IR 05000219/1987099
| ML20246G164 | |
| Person / Time | |
|---|---|
| Site: | Oyster Creek |
| Issue date: | 08/21/1989 |
| From: | Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Phyllis Clark GENERAL PUBLIC UTILITIES CORP. |
| References | |
| NUDOCS 8908310237 | |
| Download: ML20246G164 (3) | |
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MG 211989 Docket No. 50-219 GPU Nuclear Corporation i ATTN: Mr. P. R. Clark '
President
1 Upper P,ond Road Parsippany, New Jersey 07054 {
Centlemen:
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Subject: SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP) FINAL REPORT ,
NO. 50-219/87-99 (
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This letter transmits our final SALP Report for the Oyster Creek facility for the period October 1, 1987 through January 31, 1989. The final SALP Report (Enclosure 1), our earlier transmittal letter (Enclosure 2), SALP {!
meeting attendees (Enclosure 3), and your response to the SALP Report ;
(Enclosure 4) are enclosed and will be placed in the Public Document Room. j Thank you for your letter of June 15, 1989, wherein you presented, as a followup to our May 8, 1989 meeting, a detailed response to the SALP Report and a description of some of your actions subsequent to the end of the SALP period.
No changes ware made to the SALP Report after our review of your response.
Overall, the facility has been operated in a safe manner. Your site and corporate management continues to display a strong commitment to nuclear safety. The performance at Oyster Creek, however, remains inconsistent in some areas. Although adequate, the level of performance in some areas, particularly in Radiological Controls, was less effective than in the previous SALP cycle. We acknowledge the initiatives and changes which you have made to improve the overall performance in the area of Radiological Controls. We will continue to monitor your progress in improving performance. Additionally, we look forward to meeting with you again in September to discuss the progress of the Radiological Controls programs which you have initiated and the conclusions you have drawn from the assessments of the INPO Evaluation team, the special INPO assistance team and GPU Nuclear's task force.
In summary, the report, our meeting, and your response letter resulted in a constructive assessment of the performance at Oyster Creek and provided a thorough understanding of the extensive corrective actions and improvements undertaken since January 15, 1989.
Your cooperation is appreciated.
Sincerely, Original Signed By:
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Thomas T. MartiQ g William T. Russell Regional Administrator 0FFICIAL R- ORD
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COPY OY SALP 87-99 - 0001.0.0 890G330237 89082J 08/03/89
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Enclosures:
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13 Systematic Assessment of' Licensee Performance. (SALP) Final Report
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.No;.350-219/87-99 .
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2. . NRC: Letter, W. T. Russell to E. E. Fitzpatrick dated April 17, 1988
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3.7 May'8, 1989 SALP Management Meeting Attendees.
4. GPU:-Letter from P..R. ClarkTdated June.15, 1989
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REGION I
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475 ALLENDALE ROAD
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Docket No. 50-219 MR 11 W GPU Nuclear Corporation ATTN: Mr. Eugene E. Fitzpatrick Vice President and Director Oyster Creek Nuclear Generating Station
'P. O. Box 388 Forked River, New Jersey 08731 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP) Report No.
.50-219/87-99 The NRC Region I SALP Board conducted a review on March 14, 1989, and evaluated the performance of activities associated with the Oyster Creek Nuclear Generating Station. The results of this assessment are documented in the enclosed SALP report, which covers the period October 1,1987 to January 31, 1989. We will contact you shortly to schedule a meeting to discuss the report.
At the meeting, be prepared to discuss our assessment and any plans you have to
, improve performance. 'In particular, be prepared to discuss your plans yith respect to programs to identify and correct deficiencies in the areas of Radiological Controls, Security,-and Plant Operations in light of the problems
'identi fi ed. Continued inconsistent performance at the plant is a concern to us.
Following our meeting and receipt of your response, the enclosed report, your response, and summary of our findings and planned actions will be placed in the NRC Public Document Room.
Your cooperation is appreciated.
