ML20234B931
| ML20234B931 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 06/25/1987 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8707060280 | |
| Download: ML20234B931 (3) | |
See also: IR 05000219/1985098
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JUN 2 51987 Docket No. 50-219 GPU Nuclear Corporation ATTN: P. R. Clark President 1 Upper Pond Road Parsippany, New Jersey 07054 Gentlemen: Subject: Systematic Assessment of Licensee Performance (SALP) No. 50-219/85-98 Thank you for your letter dated April 28, 1987 wherein you presented, as a follow-up to our April 6, 1987 meeting, a detailed response to the Oyster Creek SALP for the period July 1,1985 through October 15, 1986. We appreciate the efforts you are making to address our concerns and will monitor the implemen- tation of your initiatives. The SALP report, our transmittal letter, and your , response letter are enclosed and will be placed in the Public Document Room. Recently we were informed that emphasis has been placed on reducing the work backlog in both Plant Engineering and Maintenance, Construction, and Facilities. This effort addresses one of the major SALP concerns and we will monitor your progress. We have also observed management efforts to improve shift management decision making. We were disappointed, however, in the various factors and decisions that recently led to tieing open the torus-to-drywell vacuum breakers i when containment. was required (Reference: NRC Region I Inspection Report 50-219/87-16). l We acknowledge your request to delay a team inspection of technical support { groups until you have completed a self-assessment and initiated corrective actions. This request is under consideration and we will contact you to j determine the intended scope and schedule of your activities in order to determine if a delay in our inspection is appropriate. The final paragraph in the cover letter to your April 28, 1987 response states you feel it to be important ". . .that NRC emphasize prcminently in each report the manner in which they can be appropriately utilized." We believe the introductory material included at the beginning of each SALP provides a good description and overview of the SALP process and its purpose. This information t would assist any reader in determining both the relevance of the SALP to that i reader's particular circumstances and the appropriate use for that reader. If you have additional thoughts in the area, please feel free to contact us. 8707060280 870625 PDR ADDCK 05000219
G PDR " h'/ T ' 0FFICIAL RECORD COPY OYC SALP LTR - 0001.0.0 4 06/26/87 j gli % _ , _
r b' slllN z 51987 GPU Nuclear Corporation 2 ,. In summary, we felt the report, our meeting and your response letter resulted in a constructive assessment of the performance at Oyster Creek. Your cooperation is appreciated. Sincerely, Originni Signed By WILLIAM T. EUSSELL William T. Russell Regional Administrator Enclosures: As stated cc w/encis: P. B. Fiedler, Vice President and Director M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR) local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of New Jersey Chairman Zech Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Carr bec w/encls: Region I Docket Room (with concurrences) Management Assistant, DRMA (w/o encis) Section Chief, DRP R. J. Bores, DRSS J. Taylor, DEDRO W. Russell, RI J. Allan, RI D. Holody, RI K. Abraham, PA0 (2) Management Meeting Attendees W. Johnston, DRS T. Martin, DRSS W. Oliveira, DRS Wish List Coordinators (2) (Ltr Only) 0FFICIAL RECORD COPY OYC SALP LIR - 0002.0.0 06/2S/87
r' s~ l GPU Nuclear Corporation 3 .- rJUN 251987 M hY N fo( Bateman/mjd RI:DRP RI:DRP I.DRP RI:DRS fIh [ RA
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Blough 0111ns Johnston F- e A)l' Russell 6/2?/87 6/Q87 7 6g87 6/1 /87 6/2,f/87 6/p/87 6 /87 0FFICIAL RECORD COPY OYC SALP LTR - 0003.0.0 . . 06/22/87
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-t o UNITED STATES ,. .p* 3 NUCLEAR REGULATORY COMMISSION 4' .E REGION I
og,.....,/ 631 PARK AVENUE - - - xiuo or caussi4,eEuusvtvAu A ie40s ,. < d' MAR 1% 1987 Docket No. 50-219 GPU Nuclear Corporation ATTN: Mr. P. B. Fiedler Vice President and Director Oyster Creek Nuclear Generating Station P.O. Box 388 Forked River, NJ 08731 Gentlemen: Subject: Systematic Assessment of Licensee Performance (SALP); Report No. 50-219/85-98 The NRC Region I SALP Board conducted a review on November 25 and 26, 1986, i and evaluated the performance of activities associated with the Oyster Creek Nuclear Generating Station. The results of this assessment are documented in the enclosed SALP report, which covers the period July 1, 1985 to October 15, 1986. We will contact you shortly to schedule a meeting to discuss the report. At the meeting, you should be prepared to discuss our assessment and any plans ' you may have to improve performance further. Any comments you may have regarding our report may be discussed at the meeting. Additionally, you may provide written comments within twenty days after the meeting. . Following our meeting and receipt of your response, the enclosed report, your response, and summary of our findings and planned actions will be placed in the NRC Public Document Room. Your cooperation is appreciated. Sincerely, Thomas E. Murley Regional Administrator ~ Enclosure: As Stated , e n ,3 d g/
e , , .. , . - GPU Nuclear Corporation .2 g4p . , 9j,. ,, . E cc w/ enc 1: M. Laggart, BWR Licensing Manager Licensing Manager, Oyster Creek Public Document Room (PDR) Local Public Document _ Room (LPDR). Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of New Jersey Chairman Zech Commissioner Roberts Commissioner Asselstine Commissioner Bernthal Commissioner Carr bec w/ enc 1: Region I Docket Room (with concurrences) Management Assistant, DRMA (w/o enc 1) DRP Section Chief K. Abraham, PA0 (2 copies) T. Murley, RI J. Allan, RI S. Ebneter, RI T. Martin, RI i D. Holody, RI - (- J. Taylor, IE' Board Members ) ' I
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U.S. NUCLEAR REGULATORY COMMISSION REGION I 4 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 BOARD MEETING DATE: NOVEMBER 25 and 26,:1986 i . [ _/- _ . O 9 j y w -r 7- a NY ,I
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) ,. . .. . .- t ! TABLE OF CONTENTS ' Page I. INTRODUCTION ....................... 1 l 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. Cvera11 Facility Evaluation 8 ............. IV. PERFORMANCE ANALYSIS 9 ...................
A. Plant Operations . . . . . . . . . . . . . . . . . . . 9 B. Radiological Controls 13 ................ C. Maintenance ..................... 18 D. Surveillance / Inservice Testing . . . . . . . . . . . . 22 ( E. Emergency Preparedness . . . . . . . . . . . . . . . . 25 F. Security and Safeguards 27 ............... G. Outage Management / Refueling 30 i ............. H. Technical Support 34 .................. I. Training and Qualification Effectiveness . . . . . . . 37 J. Assurance of Quality . 40 i ................ K. Licensing Activities . . . . . . . . . . . . . . . . . 44 i V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . 47 I 1 A. Investigations and Allegations Reviews . 47 - ....... B. Escalated Enforcement Actions 48 ............ C. Management Conferences . . . . . . . . . . . . . . . . 49 D. Licensee Event Reports . . . . . . . . . . . . . . . . 50 TABLES Table 1 - Tabular Listing of LERs by Functional Area T1-1 ...... Table 2 - LER Summary . T2-1 ..................... Table 3 - Enforcement Summary . T3-1 ................. Table 4 - Inspection Hours Summary T4-1 ............... Table 5 - Inspection Report Activities T5-1 ............. 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 ................ Figures Figure 1 - Number of Days Shutdown F1-1 ...............
