Text

Insp Repts 50-219/88-27 & 50-289/88-25 on 880913-19.No Violations or Deviations Noted.Major Areas Inspected: Engineering Support of Plants by Corporate Technical Functions Organization
	ML20207M161
Person / Time
Site:	Oyster Creek, 05000000, Crane
Issue date:	10/05/1988
From:	Chaudhary S, Strosnider J, Winters R; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20207M135	List: ML20207M161;
References
	50-219-88-27, 50-289-88-25, NUDOCS 8810180141
	Download: ML20207M161 (15)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report Nos.

50-219/88-27

50 289/88-25

docket No.

50-219

50-289

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License No.

OPR-16

DPR-50

Licensee:

GPU Nuclear Corpor: tion

Parsippany, New Jersey

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Facility Name: Oyster Creek Nuclear Generating Station

Three Mile Island Nuclear Generating Statica - Unit

Inspection At: Parsippany, New Jersey

Inspection Dates: September 13 - 19, 1988

Inspectors:

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3. Chaudhary, Senior Reactor Engineer, MPS,

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EB, ORS, Region I

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, W. Winters, Reactor Engineer, MPS, EB,

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DRS Region I

Approved by:

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Strosnider, Chief, Materials a Processes

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ection, Engineering Branch, DRS, RI

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Inspection Summary: Routine unannourced inspection on September 13-19, 1988

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(Report Nos. 50-219/88-27 and 50-289/88-25)

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Areas Inspected: The inspection covered engineering support of the Oyster

Creek and Three Mile Island Unit 1 operating plants by the co ; orate Technical

Functions Organization

Results: No violations or deviations were identified.

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DETAILS

1.0 Persons Con + acted

GPU Nuclear Corporation

G. Bond, Director, Systems Engineering

E. Wallace, Engineering Services Director

A. Rone, Plant Engineering Director

M. Sanford, Component and Structures Director

D. Croneberger. Director, Engineering Projects

D. Distel, PWR Licensing Engineer

M. Laggart, BWR Licensing Engineer

G. Capodanno, Director, Engineering and Design

J. Flynn, Manager, Engineering Standards

D. Snivas, Engineering Data Configuration Centrol Manager

Denotes t..cse attending the exit meeting.

The inspectors also contacted other administrative and technical

personnel during the inspection.

2.0 Objectives

The objective of the inspection was to assess the adequacy of the

licensee's program for engineering support to plant operations including

design and configuration control, interfaces with other internal and

external organizations, management support, staffing levels and

experience, training, and responses to NRC requirements and requests.

3.0 Licensee Commitments

The licensee's commitments and documents reviewed are listed in

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Attachment 'A'

to this report.

4.0 Technical Functions Division - Overview

Management Support

The inspectors observed that the licensee's engineering operations are

grouped in a division called Technical Functions.

The division is headed

by a Vice President.

Technical Functions is comprised of five

departments, each headed by a director, with responsibilities to provide

technical support.

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The NRC documented in the previous SALP (Report 50-219/86-99) a number of

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concerns regarding the engineering support provided to GPU's operating

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plants by the Technical Functions Division. In response to the NRC's

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observations, the licensee initiated a program of self assessment to

determine the cause and extent of the NRC's identified concerns, and to

evaluate, plan, and implement any corrective actions necessary.

The

licensee's self assessment confirmed that there are some programmatic

inadequacies which required corrective action.

Based on the findings of

the self assessment the licensee developed an action plan to correct the

identified problems. Major objectives of this action plan are to (1)

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improve response to engineering assistance requests from the plant and

(2) better plan and control modification, design, and installation processes.

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To accomplish these objectives, the licensee is emphasizing improved long

range planning and better problem definition and has reemphasized the use

of formal planning tools and documentation to enhance the modification

process.

With regard to configuration management of the plants, the licensee is

developing an overall GPUN Configuration Management Model that will

document the current process for engineering configuration management

(ECM) and implement a plan to improve the ECM program.

The licensee has budgeted for improving design basis documents,

conducting safety system functional inspections, improving as-built

drawings to reflect plant conditions, and establishing a conf guration

management council to identify further improvements in the ECM program.

The licensee strongly supports participation .n industry, owners groups,

and professional societies.

