ML20207S775
| ML20207S775 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 03/12/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207S761 | List: |
| References | |
| 50-219-85-98, NUDOCS 8703200261 | |
| Download: ML20207S775 (69) | |
See also: IR 05000219/1985098
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-219/85-98
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION
OYSTER CREEK NUCLEAR GENERATING STATION
ASSESSMENT PERIOD: JULY 1, 1985 - OCTOBER 15, 1986
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BOARD MEETING DATE: NOVEMBER 25 and 26, 1986
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0703200261 070312
PDH ADOCK 05000J19
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. TABLE OF CONTENTS
.P. agg
I. INTRODUCTION ....................... 1
A. Purpose and Overview . . . . . . . . . . . . . . . . . 1
B. SALP Board Members . . . . . . . . . . . . . . . . . . 2
C. Background . . . .................. 3
II. CRITERIA ......................... 5
III. SUMMARY OF RESULTS .................... 7
A. Facility Performance . . . . . . . . . . . . . . . . . 7
B. Overall Facility Evaluation ............. 8
IV. PERFORMANCE ANALYSIS ................... 9
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A. Plant Operations . . . . . . . . . . . . . . . . . . . 9
B. Radiological Controls ................ 13
C. Maintenance ..................... 18
D. Surveillance / Inservice Testing . . . . . . . . . . . . 22
E. Emergency Preparedness . . . . . . . . . . . . . . . . 25 i
F. Security and Safeguards ............... 27
G. Outage Management / Refueling ............. 30 ;
H. Technical Support .................. 34
I. Training and Qualification Effectiveness . . . . . . . 37
J. A s s ura nce o f Qua l i ty . . . . . . . . . . . . . . . . . 40
K. Licensing Activities . . . . . . . . . . . . . . . . . 44
V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . 47
A. Investigations and Allegations Reviews . . . . . . . . 47
B. Escalated Enforcement Actions ............ 48
C. Management Conferences . . . . . . . . . . . . . . . . 49
0. Licensee Event Reports . . . . . . . . . . . . . . . . 50
_ TABLES
Table 1 - Tabular Listing of LERs by Functional Area ...... T1-1
Table 2 - LER Summary . . . . . . . . . . . . . . . . . . . . . . T2-1 r
Table 3 - Enforcement Summary . . . . . . . . . . . . . . . . . . T3-1
Table 4 - Inspection Hours Summary ............... T4-1
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Table 5 - Inspection Report Activities ............. TS-1
Table 6 - Enforcement Data ................... T6-1
Table 7 - Unplanned Trips and Shutdowns . . . . . . . . . . . . . T7-1
Table 8 - SALP History. . . . . . . . . . . . . . . . . . . . . . T8-1
Table 9 - Licensing Activities. . . . . . . . . . . . . . . . . . T9-1
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Figure 1 - Number of Days Shutdown ............... F1-1
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I. Introduction
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A. Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an
integrated NRC staff effort to collect available observations and
data on a sampling and periodic basis and,to evaluate licensee
performance based upon this information. The SALP is supplemental
to normal processes used to ensure compliance to NRC rules and
regulations. It is intended to be sufficiently diagnostic to provide
a rational basis for allocating NRC resources and to provide
meaningful guidance to the licensee's management to promote quality
and safety of plant operations and modifications.
l A NRC SALP Board, composed of the staff members listed below, met on
November 25 and 26, 1986, to review the collection of performance
observations and data to assess the licensee's performance in
accordance with the guidance in NRC Manual Chapter 0516, " Systematic
, Assessment of Licensee Performance." A summary of the guidance and
l evaluation criteria is provided in Section II of this report.
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This report is the SALP Board's assessment of the licensee's
, performance at the Oyster Creek Nuclear Generating Station for the
period July 1,1985 to October 15,1986. The summary findings and
totals reflect the fifteen and one-half month assessment period.
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B. SALP Board Members
Chairman
W. Kane, Director, Division of Reactor Projects (DRP)
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l Members
S. Collins, Deputy Director, Division of Reactor Projects (Part-time)
W. Bateman, Dyster Creek Senior Resident Inspector
R. Blough, Chief, Reactor Projects Section IA
J. Donohew, Project Manager, BWR Project Directorate #1, Division of
BWR Licensing
W. Johnston, Deputy Director, Division of Reactor Safety
! J. Joyner, Chief, NMSS Branch, (DRSS)
, R. Keimig, Chief, Safeguards Section, NMS&SB, DRSS (Part-time)
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M. Shanbaky, Chief, Facilities Radiation Protection Section
(Part-time)
Attendees
, W. Baunack, Project Engineer, RPS 1A, PB No. 1, DRP
l R. Conte, TMI #1 Senior Resident Inspector
R. Freudenberger, Reactor Engineer, RPS 1A, PB 1 DRP
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H. Kister, Chief, Project Branch No.1, DRP (Part-time)
W. Madden, Physical Security Inspector, SS, NMS&SB, DRSS (Part Time)
S. Sherbini, Radiation Specialist (Part Time)
J. Wechselberger, Resident Inspector, Oyster Creek
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C. Background
1. Licensee Activities
At the beginning of the period, the unit was operating at full
power. On July 8, a reactor scram occurred due to low condenser
vacuum which resulted from steam Jet air ejector drain tank pump
problems. The reactor was restarted on July 9. During the
period from July 15 to July 22, problems were experienced with
the emergency service water (ESW) system. These problems resulted
primarily from the loosening of a protective coating inside the
ESV system piping. On July 22 the unit was placed in cold shutdown
to inspect, clean, and hydrolaze sections of ESW piping, flush
the systen . and perform post-maintenance testing.
The reactor was restarted on August 3. On August 9 the reactor
was again shut down to add oil to two unit substation transform-
ers in which low oil level had been detected. During the
shutdown process, a reactor scram occurred due to inadvertent
insertion of all intermediate range monitors. On August 10, a
restart was initiated. Various equipment problems were experienced;
however, the plant continued to operate until October 18, when
the unit was shutdown for a month-long mini-outage to complete
required environmental qualification modifications.
Following the mini-outage the plant was restarted on November
16. On November 20, a reactor trip occurred due to a generator
trip which resulted from a current transformer (CT) failure.
The CT was replaced and the unit restarted on November 23. The
unit continued to operate until December 15, at which time the
reactor scrammed due to high flux caused by turbine control
valve closure. The control valve closure was caused by a loose
connection in the valve controls. The plant was restarted on
December 16. Plant operation continued and on February 11, all
rods were essentially withdrawn and end of fuel cycle
"coastdown" began.
On March 6, a scram during turbine stop valve surveillance
testing occurred. The plant was restarted on March 7. During
subsequent surveillance testing of Static-0-Ring reactor water
level instruments, a setpoint drift problem was discovered and
on March 27 the plant was shutdown to replace these sensors.
Following replacement and testing, the unit was restarted on
March 30. The setpoint drift problems continued and an
increased surveillance frequency was implemented. On April 5,
one recirculation pump was removed from service due to seal
failure and operation continued with the remaining four recir-
culation pumps until April 12 when the plant was shutdown for
the 11R Refueling / Maintenance / Modification outage. The outage
was scheduled for six months and was still in progress at the
end of this report period.
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2. Inspection Activities s '
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Two NRC resident inspectors were assigned to the 'iitte throughout
the assessment period. The total NRC inspection. hours for the " ?q' .
15 1/2 month period was 5189 hours0.0601 days <br />1.441 hours <br />0.00858 weeks <br />0.00197 months <br /> (Resident, Royion, and
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Headquarters based) with a distribution in tSe9ppraisal r
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functional areas as shown in Table IV. This equates to 4017 '
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hours.on an annual basis. ' t .- .
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During the period, NRC team inspections were conducted to review
potential for overpressurization of low pre'ssure ' emergency core
cooling systems and to evaluate the licensee's program Wor the -
environmental qualification of equipment. Also, special.inspec-' ..
tions were conducted to review implementation of NUREC 0737 items
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and the circumstances associated with iodine upt'akes ty workers.
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A NRC Emergency Preparedness inspection team observed the annual "
emergency exercise on April 9, 1986. -
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Tabulations of inspection and enforcement activities are ,
attached as Tables 5 and 6, respectively. '
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II. CRITERIA
Licensee performance is assessed in selected-functional areas, depending
upon whether the facility is-in a construction, preoperational, or opera-
tional phase. Each functional area normally represents areas significant
to nuclear 9 etyf tM the environment, and are normal programmatic areas.
Special areas may be added to highlight.significant observations.
One or more of the following evaluation criteria were used to assess each
functional area:
1. Management involvement and control in assuring quality
$ n , 2. ' Approach to resolution of technical issues from a safety standpoint
, 3. Responsiveness to NRC initiatives
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4. . Enforcement 17 story
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5.- depor.tingandanalysisofreportableevents
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6. Staffing (including management)
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7. Training effectiveness and qualification
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No This report also discusses " Training and Qualification Effectiveness"
and " Assurance of Quality" as separate functional areas. Although these
topics, in themselves, are assessed in the other functional areas through
their use as criteria, the two areas provide a synopsis. For example,
, quality assurance effectiveness has been assessed on a day-to-day basis by
r resident inspectors and as an integral aspect of specialist inspections.
C' Although quality work is the responsibility of every employee, one of the
C', management tools to measure this effectiveness is reliance on quality
, assurance inspections and audits. Other major factors that influence
quality, such as involvement of first-line supervision, safety committees,
and work attitudes, are discussed in each area.
The topic of fire protection is not discussed as a separate functional
area because of insufficient inspection activity. The available observa-
. tions on fire protection and housekeeping are included in the various
relevant functional areas.
Technical Support continued as a functional area because of the signifi-
cant involvement of Plant Engineering and Technical Functions in Oyster
Creek activities.
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:
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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 performance with respect to operational safety or construction is
being achieved.
Category 2. NRC attention should be maintained at normal levels. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; the licensee resources are adequate and reasonably effec-
tive 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
nuclasr safety, br+ weak.nesses are evident; licensee resources appear to
be strained or not effee.*ively used so that minimally satisfactory
per'formance with respect to operational safety or construction is being
achieved.
The SALP Board has also assessed each functional area to compare the
licensee's performence 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. The trend categories used by the SALP Board are as
fcitows:
Improving: Licensee performance has generally improved over the last
quarter of the current SALP assessment period.
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, Declining: Licensee performance has generally declined over the last
quarter of the current SALP assessment pcriod.
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A trend is assigned only when, in the opinion of the SALP board, the
, trend indicates a clear potential to change the overall performance to a
different classification in the near future. For example, a classifica-
tion of " Category 2, Improving," indicates clear potential for Category 1
performance.
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III. Summary of Results
A. Facility Performance
Category Category
Last Period This Period
(5/1/84- (7/1/85- Recent
Functional Area 6/30/85) 10/15/86) Trend *
A. ' Plant Operations 2 2 -
B. Radiological Controls 1 2 -
C. Maintenance 3 2 -
D. Surveillance / Inservice Testing 2 1 -
E. Emergency Preparedness 1 1 -
F. Security and Safeguards 2 1 -
G. Outage Management / Refueling 2 2 -
H. Technical Support 2 2 -
I. Training and Qualification N/A 1 -
Effectiveness
J. Assurance of Quality N/A 2 -
K. Licensing Activities 2 2 Improving
- Trend during the last quarter of the assessment period.
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B. Overall ' Facility Evaluation
Site and corporate management demonstrate a strong commitment to safety.
Furthermore, the licensee appears to be committed to a program of
improved training in all aspects of facility operation. During this
SALP period the~ licensee put forth substantial effort to improve those
weaknesses noted in the last SALP; these efforts were moderately
successful and resulted in a general improvement in performance. A
high level of performance was achieved in the emergency preparedness,
security, and surveillance areas. However, the licensee still faces
a variety of problems and challenges in several areas. Power generation
was interrupted in five instances by reactor scrams and in three
instances by unplanned shutdowns. Plant operation was often plagued
by equipment problems, and aging of plant eouipment appears to be a
developing problem. Recovery from events was complicated in several
instances by operator errors. Continuing attention should also be
given to reducing operator errors and improving shift management's
decision-making on safety issues.
Performance in the areas of maintenance and modification installation
has improved. Licensee efforts to strengthen management capability
and further improve the organization were the major reasons for better
performance. Continued effort is 'equired to provide resources to
permit reduction of the large backlog of work as well as to improve
supervisory and craft work performance, management of resources, and
ALARA. The large backlog of work has not been significantly reduced
due, in part, to the lack of resources and a constant influx of new
problems. Technical support to evaluate and correct problems has
been inconsistent regarding quality and timeliness. Technical support
has generally-improved, however, in the timely development of engi-
neering needed to support planned work and responsiveness to site
questions regarding this work.
The licensee needs to effectively address the equipment aging issue
in order to maintain operator confidence in plant operations. Since
this effort may initially increase the work backlog it is also impor-
tant to properly prioritize the work using such tools as probabilistic
risk assessment and an integrated living schedule, and to ensure that
adequate resources are committed and applied. It is also important
to complete expeditiously the substantial ongoing effort to re-estab-
lish the as-built basis of the plant.
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IV. PERFORMANCE ANALYSIS
A. Plant Operations (1971 hr. 38%)
The previous SALP rating in this area was Category 2. Generally-
good performance in all facets of plant operations was noted with
training identified as a strong point. Weaknesses were identified
in supervision of contractor maintenance activities, instructions to
operating personnel, operator control of reactor water level, repair
or replacement of defective equipment, and improvement in communica-
tions between operations and other divisions.