. . . . ' . - , i I.- Introduction 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. 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 evaluation criteria is provided in Section II of this report. This report is the SALP Board's assessment of the licensee's k 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, i i s
, ! . ,. ,' 2 .- -( B. SALP Board Members Chairman W. Kane, Director, Division of Reactor Projects (CRP) 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) j
M. Shanbaky, Chief, Facilities Radiation Protection Section ' (Part-time) Attendees W. Baunack, Project Engineer, RPS 1A, PB No. 1, DRP ( R. Conte, TMI #1 Senior Resident Inspector R. Freudenberger, Reactor Engineer, RPS 1A, PB 1, DRP 1 H. Kister, Chief, Project Branch No. 1 DRP (Part-time) W. Madden, Physical Security Inspector, SS, NMS&SB, DRSS (Part Time) j S. Sherbini, Radiatien Specialist (Part Time) J. Wechselberger, Resident Inspector, Dyster Creek , 1 l i
l . ,. ,' 3 3 \\ ,. ( l 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 ESW system piping. On July 22 the unit was placed in cold shutdown to inspect, clean, and hydrolaze sections of ESW piping, flush the system, 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 v.ini-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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4 , . 2. Inspection Activities- Two NRC resident inspectors were assigned to the site throughout the assessment period. The total NRC inspection hours for the 15 1/2 month period was 5189 hours (Resident, Region, and Headquarters based) with a distribution in the appraisal J functional areas as shown in Table IV. This equates to 4017 hours on an annual basis. j During the period, NRC team inspections were conducted to review f potential for overpressurization of low pressure emergency core cooling systems and to evaluate the licensee's program for the i environmental qualification of equipment. Also, special inspec- tions were conducted to review implementation of NUREG 0737 items and the circumstances associated with iodine uptakes by workers. A Nhc Emergency Preparedness inspection team observed the annual emergency exercise on April 9,1986. Tabulations of-inspection and enforcement activities are attached as Tables 5 and 6, respectively. , ' (.
,. . 5 - ~ . k 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 safety and 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 2. Approach to resolution of technical issues from a safety standpoint 3. Responsiveness to NRC initiatives 4. Enforcement history- 5. Reporting and analysis of reportable events 6. Staffing (including management) 7. Training effectiveness and qualification 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 resident . inspectors and as an integral aspect of specialist inspections. Although quality work is the responsibility of every employee, one of the 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 nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety or construction is being achieved. The SALF Board has also assessed each functional area to compare the licensee's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend for each functional area. The trend categories used by the SALP Board are as follows: ( Improving: Licensee performance has generally improved over the last i quarter of the current SALP assessment period. Declining: Licensee performance has generally declined over the last quarter of the current SALP assessment period. 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. 1 L
. ,. l s , + . ( 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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_ __ __ _ -___ __ - . ,. 8 . ( 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 facG ity 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 8 Seneral imprevement 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 equipment 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 required 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 f l 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 end responsiveness to site questions regarding this work. l 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 thet 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. _ _ _ _ _ - _ _ _ - _ . __ -_ --- _. - _
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . ,. .' 9 .' I ' IV. PERFORMANCE ANALYSIS A. Plant Operations (1971 hr. 38*s) 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 I 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 l System. The previous SALP discussed these areas as significant i 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 -- -_ _ _ _ _ _ _ _ _ - _ _ - _ _ _ ___--____--
. ,. .- 10 . ( 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 considering 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 Among the errors which occurred are (1) improper upranging a scram. 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, j 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. Other significant equipment problems included electromatic relief valve seat leakage, feedwater isolation valve leakage, hydraulic control unit deficiencies, and feedwater control problems. Reactor water level control was consistently a major operator concern following a reactor scram during this assessment period. In virtually every scram recovery, high reactor water level pre- cluded the use of the isolation condenser. In another case, while attempting to reseat a leaking EMRV after a scram, unstable water 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, over. coking other immediate i operator actions. The licensee has recognized this problem, revised operating procedures, and is contemplating a feedwater control system } modification. ' 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- 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 Technical 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- servatism regarding issues affecting safety was generally evident.
i . - ' .. 11 - , .- ( Senior operations management continues to be a streng contributor to safe efficient operation of the Oyster Creek Nuclear Generating Station. Post-transient analysis and reviews are ganerally conducted in a thorough manner, determining root causes and establishing proper corrective action prior to resumption of power operation. Another 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 been completed or appropriately dispositioned prior to commencing a major milestone. The addition of a dedicated senior reactor operator during outages to improve the interface and working relations between operations and maintenance was another positive management initiative that helped coordination of work activities. Another initiative was the. establishment during the 11R outage of back shift coverage by senior plant management to more rapidly identify and resolve problems. Management personnel are frequently found in the plant and involved in the solution of plant problems. The licensee has established good programs to manage operator overtime hours. Housekeeping in the plant during operations is usually excellent and is a reflection of the concerted effort by plant management in this area. Housekeeping during outages needs to be improved, though, and is discussed in the Maintenance and Radiological Controls sections. In summary, strong senior operations management continues to be a ( 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 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 complicated reactor trips. There is an apparent operator pre-occupation with water level control problems to the exclusion of performing immediate operator actions during a reactor scram. Additional training, including plant-specific simulator training, would improve operator performance and reduce operator cognitive errors during scram recovery 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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Licensee: Improve shift managements' abilities to recognize and fully -- consider all safety aspects of an issue and then act decisively on that issue. Decrease the number of operator' errors through enhanced opera- -- tional training including use of plant specific simulator training. NRC: -None i i . ( l
. . ,. 13 l - . .- 1 ( i - B. Radiological Controls (478 hrs. 9%) j The previous SALP rating in this area was Category 1 with effective control of radiation protection activities and high levels of per- sonnel performance noted. Strong points included training, exposure j control, whole body counting, timely corrective action to identified ( problems, effective radwaste management and radwaste volume reduction. i 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 transportation 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 contr:111ng radiation exposure on site, radiological effluents, and waste. shipments. Inspec- tions during the outage shiwed 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 3 classified as clean. This appears to be indicative of insufficient j training and indoctrination in station procedures and general good l 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.
. . . . . . . <. . .. 14 . , .- Issuance of RWPs appeared to have been well controlled, and i > 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 by 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 4 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 crea, 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 another general area of weakness, namely, inadequate commu- nications between at least some of the departments on site. Another l 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 persor:nel 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 l effective. Staffing levels appear to be good, and the procedures are adequate. Equipment and facilities are also adequate in most areas. l _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ __ - _ _ _ _ _ _ _ ________
I i . . ,. 15 ^ ' ,. ! The licensee is in general responsive to regulatory and safety An example is provided by underwater diving operations on concerns. 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 ! 1mproving 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 l 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 t 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 i 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 . . . ,. 4 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 addition, 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 j Bulletin 79-19. 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 (referred 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 f- fully discussed in the Technical Support functional area. After further discussions with the NRC, a more responsive schedule was submitted. The licensee showad good implementation for PASS { i 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 1 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 i 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. l
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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 .
