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{{Adams
{{Adams
| number = ML20207M405
| number = ML20213G454
| issue date = 01/05/1987
| issue date = 12/03/1986
| title = SALP Rept 50-289/86-99 for May-Oct 1986
| title = Final SALP Rept 50-289/86-99 for May-Oct 1986,including Revs to Table 8
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Line 10: Line 10:
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-289-86-99, NUDOCS 8701130171
| document report number = 50-289-86-99-01, 50-289-86-99-1, NUDOCS 8705180299
| package number = ML20207M383
| package number = ML20213G433
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 54
| page count = 58
}}
}}


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=Text=
=Text=
{{#Wiki_filter:.o
{{#Wiki_filter:ENCLOSURE ~4
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U. S. NUCLEAR P.EGULATORY COMMISSION
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U. S. NUCLEAR REGULATORY COMMISSION


==REGION I==
==REGION I==
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT S0-289/86-99 GENERAL PU81IC UTILITIES NUCLEAR CORPORATION THREE MILE ISLAND (UNIT 1) NUCLEAR GENERATING STATION ASSESSMENT PERIOD: MAY 1, 1986 - OCTOBER 31, 1986 BOARD MEETING DATE: DECEMBER 3, 1986 hDR ___ ,
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-289/86-99 (FINAL REPORT)
_
GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION THREE MILE ISLAND (UNIT 1) NUCLEAR GENERATING STATION ASSESSMENT PERIOD: MAY 1, 1986 - OCTOBER 31, 198 BOARD MEETING DATE: DECEMBER 3, 1986
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SUMMARY OF RESULTS Facility Performance Recent SALP I SALP II Trend Functional Area (9/16/85-4/30/86) (5/1/86-10/31/86) (Last 3 Mos.) Plant Operations 2  2 - Radiological Controls 1  1 - Maintenance  2  1 - Surveillance Testing 1  1 - Startup Testing 1  NA NA Emergency Preparedness 1  1 - Security and Safeguards 2  2 Improving Technical Support 3  2 - Training and Qualifi- 1  1 -
cation Effectiveness 10. Assurance of Quality 2  2 -
1 Licensing  1  1 Declining i
B. Overview Overall, the licensee has continued to operate TMI-1 safely with a generally <trong orientation toward nuclear safety. The organization is compris J of highly qualified and well-trained personnel. Many licensee initiatives go beyond regulatory requirements.


. The strong support functional areas that remain noteworthy are radiological controls and emergency preparedness. Although improve-ment has been noted in the security / safeguards area, licensee per-formance and self ovaluation in this area appear to be heavily compliance orientec ind a broader, performance-oriented approach to program and system evaluation is needed. The maintenance and serveillance programs provide good assurance of the operability of safety-related equipment. The maintenance area has shown significant improvement as evidenced by (1) the material condition of the plant; (2) the relatively low number of plant trips and equipment problems for the SALP II period; and, (3) the licensee's positive control of work activities in the plant space .- .
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SUMMARY OF RESULTS Facility Performance Recent SALP I  SALP II- Trend Functional Area (9/16/85-4/30/86) (5/1/86-10/31/86)- (Last 3 Mos.)


However, in the past three SALP periods, the licensee's performance in the plant operations, technical support, and assurance of quality functional areas has remained at or below a Category 2 level. A number of factors appear to be inhibiting performance improvements i-these areas. These include (1) additional attention on the need to instill a keen sense of quality at all levels of the work force, which includes such attributes as strict procedure adherence and attention to detail in procedure review or implementation; (2) in-consistent policies and programmatic weaknesses; (3) additional attention on the need to properly balance work production with safety perspective; and, (4) various individual personnnel error In the assurance of quality functional area, there is one aspect of licensee self-review processes that remains a concern of the NRC staf All licensee review groups have substantial qualifications and exper-tise to properly exercise their responsibility, they are thorough and inquisitive in their review, and they have demonstrated their ability to identify regulatory or safety issues. However, management self-review of the more important issues raised by these groups is exces-sively delayed or lacks thoroughness, inquisitiveness, or responsive-ness to formulate effective corrective actions. Further management attention is needed to assure that the issues raised by the licensee's
. . Plant 0perations  2  2 - Radiological Controls 1  1 - Maintenance  2    1 - Surveillance Testing  1  1 - Startup Testing _  1  NA NA Emergency' Preparedness 1  1 -
.
own internal review groups are aggressively pursued to resolutinn.


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  ' Security and Safeguards 2    2 Improving Technical Support  3    2 - Training and Qualifi- 1    1 -
i i
cation Effectiveness 1 Assurance of Quality 2    2 -
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  -- 1 Licensing  1    1 Declining
! - .. -. . - - - - _ _ - . -
< Overview Overall, the licensee has continued to operate TMI-1 safely with a generally strong orientation toward nuclear safety. The organization is comprised of highly qualified and well-trained personnel. Many licensee initiatives go beyond regulatory requirement The strong support functional areas that remain noteworthy are radiological controls and emergency preparedness. Although improve-ment has been noted in the security / safeguards area, licensee per-formance and self-evaluation in this area appear to be heavily compliance oriented, and a broader, performance-oriented approach to program and system evaluation is needed. The maintenance and surveillance programs provide good assurance of the operability of safety-related equipment. The maintenance area has shown significant improvement as evidenced by (1) the material condition of the plant; (2) the relatively low number of plant trips and equipment problems for the SALP II period; and, (3) the licensee's positive control of work activities in the plant space . - , _ , . _ . . . _ _ __ . _ , . _ - _- _ - . _ _ - - . . _ _ . _ . __ - _ . . - _


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IV. PERFORMANCE ANALYSIS Plant Operations (1082 hours, 41.6%)
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Analysis During the previous assessment the licensee's performance was rated as Category 2. The NRC found that licensee management exhibited strong involvement in daily operations of the plan Licensed operator per-formance and administrative controls were strong. Procedures were technically adequate but individual procedure step inadequacies per-sisted. The inability by middle managers to balance the pace of work activities along with proper procedure adherence was note The control room environment and overall operator command and control of plant operations contribute significantly to safe nuclear opera-tions. Control room physical arrangement and policies are conducive to overall positive control of operation Limited access by non-licensed operators is maintained in the control roo Routine business, including shift briefings, is conducted away from the main control boards. A dedicated plant page line is used to eliminate the noise from other page lines in the control roo Plant operations are conducted in an orderly, professional, and business-like manner, keeping the control room quiet. For the most part, procedures, plant records, and manuals are properly stored. A dress code continues to be implemente Licensed operator performance continued to be oriented toward nuclear safety but, in some instances, was not completely conservative. For example, their attempt to energize a non-safety related electrical
  - However, in the past three SALP periods, the licensee's performance in the plant operations, . technical support, and assurance of quality functional areas has remained at or below a Category 2 level. A number of factors appear to be inhibiting performance improvements in these areas. These include (1) additional attention on the need to-instill a keen sense of quality-at all levels of the work force, which includes such attributes as strict procedure adherence and attention to detail in procedure review or implementation; (2) in-consistent policies and programmatic weaknesses; (3) additional attention on the need to properly balance work ~ production with safety perspective; and, (4) various individual personnnel error .In the assurance of quality functional area, there is one aspect of licensee self review processes that remains a concern of the NRC staf All licensee review groups have substantial qualifications and exper-tise to properly exercise their responsibility, they are thorough and inquisitive in their review, and they have demonstrated their ability to identify regulatory or safety issue However, management self-review of the more important issues raised by these groups is exces-
,
  .
'
sively delayed or lacks thoroughness, inquisitiveness, or responsive-ness to formulate effective corrective actions. Further management attention is needed to assure that the issues raised by the Itcensee's
bus from a safety bus, apparently in order to prevent a turbine trip, was done without fully considering the full effects of their actions,
  - own internal review groups are aggressively pursued to resolution.
, and those actions were not conservative. In general, strong depth of j knowledge of plant conditions and on going evolutions by operating ,
:
crews was noted. Continued use of shift technical advisers in trend-
! ing and early detection of plant equipment degradation is a positive attribut There is an overall respect for the use and proper implementation of procedure However, instances were again noted in which the proce-i dure adherence problem resurfaced during this SALP period. Personal i
error was a factor but middle management influence also contributed
,
to the problem. Of particular significance, for an engineered safety j features actuation system test the operations department conducted a l key plant evolution by use of many specific plant operating procedures l instead of using an overall controlling surveillance procedure. This j contributed to a valve mispositioning, lack of independent verifica-tion, and an unknown entry into a TS action statement for the High Pressure Injection (HPI) system. The associated Plant Incident Report was shortsighted in that it focused on the personnel error aspects rather than programmatic / managerial problems surrounding the event.


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As exhibited in this instance, licensee personnel tend to overestimate their ability to conduct evolutions from memory or without rigorous control. The potential to adversely affect safety does exist if remedial actions on the procedure adherence problem are not effec-tiv As noted in the previous SALP, technical adequacy of station proce-dures was sufficient; however, some minor weaknesses continued to be noted. For example, station procedures addressing requirements for plant startup never addressed the control of the reactor building aircraft missile door; and, procedures on license power limit were not sufficiently clear in providing guidance for evaluation of brief excursions above licensed power level. In each case, the licensee took proper corrective action, but with some delay, to alleviate the specific deficienc However, licensee management did not question its own self-review process that permitted these inadequacie A factor in the procedure adequacy problem is the licensee's technical / safety review system. Inspections identified the following weaknesses: applicable procedures provided limited guidance and training on what constitutes an adequate responsible technical review and/or independent safety review; middle management performed a significant number of these reviews themselves despite their busy schedules and availability to do a quality review; and, an apparent misuse of the independence of review latitude provided by TS in that new but temporary procedures were written, reviewed, and approved by one department. Further inspections identified that the TS required technical / safety review was not properly implemented. A number of instances were noted when procedure changes were classified as not important to safety when they affected important-to-safety systems (ITS). Several special temporary procedures (new procedures)
IV. PERFORMANCE ANALYSIS Plant Operations (1082 hours, 41.6%)
involved system evolutions on ITS systems, but they were classified not ITS. This resulted in the 10 CFR 50.59 evaluation criteria not being considered prior to issuance of these procedures. Also, corporate procedures that administratively direct and document safety-related modifications to the plant were declassified from important to safety, apparently with no safety review required for these procedure In general, management resolution of issues developed by the NRC was acceptabl However one licensee response to a notice of violation reflected a non-conservative approach in implementing
Analysis During the previous assessment the licensee's performance was rated as Category 2. The NRC found that licensee management exhibited strong involvement in daily operations of the plant. Licensed operator per-formance and administrative controls were strong. Procedures were technically adequate but individual procedure step inadequacies per-sisted. The inability by middle managers to balance the pace of work activities along with proper procedure adherence was note The control room environment and overall operator command and control of plant operations contribute significantly to safe nuclear opera-tion Control room physical arrangement and policies are conducive to overall positive control of operation Limited access by non-licensed operators is maintained in the control roo Routine business, including shift briefings, is conducted away from the main control boards. A dedicated plant page line is used to eliminate the noise from other page lines in the control rm Plant operations are conducted in an orderly, professional, anc business-like manner, keeping the control room quiet. For the most part, procedures, plant records, and manuals are properly stored. A dress code continues to be implemente Licensed operator performance continued to be oriented toward nuclear safety but, in some instances, was not completely conservative. For example, their attempt to energize a non-safety related electrical bus from a safety bus, apparently in order to prevent a turbine trip, was done without fully considering the full effects of their actions, and those actions were not conservative. In general, strong depth of knowledge of plant conditions and on going evolutions by operating crews was noted. Continued use of shift technical advisers in trend-ing and early detection of plant equipment degradation is a positive attribut There is an overall respect for the use and proper implementation of procedure However, instances were again noted in which the proce-dure adherence problem resurfaced during this SALP period. Personal error was a factor but middle management influence also contributed to the problem. Of particular significance, for an engineered safety features actuation system test the operations department conducted a key plant evolution by use of many specific plant operating procedures instead of using an overall controlling surveillance procedur This contributed to a valve mispositioning, lack of independant verifica-tion, and an unknown entry into a TS action statement for the High Pressure Injection (HPI) system. The associated Plant Incident Report was shortsighted in that it focused on the personnel error aspects rather than programmatic / managerial problems surrounding the even _ . __
;
'
procedures with respect to alarm response procedure violations. This is repetitive of poor responses noted in the last SAL It is not clear whether licensee management has enhanced their attention to responses to violation Further, the licensee management tenta-tively disagrees with the safety review findings noted above (to be the subject of a forthcoming meeting with the licensee).


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There was one reactor trip during the SALP period. This equates to a scram rate of two trips per year which is significantly better than the last SALP period. Including the one trip, there were only five licensee event reports submitted, three of which involved events from before the start of the SALP period. No particular conclusions can be drawn with respect to the limited number of LER's during this period. (See also Section V.D for additional information on LER's submitted from outside this assessment period.)
-As exhibited in this instance, licensee personnel tend to overestimate their ability to conduct evolutions from memory or without rigorous control. The potential to adversely affect safety does exist if remedial actions on the procedure adherence problem are not effec-tiv As noted in the previous SALP, technical adequacy of station proce-dures was sufficient; however, some minor weaknesses continued to be noted. For example, station procedures addressing requirements for plant startup never addressed the control of the reactor building aircraft missile door; and, procedures on license power limit were not sufficiently clear in providing guidance for evaluation of brief excursions above licensed power leve In each case, the licensee took proper corrective action, but with some delay, to alleviate the specific deficienc However, licensee management did not question its own self-review process that permitted these inadequacie A factor in the procedure adequacy problem is the licensee's technical / safety review system. Inspections identified the following weaknesses: applicable procedures provided limited guidance and training on what constitutes an adequate responsible technical review and/or independent safety review; middle management performed a significant number of these reviews themselves despite their busy schedules and availability to do a quality review; and, an apparent misuse of the independence of review latitude provided by TS in that new but temporary procedures were written, reviewed, and approved by one department. Further inspections identified that the TS required technical / safety review was not properly implemented. A number of instances were noted when procedure changes were classified as not important to safety when they affected important-to-safety systems (ITS). Several special temporary procedures (new procedures)
involved system evolutions on ITS systems, but they were classified not ITS. This resulted in the 10 CFR 50.59 evaluation criteria not being considered prior to issuance of these procedures. Also, corporate procedures that administratively direct and document safety-related modifications to the plant were declassified from important to safety, apparently with no safety review required for these procedure In general, management resolution of issues developed by the NRC was acceptabl However one licensee response to a notice of violation reflected a non-conservative approach in implementing procedures with respect to alarm response procedure violations. This is repetitive of poor responses noted in the last SAL It is not clear whether licensee management has enhanced their attention to responses to violation Further, the licensee management tenta-tively disagrees with the safety review findings noted above (to be the subject of a forthcoming meeting wi+h the licensee).


Site management continued to exhibit strong attention and involvement in various aspects of plant operations. This was especially true for non-routine problems having potential safety significance; such as, the various seal problems with two reactor coolant pumps. Routine problems are also handled reasonably well with appropriate site operations, maintenance and/or engineering personnel assigned to take corrective action. However, as noted in the last SALP, for certain issues corrective actions appear to be weak or not completely effec-tive such as for the procedure adherence and procedure adequacy problems noted above. Various licensee review groups from the Quality Assurance (QA) Department to the sub-committee members of the Board of Directors (Nuclear Safety and Compliance Committee) have identified these and other problems. Sufficient resources and management attention were not effectively applied in a timely manner before they became issues with the NRC staf Overall, the licensee's operation and management direction has been oriented toward safe nuclear operations, but it is not always fully conservative. Adequate resources have been applied to the operations of the unit to ensure safe operation. The review group organizations continue to be an effective tool in identification of
.
-e,
''      10-There was one reactor trip during the'SALP' period. This equates to a scram rate of two trips per year which is significantly better than the last SALP period. Including the one trip, there were only five licensee event reports submitted, three of which involved events from
  . before.the start of the SALP period. -No particular conclusions'can be drawn with respect to the limited number of LER's during this period. (See also Section V.D for additional information on LER's submitted from outside this assessment period.)


licensee problems; however, they are less effective in causing change to resolve noted problems. Weakaesses in procedure adherence and technical adequacy still continues to be noted due to personnel error and programmatic deficiencies. Licensee personnel tend to overesti-mate their abilities on conducting procedures from memory and do not always rigorously use procedures. A programmatic deficiency in the area of required technical / safety reviews for procedures has developed and warrants closer review and evaluation by the licensee and Nf: staf Conclusion Category 2 Recommendation See Assurance of Quality Recoramendations
-Site management continued to exhibit strong attention and involvement'  '
. - - ._
in various aspects of plant operations. This was especially true for non-routine problems having potential safety significance; such as, the various seal problems with two reactor coolant pumps. Routine problems are also handled reasonably well with appropriate site operations,' maintenance and/or engineering personnel assigned to take corrective action. However, as noted in the last SALP, for certain issues corrective actions appear to be weak or not completely effec-tive such as for the procedure adherence and procedure adequacy problems noted above. Various licensee review groups from the
  - _ ,
  - Quality Assurance (QA) Department to the sub-committee members of the Board of Directors (Nuclear Safety and Compliance Committee) have identified these' and other problems. Sufficient resources and management attention were not effectively applied in a timely manner before they became issues with the NRC staf Overall,.the licensee's operation and management direction has been oriented toward safe nuclear operations, but it is not always fully conservative. Adequate resources have been applied to the operations of the unit to ensure safe operation. The review group organizations continue to be an effective tool in identification of licensee problems; however, they are less effective in causing change to resolve noted problems. Weaknesses in procedure adherence and technical adequacy still continues to be noted due to personnel error and programmatic deficiencies. Licensee personnel tend to overesti-mate'their abilities on conducting procedures from memory and do not always rigorously use procedures. A programmatic deficiency in the area of required technical / safety reviews for procedures has developed and warrants closer review and evaluation by the licensee and NRC staf Conclusion Category 2 Recommendation See Assurance of Quality Recommendations
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B. Radiological Controls (241 hours, 9.2%)
B. Radiological Controls (241 hours, 9.2%)
Analysis During the previous SALP period, licensee performance was rated as Category 1, declining. The overall Radiological Controls program was noted to be sound and effective. The effluents reporting program was well organized and functional. Some lapses of performance occurred, particularly in the areas of communication and outage management, as evidence.d by the problems experienced at the start of the SM outag Implementation of the Radiological Controls program was of high quality during this assessment period, with well qualified staff, good procedures, suitable facilities, and effective implementation and management oversight. The licensee's radwaste management, effluent control and chemistry programs continued to be effectively implemented; however, minor problems were noted in achieving good analytical accuracies and sensitivitie The licensee organization and current level of management involvement is adequate for effectively implementing the Radiological Controls progra Positions-are clearly identified with well-defined authori-ties and responsibilities. Clear policies and procedures are in place and are strictly adhered to. Cooperation and communications among the Field Operations and Radiological Engineering staffs within the Radiation Protection Department appear effective and ensure adequate technical oversight of day-to-day work and outage activi-ties. A multi-level audit system provides an ambitious review of radiological activities and is implemented in accordance with controlling procedures. Corrective actions for internally and NRC-identified items are comprehensive and technically soun Qualifications and staffing levels of radiation protection personnel were found to be suitable for the routine implementE-tion of the Radiological Controls program. Preparations were made in a timely fashion to augment field operations staffing in preparation for the upcoming 6R outage. Inspections identi-fled a weakness in the general lack of experience with refuel-ing operations among the Field Operations and Radiological Engineering staffs. This has been recognized and responded to by the licensee with the presentation of specialized refueling training to all the health physics (HP) technicians. A staff member from both the Field Operations and Radiological Engi-neering sections was also sent to another site to observe ongoing refueling operation Licensee radiological preparation for the upcoming 6R outage has been extensive. Instrument and facility upgrades have been completed to enhance contamination control and speed personnel access. Designated radiological engineers have been assigned ALARA (as low as reasonably achievable) planning and exposure-
Analysis During the previous SALP period, licensee performance was rated as Category 1, declining. The overall Radiological Controls program was noted to be sound and effective. The effluents reporting. program was well organized and functional. Some lapses of performance occurred, particularly in the areas of communication and outage management, as evidenced by the problems experienced at the start of the SM outag Implementation of the Radiological Controls program was of high quality during this assessment period, with well qualified staff, good procedures, suitable facilities, and effective implementation and management oversight. The licensee's radwaste management, effluent control and chemistry programs continued to be effectively implemented; however, minor problems were noted in achieving good analytical accuracies and sensitivitie The licensee organization and current level of management involvement is adequate for effectively implementing the Radiological Controls progra Positions are clearly identified with well-defined authori-ties and responsibilities. Clear policies and procedures are in place and are strictly adhered t Cooperation and communications among the Field Operations and Radiological Engineering staffs within the Radiation Protection Department appear effective and ensure adequate technical oversight of day-to-day work and outage activi-ties. A multi-level audit system provides an ambitious review of radiological activities and is implemented in accordance with controlling procedures. Corrective actions for internally and NRC-identified items are comprehensive and technically soun i


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Qualifications and staffing levels of radiation protection  !
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personnel were found to be suitable for the routine implementa-tion of the Radiological Controls program. Preparations were made in a timely fashion to augment field operations staffing in preparation for the upcoming 6R outage. Inspections identi-fied a weakness in the general lack of experience with refuel-ing operations among the Field Operations and Radiological Engineering staffs. This has been recognized and responded to by the licensee with the presentation of specialized refueling training to all the health physics (HP) technicians. A staff member from both the Field Operations and Radiological Engi-neering sections was also sent to another site to observe j ongoing refueling operation Licensee radiological preparation for the upcoming 6R outage has been extensive. Instrument and facility upgrades have been completed to enhance contamination control and speed personnel access. Designated radiological engineers have been assigned ALARA (as low as reasonably achievable) planning and exposure-
_ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _


tracking responsibilities for identified high exposure jobs. Dis-cussions with the engineering-staff indicated radiological planning for each job and incorporation of " lessons learned" was generally carried out in a-timely manne A review of routine health physics activities indicated the licensee is effectively performing radiological posting, routine surveillance, and internal exposure control activities. The licensee continues to effectively utilize a radiation work permit (RWP) system to provide positive control over radiological work activitie Surveys performed in support of work were well documented and readily accessible. The licensee is implementing a particularly well-controlled high radiation area key control program to ensure access is controlled to locked high radiation area The licensee has demorstrated good control over liquid radwast There is evidence of improved communication among responsible groups and management goals have been established for waste minimization, inleakage reduction, dose commitment reduction, and decontamination effort Progress is reviewed monthly. Performance reports for all evaporator runs are distributed to staff and managemen The licensee utilizes good trending technique in tracking the parameters which reflect system performanc The licensee continued to maintain an effective program for effluent control and monitoring during the assessment perio Surveillances were performed as required and, in many cases more frequently than required, for effluent releases and for primary and secondary coolant chemistr A technically sound and thorough approach to preventive mainte-nance for effluent radiation monitors was in place. A continuing systematic review of monitor surveillance records is performed to l determine if "as-found" conditions require action to correct malfunc-l tions. Radiological Engineering personnel were well acquainted with procedures for implementation of On-Site Dose Calculation Manual (ODCM) methodology.
.


, The licensee's radiochemistry program is generally able to make l accurate analysis of routine in plant and effluent samples. Only l minor deficiencies, stemming from calibration and counting geometry l differences, were identified during a sample analysis intercomp:c.ison with the NRC Mobile Laboratory. These deficiencies were found not to i
tracking responsibilities for identified high exposure jobs. Dis-cussions with the engineering staff indicated radiological planning for each job and incorporation of " lessons learned" was generally carried out in a timely manne A review of routine health physics activities indicated the licensee is effectively performing radiological posting, routine surveillance, and internal exposure control activities. The licensee continues to effectively utilize a radiation work permit (RWP) system to provide positive control over radiological work activitie Surveys performed in support of work were well documented and readily accessible. The licensee is implementing a particularly well-controlled high radiation area key control program to ensure access is controlled to locked high radiation area The licensee has demonstrated good control over liquid radwast There is evidence of improved communication among responsible groups and management goals have been established for waste minimization, inleakage reduction, dose commitment reduction, and decontamination efforts. Progress is reviewed monthl Performance reports for all evaporator runs are distributed to staff and managemen The licensee utilizes good trending technique in tracking the carameters which reflect system performanc The licensee continued to maintain an effective program for effluent control and monitoring during the assessment peric Surveillances were performed as required and, in many cases more frequently than required, for effluent releases and for primary and secondary coolant chemistr A technically sound and thorough approach to preventive mainte-nance for effluent radiation monitors was in place. A continuing systematic review of monitor surveillance records is perform?d to determine if "as-found" conditions require action to correct malfunc-tions. Radiological Engineering personnel were well acquainted with procedures for implementation of On-Site Dose Calculation Marual (00CM) methodolog The licensee's radiochemistry program is generally able to make accurate analysis of routine in plant and effluent samples. Only minor deficiencies, stemming from calibration and counting gecmetry differences, were identified during a sample analysis intercorrparison with the NRC Mobile Laboratory. These deficiencies were found not to affect the licensee's ability to conservatively quantify sample activity. However, a review of the licensee's post-accident sempling capability identified that the licensee was unable to meet the boron analysis sensitivities committed to in a 1983 letter to the NR Corrective action was initiated for this problem and it appears to be attributed to poor quality of review that determined the draft aro-cedure to do the analysis was no longer neede _ _ . . _
affect the licensee's ability to conservatively quantify sample I
activity. However, a review of the licensee's post-accident sampling
!
capability identified that the licensee was unable to meet the boron j analysis sensitivities committed to in a 1983 letter to the NRC.


l Corrective action was initiated for this problem and it appears to be attributed to poor quality of review that determined the draft pro-cedure to do the analysis was no longer needed.
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Effective chemistry and radiochemistry procedures are in place; however, deficiencies were noted in the implementation of these procedures. Additional licensee attention should be paid to ensure effluent batch sample sensitivities are met and quality control intercomparisons are effectively performe Semi-Annual Radioactive' Effluent and Release Reports were generally satisfactory; however, one minor apparent violation resulted from the
    . - - _ . - -
  .  - failure of one report to include all required assessments. Audits of the ef fluents and chemistry areas were complete, timely, and thorough, and performed by technically knowledgeable personne In summary, licensee performance in the areas of radiation protection and effluent controls and measurements has generally impr.oved over the previous assessment period. No major viola-tions or programmatic weaknesses were identifie Conclusion Category 1 Recommendations
 
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None
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:  Effective chemistry and radiochemistry procedures are in place;
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however, deficiencies were noted in the implementation of these procedures. Additional licensee attention should be paid to ensure effluent batch sample sensitivities are met and quality control intercomparisons are effectively performed, i Semi-Annual Radioactive Effluent and Release Reports were generally satisfactory; however, one minor apparent violation resulted from the  ~'
M f
;  failure of one report to include all required assessments. Audits of the effluents and chemistry areas were complete, timely, and j  thorough, and performed by technically knowledgeable personnel.
  --_ . . --. ._ _ . - - , ___.____.._~_,,___..-m - _ _ _ , - - , , , . _ . _ _ , - _ , - - , , - _ - _ . - , , ~ . , _ . - ,-.
 
