ML20207B094

1.07 E-6

3.8 E-8

at 40%

Relief Valves

(MSRV)

e

10/28/85 Makeup Pump

Station Vent

0.7

0.0015

(SV)

11/2/85

Reactor

1.05

0.025

Coolant

.

Evaporator

i

l

11/19-

1.6 E-7

3.48 E-9

!

20/85

Valve Testing

I

12/1/85

7.32 E-6

1.5 E-7

at 75%

4

12/17/85 Waste Gas

1.4

0.001

-

Compressor

12/30/85 Makeup Pump

46.3

0.07

1

1/2/86

1.22 E-5

2.3 E-7

'

at 88%

v

1

1/4/86

2.14 E-5

3.06 E-7

1

at 22%

,

'

1/9/86

RCLD Gas

1.6E-1

8.34 E-5

4

Sample

1/9/86

Flush of

2.76

2.22 E-3

MU-V-129A

-

,

-

. .-

_

m

M

g

1

-

.

-

.

_ . -

_

.

f

. -

--.--m-y.--,c-,----+

~%

_7

y--,

. - . . - - -

--

g.,

- - _ .,,

-...7-----------g-

, . - . . _ , , , - - _

-

,

y.

-. - -

-,,,

.-- - - --,

,

.-

.

..

-

_

-..

.

, . . . -

.

TABLE 8 (Continued)

,

RADIOLOGICAL EFFLUENT RELEASES

<

1/28/86

DH-V-57B

3.96

2.0 E-3

Spill

i

2/13/86

AHC-14C

6.5 E-1

3.3 E-4

l

Fan Shutdown

2/13/86

Drain Trap

1.5

1.16 E-9

<

Chem Lab

1

]

Sample Sink

2/24/86

CA-V-2

11.6

6.44 E-9

]

Leakage

2/24/86

CA-V-2

2.79

1.91 E-3

-

Repair

_

3/4/86

Waste Gas

1.47

7.7 E-4

Comoressor

3/15/86

3.7 E-5

7.86 E-7

from 100%

5

3/22/86

CA-V-5

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

14.8

8.54 E-3

Relief Lift

T

Normal (Routine / Continuous) Operating Re?>Jses - Predominantly Noble Gas

!

% of Technical

.

!

Specification

i

Activity Released (C1)

Quarterly Limit, Gamma

-

'

!

j

October

0.15

1.32 E-3

November

18.8

2.0 E-2

'

December

5.29

7.6 E-3

January

262

2.78 E-1

.,

4

February

1150

1.23 E-0

i

.

March

830

8.8 E-1

l

-

..

._

r

__

,

<

_

..

.

I

.

-

,

h

-

._

_

_ .

.-,g.

. - ,r.,

-..,

,

- ,

-

-c.

.m

,, ,

.-_m+.-

-~ . . ,

, , .

.__y-

_

.rw

- . . .-

r.

rv,

-

-,-

_ . _ _ _ -_

. _ _ . _ _ _ _ _ _ _ _

_ _ _

_ _ . _ . . _ .

. _ . _ _ . - _

_ - _ _ . _ - _ __ _ -.

_ _ _ _

_

.. *

a

!

]

i

!

4

T8-3

..

TABLE 8 (Continued)

,

i

]

RADIOLOGICAL EFFLUENT RELEASES ~

,

1

Normal (Routine) Operating Releases - Liquid - Predominantly Tritium

'i

Activity

Date

Released (C1)

i

~

October

1.0

1

November

1.19

i

r

December

5.99

January

24.1

February

26.3

Mr.rch'

17.6

i

!

1

!

r

'

.

l

4

l

l.

i

1

!

3

-

_

-

.

-

._

_

.

!

, . .

- - . .

,

- . . . .

_ _ .

-

. ..

. - - .

.. -

..

>

-. -

.

-

.-

_

.

-

..

-

.

_

,

f '

,

9

U. S. NUCLEAR REGULATORY COMMISSION

REGION I

,

INSPECTION REPORT 50-289/85-98

GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION

THREE MILE ISLAND NUCLEAR GENERATING STATION UNIT ONE

ASSESSMENT. PERIOD:

SEPTEMBER 16, 1985 - JANUARY 10, 1986

BOARD MEETING DATE: JANUARY 24,198b

.

1

I

d

s

..

-

c.

.

_

__

___

_

.

m

-

.

_

.

TABLE _DF'C NTENTS

__ _ -.

--

_ _ - -

.

_

Page

I.

INTRODUCTION

1

A.

Purpose and Overview. . . . . . . . . . . . . . . .

2

B.

SALP Board Members

................

3

-

C.

Background. . . . . . . . . . . . . . . . . . . . .

6

II.

CRITERIA . . . . . . . . . . . . . . . . . . . . . . . .

III.

SUMMARY OF RESULTS

8

A.

Facility Performance. . . . . . . . . . . . . . . .

9

B.

Overview. . . . . . . . ..............

IV.

PERFORMANCE ANALYSIS

Il

A.

Plant Operations. . . . . . . . . . . . . . . . . .

14

B.

Radiological Centrols . . . . . . . . . . . . . . .

16

C.

Maintenanc

. . . . . . . . . . . . . . . . . . . .

.

19

D.

Surveillance Testing. . . . . . . . . . . . . . . .

21

E.

Startup Testing . . . . . . . . . . . . . . . . . .

24

F.

Training and Qualification Effectiveness

.....

26

G.

Assurance of Quality. . .

.............

V.

SUPPORTING DATA AND SUMMARIES

28

A.

Investigations and Allegations Review . . . . . . .

B.

Escalated Enforcement Actions . . . . . . . . . . .

28

C.

Management Conferences. . . . . . . . . . . . . . .

28

D.

Licensee Event Reports. . . . . . . . . . . . . . .

29

E.

Reactor Trips / Forced Outages

...........

29

F.

Planned / Unplanned Releases. . . . . . . . . . . . .

TABLES

T1-1

Table 1 - Inspection Report Activities . . . . . . . . . . . . .

T2-1

Table 2 - Inspection Hours Summary . .

.............

T3-1

Table 3 - Enforcement Summary. .

................

T4-1

-

Table 4 - Enforcement Data . . . . . . . . . . . . . . . . . . .

T5-1

,

Table 5 - Unplanned Reactor Trips and Snutdowns

........

T6-1

Table 6 - Radiological Effluent Releases . . . . . . . . . . . .

.

_

I.

,-

- -

, , .

_

1

.

-

.

-

-- I.

'INIEODUCTION

-

=

-

.