Evaluation of this area is based on performance during the Cycle 10
operating period and the Cycle 11 refueling outage. Assessment in
this area includes an evaluation of the licensee's progress in meeting
commitments made in their response to the previous SALP.
Licensee management has generally been successful in meeting the
commitments made in response to the previous SALP. The licensee
has made a number of physical improvements in the control room.
Improvement in control room professional environment was noted,
but improvement is still required as indicated by two examples of
improper manning of the control room and inconsistent control of
control room access. The licensee previously committed to provide an
assembly space for relief crews and equipment operators to limit
their access to the control room but was not able to accomplish this.
Log keeping has shown significant improvement as a result of daily
management reviews of control room logs and emphasis placed on proper
log keeping during simulator training sessions. One log keeping
deficiency that still needs improvement is documentation of details
related to significant operating events. Another concern is the
proper recording and review of out-of-specification readings on logs.
Plant management is aware of their weaknesses in these areas and
continues to strive for improvement.
Six reactor trips occurred in 1985 and operating problems persist.
Reactor level control problems continued and fuel failures occurred
as a result of improper utilization of the new Power Shape Monitoring
System. The previous SALP discussed these areas as significant
concerns. Most trips resulted from secondary system equipment
problems which may be due to plant aging or lack of proper maintenance.
Shift operations are generally well conducted, although there seems
to be a lack of decision-making ability on the part of shift manage-
ment. Shift management decision making was noted to be lacking
during a drywell inerting evolution which led to a violation. Other
weaknesses associated with shift management include approving
maintenance making a safety-related snubber inoperable, failing to
recognize the importance of shutting a recirculation pump discharge
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valve following a pump trip, and the failure to deactivate a con-
tainment isolation valve in accordance with Technical Specification
requirements. Shift management needs to improve in coasidering all
aspects of' safety issues, and in acting. decisively upon the issue in
accordance with applicable regulations and procedures.
During scram' recoveries, a number of operating errors have occurred
which complicated recovery operations and, in one instance, initiated
a scram. Among the errors which occurred a're (1) improper upranging
of IRMs to range 10, (2) initiation of a scram by simultaneously
inserting all eight IRMs, (3) failing to place the mode switch in
shutdown following a reactor scram which. led to significant operating
difficulties, and (4) initiation of a MSIV closure by jiggling of the
mode switch. There appears to be a need to evaluate training to
focus on these types of errors.
Equipment problems still persist, as noted, and have directly
contributed to four scrams during the assessment period. Scrams have
occurred as a result of failure of steam jet air ejector drain pumps,
a' main generator current transformer, a turbine stop valve limit
switch, and the electric pressure regulator. The licensee has
recognized this and formed a scram reduction task force. 0ther-
significant equipment problems included electromatic relief valve
seat leakage, feedwater isolation valve leakage, hydraulic control
unit deficiencies, and feedwater control problems.
Reactor water level centrol was consistently a major operator
concern following a reactor scram during this assessment period.
In virtually every scram recovery, high reactor water level pre-
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cluded the use of the isolation condenser. In another case, while
attempting to reseat a leaking EMRV after a scram,-unstable water
c level control resulted in low reactor water level. ~ This has led
- also to complicating scram recoveries as the operators' full attention
[ has been devoted to water level control, overlooking other immediate
operator' actions. The licensee has recognized this problem, revised-
operating procedures, and is contemplating a feedwater control system
j modification.
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Fire protection staffing levels are acceptable. The fire protection
staff was found to be experienced and knowledgeable of requirements.
Fire brigade training and drills were verified to have been conducted
in accordance with the requirements of the plant Fire Protection Pro-
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gram Manual. The training records were well maintained and available.
In general, the plant fire protection system and equipment were well-
maintained and were in good working condition. The annual and
biennial fire protection audits were conducted in accordance with the
Technicel Specifications.- One area of concern was the slow response
to apparent nonconformances, as evidenced by audit findings which
had been identified for over a year and which had not been resolved.
However, management's attention to fire protection concerns and con-
servr.tism regarding issues affecting safety was generally evident.
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Senior operations mana'gement continues to be a strong contributor to
, safe efficient operation of the 0yster. Creek Nuclear Generating Station.
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Post-transient analysis and reviews.are generally conducted in a
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thorough ~ manner, determining root causes and establishing proper
corrective action prior to resumption of power operation. Another
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strong. management control has been the establishment of certification
reports for such . significant milestones as refueling and restart.
This helps to ensure that all required tasks, including maintenance
work items, quality assurance deficiencies, surveillances, etc., have
1: been . completed or appropriately dispositioned prior to commencing a
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major milestone. The addition of a dedicated senior reactor operator
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during outages to improve the interface and working relations between
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operations and maintenance was another positive management initiative
that helped coordination of work activities. Another initiative was
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the establishment during the 11R outage of back shift coverage by
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senior plant management to more rapidly identify ar.d resolve problems.
Management personnel are frequently founo in the plant and involved
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in the solution of plant problems. The licensee has established good
programs to manage operator overtime hours. Housekeeping-in the plant
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during operations is usually excellent and is a reflection of the
concerted effort by plant management in this area. Housekeeping
3 during outages needs to be improved, though, and is7 discussed in the
Maintenance and Radiological Controls sections.
In summary, strong senior operations management continues to be a
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major attribute in the good performance of the station. Management
has generally been successful in meeting commitments made in their
SALP response letter. Significant changes have been-noted in the-
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control room environment but plant management attention is still
warranted. The operations-maintenance interface has improved as a
result of management initiatives, including an operational outage .
coordinator and senior management coverage on backshifts. Weaknesses
were noted in the resolution of.long standing operational equipment
problems that continue to confront the operators and hinder plant
operations. Of potential significance is the apparent loss of operator
- confidence in equipment. Personnel errors contributed to and
j complicated reactor trips. There is an apparent operator pre-occupation
U with water level control problems to the exclusion of performing
l immediate operator actions during a reactar scram. Additional-training,
,. including plant-specific simulator train 1ng, would improve operator
performance and reduce operator cognitive errors during scram recovery
i. operations. Improvement in the shift management's nuclear safety
perspective is needed to promote the desired control room environment
and increase operational assessment and performance during events.
Conclusion
Category 2
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-Board Recommendations
Licensee:
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Improve shift managements' abilities to recognize and fully
consider all safety aspects of an ' issue and then act decisively
on that issue.
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Decrease the number of operator errors through enhanced opera-
tional training including use of plant specific simulator
training.
NRC:
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B. Radiological Controls (478 hrs. 9%)
The previous SALP rating in this area was Category I with effective
control of radiation protection activities and high levels of per-
sonnel performance noted. Strong points included training, exposure
control, whole body counting,. timely corrective action to identified
problems, effective radwaste management and radwaste volume reduction.
Positive contributions of the chemistry program and the upgrading of
the chemistry facilities were also noted.
During the current period, there were six violations in the area of
radiological controls, two of these in the area of radwaste and
trantportation and four in control of radiation areas and radiation
surveys. Two of the latter incidents involved workers receiving
unplanned exposure in excess of the site administrative whole body
exposure limits.
The assessment of the performance of the radiological controls
program is that, on the whole, the licensee continues to show a
relatively high_ level of effort in controlling radiation exposure
on site, radiological effluents, and waste shipments. Inspec-
tions during the outage showed good control of access into the
radiologically controlled areas, although long delays in gaining
access to these areas were sometimes observed at shift changes.
Housekeeping in the_ reactor building was not consistent or uniform
throughout the radiologically controlled areas. There were many
instances in which waste, including radioactive waste, was allowed
to accumulate in excessive quantities before being removed. Effort
was evident in the extensive and thorough posting and barricading of
radiation and contaminated areas, in the arrangement of suiting-up
areas outside the drywell, and in the arrangement of containers and
methods of segregating contaminated items of clothing and equipment.
However, the suiting-up areas were often of insufficient capacity
to comfortably accommodate the large numbers of people using them.
Although the waste segregation system is in principle a good idea,
the workers in many instances did not appear to adhere to that system
and, as a result, contaminated items were sometimes mixed with waste
classified as clean. This appears to be indicative of insufficient
training and indoctrination in station procedures and general good
practice, and insufficient insistence that such practices and pro-
cedures be followed. An example of a tendency not to insist on
proper and conservative practices is the response of radiological
controls personnel to radiation monitor alarms during fuel manipu-
lations in the recent outages wherein fuel movement was allowed to
continue before the cause of the alarms was understood and corrected.
Other instances indicative of weakness include instances of poor
frisking at exits from radiologically controlled areas, and a
failure to ensure that a locked high radiation area access door was
locked after use.
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Issuance of RWPs appeared to have been well controlled, and
assignment of' personnel dosimetry was generally good.
The radiological controls program appears to be a well managed and
effective program, however, there are weaknesses. The main area of
weakness is in ALARA. The ALARA program shares the same commendable
attributes found in other areas of the radiological controls program, ;
namely full staffing by competent individuals, apparently adequate
funding for program activities, reports, and presentations to
management. Despite this apparent dedication in effort and
resources, the program has not been successful in minimizing
exposures. The accumulated exposure for the year to date (October
1986) of 2100 man-rem is much higher than industry averages for BWRs,
even after allowing for the large number of radiologically signifi-
cant jobs that were performed during the outage. It also far exceeds
the 1986 annual estimate for the site of 1000 man-rem. The reasons
for this large discrepancy between the estimates and the actual
exposures are partly due to inaccurate estimates, less than expected
decontamination factors from decontamination of recirculation system
piping, and insufficient job planning and control.
Another program weakness was noted in the area of surveys for air-
borne contamination and ambient radiation fields prior to and during
job execution. This assessment is based on four incidents that
occurred during the current SALP period. Two of these incidents
involved inadvertent intakes of radioiodine 6y several workers. The
other two incidents involved unplanned exposures to the whole bodies
of two workers that exceeded site administrative limits. Although
none of these exposures was reportable or in excess of regulatory
limits, they were unplanned and resulted from the existence of con -
tamination or radiation fields that were not well characterized at
the time of exposure. Although extensive radiological surveys and
air sampling are conducted on a routine basis in the radiologically
controlled area, review of the circumstances surrounding these
-
incidents indicates that surveys for protection purposes were neither
emphasized nor closely controlled for timeliness. The review also
revealed mother general area of weakness, namely, inadequate commu-
nications between at least some of the departments on site. Another
area of weakness is the frequent equipment breakdowns and maintenance
problems in the New Radwaste and Augmented Offgas buildings. These
breakdowns have led to incidents of personnel contamination and
environmental releases. Although these incidents were not
radiologically significant, they do point to the need to review the
design and maintenance practices for these systems.
Other than the weaknesses noted above, the licensee's program
for external and internal exposure controls are well managed and
effective. Staffing levels appear to be good, and the procedures
are adequate. Equipment and facilities are also adequate in most
areas.
i
_ _ - _ . . _ _ - > -
.. .
15
The licensee is in general responsive to regulatory and safety
concerns. An example is provided by underwater diving operations on
site. Preparations for the first diving operation in this SALP
period were reviewed by a NRC inspector and were found to be lacking
in certain areas. Subsequent diving operations were well planned and
well executed.
Radwaste operations was an area in which the licensee made
improvements since the last SALP. Considerable effort was made in
improving radwaste operations equipment. Additionally, radwaste
operator ability to recognize the significance of off-normal readings
was improved by. implementing the necessary training and management
reviews. Although improvements have occurred in this area, equipment
problems persist. Continued management attention is required to
ensure radwaste system availability is improved.
The licensee has an adequate effluent controls and monitoring
program. The licensee is performing sampling and analyses in excess
- of Technical Specification requirements for inplant and effluent
sampling analyses. Management involvement is evident in the plan-
ning for the implementation of the Radiological Effluent Technical
Specifications (RETS), which will become effective during the next
assessment period.
Consistent with the previous assessment period, the licensee main-
tained a strong chemistry department. Recently, the chemistry
department manager was also designated the acting radwaste operations
manager. There was no evidence of a loss of management control in
either department as of the writing of this evaluation. However, the
plant is in an extended outage, with less demand on effluent proces-
sing and monitoring. Procedures for gaseous and liquid effluent
controls are implemented and documentation is reviewed in a timely
manner. Higher than usual gaseous effluent releases were determined
to have peaked in December 1985 and remained elevated until the
planned shutdown in April 1986. The licensee attributed the elevated
gaseous releases to leaking fuel and equipment problems related to
the Augmented Offgas (A0G) Facility. During the refueling outage, the
licensee completed extensive repairs to the A0G.
Management attention is also being directed to improve the back-
ground radiation levels for two of the liquid process monitors and
to install a turbine building vent monitoring system. The licensee
has operated without a liquid overboard discharge for 22 months. An
example of a less than conservative approach was the licensee's
response to a failure of the charcoal efficiency test for one of the
standby gas treatment system trains. The cause of the failure was
not investigated, nor was the alternate train tested to confirm its
required efficiency. Testing of the alternate train was to be under-
taken at the first available opportunity after being suggested by the
NRC.
.. - --
. .
16
There were two transportation reviews conducted during this assess-
ment period. Two minor problems which related to excessive dose
rates and quality control involvement to assure compliance-with 10
CFR 61 were identified. These were not indicative of a programmatic
breakdown and thorough responses were evident in both cases. In
addit'on, for the problems involving excessive dose rates and
inadvertent shipment of an irradiated material, the licensee con-
ducted an extensive critique and analysis of the causal factors.
