ML20207M405

SALP Rept 50-289/86-99 for May-Oct 1986

ML20207M405
Person / Time
Site:	Three Mile Island
Issue date:	01/05/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207M383	List: ML20207M380 ML20207M405
References
50-289-86-99, NUDOCS 8701130171
Download: ML20207M405 (54)

See also: IR 05000289/1986099

Text

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U. S. NUCLEAR P.EGULATORY COMMISSION

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

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TABLE OF CONTENTS

Page

I. INTRODUCTION

A. Purpose and Overview. . . . . . . . . . . . . . . . 1

B. SALP Board Members. . . . . . . . . . . . . . . . . 1

C. Background. . . . . . . . . . . . . . . . . . . . . 3

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II. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . . 4

III. SUMMARY OF RESULTS

A. Facility Performance. . . . . . . . . . . . . . . . 6

B. Overview. . . . . . . . . . . . . . . . . . . . . . 6

IV. PERFORMANCE ANALYSIS

A. Plant Operations. . . . . . . . . . . . . . . . . . 8

B. Radiological Controls . . . . . . . . . . . . . . . 11

C. Maintenance . . . . . . . . . . . . . . . . . . . . 14

D. Surveillance. . . . . . . . . . . . . . . . . . . . 17

E. Emergency Preparedness. . . . . . . . . . . . . . . 19

F. Security and Safeguards . . . . . . . . . . . . . . 21

G. Technical Support . ................ 25

H. Training and Qualification Effectiveness. . . . . . 29

I. Assurance of Quclity. . .............. 32

J. Licensing . . . . . . . . . . . . . . . . . . . . . 36

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V. SUPPORTING DATA AND SUMMARIES

A. Investigations and Allegations Review . . . . . . . 38

B. Escalated Enforcement Actions . . . . . . . . . . . 38

C. Management Conferences. . . . . . . . . . . . . . . 38

D. Licensee Event Reports. .............. 38

E. Reactor Trips / Forced Outages. . . . . . . . . . . . 39

TABLES

Table 1 - Listing of LER's by Functional Area. . . . . . . . . . .T1-1

Table 2 - Inspection Hour Summary . . . . . . . . . . . . . . . .T2-1

Table 3 - Enforcement Summary. . . . . . . . . . . . . . . . . . .T3-1

Table 4 - Inspection Report Activities . . . . . . . . . . . . . .T4-1

Table 5 - LER Synopsis . . . . . . . . . . . . . . . . . . . . . .T5-1

Table 6 - Forced Outages and Unplanned Automatic Scrams. . . . . .T6-1

Table 7 - Licensing Actions. . . . . . . . . . . . . . . . . . . .T7-1

Table 8 - Radiological Effluent Releases . . . . . . . . . . . . .T8-1

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I. INTRODUCTION

A. Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an

integrated NRC staff effort to collect available observations

and data on a periodic basis to evaluate licensee performance. The

SALP process is supplemental to the normal inspection processes used

to ensure compliance with NRC rules and regulations. It is intended

to be sufficiently diagnostic in order to provide a rational basis

for allocating NRC resources and to provide meaningful guidance to

the licensee's management in order to improve the quality and safety

of plant operations and modifications.

This report is the SALP Board's assessment of the licensee's perfor-

mance at TMI-1 Nuclear Generating Station for the six-month period

from May 1, 1986, to October 31, 1986.

This SALP is termed SALP II since it is the second of two SALP's

directed by the Commission in its restart order. It is also the

third of three SALP's covering the period since TMI-1 restart

(October 3, 1985). The first SALP of this series was termed interim

to focus on the first three months of operations during an intense

testing period. SALP I included the interim SALP period and was

directed by the Commission's restart order.

An NRC SALP Board, comprised of the staff members listed in

Section B, met on December 3, 1986, to review the collection of

performance observations and data to assess the licensee's

performance in accordance with the guidance in NRC Manual

Chapter 0516, " Systematic Assessment of Licensee Performance."

