ML20207S775

SALP Rept 50-219/85-98 for 850701-861015

ML20207S775
Person / Time
Site:	Oyster Creek
Issue date:	03/12/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207S761	List: IR 05000219/1985098 ML20207S760 ML20207S775
References
50-219-85-98, NUDOCS 8703200261
Download: ML20207S775 (69)

See also: IR 05000219/1985098

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-219/85-98

GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION

OYSTER CREEK NUCLEAR GENERATING STATION

ASSESSMENT PERIOD: JULY 1, 1985 - OCTOBER 15, 1986

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BOARD MEETING DATE: NOVEMBER 25 and 26, 1986

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PDH ADOCK 05000J19

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. TABLE OF CONTENTS

.P. agg

I. INTRODUCTION ....................... 1

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

B. SALP Board Members . . . . . . . . . . . . . . . . . . 2

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

II. CRITERIA ......................... 5

III. SUMMARY OF RESULTS .................... 7

A. Facility Performance . . . . . . . . . . . . . . . . . 7

B. Overall Facility Evaluation ............. 8

IV. PERFORMANCE ANALYSIS ................... 9

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A. Plant Operations . . . . . . . . . . . . . . . . . . . 9

B. Radiological Controls ................ 13

C. Maintenance ..................... 18

D. Surveillance / Inservice Testing . . . . . . . . . . . . 22

E. Emergency Preparedness . . . . . . . . . . . . . . . . 25 i

F. Security and Safeguards ............... 27

G. Outage Management / Refueling ............. 30  ;

H. Technical Support .................. 34

I. Training and Qualification Effectiveness . . . . . . . 37

J. A s s ura nce o f Qua l i ty . . . . . . . . . . . . . . . . . 40

K. Licensing Activities . . . . . . . . . . . . . . . . . 44

V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . 47

A. Investigations and Allegations Reviews . . . . . . . . 47

B. Escalated Enforcement Actions ............ 48

C. Management Conferences . . . . . . . . . . . . . . . . 49

0. Licensee Event Reports . . . . . . . . . . . . . . . . 50

_ TABLES

Table 1 - Tabular Listing of LERs by Functional Area ...... T1-1

Table 2 - LER Summary . . . . . . . . . . . . . . . . . . . . . . T2-1 r

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

Table 4 - Inspection Hours Summary ............... T4-1

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Table 5 - Inspection Report Activities ............. TS-1

Table 6 - Enforcement Data ................... T6-1

Table 7 - Unplanned Trips and Shutdowns . . . . . . . . . . . . . T7-1

Table 8 - SALP History. . . . . . . . . . . . . . . . . . . . . . T8-1

Table 9 - Licensing Activities. . . . . . . . . . . . . . . . . . T9-1

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Figure 1 - Number of Days Shutdown ............... F1-1

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I. Introduction

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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 sampling and periodic basis and,to evaluate licensee

performance based upon this information. The SALP is supplemental

to normal processes used to ensure compliance to NRC rules and

regulations. It is intended to be sufficiently diagnostic to provide

a rational basis for allocating NRC resources and to provide

meaningful guidance to the licensee's management to promote quality

and safety of plant operations and modifications.

l A NRC SALP Board, composed of the staff members listed below, met on

November 25 and 26, 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

l evaluation criteria is provided in Section II of this report.

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

, performance at the Oyster Creek Nuclear Generating Station for the

period July 1,1985 to October 15,1986. The summary findings and

totals reflect the fifteen and one-half month assessment period.

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B. SALP Board Members

Chairman

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

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l Members

S. Collins, Deputy Director, Division of Reactor Projects (Part-time)

W. Bateman, Dyster Creek Senior Resident Inspector

R. Blough, Chief, Reactor Projects Section IA

J. Donohew, Project Manager, BWR Project Directorate #1, Division of

BWR Licensing

W. Johnston, Deputy Director, Division of Reactor Safety

! J. Joyner, Chief, NMSS Branch, (DRSS)

, R. Keimig, Chief, Safeguards Section, NMS&SB, DRSS (Part-time)

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M. Shanbaky, Chief, Facilities Radiation Protection Section

(Part-time)

Attendees

, W. Baunack, Project Engineer, RPS 1A, PB No. 1, DRP

l R. Conte, TMI #1 Senior Resident Inspector

R. Freudenberger, Reactor Engineer, RPS 1A, PB 1 DRP

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H. Kister, Chief, Project Branch No.1, DRP (Part-time)

W. Madden, Physical Security Inspector, SS, NMS&SB, DRSS (Part Time)

S. Sherbini, Radiation Specialist (Part Time)

J. Wechselberger, Resident Inspector, Oyster Creek

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C. Background

1. Licensee Activities

At the beginning of the period, the unit was operating at full

power. On July 8, a reactor scram occurred due to low condenser

vacuum which resulted from steam Jet air ejector drain tank pump

problems. The reactor was restarted on July 9. During the

period from July 15 to July 22, problems were experienced with

the emergency service water (ESW) system. These problems resulted

primarily from the loosening of a protective coating inside the

ESV system piping. On July 22 the unit was placed in cold shutdown

to inspect, clean, and hydrolaze sections of ESW piping, flush

the systen . and perform post-maintenance testing.

The reactor was restarted on August 3. On August 9 the reactor

was again shut down to add oil to two unit substation transform-

ers in which low oil level had been detected. During the

shutdown process, a reactor scram occurred due to inadvertent

insertion of all intermediate range monitors. On August 10, a

restart was initiated. Various equipment problems were experienced;

however, the plant continued to operate until October 18, when

the unit was shutdown for a month-long mini-outage to complete

required environmental qualification modifications.

Following the mini-outage the plant was restarted on November

16. On November 20, a reactor trip occurred due to a generator

trip which resulted from a current transformer (CT) failure.

The CT was replaced and the unit restarted on November 23. The

unit continued to operate until December 15, at which time the

reactor scrammed due to high flux caused by turbine control

valve closure. The control valve closure was caused by a loose

connection in the valve controls. The plant was restarted on

December 16. Plant operation continued and on February 11, all

rods were essentially withdrawn and end of fuel cycle

"coastdown" began.

On March 6, a scram during turbine stop valve surveillance

testing occurred. The plant was restarted on March 7. During

subsequent surveillance testing of Static-0-Ring reactor water

level instruments, a setpoint drift problem was discovered and

on March 27 the plant was shutdown to replace these sensors.

Following replacement and testing, the unit was restarted on

March 30. The setpoint drift problems continued and an

increased surveillance frequency was implemented. On April 5,

one recirculation pump was removed from service due to seal

failure and operation continued with the remaining four recir-

culation pumps until April 12 when the plant was shutdown for

the 11R Refueling / Maintenance / Modification outage. The outage

was scheduled for six months and was still in progress at the

end of this report period.

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2. Inspection Activities s '

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Two NRC resident inspectors were assigned to the 'iitte throughout

the assessment period. The total NRC inspection. hours for the " ?q' .

15 1/2 month period was 5189 hours0.0601 days <br />1.441 hours <br />0.00858 weeks <br />0.00197 months <br /> (Resident, Royion, and

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Headquarters based) with a distribution in tSe9ppraisal r

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functional areas as shown in Table IV. This equates to 4017 '

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hours.on an annual basis. ' t .- .

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During the period, NRC team inspections were conducted to review

potential for overpressurization of low pre'ssure ' emergency core

cooling systems and to evaluate the licensee's program Wor the -

environmental qualification of equipment. Also, special.inspec-' ..

tions were conducted to review implementation of NUREC 0737 items

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and the circumstances associated with iodine upt'akes ty workers.

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A NRC Emergency Preparedness inspection team observed the annual "

emergency exercise on April 9, 1986. -

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Tabulations of inspection and enforcement activities are ,

attached as Tables 5 and 6, respectively. '

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II. CRITERIA

Licensee performance is assessed in selected-functional areas, depending

upon whether the facility is-in a construction, preoperational, or opera-

tional phase. Each functional area normally represents areas significant

to nuclear 9 etyf tM the environment, and are normal programmatic areas.

Special areas may be added to highlight.significant observations.

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

functional area:

1. Management involvement and control in assuring quality

$ n , 2. ' Approach to resolution of technical issues from a safety standpoint

, 3. Responsiveness to NRC initiatives

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4. . Enforcement 17 story

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5.- depor.tingandanalysisofreportableevents

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6. Staffing (including management)

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7. Training effectiveness and qualification

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No 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 criteria, the two areas provide a synopsis. For example,

, quality assurance effectiveness has been assessed on a day-to-day basis by

r resident inspectors and as an integral aspect of specialist inspections.

C' Although quality work is the responsibility of every employee, one of the

C', 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 work attitudes, are discussed in each area.

The topic of fire protection is not discussed as a separate functional

area because of insufficient inspection activity. The available observa-

. tions on fire protection and housekeeping are included in the various

relevant functional areas.

Technical Support continued as a functional area because of the signifi-

cant involvement of Plant Engineering and Technical Functions in Oyster

Creek activities.

Based upon the SALP Board assessment, each functional area evaluated is

classified into one of three performance categories. The definitions of

these performance categories are:

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Category 1. Reduced NRC attention may be appropriate. Licensee manage-

ment 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; the licensee resources are adequate and reasonably effec-

tive 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

nuclasr safety, br+ weak.nesses are evident; licensee resources appear to

be strained or not effee.*ively used so that minimally satisfactory

per'formance with respect to operational safety or construction is being

achieved.

The SALP Board has also assessed each functional area to compare the

licensee's performence during the last quarter of the assessment period to

. that during the entire period in , order to determine the recent trend for

each functional area. The trend categories used by the SALP Board are as

fcitows:

Improving: Licensee performance has generally improved over the last

quarter of the current SALP assessment period.

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, Declining: Licensee performance has generally declined over the last

quarter of the current SALP assessment pcriod.

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

, trend indicates a clear potential to change the overall performance to a

different classification in the near future. For example, a classifica-

tion of " Category 2, Improving," indicates clear potential for Category 1

performance.

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III. Summary of Results

A. Facility Performance

Category Category

Last Period This Period

(5/1/84- (7/1/85- Recent

Functional Area 6/30/85) 10/15/86) Trend *

A. ' Plant Operations 2 2 -

B. Radiological Controls 1 2 -

C. Maintenance 3 2 -

D. Surveillance / Inservice Testing 2 1 -

E. Emergency Preparedness 1 1 -

F. Security and Safeguards 2 1 -

G. Outage Management / Refueling 2 2 -

H. Technical Support 2 2 -

I. Training and Qualification N/A 1 -

Effectiveness

J. Assurance of Quality N/A 2 -

K. Licensing Activities 2 2 Improving

• Trend during the last quarter of the assessment period.

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B. Overall ' Facility Evaluation

Site and corporate management demonstrate a strong commitment to safety.

Furthermore, the licensee appears to be committed to a program of

improved training in all aspects of facility operation. During this

SALP period the~ licensee put forth substantial effort to improve those

weaknesses noted in the last SALP; these efforts were moderately

successful and resulted in a general improvement in performance. A

high level of performance was achieved in the emergency preparedness,

security, and surveillance areas. However, the licensee still faces

a variety of problems and challenges in several areas. Power generation

was interrupted in five instances by reactor scrams and in three

instances by unplanned shutdowns. Plant operation was often plagued

by equipment problems, and aging of plant eouipment appears to be a

developing problem. Recovery from events was complicated in several

instances by operator errors. Continuing attention should also be

given to reducing operator errors and improving shift management's

decision-making on safety issues.

Performance in the areas of maintenance and modification installation

has improved. Licensee efforts to strengthen management capability

and further improve the organization were the major reasons for better

performance. Continued effort is 'equired to provide resources to

permit reduction of the large backlog of work as well as to improve

supervisory and craft work performance, management of resources, and

ALARA. The large backlog of work has not been significantly reduced

due, in part, to the lack of resources and a constant influx of new

problems. Technical support to evaluate and correct problems has

been inconsistent regarding quality and timeliness. Technical support

has generally-improved, however, in the timely development of engi-

neering needed to support planned work and responsiveness to site

questions regarding this work.

The licensee needs to effectively address the equipment aging issue

in order to maintain operator confidence in plant operations. Since

this effort may initially increase the work backlog it is also impor-

tant to properly prioritize the work using such tools as probabilistic

risk assessment and an integrated living schedule, and to ensure that

adequate resources are committed and applied. It is also important

to complete expeditiously the substantial ongoing effort to re-estab-

lish the as-built basis of the plant.

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IV. PERFORMANCE ANALYSIS

A. Plant Operations (1971 hr. 38%)

The previous SALP rating in this area was Category 2. Generally-

good performance in all facets of plant operations was noted with

training identified as a strong point. Weaknesses were identified

in supervision of contractor maintenance activities, instructions to

operating personnel, operator control of reactor water level, repair

or replacement of defective equipment, and improvement in communica-

tions between operations and other divisions.

Evaluation of this area is based on performance during the Cycle 10

operating period and the Cycle 11 refueling outage. Assessment in

this area includes an evaluation of the licensee's progress in meeting

commitments made in their response to the previous SALP.

Licensee management has generally been successful in meeting the

commitments made in response to the previous SALP. The licensee

has made a number of physical improvements in the control room.