This was evident by the number of people

representing GPUN on the owners and other industry groups, and financial

support to INPO.

GPUN has funded an employee who was elected chairman of

the B&W Owners Group.

A scoring system has been established by Technical Functions Division to

assign priorities to tasks.

This scoring system is based on four

categories with a point system within each category.

The categories are:

regulations / requirements, safety, availability, and economics.

Those

tasks scoring highest are placed in the five year plan.

The inspectors noted that the licensee has an established program to

trend and analyze generic technical information and plant parameters.

These analyses and evaluations are documented in topical reports.

The

inspectors reviewed a sample of topical reports and found them to be

comprehensive, indepth analyses of the subject matters covered.

In addition to the management reports generated by the Engineering

Service Department, an interdepartmental management meeting is held

biweekly.

This meeting is intended to discuss priorities, backlog, any

special problems, and to resolve any identified or potential problems

within the departments.

5.0. Organization

Details of the Review

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The inspectors reviewed the licensee's current engineering organization

and held discuss;ons with management personnel to determine the structure

and controls established in the department.

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The procedural control of work in the engineering organization was

reviewed to assess the effectiveness of engineering procedures and

control of design interfaces. The procedures were reviewed for clarity

of requirements, and levels of authority and responsibility assigned to

various groups and positions.

The inspectors also reviewed selected work by different engineering

groups to assess the technical adequacy, completeness and complexity of

the engineering analy:*s, design, and evaluations. Specific attention

was paid to assess tne gaality of engineering output to support plant

operations, configuration control and enhancement of plant safety in

general.

Observations

Engineering Services:

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This Department is organized to provide support services, such as,

drawing and document control, and computer programming for

management controls, design and drafting.

The departmint also

prepares and coordinates engineering and licensing procedures and

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standards and is responsible for planning and scheduling of

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modifications and outage activities.

Engineering and Design:

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This Department is organized on the basis of classical engineering

disciplines. The Department provides engineering and design

services to the operating plants for modification, systems

evaluation, regulatory requirements, and maintenance.

The

assignments to this Department are channeled through the plant, or

project engineering. When in-house engineering expertise or

staffing is not available, the Director of this Department is

authorized to supplement the department resources by contracting to

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appropriate consultants.

The Department investigates plant system

and equipment failures and is responsible for the evaluation of the

technical performance of plant hardware, and provides chemistry

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requirements to fossil and nuclear plants.

3ystems Engineering:

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This Department is responsible for providing systems engineering

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support to the operating plants (0yster Creek, Three Mile id:nd -

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Unit 1).

The responsibilities include fuel engineering, plant

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systems performance, risk analysis, human f actors engineering,

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radiological engineering, and plant dynamics and simulation.

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This Department is responsible for maintaining software and software

configuration control for the training simulators, staff,

operations, and plant process computers.

It also avaluates safety

significance and operating experience from NRC Notices and Bulletins

and other industry and professional reports and recommends

appropriate action.

In addition, the Department provides Shift k ehnical Advisors (STA)

to the operating plants to assure independent oversight and

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engineering perspective at the plants.

STAS independently report

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daily the plant status and their evaluations to the Director of the

Department.

Engineering Projects:

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The Department of Engineering Projects is assigned the

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responsibility to manage and assure completion of physical plant

modifications, additions, or major non-routine repairs; coordinate

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Technical Function Civision personnel and activities on the plant

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sites; and provide approval and release of detailed engineering for

all Technical Functions sponsored projects.

In general, this

department functions as project engineers in organizing, planning,

and coordinating all engineering efforts for projects for which GPUN

performs the design engineering.

It also represents the licensee on

the Babcock and Wilcox and BWR Owners Groups.

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Startup and Test:

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This Department is responsible for developing and maintaining test

plans, implementing procedures, test documentation, coordinating

technical acceptance nf testing; and providing testability inputs to

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Design Engineering for plant modifications.

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To asses the adequacy, complexity and technical depth of the Technical

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Functions Division work the inspectors reviewed a sample of work from

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each departtrent.

The documents were reviewed for procedural conformance,

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depth and breath of technical analysis and validity of any

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recommendations made, or conclusions derived from the analysis under

consideration.

