ML20246B057
| ML20246B057 | |
| Person / Time | |
|---|---|
| Site: | Three Mile Island  |
| Issue date: | 06/28/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20246B052 | List: |
| References | |
| 50-289-87-99, NUDOCS 8907070185 | |
| Download: ML20246B057 (48) | |
See also: IR 05000289/1987099
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ENCLOSURE 1
FINAL SALP REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I )
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-289/87-99
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION
THREE MILE ISLAND NUCLEAR GENERATING STATION
ASSESSMENT PERIOD: November 1, 1987 - January 15, 1989
MANAGEMENT MEETING DATE: April 10, 1989
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TABLE OF CONTENTS
PAGE
.I. INTRODUCTION.......................................................... 1
I . A Li c e n s e e Act i v i t i e s . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . 2
1.B Direct-Inspection end Review Activities......................... 2
'II. SUMMARY O F RES U LTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
II.A 0verview..............................,......................... 3
. I I . B Fa ci l i ty Pe rf o rma nce ' Tabul a t i on . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
- II.C Unplanned Trips and Forced Shutdowns............................. 5
- II.D Other Minor Plant Transients and Reduced Power Periods. .. . . . .. .. 6
'III. CRITERIA......................... ................................... 7
IV. PERFORMANCE ANALYSIS......................................... ....... 8
JV.A Plant Operations.. .............................................. .8
IV.B Radiological Controls........................................... 12.
IV.C Maintenance / Surveillance........................................ 14
.IV.D Emergency Preparedness................. ........................ 18
IV.E Secur.ity........................................................ 19.
IV. F Engi neeri ng/ Technical Support. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
IV.G Safety Assessment / Quality Verification.......................... 25
SUPPORTlNG GATA AND SUMMARIES
A. I n specti o n Hi s to ry S umma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SD/S-1.
B. E n f o rceme n t ' S umma ry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SD/S-2
C. Li cen see Event Reports /Analysi s. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . SD/S-2
D. A11egations..................................................... SD/S-2
TABLES
Table 1 - Inspection Hours Summary
Table 2 - TMI-1 Enforcement / Severity Levels
. Table 3 - Licensee Event Reports
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an integrated
NRC staff effort to collect the available observations and data on a periodic basis
and to evaluate licensee performance based upon this information. The SALP is sup-
plemental to normal regulatory processes used to ensure compliance with NRC rules
and regulations. The SALP is intended to be sufficiently diagnostic to provide
meaningful guidance to the licensee's management to promote quality and safety of
plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on March 2,1989, l
to review the collection of performance observations and data to assess the 11cen-
see performance in accordance with the guidance in NRC Manual Chapter 0516, "Sys-
tematic Assessment of Licensee Performance " A summary of the guidance and evalu-
ation criteria is provided in Section III of this report.
This report is the SALP Board's assessment of the licensee's safety performan'ce
at the Three Mile Island Nuclear Generating Station, Unit 1 (TMI-1) from November
1, 1987 through January 15, 1989. The summary findings reflect a 15-month assess-
ment period.
SALP Board
Chairman: W. Kane, Director, Division of Reactor Projects (DRP)
Members:
M. Knapp, Director, Division of Radiation Safety aM Safeguards (DRSS)
T. Martin, Director, Division of Reactor Safety (DFS)
L. Bettenhausen, Chief,. Projects Branch No. 1, DRP
- J. Durr, Chief, Engineering Branch, DRS
- R. Bellamy, Chief, Facilities Radiological Safety and Safeguards Branch, DRSS
R. Gallo, Chief, Operations Branch, DRS
C. Cowgill, Chief, Reactor Projects Section IA, DRP
R. Conte, Senior Resident Inspector (TMI) DRP
J. Stolz, Director, Project Directorate I-4, Office of Nuclear Reactor Regulation
(NRR)
R. Het aan, Operating Reactors Project Manager, NRR
Other Attendees:
- C. Amato, Emergency Preparedness Specialist, DRSS )
- W. Pasciak, Chief, Effluents Radiation Protection Section, DRSS
- M. Shanbaky, Chief, Facilities Radiation Prr,tection Section, DRSS
- S. Sherbini, Senior Radiation Specialist, DRSS
- C, Smith, Safeguards Specialist, DRSS
D. Johnson, Resident Inspector (TMI), DRP
T. Moslak, Resident Inspector (TMI), DRP
F. Young, Senior Resident Inspector (Susquehanna), DRP
- Part-Time Attendees
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'I.A Licensee Activities
During this. period, the licensee operated TMI-1 essentially at full power, except
for a refueling outage and as noted in Section II.C and II.D (Forced Outages and
Plant Transients). This reflected ten transition periods between' power operations j
and hot (or cold) shutdown in addition to the two transition periods for their
l. refueling outage. The one trip during this' SALP period occurred on October 30,
L' 1988 (the last one being on September 16,1987). A scheduled sixty-foer day re-
fueling outage started June 17, 1988, and the. licensee completed it about five days !
ea rly..
Major safety-related work completed during the refueling outage was: "8" make-up
pump overhaul; seal replacement for four reactor coolant pumps; steam generator
mechanical cleaning and eddy current testing; installation of Regulatory Guide (RG) j
1.97, Instrumentation; fuel handling bridge modification; upgrade power supply for
the Integrated Control System /Non-Nuclear Instrumentation System (ICS/NNI).
At the beginning of this period, the licensee's maintenance department at TMI-1
was in the process of reorganizing into a Materiel Department. Four major groups
in this department were to perform the following functions: plant materiel (cor-
rective and preventive maintenance implementation), planning and scheduling, ma-
teriel assessment and administration.
Also, during this period, the licensee implemented a corporate reorganization,
establishing a new division with Vice President for Quality and Training.
Self-assessments were completed in the maintenance and technical support functional
areas.
I.B Direct Inspection and Review Activities
Four NRC resident. inspectors were assigned to the site (TMI-1 and 2) throughout
most. of the assessment period. Total NRC inspection effort was 4693 hours0.0543 days <br />1.304 hours <br />0.00776 weeks <br />0.00179 months <br /> (4107
hours per year). See Table I for functional area expenditures.
Special team inspections were: Outage Team Inspection (88-17) and Emergency Pre-
paredness Exercise (88-28).
Also, the Office of Nuclear Reactor Regulation (NRR) sent a team to review the
design of electrical power distribution.
Six violations (five Severity 4, one Severity 5) were issued. These are listed
in Table 2.
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II. SUMMARY OF RESULTS _,
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II.A Overview
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The licensee operated TMI-l in a safe manner throughout the rating per od. In all
functional areas, programs are well established. These programs are arried out
by knowledgeable personnel who are appropriately trained.
During the period, the operating record at the facility was exc lent. Overall
plant material condition remained good. One reactor trip occur ed as a result
of equipment failure. Operators responded alertly to other nditions such as
equipment malfunctions to prevent plant transients. The exc lent operating
record is a reflection of a high level of performance in plant equipment material
condition, operator performance, and overall manageme t oversight of the facility.
In general, management involvement in maintenance .id s veillance was effective
and outage management was excellent. Several impfrtan initiatives have been taken
including a restructuring of the maintenance dep6rtm t. The principal weaknesses
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observed were in specific job planning, increp(ed p rsonnel errors, and nonradio-
logical chem 1stry laboratory operations. Th)s le to the decline in performance
. inthemaintenanceareanotedduringthepgri(gb. ,
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Strong programs continue in the radiologi ontrols, emergency preparedness,
and security areas. Improvements in the < gency preparedness area in response
to NRC concerns and communication prob in the last SALP were positive and
returned that program to its previous rsng level of performance.
Engineeringandtechnicalsupportsh rmance improved; this was most notable in
engineering support to the 7R refuel ng outage. A technical support self-assess-
ment was completed and corrective ctions were begun.
Licensee programs to identify a J correct problems are thorough and the various
review groups are active in a essing plant performance. Root cause determination
and corrective action implem ntation although effective, sometimes result in a
lengthy process. A recent teworthy improvement in this process is the high qual-
ity of the human performa ce evaluations of selected incidents. Although overall
improvements have be s de in procedure adherence, progress in these achievements
has been slow, part larly in administrative controls. l
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Overall, license performance during this period continued to be very good. The j
refueling outag was a noteworthy example of this performance. Completion of '
corrective at .on programs underway and management attention to problems existing
or identifie in the futu.e should continue this progress,
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.II. SUMMARY OF RESULTS
II.A Overview
The licensee operated TMI-1 in a safe manner throughout the rating period. In all
functional areas, programs are well established. These programs are carried out
by knowledgeable personnel who are appropriately trained.
During the period, the operating record at the facility was excellent. Overall
plant material condition remained good. One reactor trip occurred as a result
of equipment failure. Operators responded alertly to other condition: such as
equipment malfunctions to prevent plant transients. The excellent operating
record is a reflection of a high level of performance in plant equipment material
condition, operator performance, and overall management oversight of the facility.
In general, management involvement in maintenance and surveillance was effective
and outage management was excellent. Several important initiatives have been taken
including a restructuring of the maintenance department. The principal weaknesses
observed were in specific job olanning and increased personnel errors. This
led to the decline in performar,ce in the maintenance area noted during the
period.
Strong programs continue in the radiological controls, emergency preparedness,
and security areas. Improvements in the emergency preparedness area in response
to NRC concerns and communication problems in the last SALP were positive 3nd
returned that program to its previous strong level of performance.
Engineering and technical support performance improved; this was most notable in I
engineering support to the 7R refueling outage. A technical support self-assess-
ment was completed and corrective actions were begun.
Licensee programs to identify and correct problems are thorough and the various
review groups are active in assessing plant performance. Root cause determination
and corrective action implementation although effective, sometimes result in a
lengthy process. A recent noteworthy improvement in this process is the high qual-
ity of the human performance evaluations of selected incidents. Although overall
improvements have been made in procedure adherence, progress in these achievements
has been slow, particularly in administrative controls.
Overall, licensee performance during this period continued to be very good. The
refueling outage was a noteworthy example of this performance. Completion of
corrective action programs underway and management attention to problems existing
l or identified in the future should continue this progress.
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II.B Facility Performance Tabulation
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 section is largely a synopsis of obser-
vations in other functional areas. Additionally, the fire protection, licensing,
refueling / outage, training, and assurance of quality areas have been incorporated
into the remaining functional areas as appropriate.
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Rating Rating
Last This
Functional Area Period * Period ** Trend
A. Plant Operations 2 1
B. Radiological Controls 1 1
C. Maintenance / Surveillance *** 1/1 2
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D. Emergency Preparedness 1 1
E. Security / Safeguards 1 1
F. Engineering / Technical Support 2 2 Improving
G. Safety Assessment / Quality Verification # 2
H. Fire Protection 2 #
I. Licensing Activities 2 #
J. Refueling / Outages 2 #
K. Training and Qualification Effectiveness 1 #
L. Assurance of Quality 2 #
" November 1,1986, to October 30, 1987
- November 1, 1987, to January 15, 1989
- Previously addressed as separate areas of Maintenance and Surveillance
- Not addressed as a separate area
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II.C Unplanned Shutdowns, Plant. Trips / Transients, Forced Outages
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Functional Root
'Date' Level ' Area Cause Description
11/17/87 100% Maintenance / Procedure Turbine runback from 100
Surveillance Inadequacy percent to 70 percent power
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due to the loss of one main
loss of one MFW pump was
E due to poor maintenance
procedure for restoring a.
condensate booster pump
breaker to service which
resulted in inadvertent loss
of the second feedwater
booster sump such that only
one booster pump remained
running. This condition
tripped one MFW pump.
2/16/88 100% N/A~ Unknown A three-day forced outage'
due to heat transfer surface
fouling of the main gene-
rator stator cooling system,
apparently due to excessive
levels of oxygen in the
cooling system.
9/17/88- 100% N/A Unknown A nine-day forced outage
(Repetitive - to repair the No. I seal
See for the "D" reactor coolant
~12/15/88) pump (RCP) that was appar-
ently improperly installed
during the Cycle 7 refueling
outage.