. . ,. ., 18 . . . - C. Maintenance '(647 hrs., 12%) 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. i 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 vaintenance 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 l . . effectiveness of the corrective actions. .One of the major keys to improvement was the emphasis placed on controlling work scope which enabled the licensee to.better control This resulted in more comprehensive supervision which, resources. 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 IOM 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 df 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. i
l . ,. 19 - , . ( During the IOM 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, f ailure of a job supervisar to sign off production holdpoints for a weld j ) repair, failure to implement or change a procedure prerequisite, and i failure of MCF personnel (along with others) to frisk carry along items when leaving the radiologically controlled area. Just after conclusion of the IOM 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 and accepted work for which MCF still had responsibility and improper issuance of weld rod used to connect a pipe restraint of known material to a floor penetration of unknown material. Additional concerns identified included the finding that 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. Routine 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
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. (' 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 IOM outage was controlled at an acceptable level, however, during the 11R outage, it was inconsistent. The housekeeping problems O scussed 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 initiated. 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- sta11ation resulted in the eighty HCOs not meeting seismic require -
ments and a significant Technical Specification violation in that i these HCUs were never operable by Technical Specification definition. i Add tional 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 the 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 I i
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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. Thistissue 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 procedures 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 11R 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 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. 1 On several occasions problems were identified relative tu 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.
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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 I 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 I testing of snubbers. This was accomplished. Procedures displayed sound technical judgement, reflected plant experiences, and incorporated licensee commitments to prevent recurrence of problems I 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, l were thoroughly familiar with the snubber TS amendment request and provided supplemental data to clarify several TS provisions.
a 6 . ,. ' 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 I 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 / certification 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 t None l ! l l I i
s . ,. 25 . . - E. Emergency preparedness (267 hrs., 5%) Analysis l During the previous assessment period the licensee was rated as Category 1 in this area. Strengths ~were noted in responsiveness to NRC initiatives, management participation in exercise activities as - well as planning and cont;al of exercises. Also, the activation of a new Technical Support Center occurred during the last assessment 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 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 i( 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 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 during this exercise demonstrated a. highly developed level of emergency preparedness. Technical Support Center performance was j 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 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- 3 nical Support Center was manned and shift staffing was increased. No i action was required for Hurricane Charley due to its path. l- In summary, licensee performance remains strong in this area, and sufficient management attention is being provided.
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O { Conclusion ' Category - 1 Board Recommendations None i l i 1 I 4 ' i 1 ' \\ 4 l , l 1
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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, j 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 n.anagement 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 tha performance of the security force. ,
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. 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 changer cre adequate for all condi!, ions. 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 i 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 deteFted. 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 licensee audits of the program and in the previous NRC SALP. This group's function is to evaluate the maintenance require- , t ments for the various security program systems and equipment and to carry out those maintenance activities that can be performed on-site 1 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 summary, the licensee initiated and/or made several improvements and implemented 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 k Category - 1 Board Recommendations Licensee: None N_R._C : 1 -- 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 eatnoment, 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. , i 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 Implementation. 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 I planning group was formed in Technical (Tech) Functions. Its function is to aid in determining, prioritizing, and scheduling future work. 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 j , 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 i 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 esttblish a mutually agreeable plan for accomplishing work activities.
. ,. , 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 l activities. The schedules were generally realistic. i Control and Implementation: The corporate commitment to planning and scheduling was evident during the IOM outage but not as evident during IIR. 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 I 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 I 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 addrested. 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 contro11$ng 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
1 . -. ~ 32 j
- i , of an effort has, in the past, resulted in deficient documentation. Control of radiation exposure to meet the intent of ALARA was not successful as discussed in the Radiological Controls functional area. The Outage Manager was aggressive in controlling work assignments for
work that was not clearly the responsibility of a corporate 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- q 1mproved during this period and efforts to continue the improvement j should be sustained. ' 1 Refueling: i ] The key events related to refueling were total defueling of the core, sipping of all removed fuel assemblies to be reloaded into the core, inservice inspection of reactor vessel internals, shuffling control 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 activities indicated that the procedures were adequate, the personnel were well trained, ! and the activities were carried out in accordance with approved procedures. Ongoing QA coverage appeared adequate. Plant management was directly involved in day-to-day refueling activities and a comprehensive refueling certification program was implemented to (. ensure all prerequisite work was completed prior to commencing refueling. The large amount of work activity on the refueling floor j i 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 with 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 . j were functional prior to the outage. An evaluation of this situation 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 I resulted in radiation streaming that set off various alarms on the ] i 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. . _ _ _ _ . J
- , . ,. 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 - 3 i Board Recommendations i Licensee: _( Improve contingency planning. --
-- ' Continue efforts to match resources and workload. Investigate a'd clarify workforce perceptiens of management's -- n attitude regarding safety versus schedule. N_RC : None ._ _
_ . ,. 34 . . . . H. Technical Support (968 hrs., 19%) The previous SALP rated performance in this area as Category 2. This functional 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 reduce 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 qu.nlification, 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 failures, 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 procedure; 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 J Engineering that indicated Plant Engineering was knowingly operating . differently than described in their procedures governing tasking 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 priority issue not being addressed.
. ,. 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 prob: ems 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 ] a operability, maintainability, arJ constructability reviews. The work performed by the Str.rtup and Test Group (SU & T) is a good example of ef fective and tinely t echnical support. SU & T is effec- tively managed, contains dedica~ted 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. ( 1
e i 36 . . In summary, technical support has a number 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 paradoxicti 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 - , l Board Recommendations l 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: I Conduct a team inspection of technical support groups with an emphasis on determining the causes of inconsistent performance. _ _ _ _ -
_ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
. 37 l .
+ 1. 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 evaluation during the SALP process -- Training and Qualification l Effectiveness. Training and qualification effectiveness still i 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 1 training, non-licensed staff training, and the status of INPD training accreditation, , The licensee is committed to a program of improved training in all . I aspects of facility operation. They are one of the first plants l ' to gain INPO accreditation of all ten training programs. Overall management support of and involvement in training is evident by its support of INPO accreditation and overall improvement in the { programs. Emphasis has been placed upon not only maintaining an lf( 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 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 requalification training program inspection was also conducted by the , NRC and no deficiencies were noted. Both the licensee's replacement operator and operator requalification training programs make a posi- tive contribution to operator knowledge and understanding of the facility. The licensee appears to be providing operators with adequate training on plant changes and modifications. Effective training for personnel l performing refueling was noted to have been performed. Also, guides, l course outlines, and class lecture lists showed the licensee provided l 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. l - _ _ _ _ - _ _ _ _ - - - _ - _ _ _ _ _ _ _ _ _ - - - __ _ -_- _ - _ - -___
1 - . , - 38 i ( As noted in other sections of this report, there have been events in which operator error has occurred. Fewer operator errors would 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 management's ability to recognize and fully consider all safety aspects of an issue and then act decisively on that issue. The licensee has established a well-designed program for both class- room and on-the-job training for in-house electricians, mechanics, and instrument and control (I & C) technicians. It was noted that 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 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 general improvement in performance is noted, however, only minor improvement has been observed during this evaluation period. In an effort to further upgrade craft and supervisory personnel 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 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 in its implementation. Based on weaknesses in the ALARA program implementation as discussed in this report, this training program should receive more management attention to establish an implementation date. The security officer training and requalification program is well- developed and administered. The new initiative of security personnoi on-the-job performance evaluation has proven to be effective as a management tool to measure the effectiveness of the security training program. Also, the licensee's staff performance during a full par- ticipation emergency preparednesss exercise reflected a nigh level of training and readiness to respond to emergencies.