Improvement in control room professional environment was noted,

but improvement is still required as indicated by two examples of

improper manning of the control room and inconsistent control of

control room access. The licensee previously committed to provide an

assembly space for relief crews and equipment operators to limit

their access to the control room but was not able to accomplish this.

Log keeping has shown significant improvement as a result of daily

management reviews of control room logs and emphasis placed on proper

log keeping during simulator training sessions. One log keeping

deficiency that still needs improvement is documentation of details

related to significant operating events. Another concern is the

proper recording and review of out-of-specification readings on logs.

Plant management is aware of their weaknesses in these areas and

continues to strive for improvement.

Six reactor trips occurred in 1985 and operating problems persist.

Reactor level control problems continued and fuel failures occurred

as a result of improper utilization of the new Power Shape Monitoring

System. The previous SALP discussed these areas as significant

concerns. Most trips resulted from secondary system equipment

problems which may be due to plant aging or lack of proper maintenance.

Shift operations are generally well conducted, although there seems

to be a lack of decision-making ability on the part of shift manage-

ment. Shift management decision making was noted to be lacking

during a drywell inerting evolution which led to a violation. Other

weaknesses associated with shift management include approving

maintenance making a safety-related snubber inoperable, failing to

recognize the importance of shutting a recirculation pump discharge

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valve following a pump trip, and the failure to deactivate a con-

tainment isolation valve in accordance with Technical Specification

requirements. Shift management needs to improve in coasidering all

aspects of' safety issues, and in acting. decisively upon the issue in

accordance with applicable regulations and procedures.

During scram' recoveries, a number of operating errors have occurred

which complicated recovery operations and, in one instance, initiated

a scram. Among the errors which occurred a're (1) improper upranging

of IRMs to range 10, (2) initiation of a scram by simultaneously

inserting all eight IRMs, (3) failing to place the mode switch in

shutdown following a reactor scram which. led to significant operating

difficulties, and (4) initiation of a MSIV closure by jiggling of the

mode switch. There appears to be a need to evaluate training to

focus on these types of errors.

Equipment problems still persist, as noted, and have directly

contributed to four scrams during the assessment period. Scrams have

occurred as a result of failure of steam jet air ejector drain pumps,

a' main generator current transformer, a turbine stop valve limit

switch, and the electric pressure regulator. The licensee has

recognized this and formed a scram reduction task force. 0ther-

significant equipment problems included electromatic relief valve

seat leakage, feedwater isolation valve leakage, hydraulic control

unit deficiencies, and feedwater control problems.

Reactor water level centrol was consistently a major operator

concern following a reactor scram during this assessment period.

In virtually every scram recovery, high reactor water level pre-

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cluded the use of the isolation condenser. In another case, while

attempting to reseat a leaking EMRV after a scram,-unstable water

c level control resulted in low reactor water level. ~ This has led

also to complicating scram recoveries as the operators' full attention

[ has been devoted to water level control, overlooking other immediate

operator' actions. The licensee has recognized this problem, revised-

operating procedures, and is contemplating a feedwater control system

j modification.

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Fire protection staffing levels are acceptable. The fire protection

staff was found to be experienced and knowledgeable of requirements.

Fire brigade training and drills were verified to have been conducted

in accordance with the requirements of the plant Fire Protection Pro-

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gram Manual. The training records were well maintained and available.

In general, the plant fire protection system and equipment were well-

maintained and were in good working condition. The annual and

biennial fire protection audits were conducted in accordance with the

Technicel Specifications.- One area of concern was the slow response

to apparent nonconformances, as evidenced by audit findings which

had been identified for over a year and which had not been resolved.

However, management's attention to fire protection concerns and con-

servr.tism regarding issues affecting safety was generally evident.

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Senior operations mana'gement continues to be a strong contributor to

, safe efficient operation of the 0yster. Creek Nuclear Generating Station.

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Post-transient analysis and reviews.are generally conducted in a

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thorough ~ manner, determining root causes and establishing proper

corrective action prior to resumption of power operation. Another

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strong. management control has been the establishment of certification

reports for such . significant milestones as refueling and restart.

This helps to ensure that all required tasks, including maintenance

work items, quality assurance deficiencies, surveillances, etc., have

1: been . completed or appropriately dispositioned prior to commencing a

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major milestone. The addition of a dedicated senior reactor operator

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during outages to improve the interface and working relations between

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operations and maintenance was another positive management initiative

that helped coordination of work activities. Another initiative was

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the establishment during the 11R outage of back shift coverage by

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senior plant management to more rapidly identify ar.d resolve problems.

Management personnel are frequently founo in the plant and involved

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in the solution of plant problems. The licensee has established good

programs to manage operator overtime hours. Housekeeping-in the plant

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during operations is usually excellent and is a reflection of the

concerted effort by plant management in this area. Housekeeping

3 during outages needs to be improved, though, and is7 discussed in the

Maintenance and Radiological Controls sections.

In summary, strong senior operations management continues to be a

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major attribute in the good performance of the station. Management

has generally been successful in meeting commitments made in their

SALP response letter. Significant changes have been-noted in the-

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control room environment but plant management attention is still

warranted. The operations-maintenance interface has improved as a

result of management initiatives, including an operational outage .

coordinator and senior management coverage on backshifts. Weaknesses

were noted in the resolution of.long standing operational equipment

problems that continue to confront the operators and hinder plant

operations. Of potential significance is the apparent loss of operator

confidence in equipment. Personnel errors contributed to and

j complicated reactor trips. There is an apparent operator pre-occupation

U with water level control problems to the exclusion of performing

l immediate operator actions during a reactar scram. Additional-training,

,. including plant-specific simulator train 1ng, would improve operator

performance and reduce operator cognitive errors during scram recovery

i. operations. Improvement in the shift management's nuclear safety

perspective is needed to promote the desired control room environment

and increase operational assessment and performance during events.

Conclusion

Category 2

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-Board Recommendations

Licensee:

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Improve shift managements' abilities to recognize and fully

consider all safety aspects of an ' issue and then act decisively

on that issue.

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Decrease the number of operator errors through enhanced opera-

tional training including use of plant specific simulator

training.

NRC:

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B. Radiological Controls (478 hrs. 9%)

The previous SALP rating in this area was Category I with effective

control of radiation protection activities and high levels of per-

sonnel performance noted. Strong points included training, exposure

control, whole body counting,. timely corrective action to identified

problems, effective radwaste management and radwaste volume reduction.

Positive contributions of the chemistry program and the upgrading of

the chemistry facilities were also noted.

During the current period, there were six violations in the area of

radiological controls, two of these in the area of radwaste and

trantportation and four in control of radiation areas and radiation

surveys. Two of the latter incidents involved workers receiving

unplanned exposure in excess of the site administrative whole body

exposure limits.

The assessment of the performance of the radiological controls

program is that, on the whole, the licensee continues to show a

relatively high_ level of effort in controlling radiation exposure

on site, radiological effluents, and waste shipments. Inspec-

tions during the outage showed good control of access into the

radiologically controlled areas, although long delays in gaining

access to these areas were sometimes observed at shift changes.

Housekeeping in the_ reactor building was not consistent or uniform

throughout the radiologically controlled areas. There were many

instances in which waste, including radioactive waste, was allowed

to accumulate in excessive quantities before being removed. Effort

was evident in the extensive and thorough posting and barricading of

radiation and contaminated areas, in the arrangement of suiting-up

areas outside the drywell, and in the arrangement of containers and

methods of segregating contaminated items of clothing and equipment.

However, the suiting-up areas were often of insufficient capacity

to comfortably accommodate the large numbers of people using them.

Although the waste segregation system is in principle a good idea,

the workers in many instances did not appear to adhere to that system

and, as a result, contaminated items were sometimes mixed with waste

classified as clean. This appears to be indicative of insufficient

training and indoctrination in station procedures and general good

practice, and insufficient insistence that such practices and pro-

cedures be followed. An example of a tendency not to insist on

proper and conservative practices is the response of radiological

controls personnel to radiation monitor alarms during fuel manipu-

lations in the recent outages wherein fuel movement was allowed to

continue before the cause of the alarms was understood and corrected.

Other instances indicative of weakness include instances of poor

frisking at exits from radiologically controlled areas, and a

failure to ensure that a locked high radiation area access door was

locked after use.

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Issuance of RWPs appeared to have been well controlled, and

assignment of' personnel dosimetry was generally good.

The radiological controls program appears to be a well managed and

effective program, however, there are weaknesses. The main area of

weakness is in ALARA. The ALARA program shares the same commendable

attributes found in other areas of the radiological controls program,  ;

namely full staffing by competent individuals, apparently adequate

funding for program activities, reports, and presentations to

management. Despite this apparent dedication in effort and

resources, the program has not been successful in minimizing

exposures. The accumulated exposure for the year to date (October

1986) of 2100 man-rem is much higher than industry averages for BWRs,

even after allowing for the large number of radiologically signifi-

cant jobs that were performed during the outage. It also far exceeds

the 1986 annual estimate for the site of 1000 man-rem. The reasons

for this large discrepancy between the estimates and the actual

exposures are partly due to inaccurate estimates, less than expected

decontamination factors from decontamination of recirculation system

piping, and insufficient job planning and control.

Another program weakness was noted in the area of surveys for air-

borne contamination and ambient radiation fields prior to and during

job execution. This assessment is based on four incidents that

occurred during the current SALP period. Two of these incidents

involved inadvertent intakes of radioiodine 6y several workers. The

other two incidents involved unplanned exposures to the whole bodies

of two workers that exceeded site administrative limits. Although

none of these exposures was reportable or in excess of regulatory

limits, they were unplanned and resulted from the existence of con -

tamination or radiation fields that were not well characterized at

the time of exposure. Although extensive radiological surveys and

air sampling are conducted on a routine basis in the radiologically

controlled area, review of the circumstances surrounding these

-

incidents indicates that surveys for protection purposes were neither

emphasized nor closely controlled for timeliness. The review also

revealed mother general area of weakness, namely, inadequate commu-

nications between at least some of the departments on site. Another

area of weakness is the frequent equipment breakdowns and maintenance

problems in the New Radwaste and Augmented Offgas buildings. These

breakdowns have led to incidents of personnel contamination and

environmental releases. Although these incidents were not

radiologically significant, they do point to the need to review the

design and maintenance practices for these systems.

Other than the weaknesses noted above, the licensee's program

for external and internal exposure controls are well managed and

effective. Staffing levels appear to be good, and the procedures

are adequate. Equipment and facilities are also adequate in most

areas.

i

_ _ - _ . . _ _ - > -

.. .

15

The licensee is in general responsive to regulatory and safety

concerns. An example is provided by underwater diving operations on

site. Preparations for the first diving operation in this SALP

period were reviewed by a NRC inspector and were found to be lacking

in certain areas. Subsequent diving operations were well planned and

well executed.

Radwaste operations was an area in which the licensee made

improvements since the last SALP. Considerable effort was made in

improving radwaste operations equipment. Additionally, radwaste

operator ability to recognize the significance of off-normal readings

was improved by. implementing the necessary training and management

reviews. Although improvements have occurred in this area, equipment

problems persist. Continued management attention is required to

ensure radwaste system availability is improved.

The licensee has an adequate effluent controls and monitoring

program. The licensee is performing sampling and analyses in excess

of Technical Specification requirements for inplant and effluent

sampling analyses. Management involvement is evident in the plan-

ning for the implementation of the Radiological Effluent Technical

Specifications (RETS), which will become effective during the next

assessment period.

Consistent with the previous assessment period, the licensee main-

tained a strong chemistry department. Recently, the chemistry

department manager was also designated the acting radwaste operations

manager. There was no evidence of a loss of management control in

either department as of the writing of this evaluation. However, the

plant is in an extended outage, with less demand on effluent proces-

sing and monitoring. Procedures for gaseous and liquid effluent

controls are implemented and documentation is reviewed in a timely

manner. Higher than usual gaseous effluent releases were determined

to have peaked in December 1985 and remained elevated until the

planned shutdown in April 1986. The licensee attributed the elevated

gaseous releases to leaking fuel and equipment problems related to

the Augmented Offgas (A0G) Facility. During the refueling outage, the

licensee completed extensive repairs to the A0G.

Management attention is also being directed to improve the back-

ground radiation levels for two of the liquid process monitors and

to install a turbine building vent monitoring system. The licensee

has operated without a liquid overboard discharge for 22 months. An

example of a less than conservative approach was the licensee's

response to a failure of the charcoal efficiency test for one of the

standby gas treatment system trains. The cause of the failure was

not investigated, nor was the alternate train tested to confirm its

required efficiency. Testing of the alternate train was to be under-

taken at the first available opportunity after being suggested by the

NRC.

.. - --

. .

16

There were two transportation reviews conducted during this assess-

ment period. Two minor problems which related to excessive dose

rates and quality control involvement to assure compliance-with 10

CFR 61 were identified. These were not indicative of a programmatic

breakdown and thorough responses were evident in both cases. In

addit'on, for the problems involving excessive dose rates and

inadvertent shipment of an irradiated material, the licensee con-

ducted an extensive critique and analysis of the causal factors.

Corrective actions were timely and complete. Regarding training

and qualification of radwaste/ shipping personnel, the licensee

provides periodic training in accordance with the guidance of IE

Bulletin 79-19.

