ML20245B959
| ML20245B959 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 04/17/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20245B957 | List: |
| References | |
| 50-219-87-99, NUDOCS 8904260403 | |
| Download: ML20245B959 (41) | |
See also: IR 05000219/1987099
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ENCLOSURE 1
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
BOARD REPORT
50-219/87-99
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION
OYSTER CREEK NUCLEAR GENERATION STATION
ASSESSMENT PERIOD: OCTOBER 1, 1987 - JANUARY 31, 1989
BOARD MEETING DATE: MARCH 14, 1989
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8904260403 890417 i
PDR ADOCK 05000219 l
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TABLE OF CONTENTS
PAGE
I. Introduction......................................................... 1
I.A Background.................... ................................. 2
I.B Licensee Activities............................................. 2
I.C Direct Inspection and Review Activities......................... 3
II. S u mm a ry o f R e s u l t s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
I I . A O v e ra l l S umma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...... 5
II.B Facility Performance Analysis Summary........................... 6
II.C Unplanned Shutdowns, Plant Trips, and Forced Outages. . . . . . . . . . . . 7
III. Criteria................ ................ ........................... 8
IV. Performance Analysis................................................. 10
IV.A Plant Operations..................................... ..... 10
IV.B Radiological Controls...... ......... ..................... 14
IV.C Maintenance / Surveillance.............. .................... 18
IV.D . Emergency Preparedness..................................... 22
IV.E Security................ .................................. 24
IV.F Engineering / Technical Support........... .................. 26
IV.G Safety Assessment / Quality Veri fication. . . . . . . . . . . . . . . . . . . . . 29
SUPPORTING DATA AND SUMMARIES
A. Investigations and Allegations Review................................SD/S-1
8. Escalated Enforcement Actions................... ....................SD/S-1
C. Co n fi rmato ry Ac ti on Lette r s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SD/S-1
D. Li c e n s e e Ev e n t Re p o rt s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . S D/S-1
TABLES
Table I - Enforcement Activity
Table II - Listing of LERs by Functiona'l Area
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an integrated I
agency effort to collect and evaluate available agency insights, data, and other
information on a plant / site basis in a structured manner in order to assess and
better understand the reasons for a licensee's performance. Unacceptable perform-
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ance is addressed through NRC's enforcement policy and the implementation of this
l policy should not be delayed to await the results of a SALP. Compliance with NRC
rules and regulations satisfies the minimum requirements for continued operation
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of a facility; the degree to which a licensee exceeds regulatory requirements is
a measure of the licensee's commitment to nuclear safety and plant reliability.
The SALP process is used by the NRC to synthesize its observations of and insights
into a licensee's performance and to identify common themes or symptoms. As such,
the NRC needs to recognize and understand the reasons for a licensee's strengths
as well as weaknesses. The SALP process is a means of expressing NRC senior man-
agement's observations and judgements on licensee performance. It should not be
limited to focusing on weaknesses, and it is not intended to identify proposed
resolutions or solutions of problems. The licensee's management is responsible
for ensuring plant safety and establishing effective means to measure, monitor,
and evaluate the quality of all aspects of plant design, hardware, and operation.
The SALP process is intended to further NRC's understanding of (1) how the licen-
see's management guides, directs, evaluates, and provides resources for safe plant
operations, and (2) how these resources are applied and used. As a result, em-
phasis is placed on understanding the reasons for a licensee's performance in
identified functional areas and on sharing this understanding with the licensee
and the public. The SALP process is intended to be sufficiently diagnostic to
provide a rational for allocating NRC resources and to provide meaningful feedback
to the licensee's management.
An NRC SALP Board, composed of the staff members listed below, met on March 14,
1989, to review the observations and data of performance, and to assess licensee
performance in accordance with Chapter NRC-0516, " Systematic Assessment of Licensee
Performance." This guidance and evaluation criteria are summarized in Section III
of this report. The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
This report is the NRC's assestment of the licensee's safety performance at Oyster
Creek for the period October 1, 1987 to January 31, 1989.
The SALP Board for Oyster Creek was composed of:
SALP Board
Board Chairman
W. Kane, Director, Division of Reactor Projects (DRP)
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Members
S. Colli"s, Deputy Director, DRP
M. Knapp, Director, Division of Radiation Safety and Safeguards (DRSS) (part time)
T. Martin,. Director, Division of Reactor Safety (DRS).
L._Bettenhausen, Chief, Projects Branch No. 1, DRP
R. Gallo, Chief, Dperations Branch, DRS (part time)
C. Cowgill, Chief,. Reactor Projects Section IA, DRP
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J. Wechselberger,' Senior Operations Engineer, NRR (voting for Senior Resident
Inspector).
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J. Stolz, Director, Project Directorate 1-4, NRR
A. Dromerick, Project Manager, NRR
W.- Johnston, Deputy Director, DRSS'(part time)
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k. Baunack, Project Engineer, DRP i
'0. Lew, Resident Inspector '
E. Collins, Senior Resident Inspector
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I.A Background
Oyster Creek is a GE BWR/2 with a Mark I containment. The Construction Permit'was
issued in December 1964 and commercial operation commenced on December 23, 1969 !
at-1600 Megawatts thermal.
This unit- was delivered to Jersey Central Power and Light Company for operation
as one of the first GE " turnkey" reactor plants. Later, the unit's licensed power
was increased to 1930 Megawatts thermal.
The nuclear steam supply system differs from later model BWRs in that it uses 5
reactor recirculation pumps and the reactor vessel has no internal jet pumps. The
emergency cor* cooling systems consist of two low pressure core spray systems, 2
isolation condensers for heat removal, and an automatic depressurization system. j
I.B Licensee Activities
At the beginning of the assessment period, the plant was shut down in accordance
with a confirmatory action letter. This letter was issued as a result of a safety
limit violation which occurred on September 11, 1987. On November 6, 1987, a let- i
ter permitting restart was issued to the licensee. On November 20, 1987, the In- I
ternational Brotherhood of Electrical Workers initiated a strike against the util-
ity. Management personnel assumed the duties of bargaining unit personnel and
. preparations for plant startup continued. Reactor startup occurred on November
'22, 1987 and the turbine was placed on line on November 24, 1987. The startup and
subsequent plant operation were conducted by supervisory personnel.
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On December. 11, 1987, the strike was settled. Returning workers were trained and
reoriented before resuming normal duties. Plant operation continued at full power
with only minor power reductions for surveillance or maintenance until July 9,
1988 when, following main steam isolation valve (MSIV) surveillance testing, no
steam flow was indicated in the "A" steam line. A shutdown was initiated and the
plant was placed in cold shutdown on July 10, 1988. This terminated'a 229 day
. continuous run.
Subsequent' investigation of the cause of no steam flow in the "A" steam line re-
vealed an.MSIV stem failure. Following MSIV repairs a plant startup commenced on
August 9, 1988, and the generator was placed on the.line on August 12.
On August 28, 1988, the "B" isolation condenser started " steaming" following a six
day out of service period for maintenance. On September 2, 1988, a plant shutdown
was initiated due to both isolation condensers being declared inoperable. One
isolation condenser was inoperable due to maintenance; the other due to a manual
vent line valve being found in the closed position. The shutdown was terminated
after the vent valve was opened and noncondensibles were calculated to have been-
purged on September 3, 1988.
On September 26, 1988, following a surveillance of the "A" isolation condenser it
also began to " steam". On September 23, following an evaluation of isolation con-
denser' conditions, both condensers were declared inoperable, and a plant shutdown
was initiated. Cold shutdown was achieved on September 30, 1988. Following the
shutdown a decision was made to commence the Cycle 12 Refueling Outage which was
originally scheduled to begin on October 15, 1988. The plant remained shut cown
for the remainder of the SALP period.
On May 1,1988, a new Vice President and Director of Oyster Creek was appointed.
The previous Director of Oyster Creek was appointed Vice President and Director
of a new GPUN division encompassing corporate-wide training and education and
quality assurance programs.
I.C Direct Inspection and Review Activities
Three NRC resident inspectors were assigned to the site. One new tesident was
assigned in January,1988; the third resident was assigned in July 1988. Addition-
ally, two temporary resident inspectors were assigned for a period of six weeks
each. The total inspection time for the assessment period was 8569 hours0.0992 days <br />2.38 hours <br />0.0142 weeks <br />0.00326 months <br /> (resident,
region and headquarters based) with a distribution in the appraisal functional area
as shown with each functional area. This equates to 6427 hours0.0744 days <br />1.785 hours <br />0.0106 weeks <br />0.00245 months <br /> on an annual basis.
Special inspections included the following:
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Special team inspection to assess the safety significance of freezing condi-
tions identified in the reactor building on January 6, 1988 (January 25-29,
1988).
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The annual emergency preparedness exercise was heid on May 11-12, 1988.
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-. ~ Special team inspection to review the circumstances and events leading up to
L a subsystem of the containment spray / emergency service water being returned
to service exceeding operability acceptance' criterion (July 11-15,1988).
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, Regulatory Effectiveness Review conducted July 18-22, 1988.
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. Special team inspection to review licensee's evaluation and response to a main
steam isolation valve broken stem (July 18-22,1988).
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Emergency Operating Procedure inspection conducted September 6-15, 1988.
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Augmented Inspection Team inspection to review the circumstances, events and
licensee response to a situation where both emergency condensers _were inoper-
able (October 5-13,1988).
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Safety System Outage Modification Inspection conducted October 17 through
November 4, 1988 and November 28 through December 16, 1988.