Corrective actions were timely and complete. Regarding training
and qualification of radwaste/ shipping personnel, the licensee
provides periodic training in accordance with the guidance of IE
A team inspection to verify and evaluate the licensee's Post Accident
Sampling and Monitoring System was conducted during this assessment
period. During this review, substantive problems were identified
regarding the effluent monitoring system (ieferred to as RAGEMS) such
as inadequate calibration, no continuous sampling, lost monitoring
capabilities under some accident conditions, and lack of procedures
.to address representative sample collection and exposure control.
Follow-up management meetings and inspections have found that the
licensee has developed a technically sound and thorough corrective
action plan. Initially, the licensee's commitment to complete the
necessary actions was not timely. These types of concerns are more
fully discussed in the Technical Support functional area. After
further discussions with the NRC, a more responsive schedule was
submitted. The licensee showed good implementation for PASS
modifications. No equipment problems were identified and an ade-
quate complement of personnel were trained. Follow-up reviews
indicate a continued effort for thorough implementation of PASS,
including surveillance, procedure reviews, and training additional
personnel in the use of PASS.
In summary, the licensee has shown reasonably good control of the
radiologically controlled area, both in terms of access and in terms
of housekeeping and equipment. Good performance has also been
demonstrated in the areas of effluent control and shipping, as well
as in PASS implementation. The licensee has also shown responsive-
ness to regulatory concerns. However, certain areas of weakness
need to be addressed. These areas include emphasis on the preventive
and protective aspects of sampling and surveys, conservatism in the
control of radiation exposures, and handling of unexpected or anom-
alous monitor readings. Good radiation and housekeeping practices
need strengthening. ALARA performance is still weak despite
investment of resources. A review of ALARA methods and procedures
may be required. Communication between departments during planning
and execution of jobs appears to be a problem. Finally, maintenance
problems in the Augmented Offgas and New Radwaste buildings have been
the cause of several contamination and airborne release incidents,
and the design, as well as the maintenance practices for these
systems, should be reviewed.
.
I
_ _ _ _ . _ _ _ ._.
. . . -. - - _ . - ._ . - ~ - = . . _
. - . - - .
- .. .
17
Conclusion
Category -
2
Board Recommendations
Licensee:
--
'Re-evaluate the ALARA process to identify organizational and
. procedural weaknesses both in and out of the Radiological Controls
Department'and implement improvements in communications between
departments involved in planning and execution of a job.
NRC:
None
.
l'
i
- ,, . = , _ . . - ,,_,-, , ,- - ,, ,... - - , - - , , _ _ . - - _ . . _ - . ,,- . - - . -
..- ..
18
C. Mair.tenance (647 hrs.,IP3)
This functional area evaluates licensee performance of routine
maintenance and minor modifications. It includes a one month outage
(10M) in October 1985 for mainly environmental qualification (EQ)
work and a planned six month refueling outage (11R) that included
major fire protection work to satisfy 10 CFR 50 Appendix R. It does
not include restart from the 11R outage. NRC inspections identified
that the Maintenance, Construction, and Facilities (MCF) Division
improved its overall performance as compared to the performance
evaluated in the previous SALP.
The previous SALP rated Maintenance a Category 3. Specific concerns
included the need to reduce rework and improve workmanship, first
line supervision, feedback to engineering, knowledge of job, con-
tractor supervision, post maintenance testing, and responsiveness
to the QA/QC program. Based on NRC inspections of the corrective
actions taken by the licensee, it was evident at the end of this
evaluation period that efforts to improve performance in mair.tenance
were generally successful. However, many of the concerns discussed
in the past SALP were not evident until after restart from the 10R
outage and the end of this SALP period precedes the 11R restart,
thereby, precluding a complete basis for comparison as to the overall
effectiveness of the corrective actions.
One of the majcr keys to improvement was the emphasis placed on
controlling work scope which enabled the licensee to better control
resources. This resulted in more comprehensive supervision which,
in turn, resulted in better workmanship and feedback to engineering.
Other keys to improved performance included effective management
changes, further development and implementation of the work manage-
ment system (WMS), use of shift technical advisors as job monitors,
better prepared technicians as a result of the MCF training program,
improved control of contractors, and an increase in the number of job
supervisors. The 10M outage was notable in that the large majority
of the engineering work was completed prior to the outage, much of
the material was prestaged by individual job, mock-ups were developed
for the critical jobs to ensure ease of installation, and ample
resources and time were provided.
Despite the positive upper level MCF management changes that resulted
in incorporating personnel with more management and/or plant opera-
tions and engineering experience into MCF, some of the same problems
discussed in the previous SALP with inadequate supervision and craft
workmanship persisted.
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _
.- .
19
During the 10M outage, NRC inspections of the RK01 and RK02 EQ
instrument changeout identified examples of MCF's failure to perform
work in accordance with drawing and procedure requirements, failure
of a job supervisor to sign off production holdpoints for a weld
repair, failure to implement or change a procedure prerequisite, and
failure of MCF personnel (along with others) to frisk carry along
items when leaving the radiologically controlled area. Just after
conclusion of the 10M outage, inadequate communications from lower
levels to higher levels of MCF management contributed to an identified
EQ deficiency not being corrected before the November 30, 1985 dead-
line. During the 11R outage, NRC inspections of the spent fuel pool
cooling seismic upgrade revealed the lack of a mechanism to control
rework of QC inspected s..d acceoted work for which MCF still had
responsibility and improper issuance of weld rod used to connect a
l pipe restraint of known material to a floor penetration of unknown
l material. Additional concerns identified included the finding that
j four Technical Specification required snubbers had been inoperable
since the 10R outage. Another resulted when MCF supervisory and
craft personnel failed to properly control a locked high radiation
door. These problems indicate that continued improvement is needed
in the areas of procedure compliance, supervision, control of rework,
craft training, control of contractors, workmanship practices, and
communications within MCF and between interfacing divisions.
Improvements in MCF corrective maintenance efforts resulted mainly
from newly implemented craft training, improved management control,
and prioritization and tracking of work orders. As a result of
these improvements, there is a sense that problems are identified
and prioritized and that management is in control. There are, how-
ever, many backlogged work orders. Manpower and resource limita-
tions, combined with a continuous influx of new problems, have
limited progress to reduce the backlog. NRC review of the causes of
significant corrective maintenance activities indicates that: (1)
secondary side components are impacting the primary side, (2) much
equipment has reached or is reaching the end of useful life, and (3)
not all corrective maintenance performed is effective in correcting
the problem. The licensee should review these problems and take
appropriate corrective action.
Routina corrective maintenance has generally been successful in
correcting identified problems. However, enough problems remain to
indicate management attention is still required to fully implement
the WMS, bring the complete Station Information Management System on
line, improve the quality of craft and supervisory personnel, and
fully utilize available resources to quickly identify and correct
problems. Examples of problems include: (1) difficulty finding the
cause of various spurious signals including area radiation monitor
spikes that initiated the standby gas treatment system on numerous
occasions, intermediate range channel spikes, and unexplained half
scrams; (2) various and repetitive problems with the diesel fire
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _
.- .-
20
pumps and associated equipment; (3) coordination problems with
operations involving temporary variations; and (4) poor workmanship
as evidenced by loose leads, improperly installed jumpers, and the
initiation of the fire suppression system in both a control room
panel and the cable spreading room when careless use of a heat gun
set off nearby fire detectors.
Housekeeping during the 10M outage was controlled at an acceptable
level, however, during the 11R outage, it was inconsistent. The
housekeeping problems discussed in the previous SALP still exist
and licensee action to make housekeeping a part of everyone's job
and hold people accountable remains an unfulfilled commitment.
Additional NRC inspection in this area indicated the procedure for
both radiological and non-radiological housekeeping was weak.
A major concern of the previous SALP was inadequate post-maintenance
testing (PMT). During this evaluation period, the licensee developed
a PMT program, however, it was not yet formally implemented.
MCF responsiveness to QA/QC was also an issue in the past SALP. Only
slight improvement has been noted. The improvement resulted when MCF
management implemented a QDR tracking system in the MCF technical
support department. However, even with this MCF QDR tracking system,
a NRC review of QC's QDR files indicated MCF was still slow in re-
sponding. This appears to indicate that MCF placed too low a priority
on QA/QC, especially when outage workload was high. MCF still needs
to improve their attitude and responsiveness regarding QA/QC.
Preventive maintenance (PM) remained a strength. This is a com-
bined effort of MCF and the Plant Materiel department under Plant
Operations. PM schedules are computerized and generally strictly
adhered to. Maintenance histories are kept on all important-
to-safety pieces of equipment. Predictive maintenance has not
been instituted and should be investigated as a potentially
useful tool, especially in light of the age of the plant. Addi-
tionally, investigation into increased secondary side PM should
be initiatei.
A concern that arose during this evaluation period evolved from the
identification of original construction installation discrepancies
associated with the mounting of 80 of 137 hydraulic control units
(HCUs). Follow-up investigation determined that the deficient in-
stallation resulted in the eighty HCUs not meeting seismic require-
ments and a significant Technical Specification violation in that
these HCUs were never operable by Technical Specification definition.
Additional plant construction discrepancies were identified by NRC
inspections of licensee action to address Bulletins 79-02, 79-14, and
80-11. Because the expertise required to identify these types of
. discrepancies resides mainly in MCF, it is incumbent upon MCF per-
sonnel to identify questionable installations for evaluation of their
acceptability.
, ..
21
In summary, overall performance during this assessment period improved.
The licensee focused a significant amount of attention and resources
on MCF, These efforts met with success at the upper levels of manage-
ment and, in turn resulted in better overall control of MCF activities.
Regarding outage work, MCF realized the benefits of front end engineering,
preplanning, prestaging, work scope control, and improved control of
contractors. Corrective maintenance kept up with the immediate problems
but was not able to make much progress on reducing tne backlog. The
newly instituted system of identifying and prioritizing work orders
has proven to be useful, not only for keeping track of the large volume
of work orders, but also for identifying their large volume to upper
levels of management. Efforts to fully implement the WMS, Station
Information Management System, and PMT should continue. Areas where
continued improvement is needed include performance of lower level
management and craft, workmanship, communications, rework control,
procedure compliance, contractor control, housekeeping, and respon-
siveness to QA/QC.
Conclusion
Category --
2
Board Recommendations
Licensee:
--
Continue to improve compliance with procedures, quality and
effectiveness of supervision and craft, control of rework, craft
training, contractor control, workmanship practices, internal
and external communications, and attitude and responsiveness to
QA/QC. Additionally, stress to all personnel the importance of
asking questions about the acceptability of installations that
appear questionable and be responsive to these questions.
--
Reduce the backlog of outstanding work and provide resources to
accomplish this.
--
Increase efforts to identify and upgrade secondary side items
that have the potential to impact the primary side and address
the overall plant equipment aging problem.
NRC:
None
.- ,
22
D. Surveillance / Inservice Testing (417 Hrs., 8%)
The previous SALP rated this area as Category 2 and identified ~
several concerns. One involved the failure to control instrument
out-of-service times during surveillance activities. This issue was
successfully addressed during this assessment period by determining,
before a surveillance is started, how long the instrument can be out
of service and by closer and more effective communication with the
control room to ensure the time is not exceeded. To minimize the
impact of the one-hour time limit, the licensee requested a. change to
their Technical Specifications to increase the time an instrument may
be out of service to two hours. Another concern involved weaknesses
in the-I & C department. This area was improved by the licensee
through a more aggressive training program. Concerns regarding
ambiguous operability criteria as contained in the surveillance
procedures are being addressed by revising the procedurer, to indicate
the appropriate criteria that must be satisfied to determine opera-
bility by the Technical Specification definition. This is a major
undertaking expected to be complete by the end of 1987. Other
concerns, including weak communications, ineffective corrective
action, and inadequate procedure reviews appear to have been addressed
but were concerns that arose primarily during restart from a long
refueling outage. Results from IIR restart activities will indicate
whether or not licensee corrective action was effective.
During this evaluation period, surveillance activities continued to
be performed satisfactorily and in a timely manner in accordance with
a master surveillance schedule. Surveillance procedures provided for
proper removal from service and restoration to service of equipment,
and assured that test results were properly documented. The perfor-
mance of individuals performing surveillance testing was observed and
found to be generally acceptable.
During the assessment period, no violations were identified by the
NRC in the area of surveillance. One instance was identified by the
licensee in which the Technical Specification out-of-service time for
an instrument was slightly exceeded. This occurred during a period
in which problems were being experienced with Static-0-Ring instru-
ments and is considered to be an isolated incident. Inspection
findings showed licensee adherence to applicable Technical Specifica-
tion action statements.
On several occasions problems were identified relative to procedures.
In general, these problems were minor and are not indicative of a
programmatic weakness in procedures.
Other deficiencies identified during surveillance testing which
require plant management attention are the inaccuracy of the instrument
that provides local and control room indication of the standby liquid
control tank (SLCT) level and the inability to establish consistent
inservice test data for emergency service water (ESW) system II.
. .-
23
The licensee's corrective actions for the SLCT problem were not
timely. Another example of slow response to problems involves
the ESW pump flow instrument which is not reliable or accurate enough
to support effective inservice testing. This problem was identified
in the previous SALP and is still not corrected. It should be noted
that Technical Support effort is required to resolve these matters.
During the operating cycle, the licensee experienced erratic
performance of the Static-0-Ring (SOR) reactor water level sensors.
Continuing setpoint drift problems eventually required a plant shut-
down to modify the instruments. The licensee's efforts to monitor
and address the setpoint drift problems were noted to be sound in
engineering judgement and conservative regarding safe plant
operation.