Sincerely,
liiam T. Russell Regional Administrator Eq:losure: NRC Region I SALP Report No. 87-99
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GPU Nuclear Corporation 2
l APR 171989 1
, cc w/ encl:
1 M. Laggart, BWR Licensing Manaaer Public Document Room (PDR)
Chairman Zech Commissioner Roberts Commissioner Carr l
i Commissioner Rogers l
l Commissioner Curtiss 5 L K. Abraham, PAO, RI (27 copies)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New Jersey bcc w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, DRMA (w/o encl)
J. Taylor, DERO l W. Russell, RI M. Knapp, RI T. Martin, RI SALP Board Attendees R. Brady, RI J. Lieberman, OE W. 011veria, DRS
} D. Holody, ES '
G. Kelly, DRP E. Conner, DRP Section Chief, DRP.
- Robert J. Bores, DF
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ENCLOSURE 3 1 ,
SALP MANAGEMENT MEETING OYSTER CREEK.
MAY 8, 1989 L
l GPUN ATTENDEES G. Busch, Oyster Creek Licensing Manager, GPUN P. Clark, President,.GPUN l C. Clawson, Director, Communications, GPUN l R. Coe, Training and Education Director., GPUN C. Comerford, Administrative Support Manager, GPUN
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D. Croneberger, Director-Engineering Projtets, GPUN B. DeMerchant, BWR Licensing Engineer, GPUN L C. DePinto, Rate Analyst, GPUSC l D. Distel, PWR Licensing Engineer, GPUN '
P. Fiedler, Director, Quality and Training, GPUN I, Finfrock, Jr., Chairman, GORB, GPUN E.' Fitzpatrick, Director, Oyster Creek, GPUN R. Heward, Jr., Director, Maintenance, Construction and Facilities, GPUN J. Hildebrand, Director, Radiological & Environmental Controls, GPUN R. Keaten, Director, Quality Assurance, GPUN
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E. Kintner, Executive Vice-President, GPUN J. Knubel, Nuclear Security Director, GPUN K. Kutch, Senior Staff Analyst, GPUN V. Laggart, Manager,' BWR Licensing, GPUN R. Long, Director, Planning and Nuclear Safety, GPUN R. McGoey, Manager, PWR Licensing, GPUN
- K. Neddenien, Senior Media Representative, GPUN E. O'Donnell, Director, Corporate Planning, GPUN W. Runtie, Manager, Rate Affairs, GPUN M. Slobodien, Radiological Controls Director, Oyster Creek, GPUN L. Sullivan, Jr., Licensing and Regulatory Affairs Director, GPUN P. Wells, Safety Review Engineer, GPUN R. Wilson, Director, Technical Functions, GPUN NRC ATTENDEES R. Bellamy, NRC Region I, Chief, Facilities Radiological Safety & Safeguards E. Collins, Senior Resident Inspector, NRC C. Cowgill, NRC Region I, Chief, Reactor Projects Section 4B J. Durr, Chief (Acting) Projects Branch I, NRC A. Dromerick, NRR, Division of Projects 1/II, Project Manager W. Kane, NRC Region I, Director, Division of Reactor Projects D. Lew, Resident Inspector, NRC J. Stolz, NRR, Division of Reactor Projects I/II, Projects Cirector PUBLIC ATTENDEES R. Ebright, NJ-D.E.P. - Bureau of Nuclear Engineering M. Jacobs, NJ-D.E.P. - Bureau of Nuclear Engineering M. Van Ess, Neclear Engineer, N.J. Board of Public Utilities
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[ ENCLOSURE _4 GPU Nuclear Corporation
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arsip any, New Je sey 07054 201-316-7000 TELEX 136-482 Writer's Direct Dial Number:
June 15, 1989 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555
Dear Sir:
Subject: Oyster Creek Nuclear Generating Station Docket No. 50-219 Systematic Assessment of Licensee Performance (SALP) Respcnse Ref'erence: Letter dated January 25, 1989, P. R. Clark to USNRC As discussed with you at our meeting held in Parsippany on May 8, 1989, this letter' and its attachment provides our response to the Systematic Assessment of Licensee Performance (SALP) report.-
! As stated during our meeting of May 8, 1989, we believe the value of the SALP prccess lies in the dialogue it promotes and the identification cf areas where improvements can be made. Attachment I provides our. response by functional area and summarizes key elements of our efforts for further improvement.
GPU Nuclear believes substantial . improvements have been made particularly in the latter part of the previous SALP period, and welcomes a mid-period review during the current period.