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II. SUMMARY OF RESULTS
II.A Overall Summary
Overall, inconsistent performance was.again noted at the facility. Improvements
were made in the plant material condition, the number of forced outages were
significantly reduced and there were no plant trips. In addition, the number
of operator. errors was reduced. In contrast, however, performance in the areas
of Security and Radiological Controls degraded during the period.
The site and corporate management have undertaken many new initiatives to improve
the performance of the facility both in the area of safety and plant performance.
GPUN maintains a policy for its employees which stresses a high standard of
integrity and procedure adherence and a concept of safety before schedule This
policy is well understood but inconsistently applied at the lower levels of
the organization.
Licensee programs to surface and correct deficiencies are in place but, are not
fully effective. A preliminary safety concern program has evidenced problems
in bringing issues to closure and providing feedback to individuals. Interfaces
between operators and their management have not worked well to resolve identified
deficiencies. Communications problems between the operations department and
support organizations have also been noted.
In the Radiological Controls area, weaknesses were identified that contributed
to a decline in the program's effectiveness. Those weaknesses include ineffective
root cause analysis, incomplete control and planning of radiological operations,
incomplete corrective actions on identified problems, and lax worker attitudes.
The licensee has made significant progress in reducing the maintenance backlog
at the facility and instituted changes to further enhance maintenance effectiveness.
A new training program for maintenance technicians and a shift to a computerized
maintenance control system have been implemented. Rework remains a problem at the
facility and problems were identified associated with implementing the maintenance
control program.
In the area of Technical Support, the licensee has actively responded to
previous SALP concerns. These efforts have resulted in an enhanced root cause
analysis of engineering support and a reduction in the engineering work backlog.
Some examples of insensitivity to emerging and long standing technical problems
still exist. Communications between site and corporate engineering were weak at ,
times and as a result the licensee's engineering resources were sometimes not '
effectively used. The difficulties encountered in correcting some of the long
standing problems are due in part to issues resulting from the age of the plant,
the volume of issues to be resolved, and an ill-defined plant design basis.
Development of a sound design basis for the plant is an essential element i
central to attaining substantial overall improvement in facility performance. l
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In summary, the licensee remains committed to establishing and implementing
programs to support safe, efficient operation of the facility. Full
application and integration of these initiatives is hindered by the age and
design of the facility. These equipment and material issues continue to
challenge personnel performance and stress the licensee's organization.
II.B Facility Performance Analysis Summary
This SALP report incorporates the recent NRC redefinition of the assessment func-
tional areas. Changes include combining the previously separate Maintenance and
Surveillance areas and addition of'the Safety Assessment / Quality Verification area. ,
The Safety Assessment / Quality Verification :ection is largely a synopsis of obser-
vations in other functional areas. Additionally, the Fire Protection, Licensing,
Refueling /0utage, Training, and Assurance of Quality areas have been incorporated
into the remaining functional areas as appropriate.
Rating Rating
Last This
Functional Area Period * Period ** Trend
A. Plant Operations 3 3 Improving
B. Radiological Controls . 3 --
C. Maintenance / Surveillance *** 2/2 2 --
D. Emergency Preparedness 2 2 --
E. Security 1 2 --
F. Engineering / Technical Support 3 2 --
G. Safety Assessment / Quality Verification # 2 --
H. Licensing Activities 2 # --
I. Training & Qualification Effectiveness 2 # --
J. Assurance of Quality 2 # --
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October 16, 1986 to September 30, 1987
- October 1, 1987 to January 31, 1989
Previously addressed as. separate areas of Maintenance and Surveillance.
- Not addressed as a separate area.
NOTE: It is important to note that a major revision of the SALP Manual Chapter
has been made which combined some areas and made changes to the attri-
butes in the functional areas. Therefore, a direct comparison of the
functional area grades cannot be made between the previous SALP and the
current one.
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II.C Unplanned Shutdowns, Plant Trips, and Forced Outages
POWER ROOT FUNCTIONAL i
DATE LEVEL DESCRIPTION CAUSE AREA
7/9/88 40% During testing one MSIV Main Steam N/A
failed to close. The series isolation
MSIV was closed and disabled valve (MSIV)
until the operability of stem had sepa-
the affected valve could be rated from the
established. After several pilot poppet.
attempts, the MSIV appeared Root cause for
to close and open within the the shear fail-
normally expected stroke ure of the MSIV
times. After attempting to stem has not
open both MSIV's, no steam been determined.
flow was indicated in the "A"
steam line. A shutdown of
the reactor was initiated to
determine the cause of no
steam flow in the "A" steam
line header and make appro-
priate repairs.
9/29/88 99% An evaluation of thermal During main- N/A
profiles of the isolation tenance of
condenser piping concluded Isolation Con-
that water was present in denser valve
the steam piping. Due to steam lines
the potential for severe filled with
water hammer upon system water,
initiation, both isolation
condensers were isolated
and declared inoperable
and the reactor was shut
down.
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III. CRITERIA
Licensee performance is assessed in selected functional areas, depending upon
whether the facility is in a construction, preoperational, or operational phase.
Functional areas normally represent areas significant to nuclear safety and the
environment. Some functional areas may not be assessed because of little or no
licensee activities or lack of meaningful observations. Special areas may be added
to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each func-
tional area.
1. Assurance of quality, including management involvement and control;
2. Approach to the identification and resolution of technical issues from a
safety standpoint;
3. Responsiveness to NRC initiatives;
4. Enforcement history;
5. Operational and construction events (including response to, analyses of,
reporting of, and corrective actions for);
6. Staffing (including management); and
7. Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been used
where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated into
to three performance categories. The performance categories used when rating lic-
ensee performance are defined as follows:
Category 1. Licensee management attention and involvement are readily evident and
place emphasis on superior performance of nuclear safety or safeguards activities,
with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant
and personnel performance is being achieved. Reduced NRC attention may be appro-
priate.
Category 2. Licensee management attention to and involvement in the performance
of nuclear safety or safeguards activities are good. The licensee has attained
a level of performance above that needed to meet regulatory requirements. Licensee
resources are adequate and reasonably allocated so that good plant and personnel
performance is being achieved. NRC attention may be maintained at normal levels.
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Category 3. Licensee management attention to and involvement in the performance
of nuclear safety or safeguards activities are not sufficient. The licensee's
performance does not significantly exceed that needed to meet minimal regulatory
requirements. Licensee resources appear to be strained or not effectively used.
NRC attention should be increased above normal levels.
The SALP Board may assess a 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. The SALP trend categories are as follows:
Improving: Licensee performance was determined to be improving near the close of
the assessment period.
Declining: Licensee performance was determined to be declining near the close of
the assessment period and the licensee had not taken meaningful steps to address
this pattern.
A trend'is assigned only when, in the opinion of the SALP Board, the trend is sig-
nificant enough to be' considered indicative of a. likely change in the performance
category in the near future. For example, a classification of " Category 2, Im-
proving" indicates the ' clear potential for " Category 1" performance in the next
SALP period.
It should be noted that Category 3 performance, the lowest category, represents
acceptable, although~ minimally adequate, safety performance. If at any time the
NRC concluded that a licensee was not achieving an adequate level of safety per-
formance, it would then be incumbent upon NRC to take prompt appropriate action
in the interest-of public health and safety. Such matters would be dealt with
independently from, and on a more urgent schedule than, the SALP process.
It should also be noted that the industry continues to be subject to rising per-
formance expectations. NRC expects licensees to use industry-wide and plant-speci-
fic operating ' experience actively in order to effect performance improvement. Thus,
a licensee s safety performance would be expected to show improvement over the
8
years in order to maintain consistent SALP ratings.
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IV. PERFORMANCE ANALYSIS
.IV.A Plant Operations (2840 Hrs., 33%)
IV.A.1 Analysis
The previous SALP rating in this area was Category 3. Improvements were noted in
onshift decisionmaking, emphasis on shift teamwork, control room professional en-
vironment and operator action to control water level transients. Special NRC in-
spection findings were generally positive; concluding that a competent organization
with strong management and effective programs were in place. However, the special
inspections also observed a lack of promulgation of management goals to lower level
personnel to ensure understanding of risk importance and a more inquisitive ap-
proach to non-routine plant conditions. Positive observations were contrasted with
safety significant events indicating inconsistencies in program application and
personnel performance. Additional assessment concluded that equipment challenges
<added to a decrease in the operators performance. Procedural . conflicts fostering
a graded approach to compliance, schedule pressure and housekeeping problems, all
contributed to a conclusion of overall inconsistent operational performance.
During the current SALP cycle, senior operations management was changed and the
new managers encouraged an increased emphasis in identifying problems for resolu-
tion. Improved periodic meetings were held with shift management to develop a bet-
ter understanding of problems and to unify operations management. Senior site
management has continued to emphasize cooperation and teamwork through periodic
meetings of all key site management personnel to resolve problems and increase
communication among divisional representatives at the facility. Other positive
attributes include major evolutions by operational plans specifying organizational
responsibility, restart certifications, senior corporate management review of re-
start readiness, and implementation of the INPO sponsored HPES process. Senior
site management took a major step in reenforcing the concept of safety before
schedule, when, with the direct involvement of the site director, refueling errors
were dramatically decreased. Refueling activities were delayed to facilitate ex-
tensive training sessions for operators, core engineers, and operations management
to discuss the " error-free" refueling plan, refueling operations and the concept
of safety before schedule. The reactor refueling was subsequently conducted with-
out error.
The plant continuously operated for 229 days. This was due in part from increased
attention to plant equipment problems. This is in direct contrast to the past when
numerous reactor scrams and unplanned shutdowns have impacted plant performance.