. . ,. 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 it 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 i I ,
, '
. 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 e .sessment 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 ef;setiveness of the QA organization to help keep quality in the foret cont, 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 s 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, l 1986. i
' .
' . C 41 . .I-
A NRC special review of MNCRs, QDRs, and QA audit findings was conducted in an effort to evaluate a commitment to improve the i timeliness and aggressive pursuit of resolution of QA/QC findings. 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 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 satitfactory 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, cocperation 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 suomitted 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 , l 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. ! l 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 1 room for improvement. Plant Operations management realizes that i j 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 management have been established to identify areas requiring improvement. QA/QC at Oyster Creek plays an important role in assuring quality in I 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' l understanding of structural weld codes. NRC inspector reviews of QA i audits and Quality Deficiency Reports (QDRs) indicated a reluctance to escaiate when lack of timely response required it. More rigid i 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. l 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 l (5) an 1,n depth review of vendor NDE personnel qualification / l certification records. 1 ____ _ - _ - _ _ -
, . , 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 (GORB). NRC
inspection of the GORB determined the program established for the GORB was in accordance with the license requirements and comm' wents. The GORB was adequately staffed by licensee employees and co, t rHed 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 evident 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 at 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. N_RC : None
t ] . ,. s 44 . K. Licensing Activities i 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 cor1 plex 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 isoletion 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 modificat on before plant restart from the Cycle 11R cutage; 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 31R 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 j i - -
l - . ,. 4S . . 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 (OCLRA) 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 j 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 ;mepared 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 (BWDI), NRR, initiatives to improve com- munications between NRC and the licensee and among the licensee within BWD1, NRR. These initiatives were in the utility contacts meetings in 1986; a mini owner's group among the licensees in BWDI, NRR to discuss common 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 SDR 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 I been completed. The licensee's efforts in the functiont.1 area of Licensing Activities has improved during this evaluation period. Conclasion i Category 2 - Trend - Improving Board Recommendations Licensee: ! None l NRC: l l None j l ! !
i 4
.: 47
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- V. Supporting Data and Summaries A. Investigations and Allegations Review During this assessment period, six allegations were received and i 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. , ' i
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. B. Escalated Enforcement Actions 1. Civil Penalties None j 2. Orders None 3. Confirmatory Action Letters None ( . . ) .
-- . ,....o 49 s. .- 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 (. ,
.0 ,. 50 2 . 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 . . . . . . . . . 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, ,
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. i i TABLE 1 LISTING OF LERs BY FUNCTIONAL AREA OYSTER CREEK NUCLEAR GENERATING STATION 1 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- Emergency Preparedness -- Security and Safeguards -- ( Outage Management / Refueling -- Technical Support 2 2 ~ Training and Qualification -- Licensing ' -- Other 7 2 2 11 1 - 1 __ q 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
, . ,. r . .~ ' - 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 i 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 k
l 4 . ,. T2-2
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j- ( 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 l 86-06 Isolation Condenser Actuation Pressure Sensors Exceeded ~ Setpoint Limit i 86-07 Reactor Shutdown Due to Reactor Low Water Level Scram I Switch Repeatability Problems 86-08 Local Leak Rate Testing Results (Voluntary Report) I 86-09 Scram Signal Received Due to Neutron Instrumentation Noise
86-10 Inoperable Isolation Condenser Snubbers l 86-11 Secondary Containment Isolation and Initiation of Standby ' Gas Treatment System 86-12 Containnient 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 4 86-17 Containment Isolations and Standby Gas Initiation Caused by Storms
i 86-18 Secondary Contaiment Leak Rate 86-19 Standby Gas Initiation Caused by Personnel Error i 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 1 4
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g. o. < , , - TABLE 3 ENFORCEMENT SUMMARY 7/'/85 - 10/15/86 OYSTER CREEK NUCLEAR GENERATING STATION A. Number and Severity Level of Violations Severity Level I O Severity Level II O Severity Level III 0 Severity Level IV 21 Severity Level V 2 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 Emergency Preparedness 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. k .
-. M ^ e ,. i ..- . 1 TABLE 4 INSPECTION HOURS SUMMARY (7/1/85 - 10/15/86) OYSTER CREEK NUCLEAR GENERATING STATION HOURS % OF TIME ) Plant Operations 1971 38 ' Radiological Controls 478 9 Maintenance 647 12 Surveillance / Inservice Testing 417 8 Emergency. Preparedness 267 5 Security and Safeguards 140 3 Outage Management / Refueling 301 6 i Technical Support 968 19 ') Training and Qualification 0 0 1 Assurance of Quality 0 0 Licensing Not Applicable Total 5189 100 . I i 1 ,
, ,.
k' 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 f 85-25 . Specialist 102 Transportation Activities 7/29 - 8/1/85 j i 85-26 Resident 124 Routine I 8/29 - 9/22/85 { l 85-27 Specialist 39 Shock Suppressors 8/19-23/85 85-28 Specialist 66 Transformers Low Oil 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 3 0.5-31 Specialist 27 Inservice Inspection Data 30/7-10/85 85-32 Specialist 103 QA Program, Document Control, 10/21-25/85 Onsite Review Committees, and Record Program . j .