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The inspectors also discussed the technical bases, analytical techniques,

and the validity of the conclusions with cognizant engineers and

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trana g e r s .

The inspectors had extensive discussions with the Director of Engineering

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Services Department regarding records management and document control

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practices; upgrading and revising of drawings including, revision

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priorities, and any backlog of work in these areas.

Findings

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The inspectors determined that the Technical Functions Division is

appropriately organized to provide adequate technical support to the

operating plants.

This observation was based on the inspectors review of

engineering analyses, Topical Reports, Technical Data Reports and

Engineering Calculations, Licensing Action Item Reports, Trend and

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Performance Analysis Reports, and Cycle 12 Reload Design and Plant Safety

Analysis.

6.0 Staffing and Workload

Details of the Review

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In conjunction with the review of the organir,ation the inspectors

exarnined the staffing and current workload in each department.

The

results of examination for each department are as follows:

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Engineering Services:

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The Engineering Servi;es Department has 28 professional employees

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with adequate administrative support staff.

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The revision of drawings are prioritized on the basis of their

intended use.

There are four levels of priority assigned to various

drawings.

Priority 1 is assigned to the drawings that are necessary

for plant operational safety. A tott.1 of 300 drawings are assigned

priority 1 for Oyster Creek. Out of these 300 drawings, 180 drawings

are maintained in the control room for operations.

The licensee

informed the inspector that in the area of drawing update and revision,

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there were approximately 21 priority 1 (other than control room)

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drawings awaiting revisions for Oyster Creek.

Fifteen of these

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drawings were overdue for revision in accordance with the licensee's

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procedural requirement of thirty day limit.

For Three Mile Island

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Unit 1 there was essentially no drawings overdue.

The inspectors observed that the department was heavily involved in

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developing the long range plans of the Technical Functions Division

for the operating plants to increase the effectiveness of resources,

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and outage and modification planning.

The objective of the long

range plan is to enhance plant safety and operability. The

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effectiveness of this long range planning was evidenced by the

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TMI-7R outage being completed four days ahead of schedule.

Also for

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Oyster Creek, the 12R outage engineering was essentially complete

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prior to the start of the outage.

This was in sharp contrast with

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the licensee's previous practice of engineering modifications while

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the work progressed during outages.

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The computer assisted records and information retrieval system

(CARIRS) is a corporate record managen ent system.

It has many

databases used by various corporate entities.

The Technical

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Functions Division of GPtn controls and maintains six databases

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applicable to the two operating nuclear facilities.

These six

databases are:

one database for each plant designated an active database

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containing the indices of currently applicable documents.

one database for each plant is designated archival which

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contains indices of superseded and historical information.

one database is maintained for each plant simulator.

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The input to these databases is controlled by the Engineering

Services group of the Technical Functions Division.

The output of

the CARIRS system is available throughout the corporation on an

authorized access basis. The access is also controlled by the

Engineering Services Department.

The inspectors observed that the inputs to the database is designea

to provide information regarding the authenticity, status, and

availability of selected documents and the cross references

documents affecting the subject entry.

This system is also used in

the configuration control of the plants, and establishing design

bases of equipment and plant systems.

In addition, engineering uses

the sy: tem as a data base to retrieve information for use in

modifications, design and other engineering anal.vsis and

evaluations.

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Actions have also been initiated to improve the computer assisted

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records and information retrieval system (CARIRS) utilization.

The

effectiveness of the CARIRS system in accomplishing its intended

function to provide current document status was diminished due to

the licensee's present practice of creating a "Roll Over Design

Change Notice (RODCN)" to tabulate all change documents in one

master package.

The creation, review, audit and approval of the

ROOCN may take anywhere from a few weeks to several months depending

upon the size, complexity, and schedule of the completion of the

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modification. The inspectors noted that the CARIRS system inputs

had a lag of one to three days after receipt of the approved

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documents by the Record Management Group.

However, the delay due to

the review and approval cycle of the RODCN creates an apparent

backlog in document status input.

This apparent inconsistency

creates a user perception of the inaccuracy, especially in the

plants, that the CARIRS system is inaccurate.

Engineering and Design:

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The Engineering and Design Department is authorized 150 positions.