_

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 performance. 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 after 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 from a long-term shutdown condition

to commercial power operation, and (3) to determine the allocation of

NRC resources 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

observations 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 THI-1 Nuclear Generating Station for the period

September 16, 1985, through January 10, 1986. The summary findings

and totals reflect a relatively short period compared to the normal

assessment period which is at least 12 months.

,

e

-

.

_

.

..

_

- _ _ _

_ _ _ _ _ _ _ - _ _ _ _ _ _ - .

.

.-

-

2

.

-

..

-

B.

SALP Board Members

-.

Chai rman

R. Starostecki, Director, Division of Reactor Projects

Members

.

R. Bellamy, Chief, Radiation Protection Branch, DRSS (Part Time)

i

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 Branch No.1, DRP (Part Time)

P. McKee, Chief, Operating Reactor Programs Branch, Division of

Inspection Programs, IE

J. Thoma, THI-I Operating Reactors Project Manager, Project

Directorate No. 6

Other Attendees

N. Bluccerg, 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

1

,

--

_ _ _ _ _ _ _

_ _ _ - _ _ _ _ _ _ _ - _

I,

. -

.

_

--

-

_

3

_

.

-

.

-

~

C.

BacEiro~und

--

--

-

.

_

.

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 licer.see completed its program within a few days of the plan-

,'

ned schedule. The program included six NRC Region I hold points.

The

The assessment period began with the plant in hot shutdown.

reactor was taken critical on October 3,1985, for natural cir-

culation testing and other low power tests. On October 9, 1985,

the main generator was placed on-line.

Between October 13 and 18, 1985, the turbine was taken off-line

several times with the reactor at low power to repair weld fail-

ures on drain lines from steam inlet piping to the main turbine.

On October 19, 1985, a test of the reactor trip on loss of main

feedwater was initiated from 40 percent power and a subsequent

natural circulation test was completed. The reactor was re-

started and the main turbine generator placed on-line on

October 23, 1985, then taken to 48 percent power.

The reactor was then op2 rated at 48 percent power for operator

training and steam generator leakage monitoring. Between

November 24, 1935. and December 27, 1985, the licensee completed

additional plannen steady-state power operation at 75 percent

power. On December 27, 1985, the NRC released the licensee to

take the plant to full power. However, the maximum achievable

power was limited due to secondary side fouling of the steam

generator, which caused higher than expected steam generator

water levels. Even after raising the steam generator water

level limit, as has been done at other B&W plants which experi-

enced the same problem, the licensee was able to achieve only

88 percent of full power.

On January 2, 1986, the licensee satisfactorily completed the

final power ascension tests -- reactor trip on turbine trip and

EFW initiation on loss of reactor coolant pumps. After the

planned January 2 trip and an unplanned trip during start-up on

January 4, the steam generator fouling was apparently alleviated

and the plant reached full power.

During the above period, two unp'anned reactor trips occurred:

l

on December 1, 1985, from 75 percent power, as discussed above,

and on January 4, 1986, from 22 percent power. The first

l

occurred because of a main generator breaker trip due to a mal-

function in a main electrical generator protection relay.

The

!

l

<

.

-

.

-

.

-

. . .

-

.

.- .

_

l

~

..

.

I

4

-

'

-

.

~

-

other occurred because of another secondary plant malfunction

,

-

that caused a high level in a moisture separator which resulted

i

in a turbine-to-reactor trip.

'

The annual emergency preparedness exercise was comple'ted satis-

l

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 scheddled for delivery in June 1986.

l

2.

Inspection Activities

,

l

In May 1985, Region I established the TMI-1 Restart Staff organ-

ization to provide an intensive review of licensee activities

1

using an augmented shift coverage plan. This organization

"

continued to function from that time through delays in restart

i

authorization and through the licensee's power escalation

testing (PET) program. There was a high level of Region I

management involvement including the Deputy Director, Division

of Reactor Projects, who served as THI-I Restart Director on

i

I

site.

Because of his knowledge of the TMI-1 plant and experience with

the TMI-1 restart process, the senior resident inspector was

designated TMI-1 Restart Manager and assigned the responsibility

to manage inspection activities. Shift inspectors, experienced

in B&W plant operations, included resident / project engineers

,

from Region I, other regions, the NRt. training center, and NRC

contractors. Shift inspector activities ranged from 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

per day to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months per day, depending on the pace of licensee

'

activities. The resident inspector and Region I inspectors

conducted follow up reviews of a programmatic nature in response

to shift inspector concerns. As time permitted, they conducted

reviews of equipment operability and of the technical adequacy

l

of selected procedures. Region-based specialist reviews also

occurred in the areas of radiation protection, training,

-

j

engineering support, security, and emergency preparedness.

To provide additional technical expert,ise and experience 'sith

the TMI-1 restart, the former senior resident inspector 'or

i

TMI-1 was assigned as a technical assistant to the THI ' Restart

l

Director.

!

A total of 3936 inspection hours were expended during the period

!

(shift inspector coverage was approximately 40% of that total)

with a distribution in the appraisal functional areas as shown

in Table 2.

The inspection hours occurred during a 17-week

period which converts to 232 hours0.00269 days 0.0644 hours 3.835979e-4 weeks 8.8276e-5 months / week or approximately 12,000

,

l

hours annually.

Summaries of inspection activities and identi-

fied violations a-e tabulated in Tables 1 and 4 respe:tively.

f

.

4

- , . - - - -

_ . , - - . , , , - - - - - . - , . - - -

,--,.,-.,r,

. , , , , ,

- . - , ,

--

,,m-

,

,m-

,,

.

!

_

,

.

-

. _

.

_

5

-

_

This report also discusses " Training and Qualification Effec?

_ '

tiveness" and " Assurance of Quality" as separate functional

Although these topics, in themselves, are assessed in

areas.

the other functional areas through their use as criteria, the

i

.

two areas provide a synopsis.

For example, quality assurance

i

'

effectiveness has been. assessed on a day-to-day basis by resi-

dent inspectors and as an integral a.spect 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.

.

O

e

O

9

h

e

.

_

__

,

_ -

.

_ _ .

_

-

6

.

-

_.

-

~

~~ II. CRtTERIA 3

'

~

-

_

Licensee performance was assessed in selected functional areas significant

to, nuclear safety and the environment. Assessment areas were selected

based on facility status (i.e., restart testing phase) and, for this in-

terim SALP, NRC inspection program focus. Consequently, this interim SALP

does not include certain typical SALP functional areas, such as emergency

preparedness, security and safeguards, fire protection, technical support,

and licensing. These will be addressed in the next SALP.

,

One or more of the following evaluation criteria were used to assess each

functional area:

1.

Management involvement and control in assuring quality

2.

Approach to resolution of technical issues from a safety standpoint

3.

Responsiveness to NRC initiatives

4.

Enforcement history

5.

