ML20236J255

Nuclear Safety & Compliance Committee Semiannual Rept 7 for Apr-Sept 1987

ML20236J255
Person / Time
Site:	Oyster Creek, 05000000, Crane
Issue date:	09/30/1987
From:	Phyllis Clark, Humphreys L, Laney R, Witzig W GENERAL PUBLIC UTILITIES CORP.
To:	Murley T Office of Nuclear Reactor Regulation
References
2175, NUDOCS 8711050231
Download: ML20236J255 (18)

Text

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NUCLEAR SAFETY AND COMPLIANCE COMMITTEE

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SEMIANNUAL REPORT NUMBER 7 FOR THE PERIOD i

APRIL-1, 1987 TO SEPTEMBER 30, 1987 i

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1.0

SUMMARY

i 2.0 EVALUATION OF SAFETY AND COMPLIANCE 2.1 OPERATIONS 2,2 MAINTENANCE 2.3 TECHNICAL SUPPORT 2.4 NUCLEAR ASSURANCE l

2.5 TRAINING l

2.6 RADIOLOGICAL CONTROLS 2.7 OTHER ACTIVITIES 3.0 ACTIVITIES OF COMMITTEE AND STAFF I

3.1 GENERAL 3.2 COMMITTEE-ACTIVITIES 3.3. STAFF ACTIVITIES EXHIBIT 1 NSCC DOCUMENT /INFORMATION SOURCES-EXHIBIT 2 NSCC STAFF ACTIVITIES /INFORMATION. SOURCES-EXHIBIT 3 PERSONS INTERVIEWED / CONTACTED BY NSCC STAFF DURING l

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SUMMARY

Safety and compliance at the General Public Utilities Nuclear (GPUN)

Oyster Creek and TMI-l facilities were the object of independent evaluations by the Nuclear Safety and Compliance Committee (NSCC) of the GPUN Board of Directors and by the NSCC Staff during the period April 1

through September 30 1987.

operator performance, proc,edural These evaluations focused on compliance, and maintenance activities.

TMI-l operated at nearly full power for most of this period.

At the end of this period Oyster Creek remained shutdown by a U.

S.

Nuclear Regulatory Commission (NRC) Confirmatory Action Letter.

Throughout the period, Oyster Creek operation was interrupted by i

three forced

outages, and output was frequently reduced by 4

equipment failure and seasonal environmental limits.

TMI-l activities were saf e and a positive attitude toward safety and compliance was apparent.

However, recent operator errors at i

THI-1 indicate a need for reaffirmation of management's position

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regarding attention to detail in the conduct of operations.

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Committee and Staff observations lead us to conclude that there was a less than satisfactory compliance record at Oyster Creek during this period.

A Technical Specification Saf9.ty Limit violation, seven Notices of Violation from the NRC, and thirteen Licensee Event Reports substantiate this conclusion.

Violations i

noted were attributable to deficiencies in personnel performance, procedures, communication, and management controls.

Although

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performance has been less than satisfactory, actions taken to l

correct deficiencies indicate that there is still a positive

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attitude toward safe operation.

The recent discontinuance of one nonconservative practice, bypassing operable neutron monitoring channels, is seen as indicative of that attitude.

Corrective actions to address additional concerns associated with the Safety Limit violation were still being formulated at the end of the period, and will be evaluated by the Committee in the future.

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2.0 EVALUATION OF SAFETY AND COMPLIANCE The following is a functional breakdown of the evaluation of TMI-1 and Oyster Creek for the period April 1 through September 30, 1987.

The evaluation was performed by the NSCC and the NSCC Staff.

For the most part the statements pertain to conditions existing at the time of the evaluation.

Corrective actions of which the Committee is aware are also noted.

All items of significance have been discussed by the Committee and the Staff and reported by the Committee to the GPUN Board of Directors and corporate management at regular monthly meetings.

1 2.1 OPERATIONS TMI-1 was at power during most of the evaluation period.

A planned trip and recovery was performed on May 1-2 to test transient effects on the redistribution of flow restricting mineral deposits in the Once Through Steam Generators (OTSG).

The test was completed safely and resulted in improved OTSG performance.

