ML20215M917
| ML20215M917 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek, 05000000, Crane |
| Issue date: | 09/30/1986 |
| From: | Phyllis Clark, Humphreys L, Laney R GENERAL PUBLIC UTILITIES CORP. |
| To: | Harold Denton Office of Nuclear Reactor Regulation |
| References | |
| NUDOCS 8611030464 | |
| Download: ML20215M917 (16) | |
Text
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l NUCLEAR SAFETY AND COMPLIANCE COMMITTEE SEMIANNUAL REPORT l
For the period April 1, 1985 to September 30, 1986 October 15, 1986 1
APPROVED:
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R. V. LAtEY v
L. L. HOPHEYS Y
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OR. W. F. WITZg7 (
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8611030464 860730 l
PDR TOPRP EUTGPU C
PDR l -
TABLE OF CONTENTS
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TABLE OF CONTENTS 1.0 SUMMARE AND INTRODUCTION
2.0 ASSESSMENT
OF SAFETY AND COMPLIANCE 2.1 Operations 2.2 Maintenance 2.3 Technical Functions 2.4 Nuclear Assurance 2.4.1 Quality Assurance 2.4.2 Training 2.4.3 Emergency Preparedness 2.5 Radiological Controls 2.6 Other 3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 General 3.2 Committee Activities 3.3 Staff Activities Table 3-1 NSCC Document /Information Sources l
Table 3-2 NSCC Staff Activities /Information Sources Table 3-3 Persons Interviewed / Contacted by NSCC Staff j
During This Period l
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'1. 0
SUMMARY
AND INTRODUCTION This report provides an assessment of safety and compliance at the General Public Utilities Nuclear (GPUN) Oyster Creek and TMI-1 facilities, based on independent observations by the Nuclear Safety and Compliance Committee (NSCC) of the GPUN Board of Directors and NSCC Staff during the period April 1, 1986 through September 30, 1986.
As TMI-l has primarily operated at full power during this time frame and Oyster Creek has been involved in a major outage, the emphasis at each site has been different.
At THI-l the Committee and Staff activities have continued to concentrate on performance of licensed operators, maintenance activities, and procedure compliance.
At Oyster Creek the emphasis has been on procedure compliance, outage progression, and work completion with respect to safety.
Oyster Creek and TMI-l activities were conducted safely and with a positive attitude towards safety and compliance.
Areas noted for improvement include: operator performance, incident investigation, radiological planning for outages, Technical Functions support of the Oyster Creek outage, and functional maintenance at Oyster Creek.
The NSCC's detailed assessment of safety and compliance, segregated by functional area, is reported in Section 2.0.
Evaluations are based upon investigations and observations throughout the period.
Unless noted otherwise, conclusions apply to both TMI-1 and Oyster Creek.
Evaluations normally discuss conditions existing at the time of the evaluation.
Where the Committee is aware of subsequent corrective actions that have been taken, or are in progress, this is also noted.
In all cases, items of significance have been discussed between the Staff and the Committee and reported by the Committee to the GPUN Board of Directors and corporate management at regular monthly meetings.
The Committee's assessment methodology is presented in Section 3.0.
The Committee received GPUN's response to our previous semiannual report on October 9.
A preliminary review indicates that all of the Committee's comments have received thoughtful consideration and discussion.
If, after a full review, the Committee has any questions we will discuss them with Mr. Clark.
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2.0 ASSESSMENT
OF SAFETY AND COMPLIANCE 2.1 OPERATIONS During power operations, licensed operator performance at both units has been satisfactory.
As the llR outage at Oyster Creek commenced on April 12, only a limited assessment of licensed operator performance at power was possible at Oyster Creek.
Responses to abnormal situations have been good.
Two scraes occurred at TMI-l which might have been prevented by better operator performance.
On April 23, during return to power from the eddy current outage, a loss of feedwater occurred due to operator inattention to changing system conditions.
On June 2, in preparation for removing and replacing breaker IC-02, which supplies a turbine plant electrical bus, loads from the 1C 480V bus were cross-tied to parallel loads on another bus.
Shortly thereafter one of these alternate feeder breakers tripped, resulting in the loss of both turbine Electro Hydraulic Control pumps and subsequent turbine trip and reactor trip.
Operator and plant response following the trip were normal.
The follow-up to this incident by the plant staff was excellent.
The Plant Operations Director issued a memorandum within three days acknowledging that the plant trip was caused by the plant staff through inadequate planning and inadequate communications, even though the cross-tie breaker overload setpoint was found to be low.