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Currently there tre 137 positions filled of which 99 are technical

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and professional personnel.

Included in the above staff, forty are

assigned to functions supporting both nuclear and fossil fueled

facilities. These functions include metallurgical and chemistry

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laboratories and services. The balance of the staff is dedicated to

engineering services for the operating nuclear plants.

The inspectors held discussions with the Director of the department

and responsible engineers, and reviewed the departmental work load

and a selected sample of engineering analyses performed by the

department.

The Director informed the inspectors that there were

approximately 250 projects assigned to the department.

These

projects are of various sizes and complexity.

They include both

short and long term projects, and are at various stages of

completion. A high priority has been assigned to projects that are

necessary to support to 12R outage of Oyster Creek scheduled for

October, 1988.

The priorities established for each task are

reviewed quarterly by department managers. Any change in the target

dates or priority level of key projects requires approval of the

department managers concerned i.e. no one department manager has

authority to unilaterally change the target date or priority of a

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task which impacts other departments or the operating plants.

The Engineering and Design Department is essentially an in-house

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engineering service organization that receives assignments from

other departments within the Technical Functions Division and

provides design services to those groups.

The work within the

department is controlled by formal engineering procedures and well

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documented.

The output of this department consists of design

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packages for modifications, system and equipment performance

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analysis, and assorted engineering evaluatisns on an as needed

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The department uses engineering consulsants to supplement the

in-house cattbilities.

The Director of the department is authorized

to retain consultants when necessary without prior approval within

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his departmental budget.

For more complex and long term consultant

services the approval is required on a case by case basis.

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Currently, the department has retainer contracts with the nuclear

steam system supplier and one major architect engineering

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organization.

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The inspectors reviewed the use and control of computers during

design and analysis.

The majority of the computer programs used by

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the department are commercially available, benchmarked programs used

throughout the industry.

Any specific program designed and

developed in-house is reviewed, verified by simplified hand

calculations, and approved prior to use.

The department procedures require that the design calculations and

, assumptions be checked and verified by independent qualified

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personnel.

The department policy also requires that design

engineers familiarize themselves with the physical layout and

installation of the system by direct observations prior to the start

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of the design process.

This policy has been initiated to minimize

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change requests by assuring that the design will not interfere with

existing conditions in the plant.

This policy also assures that the

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as installed condition of the plants systems are idertified and

documented for inclusion into the plant configuratf or control

program.

Systems Engineering:

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The Systems Engineering Department is authorized 103 positions.

Currently there are 92 positions filled of these 77 are technical

and professional personnel, which include 10 Shift Technical

Advisors and the rest are administrative support staff.

An independent technical overview function of plant operational

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safety, and fuel engineering is the primary responsibility of this

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department. The department also staffs, operates, programs and

upgrades plant process computers, and maintains and controls the

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plant training simulators.

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The inspectors reviewed sample outputs of the department's work;

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training and qualification procedures for Shift Technical Advisors;

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documents related to plant performance, transient analysis, trending

ano operating experience, and fuel engineering reports. This

department's responsibility is oriented towards plant operability

and safety.

The department supports plant operations by monitoring

plant status, operability, and safety and by irdependent transient

analysis through the Shift Technical Advisors.

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The inspectors observed that the department has an established

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program to monitor and analyze safety significant ope-ating

experiences from external sources, i.e. NRC Notices and Bulletins,

INPO Data Base and other industry reports.

This program is designed

to provide recommendations in appropriate cases to enhance the

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safety and reliability of the operating plants.

The inspectors reviewed three reports (TDR-850, TDR-886 and The

Event Trending and Operating Experience Review Program Reports for

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TMI-1 and OC) to determine the scope and technical acequacy, depth

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of the analysis, methods of evaluation and the validity of the

conclusions reached in the reports.

The reports indicated an

indepth analysis and evaluation of the covered subjects.

The

technical content of the reports was of high quality.

There were

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extensive backup data included in the reports in the form of graphs

and tables to support the conclusions.

As an example, in TDR No.

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886, TMI-1 Specific ATWS Analysis, The ATWS rule 10 CFR 50.62, that

requires B&W plaats to provide Diverse Scram Systems (DSS) and

Mitigation Systems to reduce risk from ATWS was analyzed.