Planning, walkthrough briefings, and increased personnel coverage were keys to that success.

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been informed that long-term plans do not rule out further test trips for transient redistribution of OTSG deposits.

In the Committee's view, cuch actions unnecessarily challenge the plant and should be avoided in the future.

i Control Room formality remained high throughout the period at TMI-1 and showed continued improvement at Oyster Creek.

Operator errors at TMI-1 indicate a

decrease in operator attentiveness and a possible need for more management / supervisory surveillance during major plant activities.

On May 2

an unplanned trip resulted from an operator switching error; on June 13 an unplanned trip occurred when an cperator overcompensated in his efforts to manually control feedwnter; on June 26 the Reactor Protection System was actuated by en operator switching error; on September 27 a

lanned liquid release was performed with one radiation monitor RM-L-6) in defeat.

Oyster Creek Control Room operators displayed improved proficiency during plant transients.

Quick operator action averted scrams on two occasions (loss of instrument air on April 15, and feedwater control valve failure on July

9) and almost averted a scram on July 30 when a Main Steam isolation valve failed closed.

However, other events revealed serious deficiencies in maintaining awareness of overall plant status and applying Technical Specification requirements.

The Safety Limit violation on September 11 and the violation of containment integrity on April 24 are the principal examples.

The Committee is aware of the many initiatives completed or underway as a result of these j

events and will continue to monitor progress.

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.The violation of primary containment integrity at Oyster Creek on April 24-was due, in'part,.

to inadequate response to previous

- events which identified deficiencies in.the control of temporary

- variations.

Since this event there has been a concerted. effort to reduce the number and improve control of temporary variations.

Review.of the contrpl of temporary modifications at THI-1 has

'also revealed some problems

- a revolving numbering system, the lack of a controlled index of temporary. modifications, and the failure to cross-reference related-log sheets are not typical 1 of

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a sound administrative practice.

There does not appear to be a control mechanism at TMI-1 by which to ensure that all shift operating personnel are cognizant of the status of temporary modifications.

Management attention to such controls -is essential.

On several occasions at Oyster Creek, operable neutron monitoring

. ere bypassed to eliminate operational channels or.their inputs w

- restrictions.

While it acknowledges that care was taken in each instance to ensure that Technical Specifications were not violated,. the Committee does not. regard these actions as indicative of a conservative attitude toward plant' safety.

By way of.an Operations Memorandum, an acceptable policy regarding the. bypassing of. these channels-has-been promulgated,- and compliance-with that policy is evident.

During startup.from the 11U-5

outage, for

example, the-operators took appropriate, conservative action.

The Committee is satisfied with the results of actions to date, but recommends that long-term action-include appropriate procedural revisions and discussion of the policy in operator training.

The incident at the Peach Bottom nuclear plant has focused industry. attention on operator -alertness.

The Committee notes that GPUN has responded with further emphasis on existing administrative programs concerning operator alertness and offshift management tours.

2.2 MAINTENANCE The 6U-1 outage at THI-1 and the three forced outages at Oyster Creek were well-planned and controlled.

The Committee notes with l.

approval that at Oyster Creek. outage length has not been limited to.that required for dealing with the immediate causes of outages; time for work to improve plant reliability - e.g.,

drywell fan cooler replacement in 11U-4, and V-2-35 repairs in 11U-5 and 110 has also been provided.

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Maintenance management. attitude and quality performance of maintenance activities at TMI-1 have been instrumental in meeting operational commitments.

However, the quality of maintenance and maintenance administ.rative controls at Oyster Creek remains a concern.

The 11U-4 outage was caused by the failure of an acoustic monitor that had been replaced during the 11R outage.

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were installed in' a', control valve.

tae July 9 feedwater Ltransient was the result of improper reassembly of a feedwater regulating valve following overhaul.

Valve V2-11 did not receive applicable code testing-following replacement because post-maintenance test requirements were.not properly incorporated into Lthe work package..

.Four out.of 10 containment vent and purge valves were found'to exceed Technical Specification limits on

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opening because of procedural. inadequacies..

The safety. limit violation..of ' September 11 was precipitated by violations'of maintenance procedures and work control procedures relative'to the. rapacking of valve, V5-167.