.- 7 . 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 I 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)- f 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 8S Non-licensed Operator Training i 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 ( 1
i .= /- ' T5-3 - ?.- . 'IL 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 II 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 7/7-11/86 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 f( i . _ _ _ _ _
- ' , . " ' , . NggIg{ GPU Nuclear ~ 100 Interoace Parkway ParstDpany. New Jersey 07054 201 263 6500 TELEX 136-482 Writer s Direct Daal Number April 28, 1987 U.S. Nuclear Regulatory Comistion Attention: Document Control Desk Washington, D.C. 20555 Gentlemen: Subject: Systematic Assessment of Licensee Performance Oyster Creek Nuclear Station Docket No. 50-219 , This letter and its attachments provide our response to the Systematic Assessment of Licensee Performance (SALP) report as requested by your letter of March 12, 1987. It sumarizes, and in some areas, expands the information provided in our meeting of April 6,1987. We believe the SALP process and the direct discussions it promotes between the NRC and GPU Nuclear manngement is of considerable value. By design, the SALP identifies areas for improvements, and GPU Nuclear takes very j seriously the comments and observations in your assessment. We remain fully comitted to continually improving our nuclear activities and I believe the attachment addresses that goal in a positive manner. We continue to believe that SALP reports are becoming more widely known and used. Therefore, it is particularly important that they be as consistent as practical among plants and that NRC emphasize prominently in each report the manner in which they can be appropriately utilized. cc P. R. Clark President j i i PRC/MWL/pa(4585 ) 9 cc: Regional Administrator U.S. Nuclear Regulatory Comission ' 631 Park Avenue King of Prussia, PA. 19406 NRC Resident Inspector Oyster Creek Nuclear Generating Station Forked River, N.J. 08731 87p56[$O GPU Nuclear is a part of tne General Pubuc Utmties System f , C jj
i i ' c, ,;. PLANT OPERATIONS ' e Two concerns expressed in the SALP board's recommendation were in the areas of decision making on shift and operator errort. The two areas are - ' addressed separately below. -Decision Making on Shift: 1 { Direction to management shift supervisors to call and discuss significant operating events has resulted in a shift of some decision-making to a higher level. We agree this should be corrected and will take action to distinguish decision-making from notification and return proper l decision-making to shift management. Additional measures being taken ir this area include: In the Simulator Training Program, additional emphasis will be placed on shift management decision-making. Technical Specification related discrepancies and action items will be factored into training scenarios to exercise the shift supervisors decision-making abilities. 1 Specific evolutions and events were discussed with each Group Shift Supervisor (GSS) during one-on-one meetings between each of them and the Plant Operations Director. Special emphasis was placed on the GSS's role and responsibilities. The " Command Authority" memorandum was reissued and reviewed by Operations Management and the shift supervisors. During the coming year, the GSS's and Group Operating Supervisor's (GOS) will be scheduled to participate in Company sponsored management and supervisory training programs. In addition, they will also be attending GPUN teamwork and leadership seminars. Future interfaces in this area between Operations Management and tha :hift supervisors will intentionally emphasize the shift supervisors role of decision maker. Personnel Errors: Management recognized the continuing need for improvement (reduction) in the number of personnel errors. Operating incidents are thoroughly investigated to determine cause and develop measures to improve future performance. A number of measures have been taken in this area: During early 1987, the Director, Oyster Creek and Plant Operations Director met with each shift to discuss each individual's role and specific accountabilities. Additionally, the Plant Operations Director met with each shift of GSS, GOS and Control Room Operators (CRO). During these meetings, topics of discussion included individual's responsibilities, attention to detail, awareness, communications and attitude. Previous events were reviewed and Lessons Learned evaluated for the positive contributions that could be derived from these events, j 45859 -1-
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The Plant Operations Director is currently working with the Training Department to develop a revised simulator training ,. program. . The intent is to restructure simulator training to include additional operator evolutions that are more closely related to actual Plant evolutions and upsets that have been experienced. More attention will be given to startups, shutdowns and low power operation utilizing manual water level control. In addition to revising the current training program, the Company j is in the process of purchasing a full scale replica simulator. j The availability of a full scale simulator should significantly enhance operator training and result in improved response and reduction in errors. A basic principles trainer is currently i being utilized for Licensed Operator Requalification Training and l 1s proving to-be a very positive enhancement to the training program. I Technical support of plant operation has been improved. ) Appropriate technical personnel are involved in plant problems at l an earlier stage and tasked to provide more in-depth support. ' This additional engineering attention should help reduce the number of challenges'to the operators. ! Procedure, hardware and equipment improvements should also significantly contribute to a reduction in personnel error. Specifically, during the last refueling outage, there were , numerous " human factors" improvements in the Control Room. These tmprovements included control panel upgrade, controls and ' instrumentation demarcation, and reduction in annunciated alarms, The feedwater control units were replaced with a new type that should improve the operator's ability to control feedwater when in the manual mode. High priority was given to the reduction of~ Control Room deficiencies and temporary variations. Division goals were established for.both. To date, significant reductions have.been realized, and continued efforts are being directed to further reduce the number of Control Room deficiencies and temporary variations. Procedure revision and upgrade continues to receive high visibility. All these enhancements collectively should reduce the number of unnecessary challenges to the operators and significantly reduce the number of operator errors. Increased emphasis is planned for incident investigation, review with operating personnel and implementation of corrective / preventive measures. This increased emphasis on reviewing events and correcting observed problems should improve performance and reduce future problems. l l l 4585g -2- ,
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RADIOLOGICAL CONTROLS . .e-
. We' concur with the. finding that the radiation protection program is fundamentally sound as noted in the SALP Report. , , GPUN is aware of and understands the concerns raised with regard to the implementation of the programmatic approach to achieving control of radiation exposures to ensure that they are maintained at levels as low as reasonably achievable. We believe that the functional ALARA program is working well. The functional ALARA program consists of_those elements of near term job plannir.g, worker b_riefing, radiation and contamination monitoring and control, and the use of engineering controls. The performance of the functional ALARA program is measured in part by the low individual external doses and virtually negligible internal dose commitments during the evaluation period. GPUN is committed to the ALARA concept and as a result of our experience during the 10R outage, actions were taken to reduce exposure such as the following: o As part of the llR outage, the recirculation system was chemically decontaminated, the surface of the drywell was decontaminated and the atmosphere of the drywell was cooled. With these actions and others, over.950 man rems were saved during the outage. o Radiological engineers were hired by the Maintenance, Construction and Facilities and Technical Functions Divisions to provide a person knowledgeable in radiological controls within the work center. t o Considerations of radiation controls have been incorporated into the ' Preliminary Engineering Design Review. With regard to continuing concerns with the programmatic ALARA at Oyster Creek, the following actions have been taken or are underway: 1. An extensive study of ALARA performance during the llR outage was , undertaken by a group representing the Radiological Controls, Maintenance, Construction and Facilities (MCF) and Technical Functions Divisions. This study identified several areas including long range planning, work scope control, work area access control, system decontamination, and source term reduction as being responsible for the relatively large collective dose incurred in 1986 at the Oyster Creek plant. Recommendations of this study are being reviewed with regard to implementation. The dose estimation process identified in the SALP report as responsible for higher than anticipated personnel exposures is not seen as contributing to the collective dose. However, it is clear that the process needs to be iterative and dynamic in nature as opposed to the static approach taken in recent past. 2. A multi-disciplinary group representing all segments of the Oyster Creek community was convened on March 18, 1987. This group is I currently developing recommendations for an action plan to address the following areas related to the control and reduction of occupational radiation exposures: 4585g -3- ! 1
.3 Scope Control l Long Range Plan Management " ' Improving Perception of Collective Dose as a Limited Resource' Source Term Reduction Achieving Production Efficiencies Enhancing _the Role of the Dose Reduction Working Groups Reducing the Amount of Work which must be Performed in Radiologically Controlled Areas Achieving Structured Approach to ALARA Design and Engineering Reviews j These include and go beyond the elements identified in the SALP report. Another area identified as having programmatic weakness is the conservatism in the control of radiation exposure. He believe that the record of individual doses over the past years demonstrates that the Oyster Creek plant has taken aggressive steps to control the individual worker's dose at the job site. He do note that on two occasions'during the SALP evaluation period, persons did exceed station administrative dose limits although they remained well within regulatory limits. These instances point out a need to enhance our programs for routine and special surveillance and the supervisory review of radiation survey data. Senior Radiological Controls managers will conduct periodic formal reviews of all aspects of the field operations activities to ensure a level of , performance which meets established standards. The SALP report concerns with regard to access control problems had also l been identified on the basis of in-house reviews. A facility upgrade is under development to provide better control of personnel entering and exiting the Oyster Creek drywell - the highest work hour area and the one which suffers from the most congestion. We anticipate the facility improvements to be in place and ready for the 12R outage which is currently scheduled for the Fall of 1988. While we acknowledge the delays in formalizing the in-house Radiological engineering training, we do not agree it is responsible for the weakness identified in the programmatic ALARA program. We had committed to enhance the professional skills of our Radiological Engineering staff following the previous SALP. As you noted in your report, this program has changed from an Oyster Creek to Corporate responsibility. Along with the change in responsibility, we have expanded the scope of the program so that it is more appropriately a professional enhancement program (PEP). The program is being developed along INPO guidelines for Training System Development ! l l 45859 -4-
(TSD). While this PEP is under development, there is an on-going effort - .. ~ ~ to maiatain and upgrade.the professional abilities of our Radiological Engineering staff. Individual professional training is scheduled for each ! ,- member of the staff to maintain state-of-the-art competence and enhance abilities. In 1987 for example, members of the Oyster Creek staff have attended or are scheduled to attend programs in the following areas: o Principles of Respiratory Protection Program o Management Oversight Risk Tree (MORT) Analysis o Advanced theory and applied gamma spectroscopy for nuclear power plant applications o Health physics theory o Skin dose assessment He remain committed to the PEP for Radiological Engineers. In order to expedite this program, we have made a special assignment to one member of our staff to coordinate the multitude of administrative and technical tasks in this area. We have relieved this staff member from routine duties while action on the PEP is pursued. We have developed and commenced a course in ALARA techniques for managers and engineers. This program has been used for the Technical Functions Division personnel. A modified program has been developed for use by our ! personnel in the Maintenance, Construction and Facilities Division. The area of communications was identified as being weak and contributing to the concerns with the ALARA program. We concur with this assessment. Actions have been taken at the functional and programmatic levels to improve communications. At the functional level, a work planning meeting j takes place daily among the supervisors of Radiological Controls, MCF, and ' Plant Operations. This meeting serves to prioritize and allocate resources to achieve the goals set in the higher tier Plan of the Day .