Interim guidance provided, prior to the final corrective action of guidance being incorporated into procedures, was not to close cross-ties except in an emergency, to quantify bus loads prior to cross-tying, to minimize the time that cross-ties are closed, and to require headset communications at critical areas when cross-ties are closed.
At Oyster Creek proper operator response was noted during an inadvertent initiation of the Core Spray System at power on April 7.
The Core Spray initiation was due to inadequate maintenance procedural guidance on refilling instrument lines during calibration.
l The Oyster Creek plant shutdown and defueling were accomplished in a competent, professional manner.
However, contrary to the Committee's perception of good practices, once the reactor was l
defueled there was a reduction in control of access to the operating area of the Control Room.
In addition to the Core Spray initiation described above, there were instances of a lack of attention to detail during the outage as indicated in the following examples.
On May 29 radiation alarms were actuated as a result of moving fuel adjacent to the fuel transfer gate in the fuel pool.
The Fuel Transfer Bridge radiation alarm, the Turbine Building personnel frisker alarms, the Main Gate personnel monitor alarms, and the Refueling Floor criticality alarm in the Control Room were all actuated.
Initial 2
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. investigations did not determine thm csuse of the radiation alarms because of inadequate intra-and inter-departmental communications.
The critique of this incident revealed lack of good judgement by the operators on the refueling floor and in the Control Room, insufficient design review of storing spent fuel adjacent to the fuel transfer gate, procedural inadequacies, and inadequate radiological planning.
Although the formal critique was excellent, it took four weeks to issue.
No overexposures were experienced as a result of this incident.
On June 9 a Standby Gas Treatment System started due to a power supply problem.
Proper notification of the NRC was not made within the required four hours.
Corrective actions for the above occurrences were proper.
2.2 MAINTENANCE The eddy current outage at TMI-1, completed on April 23 was conducted in an exemplary manner.
Upon return to power, main steam header drain line leakage similar to that experienced during startup in October, 1985 recurred.
The Committee has been appraised of the temporary resolution and of evaluations being performed to provide long term permanent resolution of the drain i
line problem.
Sound judgement was used in postponing certain Integrated Control System adjustments (at power) that were proposed for collection of data to support these evaluations.
A key element in the decision to postpone the proposed adjustments was Plant Management's commitment to a reduction in the number of scrams related to maintenance and testing and a reduction in the i
total number of unplanned scrams per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> of critical i
operation.
The Committee will continue to follow the resolution of the drain line leakage problem.
t The Oyster Creek 11R outage commenced on April 12 and continued throughout this seriod.
The outage schedule at Oyster Creek has i
slipped slowly taroughout this period.
Although considerable i
functional maintenance has been accomplished during the 11R outage, the numbers of items in the backlog has remained fairly constant.
The Committee is concerned that efforts to meet the i
scheduled completion dates have resulted in deferring functional maintenance work which may affect equipment reliability.
The reduction of functional maintenance will make the achievement of availability goals more difficult.
I The Committee believes the materiel condition of the Oyster Creek Control Room, as indicated by the number of deficiency tags, tends to reflect standards of acceptability applied throughout the plant.
The Committee's concerns regarding the Control Room i'
deficiencies were reported to the Board of Directors in July.
GPUN should intensify efforts to clear Control Room deficiencies before restart and to keep the number of deficiencies thereafter to an acceptably low level.
As the Startup Certification process will include Control Room deficiency status, it is an appropriate vehicle for determining progress in this area prior to restart.
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In April the Oyster Creek and Maintenance, Construction and Facilities (MCF) Divisions concurred in Station Procedure 105
" Conduct of Maintenance", thus resolving the technical issue of lack of administrative controls for maintenance.
Specific implementation issues remain to be resolved.
It is noted that biennial procedure review requirements at Oyster Creek have not been fully implemented even though an MCF memorandum apparently addressed this item by requiring MCF planners to assure that the biennial review is complete prior to issuing a procedure for use.
As reported at the September Board of Diretors meeting, a recent Staff review of this area indicated that the planners were not implementing the requirements of the memorandum.
The Committee notes, however, that Oyster Creek has recently initiated a project to upgrade maintenance procedures.
The Committee also notes that not all TMI-1 biennial reviews are being conducted within the allotted time frame, although the number delinquent remains very small.
Management attention is still required to ensure that biennial procedure reviews are conducted as committed.