T In summary, licensee performance in the areas of radiation    t
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protection and effluent controls and measurements has generally improved over the previous assessment period. No major viola-
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tions. or programmatic weaknesses were identifie Conclusion
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Category 1 Recommendations l~  None i
 
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  ._ . - . _ _ _ _ _ _ _ _ . - _ _ _ . - . _ _ . _ . _ _
    -      _ . = _
w
.
  .
  .
..-
14 Maintenance (260 hours, 10%)
Analysis The previous SALP rated the licensee's performance as Category 2, consistent. Overall, performance of maintenance activities was good and reflected proper establishment, implementation, and staffing for the program. Some instances of weak implementation; such as, proce-
-dure adequacy and technical support, were noted that required more management involvement. Performance during the Once-Through Steam Generator (OTSG) eddy-current outage was good as evidenced by the accomplishment of a large workload with few problems. Problems occurred during restart where personnel, primarily those conducting maintenance or modification work, were not aware of how their actions had the potential to cause a challenge to a safety syste The preventive and corrective maintenance program qualities were evidenced by the continuing good material condition of the plan The motor-operated valve test program, which is considered a strength, has identified several valve problems that resulted in repairs; adjustments; and, in one situation, motor replacement of a different size motor to alleviate a situation with excessive opera-ting torque. There have been no forced outages or reactor trips that were directly attributable to poor equipment maintenance. Isolated events had poor maintenance planning as a contributing factor. NRC inspections of the high pressure injection (HPI) and decay-heat removal valves indicated overall good maintenance practice and good material condition. The inspectors observed extensive quality assurance department oversight in this are The PAT II inspection determined that personnel were knowledgeable, work was technically sound, and job tickets were appropriately prioritized. The failure trending program was effective in identifying components that require repetitive repair. The vendor manual control and update program is still in the process of being completed. An example of poor vendor manual control was identified when an uncontrolled copy of a technical manual was used to calibrate Bailey meter multiplier modules and signal monitors. The use of this manual did not adversely affect the calibratio Maintenance procedures generally continue to be adequate to properly control work on safety related components. Two procedure weaknesses were identified that caused problems. One instance involved mis-handlino of a letdown system prefilter, which resulted in significant contamination of the filter cubicle. In another instance, weak procedures (part of the poor planning noted above) contributed to the reactor trip during this assessment. The root cause of the reactor trip was considered by the SALP board to be an equipment malfunction with a breaker over-current trip device, coupled with poor mainte-nance plannin .
*


.
The licensee has apparently taken effective corrective action with respect to improving worker attitudes while working in safety-related areas. No instances were noted by the inspectors where worker actions had the potential to cause a challenge to a safety system. With the current outage, worker conditioning to the shutdown mode could easily be established again and, accordingly, management would need to enhance their attention to that area on subsequent plant startu Environmental qualification (EQ) issues generally appeared to be properly addressed in maintenance procedures. The NRC review of maintenance on Westinghouse 08-25/50 breaker over-current trip device retrofit work revealed that the EQ issues were properly addressed and maintenance was performed satisfactorily. However, the PAT found that the licensee's review of hydrogen recombiner blower motor work did not identify and address potential EQ issues associated with lubrication of the motors. For the latter event, it was determined that maintenance personnel and the responsible technical reviewers (RTR's) for maintenance procedures had a lack of knowledge of the EQ program requirements indicating the need for additional training in this are Procurement and storage of components were also examined in cetail during this perio The preventive maintenance program extends into this area also. No major problems were identified although shelf life determination for certain components was questioned due to the potential for degradation of some internal components of certain solenoid valve Internal reporting of maintenance-related events is weak. No Plant Incident Report (PIR) was generated when a technician accidentally caused a ground while working on RM-L-6 that resulted in a trip of one of the a.c. reactor trip breaker The PIR for the make-up filter drop addressed the specific concerns of the filter work but did not evaluate other areas in plant maintenance activities where similar situations could cause similar problems. The threshold for reporting of these types of of events appears to be relatively hig A more thorough and extensive .se of the PIR system would enhance performance in this are The licensee has a strong :ommitment to an effective housekeeping program and has been aggressive in maintaining the plant clean and free of transient combustibles. Continued daily involvement is maintained through middle management daily backshift tours and frequent inspections of the entire plant. Noted deficiencies were tracked and quickly corrected by the maintenance department. A positive attitude toward maintaining area cleanliness existed; also the licensee attempted to reduce the number of areas that require radiological work permits (RWP's) for entries. There is strong
          , Maintenance (260 hours, 10%)
i  Analysis The previous SALP rated the licensee's performance as Category 2, consistent. Overall, performance of me.intenance activities was good
;  -and reflected proper establishment, implementation, and staffing for j  the_ program. Some instances of weak implementation; such as, proce-dure adequacy and technical-support, were noted that required more-l  manageme.nt-involvement. Performance during the Once-Through Steam  :
  ' Generator (OTSG) eddy-current outage was good as evidenced by the   r accomplishment of a large workload with few problems. Problems occurred during restart where personnel, primarily those conducting-maintenance or modification work, were not aware of how their actions i  had the potential to cause a challenge to a safety system.


;   The preventive and corrective maintenance program qualities were
   - _ _ _ _ - _ ____- - _ _ - -__ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _
-
..
evidenced by the continuing good material condition of.the plant.
*


i  The motor-operated valve test program, which .is considered a    ;
emphasis in general employee training (GET) on the responsibility of each individual to maintain the plant clean. A similar philosophy is noted in licensee's approach in fire protection. Engineering involvement in inspections and program update has been note Hardware improvements continue to be performed to support full compliance with 10 CFR 50 Appendix Overall, performance of the maintenance activities has been well controlled. The organization, scheduling, and staffing of mainte-nance evolutions has not caused any major plant problems, except for contributing to the one reactor trip. Maintenance personnel are alert-to the changing conditions of the plant with respect to opera-tional condition Conclusion Category 1 Recommendations None
strength, has identified several valve' problems that resulted in
'
!  repairs; adjustments; and, in one situation, motor replacement.of a j  different size motor.to alleviate a situation with excessive opera-ting torque. There have been no forced outages or reactor trips that
'
!_  were directly attributable to poor equipment maintenance. Isolated l  events had poor maintenance planning as a contributing factor. NRC.


t  inspections of the high pressure injection (HPI) and decay heat
l
''
_ _ _ _ _ _ _ _ _ _ _ _ - _ _ -
removal valves indicated overall good maintenance practice and good i  material condition. The inspectors observed extensive quality
:  assurance department oversight in this area.


!-
. . . . . .. . .. - - - - - - - - .
:  The PAT II inspection determined that personnel were knowledgeable, l  . work was technically sound, and job tickets were appropriately prioritized. The failure trending program was effective in
.
,   identifying -components that require repetitive repair. The vendor
*
;;  manual control and update program is still in the process of being completed. An example of poor vendor manual control was identified 1  when an uncontrolled copy of a technical manual was used to calibrate i
17 Surveillance Testing (333 hours, 12.8%)
Bailey meter multiplier modules and signal monitors. The use of this l'  manual did not adversely affect the calibration.
Analysis During the previous SALP period, the licensee's performance was rated as Category 1. The licensee's surveillance program was adequate and aggressively implemented. Procedural weaknesses in the emergency feedwater system check valves and an inconsis-tency in the testing of the two vital battery banks was note These situations needed additional management attentio During this period, the licensee's surveillance program was exten-sively reviewed by NRC. The surveillance program continues to be a strength in the licensee's overall operation, with some minor excep-tions. Procedures are adequate and the computerized scheduling process continues to work well with no missed surveillances. A minor problem was noted with surveillance procedure change approval dates versus implementation times to be specified. The licensee program for controlling this process is still in the process of being changed so that approved procedure changes will have sufficient time to be issued in the field prior to their required use. With respect to inservice testing of pumps and valves, a number of programmatic issues remain open and are longstanding. Program enhancement in the area has been stifled or has been excessively delayed for test items not requiring major plant modification because of performance problems in the licensing area (see Section IV.J).


i.
Procedure implementation in the past has generally been a strong point in the licensee's program. A review of instrument calibration with respect to recording "as-found" data (e.g., the static 0-ring pressure switch problem) revealed good practices in this area. There was generally good planning and pursuit of alternative approaches when problems were encountered with calibration of the boric acid mix tank (BAMT) level instrumentation. Implementation problems with a
 
,
i  Maintenance procedures generally continue to be adequate to properly
particular engineered safety features surveillance are addressed in the plant operations functional area. During the shutdown /cooldown evolution at the end of the SALP period, the conduct of several long complicated surveillances was accomplished in an orderly and controlled manne The reactor building tendon surveillance program report was I adequately prepared and reflected a complete test program in this are The PAT review of numerous procedures revealed no major weaknesses or problems. Periodic review of completed procedure Exception and Deficiency (E&D) sheets also confirmed that surveillance procedures can be performed with few exceptions. One minor problem involving an incomplete technical review was identified with the reactor vessel internals vent valve surveillanc _ _ _ _ _ _ _ _ - _ _ _ _ .
'
control work on safety-related components. Two procedure weaknesses
-
were identified that caused problems. One instance involved mis-4  handling of a letdown system prefilter, which resulted in significant I  contamination of the filter cubicl In another instance, weak j  procedures (part of the poor planning noted above) contributed to the reactor trip during this assessment. The root cause of the reactor
!  trip was considered by the SALP board to be an equipment malfunction
'  with a breaker over-current trip device, coupled with poor mainte-
!
nance planning.
:
!
k i
i i
L .- , . _ _ , _ , _ ,  - _ . _ _ -,- ,, _ ...-.,., _ _ ... _ ._ _ _ _ _._ _.. _ _


  -_ _ - - _ _ - _ _ - - - _ - _ _ - _ _
!
  .
  .
  .
h'
l*- l-L Overal.1, the surveillance program is considered a strength. Poor performance in the licensing area'is negatively affecting the -
inservice testing program. There is respect for the use and proper I' implementation of surveillances. Procedural weaknesses are rare and previous problems appear to have been correcte Conclusion Category 1
  <
Recommendations None i
l I
l I
      .
_ _ _ _ . _ _ _ . . _ _ . _ _ _ _ . _ _ _ _ . - . . . . . - . _


The licensee has apparently taken effective corrective action with respect to improving worker attitudes while working in safety-related areas. No instances were noted by the inspectors where worker actions had the potential to cause a challenge to a safety system. With the current outage, worker conditioning to the shutdown mode could easily be established again and, accordingly, management would need to enhance their attention to that area on subsequent plant startu Environmental qualification (EQ) issues generally appeared to be properly addressed in maintenance procedures. The NRC review of maintenance on Westinghouse 08-25/50 breaker over-current trip device retrofit work revealed that the EQ issues were properly addressed and maintenance was performed satisfactorily. However, the PAT found that the licensee's review of hydrogen recombiner blower motor work did not identify and address potential EQ issues associated with lubrication of the motors. For the latter event, it was determined that maintenance personnel and the responsible technical reviewers (RTR's) for maintenance procedures had a lack of knowledge of the EQ program requirements indicating the need for additional training in this are Procurement and storage of components were also examined in detail during this period. The preventive maintenance program extends into this area also. No major problems were identified although shelf life determination for certain components was questioned due to the potential for degradation of some internal components of certain solenoid valves.
a
 
.
Internal reporting of maintenance-related events is weak. No Plant Incident Report (PIR) was generated when a technician accidentally caused a ground while working on RM-L-6 that resulted in a trip of one of the a.c. reactor trip breakers. The PIR for the make-up filter drop addressed the specific concerns of the filter work but did not evaluate other areas in plant maintenance activities where similar situations could cause similar problems. The threshold for
*
*
reporting of these types of of events appears to be relatively high.
19 Emergency Preparedness (:7 hours, 1.4%)
Analysis During the SALP I assessment period, the licensee was rated as Category 1 in the area of emergency preparedness. This assessment was based on observation of the Federal Emergency Management Agency (FEMA) full participation exercise, which included NRC response team participation held on November 20, 1985. The licensee's execution and participation during the exercise demonstrated thorough planning and a strong commitment to emergency preparednes During this assessment period, there was a two part routine inspec-tion conducted on the recent consolidation of the three plant emer-gency plans (TMI-1, TMI-2, and Oyster Creek) into one GPU Nuclear Corporate plan. This consolidation is intended to standardize approaches to emergency response at all three plants. NRC review of the emergency plan consolidation indicated that generic information for the three sites had been combined, extraneous information elimi-nated, and essential plan elements (letters of agreement, evacuation time estimates) referenced. No decrease in the overall effectiveness of the plan had occurred and the plan continues to meet the require-ments of 10 CFR 50, Appendix E. The consolidation effort appears to be effective in providing a unified approach to emergency prepared-ness. No significant problems arose from the implementation of this new plan during the November 1986 exercise (which occurred outside this assessraent period).


l A more thorough and extensive use of the PIR system would enhance
The licensee continues to demonstrate a strong commitment to emer-gency preparedness. The emergency preparedness staff has been increased both in numbers and experience. The licensee has committed to do more unannounced drills and exercises per year and emergency preparedness training has been enhanced, which provides more depth and more trained personnel for emergency response. Quality Assurance audits of emergency preparedness activities are comprehensive and are reviewed by appropriate corporate officer The licensee has permitted local area fire fighters to use the licensee's " burn building" for training. This has made a positive contribution to local fire fighter preparedness to support an emer-gency at TMI. This reflects the licensees' commitment and initiative to emergency preparednes Emergency plans and implementing procedures are curren FEMA final review and approval of off-site plans will not be complete until next year; however, the delay is not attributable to the license .
; performance in this area.
*


i l The licensee has a strong commitment to an effective housekeeping i
Conclusion Category 1 Recommendations None
'
!
program and has been aggressive in maintaining the plant clean and free of transient combustibles. Continued daily involvement is
!
! maintained through middle management daily backshift tours and ( frequent inspections of the entire plant. Noted deficiencies were l tracked and quickly corrected by the maintenance department. A l positive attitude toward maintaining area cleanliness existed; also the licensee attempted to reduce the number of areas that require radiological work permits (RWP's) for entries. There is strong L    ,____
!
 
;
.
!
.
,
I I
r l
:
i


_ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ __
.
.
emphasis in general employee training (GET) on the responsibility of each individual to maintain the plant clean. A similar philosophy is noted in licensee's approach in. fire protection. Engineering involvement in inspections and program update has been note Hardware improvements continue to be performed to support full compliance with 10 CFR 50 Appendix Overall, performance of the maintenance activities has'been well controlled. The organization, scheduling, and staffing of mainte-nance evolutions has not caused any major plant problems, except for contributing to the one reactor trip. Maintenance personnel are alert to the changing conditions of the plant with respect to opera-tional condition Conclusion Category 1 Recommendations None
-
!
L
    -.
      .
  . . - - - . - . . . -.-_ .-- ,- .
 
.
.
 
D. Surveillance Testing (333 hours, 12.8%)
Analysis
'
'
During the previous SALP period, the licensee's performance was rated as Category 1. The licensee's surveillance program was adequate and aggressively implemented. Procedural weaknesses in the emergency feedwater system check valves and an inconsis-tency in the testing of the two vital battery banks was note These si.tuations needed additional management attentio During this period, the licensee's surveillance program was exten-sively reviewed by NRC. The surveillance program continues to be a strength in the licensee's overall operation, with some minor excep-tions. Procedures are adequate and the computerized scheduling process continues to work well with no missed surveillances. A minor problem was noted with surveillance procedure change approval dates versus implementation times to be specified. The licensee program for controlling this process is still in the process of being chang;d so that approved procedure changes will have sufficient time to be issued in the field prior to their required use. With respect to inservice testing of pumps and valves, a number of programmatic issues remain open and are longstanding. Program enhancement in the area has been stifled or has been excessively delayed for test items not requiring major plant modification because of performance problems in the licensing area (see Section IV.J).
21 Security / Safeguards (78 hours, 3.1%)
Analysis During the previous SALP pericd, the licensee's performance in this area was Category 2. The rating was influenced by a long-standing issue involving the perimeter intrusion detection system and a repetitive vic,lation on badge contro During 'this assessment period, one unannounced physical security .
. inspection and one material control and accountability inspection were performed by region-based inspectors, an NRC Regulatory Effec-tiveness Review (RER) was conducted, and routine resident inspections were performed throughout the period. Although no violations were identified, the RER tean identified several program vulnerabilitie Most of these were immediately corrected by the licensee; compensa-tory measures were taken for the remaining items since they may require more significant action to correc Both site and corporate management are actively involved in planning for current and long-term security program needs. Efforts to improve the quality of security operations are evident in the licensee's use of a self-inspection program and the accomplishment of comprehensive corporate audit Both the self-inspections and corporate audits are conducted by qualified personnel with extensive background and experience in physical security and focus on compliance with the licensee's commitments contained in the NRC-approved security program plans and their implementing procedures. Although the inspections and audits have significantly enhanced compliance (no violations of NRC requirements during this period), by being too compliance oriented they may overlook alternative means of improving the program. For example several of the problems found by the RER team should have been prev.ausly identified and corrected by the license The lack of this identification indicated either a need for a better understanding of NRC security program objectives by the licensee or a broader focus during audits to include program objective The licensee's Nuclear Security Director continues to be actively involved in matters affecting the program; e.g., frequent staff assistance visits, sponsorship of experienced audit team members, and participation in program implementation, modifications, and major upgrade plans. That level of involvement is indicative of senior management's interest in establishing and maintaining a quality security program. The Nuclear Security Director is also actively involved in the Region I Nuclear Security Association and other industry groups 2ngaged in addressing issues in the nuclear plant security are The licensee has implemented a " fitness for duty" program, which includes statements regarding the use of drugs and alcohol. The program requires employee scraening upon initial


Procedure implementation in the past has generally been a strong point in the licensee's program. A review of instrument calibration with respect to recording "as-found" data (e.g., the static 0-ring pressure switch problem) revealed good practices in this area. There was generally good planning and pursuit of alternative approaches when problems were encountered with calibration of the boric acid mix tank (BAMT) level instrumentation. Implementation problems with a particular engineered safety features surveillance are addressed in the plant operations functional area. During the shutdown /cooldown evolution at the end of the SALP period, the conduct of several long complicated surveillances was accomplished in an orderly and controlled manne The reactor building tendon surveillance program report was adequately prepared and reflected a complete test program in this are The PAT review of numerous procedures revealed no major weaknesses or problems. Periodic review of completed procedure Exception and Deficiency (E&D) sheets also confirmed that surveillance procedures can be performed with few exceptions. One minor problem involving an incomplete technical review was identified with the reactor vessel internals vent valve surveillance, i
    -
  . . _ _ _ _ __ - -
., _
    .__ . .- _
''


_ _ _ . ._ _ . _ __. .
hire with the company. Additionally, requirements are placed on contract organizations to screen their personnel prior to employmen The licensee has instituted a random screening process at the department head level and abov Program enhancements implemented during this period included the updating of a Civil Disorder Plan, and the expansion of security organization policies to address such subjects as NRC Information Notices, Circulars, fitness for duty, uniform and appearance standards, and media matters. Another enhancement undertaken involves the contingency plan dril'. program. To ensure a more mean-ingful drill program, the number of required drills has been increased by the licensee and the drill scenarios are prepared by the security supervisors and approved in advance by management to ensure variations in the scenarios and exposure of all security force members to different scenarios. Critiques are performed for all drills and the results documented for feedback into the program. Any deficiencies identified during a drill, including personnel errors, result in the same drill being repeated until performance is accom-plished consistent with plan and procedural requirement These self-imposed criteria reflect the licensee's effort to improve the quality of training in order to be better prepared for contingency event Staffing of the security organization was observed to be consistent with the commitments in the NRC-approved security plan and adequate for the workload. Authority and responsibility were effectively organized among management and supervisory personnel and security force members were observed to be knowledgeable of their assigned duties and responsibilitie Facilities were found to be well maintained with sufficient space allocated for the operational needs of the program, as well as for both management and supervisio The design layout of equipment in the Central Alarm Station (CAS) incorporated human factors considera-tions that facilitates the CAS operator's ability to interface with other members of the security force and plant groups. Records were well maintained and readily accessible with repositories located and secured in accordance with safeguards information requirement Sufficient administrative, technical and logistical resources were allocated to provide support to the program. These factors are indicative of management attention to and oversight of the progra Although no required event reports were submitted to NRC during this assessment period, it was noted that the licensee's event reporting procedures and policies were consistent with the require-ments of 10 CFR 73.71. Personnel were found to be knowledgeable of their responsibilities in this area, including when reports are required and how and when to employ compensatory measures. The liccnsee's program for identifying and reporting security events was considered adequat O
..
*
M
  '3 The training program continued to be effective as evidenced by no problems related to security personnel parformance during this assessment period. The training of the security organization continued to improve during this assessment period. The licensee's initiatives with regard to contingency drills are noteworthy and should improve the professional capability of the security forc With regard to control and accounting practices for special nuclear materials, the licensee was found to be in compliance with NRC requirement Procedures were generally understood and carried out by the responsible personnel. Records and reports were generally complete, well maintained, and avail-able. While the submittal of several material transaction reports was tardy due to a misinterpretation or misunderstand-ing of the directions associated with accounting for inventory changes, implementation of the program was judged as adequat During this assessment period, the licensee submitted a complete revision to the Contingency Plan in accordance with the provision of 10 CFR 50.54(p). This revision was reviewed by Region I and deter-mined to be acceptable. A summary of changes was provided with the revision to describe each change and pages were marked to identify areas changed to facilitate revie However, the summary was brief and, in a few cases, did not fully describe each change. That revision, as well as others under 10 CFR 50.54(p), are routinely being transmitted to NRR rather than to Region I, as required, causing unnecessary delays in the licensing review proces Generally, the quality of the submittals continues to be improve The prior SALP report, covering the period September 16, 1985, to April 30, 1986, idertified a longstanding safeguards licensing issue regarding the perimeter intrusion detection system (PIDS). The licensee has finally committed to accomplish this PIDS project by December 1987. Management attention is needed to assure that this completion date is met and to preclude such longstanding issues in the futur In summary, the licensee continued to make improvements to the security and safeguards areas during this assessment perio Increases in the program direction, management involvement and over-sight, and effective training were evident throughout the assessment period. Resolution of the outstanding intrusion detection system issue and management attention to preclude longstanding issues in the future will further enhance the total effectiveness of the security progra The security program, which appears to be very compliance oriented, could be enhanced by a more pro-active perspective and broader approach in light of the RER finding _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
...
 
Overall, the surveillance program is considered a strength. Poor
, performance in the licensing area is negatively affecting the inservice testing program. There is respect for the use and proper implementation of surveillances. Procedural weaknesses are rare and previous problems appear to have been correcte Conclusion Category 1          -
Recommendations None
            ,
u
 
4
 
5
 
!
I
_- - . - _ , _ . _ _ _ . . . - _ _ _ _ _ _ . . . . . _ . . _ _ _ , _ _ _ _ _ _ _ . _ . . _ . . _ _ _ _ _ . _ _ _ _ , _ - . _ _ . , _ _ _ - . . . _ . .
 
-.
  .
  .
''


E. Emergency Preparedness (37 hours, 1.4%)
Conclusion Category 2, improving Recommendations i
Analysis During the SALP I assessment period, the licensee was rated as Category 1 in the area of emergency preparedness. This assessment was based on observation of the Federal Emergency Management Agency (FEMA) full participation exercise, which included NRC response team participation held on November 20, 1985. The licensee's execution and part.icipation during the exercise demonstrated thorough planning and a strong commitment to emergency preparednes During this assessment period, there was a two part routine inspec-tion conducted on the recent consolidation of the three plant emer-gency plans (TMI-1, TMI-2, and Oyster Creek) into one GPU Nuclear Corporate plan. This consolidation is intended to standardize approaches to emergency response at all three plants. NRC review of the emergency plan consolidation indicated that generic information for the three sites had been combined, extraneous information elimi-nated, and essential plan elements (letters of agreement, evacuation time estimates) referenced. No decrease in the overall effectiveness of the plan had occurred and the plan continues to meet the require-ments of 10 CFR 50, Appendix E. The consolidation effort appears to be effective in providing a unified approach to emergency prepared-ness. No significant problems arose from the implementation of this new plan during the November 1986 exercise (which occurred outside this. assessment period).
None I


The licensee continues to demonstrate a strong commitment to emer-gency preparedness. The emergency preparedness staff has been increased both in numbers and experience. The licensee has committed to do more unannounced drills and exercises per year and emergency preparedness training has been enhanced, which provides more depth and more trained personnel for emergency response. Quality Assurance audits of emergency preparedness activities are comprehensive and are
  .
>
_ _ _ _ _ _ _ _  _ _ _ _ _ _ _ . _  _
reviewed by appropriate corporate officer The licensee has permitted local area fire fighters to use the licensee's " burn building" for training. This has made a positive contribution to local fire fighter preparedness to support an emer-gency at TMI. This reflects the licensees' commitment and initiative to emergency preparednes Emergency plans and implementing procedures are curren FEMA final review and approval of off-site plans will not be complete until next >
year; however, the delay is not attributable to the licensee.


k
_ _ _ ._ .
 
  -
u
  *
  ~
25 Technical Support (567 hours, 21.8%)
 
Analysis The SALP I found a well-established modification control program but full implementation was not achieved. There were suspected programmatic weaknesses that would be reviewed by PAT II and other inspections during the SALP-II period. For modifications, the SALP I found poor supervision, lack of attention to detail in properly following applicable procedures, and poor technical / safety reviews. With respect to technical support for plant operational problems, the SALP I noted strengths in the highly i
.
visible items; such as, TMI-1 restart testing. However, technical support on routine and apparently less significant problems at the corporate and the site levels was weak. In plant and on-site control of outage work was good during the SALP I perio The licensee's modification control program was extensively reviewed by PAT II, except for a detailed engineering analysis of selected design
20 j i
'
Conclusion !
changes (conducted by PAT'I). The team noted significant improvement in the program subsequent to PAT I/SALP I findings. Applicable procedures had been reviewed and revised by the licensee to provide more explicit requirements. As an example, design verification procedures were revised to assure the verification process occurred before or at the time of modification turnover to the TMI-1 Division. Substantial training was
l
'
  '
conducted on these program revisions and in applicable regulatory requi rer.:ents .
Category 1 Recommendations None i
Regarding niodification control procedures, the frequent use of vague wording detracts from clarity and self-assessment and it has resulted in the above-noted problems. Management attention to the clarity of these
.
.
 
types of procedures was apparently lackin The " Mini Mods" program was noted to be a licensee initiative to reduce inefficiencies without bypassing regulatory requirements for the instal-lation of minor safety grade modifications. Another recognized licensee initiative was the consolidation of modification control procedures at the corporate level, since plant engineering personnel must essentially use those procedures for work accomplished by them. However, weaknesses were noted in procedures governing plant modifications engineered by plant engineering. These weaknesses were: lack of definitive criteria or what
I I
!  constitutes a replacement in kind; lack of a systematic process of assur-ing that replacement components conformed to detailed design specifica-tions (apparently left to discretion of plant engineer); lack of engineer-ing review of test data for modifications initiated by plant engineering; and, based on a review of implementation, insufficient support of technical / safety review assumptions.
 