Very truly yours,
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W P. R. Clark President GPUN PRC:BDe:dmd Attachment 0773A l
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-8906230136 890615 Il[fj
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GPU Nuclear Corporation is a subsidiary of General Public Utihties Corporation
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-cc: Mr. William T.: Russell, Administrator Region l-
U.S. Nuclear Regulatory Commission 1475 Allendale Road.
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.Mr. Alexander W. Dromerick, Project Manager U.S.' Nuclear Regulatory Commission Division of Reactor Projects 1/11
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.Washington,.DC L20555
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NRC Rbsident Inspector .. .
Dyster Creek Nuclear Generating Station
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OC SALP-MAY 15, 1989l ATTACHMENT I Functional Area: Plant Operations GPU Nuclear believes we have made. substantial improvements particularly since the end of the SALP period. The SALP cited in'a positive sense on-shift decision making, improved materiel . condition, no plant trips, fewer operator et rors, control room professionalism, operator action to control transients, our emphasis on cooperation and teamwork, and others. In our view, the SALP commented favorably on two key items - the emphasis placed en safety befero schedule and our error-free plan approach. These are two concepts _that we are continuing to stress as fundamental philosophies. All of the items the SALP noted as positive will continue to be built upon and strengthened during the current,SALP period.
With regard to secondary equipment problems, actions have been taken to address this concern. Plant Materiel conducted a survey of various plant personnel' to understand what plant equipment problems were thought to be significant. The equipment problems and concerns from that servey along with the Materiel Condition Report (Phase II) conducted during this SALP period, were consolidated into a Materiel Condition Issue (MCI) List. The MCIs were distributed to senior management for review and comment and then finalized.
The list has been divided into segments to be worked on based on availability of the equipment. Development of action guidelines and assignment of actions to address the issues is underway as part of the Plan for Excellence discussed during the SALP meeting on May 8, 1989.
The SALP also noted a five-shift rotation. During the summer of 1988 GPU Nuclear institut -l a " pipeline" in which a continuous supply of control room operators are in training. It is anticipated that a six-shift rotation will be established in early 1990.
The concern regarding procedural weaknesses is being addressed. Action was initiated immediately following the isolation condenser vent valving error to correct the method of determining that valves had been returned to their proper position following testing. In addition, GPUN has formed a Procedure Compliance Task Force to work on a wide ranger of procedural problem areas.
l The Oyster Creek site has also independently looked at specific Oyster Creek procedural problem areas. As an initial step, standard guidance is being developed in the form of Writer's Guides to ensure consistency and good human factors practices. Additionally, actions have been or are being initiated to L address procedural problems. For example, Plant Operations now has
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responsibility for plant procedures which affect Operations. Licensed personnel are responsible for performing biennial review of these procedures, l
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Alliconcerns related' to Plant Operations identified in the SALP will be reviewed as part of the ongoing Operations Self-Assessment. GPU Nuclear intends to complete 'this assessment including any needed' revisions to the Plan for Excellence action plans by October 1,1989. The results of this .
assessment will be available for NRC review.
L i In conclusion, NRC's recognition of our improving trend in operations is :!
appreciated. GPU . Nuclear is especially committed to improving performance in
.this area. GPU Nuclear personnel are anxious to demonstrate that performance similar to the record setting 229 day run during the last cycle can be repeated. It is our intention to operate the plant safely, in accordance with
, the regulations, in accordance with sound judgement and good practices, and in accordance with our procedures.
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-OC SALP MAY 15E1989 ,
Functional-Area: Radiological Controls 1 The four: areas of- concern addressed'in the Radiological _ Controls portion of the SALP are.(1) control and planning of radiological operations, (2)
incomplete corrective. action on identified problems, (3)- continued examples of l ineffective root.cause analysis, and.(4) lack of. aggressive action to reduce collective worker exposure. Items 2 and 3 appear to be essentially the same
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from the details of the report'and our response is divided into-sections corresponding to items 1, 2 and 3, and 4.
While we acknowledge the deficiencies and areas needing improvement, and have undertaken actions to respond, we believe performance did not degrade as stated in the SALP Overall Summary, but in. fact improved.
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- CONTROL AND PLANNING 0F RADIOLOGICAL OPERATIONS GPU Nuclear recognizes.that there were instances in which planning and control of radiological work was less than desired. The items cited in the-SALP report were largely self identified through the various internal controls processes within the Radiological Controls program at Oyster Creek.