10/17/88 100% Maintenance / Material A two-day forced outage to
Surveillance Failure repair an oil leak in the
lubricating system for "C"
RCP. The oil leak was at
pipe-to-oil cooler weld.
The licensee conducted a
reactor startup prior to
completion of a proper post-
maintenance test. This
required a reactor shutdown
and second startup to com-
pletely repair the leak.
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Date- Level Area .Cause Description
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-10/30/88 100% N/A Unknown A reactor trip occurred on
high Reactor Coolant System.
(RCS) pressure because the
main turbine generator con-
trol valve went shut. The
root cause could not be
specifically identified, ..
but certain electro-hydraulic.
control system components
were found to be'malfunc-
tioning and were replaced
without a repetitive event.
12/15/88 100% N/A Unknown A fourteen-day forced outage
(Repetitive - to repair the No. I seal
See of the "D" RCP. This was
9/17/88) the second failure of the
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No. I seal runner 0-ring -
since start-up from the 7R
outage. A shaft alignment
problem was suspected.
II.D Other Minor Plant Transients and Reduced Power Periods
This listing is representative of the types of events that resulted in situations
which challenged operators to respond.
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On January 18,1988, at 4:46 a.m. , there was a transient from 100 to 101 per-
cent power, due to a malfunction in the Integrated Control System (ICS). The
operators manually stopped the transient.
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On January 22, 1988, between 5:19 p.m. and 5:33 p.m., there was a transient
between 101 and 90 percent power which was operator induced while switching
between manual and automatic ICS control during maintenance work on the ICS.
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On January 28, 1988, between 1:10 p.m. and 1:20 p.m., there was a transient
from 100 to 97 percent power, apparently due to ICS malfunction in feedwater
demand signal processing circuits.
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Between 3:57 p.m., January 31,1988, and 2:10 a.m., February 1,1988, the
licensee operated at reduced power (approximately 77 percent) in order to make
1. repairs to a feedwater pump (FW-P-1A). Coupling grease had leaked out of the
feedwater pump coupling causing excessive vibrations on the pump.
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On October 11, 1988, a momentary plant runback (100 percent to 96 percent)
occurred when a component in the ICS unit load demand circuit malfunctioned.
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On October'13,'1988, a minor plant transient occurred when an instrument and
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control (I&C) technician ' inadvertently removed an electronic component from
service in the ICS.
Control room operators responded to all the above transients to prevent a plant
, trip / runback and to restore.the plant to normal steady-state conditions.
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III. CRITERIA
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Licensee performance was assessed in selected functional areas significant to nuc-
lear safety and/or the environment. The following were evaluated, as applicable,
to assess each area.
' 1. Assurance of quality, including management involven,ent and control.
2. Approach'to the' resolution of technical issues from a safety standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Operational events (including response to. analyses of, reporting of, and
corrective actions for).
6, Staffing (including management).
7. Effectiveness of training and qualification.
Each functional area was rated as being one of the following.
1. 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 appropriate.
2. Category 2. Licensee management attention to and-involvement in the perform-
ance of nuclear. safety or safeguards activities is good. The licensee has-
attained a level of performance above that needed to meet regulatory require-
ments. 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. i
3. Category 3. Licensee management attention to and involvement in the perform-
ance of nuclear safety or safeguards activities are not sufficient. The lic-
ensee's performance does not significantly exceed minimum regulatory require-
ments. Licensee resources appear to be strained or not effectively used.
NRC attention should be increased abose normal levels.
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The SALP Board'also considered assigned performance trends for the last quarter
of the SALP period. A trend is assigned if definitely discernible, if the SALP
Board concludes that its continuation might change the performance level, and if
considered necessary to either focus attention on declining performance of acknowl-
edge improving performance. .The SALP trend definitions are:
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
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the assessment period and the Itcensee 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
years in order to maintain consistent SALP ratings.
Further, in this assessment, training programs are evaluated within the engineer-
ing/ technical support functional area.
IV. PERFORMANCE ANALYSIS
IV.A Plant Operations
IV.A.1 Analysis
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The previous SALP report rated this area as Category 2 with a need to further im-
prove procedural compliance, develop documentation and evaluation for minor opera-
tional events, enhance interfaces between operations and engineering / test personnel
. under schedular pressure. Positive aspects identified in this functional area in-
cluded a strong post-trip review process, improvements in management's involvement
in day-to-day operations, a high quality of operator training, and a high degree
of professionalism by control room personnel.
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This section of the SALP report now includes' refueling and outage management (pre-
viously Category 2), which was previously rated as a separate functional area. {
This SALP was based on monthly resident inspections and one team inspection cover-
ing the maintenance / modification activities conducted during the 7R refueling out- :
age. It also was based on augmented NRC coverage during Cycle 7 start-up and dur-
ing other outage transition periods.
During routine power operations, the licensee maintained a professional environment
in the control room and assured that distractions to the opersting crews would be
kept to a minimum. Operators rigorously controlled access ta'the control room
proper.to restrict the number of non essential personnel ir, this area. Shift
supervisors consistently maintained authority over activities and provided detailed
turnover. briefings to the relief crews. Operating crews consistently demonstrated
a detailed knowledge of plant design and procedural requirements associated with
equipment operation. The approach to full power operation following the 7R re-
fueling outage was deemed to be deliberate, conservative, and professional. Man-
agement decisions to address a number of typical minor equipment problems were
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based upon safety considerations even if it meant slipping the schedule. Although
frequent involvement by the Operations Manager; Director, Operations and Mainten-
ance; and TMI Director were. apparent, the operators did not appear to be rushed
to get the plant back on line. Response to alarms and off-normal conditions was
prompt and appropriate to the situation.
Operator vigilance during steady-state and transient conditions was excellent.
A number of minor transients-(Section II.D) resulted from equipment malfunctions i
'and maintenance personnel errors. Licensee middle management appropriately sensi-
tized operators to the potential impact on the plant when the Integrated Control
System'(ICS) manipulations or work was on going. For all transients, control room
operators responded alertly to prevent a plant trip / runback and quickly restored
the plant to normal, steady-state operations. The event that resulted in exceeding
the RCS technical specification limit for plant heat-up rate and some other minor
events were due to poor communications, not poor vigilance. Overall, operators
acted in a conservative manner with respect to nuclear safety.
There were some misunderstandings during power operation and during the outage re-
garding operator knowledge of plant status. One significant miscommunication oc-
curred during simultaneous maintenance and operational use of Reactor Coolant Sys-
tem (RCS) drain piping. The event resulted in a spill of radioactive water onto
the reactor building (containment) floor. One LER on inoperable chlorine detectors
resulted from a miscommunication on the status of the detectors. The licensee's
self-review identified a problem in maintaining a knowledge of plant status during
outages. Operating personnel had to coordinate and control a large number of
diversified maintenance jobs and modification activities being performed in various
plant areas. There was not an effective method of keeping track of all of these
activities early in the outage.
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Two senior reactor operator and five reactor operator candidates were administered
written and operational examinations and licenses were issued to all including one
RO candidate who required a retest. All candidates exhibited weaknesses during
the operating test portion of the examinations on the simulator in that they were
unable to identify the cause of various instrument failures in the Integrated Con-
trol System (ICS). While overall operator training is satisfactory, training man-
agement needs to pay closer attention to simulator transient response training.
However, as stated above, operator response to actual transients was good.
Overall, operators were well trained for all plant modifications installed during
the refueling outage. In addition to classroom training on major changes, the
operations department issued substantial training handouts which also were bene-
M clal to the support and management personnel who needed knowledge of facility
changes.
Upper and middle management attention to and involvement in plant operations were
evident. They continued to implement a number of positive measures described in
past SALP reports. Such involvement resulted in an enhancement to identify plant
problem areas. The most notable example of their conservative approach to safe
operation includd M.utting sun the plant to investigate the cause of the reactor
coolant pump problem before they exceeded any Technical Specification (TS) limits.
As further evidence of their involvement in this area, middle management instituted
a number of initiatives as described below. Plant housekeeping was good throughout
this SALP period as a rule. Following the refueling outage, the quality of house-
keeping trended downward in areas where system modification work was in progress.
Housekeeping in the radiologically controlled areas as noted in the Radiological
Controls section of this report is good.
Middle management took a number of initiatives to further improve overall opera-
tional performance. Included in these initiatives was a program to cross-assign
extra shift supervisors (SS) among shifts in order to free up the most experienced
SS's for other support duties, such as simulator training. They also instituted
a plant component labeling system along with enhanced shift turnover notes in the
interest of efficiency. Further, upper management detailed operating personnel
to participate in INPO evaluations at other sites. Also, the licensee implemented
several administrative control initiatives to adequately log and further evaluate l
incidents having relatively minor significance. However, these actions were not
completely effective. Preliminary review by inspectors identified that related
guidance on such incidents was incomplete. The licensee implemented revised guid- {
ante at the end of the SALP period. The effectiveness of all of these measures
remained to be determined.
The overall planning of all the outage activities was effective due to good per-
formance in the areas of inter-departmental and contractor interfaces, routine
status meetings, radiological controls, as well as management attention and in-
volvement. The plant had four forced outages (Table II.C); two of these were for
maintenance to repair the No. I seal on the "D" reactor coolant pump (RCP). Each
unplanned outage required significant " impromptu" replanning of manpower resources,
vendor interfaces, training, as well as special testing, especially during weekends.
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The results were that the licensee's overall planning and implementation of main-
tenance activities were well coordinated and effective. Management's involvement
in assuring successful completion of each outage was noteworthy. Considerable
resources were expended on determining the cause of the "D" RCP seal problem but
no definitive root cause was determined.
Inspections noted improved performance in the area of adhering to operational pro-
cedures. This is in contrast to administrative control procedure adherence. The
licensee's Quality Assurance Department similarly noted these results, but they
also identified a continuing problem in the area of adherence to administrative
controls (see Section IV.G). Inspectors noted proper alignment of systems in ac-
cordance with operational procedures. Despite weaknesses stated in the last SALP
report, the licensee's independent verification program continued to be effectively
implemented to assure proper safety system alignments. However, as noted below,
some discrepancies in the area of procedure adequacy continued to challenge opera-
tors to comply with procedures.
In general, inspections confirmed the adequacy of procedures, especially with re-
spect to safety system alignments. The licensee made improvements in the quality
of emergency operating procedures (EOP's). However, inspectors continued to note
individual step inadequacies in some of the relatively frequently used procedures.
One problem occurred in that two valves had been inadvertently omitted from a valve
lineup checklist for the emergency diesel generators. Other minor procedural de-
ficiencies caused operator confusion in some instances and had the potential to
cause procedural non-adherence. None of these examples within this functional area
resulted in an event of major safety significance. However, such discrepancies
indicated that the biennial procedure review process, was not completely effective
in preventing procedure problems.
In summary, operator professionalism, competence, and vigilance were significant
operational strengths and operator training was conducive to this strong overall
performance. There was improved performance in adhering to the operational
procedures, but the quality of certain administrative control procedures needs i
to be improved. Middle management control of plant operations and outage )
activities was very good. All levels of management were involved in the conduct 1
of daily operations. Middle and upper management acknowledged areas where
improvements were needed. In some cases, however, management response was slow
in implementing corrective actions to improve performance in these areas.
Operator performance continued to significantly contribute to the overall
. excellent operating record i
of TMI-1. l
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IV.A.2 performance Rating: Category 1.
IV.A.3 Recommendations: None.
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IV.B Radiological Controls
IV.B.1 Analysis
The last SALP report rated this area as Category 1. Concerns during that period
were limited to occasional improper posting of high radiation areas as well as
several deficiencies in performing surveys in connection with some radwaste opera-
tions.
Two specialist inspections were conducted in this area during the current SALP
period. In addition, there were routine reviews by the resident inspectors.
! Performance in the areas of concern identified during the last period has improved.