2.3 TECHNICAL FUNCTIONS The NSCC sees indications at Oyster Creek that Technical Functions support for the outage is not provided as promptly as needed.
At the beginning of the outage the planning was incomplete due to incomplete engineering or late delivery of engineering packages.
The number of problems experienced during installation of the drywell chillers indicate that detailed engineering in the drywell, which was to have been completed during the 10M outage, was incomplete.
More recently on July 22, the operability of the diesel generators was questioned based on a Technical Functions finding that an electrical surge suppressor was not seismically mounted.
For the conditions existing, the Technical Specifications required that at least one diesel be operable.
When Technical Functions did not respond to the concern, a Plant Review Group (PRG) was convened on July 23 and it was determined that the surge suppressor only affected indication and not operability.
Although the PRG resolution was satisfactory, it should, in our opinion, have been resolved by Technical Functions the day it was discovered.
The Technical Functions representative at the daily planning meeting changed frequently during the outage.
As a result, questions asked of Technical Functions one day were not passed on to the representative attending the meeting on the following day, and therefore answers and work progress were delayed.
2.4 NUCLEAR ASSURANCE Nuclear Assurance support was evaluated for Quality Assurance, Emergency Preparedness, and Training.
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2.4.1 QUALITY ASSURANCE QA/QC Corrective Action systems were reviewed in depth at Oyster Creek and were found to be comprehensive and effective.
All open issues appear to be receiving attention.
Numerous deficiencies resulting from the outage and ongoing inspection programs are presently open.
Progress towards closure of these items may require management attentien in order to complete them before the restart.
Two long standing QA Audit findings regarding the Safety Review process were closed after the revised corporate procedure 1000-ADM-1291.01 "GPUN Nuclear Safety Review and Approval Procedure" was issued.
During a recent NRC exit meeting, however, the Safety Review Process was questioned by the NRC and may remain an open issue.
2.4.2 TRAINING Progress towards INPO accreditation of training programs was evaluated.
Ten Oyster Creek programs have received INPO accreditation during this report period, thus making Oyster Creek one of the few plants with full INPO accreditation.
Progress towards accreditation at TMI-1 is continuing, however, some goal dates may not be met for Maintenance Training.
Considering the present status of the TMI-1 Maintenance Training, the need for significant participation by Plant Maintenance in these training programs, and the potential unavailability of Plant Maintenance personnel during the 6R outage, these programs may not receive accreditation by the desired dates.
RO and SRO requalification results at both sites have been excellent.
2.4.3 EMERGENCY PREPAREDNESS The Oyster Creek annual exercise conducted in April demonstrated the ability to respond to emergencies and protect public health and safety.
Self-evaluation by Oyster Creek was excellent.
2.5 RADIOLOGICAL CONTROLS Radiological Controls were evaluated primarily by observing operations, maintenance, and modification activities.
TMI-1 experienced problems during the early stages of the eddy current I
outage with skin contaminations and airborne Iodine which indicated they were not fully prepared for the increased activity levels experienced.
Radiological Control personnel subsequently imposed more stringent controls and fewer problems were experienced as the outage progressed.
Lessons learned are apparent in preparation for the 6R outage.
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r At Oyster Creek the 1986 radiation exposure goal has been significantly exceeded.
It appears that this goal was overly optimistic in its assumptions regarding chemical decontamination efficiency and progress, as well as progress in surface 1
I decontamination.
After the goal was exceeded improved controls l
were implemented which included a number of measures to increase i
productivity and reduce worker times in the work areas.
Application of these controls earlier could have reduced the amount by which the exposure goal was exceeded.
Oyster Creek is to be commended for preventing any significant increase in i
contaminated areas during the outage.
i 2.6 OTHER i
j Numerous problems were experienced with the replacement Oyster Creek Reactor Building Closed Cooling Water Heat Exchangers due j
to manufacturing flaws and errors.
This could indicate l
inadequate engineering, quality control, or both.
It would be appropriate for GPUN to critique these problems and take 4
appropriate corrective actions to prevent recurrence.
i Problems in the corrective action process within MCF at Oyster Creek are evident.
Many formal incident critiques have not been 4
issued although some have been assigned for over one year.
The j
Committee views this as a significant breakdown of the corrective l
action system requiring increased management attention.
The implementation of incident investigation is inconsistent.
On May 13, at Oyster Creek, a scram signal due to apparent noise in the Intermediate Range Monitor channels was not critiqued because 1
it was similar to an occurrence on May 1, which had been i
critiqued.