Report and analysis of reportable events

6.

Staffing (including management)

,

7.

Training effectiveness and qualification

Based upon the SALP Board assessment, each functional area evaluated is

classified into one of three performance categories. The definitions of

these performance categories are:

Category 1.

Reduced NRC attention may be appropriate. Licensee manage-

ment attention and involvement are aggressive and oriented toward nuclear

safety; licensee resources are ample and effectively used so that a high

level of performanc,e with respect to operational safety or construction is

being achieved.

The NRC attention recommendation may not be consistent with the above

categories for a given SALP rating in a specific functional area.

This is because of unique aspects of TMI-1 and because of public sen-

sitivity to operational activities at the facility to which the NRC

-

"

staff must be prepared to respond.

Category 2.

NRC attention should be maintained at normal levels. Licensee

management attention and involvement are evident and are concerned with

nuclear safety; licensee resources are adequate and reasonably effective

so that satisfactory performance with respect to operational safety or

construction is being achieved.

,

Category 3.

Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear

-

^^

,-

,,g.,.

. _ _ - -

I.

&

_

-

7

_

.

safety, but weaknesses are evident; licensee resources appear to bi~

--

strained or not effectively used so that minimally satisfactory perfor-

mance with respect to operational safety or construction is being

achieved.

Normally, the SALP Board assesses each functional area to compare the

licensee's performance during the last quarter. of the assessment period

to that during the entire period in order to determine the recent trend

for each functional area. Because of the short period covered by this

SALP, the trend categ6 ries are not addressed, however, perceptible changes

in performance in the last month of the period are addressed in the

functional areas.

..

-

. . _ . .

__. _

!:

_ _

.

_

8

-

.

-

.

_

.

~

.

-

III. SURMARY OF RESULT F - -

--

_

-

--

_

.

_

A.

Facility Performance (September 16, 1985 - January 10,1986)

Category

This Period

Functional Area

2

1.

Plant Operations

1

2.

Radiological Controls

2

3.

Maintenance

1

4.

Surveillance Testing

1

5.

Startup Testing

1

6.

Training and Qualification

Effectiveness

7.

Assurance of Quality

1

,

_

!

I

_

v

-

r

+-r

r-

--

-

- _

I

-

- -

.

_

-

9

.

_

~

-

J

1

-B.

Overview

Overall, licensee management prepared their operators and the plant

well for restart in light of the long shutdown.

Licensed operators

conducted themselves competently and exhibited a detailed knowledge

of the facility design and plant status. They demonstrated their

skills especially well in operating the integrated control system in

the manual mode. Despite signs of inexperience, non-licensed person-

nel also performed well. No plant trips occurred due to personnel

error, but workers in safety-related spaces were not always careful

in working around the equipment; this had the potential to cause

safety system challenges. A strong training program contributed to

the overall good results in operator performance.

Plant equipment was in good material condition and it reflected a

strong preventive and corrective maintenance program applied during

The startup group assured that the numerous re-

the long shutdown.

start modifications were adequately tested to minimize operational

problems during power ascension.

Plant maintenance adequately

maintained equipment-subsequent to plant turnover. Very little

safety-related equipment needed repairs during the startup test

program.

In general, procedures were adequate but, in certain instances, prob-

lems with individual procedure steps challenged personnel in the prop-

er implementation of the procedures. Even though a strong precedure

control policy exists, apparently not all workers understand their

responsibilities when procedures cannot be followed.

To varying degrees, the oversight review groups performed adequately.

However, it appears that certain important findings by review groups

were not effectively acted on by licensee management.

The radiological controls program continued to be implemented effec-

-

tively during power operation. The unplanned radiological releases

that occurred were due to poor work planning, not radiological plan-

ning.

The surveillance and starttp test programs were strong, involved com-

petent and dedicated personnel, and complemented each other in the

The power escalation program was slow and deliberate, and

restart.

was effective in providing familiarization training for operators. "

-

It was also effective in identifying and correcting overall system

integration problems.

The assessment covered a period of intense NRC staff review during

transition from a long shutdown to commercial power operation.

Licensee personnel attentiveness to the plant was probably heightened

Although many of the licensee's programs are

by these circumstances.

strong, continued gooc ruclear safety performance will result only

with ef fective program implementation and sustained personnel

attentiveness and involve ent.

i

.

-

10

-

.

-

.

-

-.

\\

-

--

__

j

Technical Support

!

Technical support staffing was ample with definite signs of both cor-

4

porate and site engineering presence and involvement in plant activi-

In general, management exhibited conservatism when faced with

ties.

technical problems and, overall, technical support by licensee per-

sonnel was adequate but not aggressive. When technical problems

could not be resolved immediately, appropriate interim measures ware

provided to assure nuclear safety, such as with the relief / safety

valve problems associated with both-the steam generators and the

In

turbine-driven emergency feedwater pump steam inlet piping.

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

unreviewed safety questions were identified, and ultimately, the

licensee competently resolved the technical problems.

,

e

.

,

._m,.___

m

_,

--

,-

. . ,

_

.

. _

-_

._

_ _

_ _ _ _

-

-. -- - - - - -

9

I.

. -

7

-,

--

-

..

"

.

-

.

IV. -PERFORMANCE ANAt% SIS

-

.;

y

-

.

_

u

,t

- A.

Plant Operations (974 hours0.0113 days 0.271 hours 0.00161 weeks 3.70607e-4 months , 25';)

!

Analysis

The licensee displayed excellent overall control of the plant. Li-

censed shift personnel were professional and competent in handling

routine evolutions and tests and were especially skillful in operat-

ing the integrated control system.

Further, operators performed well

and demonstrated a safety conscious attitude during unexpected

events, such as the two unplanned reactor trips. The operators

l

showed a high level of knowledge and the ability to use that knowledge

in operating the plant safely.

Shift turnovers were thorough and

The shift technical advisor was integrated into plant

professional.

-

operations, especially in the evaluation of individual parameter

trends and of plant transients. Licensee management instilled a team

concept in the shift organization. Operations management insisted on

a quiet, professional control room atmosphere. Resources were well

managed to avoid excessive operator overtime while optimizing perfor-

The licensee made

mance and training benefits of the test program.

effective use of pre-briefings for special evolutions and tests and

Licensee

was responsive to NRC comments for improving the briefings.

management asserted their presence and involvement during the dayshift

as well as backshifts. In summary, noteworthy performance by licensed

i

operators, supervisors, and operations management resulted in excel-

lent overall plant control.