Six Licensee Event Reports (LERs) associated with surveillance
activities were reported. Two of these were a result of the SOR
problems noted above. Two were due to instrument setpoint drift
problems. One was the identification of a minor error in a set-
point calculation, and one was due to a procedure failing to
provide sufficient instructions for returning an instrument to
service, which resulted in an ECCS initiation. The licensee's
action to prevent or correct these problems was considered
acceptable.
The local leak rate testing (LLRT) program was reviewed by the NRC
during the period. The licensee's procedure for conducting LLRTs
was found to be comprehensive, well established, and orderly. The
LLRT results were recorded and tracked such that "as found" and "as
left" results were easily distinguishable. Test results were
formally reviewed and approved by a single individual responsible
for LLRT. Administrative control of valve maintenance was also well-
established. Test personnel were knowledgeable and well-trained in
LLRT.
Snubber surveillance activities were inspected, and it was determined
the licensee's management and staff were knowledgeable regarding
snubber surveillance requirements. The licensee made a commitment to
eliminate snubber problems by revising plant procedures to provide
clear instructions and sketches which ensure proper installation and
testing of snubbers. This was accomplished. Procedures displayed
sound technical judgement, reflected plant experiences, and
incorporated licensee commitments to prevent recurrence of problems
previously encountered. The licensee's willingness to discuss and
commit to snubber Technical Specification (TS) changes to assure
compliance with NRC Generic Letter 84-13 demonstrated responsiveness.
Licensing personnel, including corporate office and site personnel,
were thoroughly familiar with the snubber TS amendment request and
provided supplemental data to clarify several TS provisions.
. - - - - - - _ _._
.. .
24
In general, inservice inspection (ISI) activities were found to be
well planned and performed according to applicable regulatory
requirements and procedures. The documentation reviewed was complete
and legible. Those technical issues addressed were resolved expe-
ditiously and in a technically conservative manner. Throughout NRC
inspections of ISI activities, _ responses to NRC requests were timely
and complete. Also, the licensee completed induction heat stress
improvement (IHSI) of Class 1 stainless steel weld joints and post .
IHSI ultrasonic examination to establish new baseline data. GPUN
technical data reports (TDRs) No. 571 and No. 657 define the require-
ments and background for activities of inspection and mitigation of
IGSCC. These reports indicate engineering and management involvement
in evaluation and resolution of plant mechanical equipment (piping)
problems. The good quality of the licensee's program for the ultra-
sonic examination of IHSI welds was, in part, a result of the
management decision to use an Ultra Image System and independent
Level III individuals to perform an overview analysis of the GE data
evaluation and disposition process. Additionally, the licensee's
documented review of vendor NDE personnel qualification /certificattoa
records was very thorough.
In general, surveillance, IST, and ISI activities were performed
satisfactorily with adequate management attention in the areas of
procedure preparation, review, and adherence. Technician training
is improved and appears to contribute to proper performance of sur-
veillance activities. The problems identified associated with
procedures were promptly resolved. The licensee's identification,
evaluation, and resolution to the SOR problem was considered to be
very good. Action should be taken to restore SLCT level indication
to a functional status and install a flow measuring device in ESW
System II.
Conclusion
Category -1
Board Recommendations
None
,_, ._
.. . .- . . -. - - . _ - . _ ~ - . .
'
, . .-
25
$
E. Emergency Preparedness (267 hrs., 5%)
4
Analysis
During the previous assessment period, the licensee was_ rated _as
2
Category 1 in this area. Strengths were noted in responsiveness to
NRC initiatives, management participation in exercise activities as
- well as planning and control of exercises. Also, the activation of
a new Technical Support Center occurred during the last assessment
h. period. The licensee's performance during the 1985 exercise demon-
strated management involvement and emphasis in maintaining a high
- level of emergency preparedness. No-significant deficiencies were
identified. The staff's performance reflected.a high level of
,
,
training and readiness to respond to emergencies.
!-
During.this assessment period, the licensee maintained a strong
-emergency response preparedness capability. There was one announced
- inspection of emergency preparedness activities consisting of obser-
vation of a full participation exercise on April 9, 1986. Licensee
responsiveness to NRC initiatives was demonstrated by the attention
i
given to.the NRC critique of the scenario. The licensee made appro-
priate changes to the scenario and to supporting data to satisfy NRC
concerns in a timely and thorough manner. The revised scenario tested
major portions of the emergency plan and its implementing procedures
and provided an opportunity for licensee personnel to demonstrate
those areas previously identified by the NRC as in need of corrective
actions. All such problem areas identified during the 1985 exercise
were corrected and did not recur during the 1986 exercise.
During the 1986 exercise no significant deficiencies were identi-
fied, however, eleven relatively minor areas were identified for
4
'
improvement. Throughout the exercise, established policies and
procedures were strictly adhered to, Emergency Action Levels (EALs)
were correctly identified, and appropriate and timely protective
action recommendations were formulated. The licensee's performance
L during this exercise demonstrated a' highly developed level of
emergency preparedness. Technical Support Center performance was
excellent. The licensee's emergency preparedness administrative
,
staff numbers six including an SRO-certified staff member and a
! senior health physicist. The manager assumed his position during
l February 1985 and appears to be aggressively pursuing problem
resolution.
,
During Hurricane Gloria, power was reduced to 35% (a precaution that
would simplify plant response in the event of an unplanned turbine
[' trip during the hurricane), an Unusual Event was declared, the Tech- t
nical Support Center was manned and shift staffing was increased. No-
l action was required for Hurricane Charley due to its path.
'
In summary, licensee performance remains strong in this area, and
sufficient management attention is being provided.
l
!
l
.
-
. , . - .~ ~ . _ . _ _ . ,_ _ _._ _ _ _ _ . . . . _ . . . _ _ _ _ _ _ . _ , . _ _ _ . . _ _
.. .
.
26
i
Conclusion
Category - 1
Board Recommendations
None
. _ ._. . _ _ . _ _ _ _ _ _ _
. .
27
F. Security and Safeguards (140 hrs. , 3%)
Analysis
In the previous SALP, this area was rated Category 2 and three
security program implementation concerns affecting guard performance,
compensatory measures and access control were identified. Additionally,
the licensee was in the process of effecting improvements in preven-
tive maintenance support for security equipment and systems. During
this assessment period, improvements in all these areas were noted.
No violations of program requirements were identified during two
routine physical security inspections, one material control and
accountability inspection, and continuing inspections by the NRC
resident inspectors. Both plant and corporate security management
exhibited a strong interest in, and influence on, the security
program at Oyster Creek. This was demonstrated by the licensee's
planning and budgeting for the gradual upgrading and/or replacement
of security program systems and equipment. Many improvements were
made and/or initiated during this assessment period and a major
upgrade of the perimeter intrusion system is scheduled for completion
by December 1987.
Corporate security management continued to be actively involved in
all site security program matters, e.g., staff assistance visits,
human resource allocations, program appraisals, and direct support
for the budgeting and planning processes affecting program
modifications and major upgrade plans. This involvement is viewed by
NRC to be attributable to the establishment, in early 1984, of the
corporate position of Nuclear Security Director. The incumbent of
that position has been effective in providing the necessary corporate
attention to and direction for the program, in addition to oversight
of program implementation. Key security management personnel are
also actively involved in the Region I Nuclear Security Association
and other groups in innovations in the nuclear plant security area.
A new initiative implemented by the licensee's corporate security
management during this period was the development of an audit team
comprising experienced security management and supervisory personnel
from other NRC licensed nuclear power plants. This team approach has
been successful in providing licensee management with a new and
in-depth perspective of program implementation and compliance with
NRC requirements. This approach also provides cross fertilization
among licensees that should result in improved performance, effec-
tiveness and efficiency of security operations. These audits are
reinforced by comprehensive formal quality assurance audits and by
on-the-job performance evaluations conducted by site protection
program supervisors. This combination of techniques demonstrates a
significant management initiative to promptly identify and resolve
program weaknesses and provides evidence that the licensee desires to
attain a high quality security program. It also appears to have been
effective in improving the performance of the security force.
_ _ __ ___ . - _ _ _ - _ - _ _ _ _ ___ __-__ __ _ ___ -___ _ _ _ _____ _ _ __
.
. .
28
The licensee. submitted six security event reports during the assess-
ment period,'in accordance with 10 CFR 73.71. One report involved
the receipt of a bomb threat, four reports involved equipment failures
'and the other identified an access control problem with a contract
worker. These events were promptly reported and the written reports
were adequate, but could be clearer to ensure a full understanding of
the circumstances. The four events that involved equipment problems
should indicate to the licensee the need to upgrade the affected
equipment expeditiously. In the interim, however, and because the
licensee's implementation of compensatory actions was not always
timely when these equipment failures occurred, the licensee must be
'
prepared for such failures and must ensure that adequate plans have
been developed to implement prompt and effective compensatory actions,
including the posting of security force members, when necessary.
As a result of an NRC identified concern regarding the handling of
badges at the issuing point, the licensee made some physical changes
to improve this aspect of the access control program. While these
changes apparently eliminated the concern during routine conditions,
continued attention is warranted to ensure that these changes are
adequate for all conditions.
Staffing of the licensee's security organization was generally
adequate. However, due to the susceptibility of some equipment to
failure (as noted above), additional manning may sometimes be
necessary to ensure effective and timely compensatory actions. The
licensee should continue to review the need for contingency manning.
The security officer training and requalification program is well
developed and administered by two full time instructors. The new
initiative of on-the-job performance evaluation, which tests an
individual's proficiency level on general operational security
program criteria and on specific security officer positions, has
proven effective as a management / supervisory tool with which to
measure the effectiveness of the security training program. This
technique provides a continuing capability for management to review
the performance and knowledge of security personnel and to correct
deficiencies as they are detected. Additionally, it provides bene-
fits in terms of feedback on morale and performance. Implementation
of this technique provided further evidence that the licensee desires
to establish a quality program.
During this assessment period, the licensee established a preventive
maintenance support group for the security program systems and
equipment. The need for such a support group had been identified in
two previous li casee audits of the program and in the previous NRC
SALP. This group's function is to evaluate the maintenance require-
ments for the various security program systems and equipment and to
carry out those maintenance activities that can be performed on-site
and oversee those performed off-site. The group appeared to have
_ _ _ - _ _ _ _ _ _ _ _ _
. .
29
developed a comprehensive plan for accomplishing its tasks and was
staffed with qualified individuals. However, the NRC did not have
an opportunity to assess the effectiveness of the group during this
period.
Security facilities and spaces were adequate and well maintained.
Records were readily retrievable, complete and centrally located for
ease of use. Members of the security force exhibited a good
appearance and a professional demeanor.
In suxnary, the licensee initiated and/or made several improvements
and impicmented several innovations during this period that should
significantly improve the security program, if given continued
attention and oversight by management. The timely completion of work
projects associated with several licensing issues, as well as a
continued demonstration of improvements in quality in the submittal
of licensing changes will further enhance the overall effectiveness
of the security program. There was ample evidence during this period
of the licensee's effort to improve the program, however, the process
of bringing about improvements and sustaining them in this area
historically has been weak,
Conclusion
Category -
1
Board Recommendations
Licensee:
None
MC:
--
Continue basic inspection program throughout the next assessment
period to determine whether the licensee's performance, as
demonstrated during this assessment period, continues.
.' .
30
G. Outage Management / Refueling (301 hrs., 6%)
Outage Management
The previous SALP rated this area Category 2 and identified several
weaknesses in outage control including delays in receipt of equipment,
mismatches of resources and workload, interdivisional interface
problems, control of contractors, and a large Incomplete Work List
at the conclusion of the 10R outage. The licensee was aware of
these problems and had implemented corrective action programs at the
end of the 10R outage.
During this evaluation period, there was a one-month environmental
qualification outage and a scheduled six month refueling outage. The
effectiveness of the corrective action programs and inspector con-
cerns are discussed below under the subheadings of Planning and
Scheduling, and Control and Implementatinn. Information discussed
in other functional areas of this report is used as part of this
evaluation.
Planning and Scheduling: To improve outage planning, a long-range
planning group was formed in Technical (Tech) Functions. Its function
is to aid in determining, prioritizing, and scheduling future work,
f
Benefits from this recent long-range planning initiative were-evident
in both outages during this assessment.
The onsite planning process that results in job packages cannot move
effectively until engineering work is complete. Efforts have been
made by Tech Functions to improve timeliness and quality of engi-
neering to facilitate timely issuance of job packages. This effort
was notably successful for 10M. Although improved over 10R, 11R
was not as successful as 10M. The timely issuance of job packages
to accomplish work not in the original scope of an outage is a
problem. This is generally hampered by the effort required to
obtain resources and indicates a lack of contingency planning.
Another problem involved the impact of Technical Specification
requirements on planned activities. During the 10M outage, it
was necessary for the licensee to request an emergency change to
the Technical Specifications to accomplish equipment installation.
Efforts in the preliminary planning stage could prevent this type
of problem. .
A concern expressed in the previous SALP involved a procurement
problem that resulted in unavailability of parts when required. This
problem did not recur to any major extent during either outage and is
indicative of effective planning in that area.
A joint effort between the licensee and NRC is underway to establish
an Integrated Living Schedule. This initiative should enable both
parties to establish a mutually agreeable plan for accomplishing work
activities.
t
I
,
l
. - - . .
_
. _ - - -. .-. . . .
,. .
, 31
During both outages schedules were routinely issued that accurately
reflected the critical path and correct work sequence. The 10M outage-
scheduling was relatively straightforward and required little change.