Performance in radiological controls, in general, has maintained the same level
of high quality as that observed during the last SALP period. Management at all
levels remains involved in the daily activities on site and is also constantly
apprised of the details of on going and future radiologically significant activi-
ties. The responsibilities of the tinagers and supervisors are clearly defined
and are well understood by the staff. Management at all levels also remains re-
sponsive to concerns expressed by the staff or by the NRC. As an example, a review
of the issues raised in incident reports and concerns raised by workers shows that
the radiological engineers consistently study these issues, make recommendations,
and initiate corrective action, if appropriate. Audits of the site radiological
controls program, both internal and corporate, are performed periodically and the
findings are evaluated and acted upon. One concern in this area was the inadequate
planning of scaffolding erection during the last outage. The result was unneces-
sary radiation exposure. Management's responsiveness is exemplified by the fact
that this deficiency was recognized and plans were made to improve performance in
the next outage.
Radiation exposure and access control by radiation work permit remains effective
and the job descriptions and access requirements in the permits are generally good.
Surveys are usually of high quality and are timely as is the air sampling program.
Personnel contamination control is effective and well documented. Although surveys
are routinely performed on schedule, a minor concern in this area is that new sur- ;
veys are sometimes not posted in place of the expired surveys in all the areas. l
l Surveys and measuring instruments are routinely calibrated on schedule. Support !
programs, such as the respirator maintenance facility, personnel dosimetry, and I
instrument service and calibration facility, are effective and well run by com- )
petent professionals.
]
The training programs for radiation workers and for the health physics technicians
are good. The staff in charge of these programs are competent and expe-ienced in
plant operations. Based upon the staff's limited observations, we cons der the
health physics staff to be well qualified and well trained.
Performance in the area of ALARA continues to be goud. Outage planning 15 still
being performed in a satisfactory manner and ALARA oversight duris.3 njcr jobs is i
being provided by competent radiological engineers. Jobs are being reviewed rou- )
tinely for incorporation of ALARA measures and long-term source reduction efforts
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are on going. These efforts include system and area decontamination, a cobalt
.
reduction program, mock-up training, and improved procedures, such as those for
l eddy current inspections, based on lessons learned from previous outages. Despite
l. these efforts, however, the dose goal (120 man rem) was exceeded during the last
L outage (157 man-rem). The reasons appear to be a combination of planning
l' problems associated with scaffolding erection, hot transient working conditions,
I and unexpectedly high minor maintenance work, Licensee's responsiveness to
l identified problems is exemplified by a demonstrated awareness of the problem
i (scaffolding erection planning) and its causes and the formulation of solutions
l to prevent recurrence. Solutions include the use of permanent or semi permanent
scaffolding and a more detailed mapping of the locations of items such as valves
and welds that may require maintenance and inspection in the future. Locating
such items, many of which are in relatively high dose rate areas, has contributed
significantly to the cumulative exposure for the last outage. The cumulative
exposure, though higher than the estimate, is indicative of good performance.
Three inspections of the licensee's solid radioactive waste (radwaste) and trans-
portation program were performed, including processing, preparation, packaging,
shipping, quality controls, and audits. Two problems occurred with radwaste ship-
ment manifests associated with TMI-2 decontamination. Licensee corrective actions
to correct the problem were prompt and appeared to be of sufficient depth to pre-
vent recurrence. Additionally, the training program for personnel in this area
was found to be strong. Despite the problems, the licensee is maintaining an ef-
fective program in this area. ,
Three inspections of the licensee's effluent controls were performed during the
assessment period. Effluent control procedures were very detailed and accurate.
The licensee properly implemented its Off-Site Dose Calculation Manual (ODCM).
The dose calculation methods were found to be comprehensive and adequate to accomp-
lish their purpose. The licensee's dose calculations were performed in accordance
. with the procedures that implement the methodology described in the ODCM. Release I
permits were properly completed and accurate with respect to dose calculations. ]
Good agreement was obtained between expected and actual responses of selected ef-
fluent monitors, as confirmed by the inspector's calculations. Operability checks
and calibrations were performed as required. The licensee maintains good control
over deficiencies identified during calibrations and tests. The licensee is main-
~taining an excellent program in this area.
Two inspections of the licensee's radiological environmental monitoring program
were conducted including Quality Assurance / Quality Control (QA/QC) of the analy-
tical laboratory, comparison of the collocated thermoluminescent (TLD) monitoring
results and meteorological monitoring program. QA/AC of the analytical laboratory
is well maintained. The monitoring results of the licensee's TLD's collocated with
NRC's are generally in agreement. Calibration and preventive maintenance of the
meteorological instrumentation was found to be adequate. The annual environmental
monitoring report was reviewed and found the licensee performed all aspects (samp-
ling, analytical sensitivities, reporting schedules, and inter-laboratory compari-
son) as required. The licensee is maintaining an effective program in this area.
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An inspection was conducted using the NRC's mobile laboratory during the last
quarter of the assessment period. The licensee's performance with respect to ac-
.tual samples during the inspection was good with the exception of detecting radio-
activity in a charcoal cartridge used to sample iodine effluent from the main con-
' denser exhaust. Because of an erroneous essumption regarding distribution of
iodine within the cartridge, the licensee's analysis indicated an' activity of 30%
lower than that measured by NRC. This problem was initially identified in 1986,
During the NRC mobile laboratory analysis in 1988, the staff determined that the
iodine was deposited uniformly.throughout tne' cartridge resulting in the analysis
error, and also indicating excessive moisture in the sample stream. The licensee
has now committed to resolve the moisture problem and correct past effluent reports.
Management response to this issue was very slow indicating that the original issue
had not been elevated to the proper level of management attention. The public
health consequences of this error was very small. However, the length of time
taken to resolve the issue indicates occasional lack of attention to NRC inspection
findings.
Summary
In. summary, the radiological controls program remains effective in controlling
access to radiologically controlled spaces, controlled areas are posted in accord-
- ance with applicable requirements, and good housekeeping is generally maintained
in the controlled areas. Planning and control of jobs in radiological areas is
'
also good, and_ efforts.to minimize individual and cumulative exposure appears to .
- . be effective. Training of radiation workers and of health physics technicians is
good. Support programs such as dosimetry and respiratory protection are well
managed and technically current. The overall assessment is that the radiological -
control program onsite is a high quality program. ;
IV.B.2 Performance Rating: Category 1.
IV.B.3 Recommendations: None.
IV.C Maintenance / Surveillance
IV.C.1 Analysis
During the last SALP period, no major maintenance programmatic problems were evi-
dent and the licensee's performance was judged to be a positive influence on opera- 4
.tions. The surveillance program was well managed. The implementation of the in- '
. service inspection (ISI)., as well as inservice testing (IST) of equipment, ensuring
operability of safety-related equipment, was adequate and effective. A Category
1 rating was assigned to both the maintenance and surveillance areas.
l
During this assessment, the NRC staff combined the maintenance and surveillance I
areas into an equipment operability perspective. The overall assessment included
routine inspections by the resident inspectors, specialist inspections by region- 1
based inspectors, as well as a special team inspection, covering major 7R mainten-
ance/ refueling outage sctivities.
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Maintenance Organization and Planning
The licensee conducted a self-assessment and changed the maintenance organization "
stru'cture, emphasizing three areas: materiel assessment, corrective / preventive
maintenance, and planning and scheduling. The new organization had qualified and
experienced people in these areas and there were indications that this change would
be instrumental in improving performance. Examples of the effectiveness of these
,
changes included successful completion of the 7R outage ahead of schedule, compu-
terizing work packages, strengthening of motor-operated valve actuator testing
programs, implementation of scientific event review process, development of a mai-
ntenance plan to further improve materiel conditions of the plant. Most notable,
the maintenance organization initiated a new reliability centered maintenance (RCM)
program, which involved systematic assessment of systems, emphasizing functional
reliability, current preventive maintenance measures, and then upgrades as neces-
sary to enhance equipment reliability.
Despite the overall good planning and outage management efforts, several shortcom-
ings in specific job planning and implementation for routine and outage work ex-
isted. The licensee had a total of seven violations during this assessment, with
five violations attributed to this functional area. The problems were generally
reflective of poor specific job planning, inadequacies in maintenance / surveillance
procedures, and failure to follow administrative procedures. With respect to
specific job planning, a significant example was the installation of a wrong ex-
pansion joint in the reactor building emergency cooling water system. In addition
to this, there were other examples of inadequate maintenance program implementation
as addressed below.
Maintenance Implementation
'
With respect to maintenance procedure adequacy, the inspectors noted that a sub-
stantial number of preventive and corrective maintenance procedures were estab-
lished. Overall, these procedures were adequate. However, pump work was performed
using a generic maintenance procedure and a substantial rework effort on one of
the pumps resulted from the failure to incorporate appropriate vendor guidance into
the procedure.
With respect to properly following administrative controls, there was overall
satisfactory performance considering the number of measures that need to be im-
plemented for substantial maintenance / modification work packages. However, the
examples of nonadherence were significant. For example, two problems involved
licensee failures to properly incorporate vendor-supplied information into specific
work instructions. There were also examples of incomplete job tickets and exces-
sive delays in making return to service signoffs, some up to three months. The
licensee recognized the administrative controls problem and they were to address
it by their administrative compliance task force (see Section IV.G). However,
these examples were also generally reflective of a lack of awareaess by licensee
and contractor personnel on the numerous administrative measures that existed in
this functional area.
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Overall, the materiel condition of the plant based upon routine plant tours by.the
inspectors remained generally good. Despite a licensee program in this functional
area,.the inspectors noted some materiel deficiencies, such as loose conduits,
connections, supports, bolts, and missing clamps. This reflects a lack of atten-
tion to detail by licensee personnel in identifying minor material deficiencies
during routine and special plant tours. The licensee was responsive by developing
a new procedure to further improve their current program. However, its effective- i
ness remained to be determined at the end of the SALP period. i
Maintenance Activity Interface
During several maintenance activities, the inspectors noted substantial interfacing
among the Quality Assurance / Quality Control (QA/QC), Plant Maintenance, Engineering
and Operations groups. . However, inspectors noted some weaknesses. Maintenance
personnel caused a number of transients which challenged operators. In addition
to personnel error, the root causes were similar to the causes of the examples
noted above. In the area of receipt inspection, two different kinds of injectors
and thermocouple as well as the jacket cooling water pump motor having the same
part numbers, were received, accepted, and installed on the emergency diesels
without adequate review by the responsible work groups. In one case, a diesel
generator inoperability resulted. A receipt inspection error contributed to tne
installation. The licensee planned to re-evaluate their receipt inspection program,
as well as other interface deficiencies, to prevent recurrence.
The major plant modifications were installed by Maintenance, Construction and
Facilities. During the 7R outage, some of the major modifications, such as me-
chanical' cleaning and tube plugging of main steam generators, were well managed
and completed in a safe manner on or ahead of schedule with successful post-modi-
fication testing. In general, surveillance /special testing compleinented mainten-
ance/ modification work.
Surveillance
Overall, the licensee continued to imp Nment a well-established surveillance pro-
. gram. The surveillance were performed on schedule and adequately documented.
Even though various groups were involved, they were, in general, well coordinated
and the interfaces properly defined. A Not.cle example was the licensee's reactor
building local leak rate testing. In general, the surveillance procedures ade-
quately addressed the acceptasce criteria, as well as follow-up actions, on failed
surveillance. The test methods and procedures were technically sound and con-
sistent with accepted industry practice. The procedures were clear, detailed, and
provided good administrative control. The personnel performing the tests were well
trained and qualified. During surveillance activities, the inspectors noted that
the communication among various groups was clear and each procedure step was fol-
lowed and signed off by designated per;onnel.
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There was one Licensee Event Report (LER) in this area. During a low press e
injection flow test, the l'ipensee exceeded the technical specifications (T ) level
and cooldown rate limits fohthe pressurizer due to procedural inadequac . Thes
applicable surveillance procedure had several biennial reviews (see Se ion IV.%)
which had not identified the problem. No renctor trips were caused b surveillance
activities and the personnel in various groups were knowledgeable of surveillance
requirements and plant equipment.