1

Administrative controls, procedures, and procedural adherence are

generally strong, but exceptions have been noted that require

liceasee management attention. Administrative controls for TMI-1 are

well established and they reflect a strong commitment to meeting re-

quirements to assure nuclear safety. These procedures also include

licensee initiatives beyond regulatory requirements. However, cer-

tain equipment control administrative procedures are inconsistent

with each other and with sub-tier documents with respect to indepen-

dent verification of equipment control measures as described in

NUREG-0737, TMI Task Action Plan item I.C.6.

Some of these proce-

4

dures impose independent verification for less than the full

safety grade scope of equipment to which it is intended to apply.

1

l

Although most licensee personnel exhibited respect for administrative

controls and attention to detail in implementing procedures, a sig-

nificant numbe'r of exceptions were noted. These included three cases

(two of which involved safety-related equipment) of conducting activ-

ities without a procedure, several minor examples of failure to ad-

here to procedures, and several other examples where personnel worked

around obvious procedure errors rather than stopping implementation

to obtain procedure change approval. There were also cases where a

more conservative approach was needed in implementing equipment con-

trol (tagout) measures.

In two cases, reliance on minimal isolation

.

-

e

m

--, , ----i

--

e

--m--ye,wgp--

ye-y

+

w

eg

=p

e wr -e

we

i

.

-

12

-

,.

-

.

barriers for maintenance work resulted in small releases of

-

f.

radioactivity when single isolation points leaked. Management'atten-

!

tion is needed to ensure that all personnel properly and conserva-

tively implerent administrative and procedural controls. Aleo, some

upgrading of the quality of reviews of routine system operating and

-

test procedures may be warranted to fos,ter worker respect for proce-

This is highlighted by the fact that where procedures have

dures.

received extra attention, they are genera'11y of good quality and are

strictly followed. Examples include safety system valve lineups and

major tests.

There was a definite presence and attentiveness on the part of vart-

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 their

use of shift monitors, a unique and important licensee initiative.

The presence of experienced (formerly licensed) operations personnel

in the QA department enhances performance and credibility. Some

<

problems were noted with the Independent On-Site Safety Review Group

(IOSRG), including (1) f ailure to follow its own procedures and (2)

lack of a systematic approach and sufficient, depth in procedure re-

l

Overall, the oversight groups provide potentially beneficial

view.

insights, but the degree 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 QA assessments regard-

--

ing procedure implementation problems; and,

IOSRG discovery of a part of the independent verification prob-

--

lems did not lead to comprehensive resolution of

inconsistencies.

In general, management exhibited conservatism when faced with techni-

cal problems and, overall, licensee technical support was adequate

but not aggressive. When technical problems could not be resolved

immediately, appropriate interim measures were provided to assure

nuclear safety, such as with the relief / safety valves problem fof

steam generators and the emergency feedwater pump steam inlet piping.

In certain instances, however, these measures were established only

after predding by NRC staff.

Further, licensee review of certain

Exam-

problems or events could have been more thorough and complete.

pies included review of an RpS breaker malfunction, evaluation of

letdown cooler leakage, and evaluation of decay heat system pressure

,

indicator discrepancies.

In general, corrective action was timely,

but there were exceptions.

For example, had a more aggressive ap-

proach been taken towa-d ver.tilation system balancing, noble gas

_

. _ - .

. _ _

l

_

- -

'

.

-

--

-

_

.

13

>d

.

l,i

-

.

._

_

.

I

-

_ _ _ '

-

5

contamination incidents might-have-been precluded or_minimiz_ed.

Oth--

_

l

er functional areas describe related instances of poor technical sup-

port, most notably reflected in "Furmanite" repair jobs. Apparently,

6

engineering personnel and management were not sufficiently inquist- ~

!

tive to assure a complete understanding of certain problems, espe-

cially when a short-term, multi-disciplined review was needed. Upon

final resolution, no unreviewed safety questions were identified and,

ultimately, the licensee competently resolved the technical problems.

-

In summary, licensee management prepared the plant and their opera-

For the most part, procedures were techni-

tors well for restart.

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

It appears that in certain instances, personnel

procedure step.

understanding of the licensee's strong procedural control policies

are not well understood. To varying degrees, the oversight review

groups are performing adequately; however, some important findings

Overall

were not acted on effectively by licensee management.

licensee performance in this area was effective and well oriented

toward nuclear safety.

Conclusion

Category 2

Recommendation

Discuss at the SALP meeting (1) licensee actions to im-

~

Licensee:

prove the technical support area, (2) measures to instill in all

workers appropriate attention to operations phase administrative con-

trols, and (3) licensee measures to ensure optimal benefits from

oversight group findings.

PAT I should review extensively the licensee's independent

NRC:

technical and safety review process; by PAT II, an assessment

should be made of the licensee's plant safety review processes; in

particular, the reliance on individual. reviews as contrasted with

interdisciplinary committee reviews.

-

_

,

_

. - _ _ _ _ _ _ _ _ _ _ _ _ _ -

_ _

.

-.

_

14

-

k.

.

_

_ . . -

.

-

--

E.

Radiological- Control s (244 hours0.00282 days 0.0678 hours 4.034392e-4 weeks 9.2842e-5 months , 6%)

-

Analysis

The licensee's radiation protection program continued to be well de-

fined by clear policies and directives. Startup inspections indicat-

,

ed that the licensee satisfactorily implemented the radiation

An

protection program in accordance with reg 01atory requirements.

'

adequate staff.was available to carry out the program, and the per-

sonnel involved were well qualified and capable of performing satis-

A formalized-

factorily in their assigned areas of responsibility.

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 quality assurance department has a lead monitor in this area

The radiation

for oversight of radiological control activities.

protection management staff takes the initiative in improving and

For example,

enhancing radiological control practices and procedures.

(1) the licensee's radiological staff initiated the investigation of

noble gas migration pathways in the auxiliary and fuel handling build-

ings, and consequently effected corrective measures to better control

airborne activity in the facility; (2) both health physics-field

operations and radiological engineering groups perform frequent

planned inspections and audits of radiologically controlled areas,

work activities, policies and procedures to assure quality perform-

ance; and (3).all anomalous occurrences that have the potential to

affect exposures to workers or the general public are aggressively

reviewed and evaluated to ascertain causal factors, corrective

measures, and dose effects. Additionally, radiological controls

awareness meetings are held monthly by the radiation protection,

maintenance, and operation departments to exchange information and

resolve concerns pertaining to radiological work, practices, and pol-

These meetings are also attended by representatives from the

icies.

bargaining unit, the Vice. President and Director of TMI-1, and con-

cerned workers.

The licensee generally exhibits good radiological-control practices

and they implement a very thorough radiation worker training program

in'an effort to ensure that radiation workers are aware of radiolog-

ical safety procedures and are' able to implement them competently.