  -
___  - .m _ _ _ .
  :-
  ...
21 Security / Safeguards (78 hours, 3.1%)
Analysis During the previous SALP period, the licensee's performance in  ;
this area was Category 2. The' rating was influenced by a long-standing ' issue involving the perimeter intrusion detection system and a repetitive violation on badge contro ,
During this assessment period, one. unannounced physical security inspection and one material control.and accountability inspection  L were performed by region-based inspectors, an NRC Regulatory Effec .
tiveness-Review (RER) was conducted, and routine resident inspections were performed throughout the period. Although no violations were identified, the RER team identified several program vulnerabilitie Most of these were immediately corrected by the licensee; compensa-tory measures were taken for the remaining items since they may require more significant action to correc Both site and corporate management are actively involved in planning for current and long-term security program needs. Efforts to improve the quality of security operations are evident in the licensee's use of a self-inspection program and the accomplishment of comprehensive corporate audits. Both the self-inspections and corporate audits are-conducted by qualified personnel with extensive background and experience in physical security and focus on compliance with the licensee's commitments contained in the NRC-approved security program plans and their implementing procedures. Although the inspections and audits have significantly enhanced compliance (no violations of NRC requirements during this period), by being too compliance oriented they may overlook alternative means of improving the program. For. example, several of the problems found by the RER team snould have been previously identified and corrected by the license The lack of this identification indicated either a need for a better understanding of NRC security program objectives by the licensee or a-breader focus during audits to include program objective The licensee's Nuclear Security Director continues to be actively involved in matters affecting the program; e.g., frequent staff assistance visits, sponsorship of experienced audit team members, and participation in program implementation, modificaticns, and major upgrade plans. That level of involvement is indicative of senior management's interest in establishing and maintaining a quality security program. The Nuclear Security Director is also actively involved in the Region I Nuclear Security Association and other industry groups engaged in addressing issues in the nuclear plant
; security area.


''
The licensee has implemented a " fitness for duty" program,
.-
which includes statements regarding the use of drugs and
'
'
alcohol. The program requires employee screening upon initial
In general, procedures associated with the modification control program were properly implemente However, persistent problems continued to be i
        ,
noted in drawing control and self review. The following drawing control problems were noted: inaccuracies in controlled hard copy drawings
  .,. v-., ,. , ,. , , - - - , . . + - , w, n -,.,--w,-r , -._.__--.-n..,n.- ~-_..n.n. , , - - -.-. , , .--
!
  , _ . . . - . . - - , - - - - . - . - - . - - - - . = . - - - _ - -. -


  ..
    ._
  .
  .
  .
  :  9 T
  *
$,.
 
hire with the company. Additionally, requirements are placed on contract organizations to screen their personnel _ prior to employment. The licensee has instituted a random screening process at the department head level and abov Program enhancements implemented during this period included the updating of a Civil Disorder Plan, a'nd the' expansion of security organization policies to address such subjects as NRC Information Notices, Circulars, fitness for duty, uniform and appearance
, standard.s, and media matters. An5ther enhancement undertaken i
involves the contingency plan drill progra To ensure a more mean-ingful drill program, the number of required drills has been l increased by the licensee and the drill scenariostare prepared by the security supervisors and approved in advance by management to ensure variations in the scenarios and exposure of all security force members to different scenarios. Critiques are performed for all
. drills and the results documented for feedback into the program. Any deficiencies identified during a drill, including personnel errors, result in the same drill being repeated until performance is accom-plished consistent with plan and procedural requirements. These self-imposed criteria reflect the licensee's effort to improve the quality of training in order to be better prepared for contingency event .
Staffing of the security organization was observed to be consistent with the commitments in the NRC-approved security. plan and adequate for the workload. Authority and responsibility-were effectively organized among management and supervisory personnel and security force members were observed to be knowledgeable of their assigned duties and responsibilitie Facilities were found to be well maintained with sufficient space allocated for the operational needs of the program, as well as for both management and supervision. The design layout of equipment in the Central Alarm Station (CAS) incorporated human factors considera-tions that facilitates the CAS operator's ability to interface with other members of the security force and plant groups. Records were well maintained and readily accessible with repositories located and secured in accordance with safeguards information requirement Sufficient administrative, technical and logistical resources were allocated to provide support to the program. These factors are indicative of management attention to and oversight of the progra Although no required event reports were submitted to NRC during this assessment period, it was noted that the licensee's event reporting procedures and policies were consistent with the require-ments of 19 CFR 73.7 Personnel were found to be knowledgeable of thei* responsibilities in this area, including when reports are required and how and when to employ compensatory measures. The licensee's program for identifying and reporting security events was considered adequat , , - .


  (including several control room drawings); excessiva delays in updating operations card drawings, which needed verification on updated status upon use; and, inaccuracies with the computer-based assistance system because of excessive delays in updating the computer file upon issuance of con-figuration changes. These problems could result in the use of outdated drawings to conduct design or operational activities. No instances of outdated procedure use were note The QA audits in this area subsequent to PAT I identified no discrepancies in this area. Overall, it appears that the corporate and site drawing control systems are not welt defined in a consistent set of procedures. Further, resources appear to be strained in this area. This resource problem in drawing control is a repetitive and longstanding issue at TMI-1. The PAT II team noted that knowledgeable personnel had difficulty in resolving obvious drawing dis-crepancy problems identified by PAT team members while using the licensee's control drawing system. The complexity of the system is high-lighted by another manually kept transaction file being used to complement the computer-based system for the current "as built" configuration of the plant. It would be unlikely that less familiar personnel who have to use this system on a routine basis would have the ability and patience to resolve obvious problems, considering schedular or operational pressure .
Also, the licensee self-review processes were weak to not identify these and other problems in advance of NRC staff inspections. For example, Technical Functions (TF) procedures were declassified from the Quality Assurance Plan (QAP) definitions of "important to safety" and "not important to safety". As a result, a different review process was in place and many
,
,
a
of the (TF) procedures governing the modification control program did not require safety review. This area will be discussed in a forthcoming meeting between NRC staff and the license The NRC staff review on the Environmental Qualification (EQ) of a certain cable types identified continued problems with EQ files. During NRC staff follow-up to PAT I concerns on the Kerite FR cable, the licensee was able to establish qualifications but minor errors in the EQ files were noted, necessitating licensee issuance of a design document revision. Related to this review was NRC staff follow-up on EQ concerns for BIW cable. The EQ
 
The training program continued to be effective as evidenced by no problems related to security personnel performance during this assessment period. The training of the security organization continued to improve during this assessment period. The licensee's initiatives with regard to contingency drills are noteworthy and should improve the professional capability of the security forc With regard to control and accounting practices for special nuclear materials, the licensee was found to be in compliance with NRC requirements. Procedures were generally understood and carried out by the responsible personnel. Records and reports were generally complete, well maintained, and avail-able. While the submittal of several material transaction reports was tardy due to a misinterpretation or misunderstand-ing of the directions associated with accounting for inventory changes, implementation of the program was judgea as adequat During this assessment period, the licensee submitted a complete revision to the Contingency Plan in accordance with the provision of 10 CFR 50.54(p). This revision was reviewed by Rdgion I and deter-mined to-be acceptable. A summary of changes was provided with the
' revision to describe each change and pages were marked to identify areas changed to facilitate revie However, the summary was brief and, ir a few cases, did not fully describe each change. That revision, as well as others under 10 CFR 50.54(p), are routinely being transmitted to NRR rather than to Region I, as required, causing unnecessary delays in the licensing review proces Generally, the quality of the submittals continues to be improve The prior SALP report, covering the period September 16, 1985, to April 30, 1986, identified a longstanding safeguards licensing issue regarding the perimeter intrusion detection system (PIDS). The licensee has finally committed to accomplish this PIDS project by December 1987. Management attention is needed to assure that this completion date is met and to preclude such longstanding issues in the futur In summary, the licensee continued to make improvements to the security and safeguards areas during this assessment perio Increases in the program direction, management involvement and over-sight, and effective training were evident throughout the assessment period. Resolution of the outstanding intrusion detection system issue and management attention to preclude longstanding issues in the future will further enhance the total effectiveness of the security progra The security program, which appears to be very compliance oriented, could be erhanced by a more pro-active perspective and broader approach in light of the RER finding ._. .  .  .. . . .. ._. _ _ ._ .
  .
  .
for this cable is still under NRC staff review because the licensee attempted to qualify the cable by analysis, not type testing. The EQ file lacked sufficient justification for this analysis so that a knowledgeable
  .
  .
individual could independently conclude on qualifications. The above-l  noted errors and lack of significant documentation in the EQ files are a repetitive proble Training of engineering personnel involved in modification has been improved. In conjunction with the procedure revisions since SALP I, engineer training on these procedure revisions was conducted. Based on engineer interviews, there was positive feedback to NRC staff members on the training. This training was oriented toward the root cause of problems identified in the last SALP and at addressing the
,  source of base regulatory requirements such as applicable ANSI Standards on the design control area. It appeared that this was the
._
- - . _ . - - .  - - - - - , - - - - . - - - . _ - - - - - - - , . ~ ,


Conclusion Category 2, improving Recommendations None l
.
l
*
_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _


.
first such training for many, even senior, engineers other than indoctri-nation reading of applicable modification control procedures that engineers would potentially use. It appears that the recently conducted training will be factored into future new or refresher training sessions for new and experienced engineers. The Technical Personnel and Management Training area was not accredited by INPO as of the end of the SALP perio Past training weaknesses were a contributing factor in the cause of per-formance problems noted in the last SALP. Licensee management has shown initiative in being very supportive of outside professional development training. They also support owner group technical committees, which enhance the licensee's knowledge of the B&W design and related technical problems. Continued management attention to engineering training is neede Technical support to routine operational problems appears to have improved over the period at both the corporate and site levels. However, this was a somewhat less challenging period in that the intensive support needed for the TMI-1 restart and test program was lessened. Further, major operational problems have been minimal. Technical support problems occurred but they seemed to be minor and were related to communication difficultie Technical support for the refueling outage also appears to be adequat Some engineering delays were evident and have resulted in a relatively large amount of submittals needed to be submitted to NRC staff in the November-December 1986 time period to support needed NRC action for fuel movement or Cycle 6 startup activities. Pre-outage meetings on site started several months before the start of the refueling outage. Action items are tabulated on a computer-based file to permit various sorting and to enhance management attention to problem areas such as redesign work and procurement schedular problems. Overall, the licensee appears to have prepared adequately for the refueling outag In summary, the modification control program was well established and has improved but certain controlling procedures reflect weaknesse This lack of clarity and definitiveness in modification-controlling pro-cedures puts an undue burden on the discretion of individuals despite their high qualification and improved training. Implementation problems persist such as in the areas of drawing control and EQ. Overall, tech-nical support for routine operational problems appears to be appropriate; but it did not appear to be severely taxed during this period. Good overall preparations occurred for the refueling outag _ _
.
    . - . _
 
G. Technical Support (567 hours, 21.8%)
Analysis The SALP I found a well-established modification control program but full implementation was not achieved. There were suspected programmatic-weaknesses that would be reviewed by-PAT II and other inspections during the SALP II period. For modifications, the SALP I found poor supervision, lack of attention to detail in properly following applicable procedures, and poor technical / safety reviews. With respect to tec.hnical support for plant operational problems, the SALP I noted strengths in the highly visible items; such as, TMI-1 restart testing. However, technical support on routine and apparently less significant problems at the corporate and the site levels was weak. In plant and cn-site control of outage work was good during the SALP I perio The Itcensee's modification control program was extensively reviewed by PAT II, except for a detailed engineering analysis of selected design changes (conducted by PAT I). The team noted significant improvement in the program subsequent to PAT I/SALP I findings. Applicable procedures had been reviewed and revised by the licensee to provide more explicit requirements. As an example, design verification procedures were revised to assure the verification process occurred before or at the time of modification turnover to the TMI-1 Division. Substantial training was conducted on these program revisions and in applicable regulatory requirement Regarding modification control procedures, the frequent use of vague wording detracts from clarity and self-assessment and it has resulted in the above-noted problems. Management attention to the clarity of these types of procedures was apparently lacking.


.
.
The " Mini Mods" program was noted to be a licensee initiative to reduce
*
!
inefficiencies without bypassing regulatory requirements for the instal-lation of minor safety grade modifications. Another recognized licensee initiative was the consolidation of modification control procedures at the corporate level, since plant engineering personnel must essentially use
; those procedures for work accomplished by them. However, weaknesses were l noted in procedures governing plant modifications engineered by plant i engineering. These weaknesses were: lack of definitive criteria or what l constitutes a replacement in kind; lack of a systematic process of assur-ing that replacemant components conformed to detailed design specifica-tions (apparently left to discretion of plant engineer); lack of engineer-ing review of test data for modifications initiated by plant engineering; and, based on a review of implementation, insufficient support of technical / safety review assumption In general, procedures associated with the modification control program i were properly implemented. However, persistent problems continued to be i noted in drawing control and self review. The following drawing control l problems were noted: inaccuracies in controlled hard copy drawings i
!
yW  - --ayee


.
Conclusion Category 2 Recommendations Licensee:
.
Undertake a self-analysis to determine the causes for inconsistent performance within this are NRC:
Conduct a team inspection of technical support groups with an emphasis on determining the causes of inconsistent performanc "
29 Training and Qualification Effectiveness Analysis-The various aspects of this functional area have been considered and i discussed as an integral part of other functional areas and the respective inspection hours have been included in each of the other functional areas. Consequently, this discussion is a synopsis of the assessment related to the training conducted in other functional areas. Training effectiveness has been measured primarily by observed performance of licensee's personnel and, to a lesser degree, by a review of the program adequacy. The discussion below, thus, addresses the training attributes and weaknesses as noted throughout all functional areas and the effect that these have on the overall safe operation of the plan During the previous assessment, the licensee performance was rated as Category 1. The training program was effective and oriented toward safe plant operations. Personnel were knowledgeable of plant work activities, procedural requirements, and, in general, conducted plant evolutions with care. Accreditation from the Institute of Nuclear Plant Operations (INP0) was received in five areas as of the end of the SALP perio No licensed operator exams were administered during this assessment period. The training programs were reviewed from a performance viewpoint in distinction to a programmatic viewpoint. Particular focus occurred on engineer training in light of past performance problems noted in the last SALP. The plant specific simulator was received near site and placed into a testing phase which should be completed by the end of 1986. Also, an INPO site visit occurred which should result in INPO accreditation for all ten area The NRC interviews of licensee's engineers confirmed that they are well qualified and technically traine They were experienced individuals and they were knowledgeable in the areas of their responsiblity. They felt that they had sufficient training to per-form the jobs that they did. They confirmed that the licensee management was supportive of formalized internal courses and outside courses. Many recognized the training aspect of their participating l in the B&W Owners' Group activities, which was also fully supported by the license From the previous assessment period, a weakness of engineers to fully understand related regulatory requirements and to follow procedures rigorously was note These weaknesses appear to be attributed to lack of specific training in this area. Based on review of the training program during this assessment period, it aopears that the performance in this area has improved and appropriate planned actions by licensee successfully corrected these deficiencie .
,-


(including several control room drawings); excessive delays in updating operations card drawings, which needed verification on updated status upon use; and, inaccuracies with the computer-based assistance system because of excessive. delays in updating the computer file upon issuance of con-figuration changes. These problems could result in the use of outdated drawings to conduct design or operational activities. No instances of .
The licensee's operator training and requalification training programs function well as evidenced by the licensee's performance during plant operations. Few events were attributed to operator /
outdated procedure use were noted. The QA audits in this area subsequent to PAT I identified no discrepancies in this area. Overall, it appears that the corporate and site drawing control systems are not well defined in a consiste.nt set of procedures. Further, resources appear to be strained in this area. This resource problem in drawing control is a repetitive and longstanding issue at TMI-1. The PAT II team noted that knowledgeable personnel had difficulty in resolving obvious drawing dis-crepancy problems identified by PAT team members while using the licensee's control drawing system. The complexity of the system is high-lighted by ano*her manually kept transaction file being used to complement the computer-based system for the current "as built" configuration of the plant. It would be unlikely that less familiar personnel who have to use this system on a routine basis would have the ability and patience to resolve obvious problems, considering schedular or operational pressure Also, the licensee self-review processes were weak to not identify these and other problems in advance of NRC staff inspections. For example, Technical Functions (TF) procedures were declassified from the Quality Assurance Plan (QAP) definitions of "important to safety" and "not important to safety". As a result, a different review process was in place and many of the (TF) procedures governing the modification control program did not require safety review. This area will be discussed in a forthcoming meeting between NRC staff and the license The NRC staff review on the Environmental Qualification (EQ) of a certain cable types identified continued problems with EQ files. During NRC staff follow-up to PAT I concerns on the Kerite FR cable, the licensee was able to establish qualifications but minor errors in the EQ files were noted, necessitating licensee issuance of a design document revision. Related to this review was NRC staff follow-up on EQ concerns for BIW cable. The EQ for this cable is still under NRC staff review because the licensee attempted to qualify the cable by analysis, not type testing. The EQ file lacked sufficient justification for this analysis so that a knowledgeable individual could independently conclude on qualifications. The above-noted errors and lack of significant documentation in the EQ files are a repetitive proble Training of engineering personnel involved in modification has been improved. In conjunction with the procedure revisions since SALP I, engineer training on these procedure revisions was conducted. Based on engineer interviews, there was positive feedback to NRC staff members on the training. This training was oriented toward the root cause of problems identified in the last SALP and at addressing the source of base regulatory requirements such as applicable ANSI Standards on the design control area. It appeared that this was the
training deficiencies. A noted strength of the licensee's training program is their pre-job briefings that are conducted by senior reactor operators (SRO's) or control room operators (CR0's) prior to conducting a special evolution in the plant. Discussions are held prior to the evolutions and, in most cases, contributed to successful completion of special evolutions in a safe and timely manner. An example of this is troubleshooting the integrated control system (ICS). This required the licensee to place many stations in manual mode and the operators received additional training prior to doing that to assist them in assuring that they maintained the plant in a safe condition. As noted below, there were isolated lapses in conservatism exhibited by licensed operator The licensee's training program for both licensed and non-licensed personnel is strong when dealing with reactor plant systems. Some weaknesses, however, have been noted in the training in the area of balance of the plant. In response to a balance of plant electrical bus loss and, apparently, in order to prevent a reactor trip, licensed operators attempted to re-energize these busses from a safety bus without fully knowing the cause of the electrical malfunction. Further, operations department handling of a change to procedures reflecting the licensed power limit was not conservativ The licensee's ability to maintain operators and technicians in six rotating sections, allowing one section to be in training status is also noted as a strong attribute in their training program. Review of the training that is performed demonstrates adequate in-depth knowledge is being gained by both non-licensed and licensed training operator In addition, prior to conducting a large or difficult maintenance job, maintenance-related training is conducted prior to the actual in-job performanc During this assessment period, a performance-oriented review of engineer training was conducted by NRC. In addition, portions of radiation protection, general employee training (GET), maintenance, fire protection, emergency preparedness, licensed / non-licensed requalification programs, and training programs were reviewed. In each of these areas, the licensee has provided adequate resources to conduct good, meaningful training. Adequate staff, good environment, and good training aids are provided by the licensee to ensure that adequate training for each of these groups is performed. However, in highly specialized areas for which personnel must take proper action, such as the EQ area, training appears to be lacking such as for the maintenance departmen . . . .. _ ..__ . . _ . - - . .- - . . .
..
        ,
'


  -
Individual technical and safety reviewers are specifically trained and qualified to perform their functions. The PAT II noted that, based on interviews, weaknesses existed with respect to reviewer's knowledge levels and processes for accomplishing responsible revie Thre interviews were conducted at a time of transition into a revised safety review process. Despite two years of planning, the revised review program was evidently hastily implemented and this, apparently, resulted in some reviewer confusion. However,.with respect to the
  .
,  definition of " licensing basis document," personnel knowledge level I was weak because the program did not practically define how the i
reviewer was to reference these documents. No adversity to safety resulted. Overall, reviewers did not pay enough attention to detail during their reviews, which has contributed to the procedure adequacy problems noted elsewhere in this repor In summary, the licensee's training program appears to be very
,
effective and performance oriented. There were isolated lapses in
  <
conservatism with respect to operator performance. In general, i
personnel were knowledgeable on plant design and conditions and the workers had a good attitude toward safe operation of the plant.


first such training for many, even senior, engineers other than indoctri-nation reading of applicable modification control procedures that engineers would potentially use. It appears that the recently conducted training will be factored into future new or refresher training sessions for new and experienced engineers. The Technical Personnel and Management Training area was not accredited by INPO as of the end of the SALP perio Past training weaknesses were a contributing factor in the cause of per-formance problems noted in the last SALP. Licensee management has shown initiative in being very supportive of outside professional development training. Th.ey also support owner group technical committees, which enhance the licensee's knowledge of the B&W design and related technical problems. Continued manage =ent attention to engineering training is neede Technical support to routine operational problems appears to have improved over the period at both the corporate and site levels. However, this was a somewhat less challenging period in that the intensive support needed for the TMI-1 restart and test program was lessened. Further, major operational problems have been minimal. Technical support problems occurred but they seemed to be minor and were related to communication difficultie Technical support for the refueling outage also appears to be adequat Some engineering delays were evident and have resulted'in a relatively large amount of submittals needed to be submitted to NRC staff in the November-December 1986 time period to support needed NRC action for fuel movement or Cycle 6 startup activities. Pre-outage meetings on site started several months before the start of the refueling outage. Action items are tabulated on a computer-based file to permit various sorting and to enhance management attention to problem areas such as redesign work and procurement schedular problems. Overall, the licensee appears to have prepared adequately for the refueling outage.
l In summary, the modification control program was well established
; and has improved but certain controlling procedures reflect weaknesses.
-
This lack of clarity and definitiveness in modification-controlling pro-
;
;
cedures puts an undue burden on the discretion of individuals despite their hig5 qualification and improved training. Implementation problems persist such as in the areas of drawing control and EQ. Overall, tech-nical support for routine operational problems appears to be appropriate;
Engineer training has been weak and has apparently contributed to past poor performance, but licensee improvements are encouragin Licensee management continues to be supportive of the training
, but it did not appear to be severely taxed during this period. Good l overall preparations occurred for the refueling outag .
;
!
program by providing necessary direction and involvement to ensure
l l
;
 
that the training program remains a positive contribution to overall plant safet Conclusion
,-_ -
,  Category 1
 
,
  . - ~:
; Recommendations None i
l
         '
            :
,
o            ,
i l
 
  - ,
i i
Conclusion
  . Category 2 Recommendations-
  . Licensee:         I
      .
  . .
.
'
Undertake a self-analysis to determine the causes for inconsistent performance within this area, a
NRC:
Conduct a team inspection of technical support groups with an emphasis on -
determining the causes of inconsistent performanc >
<


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,
,
i
i
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.
.
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  .
e'~w n- "~~w~~~w~~sm- e m w r~--
. _ _ . _ _ , _ . . . , _ ..__, ._,.. ,.- ,. ._._,_ , , ~ , . . . . _ . _ _ . . . , . _ _ . . . _ . . _ _ , _ , , . , . _ . , . , . _ _ . _ , _ , _ , _ _ _ . , _ _ -
 
*


.. H. Training and Qualification Effectiveness Analysis The various aspects of this functional area have been considered and discussed as an integral part of other functional areas and the respective inspection hours have been included in each of the other functional areas. Consequently, this discussion is a synopsis of the assessment related to the training conducted in other functional areas. . Training effectiveness has been measured primarily by observed performance of licensee's personnel and, to a lesser degree,.
I. Assurance of Quality Analysis Management involvement and control in assuring quality continues to be an evaluation criterion for each functional area. The various aspects of the programs to assure quality have been considered and discussed as an integral part of each functional area and the respective inspection hours are included in each one. Consequently, this discussion is a synopsis of the assessments relating to the quality of work conducted in other area During the previous assessment, the licensee performance was rated as Category 2. The previous assessment period highlighted several strengths in the licensee manageinent attention to and involvement with facility activities. In particular was noted Quality Assurance (QA) Department presence and involvement in all facets of operatio Weaknesses were noted in the area of procedure adherence and adequacy and in the effectiveness licensee's corrective actions on problems noted as a result of the licensee's self-review program that, at times, lacked inquisitiveness and thoroughnes In general, there is a respect for procedure use and proper imple-mentation, but nonadherences continue to be too frequent and too significan This repetitive problem is not solely attributed to personnel error which the licensee usually handles with varying degrees of disciplinary action. There appear to be varying, and sometimes adverse, personnel attitudes on procedure adherence, apparently dictated by middle management's action to excel or complete work. Although personnel error occurred, the poor procedure adherence for the recent ES testing was an example of middle manage-ment negatively influencing performances. Corrective actions appear to be delayed or not completely effective in resolving the procedure adherence proble As further insight into this problem, the licensee's Corporate Procedure Task Group, formed during the last assessment period,
by a review of the program adequacy. The discussion below, thus, addresses the training attributes and weaknesses as noted throughout all functional areas and the effect that these have on the or -all safe operation of the plan During the previous assessment, the licensee performance was rated as Category 1. The training program was effective and oriented toward safe plant operations. Personnel were knowledgeable of plant work activities, procedural requirements, and, in general, conducted plant evolutions with care. Accreditation from the Institute of Nuclear Plant Operations (INPO) was received in five areas as of the end of the SALP perio No licensed operator exams were administered during this assessment period. The training programs were reviewed from a performance viewpoint in distinction to a programmatic viewpoint. Particular focus occurred on engineer training in light of past performance problems noted in the last SALP. The plant specific simulator was received near site and placed into a testing phase which should be completed by the end of 1986. Also, an INP0 site visit occurred which should result in INP0 accreditation for all ten area The NRC interviews of licensee's engineers confirmed that they are well qualified and technically trained. They were experienced individuals and they were knowledgeable in the areas of their responsiblity. They felt that they had sufficient training to per-form the jobs that they did. They confirmed that the licensee management was supportive of formalized internal courses and outside courses. Many recognized the training aspect of their participating in the B&W Owners' Group activities, which was also fully suppcrted by the licensee.
, concluded, in part, that strict procedure compliance policy was not uniformly implemented by the different divisions of GPU This ta.sk group was thorough and its report identified that various divisions had varying degrees of compliance policie Further, the group found that division procedures were inconsistent with corporate policy / procedures. Due to a lack of specific guidance, middle managers of different divisions developed varying levels of procedure adherence and performance criterion in the division policies. Certain divisions adopted verbatim compliance, while others used vague wording like "should" or "if appropriate."