Changes.in organization and administrative control such as those recommended by.the Work Simplification Task Force have been; initiated.

The'. Committee

.will continue monitoring maintenance activities for signs of.

improvement.

Recent. elevation of the Plant Materiel function at each' plant'.is

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an appropriate step-toward addressing continuous and/or recurring problems.

'In the case of-' Oyster

Creek, the challenge to management increases'because.of equipment aging.

There has been a concerted effort to reduce the number of Control Room _ deficiencies and temporary. variations at Oyster Creek'.

While the latter remains ' higher than desirable, the Committee acknowledges the progress being made.

The Maintenance backlog is high at both sites but.recent efforts.

have succeeded-in reducing them.

2.3 TECHNICAL SUPPOP.T Site Technical Functions representatives have been responsive to plant requests

.for engineering and ' modification

support.

However,,-design modifications have not always satisfied plant needs - Intermediate Range Monitor range switch and chlorination

. system modifications at Oyster Creek, for example.

Corporate support was effectively applied to the Oyster Creek drywell wall thinning problem._

Under the direction of a

Technical Functions Project Manager, the problem was aggressively analyzed 'for -corrosion. mechanisms, corrective measures were

. evaluated,-and the cathodic protection system was designed.

Nith respect to Core. Engineering at Oyster Creek, support has L

been erratic.

In April, poor' communication on the reason for a flux. peak contributed to the bypassing of an operable APRM channel.

Organization changes and the temporary assignment of Parsippany-based engineers to the site appeared to improve j

' internal communication and responsiveness to plant needs.

In August, a similar flux peak was experienced and the Core 4

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Engineer again recommended bypassing the APRM channel.

When the operators refused, the' problem was solved by a change in the rod

. withdrawal sequence.

This indicated that -the lessons learned from the first event and the changes in operating. philosophy had not been-effectively communicated to'the Core Engineering group.

Continued effort to improve the interface with Operations is required.

Plant ~ Engineering organization's have been. responsive to plant needs.

.At Oyster

Creek, demand for engineering services has i

. exceeded the capacity for support, which has resulted in a-large backlo f Plant Engineering Work Requests.

This is currently

.being'g oaddressed by-a special task force.

l Plant _ Chemistry groups have provided good support to Operations, although the Committee notes with concern that the source of

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chloride contamination of a. portion of the THI-1 Decay Heat J

Removal System and Reactor Coolant System during the 60-1 outage

- has not yet been identified.

Site Licensing groups continue to provide good support.

However, the Committee notes with concern tsat more than 50. percent of the Licensee Event / Reports submitted by Oyster Creek this year have exceeded the-30-day time limit.

As coordinator of these st.omittals, site Licensing bears primary responsibility, but all

- departments that contribute technical input or conduct reviews must work together to correct this situation.

'2.4 NUCLEAR ASSURANCE The. Quality Assurance / Quality Control (QA/QC) organization at each site is effective.

Reorganization of the TMI-l Independent On-Site Safety Review Group (IOSRG) has-been beneficial.

Details.of this j

reorganization and long-range expectations were presented to the l

Committee by the newly appointed Manager of Nuclear Safety for l

TMI-1.

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The Oyster' Creek IOSRG has conducted in-depth investigations of

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significant events.

It provided detailed analysis and j

recommendations on the April flux peak' incident and the violation

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the tying open of the drywell to of containment integrity)(i.e.,

torus vacuum breakers.

It also conducted the initial l

investigation of the Safety Limit violation.

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Emergency preparedness at both sites has been satisfactory.

The j

I annual-graded exercise at Oyster Creek, conducted on May 12, demonstrated the ability of the emergency organization to protect public health and safety.

Many previously open items were closed in.the NRC critique of the exercise.

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during the evaluation. period, long-distance phone communications and all dedicated emergency lines to offsite organizations were rendered inoperable.

In each

case, alternative means of communication were available.

It is noteworthy that lessons learned from the first occurrence significantly reduced the time required to initiate backup communications in the second.

2.5 TRAINING Site Training organizations at both sites have been effective in responding to plant needs.

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commitment to provide additional training to Oyster Creek

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operators on feedwater control has been satisfactorily met.