A team inspection to verify and evaluate the licensee's Post Accident

Sampling and Monitoring System was conducted during this assessment

period. During this review, substantive problems were identified

regarding the effluent monitoring system (ieferred to as RAGEMS) such

as inadequate calibration, no continuous sampling, lost monitoring

capabilities under some accident conditions, and lack of procedures

.to address representative sample collection and exposure control.

Follow-up management meetings and inspections have found that the

licensee has developed a technically sound and thorough corrective

action plan. Initially, the licensee's commitment to complete the

necessary actions was not timely. These types of concerns are more

fully discussed in the Technical Support functional area. After

further discussions with the NRC, a more responsive schedule was

submitted. The licensee showed good implementation for PASS

modifications. No equipment problems were identified and an ade-

quate complement of personnel were trained. Follow-up reviews

indicate a continued effort for thorough implementation of PASS,

including surveillance, procedure reviews, and training additional

personnel in the use of PASS.

In summary, the licensee has shown reasonably good control of the

radiologically controlled area, both in terms of access and in terms

of housekeeping and equipment. Good performance has also been

demonstrated in the areas of effluent control and shipping, as well

as in PASS implementation. The licensee has also shown responsive-

ness to regulatory concerns. However, certain areas of weakness

need to be addressed. These areas include emphasis on the preventive

and protective aspects of sampling and surveys, conservatism in the

control of radiation exposures, and handling of unexpected or anom-

alous monitor readings. Good radiation and housekeeping practices

need strengthening. ALARA performance is still weak despite

investment of resources. A review of ALARA methods and procedures

may be required. Communication between departments during planning

and execution of jobs appears to be a problem. Finally, maintenance

problems in the Augmented Offgas and New Radwaste buildings have been

the cause of several contamination and airborne release incidents,

and the design, as well as the maintenance practices for these

systems, should be reviewed.

.

I

_ _ _ _ . _ _ _ ._.

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

. - . - - .

.. .

17

Conclusion

Category -

2

Board Recommendations

Licensee:

--

'Re-evaluate the ALARA process to identify organizational and

. procedural weaknesses both in and out of the Radiological Controls

Department'and implement improvements in communications between

departments involved in planning and execution of a job.

NRC:

None

.

l'

i

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

..- ..

18

C. Mair.tenance (647 hrs.,IP3)

This functional area evaluates licensee performance of routine

maintenance and minor modifications. It includes a one month outage

(10M) in October 1985 for mainly environmental qualification (EQ)

work and a planned six month refueling outage (11R) that included

major fire protection work to satisfy 10 CFR 50 Appendix R. It does

not include restart from the 11R outage. NRC inspections identified

that the Maintenance, Construction, and Facilities (MCF) Division

improved its overall performance as compared to the performance

evaluated in the previous SALP.

The previous SALP rated Maintenance a Category 3. Specific concerns

included the need to reduce rework and improve workmanship, first

line supervision, feedback to engineering, knowledge of job, con-

tractor supervision, post maintenance testing, and responsiveness

to the QA/QC program. Based on NRC inspections of the corrective

actions taken by the licensee, it was evident at the end of this

evaluation period that efforts to improve performance in mair.tenance

were generally successful. However, many of the concerns discussed

in the past SALP were not evident until after restart from the 10R

outage and the end of this SALP period precedes the 11R restart,

thereby, precluding a complete basis for comparison as to the overall

effectiveness of the corrective actions.

One of the majcr keys to improvement was the emphasis placed on

controlling work scope which enabled the licensee to better control

resources. This resulted in more comprehensive supervision which,

in turn, resulted in better workmanship and feedback to engineering.

Other keys to improved performance included effective management

changes, further development and implementation of the work manage-

ment system (WMS), use of shift technical advisors as job monitors,

better prepared technicians as a result of the MCF training program,

improved control of contractors, and an increase in the number of job

supervisors. The 10M outage was notable in that the large majority

of the engineering work was completed prior to the outage, much of

the material was prestaged by individual job, mock-ups were developed

for the critical jobs to ensure ease of installation, and ample

resources and time were provided.

Despite the positive upper level MCF management changes that resulted

in incorporating personnel with more management and/or plant opera-

tions and engineering experience into MCF, some of the same problems

discussed in the previous SALP with inadequate supervision and craft

workmanship persisted.

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

.- .

19

During the 10M outage, NRC inspections of the RK01 and RK02 EQ

instrument changeout identified examples of MCF's failure to perform

work in accordance with drawing and procedure requirements, failure

of a job supervisor to sign off production holdpoints for a weld

repair, failure to implement or change a procedure prerequisite, and

failure of MCF personnel (along with others) to frisk carry along

items when leaving the radiologically controlled area. Just after

conclusion of the 10M outage, inadequate communications from lower

levels to higher levels of MCF management contributed to an identified

EQ deficiency not being corrected before the November 30, 1985 dead-

line. During the 11R outage, NRC inspections of the spent fuel pool

cooling seismic upgrade revealed the lack of a mechanism to control

rework of QC inspected s..d acceoted work for which MCF still had

responsibility and improper issuance of weld rod used to connect a

l pipe restraint of known material to a floor penetration of unknown

l material. Additional concerns identified included the finding that

j four Technical Specification required snubbers had been inoperable

since the 10R outage. Another resulted when MCF supervisory and

craft personnel failed to properly control a locked high radiation

door. These problems indicate that continued improvement is needed

in the areas of procedure compliance, supervision, control of rework,

craft training, control of contractors, workmanship practices, and

communications within MCF and between interfacing divisions.

Improvements in MCF corrective maintenance efforts resulted mainly

from newly implemented craft training, improved management control,

and prioritization and tracking of work orders. As a result of

these improvements, there is a sense that problems are identified

and prioritized and that management is in control. There are, how-

ever, many backlogged work orders. Manpower and resource limita-

tions, combined with a continuous influx of new problems, have

limited progress to reduce the backlog. NRC review of the causes of

significant corrective maintenance activities indicates that: (1)

secondary side components are impacting the primary side, (2) much

equipment has reached or is reaching the end of useful life, and (3)

not all corrective maintenance performed is effective in correcting

the problem. The licensee should review these problems and take

appropriate corrective action.

Routina corrective maintenance has generally been successful in

correcting identified problems. However, enough problems remain to

indicate management attention is still required to fully implement

the WMS, bring the complete Station Information Management System on

line, improve the quality of craft and supervisory personnel, and

fully utilize available resources to quickly identify and correct

problems. Examples of problems include: (1) difficulty finding the

cause of various spurious signals including area radiation monitor

spikes that initiated the standby gas treatment system on numerous

occasions, intermediate range channel spikes, and unexplained half

scrams; (2) various and repetitive problems with the diesel fire

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

.- .-

20

pumps and associated equipment; (3) coordination problems with

operations involving temporary variations; and (4) poor workmanship

as evidenced by loose leads, improperly installed jumpers, and the

initiation of the fire suppression system in both a control room

panel and the cable spreading room when careless use of a heat gun

set off nearby fire detectors.

Housekeeping during the 10M outage was controlled at an acceptable

level, however, during the 11R outage, it was inconsistent. The

housekeeping problems discussed in the previous SALP still exist

and licensee action to make housekeeping a part of everyone's job

and hold people accountable remains an unfulfilled commitment.

Additional NRC inspection in this area indicated the procedure for

both radiological and non-radiological housekeeping was weak.

A major concern of the previous SALP was inadequate post-maintenance

testing (PMT). During this evaluation period, the licensee developed

a PMT program, however, it was not yet formally implemented.

MCF responsiveness to QA/QC was also an issue in the past SALP. Only

slight improvement has been noted. The improvement resulted when MCF

management implemented a QDR tracking system in the MCF technical

support department. However, even with this MCF QDR tracking system,

a NRC review of QC's QDR files indicated MCF was still slow in re-

sponding. This appears to indicate that MCF placed too low a priority

on QA/QC, especially when outage workload was high. MCF still needs

to improve their attitude and responsiveness regarding QA/QC.

Preventive maintenance (PM) remained a strength. This is a com-

bined effort of MCF and the Plant Materiel department under Plant

Operations. PM schedules are computerized and generally strictly

adhered to. Maintenance histories are kept on all important-

to-safety pieces of equipment. Predictive maintenance has not

been instituted and should be investigated as a potentially

useful tool, especially in light of the age of the plant. Addi-

tionally, investigation into increased secondary side PM should

be initiatei.

A concern that arose during this evaluation period evolved from the

identification of original construction installation discrepancies

associated with the mounting of 80 of 137 hydraulic control units

(HCUs). Follow-up investigation determined that the deficient in-

stallation resulted in the eighty HCUs not meeting seismic require-

ments and a significant Technical Specification violation in that

these HCUs were never operable by Technical Specification definition.

Additional plant construction discrepancies were identified by NRC

inspections of licensee action to addressBulletins 79-02, 79-14, and

80-11. Because the expertise required to identify these types of

. discrepancies resides mainly in MCF, it is incumbent upon MCF per-

sonnel to identify questionable installations for evaluation of their

acceptability.

, ..

21

In summary, overall performance during this assessment period improved.

The licensee focused a significant amount of attention and resources

on MCF, These efforts met with success at the upper levels of manage-

ment and, in turn resulted in better overall control of MCF activities.

Regarding outage work, MCF realized the benefits of front end engineering,

preplanning, prestaging, work scope control, and improved control of

contractors. Corrective maintenance kept up with the immediate problems

but was not able to make much progress on reducing tne backlog. The

newly instituted system of identifying and prioritizing work orders

has proven to be useful, not only for keeping track of the large volume

of work orders, but also for identifying their large volume to upper

levels of management. Efforts to fully implement the WMS, Station

Information Management System, and PMT should continue. Areas where

continued improvement is needed include performance of lower level

management and craft, workmanship, communications, rework control,

procedure compliance, contractor control, housekeeping, and respon-

siveness to QA/QC.

Conclusion

Category --

2

Board Recommendations

Licensee:

--

Continue to improve compliance with procedures, quality and

effectiveness of supervision and craft, control of rework, craft

training, contractor control, workmanship practices, internal

and external communications, and attitude and responsiveness to

QA/QC. Additionally, stress to all personnel the importance of

asking questions about the acceptability of installations that

appear questionable and be responsive to these questions.

--

Reduce the backlog of outstanding work and provide resources to

accomplish this.

--

Increase efforts to identify and upgrade secondary side items

that have the potential to impact the primary side and address

the overall plant equipment aging problem.

NRC:

None

.- ,

22

D. Surveillance / Inservice Testing (417 Hrs., 8%)

The previous SALP rated this area as Category 2 and identified ~

several concerns. One involved the failure to control instrument

out-of-service times during surveillance activities. This issue was

successfully addressed during this assessment period by determining,

before a surveillance is started, how long the instrument can be out

of service and by closer and more effective communication with the

control room to ensure the time is not exceeded. To minimize the

impact of the one-hour time limit, the licensee requested a. change to

their Technical Specifications to increase the time an instrument may

be out of service to two hours. Another concern involved weaknesses

in the-I & C department. This area was improved by the licensee

through a more aggressive training program. Concerns regarding

ambiguous operability criteria as contained in the surveillance

procedures are being addressed by revising the procedurer, to indicate

the appropriate criteria that must be satisfied to determine opera-

bility by the Technical Specification definition. This is a major

undertaking expected to be complete by the end of 1987. Other

concerns, including weak communications, ineffective corrective

action, and inadequate procedure reviews appear to have been addressed

but were concerns that arose primarily during restart from a long

refueling outage. Results from IIR restart activities will indicate

whether or not licensee corrective action was effective.

During this evaluation period, surveillance activities continued to

be performed satisfactorily and in a timely manner in accordance with

a master surveillance schedule. Surveillance procedures provided for

proper removal from service and restoration to service of equipment,

and assured that test results were properly documented. The perfor-

mance of individuals performing surveillance testing was observed and

found to be generally acceptable.

During the assessment period, no violations were identified by the

NRC in the area of surveillance. One instance was identified by the

licensee in which the Technical Specification out-of-service time for

an instrument was slightly exceeded. This occurred during a period

in which problems were being experienced with Static-0-Ring instru-

ments and is considered to be an isolated incident. Inspection

findings showed licensee adherence to applicable Technical Specifica-

tion action statements.

On several occasions problems were identified relative to procedures.

In general, these problems were minor and are not indicative of a

programmatic weakness in procedures.

Other deficiencies identified during surveillance testing which

require plant management attention are the inaccuracy of the instrument

that provides local and control room indication of the standby liquid

control tank (SLCT) level and the inability to establish consistent

inservice test data for emergency service water (ESW) system II.

. .-

23

The licensee's corrective actions for the SLCT problem were not

timely. Another example of slow response to problems involves

the ESW pump flow instrument which is not reliable or accurate enough

to support effective inservice testing. This problem was identified

in the previous SALP and is still not corrected. It should be noted

that Technical Support effort is required to resolve these matters.

During the operating cycle, the licensee experienced erratic

performance of the Static-0-Ring (SOR) reactor water level sensors.

Continuing setpoint drift problems eventually required a plant shut-

down to modify the instruments. The licensee's efforts to monitor

and address the setpoint drift problems were noted to be sound in

engineering judgement and conservative regarding safe plant

operation.

Six Licensee Event Reports (LERs) associated with surveillance

activities were reported. Two of these were a result of the SOR

problems noted above. Two were due to instrument setpoint drift

problems. One was the identification of a minor error in a set-

point calculation, and one was due to a procedure failing to

provide sufficient instructions for returning an instrument to

service, which resulted in an ECCS initiation. The licensee's

action to prevent or correct these problems was considered

acceptable.