i From the previous assessn.ent period, a weakness of engineers to
Corrective actions are being formulated and the licensee showed initiative in forming the task group; however, existing review groups should have identified the policy inconsistency earlie This demonstrated a weakness in the licensee self-review proces .
*


fully understand related regulatory requirements and to follow procedures rigorously was noted. These weaknesses appear to be attributed to lack of specific training in this are Based on review of the training program during this assessment period, it appears that the performance in this area has improved and appropriate planned actions by licensee successfully corrected these deficiencie ._- --  - . - - . - ,- - ---
Overall, procedures are adequate to safely operate the facility; but, here again, individual step inadequacies are too numerous and too significant to be considered isolated cases. There appears to be a correlation between the attention to detail of technical / safety reviewers and the individual step inadequacies. Contributing factors appear to be a lack of specific administrative guidance on what constitutes an adequate review, misuse of the independence latitude provided by TS, and a heavy middle management involvement in perform-ing these reviews. Middle management attention to the program is noteworthy; but, in light of their schedules and workload, the quality of review appears to suffe Also, there appears to have been an improper implementation of-the review program for the procedures, tests, and modifications required by 10 CFR 50.59 and the Technical Specifications. A number of pro-cedure/ procedure changes were not properly classified "important to safety" (ITS) when they dealt with evolution on ITS systems. This resulted in the 10 CFR 50.59 evaluation criteria not being applied for the changes as required by TS. This is a longstanding issue between plant staff and the QA department. Corrective actions have been excessively delaye Apparently, in response to the QA department's classification issue, the licensee revised the review process in a manner which also apparently conflicts with the existing TS. 'The new review process relaxed requirements on when a detailed safety evaluation is to be conducted. The 10 CFR 50.59 evaluation associated with this new review process did not adequately address how the new system imple-mented TS, Management apparently felt the prior review system was too constraining or resource intensive. The products of this new review process have not resulted in any adverse safety issue based on an intensive review by the resident staff. However, many procedure changes are made without the benefit of a more detailed 10 CFR 50.59 type analysis. In several instances, procedures dealing with nuclear safety-related systems would now not receive a detailed evaluation and documentation to provide a basis for the determination as to whether the change involved an unreviewed safety question. The programmatic change is apparently inconsistent with the intent of the unit's technical specifications addressing procedure reviews. The change in the review system was implemented and not sufficiently challenged internally by any licensee review groups to preclude implementation without referral to the NRC staff. In this case, corrective actions appear to be inadequat In general, the Quality Assurance Department continues to be aggressive in their involvement in oversight activities. The QA audits were typically in-depth and adequately identify both positive and negative elements of the licensee's programs. The QA Department is using innovative techniques, such as safety system functional inspections and additional technical expertise to enhance the self-review process and provide better feedback to managemen .
*


r-w
Although 24-hour QA shift caverage stopped during this assessment period, licensee management continued " management backshift tours" and random backshift inspections by QA Departmen The required review process is individually based, rather than collegially based. Some collegial reviews were accomplished, at licensee's initiative. These initiatives include the continued use of the collegial review by the General Office Review Board (G0RB), Plant Review Group (PRG), Preliminary Engineering Design Reviews (PEDR), and Nuclear Safety and Compliance Committee (NSCC). These review groups or individuals responsi-ble for individual technical / safety review appear to be well qualified and are competent to perform their functions. Of particular note is the varied and substantial expertise within
  -
  . the GORB and NSCC, including its staff. It appears that the licensee's initiatives are much needed. All reviews have been successful in identifying significant weaknesses or problems; however, management responsiveness for effective corrective action was either delayed or weak, such as for the procedure adherence or adequacy problems addressed abov Responsible technical and safety review training was adequate (see previous section), but weaknesses in that area appear to be compounded by safety review programmatic deficiencies described abov The Independent On-Site Safety Review Group progressed in enhancing its own administrative program and implementatio Its effectiveness received limited review by NRC staff during this assessment, but an isolated problem was noted in their ability to initiate effective corrective actions with respect to why the reactor building missile door was open during power operation In summary, there is a respect for procedures at the facility and procedures are adequate for safe operatio However, procedure adherence and adequacy problems persist which are too numerous and significant to be considered isolated cases. Contributing factors, in addition to personnel error, are traceable to attitudes and programmatic weaknesses. Further, the different aspects of the licensee's organization have the attributes necessary to achieve the requirements to ensure safe nuclear power operations. Licensee review groups are capable of identifying both positive and negative elements of licensee programs. However, licensee corrective actions, in some instances, appear to be excessively delayed or weak. This may be due, in part, to a weak process of escalating issues to upper management. In general, management is responsive to correcting problems, but they appear to not aggressively pursue these issues to completio .
.
.
*


The licensee's operator training and requalification training programs function well as evidenced by the licensee's performance during plant operations. Few events were attributed to operator /
Conclusion Category 2 Recommendations Licensee:
training deficiencies. A noted strength of the licensee's training program is their pre-job briefings that are conducted by senior reactor operators (SR0's) or control room operators (CRO's) prior to conducting a special evolution in the plant. Discussions are held prior to the evolutions and, in most cases, contributed to successful completion of special evolutions in a safe and timely manner. An example of this is troubleshoocing the integrated control system (ICS). This required the licensee to place many stations in manual mode and the operators received additional training prior to doing that to assist them in assuring that they maintained the plant in a safe condition. As noted below, there were isolated lapses in conservatism exhibited by licensed operator The licensee's training program for both licensed and non-licensed personnel'is strong when dealing with reactor plant systems. Some weaknesses, however, have been noted in the training in the area of
(1) Continue efforts in correcting procedure adherence and procedure adequacy problem (2) Independently meet with the NRC staff to discuss the revised safety review process and the findings and corrective actions of the Procedure Compliance Task Grou NRC:
- balance of the plant. In response to a balance of plant electrical bus less and, apparently, in order to prevent a reactor trip, licensed operators attempted to re-energize these busses from a safety bus without fully knowing the cause of the electrical malfunction. Further, operations department handling of a change to procedures reflecting the licensed power limit was not conservativ The licensee's ability to maintain operators and technicians in six rotating sections, allowing one sec+. ion to be in training status is also noted as a strong attribute in their training progra Review of the training that is performed demonstrates adequate in-depth knowledge is being gained by both non-licensed and licensed training operator In addition, prior to conducting a large or difficult maintenance job, maintenance-related training is conducted prior to the actual in-job performanc During this assessment period, a performance-oriented review of engineer training was conducted by NRC. In addition, portions of radiation protection, general employee training (GET), maintenance, fire protection, emergency preparedness, licensed / non-licensed requalification programs, and training programs were reviewed. In each~of these areas, the licensee has provided adequate resources to conduct good, meaningful training. Adequate staff, good environment, and good training aids are provided by the licensee to ensure that adequate training for each of these groups is performed. However, in highly specialized areas for which personnel must take proper action, such as the EQ area, training appears to be lacking such as for the maintenance departmen __
Meet with the licensee as noted abov _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _
  .
  .
s-
*


Individual technical and safety reviewers are specifically trained and qualified to perform their functions. The PAT II noted that, based on interviews, weaknesses existed with respect to reviewer's knowledge levels and processes for accomplishing responsible revie The interviews were conducted at a time of transition into a revised safety review process. Despite two years of planning, the revised review program was evidently hastily implemented and this, apparently, resulted in some reviewer confusion. However, with respect to the
J. Licensing Analysis In the previous SALP evaluation, the licensee was rated a Category In that SALP, GPUN was credited for aggressive management involve-ment, primarily as a result of monthly meetings with NRR to discuss all active licensing issues. GPUN had also shown improvement in their no significant hazards determination (NSHD), which is required to accompany each technical specification change request. Although the licensee's overall performance has not changed significantly, some declining trends are developin The licensee is still meeting with NRR on a monthly basis to discuss priorities on all active licensing issues. This action is beneficial as several older licensing actions, which previously had lower priorities because of restart, are being actively pursued and completed. For example, technical specifications (TS) concerning decay heat removal requirements, an active issue since mid-1980, was issued during this report period. Additionally, the licensee's proposed resolutions of technical issues have been generally conser-vative and sound. GpuN's analysis and conclusiols concerning NSHD
' definition of " licensing basis document," personnel knowledge level was weak because the program did not practically define how the reviewer was to reference these documents. No adversity to safety resulted. Overall, reviewers did not pay enough attention to detail during their reviews, which has contributed to the procedure adequacy problems noted elsewhere in this repor In summary, the licensee's training program appears to be very effective and performance oriented. There were isolated lapses in conservatism with respect to operator performance. In general, personnel were knowledgeable on plant design and conditions and the workers had a good attitude toward safe operation of the plan Engineer training has been weak and has apparently contributed to past poor performance, but licensee improvements are encouragin Licensee management continues to be supportive of the training program by providing necessary direction and involvement to ensure that the training program remains a positive contribution to overall plant safet Conclusion Category 1 Recommendations None
'
!
were usually well writte The licensee has responded quickly to NRR staff questions on various reviews in progress and provided adequate staff for NRC site visits to resolve particular concerns. Furthermore, the licensee was consistently responsive to NRC staff requests for information, even when they were made on short notice and did not involve an active licensing issue on TMI-1. An example of this cooperation was demonstrated when an NRC staff reviewer spent several hours with shift operators discussing operation of the Integrated Control System (ICS).
. - - ,  . - - , . _ , - - - . _ . - - -


    -_ . . - - . - .  . - -
However, a recurrent problem has occurred during several reviews of the Inservice Testing Program (IST). There have been several exemp-tions from IST program requirements repeatedly requested by the licensee and denied by the NRC, For some of these exemptions, it does not appear that the licensee was vigorously pursuing alterna-
.
' g' .
32-
        .
-
'I. Assurance of Quality Analysis-Management involvement and control in assuring quality continues tr.-
be an evaluation criterion for each functional area. The various aspects of the programs to assure quality have been considered and discussed as an. integral part of each. functional area and the respective inspection hours are included'in each one. Consequently, this dis.cussion is a synopsis of.the assessments relating to the quality of work conducted in other area During the previous assessment, the licensee performance was rated as Category 2. .The previous assessment period highlighted several strengths in the_ licensee management attention to and involvement  ,
with facility activities. In particular was noted Quality Assurance-(QA) Department presence and involvement in all facets of operatio Weaknesses were noted in the area of procedure adherence and' adequacy and in the effectiveness _ licensee's corrective actions on problems noted as a result of the -licensee's self-review program that, at times, lacked inquisitiveness and thoroughnes In -general, there is a respect for procedure use and proper imple-mentation, but nonadherences continue to be too frequent and too significant. This repetitive problem is not solely attributed to personnel error which the licensee usually handles with varying degrees of disciplinary action. There appear to be varying, and sometimes adverse, personnel attitudes on procedure adherence, apparently dictated by middle management's action to excel or complete work. Although personnel error occurred, the poor procedure adherence for the recent ES testing was'an example of middle manage-ment negatively influencing performances. Corrective actions appear to be delayed or not completely effective in resolving the procedure adherence proble As further insight into this problem, the licensee's Corporate
, Procedure Task Group, formed during the last assessment period, concluded, in part, that strict procedure compliance policy was not uniformly implemented by the different divisions of
'
GPUN. This task group was thorough and its report identified that various divisions had varying degrees of compliance policie Further, the group found that division procedures were inconsistent with corporate policy / procedures. Due to a lack of specific
.
.
guidance, middle managers of different divisions developed varying levels of procedure adherence and performance criterion in the i
tives to the required testing but was requesting an exemption based strictly on cost consideration The licensee apparently has assumed that exemptions requested would eventually be approved and has made no preparations for including the components in the IST program,    i This is an example of a poor approach to testing of safety-related components. Either licensing should have more vigorously pursued the
division policies. Certain divisions adopted verbatim compliance,
; exemption requests by initially exploring alternatives with the NRC and explaining why they were not feasible or licensee management should have mado plans to include the components in the IST program, as scheduled, while the exemptions were again under staff review, i
; while others used vague wording like "should" or "if appropriate."
 
j- Corrective actions are being formulated and the licensee showed initiative in forming the task group; however, existing review groups
:  should have identified the policy inconsistency earlier. This demonstrated a weakness in the licensee self-review process.
 
,
o i
I
I
,
      .-,---ev.a.,r-ne.---
      -  ,,-,-n----.w-


- , . . .. . _ _ . - _ -_ . _ _ _ __ _ . . _ . _ . _ ___
.
1 s-t
*
. x


,
The quality of the licensee's documentation of the basis for proposed TS changes has declined. There have been several instances where specific TS changes were either not discussed in the accompany-ing safety evaluation or were discussed only in vague and generalized terms. An example is the proposed amendment for the fuel handling building engineering safety features (ESF) ventilation system. The licensee's safety evaluation did not clearly identify or describe the basis for changes to the TS involving the auxiliary building ventila-tion system. A similar problem was noted in Section F, Security /
Overall, procedures are adequate.to safely operate the facility; but, here again, individual step inadequacies are too numerous and too
Safeguards, of this SALP for 10 CFR 50.54p reviews and Section G, Technical Support, for modification control procedures. Additionally, there has been a tendency in recent submittals to over-categorize changes as administrative in nature. An example of this is the proposed amendment to make existing radiological effluent TS conform with standard TS (NUREG-0472). Licensee management should be sensi-tive to TS changes that are not necessarily administrative in nature, but are easy to justify technically. These problems are not considered a major concern, because so far they have occurred in only I a few proposed amendments. However, they do reflect a developing trend because these applications with the above-noted weaknesses were
    ,
    !
submitted in succession during the latter part of the SALP perio l The licensee needs to improv.t itt. documentation describing and '
supporting proposed TS chang Additionally, there has been an increasing tendency to submit TS j changes which require a relativ91y quick turn-around review by the e NRC staff. Examples have included the axial power shaping rod (APSR)
    [
withdrawal amendment and TS for the fuel handling building ESF l ventilation system. Further, there are numerous plant modifications scheduled for the Cycle 6 refueling outage that were known well in
    .
    !
advance but for which no amendment have been submitted as of the end of this SALP period. For those instances where a submittal required i rapid turnaround, the licensee has been very cooperative with the NRC l to quickly resolve discrepancies and/or staff concern Nonetheless, a trend of untimely submittals has develope !
In summary, the licensee's performance in the functional area of 7 licensing activities is considered acceptable with some decline noted :
in certain areas such as timely submittals of TS change requests and the quality of evaluations accompanying these change request Conclusion Category 1, declining    i
    !
Recommendations None    !
    :
    <
f I
l i


'
,
significant to be considered isolated cases. There appears to be a correlation between the attention to-detail of technical / safety
*
'
reviewers and the individual step inadequacies. Contributing. factors
;  appear to be a. lack of specific administrative guidance on what j-  constitutes an adequate review,-misuse of the independence latitude
:  provided by TS, and a heavy middle management involvement in perform-1-  ing these reviews. Middle management attention to the program is l  noteworthy; but, in light of their schedules and workload, the quality of review appears to suffe ,


V. SUPPORTING DATA AND SUMMARIES Investigations and Allegations Review There are no open investigations for TMI-1. The investigation on the environmental equipment qualification deficiencies and inaccurate submittals during 1981-1984 was completed outside the assessment period and reviewed by IE and Region I staff. Violations of NRC requirements were identified and they will be discussed in an upcoming enforcement conferenc The other allegation dealt with a concern on the potential for recriticality during post-engineering safety feature actuation situations. This is currently under review by Region Escalation Enforcement Actions None Management Conferences There was one management conference on August 12, 1986, to discuss the licensee's response to a violation dealing with fire brigade training and as follow-up on SALP I comments in the fire brigade training area. A re-submittal was received and it constituted a satisfactory response to the violation. A minor clarification was made to the SALP I repor On July 30, 1986, there was also a management meeting to discuss the SALP I result Licensco Event Reports In reference to Table 5, two Licensee Event Reports (LER's) were due to equipment / component malfunction, two were due to personnel error, and one was due to inadequate environmental qualification documenta-tion (which has a possible root cause of personnel error). No causal link can be inferred among the five LER's that were submitted during this assessment perio The Of fice of Analysis and Evaluation of Operational Data (AE00)
performed an analysis for LER's for the period from January 1,1986, to October 31, 1986. In general, the evaluation found the quality of the licenseo's LER's to be above average. Two weaknesses, however, were identified in terms of proper characterization of safety signi-ficance of key parameter The identified weaknesses involve the need to more fully assess the safety significance of the event and to provide a more complete discussion of personnel errors and procedure defic'encie The AE00 evaluation of LER's is being forwarded to the licensee under separate correspondence to present specific suggestions on Improving the quality of the report .
  '
  '
Also, there appears to.have been an improper implementation of the j  review program for the procedures, tests, and modifications required j  by 10 CFR 50.59 and the Technical Specifications. A number of pro-cedure/ procedure changes were not properly classified "important to :
*  . safety" (ITS) when they dealt with evolution on ITS systems. This
,
resulted in the 10 CFR.50.59 evaluation criteria not being applied i 4  for the changes as required by TS. This is a longstanding issue i
  .between plant staff and the OA department. Corrective actions have L  been excessively delayed.


i-
E. Reactor Trips / Forced Outages l
}  Apparently, in response to the QA department's classification issue, E  the licensee revised the review process in a manner which also I  apparently conflicts with the existing TS. The new review process relaxed requirements on when a detailed ^ safety evaluation is to be
l There was only one unplanned reactor trip on June 2, 1986, due to a turbine trip. The turbine trip occurred because of a loss of
'
'
conducted. The 10 CFR 50.59 evaluation associated with this new ,
electro-hydraulic control oil pressure, which resulted from elec-
review process did not' adequately address how the new system imple-
!  mented TS. Management apparently felt the prior review system was i  too constraining or resource intensive. The products of this new review process have not resulted in any adverse safety issue based on .
an intensive review by the resident staff. However, many procedure !
'
:  changes are made without the benefit of a more detailed 10 CFR 50.59
,
,
type analysis. In several instances, procedures dealing with nuclear
trical bus de-energization. The root cause was poor design which
-  safety-related systems would now not receive a detailed evaluation -
! resulted in the unexpected low settings of a breaker over-current
;  and documentation to provide a basis for the determination as to L  whether the change involved an unreviewed safety question. The
; device. A contributing factor was poor maintenance planning. There l were no forced outages during this period.
.
programmatic change is apparently inconsistent with the intent of the '
!  unit's technical specifications addressing procedure reviews. The change in the review system was implemented and not sufficiently j  challenged internally by any licensee review groups to preclude
!  implementation without referral to the NRC staff. In this case,
{  corrective actions appear to be inadequate.


i i
l l
'
t t
In general, the Quality Assurance Department continues to be
i
;  aggressive in their involvement in oversight activities. The QA '
!
j  audits were typically in-depth and adequately identify both il  positive and negative elements of the licensee's programs. The QA
l l
[  Department is using innovative techniques, such as safety system *
l
i  functional inspections and additional technical expertise to enhance the self-review process and provide better feedback to management.


!
!
l I
l f
\, .
!
      *
!
e


o y
!
 
.
Although 24-hour QA shift coverage stopped during this assessment period, licensee management continued " management backshift tours" and random backshift inspections by QA Departmen The required review process is individually based, rather than collegially based. Some collegial reviews were accomplished, at licensee's initiative. These initiatives include the continued use of the collegial review by the General Office Review Board (G0RB), Plant Review Group (PRG), Preliminary Engineering Design R.eviews (PEDR), and Nuclear Safety and Compliance Committee (NSCC). These review groups or individuals responsi-ble for individual technical / safety review appear to be well qualified and are competent to perform their functions. Of particular note is the varied and substantial expertise within the GORB and NSCC, including its staff. It appears that the licensee's initiatives are much needed. All reviews have been successful in identifying significant weaknesses or problems; however, management responsiveness for effective corrective action was either delayed or weak, such as for the procedure adherence or adequacy problems addressed abov Responsible technical and safety review training was adequate (see previous section), but weaknesses in that area appear to be compounded by safety review programmatic deficiencies described abov The Independent On-Site Safety Review Group progressed in enhancing its own administrative program and implementatio Its effectiveness received limited review by NRC staff during this assessment, but an isolated problem was noted in their ability to initiate effective corrective actions with respect to why the reactor building missile door was open during power operation In summary, there is a respect for procedures at the facility and procedures are adequate for safe operation. However, procedure adherence and adequacy problems persist which are too numerous and significant to be considered isolated case Contributing factors, in addition to personnel error, are traceable to attitudes and programmatic weaknesse Further, the different aspects of the licensee's organization have the attributes necessary to achieve the requirements to ensure safe nuclear power operations. Licensee review groups are capable of identifying both positive and negative elements of licensee programs. However, licensee corrective actions, in some instances, appear to be excessively delayed or weak. This may be due, in part, to a weak process of escalating issues to upper management. In general, management is responsive to correcting problems, but they appear to not aggressively pursue these issues to completio ,
  .
  .
T1-1 SALP TABLE 1
.
LISTING OF LERs BY FUNCTIONAL AREA CAUSE CODES AREA  A B C D E X TOTA [
OPERATIONS  1  2 3 RAD CONTROLS MAINTENANCE  1  1 SURVEILLANCE EMERGENCY PRE SEC/ SAFEGUARDS TECHNICAL SUPPORT  1 1 i
'
TRAINING QUALITY ASSURANCE LICENSING
...................
    - ~~ -
TOTALS: 7  ~f "T ~5 KEY: Cause Codes A - Personnel Error R - Design, Manufacture, Construction C - External 0 - Procedure Deficiency E - Equipment Malfunction / Failure X - Other/ Unknown
!
l f
      .
i e
mi


Conclusion Category 2 v Recommendations Licensee:
(1) Continue efforts in correcting procedure adherence and procedure adequacy problem (2) . Independently meet with the NRC staff to discuss the revised safety review process and the findings and corrective actions of the Procedure Compliance Task Grou NRC:
Meet with the licensee as noted abov .
  .
  .
-
,
J. Licensing Analysis In the previous SALP evaluation, the licensee was rated a Category In that SALP, GPUN was credited for aggressive management involve-ment, primarily as a result of monthly meetings with NRR to discuss all active licensing issues. GPUN had also shown improvement in their no significant hazards determination (NSHD), which is required to accompany each technical specification change request. Although the licensee's overall performance has not changed significantly, some declining trends are developin The licensee is still meeting with NRR on a monthly basis to discuss priorities on all active licensing issues. This action is beneficial as several older licensing actions, which previously had lower priorities because of restart, are being actively pursued and completed. For example, technical specifications (TS) concerning decay heat removal requirements, an active issue since mid-1980, was issued during this report period. Additionally, the licensee's proposed resolutions of technical issues have been generally conser-vative and sound. GPUN's analysis and conclusions concerning NSHO were usually well writte The licensee has responded quickly to NRR staff questions on various reviews in progress and provided adequate staff for NRC site visits to resolve particular concern Furthermore, the licensee was consistently responsive to NRC staff requests for information, even when they were made on short notice and did not involve an active licensing issue on TMI-1. An example of this cooperation was demonstrated when an NRC staff reviewer spent several hours with shift operators discussing operation of the Integrated Control System (ICS).
However, a recurrent problem has occurred during several reviews of the Inservice Testing Program (IST). There have been several exemp-tions from IST program requirements repeatedly requested by the licensee and denied by the NRC. For some of these exemptions, it does not appear that the licensee was vigorously pursuing alterna-tives to the required testing but was requesting an exemption based strictly on cost considerations. The licensee apparently has assumed that exemptions requested would eventually be approved and has made no preparations for including the components in the IST progra This is an example of a poor approach to testing of safety-related components. Either licensing should have more vigorously pursued the exemption requests by initially exploring alternatives with the NRC and explaining why they were not feasible or licensee management should have made plans to include the components in tne IST program, as scheduled, while the exemptions were again under staff review.
;
..-
  .
  .
T2-1 SALP TABLE 2 INSPECTION HOUR SUMMARY AREA  HOURS % OF TIME OPERATIONS  1082 4 RAD CONTROLS  241 MAINTENANCE  260 1 SURVEILLANCE  333 1 EMERGENCY PREP,  37 SEC/ SAFEGUARDS  78 TECHNICAL SUPPORT  567 2 TRAINING  NA NA  ,
LICENSING QUALITY ASSURANCE NA NA NA NA (
I
...................
TOTALS: 2535 ID6TD i
I
!
/
  . .. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _


The quality of the licensee's documentation of the basis for proposed TS changes has declined. There have been several instances where specific TS changes were either not discussed in the accompany-ing safety evaluation or were discussed only in vague and generalized te rms. An example is the proposed amendment for the fuel handling building engineering safety- features (ESF) ventilation system. The licensee's safety evaluation did not clearly identify or describe the basis for changes to the TS involving the auxiliary building ventila-tion system. A similar problem was noted in Section F, Security /
O
Safeguar.ds, of this SALP for 10 CFR 50.54p reviews and Section G, Technical Support, for modification control procedures. Additionally, there has been a tendency in recent submittals to over-categorize changes as administrative in nature. An example of this is the proposed amendment to make existing radiological effluent TS conform with standard TS (NUREG-0472). Licensee management should be sensi-tive to TS changes that are not necessarily administrative in nature, but are easy to justify technically. These probleus are not considered a major concern, because so far they have occurred in only a few proposed amendments. However, they do reflect a devel_oping trend because these applications with the above-noted weaknesses were submitted in succession during the latter part of the SALP perio The licensee needs to improve its documentation describing and supporting proposed TS change Additionally, there has been an increasing tendency to submit TS changes which require a relatively quick turn-around review by the NRC staff. Examples have included the axial power shaping rod (APSR)
withdrawal amendment and TS for the fuel handling building ESF ventilation system. Further, there are numerous plant modifications scheduled for the Cycle 6 refueling outage that were known well in advance but for which no amendment have been submitted a; of the end of this SALP period. For those instances where a submit:al required rapid turnaround, the licensee has been very cooperative with the NRC to quickly resolve discrepancies and/or staff concerns. Nonetheless, a trend of untimely submittals has develope In summary, the licensee's performance in the functional area of licensing activities is considered acceptable with some decline noted in certain areas such as timely submittals of TS change requests and the quality of evaluations accompanying these change request Conclusion Category 1, declining Recommendations None
- ___ _ __ _ _ . _ . - --


  *
T3-1
  ,
-
SALP TABLE 3 ENFORCEMENT SUMMARY SEVERITY LEVEL AREA 1 2 3 4 5 DEV TOTAL __ _ _
OPERATIONS  3 3 RAD CONTROLS MAINTENANCE  1 1 SURVEILLANCE  1 1 EMERGENCY PRE SEC/ SAFEGUARDS TECHNICAL SUPPORT 3 3 TRAINING LICENSING QUALITY ASSURANCE
...................
  ~ ~ ~ - -
TOTALS: l ~B