In contrast the 11R schedule underwent many changes due to work scope
changes that resulted from new work and cancelation or deferment of
scheduled work. Daily meetings were attended by GPUN divisions to
discuss problems and update the schedule. These meetings were
chaired by the Outage Manager who performed well in coordinating
input from all divisions and keeping track of the many support
activities. The schedules were generally realistic.
Control and Implementation: The corporate commitment to planning.
and scheduling was evident during the 10M outage but not as evident
during 11R. One of the keys to success of 10M was a management
decision to borrow proven performers from their permanent positions
and place them in temporary positions within MCF to ensure expertise
at all levels of the outage organization. This action was not taken
to the same extent for 11R. Most of the strengths and weaknesses
involving implementation are discussed in the Maintenance functional
area. Occasionally, poor timeliness of feedback of information or
feedback of inaccurate or incorrect information affected work
activities. This feedback was between divisions or between-craft,
supervision, and upper management. Establishment of a 24-hour senior
management watch bill towards the end of the outage helped improve
the accuracy and timeliness of feedback on site.
Control of work scope was the major emphasis placed on both outages.
It was generally successful although difficult to accomplish in 11R
because of the many unexpected findings that required resolution
prior to restart. To compensate for added work scope that affected
the outage, the licensee put extra manpower on more shifts. In
addition, a " rolling forties" work week was implemented for several
types of craft personnel that resulted in 24-hour, seven day a week
coverage with no overtime. Continued emphasis is needed to match
work load and resources. Control of the contractor work force was
another major concern of the previous SALP that was in general
successfully addressed. Problems still remain, however, with delays
in badging and entry into the RCA through the dose assessment system,
poor productivity and workmanship, manpower loading peaks that are
too high for support organizations to handle, and inadequate con-
tractor supervision.
Completion of documentation packages and the turnover process was
completed in time to support restart from 10M. There were problems
with completed and signed off documentation, however, that indicated
document control was not of consistently high quality. For example
QC inspection reports documenting inspections of electrical activ-
ities could not be reconciled with the data contained in the master
copy of the controlling procedure. Turnover of documentation at the
end of the 11R outage was slow and indicated a major effort to
complete the process would be needed to support restart. This type
' '
- -
', p s
h' * ' ~~~
~
, . !
'
.
-
_
.
,\
,'% '_.
' ~.
32
.m 'h .
~
u
v
ofanefforthas,inthepast,resultedindeficientdocubentation. -
Control of radiation exposure to meet the intent of ALARA was not ' /ID
successful as discussed in the Radiological Controls Yanctional area. ~
.
The Outage Manager was aggressive in controlling work. assignments for ,. a
work that was not clearly the responsibility of a 'Eorpor' ate division. ,
'
The unwillingness of division personnel to accept responsibility for
an assignment not clearly within their division's workscope continued
'
to be a problem as discussed in the previous SALP. Cooperation ' "
- i-
improved during this period and efforts to continue the-improvement -s
should be sustained. '
/
Refueling: ,
The key events related to refueling were total defueTi.cq of the core,
sipping of all removed fuel assemblies to be reloaded-into_ the core,
inservice inspection of reactor vessel internals, shufflingecontrol
rod blades, underwater repair of a steam dryer baffle plate support
weld, replacement of nuclear instrumentation, reloading' the core, and ~-
shutdown margin testing. Review of refueling activ'ittes. indicated -
' '
that the procedures were adequate, the personnel were w61i trainsd, ~es
and the activities were carried out in accordance with approved ,% ,
procedures. Ongoing QA coverage appeared adequate. _ Plant nianagement / ',
was directly involved in day-to-day refueling activities and'a
comprehensive refueling certification program was implemented to ' - "' J
ensure-all prerequisite work was completed prior tu commencing
refueling. The large amount of work activity on the refueling floor
during the 11R outage was coordinated effectively by a management-
appointed coordinator.
Performance of many of the activities conducted as part of the
- overall refueling evolution was hampered by breakdown.of equipment
and tools. For example problems were encountered witli'the fuel
grapple, the reactor vessel stud detensioning devices, the refueling
bridge, and various tools associated with operations on core
internals. The licensee had taken steps to ensure;all these items
were functional prior to the outage. An evaluation of this situatinn
'
should be conducted by the licensee to determine additional action
required to minimize breakdown problems.
During the fuel sipping evolution, a unique set of circumstances
resulted in radiation streaming that set off various alarms'on the
refueling floor and around the plant. This event is discussed in -
the Radiological Controls functional area. The licensee critiqued ~
this event and several corrective steps were taken, however; the
underlying attitudes that resulted in the incorrect reaction to '
-
this problem could surface under a new set of circumstances.
Management's expectations of plant personnel as perceived by plant
personnel should be investigated to ensure there is no misunder -
standing regarding the importance of nuclear safety when there is
an emphasis on completing an evolution that may be behind schedule.
~
,
f
_,..m. . -, . ,, - -
_ - . _ ,
c
. .
33
In summary, outage management continued to improve. Emphasis on
controlling work scope was a key reason for this improvement. The
long-range planning effort should result in continued control of
work scope. Tech Functions upgrading of the quality and timeliness
of engineering for planned outage activities was important and these
efforts need to continue. Contingency planning needs to be improved.
Emphasis should be placed on timely and accurate feedback of
information from the field to its ultimate destination. Better
understanding should be developed regarding scope of responsibilities
and accountability for delayed corrective actions. Additionally,
emphasis on control of documentation flow and ALARA should continue.
Refueling should continue to be conducted in the controlled fashion '
it has been. Improvements in performance of support equipment would
be beneficial. Workforce perceptions of management's goals should be
investigated and clarifications made where appropriate.
Conclusion
Category - 2
Board Recommendations
Licensee:
--
Improve contingency planning.
--
Continue efforts to match resources and workload.
--
Investigate and clarify workforce perceptions of management's
attitude regarding safety versus schedule.
NRC:
None
-- - -- .- -- -. .- _- .- - - -
'ihrl
w
r
m
y n
~
'
m
34
~
H. Technical Support (968 hrs.,.19%)
The preyfous'SALP rated performance in this area as Category 2.
N'
.
This' fun 6tional area evaluates Technical (Tech) Functions and Plant
Engineering, the two key groups tasked with providing technical
support of Oyster Creek. Inspection efforts were increased in this
area to gain a better understanding of the overall structure of
technical support and because of concerns identified in the previous
SALP that justified a need to isolate technical support as a separate
'
functional area; These problems included lack of timeliness, weak
technical support, and lapses in procedural adherence. Upon a review
of this period's inspection results, it appears that only limited
progress was made towards addressing and correcting NRC concerns
raised in the previous SALP.
The timeliness concern resulted from extended delays in addressing
NRC initiatives and plant problems that have contributed to compli-
cating' plant operation. Because of a substantial backlog of work and
limited resources, technical support groups have had to establish a
priority ranking system to control the sequence of work. Prioriti-
zation ranking involves a judgement as to the importance of each work
item and those judged less important suffer, at times, substantial
delays before. final implementation. Implementation of the Integrated
Living Schedule concept should eventually result.in mutual agreement
between the licensee and the NRC regarding-sequencing of work to
reduce2 the backlog.
Concerns that technical support was, at times, weak were precipitated
by NRC inspection findings in several different areas. Inspections
of RAGEMS'(see Radiological Controls), environmental qualification,
and responses to Bulletin 80-08 and 80-11 indicated inadequacies in
technical responses to NRC initiatives. Other weaknesses became
'^
'
evident during inspector reviews of Bulletin 79-02 data, fuel
f4ilures, problems associated'with motor operated valves, adequacy
and implementation of the welding program, and resolution of various
structural concrete concerns. Additional weaknesses were evident in
the, control of vendors to whom design work was contracted and the
adequacy of drawings that formed a part of contract documents.
Adherence to approved procedures by technical support personnel was
inconsistent. Inspectors identified several examples of Tech Func-
.tions personnel not adhering to procedures that govern the design
review process. Similarly, inspector findings were made in Plant
d_ Engineering that indicated Plant Engineering was knowingly operating
M A. differently than described in' their procedures governing tasking
y and prioritization of work requests. This contributed to improper ,
prioritization of a work request regarding the acceptability of
moving heavy loads at the intake structure and resulted in this
s
priority issue not being addressed.
.
Y
e= , - .- - , .- _ _ , -
,, r ---,
__
.. .
35
The causes of the inconsistent performance discussed above
appear to be lack of management aggressiveness in making respon-
sible individuals accountable, weak technical expertise, poor
control'of vendor work, lack of comprehensive design criteria, and
poor communications. Many of these same concerns were discussed in
the previous SALP yet remain uncorrected. Management attention is
required to effect corrective actions to eliminate the inconsistent
performance.
Notwithstanding the above noted problems, improvements were made in
technical support, good initiatives were undertaken or continued, and
technical support was responsible for or contributed to many plant
upgrades and critical repairs that required timely actions. Regard-
ing improvements, Tech Functions has become more closely involved
in site activities with which they interface. This improvement was
effected by management insistence that Parsippany-based personnel
spend-more time on site in their areas of responsibility. As a
result of this, the potential for communications problems in
transmitting information was lessened and more accurate and timely
resolutions resulted. Another improvement included an overall
upgrading of the action item tracking system. Again, management
focused attention in this area and the result was more accurate
tracking, better quality and more timely responses, and improved
assignment of responsibility for action items. Additionally, a long
range planning group was added to Tech Functions to, in part, control
input of new work, develop a long range plan to prioritize backlogged
work,' and, in conjunction with NRC licensing, establish an Integrated
Living Schedule that will allow establishment of realistic goals for
accomplishment of the work backlog. Lastly, continuing efforts to
improve the design review process met with some success, i.e.,
problems have been averted as a result of thorough discussions of
proposed designs in both the preliminary engineering design and the
operability, maintainability, and constructability reviews.
The work performed by the Startup and Test Group (SU & T) is a good
example of effective and timely technical support. SU & T is effec-
tively managed, contains dedicated and well-trained personnel, and
meets the challenge of completing the test program within the con-
fines of an ever-shrinking schedule at the end of an outage. SU & T
is an aggressive organization that oftentimes identifies hardware,
software, installation, and design problems that go through the
corporate program unnoticed.
Initiatives completed or still working that represent responses to
NRC concerns or self-identified concerns include the development of a
post-maintenance testing program, continued upgrading of as-built
drawings, actions to mitigate IGSCC, upgraded emergency operating and
surveillance procedures, and formation of a scram reduction task
force.
l
..- .-
- 36
In. summary, technical support has a numbe: of strengths-and
weaknesses but mainly it is inconsistent. It demonstrates the
ability to perform quality technical work in a timely fashion in
accordance with procedures yet, in other instances, does just the
opposite. Root cause analysis of this paradoxical performance would
indicate the problem to be. management. Upper management should be
aware of this problem and should correct it by making lower level
management accountable when excessive deviations from the norm are
experienced. Assuming this corrective action was effected, there
are several other problems that have tended to bring into sharper
contrast the good and poor performances and need to be corrected.
These include inadequate control of vendors, a large backlog of
work, inadequate technical expertise, and at times ineffective
communications within technical support and between technical
support and other divisions.
Conclusion
Category 2
Board Recommendations
Licensee:
--
Undertake a self-analysis to determine the causes for
inconsistent performance.
--
Provide resources to facilitate reduction in the backlog of
work. Expedite completion of the plant specific Probablistic
Risk Assessment report and use it as a tool to aid in
prioritizing this work.
NRC:
Conduct a team inspection of technical support groups with an
emphasis on determining the causes of inconsistent performance.
. _
._ - - _ --- . _ - _ __. _ ___ . . _
- y y
V
7
37-
E ,
I. ' Training and Qualification Effectiveness-
>
Based on NRC awareness of the importance of an effective training
- . and qualification process, a new functional area has been added.for
J evaluation during the SALP. process.-- Training and Qualification -
- Effectiveness. Training ~and qualification effectiveness.still
' continues to be an evaluation criterion for each functional area.
"
The various aspects of this functional area have'been considered
- and discussed as an. integral part of other functional areas and the
respective inspection hours have been included in each one. Conse-
quently, this discussion is a synopsis of the assessments related to
training conducted in other areas. Training effectiveness has been
+
measured primarily by the observed. performance of. licensee personnel
and, to a lesser degree, by a review of program adequacy. The dis =
cussion below addresses three principle areas: licensed operator
-training, non-licensed staff training, and the status of INP0
training accreditation.
4
The licensee is committed to a program of improved training in all
i aspects of facility operation.' They are one of the first plants
,
i
to gain INPO accreditation of all ten training programs. Overall
management support of and involvement in training is evident by
4
its' support of INP0 accreditation and overall improvement in the.
4- programs. Emphasis has been placed upon not only maintaining an
p acceptable program but also continuously improving it.
- During the assessment period, NRC Operator Licensing administered
- one set of requalification and one. set of replacement operator
- examinations. Six R0s and eight SR0s passed their written requali-
( fication examinations. An additional four R0s and four SR0s were
! administered oral examinations and all passed. 'The replacement:
i operator examination resulted in the licensing of four SR0s and the
" issuance of two instructor certifications. Of all the candidates-
examined, just one failed the oral portion of the examination. A
j requalification training program inspection was also conducted by the
! NRC and no deficiencies were noted. Both the licensee's replacement
l. operator and operator requalification training programs make a posi-
U tive contribution ~to operator knowledge and understanding of the
facility.
