8 E-8 at 40%
Relief Valves (MSRV) 10/2E/E5 Makeur Pum; Station Vent 0.7 4Z min 0.0015 (SV) 11/2/E6 Reactor SV 1.05 75 min 0.027 Coolant Evaporator 11/ i ':-
Main Steam MSRV 1.6 E-7 5 sec 3.45 E-0 20/85 Valve Testing 12/1/E5 Rea :or T-ip MSRV 7.32 E-6 7 min 1.5 E-7 at 75%
12/17/E5 Waste Gas SV 1.4 5d ein 0.001 Compre:
c-12,30 E5 MD e r-
/-
SV 46.3 27 min 0.07
- _ _0 : -
'.c__R_eis_a_s_e;. : m " o -
- h. _e : '.e._. G.. _a.s_e. s October 0.15 (0.02%
0.00132 pa -O :u : e te:.)
November 1E.S (0.0C03% tritium) 0.02 Decembe-5.29 0.0076 Norma l. 0B 'at O:iit9_ses - Li cuid __ _P edcmi na n t ly Tri ti um October 1.0 (C C3% non-tritium)
November 1.19 (C
'.S non-tritium)
Decem3er 5.;0 (0.4 E-35 ncr.- -itium)
.