The local leak rate testing (LLRT) program was reviewed by the NRC

during the period. The licensee's procedure for conducting LLRTs

was found to be comprehensive, well established, and orderly. The

LLRT results were recorded and tracked such that "as found" and "as

left" results were easily distinguishable. Test results were

formally reviewed and approved by a single individual responsible

for LLRT. Administrative control of valve maintenance was also well-

established. Test personnel were knowledgeable and well-trained in

LLRT.

Snubber surveillance activities were inspected, and it was determined

the licensee's management and staff were knowledgeable regarding

snubber surveillance requirements. The licensee made a commitment to

eliminate snubber problems by revising plant procedures to provide

clear instructions and sketches which ensure proper installation and

testing of snubbers. This was accomplished. Procedures displayed

sound technical judgement, reflected plant experiences, and

incorporated licensee commitments to prevent recurrence of problems

previously encountered. The licensee's willingness to discuss and

commit to snubber Technical Specification (TS) changes to assure

compliance with NRC Generic Letter 84-13 demonstrated responsiveness.

Licensing personnel, including corporate office and site personnel,

were thoroughly familiar with the snubber TS amendment request and

provided supplemental data to clarify several TS provisions.

. - - - - - - _ _._

.. .

24

In general, inservice inspection (ISI) activities were found to be

well planned and performed according to applicable regulatory

requirements and procedures. The documentation reviewed was complete

and legible. Those technical issues addressed were resolved expe-

ditiously and in a technically conservative manner. Throughout NRC

inspections of ISI activities, _ responses to NRC requests were timely

and complete. Also, the licensee completed induction heat stress

improvement (IHSI) of Class 1 stainless steel weld joints and post .

IHSI ultrasonic examination to establish new baseline data. GPUN

technical data reports (TDRs) No. 571 and No. 657 define the require-

ments and background for activities of inspection and mitigation of

IGSCC. These reports indicate engineering and management involvement

in evaluation and resolution of plant mechanical equipment (piping)

problems. The good quality of the licensee's program for the ultra-

sonic examination of IHSI welds was, in part, a result of the

management decision to use an Ultra Image System and independent

Level III individuals to perform an overview analysis of the GE data

evaluation and disposition process. Additionally, the licensee's

documented review of vendor NDE personnel qualification /certificattoa

records was very thorough.

In general, surveillance, IST, and ISI activities were performed

satisfactorily with adequate management attention in the areas of

procedure preparation, review, and adherence. Technician training

is improved and appears to contribute to proper performance of sur-

veillance activities. The problems identified associated with

procedures were promptly resolved. The licensee's identification,

evaluation, and resolution to the SOR problem was considered to be

very good. Action should be taken to restore SLCT level indication

to a functional status and install a flow measuring device in ESW

System II.

Conclusion

Category -1

Board Recommendations

None

,_, ._

.. . .- . . -. - - . _ - . _ ~ - . .

'

, . .-

25

$

E. Emergency Preparedness (267 hrs., 5%)

4

Analysis

During the previous assessment period, the licensee was_ rated _as

2

Category 1 in this area. Strengths were noted in responsiveness to

NRC initiatives, management participation in exercise activities as

well as planning and control of exercises. Also, the activation of

a new Technical Support Center occurred during the last assessment

h. period. The licensee's performance during the 1985 exercise demon-

strated management involvement and emphasis in maintaining a high

level of emergency preparedness. No-significant deficiencies were

identified. The staff's performance reflected.a high level of

,

,

training and readiness to respond to emergencies.

!-

During.this assessment period, the licensee maintained a strong

-emergency response preparedness capability. There was one announced

inspection of emergency preparedness activities consisting of obser-

vation of a full participation exercise on April 9, 1986. Licensee

responsiveness to NRC initiatives was demonstrated by the attention

i

given to.the NRC critique of the scenario. The licensee made appro-

priate changes to the scenario and to supporting data to satisfy NRC

concerns in a timely and thorough manner. The revised scenario tested

major portions of the emergency plan and its implementing procedures

and provided an opportunity for licensee personnel to demonstrate

those areas previously identified by the NRC as in need of corrective

actions. All such problem areas identified during the 1985 exercise

were corrected and did not recur during the 1986 exercise.

During the 1986 exercise no significant deficiencies were identi-

fied, however, eleven relatively minor areas were identified for

4

'

improvement. Throughout the exercise, established policies and

procedures were strictly adhered to, Emergency Action Levels (EALs)

were correctly identified, and appropriate and timely protective

action recommendations were formulated. The licensee's performance

L during this exercise demonstrated a' highly developed level of

emergency preparedness. Technical Support Center performance was

excellent. The licensee's emergency preparedness administrative

,

staff numbers six including an SRO-certified staff member and a

! senior health physicist. The manager assumed his position during

l February 1985 and appears to be aggressively pursuing problem

resolution.

,

During Hurricane Gloria, power was reduced to 35% (a precaution that

would simplify plant response in the event of an unplanned turbine

[' trip during the hurricane), an Unusual Event was declared, the Tech- t

nical Support Center was manned and shift staffing was increased. No-

l action was required for Hurricane Charley due to its path.

'

In summary, licensee performance remains strong in this area, and

sufficient management attention is being provided.

l

!

l

.

-

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

.. .

.

26

i

Conclusion

Category - 1

Board Recommendations

None

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

. .

27

F. Security and Safeguards (140 hrs. , 3%)

Analysis

In the previous SALP, this area was rated Category 2 and three

security program implementation concerns affecting guard performance,

compensatory measures and access control were identified. Additionally,

the licensee was in the process of effecting improvements in preven-

tive maintenance support for security equipment and systems. During

this assessment period, improvements in all these areas were noted.

No violations of program requirements were identified during two

routine physical security inspections, one material control and

accountability inspection, and continuing inspections by the NRC

resident inspectors. Both plant and corporate security management

exhibited a strong interest in, and influence on, the security

program at Oyster Creek. This was demonstrated by the licensee's

planning and budgeting for the gradual upgrading and/or replacement

of security program systems and equipment. Many improvements were

made and/or initiated during this assessment period and a major

upgrade of the perimeter intrusion system is scheduled for completion

by December 1987.

Corporate security management continued to be actively involved in

all site security program matters, e.g., staff assistance visits,

human resource allocations, program appraisals, and direct support

for the budgeting and planning processes affecting program

modifications and major upgrade plans. This involvement is viewed by

NRC to be attributable to the establishment, in early 1984, of the

corporate position of Nuclear Security Director. The incumbent of

that position has been effective in providing the necessary corporate

attention to and direction for the program, in addition to oversight

of program implementation. Key security management personnel are

also actively involved in the Region I Nuclear Security Association

and other groups in innovations in the nuclear plant security area.

A new initiative implemented by the licensee's corporate security

management during this period was the development of an audit team

comprising experienced security management and supervisory personnel

from other NRC licensed nuclear power plants. This team approach has

been successful in providing licensee management with a new and

in-depth perspective of program implementation and compliance with

NRC requirements. This approach also provides cross fertilization

among licensees that should result in improved performance, effec-

tiveness and efficiency of security operations. These audits are

reinforced by comprehensive formal quality assurance audits and by

on-the-job performance evaluations conducted by site protection

program supervisors. This combination of techniques demonstrates a

significant management initiative to promptly identify and resolve

program weaknesses and provides evidence that the licensee desires to

attain a high quality security program. It also appears to have been

effective in improving the performance of the security force.

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

.

. .

28

The licensee. submitted six security event reports during the assess-

ment period,'in accordance with 10 CFR 73.71. One report involved

the receipt of a bomb threat, four reports involved equipment failures

'and the other identified an access control problem with a contract

worker. These events were promptly reported and the written reports

were adequate, but could be clearer to ensure a full understanding of

the circumstances. The four events that involved equipment problems

should indicate to the licensee the need to upgrade the affected

equipment expeditiously. In the interim, however, and because the

licensee's implementation of compensatory actions was not always

timely when these equipment failures occurred, the licensee must be

'

prepared for such failures and must ensure that adequate plans have

been developed to implement prompt and effective compensatory actions,

including the posting of security force members, when necessary.

As a result of an NRC identified concern regarding the handling of

badges at the issuing point, the licensee made some physical changes

to improve this aspect of the access control program. While these

changes apparently eliminated the concern during routine conditions,

continued attention is warranted to ensure that these changes are

adequate for all conditions.

Staffing of the licensee's security organization was generally

adequate. However, due to the susceptibility of some equipment to

failure (as noted above), additional manning may sometimes be

necessary to ensure effective and timely compensatory actions. The

licensee should continue to review the need for contingency manning.

The security officer training and requalification program is well

developed and administered by two full time instructors. The new

initiative of on-the-job performance evaluation, which tests an

individual's proficiency level on general operational security

program criteria and on specific security officer positions, has

proven effective as a management / supervisory tool with which to

measure the effectiveness of the security training program. This

technique provides a continuing capability for management to review

the performance and knowledge of security personnel and to correct

deficiencies as they are detected. Additionally, it provides bene-

fits in terms of feedback on morale and performance. Implementation

of this technique provided further evidence that the licensee desires

to establish a quality program.

During this assessment period, the licensee established a preventive

maintenance support group for the security program systems and

equipment. The need for such a support group had been identified in

two previous li casee audits of the program and in the previous NRC

SALP. This group's function is to evaluate the maintenance require-

ments for the various security program systems and equipment and to

carry out those maintenance activities that can be performed on-site

and oversee those performed off-site. The group appeared to have

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

. .

29

developed a comprehensive plan for accomplishing its tasks and was

staffed with qualified individuals. However, the NRC did not have

an opportunity to assess the effectiveness of the group during this

period.

Security facilities and spaces were adequate and well maintained.

Records were readily retrievable, complete and centrally located for

ease of use. Members of the security force exhibited a good

appearance and a professional demeanor.

In suxnary, the licensee initiated and/or made several improvements

and impicmented several innovations during this period that should

significantly improve the security program, if given continued

attention and oversight by management. The timely completion of work

projects associated with several licensing issues, as well as a

continued demonstration of improvements in quality in the submittal

of licensing changes will further enhance the overall effectiveness

of the security program. There was ample evidence during this period

of the licensee's effort to improve the program, however, the process

of bringing about improvements and sustaining them in this area

historically has been weak,

Conclusion

Category -

1

Board Recommendations

Licensee:

None

MC:

--

Continue basic inspection program throughout the next assessment

period to determine whether the licensee's performance, as

demonstrated during this assessment period, continues.

.' .

30

G. Outage Management / Refueling (301 hrs., 6%)

Outage Management

The previous SALP rated this area Category 2 and identified several

weaknesses in outage control including delays in receipt of equipment,

mismatches of resources and workload, interdivisional interface

problems, control of contractors, and a large Incomplete Work List

at the conclusion of the 10R outage. The licensee was aware of

these problems and had implemented corrective action programs at the

end of the 10R outage.

During this evaluation period, there was a one-month environmental

qualification outage and a scheduled six month refueling outage. The

effectiveness of the corrective action programs and inspector con-

cerns are discussed below under the subheadings of Planning and

Scheduling, and Control and Implementatinn. Information discussed

in other functional areas of this report is used as part of this

evaluation.

Planning and Scheduling: To improve outage planning, a long-range

planning group was formed in Technical (Tech) Functions. Its function

is to aid in determining, prioritizing, and scheduling future work,

f

Benefits from this recent long-range planning initiative were-evident

in both outages during this assessment.

The onsite planning process that results in job packages cannot move

effectively until engineering work is complete. Efforts have been

made by Tech Functions to improve timeliness and quality of engi-

neering to facilitate timely issuance of job packages. This effort

was notably successful for 10M. Although improved over 10R, 11R

was not as successful as 10M. The timely issuance of job packages

to accomplish work not in the original scope of an outage is a

problem. This is generally hampered by the effort required to

obtain resources and indicates a lack of contingency planning.

Another problem involved the impact of Technical Specification

requirements on planned activities. During the 10M outage, it

was necessary for the licensee to request an emergency change to

the Technical Specifications to accomplish equipment installation.

Efforts in the preliminary planning stage could prevent this type

of problem. .

A concern expressed in the previous SALP involved a procurement

problem that resulted in unavailability of parts when required. This

problem did not recur to any major extent during either outage and is

indicative of effective planning in that area.

A joint effort between the licensee and NRC is underway to establish

an Integrated Living Schedule. This initiative should enable both

parties to establish a mutually agreeable plan for accomplishing work

activities.

t

I

,

l

. - - . .

_

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

,. .

, 31

During both outages schedules were routinely issued that accurately

reflected the critical path and correct work sequence. The 10M outage-

scheduling was relatively straightforward and required little change.

In contrast the 11R schedule underwent many changes due to work scope

changes that resulted from new work and cancelation or deferment of

scheduled work. Daily meetings were attended by GPUN divisions to

discuss problems and update the schedule. These meetings were

chaired by the Outage Manager who performed well in coordinating

input from all divisions and keeping track of the many support

activities. The schedules were generally realistic.