The licensee appears to be providing operators with adequate training
L on plant changes and modifications. Effective training for personnel
i performing refueling was noted to have been performed. Also, guides,
i course outlines, and class lecture lists showed the licensee provided
. in-depth training for all TMI Action Plan training requirements.
! During this assessment period a Basic Principles Trainer was made
- ' available to improve training capabilities. Long-term plans include
the purchase and installation of a plant specific simulator. Bids
'
'
for the simulator are to be accepted during 1987. The earliest an
- operable simulator can be expected is the end of 1990.
.
. . _ ___. ,__ _ _ . . . . _ ._. __ _
~
.
1 u.
i
,
-
38
.
>
F
l- As'noted_in other sections of this report, there have been events
~
in'which operator error has occurred. Fewer operator errors would
4- have occurred had the number of operator challenges caused by
.,
'
- equipment failures been less. However, some of these errors appear
. to be a result of the licensee's inability to provide more hands-on
training due~to lack of a site-specific simulator and an occasional
-
. lack of understanding of the importance of adhering to requirements.
. There also appears to be a need for overall improvement in shift
b management's_ ability to recognize and fully consider all safety
d
aspects of an-_ issue and then act decisively on that. issue.
'
The licensee has established a well-designed program for both class-
r
I
- room and on-the-job training for in-house electricians, mechanics, ,
and instrument and control-(I & C) technicians. It was noted that
L - the backlog of I & C outstanding items was reduced due, in part, to
- improved I & C technician training. - The I & C technician program has
been generally _well-received by the I & C technicians.and supervisors
, and, as a result, has shown early success. The electrician and
mechanic program has as yet not experienced this early degree of
- success-due to a lack of supervisory enthusiasm in implementing the
i program and also the heavy work load. Added management emphasis-
appears to be required to help the program succeed.
'
Along with improved training, new GPUN craft personnel are screened
by an examination process prior to being hired by the company. Also,
GPUN screens contractor employees' resumes before allowing' contractor
-
- management to employ an individual at Oyster Creek. The overall
success of these programs will be measured-in the long-term-if_a
i - general improvement in performance is noted, however,. only minor
. improvement has baen observed during this evaluation period. In an
effort to further upgrade craft and supervisory personne1' perform-
- ance, the licensee has initiated an informal control which identifies
, rework and determines root cause, corrective action, and lessons
learned. This is an additional attempt by the-licensee to-identify *
, areas _where further training would serve to improve the quality of.
I work performed. The effectiveness of this effort is not yet evident.
!.
Radiological Controls had committed in their response to the previous
SALP to formalize in-house radiological engineering training. This
training program was, however, changed from an Oyster Creek project
< to a corporate responsibility. This has caused an indefinite delay
l
in its implementation. Based on weaknesses in the ALARA program
l implementation as discussed in this report, this training program
[ should receive more management attention to establish an
implementation date.
'
i
The security officer training and requalification program is well-
developed and administered. The new initiative of security personnel
4: on-the-job performance evaluation has proven to be effective as a
l'
'
management tool to measure the effectiveness of the security training
program. Also, the licensee's staff performance during a full par-
1
ticipation emergency preparednesss exercise reflected a high level
of training and readiness to respond to emergencies.
,
g >,r-y y , e ee-ve --t u--&- v - ry e t
. .
39
As part of-an overall program to improve management performance,
GPUN had 24 corporate officers attend a special three-day team-
building seminar conducted by a consultant. Plans are to enroll
additional employees in this course, including some onsite management.
These seminars may have the effect of improving cooperation and
communication among the various divisions involved in facility
operation.
In summary the licensee has established a functional training
facility that is well-staffed and capable of providing good opera-
tor requalification and STA training programs. Adequate attention
appears to be given to training operators on plant changes and
modifications. Well-designed programs have been established and
partially implemented to improve the capabilities of electricians,
mechanics, and I & C personnel. Means of improving these programs
are continuously being pursued, including bringing in various vendor
personnel to provide specific training. An overall attempt to
improve the quality of new hires and contractor personnel has also
been initiated. Efforts are in progress to provide team-building
management training which is intended to improve management
performance.
Conclusion
Category - 1
Board Recommendations
Licensee:
--
Expedite acquisition of plant specific simulator. In the
interim, attempt to develop other means of improving the
practical, operational focus of training.
NRC:
None
. .
.
40
J. Assurance of Quality
Management involvement and control in assuring quality is being
considered as a separate functional area for the first time and
continued to be an evaluation criterion for each functional area.
The various aspects of the Quality Assurance program 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
relating to quality work conducted in other areas and is not solely
an assessment of the quality assurance (QA/QC) departments.
The Oyster Creek overall organization is relatively new and is a
matrix type organization with QA/QC being part of one of seven
'
divisions responsible for safe operation of the plant. This type
of organization relies primarily on the quality consciousness of
each division manager to assure quality within his division. The
need for quality is obvious and is a goal of all division managers.
To augment the quality consciousness of management, the organization
provides a QA/QC department. In discussions with NRC, division
management expresses a commitment to quality. Inspector observations
have not identified any consistent trends that would tend to refute
this position. As regards the effectiveness of the QA organization
to help keep quality in the forefront, it appears they are generally
successful.
In assessing how the licensee assures quality, the SALP board has
considered various attributes normally considered key contributors
to the assurance of quality. Among the attributes considered
are implementation of management goals, planning / control of routine
activities, worker enthusiasm / attitudes, management involvement,
staffing, and training. Licensee management addresses these
attributes in a positive way. A quality issue facing the licensee
is the lack of quality requirements that existed during original
plant construction. This coupled with the aging of many components
has resulted in establishing a large work backlog and strain on the
resources necessary for plant operation. The following paragraphs
discuss examples of strengths and weaknesses within various licensee
organizations that relate to one or more of the contributing elements
that affect quality.
GPUN responded to the previous SALP report with commitments to
improve their performance in the QA/QC area. One concern involved
the effectiveness of the safety review process which the licensee
committed to review within three to six months after implementation
of the revised safety review procedure. This has not been accom-
plished as the revised procedure was not approved until September 1,
1986.
- _ - _ _ - . .-
-. - . - . - .-. . . - -
. . l
41
A NRC special review of MNCRs, QDRs, and QA audit findings was
conducted in an effort to evaluate a commitment to improve the ,
timeliness and aggressive pursuit of resolution of QA/QC findings. I
While this review indicated that there is a reluctance to implement
the escalation process when conditions dictate, it also revealed a
majority of the responses were timely. QA has taken some initia- .
tives to assist management with root cause identification to l
resolve deficiencies. It appears that management effort to assess '
and correct root cause deficiencies is directly proportional to the
perceived significance of the findings. QA should strive to focus
more clearly on significant safety issues -- certain QA findings
involved minor administrative details. Generally, there has been
improvement in the areas discussed in the licensee SALP response
letter, but continued management attention is required to continue
the improvement.
The Maintenance, Construction and Facilities (MCF) division has
made substantial changes to improve their performance since the
last SALP assessment period. They have added experienced personnel
to key management positions, initiated programs to improve super-
visory performance, continued with craft training programs,
encouraged cooperation between all interfacing divisions, adopted
a more professional approach to the management of their own and
contractor personnel, and demonstrated a concern for improving
overall performance. Areas in which improvements were not as evi-
dent included implementation of a post maintenance testing program,
timely response to QA/QC concerns, control of contractors, pro-
cedural compliance, and control of documentation. Additionally,
cleanliness during outages was erratic, worker attitudes were
oftentimes poor because of the many restrictions and controls they
face that prohibit them from efficiently accomplishing a job,
attention to detail and communication were found lacking in several
instances, rework accountability programs were not uniformly imple-
mented, timely reduction of the work backlog was not evident, and
ALARA was not as effective as anticipated. A lack of professional
curiosity was evident that appeared to result from the knowledge
that a satisfactory response to a query would be long in coming due
to the large work backlog. MCF management needs to continue with
their improvement programs in order to achieve a sustained improve-
ment and a broader realization of their concern for assurance of
quality.
Technical support performance was inconsistent in technical adequacy,
timeliness, willingness to accept responsibility, adherence to pro-
gram requirements, attention to detail, communications, cooperation
between divisions, responsiveness, and accountability. In the past
the licensee has had problems in submitting Licensee Event Reports
(LERs) in a timely manner. Improvements have been made in this area
and LERs are now generally submitted on time. One deficiency still
remains and that is the submittal of follow up reports to LERs.
Also, on a number of occasions responses to violations have not been
_ _ - - - _ - _ _
. .
42
submitted within the time required. The inspectors did not perceive
the same degree of licensee attention and concern for assurance of
quality within technical support that was evident in other functional
areas. Management effort is needed to sustain the areas of good
performance and improve the weaknesses to better assure quality in
the area of technical support.
Plant Operations, by its nature strives to assure quality mainly by
maintaining a strong operating staff, conducting effective training,
maintaining and adhering to good procedures, paying attention to
detail, and fostering effective communications. They are generally
successful at this, although they had several problems that indicate
room for improvement. Plant Operations management realizes that
quality impacts power production and, therefore, appears to have a
more full appreciation than other divisions as to the benefits of
assuring quality. Backshift tours by maragement have been
established to identify areas requiring improvement.
QA/QC at Oyster Creek plays an important role in assuring quality in
that it is the group that attempts to ensure other divisions neither
relax their approach to quality nor compromise it for other competing
factors. They are generally successful, due in large part, to an
overall corporate stance that endorses quality. Within the QA/QC
organizations, permanent licensee personnel are generally committed
to understanding and following the requirements of the quality
program. Personnel weaknesses with QC appear mainly during outages
when temporary help is used to carry the extra workload. Violations
were identified during this evaluation period that indicated problems
in this area. Weaknesses appeared in the quality organization in the
welding program and in structural weld inspections. These were due,
in part, to unclear program requirements, inadequate standard forms
used to record inspection results, and a weakness in QA inspectors'
understanding of structural weld codes. NRC inspector reviews of QA
audits and Quality Deficiency Reports (QDRs) indicated a reluctance
to escalate when lack of timely response required it. More rigid
adherence to escalation procedures is required. Also some of the QDR
findings have been somewhat trivial in nature which could explain, in
part, the problem of untimely responses to these documents from other
divisions.
The quality assurance organization has undergone some program changes
that should prove to be beneficial for the onsite organization.
Notable improvements have included (1) the use of technical special-
ists to assist site auditors during technical inspection activities,
(2) the performance of a system functional audit, (3) increased
quality control inspector training to improve infield awareness,
(4) the use of an independent Level III inspector to perform overview
analysis of contractor evaluation and disposition of ISI data, and
(5) an in depth review of vendor NDE personnel qualification /
certification records.
. .
43
One of the_ keys to an effective quality organization is
inquisitiveness. The quality program at Oyster Creek needs to
provide for more effective independent inspection throughout the
organization. The licensee has taken steps to move people into
QA/QC who have a good working knowledge of plant operations and
technical support. These changes should provide the ability for
more effective independent inspection if the flexibility in the
quality program allows it.
The licensee's corporate awareness of quality is particularly demon-
strated by an effective General Office Review Board (G0RB). NRC
inspection of the GORB determined the program established for the
GORB was in accordance with the license requirements and commitments.
The GORB was adequately staffed by licensee employees and contained
outside expertise. Provisions were in place and functional for
assuring that the GORB received information responsive to its
charter. The GORB Committee was thorough in its review of licensed
activities under its cognizance and its recommendations were well
formulated, received prompt attention from the licensee's staff, and
were acceptably closed out.
In summary, the assurance of quality is a stated commitment of Oyster
Creek and GPUN corporate management. Based on inspector observa--
tions, it is evidenc that this is a serious commitment. The various
organizations that participate in the safe operation of the plant
strive to assure quality through positive approaches towards those
attributes that contribute to quality. The results of the licensee's
efforts are generally successful. Improvements in various areas as
discussed throughout this SALP report are needed to continue and
improve upon this success. Management attention should be particu-
larly directed towards improving technical support, reducing the
large backlog of work in both MCF and technical support, and
improving timeliness and quality of response to communications
within and between divisions.
Conclusion
Category -
2
Board Recommendations
Licensee:
--
Reduce the number of trivial QA/QC findings that other divisions
must respond to and continue to upgrade the professionalism in
QA/QC.
--
Strengthen interfaces to improve the performance of the matrix
organization.
NRC:
None
. _ .
. - - - - . .
, .. .. . _ - - -_
. .
44
K. Licensing Activities
During the previous SALP period, the licensee was rated as Category 2
in this functional area. The previous SALP identified the need for
more management involvement in the decision on the dates to respond
to licensing actions and in meeting these dates.
During the current SALP period, 128 licensing actions were under
review and are partially identified in Table 8. Of these, 66% were
completed. The majority of these were complex and difficult. Fifty
licensing actions remained at the end of the SALP period. The
licensee also submitted 8 changes to its Safeguards Plan in accordance
with 10 CFR 50.54(p) and NRC completed its review of a Security Plan
change submitted during the prior SALP period.
The significant licensing actions completed in the SALP rating period
include the following: three emergency Technical Specification (TS)
amendments, exemptions to Appendix R, alternate shutdown capability,
deferment of SPDS implementation and of completion of Mark I Contain-
ment Confirmatory Order to the Cycle 12 outage, cancellation of
replacement of containment purge / vent isolation valves, deferment of
feedwater nozzle inspection to Cycle 12R outage, Safety Parameter
Display System review, Detailed Control Room Design Review, Safety
Issues Management System (SIMS), retyped Appendix A TS, high point
vents on the isolation condensers, control room habitability, maximum
drywell temperature, and completion of four old MPAs.