Recently the plant implemented a modification to help control reactor water level
following post plant trips; this been an identified problem in previous SALP re-
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ports. Other positive indicators of current plant performance are the reduction
in temporary procedure changes exceeding the 14 day technical specification appro-
val limit, increased personnel in operator training programs and periodic meet-
ings between the site director and the QA organization to effect resolution of
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quality issues. In addition, the licensee has established an Operations Coordina-
tions office to alleviate some of the administrative burden from the shift super- l
visor during outages. This is perceived as positive; however, early in the outage, '
shift supervisors were at times concerned about effective communication regarding
outage activities.
Operators have shown improvement by a professional attitude toward their duties
and proper control room decorum; however, some distractions are still noted.
One particular bright spot has been the determination of a few operators to
identify and report potential significant equipment and system problems and to
correct long standing facility problems. Operators and operations personnel in
general are responsive to inspector concerns and are open in their communications.
Conditions are not conducive to promoting cooperation and teamwork between
operators and operations middle management. Likewise, lack of support to the
operators by operations middle management was noted. This was evidenced by
certain equipment being allowed to remain out of service for long periods, as
in the case of the reactor building heating and ventilation problems that lead
to freezing in the reactor building despite operator complaints, and isolation
condenser steam line temperature anomalies not being addressed. Operations
management did not adequately respond to QA findings associated with the contain-
ment spray / emergency service water system, and this eventually led to a plant
problem. Also, the acceptance by operations management of modified systems for
operation without a formal turnover of the completed modification has resulted
in system operation without complete documentation.
A strike occurred immediately before returning the plant to power operation in the
fall of 1987. The NRC determined that the licensee's strike plans were comprehen-
sive and appropriate to address the situation. Management personnel assigned to
perform operator duties during this time were thorough and knowledgeable in plant
operation and startup activities. Management plans to transfer operation of the
plant to union personnel after the strike were also considered highly effective.
The licensee has initiated a number of programs to improve worker attitudes and
increase productivity since the conclusion of the strike.
During this SALP period, operator license examinations were successfully admini-
stered to five SR0 and 3 R0 candidates. It was noted that control room staffing
consisted of only a five shift rotation.
Operations have improved in specific areas, which may be attributed to self initi-
ated actions as well as significant input from internal license and regulatory
organizations. Although the plant operated continuously for 229 days, power re-
ductions were required to repair plant equipment problems. Some long standing
equipment problems still persist. These include intermediate range monitors,
control rod drive hydraulic control units, safety relief valve acoustic monitors
and thermocouple and various secondary equipment problems.
NRC observations indicate that, although daily planning meetings effectively com-
municate plant and maintenance status, there are interface problems at the working
level between the Operations Department and support organizations. Examples of
conditions that resulted from this are: worker contamination from poorly planned
post maintenance testing of the offgas system, the loss of secondary containment
during isolation condenser maintenance, overlapping stack gas monitor tagouts which
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resulted in making the monitor inoperable and the removing of a station battery
and the opposite train diesel from service simultaneously, thus, making both
diesels unable to respond in the event of a loss of offsite power.
Operations understanding of the technical specifications and the design basis and
evaluating plant conditions against these requirements is a weakness. Examples
include operations attempt to startup the plant in an action statement with an
inoperable offgas sample pump and three control rods made inoperable due to in-
adequate operator response to low gas pressure alarms.
Station procedures are generally good, but have been key contributors to two major
events during this SALP period. Placing the isolation condensers in a questionable
condition and potentially exceeding a limiting condition for operation with the
containment spray / emergency service water system were direct results of poor pro-
cedures. In the first case, a long standing procedure deficiency became evident
and in the second, a poor modification process resulted in the procedure problems.
Also, during the freezing reactor building temperature inspection, inadequate pro-
cedure reviews were discovered. In this case, the system procedure had been re-
vised 13 times over a 20 year period without detecting that the control room reac-
tor building temperature gauge referred to in the procedure was never installed.
Other examples include operator confusion from the conflictir g instructions for
equalizing pressure across the MSIVs and minimum battery room air temperature pro-
vided by different procedures, and an unspecified action in response to a refueling
cavity seal leak alarm.
Operator errors have decreased since the last SALP, and, overall, improvement in
this area has been seen. However, there were some errors during the plant opera-
tion. During reactor defueling numerous operational errors occurred that resulted
in the direct involvement of the Site Director to bring about a positive change.
There was one instance of a lack of command and control during the MSIV stem fail-
ure in which a half trip was not inserted promptly. Also, logging of some events
was not timely such as the isolation condenser initiation which was not logged or
reported until some time after it occurred.
During this SALP period, a special inspection was performed of the Emergency
Operating Procedures (EOPs). This inspection concluded that the E0Ps were tech-
nically sound, that the operators understood their fundamental technical principles,
and that the operators were able to execute the E0Ps. The overall quality of the
emergency operating procedures is considered to be a strength. The team did ob- !
serve an unfamiliarity with the " hands-on" use of the procedures and flow charts.
This unfamiliarity is considered a training deficiency.
Operator attitude was a concern identified during the E0P inspection as well as i
during defueling. The E0P inspection identified an attitude of overconfidence as
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well as a tendency to minimize the significance of the E0Ps. Likewise, in response
to the number of errors which occurred during the defueling, operators displayed
an attitude that this performance was no different than that of the previous years.
Management did take corrective action to improve refueling performance.
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In conclusion, operations has shown improvement, including a reduction in operator
errors. Senior site management has made efforts to build cooperation and teamwork.
Operations middle management has not aggressively supported operators by correcting i'
identified S concerns, addressing operator questions and concerns, and improving
middle management and operator cooperation and teamwork. Plant material condition
continues to improve as evidenced by a long operational period. The initiative
shown by several operators to correct long standing facility problems is encourag-
ing. Procedure weaknesses still exist and contributed to plant events.
IV.A.2 Conclusion
Category 3, Improving.
IV.A.3 Recommendation
None.
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. _ _ _ _ _ _ _ _ _ _ _ _
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IV.B Radiological Controls (560 Hrs., 6.5%)
IV.B.1 Analysis
Previous SALP-
The last SALP rated this area as Category 2. Weaknesses noted included: incomplete
pre-job briefing of workers; ineffective root cause analyses following radiological
incidents; lack of emphasis and followup of quality control functions performed
by Radiological Engineering; and poor ALARA effort and ineffective goal setting
and goal tracking. Strengths included an adequate staff with good qualifications,
good facilities ard equipment, training, posting, and access control.
Current SALP
Four special .nspections were conducted in this area during the current SALP period,
in addition co the routine reviews by the resident inspectors.
Overall, the licensee's radiological control program remains adequate. However,
continuing weaknesses were identified that contributed to a noticeable degradation
in program effectiveness. These weaknesses include (1) deterioration of control
and planning of radiological operations, (2) incomplete corrective action on iden-
tified problems, (3) continued examples of ineffective root cause analysis, and
(4) a lack of aggressive action to reduce collective worker exposure.
Control and planning of radiological work is generally adequate, but instances of
. poor performance were noted. Appropriate actions to address deteriorating radio-
logical conditions were not taken in some cases. As an example, a control rod
manipulator was used to facilitate the removal of control rod drives from the
reactor. This resulted in an increase in the rate at which the drives were removed
and sent to the drive maintenance and rebuild area. However, the effects of this
increased rate on radiological conditions in that area were not adequately consi-
dered. As the backlog of control rod drives in the rebuild area became excessive,
the area became highly contaminated. The contamination subsequently spread outside
the rebuild area to other areas of the reactor building. The problem was compounded
by the lack of experience and incomplete training of the workers in the rebuild
area. Although the workers had been put through mockup training, the pace of the
training was rapid, and many were not trained on the actual work performed in the
rebuild area.
Although the licensee continues to demonstrate an ability to identify problems,
the corrective action program was at times ineffective in achieving desired im-
provements and preventing recurrence. The following are examples of this problem.
--
Improper priority assignments to radiological control problems were observed.
For example, high radiation area doors which were required to be locked were
found unlocked due to their poor mechanical condition. Although corrective
action was proposed, it was not cr lated because of the low assigned job
priority and subsequent cancellation of the work orders. This resulted in
continued instances where high radiation area access control was compromised.
- _ _ _ _ _ . _ _
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'--
Investigation following the occurrence of radiological incidents is prompt,
but the depth of review conducted is frequently limited in scope and effec-
tiveness. As an example, disturbances in the ventilation flow pathways in
the Augmented Offgas system building produced airborne contamination in the
building. Following a nunber of personnel contaminations, the licensee com-
mitted to sampling the air for radioactive gas in case of such incidents.
However, the sampling is still not being done in a systematic and controlled
manner. The lack of timely performance of air samples was identified during
the previous SALP period. In the past this weakness could have led to situ-
ations where the licensee was not able to adequately assess the exposure that
workers were receiving from airborne contamination. The licensee was not
responsive and did not acknowledge the concern, and this weakness still re-
mains. Another identified weakness has been the failure to perform appro-
priate surveys in areas with non-uniform radiation fields. This program
weakness recurs despite licensee's corrective actions implemented to date.