The TMI-I Restart Staff noted that the licensee consistently demon-

strated a strong commitment to ALARA. During radiological work

performed in this assessment period, the licensee used ALARA

engineering practices, job planning, and worker training to reduce

j

personnel exposure.

_

1

.

_

__

_

-

15

i-

-

.

-

a

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.

In summary, the licensee was able to demonstrate that program ele-

ments continued to be effectively implemented during power operations,

and the licensee acequately trained and qualified personnel responsi-

ble for implementation of the radiological control program. Implemen-

tation problems were not due to programmatic weaknesses but were

related to poor individual worker performance or inadequate support

from other departments such as operations or engineering. The

licensee's program in this area is technically sound.

Conclusion

Category 1

Recommendations

None

i

l

__

_

_ _ _ -

-

- -_

'l*

. .

..

.

. .e

16

'

-

.

..

t

.

'

f

~

C.

Maintinance ~(288 hours0.00333 days 0.08 hours 4.761905e-4 weeks 1.09584e-4 months , 75) 1" ~

-

.

_.

_

.

_

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 reduced 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 experience in the I&C area caused

minor operational problems which resulted in delays in retests until

'

supervision arrived on site.

The electrical and mechanical main-

tenance experience remained at a high level. The collective know-

ledge of the maintenance department was sufficient to resolve equip-

ment problems.

In addition, maintenance personnel appeared to be

highly motivated and supportive of management.

Administrative controls in the area are adequate and properly imple-

mented along with maintenance procedures. The staff identified a

^

minor drawing control violation with respect to posted drawings in-

side control room cabinets.

This was uncharacteristic of the

licensee's drawing control program. Another instance was noted where

individuals failed to follow a maintenance procedure and this result-

ed in the loss of a safety-related electrical bus. The individuals

,

'

involved were disciplined for failing to cooperate in the licensee's

i

review of this event.

I&C personnel were involved to a limited ex-

tent in the procedure implementation problems addressed in other

sections.

.

,

j

During this assessment period, several major safety-related systems

were reviewed closely by inspectors to determine overall reliability

l

'

and operability of the equipment.

Emphasis was placed on preventive,

as well as~ corrective maintenance by management in response to plant

restart.

Preventive maintenance procedures appropriately reflected

,

vendor technical manual recommendations. Safety-related eauf pment was

<

found to be in good material condition. Machinery history and mainte-

nance records reflected proper documentation (consistent with restart

hearing board requirements) and this resulted in development of a

useful historical data base on plant equipme.nt.

Records and field

observations reflected the involvement of the QA department in as-

suring operability of safety-related equipment.

.

. - - .

-

- - .

v.

-

- . -

- - - . - - . - - - _ . - - - - , .

, - -

_ _ _

_ _ _ ,

.

17

"

.; .'

-

h

-

No instances were noted of inoperability or poor testing because of

,!-

-

_

maintenance procedures. However, certain maintenance procedures

-

'I

lacked specificity and clarity associated with the recording and/or

'

evaluation of as-found conditions. This lack of clarity has forced

maintenance personnel, independent of plant engineering, to evaluate

!

and determine the operability of equipment in the field with limited

~

guidance. This has pointed out a need for enhanced procedure review

and approval and better technical support on the evaluation of

~

as-found conditions.

p w .e

Maintenance personnel, in particular, and other groups of personnel

doing work in safety-related spaces, were somewhat insensitive to the

change to an operating mode.

In certain instances, personnel contin-

ued their working habits as though the plant was in a shutdown condi-

-

tion. As a result, a violation occurred on unsecured scaffolding

'

that in a seismic event may have jeopardized the ability of the die-

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 De 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.

Housekeeping and fire protection measures remained consistent with

the previous high standards implemented during the long shutdown.

Extensive use of absorbent material to collect oil drippings was used

and contaminated drainage was directed to floor drains using tygon

tubing. However, certain areas of the turbine building were not re-

flective of those cleanliness standards that were applied to safety-

related areas. No fire hazards were created in the turbine building;

by the si.J of the period, conditions improved substantially in that

}

building.

Sufficient technical support was provided to maintenance and good

j

communication existed between this department and plant engineering.

There was consistent evidence of engineering evaluations in mainte-

i

nance packages. There was, however, incomplete support for " Fur-

,

.

manite" repair to leaking flanges and valves. The licensee. started

work during the 40% trip outage without considering the stress

induced by this process on the flange bolts. Another example was the

,

poor control of the amount of Furmanite for repeat injections evi-

denced during the full power trip outage. As a result, an OTSG level

1

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

j

by the NRC staff occurred. Upon complete review of these problems,

no unreviewed safety questions were identified by the licensee.

These examples reflect a need for licensee management to assure a

more inquisitive evaluation of plant problems.

.

..

_

. . _ . _ _

__

, . , . . . _

_

,

_ . _ .

.

I[ ,

. -

.

_

_ _ .

._

_

~

18

s' ;

-

.

-

.

-

.

Overall, the maintenance program is properly established, imp.1[ement _

__

~

.

ed, and adequately staffed. Management involvement at all levels is'

~'

evident. Equipment and plant material condition are wel1 maintained

and in a condition that supported unit startup. The QA department is

5

Personnel attitude toward work in the

very active in this area.

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

-

m

-

. _ _ .

.

._ . _ . .

-

- -

.

. _

-

. - . _ _ _

l'

,

i

.

- -

i

.

,

- -.

-

.

_ -

19

)

i

..

-

[

,

.

'

-

D'.__3ufveillance . Testing'. (252 hours0.00292 days 0.07 hours 4.166667e-4 weeks 9.5886e-5 months , M)

I

>

l

-

Analysis

,r

During this inspection there was a high level of NRC inspection cov-

erage in this area as evidenced by inspection report documentation of

all or portions of over sixty surveillance tests. This included all

types of surveillances, including maintenance, operations, radiolog-

,

i

ical controls, and instrument and control surveillance.

In addition,

i

the data and calculations of numerous other surveillance tests were

i

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

Accordingly, surveillance tests were effectively integrated

program.

.

with routine plant operations and well coordinated with operations

department activities. Surveillance procedures, with a few minor

exceptions, were properly implemented. Surveillance tests required

i

l

by the technical specifications were conducted at the specified fre-

'

l

quency with one exception. A fire surveillance was missed for sever-

al days due to the improper issuance of a procedure change. This-

violation of requirements was considered minor.

During this inspection period, NRC staff performed an extensive re-

view of safety-related equipment operability regarding the following

)

,

components: the makeup pumps, decay heat pumps, and the diesel gen-

The review included operating procedures, technical speci-

)

fication compliance, inservice testing, preventive maintenance,

erators.

i

!