On July 21 a Local Power Kange Monitor (LPRM) string i
was dropped at Oyster Creek.
No formal critique was conducted regarding the LPRM handling tool.
The May 29, incident at Oyster Creek regarding fuel movement discussed in section 2.1 was j
critiqued in an excellent manner.
It has previously been noted I
that root cause determination for non-operations critiques at THI-1 are not as thorough as the Operations critiques.
Inconsistencies in the GPUN incident criticue program have also been pointed out in an evaluation performec by the Nuclear Safety i
Assurance Division.
The Committee recommends that GPUN improve the evaluation of incidents.
At the July Board of Directors meeting the Committee recommended that GPUN evaluate the need to replace SOR switches in systems i'
other than for reactor low level trip.
The NRC subsequently i
issued I&E Bulletin 86-02 regarding these switches.
Responses l
to this Bulletin have been made, and GPUN is taking other actions i
to address these switch problems.
The Committee will follow the resolution of this issue.
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- Reports of off shift tours by management were reviewed at both sites throughout the period.
They continue to reflect significant management presence in the plants, perceptive observations, and effective follow-up to deficiencies noted.
Although housekeeping has lapsed at times at both plants, management attention has always returned it to its previous high level.
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3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL The Committee guides the Staff's investigations and approves Staff schedules and expenditures.
NSCC Staff activities involve both routind monitoring and special reviews.
Routine monitoring covers all functional areas at each site and at corporate headquarters.
A long range schedule of monitoring activities is developed every six months.
Additional activities are added at the request of the committee whenever plant events or industry occurrences (e.g., SOR switches, Mark I containment questions) dictate.
The Committee reviews various coraorate reports such as those listed in Table 3-1.
Upon occasion taese result in special tasks for the Staff.
3.2 COMMITTEE ACTIVITIES In addition to the activities described above, the Committee meets with the GPUN Board of Directors at regular monthly meetings and reports on any items with safety or compliance significance.
Questions or concerns which may arise between board meetings may be conveyed to the Chairman or President, GPUN.
The Committee meets with senior members of the Staff prior to the monthly meetings of the Board of Directors.
These meetings frequently include presentations by and discussions with selected GPUN managers on subjects of interest to the Committee.
(e.g. Probabilistic Risk Assessment, Mark I Containment).
During this report period, two additional Observations Meetings between the Committee, Staff, and GPUN executives were held.
Observations Meetings provide a forum for the Staff to present additional observations and comments on plant activities which do not have safety significance.
NSCC Members attended one TMI-1 GORB meeting and one Oyster Creek GORB meeting during the period.
Dr. Witzig toured THI-1 twice during this period.
Mr. Laney and Dr. Witzig also toured the New Radwaste Control Room and the Augmented Offgas Facility at Oyster Creek.
Tours were also conducted at both sites as a part of the Board of Directors meetings.
i 3.3 STAFF ACTIVITIES The Staff, permanently located at the plants, gathers information on plant activities in many ways.
Plant tours, monitoring of activities, attendance at meetings, interviews with GPUN personnel, and review of reports, correspondence and other documents are all used in conducting evaluations.
Plant operations and maintenance activities receive primary attention.
i Support functions are also evaluated.
The NSCC Staff has l
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bcncgsacnt, op3rctions, anintGnatics, training, cnd liconsing/sofety reviGw exp2rtiss.
Evaluations during this period concentrated on areas and activities described in Section 2.0.
Table 3-2 lists activities and information sources used in Staff evaluations.
Table 3-3 indicates the types and numbers of GPUN personnel contacted during this-period.
During this period, one Staff member attended a training seminar on use of Management Oversight and Risk Tree (MORT) analysis.
MORT analysis provides a systematic, structured methodology for investigating incidents, and should be useful in conducting Staff evaluations.
Five Staff members have now received MORT training.
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TABLE 3-1 NSCC DOCUMENT /INFORMATION SOURCES GPUN Sources (both sites unless otherwise noted):
Plant Inciddnt Reports (TMI-1)
Deviation Reports (OC)
Licensee Event Reports Licensing Correspondence Significant Events Reports Off Shift Tour Reports Post Trip Review Group Reports Transient Assessments Reports IOSRG Evaluation Reports GORB Meeting Reports QA Monthly Assessment Reports QA Quarterly Trend Reports Attendance at GORB Meetings Plant Tours Meetings with GPUN Management Other Sources NRC Notices NRC Ceneric Letters NRC Regulatory Guides and NUREGs NRC SALP Reports Industry Periodicals (Inside NRC, Nucleonics Week, etc.)