Control and Implementation: The corporate commitment to planning.

and scheduling was evident during the 10M outage but not as evident

during 11R. One of the keys to success of 10M was a management

decision to borrow proven performers from their permanent positions

and place them in temporary positions within MCF to ensure expertise

at all levels of the outage organization. This action was not taken

to the same extent for 11R. Most of the strengths and weaknesses

involving implementation are discussed in the Maintenance functional

area. Occasionally, poor timeliness of feedback of information or

feedback of inaccurate or incorrect information affected work

activities. This feedback was between divisions or between-craft,

supervision, and upper management. Establishment of a 24-hour senior

management watch bill towards the end of the outage helped improve

the accuracy and timeliness of feedback on site.

Control of work scope was the major emphasis placed on both outages.

It was generally successful although difficult to accomplish in 11R

because of the many unexpected findings that required resolution

prior to restart. To compensate for added work scope that affected

the outage, the licensee put extra manpower on more shifts. In

addition, a " rolling forties" work week was implemented for several

types of craft personnel that resulted in 24-hour, seven day a week

coverage with no overtime. Continued emphasis is needed to match

work load and resources. Control of the contractor work force was

another major concern of the previous SALP that was in general

successfully addressed. Problems still remain, however, with delays

in badging and entry into the RCA through the dose assessment system,

poor productivity and workmanship, manpower loading peaks that are

too high for support organizations to handle, and inadequate con-

tractor supervision.

Completion of documentation packages and the turnover process was

completed in time to support restart from 10M. There were problems

with completed and signed off documentation, however, that indicated

document control was not of consistently high quality. For example

QC inspection reports documenting inspections of electrical activ-

ities could not be reconciled with the data contained in the master

copy of the controlling procedure. Turnover of documentation at the

end of the 11R outage was slow and indicated a major effort to

complete the process would be needed to support restart. This type

' '

• 1. -

', p s

h' * ' ~~~

~

, .  !

'

.

-

_

.

,\

,'% '_.

' ~.

32

.m 'h .

~

u

v

ofanefforthas,inthepast,resultedindeficientdocubentation. -

Control of radiation exposure to meet the intent of ALARA was not ' /ID

successful as discussed in the Radiological Controls Yanctional area. ~

.

The Outage Manager was aggressive in controlling work. assignments for ,. a

work that was not clearly the responsibility of a 'Eorpor' ate division. ,

'

The unwillingness of division personnel to accept responsibility for

an assignment not clearly within their division's workscope continued

'

to be a problem as discussed in the previous SALP. Cooperation ' "

i-

improved during this period and efforts to continue the-improvement -s

should be sustained. '

/

Refueling: ,

The key events related to refueling were total defueTi.cq of the core,

sipping of all removed fuel assemblies to be reloaded-into_ the core,

inservice inspection of reactor vessel internals, shufflingecontrol

rod blades, underwater repair of a steam dryer baffle plate support

weld, replacement of nuclear instrumentation, reloading' the core, and ~-

shutdown margin testing. Review of refueling activ'ittes. indicated -

' '

that the procedures were adequate, the personnel were w61i trainsd, ~es

and the activities were carried out in accordance with approved ,% ,

procedures. Ongoing QA coverage appeared adequate. _ Plant nianagement / ',

was directly involved in day-to-day refueling activities and'a

comprehensive refueling certification program was implemented to ' - "' J

ensure-all prerequisite work was completed prior tu commencing

refueling. The large amount of work activity on the refueling floor

during the 11R outage was coordinated effectively by a management-

appointed coordinator.

Performance of many of the activities conducted as part of the

overall refueling evolution was hampered by breakdown.of equipment

and tools. For example problems were encountered witli'the fuel

grapple, the reactor vessel stud detensioning devices, the refueling

bridge, and various tools associated with operations on core

internals. The licensee had taken steps to ensure;all these items

were functional prior to the outage. An evaluation of this situatinn

'

should be conducted by the licensee to determine additional action

required to minimize breakdown problems.

During the fuel sipping evolution, a unique set of circumstances

resulted in radiation streaming that set off various alarms'on the

refueling floor and around the plant. This event is discussed in -

the Radiological Controls functional area. The licensee critiqued ~

this event and several corrective steps were taken, however; the

underlying attitudes that resulted in the incorrect reaction to '

-

this problem could surface under a new set of circumstances.

Management's expectations of plant personnel as perceived by plant

personnel should be investigated to ensure there is no misunder -

standing regarding the importance of nuclear safety when there is

an emphasis on completing an evolution that may be behind schedule.

~

,

f

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

_ - . _ ,

c

. .

33

In summary, outage management continued to improve. Emphasis on

controlling work scope was a key reason for this improvement. The

long-range planning effort should result in continued control of

work scope. Tech Functions upgrading of the quality and timeliness

of engineering for planned outage activities was important and these

efforts need to continue. Contingency planning needs to be improved.

Emphasis should be placed on timely and accurate feedback of

information from the field to its ultimate destination. Better

understanding should be developed regarding scope of responsibilities

and accountability for delayed corrective actions. Additionally,

emphasis on control of documentation flow and ALARA should continue.

Refueling should continue to be conducted in the controlled fashion '

it has been. Improvements in performance of support equipment would

be beneficial. Workforce perceptions of management's goals should be

investigated and clarifications made where appropriate.

Conclusion

Category - 2

Board Recommendations

Licensee:

--

Improve contingency planning.

--

Continue efforts to match resources and workload.

--

Investigate and clarify workforce perceptions of management's

attitude regarding safety versus schedule.

NRC:

None

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

'ihrl

w

r

m

y n

~

'

m

34

~

H. Technical Support (968 hrs.,.19%)

The preyfous'SALP rated performance in this area as Category 2.

N'

.

This' fun 6tional area evaluates Technical (Tech) Functions and Plant

Engineering, the two key groups tasked with providing technical

support of Oyster Creek. Inspection efforts were increased in this

area to gain a better understanding of the overall structure of

technical support and because of concerns identified in the previous

SALP that justified a need to isolate technical support as a separate

'

functional area; These problems included lack of timeliness, weak

technical support, and lapses in procedural adherence. Upon a review

of this period's inspection results, it appears that only limited

progress was made towards addressing and correcting NRC concerns

raised in the previous SALP.

The timeliness concern resulted from extended delays in addressing

NRC initiatives and plant problems that have contributed to compli-

cating' plant operation. Because of a substantial backlog of work and

limited resources, technical support groups have had to establish a

priority ranking system to control the sequence of work. Prioriti-

zation ranking involves a judgement as to the importance of each work

item and those judged less important suffer, at times, substantial

delays before. final implementation. Implementation of the Integrated

Living Schedule concept should eventually result.in mutual agreement

between the licensee and the NRC regarding-sequencing of work to

reduce2 the backlog.

Concerns that technical support was, at times, weak were precipitated

by NRC inspection findings in several different areas. Inspections

of RAGEMS'(see Radiological Controls), environmental qualification,

and responses to Bulletin 80-08 and 80-11 indicated inadequacies in

technical responses to NRC initiatives. Other weaknesses became

'^

'

evident during inspector reviews of Bulletin 79-02 data, fuel

f4ilures, problems associated'with motor operated valves, adequacy

and implementation of the welding program, and resolution of various

structural concrete concerns. Additional weaknesses were evident in

the, control of vendors to whom design work was contracted and the

adequacy of drawings that formed a part of contract documents.

Adherence to approved procedures by technical support personnel was

inconsistent. Inspectors identified several examples of Tech Func-

.tions personnel not adhering to procedures that govern the design

review process. Similarly, inspector findings were made in Plant

d_ Engineering that indicated Plant Engineering was knowingly operating

M A. differently than described in' their procedures governing tasking

y and prioritization of work requests. This contributed to improper ,

prioritization of a work request regarding the acceptability of

moving heavy loads at the intake structure and resulted in this

s

priority issue not being addressed.

.

Y

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

,, r ---,

__

.. .

35

The causes of the inconsistent performance discussed above

appear to be lack of management aggressiveness in making respon-

sible individuals accountable, weak technical expertise, poor

control'of vendor work, lack of comprehensive design criteria, and

poor communications. Many of these same concerns were discussed in

the previous SALP yet remain uncorrected. Management attention is

required to effect corrective actions to eliminate the inconsistent

performance.

Notwithstanding the above noted problems, improvements were made in

technical support, good initiatives were undertaken or continued, and

technical support was responsible for or contributed to many plant

upgrades and critical repairs that required timely actions. Regard-

ing improvements, Tech Functions has become more closely involved

in site activities with which they interface. This improvement was

effected by management insistence that Parsippany-based personnel

spend-more time on site in their areas of responsibility. As a

result of this, the potential for communications problems in

transmitting information was lessened and more accurate and timely

resolutions resulted. Another improvement included an overall

upgrading of the action item tracking system. Again, management

focused attention in this area and the result was more accurate

tracking, better quality and more timely responses, and improved

assignment of responsibility for action items. Additionally, a long

range planning group was added to Tech Functions to, in part, control

input of new work, develop a long range plan to prioritize backlogged

work,' and, in conjunction with NRC licensing, establish an Integrated

Living Schedule that will allow establishment of realistic goals for

accomplishment of the work backlog. Lastly, continuing efforts to

improve the design review process met with some success, i.e.,

problems have been averted as a result of thorough discussions of

proposed designs in both the preliminary engineering design and the

operability, maintainability, and constructability reviews.

The work performed by the Startup and Test Group (SU & T) is a good

example of effective and timely technical support. SU & T is effec-

tively managed, contains dedicated and well-trained personnel, and

meets the challenge of completing the test program within the con-

fines of an ever-shrinking schedule at the end of an outage. SU & T

is an aggressive organization that oftentimes identifies hardware,

software, installation, and design problems that go through the

corporate program unnoticed.

Initiatives completed or still working that represent responses to

NRC concerns or self-identified concerns include the development of a

post-maintenance testing program, continued upgrading of as-built

drawings, actions to mitigate IGSCC, upgraded emergency operating and

surveillance procedures, and formation of a scram reduction task

force.

l

..- .-

36

In. summary, technical support has a numbe: of strengths-and

weaknesses but mainly it is inconsistent. It demonstrates the

ability to perform quality technical work in a timely fashion in

accordance with procedures yet, in other instances, does just the

opposite. Root cause analysis of this paradoxical performance would

indicate the problem to be. management. Upper management should be

aware of this problem and should correct it by making lower level

management accountable when excessive deviations from the norm are

experienced. Assuming this corrective action was effected, there

are several other problems that have tended to bring into sharper

contrast the good and poor performances and need to be corrected.

These include inadequate control of vendors, a large backlog of

work, inadequate technical expertise, and at times ineffective

communications within technical support and between technical

support and other divisions.

Conclusion

Category 2

Board Recommendations

Licensee:

--

Undertake a self-analysis to determine the causes for

inconsistent performance.

--

Provide resources to facilitate reduction in the backlog of

work. Expedite completion of the plant specific Probablistic

Risk Assessment report and use it as a tool to aid in

prioritizing this work.

NRC:

Conduct a team inspection of technical support groups with an

emphasis on determining the causes of inconsistent performance.

. _

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

y y

V

7

37-

E ,

I. ' Training and Qualification Effectiveness-

>

Based on NRC awareness of the importance of an effective training

. and qualification process, a new functional area has been added.for

J evaluation during the SALP. process.-- Training and Qualification -

Effectiveness. Training ~and qualification effectiveness.still

' continues to be an evaluation criterion for each functional area.

"

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 one. Conse-

quently, this discussion is a synopsis of the assessments related to

training conducted in other areas. Training effectiveness has been

+

measured primarily by the observed. performance of. licensee personnel

and, to a lesser degree, by a review of program adequacy. The dis =

cussion below addresses three principle areas: licensed operator

-training, non-licensed staff training, and the status of INP0

training accreditation.

4

The licensee is committed to a program of improved training in all

i aspects of facility operation.' They are one of the first plants

,

i

to gain INPO accreditation of all ten training programs. Overall

management support of and involvement in training is evident by

4

its' support of INP0 accreditation and overall improvement in the.

4- programs. Emphasis has been placed upon not only maintaining an

p acceptable program but also continuously improving it.

During the assessment period, NRC Operator Licensing administered

one set of requalification and one. set of replacement operator

examinations. Six R0s and eight SR0s passed their written requali-

( fication examinations. An additional four R0s and four SR0s were

! administered oral examinations and all passed. 'The replacement:

i operator examination resulted in the licensing of four SR0s and the

" issuance of two instructor certifications. Of all the candidates-

examined, just one failed the oral portion of the examination. A

j requalification training program inspection was also conducted by the

! NRC and no deficiencies were noted. Both the licensee's replacement

l. operator and operator requalification training programs make a posi-

U tive contribution ~to operator knowledge and understanding of the

facility.

The licensee appears to be providing operators with adequate training

L on plant changes and modifications. Effective training for personnel

i performing refueling was noted to have been performed. Also, guides,

i course outlines, and class lecture lists showed the licensee provided

. in-depth training for all TMI Action Plan training requirements.

! During this assessment period a Basic Principles Trainer was made

' available to improve training capabilities. Long-term plans include

the purchase and installation of a plant specific simulator. Bids

'

'

for the simulator are to be accepted during 1987. The earliest an

operable simulator can be expected is the end of 1990.

.

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

~

.

1 u.

i

,

-

38

.