Special Tests
The inservice testing (IST) implementation was well organize and conducted by a
knowledgeable, dedicated staff. Extensive and detailed te records were readily
available, an example being the setting of the main steam safety valve ring. The
coordination between operations, who performed the te ting, engineering, who re-
viewed the results, and Plant Materiel, who was res nsityle for overall scheduling
(computerized) was excellent. An extensive audit y the' Quality Assurance Depart-
ment (QAD) of IST implementation in 1987 was evi
in plant activities. nce /f QA's continued involvement
The accomplishment of ero ion / orrosion inspection on second-
ary plant piping was ahead of schedule as evi >nce by the completion of approxi-
mately 75 percent of the required inspection. by e end of the 7R outage.
. Secondary water chemistry data were reviewe part of the steam generators main-
tenance program. Eddycurrenttestingof4ha steam generators clearly indicated
having adequate water chemistry paramete During the last two months of opera-
tion before the 7R refueling outage, t censee experimented with morpholine for
pH and oxygen control and the results e positive, justifying a shift to that
type of chemistry control. The lic a also upgraded the chemistry laboratory
by installing additional equipmentcg'ne 3 licensee ef fectively controlled secondary
water chemistry and provided initia ves to improve performance.
Relative to the last SALP assess ent, the nonradiological chemistry control pro-
gram has declined. During an i,spection of the licensee's nonradiological chemis-
try control program, standard olutions prepared by Brookhaven National Laboratory
for the NRC were submitted the licensee to analyze using the licensee's normal
methods and equipment. Ev uation of the results indicated about 31 percent (11
measurements out of )6) the results were in disagreement with the criteria used
for comparison. The K sagreements were attributable to equipment calibration
technique, sampling / error,determinationoftheminimumdetectableconcentrations, j
and training. Th licensee's inter-comparison program was ineffective in identi-
fying these conc {
'n s . The laboratory operation lacked substantial management at- '
tention.
Summary I
j
In summar , the maintenance and surveillance activities continued to be accomp-
11shed i a safe manner. The completion of 7R outage ahead of schedule with sus-
taine successful Cycle 6 operating run clearly demonstrated a substantial main-
tena ce/ surveillance program. Licensee management involvement at all levels was l'
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There was one Licensee Event Report (LER) in this area. During a low pressure I
injection flow test, the licensee exceeded the technical specifications (TS) level
and cooldown rate limits for the pressurizer due to procedural inadequacy. The
applicable surveillance procedure had several biennial reviews (see Section IV.G) ;
which had not identified the problem. No reactor trips were caused by surveillance i
activities and the personnel in various groups were knowledgeable of surveillance !
requirements and plant equipment.
Special Tests
The inservice testing (IST) implementation was well organized and conducted by a
knowledgeable, dedicated staff. Extensive and detailed test records were readily
available, an example being the setting of the main steam safety valve ring. The
coordination between operations, who performed the testing, engineering, who re-
viewed the results, and Plant Materiel, who was responsible for overall scheduling
(computerized) was excellent. An extensive audit by the Quality Assurance Depart-
ment (QAD) of IST implementation in 1987 was evidence of QA's continued involvement
in plant acti.vities. The accomplishment of erosion / corrosion inspection on second-
ary plant piping was ahead of schedule as evidenced by the completion of approxi-
mately 75 percent of the required inspections by the end of the 7R outage.
Secondary water chemistry data were reviewed as part of the steam generators main-
tenance program. Eddy current testing of the steam generators clearly indicated
having adequate water chemistry parameters. During the last two months of opera-
tion before the 7R refueling outage, the licensee experimented with morpholine for
pH and oxygen control and the results were positive, justifying a shift to that
type of chemistry control. The licensee also upgraded the chemistry laboratory
by installing additional equipment. The licensee effectively controlled secondary
water chei.Mstry and provided initiatives to improve performance.
Relative to the last SALp assessment, the nonradiological chemistry control ,
program remained constant. During an inspection of the 1icensee's nonradio- j
logical chemistry control program, standard solutions prepared by Brookhaven l
National Laboratory for the NRC were submitted to the licensee for analysis {
using the licensee's routine methods and equipment. Licensee performance on j
the standards was acceptable. Some minor problems were identified in the areas l
of instrument calibration. A recent inspection determined that this problem j
has been resolved. l
Summary
In summary, the maintenance and surveillance activities continued to be accomp- )
lished in a safe manner. The completion of 7R outage ahead of schedule with sus- l
tained successful Cycle 6 operating run clearly demonstrated a substantial main-
tenance/ surveillance program. Licensee management involvement at all levels was
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I noteworthy in development and implementation of corrective actions required
responsetoproblems,estabTjshmentoflicenseeinitiatives,departmentre gani-
zation, and in conducting a seif-assessment.
s The newly structured mainte ante
organization was fully staffed and functional, but its effectiveness re inedtdt
be realized in certain cases. The primary weaknesses observed were in tances of
poor specific job planning, failure to follow administrative control , increased
personnel errors, and deficiencies in nonradiological chemistry lab ratory opera-
tions.
IV.C.2 Performance Rating: Category 2.
IV.C.3 Recommendations: None.
IV.D.1 Analysis
Duringthepreviousassessmentperiod,licenseepIrfo ance in this area was rated
category 1. This rating was based upon satisf
full participation exercise.and results of a y%outitory> response capability in the
safety inspection
.During the current assessment period, a par t/ participation exercise was observed.
A routine safety inspection was conducted t n a week of the close of the SALP
period. This analysis is based on the re of these inspections. The licensee
issued a new Corporate Emergency Plan f th GPU Nuclear sites. Because of the
significance of the changes, the revis lan was submitted for NRC review prior
to implementation. During the revie i was identified that the Plan did not re-
flect the NRC guidance concerning peg ' ctive actions for a General Emergency. Ac-
ceptable changes were made to the P1 and it was subsequently implemented and
distributed.
The partial participation exerci e was conducted on November 16, 1988. The licen-
see's response was satisfactory The scenario specified a potential station black-
out, primary to secondary lea age, loss of main condenser vacuum and atmospheric
steam dump. Barrier breech nalysis as givan in NRC guidance was applied correctly
avoiding declaration pf a eneral Emergency, the correct source term was used to
calculate projected d6se and Technical Support Center engineers performance was
markedly improved ovpf that for the 1987 exercise.
/
During the routin safety inspection, thirty items encompassing facilities, equip-
ment, plans, pro edures, communication capabilities, ongoing and improvement acti-
vities were re ewed. The Emergency Plan and Implementing Procedures are being
followed and n effective emergency preparedness program and associated training
program are n place. The emergency preparedness-security interface is well main-
tained inc uding frequent interface meetings between the two programs. There are
no appart it off site problems. The TMI off-site Radiological Emergency Response
Plans h ve been incorporated into the single, all hazard State wide emergency plan.
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noteworthy in development and implementation of corrective actions required in
response to problems, establishment of licensee initiatives, department reorgani-
zation,; and in conducting a self-assessment. The newly' structured maintenance
organization was fully staffed and functional, but its effectiveness remained to
be realized in certain cases. The primary weaknesses observed were instances of.
poor specific' job planning, failure to follow administrative controls and in-
creased personnel errors.
Performance Rating: I
IV.C.2 Category'2. '
-IV.C.3 Recommendations: None.
. IV.D Emergency Preparedness
IV.D.1 Analysis
.
1
. During the previous assessment period, licensee performance in this area was rated i
category 1. This rating was based upon satisfactory response capability in the 1
full participation exercise and results of a routine safety inspection.
During the current assessment period, a partial participation exercise was observed.
A routine safety inspection was conducted within a week of the close of the SALP
period. This analysis is based on the results of these inspections. The licensee
issued a new Corporate Emergency Plan for both GPU Nuclear sites. Bocause of the. !
significance of the changes, the revised Plan was submitted for NRC review prior
to implementation. During the review it was identified that the Plan did not re-
flect the NRC guidance concerning protective actions f.or a General Emergency. Ac-
ceptable changes were made to the Plan and it was subsequently implemented and
distributed.
The partial participation exercise was conducted on November 16, 1988. The licen-
see's response was satisfactory. The scenario specified a potential station black-
out, primary to secondary leakage, loss of main condenser vac;um and atmospheric j
steam dump. Barrier breech analysis as given in NRC guidance was applied correctly '
avoiding declaration of a General Emergency, the correct source term was used to
calculate projected doses and Technical Support Center engineers performance was
markedly improved over that for the 1987 exercise.
During the routine safety inspection, thirty items encompassing facilities, equip-
ment, plans, procedures, communication capabilities, ongoing and improvement acti-
vities were reviewed. The Emergency Plan and Implementing Procedures are being
followed and an effective emergency preparedness program and associated training
program are in place. The emergency preparedness security interface is well main-
tained including frequent interface meetings between the two programs. There are ;
no appacent off site problems. The TMI off-site Radiological Emergency Response q
Plans have been incorporated into the single, all hazard State wide emergency plan. l
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1
In addition to maintaining emergency preparedness effectiveness, the licensee has
undertaken a number of improvement activities in response to NRC and GPU initi-
atives. In response to an NRC concern, the Technical Support Center (TSC) engi-
neering staff number has been increased and training is being upgraded. Five en-
gineers and a senior reactor operator have been added to the staff. In addition,
a TSC Engineer's. Handbook has been developed. TSC engineers have received problem
solving training using this handbook plus training in Abnormal Transient Operating
Guides. In order to significantly reduce the probability of a recurrence of the
May 1987 communication system failure (noted in the 1987 SALP report), GPU cnd the
Pennsylvania Emergency Management Agency (PEMA) have installed additional communi-
cation systems including an additional land line and radios for PEMA.
. Senior management attention to emergency preparedness activities is evident by the
interfaces with outside organizations and response to issues. 'The Director of
GPU's Division of Environmental and Radiological Controls devotes much of his time
to emergency preparedness activities and regularly updates the GPU Nuclear President-
-on emergency preparedness matters or responds to his requests in this area.
In summary, the licensee has committed sufficient resources to emergency prepared-
ness and has demonstrated response to GPU and NRC identified concerns. Technical
issues have been resolved. Upper management has become routinely involved in
emergency preparedness activities. There are no off-site problems. Exercise per-
formance was satisfactory.
'
IV.D.2 Performance Rating: Category 1.
1
IV.D.3 Recommendations: None.
IV.E Security
IV.E.1 Analysis
.
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During the previous assessment period, the licensee's performance was rated as a
Category 1, based on a very effective security program. No major regulatory issues
were identified by either region-based or resident inspectors.
During this assessment period, there were two routine unannounced security inspec-
tions performed by region-based inspectors. Routine inspections by the resident
inspectors continued through the period. There was one licensee-identified viola-
tion during this assessment period for which the licensee took timely and effective
action to correct the problem, identify the root cause and strengthen procedures
to prevent recurrence. The self-identification of that violation and the lack of
any NRC-identified violations during this and the previous assessment period are i
indicative of the licensee's commitment to implement an effective security program.
The licensee consolidated implementation of the Unit 1 and Unit 2 security program
during this assessment period. Due to some unique circumstances at TMI, implemen-
tation of certain aspects of the physical security program were different between
!
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Unit I and Unit 2. The NRC completed its review of the licensee's request to unify
the program, as well as the licensee's submittals in response to the Miscellaneous
Amendments and Search Requirements rulemaking and the staff's Regulatory Effective-
ness Review. This review was complex and required a number of meetings, site
visits and conference calls. The NRC received good cooperation from licensee per-
sonnel and was able to issue a favorable Safety Evaluation Report (SER) in Septem-
ber 1988. Within a month, all procedures that implement the revised Plan were also
revised by the licensee. These modifications were accomplished without any adverse
impact on the effectiveness of the program and is evidence of effective planning
and management, as well as a sound program.