V. SUPPORTING DATA AND SUMMARIES Investigations and Allegations Review There are no open investigations for TMI-1. The investigation on the environmental equipment qualification deficiencies and inaccurate submittals during 1981-1984 was completed outside the assessment period and reviewed by IE and Region I staff. Violations of NRC requirements were identified and they will be discussed in an upcoming enforcement conferenc The other allegation dealt with a concern on the potential for recriticality during post-engineering safety feature actuation situations. This is currently under review by Region Escalation Enforcement Actions None Management Conferences There was one management conference on August 12, 1986, to discuss the licensee's response to a violation dealing with fire brigade training and as follow-up on SALP I comments in the fire brigade training area. A re-submittal was received and it constituted a satisfactory response to the violation. A minor clarification was made to the SALP I repor On July 30, 1986, there was also a management meeting to discuss the SALP I result Licensee Event Reports In reference to Table 5, two Licensee Event Reports (LER'.s) were due to equipment / component malfunction, two were due to personnel error, and one was due to inadequate environmental qualification documenta-tion (which has a possible root cause of personnel error). No causal link can be inferred among the five LER's that were submitted during this assessment perio The Office of Analysis and Evaluation of Operational Data (AE00)
o
performed an analysis for LER's for the period from January 1,1986,
, to October 31, 1986. In general, the evaluation found the quality of the licensee's LER's to be above average. Two weaknesses, however, were identified in terms of proper characterization of safety signi-ficance of key parameters. The identified weaknesses involve the need to more fully assess the safety significance of the event and to
!.
provide a more complete discussion of personnel errors and procedure deficiencies. The AE00 evaluation of LER's is being' forwarded to the licensee under separate correspondence to present specific
: suggestion.,on improving the quality of the report . ."
e


E. Reactor Trips / Forced Outages There was only one unplanned reactor trip on June 2, 1986, due to a turbine trip. The turbine trip occurred because of a loss of electro-hydraulic control oil pressure, which resulted from elec-trical bus de-energization. The root cause was poor design which resulted in the unexpected low settings of a breaker over-current device. A contributing factor was poor maintenance planning. There were no forced outages during this perio r--
-   T3-2 TABLE 3 (Continued)
  .
ENFORCEMENT SUMMARY INSPECTION VIOL, FUNCTIONAL REPORT _REQUIREMENTLEVEL _ AREA _ VIOLATION
  .,
  *289/86-12 10CFR50 APP 4 OPERATIONS INADEQUATE SAFETY EVALUATION FOR B,CT V  CHANGE TO PROCEDURES DESCRIBE 0 IN .
T1-l'
07/07/86 08/14/86  FSAR
    .SALP TABLE 1
*289/86-12 10CFR50 APP 4 OPERATIONS FAILURE TO TAKE PROMPT C03RECTIVE B/XVI ACTIONS ON CONDITIONS ADVERSE TO 07/07/86 08/14/86 QUALITY
  : LISTING OF LERs BY FUNCTIONAL AREA CAUSE CODES _
  '289/86-12 10CFR50 APP 4 TECHNICAL INADEQUATE IMPLEMENTATION OF QUALITY 8/XVI SUPPORT ASSURANCE PLAN 07/07/86 08/14/86    i
AREA' A B C- D E X TOTAL
  *289/86-12 10CFR50 APP 4 TECHNICAL FAILURE TO ADHERE TO REQUIREMENTS OF B/II SUPPORT MODIFICATION CONTROL PROCEDURES 07/07/86 08/14/86 289/86-17 10 CFR 4 MAINTENANCE FAILURE TO EVALUATE CABLE MODIFICATION 50.5 IN REACTOR BUILDING PENETRATION 09/08/86 10/03/86 289/86-17 TS 6. SURVE!LLANCE FAILURE TO PROPERLY CONDUCT ESAS SURVEILLANCC PROCEDURE 09/08/86 10/03/86 289/86-17 10CFR50 B/3 4 OPERATIONS FAILURE TO IMPLEMENT A DESIGN BASES
  .
  & A/4  ASSUMPTION ON REACTOR DUILDING EQUIP-09/08/86 10/03/86  MENT HATCH MISSILE 000R 289/86-17 ANSI 4 TECHNICAL FAILURE TO PROVIDE DESIGN BASIS FOR 45.2.11 P $UPPORT RADIATION MONITOR SETTINGS 09/08/86 10/03/86
OPERATIONS  1 2 3 RAD CONTROLS MAINTENANCE 1  1 SURVEILLANCE EMERGENCY PRE SEC/ SAFEGUARDS TECHNICAL' SUPPORT :  1 1 TRAINING QUALITY ASSURANCE LICENSING
' Violations identiflod by asterisk were discussed in SALP ! and issued during this assessment perio P
___________________
TOTALS: 2 2 1 5 KEY: Cause Codes A - Personnel Error B - Design, Manufacture, Construction C - External'
D - Procedure Deficiency E - Equipment Malfunction / Failure X - Other/ Unknown i


__. - _ _ . -
. _ - _ _ - _ _ .
  .
  .
  :,.
  .-
T2-1 SALP TABLE 2-INSPECTION HOUR SUMMARY AREA  HOURS % OF TIME
  ,
. OPERATIONS 1082 4 RAD CONTROLS 241 MAINTENANCE 260 1 SURVEILLANCE 333 1 EMERGENCY PRE .4 SEC/ SAFEGUARDS 78 '
T4-1 TABLE 4 INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS  AREAS INSPECTED 289/86-08 SPECIALIST 11 CORPORATE INDEPENDENT TECHNICAL AND SAFETY 04/30/86 05/02/86 REVIEW - OTHER REVIEW INITIATIVES SUCH AS GENERAL OFFICE REVIEW BOARD 289/86-09 RESIDENT 323 ROUTINE PLANT OPERATIONS AND REACTOR TRIP 05/17/86 06/27/86 EVENT - MAINTENANCE AND SURVEILLANCE ON BORIC ACID INJECTION SYSTEM (IST) -
TECHNICAL SUPPORT 567 2 TRAINING  NA NA LICENSING  .NA NA QUALITY ASSURANCE  NA NA
MODIFICATIONS OF CONTAINMENT ISOLATION SYSTEM 289/86-10 RESIDENT 206 ROUTINE OPERATIONS, REPORTS RECEIVED, 06/27/86 08/01/86 FILTER OROP EVENT - ROUTINE MAINTENANCE AND SURVEILLANCE, DECAY HEAT VALVE MAINTENANCE - l ESF VENTTILATION INSTALLATION (NRR WALK 00WN)
...........= _==-
289/86-11 SPECIALIST 49 REVIEW OF MATERIAL CONTROL AND ACCOUNTING 7/22/86 07/24/86 FOR SPECIAL NUCLEAR MATERIAL 289/86-12 RESIDENT 54 SPECIAL SAFETY INSPECTION BASED ON PAT I 07/07/86 08/14/86 FINDINGS ADDRESSING AREAS OF IMPLEMENTATION AND MODIFICATION CONTROL, CONDUCT OF SAFETY EVALUATION IMPLEMENTATION, DESIGN CONTROL l   REQUIREMENTS 289/86-13 RESIDENT 318 ROUTINE REVIEW OF PLANT OPERATIONS AND i
TOTALS: 2598 10 .
08/01/86-08/08/86  SURVEILLANCE AND VARIOUS EVENTS, i   MAINTENANCE PROGRAM, RAOCON CONTROLS, REPORT REVIEW (ECT) AND PREVIOUS FINDINGS I    - DESIGN CHANGES l  289/86-14 SPECIALIST 720 PAT II - PROGRAMMATIC REV!EW OF PLANT
   --
,  08/25/86-09/05/86  OPERATIONS, MAINTENANCE, SURVEILLANCE, l    TECHNICAL / SAFETY REVIEW, M00!FICATION <
   ,p-%e*-w&w we y-e-.* *i:+w*mvee-T'Wy---=v-M--y=F-N'*wN-'*-v-em''T*""* **'W "N"*'8'-"Y
CONTROL, ASSURANCE OF QUALITY 289/86-15 SPECIALIST 29 SECURITY ORGANIZATION, ACCESS CONTROL, 08/11/86-08/14/86  PERSONNEL SEARCH, BOUNDARIES, COMMUNICATIONS, RER FOLLOW UP  ,
289/86-16 SPECIALIST 37 PROGRAMMATIC REVIEW IN THE AREA 0F EMERGENCY 09/22/86-10/17/86  PREPARE 0 NESS l
l I


-d
_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _
  .
  .
  -T3-1 SALP TABLE 3 ENFORCEMENT SUMMARY SEVERITY LEVEL AREA 1 2 3 4 5 DEV TOTAL OPERATIONS  3 3 RAD CONTROLS MAINTENANCE  1 1 SURVEILLANCE  1 1 EMERGENCY PRE SEC/ SAFEGUARDS TECHNICAL SUPPORT-  3 3 TRAINING LICENSING QUALITY ASSURANCE
___________________
TOTALS:  8 8


s
T4-2 TABLE 4 (Continued)
%
INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS  AREAS INSPECTED 289/86-17 RESIDENT 482 ROUTINE PLANT OPERATIONS - RCP SEAL PROBLEMS 09/08/86-10/03/86  AND HIGH REACTOR BUILDING RADIOLOGICAL ACTIVITY - MAINTENANCE / SURVEILLANCE ON MAKE-UP VALVE OPERABILITY, FIRE PROTECTION, REPORTING PROGRAM, SAFETY REVIEW, CHEMISTRY, i  MATERIAL, DOCUMENT CONTROL
l T3-2 TABLE 3 (Continued)
ENFORCEMENT SUMMARY
,
INSPECTION VIOL. FUNCTIONAL REPORT _ REQUIREMENT LEVEL _ AREA _  VIOLATION
-*289/86-12 10CFR50 APP 4 OPERATIONS INADEQUATE SAFETY EVALUATION FOR B,CT V  CHANGE TO PROCEDURES DESCRIBED IN 07/07/86 08/14/86  FSAR
*289/86-12 10CFR50 APP 4 OPERATIONS FAILURE TO TAKE PROMPT CORRECTIVE B/XVI  ACTIONS ON CONDITIONS ADVERSE TO 07/07/86 08/14/86  QUALITY
,
*289/86-12 10CFR50 APP 4 TECHNICAL INADEQUATE IMPLEMENTATION OF QUALITY B/XVI SUPPORT ASSURANCE PLAN 07/07/86 08/14/86
*289/86-12 10CFR50 APP 4 TECHNICAL FAILURE TO ADHERE TO REQUIREMENTS OF B/II SUPPORT MODIFICATION CONTROL PROCEDURES 07/07/86 08/14/86
'.
289/86-17 10 CFR 4 MAINTENANCE FAILURE TO EVALUATE CABLE MODIFICATION 50.5 IN REACTOR BUILDING PENETRATION 09/08/86 10/03/86 289/86-17 TS 6. SURVEILLANCE FAILURE TO PROPERLY CONDUCT ESAS SURVEILLANCE PROCEDURE 09/08/86 10/03/86 289/86-17 10CFR50 B/3 4 OPERATIONS FAILURE TO IMPLEMENT A DESIGN BASES
  & A/4  ASSUMPTION ON REACTOR BUILDING EQUIP- .
09/08/86 10/03/86  MENT HATCH MISSILE 000R 289/86-17 ANSI 4 TECHNICAL FAILURE TO PROVIDE DESIGN BASIS FOR 45.2.11 P SUPPORT RADIATION MONITOR SETTINGS 09/08/86 10/03/86
 
* Violations identified by asterisk were discussed in SALP I and issued during l this assessment perio i
 
s
,
T4-1 TABLE 4 INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS  AREAS INSPECTED 289/86-08 SPECIALIST 11 CORPORATE INDEPENDENT TECHNICAL AND SAFETY 04/30/86 05/02/86  REVIEW - OTHER REVIEW INITIATIVES SUCH AS GENERAL OFFICE REVIEW BOARD 289/86-09 RESIDENT 323 ROUTINE PLANT OPERATIONS AND REACTOR TRIP 05/17/86 06/27/86  EVENT - MAINTENANCE AND SURVEILLANCE ON BORIC ACID INJECTION SYSTEM (IST) -
MODIFICATIONS OF CONTAINMENT ISOLATION SYSTEM 289/86-10 RESIDENT 206 ROUTINE OPERATIONS, REPORTS RECEIVED, 06/27/86 08/01/86 FILTER OROP EVENT - ROUTINE MAINTENANCE AND SURVEILLANCE, DECAY HEAT VALVE MAINTENANCE -
ESF VENTTILATION INSTALLATION (NRR WALKDOWN)
289/86-11 SPECIALIST 49 REVIEW 0F MATERIAL CONTROL AND ACCOUNTING 7/22/86 07/24/86  FOR SPECIAL NUCLEAR MATERIAL 289/86-12 RESIDENT 54 SPECIAL SAFETY INSPECTION BASED ON PAT I 07/07/86 08/14/86  FINDINGS ADDRESSING AREAS OF IMPLEMENTATION AND MODIFICATION CONTROL, CONDUCT OF SAFETY EVALUATION IMPLEMENTATION, DESIGN CONTROL REQUIREMENTS 289/86-13 RESIDENT 318 ROUTINE REVIEW 0F PLANT OPERATIONS AND 08/01/86-08/08/86  SURVEILLANCE AND VARIOUS EVENTS, MAINTENANCE PROGRAM, RADCON CONTROLS, REPORT REVIEW (ECT) AND PREVIOUS FINDINGS
  - DESIGN CHANGES 289/86-14 SPECIALIST 720 PAT II - PROGRAMMATIC REVIEW OF PLANT 08/25/86-09/05/86  OPERATIONS, MAINTENANCE, SURVEILLANCE, TECHNICAL / SAFETY REVIEW, MODIFICATION CONTROL, ASSURANCE OF QUALITY 289/86-15 SPECIALIST 29 SECURITY ORGANIZATION, ACCESS CONTROL, 08/11/86-08/14/86  PERSONNEL SEARCH, BOUNDARIES, COMMUNICATIONS, RER FOLLOW-UP 289/86-16 SPECIALIST 37 PROGRAMMATIC REVIEW IN THE AREA 0F EMERGENCY 09/22/86-10/17/86  PREPAREDNESS
!
l
  , _ _ , , _.- - , - - , . . ,, , -,--


s.
289/86-18 SPECIALIST NA MANAGEMENT MEETING ON CONTESTED VIOLATION 08/12/86-08/12/86  ON FIRE BRIGADE TRAINING 289/86-19 RESIDENT 369 PLANT OPERATIONS AND POWER COAST 00WN, RCP 10/03/86-10/31/86  - MAINTENANCE / SURVEILLANCE ON OH VALVES -
 
.$_
T4-2 TABLE 4 (Continued)
INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS  ' AREAS INSPECTED 289/86-17 RESIDENT 482 ROUTINE PLANT OPERATIONS - RCP SEAL PROBLEMS 09/08/86-10/03/86  AND HIGH REACTOR BUILDING RADIOLOGICAL ACTIVITY - MAINTENANCE / SURVEILLANCE ON MAKE-UP VALVE OPERABILITY, FIRE PROTECTION, REPORTING PROGRAM, SAFETY REVIEW, CHEMISTRY, MATERIAL, DOCUMENT CONTROL 289/86-18 . SPECIALIST NA MANAGEMENT MEETING ON CONTESTED VIOLATION 08/12/86-08/12/86  ON FIRE BRIGADE TRAINING 289/86-19 RESIDENT 369 PLANT OPERATIONS AND POWER C0ASTDOWN, RCP 10/03/86-10/31/86  - MAINTENANCE / SURVEILLANCE ON DH VALVES -
RADIATION PROTECTION ON EFFLUENTS CONTROL, INDEPENDENT MEASUREMENTS - PRE-0UTAGE REVIEW
RADIATION PROTECTION ON EFFLUENTS CONTROL, INDEPENDENT MEASUREMENTS - PRE-0UTAGE REVIEW
_ _ _ _ -


  .
  - _ _ _ _ _ _ _ _ - _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _-__
._
o
o
  .
  .
T5-1 TABLE 5 LER SYNOPSIS LER NUMBER EVENT DATE CAUSE CODE * DESCRIPTION 86-08 04/21/86 E REACTOR TRIP DURING STARTUP DUE TO MALFUNCTION OF 4160 V CLASS IE CIRCUIT D BREAKER DUE TO EQUIPMENT / COMPONENT MALFUNCTION 86-09 04/22/86 X ENVIRONMENTAL QUALIFICATION FOR REACTOR
T5-1 TABLE 5
  '
    ,LER SYNOPSIS LER NUMBER EVENT DATE CAUSE CODE' pESCRIPTION i
BUILDING EMERGENCY COOLING FANS CABLE WERE NOT AVAILABLE 86-10 04/23/86 A REACTOR TRIP FROM 8% POWER DUE TO HIGH PRESSURE FROM LOSS OF MAIN FEED DUE TO PERSONNEL ERROR AND PROCEDURE INADEQUACY 86-11 06/02/86 E REACTOR TRIP FROM TURBINE TRIP AT 100%
86-08 04/21/86 E REACTOR TRIP DURING STARTUP DUE TO MALFUNCTION OF 4160 V CLASS IE CIRCUIT D BREAKER DUE TO EQUIPMENT / COMPONENT MALFUNCTION 86-09 04/22/86 X ENVIRONMENTAL QUALIFICATION FOR REACTOR BUILDING EMERGENCY COOLING FANS CABLE WERE NOT AVAILABLE 86-10 04/23/86 A REACTOR TRIP FROM 8% POWER DUE TO HIGH PRES $URE FROM LOSS OF MAIN FEED DUE TO PERSONNEL ERROR AND PROCEDURE INADEQUACY 86-11 06/02/86 E REACTOR TRIP FROM TUR0!NE TRIP AT 100%
POWER DUE TO EQUIPMENT MALFUNCTION OF A FEEDER BREAKER OVERCURRENT DEVICE COUPLED WITH POOR MAINTENANCE PLANNING 86-12 09/04/86 A IN0PERABLE FIRE DETECTOR FOR 1D ES SWITCHGEAR ROOM
POWER DUE TO EQUIPMENT MALFUNCTION OF A
*See Table T1 for cause codes
:
:
FEEDER BREAKER OVERCURRENT DEVICE COUPLED WITH P0OR MAINTENANCE PLANNING 86-12 09/04/86 A INOPERABLE FIRE DETECTOR FOR 10 ES SWITCHGEAR ROOM
  *$ee Table il for cause codes
,
i s
i
        ,


r
_ _ - _
~ .
.
..
.
T6-1 TABLE 6 FORCED OUTAGES AND UNPLANNED AUTOMATIC SCRAMS POWER PROXIMATE ROOT DATE LEVEL CAUSE _  CAUSE 06/02/86 100% TURBINE TRIP MALFUNCTION OF NON 1E. FEEDER BREAKER OVERCURRENT DEVICE COUDLED WITH POOR MAINTENANCE PLANNING DESCRIPTION: TURBINE TRIP DUE TO LOSS OF BOTH ELECTRO-HYDRAULIC CONTROL OIL PUMPS DURING TURBINE PLANT ELECTRICAL REPAIRS
T6-1 TABLE 6 FORCED OUTAGES AND UNPLANNED AUTOMATIC SCRAMS POWER PROXIMATE ROOT DATE LEVEL CAUSE _  CAUSE 06/02/86 100% TURBINE TRIP MALFUNCTION OF NON 1E FEEDER BREAKER OVERCURRENT DEVICE COUPLED WITH POOR MAINTENANCE PLANNING DESCRIPTION: TURBINE TRIP OUE TO LOSS OF BOTH ELECTRO-HYORAULIC CONTROL OIL PUMPS DURING TUR0!NE PLANT ELECTRICAL REPAIRS r
      !
I t
I l
       ,
       ,


_
,
        -
r-s
  .
  .
e T7-1 TABLE 7 LICENSING ACTIVITIES
l
      <
This section provides a summary of significant licensing actions and other activities during the SALP evaluation period NRR/ Licensee Meetings at Bethesda - 8 NRR Site Visits - 5 Commission Briefings - None Schedule Extensions Granted - 1 . Appendix H (Surveillance Capsule) - discussed in last SALP Reliefs Granted - 1 Exemptions Granted - 1 (See No.4, Schedule Extensions) Licensee Amendments Issued - 5 Emergency Technical Specification Changes Issued - None Orders Issued - None t
i f
'l r
!
!
.
T7-1 TABLE 7 LICENSING ACTIVITIES This section provides a sumnary of significant licensing actions and other activities during the SALP evaluation period NRR/ Licensee Mootings at Bethesda - 8 NRR Sito Visits - 5 Commission Ortefings - None Schedule Extensions Granted - 1 Appendix H (Surveillance Capsule) - discussed in last SALP Reitof t Granted - 1 Exemptions Granted - 1 (See No.4, Schedulo Extensions) Licensee Amendments !ssued - 5 Emergency Technical Specification Changes !ssued - None i Orders !ssued - None
  *
l i
 
*/
*
SEE AMENDED PAGE FOLLOWING T8-1 TABLE __8 RADIOLOGICAL EFFLUENT RELEASES *
Non- ut_in Events Resulting in Off-Site Releases of Noble Gases (Licensee Report _1
      % of Technical Specifications Componen  Release Activity Quarterly Date  involved  point Released (C1) Limit. Gamma 5/12/86 RC-RV-5  SV (Station Vent) 5.85 3.7 E-3 5/13/86 Reactor Coolant SV  6.3 E-1 3.2 E-4 System (RCS) &
Pressurizer (P2R)
Sampling 5/27/86 WDGT-B Loss of $  2.11 1.07 E-3 Pressure While Releasing WDGT-A 6/2/86 Rx Trip Main Steam Main Ste- Relief 2.50 E-5 4.7 E-7 Release  Valvo(MSR 6/4/86 MU Domin vent-to- SV  5.51 E-1 2.8 E-4 Vent Header 6/10/86 RC Letdown Sample $V  19 E-1 6.04 E-5 6/12/86 RC Letdown Sample SV .04 E-4 6/24/86 Testing of CAV 1, 2, SV .42 E-3
  & 3 Interlocks 6/25/86 Recirculation or RC$ SV  0.752 3.82 E-4 Letdown 7/11/86 Blown Ruptured Disc $V  1.73 ' 6E4 on RC Evporator 7/15/86 MV Filter 2b Venting SV  1.51 7.62 .4 7/24/86 Sample Casket failure $V  4.01 2.04 E 3
*This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor ._ . _ ___ _ __


  --nr -
_ _ _ _ _ _ _ _ _
  .r ,c---- ew , , - .-~ - .,--.--,~~p--- -n--,-m-m-- -,-,.~,-m- w-v-, y ew, -
a
        -m- e~--
'
  .
T8-1 TABLE 8 l  RADIOLOGICAL EFFLUENT RELEASES *
Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee-Reported
    % of Technical l    Specifications l Component  Release Activity Quarterly i Date involved  Point Released (C1) Limit, Gamma l
5/12/86 RC-RV-5  SV (Station Vent) 5.85 3.7 E-3 5/13/86 Reactor Coolant SV  6.3 E-1 3.2 E-4
: System (RCS) &
i Pressurizer (PZR)
Sampling
,
5/27/86 WDGT-B Loss of SV  2.11 1.07 E-3 l Pressure While Releasing WOGT-A
; 6/2/86 Rx Trip Main Steam Main Steam Relief 2.50 E-5 4.7 E-7 Release  Valve (MSRV)
6/4/86 MU Domin Vent-to- SV  5.51 E-1 2.8 E-4
;
Vent Header 6/10/86 RC Letdown Sample SV  1.19 E-1 6.04 E-5  i 6/12/86 RC Letdown Sample SV  1.19 6.04 E-4 6'24/86 Testing of CAV 1, 2, SV .42 E-3
  & 3 Interlocks l'
6/25/86 Recirculation or RCS SV  ^ 752 3.82 E-4
*
Letdown 7/5/86 M0 Filter 2b Venting SV  1.51 7.62 E-4 l
l 7/11/86 Blown Ruptured Disc SV  1.71 9.48 E-4 on RC Evporator 7/24/86 Sample Gasket failure SV  0.251 1.28 E-4
*This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Report.