>

F

l- As'noted_in other sections of this report, there have been events

~

in'which operator error has occurred. Fewer operator errors would

4- have occurred had the number of operator challenges caused by

.,

'

- equipment failures been less. However, some of these errors appear

. to be a result of the licensee's inability to provide more hands-on

training due~to lack of a site-specific simulator and an occasional

-

. lack of understanding of the importance of adhering to requirements.

. There also appears to be a need for overall improvement in shift

b management's_ ability to recognize and fully consider all safety

d

aspects of an-_ issue and then act decisively on that. issue.

'

The licensee has established a well-designed program for both class-

r

I

- room and on-the-job training for in-house electricians, mechanics, ,

and instrument and control-(I & C) technicians. It was noted that

L - the backlog of I & C outstanding items was reduced due, in part, to

- improved I & C technician training. - The I & C technician program has

been generally _well-received by the I & C technicians.and supervisors

, and, as a result, has shown early success. The electrician and

mechanic program has as yet not experienced this early degree of

success-due to a lack of supervisory enthusiasm in implementing the

i program and also the heavy work load. Added management emphasis-

appears to be required to help the program succeed.

'

Along with improved training, new GPUN craft personnel are screened

by an examination process prior to being hired by the company. Also,

GPUN screens contractor employees' resumes before allowing' contractor

-

- management to employ an individual at Oyster Creek. The overall

success of these programs will be measured-in the long-term-if_a

i - general improvement in performance is noted, however,. only minor

. improvement has baen observed during this evaluation period. In an

effort to further upgrade craft and supervisory personne1' perform-

ance, the licensee has initiated an informal control which identifies

, rework and determines root cause, corrective action, and lessons

learned. This is an additional attempt by the-licensee to-identify *

, areas _where further training would serve to improve the quality of.

I work performed. The effectiveness of this effort is not yet evident.

!.

Radiological Controls had committed in their response to the previous

SALP to formalize in-house radiological engineering training. This

training program was, however, changed from an Oyster Creek project

< to a corporate responsibility. This has caused an indefinite delay

l

in its implementation. Based on weaknesses in the ALARA program

l implementation as discussed in this report, this training program

[ should receive more management attention to establish an

implementation date.

'

i

The security officer training and requalification program is well-

developed and administered. The new initiative of security personnel

4: on-the-job performance evaluation has proven to be effective as a

l'

'

management tool to measure the effectiveness of the security training

program. Also, the licensee's staff performance during a full par-

1

ticipation emergency preparednesss exercise reflected a high level

of training and readiness to respond to emergencies.

,

g >,r-y y , e ee-ve --t u--&- v - ry e t

. .

39

As part of-an overall program to improve management performance,

GPUN had 24 corporate officers attend a special three-day team-

building seminar conducted by a consultant. Plans are to enroll

additional employees in this course, including some onsite management.

These seminars may have the effect of improving cooperation and

communication among the various divisions involved in facility

operation.

In summary the licensee has established a functional training

facility that is well-staffed and capable of providing good opera-

tor requalification and STA training programs. Adequate attention

appears to be given to training operators on plant changes and

modifications. Well-designed programs have been established and

partially implemented to improve the capabilities of electricians,

mechanics, and I & C personnel. Means of improving these programs

are continuously being pursued, including bringing in various vendor

personnel to provide specific training. An overall attempt to

improve the quality of new hires and contractor personnel has also

been initiated. Efforts are in progress to provide team-building

management training which is intended to improve management

performance.

Conclusion

Category - 1

Board Recommendations

Licensee:

--

Expedite acquisition of plant specific simulator. In the

interim, attempt to develop other means of improving the

practical, operational focus of training.

NRC:

None

. .

.

40

J. Assurance of Quality

Management involvement and control in assuring quality is being

considered as a separate functional area for the first time and

continued to be an evaluation criterion for each functional area.

The various aspects of the Quality Assurance program have been

considered and discussed as an integral part of each functional

area and the respective inspection hours are included in each one.

Consequently, this discussion is a synopsis of the assessments

relating to quality work conducted in other areas and is not solely

an assessment of the quality assurance (QA/QC) departments.

The Oyster Creek overall organization is relatively new and is a

matrix type organization with QA/QC being part of one of seven

'

divisions responsible for safe operation of the plant. This type

of organization relies primarily on the quality consciousness of

each division manager to assure quality within his division. The

need for quality is obvious and is a goal of all division managers.

To augment the quality consciousness of management, the organization

provides a QA/QC department. In discussions with NRC, division

management expresses a commitment to quality. Inspector observations

have not identified any consistent trends that would tend to refute

this position. As regards the effectiveness of the QA organization

to help keep quality in the forefront, it appears they are generally

successful.

In assessing how the licensee assures quality, the SALP board has

considered various attributes normally considered key contributors

to the assurance of quality. Among the attributes considered

are implementation of management goals, planning / control of routine

activities, worker enthusiasm / attitudes, management involvement,

staffing, and training. Licensee management addresses these

attributes in a positive way. A quality issue facing the licensee

is the lack of quality requirements that existed during original

plant construction. This coupled with the aging of many components

has resulted in establishing a large work backlog and strain on the

resources necessary for plant operation. The following paragraphs

discuss examples of strengths and weaknesses within various licensee

organizations that relate to one or more of the contributing elements

that affect quality.

GPUN responded to the previous SALP report with commitments to

improve their performance in the QA/QC area. One concern involved

the effectiveness of the safety review process which the licensee

committed to review within three to six months after implementation

of the revised safety review procedure. This has not been accom-

plished as the revised procedure was not approved until September 1,

1986.

- _ - _ _ - . .-

-. - . - . - .-. . . - -

. . l

41

A NRC special review of MNCRs, QDRs, and QA audit findings was

conducted in an effort to evaluate a commitment to improve the ,

timeliness and aggressive pursuit of resolution of QA/QC findings. I

While this review indicated that there is a reluctance to implement

the escalation process when conditions dictate, it also revealed a

majority of the responses were timely. QA has taken some initia- .

tives to assist management with root cause identification to l

resolve deficiencies. It appears that management effort to assess '

and correct root cause deficiencies is directly proportional to the

perceived significance of the findings. QA should strive to focus

more clearly on significant safety issues -- certain QA findings

involved minor administrative details. Generally, there has been

improvement in the areas discussed in the licensee SALP response

letter, but continued management attention is required to continue

the improvement.

The Maintenance, Construction and Facilities (MCF) division has

made substantial changes to improve their performance since the

last SALP assessment period. They have added experienced personnel

to key management positions, initiated programs to improve super-

visory performance, continued with craft training programs,

encouraged cooperation between all interfacing divisions, adopted

a more professional approach to the management of their own and

contractor personnel, and demonstrated a concern for improving

overall performance. Areas in which improvements were not as evi-

dent included implementation of a post maintenance testing program,

timely response to QA/QC concerns, control of contractors, pro-

cedural compliance, and control of documentation. Additionally,

cleanliness during outages was erratic, worker attitudes were

oftentimes poor because of the many restrictions and controls they

face that prohibit them from efficiently accomplishing a job,

attention to detail and communication were found lacking in several

instances, rework accountability programs were not uniformly imple-

mented, timely reduction of the work backlog was not evident, and

ALARA was not as effective as anticipated. A lack of professional

curiosity was evident that appeared to result from the knowledge

that a satisfactory response to a query would be long in coming due

to the large work backlog. MCF management needs to continue with

their improvement programs in order to achieve a sustained improve-

ment and a broader realization of their concern for assurance of

quality.

Technical support performance was inconsistent in technical adequacy,

timeliness, willingness to accept responsibility, adherence to pro-

gram requirements, attention to detail, communications, cooperation

between divisions, responsiveness, and accountability. In the past

the licensee has had problems in submitting Licensee Event Reports

(LERs) in a timely manner. Improvements have been made in this area

and LERs are now generally submitted on time. One deficiency still

remains and that is the submittal of follow up reports to LERs.

Also, on a number of occasions responses to violations have not been

_ _ - - - _ - _ _

. .

42

submitted within the time required. The inspectors did not perceive

the same degree of licensee attention and concern for assurance of

quality within technical support that was evident in other functional

areas. Management effort is needed to sustain the areas of good

performance and improve the weaknesses to better assure quality in

the area of technical support.

Plant Operations, by its nature strives to assure quality mainly by

maintaining a strong operating staff, conducting effective training,

maintaining and adhering to good procedures, paying attention to

detail, and fostering effective communications. They are generally

successful at this, although they had several problems that indicate

room for improvement. Plant Operations management realizes that

quality impacts power production and, therefore, appears to have a

more full appreciation than other divisions as to the benefits of

assuring quality. Backshift tours by maragement have been

established to identify areas requiring improvement.

QA/QC at Oyster Creek plays an important role in assuring quality in

that it is the group that attempts to ensure other divisions neither

relax their approach to quality nor compromise it for other competing

factors. They are generally successful, due in large part, to an

overall corporate stance that endorses quality. Within the QA/QC

organizations, permanent licensee personnel are generally committed

to understanding and following the requirements of the quality

program. Personnel weaknesses with QC appear mainly during outages

when temporary help is used to carry the extra workload. Violations

were identified during this evaluation period that indicated problems

in this area. Weaknesses appeared in the quality organization in the

welding program and in structural weld inspections. These were due,

in part, to unclear program requirements, inadequate standard forms

used to record inspection results, and a weakness in QA inspectors'

understanding of structural weld codes. NRC inspector reviews of QA

audits and Quality Deficiency Reports (QDRs) indicated a reluctance

to escalate when lack of timely response required it. More rigid

adherence to escalation procedures is required. Also some of the QDR

findings have been somewhat trivial in nature which could explain, in

part, the problem of untimely responses to these documents from other

divisions.

The quality assurance organization has undergone some program changes

that should prove to be beneficial for the onsite organization.

Notable improvements have included (1) the use of technical special-

ists to assist site auditors during technical inspection activities,

(2) the performance of a system functional audit, (3) increased

quality control inspector training to improve infield awareness,

(4) the use of an independent Level III inspector to perform overview

analysis of contractor evaluation and disposition of ISI data, and

(5) an in depth review of vendor NDE personnel qualification /

certification records.

. .

43

One of the_ keys to an effective quality organization is

inquisitiveness. The quality program at Oyster Creek needs to

provide for more effective independent inspection throughout the

organization. The licensee has taken steps to move people into

QA/QC who have a good working knowledge of plant operations and

technical support. These changes should provide the ability for

more effective independent inspection if the flexibility in the

quality program allows it.

The licensee's corporate awareness of quality is particularly demon-

strated by an effective General Office Review Board (G0RB). NRC

inspection of the GORB determined the program established for the

GORB was in accordance with the license requirements and commitments.

The GORB was adequately staffed by licensee employees and contained

outside expertise. Provisions were in place and functional for

assuring that the GORB received information responsive to its

charter. The GORB Committee was thorough in its review of licensed

activities under its cognizance and its recommendations were well

formulated, received prompt attention from the licensee's staff, and

were acceptably closed out.

In summary, the assurance of quality is a stated commitment of Oyster

Creek and GPUN corporate management. Based on inspector observa--

tions, it is evidenc that this is a serious commitment. The various

organizations that participate in the safe operation of the plant

strive to assure quality through positive approaches towards those

attributes that contribute to quality. The results of the licensee's

efforts are generally successful. Improvements in various areas as

discussed throughout this SALP report are needed to continue and

improve upon this success. Management attention should be particu-

larly directed towards improving technical support, reducing the

large backlog of work in both MCF and technical support, and

improving timeliness and quality of response to communications

within and between divisions.

Conclusion

Category -

2

Board Recommendations

Licensee:

--

Reduce the number of trivial QA/QC findings that other divisions

must respond to and continue to upgrade the professionalism in

QA/QC.

--

Strengthen interfaces to improve the performance of the matrix

organization.

NRC:

None

. _ .

. - - - - . .

, .. .. . _ - - -_

. .

44

K. Licensing Activities

During the previous SALP period, the licensee was rated as Category 2

in this functional area. The previous SALP identified the need for

more management involvement in the decision on the dates to respond

to licensing actions and in meeting these dates.

During the current SALP period, 128 licensing actions were under

review and are partially identified in Table 8. Of these, 66% were

completed. The majority of these were complex and difficult. Fifty

licensing actions remained at the end of the SALP period. The

licensee also submitted 8 changes to its Safeguards Plan in accordance

with 10 CFR 50.54(p) and NRC completed its review of a Security Plan

change submitted during the prior SALP period.

The significant licensing actions completed in the SALP rating period

include the following: three emergency Technical Specification (TS)

amendments, exemptions to Appendix R, alternate shutdown capability,

deferment of SPDS implementation and of completion of Mark I Contain-

ment Confirmatory Order to the Cycle 12 outage, cancellation of

replacement of containment purge / vent isolation valves, deferment of

feedwater nozzle inspection to Cycle 12R outage, Safety Parameter

Display System review, Detailed Control Room Design Review, Safety

Issues Management System (SIMS), retyped Appendix A TS, high point

vents on the isolation condensers, control room habitability, maximum

drywell temperature, and completion of four old MPAs.