This TDR

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evaluates the peak pressure resulting from a loss of main feednater

event and to develop the set point for the 055.

For tnis analysis,

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a THI-1 RELAPS model was developed and benchmarked against a loss of

main feedwater ATWS analysis performed by B&W using similar generic

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assumptions.

Specific values for moderator and doppler

coefficierts, emergency feedwater setpoints and flow, and feedwater

coastdown were incorporated to assure the analysis specifically

modeled the TMI-1 operating characteristics.

This department has developed in-house capabilities for fuel

management and engineering for Oyster Creek Nuclear Generating

Station, and currently is in the process of developing similar

capabilities for Three Mile Island Nuclear Generating Station - Unit

1.

This is a good initiative on the part of the licensee to reduce

dependence on outside contractors. A fully developed capability in

this area will provide consistent analysis and overview by personnel

dedicated to specific plants.

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Another example of the groups effective monitoring of the plant

operations was evident by the awareness in the group of the heat

exchanger biofouling problems before the plant requested any

assistance with this problem.

Engineering Projects:

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The Engineering projects Department is authorized 63 positions

Currently there are 61 positions filled, cf these 52 are technical

and professional personnel.

The inspectors discussed policies, practices, and the

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responsibilities of this department with the department Director to

assess the departments involvement with the engineering and

technical support provided to the operating plants.

The interface

of this department with other engineering support groups was

evaluated by re"iew of procedures and departraent policies.

Through

these discussions and the review of documented policies and

procedures, the inspectors noted that this department primarily is

responsible for providing project management services for all major

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modifications and also some minor modifications that are classified

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Capital projects.

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In summary, the department provides management of modifications and

engineering liaison with the plants from the conceptual stage to the

final implementation of the modifications in the operating plants.

Startup and Test:

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The functions of this department were not reviewed during this

inspection.

Co clusions

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Th! inspectors determined the following:

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Engineering Services

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The Engineering Services Department is appropriately organized and

staffed to support the Technical Functions Division responsibilities.

The procedure control is exercised by the Procedures and Standards

Group within this department. The design and drafting groups

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effectiveness was also evidenced by the lack of substantial backlog

for drawing updates fo- Oyster Creek, and essentially no backlog for

Three Mile Island, Unit 1.

The engineering service department is the focal point for assembling,

analyzing, and generating the management information reports on a

regular schedule.

These reports provide higher management with an

overview of the Divisional operations.

The reports are used to

formulate divisional long range plans, budgetary forecasts, workload

distribution, and identify areas requiring management attention. The

inspectors reviewed a sample of these reports and found no deficiencies

in the information content, methods of presentation, and their

distribution.

Engineering and Design

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The inspectors cetermined that the current staffing of this

department is adequate to perforn assigned functions.

The work

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cacklog as defined by the department Director appeared to be at an

acceptable level.

Sy;tems Engineering

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The Systems Engineering Department is appropriately organized and

staffed to support the departments responsibilities.

The strength

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of the department is in operational support and analyses required by

the plants.

The department's oversight responsibility is enhanced

by the plant STA's reporting to this organization.

Engineering Projects

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The staf fing in this department appeared to be suf ficient to

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effectively perform the departmental responsibilities.

The inspectors determined that this deoartment essentially provides

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the project management services for modifications and other

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miscellaneous construction to the plants.

The department's function

is to provide liaison among design engineering, facilities

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construction, plant operations, and engineering consultants, if any,

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during the design and installation of modifications.

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controls, such as, budget, schedule, and manpower are also under the

purview of this department.

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7.0 Training

The licensee's training department provides training and instructional

facilities on a company wide basis. The individual divisions and

departments are responsible for identifying their training needs,

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The Techr cal Functions Division uses the training department's facilities

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and ex,;* :ise in providing training to division personnel.

The inspector

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determined that the division had established a comprehensive training

program for entry level engineers.

The Shift Technical Advisor Training

also was provided by the training department.

The inspectors noted that although the STAS are part of the Technical

Functions and administrative 1y report to the Director of Systems

Engineering who establishes their training and certification require.nents,

the Training Department procedure for STAS was neither approved by,

concurred with, nor distr:buted to the Systems Engineering Department.