A summary of the guidance and evaluation criteria is provided

in Section II of this report.

B. SALP Board Members

Chairman

W. Kane, Director, Division of Reactor Projects (DRP), Region I (RI)

Members -

L. Bettenhausen, Chief, Operations Branch, Division of Reactor

Safety (DRS), RI

A. Blough, Chief, Reactor Projects Branch No.1, DRP, RI

R. Conte, Chief, Reactor Projects Section No. IA, DRP, RI

W. Johnston, Deputy Director, DRS, RI (Part Time)

T. Martin, Director, Division of Radiation Safety and Safeguards

(DRSS),RI

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J. Thoma, Operating Reactors Project Manager (TMI-1), Project

Directorate (PD) No. 6, Office of Nuclear Reactor Regulation

(NRR)

J. Weller, Section Leader, PD No. 6, NRR

F. Young,. Senior Resident Inspector. (TMI-1), DRP, RI

Other-Attendees

D. Johnson, Resident Inspector (TMI-1), DRP, RI

R. Pearson, Inspection Specialist, Office of Inspection and

Enforcement

T. Ross, Project Manager (TMI-1), PD No. 6, NRR

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C. Background

1. Licensee Activities

During this 6-month period, the -licensee operated the plant at

essentially full power. There was one reactor trip on June 2,

1986, due to a turbine trip and the plant returned _to service

within one day. In September 1986, there was a brief power

reduction to fully withdraw axial power shaping control rods

(APSR's) to extend the fuel cycle to 290 115 effective full

power days. An end-of-cycle power coastdown to approximately

95 percent power occurred during the last week of this period.

The planned reactor shutdown for the Cycle 6 refueling outage

occurred on the last day n! the SALP II period (October 31,

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1986).

Operational problems potentially affecting power operation were

minimal during this period. Of significance were the excessive

leakage from the No. 1 seal on the "C" Reactor Coolant Pump

(RCP) and the below normal leakage from the No. I seal on the

"A" RCP. Seal replacements were scheduled for the refueling

outage. There was no adverse effect on Reactor Coolant System

(RCS) unidentified leakage.

Routine surveillance and maintenance continued through the SALP

II period and progress was made on Cycle 6 required modifica-

tions without impacting power operations.

2. Inspection Activities

One senior resident inspector and three resident inspectors

were assigned to the site. They were supported by region-based

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and headquarters inspectors in order to complete NRC staff

commitments to the Commission to review various licensee

programs. This included the second of two Commission-directed

Performance Appraisal Team inspections (termed " PAT II"). The

PAT II inspection not only followed up on PAT I/SALP I findings

but also covered the following functional areas programmatically:

plant operations; ma.intenance; surveillance; technical support

(primarily modification control); and, assurance of quality.

In reference to Table 2, the total inspection hours for the 6-month

period was 2,598 or 5,196 hours0.00227 days <br />0.0544 hours <br />3.240741e-4 weeks <br />7.4578e-5 months <br /> on an annual basis. Of that

six-month total, 28 percent occurred during the PAT II inspection.

For the SALP I and SALP II periods (September 16, 1985 - October 31,

1986), the combined total inspection hours was 9,059.

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II. CRITERIA

Licensee performance was assessed in selected functional areas significant

to nuclear safety and the environment. Assessment areas were selected

based on facility status of normal operations. Consequently, SALP II

includes typical SALP functional areas for an operating plant.

One or more of the following evaluation criteria were used to assess

each functional area.

1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety

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standpoint

3. Responsiveness to NRC initiatives

4. Enforcement history

5. Reporting and analysis of reportable events

6. Staffing (including management)

7. Training qualification end effectiveness

This report also discusses " Training and Qualification Effectiveness" and

" Assurance of Quality" as separate functional areas. Although these

topics, in themselves, are assessed in the other functional areas, through

their use as evaluation criteria, a synopsis of these two areas

is provided. For example, quality assurance effectiveness has been

assessed on a day-to-day basis by resident inspectors and as an integral

aspect of specialist inspections. Although quality work is the respon-

sibility of every employee, one of the management tools to measure this

effectiveness is reliance on quality assurance inspections and audits.