The licensee has generally shown prior planning and assignment of

priorities in licensing and security activities. This has been shown

in the good working relationship between the NRC Project Manager and

the licensee. This is also shown in the licensee's above average

response to SIMS; the active participation in the NRR utility

contacts meetings; the work to complete the Appendix R modification

before plant restart from the Cycle 11R outage; the completion of

10 CFR 50.49 in the voluntary one-month outage in October 1985; the

shutdown to replace Static-0-Ring differential pressure (SOR dp)

switches in 1986 and the later replacement of these switches by an

analog trip system in the Cycle 11R outage; and the review of the

supports for the drywell piping penetrations. In addition, there

have been several Licensee Event Reports (LERs) on equipment found,

in the Cycle 11R outage, not built to design, where the licensee has

voluntarily upgraded the equipment in the outage.

Licensee management has worked to have good communication with the

NRC staff and participated in a significant number of meetings in

Bethesda on short notice. With this involvement, there has, however,

been two emergency TS amendments for the Cycle 10M outage; the poorly

prepared for meeting in 1986 on the integrated schedule; the late

submittals on several issues involved in the plant restart from

, .-

45

the Cycle 11R outage; and the requested deferment of the isolation

condenser makeup pump from the Cycle 11R outage. With good manage-

ment involvement and control, these should not have happened.

The licensee's Oyster Creek Licensing and Regulatory Affairs (0CLRA)

staff has worked constructively with the NRC staff throughout the

SALP period. This is one reason for the large number of licensing

actions completed in this period. The problem discussed above with

the licensee management includes a problem between the licensing

function and the engineering function of the licensee. This problem

is illustrated when the licensee interacted with the staff in 1986 on

the issue of a schedular exemption to 10 CFR 50.48 and Appendix R.

The licensee management in Technical Functions appeared to attempt

to involve the staff management prematurely, i.e., prior to com-

pleting sufficient engineering to provide a basis for a schedular

exemption. This was after a meeting had already been arranged for a

later date to discuss the exemption after sufficient engineering was

completed. The OCLRA appeared to be used in a manner which showed an

apparent conflict of interest between the licensing function and the

engineering function of the licensee. This resulted in a letter to

the licensee on March 17, 1986 and a response from the licensee on

March 24, 1986. However, since the letters, the relationship between

NRR and the licensee has returned to the relationship that existed

before and the licensee will complete all Appendix R modifications in

the Cycle 11R outage before restart.

The licensee has generally demonstrated a good understanding of the

technical issues involved in licensing actions and has generally

proposed technically sound, thorough, and timely resolutions to

these issues including security activities. However, there were

two issues, requesting a containment leak rate testing TS change

and requesting no high radiation signal to containment purge / vent

isolation valves, where the licensee's approach seems to indicate

it did not understand the requirements.

The licensee has generally made timely submittals to meet deadlines.

Exceptions are the last submittal for the Appendix I TS, primary

coolant radioactivity TS, TS Change Requests for the Cycle 11R

outage, responses to requests for additional information for the

Safety Parameter Display System deferment, justification for

deferring work on torus / reactor building vacuum breakers for the

Cycle 11R outage, additional exemptions to 10 CFR 50, Appendix R,

and several LER responses.

The licensee has actively participated in meetings with the staff.

The licensee has been responsive to NRR in meeting on a monthly basis

to discuss all active licensing actions including priorities and

future licensee submittals. As a result, lower priority reviews,

which had been backlogged, are being completed. There have been 28

meetings in this rating period. These meetings were generally well-

conducted, well prepared for and helpful in resolving the issues.

..

. .

46

This was especially true for the meeting on the deferment of the

feedwater nozzle inspection from the Cycle 11R outage.

The licensee has been responsive to NRR initiatives. The quality of

its "no significant hazards consideration" analyses improved signifi-

cantly in 1986. The licensee has responded promptly to several

surveys from the staff during the reporting period including a

meeting on Generic Issue 77. The licensee participated in several

BWR Project Directorate #1 (BWD1), NRR, initiatives to improve com-

munications between NRC and the licensee and among the licensee

within BWDI, NRR. These initiatives were in the utility contacts

meetings in 1986; a mini owner's group among the licensees in BWDI,

NRR to discuss commen technical issues; and the purchase of equipment

to use the BWD1 tracking system for licensing actions.

Events at the facility have been generally reported promptly and

accurately and are above average in quality. The licensee volun-

tarily provided information by reports on the erratic behavior

of SOR dp switches and on HFA relay window fogging.

During this period, the licensee's performance was generally found to

be above average. Management attention and involvement was generally

good showing prior planning and assignment of priorities but there

have been a number of issues which, with good management involvement,

should not have happened. The submittals have generally demonstrated

an understanding of the issues and have been generally technically

sound. thorough and timely. Staffing levels and quality of staff are,

therefore, adequate and communication levels between the operating

staff and management are well established and effective. The licensee

has been effective in dealing with problems and has been responsive

to NRC initiatives. A significant number of licensing issues have

been completed. The licensee's efforts in the functional area of

~

Licensing Activities has im;, roved during this evaluation period.

Conclusion

Category -

2

Trend - Improving

Board Recommendations

Licensee:

None

NRC:

None

<

,

,. .

47

V. Supporting Data and Summaries

A. Investigations and Allegations Review

During this assessment period, six allegations were received and

acted on. Four involved radiation control, one security, and one

drugs. Of the four radiation control allegations, two were not

substantiated and two were found to be partially valid and corrective

action was taken by the licensee. The security and drug allegations

were not substantiated.

At the end of the last SALP period, an investigation was in progress

to determine if there was any management involvement in licensee

staff employee lying to a NRC inspector. This investigation

concluded there was no management involvement and that the problem

appeared to be limited to the two involved employees who were

subsequently discharged.

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

. .

48

B. Escalated Enforcement Actions

1. Civil Penalties None

,

2. Orders None

3. Confirmatory Action Letters None

-

i

.. .. '!

, 1

.49

C. Management Conferences

Date Subject

10/28/85 SALP (219/85-99)

11/13/85 Discuss IEB 79-02 and 79-14

4/01/86 Discuss IEB 79-02 and 79-14

9/13/86 Enforcement Conference dealing with QA-

and management of contractors during-

isolation condenser piping repairs performed

during 10R outage

9/16/86 Discuss piping reverification program

9/26/86 Discuss radiation control issues

.

. _ . ..

. 5

50

D. Licensee Event Reports (LERs)

Tabular Listing

Type of Events:

A. Personnel Error . . . . . . . . . . . 11

B. Design / Man./Construc./ Install . . . . . . 12

C. External Cause . . . . . . . . . . . 2

D. Defective Procedures . . . . . . . . . 1

.c"' E. Component Failure . . . .- . . . . . . 9

X. Other . . . . . . . . . . . . . . 1

>

Total 36*

Licensee Event Reports Reviewed:

Report Nos. 85-12 to 85-26, and 86-01 to 86-22

(See Table 1 for LER. listing by functional area and Table 2 for a

LER summary.)

• LER 86-08 was not included in this count as it was a voluntary

report.

.

E

, ..

.

TABLE 1

LISTING OF LERs BY FUNCTIONAL AREA

OYSTER CREEK NUCLEAR GENERATING STATION

AREA NUMBER /CAUSE/ CODE -TOTAL

A B C D E X

Plant Operations 6 1 6 1 14

Radiological Controls --

Maintenance 2 2

Surveillance / Inservice 4 1 1 6

Testing

Assurance of Quality 1 1

Emergency Preparedness --

-Security and Safeguards --

Outage Management / Refueling --

Technical Support 2 2

Training and Qualification --

Licensing --

Other 7 2 2 11

__

Total 36

Cause Codes:

A - Personnel Error

B - Design, Manufacturing, Construction, or Installation Error

C - External Cause

D - Defective Procedures

E - Component Failure

X - Other

. .

TABLE 2

LER SUMMARY (7/1/85 - 10/15/86)

OYSTER CREEK

LER Number Summary Description

85-12 Reactor Isolation Scram

85-13 Failure to Maintain Drywell to Torus Differential

Pressure

85-14 Unit Substatation Transformers IA2 and 1B2 Low 011

85-15 Automatic Scram on Low Condenser Vacuum

85-16 Reactor Scram on APRM Downscale and IRM Hi Hi

85-17 Drywell Bulk Temperature

85-18 Emergency Service Water Pipe Coating Failure

85-19 Non-Conservative Error in Technical Specification Setpoint

Calculation

85-20 Loss of Both Diesel Generators

85-21 APRM Setpoint Did Not Meet Acceptance Criteria

85-22 Reactor Scram Due to Main Generator Trip

85-23 Emergency Service Water System Seismic Concerns

85-24 Reactor Trip Due to High Neutron Flux

85-25 Main Steam Isolation Valve Closure Caused by Operator

Error

85-26 Neutron Flux Setpoints Exceed Technical Specification

Limits

86-01 Reactor Low Level Sensors Found out of Specification

86-02 Inoperative Containment Spray Snubber Caused by Personnel

Error

86-03 Three Out of Eight Isolation Condenser Pipe Break Sensors

Out of Specification

-. .

T2-2

86-04 Reactor Scram on Anticipatory Turbine Trip Caused by Limit

Switch Failure

86-05 Core Spray and Diesel Generator Initiation Caused by

Procedural Deficiency

86-06 Isolation Condenser Actuation Pressure Sensors Exceeded

Setpoint Limit

86-07 Reactor Shutdown Due to Reactor Low Water Level Scram

Switch Repeatability Problems

86-08 Local. Leak Rate Testing Results (Voluntary Report)

86-09 Scram Signal Received Due to Neutron Instrumentation . Noise

86-10 Inoperable Isolation Cendenser Snubbers

86-11 Secondary Containment Isolation and Initiation of Standby

Gas Treatment System

86-12 Containment Isolation and Standby Gas Initiation Caused by

Electrical Storm

86-13 Secondary Containment Isolation and Initiation of Standby

Gas Treatment System

86-14 Containment Spray System Seismic Concerns

86-15 Refueling Bridge Limit Switch Failure Due to Personnel

Error

86-16 Fuel Clad Failures

86-17 Containment Isolations and Standby Gas Initiation Caused

by Storms

86-18 Secondary Contaiment Leak Rate

86-19 Standby Gas Initiation Caused by Personnel Error

86-20 Broken Valve Disc in Control Rod Drive Hydraulic Unit

86-21 Plant Systems did not Meet Seismic Design Bases

86-22 Control Rod Drive Hydraulic Control Units not Installed

Per Design

.. .

,

,

TABLE 3

ENFORCEMENT SUMMARY 7/1/85 - 10/15/86

OYSTER CREEK NUCLEAR GENERATING STATION

A. Number and Severity Level of Violations

Severity Level I 0

Severity Level II O

Severity. Level III 0

Severity Level IV 21

Severity Level V 2

Deviations 1

Total '. 24

B. Violation vs.' Functional Area

Functional Area Severity Level

I II III IV V Dev

Plant Operations 3 1

Radiological Controls 6

Maintenance 2

Surveillance / Inservice Testing 0

Emergency Preparedness O

Security and Safeguards 0

Outage Management / Refueling 0

Technical Support 7 1 1

Training and Qualification 0-

Assurance of Quality 3

Licensing 0

Totals 21 2 1

Note: Enforcement action is pending on several EQ concerns

identified during this evaluation period.

_ _ . - . .

_ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ -___

, ..:

l

TABLE 4

INSPECTION HOURS SUMMARY (7/1/85 - 10/15/86)

OYSTER CREEK NUCLEAR GENERATING STATION

HOURS  % OF TIME

l

Plant Operations 1971 38

Radiological Controls 478 9

Maintenance 647 12

i Surveillance / Inservice Testing 417 8

Emergency Preparedness

> ,

267 5'

Security and Safeguards 140 3

Outage Management / Refueling 301 6

i

Technical Support 968 19

Training and Qualification 0 0

i Assurance of Quality 0 0

!

Licensing Not Applicable

l

?

Total 5189 -100

i

1

I

l

t.

. ___ . _ _ _ _ __

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

. .

TABLE 5

INSPECTION REPORT ACTIVITIES

OYSTER CREEK NUCLEAR GENERATING STATION

Report No.

Inspections

Dates Inspector Hours Area Inspected

85-20 N/A -

Management Meeting - Security

6/17/85 Issue

85-21 N/A -

Management Meeting - Enforcement

6/13/85 Conference

85-22 Specialist 22 Meeting and Examination of IEB

6/25/85 79-02 and 79-14 Documentation

85-23 Resident 215 Routine

7/1 - 8/18/85

85-24 Specialist 35 Security

7/22-26/85

85-25 Specialist 102 Transportation Activities

7/29 - 8/1/85

85-26 Resident 124 Routine

8/19 - 9/22/85

85-27 Specialist 39 Shock Suppressors

8/19-23/85

85-28 Specialist 66 Transformers Low 011 Level and

9/23-27/85 Fire Protection / Prevention

Program

85-29 Resident 316 Routine

9/23 -10/20/85

85-30 Specialist 28 Material Control and Accounting

10/1-4/85

85-31 Specialist 27 Inservice Inspection Data

10/7-10/85

85-32 Specialist 103 QA Program, Document Control,

10/21-25/85 Onatte Review Committees, and

Record Program

-.

. .