1

maintenance history, and surveillance testing. Applicable surveil-

lance tests were found to be technically adequate in that they met

!

l

all applicable NRC requirements. Surveillance test procedures, along

with. maintenance procedures and post-maintenance testing, provided

adequate assurance that the selected safety-related components were

i

1

operable when called upon.

Surveillance procedures were properly followed. Tests were performed

in a deliberate manner ensuring that each step was completed prior to

proceeding to the next step.

Records were well kept. For a surveillance test of frequency of

ninety days or longer, a hard copy record of the last completed test

was maintained in the control ~ room. Once a test was completed, the

2

'

newer test was placed in the file and the older test was sent to

plant records for microfilming. This system enabled technicians or

operators good access to the most recently completed tests, .if neces-

In addition, extensive test records were reviewed by NRC and

'

sary.

l

found to be complete with one exception, discussed below.

.

-

,_..,_--y

-

. _ - , . ~ , - . . , , . . - - _ _ , _ _ _ - -

. - . .

-

.r..

r

.

-

20

1

_

.

h

Of particular concern during this period were the circumstances that

--

developed during and after'a routine surveillance test of the

pressurizer power operated relief valve (PORV). The issues of con-

r

{

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 documen tion used to substantiate

the shift supervisor's determination

ability of the PORV.

There was prompt involvement by senior management in the retest when

operability questions arose. However, the NRC staff's early involve-

ment in this process led to discovery of the exception and deficiency

sheets that had been thrown away and the identification of the poor

instructions for handling exceptions and deficiencies. This records

handling problem was considered uncharacteristic of the licensee's

records management program.

It did point out a need for additional

attention to detail on the part of licensee personnel in handling

these particular records.

Further, the licensee's review and approv-

al process could have developed better instructions for the handling

of test problems.

Although other mistakes were made by personnel, in general, licensee

supervision caught them before any adverse condition resulted. A

number of examples were noted in which supervision or senior person-

nel corrected errors made by junior personnel. Tnis was especially

evident in the I&C area. Because of supervisory presence, corrective

actions were appropriate to satisfactorily complete tests and avoid

challenges to safety systems.

Staffing was ample in this area along with good interdepartment in-

terfacing. A specially assigned staff representing the maintenance

and operations department assured overall good coordination of sur-

veillance test implementation and records. Personnel, in general,

were qualified to perform surveillances but as noted above, some in-

experience was evidenced by a few individuals.

None of the unplanned

reactor trips during this period were caused by surveillance tests.

Overall, the licensee has a strong surveillance program. Management

and 0A department involvement in this area is evident. The problems

observed were few in number and did not adversely affect plant safe-

ty.

The licensee safely conducts surveillance tests during plant

operations.

Conclusion

Category 1

Recommendations

None

-

.

_ _ _ .

l

- -

..

.-

_

21

.,.

-

..

.

'

l

E.

Startup Testing (-56F hours,14%)

~_ ~~~

_

_ . -

_

.

-

.

_

5

4

During this SALP period, the licensee performed an extensive power

escalation test program over a three-month period. This program was

successfully completed with only minor performance problems noted.

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 ergineers, test engineers, and supporting personnel

.

from the headquarters safety analysis group, was very good. Opera-

I

tors always remained in control of the plant during special and in-

tensive test periods. The reactor engineering group, which performed

the physic testing, was well prepared in this aspect of the startup

The licensee assured that ample supporting specialists

test program.

i

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 intorfacing

with the licansed operators, this resulted in tests being completed

<

in an effective and well-controlled manner. Although reactor engi-

1

neers initially were aggressive in their requests to operators to

establish plant test conditions, plant operators were always in

control of plant operations.

l

The 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 testing at 100 percent power. Except for the first.part of the

natural circulation test, plant testing was well-coordinated with

good interface with the plant operators. Data were properly taken,

data stations were adequately manned, and data reduction was per-

formed properly. Test exceptions and deficiencies (E&Ds) were pro-

perly resolved and all data along with test problems were reviewed by

the Test Acceptance Group in formal meetings conducted periodically

during each test phase.

In spite of some minor delays during the

program, all testing was completed within the scheduled time frame of

the test program.

The extensive pre-test training of reactor engineering and test engi-

neering personnel was evident in the overall lack of personnel prob-

lems during test performance. Test briefings for major evolutions

i

were thorough and extensive.

Problems noted during earlier tests,

where applicable, were factored into briefings for later tests.

Quality assurance involvement in startup testing was extensive in

.

v-mw-

'--v'

-

7'

7--

_

_______

l'

-

1

l

,.

-.

22

r,

-

~

-

'

.;

--

-

. that QA monitors were on shift for all testing.

In addition, QA had

I

-

!

prepared a detailed test monitoring plan and documentation of QA mon-

-

?

itoring activities was comprehensive.

Licensee management attention

and involvement were very evident in that top management was present

and witnessed major test evolutions and power escalations.

Generally, in handling technical problems, licensee management did

exhibit conservatism. During the initial startup, licensee manage-

ment ordered the reactor to be stabilized high in .the source range

until one of the two instrument channels for the intermediate range

neutron power was fixed. While performing an all-rods-out boron mea-

surement test during zero power physics testing, too much boron was

added to the reactor causing suberiticality. This " boron overshoot"

condition was promptly noted and the reactor engineers and operators

displayed a cautious approach in the boron dilution needed to correct

the problem. The licensee was responsive to staff concerns on the

emergency feedwater system turbine relief valve inadvertent actuation

problem and to the interaction problem between the steam generator

safety valves and the turbine bypass valves. Adequate interim

corrective action in terms of procedural guidance was provided to the

operators for both of these technical problems. Overall, licensee

management competently resolved their technical problems.

Based on staff review, the startup test procedures were comprehensive

and accomplished the desired test objectives with some minor problems

as discussed below.

Procedures were followed completely during the

All test data reviewed by the NRC staff were correct, and E&Ds

test.

were properly resolved.

Notwithstanding the positive aspects of the test program, some

problems with procedures and personnel were observed. During the

first part of natural circulation testing, test engineers did not

appear to be fully organized. This problem was recognized by manage-

ment and was quickly corrected. The test could have been better

planned to instruct the operators how to recover from the unique plant

conditions. As a result, at initial restoration of forced circulation

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

the conclusion of the test program followin'g the reactor trip at 88

percent power, one further test deficiency was noted in that the

reactor trip test failed to document the reset function of the let-

down isolation valve MU-V3 following the reactor trip. The adequacy

of MU-V3 to open af ter a trip was subsequently demonstrated through a

separate retest after NRC staff prodding on the issue.

In summary, the licensee performed very well during the TMI-1 restart

startup testing program. Aggressive management attention and involve-

ment at the upper and middle management levels contributed to the

i-

l

_

.