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Moreover, according to a

Staff follow-up of several Licensee Event Reports (LERs), site training programs have been effective in providing feedback to affected employees on significant events.

Staff review findings also reflect satisfactory progress in meeting commitments made to the Institute of Nuclear Power Operations at the time of Oyster Creek accreditation.

One exception to such progress is Mechanical Maintenance on-the-job training, which at the current rate will not be completed on schedule.

The results of the Licensed Operator Requalification Program annual examinations were reviewed at both sites.

Oyster Creek results were favorable.

THI-l experienced a slightly higher than normal failure

rate, but no programmatic problems were identified.

j The vacuum breaker incident and Safety Limit violation at Oyster Creek indicate a need for a more detailed review of Technical Specifications and their bases.

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The THI-1 simulator is being effectively used for operator j

training.

Staff review of the TMI-1 simulator indicates that performance deficiencies remain that must be corrected to satisfy

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future NRC certification requirements.

However, discussions with GPUN personnel afirm that appropriate actions are being taken to correct these deficiencies.

2.6 RADIOLOGICAL CONTROLS Strong emphasis has been placed on ALARA (as-low-as-reasonably-achievable) and other exposure cont.rols at both sites.

Despite these efforts, it appears that Oyster Creek will exceed its 1987 goal by a

substantial

margin, even when the calculation is corrected for unplanned outages.

Goals are important and with realistic estimates can be achievable.

Rather than demanding an arbitrarily low number, goals should be set to achieve constant incremental improvement.

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Review of 1987 Radiation Incident Reports revealed that there j

have been six violations of locked high radiation areas.

Three i

of these incidents have occurred within the past two months.

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trend indicates a lack of awareness and control.

While none have resulted in overexposure of personnel, a

breakdown in these potentially dangerous consequences.

The procedures has 1

Committee will continue to monitor and evaluate corrective l

actions.

1 Maintenance efforts have been effective in achieving a very high availability for the Augmented Off-Gas System at Oyster. Creek.

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However, there are still excessive deficiencies in radioactive l

waste processing equipment, resulting in chronic lack of redundancy.

2.7 OTHER ACTIVITIES The vacuum breaker incident at Oyster Creek was caused by improper control of temporary variations, compounded by deficiencies in the implementation of the safety review process.

Procedural revisions, personnel retraining, and other appropriate corrective measures.were initiated as a result.

Despite these actions,. monitoring of temporary variations by Operations QA revealed that in the three months subsequent to the event, the majority of safety reviews had deficiencies.

Deficiencies identified in this event are typical of generic weaknesses in process implementation that are common throughout the GPUN system.

The Committee is concerned that so many deficiencies in implementation exist a full year after the corporate procedure was issued.

The Committee and Staff routinely review reports of event investigation such as LERs, Transient Assessment Reports, Plant Incident Reports, and division and department critiques.

These reports vary widely in quality of analysis, particularly with regard to the determination of root cause, and also in format.

A corporate procedure intended to establish uniformity in such evaluations was drafted in December 1986, but has not yet been issued.

The Committee recommends that issuance of this procedure be expedited to improve the consistency and quality of event investigations.

The Committee finds the Plant Performance Reports to be informative with respect to the trends in plant parameters, but that differences in the presentation of data make the comparison of plants difficult.

In previous

reports, the Committee has expressed concern regarding the biennial review of procedures In response, GPUN committed to having all reviews current by June 1, 1987.

It is apparent that this commitment was not stressed to the persons primarily responsible for the conduct of the review programs at each site.

The goal was not achieved at Oyster Creek.

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The' Committee-received the GPUN response dated September 18, 1987.

to 'its Semiannual-Report Number 6.

A preliminary review I.

indicates that all-l of the Committee's comments-have received thoughtful-consideration and discussion.

If, -after.a full review,.the Committee has any questions, 'it will discuss them with Mr. Clark..

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' ACTIVITIES OF' COMMITTEE AND STAFF

-3.1.

GENERAL The Nuclear Safety: and Compliance Committee guides.the NSCC Staff's investigations

.and approves

.its schudules

_and expenditures.. Staff activities' involve both routine-monitoring andispecial'. reviews.

