ML20078C642

Nuclear Safety & Compliance Committee Semiannual Rept 21 940401-0930

ML20078C642
Person / Time
Site:	Three Mile Island
Issue date:	09/30/1994
From:	Humphreys L, Trost C, Wilson W GENERAL PUBLIC UTILITIES CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
C311-94-2155, NUDOCS 9411010161
Download: ML20078C642 (15)

Text

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r GPU Nuclear Corporation j hw g gg{ one upper Pond Road Parsippany. New Jersey 07054 j

j 201-316-7000 i TELEX 136-482 i Writers :"ect Dial Number )

l October 25,1994 C311-94-2155 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Gentlemen:

Subject:

Three Mile Island Nuclear Generating Station Operating License No. DPR-50 Docket No. 50-289 Nuclear Safety and Compliance Committee Semiannual Report No. 21 On October 19,1994, I provided the Semiannual Report of the Nuclear Safety and Compliance Committee (NSCC) to the GPU Nuclear Corporation Board of Directors.

Mr. James R. Leva, Chairman of the Board, GPU Nuclear Corporation, has requested that I provide the NSCC's Semiannual Report No. 21 for the period April 1, 1994 through September 30,1994 a copy of which is enclosed.

I would be pleased to provide additional information or respond to any questions you have.

Sincerely, 8

P. R. Clark President Enclosure ,."i;nR~

/crb c: Administrator, Region i NRC Resident inspector 941101o161 94o93o TMl NRC Project Manager PDR ADoCK 0500o289 ' 00 R PDR GPu Nuclear Corporahon is a subsidiary of General Pubhc utaties Corporabon

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4 NUCLEAR SAFETY AND COMPLIANCE COMMITTEE SEMIANNUAL REPORT NUMBER 21 APRIL 1, 1994 THROUGH SEPTEMBER 30, 1994 OCTOBER 15, 1994 GAu!:twf ADM C. A. H. TROST 1

ALs+* m ee LAWRENCE L. HUMPHREYS V t' ,' f ,

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/f)sjI -

' v ll ./&' l WILLIAM A. WILSON 1

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l CONTENTS 1.O

SUMMARY

2.0 EVALUATION OF SAFETY AND COMPLIANCE 2.1 FACILITY OPERATION 2.2 MAINTENANCE / MATERIEL CONDITION 2.3 TECHNICAL SUPPORT '

2.4 TRAINING-2.5 RADIOLOGICAL CONTROLS AND ENVIRONMENTAL CONTROLS 2.6 EMERGENCY PREPAREDNESS 2.7 MANAGEMENT / SAFETY ATTITUDE 3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL 3.2 COMMITTEE ACTIVITIES 3.3 STAFF ACTIVITIES EXHIBIT 1

• STAFF ACTIVITIES /INFORMATION SOURCES EXHIBIT 2 PERSONS INTERVIEWED / CONTACTED DURING REPORT PERIOD ,

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1.0

SUMMARY

Safety and compliance at the Oyster Creek, Three Mile Island (TMI-1 and TMI-2), and Saxton facilities of the GPU Nuclear Corporation (GPUN) were the object of independent evaluations by ,

the Nuclear Safety and Compliance Committee (NSCC) of the GPUN Board of Directors and the NSCC Staff during_the period April 1, 1994 through September 30, 1994. These evaluations focused on operator performance, procedure utilization, and maintenance activities as they relate to compliance and safety.

The Committee believes that during this period all facilities were operated safely and, with the exceptions noted herein, in compliance with relevant requirements and good practices.

TMI-1 and Oyster Creek maintained strong performance indicators due to the commendable efforts of both plant operators and support organizations.

Materiel deficiencies were the primary cause of outages and power reductions. Corrosion product buildup in TMI-l control rod drives, and biological fouling of Oyster Creek Containment Spray heat exchangers were significant contributors and each will require continued evaluation of corrective measures.

The accomplishments of the initial weeks of the Oyster Creek 15R Refueling Outage attested to the significant planning and preparation by the Outage Management organization. The major delays encountered were again primarily due to equipment problems. The outage work scope includes many modifications to correct previously identified design deficiencies and operational problems.