Other major factors that influence quality, such as involvement of

first-line supervision, safety committees, and worker attitudes, are

discussed in each area.

Technical Support continued as a special functional crea because of the

involvement of Plant Engineering and Technical Functions in significant

safety activities at TMI-1. The startup and test functional area was not

evaluated during this SALP period because no activities occurred in that

area. Similarly, the fire protection area is not discussed as a separate

functional area because of insufficient inspection activity to warrant a

separate assessment. The available observations on fire protection and

housekeeping are included in the various relevant functional areas.

Based upon the SALP Board assessment, each functional area evaluated

is classified into one of three categories. The definitions of

these performance categories are:

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Category 1. Reduced NRC attention may be appropriate. Licensee

management attention and involvement are aggressive and oriented

toward nuclear safety; licensee resources are ample and effectively

used so that a high level of performance with respect to operational

safety or construction is being achieved.

Category 2. NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are

concerned with nuclear safety; licensee resources are adequate and

reasonably effective so that satisfactory performance with respect

to operational safety or construction is being achieved.

Category 3. Both NRC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and

considers nuclear safety, but weaknesses are evident; licensee

resources appear to be strained er not effectively used so that

minimally satisfactory performance _ with respect to operational

safety or construction is being achieved.

Normally, the SALP Board assesses each functional area to compare

the licensee's performance during the last quarter of the assessment

period to that during the entire period (normally one year) in order

to determine the recent trend for each functional area. Because of

the short period covered by this SALP, the SALP board evaluated

performance for discernible trends in the last three months (one

half) of the SALP period. The SALP trend categories are as follows.

Improving: Licensee performance has generally improved over

the last part of the SALP assessment period.

Declining: Licensee performance has generally declined over

the last part of the SALP assessment period.

A trend is assigned only when, in the opinion of the SALP board, the

trend is significant enough to be considered indicative of a likely change

in the performance category in the near future. For example, a classi-

fication of " Category 2, Improving" indicates the clear potential for

" Category 1" performance in the next SALP period.

Notwithstanding the allowance permitted by a Category 1 rating to permit

reduced NRC attention, NRC oversight at TMI-1 will be maintained at a

high level because of its unique circumstances; i.e., the return to

operations after over six years of shutdown, as well as enhanced

government and public attention to TMI-1 events. Due to the nature

and scope of activities at TMI-1, it is NRC's intention that close scrutiny

be provided for the first two years of operation from restart similar to

that provided for a plant receiving its initial full power license. The

next SALP evaluation period will, therefore, be 12 months.

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III. SUMMARY OF RESULTS

A. 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.)

1. Plant Operations 2 2 -

2. Radiological Controls 1 1 -

3. Maintenance 2 1 -

4. Surveillance Testing 1 1 -

5. Startup Testing 1 NA NA

6. Emergency Preparedness 1 1 -

7. Security and Safeguards 2 2 Improving

8. Technical Support 3 2 -

9. Training and Qualifi- 1 1 -

cation Effectiveness

10. Assurance of Quality 2 2 -

11. Licensing 1 1 Declining

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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 spaces.

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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 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 errors.

In the assurance of quality functional area, there is one aspect of

licensee self-review processes that remains a concern of the NRC staff.

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

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own internal review groups are aggressively pursued to resolutinn.

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IV. PERFORMANCE ANALYSIS

A. 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 noted.

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 operations. Limited access by

non-licensed operators is maintained in the control room. 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 room. 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 implemented.

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

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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

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

attribute.

There is an overall respect for the use and proper implementation of

procedures. However, instances were again noted in which the proce-

i dure adherence problem resurfaced during this SALP period. Personal

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error was a factor but middle management influence also contributed

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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-

tive.