Routine monitoring. covers:all functional areas at each site and. at corporate' headquarters.

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long-range schedule' of monitoring activities. is developed every 6 months, and activities are added at the request of the Committee'whenever plant-events o r.

industry; occurrences dictate.

The' Committee reviews-various corporate reports such as those listed in Exhibit-1.

Upon occasion these result in special tasks for the Staff.

3.2 COMMITTEE ACTIVITIES In addition ;to the activities described above, the' Committee meets-monthly; with 'the Board of Directors of General Public

. Utilities Nuclear-and reports on any itemssof significance with

arise between board meetings may.

Questions or concerns which may respect to safety 1or compliance.

be conveyed to the_ Chairman or President'of'GPUN.

The-Committee meets with senior members of the-Staff prior to the monthly. meetings of the Board of Directors.

These meetings frequently include presentations by and discussions with selected GPUN personnel, on subjects of interest to the Committee.

During this report period, discussion topics have included TMI-1 IOSRG reorganization,' Babcock & Wilcox J

'0wners. Group activities, TMI-1 simulator

status, pipe wall h

thinning, TMI-1 once-through steam generator fouling, emergency preparedness, filtered vent systems, Reed report,. and the safety review process.

This report period ' contained two additional Observations Meetings between the Committee, Staf f, and GPUN executives.

Observations Meetings provide a

forum for the Staff to present additional observations and comments on plant activities which may not have safety significance.

Committee-members attended two TMI-1 General Office Review Board meetings during the period, Dr. Witzig toured.0yster Creek

once, and tours were conducted at both sites as a part of the Board of-E Directors meetings.

3.3 STAFF ACTIVITIES The Staff, which is. permanently stationed at the plants, gathers information on plant activities in many ways:

plant tours; monitoring-of activities; attendance at meetings; interviews with GPUN personnel; and reviews of reports, correspondence, and other 9

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Plant operations and maintenance activities receive

' primary attention, but support functions are also evaluated.

The NSCC Staff has management, operations, maintenance, training, and licensing and safety review expertise.

Evaluations during this period concentrated on areas an'd activities described ~in 'Section 2.0.-

A list of-activities'and

'information sources used in the Staff. evaluations is presented as Exhibit 2.

The types and number of GPUN personnel contacted during this period are indicated in Exhibit 3.

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' EXHIBIT 1 I

NSCC DOCUMENT / INFORMATION ' SOURCES GPUN SOURCES (both sites unless otherwise noted)

Plant Incident' Reports (THI-1)

Deviation Reports.(OC) j Licensee Event Reports Licensing Correspondence Significant Events Reports l

Off-Shift Tour Reports i

Post-Trip Review Group Reports Transient Assessments Reports l

IOSRG Evaluation-Reports GORB Meeting Reports-QA Monthly Assessment: Reports QA Quarterly Trend Reports

' Attendance at GORB Meetings Plant Tours Meetings with GPUN Management l

OTHER SOURCES NRC Notices NRC Generic Letters NRC Regulatory Guides and NUREGs NRC SALP Reports Industry Periodicals (e.g. Inside NRC, Nucleonics Week)

NRC Inspection Reports INPO Evaluation Reports INPO Nuclear Power Plant Operational Data Report NRC Performance Appraisal Team Reports h

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s EXHIBIT 2 NSCC; STAFF ACTIVITIES /INFORMATION SOURCES

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r PLANT' TOURS General Walkthrough/ Housekeeping Observations Off-Shift Tours Control Room Observations Maintenance Observations Surveillance. Test Observations Radwaste Handling Observations MEETINGS Daily Plant' Status : Meetings

' Outage Planning' Meetings NRCLEntrance/ Exit Meetings INP0. Training Evaluations GORB Meetings Post-Trip Review Group Meetings Maintenance Critiques (OC)

DOCUMENT REVIEW GPUN' Sources Plant Incident Reports (TMI-1)

Deviation Report-(0C).