Although materiel deficiencies had the greatest effect on plant operation, human performance deficiencies occurred at an undesirable rate. GPUN management focused on correcting this problem. In particular, TMI recognized the need to improve its methods for identifying, evaluating and trending human performance deficiencies, and instituted a new program to accomplish these objectives.

Staff reductions and functional reorganizations were initiated during this period with no apparent detriment to safe operation.

Monitoring and evaluation of the impact of these changes on safety should continue.

2.0 EVALUATION OF SAFETY AND COMPLIANCE The following is an evaluation'of GPUN performance from April 1, 1994 through September 30, 1994. The division into topics does not necessarily correspond to GPUN's organizational units. Statements pertain largely to conditions existing at the time of the evaluation. Corrective actions of which the Committee is aware are also noted. All items have been discussed by the Committee and the Staff and, if appropriate, have been reported by the Committee to the GPUN Board of Directors and corporate management at scheduled meetings.

The Committee has reviewed the GPUN response to its previous report (No. 20). Where pertinent, these responses are commented on in this report.

2.1 FACILITY OPERATION GPUN continued to operate its facilities safely, while maintaining excellent availability. TMI-1 had two short outages during the period; Oyster Creek had three. On September 10, oyster Creek commenced the 15R Refueling Outage. TMI-2 continued in the Post Defueling Monitored Storage mode, and removal of unused and unneeded structures continued. Arrangements for shipment of low-activity soil from the Saxton site were completed and shipments commenced during this period. Also, refurbishment of the Saxton polar crane commenced in preparation for decommissioning of the containment structure.

Operators at TMI-1 and Oyster Creek generally performed their duties in a proficient and professional manner. However, there were several events at each plant which indicate a need for continued improvement in human performance and communications.

At TMI, for instance, there were repeat occurrences of improper log keeping and failure to obtain required samples before a liquid radioactive waste release. Also, there were Technical Specifications violations for failure to maintain proper control rod overlap during a startup, and an unplanned reduction in the Sodium Hydroxide Tank level during a surveillance. At Oyster Creek, a control rod was tagged out for maintenance without proper consideration of chutdown margin requirements; and on another occasion, a control rod was mispositioned during a plant shutdown. Other errors resulted in overflowing a liquid radioactive waste tank and unplanned emptying of the Demineralized Water Storage Tank.

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2.2 MAINTENANCE / MATERIEL CONDITION Maintenance departments at both sites have been responsive to plant needs, which contributed significantly to the high availability factors of TMI and Oyster Creek.

There were several occasions at each site where prompt and effective maintenance prevented or minimized outage time.

Examples include Containment Spray heat exchanger cleaning and Service Water Pump motor replacement at Oyster Creek, and Control Rod Drive replacement and Integrated Control System module replacement at TMI.

On the other hand, maintenance personnel also exhibited some performance deficiencies. For example, at TMI two radiation monitors were not calihiated within the required period, and six months of sample data from the TMI-2 breather system was lost due to not installing the filter paper. At Oyster Creek, errors were noted in air compressor overhauls, replacement of solenoid valves on control rod hydraulic control units, and reactor level surveillance. Ineffective control of switchyard maintenance resulted in a scram at Oyster Creek in May.

Maintenance planning and scheduling has been very effective at both sites. Use of an integrated schedule and planned system outages has improved efficiency and kept the maintenance backlog at a manageable level.

The 15R outage at Oyster Creek began in September. The accomplishments of the first few weeks indicate that the significant planning and preparation by the Outage Management organization were successful. One notable exception was delays caused by several problems with the refueling bridge despite extensive maintenance and surveillance prior to the outage.

Although two outager at each site during this report period were the result of equiprent failures, the high availability factors of TMI-l and Oyster Creek indicate th h their overall materiel condition is good.

Areas of concern to the Committee at TMI-1 include control rod drive mechanism (CRDM) fouling, boron / erosion control programs, steam generator tube leakage and main condenser tube leakage.