NRC Inspection Reports INPO Evaluation Reports INPO Nuclear Power Plant Operational Data Report 1
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TABLE 3-2 NSCC STAFF ACTIVITIES /INFORMATION SOURCES (Both sites unless otherwise noted)
PLANT TOURS General Walk-Through/ Housekeeping Observations Off Shift Tours Control Room Observations Maintenance Observations Surveillance Test Observations Rad Waste Handling Observations MEETINGS Daily Plant Status Meetings Weekly Plan of the Day Meetings Outage Planning Meetings NRC Entrance / Exit Meetings INPO Training Evaluations GORB Meetings Post Trip Review Group Meetings Maintenance Critiques (OC)
DOCUMENT REVIEW GPUN Sources:
Plant Incident Reports (TMI-1)
Deviation Report (OC)
Licensee Event Reports Incident Critiques Licensing Correspondence Significant Events Reports Off Shift Tour Reports QA Audit Reports QA Monthly Assessment Reports QA Quarterly Trend Reports QA Annual Assessment Reports Operations QA Monitoring Reports Operations Daily Reports (OC)
Shift Monitor Reports (THI-1)
STA Daily Reports Operation Night Order Book Log Books (Operations, STA, Chemistry, Maintenance, Rad Waste)
Shift Turnover Forms MNCRs, QDRs 11 1
Rcdiction Awaronoss RGports Post Trip Review Group Reports Transient Assessment Reports Maintenance Work Order Packages GPUN Administrative Policies and Procedures Station Procedures (Admin, Operations, Maintenance, etc)
Operations _QA Plan Technical Specifications Training System Descriptions Training Lesson Plans Plant Drawings IOSRG Evaluation Reports GORB Meeting Reports Other Sources:
NRC Notices NRC Generic Letters NRC Regulatory Guides and NUREGs NRC SALP Reports INPO Evaluation Reports INPO Guides ANSI Standards ASME Codes Code of Federal f.egulations (10CFR)
Industry Periodicals (Ir, side NRC, Nucleonics Week, etc.)
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T TABLE 3-3 PERSONS INTERVIEWED / CONTACTED BY THE NSCC STAFF DURING THIS PERIOD Site Personnel (both sites unless otherwise noted):
Vice President / Director-TMI-1 Vice President / Director-0C Deputy Director-0C Operations and Maintenance Director (TMI-1)
Plant Operations Director (OC)
MCF Director (OC)
Department Managers, Supervisors, and Personnel of the following:
Plant Operations Plant Maintenance (TMI-1)
Plant Materiel (OC)
Maintenance, Construction, and Facilities Plant Engineering Plant Chemistry Special Projects Plans and Programs Safety Review Group (OC)
Plant Review Group (TMI-1)
Technical Functions Licensing Plant Analysis and STA Startup and Test Nuclear Assurance - QA/QC Training and Education Emergency Preparedness Core Group - Operations Engineering (OC)
Radiological Controls 10SRG Environmental Controls (OC)
Corporate Personnel Vice President - Maintenance Construction and Facilities Vice President - Technical Functions Vice President - Nuclear Assurance Director - Engineering Projects Director - Training And Education Director - Quality Assurance Managers and other personnel of the following:
Licensing Training and Education Safety Analysis and Plant Control Quality Assurance Technical Functions Maintenance, Construction, and Facilities 13
l E
GPU Nuclear Corporation M"r 100 interpace Parkway w
Parsippany, New Jersey 07054 201 263-6500 TELEX 136 482 Writer's Direct Dial Number:
October 31, 1986 (201) 316-7797 Mr. Harold Denton, Director Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555
Dear Mr. Denton:
My letter dated April 24, 1986 provided the fourth report of the Nuclear Safety Compliance Coranittee (NSCC) to the GPU Nuclear Corporation Board of Directors.
Mr.
J.
F.
O' Leary, Chairman of the
- Board, GPU Nuclear Corporation, has requested that I provide to you the NSCC's fif th report for the period April 1,1986 through September 30, 1986.
A copy of the report is enclosed.
Very truly yours, l.( [
s,-
P. R. Clark President pfk 1244 Enclosure cc: J. F. O' Leary, Chairman of the Board (10 GPU NuclNr Colpotation is a subsulldf y of the General Pubhc Utilities Corroration Y