(P00) meetings. We have found that in the short time that the work planning meeting has been in place, we have experienced better coordination of efforts involving work in the Radiologically Controlled l Area. At the Programmatic level, the addition of a Radiological Engineer to our . Technical Functions Division staff along with the Radiological Engineer I already a member of the MCF staff has improved the lines of communications regarding the long range planning of radiologically significant work. Additional staff in our Corporate Radiological Engineering Group have also facilitated the input of radiation protection concerns into mid and long range planning. We are continuing to upgrade the communications in these areas through development of procedures and an insistence on more frequent ! formal and informal contact among Radiological Engineers in the R&EC, MCF and TF Divisions. l 4585g -5- ,
l ~ In summary, although we believe that our radiological controls program is sound, we recognize the need for improvement. Our efforts are directed at the work planning and execution process. This involves the elements of . g interdivisional communications, improved control of work scope, access control and coordination of work through improved facilities and administrative practices and better processes for the on-going estimation of exposure goals. In addition, we are taking action to assess our radiological controls practices in our Field Operations group to reduce administrative tasks and concentrate on the surveillance and assessment elements of the program. { l We have set an ambitious 1987 collective dose goal of 300 person rem for Oyster Creek Plant Operations. Planned outage activities such as the drywell wall inspection and corrosive arrest work, and unusual forced outage work such as the drywell air cooler upgrades are not included in 1 i the 300 rem goal. Typical forced outage activities are included in the goal. We also are now treating radiation exposure as a resourc2 ic be budgeted f and controlled with the Long Range Plan. , i 45859 -6- 4 <
MAINTENANCE . ,, Based on GPUN's review of the SALP assessment and discussions with the NRC staff at the April 6, 1987 meeting, it is appropriate to comment in three , d specific areas and discuss in general the results of the MC&F self evaluation. Predictive Maintenance: The NRC Region I, 1986 Systematic _ Assessment of Licensee Performance Inspection (SALP) Report #50-219/85-98 for Oyster Creek, contains on Page 20 under Section C Maintenance, a brief paragraph concerning Predictive Maintenance at Oyster Creek. Specifically, " Predictive Maintenance has not been instituted and should be investigated as a potentially useful tool, especially in light of the age of the plant". During the April 6, 1987, SALP Review Meeting held at Oyster Creek, the Resident NRC Inspector, Mr. W. Bateman, clarified that this comment referred to the fact that Oyster Creek has no program to evaluate the life time of equipment and replace same prior to its self destruction due to age, heavy usage, wear, design, etc. This is indicative of a " Reliability Centered Maintenance Program" (RCMP) as opposed to a " Predictive Maintenance Program" (PMP). The following is a description of these programs: o Reliability Centered Maintenance A logical discipline for developing a PM Program that will realize the " Inherent Reliability Levels" of equipment at minimum Cost. Inherent Reliability Levels - the level of reliability of an - item or equipment that is derived from its design, is characterized.by a near constant conditional probability of failure, and cannot be improved by maintenance. o Predictive Maintenance - Methods used to analyze and predict equipment performance so that planned action can be taken to correct abnormalities prior to equipment failure. RCMP determines when to replace a component and PMP determines when to repair a component to avoid catastrophic failure. Oyster Creek's Plant Materiel Department, does have a working Predictive Maintenance Program. It includes Vibration Analysis, Lube Oil Analysis, failure Trending, Performance Trending, Thermovision, and Pipe Wall Thinning Inspection Programs that are working. These programs are being refined and upgraded all the time as is our Preventive Maintenance Program which we use as the vehicle to schedule all the above-mentioned evolutions. l Oyster Creek does not have a formal RCMP as yet, although Plant Materiel has researched the idea. We plan on integrating RCMP into our PMP in the future. In this way we will assure ourselves of identifying questionable equipment, particularly ITS equipment, early enough to allow advance planning and budgeting for future replacement. 4585g -7-
' ., _ Workmanship:
. g .MCf. Management and supervision are working hard to build up a qualified o work force at.0C and are committed to various programs to enhance this 7 effort. In the recent past we have not only emphasized a strong craft training program but have also instituted the use of job mock-ups, required reading items, job critiques, new procedural control for rework and recurring maintenance, and procedural control for a new PMT program. In addition, MCF is working on improving internal and external communications and simplification of work documents and reviews. Specialty contractors are also used for the obvious reason of getting a better end product in an area where our own work force has not been adequately trained. At present, all GPUN Divisions are working diligently on work -o simplification to overcome several concerns. The Interdivisional Work Simplification Committee is looking hard at reducing lengthy procedures, encouraging more work to be controlled by work orders (Short forms Long forms), improving / reducing document flow paths, simplify / reduce paper tracking (via GMS/2, etc.), and simplifying some areas dealing with contractors. One of the direct benefits of the work simplification effort will be to allow Job Supervisors to spend a greater percentage of their time in the field monitoring the craft and workmanship. The issuance of the MCF Division Procedure, A000-ADM-7100.01 titled o " Control of Rework and Recurring Maintenance" effective February 4, 1987, formally addresses this SALP concern. While it is too early to quantitatively or qualitatively evaluate improvement based upon the issuance of this procedure, it is anticipated that the existence of the procedure will bring salutary effects in the near future. The MCF Production Director recently gave a detailed presentation of the new procedure to all MCF management at an expanded staff meeting. o MCF Division Procedure A000-ADM-7175.01 was issued in December of 1986 I and controls the new Post Maintenance Testing Program which is expected to have a positive affect on the workmanship issue as well as the rework and recurring maintenance issues. Recent training of MCF planners on their new PMT responsibilities and available resources has already produced a marked improvement in PMT awareness and establishing requirements in work packages. PMT is also being addressed in the rewriting / upgrading of standard maintenance procedures during the required biennial reviews. This process will continue through October 1988. In contrast to the prior SALP findings, today's electrician and mechanic o On the Job Training (0]T) has experienced great success largely because of management involvement and management's recognition of the OJT benefits. Management is committed to the goals that 50% of all craft will have some OJT in 1987 and that all craft will have completed their, 0]T in two years. The attached Training Program OJT sheets and Classroom Hours demonstrate, graphically, this commitment. 1 45859 -8-
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Procedure Compiiance: ,,g. The MCF Division has established written procedures and policies concerning procedure compliance and revision. The requirements are clear in regards to 8' action to be taken when procedures appear not to be implementible as written. Division programs to minimize procedure non-compliance have and will continue to be improved to reduce the potential for a non-compliance occurring which could have an impact on the safety of the plant. The Company undertook a general review of procedure compliance in the Company during 1986. The following excerpt is from the final report (Procedure Compliance Task Group Report, 6/31/86), of the review as pertains to the Oyster Creek Maintenance: "In general, MCF Division Upper / Middle Managers expect their managers, supervisors and doers to always follow procedures as written except for obvious and minor administrative issues that do not impact safety. Some personnel did indicate that procedures shall be followed as written or changed if not implementible verbatim. Supervisory and doer personnel are familiar with the expectations of the Upper / Middle Managers. Doers generally rely on the judgement of their supervisors to resolve procedure implementation problems they encounter. MCF Division doers generally resolve procedure implementation problems by contacting their supervision and stopping the job. All doers felt they had received appropriate responses when they have asked for