I
*6
*#
SEE AMENDED PAGE FOLLOWING  i l
      !
      '
T8-2
      '
RADIOLOGICAL EFFLUENT RELEASES *
n-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee
_Reborted
    % of Technical Specifications Comp e Release ' Activity Quarterly Date Involv  Point Released (Ci) Limit. Gamma 8/1/86 Hays Gas alyzer SV  0.366 2.12 E-4 Gas Release 8/8/86 Spent Resin De nt SV  0.855 4.32 E-4 !'
to MWST
      ,
8/7/86 Letdown Sample Take SV  1.56 7.92 E-4 Off Recirculation 8/12/86 Closed Cover on MUF SV  0.58 2.94 E-4 2b Housing 8/13/86 Deborating Demin SV  4.97 3.02 E-2 [
Regeneration Release
      ~
8/29/86 MUF 2A Change to Cask SV  1 .06 E-4 ;
9/1/86 RB Sump Of f Gas Af ter SV  1,29 6.6 E-4 Pumping 9/11/86 RCS Letdown Sampling: SV  7.81 3.96 E-3 MUT on Recirc    l 9/14/86 MU-V-105 Flange SV  1. 4 9.34 E-4 9/14/86 Deborating MU-V-8 S'V .66 E-4 9/22/86 MW Evap. Purge After SV  5.92 3.0 E-3 i Securing WDL-V-227    l
       -
       -
__m . _
9/23/86 Draining MU-F-2b SV  1.15 3.84 E-4 9/26/86 RM-A5 Increase & COG  .007 48 E-6 !
Sampling 9/27/86 ES Testing of CAV2 SV  1 .46 3
      '
      ,
*This information is preliminary and subject to refinement by the licensee in (
their Radiological Effluents Repor '
      !
      :
i
____t


.. T8-1 TABLE 8 RADIOLOGICAL EFFLUENT RELEASES *
_ _ _ _ - - . _ - - _ _ - - - - - - - - - _ - - - - - - - - - - --  -_
Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported
          ,
      % of Technical Specifications Component  Release  Activity Quarterly Date  Involved  Point  Released (Ci) Limit, Gamma 5/12/86  RC-RV-5  SV (Station Vent) 5.85  3.7 E-3 5/13/86  Reactor Coolant SV  6.3 E-1 3.2 E-4 System (RCS) &
  .
Pressurizer (PZR)
Sampling 5/27/86  WDGT-B Loss of SV  2.11 1.07 E-3 Pressure While Releasing WDGT-A
      .
6/2/86  Rx Trip Main Steam Main Steam Relief 2.50 E-5  4.7 E-7 Release  Valve (MSRV)
6/4/86  MU Demin Vent-to- SV  5.51 E-1 2.8 E-4 Vent Header 6/10/86  RC Letdown Sample SV  1.19 E-1 6.04 E 5 6/12/86  RC Letdown Sample SV  1.19 6.04 E-4 6/24/85  Testing of CAV 1, 2, SV .42 E-3
  & 3 Interlocks 6/25/86  Recirculation or RCS SV  0.752 3.82 E-4 Letdown
,
7/11/86  Blown Ruptured Disc SV  1.73 9.36 E-4 i  on RC Evporator 7/15/86  MU Filter 2b Venting SV  1.51 7.62 E-4
'
7/24/86  Sample Gasket Failure SV   4.01 2.04 E-3
*This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor ,.
!
. - - - . - . - - . .  . . - - . - . _ - - - - . . . . --
 
E~
t b
  .
  .
e T8-2 RADIOLOGICAL EFFLUENT RELEASES *
e T8-2 RADIOLOGICAL EFFLUENT RELEASES *
Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported
Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported
      % of Technical Specifications Componen,t  Release ' Activity Quarterly Date Involved Point Released (Ci) Limit, Gamma 8/1/86 Hays Gas Analyzer SV 0.366 2.12 E-4 Gas Release 8/8/86 Spent Resin Decant SV 0.855 4.32 E-4
          % of Technical Specifications Component    Release Activity   Quarterly Date Involved   Point Released (C1) Limit Gamma 8/1/86 Hays Gas Analyzer   SV 0.369  2.46 E-4 Gas Release 8/8/86 Spent Resin Decant   SV 0.852  4.32 E-4 I to MWST         l 8/7/86 Letdown Sample Taken   SV 1.56   7.92 E-4 Off Recirculation 8/12/86 Closed Cover on MUF   SV 0.58   2.94 E-4 2b Housing 8/13/86 Deborating Demin   SV 4.97   3.02 E-2 Regeneration Release 8/29/86 MUF 2A Change to Cask   SV 0.533  2.7 E-4 9/1/86 RB Sump Off Gas After   SV 1.29   6.6 E-4
  :to MWST 8/7/86 Letdown Sample Taken SV 1.56 7.92 E-4 Off Recirculation 8/12/86 Closed Cover on MUF SV 0.58 2.94 E-4 2b Housing
[  Pumping 9/11/86 RCS Letdown Sampling:   SV 7.81   3.96 E-3 MUT on Recirc 9/14/86 MU-V-105 Flange   SV 1.84   9.34 E-4 9/14/86 Deborating MU-V-8   SV .66 E-4 9/22/86 MW Evap. Purge After   SV 5.92   3.0 E-3 Securing WDL-V-227 9/26/86 RM-A5 Increase &    COG .007  9.48 E-6 Sampling 9/22/86 Draining MU-F-2b   SV 1.15   3.84 E-4 9/27/86 ES Testing of CAV2   SV 1 .46 E-3
; 8/13/86 Deborating Demin SV 4.97 3.02 E-2 Regeneration Release 8/29/86 MUF 2A Change to Cask SV 1 .06 E-4 9/1/86 RB Sump Off Gas After SV 1.29 6.6 E-4 Pumping 9/11/86 RCS Letdown Sampling: SV 7.81 3.96 E-3 MUT on Recirc 9/14/86 MU-V-105 Flange SV 1.84 9.34 E-4
  *This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor _ _ - - _ _ _ _ _ _ _ _ _ .
,
 
9/14/86 Deborating MU-V-8 SV .66 E-4 9/22/86 MW Evap. Purge After SV 5.92 3.0 E-3
.  . . .    - _ . -
  . Securing WDL-V-227 9/23/86 Draining MU-F-2b SV 1.15 3.84 E-4 9/26/86 RM-A5 Increase & COG  .007 9.48 E-6 Sampling 9/27/86 ES Testing of CAV2 SV 1 .46 E-3
aA
  *This information is preliminary and subject to refinement by the licensee in
'
. SEE AMENDED PAGE FOLLOWING
? F*
T8-3 RADIOLOGICAL EFFLUENT RELEASES *
No Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Repohsted
        % of Technical Specifications Compon t  Release  Activity  Quarterly Date Involve  Point  Released (Ci) Limit, Gamma 9/27/86 Regeneratin  "A" SV  1 .58 E-3 Deborating D in 9/29/86 RM-A5 Spikes  SV  .003 5.5 E-5
,
,
their Radiological Effluents Report.
10/13/86 Deborating Demin &  SV  3.52  1.79 E-3 PZR Sampling 10/20/86 Regeneration of  SV  6.43  3.94 E-3 WDL-K-1A 10/28/86 Leakage of CA-V-2  SV  8.95  4.54 E-3 During Isolation 10/28/86 Sampling RCS Gas  SV  19.87  1.01 E-2 10/29/86 Degassing Primary  SV  4 .68 E-2~
 
System
(
*This information is preliminary and subject to refineme t by the licensee in their Radiological Effluents Repor , , ..
  - .
- , , , , - - - - , - . . - - . - - . , _ , . - _ , . ..y _ . - _ . , , - _ . .--


_. . - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . ___ _ _ _ __ _  _ -
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _   . _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
              ,
  .a
;.


b o
T8-3 RADIOLOGICAL EFFLUENT RELEASES *
T8-3 RADIOLOGICAL EFFLUENT RELEASES *
              ;
Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported
Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported
            % of Technical Specifications Component       Release Activity  Quarterly Date Involved       Point Released (Ct) Limit, Gamma 9/27/86 Regenerating "A"      SV  1 .58 E-3 Deborating Demin
          % of Technical Specifications Component     Release Activity  Quarterly Date Involved     Point Released (Ci) Limit, Gamma 9/27/86 Regenerating "A"      SV  1 .58 E-3 Deborating Demin 9/29/86 RM-A5 Spikes      SV  .003 5.5 E-5 10/13/86 Deborating Demin &     SV 3.52 1.79 E-3 PZR Sampling 10/20/86 Regeneration of-      SV 6.32  3.86 E-3 WDL-K-1A 10/28/86 Leakage of CA-V-2     SV 8.95 4.54 E-3 During Isolation 10/28/86 Sampling RCS Gas     SV  19.87 1.01 E-2 10/29/86 Degassing Primary     SV  4 .68 E-2 System t
              '
*This information is preliminary and subject to refinement by the licensee in
9/29/86 RM-A5 Spikes      SV  .003 5.5 E-5 10/13/86 Deborating Demin &       SV   3.52 1.79 E-3 PZR Sampling 10/20/86 . Regeneration of       SV   6.43 3.94 E-3 WDL-K-1A 10/28/86 Leakage of CA-V-2-      SV   8.95 4.54 E-3 During Isolation 10/28/86 Sampling RCS Gas       SV  19.87 1.01 E-2 ,
-
10/29/86 Degassing Primary       SV  4 .68 E-2 System
their Radiological Effluents Report.
  *This-information is preliminary and subject to refinement by the licensee in their Radiological Effluents Report.


      -
!
        -
__  _ _ - _ _ - _ _ _ _ _ -


;
o.4-j ''  SEE AMENDED PAGE FOLLONING
o T8-4 TABLE 8 (Continued)
.-s T8-4 TABLE 8 (Continued)
RADIOLOGICAL EFFLUENT RELEASES tal Operating Releases (Gaseous) - Predominantly Noble Gas (includes non-routine releases listed above)
  ,    % of Technical Specifications Quarterl Month  tivity Releases (Ci)  Limit, Gamma _
May  127  1.01 E-1 June  204  1.55 E-1 July  7  1.27 E-1 August  27 .96 E-1 September  20 .54 E-1 October  Not Available Y  Not Available Yet Normal (Routine) Operating Releases - L uid - Predominantly Tritium  (
Month  Activity R leased (Ci)
May June  1 July  1 August  1 ,
September  1 October  Not Available Yet
*This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor . ,- _- . - - . . . ,. _ - - . . . _ .. TL g :.
.I y,
..,
.
    -T8-4 TABLE 8 (Continued)
RADIOLOGICAL EFFLUENT RELEASES Total Operating Releases (Gaseous) - Predominantly Noble Gas (includes non-routine releases listed above)
RADIOLOGICAL EFFLUENT RELEASES Total Operating Releases (Gaseous) - Predominantly Noble Gas (includes non-routine releases listed above)
  ,
    % of Technical Specifications Quarterly Month Activity Releases (C1) Limit, Gamma _
      % of Technical Specifications Quarterly Month Activity Releases (C1)   Limit, Gamma _
May 127  1.01 E-1
May   127  1.01 E-1 June   204  1.55 E-1 July   177 1.27 E-1 August   27 .96 E-1 September   20 .54 E-1 October  Not Available Yet Not Available Yet Normal (Routine) Operating Releases - Liquid - Predominantly Tritium Month   Activity Releared (Ci)
-
May June   1 July   1 August   1 September   1 October   Not Available Yet
June 204  1.55 E-1 July 173 1.27 E-1 August -220  1.96 E-1 September 200  1.54 E-1 October  221 1.64 E-1 Normal (Routine) Operating Releases - Liquid - Predominantly Tritium Month Activity Released (Ci)
  *This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _  >
May June 1 July 1 August 1 September 1 October 3.38
  *This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor  
}}
}}

Latest revision as of 18:26, 18 December 2021

Final SALP Rept 50-289/86-99 for May-Oct 1986,including Revs to Table 8
ML20213G454
Person / Time
Site: Three Mile Island Constellation icon.png
Issue date: 12/03/1986
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20213G433 List:
References
50-289-86-99-01, 50-289-86-99-1, NUDOCS 8705180299
Download: ML20213G454 (58)
v • d • e


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ENCLOSURE ~4

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-289/86-99 (FINAL REPORT)

GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION THREE MILE ISLAND (UNIT 1) NUCLEAR GENERATING STATION ASSESSMENT PERIOD: MAY 1, 1986 - OCTOBER 31, 198 BOARD MEETING DATE: DECEMBER 3, 1986

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SUMMARY OF RESULTS Facility Performance Recent SALP I SALP II- Trend Functional Area (9/16/85-4/30/86) (5/1/86-10/31/86)- (Last 3 Mos.)

. . Plant 0perations 2 2 - Radiological Controls 1 1 - Maintenance 2 1 - Surveillance Testing 1 1 - Startup Testing _ 1 NA NA Emergency' Preparedness 1 1 -

' Security and Safeguards 2 2 Improving Technical Support 3 2 - Training and Qualifi- 1 1 -

cation Effectiveness 1 Assurance of Quality 2 2 -

-- 1 Licensing 1 1 Declining

< Overview Overall, the licensee has continued to operate TMI-1 safely with a generally strong orientation toward nuclear safety. The organization is comprised of highly qualified and well-trained personnel. Many licensee initiatives go beyond regulatory requirement The strong support functional areas that remain noteworthy are radiological controls and emergency preparedness. Although improve-ment has been noted in the security / safeguards area, licensee per-formance and self-evaluation in this area appear to be heavily compliance oriented, and a broader, performance-oriented approach to program and system evaluation is needed. The maintenance and surveillance programs provide good assurance of the operability of safety-related equipment. The maintenance area has shown significant improvement as evidenced by (1) the material condition of the plant; (2) the relatively low number of plant trips and equipment problems for the SALP II period; and, (3) the licensee's positive control of work activities in the plant space . - , _ , . _ . . . _ _ __ . _ , . _ - _- _ - . _ _ - - . . _ _ . _ . __ - _ . . - _

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- However, in the past three SALP periods, the licensee's performance in the plant operations, . technical support, and assurance of quality functional areas has remained at or below a Category 2 level. A number of factors appear to be inhibiting performance improvements in these areas. These include (1) additional attention on the need to-instill a keen sense of quality-at all levels of the work force, which includes such attributes as strict procedure adherence and attention to detail in procedure review or implementation; (2) in-consistent policies and programmatic weaknesses; (3) additional attention on the need to properly balance work ~ production with safety perspective; and, (4) various individual personnnel error .In the assurance of quality functional area, there is one aspect of licensee self review processes that remains a concern of the NRC staf All licensee review groups have substantial qualifications and exper-tise to properly exercise their responsibility, they are thorough and inquisitive in their review, and they have demonstrated their ability to identify regulatory or safety issue However, management self-review of the more important issues raised by these groups is exces-

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sively delayed or lacks thoroughness, inquisitiveness, or responsive-ness to formulate effective corrective actions. Further management attention is needed to assure that the issues raised by the Itcensee's

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IV. PERFORMANCE ANALYSIS Plant Operations (1082 hours0.0125 days <br />0.301 hours <br />0.00179 weeks <br />4.11701e-4 months <br />, 41.6%)

Analysis During the previous assessment the licensee's performance was rated as Category 2. The NRC found that licensee management exhibited strong involvement in daily operations of the plant. Licensed operator per-formance and administrative controls were strong. Procedures were technically adequate but individual procedure step inadequacies per-sisted. The inability by middle managers to balance the pace of work activities along with proper procedure adherence was note The control room environment and overall operator command and control of plant operations contribute significantly to safe nuclear opera-tion Control room physical arrangement and policies are conducive to overall positive control of operation Limited access by non-licensed operators is maintained in the control roo Routine business, including shift briefings, is conducted away from the main control boards. A dedicated plant page line is used to eliminate the noise from other page lines in the control rm Plant operations are conducted in an orderly, professional, anc business-like manner, keeping the control room quiet. For the most part, procedures, plant records, and manuals are properly stored. A dress code continues to be implemente Licensed operator performance continued to be oriented toward nuclear safety but, in some instances, was not completely conservative. For example, their attempt to energize a non-safety related electrical bus from a safety bus, apparently in order to prevent a turbine trip, was done without fully considering the full effects of their actions, and those actions were not conservative. In general, strong depth of knowledge of plant conditions and on going evolutions by operating crews was noted. Continued use of shift technical advisers in trend-ing and early detection of plant equipment degradation is a positive attribut There is an overall respect for the use and proper implementation of procedure However, instances were again noted in which the proce-dure adherence problem resurfaced during this SALP period. Personal error was a factor but middle management influence also contributed to the problem. Of particular significance, for an engineered safety features actuation system test the operations department conducted a key plant evolution by use of many specific plant operating procedures instead of using an overall controlling surveillance procedur This contributed to a valve mispositioning, lack of independant verifica-tion, and an unknown entry into a TS action statement for the High Pressure Injection (HPI) system. The associated Plant Incident Report was shortsighted in that it focused on the personnel error aspects rather than programmatic / managerial problems surrounding the even _ . __

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-As exhibited in this instance, licensee personnel tend to overestimate their ability to conduct evolutions from memory or without rigorous control. The potential to adversely affect safety does exist if remedial actions on the procedure adherence problem are not effec-tiv As noted in the previous SALP, technical adequacy of station proce-dures was sufficient; however, some minor weaknesses continued to be noted. For example, station procedures addressing requirements for plant startup never addressed the control of the reactor building aircraft missile door; and, procedures on license power limit were not sufficiently clear in providing guidance for evaluation of brief excursions above licensed power leve In each case, the licensee took proper corrective action, but with some delay, to alleviate the specific deficienc However, licensee management did not question its own self-review process that permitted these inadequacie A factor in the procedure adequacy problem is the licensee's technical / safety review system. Inspections identified the following weaknesses: applicable procedures provided limited guidance and training on what constitutes an adequate responsible technical review and/or independent safety review; middle management performed a significant number of these reviews themselves despite their busy schedules and availability to do a quality review; and, an apparent misuse of the independence of review latitude provided by TS in that new but temporary procedures were written, reviewed, and approved by one department. Further inspections identified that the TS required technical / safety review was not properly implemented. A number of instances were noted when procedure changes were classified as not important to safety when they affected important-to-safety systems (ITS). Several special temporary procedures (new procedures)

involved system evolutions on ITS systems, but they were classified not ITS. This resulted in the 10 CFR 50.59 evaluation criteria not being considered prior to issuance of these procedures. Also, corporate procedures that administratively direct and document safety-related modifications to the plant were declassified from important to safety, apparently with no safety review required for these procedure In general, management resolution of issues developed by the NRC was acceptabl However one licensee response to a notice of violation reflected a non-conservative approach in implementing procedures with respect to alarm response procedure violations. This is repetitive of poor responses noted in the last SAL It is not clear whether licensee management has enhanced their attention to responses to violation Further, the licensee management tenta-tively disagrees with the safety review findings noted above (to be the subject of a forthcoming meeting wi+h the licensee).

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10-There was one reactor trip during the'SALP' period. This equates to a scram rate of two trips per year which is significantly better than the last SALP period. Including the one trip, there were only five licensee event reports submitted, three of which involved events from

. before.the start of the SALP period. -No particular conclusions'can be drawn with respect to the limited number of LER's during this period. (See also Section V.D for additional information on LER's submitted from outside this assessment period.)

-Site management continued to exhibit strong attention and involvement' '

in various aspects of plant operations. This was especially true for non-routine problems having potential safety significance; such as, the various seal problems with two reactor coolant pumps. Routine problems are also handled reasonably well with appropriate site operations,' maintenance and/or engineering personnel assigned to take corrective action. However, as noted in the last SALP, for certain issues corrective actions appear to be weak or not completely effec-tive such as for the procedure adherence and procedure adequacy problems noted above. Various licensee review groups from the

- Quality Assurance (QA) Department to the sub-committee members of the Board of Directors (Nuclear Safety and Compliance Committee) have identified these' and other problems. Sufficient resources and management attention were not effectively applied in a timely manner before they became issues with the NRC staf Overall,.the licensee's operation and management direction has been oriented toward safe nuclear operations, but it is not always fully conservative. Adequate resources have been applied to the operations of the unit to ensure safe operation. The review group organizations continue to be an effective tool in identification of licensee problems; however, they are less effective in causing change to resolve noted problems. Weaknesses in procedure adherence and technical adequacy still continues to be noted due to personnel error and programmatic deficiencies. Licensee personnel tend to overesti-mate'their abilities on conducting procedures from memory and do not always rigorously use procedures. A programmatic deficiency in the area of required technical / safety reviews for procedures has developed and warrants closer review and evaluation by the licensee and NRC staf Conclusion Category 2 Recommendation See Assurance of Quality Recommendations

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B. Radiological Controls (241 hours0.00279 days <br />0.0669 hours <br />3.984788e-4 weeks <br />9.17005e-5 months <br />, 9.2%)

Analysis During the previous SALP period, licensee performance was rated as Category 1, declining. The overall Radiological Controls program was noted to be sound and effective. The effluents reporting. program was well organized and functional. Some lapses of performance occurred, particularly in the areas of communication and outage management, as evidenced by the problems experienced at the start of the SM outag Implementation of the Radiological Controls program was of high quality during this assessment period, with well qualified staff, good procedures, suitable facilities, and effective implementation and management oversight. The licensee's radwaste management, effluent control and chemistry programs continued to be effectively implemented; however, minor problems were noted in achieving good analytical accuracies and sensitivitie The licensee organization and current level of management involvement is adequate for effectively implementing the Radiological Controls progra Positions are clearly identified with well-defined authori-ties and responsibilities. Clear policies and procedures are in place and are strictly adhered t Cooperation and communications among the Field Operations and Radiological Engineering staffs within the Radiation Protection Department appear effective and ensure adequate technical oversight of day-to-day work and outage activi-ties. A multi-level audit system provides an ambitious review of radiological activities and is implemented in accordance with controlling procedures. Corrective actions for internally and NRC-identified items are comprehensive and technically soun i

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personnel were found to be suitable for the routine implementa-tion of the Radiological Controls program. Preparations were made in a timely fashion to augment field operations staffing in preparation for the upcoming 6R outage. Inspections identi-fied a weakness in the general lack of experience with refuel-ing operations among the Field Operations and Radiological Engineering staffs. This has been recognized and responded to by the licensee with the presentation of specialized refueling training to all the health physics (HP) technicians. A staff member from both the Field Operations and Radiological Engi-neering sections was also sent to another site to observe j ongoing refueling operation Licensee radiological preparation for the upcoming 6R outage has been extensive. Instrument and facility upgrades have been completed to enhance contamination control and speed personnel access. Designated radiological engineers have been assigned ALARA (as low as reasonably achievable) planning and exposure-

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tracking responsibilities for identified high exposure jobs. Dis-cussions with the engineering staff indicated radiological planning for each job and incorporation of " lessons learned" was generally carried out in a timely manne A review of routine health physics activities indicated the licensee is effectively performing radiological posting, routine surveillance, and internal exposure control activities. The licensee continues to effectively utilize a radiation work permit (RWP) system to provide positive control over radiological work activitie Surveys performed in support of work were well documented and readily accessible. The licensee is implementing a particularly well-controlled high radiation area key control program to ensure access is controlled to locked high radiation area The licensee has demonstrated good control over liquid radwast There is evidence of improved communication among responsible groups and management goals have been established for waste minimization, inleakage reduction, dose commitment reduction, and decontamination efforts. Progress is reviewed monthl Performance reports for all evaporator runs are distributed to staff and managemen The licensee utilizes good trending technique in tracking the carameters which reflect system performanc The licensee continued to maintain an effective program for effluent control and monitoring during the assessment peric Surveillances were performed as required and, in many cases more frequently than required, for effluent releases and for primary and secondary coolant chemistr A technically sound and thorough approach to preventive mainte-nance for effluent radiation monitors was in place. A continuing systematic review of monitor surveillance records is perform?d to determine if "as-found" conditions require action to correct malfunc-tions. Radiological Engineering personnel were well acquainted with procedures for implementation of On-Site Dose Calculation Marual (00CM) methodolog The licensee's radiochemistry program is generally able to make accurate analysis of routine in plant and effluent samples. Only minor deficiencies, stemming from calibration and counting gecmetry differences, were identified during a sample analysis intercorrparison with the NRC Mobile Laboratory. These deficiencies were found not to affect the licensee's ability to conservatively quantify sample activity. However, a review of the licensee's post-accident sempling capability identified that the licensee was unable to meet the boron analysis sensitivities committed to in a 1983 letter to the NR Corrective action was initiated for this problem and it appears to be attributed to poor quality of review that determined the draft aro-cedure to do the analysis was no longer neede _ _ . . _

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Effective chemistry and radiochemistry procedures are in place; however, deficiencies were noted in the implementation of these procedures. Additional licensee attention should be paid to ensure effluent batch sample sensitivities are met and quality control intercomparisons are effectively performe Semi-Annual Radioactive' Effluent and Release Reports were generally satisfactory; however, one minor apparent violation resulted from the

. - failure of one report to include all required assessments. Audits of the ef fluents and chemistry areas were complete, timely, and thorough, and performed by technically knowledgeable personne In summary, licensee performance in the areas of radiation protection and effluent controls and measurements has generally impr.oved over the previous assessment period. No major viola-tions or programmatic weaknesses were identifie Conclusion Category 1 Recommendations

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14 Maintenance (260 hours0.00301 days <br />0.0722 hours <br />4.298942e-4 weeks <br />9.893e-5 months <br />, 10%)

Analysis The previous SALP rated the licensee's performance as Category 2, consistent. Overall, performance of maintenance activities was good and reflected proper establishment, implementation, and staffing for the program. Some instances of weak implementation; such as, proce-

-dure adequacy and technical support, were noted that required more management involvement. Performance during the Once-Through Steam Generator (OTSG) eddy-current outage was good as evidenced by the accomplishment of a large workload with few problems. Problems occurred during restart where personnel, primarily those conducting maintenance or modification work, were not aware of how their actions had the potential to cause a challenge to a safety syste The preventive and corrective maintenance program qualities were evidenced by the continuing good material condition of the plan The motor-operated valve test program, which is considered a strength, has identified several valve problems that resulted in repairs; adjustments; and, in one situation, motor replacement of a different size motor to alleviate a situation with excessive opera-ting torque. There have been no forced outages or reactor trips that were directly attributable to poor equipment maintenance. Isolated events had poor maintenance planning as a contributing factor. NRC inspections of the high pressure injection (HPI) and decay-heat removal valves indicated overall good maintenance practice and good material condition. The inspectors observed extensive quality assurance department oversight in this are The PAT II inspection determined that personnel were knowledgeable, work was technically sound, and job tickets were appropriately prioritized. The failure trending program was effective in identifying components that require repetitive repair. The vendor manual control and update program is still in the process of being completed. An example of poor vendor manual control was identified when an uncontrolled copy of a technical manual was used to calibrate Bailey meter multiplier modules and signal monitors. The use of this manual did not adversely affect the calibratio Maintenance procedures generally continue to be adequate to properly control work on safety related components. Two procedure weaknesses were identified that caused problems. One instance involved mis-handlino of a letdown system prefilter, which resulted in significant contamination of the filter cubicle. In another instance, weak procedures (part of the poor planning noted above) contributed to the reactor trip during this assessment. The root cause of the reactor trip was considered by the SALP board to be an equipment malfunction with a breaker over-current trip device, coupled with poor mainte-nance plannin .

The licensee has apparently taken effective corrective action with respect to improving worker attitudes while working in safety-related areas. No instances were noted by the inspectors where worker actions had the potential to cause a challenge to a safety system. With the current outage, worker conditioning to the shutdown mode could easily be established again and, accordingly, management would need to enhance their attention to that area on subsequent plant startu Environmental qualification (EQ) issues generally appeared to be properly addressed in maintenance procedures. The NRC review of maintenance on Westinghouse 08-25/50 breaker over-current trip device retrofit work revealed that the EQ issues were properly addressed and maintenance was performed satisfactorily. However, the PAT found that the licensee's review of hydrogen recombiner blower motor work did not identify and address potential EQ issues associated with lubrication of the motors. For the latter event, it was determined that maintenance personnel and the responsible technical reviewers (RTR's) for maintenance procedures had a lack of knowledge of the EQ program requirements indicating the need for additional training in this are Procurement and storage of components were also examined in cetail during this perio The preventive maintenance program extends into this area also. No major problems were identified although shelf life determination for certain components was questioned due to the potential for degradation of some internal components of certain solenoid valve Internal reporting of maintenance-related events is weak. No Plant Incident Report (PIR) was generated when a technician accidentally caused a ground while working on RM-L-6 that resulted in a trip of one of the a.c. reactor trip breaker The PIR for the make-up filter drop addressed the specific concerns of the filter work but did not evaluate other areas in plant maintenance activities where similar situations could cause similar problems. The threshold for reporting of these types of of events appears to be relatively hig A more thorough and extensive .se of the PIR system would enhance performance in this are The licensee has a strong :ommitment to an effective housekeeping program and has been aggressive in maintaining the plant clean and free of transient combustibles. Continued daily involvement is maintained through middle management daily backshift tours and frequent inspections of the entire plant. Noted deficiencies were tracked and quickly corrected by the maintenance department. A positive attitude toward maintaining area cleanliness existed; also the licensee attempted to reduce the number of areas that require radiological work permits (RWP's) for entries. There is strong

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emphasis in general employee training (GET) on the responsibility of each individual to maintain the plant clean. A similar philosophy is noted in licensee's approach in fire protection. Engineering involvement in inspections and program update has been note Hardware improvements continue to be performed to support full compliance with 10 CFR 50 Appendix Overall, performance of the maintenance activities has been well controlled. The organization, scheduling, and staffing of mainte-nance evolutions has not caused any major plant problems, except for contributing to the one reactor trip. Maintenance personnel are alert-to the changing conditions of the plant with respect to opera-tional condition Conclusion Category 1 Recommendations None

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17 Surveillance Testing (333 hours0.00385 days <br />0.0925 hours <br />5.505952e-4 weeks <br />1.267065e-4 months <br />, 12.8%)

Analysis During the previous SALP period, the licensee's performance was rated as Category 1. The licensee's surveillance program was adequate and aggressively implemented. Procedural weaknesses in the emergency feedwater system check valves and an inconsis-tency in the testing of the two vital battery banks was note These situations needed additional management attentio During this period, the licensee's surveillance program was exten-sively reviewed by NRC. The surveillance program continues to be a strength in the licensee's overall operation, with some minor excep-tions. Procedures are adequate and the computerized scheduling process continues to work well with no missed surveillances. A minor problem was noted with surveillance procedure change approval dates versus implementation times to be specified. The licensee program for controlling this process is still in the process of being changed so that approved procedure changes will have sufficient time to be issued in the field prior to their required use. With respect to inservice testing of pumps and valves, a number of programmatic issues remain open and are longstanding. Program enhancement in the area has been stifled or has been excessively delayed for test items not requiring major plant modification because of performance problems in the licensing area (see Section IV.J).