The licensee has generally shown prior planning and assignment of
priorities in licensing and security activities. This has been shown
in the good working relationship between the NRC Project Manager and
the licensee. This is also shown in the licensee's above average
response to SIMS; the active participation in the NRR utility
contacts meetings; the work to complete the Appendix R modification
before plant restart from the Cycle 11R outage; the completion of
10 CFR 50.49 in the voluntary one-month outage in October 1985; the
shutdown to replace Static-0-Ring differential pressure (SOR dp)
switches in 1986 and the later replacement of these switches by an
analog trip system in the Cycle 11R outage; and the review of the
supports for the drywell piping penetrations. In addition, there
have been several Licensee Event Reports (LERs) on equipment found,
in the Cycle 11R outage, not built to design, where the licensee has
voluntarily upgraded the equipment in the outage.
Licensee management has worked to have good communication with the
NRC staff and participated in a significant number of meetings in
Bethesda on short notice. With this involvement, there has, however,
been two emergency TS amendments for the Cycle 10M outage; the poorly
prepared for meeting in 1986 on the integrated schedule; the late
submittals on several issues involved in the plant restart from
, .-
45
the Cycle 11R outage; and the requested deferment of the isolation
condenser makeup pump from the Cycle 11R outage. With good manage-
ment involvement and control, these should not have happened.
The licensee's Oyster Creek Licensing and Regulatory Affairs (0CLRA)
staff has worked constructively with the NRC staff throughout the
SALP period. This is one reason for the large number of licensing
actions completed in this period. The problem discussed above with
the licensee management includes a problem between the licensing
function and the engineering function of the licensee. This problem
is illustrated when the licensee interacted with the staff in 1986 on
the issue of a schedular exemption to 10 CFR 50.48 and Appendix R.
The licensee management in Technical Functions appeared to attempt
to involve the staff management prematurely, i.e., prior to com-
pleting sufficient engineering to provide a basis for a schedular
exemption. This was after a meeting had already been arranged for a
later date to discuss the exemption after sufficient engineering was
completed. The OCLRA appeared to be used in a manner which showed an
apparent conflict of interest between the licensing function and the
engineering function of the licensee. This resulted in a letter to
the licensee on March 17, 1986 and a response from the licensee on
March 24, 1986. However, since the letters, the relationship between
NRR and the licensee has returned to the relationship that existed
before and the licensee will complete all Appendix R modifications in
the Cycle 11R outage before restart.
The licensee has generally demonstrated a good understanding of the
technical issues involved in licensing actions and has generally
proposed technically sound, thorough, and timely resolutions to
these issues including security activities. However, there were
two issues, requesting a containment leak rate testing TS change
and requesting no high radiation signal to containment purge / vent
isolation valves, where the licensee's approach seems to indicate
it did not understand the requirements.
The licensee has generally made timely submittals to meet deadlines.
Exceptions are the last submittal for the Appendix I TS, primary
coolant radioactivity TS, TS Change Requests for the Cycle 11R
outage, responses to requests for additional information for the
Safety Parameter Display System deferment, justification for
deferring work on torus / reactor building vacuum breakers for the
Cycle 11R outage, additional exemptions to 10 CFR 50, Appendix R,
and several LER responses.
The licensee has actively participated in meetings with the staff.
The licensee has been responsive to NRR in meeting on a monthly basis
to discuss all active licensing actions including priorities and
future licensee submittals. As a result, lower priority reviews,
which had been backlogged, are being completed. There have been 28
meetings in this rating period. These meetings were generally well-
conducted, well prepared for and helpful in resolving the issues.
..
. .
46
This was especially true for the meeting on the deferment of the
feedwater nozzle inspection from the Cycle 11R outage.
The licensee has been responsive to NRR initiatives. The quality of
its "no significant hazards consideration" analyses improved signifi-
cantly in 1986. The licensee has responded promptly to several
surveys from the staff during the reporting period including a
meeting on Generic Issue 77. The licensee participated in several
BWR Project Directorate #1 (BWD1), NRR, initiatives to improve com-
munications between NRC and the licensee and among the licensee
within BWDI, NRR. These initiatives were in the utility contacts
meetings in 1986; a mini owner's group among the licensees in BWDI,
NRR to discuss commen technical issues; and the purchase of equipment
to use the BWD1 tracking system for licensing actions.
Events at the facility have been generally reported promptly and
accurately and are above average in quality. The licensee volun-
tarily provided information by reports on the erratic behavior
of SOR dp switches and on HFA relay window fogging.
During this period, the licensee's performance was generally found to
be above average. Management attention and involvement was generally
good showing prior planning and assignment of priorities but there
have been a number of issues which, with good management involvement,
should not have happened. The submittals have generally demonstrated
an understanding of the issues and have been generally technically
sound. thorough and timely. Staffing levels and quality of staff are,
therefore, adequate and communication levels between the operating
staff and management are well established and effective. The licensee
has been effective in dealing with problems and has been responsive
to NRC initiatives. A significant number of licensing issues have
been completed. The licensee's efforts in the functional area of
~
Licensing Activities has im;, roved during this evaluation period.
Conclusion
Category -
2
Trend - Improving
Board Recommendations
Licensee:
None
NRC:
None
<
,
,. .
47
V. Supporting Data and Summaries
A. Investigations and Allegations Review
During this assessment period, six allegations were received and
acted on. Four involved radiation control, one security, and one
drugs. Of the four radiation control allegations, two were not
substantiated and two were found to be partially valid and corrective
action was taken by the licensee. The security and drug allegations
were not substantiated.
At the end of the last SALP period, an investigation was in progress
to determine if there was any management involvement in licensee
staff employee lying to a NRC inspector. This investigation
concluded there was no management involvement and that the problem
appeared to be limited to the two involved employees who were
subsequently discharged.
,_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ - _ - _ _
. .
48
B. Escalated Enforcement Actions
1. Civil Penalties None
,
2. Orders None
3. Confirmatory Action Letters None
-
i
.. .. '!
, 1
.49
C. Management Conferences
Date Subject
10/28/85 SALP (219/85-99)
11/13/85 Discuss IEB 79-02 and 79-14
4/01/86 Discuss IEB 79-02 and 79-14
9/13/86 Enforcement Conference dealing with QA-
and management of contractors during-
isolation condenser piping repairs performed
during 10R outage
9/16/86 Discuss piping reverification program
9/26/86 Discuss radiation control issues
.
. _ . ..
. 5
50
D. Licensee Event Reports (LERs)
Tabular Listing
Type of Events:
A. Personnel Error . . . . . . . . . . . 11
B. Design / Man./Construc./ Install . . . . . . 12
C. External Cause . . . . . . . . . . . 2
D. Defective Procedures . . . . . . . . . 1
.c"' E. Component Failure . . . .- . . . . . . 9
X. Other . . . . . . . . . . . . . . 1
>
Total 36*
Licensee Event Reports Reviewed:
Report Nos. 85-12 to 85-26, and 86-01 to 86-22
(See Table 1 for LER. listing by functional area and Table 2 for a
LER summary.)
- LER 86-08 was not included in this count as it was a voluntary
report.
.
E
, ..
.
TABLE 1
LISTING OF LERs BY FUNCTIONAL AREA
OYSTER CREEK NUCLEAR GENERATING STATION
AREA NUMBER /CAUSE/ CODE -TOTAL
A B C D E X
Plant Operations 6 1 6 1 14
Radiological Controls --
Maintenance 2 2
Surveillance / Inservice 4 1 1 6
Testing
Assurance of Quality 1 1
-Security and Safeguards --
Outage Management / Refueling --
Technical Support 2 2
Training and Qualification --
Licensing --
Other 7 2 2 11
__
Total 36
Cause Codes:
A - Personnel Error
B - Design, Manufacturing, Construction, or Installation Error
C - External Cause
D - Defective Procedures
E - Component Failure
X - Other
. .
TABLE 2
LER SUMMARY (7/1/85 - 10/15/86)
OYSTER CREEK
LER Number Summary Description
85-12 Reactor Isolation Scram
85-13 Failure to Maintain Drywell to Torus Differential
Pressure
85-14 Unit Substatation Transformers IA2 and 1B2 Low 011
85-15 Automatic Scram on Low Condenser Vacuum
85-16 Reactor Scram on APRM Downscale and IRM Hi Hi
85-17 Drywell Bulk Temperature
85-18 Emergency Service Water Pipe Coating Failure
85-19 Non-Conservative Error in Technical Specification Setpoint
Calculation
85-20 Loss of Both Diesel Generators
85-21 APRM Setpoint Did Not Meet Acceptance Criteria
85-22 Reactor Scram Due to Main Generator Trip
85-23 Emergency Service Water System Seismic Concerns
85-24 Reactor Trip Due to High Neutron Flux
85-25 Main Steam Isolation Valve Closure Caused by Operator
Error
85-26 Neutron Flux Setpoints Exceed Technical Specification
Limits
86-01 Reactor Low Level Sensors Found out of Specification
86-02 Inoperative Containment Spray Snubber Caused by Personnel
Error
86-03 Three Out of Eight Isolation Condenser Pipe Break Sensors
Out of Specification
-. .
T2-2
86-04 Reactor Scram on Anticipatory Turbine Trip Caused by Limit
Switch Failure
86-05 Core Spray and Diesel Generator Initiation Caused by
Procedural Deficiency
86-06 Isolation Condenser Actuation Pressure Sensors Exceeded
Setpoint Limit
86-07 Reactor Shutdown Due to Reactor Low Water Level Scram
Switch Repeatability Problems
86-08 Local. Leak Rate Testing Results (Voluntary Report)
86-09 Scram Signal Received Due to Neutron Instrumentation . Noise
86-10 Inoperable Isolation Cendenser Snubbers
86-11 Secondary Containment Isolation and Initiation of Standby
Gas Treatment System
86-12 Containment Isolation and Standby Gas Initiation Caused by
Electrical Storm
86-13 Secondary Containment Isolation and Initiation of Standby
Gas Treatment System
86-14 Containment Spray System Seismic Concerns
86-15 Refueling Bridge Limit Switch Failure Due to Personnel
Error
86-16 Fuel Clad Failures
86-17 Containment Isolations and Standby Gas Initiation Caused
by Storms
86-18 Secondary Contaiment Leak Rate
86-19 Standby Gas Initiation Caused by Personnel Error
86-20 Broken Valve Disc in Control Rod Drive Hydraulic Unit
86-21 Plant Systems did not Meet Seismic Design Bases
86-22 Control Rod Drive Hydraulic Control Units not Installed
Per Design
.. .
,
,
TABLE 3
ENFORCEMENT SUMMARY 7/1/85 - 10/15/86
OYSTER CREEK NUCLEAR GENERATING STATION
A. Number and Severity Level of Violations
Severity. Level III 0
Deviations 1
Total '. 24
B. Violation vs.' Functional Area
Functional Area Severity Level
I II III IV V Dev
Plant Operations 3 1
Radiological Controls 6
Maintenance 2
Surveillance / Inservice Testing 0
Security and Safeguards 0
Outage Management / Refueling 0
Technical Support 7 1 1
Training and Qualification 0-
Assurance of Quality 3
Licensing 0
Totals 21 2 1
Note: Enforcement action is pending on several EQ concerns
identified during this evaluation period.
_ _ . - . .
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -___
, ..:
l
TABLE 4
INSPECTION HOURS SUMMARY (7/1/85 - 10/15/86)
OYSTER CREEK NUCLEAR GENERATING STATION
HOURS % OF TIME
l
Plant Operations 1971 38
Radiological Controls 478 9
Maintenance 647 12
i Surveillance / Inservice Testing 417 8
> ,
267 5'
Security and Safeguards 140 3
Outage Management / Refueling 301 6
i
Technical Support 968 19
Training and Qualification 0 0
i Assurance of Quality 0 0
!
Licensing Not Applicable
l
?
Total 5189 -100
i
1
I
l
t.
. ___ . _ _ _ _ __
_ _ _ _ _ . - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
. .
TABLE 5
INSPECTION REPORT ACTIVITIES
OYSTER CREEK NUCLEAR GENERATING STATION
Report No.
Inspections
Dates Inspector Hours Area Inspected
85-20 N/A -
Management Meeting - Security
6/17/85 Issue
85-21 N/A -
Management Meeting - Enforcement
6/13/85 Conference
85-22 Specialist 22 Meeting and Examination of IEB
6/25/85 79-02 and 79-14 Documentation
85-23 Resident 215 Routine
7/1 - 8/18/85
85-24 Specialist 35 Security
7/22-26/85
85-25 Specialist 102 Transportation Activities
7/29 - 8/1/85
85-26 Resident 124 Routine
8/19 - 9/22/85
85-27 Specialist 39 Shock Suppressors
8/19-23/85
85-28 Specialist 66 Transformers Low 011 Level and
9/23-27/85 Fire Protection / Prevention
Program
85-29 Resident 316 Routine
9/23 -10/20/85
85-30 Specialist 28 Material Control and Accounting
10/1-4/85
85-31 Specialist 27 Inservice Inspection Data
10/7-10/85
85-32 Specialist 103 QA Program, Document Control,
10/21-25/85 Onatte Review Committees, and
Record Program
-.
. .