--
One of the principal reasons for the failure of corrective actions is that
investigations conducted by the licensee following an incident do not identify
root causes.but-instead concentrate on immediate and sometimes superficial
factors. The critiques rarely address problems that result from poor super-
visory practices or poor planning, and tend to concentrate on errors committed
by the worker and by first line supervisors. In the control rod rebuild room
incident mentioned above, important and key contributing factors were not
considered in the critique, including failure to anticipate a potential over-
load of the work area, a lack of clear and adequate procedures to control the
work, and poorly trained technicians with little or no experience in covering
this type of work. In another incident, a technician and his supervisor
removed some temporary shielding in accordance with instructions from radio-
logical engineering causing an increase in the dose rate in the area and un-
knowingly created conditions that classified the area as a locked high radi-
ation area-. The critique of the incident failed to point out that, among the
root causes of the incident were improper surveys in a non-uniform radiation
field, incomplete supervisory shift briefings, and problems with the tagging
and tracking system for temporary shielding.
--
Engineering evaluation in response to NRC concerns has generally been thorough
and professional when the problem in question was internal to the Radiological
Controls organization on site. This is contrasted by situations in which the
evaluations had to be performed by some departments other than Radiological
Controls which were poor in quality, excessively brief and unsubstantiated,
and reluctantly given. One example was in connection with the licensee's
request to permit occupancy of the upper levels of the drywell during fuel
movements. In response to an NRC concern regarding radiological safety in
the upper elevations in case of a fuel drop accident, the licensee proposed
a fence, but did not supply adequate supporting calculations on fence strength.
Subsequent calculations were brief, with no stated assumptions. Also, as part
of this evaluation, the licensee proposed mechanical stops to limit the range
of horizontal movement of the refueling bridge. However, the stops were not
installed because of an oversight, and defueling proceeded without these stops
until detected by licensed operators while testing the fuel handling bridge.
__________ _ _ _ _ _ _ _ _ __ ._ 3
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Lack of aggressive action to reduce collective worker exposure can be found in
examples of a lax attitude towards adherence to radiological controls procedures.
For example, personnel, including maintenance and quality assurance, have been
observed on several occasions entering posted contamination areas and ignoring
entry requirements,.such as the use of proper protective clothing. One individual
repeated this infringement of the rules immediately after his attention was drawn
to that fact.
Performance in the area of ALARA remained consistent with that observed during
the previous assessment period. The cumulative exposure for the current outage
to date is over 1500 man-rem despite an outage goal of 900 man-rem. This goal is
still high in comparison to the national average due to a high in plant source term,
plant design and the scope of work in the outage. Compared with previous outages,
more efforts to reduce exposure were taken during this outage, however, a lack of
progress in long range source term reduction was evident. Source term reduction
initiatives included decontamination of many areas of the plant and several highly
contaminated systems and the use.of shielding in the drywell. Job planning, how-
ever, still needs improvement. An exposure reduction plan has recently been de-
veloped by the licensee in an effort to identify the areas in which exposure re-
duction methods can be effectively used. According to this plan, implementation
of-the recommended measures should produce a realistic two year rolling average
during 1990-1992 of 470 man-rem. Some items recommended in the plan were imple-
mented during the current outage, but to date, no specific timetable was published
to implement the major recommendations in the plan to achieve the desired collec-
tive dose reduction and to achieve parity with the rest of the industry. ,
Radiological Effluent Monitoring and Control
One inspection of the licensee's radioactive effluent control program was conducted
near the end of the assessment period. The licensee has in place an effective pro-
gram for controlling radioactive effluent releases from the site. The licensee
is meeting Technical Specification requirements with respect to radioactive ef-
fluent sampling, analysis, surveillance-, and reporting requirements. The required
reports are complete and thorough. A noted strength of the licensee's radioactive ;
effluent control program is the attempt to minimize the release of liquid radio- i
active effluents from the site. During the third quarter of 1987 and for the j
period January 1,1988 - May 31,1988 no liquid effluent releases were made from
the site.
Quality assurance audits of the gaseous and liquid radioactive effluent areas were l
thorough and of sufficient technical depth to adequately assess program capabili-
ties and performance. In addition, Operational QA surveillance activities were
of excellent technical depth and were conducted by an individual with appropriate
technical expertise.
Chemistry Control
The area of chemical measurement has improved during this assessment period. In-
itially several analytical results (chloride, sulfate, silica, iron, and boron)
were in disagreement with the criteria used for comparison. These results were
_ _ - _ _ _ _ - - - _ - _ _ _ _ - _. -
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possibly due to high laboratory room temperature, high reagent water temperature,
and an inadequate pipet calibration technique. With special attention to control
of these problems, all analyzed results were in agreement with the standards.
Currently, the licensee is upgrading the room temperature control system which is
indication of the management attention to the chemical measurement program.
Training was of high quality as reflected by the technical depth and also for ap-
placability in the chemistry laboratory. Quality assurance audits of the chemistry
program were thorough and of sufficient technical depth to adequately assess pro-
gram performance.
In summary, the licensee's effluent controls program remains effective and labora-
tory chemistry control improved. Nonetheless, a number of problems persisted during
this period which reflect a decrease in the Radiological Controls program effec-
tiveness. Job planning and control were weak in some areas; incident evaluation
and corrective action were incomplete and did not always identify the root cause
of a problem. ALARA planning suffered from the lack of aggressive source term
reduction and resulted in elevated collective exposure.
IV.B.2 Conclusion
Category 3.
IV.B.3 Recommendation
Licensee: Perform prompt self-assessment of third party review to assure problems
are fully identified and corrective action plan developed.
NRC: Follow up self-assessment with review and appraisal.
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18
IV.C Maintenance / Surveillance (2653 Hrs., 31%)
IV.C.1 Analysis
The previous SALP rated both areas of maintenance and surveillance as Category 2.
Inlthe area of Surveillance / Inservice Testing, strong administrative control and
strong procedures were noted. Concerns were expressed regarding a lack of aggres-
siveness in root cause analysis of some surveillance . identified problems, and that
communications between plant departments required improvement. In Maintenance,
plant impacting reliability and maintenance associated equipment problems indicated
a need for improvement in the overall quality of work performed, and a need for
improvement in communications between groups. Also noted were significant steps
taken by the licensee to improve overall performance including: personnel changes,
a critical self-assessment, establishment of ccmmittees to review problems, im-
provements in post-maintenance testing, and efforts to reduce work backlog.
During this SALP period, the-licensee has demonstrated responsiveness to NRC con-
cerns and resolve to improve'the performance of plant maintenance. The maintenance
program at Oyster Creek remains generally effective and the licensee has imple-
mented several major initiatives to build.a more effective maintenance program.
The Oyster Creek surveillance program continues to be effective, characterized by
strong administrative controls.
Two areas that remain weak are maintenance rework and surveillance which fre-
quently fail. Examples of rework have occurred, including valve leaks at control
rod drive hydraulic control units, main steam isolation valve (MSIV) work, inter-
Emediate range neutron monitors, and recirculation pump speed control. In each case,
corrective maintenance was performed, which failed to correct the deficiency. In
addition, surveillance test repeat failures have been main steam isolation valve
slow closure test stroke times too long, snubber and hanger deficiencies, anc'
reactor pressure switches out of tolerance. In some cases, equipment age is a
factor in these recurring deficiencies and the licensee has implemented major
modifications to improve or upgrade equipment. In other cases, however, rework
items are a result of ineffective root cause determination and rework identifica-
tion and correction program.
During an unplanned outage, July 1988, the licensee repaired a temperature problem
on a reactor feed pump, speed control on the recirculation pump, safety relief
valve thermocouple, intermediate range neutron monitors, and a hydraulic control
unit. In each case the problem reoccurred during the subsequent startup. The
licensee has programmatic controls in place to address rework, but these have not
been used. The licensee has taken several additional steps to uddress this area.
This includes a Human Performance Evaluation Program to aid in root cause identi-
fication, the establishment of a goal of no restart errors as a result of 12R work
and a formalized administrative control procedure for post maintenance testing.
The effectiveness of these measures to address rework concerns has not been as-
sessed.
- .. .. .
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The licensee has significantly reduced its maintenance backlog and committed to
achieving 100% equipment operability. As a result of this effort, the licensee
is performing a greater quantity and more complex work during plant operation.
The licensee made errors in coordinating some activities which resulted in equip-
ment inoperability. Examples of this problem are a major bus outage and overlap-
ping maintenance resulting in loss of stack gas sample flow. In these cases, there
was a lack of understanding of the effect of the maintenance activity on plant
equipment. This resulted, in part, from a lack of communication between work force
and plant operations. The licensee has recognized the need for better communica-
tion between departments and strengthened the Plan of the Day status meeting and
has added other daily planning meetings. Generally, these meetings are effective
at surfacing plant problems and identifying who is responsible for corrective
action.
In addition to the coordination of major maintenance efforts, work control has
shown some weaknesses. Examples include: snubber repair in progress and the snub-
bers not being declared inoperable, inadvertently boring into the drywell shell,
secondary containment boundary work degrading containment integrity, and diesel
generator overhaul and testing. These examples demonstrate the need to continue
to reinforce that work activities must be planned, approved and effectively con-
trolled by the written work documents.
The licensee has undertaken several major initiatives to improve maintenance. The
first was a reorganization of the maintenance division. This fundamentally changed
the functional structure from one of " area" supervisors to one of " work discipline"
supervisors. In addition, the licensee has implemented changes to the work man-
agement system to computerize and simplify the job order generation process. The
effectiveness of this change has not been assessed, however, during implementation
of the new computerized system, some inadequate work control occurred. Also, a
Short Form Job Order was revised to change the scope to implement a modification
to a plant cooling water system, and it was not treated as a modification.
Another licensee initiative is increased training for workers and development of
a craft training facility. The licensee has also effectively used mockups for
major maintenance tasks such as the feedwater line freeze seal and torus to drywell
vacuum breaker repairs.