Corporate security management continued to be actively involved in all site secur-
ity program matters. This involvement included site visits by the corporate staff
to provide assistance, program appraisals, and direct support in the budgeting and
planning processes affecting program modifications and upgrades. Site and corpor-
ate senior security management personnel also remained active in the Region I Nuc-
lear Security Association and other organizations engaged in nuclear plant security
matters. This demonstrates program support from upper level management.
The NRC-required annual audit of the security program, performed by the licensee's ,
quality assurance group, was comprehensive in scope and depth. Contributing to
'
the effectiveness of audits were a thorough understanding and appreciation for
nuclear plant security objectives by the audit team members. In addition to the
NRC-required audit, the licensee also continued to conduct self-assessments of the
program utilizing experienced security management personnel from corporate head-
quarters and the licensee's Oyster Creek plant.
Corrective actions on findings and recommendations identified during audits and
self-assessments were prompt and effective with adequate follow-up to ensure their
proper implementation. The NRC believes that the comprehensive quality assurance
audits and the self assessments are major contributing factors in the licensee's
excellent enforcement history and are indicative of the licensee's desire to im-
plement an effective security program. Further evidence of this is the licensee's
continued effective implementation of program enhancements that were initiated
during the previous assessment period.
The programmatic problem with source training documents, which was addressed in
the previous SALP period, was subsequently determined by the NRC to be inconse-
quential once the transition from hard copy documents to microfiche files was com-
pleted. During this assessment period, records retrieval was adequate.
The licensee submitted one security event report in accordance with 10 CFR 73.71
during this assessment period. That event involved the control of Safeguards In-
formation that was subsequently determined to be a licensee-identified violation.
The event was properly reported to the NRC and the documentation was sufficiently
comprehensive to permit NRC analysis without the need for additional information.
Recordable events were also found to be consistent with NRC guidance. Review of
the licensee's event reportiog procedures found them to be consistent with regula-
tory requirements and implemented by knowledgeable personnel. This is further
evidence of the implementation of an effective security program.
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Staffing of the security force is consistent with program needs, as evidenc by
the minimal use of overtimT(. Members of the security force exhibited a pr fes-
sional appearance, good mora'le and demeanor. The turnover rate remains v ry lo .
The training and requalification program is administered by two full- me instruc-
tors with assistance, as necessary, for specialized training. The e festiveness
of the training program is reflected by the small number of person el errors that
occurred during the assessment period.
The licensee continued to implement a well-disseminated, stro and effective fit-
ness-for-duty program during this assessment period. Only ope instance, following
an allegation, resulted in the identification of drug use bf contractor employees
(non-licensee personnel). The licensee took appropriate disciplinary action.
1
In summary, the licensee continues to maintain a ver ef fective and performance-
oriented security program. Management attention t and/uppnrtoftheprogramare
clearly evident in all aspects of program implemg tatij ln. The efforts expended
to maintain an effective program are commendabl( and emonstrate the licensee's
continued emphasis on a high quality securit ,4rogr m.
IV.E.2 P_erformance Rating: Category 1.j
IV.E.3 Recommendations: None.
IV.F Engineering / Technical Support
IV.F.1 Analysis
g
This area was rated Category 2 in t . previous SALP report. This area now includes
Fire Protection, which was previou y rated at Category 2. Inconsistent perform-
ance was noted in the areas of dr >ign and drawing control, fire protection, en-
vironmental qualification, and .afety review. It was noted in the previous SALP
report that in some cases sit operational feedback was not effective due to sched-
ule pressures. Discussion o licensee actions in response to these observations
is included in the assessmr t below.
Management Involveme d Initiatives
Management has est lished a formal system to assign work priorities in the Tech-
nical Functions vision. This system provides a proper safety perspective in
establishing pr crities. Also, licensee management has established a good program
to trend and alyze generic technical information and plant parameters.
The licens has initiated an extensive, formalized training progran to improve
i
'
safety re iews and control over plant modifications and procedure changes performed
under 1 CFR 50.59. This program has effectively improved plant modifications;
howeve , the area of procedure changes still requires improvement. Also, in one
case minor revision to the TMI-l 50.59 review procedure was made at the site
wit out the concurrence of the lead corporate safety review coordinator (SRC).
.
/
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Staffing of the security force is consistent with program needs, as evidenced by
the minimal use of overtime. - Members of the security force exhibited-a profes-
sional appearance, good morale and demeanor. The turnover rate remains very low.
The training'and requalification program is administered by two full-time instruc-
tors with assistance, .as necessary, for specialized training. The effectiveness
( of the training program is reflected by the small number of personnel errors that
occurred during the assessment period.
The-licensee continued to implement a well-disseminated, strong and effective fit--
ness-for-duty program during this assessment period. Only one instance, following
an allegation, resulted in the identification of drug use by contractor employees
(non-licensee personnel). The licensee took appropriate disciplinary action.
In summa 5 , i.ne licensee continues to maintain a very effective and performance-
oriented security program. Management attention to and support of the program are.
clearly evident in all aspects of program implementation. The efforts expended
to maintain an effective program are commendable and demonstrate the licensee's
continued emphasis on a high quality security program.
IV.E.2 performance Rating: Category 1.
IV.E.3 Recommendations: None.
IV.F Engineering / Technical Support
IV.F.1 Analysis
This area was rated Category 2 in the previous SALP report. This area now includes
Fire Protection, which was previously rated at Category 2. Inconsistent perform-
ance was noted in the areas of design and drawing control, fire protection, en-
vironmental qualification, and safety review. It was noted in the previous SALP
report that in some cases site operational feedback was not effective due to sched-
ule pressures. Discussion of licensee actions in response to these observations
is included in the assessment below.
Management Involvement and Initiatives
Management has established a formal system to assign work priorities in the Tech-
nical Functions Division. This system provides a proper safety perspective in
establishing priorities. Also, licensee management has established a good program
to trend and analyze generic technical information and plant parameters.
The licensee has initiated an extensive, formalized training program to improve
safety reviews and control over plant modifications and procedure changes performed
under 10 CFR 50.59. This program has effectively improved plant modifications;
however, the area of procedure changes still requires improvement.
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The licensee has documented the process for engineering configuration management
and has established programs for improving design basis documents, conducting
safety system functional inspections, and improving as-built drawings to reflect
plant conditions. These are good initiatives; their effectiveness has yet to be
assessed by the NRC.
The Computer Assisted Record and Information Retrieval System provides accurate
tracking and documentation of plant configuration; however, NRC inspectors found
that using the system to construct the current configuration of a system is very
time consuming.
The licensee is effectively using architect engineers (AE) to supplement the staff.
A prime AE has been selected for each of the plants and a wide spectrum of engi-
neering expertise is available on short notice to work with the licensee's staff.
The liconsee also took the initiative to make a number of significant capital im-
provements not required by NRC; namely, the reactor building closed circuit tele-
vision and the plant communications tie switch for simulator use during emergency
drills.
The licensee submitted a Level I PRA in December 1987 for the staff's information.
The PRA is a state-of-the-art document and includes external events and human per-
formance considerations. The staff is performing an abbreviated review of the PRA
to assess the level of confidence that might be placed on it should it be refer-
enced in the future licensing action decisions. The licensee has initiated an
internal program to assess, on a cost-benefit basis, possible design, procedure
and policy changes to address various risk contributors disclosed by the PRA. Some
modifications, including those to the instrument air system, have already been
initiated due, in part, to the PRA results.
Licensee upper management strongly supports participation in industry, owners
groups, and professional societies. This was evident by individual participation
and financial support to INPO and the number of people representing GPUN on the
owners and other industry groups.
Support of Operations
During this assessment period, the licensee was effective in resolving emerging
technical problems. Self-identification and resolution of the pressurizer vent
valve environmental qualifications issue were noteworthy. lhe review of the valve
function and the justification for continued operation with the valve not environ-
mentally qualified was thorough and complete. Also, the identification of the
Borated Water Storage Tank (BWST) vortexing issue was resolved in a timely and
adequate manner. Resolution of a potential problem with the net positive suction
head (NPSH) available to the high pressure injection (HPI) pumps in the recircula-
tion mode was also thorough. These actions reflected good corporate engineering
support. However, some other activities indicated that improvement can still be
made in engineering support. For example, the load calculation for assuring the
adequacy of the diesel generator was not well supported. Also, the emergency
feedwater (EFW) system upgrade was not sufficiently followed through in the non-
safety-related area.
1
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Engineering support for low power physics testing was well coordinated and resulted
in a trouble free start-up after the 7R refueling. The nuclear engineering staff
provided good support to the operations staff during_these activities.
The licensee's shift technical advisors report to the systems engineering depart-
ment of Technical Functions Division. This system appears effective in providing
an independent technical overview of the plant operations by the Technical Func-
tions Division staff knowing the plant status on a day-to-day basis and being ready.
to provide assistance at short notice. This was evidenced by the division staff's I
readiness to provide assistance for the problem of biofouling in the heat exchan-
gers at TMI before the operating staff made a request'for evaluation.
Previous fire protection issues were resolved during this period. The licensee's
l engineering analysis was thorough. It included in plant testing to validate the
air flow / temperature models and demonstrated a significant reduction in the core
melt frequency estimated in the TMI-1 PRA.
i
Outage Activities
Improvement in engineering support of outage activities was evidenced by successful
and early completion of cycle 7R outage. Outage activities were well' controlled
and few problems occurred in plant restart, demonstrating the quality of the work
performed. The licensee's new policy of completing the design, engineering, and
supporting technical evaluations for modifications and other associated work before
the start of the outage contributed to this success. This is in sharp contrast
to the licensee's previous practice of engineering, design and erection of modifi-
cations going concurrently throughout the outage. Also, changes in administrative
controls to improve the turnover of modifications from construction to operations
were made during the assessment period.
Technical support of. post modification activities needs greater attention as shown
by the following instances. Opportunities to verify functional acceptability of
the new post accident monitoring systems were missed. For example, functional
checks of the Rector Coolant Inventory Tracking System (RCITS) level indicators
during RCS fill were not routinely planned. Also, during power decreases and in-
creases following 7R, operation of the NI-11/12 full range nuclear instrumentation 1
was not functionally verified.
The quality of the information submitted in support of the 7R refueling and the
evaluations to support raising the licensed core power level were of high quality
and made requests for additional information by the staff unnecessary. The com-
pleteness of the submittals allowed issuance of the required amendments several
weeks early.
Response to NRC Initiatives
Examhles of response to NRC initiatives included the Integrated Control System /Non-
Nuclear Instrumentation (ICS/NNI) power supply modifications and ICS upgrades with
incorporation of the Smart Automatic Selector Switch (SASS) modifications for ICS
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control parameters. Significant progress was made in the closeout of NRC inspec-
' tion items during this assessment period. The licensee provided good support of
an NRC review of several Safety Issues Management System (SIMS) issues during this
SALP period.
l During this period, the staff completed its review of the Babcock &.Wilcox Dwners
Group (BWOG) generic design to fulfill the Anticipated Transient Without Scram
(ATWS) rule requirements in accordance with 10 CFR 50.62. Contrary to guidance
provided by the staff, the licensee proposed design failed to address a power sup-
ply separation issue and resubmittal will be required. The staff also has concerns
regarding the implementation schedule for these design changes.
During the SALP period, the licensee was responsive to the previous SALP Board
recommendation by briefing the NRC staff on the status of their technical support
self-assessment. They conducted these briefings on-two occasions during 1988; the
second briefing was more definitive in terms of specifying short-term corrective
actions to improve engineering support. Implementation of these corrective actions 4
was in progress at the end of the SALP period. From these briefings, it was un- I
clear which of these corrective actions would be preceduralized or become formal
matters of corporate policy. Effectiveness of these measures also remained to be
evaluated.
Staffing and Training
The licensee has maintained a stable work force in the engineering organization.