T5-2
85-33 Specialist 46 Radiation Control Program
10/21-25/85
85-34 Cancelled
85-35 Resident 284 Routine
10/21 -12/1/85
85-36 Specialist 254 Overpressurization of Low
11/7-22/85 (Team) Pressure ECCS Systems
85-37 N/A Management Meeting - IEB 79-02
11/13/85 and 79-14
85-38 Resident 125 Routine
12/2/85 -
1/5/86
85-39 Resident / 36 Environmental Qualification of
12/6-9, 19/85 Specialist Main Steam Sensing Devices
85-40 Specialist 8 Iodine Uptakes by Workers
12/21/85 (Special)
85-99 SALP
86-01 Specialist 201 Implementation of 0737 Items
1/13-17/86 (Special)
86-02 Resident 215 Routine
1/6 - 2/2/86
86-03 Specialist 88 Non-licensed Operator Training
2/10-14/86 and Offsite Support
86-04 Resident 171 Routine
2/3 - 3/2/86
86-05 Specialist 56 Security
2/18-21/86
86-06 Resident 373 Routine
3/3 - 4/13/86
86-07 Specialist 58 Emergency Preparedness Exercise
4/9-10/86 (Team)
86-08 Specialist 280 Qualification of Electric
3/24-27/86 (Team) Equipment
- _ _ _ _ _ _ .
,- _ - - _ _ - - _ - - - _ - - - -
. .
T5-3
86-09 Specialist 105 IEB 80-11
5/5-9/86
86-10 Specialist Requalification Examinations
5/9-15/86
86-11 Specialist 42 Fire Protection / Prevention
4/14-18/86 Program
86-12 Resident 393 Routine
4/14 - 6/1/86
86-13 Specialist 74 Refueling Radiological Controls
4/21-25/86
86-14 Specialist 80 Maintenance Program / Activities
4/28 - 5/2/86
86-15 Specialist 11 Independent Safety Reviews and
4/30 - 5/2/86 GORB
86-16 Specialist 55 Nonradiological Chemistry
6/3-6/86 Program
86-17 Resident 179 Routine
6/1 - 7/6/86
86-18 Specialist 33 Diesel Generator Modifications
6/24-27/86
86-19 Specialist 44 Welding and Inservice Inspection
7/7-11/66
86-20 Cancelled
86-21 Resident 252 Routine
7/7 - 8/17/86
86-22 Specialist Operator Licensing Examinations
8/11-15/86 and Requalification Training
86-23 Specialist 43 Ultrasonic Examination of Welds
8/11-15/86
86-24 Resident 356 Routine
8/18 - 10/5/86
86-25 Specialist 35 Refueling Activities
8/25-29/86
-_. . _ _ . _
- - . _ _ _ . ._
r
-.. .
l.
- T5-4
L.
!
l ' 86-26 '
Specialist 17. Review and Planning for
L 8/26/86 Underwater Weld Repair
86-27 Specialist 4-6 Local Leak Rate Testing and
- 9/4-9/86 CILRT Procedure-
i
I_ 86-28 Specialist 42 Review of Administrative
! 8/18-20/86 Overexposure
l 9/8-10/86
l
- 86-29 Specialist 32 Effluents and Open Items
s 9/30 -
10/3/86
!
86-30 Specialist 70 Maintenance, Calibration, and
9/30 - 10/9/86 Concrete Deficiencies
! 86-31 N/A 8 Management Meeting - Piping
9/16/86 Reverification Program
!
!
!
l~
I
l
t
I
l
l
1
- $ .; Cbc (
. o. ..j ,
e
--
'
,
,3 c
, ..
- 'y. , , ,
- . , -
f*
Table 6 c--
~
Enforcement Data
~
'
OYSTER CREEK NUCLEAR GENERATING STATI'ON
-
c.-
3 ,
Inspection Inspection Severity Functional x .
l
Report No. Date Level Area Violation
- ~
85-23 7/1 - 8/18/85 IV Plant Failure to adhere to a
Operations , station procedure
IV Plant Failure to adhere to a
Operations ' station procedure
' ~
85-25 7/29 - 8/1/85 IV Radiological ' Quality Co61.ro11of '
Controls * waste shilments i
l 85-33 10/21-25/85 IV Radiological :Transporiatidrb '
Controls fregulations,
85-35 10/21 - 12/1/85 IV Assurance of $21dingProhram
) Quality
l IV Technical Failure to provide weld -
-
l Support configuration -
- _
l
information "
IV Maintenance Modification :v
inadequacies
'
- '
_ IV Assurance of QC Inspecticas
f Quality *
l IV Radiological Failure to survey
Controls carry-along items
i
- 85-39 EQ enforcement pending .
t
'
1/6 - 2/2/86
"
86-02 IV Plant Snubb'er made~ inoperable -
Operations
3/3 - 4/13/86 Failure to maintain
~
86-06 IV Technical
Support station procedure
IV Technical Failure to adhere to
Support proaect reviews
procedtres
86-08 EQ enforcement pending
.
_
., ...
T6-2
- 86-09 5/5-9/86 V Technical Evaluation of Support
Support
IV Technical ' Maintenance of records
Support
Deviation Technical Inadequate
Support documentation to
support mortar
qualification
86-11 4/14-18/86 V Plant Failure to correct
Operations a non-conformance
86-12 4/14 - 6/1/86 IV Maintenance Inadequate work control
procedure
IV Technical Inadequate design
Support information
IV Technical Weld control precedures
Support
'
IV Assurance of Inadequate QA/QC
Quality (Issued subsequent to
SALP period following
yrp ,
enforcement conference)
86-17 6/1 - 7/6/86 IV Radiological Failure to lock
Controls entrance to high rad
area
86-21 7/7 - 8/17/86 IV Radiological Inadequate survey
Controls
86-24 8/18 - 10/5/86 IV Technical Lack of safety
Support evaluation for a
procedure change that
,
required one
86-28 8/18-20/86 IV Radiological Inadequate surveys
3. . 9/8-10/86 Controls
.
-
=,
r
. ~ . .- . - - . .- - - .
.
. - . - . - --
5; J
, e. .
..
. M'
'
_ _
,
f
n,
3
s .
1
4
j TABLE 7
i l'
7 UNFLANNED TRIPS AND SHUTDOWNS
)
Date Descriotion
~
Cause
7/1/85 Plant Operating at full power-
i
7/8/85 Reactor Scram Lov. condenser vacuum due to cracked
y , steam jet air ejector drain pump
,
.;
housing - equipment failure
"
':- 7/9/85 Startup
7/22/85 Shutdown. High Containment Spray heat exchanger i
differential pressure caused by
' , delamination
inside of emergency of coalservice
tar lining on
water
piping - equipment failure-
'
8/3/85 Startup
!. 8/9/85 Reactor Scram During shutdown all IRMs were
<
inadvertently inserted while APRM's
were downscale - operator error
'8/10/85 Startup
.10/18/85 Shutdown Month long outage for environmental
qualification modifications
11/16/85 Startup
11/20/85- Reactor Scram Reactor trip due to generator trip
resulting from a current transformer
failure - equipment failure
'
11/23/85. Startup. '
12/15/85 Reactor Scram Electric pressure regulator failed
due to a loose wire connection -
personnel error
.
12/16/85 Startup
3/6/86- Reactor Scram Turbine trip resulting from
limit switch failure - equipment failure
3/7/86 Startup
3/27/86 Shutdown Reactor low level switches declared
inoperable - equipment failure
3/30/86 Startup
4/12/86 Shutdown 11R Refueling / Maintenance Modification
outage
1
.- - . _ . __ - - . . _ . . , _ _ _ . _ _ _ . . _ _ . . _ _ _ . _ . _ _ _ _ _ _ _ . . _ _ _ . . . . - .
o. *
TABLE 8
SALP HISTORY
8/1/79 - 10/15/87
g OYSTER CREEK NUCLEAR GENERATING STATION
Assessment
Report Period OPS RADCON MAIN SURV EP FP SEC OUTC QP LIC TS TRG
10/80 8/1/79 - 2 3 2 3 2 2 2 2 3 N N N
7/31/80
3/81 8/1/80 - 2 2 2 2 2 2 3 2 2 N N N
1/31/81
6/82 11/1/80 - 2 2 3 3 2 2 2 2 N 2 N N
10/31/81
7/83 2/1/82 - 2 2 2 2 2 2 1 2 N 2 N N
1/31/83
10/84 2/1/83 - 1 1 2 1 2 2 2 2 N 2 N N-
4/31/84
3/86 5/1/84 - 2 1 3 2 1 2 2 2 N 2 2 N
6/30/85.
7/1/85 - 2 2 2 1 1 N 1 2 2 2 2 1
10/15/86
N = Not Evaluated During Assessment Period
e ~ \
!
Table 9
LICENSING ACTIVITIES
1. NRR/ Licensee ~ Meetings (at NRC or Licensee HQ)
Cycle 11 Refueling outage 07/02/85
August 1985 Progress Review Meeting 09/18/85
Expanded Safety System Facility Status 09/20/85
Detailed Control Room Design Review 10/09/85
September 1985 Progress Review Meeting 10/24/85
at State of New Jersey, BRP
Deferments from Cycle 11R outage 11/20/85
Deferment of Feedwater Nozzle Inspection 12/13/85
from Cycle 11R outage
December 1985 Progress Review Meeting 01/22/86
Discuss the channel checks for RWL 01/23/86
instrumentation
Discuss special circumstances for 02/11/86
licensee's exemptions to Appendix R
Integrated living schedule program for 02/12/86
Oyster Creek
February 1986 Progress Review Meeting 03/26/86
NUREG-0737 Items II.F.1.1 and II.F.1.2 04/02/86
Containment purge / vent isolation valves 04/03/86
Upgrade containment nitrogen purge / vent 04/10/86
system
March 1986 Progress Review Meeting and 04/23/86
Director's annual visit to licensee HQ
Seismic design considerations 04/24/86
Generic Issue 77, Flooding of Safety 04/30/86
Related Equipment
Erratic behavior of dp Static-0-Ring switches 06/12/86
Isolation condenser piping penetrations 08/22/86
Integrated leak rate testing 09/10/86
August and September 1986 Progress Review 10/31/86
Meeting
2. NRR Site Visits and Meetings
June 1985 Progress Review Meeting 07/31 to 08/01/86
October / November 1985 Progress Review Meeting 12/11/85
January 1986 Progress Review Meeting 02/20-21/86
Director of DBL visited site 03/24/86
March 1986 Progress Review Meeting and 04/22/86
Director's annual visit to site
April and May 1986 Progress Review Meeting 06/16-17/86
Exemptions to Appendix R 06/23/86
_ Plant orientation visit 08/25-29/86
June and July 1986 Progress Review Meeting 08/27-28/86
. . - - , . . - -_-
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T9-2
3. Commission Meetings
None
4. Reliefs Granted
Deferment of modifications from Cycle 11R 10/06/86
Cancel replacement of containment purge / vent 10/10/86
isolation valves
Cancel modifications of torus for thermal 10/01/86
mixing and local quencher
temperature monitoring
Cancel modification to SGTS duct 04/18/86
Defer inspection of feedwater nozzles from 02/24/86
Cycle 11R outage
Revise requirements on recirculation loop 07/15/86
interlock ,
5. Schedular Extensions Granted
SPDS implementation 10/06/86
Control room habitability 07/15/86
Mark I containment modification 10/06/86
6. Exemptions Granted
Exemption to Appendix R 03/24/86
7. Licensee Amendments Issued
Amendment Title Date
87 Drywell-Suppression Chamber 07/01/85
Differential Pressure
88 Relief Valve Position Indication 07/01/85
89 Audits of the Fire Protection 07/02/85
Program and Quality Assurance
Program
90 Inservice Inspection and Testing 10/18/85
91 Low-Low Reactor Water Level 11/19/85
Instrumentation Modification
92 Limit Overtime 11/19/85
i
93 Water Purity of Reactor Coolant 11/21/85
94 NUREG-0737 Technical Specifica- 11/22/85
tions (GL 83-36)
95 Reactor Water Level Instrumenta- 11/30/85
tion Channel Check
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T9-3
7. License Amendments Issue, Continued
Amendment- -Title Date
96 Valve Position Indicator Accident 12/09/85
Monitoring Instrumentation
97 Reactor Coolant Pressure Boundary 01/06/86
Leakage
98 Post Accident Sampling Program 01/14/86
99 Standby Diesel Generator Fuel 02/04/86
Tank
100 Mechanical and Hydraulic Snubbers 03/31/86
101 Diesel Generator Pump Battery 03/31/86
System
102 Licensed Control Room Operators 05/12/86
Onsite
103 Standby Gas Treatment System 05/28/86
104 Excess Flow Check Valves 07/09/86
105 Control Room Habitability 07/15/86
106 Recirculation Pump Interlock 07/15/86
Scope Change
, 107 Appendix B Technical Specifications 07/17/86
-
Retyped Appendix A Technical 10/01/86
Specifications
8. Emergency License Amendments
Amendment Title Date
88' Relief Valve Position 07/01/85
Indication
91 Low-Low Reactor Water Level 11/19/85
Instrumentation Modification
95 Reactor Water Level Instrumentation 11/30/85
Channel Check
-. - -. -. .,. _.- . - . - - .
c:,c
FIGURE 1
NUMBER OF DAYS SHUTDOWN ( ) PER MONTH
1985
JUL 2 Shutdowns _ (10 days)
AUG I 35 (4 days)
OCT 1 Shutdown (13 days)
NOV 1 Shutdown (20 days)
1986
JAN
FEB
MAR 2 Shutdowns (5 days)
APR 1 SD Refuel / Mod /Maint Outage (18 days)
MAY
JUN
JUL
AUG
OCT End of SALP Period
5 10 15 20 25 30
_ _ . , , _ . _ _ _ ,_ . . . .