Licensee Event Reports Incident Critiques Licensing Correspondence Significant Events Reports Off Shift Tour Reports

~QA Audit Reports QA Monthly' Assessment Reports

-QA Quarterly Trend Reports Operations QA Monitoring Reports =

Shift. Monitor Reports (TMI-1)

STA Daily Reports Operations Night Order Book Log Books (Operations, STA, Chemistry, Maintenance, Radwaste)

Shift Turnover Forms MNCRs, QDRs Radiation Awareness Reports Post Trip Review Croup Reports f

Transient Assessment Reports Maintenance Work Order Packages 12

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GPUN Administrative Policies and Procedures

. Station Procedures (e.g., Admin, Operations, Maintenance)

Operations QA Plan Technical Specifications Training-System Descriptions i

J Training Lesson Plans Plant Drawings.

l IOSRG Evaluation Reports GORB Meeting Reports 8

other Sources l

NRC Notices i

NRC Generic: Letters NRC Regulatory Guides and NUREGs.

NRC SALP Reports INPO Evaluation Reports INPO Guides ANSI Standards ASME Codes l

Code of Federal Regulations (10 CFR)

Industry Periodicals (e.g., Inside NRC, Nucleonics Week,)

l NRC Inspection Reports NRC' Performance Appraisal Team Reports i

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EXHIBIT 3

. PERSONS INTERVIEWED / CONTACTED BY NSCC STAFF DURING REPORT PERIOD SITE PERSONNEL (both sites unless otherwise noted)

VicefPresident/ Director (TMI-1)

Vice President / Director (OC)

Deputy Director (OC)

Operations and. Maintenance Director (TMI-1)

Plantioperations Director MCF Director 1

Department Managers, Supervisors, and Personnel ~

Plant' Operations Plant Maintenance (TMI-1)

Plant Materiel.(OC)

Maintenance, Constructions, and Facilities Plant Engineering Plant Chemist-Special Projec - (OC)

Plansfand Programs Safety Review Group (OC)

. Plant Review Group (TMI-1)

Technical Functions (OC)

Licensing Plant Analysis and STA Startup1and Test I

CORPORATE PERSONNEL Vice President, Nuclear Assurance Director, Training and Education Director, Quality Assurance 3

Managers and Other Personnel j

Licensing Training and Education j

Safety Analysis and Plant Control Quality Assurance j

Technical Functions Maintenance, Construction, and Facilities i

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GPU Nuclear Corporation gg.

One Upper Pond Road Parsippany, New Jersey 07054 201 316-7000 TELEX 136-482 Writer's Direct Dial Number:

201-316-7797 November 2,1987 2175 Dr. Thomas E. Murley

-Office of Nuclear Reactor Regulation United States Nuclear Regulatory Commission Washington, DC 20555

SUBJECT:

NUCLEAR SAFETY & COMPLIANCE COMMITTEE (NSCC)

'My-letter to you' dated May 1,1987 provided the semiannual report of the Nuclear-Safety & Compliance Committee (NSCC) to the GPU Nuclear Corporation Board of Directors.

Mr. J. F. O' Leary, Chairman of the Board, GPU Nuclear Corporation, has requested that I provide to you the NSCC's semiannual report for the period

-April 1, 1987 through September 30, 1987.

A copy of the report is enclosed.

Sincerely, ff-P. R. Clark President

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Enclosure i

I cc:

J. F. O' Leary, Chairman of the Board l

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t GPU Nuclear Corporation is a subsid;ary of General Public Utihtes Corporation 1

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POST OFFICE BOX 696

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.MIDDLETOWN,' PENNSYLVANIA 17057 1

1 October 9,~1987 e

THI-L-87.108-C

. F. Manganaro e

IVi e President / Director-Administration U Nuclear. Corporation

-100 Interpace Parkway Parsippany, New Jersey 07057

Dear Mr. Manganaro:

Enclosed is the' Nuclear Safety and Compliance Committee-Semiannual Report for the period April 1,.1987 through September 30, 1987.

As requested by Mr. Bob Laney, please make copies and distribute them to the GPU Nuclear Board of Directors.

l Sincerely,

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Ell ry L. Hammond, NSCC Staff Director ELH:krk cc: R. V. Laney L. L. Humphreys Dr. W. Witzig Enclosure i

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