procedure clarifications or reasons for procedure requirements. Doers ' did generally acknowledge their own, their Supervisor's and their Manager's accountability to assure that procedures reflect what is being performed and that the procedures are implementible as written." In 1985 there were 55 QDR's assigned to MCF; of those, 21 were related to procedure non-compliance. In 1986 there were 76 QDR's assigned to MCF' of those, 30 were related to procedure non-compliance. In the first quarter of { 1987 while only 1 QDR has been assigned to MCF, it does not involve a . procedure non-compliance. A large factor for the number of QDR's in 1985 and j 1986 was because of numerous contractor personnel on site performing outage j r related work. The OC-MCF Technical Support section has been performing a major review and upgrade to the maintenance procedures (see below for more information on this ~ I work). During the course of the review it has become clear that the content of the majority of maintenance procedures is adequate for the work, but needed minor upgrading in several areas. A Human Factors format which will reorganize and clarify procedures in addition to expanding Post Maintenance Testing instruction is being incorporated into the procedures. . j 4585g -9- i
During 1985 the number of procedures in which improvements were made is as i* follots: MCF maintenance procedures which were reviewed and upgraded in 1986
1 January 1 July 5 February 5 August 8 March 18 September 12 April 23 October .42 May 26 November 54 June 10 December 28 1986 TOTAL 232 During the first quarter of 1987 an additional 87 procedures have been upgraded, 17 of which have been reviewed and approved. With this maintenance procedure upgrade effort, procedure compliance will be improved even more. Self Evaluation Results: The Maintenance, Construction and Facilities (MCF) self-assessment reviewed activities for the time period November 1985 to November 1986. This time period included the 11R Outage. The assessment utilized OCNGS Maintenance, . ' Construction and Facilities personnel with inputs from representatives from the Nuclear Assurance, Radiological and Environmental Controls, THI-2, and Oyster Creek Divisions. The MCF Division recognizes the need for self-evaluation and assessment to identify areas for improvement and to exercise management control over actions on a continuing nature to preclude degradation of satisfactory performance previously achieved or to identify areas for improvement in the existing program. The GPUN Maintenance Program has made substantial progress in 1986. Future improvements in the maintenance program are necessary and will flow from plans i in place or those which are being developed. These improvements are in the following areas: Continue to upgrade the maintenance procedures technically and include o the new Post Maintenance Testing requirements, Simplify the implementation of the Work Management system. o Continue training program for Company Mechanics, Electricians and I&C o Techs. Continue to improve radiological aspects of work to reduce individual o and collective exposure and properly implement ALARA concepts. Continue to reduce accidents and injuries. o l 4585g -10-
i . f." o Upgrade the required reading and PRIR programs. Issue a procedure governing the PRIR process. ' ' Close out existing critiques and perform future critiques in an o expedient manner to get to root cause and correct problem. o Continue use of specialty contractors. Reduce paperwork burden to enable supervisors to spend more time in the o field supervising work. Reduce corrective maintenance backlog to reasonable size. o formalize and implement plan to reduce rework in maintenance activities, o o Update plant drawings. Implement automated systems to simplify job closecut process. o Improve maintainability programs by providing training to engineers and o l planners. Implement corporate maintenance labeling program, o Maintain status in all aspects of maintenance program which have o improved to meet the Company's standards. The maintenance program at OCNGS has improved in 1986. Programs have been j established to continue the improvement in 1987. Continued management l attention to achieve excellence within maintenance at OCNGS continues at very ! high levels of management. l ! > l ! 45859 -11-
5 i ! I
SURVEILLANCE / INSERVICE TESTING , ' .Zn Section D,." Surveillance / Inservice Testing," a concern was identified that the Standby Liquid Control. Tank Level Indicator is not functional and that , d- flow indication for ESW System II is erratic. ~ A new level measuring system for the Standby Liquid Control Tank is scheduled for installation in Cycle 11. The engineering and material procurement is in . process with_a Final Design Review scheduled for May'1987. It is' anticipated that engineering will be released for construction in July 1987. Installation of the level sensor indicator will be accomplished during plant operation. The. remote level indicator in the Control Room will be installed during an outage. An annubar flow measuring system for ESW System II is scheduled for installation during a Cycle 11 target of opportunity outage. The installation specification was released for construction on March 26, 1987 and is in the - planning process. i 4585g -12-
I OUTAGE MANAGEMENT / REFUELING i , j ' ' s f Contingency planning at Oyster Creek is controlled in several ways. These are { by Long Range Planning, Integrated Living Schedule, Integrated Schedule, e' individual job / task contingency planning, and outage work scope control. j l The GPUN Long Range Plan basically looks ahead at the next 5 years and o projects.the work scope for both the operating and outage cycles, Work scope is controlled and authorized by cycle. -The Integrated Living ] Schedule is a joint effort between the licensee and the NRC to coordinate certain mandates / requests into the Long Range Plan. The past J ICM and llR outage and the Drywell Thinning Inspection outage due in the I fall of 1987 are examples of this coordination. At the Oyster Creek site, MCF Planning and Scheduling group develops an Integrated Schedule taking into account the Long Range Plan, the Integrated Living Schedule and all the OC site needs. This Integrated Schedule is then " fine tuned" and fed back into the plans and schedules. A manhour contingency is " built in" to this schedule (usually 20%). Approximately 3 months prior to an outage, work scope control is formally transferred to the V.P./ Director - OC. Any additional work scope then must be approved by the Site Director. Project Task Contingency Planning is developed at the project o engineering level and ultimately becomes part of the other plans and J schedules. Examples of this type of contingency planning used at Oyster Creek are: Recirculation Piping Replacement - During the llR Outage NDE was o required to be performed on all recirc piping to determine the extent of Intergranular Stress Corrosion Cracking (IGSCC). A contingency plan was developed to replace 100% of the piping if required by the NDE results. As part of this contingency plan, chemical DECON of the piping system was done to minimize exposure (ALARA) for the pipe replacement or weld overlay repairs. Core Spray Sparger Piping - Approximately 6 years ago cracks in the o sparger piping was discovered during the reactor vessel internal inspections. Special clamps were installed to correct the problem. However, a contingency plan was developed'to replace 100% of the sparger piping if required as a result of future vessel internal inspections, Emergency Condenser Piping - A contingency plan was also developed o to replace 100% of the Emergency Condenser Piping based on the results of the llR inspection. 45859 -13-
Individual task contingency planning is performed by the Job Planner by . o ' .~ doing a risk reduction assessment of parts inventory, reviewing equipment history, and thoughtful study of all the facets of the task. Based on the risk reduction assessment, the planner will ensure that , 8 long lead items and adequate quantitles of parts are available with a built in contingency in case something unforeseen develops while performing the task.