Each of these occurrences was the sublact of an internal Radiological Investigative Report or a Rad 4.ological Awareness Report and critigt.e to identify and correct root causes. The events did occur however and are examples of _less than adequate planning and control. -
GPU Nuclear has five specific actions underway to improve the planning and execution of radiological work. They are as follows:
o A task force appointed by the Office of the President of GPU Nuclear will perform an assessment of and make recommendations to improve the execution
.of work with regard to radiological control practices of the workforce. We know that the actual conduct of work in radiologically controlled areas is most oft 3n the cause of the types of problems noted in the SALP report.
The-task force charter specifically charges it to specify actions to be taken in the field at the work site, in the planning, supervision, and management of work so as to optimiza adherence to the work practices set forth in the GPU Nuclear Radiation Protection Plan.
-o A continuation of our approach to incorporate radiological and safety reviews in the Long Range Planning process, including:
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Oversight by Techn'. cal Functions Radiological Engineer of modifications and upgrades as they are developed by the engineering staff.
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-Corporate Radiological Engineering participation in the Long Range-Planning process to insure that due. consideration is given to the radiation protection aspects of the work and budgeting process. >
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Senior Management review'of exposure control activities through a Corporate Dose Oversight Group.
o' The Radiological Controls ~ Department has conducted a management self assessment to-identify areas and specific tasks for improving the conduct of work in radiologically controlled areas. The report of this group is now under evaluation. Major areas addressed in the.self assessment include deployment of radiological controls staff during outages, proper
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methods for the conduct of critiques to gain maximum information and benef;L, techniques to improve supervision within GPU system personnel and contractors.
o A Fjeld Radiological Engineer is assigned to enajor work contractors to support outage job planning and execution.
o Depicyment of GPU Nuclear Radiological Controls Technicians has been adjusted to provide more intense oversight on major tasks. This is designed to improve job knowledge, assure consistent approach to control measures, and improve accountability.
INCOMPLETE CORRECTIVE ACTION ON IDENTIFIED PROBLEMS AND INCOMPLETE ROOT CAUSE ANALYSIS.
GPU Nuclear concurs with the SALP assessment that our investigations, critiques, and analyses did not always identify and correct root causes.
Actions were taken in the last quarter of 1988 to use staff members trained in a variety of recognized investigative techniques to conduct and analyze critiques of problem activities so as to identify root causes. Some of'the
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techniques utilized include Kepner Tregoe, MORT, and INP0'c Human Performance Evaluation System (HPES). GPU Nuclear has issued a new procedure for conducting critiques and investigations that formalizes these techniques.
Although efforts in this area require more emphasis, considerable progress has been made in root cause analysis that will be apparent during the next evaluation period.
Two specific actions are underway to improve the root cause analysis and corrective act*ons. They are as follows:
I o Continuation of application of the GPU Nuclear corporate procedure for investigations and critiques.
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OC SALP MAY 15, 1989 I o Events related to radiological protection issues will have critiques performed by an independent assessor. j l
LACK OF AGGRESSIVE ACTION TO REDUCE COLLECTIVE WORKER EXPOSURE Collective dose at Oyster Creek is well above the average for United States Boiling Water Reactors. GPU Nuclear recognizes this and continues to !
take action to reduce collective dose. We will continue to pursue long term l dose reduction promulgated in the Oyster Creek Dose Reduction Plan. A schedule of activities, including specific milestone dater., is being developed for each operating cycle in conjunction with the long range planning and GPU System budgeting efforts. The fact that collective dose in 1988 exceeded the goal is not due to a lack of action to control and minimize dose but rather to the greatly expanded scope of the 12R outage. Within the original and expanded scope of the activities in the SALP period, many dose reduction actions were taken.
The issue of recirculation loop decontamination as a primary means for dose reduction at Oyster Creek is well understood by GPU Nuclear, GPU Nuclear remains committed to performing system decontamination for dose reduction purposes based on factors such as anticipated savings of dose, cost, impact on materials, and life of plant systems. A chemical decontamination of part or most of the clean up system and reactor recirculation loops will be performed prior to or during the 14R outage and may be performed as early as the 13R outare.