The majority of the engineers and other technical personnel have been with the
licensee for an extended period of time and are degreed professionals. The licen-
see has a comprehensive training program for entry level engineers and supports
continuing expansion of technical knowledge by thorough post graduate education
and attendance in technical meetings and seminars by the technical staff.
Licensee efforts to ensure that personnel are appropriately trained on new systems,
modified systems and other changes to plant systems are effective. NRC staff re-
view of operations training handouts revealed a comprehensive and effective means
for informing support personnel and management, as well as operators, of these
changes.
Summary
The licensee's performance in the area of engineering and technical support is
improving. This is particularly true in the support of outage activities; however,
in other areas such as support of operations and management controls, additional
time is required to confirm the effectiveness of licensee initiatives.
I V. F. 2 Performance Rating: Category 2, Improving.
IV.F.3 Recommendations: None.
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25
IV.G Safety Assessment / Quality Verification
IV.G.1 Analysis
In previous SALP reports, Assurance of Quality and Licensing Activities were
evaluated in separate sections of the report. This new section (Safety Assess-
ment / Quality Verification) has been created to consolidate those two sections and
to encompass activities such as safety reviews, responses to NRC generated initi-
atives and to provide a broad assessment of the licensee's ability to identify and
correct problems related to nuclear safety. In assessing this area, the SALP Board
considered attributes which are likely to be key contributors in assuring nuclear
safety and verification of quality in operation of the plant. Implementation of
management goals, planning of both' routine and infrequent activities, worker at-
titudes, management involvement and training effectiveness are examples of these
attributes.
In the previous SALP, Assurance of Quality and Licensing Activities both received
category 2 ratings. The SALP report identified as strengths a strong modification .
control program, training effectiveness, a vigorous QA program and substantial i
upper management involvement in site and licensing activities. Weaknesses included
procedure compliance, inconsistencies in the conduct of safety reviews of procedure
changes, engineering support and escalation of issues identified by the QA program.
Licensee performance in the areas of fire protection and equipment qualification
were also identified as areas requiring improvement.
During the assessment period the NRC observed activities directed towards correct-
ing previously noted problem areas and achieving agreement with the NRC to resolve
these areas. Engineering support issues have been discussed in Section IV.F of
this report. The quality of procedures and improvements in the safety review pro-
cess are discussed Lwlow. The licensee also maintained an effective level of ac-
tivity in the organizai.f onal components involved in identifying problems and veri-
fying quality including Quality Assurance oversight, Independent On-Site Safety
Review Group (IOSRG) reviews and the corporate Nuclear Safety and Compliance Com-
mittee (NSCC) audits. The licensee took substantial initiatives for self-assessing
performance in certain functional areas. Personnel were capable of performing
these self-reviews in an objective manner because of their qualifications or spe-
cial training. Results indicated that these reviews were objective. The most
noteworthy methodology was the Human Performance Evaluation System (HPES). Licen-
see management showed support for this area by committing resources to these ef-
forts including special training. The Safety Issues Assessment Program (SIAP) was
further evidence of management commitment to this effort and it represented an
attempt to organize and prioritize important safety and/or regulatory issues. This
prioritization was important in light of the numerous findings of the various re-
. view groups that were site or corporate based. The licensee also submitted a Level
I PRA for the staff's information during this period (See Section IV.F).
During the assessment period, 59 formal licensing actions were under review. These )
actions included license amendments, exemption requests, NUREG-0737 action plan 1
items, relief requests and inspection confirmatory issues. Action had been com-
pleted on 34 of these actions and 25 actions remained open as of the end of the {
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26
period. Many of these actions involved complex issues such as increasing the en-
richment of the uranium fuel, reactor refueling, increasing the authorized reactor
power level, accident monitoring instrumentation (Regulatory Guide 1.97), and fire
protection. Fifteen amendments were issued to the TMI-1 Facility Operating License
,
during this period. In addition, the NRC issued seven Generic Letters and six.
Bulletins that required licensee action and response during this period.
During this SALP period, the quality of formal submittals with regard to licensing
issues remained excellent and the licensee's cooperation in resolving these issues
was exemplary.
Quality Assurance Department (QAD) oversight activities continued to be a valuable
asset to the-licensee's organization. Audits continued to be highly technical,
detailed, thorough, and reflect innovative techniques. Inspections noted that the
' Quality Assurance Monitoring Reports (QAMR's) reflected an excellent process of
QAD documenting and verifying program implementation across all functional areas
of plant. activities. The QA inspectors provided detailed references, procedure
requirements, and verification results. This documentation was sufficient for a
knowledgeable reviewer to understand the basis on the QA inspectors' results.
Further,-QMAR's and Quality Deficiency Reports (QDR's) were sufficient vehicles
to trend procedure adherence performance for this facility.
The Operations Quality Assurance (0QA) Quarterly Trend Review identified deficien-
cies through the use of Quality Assurance Shift Monitors, who look at back shift
activities on a six-week cycle. In addition, the trend review appeared to be ef-
fective in that QAD conducted an overview and comparison of individual QA findings.
They issued additional quality assurance action items for repetitive concerns iden-
ti fi ed. For example, the October 11, 1988, 00A Quarterly Trend Review documented
eight areas where repeated QA findings indicated possible performance trends. This
overview function was effective in that a preventive philosophy was implemented.
The NRC reviewed several of the licensee's 10 CFR 50.59 evaluations for plant modi-
fications as well as changes to procedures and a special test for addition of mor-
pholine to the feedwater system. The evaluations for hardwarc changes were well-
done and typically supported by detailed technical reports or Safety Evaluations.
The 50.59 review for the morpholine test included r consultant report providing
extensive test results for morpholine exposure to various materials and data based
on previous use of morpholine in other plants. In general, licensee personnel do
a thorough job of evaluating changes or tests as provided by 10 CFR 50.59.
. _ On the.other hand, 50.59 reviews for administrative and operating procedure changes
were sometimes found to be lacking in thoroughness, depth and documentation. The
GPUN procedure for these reviews provides for an initial screening to determine
if a more detailed evaluation using the 50.59 criteria is required. In several
I cases involving procedure changes, the documentation did not clearly document the
basis for the reviewers conclusions. The staff believes additional improvements
are warranted in the reviews associated with procedure revisions.
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27
The staff notes that the licensee made progress in improving the corporate 5 fety
reviewprocessduringthis~feriod. However, the manner in which the licen ee is
implementing this procedure at the TMI site has one remaining open issue o be
resolved with the staff. Implementation of the revised corporate procej ures atk
TMI-I did not occur until after the end of the period; therefore, an assessment
of resultant improvements at the site could not be made. Also, TMI ivision Draft
Procedure was not in accordance with the corporate policy for the fety Review
Process. The licensee is also participating in a cooperative eff rt between the
NRC and the Nuclear Utility Management and Resources Council (N . ARC) to develop
uniform industry guidance relating to the safety review proces . In summary, the i
licensee has improved the quality of safety reviews in most ses and is continuing
to pursue improvements in this area.
Although the attitude of management at all levels has remained positive and visible,
a number of events occurred during this period (see gection IV. A of this report)
that demonstrate implementation problems at the wayking level. Common causes that
emerge are procedural inadequacies and lack of a'wa'rene)/s and attention to detail.
For example, the decay heat removal flow path was inadvertently interrupted
causing core heatup due to an instrument techrytcian performing one step of a
surveillance procedure out of order. The license s human performance evaluation
report on the event concluded that the techni became distracted by an
, ambiguity in the procedure, stopped to conf th other technicians, then
resumed following the procedure but at th ng step. Other procedural step
inadequacies continued to exist. A numb significant problems resulted
because of weak or inadequate procedur described in the other functional
areas. The biennial review process w t completely effective in producing a
steady improvement in procedures ov g , because of high frequency requirements
and strained resources. However, actions noted continued improvement to
the Emergency Operating Procedures JP's). Licensee management, up to and
including the Chairman of the Boar , is also aware of these problems via their
own self-assessment committees in uding the NSCC.
The staff has also noted a few cases where initial assessments of plant event
safety significance and repor ability of plant events by the licensee have been
incorrect and not initially entered in the operator's logs. For example, problems
that occurred on Jung 19, 988 during Low Pressure Injection surveillance testing
were not entered in thq perators logs until they were later determined to be re-
portable. It was de)(erinined, af ter studying the data, that two TS limits had been
violated. In the pfevious SALP report, we stated that the licensee should initiate
a program to evalpate less significant problems (i.e., those below the threshold
of requiring a JAant Incident Report (PIR) or Licensee Event Report (LER)). The
licensee has s nce initiated a progrmn to highlight and review such events. The
staff will c tinue to monitor the quality of critiques, post-trip evaluations, 4
j
event inves igation and resultant corrective actions. Overall, the staff considers j
that prograss is being made in this area but at a slow pace. '
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1
l
l
l The staff notes that the licensee made progress in improving the corporate safety
review process during this period. Implementation of the revised corporate
procedures at TMI-1 did not occur until after the end of the period; therefore,
an assessment of resultant improvements at the site could not be made. The
i licensee is also participating in a cooperative effort between the NRC and the
l Nuclear Utility Management and Resources Council (NUMARC) to develop uniform
industry guidance relating to the safety review process. In summary, the lic-
ensee has improved the quality of safety reviews in most cases and is continu-
ing to pursue improvements in this area.
Although the attitude of management at all levels has remained positive and visible,
a number of events occurred during this period (see Section IV.A of this report)
that demonstrate implementation problems at the working level. Common causes that
emerge are procedural inadequacies and lack of awareness and attention to detail.
For example, the decay heat removal flow path was inadvertently interrupted
causing core heatup due to an instrument technician performing one step of a
surveillance procedure out of order. The licensee's human performance evaluation
report cn the event concluded that the technician became distracted by an
ambiguity in the procedure, stopped to confer with other technicians, then
resumed following the procedure but at the wrong step. Other procedural step
inadequacies continued to exist. A number of significant problems resulted
because of weak or inadequate procedure as described in the other functional
areas. The biennial review process was not completely effective in producing a
steady improvement in procedures overall, because of high frequency requirements
and strained resources. However, inspections noted continued improvement to
the Emergency Operating Procedures (EOP's). Licensee management, up to and
including the Chairman of the Board, is also aware of these problems via their
own self-assessment committees including the NSCC.
The staff has also noted a few cases where licensee initial assessments of the
safety significance of plant events have been incomplete. For example, prob-
lems that occurred on June 19, 1988 during Low Pressure Injection surveillance
testing were not entered in the operators logs until they were later determined
to be reportable. It was determined, after studying the data, that two TS
limits had been violated. In the previous SALP report, we stated that the lic-
ensee should initiate a program to evaluate less significant problems (i.e.,
those below the threshold of requiring a Plant Incident Report (PIR) or Licen-
see Event Report (LER)). The licensee has since initiated a program to high-
light and review such events. The staff will continue to monitor the quality
of critiques, post-trip evaluations, event investigation and resultant correc-
tive actions. Overall, the staff considers that progress is being made in this
area but at a slow pace.
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The quality of the licensee's LER's continued to be high during this period ue
to their detailed, well-wrfTten event descriptions and root cause analyses As
noted elsewhere in this report., the nuraber of events requiring LER's drop ed frem
ten last period to six this pe'riod and there was only one unplanned rea or tri$
during this 1415 month period.
In summary, the licensee made progress in enhancing this area but p oblems per-
sisted. They took substantial initiatives in self-assessing thei performance and
this included conducting proper training and using skilled perso nel on the as-
sessment. The one noted exception was in the maintenance area n light of material
condition findings during this SALP period. Established pro am/ review groups
continued to do an outstanding job of identifying problems,/nost notably the Qual-
ity Assurance Department efforts. Despite all of these efforts, certain long-
standing problem areas continued to be noted in the apeas of safety review, pro-
cedure adequacy, procedure implementation (primarily in the administrative controls
area), and event handling / reporting. Solutions /cor ecti/e actions to these iden-
tified problems were slow in implementation.
/
IV.G.2 Performance Rating: Category 2.
/
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IV.G.3 Recommendations: None.