The licensee preventive maintenance program remains generally effective. It is
a specific area of focus of licensee attention to implement measures to better
identify specific preventive maintenance needs and more effectively track and pre-
dict equipment failures. These licensee initiatives are aimed at addressing long
term equipment performance and includes the Life of System Maintenance Program
(reliability centered maintenance). This has been implemented in a limited manner
on the service and instrument air system.
The licensee continues to implement a strong surveillance test program. Some areas
that require more attention are valve control during surveillance testing, accept-
ance of out of specification results, and that the test program include appropriate
_ _ _ _ _ - _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ -_ _
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I
plant equipment (e.g., air accumulators and underground electrical cables). Sur-
veillance test valve control is also assessed in the Operations area. In addition,
NRC inspection noted a minor weakness in Measuring and Test Equipment (M&TE) con-
trol.
In general, the quality and accuracy of the maintenance and surveillance procedures
are good. The licensee is active in identifying and correcting weaknesses as they
arise. One specific area of observed weakness in surveillance testing is valve
position control. Situations have occurred where the same individual performed
the line up and the verification, procedural direction as to "as-left" positions
were not clear, and procedural direction for valve positions was in error. Two
of these situations resulted in equipment being misaligned and led to erroneous
surveillance test data on the containment spray heat exchangers and inability to
vent the isolation condensers. These valve dispositions have occurred, in part,
due to the incompleteness of incorporating plant modifications into surveillance
test procedures; and in part due to a lack of specific direction for valve positions.
The licensee is generally effective at identifying and addressing test discrepan-
cies and establishing acceptance criteria, however, several examples of inadequate
acceptance of test results have been seen. Out of specification results have been
accepted without explanation (MSIV closure), acceptance criteria have been changed
without a safety review (containment spray heat exchangers AP), IST out of speci-
fication problems without appropriate action (liquid poison), and questionable
baseline data methodology (emergency service water). While generally effective,
licensee performance shows the need for increased attention in the area of estab-
lishing acceptance criteria, and effectively evaluating test results.
The licensee has recognized the need for improvement in jumper control and also
the need to evaluate and improve the testability of systems. On a system by system
basis, the licensee is evaluating permanent design changes to improve testability.
This outage, a modification was implemented on the core spray system to eliminate
the need to lift leads and use jumpers. The licensee initiative to improve the
testability of systems demonstrates their commitment to improve long term surveil-
lance performance.
In conclusion, the licensee has in place generally effective maintenance and sur-
veillance test programs. Significant progress has been made in reducing mainten-
ance backlogs and a strong surveillance test program is being maintained. While
some areas of weaknesses have been seen in both areas, the licensee is responsive
to NRC concerns. Improvements have been seen in the areas of interdepartmental
communications and the plant material condition. Some areas where weaknesses have
been identified are: the identification and evaluation of maintenance rework items
and surveillance repeat failures and the administrative control of the work man-
agement system. Overall performance in the areas of maintenance and surveillance
has improved.
IV.C.2 Conclusion
Category 2.
-_ _ - _ _ _ _ - _ _ _ _ . _ _ _ _ _ _ _ _ _ .
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.
IV.C.3
'
Recommendation
Licensee: Provide NRC with schedule for implementation of reliability centered
maintenance control.
NRC: None.
_ ______ ____________-_- . _ _
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!
IV.D Emergency preparedness (249 Hrs., 3%)
1
IV.D.1 Analysis
During the previous assessment period, licensee performance in this area was rated
Category 2. This rating was principally based upon observations of performance
during the full participation exercise. Although overall performance was satis-
factory, several recurrent weaknesses were identified. In addition, concerns were
identified relative to slow staff response to an actual pager call-out from an
Unusual Event.
During the current assessment period, a full participation exercise was observed
and three routine safety inspections were conducted. The licensee issued a new
corporate Emergency Plan for both GPU Nuclear sites. Because of the significance
of the changes, the Plan was submitted for NRC review prior to implementation.
During the review it was identified that the Plan did not reflect the guidance of
NRC Information Notice 83-28 concerning protective actions for a General Emergency.
Acceptable changes weta made to the Plan and it was subsequently implemented and i
distributed. '
A full participation exercise was conducted on May 11, 1988. The exercise scenario
was written to involve a security threat. The licensee's overall response was ;
satisfactory, and, in some areas, performance was excellent. These areas included
control of a hazardous material spill, communication with the bomb disposal team,
and relocation of command and control from the Emergency Command Center to the
Technical Support Center. Several weaknesses were identified. The principal con-
cerns were in the areas of contamination control, adequacy of support to the Ener-
gency Support Director by the Technical Support Coordinator, and a question of
authority for the Operations Support Center. The number of weaknesses identified
is consistent with previous exercises. Overall exercise performance has been
adequate with approximately the same number of weaknesses identified from exercise
to exercise. This trend is apparently due to a lack of effectiveness of EP train-
ing.
During the first routine safety inspection, concerns were identified in two areas.
The first involved training: lists of staff participating in drills and exercises
were not maintained; and the Training Dep, tment's computerized database for
tracking EP training was not up to date. The second was in the area of dose as-
sessment and monitoring: the dose calculation model includes an excessively large
default iodine component which could result in overly conservative protective
action recommendations; and the volume of air samples collected by field teams is
so large that the collection filter may saturate making the results unreliable.
During the se'cond routine safety inspc:: tion, the inspectors determined that the
licensee was responsive to many NRC concerns. The Emergency Dose Calculational
Manual has been revised and many but not all calculational conservatism have been
removed. However, the concern regarding the default iodine component in the dose
model and the suitability of field sampling equipment and methodology to collect
iodine still had not been adequately addressed. This raises a concern regarding
_ _ - - _ _ _ _ _ _ _ - _ _ . . _ _ _ - - __ .
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23
the licensee's approach to resolution of technical issues. The licensee demon-
strated satisfactory response and personnel call-out to an actual Unusual Event
during the inspection. Several improvements have been made to emergency response
facilities and equipment. The licensee has renovated the Emergency Operations
Facility, installed a remote siren verification system, replaced the auto-dialer
call-in system by a computer based system, established a back-up Operational Sup-
port Center and is completing installation of a second siren activation system.
Staffing is adequate both for emergency preparedness maintenance and in numbers
of trained emergency response personnel.
Efforts to improve the emergency preparedness program are evidenced by the fact
that Emergency Preparedness staff routinely handles 43 ongoing activities and at
the time of the inspection was involved in 12 special projects. Some of these
activities include 26 improv9 ment actions in areas that have been completed or were
in progress at the time of the inspection.
Oyster Creek Directors have become involved regularly in emergency preparedness
training with the result that the need to reschedule training has almost vanished.
The Training Department has also introduced several innovative approaches and a
computerized data base is in place which tracks emergency preparedness training.
The site and field team air samplers are being replaced by a system which will col-
lect a sample without risk of saturation. Stack and turbine offgas monitoring
systems are being upgraded, and an Evacuation Time Estimate update study is being
undertaken. One issue which still requires licensee action is the training of
Technical Support Center engineers in accident analysis other than Core Damage
Assessment.
In summary, the licensee has committed adequate resources to emergency preparedness
and has demonstrated adequate response to GPU and NRC identified concerns. The
Director for the Environmental and Radiological Controls Division expends about
twenty percent of his time on EP issues. Technical issues have been and are being
resolved. Site management has become routinely involved in emergency preparedness
activities and training has also responded to needs for improvement. There are
no offsite problems. The persistent number of exercise weaknesses identified re- ;
mains a concern. Finally, the licensee has not yet resolved NRC concerns regarding ;
an overly conservative dose assessment model or the lack of training of TSC engi-
neers in severe accident analysis.
IV.D.2 Conclusion
Category 2.
IV.D.3 Recommendation
None.
- _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ .
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24
IV.E Security (134 Hrs., 1.5's)
I V . E .1 ~ Analysis
Two special and one routine physical security inspection were conducted by region-
based physical security inspectors. Routine inspections by resident inspectors
were conducted throughout the assessment period. An NRC Regulatory Effectiveness
Review was conducted in July 1988.
During the previous assessment period, the licensee's performance in this area was
Category 1. This rating was based upon continued implementation of the licensee's
self-assessment program, its enforcement history, a strong training and qualifica-
' tion program and the implementation of security equipment upgrades.
Dt..ng this assessment period, the licensee's security systems were reviewed during
a Regulatory Effectiveness Review (RER), and program implementation was evaluated
during a routine and two special region-based physical security inspections. Con-
tinuing inspections by the NRC resident inspectors were conducted during the period.
In the two previous SALP reports, two longstanding regulatory issues were identi-
fied as being addressed by the licensee. Both of these issues were resolved during
this period; however, resolution of one enhancement of the perimeter intrusion
detection system required several schedule extensions, and the other, a control
room issue, was initially found to be unacceptable by the NRC and another proposal
was submitted, which was found to be acceptable. Considering the nature and com-
plexity of the issues, the licensee demonstrated an adequate response to the NRC's
l concern, albeit, timeliness could have been better.
Corporate security management continued to be actively involved in all site secur-
ity program matters. This involvement included visits to the site by the corporate
staff to provide assistance, program appraisals and direct support in the budgeting
and planning processes affecting program modifications and upgrades. Security
personnel are also actively involved in the Region I Nuclear Security Association
and other industry groups engaged in nuclear plant security matters. This demon-
strates program support from upper 1.r ~ anagement.