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 deficiency. However, licensee management did not question

its own self-review process that permitted these inadequacies.

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 procedures.

In general, management resolution of issues developed by the

NRC was acceptable. However one licensee response to a notice

of violation reflected a non-conservative approach in implementing

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procedures with respect to alarm response procedure violations. This

is repetitive of poor responses noted in the last SALP. It is not

clear whether licensee management has enhanced their attention to

responses to violations. 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.)

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 staff.

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

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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: staff.

Conclusion

Category 2

Recommendation

See Assurance of Quality Recoramendations

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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

evidence.d by the problems experienced at the start of the SM outage.

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 sensitivities.

The licensee organization and current level of management involvement

is adequate for effectively implementing the Radiological Controls

program. 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 sound.

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 operations.

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 manner.

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 activities.

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 areas.

The licensee has demorstrated good control over liquid radwaste.

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 monthly. Performance reports for all

evaporator runs are distributed to staff and management. The

licensee utilizes good trending technique in tracking the parameters

which reflect system performance.

The licensee continued to maintain an effective program for

effluent control and monitoring during the assessment period.

Surveillances were performed as required and, in many cases

more frequently than required, for effluent releases and for

primary and secondary coolant chemistry.

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

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affect the licensee's ability to conservatively quantify sample

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activity. However, a review of the licensee's post-accident sampling

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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;

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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 ~'

failure of one report to include all required assessments. Audits of

I. the effluents and chemistry areas were complete, timely, and

j thorough, and performed by technically knowledgeable personnel.

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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 identified.

Conclusion

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Category 1

Recommendations

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C. Maintenance (260 hours0.00301 days <br />0.0722 hours <br />4.298942e-4 weeks <br />9.893e-5 months <br />, 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  ;

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

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

Bailey meter multiplier modules and signal monitors. The use of this

l' manual did not adversely affect the calibration.

i.

i 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-

4 handling of a letdown system prefilter, which resulted in significant

I contamination of the filter cubicle. 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 .- , . _ _ , _ , _ , - _ . _ _ -,- ,, _ ...-.,., _ _ ... _ ._ _ _ _ _._ _.. _ _

.

.

15

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 startup.

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 area.

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.

.

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.

l A more thorough and extensive use of the PIR system would enhance

performance in this area.

i

l The licensee has a strong commitment to an effective housekeeping

i

'

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 ,____

.

.

16

.

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 noted.

Hardware improvements continue to be performed to support full

compliance with 10 CFR 50 Appendix R.

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 conditions.

Conclusion

Category 1

Recommendations

None

!

L

-.

.

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

.

.

17

D. 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 noted.

These si.tuations needed additional management attention.

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).

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 manner.

The reactor building tendon surveillance program report was

adequately prepared and reflected a complete test program in

this area.

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

. . _ _ _ _ __ - -

.__ . .- _

_ _ __. . ._ _ . _ __. .

..

M

...

18

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 corrected.

Conclusion

Category 1 -

Recommendations

None

,

u

4

4

1

5

4

!

I

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

-.

.

19

E. Emergency Preparedness (37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br />, 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 part.icipation during the exercise demonstrated thorough planning

and a strong commitment to emergency preparedness.

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).

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 officers.

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 preparedness.

Emergency plans and implementing procedures are current. 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

~

1

.

20 j

i

Conclusion  !

l

'

Category 1

Recommendations

None

i

.

1

I

I

-

___ - .m _ _ _ .

-

...

21

F. 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 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 control. ,

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 vulnerabilities.

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 correct.

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 licensee.

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 objectives.

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.

1

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

,

.,. v-., ,. , ,. , , - - - , . . + - , w, n -,.,--w,-r , -._.__--.-n..,n.- ~-_..n.n. , , - - -.-. , , .--

..

.

.

9

T

$,.

22

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 above.

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 program. 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

events. .

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 responsibilities.

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 requirements.

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 program.

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 73.71. 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 adequate.

4

- - , , - .

,

a

23

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 force.

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 adequate.