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The quality of the licensee's LER's continued to be high during this period due
to-their detailed, well written' event descriptions and root cause analyses. As
noted elsewhere in this report, the number of events requiring LER's dropped from
ten.last period to six this period and there was only one unplanned reactor trip
during this 14 month period.
In summary,- the'11censee has effective programs in place of assessing nuclear
safety and verifying quality. A number of initiatives have been taken to en- -
hance performance in this area and the personnel involved are skilled and well-
trained. Established review groups, mostly notably the Quality Assurance De-
partment, have continued to do an adequate job of identifying problems. How-
ever,' implementation of corrective action in some cases has failed to correct
the problems. One'such example noted in this report is the thoroughness of
safety reviews associated with procedure revisions, which' ultimately has had a
detrimental effect on procedure quality. The quality of some procedures
coupled with worker inattentiveness to details have led to a small number of
-operational errors during this assessment period.
IV.G.2 Performance Rating: Category 2. '
IV.G.3 Recommendations: None.
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SUPPORTING DATA AND SUMMARIES
'A. Inspection History Summary
Table 1 reflected the expenditure of staff hours in the various functional areas
~
for all inspections that occurred during the SALP period. Inspection report num-
bers that covered this period 87-21 through 87-26 and 88-01 through 88-32.
.In addition to the resident (normal monthly) inspections, the following team in-
spections occurred:
--
Outage Team Inspection (88-17); and,
--
Emergency Preparedness Exercise (88-27).
Major region-based reviews in the following programmatic areas occurred:
--
Solid Radioactive Waste Handling and Shipping (88-21 and 30);
!
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Testing and, Measuring Equipment (88-22);
--
Document (focus on drawing) Control (88-26);
--
Security Program and Implementation (88-02 and 30);
--
Inservice Test on Pumps and Valves (88-06);
--
Effluents Control Program (88-09, 10, and 30);
--
Radiological Control Program (88-12 and 19);
-- Radiological Environmental Monitoring (88-14);
--
Special Start-Up, Preoperational, Operations Testing (88-20, 21, and 22); and,
--
Corporate / Engineering. Support (88-25).
Operator licensing examinations were documented in NRC Examination (Inspection)
Report Nos. 87-25 and 88-15.
In addition to the SALP management meeting for the last SALP period, management
meetings were documented as follows:
--
Technical and Safety Review Program-on April 26, 1988 (88-08);
--
Technical Support Self-Assessment on May 23 and September 21, 1988 (88-05 and
24); and, ;
--
Refueling Outage Preparation on April 27, 1988 (88-08). ,
SD/S-1
_ - _ _-_ . - - - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . _ _ - _ . -. .-
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T.
B. EnforcementfSummary
l
l Table 2 reflected a summary of the enforcement action taken by the NRC staff for
l
'
TMI-1.. The description of the violations are also provided.
1
l
Additionally, two violations issued to Unit 2 in the radwaste area are discussed
in the analysis section of the Radiological Controls area.
On August 24, 1988, the NRC staff conducted one enforcement conference (No. 50-
289/86-06) during this period, dealing with apparent violations in the area of i
environmental qualification of safety-related equipment for items found outside
this.SALP period. As a result of this review, the. NRC staff issued a Notice of
Violation, dated December 29, 1988, with multiple examples of failure to comply
with 10 CFR 50.49. At the end of the SALP period, the licensee was preparing a
response.
I
C. Licensee Event Reports / Analysis
Table 3 reflected a summary of Licensee Event Reports (LER's) submitted during the
SALP period.
LER's adequately described events, including contributing component or system
failures and significant corrective actions. The reports were thorough, detailed,
i
well-written, and easy to understand. Narrative sections typically included de-
I
tails such as valve identification numbers, model numbers, operable redundant sys-
tems, dates of completion of repairs, etc. Root causes vere identified.
Many LER's presented information in an organized pattern with separate headings
and specific information that led to a clear understanding of the event. Previous
similar occurrences were properly referenced.
With so few LER's generated, a common casual link could not be established. These
LER's are indicative of performance problems identified in each of the functional
areas.
D. Allegations i
t
During this period, two allegations received in previous SALP periods were resolved
by the NRC staff: (1) labor relations and technical concerns by a health physics 1
technician (NRC Inspection Report No. 50-289/88-19); and, (2) concerns on health
physics technician qualification at TMI (NRC Inspection Report No. 50-289/87-24). {
A new allegation received during this period was from a private citizen on drug
abuse at TMI. The individual also implicated certain licensee employees to licen-
see representatives. The licensee completed their review of the matter with re-
sults not substantiating the allegation against the named individuals. However,
the licensee's review identified other personnel having drug test results with
indication of drug abuse. The licensee took disciplinary action.
SD/S-2
)
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TABLE 1
INSPECTION HOURS SUMMARY
TMI-1
l Area Actual Hours Annualized Hours % Time
Plant Operations 1918 1587 41%
Radiological Controls 418 345 9%'
Maintenance / Surveillance 1152 953 24%
i
Emergency Preparedness 74 61 1%
Security / Safeguards 113 93 2%
Engineering / Technical Support 1018 842 23%
Safety Assessment / Quality Verification -- --
_--
TOTAL 4693 4107 100%
T-1-1
_ _ _ - - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ - _ _ _ \
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. TABLE 2
1 TMI-1 ENFORCEMENT / SEVERITY LEVELS
l
,
A. TMI-1 Enforcement /Soverity Levels
l _.
-
AREA DEV 5 4 3 2 1 TOTAL
L _ Plant Operations 1 1
Radiological Controls 0
Maintenance / Surveillance 1 4 5
> Security / Safeguards 0
Engineering / Technical Support 1 1
l. Safety Assessment / Quality Verification 0
__ ___ __ __ __
,
TOTALS 0 1 6 0 0 'O 7
B. Violation Summary
REPORT /' SEVERITY FUNCTIONAL
DATE REQUIREMENT LEVEL AREA DESCRIPTION
88-01- 10 CFR 50, App. IV Maintenance / Failure to follow Quality
1/10- 'B, Crit. VI and Surveillance Assurance Plan (QAP) (ANSI)
2/6/88 ANSI 18-7-1976, [administrativecontrols]
Para 5.3 on completion of various
maintenance activit'ies:
(1) wrong expansion Joint
installed (RR); (2) incor-
rect information in job
tickets (JT's); and (3) JT's
not at work site.
88-13 10 CFR 50, App. IV Maintenance / Control room ventilation
6/12- B, Crit. VI, Surveillance fan blade modification con-
7/15/88 ANSI 18.7-1976, ducted without controlled
Para 5.2.15 and vendor manual (improper
AP 1065 torquing of blades and fan
hub incorrectly described
in work package.
T-2-1
_ _ - _ - _ _ - _ _ - _ _ _ _ _ _ _ _ _ - - . _ - _ _ _
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REPORT / .
SEVERITY FUNCTIONAL
DATE-- REQUIREMENT LEVEL AREA DESCRIPTION
88-17 TS 6.8.2 and IV Maintenance / Failure to, properly change
8/8-19/88 6.8.3.c Surve111ance' Maintenance Procedure (MP). ,
. (RCP seal work) (conflicting -
procedure and administrative f
controls.for MP's permit
unauthorized temporary
changes (TC's)~ .
88-17 TS'6.8.1 IV Maintenance / Failure to adequately estab-
8/8-19/88 Surveillance lish procedures. (1) Emer-
<
gency diesel generator (EDG)
jacket coolant valves not
in operating procedure (0P)
lineup. (2) MP on make-up
pump (generic procedure. '
vendor technical instruc-
tions not. incorporated into
MP.
)
88-18 TS 6.8.2/ V Maintenance / Failure to follow mainten-
~ 7/16- MP 1407-1, Surveillance ance procedures by not get-
9/1/88 Pa ra. 6.2.1.2 ting-the same level of re-
view'and approval on engi-
neering instruction to
torque pressurizer tailpipe 1
bolt as the original job
ticket.
88-18 TS 3.1.12.3/ IV Operations' Failure to adhere to tech-
7/16- 3.1.2.3 nical specifications pres-
9/1/88' surizer cooldown and (ma-
terial ductility) level
limits (same as LER 88-02). )
L
'~
87-01 & 10 CFR 50.49(f) IV Technical- Failure of safety-related )
86-07 and (j) Support equipment to meet environ- .l
12/29/88 mental qualification stand- )
, ards. i
4
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TABLE 3
LICENSEE EVENT REPORTS
, FUNCTIONAL AREA /CAUSE CODE
TMI-1
A. LER Functional Area by Cause Code
AREA A B C D E X TOTAL
Plant Operations 2 1 3
Radiological Controls
Maintenance / Surveillance 2 2
Security / Safeguards 1 1
Engineering / Technical Support 1 1
Safety Assessment / Quality Verification __ __ __ __ __ __
TOTALS 3 0 0 2 2 0 7
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.
T-3-1
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B. LER Summary.
<
LER . EVENT CAUSE FUNCTIONAL
NUMBER DATE CODE AREA DESCRIPTION.
- 88-01 3/16/88 E Maintenance / Failure of control rod drive breaker l
Surveillance to trip.on undervoltage during sur-
veillance test due to componer.t mal-
function.
88-02 6/19/88 D Plant Pressurizer cooldown and ductility
Operations (NDT) exceeded due to inadequate low-
pressure injection surveillance pro-
cedure,
w
88-03 7/28/88- A Plant Both channels of screenhouse chlorine
Operations detectors taken out of service simul-
taneously due to operator error.
'
88-04 -3/13/88 D Technical Reactor Protection System (RPS) actu-
Support ation due to faulty preoperational
test procedure.
88-05 9/25/88 A Plant Reactor Coolant System (RCS) heat-up
Operations greater than 50 F per hour due to
personnel error.
88-06 10/30/88 E Maintenance / Reactor trip due to high RCS pressure
Surveillance because control valves went shut on
mail turbine electro-hydraulic control
(EHC) system malfunction.
88-SP-01 7/21/88 A Security / Uncontrolled safeguards information.
Safeguards
- Voluntary Report
i
T-3-2
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ENCLOSURE 2
'
GPU Nuclear Corporation
N Sr One Upper Pond Road
Parsippany, New Jersey 07054
201 316-7000
]
TELEX 136-482 ,
Wnter's Direct Dial Number: '
May 10, 1989 l
C311-89-2048 i
l
!
U.S. Nuclear Regulatory Commission
Attn Document Control Desk i
Washington, DC 20555
Dear Sir:
Three Mile Island Nuclear Station, Unit 1 (TMI-1)
Operating License No. DPR-50
Docket No. 50-289
Response to SALP 87-99
On April 3, 1989, the NRC issued the Systematic Assessment of Licensee
Performance (SALP) Report for Three Mile Island Unit 1. A meeting to discuss
this report was held at the Three Mile Island Training Center on April 10,
1989. Attachment I to this letter provides the GPUN written comments on the
SALP report.
We appreciate the opportunity to review with you the SALP Report and provide
our comments. We continue to believe that this dialogue is the most meaningful
portion of the SALP process. !
It is our understanding that the NRC plans to conduct mid cycle SALP reviews to
assess progress and evaluate effects of licensee performance. We would
encourage this mid cycle review for TMI-l and are willing to participate.
Sincerely,
- , /
P. R. Clark
President
PRC/DVH/spb 2048
cc: W. Russell ,
R. Hernan l
F. Young j
y%ENO'90 f
GPU Nuclear Corporat>on is a ubssd.ary of General Pubhc Utilit.es Corporation
._____ ._ ________
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'
- 'g' ATTACHMENT I
RESPONSE TO SALP REPORT 87-99
Overview
1
i
Several sections of the SALP Report referred to issues on procedures. GPUN has !
established an Administrative Procedure Task Force which has corporate wide
responsibility. This task force has developed a list of recommendations which -j
are currer.tly being implemented. The task force will continue to monitor the
implementation of these recommendations. {
]
On the Plant level, a new Procedure Specialist has been added to the staff to
help improve the procedure preparation, change and review process. This ;
individual also will assist in the training of the procedure preparers and
reviewers. This effort has been largely associated with maintenance
procedures. In this area, we have increased monitoring of in field procedure
compliance and quality by the QA Department, the Plant Nateriel Department and
the management offshift tour program. The final approval authority of plant
prLeedures has been changed to the Department Heads in place of the O&M
Director. We continue to believe the biennial review frequency is appropriate
and that we have adequate resources to produce improvements on that schedule.