It is recognized that the collective dose at Oyster Creek continues to be a sigr.ificant challenge. Realistic expectations are that we will continue to invest more effert in plant maintenance and modification to maintain industry standards than with more recently completed plants. Thus, even with aggressive efforts at dose reduction, it is expected that collective dose at Oyster Creek will probably continue to exceed the industry average but can be significantly reduced from past experience.
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ACTION ON NRC SALP RECOMMENDATION The SALP recommendation in the Radiation Protection section was that GPU Nuclear perform a self-assessment of a third party review of the Radiation Protection Program to assure that problems are fully identified and corrective action plan is developed. Oyster Creek will receive a regular INPO Evaluation from June 5-16, 1989. Furthermore, we expect INPO to provide us with special assistance in improving our radiological protection program in the third quarter of 1989. We plan to assess the results of the INPO Evaluation and Assistance team, the special INPO assistance team, and GPU Nuclear's task force discussed earlier. It is our intention to have the Task Force report reviewed by an outside independent third party to ensure that findings and corrective actions are adequately addressed. This action h e verted to occur before the end of the third quarter of 1989. GPU Nuclear will keep the NRC apprised of the results of the assessments so that progress can be tracked in our program for improving radiation protection at Oyster Creek.
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'OCLSALP MAY:15,.1989
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] Functional Area: Maintenance / Surveillance U
LThe two' areas we would like to . address'in the Maintenance portion. of. this
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functional. area are: 1) rework / recurring maintenance and 2) GMS2:
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Implementation. . In. addition, general comments regarding our maintenance program are: also provided.
REWORK / RECURRING MAINTENANCE T The Oyster Creek' Work. Management System guideline A000-WMS-7100.01,
" Control of Rework and Recurring Maintenance" is the programmatic document used for the. identification, root _cause analysis, implementation of corrective actions,.and reporting of' rework items. Rework is defined as reperformance of work'to correct previously assigned work scope which was incorrectly or inadequately performed;by MCF craft personnel. Recurring Maintenance is the-result of circumstances other than inadequately. performed repair or installation and is usually the result of inadequate design, aged equipment, wrong; application, improper operations, etc. The primary objective of the program-is :to. minimize the occurrence of rework and recurring maintenance by identification and analysis of cause and specifying corrective action.
. MCF has been using the 7100.01 guideline as well' as direct and indirect methods to identify and address these concerns. Craft and supervisory personnel who identify' rework account for direct identification of rework. In addition, indirect monitoring methods are used by analyzing MNCRs, COTS (Corrected-On-The-Spot), critiques, QDRs, and new job order inventory to
,dentify where rework may have occurred. To capture the rework items, MCF now (since May 1, 1989) has designated rework' coordinators in the construction and maintenance areas. This is a collateral responsibility. Coordinators review each identified rework item with the appropriate MCF Construction and Maintenance personnel to determine whether rework actually occurred and how many manhours were involved. This information will be consolidated monthly and used to produce graphs showing the number of monthly events as well as monthly and year-to-date percentage of rework based on craft manhours worked. These Rework Reports will be sent to Plans and Programs for ir.clusion in the monthly Plant Performance Monitoring Report.
This process is expected to improve as the database becomes more reliable and personnel are trained to identify and report rework items. To enhance collection of data, rework and recurring maintenance job orders are now identified in specific data fields of the Work Management System. Upper management will monitor and assess this data to determine if corrective action is needed in areas such as training, increased supervision, etc.
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e OC SALP MAY 15, 1989 Determination of excessive recurring maintenance is normally based on review of maintenance history for specific equipment or systems and placed on the Plant Materiel Condition Issue (MCI) list for evaluation and establishment of action items. Plant Engineering will address recurring maintenance items via Plant Engineering Work Requests (PEWRs) issued from MCF. Plant Materiel will address recurring maintenance items via implementation of procedure 118.1. These recurring maintenance items will be tracked by Plant Materiel and reviewed by all divisions on the Quarterly Failure Tending Report.
GMS2 IMPLEMENTATION The work control system has undergenc many changes to meet our business needs. Many t,f these enhancements are listed in Reference 1.
In general, these enhancements have made Work Management Procedures reflect the us,e of our automated Work Control System (GMS2). GMS2 users have been trainsd by individual and group sessions conducted by the GMS2 Coordinator.