The licensee continued the use of self-inspection techniques to provide oversight
of security program implementation and measurement of personnel performance. A
well developed training and qualification program and on-the-job performance
evaluations contributed to minimize personnel errors by members of the security
- organization during routine operations. However, during outages, maintenance pro-
I jects resulted in the degradation of vital barriers, without prior notification
- of the security department, on several occasions. Additionally, on one occasion,
operations personnel did not notify security personnel that a protected area bar-
rier had been degraded. Because security was not notified of these degraded bar-
riers, compensatory measures were not implemented for extended periods. Also,
during the current outage, members of the security force had to work a significant
amount of overtime to support the outage work. This may have contributed to a j
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25
reduction in the alertness of security force members since on two separate occa-
sions security force members who were controlling access to vital areas allowed
individuals whose access authorizations had expired to enter the vital areas.
These cases did not result in major degradation in security, but they did have the
potential to do so. Management had planned to augment the security force with
fifteen temporary contract watchmen to support the outage work, however, only five
were able to successfully pass licensee screening and training requirements.
The licensee submitted two security event reports in accordance with 10 CFR 73.71
during this assessment period. In addition, on two occasions, the NRC identified
events that should have been reported but were not. A contributing factor in the
failure to make the required reports was a misinterpretation of 10 CFR 73, Appendix
G.
The RER, which was conducted in July 1988, reviewed the licensee's ability to meet
the general performance requirements of 10 CFR Part 73. The RER report identified
strengths in some areas and contained recommendations for upgrades in other areas.
The licensee is reviewing the report and has not yet responded.
During this assessment period the licensee submitted four revisions to the Security
Plans in accordance with provisions of 10 CFR 50.54(p). Two of the revisions were
reviewed and found to be acceptable and two revisions are currently under review
by the NRC. The licensee also submitted revisions to the Security Plan in response
to the 10 CFR 73.55 Miscellaneous Amendments and Search Requirements. The revisions
contained commitments which meet the objectives of the rule change and were found
to be acceptable. The licensee responses to requests were not timely but were,
in general, technically sound.
{ In summary, the licensee continues to maintain an effective, performance-oriented
1 security program. Management attention to and support of the program are evident
in most aspects of the program implementation. However, weaknesses were observed
in the management efforts expended to maintain security awareness among other site
personnel to maintain adequate security staffing during extended outages, and
to understand NRC's reporting requirements for security events led to an overall
decline in performance during the period.
IV.E.2 Conclusion
Category 2.
IV.E.3 Recommendation
None.
w_____-_____-_______ _
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26
IV.F Engineering / Technical Support (1716 Hrs., 20%)
IV.F.1 Analysis
During the previous assessment period, licensee performance in this area was rated
Category 3. This rating was principally based on multiple examples of inadequate
root cause analysis, ineffective problem solution once the root cause was identi-
fied, poor technical reviews, long outstanding unresolved problems, delays in im-
plementation of NRC requirements, failure to meet commitments, communication prob-
lems, weakness in vendor control, and the fact that little change has been noted
over the period of time covered by the past three SALPs. The previous SALP board
also noted continued inconsistent performance during the assessment period. The
licensee was encouraged to expedite completion of the technical support self as-
sessment (TSSA) (which was started by the licensee in response to a recommendation !
by the SALP Board in 1986) and initiation of an associated corrective action plan. ,
1
During this SALP period, the quality of engineering support activities continued
to be inconsistent. Early in the SALP period, the licensee was actively engaged
in addressing the weaknesses and concerns identified ir, previous SALP Reports. i
These initiatives slowed down significantly during the assessment period due to
events that required the licensee's immediate attention and resources. Thus, the
licensee failed to complete the TSSA and initiate corrective action as recommended
by the previous SALP Board.
The licensee has taken several positive steps to enhance the effectiveness of the
Corporate Technical Function Division. Programs were developed and established
to incorporate safety perspective in engineering work prioritization, to trend and
analyze technical information, to enhance the quality of root cause analyses, to
improve engineering configuration management, design basis documents and as-built
drawings, to conduct Safety System Functional Inspections and to provide formalized
training to improve the quality and timeliness of safety reviews and plant modifi-
cations, Architect Engineers (AE) were placed on retainer and effectively used
to supplement the licensee's staff, providing the licensee with a wide spectrum
of engineering resources at short notice.
As a result of the above efforts, the following improvements were noted in the
support provided by the corporate Technical Function Division staff. Unlike pre-
vious outages, the corporate staff was able to complete practically all engineering
work prior to the commencement of the recently completed 12 R outage. The engi-
neering work back log was substantially reduced during this assessment period.
Prompt, conservative and comprehensive corrective actions for ISI and Appendix R
issues were developed and provided to the site. The engineering support provided
to resolve the isolation condenser steaming issue and the associated AIT concerns
was thorough, well coordinated, of good quality and was provided in a timely manner.
The licensee's efforts to address NRC Bulletins 79-02 and 79-14 were also extensive l
and of good quality. However, it must be noted that it took the licensee almost
ten years to complete this task.
.
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _
_ _ _ . _ _ . . . _ - - _ - - - - - - - - - - - - - - - - - - ' - - - -
-$ $4
I
i . l
.
27
In spite of the above improvements in capability and performance, several instances
- of inadequate engineering and technical support were noted. Examples of these ,
problems are discussed later in this section. Since similar problems were not 4
observed when site and corporate resources were both focused on the same technical
issues, it appears that the licensee still does not have an effective mechanism
to determine when site and corporate coordination is necessary or to always engage
and employ appropriate combinations of licensee resources to resolve site engi-
neering problems.
Efforts are being made to improve communication between engineering and operations
organizations. Corporate policy is being revised to encourage rotational assign-
ments for engineers between corporate and sites. However, instances of inadequate
communications between site and corporate personnel continue. For example, the
engineering personnel did not adequately inform the operations personnel about a
potential diesel generator bus over loading condition. Specific operator actions
are required to avoid over loading of this bus. The necessary operator training
or direction was not established as operations personnel were not aware of the
required operator actions. Instances in which plant changes were implemented
without involving the established modification process, site engineers or corporate
engineers include: the replacement of a reactor coolant system sampling valve with
another valve that was three times heavier, the removal of a resin column under
a work request and not under the configuration control requirements, and the change
out of an IRM range switch without the system engineer involvement. As stated
previously, when corporate and site technical personnel worked together, good de-
signs and engineering resolution were normally produced.
Instances of lack of inquisitiveness to understand technical issues and to identify
root causes of problems continue. For example, upon identification by the NRC of
the anomalous steam line temperature during the first isolation condenser steaming
event, the licensee performed a literature search for explanation. This literature
search yielded no explanation and no further evaluation was conducted by the lic-
ensee until the second isolation condenser developed a similar condition. Simi-
larly, the licensee identified several significant weaknesses in the activities
related to NRC Bulletin 79-02 and 79-14 during last SALP period; however, the lic-
ensee decided to take no actions until concerns were raised by the NRC inspectors.
As discussed further in the safety a:sessment/ quality verification section, the
licensee's initial resolution of the Preliminary Safety Concern (PSC) involving
the inoperability of the automatic depressurization system was another clear ex-
ample of shallow analysis of a newly identified problem.
Concerns for the adequacy of engineering resource commitments to the resolution
of long standing problems remains. Examples of these problems include: the erratic
operation and failure of the intermediate range monitors; degradation of the emer-
gency service water system discharge butterfly valve due to throttling; inadequate
emergency service water pump performance; and erratic performance of acoustic moni-
tors.
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
- - _ _ - _ _ - _ _ _ _ _ _ _ _ _
P l
<
. . i
4.
.
28 i
As' stated in the Safety Assessment / Quality Verification section of this report, i
the safety review process was generally good and the quality of the reviews
improved. However, the licensee does not -always appropriately document the.
basis'for conclusions. For example, when the licensee's re-analysis of the
torus-attached piping indicated that the calculated stresses might be above
allowables, the licensee determined the matter was not reportable to the NRC.
When questioned by the NRC, the licensee maintained that there was no safety
significance to this issue as the analysis was overly conservative, but had no
documented analysis to back up that position. Subsequently, the licensee
completed a state-of-the-art- analysis and was able to demonstrate that the
stresses in question were within allowables.
The accuracy, quality and availability of plant engineering drawings remain a
problem. Although the SS0MI found drawings representing recent modifications to
be good and to generally reflect as-built conditions, routine NRC inspections and
discussion with operators determined that older drawings are frequently inaccurate,
unreadable.or not easily locatable. Problems precipitated by these deficiencies
are illustrated in the following examples: (1) inadequate as-built drawings con-
tributed 'to the stack gas monitor being made inoperable during the performance of
maintenance; (2) relanding of a loose wire in the control room resulted in a plant
response different from that expected, based on a review of plant drawing, and
(3) an operator was unable to identify the source of power to the reactor building
to torus vacuum relief valve since the appropriate drawings were not readily
available.
In summary, the licensee responded positively to the concerns identified in
previous SALP reports. They initiated measures to enhance the effectiveness
of the corporate engineering division, improved the quality of root cause
analysis and engineering support,'and reduced engineering work back log.
However, examples of inadequate engineering solutions, insensitivity to technical
problems, failure to meet commitments, lack of reliable design basis documents
and failure to resolve long standing technical deficiencies continue to exist.
The licensee's engineering resources are not as effectively used at this site
as at TMI, although both are supported by the same corporate staff. The
difficulty in correcting the recurring and long standing problems at this site
may be explained by the volume of the issues; the latter, in large part, is
precipitated by the vintage and age of the plant. It may also be explained by
the lingering coordination problems and communication gap between this site and
the corporate engineering office. However, the licensee has made significant
progress in resolving issues and the performance for the assessment period has
shown improvement, particularly with regard to corporate activities.
IV.F.2 Conclusion
Category 2.