4585g -14-
TECHNICAL SUPPORT , GPUN agrees that the favorable comments in the SALP regarding our Startup and Test Group is an accurate assessment and the comments are appreciated. He
also agree with your assessment that technical support h6s a number of strengths and weaknesses described as inconsistent. GPUN will undertake a self-analysis to determine the root causes for the inconsistent performance. We request that the SALP board recommendation; that is that the NRC conduct a team inspection of technical support groups to determine the causes of inconsistent performance, be delayed until GPUN has completed the self analysis and initiated corrective actions. In addition to the above self analysis, it is appropriate to comment on four general areas mentioned in the assessment summary. Inadequate Control of Vendors: GPUN recognizes that greater accountability from external engineering organizations is required. We have in the past several years established various in-house control mechanisms to insure appropriate quality engineering work is performed by the various external engineering organizations. Institution of these control mechanisms has been effective. However, with a multitude of external engineering organizations being utilized, the client / contractor interface, the administrative effort, and the review process becomes very burdensome and more prone to diffuse accountability. GPUN, therefore, has recently instituted a " Core Architect Engineer" concept. Basically the " Core Engineering Concept" will limit the number of external engineering organizations performing work for the Oyster Creek facility. Currently we are contracting with two (2) A/E organizations and expect that in the future, one of these organizations will be chosen to perform all the external design engineering needed by GPUN. The expected advantages of the concept are: 1. The organization will become thoroughly familiar with Oyster Creek. 2. The working procedures, personnel interfaces, QA expectations, documentation required, etc. will be accomplished more effectively and , ' efficiently. 3. Continuity of personnel at the A/E's firm 4. An improved concept of organizational accountability 45859 -15- - -
Backlog of Work: , , There are several factors and actions GPUN has taken which should reduce , and make more manageable the backlog of technical support work. 1 - Oyster Creek's cycle 10 and cycle 11 refueling outage included major plant upgrades and satisfied many regulatory required modifications. The level of effort expended on the initial compliance of major programs such as Appendix R, NUREG 0737 items, Environmental Qualification of Electrical Equipment, etc. has been largely completed. New controls, procedures and program awareness will preserve and maintain compliance in these areas for existing plant equipment as well as new modifications Future refueling outages can be devoted to reducing the backlog of work, provided new regulatory required items are not excessive. - For 1986, goals for the reduction of the backlog were established and efforts, including working on an overtime basis, were made to meet those goals. Some degree of success was realized during this time frame. However, the established goals were not met. The goals for reduction of backlog have been set for 1987 with additional emphasis being placed by upper management on attaining the goals. j - GPUN's long range planning and prioritization process is making more ] effective use of available resources. Although a reduction in the backlog is not an immediate benefit from this process, it insures that GPUN is addressing the "important" tasks. - GPUN submitted the Integrated Living Schedule concept as a Technical Specification Change Request on January 27, 1987. He believe that upon approval by NRC, efforts needed to accomplish NRC driven work will become more manageable. The majority of late engineering for the cycle 11 refueling outage was NRC driven. Technical Expertise: In discussion during the NRC SALP meeting on April 6, 1987, NRC clarified that the statement in the SALP inspection regarding " weak technical expertise" referred to insufficient technical expertise allocated to some projects rather than the quality of technical expertise within GPUN. GPUN agrees with the concern as expressed at the SALP meeting. Proper prioritization, adequate control of vendors, improved communications and the self-analysis committed to, should result in the proper level of technical expertise being allocated. j t 4585g -16-
' ' Communication: . , d- We recognize that a functional organization structure such as GPUN's demands that emphasis be placed on proper communitation channels being , established and maintained. 5 GPUN has established several major interface programs that address the communication concern. For example, a large percentage of management personnel has attended a Team Building and Leadership Program". This particular program emphasizes team work and mutual suppor t for more effective results. We have received very encouraging feedcack from employees who have attended this course and plan to extend the course to lower levels of management. Another example is the Divisional Interface meetings that have been formally initiated. Upper management (Division Directors and those personnel that report directly to them) from two divisions meet to discuss how working relationships between them can be improved. Recently, on April 20, 1987, a meeting between the Technical Functions Divi:lon and the Maintenance, Construction and Facilities Division took place. GPUN regards the area of technical support to be a significant program element in the safe and efficient operation of the Oyster Creek facility. We believe the specific actions described above and the self-analysis wil: i , serve to correct any inconsistent performance within this functional area. 1 1 45859 _17_ l
t ' ' , ASSURANCE OF QUALITY , st
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One of the SALP board's recommendations was to reduce the number of ,- trivial QA/QC findings that other divisions must respond to and continue to upgrade the professionalism in QA/QC. GPUN QA management have for several years been putting emphasis on identifying and correcting minor problems by on the spot action without the need for the more formal and administratively' demanding QDR process. 1Huch progress has been made in this area over the last three years but . continued attention and refinement is warranted. To assist in this, site _ QA will analyze.the specific QDR's reviewed by the NRC resident and get feedback from the resident on his particular concerns. Based on the results, QA will define and implement any additional specific actions which appear appropriate. With regard to the professionalism of the QA/QC staff, GPUN is' committed to an ongoing program of excellence in all aspects of its operation. In- this regard, QA management are continually striving for improvement in human performance and professionalism. These actions are implemented through the department's goals and objectives program, employee performance evaluation program, internal and external training. programs, and reaction to findings and recommendations of internal and external reviews and audits. . ! i i l ! 4585g -18- I ' i }}