Changes in chemistry control were initiated and the worst CRDMs were replaced in order to reduce CRDM fouling and improve control rod drop times.

At Oyster Creek, fouling of Containment Spray heat exchangers continues to be a concern. The p] ant recognizes this by making it a key issue in the Safety Issue Assessment Program, and engineering evaluation to provide a solution continues. Air compressors and radioactive waste processing equipment have had 3

d marginal availab.tlity and consumed extensive maintenance.

resou'rces. Age-related degradation such as piping erosion and corrosion, and tank bottom corrosion, continues to occur.

The installation of a digital feedwater and recirculation control system at Oyster Creek will be completed during 15R and should provide corrective action for many past operating transients.

2.3 TECHNICAL SUPPORT Technical Functions, Site Engineering and other technical support t

organizations have responded to plant needs and contributed to the excellent operating record of each plant.

l There was extensive preparation for modifications and inspections planned for the Oyster Creek refueling outage, such as core shroud inspection, reactor vessel level instrument modifications, 4160V Bus undervoltage modifications and the digital ,

feedwater/ recirculation control syctem modification. I 2.4 TRAINING INPO renewed the accreditation of several Oyster Creek programs in May. The remaining programs were evaluated in June and renewal of accreditation appears reasonably assured.

Both sites successfully completed annual requalification programs for licensed personnel. Two SRO candidates at Oyster Creek were successful in license upgrade exams in April.

Although there were staff reductions in the Oyster Creek General Employee Training section, a large number of temporary outage personnel were processed by augmenting the GET training staff with personnel from other company locations.

2.5 RADIOLOGICAL CONTROLS AND ENVIRONMENTAL CONTROLS At this point in the operating cycle, cumulative exposure at TMI is higher than predicted. T"o fuel pin failures and two outages have contributed to the higher exposure. Cumulative exposure at Oyster Creek prior to the 15R Outage was lower than predicted.

Based on emergent work identified in the first few weeks, aggressive efforts to reduce exposure will be needed to meet the outage goal. -

l l Radiation Controls personnel have been very proactive in looking j

' for ways to reduce exposure and improve efficiency of doing work.

At Oyster Creek, many areas of the plant have been relcaced from radiological posting. In August, an automated RWP log-in system i

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4 was placed into operation. TMI plans to reduce the frequency of calibration of certain radiation monitors,.which will reduce exposure and require less resources. Relief from some monitoring requirements around TMI-2 has been obtained.

Availability of an off-site facility for burial of low level radioactive waste (LLRW) ended in June. Since then each plant has been using its on-site storage facility. Management at both plants strongly emphasized the need to minimize the volume of LLRW. Both sites are also investigating methods for off-site volume reduction of liquid waste before on-site storage.

The concrete pad for the Independent Spent Fuel Storage Facility at Oyster Creek was completed in September.

2.6 EMERGENCY PREPAREDNESS Both sites had successful annual drills.

Third quarter drills at each site combined accident scenarios and security-based events. These proved to be very challenging to the emergency response organizations and identified several areas for improvement in emergency management.

In drills during June and August at TMI, personnel failed to declare appropriate activation levels. This may indicate a need for more training.

2.7 MANAGEMENT / SAFETY ATTITUDE All GPUN facilities continued to be managed with integrity and a conservative safety attitude.

Human performance deficiencies have been noted in Sections 2.1 and 2.2 above. Management at both sites continued to seek improvement. Top level involvement at both sites is essential to success.

TMI recognized that it did not have a good program for identification, analysis and correction of human performance events. In April, a Human Performance Review Board comprised of Directors and senior managers was established to recommend ways to improve. They developed a Human Performance Evaluation  !

Standard to ensure an appropriate level of evaluation of events. j A system for reporting minor events and near misses was j established, and a data base was created to track and trend 1 events.

I oyster Creek filled the Human Performance Enhancement System Coordinator position, which had been vacant for several months.