IV.F.3 Recommendations
Licensee: None.
NRC: Perform a SSFI during the fourth Quarter of FY 89.
t
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
__
___ _____ - -- . . _ _ .
,
e s
.
4
29
IV.G Safety Assessment / Quality Verification (417 Hrs., 5%)
IV.G.1 Analysis
In previous SALP reports, Assurance of Quality and Licensing Activities were evalu-
ated in separate sections of the report. This new section (Safety Assessment /
Quality Verification) has been created not only to consolidate those two sections
but also to encompass activities such as safety reviews, responses to NRC generated
initiatives such as Generic Letters and bulletins and to provide a broad assessment i
of the licensee's ability to identify and correct problems related to nuclear '
safety.
1
In the previous SALP, Assurance of Quality and Licensing Activities both received
Category 2 ratings. At that time, it was noted that the trend indicated that
the licensee had improved in the licensing area. The SALP report identified as
strengths management's commitment to safety and quality training programs for
management, craft personnel, and corporate level person'31, and other changes
made to improve overall management effectiveness and gosd communications between
licensee management and NRC staff. Weaknesses included procedure compliance,
unplanned outages from equipment malfunction, engineering support, and operations.
Licensee performance regarding timely submittals of LERs was also identified as
an area requiring improvement.
During the current SALP period 78 licensing actions were under review. Action
has been completed on 39 of these actions. Many of the significant actions com-
pleted involved complex issues and were generally well planned, technically sound,
showed thorough licensee analysis and in most cases were timely. Examples include
upper drywell .shell corrosion problems, compliance with ATWS Rule (10 CFR 50.62),
and new curves for operation beyond 10 effective full power years. However,
there were some issues where extensive staff interaction was required to resolve
issues and some miscellaneous amendments and SEP items were slow being submitted.
The licensee's safety review process is good and in general the quality of reviews
.
has improved. Also, the licensee is participating through industry groups to im-
prove overall guidance in this area. NRC review of the 50.59 review program at
Oyster Creek identified that in most cases reviews were of high quality. However,
in one case the licensee's justification was not clearly discussed and resulted
in accepting a situation not specifically authorized by regulation.
The staff has also audited the overall erosion / corrosion monitoring program in-
volving the pipe wall thinning of high energy carbon steel piping systems. As a
result of the audit, the staff concluded that in general the licensee's program
is above industry standards. The plant has appropriate controls in place and man-
agement has made a commitment to continue to implement an erosion / corrosion control
program at Oyster Creek.
!
_ _ _ - _ _ _ - -_-___ ____ ___--
- _ _ . . _ _ _ _ _ _ , _ _ _ , _ _ _ _ _ _ _ _ _
pir-----
O %
.
.
30
The licensee's QA program remains generally effective. Staffing is adequate and
training is appropriate. QA monitorings were detailed, comprehensive, and con-
ducted by knowledgeable personnel. The licensee has a comprehensive system of
audits to verify conformance with all aspects of the QA p ogram. Audits were
thorough and comprehensive. The licensee has also substantially revised their
QA plan to enhance oversight and refocus QA responsibility.
Followup to QA findings in most instances was found to be appropriate. However,
in several instances, such as the inadequate safety review program for maintenance
short forms, the QA findings had to be escalated due to insufficient corrective
action and slow response from management. Also, the finding that certain plant
modifications were being used by the plant before completing the formal modifica-
tion turnover process was not addressed. QA reviewed storage of spare parts in
shop spaces and took some corrective action, but did not document those findings.
This is one instance in which both improper activities were being conducted and
QA was ineffective in correcting the condition.
In the area of procurement and spare parts control, NRC reviews have identified
deficiencies which reflect weaknesses. These included procedural problems and the
absence of controls for spare parts housed outside the warehouse. The latter
problem had been identified by the licensee's QA organization, but effective cor-
rective action had not been implemented. Improper control of shop spare parts
permitted defective components to be installed in source range monitors prier to
refueling.
Satisfactory performance of the licensee's offsite review committee (G0RB - General
Office Review Board) was noted. The issues reviewed and the board's presentation
of findings to management is satisfactory. Improvement in the onsite review group
(PRG - Plant Review Group) was also noted particularly in the areas of review of
events and the more prompt issuance of procedure changes.
During this SALP period, NRC inspectors and the licensee were made aware of com-
plaints dealing with management relations which fostered poor worker attitudes,
low morale, high turnover rates, and low productivity. A completed licensee in-
vestigation was thorough and made certain recommendations aimed at improving wor-
ker/ management relations.
The licensee continues to maintain an adequate training facility and staff.
One deficiency noted was the submittal of out-of-aate and incomplete training
material for NRC exam preparation. Also, committed training of fire watches
was not conducted. A significant improvement has been made in the training of
maintenance mechanics. Maintenance management provided a new mechanical main-
tenance laboratory for improved on-the-job training. Plant engineering also
maintains their own training program for the purpose of providing in-depth
understanding of plant systems. It was noted little interaction between
operators and the newly created system engineers was taking place. The inservice
inspection staff demonstrated a good understanding of ASME Code and regulatory
requirements indicating effective training in this area. The licensee is
continuing to apply the concept of teamwork and leadership to programs in the
organization.
- __ _ -
o .
.
.
31
Problems were identified with operator training on E0Ps. As a result, contracted
time has been increased on a generic simulator. A plant specific simulator will
not be available until October 1990.
GPUN maintains a policy for its employees which stresses a high standard of
integrity and procedure adherence. This is frequently reinforced through
training and memoranda from management. In order to improve performance at
Oyster Creek, an employee attitude survey was conducted and efforts were made
to resolve concerns expressed. Surveys were conaucted to assess personnel
attributes in order to balance shift crews to maximize shift performance.
Also, the licensee has within the Onsite Safety Review Group initiated a Human
Performance Evaluation System to further aid in providing recommendations to
improve operations. The group's efforts were hampered due to the inability to
provide a full staff. In general, the licensee is taking many initiatives to
improve performance.
During the defueling recently conducted, numerous errors occurred. Each of these
individual errors were appropriately critiqued and corrective action taken. In
an effort to improve defueling activities, direct involvement of the Vice President
and Director, Dyster Creek, occurred. The direct involvement of a high level of
management becoming heavily involved in operations when other measures appear to
have failed is considered to be a positive move.
Quality Assurance audits of radiological controls effluent and surveillance acti-
vities was good. Hewever, due to the overall pocr performance of the onsite radi-
ation protection program, it was concluded that the quality assuring activities
such as audits, assessments, and critiques were not effective in assuring quality.
The licensee has in place a procedure by which employees may bring safety concerns
to the attention of management. These issues are processed as Preliminary Safety
Concerns (PSC). Although a good initiative, several problems have been identified,
including timeliness of resolution, quality of reviews performed and a perception
on the part of some licensee employees that the system will not effectively resolve
issues. In two cases, superficial reviews were performed and the items closed.
Subsequent review identified that corrective action was necessary. In these in-
stances, the PSC process failed to correct the valid safety concerns. NRC assess-
ment overall is that the PSC program is not performing as the licensee intended.
The quality of the licensee's LERs continues to be good. The late reporting of
LERs was a problem in the past. This deficiency has been corrected. Supporting
I data and summaries provide additional information related to LERs. Significant
findings associated with LERs include one instance where control room procedures
were not updated to reflect conditions described in a report, an instance where
information was not reported clearly, and one instance which described a condition
in which an improvement in control room command responsibilities may have pre-
vented a violation. In another instance, an incorrect fuel zone level instru-
ment evaluation was performed. This was not recognized by the licensee and the
item was closed. One noteworthy finding was that LERs reported conditions that
had been previously identified in Preliminary Safety Concerns. Overall, LERs
_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ .
_ .. . _ _ - - . _- _ - - - _ _ . - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ . _ _ _ _ .
,
1
e s
4
.
.
32
reported 17 events related to Technical Specification requirements, 6 related to
design criteria, 4 to Appendix R, and one to Appendix J. In general, no single l
cause could be attributed as responsible for any significant number of events.
t
In summary, management attention and involvement were responsive to licensing
issues, and licensing problems have generally been dealt with effectively and
in a timely manner. QA monitoring and audits were generally good; however, I
correcting of some QA findings was not timely. Offsite committee performance i
is good and improvement in onsite committee performance has been noted. The
licensee has in place policies which stress high standards of integrity. A
strong emphasis on training is being maintained. Deficiencies needing attention
were noted in the areas of installation and storage of ' shop spare parts. A
more significant concern which requires prompt and thorough resolution is the
effectiveness of the Preliminary Safety Concern process to identify and correct
deficiencies.
IV.G.2 Conclusion
Category 2.
IV.G.3 Recommendation
Licensee: Review current and previously closed Preliminary Safety Concerns to
verify that no outstanding safety issues remain unresolved.
NRC: None.
_1___-______________ . _ _ _ _ _ . _ _ _ _ _ _ _
_ _ - -
p 4.g ,,
, , .
.. ~
..
.SUPp0RTING DATA AND SUMMARIES.
1
.A. Investigations and Allegations Review
-A.1 Investigations
The NRC Office of Investigations completed two investigations during the SALP
period. 0ne. involved a self-initiated investigation to determine whether or not
licensee' statements made to NRC inspectors constituted a willful' material false
statement. The other involved investigation into the reported destruction of a
portion of an alarm tape by a licensed control room operator following the viola-
tion of a Technical Specification Safety Limit.
'A.2 Allegations
'
During this assessment period, seven allegations were received and acted upon.