Work Management Procedures now reflect the system capabilities and skills of our personnel. User support has also been enhanced by the recent issuance of a GMS2 Users Manual. (Specifically, WMS procedures A000-ADM-1220.08, "MCF Job Order" and A000-ADM-1220.01, " Work Request" have been revised to reflect the use of the electronic work request and to identify additional GMS2 requirements and user interfaces.) Procedure A000-ADM-1220.08 will be further revised to incorporate the requirements of Procedure A000-ADM-1220.13, "Short Form" when it is deleted. The resulting WMS will then use the Work Request to initiate work and the Job Order as the work controlling document for MCF work. This l situation was self-identified by GPU Nuclear (QDR 88-039 was written to address i this concern, and MCF has completed the QDR requirements as of May 19, 1989).
GENERAL COMMENTS To properly assess the results GPU nuclear has achieved in the area of maintenance, a more encompassing time frame than the SALP period addresses must be considered. GPU Nuclear's letter to Mr. Lando W. Zech, Jr., Chairman of the Nuclear Regulatory Commission, provided information on the maintenance program improvements undertaken and planned at Oyster Creek. The detailed information '
contained in that letter and recent performance indicators show continuing improvements are being made in the following areas:
o Organization Changes in organization have emphasized capability and accountability.
l o Staffing Experience, training and qualifications have been upgraded for craft personnel. Technical capability has been strengthened through the addition of multi-disciplinary personnel.
o Accuracy of Technical Information A concentrated effort to upgrade drawings and procedures has taken l place.
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L OC SALP i l MAY 15, 1989:
o Work Control Communications, responsiveness, efficiency and quality have improved.
o -Materiel Condition The work backlog reductions coupled with increased effort on preventative maintenance have improved the overall plant materiel
, condition of Oyster Creek.
Maintenance programs have and will continue to be developed with full consideration of safe, reliable _ operation. Our progress and future plans reflect GPU Nuclear's commitment to effective maintenance.
ACTION ON NRC SALP RECOMMENDATION The SALP recommendation in the MCFfSurveillance section was to provide the-NRC wiJh a schedule for implementation of re'.! ability centered maintenance control.
Application of the Reliability Centered Maintenance (RCM) methodology to the development of Life of System Maintenance Plans (LOSMP) for plant systems-and components.is in the initial stages. Based on system functions and determination of potential failure mechanisms which impact those functions, RCM produces a list of actions to assure system reliability. These actions will be formalized into the Life of System Mahtenance Plan (LOSMP) for the system.
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' LOSMP will assure that proper implementing documents are in place to execute-the actions prescribed by RCM. Completion of at least one system RCM and hnplementation of its LOSMP is intended for 1989. Future work in this area and level of effort for future years will be formulated after evaluation of the 1989 efforts however, we currently anticipate that 4 systems per year will be compieted.-
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'OC SALP MAY 15, 1989
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Fynctional Area: Emergency Preparedness
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. The.three areas to.be addressed in the Emergency Preparedness portion of this response are: 1) Consistent number of. weaknesses are apparent 1y'due to a Llack of effectiveness of Emergency Preparedness training;-2). Concern regarding the default iodine component has not been adequately addressed; and 3) Training-of TSC engineers in accident analysis other than core damage assessment should-
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EXERCISE WEAKNESSES-The report notes that the 1988 exercise performance.was adequate with approximately the same number of weaknesses. identified from exercise to exerci'se.. While'GPU Nuclear acknowledges the weaknesses,:it is our conclusion
_ that the' 1988 Annual Exercise represented a significant improvement over the 1987 exercise, and considered the NRC identified weaknesses in 1988 to be of generally lesser cor' . ce than in 1987. Action was taken to address the weaknesses and, we L M eva, the 1989 Exercise which identified no weaknesses shows they were effective.
DOSE ASSESSMENT Since the SALP, refinements have been made to the dose assessment process including revisions to the default iodine component. It is our understanding from NRC Inspection Report 88-30 that this item has been adequately resolved and closed out.