Procedure implementation in the past has generally been a strong point in the licensee's program. A review of instrument calibration with respect to recording "as-found" data (e.g., the static 0-ring pressure switch problem) revealed good practices in this area. There was generally good planning and pursuit of alternative approaches when problems were encountered with calibration of the boric acid mix tank (BAMT) level instrumentation. Implementation problems with a

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particular engineered safety features surveillance are addressed in the plant operations functional area. During the shutdown /cooldown evolution at the end of the SALP period, the conduct of several long complicated surveillances was accomplished in an orderly and controlled manne The reactor building tendon surveillance program report was I adequately prepared and reflected a complete test program in this are The PAT review of numerous procedures revealed no major weaknesses or problems. Periodic review of completed procedure Exception and Deficiency (E&D) sheets also confirmed that surveillance procedures can be performed with few exceptions. One minor problem involving an incomplete technical review was identified with the reactor vessel internals vent valve surveillanc _ _ _ _ _ _ _ _ - _ _ _ _ .

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inservice testing program. There is respect for the use and proper I' implementation of surveillances. Procedural weaknesses are rare and previous problems appear to have been correcte Conclusion Category 1

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Analysis During the SALP I assessment period, the licensee was rated as Category 1 in the area of emergency preparedness. This assessment was based on observation of the Federal Emergency Management Agency (FEMA) full participation exercise, which included NRC response team participation held on November 20, 1985. The licensee's execution and participation during the exercise demonstrated thorough planning and a strong commitment to emergency preparednes During this assessment period, there was a two part routine inspec-tion conducted on the recent consolidation of the three plant emer-gency plans (TMI-1, TMI-2, and Oyster Creek) into one GPU Nuclear Corporate plan. This consolidation is intended to standardize approaches to emergency response at all three plants. NRC review of the emergency plan consolidation indicated that generic information for the three sites had been combined, extraneous information elimi-nated, and essential plan elements (letters of agreement, evacuation time estimates) referenced. No decrease in the overall effectiveness of the plan had occurred and the plan continues to meet the require-ments of 10 CFR 50, Appendix E. The consolidation effort appears to be effective in providing a unified approach to emergency prepared-ness. No significant problems arose from the implementation of this new plan during the November 1986 exercise (which occurred outside this assessraent period).

The licensee continues to demonstrate a strong commitment to emer-gency preparedness. The emergency preparedness staff has been increased both in numbers and experience. The licensee has committed to do more unannounced drills and exercises per year and emergency preparedness training has been enhanced, which provides more depth and more trained personnel for emergency response. Quality Assurance audits of emergency preparedness activities are comprehensive and are reviewed by appropriate corporate officer The licensee has permitted local area fire fighters to use the licensee's " burn building" for training. This has made a positive contribution to local fire fighter preparedness to support an emer-gency at TMI. This reflects the licensees' commitment and initiative to emergency preparednes Emergency plans and implementing procedures are curren FEMA final review and approval of off-site plans will not be complete until next year; however, the delay is not attributable to the license .

Conclusion Category 1 Recommendations None

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21 Security / Safeguards (78 hours9.027778e-4 days <br />0.0217 hours <br />1.289683e-4 weeks <br />2.9679e-5 months <br />, 3.1%)

Analysis During the previous SALP pericd, the licensee's performance in this area was Category 2. The rating was influenced by a long-standing issue involving the perimeter intrusion detection system and a repetitive vic,lation on badge contro During 'this assessment period, one unannounced physical security .

. inspection and one material control and accountability inspection were performed by region-based inspectors, an NRC Regulatory Effec-tiveness Review (RER) was conducted, and routine resident inspections were performed throughout the period. Although no violations were identified, the RER tean identified several program vulnerabilitie Most of these were immediately corrected by the licensee; compensa-tory measures were taken for the remaining items since they may require more significant action to correc Both site and corporate management are actively involved in planning for current and long-term security program needs. Efforts to improve the quality of security operations are evident in the licensee's use of a self-inspection program and the accomplishment of comprehensive corporate audit Both the self-inspections and corporate audits are conducted by qualified personnel with extensive background and experience in physical security and focus on compliance with the licensee's commitments contained in the NRC-approved security program plans and their implementing procedures. Although the inspections and audits have significantly enhanced compliance (no violations of NRC requirements during this period), by being too compliance oriented they may overlook alternative means of improving the program. For example several of the problems found by the RER team should have been prev.ausly identified and corrected by the license The lack of this identification indicated either a need for a better understanding of NRC security program objectives by the licensee or a broader focus during audits to include program objective The licensee's Nuclear Security Director continues to be actively involved in matters affecting the program; e.g., frequent staff assistance visits, sponsorship of experienced audit team members, and participation in program implementation, modifications, and major upgrade plans. That level of involvement is indicative of senior management's interest in establishing and maintaining a quality security program. The Nuclear Security Director is also actively involved in the Region I Nuclear Security Association and other industry groups 2ngaged in addressing issues in the nuclear plant security are The licensee has implemented a " fitness for duty" program, which includes statements regarding the use of drugs and alcohol. The program requires employee scraening upon initial

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hire with the company. Additionally, requirements are placed on contract organizations to screen their personnel prior to employmen The licensee has instituted a random screening process at the department head level and abov Program enhancements implemented during this period included the updating of a Civil Disorder Plan, and the expansion of security organization policies to address such subjects as NRC Information Notices, Circulars, fitness for duty, uniform and appearance standards, and media matters. Another enhancement undertaken involves the contingency plan dril'. program. To ensure a more mean-ingful drill program, the number of required drills has been increased by the licensee and the drill scenarios are prepared by the security supervisors and approved in advance by management to ensure variations in the scenarios and exposure of all security force members to different scenarios. Critiques are performed for all drills and the results documented for feedback into the program. Any deficiencies identified during a drill, including personnel errors, result in the same drill being repeated until performance is accom-plished consistent with plan and procedural requirement These self-imposed criteria reflect the licensee's effort to improve the quality of training in order to be better prepared for contingency event Staffing of the security organization was observed to be consistent with the commitments in the NRC-approved security plan and adequate for the workload. Authority and responsibility were effectively organized among management and supervisory personnel and security force members were observed to be knowledgeable of their assigned duties and responsibilitie Facilities were found to be well maintained with sufficient space allocated for the operational needs of the program, as well as for both management and supervisio The design layout of equipment in the Central Alarm Station (CAS) incorporated human factors considera-tions that facilitates the CAS operator's ability to interface with other members of the security force and plant groups. Records were well maintained and readily accessible with repositories located and secured in accordance with safeguards information requirement Sufficient administrative, technical and logistical resources were allocated to provide support to the program. These factors are indicative of management attention to and oversight of the progra Although no required event reports were submitted to NRC during this assessment period, it was noted that the licensee's event reporting procedures and policies were consistent with the require-ments of 10 CFR 73.71. Personnel were found to be knowledgeable of their responsibilities in this area, including when reports are required and how and when to employ compensatory measures. The liccnsee's program for identifying and reporting security events was considered adequat O

'3 The training program continued to be effective as evidenced by no problems related to security personnel parformance during this assessment period. The training of the security organization continued to improve during this assessment period. The licensee's initiatives with regard to contingency drills are noteworthy and should improve the professional capability of the security forc With regard to control and accounting practices for special nuclear materials, the licensee was found to be in compliance with NRC requirement Procedures were generally understood and carried out by the responsible personnel. Records and reports were generally complete, well maintained, and avail-able. While the submittal of several material transaction reports was tardy due to a misinterpretation or misunderstand-ing of the directions associated with accounting for inventory changes, implementation of the program was judged as adequat During this assessment period, the licensee submitted a complete revision to the Contingency Plan in accordance with the provision of 10 CFR 50.54(p). This revision was reviewed by Region I and deter-mined to be acceptable. A summary of changes was provided with the revision to describe each change and pages were marked to identify areas changed to facilitate revie However, the summary was brief and, in a few cases, did not fully describe each change. That revision, as well as others under 10 CFR 50.54(p), are routinely being transmitted to NRR rather than to Region I, as required, causing unnecessary delays in the licensing review proces Generally, the quality of the submittals continues to be improve The prior SALP report, covering the period September 16, 1985, to April 30, 1986, idertified a longstanding safeguards licensing issue regarding the perimeter intrusion detection system (PIDS). The licensee has finally committed to accomplish this PIDS project by December 1987. Management attention is needed to assure that this completion date is met and to preclude such longstanding issues in the futur In summary, the licensee continued to make improvements to the security and safeguards areas during this assessment perio Increases in the program direction, management involvement and over-sight, and effective training were evident throughout the assessment period. Resolution of the outstanding intrusion detection system issue and management attention to preclude longstanding issues in the future will further enhance the total effectiveness of the security progra The security program, which appears to be very compliance oriented, could be enhanced by a more pro-active perspective and broader approach in light of the RER finding _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -

.

Conclusion Category 2, improving Recommendations i

None I

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _

_ _ _ ._ .

-

25 Technical Support (567 hours0.00656 days <br />0.158 hours <br />9.375e-4 weeks <br />2.157435e-4 months <br />, 21.8%)

Analysis The SALP I found a well-established modification control program but full implementation was not achieved. There were suspected programmatic weaknesses that would be reviewed by PAT II and other inspections during the SALP-II period. For modifications, the SALP I found poor supervision, lack of attention to detail in properly following applicable procedures, and poor technical / safety reviews. With respect to technical support for plant operational problems, the SALP I noted strengths in the highly i

visible items; such as, TMI-1 restart testing. However, technical support on routine and apparently less significant problems at the corporate and the site levels was weak. In plant and on-site control of outage work was good during the SALP I perio The licensee's modification control program was extensively reviewed by PAT II, except for a detailed engineering analysis of selected design

'

changes (conducted by PAT'I). The team noted significant improvement in the program subsequent to PAT I/SALP I findings. Applicable procedures had been reviewed and revised by the licensee to provide more explicit requirements. As an example, design verification procedures were revised to assure the verification process occurred before or at the time of modification turnover to the TMI-1 Division. Substantial training was

'

conducted on these program revisions and in applicable regulatory requi rer.:ents .

Regarding niodification control procedures, the frequent use of vague wording detracts from clarity and self-assessment and it has resulted in the above-noted problems. Management attention to the clarity of these

.

types of procedures was apparently lackin The " Mini Mods" program was noted to be a licensee initiative to reduce inefficiencies without bypassing regulatory requirements for the instal-lation of minor safety grade modifications. Another recognized licensee initiative was the consolidation of modification control procedures at the corporate level, since plant engineering personnel must essentially use those procedures for work accomplished by them. However, weaknesses were noted in procedures governing plant modifications engineered by plant engineering. These weaknesses were: lack of definitive criteria or what

! constitutes a replacement in kind; lack of a systematic process of assur-ing that replacement components conformed to detailed design specifica-tions (apparently left to discretion of plant engineer); lack of engineer-ing review of test data for modifications initiated by plant engineering; and, based on a review of implementation, insufficient support of technical / safety review assumptions.

'

In general, procedures associated with the modification control program were properly implemente However, persistent problems continued to be i

noted in drawing control and self review. The following drawing control problems were noted: inaccuracies in controlled hard copy drawings

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, _ . . . - . . - - , - - - - . - . - - . - - - - . = . - - - _ - -. -

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(including several control room drawings); excessiva delays in updating operations card drawings, which needed verification on updated status upon use; and, inaccuracies with the computer-based assistance system because of excessive delays in updating the computer file upon issuance of con-figuration changes. These problems could result in the use of outdated drawings to conduct design or operational activities. No instances of outdated procedure use were note The QA audits in this area subsequent to PAT I identified no discrepancies in this area. Overall, it appears that the corporate and site drawing control systems are not welt defined in a consistent set of procedures. Further, resources appear to be strained in this area. This resource problem in drawing control is a repetitive and longstanding issue at TMI-1. The PAT II team noted that knowledgeable personnel had difficulty in resolving obvious drawing dis-crepancy problems identified by PAT team members while using the licensee's control drawing system. The complexity of the system is high-lighted by another manually kept transaction file being used to complement the computer-based system for the current "as built" configuration of the plant. It would be unlikely that less familiar personnel who have to use this system on a routine basis would have the ability and patience to resolve obvious problems, considering schedular or operational pressure .

Also, the licensee self-review processes were weak to not identify these and other problems in advance of NRC staff inspections. For example, Technical Functions (TF) procedures were declassified from the Quality Assurance Plan (QAP) definitions of "important to safety" and "not important to safety". As a result, a different review process was in place and many

,

of the (TF) procedures governing the modification control program did not require safety review. This area will be discussed in a forthcoming meeting between NRC staff and the license The NRC staff review on the Environmental Qualification (EQ) of a certain cable types identified continued problems with EQ files. During NRC staff follow-up to PAT I concerns on the Kerite FR cable, the licensee was able to establish qualifications but minor errors in the EQ files were noted, necessitating licensee issuance of a design document revision. Related to this review was NRC staff follow-up on EQ concerns for BIW cable. The EQ

.

for this cable is still under NRC staff review because the licensee attempted to qualify the cable by analysis, not type testing. The EQ file lacked sufficient justification for this analysis so that a knowledgeable

.

individual could independently conclude on qualifications. The above-l noted errors and lack of significant documentation in the EQ files are a repetitive proble Training of engineering personnel involved in modification has been improved. In conjunction with the procedure revisions since SALP I, engineer training on these procedure revisions was conducted. Based on engineer interviews, there was positive feedback to NRC staff members on the training. This training was oriented toward the root cause of problems identified in the last SALP and at addressing the

, source of base regulatory requirements such as applicable ANSI Standards on the design control area. It appeared that this was the

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first such training for many, even senior, engineers other than indoctri-nation reading of applicable modification control procedures that engineers would potentially use. It appears that the recently conducted training will be factored into future new or refresher training sessions for new and experienced engineers. The Technical Personnel and Management Training area was not accredited by INPO as of the end of the SALP perio Past training weaknesses were a contributing factor in the cause of per-formance problems noted in the last SALP. Licensee management has shown initiative in being very supportive of outside professional development training. They also support owner group technical committees, which enhance the licensee's knowledge of the B&W design and related technical problems. Continued management attention to engineering training is neede Technical support to routine operational problems appears to have improved over the period at both the corporate and site levels. However, this was a somewhat less challenging period in that the intensive support needed for the TMI-1 restart and test program was lessened. Further, major operational problems have been minimal. Technical support problems occurred but they seemed to be minor and were related to communication difficultie Technical support for the refueling outage also appears to be adequat Some engineering delays were evident and have resulted in a relatively large amount of submittals needed to be submitted to NRC staff in the November-December 1986 time period to support needed NRC action for fuel movement or Cycle 6 startup activities. Pre-outage meetings on site started several months before the start of the refueling outage. Action items are tabulated on a computer-based file to permit various sorting and to enhance management attention to problem areas such as redesign work and procurement schedular problems. Overall, the licensee appears to have prepared adequately for the refueling outag In summary, the modification control program was well established and has improved but certain controlling procedures reflect weaknesse This lack of clarity and definitiveness in modification-controlling pro-cedures puts an undue burden on the discretion of individuals despite their high qualification and improved training. Implementation problems persist such as in the areas of drawing control and EQ. Overall, tech-nical support for routine operational problems appears to be appropriate; but it did not appear to be severely taxed during this period. Good overall preparations occurred for the refueling outag _ _

. - . _

.

Conclusion Category 2 Recommendations Licensee:

Undertake a self-analysis to determine the causes for inconsistent performance within this are NRC:

Conduct a team inspection of technical support groups with an emphasis on determining the causes of inconsistent performanc "

29 Training and Qualification Effectiveness Analysis-The various aspects of this functional area have been considered and i discussed as an integral part of other functional areas and the respective inspection hours have been included in each of the other functional areas. Consequently, this discussion is a synopsis of the assessment related to the training conducted in other functional areas. Training effectiveness has been measured primarily by observed performance of licensee's personnel and, to a lesser degree, by a review of the program adequacy. The discussion below, thus, addresses the training attributes and weaknesses as noted throughout all functional areas and the effect that these have on the overall safe operation of the plan During the previous assessment, the licensee performance was rated as Category 1. The training program was effective and oriented toward safe plant operations. Personnel were knowledgeable of plant work activities, procedural requirements, and, in general, conducted plant evolutions with care. Accreditation from the Institute of Nuclear Plant Operations (INP0) was received in five areas as of the end of the SALP perio No licensed operator exams were administered during this assessment period. The training programs were reviewed from a performance viewpoint in distinction to a programmatic viewpoint. Particular focus occurred on engineer training in light of past performance problems noted in the last SALP. The plant specific simulator was received near site and placed into a testing phase which should be completed by the end of 1986. Also, an INPO site visit occurred which should result in INPO accreditation for all ten area The NRC interviews of licensee's engineers confirmed that they are well qualified and technically traine They were experienced individuals and they were knowledgeable in the areas of their responsiblity. They felt that they had sufficient training to per-form the jobs that they did. They confirmed that the licensee management was supportive of formalized internal courses and outside courses. Many recognized the training aspect of their participating l in the B&W Owners' Group activities, which was also fully supported by the license From the previous assessment period, a weakness of engineers to fully understand related regulatory requirements and to follow procedures rigorously was note These weaknesses appear to be attributed to lack of specific training in this area. Based on review of the training program during this assessment period, it aopears that the performance in this area has improved and appropriate planned actions by licensee successfully corrected these deficiencie .

,-

The licensee's operator training and requalification training programs function well as evidenced by the licensee's performance during plant operations. Few events were attributed to operator /

training deficiencies. A noted strength of the licensee's training program is their pre-job briefings that are conducted by senior reactor operators (SRO's) or control room operators (CR0's) prior to conducting a special evolution in the plant. Discussions are held prior to the evolutions and, in most cases, contributed to successful completion of special evolutions in a safe and timely manner. An example of this is troubleshooting the integrated control system (ICS). This required the licensee to place many stations in manual mode and the operators received additional training prior to doing that to assist them in assuring that they maintained the plant in a safe condition. As noted below, there were isolated lapses in conservatism exhibited by licensed operator The licensee's training program for both licensed and non-licensed personnel is strong when dealing with reactor plant systems. Some weaknesses, however, have been noted in the training in the area of balance of the plant. In response to a balance of plant electrical bus loss and, apparently, in order to prevent a reactor trip, licensed operators attempted to re-energize these busses from a safety bus without fully knowing the cause of the electrical malfunction. Further, operations department handling of a change to procedures reflecting the licensed power limit was not conservativ The licensee's ability to maintain operators and technicians in six rotating sections, allowing one section to be in training status is also noted as a strong attribute in their training program. Review of the training that is performed demonstrates adequate in-depth knowledge is being gained by both non-licensed and licensed training operator In addition, prior to conducting a large or difficult maintenance job, maintenance-related training is conducted prior to the actual in-job performanc During this assessment period, a performance-oriented review of engineer training was conducted by NRC. In addition, portions of radiation protection, general employee training (GET), maintenance, fire protection, emergency preparedness, licensed / non-licensed requalification programs, and training programs were reviewed. In each of these areas, the licensee has provided adequate resources to conduct good, meaningful training. Adequate staff, good environment, and good training aids are provided by the licensee to ensure that adequate training for each of these groups is performed. However, in highly specialized areas for which personnel must take proper action, such as the EQ area, training appears to be lacking such as for the maintenance departmen . . . .. _ ..__ . . _ . - - . .- - . . .

..

,

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Individual technical and safety reviewers are specifically trained and qualified to perform their functions. The PAT II noted that, based on interviews, weaknesses existed with respect to reviewer's knowledge levels and processes for accomplishing responsible revie Thre interviews were conducted at a time of transition into a revised safety review process. Despite two years of planning, the revised review program was evidently hastily implemented and this, apparently, resulted in some reviewer confusion. However,.with respect to the

, definition of " licensing basis document," personnel knowledge level I was weak because the program did not practically define how the i

reviewer was to reference these documents. No adversity to safety resulted. Overall, reviewers did not pay enough attention to detail during their reviews, which has contributed to the procedure adequacy problems noted elsewhere in this repor In summary, the licensee's training program appears to be very

,

effective and performance oriented. There were isolated lapses in

<

conservatism with respect to operator performance. In general, i

personnel were knowledgeable on plant design and conditions and the workers had a good attitude toward safe operation of the plant.

Engineer training has been weak and has apparently contributed to past poor performance, but licensee improvements are encouragin Licensee management continues to be supportive of the training

program by providing necessary direction and involvement to ensure

that the training program remains a positive contribution to overall plant safet Conclusion

, Category 1

,

Recommendations None i

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I. Assurance of Quality Analysis Management involvement and control in assuring quality continues to be an evaluation criterion for each functional area. The various aspects of the programs to assure quality have been considered and discussed as an integral part of each functional area and the respective inspection hours are included in each one. Consequently, this discussion is a synopsis of the assessments relating to the quality of work conducted in other area During the previous assessment, the licensee performance was rated as Category 2. The previous assessment period highlighted several strengths in the licensee manageinent attention to and involvement with facility activities. In particular was noted Quality Assurance (QA) Department presence and involvement in all facets of operatio Weaknesses were noted in the area of procedure adherence and adequacy and in the effectiveness licensee's corrective actions on problems noted as a result of the licensee's self-review program that, at times, lacked inquisitiveness and thoroughnes In general, there is a respect for procedure use and proper imple-mentation, but nonadherences continue to be too frequent and too significan This repetitive problem is not solely attributed to personnel error which the licensee usually handles with varying degrees of disciplinary action. There appear to be varying, and sometimes adverse, personnel attitudes on procedure adherence, apparently dictated by middle management's action to excel or complete work. Although personnel error occurred, the poor procedure adherence for the recent ES testing was an example of middle manage-ment negatively influencing performances. Corrective actions appear to be delayed or not completely effective in resolving the procedure adherence proble As further insight into this problem, the licensee's Corporate Procedure Task Group, formed during the last assessment period,

, concluded, in part, that strict procedure compliance policy was not uniformly implemented by the different divisions of GPU This ta.sk group was thorough and its report identified that various divisions had varying degrees of compliance policie Further, the group found that division procedures were inconsistent with corporate policy / procedures. Due to a lack of specific guidance, middle managers of different divisions developed varying levels of procedure adherence and performance criterion in the division policies. Certain divisions adopted verbatim compliance, while others used vague wording like "should" or "if appropriate."

Corrective actions are being formulated and the licensee showed initiative in forming the task group; however, existing review groups should have identified the policy inconsistency earlie This demonstrated a weakness in the licensee self-review proces .

Overall, procedures are adequate to safely operate the facility; but, here again, individual step inadequacies are too numerous and too significant to be considered isolated cases. There appears to be a correlation between the attention to detail of technical / safety reviewers and the individual step inadequacies. Contributing factors appear to be a lack of specific administrative guidance on what constitutes an adequate review, misuse of the independence latitude provided by TS, and a heavy middle management involvement in perform-ing these reviews. Middle management attention to the program is noteworthy; but, in light of their schedules and workload, the quality of review appears to suffe Also, there appears to have been an improper implementation of-the review program for the procedures, tests, and modifications required by 10 CFR 50.59 and the Technical Specifications. A number of pro-cedure/ procedure changes were not properly classified "important to safety" (ITS) when they dealt with evolution on ITS systems. This resulted in the 10 CFR 50.59 evaluation criteria not being applied for the changes as required by TS. This is a longstanding issue between plant staff and the QA department. Corrective actions have been excessively delaye Apparently, in response to the QA department's classification issue, the licensee revised the review process in a manner which also apparently conflicts with the existing TS. 'The new review process relaxed requirements on when a detailed safety evaluation is to be conducted. The 10 CFR 50.59 evaluation associated with this new review process did not adequately address how the new system imple-mented TS, Management apparently felt the prior review system was too constraining or resource intensive. The products of this new review process have not resulted in any adverse safety issue based on an intensive review by the resident staff. However, many procedure changes are made without the benefit of a more detailed 10 CFR 50.59 type analysis. In several instances, procedures dealing with nuclear safety-related systems would now not receive a detailed evaluation and documentation to provide a basis for the determination as to whether the change involved an unreviewed safety question. The programmatic change is apparently inconsistent with the intent of the unit's technical specifications addressing procedure reviews. The change in the review system was implemented and not sufficiently challenged internally by any licensee review groups to preclude implementation without referral to the NRC staff. In this case, corrective actions appear to be inadequat In general, the Quality Assurance Department continues to be aggressive in their involvement in oversight activities. The QA audits were typically in-depth and adequately identify both positive and negative elements of the licensee's programs. The QA Department is using innovative techniques, such as safety system functional inspections and additional technical expertise to enhance the self-review process and provide better feedback to managemen .