_

__

23

k-

_

-

.

'

.

I

_

_..

effective program. The startup program was effective-in identifying ---

equipmer.t problems, especially from the viewpoint of integrated

.

system operations. The test program was thoroughly planned, accom-

i

t

plished on a realistic schedule, and provided ample time for operator

j

training and familiarization.

Licensee initiatives having generic

B&W applicability in this area were noteworthy. Although they

,

constituted unique tests, more comprehensive reviews should have

been considered by the licensee before implementation.

<

Conclusion

Category 1

Reccmmendations

None

,,

I.

a

.

M

__

.- _

'

<

.

24

,:1.

.

l

.

-

k

- - F.

Training ar.ddual'ification _Ef fectiveness (NA)

,S

Analysis

.

The various aspects of this functional area have been considered and

discussed as an integral part of the other functional areas and the

respective inspection hours have been incorporated into the respec-

tive functional areas. Consequently, this discussion is a synopsis

of the assessments conducted in other areas. Training effectiveness

is measured primarily by the obser'ved performance of licensee per-

sonnel and, to a lesser degree, as a review of program adequacy.

This discussion addresses three principal areas:

licensed operator

training, non-licensed staff training, and the status of INPO

training accreditation.

The training department was staffed with knowledgeable and experi-

enced personnel. The lesson plans, specialized manuals and courses,

hands-on experience, and/or extensive use of simulator and basic

principles simulator training provided meaningful and practical

training not only to licensed operators but also to other operator

I

technical personnel. This was evident in the performance of new

1

candidates for operator licenses. All candidates for licenses or

instructor certifications passed. They included four SR0 candidates,

,

'

one RO candidate (on retake), and one instruction certification can-

didate.

As noted in the plant operations section, observations of licensed

operator personnel by shift-inspectors produced a good deal of infor-

mation relative to their level of knowledge and performance skills.

The results of that review were favorable. The special interviews and

discussions on shift confirmed a high level of knowledge of facility

design with only minor weaknesses observed. Operators were well pre-

pared for restart and demonstrated especially strong skills in manip-

ulating the integrated control system in the manual mode. The

training for the non-licensed staff consisted of both formal and

!

1

on-the-job training. Based on NRC observations, this program was

also effective in producing performance-oriented personnel.similar to

the licensed operator program. During the implementation of work

activities, in general, non-licensed personnel were appropriately

,

knowledgeable in the ~ requirements of the' procedures and plant design.

Experienced personnel provided adequate guidance to less experienced

personnel.

4

No plant trips occurred due to personnel error. However, inspectors

saw a persistent problem with workers in various plant areas having

,

I

the potential to cause a trip or a challenge to a safety-related

system.

Personnel (licensed operators included) were also involved

in the problem with the proper implementation of administrative

controls for procedure implementation. There seemed to be a dis-

connect between the wel'-stated management policies in these areas

and the understanding of tho,e policies by certain individuals.

8

.

25

.

h-

I_-

Even with the corrective action initiated before the end of the power

-

!

escalation program, licensee management had not completely reached

!

all plant workers and corrective action is not yet complete.

The licensee received training program accreditation from INPO in the

following 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

'

support and commitment of management. The QA department is actively

involved in training.

In general, personnel are knowledgeable of

work and procedural requirements, and conduct activities with care.

When faced with problems, personnel take conservative measures and

seek help.

Conclusion

Category I (based on functional areas addressed)

Recommendations

None

l

.

___

__

.

-

_ _

3., . . -

1

'

-

26

l

.,

'

-

G.

Assurance of Quility (NA)

-

--

-

---

.:

..

-

The various aspects of quality assurance program requirements have

been considered and discussed as an integral part of each functional

-

area and the respective inspection hours are included in each one.

,

Consequently, this discussion is a synopsis of the assessments

conducted in those areas.

The quality assurance department continued their aggressive involve-

ment in oversight activities. -This was reflected in their unique

three levels of review along with a substantial resource initiative

--24-hour QA shift monitors.

Licensee management continued their

J

orientation in staffing the department with experienced personnel

along with providing career enhancement positions for licensed (or

formerly licensed) THI-1 operators. This had the added benefit for

licensee management of enhancing the operational expertise of the QA

department to fulfill its responsibilities in the oversight of

operations.

r

There was a definite QA presence and involvement in the various fac-

ett of field activities.

The monitoring level of review was effective

in identifying the procecure implementation problems later noted by

the NRC staff. As a result of successful monitoring, the audit group

more effectively used their time in reviewing programs and program

iraplementation. However, licensee management apparently did not

effectively respond to the QA department for the procedure implemen-

tation problem, which was highlighted in the QA department's annual

effectiveness review.

In summary, there was management and quality assurance (QA) depart-

ment presence and involvement in all facets of activities at the site.

Licensee management may need to provide additional attention to the

QA department's effectiveness reviews.

Conclusion

Category 1 (based on the functional areas addressed)

l

~

_

_ _ _

!

-

. -

.,

--

-

.

27

+

.

-

.

~

i

_

l

--

__

Recommendatiorm

.

-

I

Licensee: Non'e

NRC: PAT look at the effectiveness of the QA review process.

m

W

9

_ - -

_

.

?

I"

.

_

28

'

E-

-

.

-

'

V.

Supoorting Data and Summaries

~~

--

-

A.

Investigations and Allegations Review

There are no open investigations for THI-1. The investigation on 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.

B.

Escalated Enforcement Actions

None

C.

Management Conferences

9

None

D.

Licensee Event Reports

Only three licensee event reports were submitted during this period.

They are listed below instead of being tabulated in a separate table.

LER 85-002, dated October 3, 1985, for the manual reactor trip

--

(from hot shutdown condition) that occurred on September 7,

1985, due to operator action in response to a fire in the rod

control system. The root cause was an equipment / component mal-

function (re: PLANT OPERATIONS AREA).

LER 85-003, dated December 31, 1985, for the reactor trip from

--

75 percent power that occurred on December 1,1985, due to a

proximate cause'of high pressure in the RCS. The root cause was

an equipment / component malfurction with a main generator relay

that caused a main turbine rejection which caused the transient

in the RCS (re:

PLANT OPERATIONS AREA).

--

LER 85-004, dated December 26, 1985, for inoperable fire barri-

ers found on November 26, 1985, to a m.akeup pump cubicle without

a fire watch during modification work. This was due to person-

nel error (re:

PLANT OPERATION! 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.

i-i

- -

.

. . . -

-

29

-

)

__i* .-

-_

.

V.

-

r

-

LER 85-004_was indicative nf the worker in the spaces.probl_em identi-

~

!

fied in the maintenance area.