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 review. 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 process.

Generally, the quality of the submittals continues to be improved.

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 future.

In summary, the licensee continued to make improvements to the

security and safeguards areas during this assessment period.

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

program. 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 findings.

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

.

.

24

Conclusion

Category 2, improving

Recommendations

None

l

l

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

.

.

25

G. 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 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 period.

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

requirements.

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 assumptions.

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

.

.

26

(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 .

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 pressures.

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 licensee.

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 problem.

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

-

.

27

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 period.

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

needed.

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

difficulties.

Technical support for the refueling outage also appears to be adequate.

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;

, but it did not appear to be severely taxed during this period. Good

l overall preparations occurred for the refueling outage.

.

!

l

l

1

,-_ -

. - _.

1

~:

l

o ,

28

- ,

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 performance.

>

<

1

,

5

i

.

,

b

.

. _ _ . _ _ , _ . . . , _ ..__, ._,.. ,.- ,. ._._,_ , , ~ , . . . . _ . _ _ . . . , . _ _ . . . _ . . _ _ , _ , , . , . _ . , . , . _ _ . _ , _ , _ , _ _ _ . , _ _ -

..

s.

29

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,.

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 plant.

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 period.

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 areas.

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.

i From the previous assessn.ent period, a weakness of engineers to

4

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 area. 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 deficiencies.

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

r-w

-

.

30

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 (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 operators.

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 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 conservative.

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 program. Review

of the training that is performed demonstrates adequate in-depth

knowledge is being gained by both non-licensed and licensed training

operators. In addition, prior to conducting a large or difficult

maintenance job, maintenance-related training is conducted prior to

the actual in-job performance.

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 department.

__

.

s-

31

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 review.

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

' 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 report.

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 plant.

Engineer training has been weak and has apparently contributed to

past poor performance, but licensee improvements are encouraging.

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 safety.

Conclusion

Category 1

Recommendations

None

!

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

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

.

' 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 areas.

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 operation.

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 thoroughness.

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 problem.

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 policies.

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

i. levels of procedure adherence and performance criterion in the

i

division policies. Certain divisions adopted verbatim compliance,

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

,

.-,---ev.a.,r-ne.---

- ,,-,-n----.w-

- , . . .. . _ _ . - _ -_ . _ _ _ __ _ _. . . _ . _ . _ ___

1 s-

t

. x

33

,

Overall, procedures are adequate.to safely operate the facility; but,

here again, individual step inadequacies are too numerous and too

3

'

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 suffer. ,

4

'

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-

} 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

'

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

i too constraining or resource intensive. The products of this new

j. 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

L 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

i. 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

'

In general, the Quality Assurance Department continues to be

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

[ Department is using innovative techniques, such as safety system *

i functional inspections and additional technical expertise to enhance

the self-review process and provide better feedback to management.

!

l

I

\, .

o

y

34

Although 24-hour QA shift coverage stopped during this assessment

period, licensee management continued " management backshift tours"

and random backshift inspections by QA Department.

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 above. 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 above.

The Independent On-Site Safety Review Group progressed in

enhancing its own administrative program and implementation.

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

operations.

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 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

completion.

,

.

35

Conclusion

Category 2

v Recommendations

Licensee:

(1) Continue efforts in correcting procedure adherence and procedure

adequacy problems.

(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 Group.

NRC:

Meet with the licensee as noted above.

.

.

-

,

36

J. Licensing

Analysis

In the previous SALP evaluation, the licensee was rated a Category 1.

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 developing.

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 written.

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-

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 program.

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.

..-

.

37

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 /

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 period.

The licensee needs to improve its documentation describing and

supporting proposed TS changes.

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 developed.

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 requests.

Conclusion

Category 1, declining

Recommendations

None

- ___ _ _. __ _. _. _ _ . _ . - --

,

38

V. SUPPORTING DATA AND SUMMARIES

A. 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 conference.

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 I.