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i The outage risk management program was upgraded prior to the 15R l outage. Also, a computer-based system for evaluating outage risk is being used on a trial basis. If successful, it will be used  ;

in future outages. '

oyster Creek personnel surpassed one million work hours without a lost time accident during this period.

In keeping with corporate goals for greater efficiency, reductions in personnel through a voluntary early retirement program were initiated during this period. Also, several functions were consolidated (e.g., Quality Assurance and Independent On-Site Safety Review). While these measures were initiated with appropriate consideration for maintaining the goal of nuclear safety, they should be periodically evaluated to ensure the desired results are achieved.

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, l 3.0 ACTIVITIES OF COMMITTEE AND STAFF 3.1 GENERAL There were no changes in Committee membership or site support staffing during this period.

The NSCC guides the NSCC Staff's investigations and approves its schedules and expenditures. Staff activities involve both routine monitoring and special reviews. Routine monitoring covers all functional areas at each site and at corporate headquarters. Special reviews are initiated in response to Committee requests, or as plant events or industry occurrences dictate. The Committee reviews various sources of information noted in Exhibit 1. On occasion these reviews result in special tasks for the Staff.

T 3.2 COMMITTEE ACTIVITIES In addition to the activities described above, the Committee meets with the GPUN Board of Directors at scheduled meetings and reports on any items of significance with respect to safety or compliance. Questions or concerns arising between board meetings may be directed to the Chairman of the Board or the President of GPUN. The Committee may also meet with GPUN executives when appropriate. One such meeting, to discuss the 1993 NSCC assessment of safety at GPUN facilities, was held in May. The Committee meets with members of the Staff prior to the meetings of the Board of Directors. Between meetings, there is a regularly scheduled conference call to discuss the status of each plant.

The meetings of the NSCC and its staff frequently include presentations by, and discussions with, selected GPUN personnel on subjects of interest to the Committee. During this report period, discussions were held with the Vice-President / Director, Oyster Creek; the Vice-President / Director, TMI-1; the Director, Independent Safety Review; the Director, Operations and Maintenance, Oyster Creek; the Radiation Controls / Safety Director, TMI; the Manager, Component Maintenance Team, Oyster Creek; the Manager, Design and Drafting; the Manager, Nuclear Safety Assessment, TMI; and members of the Oyster Creek PREP Team. Additionally, in April, a representative of the Oyster Creek Operator Training section conducted a training session on -

reactivity control, reactor pressure and level control, and associated systems.

All Committee members completed Site Access requalification training during this period.

Committee members toured the TMI-1 and Oyster Creek sites in 7

' conjunction with meetings of the Board of Directors and General Of fice Review Boards. (GORB) . Admiral Trost attended one GORB meeting at TMI; and Mr. Wilson attended one GORB meeting at Oyster Creek. Also, in-May, the Manager, Construction Management, conducted a tour of TMI-2 for the Committee and the Staff. In September, thev toured the TMI Low Level Rad Waste Storage Facility.

3.3 STAFF ACTIVITIES The Staff, which is permanently stationed at the TMI and Oyster Creek plants, gathers information on plant activities from many sources: plant tours; the monitoring of activities; attendance at meetings; interviews with GPUN personnel; and reviews of reports, correspondence, and other documents. Plant operations and maintenance activities receive primary attention, but support functions are also evaluated. The NSCC Staff has expertise in management, operations, maintenance, engineering, licensing, training, radiological controls, environmental controls, quality assurance, and emergency preparedness. During this period, one Staff member attended an EPRI sponsored Operational Reactor Safety Engineering and Review Groups Workshop.

Evaluations during this report period concentrated on the areas and activities described in Section 2.0. Information sources to which the Staff avails itself and a list of activities and information sources used in the Staff evaluations are presented in Exhibit 1. GPUN personnel contacted during this period are indicated in Exhibit 2.