TRAINING OF TSC ENGINEERS
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.The Emergency Preparedness portion of the SALP report states that training of TSC engineers does not include severe accident analysis. TSC management
'i ncludes one or more licensed operators who perform the role of accident analysis.. Inspection findings'do.not cite a lack of accident analysis capability. NRC Inspection Report 89-03 conducted from January 17-20, 1989,
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determined EP training, including training for TSC engineers, to be I
acceptable. The inspection report further credits GPU Nuclear for providing j training to TSC engineers in the areas of core darrage assessment and core damage mitt f@lon. GPU Nuclear believes this level of training in addition to other EP tM ining and periodic participation in drills is sufficient.
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Functional Area: Security As noted at the SALP meeting on May 8, 1989, responses were made to the i Oyster Creek RER Report in October 1988 and February 1989 and we had requested reconsideration of two security violations reported in Inspection Report No.
50-219/B8-33. We are in receipt of your letter dated May 15, 1989, and note that the violation concerning failure to properly report a security event has been rescinded.
In response to weaknesses noted in the Dyster Creek Security Program, the following actions have been or will be taken, in addition to any specific corrective actions noted in any previously submitted reports:
o, The number of tours by the shift commanders was doubled from one to two per shift. The shift commanders were instructed to be particularly alert for unusual situations relating to outage work.
They were also instructed to interact with the Security patrols and fixed posts to assure alertness and attentiveness.
o Security coverage in critical areas was increased.
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Special Intake Dilution Patrol was added.
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Two to four Security officers were added to Drywell manning levels, depending on Drywell work activity.
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A closed-circuit television camera was used on the refueling floor to monitor the reactor cavity area. This helped assure no unauthorized drywell access from the Refueling floor, while minimizing radiation exposure.
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The Security Manager met with the Operations Department to reiterate the importance of the Operations / Security interface.
This information was conveyed to all Operations shift personnel.
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Security has taken the initiative to be in regular attendance at the " Plan of the Day" meetings.
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Based on the shortage of available cont,*act guards to support the added outage workload, the plans for the next outage call for using temporary GPU Nuclear personnel, rather than contractor l
personnel. In this way, more control can be exercised in
! obtaining quality personnei to supplement the Security force.
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MAY 15. 1989
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Work. Request Forms require notification of. Security when work is .
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The guidance associated with this form'has been made'more
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The following activities,= while not done directly in response to the issues '
noted above, have been taken to improve the overall. effectiveness of the Security program.
o Extra initiatives.were taken in the Fitness for Duty area:
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All new outage contractors were drug screened prior to obtaining unescorted access.
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. An extra outside patrol-- was added to'look for contraband material. or'-
consumption of. alcoholic beverages in the parking areas.
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A'11. security personnel were alerted to be observant for persons entering the Protected Area'. unfit for. duty.
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.The last annual Site Emergency Drill utilized a. Security Event as the drill scenario. This not only. tested normal emergency response capabilities, but also challenged the Security force response and the Operations / Security interfaces.
.o GPU Nuclear, at its own' initiative,' implemented the NUMARC Access Authorization program for personnel screening prior to granting unescorted access. A new person seeking unescorted access must:
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have a successful psychological test
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have a successful 5-year comprehensive background check
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be fingerprinted
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be covered.by a behavioral observation program Prior to this change to the program, only a letter stating three years of good work bistory was required for contractor personnel.
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GPO Nuclear, through its efforts, identified an industry-wide problem with the administration of INPI Examinations. GPU Nuclear took prompt corrective actions and notified the NRC and others in the ruclear industry, o
A significant new effort was undertaken to do joint tactical training on a continuing basis with the Ocean County Sheriff's Tactical Armed Response (STAR) team.
While we acknowledge the deficiencies and areas needing improvement, and have undertaken actions to respond, we believe performance did not deptade as stated in the SALP Overal? Summary, but in fact improved.
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Functional Area: Engineering / Technical Support The action plan as a follow on to the Technical Support Self-Assessment -
'(TSSA) commenced in 1988 with several of the items completed prior to the end-f-
of the SALP period. The activities completed, underway, or i.' the developmental stage'should constructively contribute to enhancement of engineering' support.
The.four areas'we would like to address in the Engineering /Techcical Support portion of the SALP are: 1) development of the Design Basis Documents;'
2) conduct of Safety System Functional Inspection (SSFIs);_3) further upgrade the drawings frequently.used; and 4) development of an improved working interface between site and~ corporate personnel.