The Director of System Engineering Department did not have a controlled

copy of this procedure in his files.

8.0 Communications

No major deficiencies in the organization, staffing, qualifications, and

training of the Technical Functions Division were observed and the Division

appears capable of providing effective technical support to the operating

plants. The NRC in previous inspection and SALP reports had identified

problems in engineering support to the plants.

The licensee's self

assessment also identified a concern regarding lack of communications

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between the plant operations and the Technical Function Division personnel.

It appears that communication between the Technical Function Division and

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the plants may be an area needing improvement.

The licensee has implemented

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several steps, such as, requiring Project and Responsible Discipline

Engineers to walkdown systems and enhance communication with their counter-

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parts on the operations staff.

The above actions are good initiatives

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toward improving communications and information transfer between the two

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organizations.

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9. 0 Management Meetings

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Licensee management was informed of the scope and purpose of the

inspection at the entrance interview on September 13, 1988. The findings

of the inspection were discussed with licensee representatives during the

course of the inspection and presented to licensee management at the

September 19, 1988 exit interview (see paragraph 1 for attendees).

At no time during the inspection was written matarial provided to the

licensee by the inspector.

The licensee did not indicate that

prsprietary information was involved within the scope of this inspection.

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ATTACHMENT A

DOCUMENTS REVIEWE0

Administrative Procedures

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1000-A0M-7350.01 (EMP-19), Revision 6, Plant Modifications Enginecred by Plant

Engineering

5000-ADM-2131.01 (TAP-004), Revision 2-00, Technical Functions Personnel

Indoctrination and Training

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5000-ADM-2600.01 (EP-015), Revision 2-00, Training Material and Program Review

5000-ADH-2620.01 (TAP-005), Revision 2-00, Shift Technical Advisor Selection

and Training

5000-ADM-7311.01 (EP-006), Revision 2-02, Calculations

5000-A0M-7311.02 (EP-009), Revision 3-00, Design Verification

5000-ADM-7350.05 (EMP-002), Revision 1-00, Mini-Mods

Policy Procedures

5000-POL-1218.02 (P0-002), Revision 1-00, Operational Flow Charts

Training Procedures

7850-PGD-2721, Revision 4, Shift Technical Advisor Training Program

Technical Data Reports

TOR-405, Revision 0, TMI-1; Evaluation of Plant Radiation Release and its 10 CFR 50, Appendix I Conformance for Different Operating Conditions

TOR-NG-850, May 14, 1987 Technical Basis for HSPS/ICG Low Level Limit Set

Point for THI-1

TOR-856, August 15, If88 Event Trending and Operating Experience Review

Program for TMI-1 an OC

TOR-919, Revision 0. Evaluation of THI-1 Rated Power Stretch to 2568 MWt

Calculation Sheet

C-1302-226-5411-158, Revision 0, Cycle 11 Rod Sequence Extansion

C-1302-226-5411-162 Revision 1, Mid-Cycle Criticals at 200 F

Topical Reports

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AT'TACHMENT A

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TR-020-A, Revision 0, Methods of Analysis of Boiling Water Reactors Water

Lattice Physics

TR-021-A, Revision 0, Methods of Analysis of Boiling Water Reactors Steady

State Physics

TR-033-A, Revision 0, Methods of Generation of Core Kinetics Data for

RETRAN-02

TR-040-A, Revision 0, Steady-State and Quasi-Steady-State Methods Used in the

Analysis of Accidents and Transients

TR-045, Recision 0, BWR Transient Analysis Model Using the RETRAN Code

TR-040 Revision 0, Reload Information and Safety Analysis Report for 0C Cycle

12 Re1 ad

Trend and Performance Analysis Report

TFAR-TMIl-06-20, Thermal Performance and Availability Report - June 1988

TPAR-TMIl-06-21 TMI-1 System and Equipment Operating Trend Summary Report,

March 1987 - June 1988

TPAR-TMIl-06-22, TMI-1 Availability Summary Cycle 6

Safety Evaluatig

i

SE-000650-001, Revision 1, Use of NAS Calculations and Displays for Compliance

with Core Related TMI-1 Technical Specifications

SE-135400-005, Revision 0, Cycle 7 Reload Design

ML20207M161

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