One remains open~and five were closed. One was closed with the subject incorpor-
ated into a future inspection plan. Only one allegation was substantiated. The
one open allegation was turned over to the licensee for evaluation.
B. Escalated Enforcement Actions
B.1 Civil Penalties
One civil penalty involving a Technical Specification Safety Limit Violation that
occurred during the previous SAlp period, was issued during the current evaluation
period.
B.2 Orders
None.
C. Confirmatory Action Letters
None.
D. Licensee Event Reports
During the last assessment period 45 LERs were generated and during this period
46 reports were generated with four of these identified as voluntary reports.
Reports for the last period were generated at the rate of 3.9/ month and for this
period at the rate of 2.8/ month.
The greatest single cause for the events reported is personnel error. Eleven of
the 46 LERs reported (24%) were attributed to personnel error. The next largest
cause was attributed to equipment failure which was 8 (17%). The number of LERs
attributed to personnel error is decreasing. During the last period 64% of the
reports were attributed to personnel error. Analysis of the cause of personnel
errors did not indicate a general training problem.
SD/S-1
- - - _--_______
___ _ _ - _ _ _ _ - -
- ,, ,,
'
.
&
~
Four events resulted from reactor scrams when shutdown, generally due to neutron
system noise spikes. Three were due to standby gas treatment system initiations
! resulting from water accumulation in the offgas line. Action.has been taken to
correct this condition.
To the extent possible during the NRC review of the LERs, where applicable, a con-
tributing cause was assigned. The most frequently noted contributing cause was .)
judged to be lack of management attention / poor supervision. Eleven of the 46 LERs '
(24%) had this attributed as a contributing cause.
The most frequent methods of identification of the LERs were control room indica-
tion 15, surveillance testing (6) and design reviews (5). Types of equipment in-
l
volved were mechanical 18, instrumentation (12) and electrical (6). No specific
conclusions were drawn from.these statistics.
The most frequently identified licensee corrective actions specified in the reports
were procedure changes (16), failed equipment repaired (10), increased training
(8), and making 'the report required reading (10). The effectiveness of the cor-
rective actions are difficult to assess, particularly the required reading of the
LERs.
Overall, LERs reported Technical Sr; edification violations (17), violations of de-
sign criteria (6),.of Appendix R (4), and one of Appendix J. In general, no single
cause could be attributed as responsible for any significant' number of events.
' Not identified as an LER at Oyster Creek but reported by another facility was the
design service water temperature being exceeded. The licensee has determined the
85 degree design service water temperature was exceeded. However, to date no de-
. termination of deportability has been made nor has the licensee's evaluation of
the effect of a higher than design service water temperature been comple~ted.
1
SD/S-2
, _ _ _ _ _ _ _ _ _ _ _ _ .___ _ _ _ _ _ _
_ _ _ _ _ . _ _ _ _ _ _ _ . _ _ _ __ _ _
go
l. .
.;
s
TABLE I
ENFORCEMENT ACTIVITY
A .~ Enforcement Activity
'
NUMBER OF VIOLATIONS BY SEVERITY LEVEL
Functional Area V IV III II I DEV ' TOTAL
Plant Operations 1 3 1 5
l
Radiological Controls 9 9
Maintenance / Surveillance 1 1
Security 1 3 4*
Engineering / Technical Support 2 8 10
Safety Assessment / Quality Verification 1 1
TOTAL 6 23~ 1 30*
- 0ne additional security violation is pending final enforcement action ~ determina-
tion.
B. Violation Summary-
REPORT- SEVERITY FUNCTIONAL
NUMBER REQUIREMENT LEVfi AREA DESCRIPTION
87-28 10 CFR 50 App. B, V Maintenance / Identified maintenance
Criterion XII Surveillance and test equipment
discrepancies not )
evaluated as required.
87-37 Physical Security IV Security Vital area barrier
Plan found to have been
degraded. ,
87-39 T.S. 6.13, High IV Radiological Worker entered high
Radiation Area Controls radiation area without
dose rate instrument.
T-I-1
__ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ ___ _
. .
-
__ - _ _- _ - -_ _ _ - _ _ -_ - _ -
,
f'+-'q.
-
,
'^
,
s. :
>
REPORT' SEVERITY FUNCTIONAL-
NUMBER- REQUIREMENT LEVEL AREA DESCRIPTION'
87-39 .T.S. 6.13, High IV Radiological Control of high radi-
Radiation Area Controls ation area access.
.
87-39 T.S. 6.11, Radiation IV Radiological Failure to adhere to ,
Protection Process Controls the requirement of a
radiation work permit.
87-41 T.S. 6.8.1, Station IV Operations Failure to follow pro-
Procedures cedures relating to
positioning of valves. ,
88-02 10 CFR 50.59_ IV Engineering / Failure to perform
Tech Support safety evaluation for
for reactor building
heating system being
out of service for ap-
proximately two years.
>
88-02 T.S. 6 8.1, Station IV Engineering / Inadequate procedure
Procedures Tech Support reviews.
88-04 T.S. 6.8.1, Station' IV Engineering / Controls to effect
Procedures Tech Support procedure revisions.
88-04 <T.S. 6.8.1, Station IV Engineering / Failure to adhere to
Procedures' Tech Support procedures relating
to snubber operability.
88-04 10 CFR 50, App. 8 IV Engineering / Failure to take prompt-
Tech Support corrective action tu
a nonconforming condi-
tion identified during ;
snubber surveillance. !
L 88-11- 10 CFR 10.101 (b) IV Radiological F.iilure to conduct
Controls adequate surveys.
88-13 T.S. 6.11, Procedure IV Radiological Failure to adhere to
for Personnel
.
Controls radiation work permit }
qadiation Protection requirements. >
88-14 T.S. 3.12. A.1, Fi re V Operations Fire detection instru-
Detection-Instrumen- mentation pressure
tation switch valved out. 1
T-I-2
1
- _ _ _ _ _ . - _ - _ _ _ _ _ _ - _ _ _ - - _ _ - - - - _ _ _ _ _ _ _ - - - - - _ - - - -
. __ ._ _ _ - _ . . _ _ _ _ _
________-_,
"
.F 4
,
o
REPORT SEVERITY FUNCTIONAL
NUMBER REQUIREMENT LEVEL AREA DESCRIPTION
88-14 Fire Protection DEV Operations Inadequate training
Program program for ignition
source fire watches.
88-15 10 CFR 50.59 IV Engineering /. Performance of an
Tech Support improper safety
evaluation.
88-21 T.S. 3.4.C, IV Operations Operation with one
Containment Spray containment spray loop
and Emergency out of service for a-
Service Water period greater than !
System Operability allowed.
'
88-21 T.S. 6.8.1, Station IV Operations System placed into
Procedures service without current
valve checkoff.
88-21 T.S. 6.8.1, Station IV Engineering / Modification placed
Procedures Tech Support into service without
control room drawing
being updated.
88-28 10 CFR 50, App. J IV Engineering / Containment airlock
Tech Support not tested as required.
88-29 10 CFR 50, App. R V Engineering / A failure to meet Ap- ,
Tech Support pendix R requirements
was promptly corrected
and no written viola-
tion was issued.
88-31 10 CFR 20.201, IV Radiological Failure to conduct a
Surveys Controls survey.
88-31 T.S. 6.11, Radiation IV Radiological Worker failed to comply
Protection Program Controls with the requirements
of a radiation work
permit.
88-32 10 CFR 50.54 (p), V Security Change to physical
Physical Security security plan without
System Commission approval.
l
T-I-3
_- -
_
- ___ - _-__ _-____ - ____-___._-_-_ _ __ _ _ _ _ _ _ - _ _ _ - _ - _ _ - _ _ - _ _ _ -_ ,- -,
.
. f ., , g
.
l; , y v' '
a
REPORT' . SEVERITY . FUNCTIONAL
l NUMBER REQUIREMENT LEVEL AREA DESCRIPTION'
E -88-33 10 CFR 50, App. B I V, . Safety Assess . Failure to control
ment / Quality storage of items out-
Verification side' warehouse.
'88-33 Physical Security IV Security ' Degraded vital area
' Plan barrier.
88-33- 10 CFR Part 73.71, IV. Security' Failure lto. report de-
App..G, Sect. I.(c)- graded vital area bar-
rier.
.
88-35 'T.S. 6.8.1, Station V Engineering / Several procedures
Procedures Tech Support- 1ssued without approval
signatures.
88-37 10 CFR 20.201 (b) IV Radiological Failure to evaluate
Controls -radiation hazard
created by control rod
drives awaiting pro-
cessing.
88-37 LT.S. 6.8.1, Station IV Radiological Inadequate procedure
Procedures Controls for the' control of rod
drive work.
.
T-I-4
- -- _ = - _ _ - _ _ _ _ _
, - _ - _
_ - _
,
o P. .
.
u,'
l
TABLE II
LISTING OF LERS BY FUNCTIONAL AREA ;
l
AREA A B C D E X TOTALS
Operation 5 4 2 1 1 13
'
Radiological Controls 2 1 3
Maintenance / Surveillance 2 4 6 2 14
Ser.urity
Engineering / Technical Support 6 7 2 1 16
Safety Assessment / Quality Verification __ __ __ __ __ __
TOTALS 15 16 10 4 1 46
Cause Codes *:
A - Personnel Error
B - Design, Manufacturing, Construction or Installation Error
C - External Cause
D - Defective Procedure
E - Component Failure
X - Other
- Cause Codes in this table are based on inspector evaluation and may differ from
those specified in the LER.
I
i
-
!
l
l T-II-1
I
. . _ _ _ _ _ . _ _ _ _ _