Overall our emphasis on procedure Improvement is focused on technical,
useability and human performance issues. This will strengthen the worker's
ability to use the procedure on the job.
Plant Coerations
We are pleased the NRC acknowledged our improvement in this area. We believe
the good, safe operation during this SALP period is indicative of our
conservative approach to safe operations, operator professionalism and
knowledgeable personnel. In addition, there is an active program in place to
improve crew communications.
Radiological Controls
We ere in agreement with the analysis as presented. We have emphasized the ,
importance of current surveys being posted. Also, significant scaffold
erection in radiological areas is now an integral part of our outage planning
and scheduling where appropriate.
In addition to the reasons stated in the SALP Report which contributed to
higher than estimated outage personnel dose, other factors included higher
working area dose rates, implementation of a more rigorous program for discrete
radioactive particle control and a greater percentage of respirator wcrk. ;
-1-
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Maintenance / Surveillance i
1. HE E i*1 oroanisation
During.this SALP period the st&ffing of the Material Department was
comp 3eted. In the planning and scheduling areas of this function we have
added additional planners, placed more emphasis on the planning process
and formed the outage'und non-outage scheduling groups. These steps,
along with the beplementation of the computerized GMS-2 work management
system cnd integrated scheduling will enable us to better plan, schedule,
and document maintenance work.
,2. Plant Materiel condition
As acknowledged in the SALP ' Report, the p' lant and its equipment are in
good materiel and operating condition. This contributed significantly to
the excellent operating record. Increased emphasis has been placed on the
identification and correction of minor materiel deficiencies.
3. Water Chemistry Control Procram
GPUN has a strong water chemistry control program as discussed at the
April 28,~1989 meeting with the NRC. We do not believe the SALP Report
accurately characterizes this program and request that yoc re-review this
section of the SALP. We constantly strive for improvement and therefore
look forward to a clear assesscent with its associated basis from which we
can continue to progress.
Emercenev Preparedness and Security
We believe these are importent areas and will continue our emphasis and
management involvement.
Knoineerino/ Technical Sucoort
We are continuing our efforts to improve in this area. The recently completed
Technical Support self Assessment has provided and will continue to provide a
mechanism for improvements.
With regard to satisfying the ATWS rule requirements, we feel we are
essentially agreement in every area. The implementation schedule of 9R is
responsive and appropriate. This schedule has been extensively communicated to
and approved by the NRC.
Safety Assessment /Ouality Verification
In our safety review process all divisions are now following the corporate
procedure requirements. We believe the GPUN safety review process is a good,
sound program and will improve the quality of our safety reviews. We will
continue to monitor the performance in this area.
I
-2- ;
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4
ENCLOSURE 3
LIST OF ATTENDEES'
w
-
TMI-1 SALP MANAGEMENT MEETING
. . APRIL 10,_ 1989
GPU Nuclear Corporation ,
e
'=
H. D. Hukill, ' Director, TMI-1
, .P. R. Clark, President- . .
lT. G. Broughton, Director, Operations and Maintenance
.
M. J. Ross, Plant Operationt Director
R. L. Long, Vice President, Planning and Nuclear Saf'ty. e
D. h. Shov11n, Plant' Materiel' Director
P. B. Fiedler, -Vice President,: Quality and Training
W. Popew, MCF Production and Technical Director
-
J. E. Hildebrand, Director, Radiological and Environmental Controls
R. Fi Wilson,, Vice President; Technical Functions
R. P. Coe, Training and Education Director
J. L.- Sullivan,'Jr , Licensing' and Regulatory Affairs Director
. -
L R. J. McGoey, Manager, PWR Licensing
, ' D. V. Hassler, TMI-I Licensing Engineer
.
L
J 'F..Stacey,' Site Security Manager
T M. Hawkins, Manager, TMI-1 Startup and Test
R. P. Shaw, Radiation Controls Director, TMI-1
M. C. Wells, Media Relations Manager
.
0. J.'Shalikashv11, Manager, Plant Training
i D.'H. Bedell, Manager, Public Information, TMI
, U.S. Nuclear Regulatory Commission
W. F.LKane, Director,. Division of Reactor Projects (DRP).
J. P. Durr, Acting Chief, Projects Branch No. 1, DRP
C. J. Cowgill,-Chief, Reactor Projects Section IA, DRP
F. I. Young, Senior Resident Inspector, TMI
.D. M. Johnson, Resident Inspector, TMI-1
'
. - - ---.-------------_-._----------------s-------w---------
c. .
,-
y + ' ]/ "% 4 ENCLOSURE 4
, - [. . .g UNITED STATES ;
j , f,;fj?#,j NUCLEAR REGULATORY COMMISSION
%- '; . '
. e REGION I
k '%' ,e
-
476 ALLENDALE ROAD
'd *00Ek'et No. 50-289 KING OF PRUSSIA. PENNSYLVANIA 19406
i
GPU Nuclear Corporation 0 8 W- 1
ATTN: Mr. H. D. Hukill
Vice President and Director, TMI-I
P.. D. Box 480
Middletown, Pennsylvania 17057
Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
50-289/87-99
On March 2, 1989, the NRC Region I SALP Board assessed the performance of Three
Mile Island Unit I for the 14 -month period from November 1,1987 to January 15,
1989. That assessment.is documented in the enclosed report. We have arranged to
meet with your staff onsite on April 10, 1989 to discuss the SALP.
At the meeting, please be prepared to discuss the assessment and any plans you have
to-improve performance. You may, of course, provide any comments you have regard-
ing the SALP at the meeting. Also, you may provide written comments within thirty'
days.after the meeting.
t
Thank you for your cooperation.
Sincerely,
M hs . %
111am T. Russell
Regional Administrator
Enclosure: NRC Region I SALP Report No. 289/87-99
.
g ? t$13 0 J-5& If
_ _ _ _ _ _ _ _ _ _ _
,- . _ _ _. ,
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GPU Nuclear Corporation 2 !
APR 0 319
cc w/ encl: ,
T. G. Broughton, Operations and Maintenance Director, TMI-1 '
C. W. Smyth, TMI-1 Licensing Manager <
R. J. McGoey, Manager, PWR Licensing j
E. L. Blake, Jr. , Esquire ;
Chairman Zech l
Commissioner Roberts i
' Commissioner Carr !
Commissioner Rogers
!
Commissioner Curtiss
K. Abraham, PAO, RI (14 copies)
TMI Alert l
j
Susquehanna Valley Alliance "
Public Document Room (PDR) i
Local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector
Commonwealth of Pennsylvania
l
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ENCLOSURE 5 l
SALP BOARD REPORT ERRATA SHEET
PAGE LINE NOW READS SHOULD READ
3 12-14 The principal weaknesses observed The principal weaknesses ob-
were in specific job planning, served were in specific job
increased personnel errors, and planning and increased per-
non-radiological chemistry sonnel errors.
operations.
1
Basis: Additional information provided by the licensee via meetings and sub- l
sequent inspections clarified the NRC assessment, and form a basis I
to conclude that non radiological chemistry operations and management ;
oversight of this area was adequate.
PAGE LINE NOW READS SHOULD READ
17 27-37 Relative to the last SALP assess- Relative to the last SALP
ment, the non-radiological assessment, the non-radiological
chemistry control program has de- chemisty control program re-
clined. During an inspection of mained constant. During an
the licensee's non-radiological inspection of the licensee's
chemistry control program, non-radiological chemistry
standard solutions prepared by control program, standard solu-
Brookhaven National Laboratory tions prepared by Brookhaven
for the NRC were submitted to the National Laboratory for the NRC
licensee to analyze using the were submitted to the licensee
licensee's normal methods and for analysis using the licen-
equipment. Evaluation of th; see's routine methods and
results indicated about 31 per- equipment. Licensee perform-
cent (11 measurements of 36) of on the standards was acceptable.
the results were in disagreement Some minor problems were iden-
with the criteria used for com- tified in the areas of instru-
parison. These disagreements ment calibration. The recent
were attributable to equipment inspection determined that this
calibration technique, sampling problem has been resolved.
error, determination of the mini-
mum detectable concentrations,
and training. The licensee's
inter-comparison program was
ineffective in identifying these
concerns, The laboratory opera-
tion lacked substantial manage-
ment attention.
Basis: Additional information provided by the licensee via meetings and sub-
sequent inspections clarified the NRC assessment, and form a basis
to conclude that non-radiological chemistry operations and management
oversight of this area was adequate.
_- _ _ _
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e
ei ~
o, O
Enclosure 5 2 l
PAGE LINE NOW READS SHOULD READ
18 6-8 ... controls, increased personnel ... controls and increased
errors, and deficiencies in non- personnel errors.
radiological chemistry laboratory >
operations.
Basis: Additional information provided by the licensee via meetings and sub-
sequent inspections clarified the NRC assessment, and form a basis
to conclude that non-radiological chemistry operations and management
oversight of this area was adequate. '
PAGE LINE NOW READS SHOULD READ
21 36-38 Also, in one case a ..... safety Delete ,
review coordinator (SRC). !
Basis: This issue was not a substantial problem and deletion does not affect
the staff's conclusion.
PAGE LINE NOW READS SHOULD READ
27 2-4 However, the manner...with the Delete
staff.
6-8 Also, TMI Division...the Safety Delete
Review Process
Basis: These minor items were resolved shortly after the completion of the
SALP period and deletion does not alter the NRC conclusions in this
area.
PAGE LINE NOW READS SHOULD READ
27 31-33 The staff has also noted a few The staff has also noted a few
cases where initial assessment of cases where licensee initial
plant noted safety significance assessment of the safety sig-
and deportability of plant events nificance of plant events have
by the licensee have been incor- Leen incomplete.
l rect and not initially entered
in the operators log.
Basis: To clarify the sentence and to note that no incorrect entries were made.
The entries made were incomplete in some cases.
l
.___-__-__ - __ - _ _ _ a
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.4
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E Enclosure 5 3
pAGE LINE~ 'NOW READS SHOULD READ
28 6-16 In summary, the licensee made pro- In summary, the licensee has
gress.in enhancing this area but effective programs in place ,
problems persisted. They took for assessing nuclear safety '
substantial initiatives in self-
.
and verifying quality. ;A
assessing thei.r performance and number of initiatives have-
this included conducting proper
.
been taken.to enhance perform- i
training ~and.using skilled person- ance in this area. and the per-
nel on.the assessment. The one sonnel involved are skilled
noted exception was in the main- and well-trained. . Established'
-tenance area in light of material review groups, mostly notably
condition findings during this the Quality Assurance Depart- )
SALP' period. Established program / ment, have continued to do an 4
review groups continued to do an adequate job of identifying
outstanding job of identifying problems. However, implemen-
problems, most notably the Qual- tation of corrective action
ity Assurance Department efforts. in some cases has failed to
Despite all of these efforts, correct the problems. One
certain longstanding problem such example noted in this
areas continue to be noted in report is the thoroughness of-
the areas of safety review, pro- safety. reviews associated with
cedure adequacy, procedure imple- procedure revisions, which
mentation (primarily in the ad- ultimately had a detrimental
ministrative controls areas), and effect on procedure quality.
event handling / reporting. Solu- The quality.of some procedures
tions/ corrective actions to these coupled with worker inattentive-
identifying problems were slow in ness to details have led to a
implementation. small number of operational
errors during this assessment
period.
Basis: This paragraph was revised to more accurately summarize the licensee
safety assessment / quality verification activities.
_ _ _ _ - - - - _ .