Although 24-hour QA shift caverage stopped during this assessment period, licensee management continued " management backshift tours" and random backshift inspections by QA Departmen The required review process is individually based, rather than collegially based. Some collegial reviews were accomplished, at licensee's initiative. These initiatives include the continued use of the collegial review by the General Office Review Board (G0RB), Plant Review Group (PRG), Preliminary Engineering Design Reviews (PEDR), and Nuclear Safety and Compliance Committee (NSCC). These review groups or individuals responsi-ble for individual technical / safety review appear to be well qualified and are competent to perform their functions. Of particular note is the varied and substantial expertise within

. the GORB and NSCC, including its staff. It appears that the licensee's initiatives are much needed. All reviews have been successful in identifying significant weaknesses or problems; however, management responsiveness for effective corrective action was either delayed or weak, such as for the procedure adherence or adequacy problems addressed abov Responsible technical and safety review training was adequate (see previous section), but weaknesses in that area appear to be compounded by safety review programmatic deficiencies described abov The Independent On-Site Safety Review Group progressed in enhancing its own administrative program and implementatio Its effectiveness received limited review by NRC staff during this assessment, but an isolated problem was noted in their ability to initiate effective corrective actions with respect to why the reactor building missile door was open during power operation In summary, there is a respect for procedures at the facility and procedures are adequate for safe operatio However, procedure adherence and adequacy problems persist which are too numerous and significant to be considered isolated cases. Contributing factors, in addition to personnel error, are traceable to attitudes and programmatic weaknesses. Further, the different aspects of the licensee's organization have the attributes necessary to achieve the requirements to ensure safe nuclear power operations. Licensee review groups are capable of identifying both positive and negative elements of licensee programs. However, licensee corrective actions, in some instances, appear to be excessively delayed or weak. This may be due, in part, to a weak process of escalating issues to upper management. In general, management is responsive to correcting problems, but they appear to not aggressively pursue these issues to completio .

.

Conclusion Category 2 Recommendations Licensee:

(1) Continue efforts in correcting procedure adherence and procedure adequacy problem (2) Independently meet with the NRC staff to discuss the revised safety review process and the findings and corrective actions of the Procedure Compliance Task Grou NRC:

Meet with the licensee as noted abov _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _

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J. Licensing Analysis In the previous SALP evaluation, the licensee was rated a Category In that SALP, GPUN was credited for aggressive management involve-ment, primarily as a result of monthly meetings with NRR to discuss all active licensing issues. GPUN had also shown improvement in their no significant hazards determination (NSHD), which is required to accompany each technical specification change request. Although the licensee's overall performance has not changed significantly, some declining trends are developin The licensee is still meeting with NRR on a monthly basis to discuss priorities on all active licensing issues. This action is beneficial as several older licensing actions, which previously had lower priorities because of restart, are being actively pursued and completed. For example, technical specifications (TS) concerning decay heat removal requirements, an active issue since mid-1980, was issued during this report period. Additionally, the licensee's proposed resolutions of technical issues have been generally conser-vative and sound. GpuN's analysis and conclusiols concerning NSHD

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were usually well writte The licensee has responded quickly to NRR staff questions on various reviews in progress and provided adequate staff for NRC site visits to resolve particular concerns. Furthermore, the licensee was consistently responsive to NRC staff requests for information, even when they were made on short notice and did not involve an active licensing issue on TMI-1. An example of this cooperation was demonstrated when an NRC staff reviewer spent several hours with shift operators discussing operation of the Integrated Control System (ICS).

However, a recurrent problem has occurred during several reviews of the Inservice Testing Program (IST). There have been several exemp-tions from IST program requirements repeatedly requested by the licensee and denied by the NRC, For some of these exemptions, it does not appear that the licensee was vigorously pursuing alterna-

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tives to the required testing but was requesting an exemption based strictly on cost consideration The licensee apparently has assumed that exemptions requested would eventually be approved and has made no preparations for including the components in the IST program, i This is an example of a poor approach to testing of safety-related components. Either licensing should have more vigorously pursued the

exemption requests by initially exploring alternatives with the NRC and explaining why they were not feasible or licensee management should have mado plans to include the components in the IST program, as scheduled, while the exemptions were again under staff review, i

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The quality of the licensee's documentation of the basis for proposed TS changes has declined. There have been several instances where specific TS changes were either not discussed in the accompany-ing safety evaluation or were discussed only in vague and generalized terms. An example is the proposed amendment for the fuel handling building engineering safety features (ESF) ventilation system. The licensee's safety evaluation did not clearly identify or describe the basis for changes to the TS involving the auxiliary building ventila-tion system. A similar problem was noted in Section F, Security /

Safeguards, of this SALP for 10 CFR 50.54p reviews and Section G, Technical Support, for modification control procedures. Additionally, there has been a tendency in recent submittals to over-categorize changes as administrative in nature. An example of this is the proposed amendment to make existing radiological effluent TS conform with standard TS (NUREG-0472). Licensee management should be sensi-tive to TS changes that are not necessarily administrative in nature, but are easy to justify technically. These problems are not considered a major concern, because so far they have occurred in only I a few proposed amendments. However, they do reflect a developing trend because these applications with the above-noted weaknesses were

,

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submitted in succession during the latter part of the SALP perio l The licensee needs to improv.t itt. documentation describing and '

supporting proposed TS chang Additionally, there has been an increasing tendency to submit TS j changes which require a relativ91y quick turn-around review by the e NRC staff. Examples have included the axial power shaping rod (APSR)

[

withdrawal amendment and TS for the fuel handling building ESF l ventilation system. Further, there are numerous plant modifications scheduled for the Cycle 6 refueling outage that were known well in

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advance but for which no amendment have been submitted as of the end of this SALP period. For those instances where a submittal required i rapid turnaround, the licensee has been very cooperative with the NRC l to quickly resolve discrepancies and/or staff concern Nonetheless, a trend of untimely submittals has develope !

In summary, the licensee's performance in the functional area of 7 licensing activities is considered acceptable with some decline noted :

in certain areas such as timely submittals of TS change requests and the quality of evaluations accompanying these change request Conclusion Category 1, declining i

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Recommendations None  !

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V. SUPPORTING DATA AND SUMMARIES Investigations and Allegations Review There are no open investigations for TMI-1. The investigation on the environmental equipment qualification deficiencies and inaccurate submittals during 1981-1984 was completed outside the assessment period and reviewed by IE and Region I staff. Violations of NRC requirements were identified and they will be discussed in an upcoming enforcement conferenc The other allegation dealt with a concern on the potential for recriticality during post-engineering safety feature actuation situations. This is currently under review by Region Escalation Enforcement Actions None Management Conferences There was one management conference on August 12, 1986, to discuss the licensee's response to a violation dealing with fire brigade training and as follow-up on SALP I comments in the fire brigade training area. A re-submittal was received and it constituted a satisfactory response to the violation. A minor clarification was made to the SALP I repor On July 30, 1986, there was also a management meeting to discuss the SALP I result Licensco Event Reports In reference to Table 5, two Licensee Event Reports (LER's) were due to equipment / component malfunction, two were due to personnel error, and one was due to inadequate environmental qualification documenta-tion (which has a possible root cause of personnel error). No causal link can be inferred among the five LER's that were submitted during this assessment perio The Of fice of Analysis and Evaluation of Operational Data (AE00)

performed an analysis for LER's for the period from January 1,1986, to October 31, 1986. In general, the evaluation found the quality of the licenseo's LER's to be above average. Two weaknesses, however, were identified in terms of proper characterization of safety signi-ficance of key parameter The identified weaknesses involve the need to more fully assess the safety significance of the event and to provide a more complete discussion of personnel errors and procedure defic'encie The AE00 evaluation of LER's is being forwarded to the licensee under separate correspondence to present specific suggestions on Improving the quality of the report .

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E. Reactor Trips / Forced Outages l

l There was only one unplanned reactor trip on June 2, 1986, due to a turbine trip. The turbine trip occurred because of a loss of

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electro-hydraulic control oil pressure, which resulted from elec-

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trical bus de-energization. The root cause was poor design which

! resulted in the unexpected low settings of a breaker over-current

device. A contributing factor was poor maintenance planning. There l were no forced outages during this period.

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T1-1 SALP TABLE 1

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LISTING OF LERs BY FUNCTIONAL AREA CAUSE CODES AREA A B C D E X TOTA [

OPERATIONS 1 2 3 RAD CONTROLS MAINTENANCE 1 1 SURVEILLANCE EMERGENCY PRE SEC/ SAFEGUARDS TECHNICAL SUPPORT 1 1 i

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TRAINING QUALITY ASSURANCE LICENSING

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TOTALS: 7 ~f "T ~5 KEY: Cause Codes A - Personnel Error R - Design, Manufacture, Construction C - External 0 - Procedure Deficiency E - Equipment Malfunction / Failure X - Other/ Unknown

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T2-1 SALP TABLE 2 INSPECTION HOUR SUMMARY AREA HOURS % OF TIME OPERATIONS 1082 4 RAD CONTROLS 241 MAINTENANCE 260 1 SURVEILLANCE 333 1 EMERGENCY PREP, 37 SEC/ SAFEGUARDS 78 TECHNICAL SUPPORT 567 2 TRAINING NA NA ,

LICENSING QUALITY ASSURANCE NA NA NA NA (

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TOTALS: 2535 ID6TD i

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T3-1

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SALP TABLE 3 ENFORCEMENT SUMMARY SEVERITY LEVEL AREA 1 2 3 4 5 DEV TOTAL __ _ _

OPERATIONS 3 3 RAD CONTROLS MAINTENANCE 1 1 SURVEILLANCE 1 1 EMERGENCY PRE SEC/ SAFEGUARDS TECHNICAL SUPPORT 3 3 TRAINING LICENSING QUALITY ASSURANCE

...................

~ ~ ~ - -

TOTALS: l ~B

o

- T3-2 TABLE 3 (Continued)

ENFORCEMENT SUMMARY INSPECTION VIOL, FUNCTIONAL REPORT _REQUIREMENTLEVEL _ AREA _ VIOLATION

  • 289/86-12 10CFR50 APP 4 OPERATIONS INADEQUATE SAFETY EVALUATION FOR B,CT V CHANGE TO PROCEDURES DESCRIBE 0 IN .

07/07/86 08/14/86 FSAR

  • 289/86-12 10CFR50 APP 4 OPERATIONS FAILURE TO TAKE PROMPT C03RECTIVE B/XVI ACTIONS ON CONDITIONS ADVERSE TO 07/07/86 08/14/86 QUALITY

'289/86-12 10CFR50 APP 4 TECHNICAL INADEQUATE IMPLEMENTATION OF QUALITY 8/XVI SUPPORT ASSURANCE PLAN 07/07/86 08/14/86 i

  • 289/86-12 10CFR50 APP 4 TECHNICAL FAILURE TO ADHERE TO REQUIREMENTS OF B/II SUPPORT MODIFICATION CONTROL PROCEDURES 07/07/86 08/14/86 289/86-17 10 CFR 4 MAINTENANCE FAILURE TO EVALUATE CABLE MODIFICATION 50.5 IN REACTOR BUILDING PENETRATION 09/08/86 10/03/86 289/86-17 TS 6. SURVE!LLANCE FAILURE TO PROPERLY CONDUCT ESAS SURVEILLANCC PROCEDURE 09/08/86 10/03/86 289/86-17 10CFR50 B/3 4 OPERATIONS FAILURE TO IMPLEMENT A DESIGN BASES

& A/4 ASSUMPTION ON REACTOR DUILDING EQUIP-09/08/86 10/03/86 MENT HATCH MISSILE 000R 289/86-17 ANSI 4 TECHNICAL FAILURE TO PROVIDE DESIGN BASIS FOR 45.2.11 P $UPPORT RADIATION MONITOR SETTINGS 09/08/86 10/03/86

' Violations identiflod by asterisk were discussed in SALP ! and issued during this assessment perio P

. _ - _ _ - _ _ .

.

.-

,

T4-1 TABLE 4 INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS AREAS INSPECTED 289/86-08 SPECIALIST 11 CORPORATE INDEPENDENT TECHNICAL AND SAFETY 04/30/86 05/02/86 REVIEW - OTHER REVIEW INITIATIVES SUCH AS GENERAL OFFICE REVIEW BOARD 289/86-09 RESIDENT 323 ROUTINE PLANT OPERATIONS AND REACTOR TRIP 05/17/86 06/27/86 EVENT - MAINTENANCE AND SURVEILLANCE ON BORIC ACID INJECTION SYSTEM (IST) -

MODIFICATIONS OF CONTAINMENT ISOLATION SYSTEM 289/86-10 RESIDENT 206 ROUTINE OPERATIONS, REPORTS RECEIVED, 06/27/86 08/01/86 FILTER OROP EVENT - ROUTINE MAINTENANCE AND SURVEILLANCE, DECAY HEAT VALVE MAINTENANCE - l ESF VENTTILATION INSTALLATION (NRR WALK 00WN)

289/86-11 SPECIALIST 49 REVIEW OF MATERIAL CONTROL AND ACCOUNTING 7/22/86 07/24/86 FOR SPECIAL NUCLEAR MATERIAL 289/86-12 RESIDENT 54 SPECIAL SAFETY INSPECTION BASED ON PAT I 07/07/86 08/14/86 FINDINGS ADDRESSING AREAS OF IMPLEMENTATION AND MODIFICATION CONTROL, CONDUCT OF SAFETY EVALUATION IMPLEMENTATION, DESIGN CONTROL l REQUIREMENTS 289/86-13 RESIDENT 318 ROUTINE REVIEW OF PLANT OPERATIONS AND i

08/01/86-08/08/86 SURVEILLANCE AND VARIOUS EVENTS, i MAINTENANCE PROGRAM, RAOCON CONTROLS, REPORT REVIEW (ECT) AND PREVIOUS FINDINGS I - DESIGN CHANGES l 289/86-14 SPECIALIST 720 PAT II - PROGRAMMATIC REV!EW OF PLANT

, 08/25/86-09/05/86 OPERATIONS, MAINTENANCE, SURVEILLANCE, l TECHNICAL / SAFETY REVIEW, M00!FICATION <

CONTROL, ASSURANCE OF QUALITY 289/86-15 SPECIALIST 29 SECURITY ORGANIZATION, ACCESS CONTROL, 08/11/86-08/14/86 PERSONNEL SEARCH, BOUNDARIES, COMMUNICATIONS, RER FOLLOW UP ,

289/86-16 SPECIALIST 37 PROGRAMMATIC REVIEW IN THE AREA 0F EMERGENCY 09/22/86-10/17/86 PREPARE 0 NESS l

l I

_ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _ _

.

T4-2 TABLE 4 (Continued)

INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS AREAS INSPECTED 289/86-17 RESIDENT 482 ROUTINE PLANT OPERATIONS - RCP SEAL PROBLEMS 09/08/86-10/03/86 AND HIGH REACTOR BUILDING RADIOLOGICAL ACTIVITY - MAINTENANCE / SURVEILLANCE ON MAKE-UP VALVE OPERABILITY, FIRE PROTECTION, REPORTING PROGRAM, SAFETY REVIEW, CHEMISTRY, i MATERIAL, DOCUMENT CONTROL

289/86-18 SPECIALIST NA MANAGEMENT MEETING ON CONTESTED VIOLATION 08/12/86-08/12/86 ON FIRE BRIGADE TRAINING 289/86-19 RESIDENT 369 PLANT OPERATIONS AND POWER COAST 00WN, RCP 10/03/86-10/31/86 - MAINTENANCE / SURVEILLANCE ON OH VALVES -

RADIATION PROTECTION ON EFFLUENTS CONTROL, INDEPENDENT MEASUREMENTS - PRE-0UTAGE REVIEW

_ _ _ _ -

- _ _ _ _ _ _ _ _ - _ _ _ _ __ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ _-__

o

.

T5-1 TABLE 5

,LER SYNOPSIS LER NUMBER EVENT DATE CAUSE CODE' pESCRIPTION i

86-08 04/21/86 E REACTOR TRIP DURING STARTUP DUE TO MALFUNCTION OF 4160 V CLASS IE CIRCUIT D BREAKER DUE TO EQUIPMENT / COMPONENT MALFUNCTION 86-09 04/22/86 X ENVIRONMENTAL QUALIFICATION FOR REACTOR BUILDING EMERGENCY COOLING FANS CABLE WERE NOT AVAILABLE 86-10 04/23/86 A REACTOR TRIP FROM 8% POWER DUE TO HIGH PRES $URE FROM LOSS OF MAIN FEED DUE TO PERSONNEL ERROR AND PROCEDURE INADEQUACY 86-11 06/02/86 E REACTOR TRIP FROM TUR0!NE TRIP AT 100%

POWER DUE TO EQUIPMENT MALFUNCTION OF A

FEEDER BREAKER OVERCURRENT DEVICE COUPLED WITH P0OR MAINTENANCE PLANNING 86-12 09/04/86 A INOPERABLE FIRE DETECTOR FOR 10 ES SWITCHGEAR ROOM

  • $ee Table il for cause codes

,

i s

i

,

_ _ - _

.

.

T6-1 TABLE 6 FORCED OUTAGES AND UNPLANNED AUTOMATIC SCRAMS POWER PROXIMATE ROOT DATE LEVEL CAUSE _ CAUSE 06/02/86 100% TURBINE TRIP MALFUNCTION OF NON 1E FEEDER BREAKER OVERCURRENT DEVICE COUPLED WITH POOR MAINTENANCE PLANNING DESCRIPTION: TURBINE TRIP OUE TO LOSS OF BOTH ELECTRO-HYORAULIC CONTROL OIL PUMPS DURING TUR0!NE PLANT ELECTRICAL REPAIRS r

!

I t

I l

,

,

.

l

!

T7-1 TABLE 7 LICENSING ACTIVITIES This section provides a sumnary of significant licensing actions and other activities during the SALP evaluation period NRR/ Licensee Mootings at Bethesda - 8 NRR Sito Visits - 5 Commission Ortefings - None Schedule Extensions Granted - 1 Appendix H (Surveillance Capsule) - discussed in last SALP Reitof t Granted - 1 Exemptions Granted - 1 (See No.4, Schedulo Extensions) Licensee Amendments !ssued - 5 Emergency Technical Specification Changes !ssued - None i Orders !ssued - None

l i

  • /

SEE AMENDED PAGE FOLLOWING T8-1 TABLE __8 RADIOLOGICAL EFFLUENT RELEASES *

Non- ut_in Events Resulting in Off-Site Releases of Noble Gases (Licensee Report _1

% of Technical Specifications Componen Release Activity Quarterly Date involved point Released (C1) Limit. Gamma 5/12/86 RC-RV-5 SV (Station Vent) 5.85 3.7 E-3 5/13/86 Reactor Coolant SV 6.3 E-1 3.2 E-4 System (RCS) &

Pressurizer (P2R)

Sampling 5/27/86 WDGT-B Loss of $ 2.11 1.07 E-3 Pressure While Releasing WDGT-A 6/2/86 Rx Trip Main Steam Main Ste- Relief 2.50 E-5 4.7 E-7 Release Valvo(MSR 6/4/86 MU Domin vent-to- SV 5.51 E-1 2.8 E-4 Vent Header 6/10/86 RC Letdown Sample $V 19 E-1 6.04 E-5 6/12/86 RC Letdown Sample SV .04 E-4 6/24/86 Testing of CAV 1, 2, SV .42 E-3

& 3 Interlocks 6/25/86 Recirculation or RC$ SV 0.752 3.82 E-4 Letdown 7/11/86 Blown Ruptured Disc $V 1.73 ' 6E4 on RC Evporator 7/15/86 MV Filter 2b Venting SV 1.51 7.62 .4 7/24/86 Sample Casket failure $V 4.01 2.04 E 3

  • This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor ._ . _ ___ _ __

_ _ _ _ _ _ _ _ _

a

'

.

T8-1 TABLE 8 l RADIOLOGICAL EFFLUENT RELEASES *

Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee-Reported

% of Technical l Specifications l Component Release Activity Quarterly i Date involved Point Released (C1) Limit, Gamma l

5/12/86 RC-RV-5 SV (Station Vent) 5.85 3.7 E-3 5/13/86 Reactor Coolant SV 6.3 E-1 3.2 E-4

System (RCS) &

i Pressurizer (PZR)

Sampling

,

5/27/86 WDGT-B Loss of SV 2.11 1.07 E-3 l Pressure While Releasing WOGT-A

6/2/86 Rx Trip Main Steam Main Steam Relief 2.50 E-5 4.7 E-7 Release Valve (MSRV)

6/4/86 MU Domin Vent-to- SV 5.51 E-1 2.8 E-4

Vent Header 6/10/86 RC Letdown Sample SV 1.19 E-1 6.04 E-5 i 6/12/86 RC Letdown Sample SV 1.19 6.04 E-4 6'24/86 Testing of CAV 1, 2, SV .42 E-3

& 3 Interlocks l'

6/25/86 Recirculation or RCS SV ^ 752 3.82 E-4

Letdown 7/5/86 M0 Filter 2b Venting SV 1.51 7.62 E-4 l

l 7/11/86 Blown Ruptured Disc SV 1.71 9.48 E-4 on RC Evporator 7/24/86 Sample Gasket failure SV 0.251 1.28 E-4

  • This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Report.

I

  • 6

SEE AMENDED PAGE FOLLOWING i l

!

'

T8-2

'

RADIOLOGICAL EFFLUENT RELEASES *

n-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee

_Reborted

% of Technical Specifications Comp e Release ' Activity Quarterly Date Involv Point Released (Ci) Limit. Gamma 8/1/86 Hays Gas alyzer SV 0.366 2.12 E-4 Gas Release 8/8/86 Spent Resin De nt SV 0.855 4.32 E-4 !'

to MWST

,

8/7/86 Letdown Sample Take SV 1.56 7.92 E-4 Off Recirculation 8/12/86 Closed Cover on MUF SV 0.58 2.94 E-4 2b Housing 8/13/86 Deborating Demin SV 4.97 3.02 E-2 [

Regeneration Release

~

8/29/86 MUF 2A Change to Cask SV 1 .06 E-4 ;

9/1/86 RB Sump Of f Gas Af ter SV 1,29 6.6 E-4 Pumping 9/11/86 RCS Letdown Sampling: SV 7.81 3.96 E-3 MUT on Recirc l 9/14/86 MU-V-105 Flange SV 1. 4 9.34 E-4 9/14/86 Deborating MU-V-8 S'V .66 E-4 9/22/86 MW Evap. Purge After SV 5.92 3.0 E-3 i Securing WDL-V-227 l

-

9/23/86 Draining MU-F-2b SV 1.15 3.84 E-4 9/26/86 RM-A5 Increase & COG .007 48 E-6 !

Sampling 9/27/86 ES Testing of CAV2 SV 1 .46 3

'

,

  • This information is preliminary and subject to refinement by the licensee in (

their Radiological Effluents Repor '

!

i

____t

_ _ _ _ - - . _ - - _ _ - - - - - - - - - _ - - - - - - - - - - -- -_

,

.

.

e T8-2 RADIOLOGICAL EFFLUENT RELEASES *

Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported

% of Technical Specifications Component Release Activity Quarterly Date Involved Point Released (C1) Limit Gamma 8/1/86 Hays Gas Analyzer SV 0.369 2.46 E-4 Gas Release 8/8/86 Spent Resin Decant SV 0.852 4.32 E-4 I to MWST l 8/7/86 Letdown Sample Taken SV 1.56 7.92 E-4 Off Recirculation 8/12/86 Closed Cover on MUF SV 0.58 2.94 E-4 2b Housing 8/13/86 Deborating Demin SV 4.97 3.02 E-2 Regeneration Release 8/29/86 MUF 2A Change to Cask SV 0.533 2.7 E-4 9/1/86 RB Sump Off Gas After SV 1.29 6.6 E-4

[ Pumping 9/11/86 RCS Letdown Sampling: SV 7.81 3.96 E-3 MUT on Recirc 9/14/86 MU-V-105 Flange SV 1.84 9.34 E-4 9/14/86 Deborating MU-V-8 SV .66 E-4 9/22/86 MW Evap. Purge After SV 5.92 3.0 E-3 Securing WDL-V-227 9/26/86 RM-A5 Increase & COG .007 9.48 E-6 Sampling 9/22/86 Draining MU-F-2b SV 1.15 3.84 E-4 9/27/86 ES Testing of CAV2 SV 1 .46 E-3

  • This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor _ _ - - _ _ _ _ _ _ _ _ _ .

. . . . - _ . -

aA

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. SEE AMENDED PAGE FOLLOWING

? F*

T8-3 RADIOLOGICAL EFFLUENT RELEASES *

No Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Repohsted

% of Technical Specifications Compon t Release Activity Quarterly Date Involve Point Released (Ci) Limit, Gamma 9/27/86 Regeneratin "A" SV 1 .58 E-3 Deborating D in 9/29/86 RM-A5 Spikes SV .003 5.5 E-5

,

10/13/86 Deborating Demin & SV 3.52 1.79 E-3 PZR Sampling 10/20/86 Regeneration of SV 6.43 3.94 E-3 WDL-K-1A 10/28/86 Leakage of CA-V-2 SV 8.95 4.54 E-3 During Isolation 10/28/86 Sampling RCS Gas SV 19.87 1.01 E-2 10/29/86 Degassing Primary SV 4 .68 E-2~

System

  • This information is preliminary and subject to refineme t by the licensee in their Radiological Effluents Repor , , ..

- , , , , - - - - , - . . - - . - - . , _ , . - _ , . ..y _ . - _ . , , - _ . .--

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.a

.

T8-3 RADIOLOGICAL EFFLUENT RELEASES *

Non-Routine Events Resulting in Off-Site Releases of Noble Gases (Licensee Reported

% of Technical Specifications Component Release Activity Quarterly Date Involved Point Released (Ci) Limit, Gamma 9/27/86 Regenerating "A" SV 1 .58 E-3 Deborating Demin 9/29/86 RM-A5 Spikes SV .003 5.5 E-5 10/13/86 Deborating Demin & SV 3.52 1.79 E-3 PZR Sampling 10/20/86 Regeneration of- SV 6.32 3.86 E-3 WDL-K-1A 10/28/86 Leakage of CA-V-2 SV 8.95 4.54 E-3 During Isolation 10/28/86 Sampling RCS Gas SV 19.87 1.01 E-2 10/29/86 Degassing Primary SV 4 .68 E-2 System t

  • This information is preliminary and subject to refinement by the licensee in

-

their Radiological Effluents Report.

!

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o.4-j SEE AMENDED PAGE FOLLONING

.-s T8-4 TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES tal Operating Releases (Gaseous) - Predominantly Noble Gas (includes non-routine releases listed above)

,  % of Technical Specifications Quarterl Month tivity Releases (Ci) Limit, Gamma _

May 127 1.01 E-1 June 204 1.55 E-1 July 7 1.27 E-1 August 27 .96 E-1 September 20 .54 E-1 October Not Available Y Not Available Yet Normal (Routine) Operating Releases - L uid - Predominantly Tritium (

Month Activity R leased (Ci)

May June 1 July 1 August 1 ,

September 1 October Not Available Yet

  • This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor . ,- _- . - - . . . ,. _ - - . . . _ .. TL g :.

.I y,

..,

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-T8-4 TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES Total Operating Releases (Gaseous) - Predominantly Noble Gas (includes non-routine releases listed above)

% of Technical Specifications Quarterly Month Activity Releases (C1) Limit, Gamma _

May 127 1.01 E-1

-

June 204 1.55 E-1 July 173 1.27 E-1 August -220 1.96 E-1 September 200 1.54 E-1 October 221 1.64 E-1 Normal (Routine) Operating Releases - Liquid - Predominantly Tritium Month Activity Released (Ci)

May June 1 July 1 August 1 September 1 October 3.38

  • This information is preliminary and subject to refinement by the licensee in their Radiological Effluents Repor
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