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DESIGN BASES DOCUMENTS-The initial pilot program to develop'two design basis documents (DBD) for Oyster Creek is underway. The products of the first two systems are expected in the third quarter of 1989. The success of this effort will mold the future plans which-presently envision four additional system DBDs per year for several years. This effort is being lead by the systems engineer responsible for each chosen system. Working with counterparts at the site and other members of the staff, improved documentation and understanding of the system will result, as well as an improved working relationship between the assigned corporate and site-based systems engineers.
SAFETY SYSTEM FUNCTIONAL INSPECTION A program to conduct two SSFIs is underway with the results expected in the third and fourth quarters. One of these SSFIs will be on the same system as a DBD which should assist us in evaluating that product. Current plans are to conduct four additional SSFIs in the next two years.
DRAWING UPGRADES The_ Oyster Creek Drawing Consolidation Project is converting approximately 750 drawings into computer-aided design products. This will have the dual benefit of significantly improving the legibility of the drawings and the usability of the drawings. The drawings selected include all of the plant P& ids, electrical one-lines, and a very large number of the most frequently used electrical elementary drawings. This project was awarded in April 1989 and is scheduled for completion by the end of 1990. A second project to improve the legibility of approximately 800 additional drawings by conventional ;
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means is also underway. This program .is scheduled for completion by the end-of 1989. These two projects are the latest phases of a program which began'in 1981.to walk down systems and assemble, update, upgrade and control-drawings at l
' Oyster Creek. Since its inception,.approximately ten thousand. revisions to-drawings have been issued under this program.
WORKING INTERFACE- d There have been a number of management and staff initiatives to improve the-interface'between site and corporate personnel. Engineering interface' meetings are being held approximately twice each month to review and improve the .I coordination of ongoing ~ engineering, activities. Additionally, on each new significant modification project,. kickoff meetings'are now being held to assure that the_ appropriate' interaction.and awareness exists between site and corporate personnel responsible for the modification. Finally, senior management interface meetings.have been initiated'to review longer-term profects of importance to the engineering support staffs. TheLinitial meeting was held in July 1988, with the next meeting deferred until after the 12R outage. The next meeting will be conducted by September, 1989 and thereafter held on a semi-annual basis. We believe these diverse efforts will play a significant role in improving the interface between site and corporate personnel.
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E LOC SALP-MAY 15, 1989 j Functional Area: Safety Assessment /Ouality Verification l
The two major areas we would like to address.in the Quality. Verification portion'of this functional area are effectiveness of the Quality Assurance (QA)
- Program and corrective action follow-up.
These issues are closely related and both generally point out weaknesses in identifying the extent of. the problem sufficiently and implementing ef fective corrective actions.
As a result of the SALP comments and GPU Nuclear identified needs, the following actions are being planned:
). GPU Nuclear will identify and implement "QA Verification Technique" training for appropriate personnel by December 31, 1989.
2. The corrective action program for handling QA identified deficiencies will be evaluated and any appropriate changes will be completed by -
September 1, 1989.
In addition, GPU Nuclear had previously identified that responsiveness to QA deficiencies was a problem. Accordingly, the Oyster Creek Plan for Excellence contains action plans to improve responsiveness. These plans contain, as a central theme, greater use of the Director's weekly 0A meeting as-a vehicle to identify responsiveness problems and achieve resolution. For example, deficiencies open longer than 60 days are now being. reviewed monthly at the meeting. In addition, quality deficiencies are tracked in the Station 3 Action Item Tracking System to improve management visibility of overdue items.
ACTION ON NRC SALP REC 0tHENDATION The SALP recommendation in the Safety Assessment, Quality Verification section.was to review the current and previously closed Preliminary Safety i Concerns to verify that no outstanding safety issues remain unresolved.
This review was completed and the results documented to the NRC by letter dated March 21, 1989. In addition the Potential Safety Concern procedure has recently been significantly revised. Major enhancements include:
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Provides definitive criteria for what constitutes a safety concern.
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Emphasizes the resolution of a safety concern rather than just the deportability aspect.
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- Assigns, responsibility for disposition of a safety concern to the cognizant technical department.
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Establishes reouired time frames for the determination'of deportability 3nd or the existance of.a' safety. concern.
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.T.equires that upper management ' approve- the' final' determinations.
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