T5-2

85-33 Specialist 46 Radiation Control Program

10/21-25/85

85-34 Cancelled

85-35 Resident 284 Routine

10/21 -12/1/85

85-36 Specialist 254 Overpressurization of Low

11/7-22/85 (Team) Pressure ECCS Systems

85-37 N/A Management Meeting - IEB 79-02

11/13/85 and 79-14

85-38 Resident 125 Routine

12/2/85 -

1/5/86

85-39 Resident / 36 Environmental Qualification of

12/6-9, 19/85 Specialist Main Steam Sensing Devices

85-40 Specialist 8 Iodine Uptakes by Workers

12/21/85 (Special)

85-99 SALP

86-01 Specialist 201 Implementation of 0737 Items

1/13-17/86 (Special)

86-02 Resident 215 Routine

1/6 - 2/2/86

86-03 Specialist 88 Non-licensed Operator Training

2/10-14/86 and Offsite Support

86-04 Resident 171 Routine

2/3 - 3/2/86

86-05 Specialist 56 Security

2/18-21/86

86-06 Resident 373 Routine

3/3 - 4/13/86

86-07 Specialist 58 Emergency Preparedness Exercise

4/9-10/86 (Team)

86-08 Specialist 280 Qualification of Electric

3/24-27/86 (Team) Equipment

- _ _ _ _ _ _ .

,- _ - - _ _ - - _ - - - _ - - - -

. .

T5-3

86-09 Specialist 105 IEB 80-11

5/5-9/86

86-10 Specialist Requalification Examinations

5/9-15/86

86-11 Specialist 42 Fire Protection / Prevention

4/14-18/86 Program

86-12 Resident 393 Routine

4/14 - 6/1/86

86-13 Specialist 74 Refueling Radiological Controls

4/21-25/86

86-14 Specialist 80 Maintenance Program / Activities

4/28 - 5/2/86

86-15 Specialist 11 Independent Safety Reviews and

4/30 - 5/2/86 GORB

86-16 Specialist 55 Nonradiological Chemistry

6/3-6/86 Program

86-17 Resident 179 Routine

6/1 - 7/6/86

86-18 Specialist 33 Diesel Generator Modifications

6/24-27/86

86-19 Specialist 44 Welding and Inservice Inspection

7/7-11/66

86-20 Cancelled

86-21 Resident 252 Routine

7/7 - 8/17/86

86-22 Specialist Operator Licensing Examinations

8/11-15/86 and Requalification Training

86-23 Specialist 43 Ultrasonic Examination of Welds

8/11-15/86

86-24 Resident 356 Routine

8/18 - 10/5/86

86-25 Specialist 35 Refueling Activities

8/25-29/86

-_. . _ _ . _

- - . _ _ _ . ._

r

-.. .

l.

T5-4

L.

!

l ' 86-26 '

Specialist 17. Review and Planning for

L 8/26/86 Underwater Weld Repair

86-27 Specialist 4-6 Local Leak Rate Testing and

9/4-9/86 CILRT Procedure-

i

I_ 86-28 Specialist 42 Review of Administrative

! 8/18-20/86 Overexposure

l 9/8-10/86

l

- 86-29 Specialist 32 Effluents and Open Items

s 9/30 -

10/3/86

!

86-30 Specialist 70 Maintenance, Calibration, and

9/30 - 10/9/86 Concrete Deficiencies

! 86-31 N/A 8 Management Meeting - Piping

9/16/86 Reverification Program

!

!

!

l~

I

l

t

I

l

l

1

$ .; Cbc (

. o. ..j ,

e

--

'

,

,3 c

, ..

'y. , , ,

. , -

f*

Table 6 c--

~

Enforcement Data

~

'

OYSTER CREEK NUCLEAR GENERATING STATI'ON

-

c.-

3 ,

Inspection Inspection Severity Functional x .

l

Report No. Date Level Area Violation

~

85-23 7/1 - 8/18/85 IV Plant Failure to adhere to a

Operations , station procedure

IV Plant Failure to adhere to a

Operations ' station procedure

' ~

85-25 7/29 - 8/1/85 IV Radiological ' Quality Co61.ro11of '

Controls * waste shilments i

l 85-33 10/21-25/85 IV Radiological :Transporiatidrb '

Controls fregulations,

85-35 10/21 - 12/1/85 IV Assurance of $21dingProhram

) Quality

l IV Technical Failure to provide weld -

-

l Support configuration -

_

l

information "

IV Maintenance Modification :v

inadequacies

'

'

_ IV Assurance of QC Inspecticas

f Quality *

l IV Radiological Failure to survey

Controls carry-along items

i

85-39 EQ enforcement pending .

t

'

1/6 - 2/2/86

"

86-02 IV Plant Snubb'er made~ inoperable -

Operations

3/3 - 4/13/86 Failure to maintain

~

86-06 IV Technical

Support station procedure

IV Technical Failure to adhere to

Support proaect reviews

procedtres

86-08 EQ enforcement pending

.

_

., ...

T6-2

- 86-09 5/5-9/86 V Technical Evaluation of Support

Support

IV Technical ' Maintenance of records

Support

Deviation Technical Inadequate

Support documentation to

support mortar

qualification

86-11 4/14-18/86 V Plant Failure to correct

Operations a non-conformance

86-12 4/14 - 6/1/86 IV Maintenance Inadequate work control

procedure

IV Technical Inadequate design

Support information

IV Technical Weld control precedures

Support

'

IV Assurance of Inadequate QA/QC

Quality (Issued subsequent to

SALP period following

yrp ,

enforcement conference)

86-17 6/1 - 7/6/86 IV Radiological Failure to lock

Controls entrance to high rad

area

86-21 7/7 - 8/17/86 IV Radiological Inadequate survey

Controls

86-24 8/18 - 10/5/86 IV Technical Lack of safety

Support evaluation for a

procedure change that

,

required one

86-28 8/18-20/86 IV Radiological Inadequate surveys

3. . 9/8-10/86 Controls

.

-

=,

r

. ~ . .- . - - . .- - - .

.

. - . - . - --

5; J

, e. .

..

. M'

'

_ _

,

f

n,

3

s .

1

4

j TABLE 7

i l'

7 UNFLANNED TRIPS AND SHUTDOWNS

)

Date Descriotion

~

Cause

7/1/85 Plant Operating at full power-

i

7/8/85 Reactor Scram Lov. condenser vacuum due to cracked

y , steam jet air ejector drain pump

,

.;

housing - equipment failure

"

':- 7/9/85 Startup

7/22/85 Shutdown. High Containment Spray heat exchanger i

differential pressure caused by

' , delamination

inside of emergency of coalservice

tar lining on

water

piping - equipment failure-

'

8/3/85 Startup

!. 8/9/85 Reactor Scram During shutdown all IRMs were

<

inadvertently inserted while APRM's

were downscale - operator error

'8/10/85 Startup

.10/18/85 Shutdown Month long outage for environmental

qualification modifications

11/16/85 Startup

11/20/85- Reactor Scram Reactor trip due to generator trip

resulting from a current transformer

failure - equipment failure

'

11/23/85. Startup. '

12/15/85 Reactor Scram Electric pressure regulator failed

due to a loose wire connection -

personnel error

.

12/16/85 Startup

3/6/86- Reactor Scram Turbine trip resulting from

limit switch failure - equipment failure

3/7/86 Startup

3/27/86 Shutdown Reactor low level switches declared

inoperable - equipment failure

3/30/86 Startup

4/12/86 Shutdown 11R Refueling / Maintenance Modification

outage

1

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

o. *

TABLE 8

SALP HISTORY

8/1/79 - 10/15/87

g OYSTER CREEK NUCLEAR GENERATING STATION

Assessment

Report Period OPS RADCON MAIN SURV EP FP SEC OUTC QP LIC TS TRG

10/80 8/1/79 - 2 3 2 3 2 2 2 2 3 N N N

7/31/80

3/81 8/1/80 - 2 2 2 2 2 2 3 2 2 N N N

1/31/81

6/82 11/1/80 - 2 2 3 3 2 2 2 2 N 2 N N

10/31/81

7/83 2/1/82 - 2 2 2 2 2 2 1 2 N 2 N N

1/31/83

10/84 2/1/83 - 1 1 2 1 2 2 2 2 N 2 N N-

4/31/84

3/86 5/1/84 - 2 1 3 2 1 2 2 2 N 2 2 N

6/30/85.

7/1/85 - 2 2 2 1 1 N 1 2 2 2 2 1

10/15/86

N = Not Evaluated During Assessment Period

e ~ \

!

Table 9

LICENSING ACTIVITIES

1. NRR/ Licensee ~ Meetings (at NRC or Licensee HQ)

Cycle 11 Refueling outage 07/02/85

August 1985 Progress Review Meeting 09/18/85

Expanded Safety System Facility Status 09/20/85

Detailed Control Room Design Review 10/09/85

September 1985 Progress Review Meeting 10/24/85

at State of New Jersey, BRP

Deferments from Cycle 11R outage 11/20/85

Deferment of Feedwater Nozzle Inspection 12/13/85

from Cycle 11R outage

December 1985 Progress Review Meeting 01/22/86

Discuss the channel checks for RWL 01/23/86

instrumentation

Discuss special circumstances for 02/11/86

licensee's exemptions to Appendix R

Integrated living schedule program for 02/12/86

Oyster Creek

February 1986 Progress Review Meeting 03/26/86

NUREG-0737 Items II.F.1.1 and II.F.1.2 04/02/86

Containment purge / vent isolation valves 04/03/86

Upgrade containment nitrogen purge / vent 04/10/86

system

March 1986 Progress Review Meeting and 04/23/86

Director's annual visit to licensee HQ

Seismic design considerations 04/24/86

Generic Issue 77, Flooding of Safety 04/30/86

Related Equipment

Erratic behavior of dp Static-0-Ring switches 06/12/86

Isolation condenser piping penetrations 08/22/86

Integrated leak rate testing 09/10/86

August and September 1986 Progress Review 10/31/86

Meeting

2. NRR Site Visits and Meetings

June 1985 Progress Review Meeting 07/31 to 08/01/86

October / November 1985 Progress Review Meeting 12/11/85

January 1986 Progress Review Meeting 02/20-21/86

Director of DBL visited site 03/24/86

March 1986 Progress Review Meeting and 04/22/86

Director's annual visit to site

April and May 1986 Progress Review Meeting 06/16-17/86

Exemptions to Appendix R 06/23/86

_ Plant orientation visit 08/25-29/86

June and July 1986 Progress Review Meeting 08/27-28/86

. . - - , . . - -_-

^'

o

T9-2

3. Commission Meetings

None

4. Reliefs Granted

Deferment of modifications from Cycle 11R 10/06/86

Cancel replacement of containment purge / vent 10/10/86

isolation valves

Cancel modifications of torus for thermal 10/01/86

mixing and local quencher

temperature monitoring

Cancel modification to SGTS duct 04/18/86

Defer inspection of feedwater nozzles from 02/24/86

Cycle 11R outage

Revise requirements on recirculation loop 07/15/86

interlock ,

5. Schedular Extensions Granted

SPDS implementation 10/06/86

Control room habitability 07/15/86

Mark I containment modification 10/06/86

6. Exemptions Granted

Exemption to Appendix R 03/24/86

7. Licensee Amendments Issued

Amendment Title Date

87 Drywell-Suppression Chamber 07/01/85

Differential Pressure

88 Relief Valve Position Indication 07/01/85

89 Audits of the Fire Protection 07/02/85

Program and Quality Assurance

Program

90 Inservice Inspection and Testing 10/18/85

91 Low-Low Reactor Water Level 11/19/85

Instrumentation Modification

92 Limit Overtime 11/19/85

i

93 Water Purity of Reactor Coolant 11/21/85

94 NUREG-0737 Technical Specifica- 11/22/85

tions (GL 83-36)

95 Reactor Water Level Instrumenta- 11/30/85

tion Channel Check

-. _ ,_ .- ,

'

.

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T9-3

7. License Amendments Issue, Continued

Amendment- -Title Date

96 Valve Position Indicator Accident 12/09/85

Monitoring Instrumentation

97 Reactor Coolant Pressure Boundary 01/06/86

Leakage

98 Post Accident Sampling Program 01/14/86

99 Standby Diesel Generator Fuel 02/04/86

Tank

100 Mechanical and Hydraulic Snubbers 03/31/86

101 Diesel Generator Pump Battery 03/31/86

System

102 Licensed Control Room Operators 05/12/86

Onsite

103 Standby Gas Treatment System 05/28/86

104 Excess Flow Check Valves 07/09/86

105 Control Room Habitability 07/15/86

106 Recirculation Pump Interlock 07/15/86

Scope Change

, 107 Appendix B Technical Specifications 07/17/86

-

Retyped Appendix A Technical 10/01/86

Specifications

8. Emergency License Amendments

Amendment Title Date

88' Relief Valve Position 07/01/85

Indication

91 Low-Low Reactor Water Level 11/19/85

Instrumentation Modification

95 Reactor Water Level Instrumentation 11/30/85

Channel Check

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

c:,c

FIGURE 1

NUMBER OF DAYS SHUTDOWN ( ) PER MONTH

1985

JUL 2 Shutdowns _ (10 days)

AUG I 35 (4 days)

SEP

OCT 1 Shutdown (13 days)

NOV 1 Shutdown (20 days)

DEC 1 SD (2 days)

1986

JAN

FEB

MAR 2 Shutdowns (5 days)

APR 1 SD Refuel / Mod /Maint Outage (18 days)

MAY

JUN

JUL

AUG

SEP

OCT End of SALP Period

NOV

5 10 15 20 25 30

_ _ . , , _ . _ _ _ ,_ . . . .