-

~

-

'

I*

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, 1985, Manual

PLANNED in accordance with

startup test procedures

--

October 21, 1985, Loss of

PLANNED in accordance with

Feedwater

power escalation procedures

Jar.uary 2,1986, Turbine Trip

PLANNED in accordance with

--

p'ower escalation procedures

F.

planned / Unplanned Releases

Table 6 is a summary c the more significant unplanned releases for

the period, along with a summary of the routine releases from the

plant on a montniy basis.

No regula*.ory limits were violated.

.

-

,

-

'

T1-1

-

j.

-

,

!

f_

__

-

TABLE 1

i

INSPECTION REPORT ACTIVITIES

TMI-1 NUCLEAR GENERATING STATION

AREAS

REPORT NO./ PERIOD

AREA INSPECTED

INSPECTOR TYPE

HOURS

INSPECTED

85-22

SHIFT

683

Power Operations

9/16/85-10/11/85

RESIDENT / PROJECT

Startup Testing

STARTUP TESTING

ENGINEERING SPECIALIST

85-24

SHIFT

369

Power Operations

10/11-18/85

RESIDENT / PROJECT

S.tartup Testing

STARTUP TEST

Licensed Operator

RADIATION SPECIALIST

Training

Radiological

Effluent Control

85-25

SHIFT

352

Plant Operations

10/18-25/85

RESIDENT / PROJECT

Startup Testing

STARTUP TEST

,

f

85-26

SHIFT

501

Plant Operations

10/25-11/12/85

RESIDENT / PROJECT

Startup Testing

RADIATION SPECIALIST

Radiological

Effluent Control

!

85-27

SHIFT

603

Plant Operations

11/12-27/85

RESIDENT / PROJECT

Startup Testing

STARTUP TESTING

Radwaste Management

85-28

SHIFT

540

Plant Operations

11/27-12/13/85

RESIDENT / PROJECT

Startup Testing

STARTUP TEST

Radiological

RADIATION SPECIALIST

Effluent Control

85-30

SHIFT

888

Plant Operations

12/13/85-1/10/86

RESIDENT / PROJECT

Startup Testing

STARTUP TEST

Radiation Protec-

RADIATION SPECIALIST

tion

ENGINEERING SPECIALIST

.

--

.

-

._

-.

_

.

~

j!'

'Y.

,.

.} r

-

--

-

.

-

$6 ~

T2-1

i.

,

_

,

.

~

~~~

~ TABLE 2

-

--

__

.

INSPECTION HOURS SUMMARY (9/16/85 - 1/10/86)

4

TMI-1 NUCLEAR GENERATOR STATION

HOURS

% OF TIME

i

974

25

Plant Operations

(Shift Inspection Hours)

1617

41

Radiological Controls

244

6

Maintenance

288

7

i

Surveillance Testing

252

7

Startup Testing

561

14

Training and Qualification Effectiveness

(included in above)

i

Assurance of Quality

(included in above)

Total

3936

100

.

m

,-.

,

v.

-., - . .

.-

i

-

. .

<

.

T3-1

'

>

EL

.

-

- . . '

-

.

P-

--

--__

-

-.

-

.

TABLE 3

-

e

ENFORCEMENT SUMMARY (9/16/85 - 1/10/86)

TMI-1 NUCLEAR GENERATING STATION

A.

Number and Severity Level of Violations

-

-

-

6

1

Deviations

-

Total

7

B.

Violations vs. Functional Area

Functional Area

Severity Levels

I

II

III

IV

V

Dev Total

Plant Operations

4

Radiological Controls

Ma'ntenance

1

2

Surveillance Testing

1

Startup Testing

Training and Qualification

Effectiveness

Assurance of Quality

Totals

6

1.

7

.

--~y

w

-

j.

.

-

./-

T4-1

['-

.

[

~

TABLE 4

-

ENFORCEMENT DATA

TMI-1 NUCLEAR GENERATING STATION

Inspection

!everity

Functional

Report No.

Date

Level

Area

Violation

85-22

9/16-10/11/85

IV

Maintenance

Failure to

properly control

scaffolding in

safety-related

areas

85-25

10/18-25/85

V

Maintenance

Failure to

properly control

drawings inside

control room elec-

trical cabinets

85-27

11/12-27/85

IV

Plant

Failure to

Operations

establish or

properly change

procedures for

safety-related

activities

85-27

11/12-27/85

IV

Plant

Failure to

Operations

completely review

for adequacy proce-

dures for indepen-

dent verification

of safety-related

+

activities

85-27

11/12-27/85

IV

Plant

Failure to

Operations

properly implement

technical specifi-

cations and related

administrative con-

trol for~1ndepen-

dent onsite safety

review group

(IOSRG) activities

.

._

-

.. _

i

!

^

-

(

e

- -

i

'

1

M.

e

"

- _

-

.

'

!

.

{

t

J=

-

? *. .

.

-

i

-

_ _ _

l

~

.

N

me

-

M""

pN,

e

w

i

,

e

- -

_

.-

..

.

.-

t

_ _

?.

_

T4-2

o

%:

.

_

~

_

-

.

TABLE 4 (Continued)

=

-

!

Inspection

Sevarity

Functional

Report No.

Date

Level

Area

Violation

85-27

11/12-27/85

IV

Security

Failure to

(Plant

properly implement

l

Operations)

security personnel

badge identifica-

tion control

'

measures

,

85-30

12/13/85

IV

Fire

Failure to

.i

Protection

properly inspect

,

(Surveillance) a fire door on

the specified

frequency

,

j

1

l

'

!

1

i

l

. _ _ _ _

-.-

-

..

. . . .

-

-.

- - _ .

- . _ .

_

-

_ _ _ _ - - .

_ _ _ _ _

-

.

f'

.

--

-.

.

T5-1

-

l *<

.

-

.

~

1

-

_..

TABLE-5

--

_ _ _

UNPLANNED REACTOR TRIPS

AND

SHUTOOWNS

-

4

Unolanned 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 drift

l

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

-

.

- , -

- . _-

-,

.-.

,

i

-

- -

.

T6-1

'T '

__

_

,

.

-

!

.

!

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 (C1) Ouration

Limit, Gamma

10/21/85

1.07E-6

10 sec

3.8 E-8

at 40%

Relief Valves

(MSRV)

10/28/85

Makeup Pump

..ation Vent

0.7

42 min

0.0015

(SV)

11/2/86

Reactor

1.05

75 min

0.027

Coolant

Evaporator

11/19-

1.6 E-7

5 sec

3.48 E-0

20/85

Valve Testing

.

12/1/85

7.32 E-6

7 min

1.5 E-7

at 75%

12/17/85

Waste Gas

1.4

54 min

0.001

Compressor

12/30/85

Makeup Pump