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, EXHIBIT 1 NSCC STAFF ACTIVITIES /INFORMA1 7N SOURCES (both TMI-1 and OC unless oth tise noted)

PLANT TOURS General walkthroughs/ housekeeping observations Off-Shift tours Control Room observations Maintenance observations Surveillance Test observations -

Radwaste Handling observations Emergency Drill observations MEETINGS Production Planning meetings Plant Review Group (PRG) meetings Daily Plant Status meetings Outage Planning meetings NRC Entrance / Exit meetings INPO Training Evaluetions

• GORB meetings Post-Trip Review Group meetings critiques Radiological Awareness Committee meetings (OC)

Project Review meetings (OC)

Department /Section Staff meetings (CC) l DOCUMF.NT REVIEW I 1

GPUN Sources

• Plant Incident Reports (TMI-1)

Plant Review Group meeting minutes

• Deviation Reports (OC)  ;

• Licensee Event Reports

• Incident Critiques Station Action Item Tracking System

• Licensing Correspondence

• Significant Events Reports

• Off-Shift Tour Reports i i

• Denotes information revie"9d by the NSCC l l

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. EXHIBIT 1

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QA Audit Reports

• QA Assessment Reports (Monthly and Annual)

• QA Quarterly Trend Reports operations QA Monitoring Reports STA Daily Reports Operations Night Order Book Log Books (Operations, STA, Chemistry, Maintenance, Radwaste)

• Independent Safety Review Annual Safety Assessment Report Design Basis Documents Shift Turnover Forms MNCRs, QDRs Radiation Awareness Reports

• Post-Trip Review Group Reports

• Transient Assessment Reports Maintenance Job Order Packages GPUN Administrative Policies and Procedures Station Procedures (e.g., Admin., Operations, Maintenance)

Division Procedures (e.g., Rad Con, Tech. Functions)

Operations QA Plan Technical Specifications Training System Descriptions Training Lesson Plans Plant Drawings

• IOSRG Evaluation Reports '

• GORB Meeting reports Potential Safety Concerns Licensing Action Items

• HPES Reports Technical Data Reports Calculations and Verifications Field Questionnaires / Change Notices Failure Trend Reports i

Databases Reviewed Computer Assisted Records & Info Retrieval System (CARIRS)

Generation Maintenance System II (CMS-2)

Material Inventory Control System (MICS) l Purchasing System (DKPS)

Nuclear COMEC (NCMC) ]

Quality Assurance (NQMI)

Nuclear Material Management System (NMMS) l Technical Functions Work Requests (TFWR/TFAAI) I Plant Engineering Work Requests (PEWR/ PETA)

• Denotes information reviewed by the NSCC 10

. EXHIBIT 1

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Other Sources

• NRC Notices and Bulletins

• NRC Generic Letters

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• NRC Regulatory Guides and NUREGs

• NRC SALP Reports

• NRC Inspection Reports

• INPO Evaluation Reports INPO Guides ANSI Standards ASME Codes Code of Federal Regulations (10 CFR)

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

• INPO Nuclear Power Plant Operational Data Report Nuclear Network l

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• Denotes information reviewed by the NSCC 11

EXHIBIT 2 PERSONS INTERVIEWED / CONTACTED DURING REPORT PERIOD SITE PERSONNEL'(both TMI-1 and OC unless otherwise noted)

Vice President / Director Vice President, Saxton, NEC Operations and Maintenance Director Plant Operations Director (TMI-1, TMI-2)

Plant Maintenance Director Plant Engineering Director Site Services Director Department Managers, Supervisors, and personnel

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Plant Operations /Radwaste/ Chemistry Plant Materiel / Maintenance Site Services Plant Engineering Logistical Support Plant Review Group IOSRG Engineering and Design Engineering Services Licensing Systems Engineering / Plant Analysis (STA)

Engineering Projects Startup and Test Training and Education Quality Assurance Emergency Planning Radiological Controls Environmental Controls Nuclear-Safety Outage Management CORPORATE PERSONNEL Vice-President, Services /TMI-2 Vice-President, Technical Functions Vice-President, Nuclear Assurance Director, Radiological Controls Director, Independent Safety Review Managers and other personnel Licensing Training and Education Systems Engineering / Plant Analysis Nuclear Safety Assessment Engineering and Design Site Services 12

(