B. Escalation Enforcement Actions

None

C. 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 report.

On July 30, 1986, there was also a management meeting to discuss the

SALP I results.

D. 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 period.

The Office 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 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 reports.

-

. ."

e

39

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 period.

r--

.

.,

T1-l'

.SALP TABLE 1

LISTING OF LERs BY FUNCTIONAL AREA

CAUSE CODES _

AREA' A B C- D E X TOTAL

.

OPERATIONS 1 2 3

RAD CONTROLS

MAINTENANCE 1 1

SURVEILLANCE

EMERGENCY PREP.

SEC/ SAFEGUARDS

TECHNICAL' SUPPORT : 1 1

TRAINING

QUALITY ASSURANCE

LICENSING

___________________

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 41.6

RAD CONTROLS 241 9.2

MAINTENANCE 260 10.1

SURVEILLANCE 333 12.8

EMERGENCY PREP. 37 1.4

SEC/ SAFEGUARDS 78 3.1 '

TECHNICAL SUPPORT 567 21.8

TRAINING NA NA

LICENSING .NA NA

QUALITY ASSURANCE NA NA

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

TOTALS: 2598 100.0

.

--

,p-%e*-w&w we y-e-.* *i:+w*mvee-T'Wy---=v-M--y=F-N'*wN-'*-v-emT*""* **'W "N"*'8'-"Y

-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 PREP.

SEC/ SAFEGUARDS

TECHNICAL SUPPORT- 3 3

TRAINING

LICENSING

QUALITY ASSURANCE

___________________

TOTALS: 8 8

s

%

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

50.59.B IN REACTOR BUILDING PENETRATION

09/08/86 10/03/86

289/86-17 TS 6.8.1 4 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 P4.2 SUPPORT RADIATION MONITOR SETTINGS

09/08/86 10/03/86

4

• Violations identified by asterisk were discussed in SALP I and issued during l

this assessment period. 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.

.$_

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

.

._

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

'

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%

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

• See Table T1 for cause codes

r

~ g.

.

..

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

,

_

-

r

-s

.

e

T7-1

TABLE 7

LICENSING ACTIVITIES

<

This section provides a summary of significant licensing actions and other

activities during the SALP evaluation period

1. NRR/ Licensee Meetings at Bethesda - 8

2. NRR Site Visits - 5

3. Commission Briefings - None

4. Schedule Extensions Granted - 1

a. . Appendix H (Surveillance Capsule) - discussed in last SALP

5. Reliefs Granted - 1

6. Exemptions Granted - 1 (See No.4, Schedule Extensions)

7. Licensee Amendments Issued - 5

8. Emergency Technical Specification Changes Issued - None

9. Orders Issued - None

t

i

f

'l

r

!

.

1

--nr -

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-m- e~--

-

__m . _

4

..

e.

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 8.7 4.42 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 Report. ,.

!

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

E~

t b

.

e

T8-2

RADIOLOGICAL EFFLUENT RELEASES *

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

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

8/13/86 Deborating Demin SV 4.97 3.02 E-2

Regeneration Release

8/29/86 MUF 2A Change to Cask SV 17.5 8.06 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

,

9/14/86 Deborating MU-V-8 SV 1.9 9.66 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 12.7 6.46 E-3

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

,

their Radiological Effluents Report.

(

- .

_. . - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ . ___ _ _ _ __ _ _ -

,

6

b

o

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 (Ct) Limit, Gamma

9/27/86 Regenerating "A" SV 16.9 8.58 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 6.43 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 47.2 3.68 E-2

System

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

their Radiological Effluents Report.

1

-

-

6

o

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 177 1.27 E-1

August 278.5 1.96 E-1

September 202.7 1.54 E-1

October Not Available Yet Not Available Yet

Normal (Routine) Operating Releases - Liquid - Predominantly Tritium

Month Activity Releared (Ci)

May 9.0

June 16.2

July 11.1

August 11.2

September 18.7

October Not Available Yet

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

their Radiological Effluents Report.

_ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ >