ML20202F636

SALP Insp Rept 50-289/85-97 for 850916-860430

ML20202F636
Person / Time
Site:	Three Mile Island
Issue date:	04/30/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20202F621	List: ML20202F614 ML20202F636
References
50-289-85-97, NUDOCS 8607150206
Download: ML20202F636 (55)

See also: IR 05000289/1985097

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-289/85-97

GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION

THREE MILE ISLAND NUCLEAR GENERATING STATION

ASSESSMENT PERIOD: SEPTEMBER 16, 1985 - APRIL 30, 1986

BOARD MEETING DATE: June 6, 1986

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TABLE OF CONTENTS

Page

I. INTRODUCTION

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

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

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

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

III. SUMMARY OF RESULTS

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

B. Overview. . . .. .... . .. .... 7

IV. PERFORMANCE ANALYSIS

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

B. Radiological Controls . .. .. .. . . . . 12

C. Maintenance . . .... . .. ........ 15

D. Surveillance. . . . .. ..... .. 18

E. Startup Testing .. .... . . .. . 20

F. Emergency Preparedness. . ........ . . . 21

G. Security and Safeguards . . ..........23

H. Technical Support . .......... ....25

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I. Training and Qualification Effectiveness. . .. . 28

J. Assurance of Quality. ..............31

K. Licensing . . . . . . . . ............33

V. SUPPORTING DATA AND SUMMARIES

A. Investigations and Allegations Review . . . . . . 35

Escalated Enforcement Actions

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C. Management Conferences. ... . .... . . . 35

D. Licensee Event Reports. . . . . . . . . . . . . . 35

E. Reactor Trips / Forced Outages. . . . . . . .. . 36

TABLES

Table 1 - Inspection Report Activities . . . . . . . . . . . . . T1-1

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

Table 3 - Enforcement Summary. ......... ........ T3-1 4

Table 4 - Enforcement Data . ... ....... ........ T4-1

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Table 5 - Licensee Event Reports . . . . . . . . . . . . .. T5-1

Table 6 - Unplanned Reactor Trips and Forced Outages . . . . . . T6-1

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

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

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! I. INTRODUCTION

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! A. Purpose and Overview

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The Systematic Assessment of Licensee Performance (SALP) is an

integrated NRC staff effort to collect available observations and

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

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process is supplemental to the normal inspection processes used to

ensure compliance with 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 in order to improve the quality and safety of plant

operations and modifications.

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

mance at TMI-1 Nuclear Generating Station for the period September

16, 1985, through April 30, 1986. The summary findings and conclu-

j sions reflect a 7 -month period.

This SALP is termed SALP I since it is the first of two SALPs

directed by the Commission in its restart order. It includes the

period (September 16, 1985, to January 10, 1986) covered by the

l interim SALP (NRC Inspection Report No. 50-289/85-98), which is

attached for completeness. The purposes of the interim SALP were:

(1) to assist in the preparation for the Performance Appraisal Team

(PAT) I, (2) to verify performance during the transition from a

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long-term shutdown condition to commercial power operation, and (3)

to determine the allocation of NRC resources for future inspections.

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However, for those functional areas addressed in the interim SALP,

the details of the performance analysis from the interim SALP period

will not be repeated unless they also apply to licensee performance

during the period January 10, 1986 to April 30, 1986.

The previous SALP period covered the period from February 1984 to

January 1985. The licensee's performance from February 1985 to

September 15, 1985, in 10 of the 11 functional areas were not con-

sidered since the plant was not operating during that period and,

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therefore, the results would not be as meaningful. In the licensing

functional area, performance from February 1, 1985 to September 15,

i 1985, was included in the period for the SALP I report. An NRC SALP

l Board, comprised of the staff members listed in Section B, met on

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June 6, 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

I Licensee Performance." A summary of the guidance and evaluation

criteria is provided in Section II of this report.

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B. SALP Board Members

Chairman

R. Starostecki, Director, Division of Reactor Projects, RI

Members

R. Bellamy, Chief, Radiation Protection Branch, Division of Radiation

Safety and Safeguards (DRSS), RI (Part Time)

R. Blough, Chief, Reactor Projects Section No. lA, Division of Reactor

Projects (DRP), RI

R. Conte, Senior Resident Inspector (TMI-1), DRP, RI

S. Ebneter, Director, Division of Reactor Safety (DRS), RI

W. Kane, Deputy Director, DRP, RI

H. Kister, Chief, Projects Branch No. 1, DRP, RI

J. Stolz, Director, Project Directorate No. 6 (PD No. 6), NRR (Part Time)

J. Thoma, Operating Reactors Project Manager (TMI-1), PD No. 6, NRR

Other Attendees

J. Callan, Chief, Performance Appraisal Section, Office of Inspection

and Enforcement

J. Durr, Chief, Engineering Branch, DRS, RI

R. Weller, Section Leader, Project Directorate No. 6, NRR

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

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C. Background +

1. Licensee Activities '

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Section I.C.1 of the interim SALP summarizes licensee activities for

the period of September 16, 1985, to January 10, 1986. Below is a

l summary for the period of January 10, 1986, to April 30, 1986.

! The licensee operated the facility at full power during this period,

i except for approximately five weeks. Throughout the period and

j during the power operation periods, routine operations, surveillance,

) and maintenance (including preventive maintenance) were conducted.

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At the beginning of the period, the licensee completed certain startup

l tests for the 100 percent power plateau. These tests were scheduled

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for completion during the startup test program in December, 1985, but

j could not be completed at that time due to a power limitation of about

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Between January 27 and February 3, 1986, the licensee placed the

plant in cold shutdown in order to repair leaking pipe expansion

< bellows on the eighth stage extraction stean lines inside the main

l condenser.

. From the return to power operation on February 3,1986 to March 21,

j 1986, the licensee operated TMI-I at full power, except for the

i reactor trip of March 15, 1986. This reactor trip resulted from a

turbine trip, which was caused by a low main turbine lubricating oil

, , pressure that occurred during the transfer of inservice coolers for

j the main lube oil system.

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i Between March 21 and April 20, 1986, the reactor was shut down with

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~ the reactor vessel drained down to support eddy current testing (ECT)

of a sample of the steam generator tubes. Initial bubble and drip

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tests showed no visible indication of leaking tubes. Based on

subsequent ECT results, twenty-five tubes were plugged before

startup.

Two significant events occurred during the initial stage of the ECT

l outage. There was a noble gas release during reactor coolant system

l (RCS) degasification on March 22, 1986, which resulted in the declara-

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tion of an Unusual Event. Also, there was a buildup of radioactive

iodine in the Reactor Building on March 24, 1986, with the RCS vented

i to the Reactor Building atmosphere.

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l 2. Inspection Activities

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-Section I.C.2 of the interim SALP summarizes NRC inspection activi-

j ties for the period September 16, 1985, to January 10, 1986. Below

j is a summary for the period of January 10, 1986 to /pril 30, 1986.

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On March 31, 1986, Region I assigned two additional resident inspec-

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tors to the facility, bringing the resident staff to one senior

resident inspector and three resident inspectors.

As directed by the Commission, a Performance Appraisal Team (PAT)

inspection was conducted to provide additional insights into licensee

performance. This inspection covered the following functional areas:

plant operations; maintenance; surveillance; technical support;

training; and assurance of quality.

In distinction to the previous SALP periods (prior to restart), this

SALP does not evaluate fire protection and housekeeping as a separate

functional area. These aspects of facility operation are covered in

several appropriate functional areas. In the future, fire protection

will be evaluated as a separate functional area only when extensive

new information is generated on performance, such as when an Appendix

R team inspection has occurred.

In reference to Table 2, the total inspection hours for the 7h-month

period was 6,461 or approximately 10,338 hours0.00391 days <br />0.0939 hours <br />5.588624e-4 weeks <br />1.28609e-4 months <br /> on an annual basis.

Of that total, 61 percent occurred during the period covered by the

interim SALP and 12 percent occurred during the PAT inspection.

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II. CRITERIA

Licensee performance was assessed in selected functional areas significant

to nuclear safety and the environment. Assessment areas were selected

based on facility status of startup testing followed by normal operations.

Consequently, SALP I includes typical SALP functional areas for an operat-

ing plant. For the interim SALP a special category of startup testing was

included.

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

functional area.

1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

3. Responsiveness to NRC initiatives

4. Enforcement history

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5. Report and analysis of reportable events

6. Staffing (including management)

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7. Training effectiveness and qualification

This report also discusses " Training and Qualification Effectiveness"

and " Assurance of Quality" as separate functional arcas. Although these

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

their use as evaluation criteria, a synopsis of these two area is provided.

For example, quality assurance effectiveness has been assessed on a day- '

to-day basis by resident inspectors and as an integral aspect of specialist j

inspections. Although quality work is the responsibility of every employee, j

one of the management tools to measure this effectiveness is reliance on

quality assurance inspections and audits. Other major factors that in-

fluence quality, such as involvement of first-line supervision, safety

committees, and worker attitudes, are discussed in each area.

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

classified into one of three categories. The definitions of these perfor- i

mance categories are: 1

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

i 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.

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

Licensee management attention and involvement are evident and are con-

cerned with nuclear safety; licensee resources are adequate and reasonably

effective so that satisfactory performance with respect to operational

safety or construction is being achieved.

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

Licensee management attention or involvement is acceptable and considers

nuclear safety, but weaknesses are evident; licensee resources appear to

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be strained or not effectively used so that minimally satisfactory perfor-

mance with respect to operational safety or construction is being

achieved.

Normally, the SALP Board assesses each functional area to compare the

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

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

the recent trend for each functional area. Because of the short period

covered by this SALP, the SALP board evaluated performance for discernible

trends in the last one-to-two months of the SALP period. The SALP trend

categories are as follows.

Improving: Licensee performance has generally improved over the last

part of the SALP assessment period.

Consistent: Licensee performance has remained essentially constant over

the last part of the SALP assessment period.

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Declining: Licensee performance has generally declined over the last

part of the SALP assessment period.

Notwithstanding the allowance permitted by a Category 1 rating to reduce

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

because of (1) plant restart following a shutdown of over six years, and

(2) extraordinary sensitivity to TMI-1 among various government agencies I

and the public. Due to the nature and scope of activities at TMI-1, it is

NRC policy that close scrutiny be provided for the first two years of

operation from restart similar to that provided for a plant receiving its

initial full power license. Subsequent SALP evaluations (beyond SALP II)

are currently planned for a 12 month frequency.

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III. SUMMARY OF RESULTS

A. Facility Performance

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SALP SALP I Trend

Functional Area (9/16/85-1/10/86) (9/16/S5-4/30/86) (Last 1-2 Mos.)

1. Plant Operations 2 2 Consistent

i 2. Radiological Controls 1 1 Declining

i 3. Maintenance 2 2 Consistent

4. Surveillance Testing 1 1 Consistent

5. Startup Testing 1 1 NA

6. Emergency Preparedness Note 1 1 Consistent

7. Security and Safeguards Note 1 2 Consistent

8. Technical Support Note 1 3 Consistent

9. Training and Qualifi- 1 1' Consistent

cation Effectiveness

10. Assurance of Quality 1 2 Consistent

11. Licensing Note 1 1 Consistent

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Note 1: This functional area was not assessed as a specific area in the

interim SALP.

B. Overview

j Overall, the licensee continued to operate TMI-1 in a competent and

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safe manner. Clear and well defined programs are in place which

a provide the necessary direction and guidance for assuring that the

j various functions are integrated and controlled. Licensed operator

i performance continued at a high level. Some problems were

identified with non-licensed staff training. Although control room

operators performed well, a number of events and violations were

attributable to persnnnel error. In some cases this was aggravated

by procedural deficiencies. The concern in the interim SALP regarding

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an apparent general disregard of workers for equipment protection in

the operating spaces was not observed during this period indicating

that the licensee's corrective actions have been effective. Plant

equipment remained in good material condition evidencing a generally

strong and aggressive prever.tive and corrective maintenance program.

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Six unplanned reactor trips and shutdowns occurred during this

period, five of which were attributed to secondary plant problems.

Unnecessary challenges to safety systems and operators continues to

be a concern. More attention to preventive maintenance and in some

instances secondary plant design could result in fewer failures of

susceptible balance of plant features that result in challenges to

the reactor protection system.

Although technical support for startup activities was good, increased

attention to the overall technical support area is warranted. As

previously mentioned, programs are strong but implementation is lack-

ing. A number of examples of improperly prepared / installed modifi-

cations reflected the lack of a thorough design review both at the

peer / supervisor level and at the regulatory-mandated technical review

level. This was further supported by problems observed by licensee-

ir.itiated review groups subsequent to the normal review process.

A recurring theme in a few areas is the stati's observation that

some activities are performed in a hurried manner to meet schedules

and that this sometimes results in problems. For example, some

unplanned exposures and radiological releases are attributed to the

higher pace of activities. In this regard the SALP Board attributes

this partially to a conflict between upper management's expressed

goals for achieving a high level of performance and middle

management's emphasis on meeting schedules. We believe that this

conflict has not yet been effectively dealt with and is responsible

for many of the problems discussed in this SALP. Similarly, the

degree of supervisory oversight in the review of routine procedures

and their implementation was found to be lacking.

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IV. PERFORMANCE ANALYSIS

A. Plant Operations (3528 hours0.0408 days <br />0.98 hours <br />0.00583 weeks <br />0.00134 months <br />, 54%)

The interim SALP period rated the licensee's performance as

Category 2. The NRC found the licensee displayed excellent overall

control of the plant; management established their presence and

involvement during all shifts; and, management exhibited conservatism

in resolving technical issues in an adequate, but not aggressive,

manner. Implementation of procedures for significant evolutions was

adequate. For the most part, procedures were technically sound but,

individual procedure step inadequacies challenged personnel in

strictly adhering to those procedures for routine activities.

Licensed operator performance continued to be oriented toward

nuclear safety. Operators conducted themselves in a professional

manner. Shift turnovers and pre-briefings for major evolutions were

thorough and detailed. Depth of knowledge of plant anomalies,

current plant conditions, and on going evolutions by operating crews )

was excellent. This is partially attributed to licensee training of

operators. In general, the licensed operators' positive attitude

toward operating the plant in a safe manner is one of the major

i factors in contributing to good performance of the plant.

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l Licensee personnel maintain the control room and conduct related to

business in a manner to avoid disruptive activities and to present a

posture of overall control of operations. Operations staff is

segregated from other personnel by an entrance barrier made up by a

panel, bookcases, and an entrance gate. Routine business and requests,

including pre-shift briefings, are conducted across that bookcase

section to avoid unnecessary personnel in the control room proper

area. No radios, televisions, and unrelated reading material are

permitted; and, for the most part notebooks, procedures, and manaals

are properly stored. A dress code continues to be implemented. Main

control board overhead annunicators that are normally lighted are

relatively few and the licensee has administrative controls to track

alarms that periodically change status or come on and stay lighted

beyond one shift. With additional effort by licensee technical sup-

port personnel, a condition where no anunciators are routinely lit is

achievable. Overall, a professional atmosphere is maintained in the

control room.

Despite upper management directives to adhere to procedures, a proce-

dure adherence problem persists and it is related to attention to

detail in complying with procedures. Moreover, it also appears to

be precipitated by middle management attempting to maintain schedules i

of activities and their ineffectiveness in communicating the expressed

upper management intention in this area. In several instances during

the startup frnm the ECT outage, inattention to detail and communi-

cation problems along with the fast pace of activities led to

improper procedure implementation. Examples include: no

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shift SR0 in control room for 1/4 hour with the plant above 200 F;

improper deboration valve alignment; and failure to properly respond

to a waste gas first alarm (alert) during a routine gas release. In

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other minor cases: completed procedures requiring steps to be signed

off or initialed as being completed were not done; out-of-specifica-

tion log readings continued for long periods of time; and some opera-

ting crews performed only minimum documentation of plant evolutions,

plant anomalies, or surveillance / maintenance activities in their logs

(representing minimal compliance with related administrative controls

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on logs and record-keeping).

From a control viewpoint, the two management directives to meet

schedules and adhere to procedures can coexist. Overall, control of

special evolutions and testing has been quite good; but, in several

operational instances, as noted above, dealing with routine activi-

ties, licensee personnel (from management down to the worker) have

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not properly implemented procedures. This demonstrates that the

conflict between the expressed procedure adherence policy and the

, desire to meet established schedules has not yet been effectively

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resolved. I

i Technical adequacy of station procedures was sufficient; however,

some weaknesses continued to be noted. For example, a reactor trip

was partially attributed to weak procedures associated with the main

turbine lube oil system. Lifting of a relief valve during a plant

degasification evolution demonstrated the need for a clearer proce-

dure. The QA monitoring of plant operations on all shifts aided the

! licensee in identifying these plant operational problems.

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An assessment of the licensee's safety and technical reviews organi-

ration found the system was operating in accordance with the mecha-

nism stated in the technical specifications. Each department thus

achieves this requirement independently in diverse ways using differ-

ent procedures and initiatives. Because of this independence, many

overview / analysis reports on the procedure review process are diverse

and for the most part, they are not diagnostic with respect to the

nature of problems in the program. As a result cognizant vice pres- )

idents are missing the opportunity to assess problem areas and take l

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appropriate corrective action. An exception to this is in the Nuclear

Assurance Department, where reports do lean toward evaluative summaries

for these reports.

The plant is generally kept clean and free of transient combustibles.

, Daily involvement by management has been aggressive with respect to ,

i fire prevention and housekeeping as evidenced by their frequent i

i tours, including a daily backshift tour. However, a poor practice '

permitted fire service water to be routinely used as a source of l

back-flushing water for other systems and equipment on a continuing j

basis which had the potential for degrading the fire service water j

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system. Further, with respect to fire protection training and prac-

tices, the licensee program meets the minimum requirements but, in

some instances, it lacks thoroughness in implementation to assure

meaningful training. The quality of training during fire drills was

noted to be limited due to the large number of participants which

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resulted in a lack of realism in the training.

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Licensee Event Reports (LERs) from TMI-1 are generally reported with-

in the required time period following the occurrence. Reporting is

accurate and appropriate corrective action generally is planned or

taken.

The four unplanned reactor trips from power operation, which occurred

in the 7-month report period, equates to a rate of approximately

seven trips per year. Several reactor trips were the result of turbine

or generator problems with the protection systems responding as expected.

Additional management attention is warranted in reducing secondary

plant upsets during startup and routine operations.

Overall, the licensee's programs are strong in the area of adminis-

trative controls and licensed operator performance. For the most

part, procedures were technically adequate but individual procedure

step inadequacies persist. The licensee continued to experience

i difficulty in providing the proper balance between schedular consid-

erations and the expressed policy on procedure adherence. This was

particularly evident when middle managers inserted themselves directly

and accelerated the pace of work activities. Licensee management

needs to review their rou:ine conduct of operations to see if competing

factors are precluding the achievement of the goal to adhere to

procedures.

i Conclusion

Category 2, Consistent

Recommendations

Licensee: See text and summary of Section IV.J Management

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B. Radiological Controls (389 hours0.0045 days <br />0.108 hours <br />6.431878e-4 weeks <br />1.480145e-4 months <br />, 6%)

Analysis

During the interim SALP period, the licensee's performance in this

area was Category 1. Program elements were noted to be sound and

thorough. Minor problems were identified in the area of radiological

work planning where better planning could have prevented releases of

radioactivity and personnel contamination. problems of this type

continue and are discussed in this section.

The licensee's radiation protection organization contains sufficient

ir-hnical expertise and an appropriate level of staffing to adequate-

ly impirment the program. Thorough and well-defined radiation worker

and radiolo9 cal controls technician training programs are in place

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and are effect;vely implemented by the licensee. An additional

cyclic training program is provided for radiation protection techni-

cians and would appear to establish a method for communicating recent

procedural modifications to the technicians. However, lapses in

communication of recent procedural changes do occur. For example, a

change in licensee policy regarding dosimeter placement inside

anti-contamination clothing when face shields were worn was observed

to be neither clearly understood nor uniformly implemented in the

field.

Audits by QA 01 the radiation protection program were conducted as

required and appeared to be of adequate technical depth and scope.

Although the ovarall audit plan in this area is formalized and

carried out in accordance with a schedule, no tracking system is in

place to ensure all individual program elements within this area are

periodically reviewed.

Well-defined procedures are established to control radiation protec-

tion program activities. Radiation protection personnel appeared

familiar with and conversant on all procedural requirements.

The licensee typically demonstrates a strong commitment to ALARA and

planning for the radiological aspects of the March 1986 steam genera-

tor outage was initiated in a timely manner. Judicious scheduling of

technician training and qualification boards allowed the licensee to

effectively staff outage operations without reliance on a large

contractor HP technician work force.

The licensee's use of the radiation work permit (RWP) system to

control radiological work activities was generally very effective.

Pre-job surveys were always taken and were of appropriate scope for

evaluating radiological hazards. No violations of RWP requirements )

were noted during this assessment. However, there was an instance '

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when middle management became intimately involved in steam generator

ECT work setup and this resulted in their personal contamination. Poor

communication and weak RWP extremity protection requirements were

contributing factors to these events.

Housekeeping and radiological posting in the work areas reflects a

management commitment to keeping workers well informed as to radio-

logical conditions. Survey information is prominently displayed at

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the HP controi point and at the access to cells and cubicles. The

licensee has been respor.sive in implementing NRC guidance to limit

posting to the appropriate area surrounding the radioactive source,

rather than simply posting large areas at the doorways. The licensee

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has also implemented a system to serialize all posted " hot spets" to

allow tracking and re surveying by the HP staff. However, inatten-

tion to detail on the part of personnel was the root cause of a

violation which was a failure to properly post a radiation area.

Overall, a programmatic problem does not appear to exist in this

area.

The recent steam generator eddy current testing performed during

March and April represented the licensee's first post-critical outage

work in several years. During this outage, c failure to perform timely

surveys for airborne radiciodine during steam generator operations

led to a late identification of reactor building airborne radiciodine.

This resulted in the unplanned uptake of radiciodine by a substantial

number of workers. Communication problems between shifts and staff

preoccupation with a concurrent noble gas problem aggravated the delay

in the licensee's identification of, and response to, the radiciodine.

Licensee corrective action, once the situation was identified, was

appropriate and mitigated further consequences. Additionally, licen-

, see staff contained sufficient technical expertise for performing

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followup whole body counting and dose assessment.

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! Licensee response towards both NRC and licensee-identified deficien-

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cies is timely and thorough. Additionally, the radiological controls

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organization often takes the initiative in identifying engineering or

design deficiencies which may adversely affect radiological condi-

tions. For example, the radiological staff initiated an investiga-

tion of sampling and floor drain flow paths in the auxiliary and fuel

handling buildings which were contributing to a noble gas airborne

problem in those buildings.

One inspection of licensee radioactive waste organization and trans-

portation activities was conducted during this assessment period.

Organizational structure and staffing of the Unit I radwaste group

appeared adequate to support the group's activities. Generally,

training for the radwaste group appeared to be timely and comprehen-

sive with one exception. Specifically, a radwaste supervisor did not

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

,

5

,

-

!

14

receive the biennial retraining as required by licensee commitments.

A review of licensee audits of the radioactive waste management area

indicted that appropriate program elements were audited.

!

The licensee has a well-organized and smoothly-functioning effluent

monitoring and control program. Licensee documentation of effluent

i

'

releases was found to be thorough and complete. Effluent monitors

were calibrated at a frequency more conservative than the technical

specification requirement. An LER received during this assessment

l period transmitted notification of the isolation of the condenser

!

offgas radiation monitor during power operation. This inadvertent

isolation was promptly discovered by the licensee and adequate

t

corrective actions have been taken.

The licensee's organizational structure, with direct reporting to the

Vice President, Radiological and Environmental Controls, provides for

added measures of independence. Quality assurance and audit activi-

ties were conducted as required and licensee response to identified

deficiencies was timely. In general, procedures were technically i

adequate. However, implementation problems did occur. Although

certain pre-job planning efforts and job performance could have been

enhanced by better communications and less direct middle management

involvement, jobs involving significant radiological hazards were

conducted in a safe manner and they were oriented toward ALARA.

Conclusion

Category 1, Declining

Recommendations

None

i

4

i

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

__

.

d

.

15

C. Maintenance (426 hours0.00493 days <br />0.118 hours <br />7.043651e-4 weeks <br />1.62093e-4 months <br />, 7%)

Analysis

The interim SALP rated the licensee's performance as Category 2.

Overall performance of maintenance activities was good and reflected

a safety conscious mode of operation. Problem areas existing during w

this period were a general overall lack of awareness concerning the

fact that the plant was now in an operating mode which requires

'

~ greater sensitivity to adverse work in safety-related areas. Engi- -

neering support / coordination was also a weak area, along with proper -

job planning, incorporating operations and radiological control input

to assist safe accomplishment of maintenance activities,

i Many positive elements of the maintenance program noted in the

interim SALP continued to be exhibited. The same level of knowledge,

staffing, scheduling, and completion of work items was maintained.

Management concern ano participation continued to be evident. The

corrective maintenance trending report developed every three months

was used to identify problem areas on a system and component basis.

Several problems continued to be exhibited ard were specifically

j identified by the PAT inspection. One problem was adequacy of

,

procedures and practices related to the emergency feedwater system.

The procedure for repacking the EFW pumps was generic and not specif-

ic enough to resolve special problems with the particular character-

istics of these punps. This apparently contributed to a failure of a

pump packing gland during post-maintenance testing. There was a lack

l of preventive maintenance on check valves fcr the EFW instrument air

system. Another problem dealt with the adjustment of limit switches

and torque switches on motor-operated valves (MOVs). The specific

switch settings were not always defined or documented, and changes

1'

were not always reviewed for impact on valve operation. An aggressive

effort was exerted during the ECT outage for the motor-operated valve

testing program and it has resolved a majority of problems with switch

settings. The continuation of the program for all safety-related

valves, other than those identified in Bulletin 85-03, is desirable

and is planned for future outages. Overall, maintenance procedures

are adequate, but these exanples point out a continuing need for

-

attention to detail in the procedure review process.

Maintenance conducted during the eddy current outage was an ambitious

effort to work on several existing problems, along with the major

effort of steam generator tube examination. Effective control of

vendor activities was exhibited during the eddy current activities.

The testing was accomplished with " state of the art" equipment and

dpplicable requirements were followed. The EFW flow nozzle thermal

sleeve cracking problem and associated extensive activities that were

3

f

4

I

l

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

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

.

.

16

not initially planned were completed in a safe manner, although formal

evaluation of the nozzle failure method is yet to be resolved. For

these major evolutions, procedures were properly implemented.

The safety-related systems reviewed by NRC dt. ring this assessment

j period continued to evidence the effects of g3od preventive and

corrective maintenance. Of particular interest was the replacement

of the "A" vital battery bank - a modification conducted by the

maintenance department in accordance with the licensee's modification

'

.

control program. The procedures used for this effort reflected

current industry standards for station storage batteries procurement

and installation. Testing confirmed that the battery replacement was

accomplished satisfactorily with no major maintenance problems

evidenced in the testing and checkout process (see Surveillance

section on the adequacy of periodic testing of battery banks).

However, several instances were noted in which minor plant modifica-

tions were conducted using the maintenance mechanism without proper

review and approval in accordance with the modification control program.

In addition to PAT I findings in this area, the most notable incident

was the licensee discovery that the high voltage power supply for a

channel of nuclear source range instrumentation was not connected to

I the detector during deboraticn to criticality. This was directly

l related to a technician switching cable connectors in a containment

I

penetration in accordance with an outdated controlled drawing. The

I

penetration configuration was changed based on previous maintenance

l work which did not use the established modification control program.

Based on previous SALP findings, these improper minor modifications

are repetitive. Enhanced management attention to this area is

warranted.

!

'

Maintenance personnel appear to have shown increased sensitivity

to existing plant conditions when planning and conducting maintenance

i activities. No plant trips or major equipment damage have occurred

! as a direct result of maintenance activities during this assessment .

j period. However, certain se:ondary plant transients / trips could be  !

! related to maintenance practices. A number of instances continued to l

3

indicate poor maintenance planning with respect to radiologically

controlled system work.

Engineering and technical support was evaluated as a problem area in

the interim SALP period. Tne licensee is working on corrective

i actions, but problems continue to occur. It was not apparent that a

j formal evaluation on the EFW nozzle cracking would be conducted.

Also, NRC staff questioning apparently caused organizational review

j of the leakage associated with Decay Heat System check valves. On

the other hand, for significant or visible issues, such as the diesel

blower problem and the steam generator tube plugging, effective actions I

were planned and implemented by the Itcensee.  !

i

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

.

i

< .

.

17

f

Housekeeping activities continued to be a strong point in maintenance

i activities. No problems were identified in routine activities c.-

during the extensive eddy current outage activities. No fire hazards

j were observed during these intensive work activities.

1

Overall, the maintenance program is properly established, imple-

mented, and staffed. However, several instances reflect weak

implementation desoite management involvement. Personnel attitudes

relevant to respect for plant equipment appear to be improving. The

ability to control extensive maintenance activities in short outage

situations and react to changing problem areas was evidenced in this '

pericd. Procedure adequacy and technical support problems continue

to be noted.

Conclusion

Category 2, Consistent

4

Rgcommendations

Licensee: See text and summary of Section IV.J, Management

'

Assurance of Quality.

1

i

.

l

l

1

I:

l

1

1

l

.i

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

.

.

18

.

0. Surveillance Testing (339 hours0.00392 days <br />0.0942 hours <br />5.605159e-4 weeks <br />1.289895e-4 months <br />, 5"I,)

1

Analysis

! The interim SALP rated the licensee's performance as Category 1.

j This was due to a strong surveillance program with quality assurance

1 (QA) involvement, ample staffing, well-kept records, and proper

j procedure adherence. Minor problems that surfaced were few and did

not adversely affect plant safety.

The licensee continued to properly implement their surveillance

I

program throughout the assessment period. The conputerized

scheduling system continues to be used effectively to ensure that ,

7

surveillance tests are accomplished in a timely manner with minimal

effort on plant operations. Surveillance proceduras were followed,

personnel were knowledgeable, and problems were documented. However,

4

I

a missed surveillance on a fire door in the diesel generator building

resulted from a poorly coordinated review / approval of several sur-

1 veillance procedure revisions.

With respect to proper problem identification and documentation, poor

i understanding by personnel of the proper use of exception and defic-

1ency (E&D) forms persisted. The interim SALP identified poor hand-

I

ling of the Power Operated Relief Valve (PORV) E&D's. During this

period, weekly and monthly surveillance for the new "A" battery bank

j were incomplete because personnel thought all fluid levels had to be

at a specific mark (high level indicator) for corrected specific

'

gravity. With the incomplete data, personnel classified the problem

only as an " exception." This precluded operations department review

i of the anomaly. Technical support personnel were slow to respond to

i correct "the deficiency." Subsequently, the results of a review by

l the licensee indicated that level correction was not needed and the

battery bank was operable. However, the problem reiterated another

example of weak technical support and the need for plant wide training

in the use of the new E&D system.

In general, technically-adeauate surveillance procedures were noted

during NRC review of the RB spray system, containment local leak rate >

l tests, station batteries tests, and emergency feedwater system tests,

i However, certain weaknesses were noted. The PAT I identified that

-

emergency feedwater pump discharge check valves were not being tested

for proper seating and ability to prevent back flow because the test

j . lineup isolated the idle pump check valves from pressure when the

l other pumps were being tested.

4

1 During this appraisal period the "A" battery bank was replaced.

i Although periodic surveillance testing requires a capacity test in

I accordance with Technical Specifications, the licensee did not

, propose to conduct future periodic duty testing af ter conducting one '

such test,

i

!

!

.

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

.

i

19

l

i Latest industry standards suggest such testing and in light of the

apparently early end of life for the previously installed battery

bank, such a practice seems appropriate. The licensee is not

specifically required to follow this edition of the standard but

this incident reflects either (1) a lack of awareness / understanding

,

of current industry standards or (2) a lack of initiative to adopt

, industry practices beyond those imposed by NRC. Although an

isolated event, it does adversely reflect on the licensee's

commitment to excellence.

Overall, the surveillance program is adequate and is aggressively

implemented. Additional training is needed in the proper processing

i of test problems. The above-noted procedural weaknesses warrant

further licensee management attention with respect to overall

j adequacy of the licensee's review process.

Conclusion

Category 1, Consistent

l Recommendation

1

i Licensee: See text and summary of Section IV.J, Management

i Assurance of Quality.

!

,

f

'

!

!

.

.

l

1

'

!

j

i

l

)

-. . .. . ._

~

I

.

20

i

E. Startup Testing (561 hours0.00649 days <br />0.156 hours <br />9.275794e-4 weeks <br />2.134605e-4 months <br />, 9%)

!

This area was evaluated in the interim SALP (see attached) and the

startup testing program was completed on January 10, 1986.

Conclusion

Category 1

.

Recommendations

i

Licensee - none

NRC - Assure that existing periodic surveillance tests are

sufficient in the long term to measure battery reliability.

l

!

,

f

a

1

i

I

i

i

a

I

i

'

l \

!

21 l

F. Emergency Preparedness (242 hours0.0028 days <br />0.0672 hours <br />4.001323e-4 weeks <br />9.2081e-5 months <br />, 4*i;)

This area was not addressed in the interim SALP. Du-ing the prior

assessment period (February 1,1984 - January 31,19d5), no signifi-

cant weaknesses were identified and this area was rated Category 1.

During this assessment period, a full-scale emergency exercise, which

included NRC participation, was held on November 20, 1985. The licen-

see's execution and participation in the exercise demonstrated thorough

planning and a strong commitment to emergency preparedness. Examples

of thoroughly planned activities observed by NRC team members included

timely staff briefings in each emergency response facility, adequate

interface with NRC Incident Response Team members, and demonstration

by emergency personnel of familiarity with emergency duties and use

of Emergency Plan Implementing Procedures (EPIPs). The licensee's

performance demonstrated that it could irplemen.t the emergency plan

and EPIPs in a manner that would adequately provide protective measures

for the health and safety of the public. Minor weaknesses noted

included a large number of personnel in the control room, information

flow, and development of protective action recommendations. Positive

corrective action by management from the previous drill was noted

where a weakness was identified. For example, significant items

observed in the 1984 exercise did not recur. Licensee management is

taking the initiative in this are.1 to further improve their emergency

response capabilities.

,

l

-

Radiological control personnel in the control room perform dose

assessment and in plant health physics functions. This results in a

larger number of people with an attendant increase in background noise

level. Consequently dose assessment information in the EOF is obtained

from a communicator and this arrangement is not as effective in

supporting the emergency support director in the EOF once it has been

activated. Similarly, in plant health physics functions need to be

communicated to the Operational Support Center where workers are

dispatched to deal with problems in the plant. Although no specific

deficiencies can be directly associated with this arrangement,

experience at other sites shows performance can be enhanced with

alternative options.

The licensee took the initiative by consolidating the three unit

emergency plans (TMI-1, TMI-2, and Oyster Creek) *into one corporate

plan. This consolidation is to help standardize approaches at all

three plants. Another noteworthy initiative was the licensee permit-

ting the local area fire fighters to use their " burn building" for

j training. This and other licensee support of these local companies

'l has made a positive contribution to local fire fighter preparedness

to support an emergency at TMI.

I

!

. _ . - _ .

-

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

6

.

i

.

22

In summary, the licensee performs well in the emergency prepared-

ness area and continues to successfully demonstrate this

during drills and annual exercises.

Conclusion

Category 1, Consistent

Recommendations

Licensee:

Assess the effectiveness of dose assessment and in plant

health physics functions in emergencies dealing with longer term

scenarios where the EOF and OSC are fully operational.

'

1

!

S

.

23

G. Security and Safeguards (79 hours9.143519e-4 days <br />0.0219 hours <br />1.306217e-4 weeks <br />3.00595e-5 months <br />,1%)

Analysis

This area was not assessed separately in the interim SALP. The

previous SALP period (February 1,1984 - January 31, 1985) rated the

licensee performance as Category 1. No major security program issues

were identified.

1

'

During this assessment period, one unannounced physical protection

inspection was performed by a region-based security inspector.

f

,

Routine resident inspections continued tnroughout the assessment

period.

Corporate management's interest in the program was exhibited by the

continued involvement of the Director of Security in the day-to-day

l

security activities on site. That involvement appears to have

further opened communication channels between site and corporate

management and has resulted in increased appreciation by corporate

management of program needs. Monthly meetings held on site between

corporate and site security management continue to enhance the

program by demonstrating strong corporate support for the program and

by allowing potential problems to be surfaced and resolved before

they can have an adverse impact.

Onsite security management is competent and knowledgeable of the

requirements and objectives of nuclear plant security. They are also

effective in directing the program.

Staffing of the program is adequate and management remains attentive

to human factors. This is evidenced by the continued high morale and

professionalism of membars of the security force and the stability in

the force. Further, the training and qualification /requalification

program continues to be managed by a competent staff whose sole

responsibility is training. Few personnel errors were attributable

to the security force during the assessment period. However,

security personnel apparently were not aggressive in enforcing badge

controls (as discussed later in this section) -- training on

program / policy changes needs strengthening. Training facilities are

well maintained and indicative of the importance management places on

security force training.

The licensee's security audit program, which consists of an annual

corporate audit and quarterly audits by site personnel, is well

planned and comprehensive. Audit reports are disseminated to appro-

priate levels of management and are generally promptly responded to

with effective actions. A recent licensee initiative, involving

!

semi-annual self-inspections conducted in conjunction with security

personnel from the licensee's Oyster Creek facility to review and

1 compare program implementation, is further evidence of a positive

management attitude toward the security ;regram. It also provides

b

.

24

for an exchange of experiences and problem solving between the

facilities. This program appears to be effective in providing

yet another perspective concerning program implementation.

While correction of problems identified by NRC staff was generally

adequate, some problems were noted during this period. Safeguards

licensing issues, e.g., perimeter intrusion detection system (PIDS),

remained outstanding for about two years despite on going dialogue

with NRC staff. The staff's frustration in resolving these issues

resulted in a letter to the licensee in March 1986, identifying those

issues which were still outstanding. Management attention is required

to resolve these long standing issues. Further, a security badge

control violation resulted because of ineffective licensee corrective

action subsequent to an NRC staff concern regarding personnel not

effectively controlling their badges and key cards. Initially,

security implementing procedures were weak in this area. After the

procedures were strengthened, personnel failed to properly implement

these procedures and licensee management was lax in enforcing them.

,

When brought to their attention, licensee management exhibited a lack

I of understanding of the issue and refuted the violation by expressing

apparent futility in how to avoid future violations. Based on sub-

l sequent discussions with licensee representatives and on actual

observations in the plar.t, it now appears that effective corrective

actions have been taken.

.

In summary, the licensee has a well-established program and, in

general, it is properly implemented. Positive measures should be

taken to resolve the PIDS deficiencies.

Conclusion

'

Category 2, Consistent

Recommendations

None

,

1

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

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

)

'

.

.

25

!

l H. Teunnical Support (127 hours0.00147 days <br />0.0353 hours <br />2.099868e-4 weeks <br />4.83235e-5 months <br />, 2*4 not including PAT inspection)

!

Analysis

The interim SALP did not specifically evaluate this functional area >

,

~

because of the operational / test emphasis for that period. However,  !

comments were made in each of the functional areas with a conclusion

in the overview section. Technical support was considered adequate

'

! but not aggressive. Specifically, licensee engineering personnel and

management demonstrated an apparent lack of inquisitiveness for a

i complete understanding of technical problems. In their response to

4 that SALP, licensee management claimed that this was due to the heavy

burden on their engineering staff from questions by oversight groups,

including NRC staff, but they committed to enhance their attention to

i this area.

For the remainder of the SALP period, some improvements were noted

but problems continued to be exhibited in other areas (see mainte-

nance and surveillance sections). However, as found by PAT I, there

does appear to be a problem, despite a well-established program, with

,

the thoroughness and completeness of design reviews for engineering

l plant modifications. This lead: NRC staff to believe that the

symptoms manifested during restart by licensee engineering personnel

and management were indicative of a more fundamental problem as

j addressed later in this section.

4

The licensee's modification control program is well established. The

Technical Functions procedures are quite detailed; and they are

organized well enough to give personnel a good understanding of what

the system is and what their responsibilities are. This system

brought on a marked improvement in the quality of the licensee's

!,

safety evaluations. The program is in place to assure that

safety grade design criteria are applied to plant modifications.

However, for various reasons, full implementation of the program

i has not been achieved.

The PAT I identified a number of examples where modifications or

, temporary mooifications were improperly prepared and/or installed.

They included: lack of 10 CFR 50.59 evaluation for temporary shield-

ing installation; lack of thorough and complete review to assure EFW

2-hour backup air supply bottles met single failure criteria; lack of.

thorough and complete review to assure cycle 6 remote shutdown panel

and safety grade signal conditioning cabinet met electrical isolation

criteria; weak documentation of design input and lack of documenta-

tion to support design assumptions and calculations; lack of complete

design verification; and, inconsistent and outdated drawings avail-

able for design and operational use. Some of these issues are

i

'

examples of failure to properly implement the licensee modification

control program procedures. These findings demonstrated that

!

- - _ - - .

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

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

i

O

i

.

26

!

licensee personnel, including first-line supervisors, and the

independent technical and safety review process were not sufficiently

thorough and comprehensive in performing their activities and lacked

l the attention to detail in properly following procedures.

!

!

The environmental qualification area is another example of poor

i engineering project implementation. The PAT I identified that the

j licensee did not complete a review, specific for TMI-1, for use of a

.

certain cable type in safety-related applications. Further, NRC

staff questioning identified another cable type (different vendor)

that was not included in the TMI-1 plant-specific file. Substantia-

tion of terminal block qualification was weak in that comparative

samples were not available for traceability markings and similarity

of kind markings. The results of a walkdown inspection by the

! licensee further disclosed that the Reactor Building fan motor power

j cable qualification could not be substantiated. This resulted in a

delay to the startup from the ECT outage because of last minute work

, to replace the connectors. Once the connectors were replaced, QA

j identified a need for rework in that splicing material conditions

] were not within the bounds of the qualified splice. Errors were

!

made in the establishment of the TMI-1 EQ file due, in part, to a

lack of a thorough and comprehensive independent review. The under-

lying causes of these problems appear to have been a lack of under-

standing of the equipment qualification process and the need for

]

technically comprehensive reviews.

! These problems also affect performance in the licensing area in that

they lead to errors in information presented to NRC staff in licensing

'

correspondence. Examples include: non-EQ equipment for emergency

feedwater system (EFW); single failure susceptibility of the EFW

instrument air system; and lack of electrical isolation between a

] safety grade signal conditioning cabinets and control room panels.

i

!

'

On the other hand, for startup activities there was good technical

support to the site. Several initiatives were exhibited as noted in

the performance of generically applicable special natural circulation

i testing. Site staffing from the corporate engineering division has

) increased and is taking on more responsibility for processing minor

t modifications.

.,

!

.

4

i

<

_ _ _ . - _.

w- _ ,_.._m_ .----. _,__,--_.__.._e _ . -,_,m,,_.u m_,_,.,,m_..,_r m _. _m - ,_ ..~,-,s-.- _, -,_ _ - ,, - ,.- ,--

. _ __

O

.

27

During the recent outage work, licensee management involvement was

adequate in maintaining positive control of all work being performed.

This was exhibited in the unplanned outage for main condenser work

in February 1986. Further, to alleviate the administrative burden

on the licensed operating crew during the ECT outage, the licensee

assigned an offshift qualified senior reactor operator (SRO) to

coordinate the work associated with different jobs. Prior to the

outage, equipment to support major tasks was prepositioned to aid in

the work starting smoothly. Pre-briefing and discussions between

major departments were performed to assist in keeping all responsible

departments abreast of the work. However, as the pace of activity

increased, such as the transition from operations to outage work, or

during plant startup, these communication links between departments

weakened. This contributed to the RB iodine buildup event and 0TSG

worker contamination event during initial set up of OTSG ECT condi-

tions.

Overall, the licensee adequately controls modification work in the

plant. Major startup activities were well supported at the site and

corporate level. The modification control program is well defined,

but implementation needs improvement. Corrective actions for these

problems have been weak and a significant increase in management

attention to this area is warranted.

Conclusion

Category 3, Consistent

Recommendations

Licensee:

In light of recurring problems in the environmental qualification

(EQ) area, assess the adequacy of or the need for better accountability

on specific engineering projects, such as EQ.

Conduct a critical evaluation of the design review process with

emphasis on the role of peer review adequacy and first line

supervisory oversight.

NRC:

Conduct team inspections of the off-site engineering efforts with

particular emphasis on preparations / modifications planned for the

for thcoming refueling outage.

I

1

l

.

.

28

I. Training and Qualification Effectiveness

Analysis

During this assessment period, training and qualification effective-

ness has been considered as a separate functional area. However, the

various aspects have been considered and discussed as an integral

part of other functional areas and the respective inspection hours

have been included in each one. Consequently, 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,

as a review of program adequacy. The discussion below addresses

three principal areas: licensed cperator training, non-licensed

staff training, and status of INPO training accreditation.

The interim SALP noted licensee performance as a Category 1 and noted

a strong licensee commitment to licensed operator and certain non-

licensed operator training areas that resulted in an effective train-

, , ing program for startup. These program areas were oriented toward

improving on-the-job performance. In general, personnel were know-

ledgeable of plant design features and status and they conducted

activities with care during special te-sting and major evolutions.

There was a problem of workers in various plant areas having the

potential to cause a safety-system challenge in that the workers were

not sufficiently careful when working around plant ?quipment. Inex-

perience was noted, especially among non-licensed personnel, but it

was compensated for by enhanced supervisory attention.

During the remainder of the SALP I period, personnel enhanced their

experience level during continuous power operations and during tran-

sition periods at the beginning and end of outage. Reportable events

attributed to personnel errors remained relatively few; and, for

those that did occur, no significant safety concerns were raised.

No additional examples were noted of workers not having respect for

equipment in safety-related areas which could cause a challenge to a

safety system (i.e., the " worker in the spaces" issue). This indi-

cated that the licensee's corrective actions of personnel counselling

(plant wide) were apparently effective in enhancing performance.

There were two plant trips partly related to personnel error, however

they were due to the way secondary plant equipment was operated and

unrelated to the " worker in the spaces" issue.

The PAT I inspection confirmed the positive elements of the

licensee's training program noted in the interim SALP. The team

found a high level of management commitment and involvement in

licensed operator and certain nonlicensed operator training programs

at TMI-1. For example, senior plant management regularly

participated in Babcock and Wilcox simulator training in order to

monitor and evaluate shift performance in non-routine evolutions and

_ __. -

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

.

.

29

'

1

!

l

emergency situations. Training in this area was given the highest  ;

priority by plant and corporate managers and supervisors. Generally, i

policies and procedures were clearly written, broadly disseminated

and well understood by all.

Maintenance training was considered especially strong, well con-  !

ceived, and well implemented. Maintenance personnel typically  :

. attended one week of classroom training during each six-week rotation  !

'

cycle. The training covers industry experience, administrative

,

procedures, and craft-specific areas.

i Some problems with regard to procedure implementation for routine

This was originally attributed to

'

activities continued to persist.

individual procedure step inadequacies. However, the PAT I and other

inspection findings identified a number of examples of licensee

personnel not properly implementing procedures, most notably in the

modification control area, both at the corporate and site levels.

,

The PAT also found that some design packages did not meet safety-

'

grade criteria and that some corporate engineering personnel were not

knowledgeable in records retrieval system use. The effectiveness of

training in this area warrants further review by the licensee.

Fire brigade training meets minimum requirements: but iccks realism

due to the large number of brigade members. In. contrast to the

licensed /nonlicensed training area, licensee management's attitude

appears to be more oriented toward minimum regulato y requirements

than toward committing to excellence. However, licensee initiatives

i

'

outside of regulatory commitments; e.g. , burn building training, help

to compensate for this shortcoming.

The licensee has received training program accreditation from INP0 in -

the following five areas: control room operators; senior reacto.-

operators; shift technical advisors; auxiliary operators; and radio-

logical control technicians.

All five SRO and five R0 candidates for operator licenses passed

the NRC license examinations. No licensed operator training program-

'

matic weaknesses were identified. Some practical weaknesses were

uncovered however, such as, the candidate familiarity with the use of

the plant computers and various data plots.

In summary, the licensed operator training program for startup and

subsequent operation was effective and performance oriented. Experi-

ence is being gained with continued full power operations and person-

nel errors remain relatively few. The licensee was responsive to

l certain training needs; such as, for the " workers in the spaces"

issue. The licensee demonstrates a poor attitude with respect to

fire brigade training. Site and corporate engineering training may

need enhancement. Licensee management should direct its attention to

-

training effectiveness on the procedure adnerence issue.

,

- - . y -,y , , . - - - ,~ , , , , .---.----s-- - _ . . . - , . . _ . _ _ - --y,s - , _ . - . - - - - - _ _ - - - - - , ,

- .-_ __ .. . ._

.

.

30

Conclusion

Category 1, Consistent

Recommendations

None

T

,

,- - _ . _

.. .- -

. - _ _ _ - _ _ _ _ _

.

.

31

J. Assurance of Quality

Management involvement and control in assuring quality is being con-

sidered as a separate functional area for this assessment period.

However, the various aspects of the programs to assure quality have

been considered and discussed as an integral part of each functional

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

Consequently, this discussion is a synopsis of the assessments

relating to the quality of work conducted in other areas. It should

be emphasized that this function area evaluates management assurance

of quality; and, as such, is much broader than merely an assessment of

QA/QC department performance.

The interim SALP rated licensee performance as a Category 1. It

noted an aggressive management and quality assurance department

(QAD) presence and involvement in site activities. However, manage-

ment attention to the QAD effectiveness reviews was questioned in

light of tne procedure adequacy and implementation problems that

persisted.

The procedure implementation problem appears now to involve more than

individual procedure step inadequacies challenging people toward

proper implementation. Considering the interim SALP results, recent

inspection findings, and PAT I findings in the modification control

area, this problem is symptomatic of an apparent corporate and site

level problem in fully adhering to procecures for routine activities.

It appears that personnel rely on memory or rush ^to meet schedules to

complete action items without referral to tne appropriate licensee

procedures. Indirectly middle management appears to be adversely

affecting performance on properly implementing procedures by their

aggressive attitude toward schedule adherence. In this regard,

indications are that management has not followed through to assure

that their procedure adherence goals are being achieved.

Overall general plant operation procedures and safety system opera-

tional procedures are adequate. However, many other important to

safety procedures have individual step inadecuacies, a persistent

problem identified throughout the SALP I period. These instances of

procedure inadequacy are too numerous to be considered an isolated

problem and they indicate a lack of attention to detail on the part

of individual reviewers along with poor supervisory oversight of the

procedure review process. Compounding this problem is the lack of

.

diagnosis in the analysis reports on the review process which are

{ submitted to the cognizant vice presidents. Licensee initiatives are

j needed to improve required review process.

The quality assurance (QA) department is well staffed and is focused

on enhancing operational experience. The QA program employs many

initiatives to uncover problems in programs or program implementation.

Other oversight groups employ substantially experienced personnel who

o

$

.

.

.

32

appear to be effective in their problem identification reviews. How-

ever, for problems not directly affecting plant operations, licensee

management is not effectively using these assets. For example, pro-

cedure adherence and drawing control problems are long-standing

issues at TMI. Licensee corrective actions were ineffective in this

area. Furthermore, QAD apparently has been unable to assure appro-

priate corrective action. In addition to examples noted above, EQ

problems and the lack of a component level quality classification

list were issues that QAD did not escalate within the licensee

organization in a timely and effective matter to assure licensee

management took appropriate corrective action before they became

issues with NRC staff.

Also in some instances, personnel and management lacked initiative

toward effective corrective action without oversight pressure.

Examples include slow action to resolve instrument anomaly problems.

In regard to a violation for failure to establish procedures the

licensee exhibited poor understanding of related management assurance

requirements.

In summary, strong quality assurance and oversight review pro-

grams employing unique techniques are in place. Nonetheless, line

organizational management needs to more effectively use these assets.

Improved personnel and management attitude toward proper procedure

implementation is warranted.

Conclusion

Category 2, Consistent

Recommendations

4

Licensee:

Establish and enforce a policy that can be understood by mid-level

managers and workers to ensure procedural adherence and resolve the

perception that schedules are of a higher priority.

Reassess the process used for assuring individual procedures are

technically adequate and complete. In particular, assess the

relative roles of peer review and management oversight in procedure

reviews and changes.

Assess the need for better indoctrination and/or training for

individuals associated with engineering design work and design

change control.

.

-

- _ _

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

_ - . _. _ _ _ __ _

.

l

4

33

K. Licensing

! Analysis

This area was not addressed in the interim SALP. In the previous

SALP evaluation for this area (February 1,1984, to January 31,

1985), the licensee received a Category 2 rating. In that SALP

report, we noted that management involvement was above average for

j significant matters which could affect plant restart. But there were

j other areas where management involvement and control appeared to be

lacking, particularly in areas of less significance to restart.

The licensee has been very aggressive in meeting with NRR on a

'

monthly basis to discuss all active licensing issues. Priorities of

review are discussed. As expected, the higher priority reviews are

proceeding in an efficient manner. But another result of these

'

meetings is that the lower priority reviews are proceeding more

j smoothly than before and are being completed. Another aspect of

'

l these meetings is that future licensee submittals are discussed along

with their priority.

i i

There was one notable breakdown in communication. Specifically, a

10 CFR 50 Appendix H time extension request-on analyzing reactor

vessel surveillance capsules was not submitted in a timely fashion.

Although the specific issue involved had a low safety significance

'

from a regulatory viewpoint, the request should have been submitted

earlier. Since this is the only notable exception found to date,

i this incident was not considered to be representative of the

{ licensee's performance.

l The licensee's understanding of the technical issues has generally

1 been goed and the proposed resolutions have been generally con-

servative and sound. There are occasional differences between the

j NRC and licensee on how to proceed on a technical issue, but, in

j general, when these differences occur, the licensee has a reasonable

I technical basis for their decision. However, in view of the findings

under the Technical Support / Outage Management section of this SALP,

questions are raised on the underlying basis of licensee submittals.

] Resolving the concerns in the Technical Support section will resolve

i these questions.

In the last SALP appraisal on licensing activities (prior to

restart), the licensee was requested to improve their No Significant

Hazards Determination (NSHD) submitted with each technical specifica-

tion change request (TSCR). The licensee has shown considerable

improvement in this area. The best examples are contained in TSCR

l

148 and TSCR 153, involving extensive reviews of steam generator

,

repair criteria. Even on less extensive TSCRs, the licensee is

providing a more meaningful technical analysis for the NSHD.

'

i

!

i

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

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

_ - _ - . _ - -

.

!

.

[ 34

The licensee has an effective system for tracking and responding to

J NRC requests. It is evident in the monthly meetings between NRR and

'

the licensee that management attention is focused on meeting sched-

ules. Rescheduling of lower priority work is done in a conscious,

controlled manner. Licensee staff was sufficient to support startup

and operation and to adequately support completion of a number of

older licensing actions.

Additionally, the licensee has been very responsive to requests for

, information on a short notice for such items as congressional inquiry

and internal NRC surveys of plant status.

In summary, the licensee's performance has improved in the licensing

area. Older licensing issues are being resolved and the licensee is

trying to minimize the backlog of licensing actions. The licensee's

'

significant hazards determination evaluations have improved. This

functional area will require continuous diligence on the licensee's

part to maintain the observed level of improvement.

i

Conclusion

Category 1, Consistent

!

Recommendations

j None

1

d

j i

,

r

I

!

I

IJ

1

.

i

i

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

.. .-

_

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

.

f

.

35

l

V. SUPPORTING DATA AND SUMMARIES

1

i

A. Investigations and Allegations Review l

There are no open investigations for TMI-1. The investigation on the

environmental equipment qualification apparent material false state-

<

merit was completed during this period and it is being reviewed by IE

and Re2 i on I staff.

Two allegations were received outside the interim SALP period. One

dealt with concerns on the design adequacy of certain restart and

post-restart modifications. The allegation was reviewed in NRC j

t

Inspection 50-289/86-06 and it was not substantiated. An unresolved

item was identified for the licensee to define a thermal transient on

nozzles for cold water injections to high temperature systems. The

other allegation dealt with a concern on the potential for recriti-

cality during post-engineered safety feature actuation situations.

This is currently under review by Region I.

B. Escalation Enforcement Actions  !

None

!

j C. Management Conferences

'

There were three management conferences during this period. On

, December 17, 1985, NRC management (Region I and NRR) met with the

licensee at the site to discuss the status of the power escalation

program and various related technical probleas identified during the

4

startup process. On March 31, 1986, NRC management (Region I and

NRR) met with licensee management in the Region I, King or Prussia,

Pennsylvania, to discuss the interim SALP issued on March 13, 1986.

On April 18, 1986, NRC management (Region I, IE and NRR) met with

licensee management at the site to discuss technical issues on the

licensee's environmental qualification program, specifically for

TMI-1 but also applicable to Oyster Creek.

D. Licensee Event Reports '

In reference to Table 5, six Licensee Event Reports (LERs) were due

to personnel error, three were due to component failure / malfunction,

j and one was due to a system design error on the two-hour backup air

supply for the EFW system (which has as a root cause, personnel

i error).

No causal link can be inferred among the ten LERs. Although the

, population of 10 LERs is small, there was a relatively large number

] of these attributable to personnel error.

!

!

I

. _ _ _ _

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

.

.

36

,

E. Reactor Trips / Forced Outages

,

Table 6 represents the unplanned reactor trips and unplanned outages

along with root causes. Also, the main turbine was taken off line

with the reactor critical at low power during October 13-18, 1985,

and April 24-25, 1986, for turbine steam inlet drain line repairs.

The following reactor trips and outages, which occurred during this

period, were planned in accordance with the licensee's test program

or regulatory requirements.

--

October 15, 1985, Manual PLANNED trip in accordance with

startup test procedures

--

October 21, 1986, Loss of PLANNED trip in accordance with

Feedwater power escalation procedures

--

January 2, 1986, Turbine PLANNED trip in accordance with

Trip power escalation procedures

--

March 21-April 21, 1986, PLANNED outage in accordance with

Outage license conditions issued as a

result of steam generator tube

repair hearing

. _ . - _ _ , .

.

.

T1-1

TABLE 1

INSPECTION REPORT ACTIVITIES

TMI-1 NUCLEAR GENERATING STATION

,

REPORT / DATES INSPECTION TYPE HOURS ACTIVITY

i

85-22 SHIFT 683 Power Operations

'

9/16/85-10/11/85 RESIDENT / PROJECT Startup Testing

STARTUP TESTING

ENGINEERING SPECIALIST

85-23 EMERGENCY PREPAREDNESS 242 Annual Emergency

11/19/85-11/21/85 SPECIALIST Exercise

RESIDENT / PROJECT

85-24 SHIFT 369 Power Operations

10/11-18/85 RESIDENT / PROJECT Startup Testing

STARTUP TEST Licensed Operator .

RADIATION SPECIALIST Training

Radiological

Effluent Control

85-25 SHIFT 352 Plant Operations

10/18-25/85 RESIDENT / PROJECT Startup Testing

STARTUP TEST

85-26 SHIFT 501 Plant Operations

10/25-11/12/85 RESIDENT / PROJECT Startup Testing

RADIATION SPECIALIST Radiological

Effluent Control

85-27 SHIFT 603 Plant Operations

11/12-27/85 RESIDENT / PROJECT Startup Testing

STARTUP TESTING Radwaste Manage-

ment

85-28 SHIFT 540 Plant Operations

11/27-12/13/85 RESIDENT / PROJECT Startup Testing

STARTUP TEST Radiological

RADIATION SPECIALIST Effluent Control

85-30 SHIFT 888 Plant Operations

12/13/85-1/10/86 RESIDENT / PROJECT Startup Testing

STARTUP TEST Radiation Protec-

RADIATION SPECIALIST tion

ENGINEERING SPECIALIST

,. - - ._ __ _

_ __ _

!

i

.

i

T1-2

TABLE 1 (Continued)

86-01 SHIFT 388 Plant Operations

1/10/86-2/7/86 RESIDENT / PROJECT Shutdown /Startup

RADIATION SPECIALIST Activities

SECURITY SPECIALIST Radiological

FIRE PROTECTION SPECIALIST Effluent Control

Security Program

Fire Protection

86-02 RESIDENT / PROJECT 273 Plant Operations

2/7/86-3/7/86 RADIATION SPECIALIST New Fuel Receipt

Radiation Protec-

tion

86-03 SAFETY SYSTEM 770 EFW Operational

3/3/86-3/27/86 FUNCTIONAL INSPECTION Readiness and

BY THE PERFORMANCE Functional

APPRAISAL TEAM (PAT) Assessment

'

86-04 SAFETY SPECIALIST 38 Performance of

4/23/86 GPU Employee

86-05 RESIDENT 440 Plant Operations

3/7/86-4/11/86 FIRE PROTECTION Fire Protection

SPECIALIST

RADIATION SPECIALIST Radiation Protec-

ENGINEERING SPECIALIST tion

86-06 RESIDENT / PROJECT 374 Plant Operations

4/11/86-5/16/86 RADIATION SPECIALIST and Startup

ENGINEERING SPECIALIST Transportation i

86-07 * l

OPERATOR LICENSING Operator Licensing ,

EXAMINER Examinations l

'

• Not Tabulated

J

d

i

h

.- - - . . - .,- - - - . , . - - - -.

. - -

.

.

.

T2-1

TABLE 2

INSPECTION 110VRS SUMMARY (9/16/85 - 4/30/86)+

TMI-I NUCLEAR GENERATOR STATION

INTERIM TOTAL  % OF TIME

SALP HOURS TOTAL HOURS

• Plant Operations 974 3528 54

(shift inspection hours) (1617)

Radiological Controls 244 389 6

• Maintenance 288 426 7

• Surveillance Testing 252 339 5

]

Startup Testing 561 561 9

Emergency Preparedness NA 242 4

Security and Safeguards NA 79 1

• Technical Support NA 127 2

l * Training and Qualification (included in above)

Effectiveness

• Assurance of Quality (included in above)

Licensing NA NA NA

l

• PAT Hours NA 770 12 l

Total 3936 6461

NA - Not Applicable

• PAT - Performance Appraisal Team hours are included in the total but have not

been broken down into individual functional areas.

+ Includes IR 86-06 Inspection to 5/16/86

!

__. .-

.

1

!

.

T3-1

TABLE 3

ENFORCEMENT SUMMARY (9/16/85 - 4/30/86)

I

TMI-1 NUCLEAR GENERATING STATION

A. Number and Severity Level of Violations

Severity Level I -

Severity Level II -

Severity Level III -

Severity Level IV 10

Severity Level V 1

Total 11

B. Deviatien: 1 in Radiological Control (Transportation) Area

C. Violations vs. Functional Area

1

5

Functional Area __ Severity Levels ___

I II III IV V Total

Plant Operations 5 5

Radiological Controls 2 2

Maintenance 1 1 2

Surveillance Testing 1 1

Startup Testing

Emergency Preparedness

Security and Safeguards 1 1

Technical Support

Training and Qualification

Effectiveness

Assurance of Quality

1

Totals 10 1 11

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

.

.

T4-1

TABLE 4

ENFORCEMENT DATA

TMI-1 NUCLEAR GENERATING STATION

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

A. Violations

85-22 9/16-10/:1/85 IV Maintenance Failure to

properly control

scaffolding in

safety-related

areas

85-25 10/18-25/85 V Maintenance Failure to

properly control

drawings inside

control room elec-

trical cabinets

!

85-27 11/12-27/85 IV Plant Failure to

Operations establish or

properly change

procedures for

safety-related

activities

85-27 11/12-27/85 IV Plant Failure to

Operations completely review

for adequacy pro-

cedures for inde- 1

pendent verifica- I

tion of

safety-related

activities

85-27 11/12-27/85 IV Plant Failure to

Operations properly implement

technical specifi-

cations and relat-

ed administrative

control for inde-

pendent on-site

safety review

group (IOSRG)

activities

- - - - . - -. - ,

_

-

. _ _ _ _ _

.

.

T4-2

TABLE 4 (Continued)

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

85-27 11/12-27/85 IV Security Failure to

properly implement

security personnel

badge identifica-

tion control

measures

85-30 12/13/85 IV Surveillance Failure to

properly inspect

a fire door on

the specified

frequency

86-01 1/10/85-2/7/86 IV Plant Failure of fire

Operations brigade members to

respond to a drill

wearing respira-

tory protection

apparatus

86-05 3/7/86-4/11/86 IV Radiological Failure to perform

Controls timely evaluation

of airoorne radio-

iodine in the

reactor building

86-05 3/7/86-4/11/86 IV Radiological Failure to con-

Controls spicuously post

radiation caution

signs at a radia- i

tion area acces-

sible to personnel

86-06 4/11/86-5/16/86 IV Plant Failure to imple-

Operations ment, in part,

important to

safety procedures

during startup

l

l

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

.

.

.

T4-3

TABLE 1 (Continued)

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

B. Deviation

86-06 4/11/86-5/16/86 NA Radiological Failure to meet a

commitment to re-

train a radwaste

supervisor bienni-

ally

C. Other Violations

By letter dated January 25, 1986, the NRC staff issued a Notice of

Violation as a result of NRC investigations into management issues related

to TMI-1 restart. Specifically, the violation dealt with only the TMI-1

reactor coolant system (RCS) leak rate for which the licensee had taken

sufficient corrective and preventive action (see below). No response was

required for the Notice of Violation. Other violations may be issued when

the staff completes its review of those investigations and management issues.

The below-listed violations do not relate to licensee performance during

the SALP I period, since they involve plant activities between April 1978

and September 1979.

--

Failure to adequately control the RCS leakrate by having a deficient

surveillance procedure and by not properly implementing that

procedure.

--

Failure to maintain records of the RCS leakrate for invalid tests.

--

Failure to properly identify and correct malfunctions and

deficiencies in a makeup tank equipment configuration.

These violations relate to the Plant Operation and/or Surveillance area.

Collectively, they were classified as a Severity Level III Violation.

_. ,_ _

. _ . --

.

.

j T5-1

TABLE 5

LER SYNOPSIS - 9/16/86 - 4/30/86

THREE MILE ISLAND - UNIT 1

LER Number Summary Description

85-02 Manual reactor trip due to response to a fire in the rod

ccatrol system. Root cause: Equipment / component mal-

function

85-03 Reactor trip due to a malfunction of a main generator relay

that caused a main turbine rejection which caused a RCS tran-

sient. Root cause: Equipment / component malfunction

85-04 Inoperable fire barrier to a make-up pump cubicle without a

fire watch during modification work. Root cause: Personnel

error

86-01 Inoperable pressurizer spray line snubber was found while plant

was in hot standby condition. The snubber was found unpinned

at one end. Root cause: Personnel error

86-02 Reactor trip following a main turbine trip due to high moisture

separator level. A faulty valve controller in the heater

drains flow path caused the high separator level. Root cause:

Equipment / component malfunction

86-03 Incorrect position of a jumper internal'to an undervoltage

relay associated with the shunt trip feature for a control rod

drive trip breaker rendering one-of-four RPS channels out of

service. Root cause: Personnel error

86-04 Isolation of condenser offgas radiation monitor RM-A-5L in

violation of technical specification. Improper valve alignment

caused the isolation. Root cause: Personnel error

86-05 Fire door C310 was found inoperable due to excess door-to-floor

!

clearance and a continuous fire watch was not posted within an

hour of occurrence as required by technical specification.

Root cause: Personnel error

86-06 Reactor trip following a main turbine trip due to a low

pressure spike in the turbine lube oil system caused by valving

in a standby lube oil cooler that was not fully pressurized. ]

Root cause: Personnel error and procedure inadequacy

.

- - - , . - - - - .

_. _ _ . - __

-.,__.,,e.--- - ,, , . , . - , , , , y -- .

_ . - . . __ _ _ _ _ _

.

.

T5-2

86-07 The Performance Appraisal Team (PAT) found that the installed

two-hour backup air supply does not meet single failure crite-

ria. The original system design verification did not identify

i this discrepancy in the final design. Root cause: Engineering

design

1

y y- - - -

- _ _ - -

.

.

T6-1

TABLE 6

UNPLANNED REACTOR TRIPS

AND

SHUTDOWNS

(9/16/86 - 4/30/86)

DATE DESCRIPTION CAUSE

Unplanned Reactor

Trip Signals / Power Level

December 1, 1985, The high RCS pressure resulted Load dispatcher

High RCS Pressure / due to a load rejection with allowed grid voltage to

from 75% power the tripping of the main drift up coupled with a

generator breaker due to an relay setpoint drift

overexcitation protective relay

malfunction coupled with relay

setpoint drift during a regional

grid voltage transient

January 4, 1986, The turbine trip resulted from Equipment malfunction

Turbine Trip / an abnormal high level in one in the secondary

frcm 22% power of six moisture separators due plant - level controller

to a level controller malfunction

in the feedwater heater drain

collection tank

March 15, 1986 The turbine trip resulted Personnel error coupled

Turbine Trip / from an abnormal low turbine with weak operating

from 100% power lube oil pressure caused by procedure

valving in a standby lube oil

cooler that was not fully

pressurized

April 21, 1986 The reactor tripped after all Equipment malfunction

Failure of "D" four reactor coolant pumps in the electrical

(vital) bus tripped following loss of one supply system coupled

supply breaker / (of two) 4160 volt vital buses with weak operating

reactor sub- and all three 4160 volt non- procedures

critical vital buses

_ _

--

_ _ _ _ _ _-

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

.

.

T6-2

, TABLE 6 (Continued)

'

Date Description Root Cause

April 23, 1986 High RCS pressure resulted Feedwater transient due

High RCS Pressure / from a main feedwater (FW) to operations personnel

from 9% power transient in which the error

turbine-driven FW pump

decreased speed during the

! transfer of steam supply

from the auxiliary system

to the main steam system

Unplanned Shutdowns / Duration

!

'

Janua ry 27, 1986 Due to a 20 MW reduction in Secondary plant fabri-

Steam Line electrical output first cation defect which

Bellows Leak / observed on January 17, the occurred during initial ,

One week licensee shut down and in- construction welding

spected the main condenser

for extraction steam expansion

bellows leakage

i

I

!

!

$

4

I

l

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

.

.

T7-1

i

TABLE 7

LICENSING ACTIONS

ACTIONS NUMBERS

NRR/ Licensee Meetings 6

NRR Site Visits 4

Commission Briefings - One by the 1

Licensee

Schedule Extensions Granted -

Appendix J (LLRT) 1

Appendix H (Surveillance Capsule) 1

Reliefs Granted 0

Exemptions Granted

Appendix J (LLRT) 1

l Appendix H (Surveillance Capsule) 1

Licensee Amendments Issues 6

Emergency Technical Specification 0  ;

Changes Issues

Orders Issued None

i

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

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

,

.

.

T8-1

TABLE 8

RADIOLOGICAL EFFLUENT RELEASES

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

Reported)

% of Technical

Specifications

Component Release Activity Quarterly

Date Involved Point Released (Ci) _ Limit, Gamma _

10/21/85 Reactor Trip Main Steam 1.07 E-6 3.8 E-8

at 40% Relief Valves

(MSRV)

10/28/85 Makeup Pump Station Vent 0.7 0.0015

(SV)

11/2/85 Reactor SV 1.05 0.025

Coolant

Evaporator

11/19- Main Steam MSRV 1.6 E-7 3.48 E-9

20/85 Valve Testing

,

12/1/85 Reactor Trip MSRV 7.32 E-6 1.5 E-7

at 75%

12/17/85 Waste Gas SV 1.4 0.001

Compressor '

12/30/85 Makeup Pump SV 46.3 0.07

1/2/86 Reactor Trip MSRV 1.22 E-5 2.3 E-7

at 88%

1/4/86 Reactor Trip MSRV 2.14 E-5 3.06 E-7

at 22%

1/9/86 RCLD Gas SV 1.6E-1 8.34 E-5

Sample

1/9/86 Flush of SV 2.76 2.22 E-3

MU-V-129A

l

O

.

'

TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES

1/28/86 DH-V-578 SV 3.96 2.0 E-3

Spill

2/13/86 AHC-14C SV 6.5 E-1 3.3 E-4

Fan Shutdown

2/13/86 Drain Trap SV 1.5 1.16 E-9

Chem Lab

Sample Sink

2/24/86 CA-V-2 SV 11.6 6.44 E-9

Leakage

2/24/86 CA-V-2 SV 2.79 1.91 E-3

Repair

l 3/4/86 Waste Gas SV 1.47 7.7 E-4

Comoressor

3/15/86 Reactor Trip MSRV 3.7 E-5 7.86 E-7

from 100%

3/22/86 CA-V-5 SV 14.8 8.54 E-3

Relief Lift

Normal (Routine / Continuous) Operating Releases - Predominantly Noble Gas

-

% of Technical

Specification

Activity Released (Ci) Quarterly Limit, Gamma

October 0.15 1.32 E-3

November 18.8 2.0 E-2

December 5.29 7.6 E-3

January 262 2.78 E-1

February 1150 1.23 E-0

March 830 8.8 E-1

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

.

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T8-3

TABLE 8 (Continued)

RADIOLOGICAL EFFLUENT RELEASES

.

Normal (Routine) Operating Releases - Liquid - Predominantly Tritium

Activity

Date Released (C1)

October 1.0

November 1.19

December 5.99

January 24.1

February 26.3

Mr.rc h' 17.6

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U. S. NUCLEAR REGULATORY COMMISSION

j REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-289/85-96

4 GENERAL PUBLIC UTILITIES NUCLEAR CORPORATION

I f

j THREE MILE ISLAND NUCLEAR GENERATING STATION UNIT ONE

j ASSESSMENT. PERIOD: SEPTEMBER 16, 1985 - JANUARY 10, 1986

BOARD MEETING DATE: JANUARY 24, 1986

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TABLE OF CONTENTS

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Page

, I. INTRODUCTION

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

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

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

II. CRITERIA . . . . , ................... 6

7

III. SUMMARY CF RESULTS

A. Facility Performance. . . . . . . . . . . . . . . . 8

B. Overview. ..................... 9

IV. PERF09.MANCE ANALYSIS

A. Plant Operations. . . . .............. 11

B. Radiological Controls . . ........ ... 14

C. Maintenance . ................... 16

D. Surveillance Testing. . . ............. 19

E. Startup Testing . . . . ..... ....... 21

F. Training and Qualification Effectiveness ..... 24

G. Assurance of Quality. . ........... .. 26

V. SUPPORTING DATA AND SUMMARIES

,

A. Investigations and Allegations Review . ... .. 28

i B. Escalated Enforcement Actions . . . . . . ..... 28

C. Management Conferences. . . . . . . . . . . . . . . 28

D. Licensee Event Reports. . . ........... 28

E. Reactor Trips / Forced Outages ........... 29

F. Planned / Unplanned Releases. . . . . . . . . . . . . 29

TABLES

] Table 1 - Inspection Report Activities . ...... ..... T1-1

Table 2 - Inspection Hours SuT. mary . . . ........... T2-1

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

Table 4 - Enforcement Data . ....... .......... T4-1

j Table 5 - Unplanned Reactor Trips and Snutdowns ........ T5-1

Table 5 - Radiological Effluent Releases . . . . . . . . . . . . T6-1

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I. INTRODUCTION

A. Purpose and Overview

The Systematic Assessment of Licensee Performance (SALP) is an inte-

grated NRC staff effort to collect available observations and data on

a periodic basis to evaluate licensee performance. The SALP process

is supplemental to the normal inspection processes used to ensure

compliance with NRC rules and regulations. It is intended to be suf-

ficiently diagnostic to provide a rational basis for allocating NRC

resources and to provide meaningful guidance to the licensee's man-

agement in order to improve the quality and safety of plant opera-

tions and modifications.  !

This SALP is termed an interim SALP in that it covers the period from

a few weeks prior to criticality to several days after the completion

of the power escalation program. The purposes of this interim SALP

"

are (1) to assist in the preparation for the first of two Commission-

directed performance appraisal team (PAT) inspections, (2) to verify

performance during the transition from a long-term shutdown condition

to commercial power operation, and (3) to determine the allocation of

-

NRC rescurces for future inspections.

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

met on January 24, 1986, to review the collection of performance

observations and data to assess the licensee'; performance in accor-

dance with the guidance in NRC Manual Chapter 0516, " Systematic

Assessment of Licensee Performance." A summary of the guidance and

evaluation criteria is provided in Section II of this report.

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

performance at TMI-1 Nuclear Generating Station for the period

September 16, 1985, through January 10, 1986. The summary findings

and totals reflect a relatively short period compared to the normal

assessment period which is at least 12 months.

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E. SAL: Eoard Members

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Chairman

i R. Starcstecki, Director, Division of Reactor Projects

Members

R. Bellamy, Chief, Radiation Protection Branch, DRSS (Part Time)

'

L. Bettenhausen, Chief, Operations Branch, DRS

R. Blough, Chief, Reactor Projects Section No. IA, DRP

1

R. Conte, TMI-1 Senior Resident Inspector

S. Ebneter, Director, DRS (Part Time) i

W. Kane, Deputy Director, DRP

H. Kister, Chief, Projects Branch No. 1, DRP (part Time)

P. McKee, Chief, Operating Reactor Programs Branch, Division of

Inspection Programs, IE

J. Thoma, TMI-I Operating Reactors Project Manager, Project

Directorate No. 6

1

Other Attendees

N. Blumberg, Lead Reactor Engineer, DRS (Part Time)

!

R. Urban, Reactor Engineer, RPS 1A, DRP (Part Time)

R. Weller. Section Leader, Project Directorate No. 6

F. Young, TMI-1 Resident Inspector

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C. Backcround

!

1. Licensee Activities

The major milestones of the licensee's power escalation program

along with completion dates are listed in Figure 1. This sched-

ule was proposed by the licensee and agreed to by the NRC staff.

The licensee completed its program within a few days of the plan-

ned schedule. The program included six NRC Region I hold points.

J

The assessment period began with the plant in hot shutdown. The

reactor was taken critical on October 3,1985, for natural cir-

culation testing and other low power tests. On October 9, 1985,

the main generator was placed on-line.

i

Between October 13 and 18, 1985, the turbine was taken off-line

l

several times with the reactor at low power to repair weld fail-

!

ures on drain lines from steam inlet piping to the main turbine.

! On October 19, 1985, a test of the reactor trip on loss of main

feedwater was initiated from 40 percent power and a subsequent

natural circulation test was completed. The reactor was re-

started and the main turbine generator placed on-line on

October 23, 1985, then taken to 48 percent power.

The reactor was tnen operated at 48 percent power for operator

training and steam generator leakage monitoring. Between

Novemoer 24, 1985, and December 27, 1985, the licensee completed

additional planned steady-state power operation at 75 percent

power. On December 27, 1985, the NRC released the licensee to

take the plant to full power. However, the maximum achievable

power was limited due to secondary side fouling of the steam

generator, which caused higher than expected steam generator

water levels. Even after raising the steam generator water

level limit, as has been done at other B&W plants which experi-

enced the same problem, the licensee was able to achieve only

88 percent of full power.

On January 2, 1986, the licensee satisfactorily completed the

final power ascension tests -- reactor trip on turbine trip and

EFW initiation on loss of reactor coolant pumps. After the

planned January 2 trip and an unplanned trip during start-up on

January 4, the steam generator fouling was apparently alleviated

and the plant reached full power.

During the above period, two unplanned reactor trips occurred: )

on December 1, 1985, from 75 percent power, as discussed above, l

and on January 4, 1986, from 22 percent power. The first

occurred because of a main generator breaker trip due to a mal- i

function in a main electrical generator protection relay. The

.

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other occurred because of anctner secondary plant malfunction

that caused a high level in a moisture separator which resulted

in a turbine-to-reactor trip.

The annual emergency preparedness exercise was completed satis-

factorily on November 20, 1985. Also, the licensee completed

construction of a new annex to the training building which,

among other support functions, will house the plant-specific

simulator scheduled for delivery in June 1986.

2. Inspection Activities

In May 1985, Region I established the TMI-1 Restart Staff organ-

ization to provide an intensive review of licensee activities

using an augmented shift coverage plan. This organization

continued to function from that time through delays in restart

authorization and through the licensee's power escalation

testing (PET) program. There was a high level of Region I

,

management involvement including the Deputy Director, Division

of Reactor Projects, who served as TMI-1 Restart Director on ,

site.

Eecause of his knosledge of the TMI-1 plant and experience with

the TMI-1 restart process, the senior resident inspector was

designated TMI-1 Restart Manager and assigned the responsibility

to manage inspection activities. Shift inspectors, experienced

in B&W plant operations, included resident / project engineers

from Region I, other regions, the NRC training center, and NRC

contractors. Shift inspector activities ranged from 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

per day to 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> per day, depending on the pace of licensee

activities. The resident inspector and Region I inspectors

conducted follow-up reviews of a programmatic nature in response

to shift inspector concerns. As time permitted, they conducted

,

'

reviews of equipment operability and of the technical adequacy

of selected procedures. Region-based specialist reviews also

occurred in the areas of radiation protection, training,

engineering support, security, and emergency preparedness.

To provide additional technical expertise and experience with

the TMI-1 restart, the former senior resident inspector for

TMI-1 was assigned as a technical assistant to the TMI-1 Restart

Director. ,

A total of 3936 inspection hours were expended during the period

(shif t inspector coverage was approximately 40% of that total)

with a distribution in the appraisal functional areas as shown

in Table 2. The inspection hours occurred during a 17-week

period which converts to 232 hours0.00269 days <br />0.0644 hours <br />3.835979e-4 weeks <br />8.8276e-5 months <br /> / week or approximately 12,000

hours annually. Summaries of inspection activities and identi-

f fied violations a-e tabulated in Tables.I and 4 respectively.

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

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

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This report aise discusses " Training and Qualification Effec-

i

tiveness" 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 resi-

dent inspectors and as an integral aspect of specialist inspec-

, tions. Although quality work is the responsibility of every

employee, one of the management tools to measure this effec-

tiveness is reliance on quality assurance inspections and audits.

Other major factors that influence quality, such as involvement

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

are discussed in each area. ,

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6

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II. CRITED.IA

Licensee performance was assessed in selected functional areas significant

to nuclear safety and the environment. Assessment areas were selected

based on facility status (i.e., restart testing phase) and, for this in-

terim SALP, NRC inspection program focus. Consequently, this interim SALP

does not include certain typical SALP functional areas, such as emergency

preparedness, security and safeguards, fire protection, technical support,

and licensing. These will be addressed in the next SALP.

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

functional area:

1. Management involvement and control in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

3. Responsiveness to NRC initiatives

4. Enforcement history I

5. Report and analysis of reportable events

6. Staffing (including management)

J

7. Training effectiveness and qualification [

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:

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.

The NRC attention recommendation may not be consistent with the above

categories for a given SALP rating in a specific functional area.

This is because of unique aspects of TMI-1 and because of public sen-

sitivity to operational activities at the facility to which the NRC

staff must be prepared to respond.

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

management attention and involvement are evident and are concerned with

nuclear safety; licensee resources are adequate and reasonably effective

,

so that satisf actory performance with respect to operational safety or

construction is being achieved.

Category 3. Bcth NRC and If:ensee attention should be increasec. Licensee

management attention or involvement is acceptable and considers nuclear

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safety, but weakresses are evicent; licensee resources apoear tc be

strained or not ef fectively used 30 that minimally satisf actory perfor-

mance with respect to operational safety or construction is being

achieved.

Normally, the SALP Board assesses each functional area to compare tne

licensee's performance 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. Because of the short period covered by this

SALP, the trend categories are not addressed, however, perceptible changes

in performance in the last month of the period are addressed in the

functional areas.

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8

III. SUMMARY OF RESULTS

A. Facility Performance (September 16, 1985 - January 10, 1956)

Category

Functional Area This Period

1. Plant Operations 2

2. Radiological Controls 1

3. Maintenance 2

4. Surveillance Testing 1

5. Startup Testing 1

6. Training and Qualification 1

Effectiveness

7. Assurance of Quality I

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B. Overview

l Overall, licensee management prepared their operators and the plant

l

well for restart in light of the long shutdown. Licensed operators

conducted themselves competently and exhibited a detailed knowledge

of the facility design and plant status. They demonstrated their

4

skills especially well in operating the integrated control system in

the manual mode. Despite signs of inexperience, non-licensed person-

i nel also performed well. No plant trips occurred due to personnel

l error, but workers in safety-related spaces were not always careful

in working around the equipment; this had the potential to cause

j safety system challenges. A strong training program contributed to

the overall good results in operator performance,

l

i Plant equipment was in good material condition and it reflected a

4 strong preventive and corrective maintenance program applied during

the long shutdown. The startup group assured that the numerous re-

i

start modifications were adequately tested to minimize operational

,

problems during power ascension. Plant maintenance adequately

maintained equipment. subsequent to plant turnover. Very little

j safety-related equipment needed repairs during the startup test

program.

In general, procedures were adequate but, in certain instances, prob-

lems with individual procedure steps challenged personnel in the prop- '

er implementation cf the procedures. Even though a strong procedure

control policy exists, apparently not all workers understand their

responsibilities when procedures cannot be followed.

]

To varying degrees, the oversight review groups performed adequately.

q

However, it apoears that certain important findings by review groups

i were not effectively acted on by licensee management.

i~

The radiological controls program continued to be implemented effec-

, tively during pcwer operation. The unplanned radiological releases

that occurred were due to poor work planning, not radiological plan-

ning.

The surveillance and startup test programs were stroag, involved com-

, petent and dedicated personnel, and complemented each other in the

restart. The power escalation program was slow and deliberate, and I

was effective in providing familiarization training for operators. l

It was also effective in identifying and correcting overall system

,

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i integration problems.

1

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The assessment covered a period of intense NRC staff review during '

1

transition from a long shutdown to commercial power operation.

{

Licensee personnel attentiveness to the plant was probably heightened

by these circumstances. Although many of the licensee's programs are

strong, r.ontinued gcoc nuclear safety performance will result only

'

with effective program implementation and sustained personnel

.

attentiveness and involve ent.

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Technical Support

.

Technical support staffing was ample with definite signs of both cor-

,

porate and site engineering presence and involvement in plant activi-

'

ties. In general, management exhibited conservatism when faced with

technical problems and, overall, technical support by licensee per-

l

sonnel was adequate but not aggressive. When technical problems

j could not be resolved immediately, appropriate interim measures were

i provided to assure nuclear safety, such as with the relief / safety

valve problems associated with both the steam generators and the

i

turbine criven emergency feedwater pump steam inlet piping. In

i certain instances, however, appropriate measures or investigations

'

were established only after prodding by NRC staff. Further, licensee

review of certain problems or events could have been more thorough

!

and complete. Apparently, engineering personnel and management were

not always sufficiently inquisitive to assure a complete understand-

ing of problems. In certain instances, especially during meetings

on the sixth and final NRC hold point, there was an apparent attitude

]

of shortsighted analysis of events. Upon final resolution, no

i unreviewed safety questions were identified, and ultimately, the

licensee competently resolved the technical problems.

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IV. PERFORMANCE ANALYSIS

A. Plant Doerations (974 hours0.0113 days <br />0.271 hours <br />0.00161 weeks <br />3.70607e-4 months <br />, 25%)

Analysis

The licensee displayed excellent overall control of the plant. Li-

censed shift personnel were professional and competent in handling

routine evolutions and tests and were especially skillful in operat-

ing the integrated control system. Further, operators performed well

and demonstrated a safety conscious attitude during unexpected

events, such as the two unplanned reactor trips. The operators

showed a high level of knowledge and the ability to use that knowledge

in operating the plant safely. . Shift turnovers were thorough and

,

professional. The shift technical advisor was integrated into plant

4

operations, especially in the evaluation of individual parameter

! trends and of plant transients. Licensee management instilled a team

I

concept in the shift organization. Operations management insisted on

.

a quiet, professional control room atmosphere. Resources were well

! managed to avoid excessive operator overtime while optimizing perfor-

{ mance and training benefits of the test program. The licensee made

~

effective use of pre-briefings for special evolutions and tests and

was responsive to NRC comments for improving the briefings. Licen see

management asserted their presence and involvement during the dayshift

as well as backshifts. In summary, notaworthy performance by licensed

operators, supervisors, and operations management resultea in excel-

lent overall plant control.

Administrative controls, procedures, and procedural adherence are

generally strong, but exceptions have been noted that require

licensee management attention. Administrative controls for TMI-1 are

well established and they reflect a strong commitment to meeting re-

quirements to assure nuclear safety. These procedures also include

licensee initiatives beyond regulatory requirements. However, cer-

tain equipment control administrative procedures are inconsistent

with each other and with sub-tier documents with respect to indepen-

dent verification of equipment control measures as described in

NUREG-0737, TMI Task Action Plan Item I.C.6. Some of these proce-

dures impose independent verification for less than the full

, safety grade scope of equipment to which it is intended to apply.

'

Although most licensee personnel exhibited respect for administrative

controls and attention to detail in implementing procedures, a sig-

nificant number of exceptions were noted. These included three cases

(two of which involved safety-related equipment) of conducting act'iv-

! ities without a procedure, several minor examples of failure to ad-

here to procedures, and several other examples where personnel worked

around obvious procedure errors rather than stopping implementation

1 to obtain procedure change approval. There were also cases where a

more conservative approach was needed in implementing equipment con-

trol (tagout) measures. In two cases, reliance on minimal isolation

,

t

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

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barriers for maintenance work resulted in small releases of

radioactivity when single isolation points leaked. Management atten-

]

tion is needed to ensure that all personnel properly and conserva-

'

tively implement administrative and procedural controls. Also, some

upgrading of the quality of reviews of routine system operating and

test procedures may be warranted to foster worker respect for proce-

.

'

4 dures This is highlighted by the fact that where procedures have

i received extra attention, they are generally of good quality and are

j strictly followed. Examples include safety system valve lineups and

major tests.

<

$ There was a definite presence and attentiveness on the part of vari-

ous oversight groups. The Nuclear Safety and Compliance Committee

(NSCC) performed well. They scheduled their reviews and were able to

i implement their plans well. Their reviews were thorough. The NSCC

j staff has a high level of experience and good channels of communica-

! tions to the board of directors. The Quality Assurance (QA) depart-

'

ment's presence on site was strong. This was exemplified by their

use of shift monitors, a unique and important licensee initiative.

The presence of experienced (formerly licensed) operations personnel

in the QA cepartment enhances performance and credibility. Some l

problems were noted with the Independent On-Site Safety Review Group

(ICSRG), including (1) failure to follow its own procedures and (2)

] lack of a systematic approach and sufficient, depth in procedure re-  !

view. Overall, the oversight groups provide potentially beneficial

insights, but the degree to which the licensee uses the information

,

4

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is unclear. For example:

1

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Board dispositions for some NSCC recommendations were not clear;

l --

Management did not respond effectively to QA assessments regard-

! ing procedure implementation problems; and,

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IOSRG discovery of a part of the independent verification prob-

lems did not lead to ccmprehensive resolution of

! inconsistencies.

In general, management exhibited conservatism when faced with techni-

cal problems and, overall, licensee technical support was adequate

but not aggressive. When technical problems could not be resolved

! immediately, appropriate interim measures were provided to assure

nuclear safety, such as with the relief / safety valves problem for

steam generators and the emergency feedwater pump steam inlet piping.

l In certain instances, however, these measures were established only

! after prodding by NRC staff. Further, licensee review of certain

I problems or events could have been more thorough and complete. Exam-

l pies included review of an RPS breaker malfunction, evaluation of

I letdown cooler leakage, and evaluation of cecay heat system pressure

j indicator discrepancies. In general, corrective action was timely,

' but there were exceptions. For example, had a more aggre-ssive ap-

,

proach been taker towa-d ventilation system balancing, noble gas

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f contamination incidents might have been precluced or minimfzed. Oth-

t er functioral areas cescribe related instances of poor tecnnical sup-

j port most notably reflected in "Furmanite" repair jobs. Apparently,

engineering personnel and management were not sufficiently inquisi-

! tive to assure a complete understanding of certain problems, espe-

j cially when a short-term, multi-disciplined review vas needed. Upon  ;

final resolution, no unreviewed safety questions were identified and,

j ultimately, the licensee competently resolved the technical problems.

!

! In summary, licensee management prepared the plant and their opera-

] tors well for restart. For the most part, procedures were techni-

i

cally adequate but individual procedure step inadequacies challenged

I personnel in strictly adhering to those procedures. In general,

there is respect for procedure adherence, but there were too many

3

j instances where personnel either did not follow or sidestepped a

j

procedure step. It appears that in certain instances, personnel

understanding of the licensee's strong procedural control policies

are not well understood. To varying degrees, the oversight review

j groups are performing adequately; however, some important findings

were not acted on effectively by licensee management. Overall

licensee performance in this area was effective and well oriented

j toward nuclear safety.

I

j Cenclusion

Category 2

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Recommendation

Licensee: Discuss at tne SALP meeting (1) licensee actions to im-

prove the technical support area, (2) measures to instill in all

werkers appropriate attention to operations phase administrative enn-

trols, and (3) licensee measures to ensure optimal benefits from

j oversight group findings.

1

I

NRC: PAT I should review extensively the licensee's independent

i technical and safety review process; by PAT II, an assessment

should be made of the licensee's plant safety review processes; in

particular, the reliance on individual reviews as contrasted with

i interdisciplinary committee reviews,

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14

E. Radiolocical Centrols (244 hours0.00282 days <br />0.0678 hours <br />4.034392e-4 weeks <br />9.2842e-5 months <br />, 6*.)

Analysis

The licensee's radiation protection program continued to be well de-

fined by clear policies and directives. Startup inspections indicat-

ed that the licensee satisfactorily implemented the radiation

protection program in accordance with regulatory requirements. An

adequate staff was available to carry out the program, and the per-

sonnel involved were well qualified and capable of performing satis-

factorily in their assigned areas of responsibility. A formalized

training trogram for the radiation protection staff continued to be

implemented and provided sufficient technical and practical instruc-

tions to assure competence in the organization.

Adequate management review and oversight are consistently evident as

demonstrated by their awareness of daily activities, the establish-

ment of effective inter-departmental communications and cooperation.

The quality assurance department has a lead monitor in this area

for oversight of radiological control activities. The radiation

protection management staff takes the initiative in improving and

enhancing radiological control practices and procedures. For example,

(1) the licensee's raciological staff initiated the iavestigation of

noble gas migration pathways in the auxiliary and fuel handling build-

ings, and consecuently effected corrective measures to better control

airborne activity in the facility; (2) both health physics-field

operations and radiological engineering groups perform frequent

planned inspections anc audits of radiologically controlled areas,

work activities, policies and procedures to assure quality perform-

ance; and (3) all anomalous occurrences that have the potential to

affect exposures to workers or the general public are aggressively

reviewed and evaluated to ascertain causal factors, corrective

measures, and dose effects. Additionally, radiological controls

awareness meetings are held monthly by the radiation protection,

maintenance, and operation departments to exchange information and

resolve concerns pertaining to radiological work, practices, and pol-

icies. These meetings are also attended by representatives from the

bargaining unit, the Vice President and Director of TMI-1, and con-

cerned workers.

The licensee generally exhibits good radiological control practices

and they implement a very thorough radiation worker training program

in an effort to ensure that radiation workers are aware of radiolog-

ical safety procedures and are able to implement them competently.

The TMI-I Restart Staff noted that the licensee consistently demon-

strated a streng commitment to ALARA. During radiological work

performed in this assessment period, the licensee used ALARA

engineering practices, job planning, and worker training to reduce

personnel exposure.

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

\-

-

!

) .

15

l

i

i Effective programs relative to radioactive waste management, effluent

monitoring, and control and transportation of radioactive materials

were implemented and maintained. Effective quality control measures

are embodied in laboratory procedures and practices. The licensee's

, performance in this area was consistent with regulatory requirements.

I

j In general the licensee's performance during various operations and

i maintenance activities involving high levels of radioactivity demon-

j strated reasonable planning and preparation, good procedure develop-

j ment and/or use, and the establishment of appropriate radiological

i

controls. However, there were examples where better planning could

have prevented releases of radioactivity and the contamination of

]

workers. For example, the work on the waste gas compressor resulted

in a release because a check valve was relied upon to isolate the

I waste gas header (see Functional Area A, Plant Operations). Other

similar instances were noted which related to poor work planning,

4 although not specifically poor radiological planning. Licensee re-

i view of the above events was thorough with extensive use of the radi-

) ological awareness report and investigative reports.

I

i In summary, the licensee was able to demonstrate that program ele-

i ments continued te be effectively implemented during power operations,

I and the licensee acequately trained and qualified personnel responsi-

1 ble for implementation of the radiological control program. Implemen-

4

tation problems were not due to programmatic weaknesses but were

related to poor individual worker performance or inadequate support

i from cther departments such as operations or engineering. The

j licensee's program in this area is technically sound.

{

Conclusion

1

Category 1

I

Recommendations

None

!

I

i

!

i

4

JI

-

_ __

.

.

16

C. Mairtenance (288 hours0.00333 days <br />0.08 hours <br />4.761905e-4 weeks <br />1.09584e-4 months <br />, 7%)

.

Analysis

,

The maintenance organization was staffed with knowledgeable and

! skilled personr.el to support the required maintenance activities to

maintain safety-related equipment in a proper condition. When

1

maintenance-related work was identified by operations, the mainte-

l

naree department was aggressive in scheduling and completing the work

1

based on the priority assigned by management. Managerial involvement

I on a daily basis in supervising, tracking, identifying and resolving

problems resulted in a high level of plant operational readiness.

I A continued positive management initiative was that of permanently

-

assigning maintenance personnel to one of the six rotating shifts.

This reduced the typical power plant peaks of high maintenance '

I activity during the dayshift. It also allowed the maintenance

I department to schedule and perform ccrrective maintenance on vital

l equipment as problems developed. Placing a portion of maintenance

personnel on shift work did, however, dilute the experience level in

'

the I&C area. This dilution of experience in the I&C area caused

minor operational problems which resulted in delays in retests until

supervision arrived on site. The electrical and rechanical main-

,

tenance experience remained at a high level. The collective know-

ledge of the maintenance department was sufficient to resolve equip-

! ment problems. In addition, maintenance personnel appeared to be

,

highly motivated and supportive of management. l

J

Administrative controls in the area are adequate and properly imple-

mented along with maintenance procedures. The staff identified a

i minor drawing control violation with respect to posted drawings in-

side control room cabinets. This was uncharacteristic of the

licensee's drawing control program. Another instance was noted where

I individuals failed to follow a maintenance procedure and this result-

ed in tne loss of a safety-related electrical bus. Tne individuals

'

involved were disciplined for failing to cooperate in the licensee's

review of this event. I&C personnel were involved to a limited ex- )

4 tent in tne procedure implementation problems addressed in other

sections.

During this assessment period, several major safety-related systems I

were reviewed closely by inspectors to determine overall reliability

,

and operability of the equipment. Emphasis was placed on preventive,

i as well as corrective maintenance by management in response to plant

restart. Preventive maintenance procedures appropriately reflected

j vendor technical manual recommendations. Safety-related equipment was

found to be in good material condition. Machinery history and mcinte-

, nance records reflected procer documentation (consistent with restart

j hearing board requirements) and this resulted in development of a

i useful historical data base on plant equipment. Records and field

4

observations reflected the involvement of the QA department in as-

suring operability of safety-related equipment.

i

-._ _. -._..____ _.__._ _ .-_,,_..- __.... . _ .,__ _ _ _ , _ _ _ _ _ __..__..,__.-____m. _ _ _ , _ _ _ _ . . _ . . . _ _ _ , _ _ . . .

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

.

(

'

17

.

No instances were noted of inoperability or poor testing because of

maintenance procedures. However, certain maintenance procedures

lacked specificity and clarity associated with the recording and/or

evaluation of as-found conditions. This lack of clarity has forced

maintenance personnel, independent of plant engineering, to evaluate

and determine the operability of equipment in the field with limited I

guidance. This has pointed out a need for enhanced procedure review

and approval and better technical support on the evaluation of

as-found conditions. p. x. p

Maintenance personnel, in particular, and other groups of personnel

doing work in safety-related spaces, were somewhat insensitive to the

change to an operating mode. In certain instances, personnel contin-

ued their working habits as though the plant was in a shutdown condi-

tion. As a result, a violation occurred on unsecured scaffolding

that in a seismic event may have jeopardized the ability of the die-

sel generator to function. Other potentially adverse conditions oc-

curred, the most significant of which was the inadvertent tripping of

the emergency feed pump during scaffold construction, causine the

pump to be inoperable for several hours. The day-to-day approach and

attitudes of non-operations personnel was changing but not completely I

corrected by the end of the period.

J

Housekeeping and fire protection measures remained consistent with

the previous high standards implemented during the long shutdown.

Extensive use of absorbent material to collect oil drippings was used

and contaminated drainage was directed to floor drains using tygon

tubing. However, certain areas of the turbine building were not re-

flective of those cleanliness standards that were applied to safety-

related areas. No fire hazards were created in the turbine building;

by the end of the period, conditions improved substantially in that l

building.

Sufficient technical support was provided to maintenance and good

communication existed between this department and plant engineering.

There was consistent evidence of engineering ' evaluations in mainte-

nance packages. There was, however, incomplete support for " Fur-

manite" repair to leaking flanges and valves. The licensee started

work during the 40% trip outage without considering the stress

induced by this process on the flange bolts. Another example was the

poor control of the amount of Furmanite for repeat injections evi-

denced during the full power trip outage. As a result, an OTSG level

instrument root valve clogged during the injection process and the

material was later blown into the OTSG. Further, no consideration ~

was given to the effects of the material in the OTSG until questioning

by the NRC staff occurred. Upon complete review of these problems,

no unreviewed safety questions were identified by the licensee.

These examples reflect a need for licensee management to assure a

more inquisitive evaluation of plant problems.

.

.

IS

Overall, the rainterance program is properly establisned, implement-

ec, and acecuately staffed. Management involvement at all levels is

evident. Equipment and plant material condition are well maintained

and in a condition that supported unit startup. The QA department is

very active in this area. Personnel attitude toward work in the

spaces still reflects attitudes associated with a plant in cold shut-

down; however, it has not as yet had an adverse effect on plant

safety.

Conclusion

Category 2

Recommendations

None

.

O

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

7

-

l

-

,

19

i .

D. Seveillance Testine (252 hours0.00292 days <br />0.07 hours <br />4.166667e-4 weeks <br />9.5886e-5 months <br />, 7',)

Analysis

During this inspection there was a high level of NRC inspection cov-

'

erage in this area as evidenced by inspection report documentation of

all or portions of over sixty surveillance tests. This included all

j types of surveillances, including maintenance, operations, radiolog-

'

- ical controls, and instrument and control surveillance. In addition,

the data and calculations of numerous other surveillance tests were

i reviewed.

!

l The licensee has a strong administrative program which assures that

i tests are conducted at the specified frequency. The overall adminis-

! trative program was properly implemented except for minor problems.

! A computerized scheduling system was used for the surveillance test

! program. Accordingly, surveillance tests were effectively integrated

. with routine plant operations and well coordinated with operations

1

department activities. Surveillance procedures, with a few minor

exceptions, were properly implemented. Surveillance tests required

by the technical specifications were conducted at the specified fre-

.

{

} quency with one exception. A fire surveillance was missed for sever-

J al days due tc the improper issuance of a procedure change. This

j violation of requirements was considered minor.

Daring this inspection period, NRC staff performed an extensive re-

view of safety-related equipment operability regarding the following

'

components: the makeup pumps, decay heat pumps, and the diesel gen-

i erators. The review included operating procedures, technical speci-

i fication compliance, inservice testing, preventive maintenance,

j maintenance history, and surveillance testing. Applicable surveil-

lance tests were found to be technically adequate in that they met

i all applicable NRC requirenents. Surveillance test procedures, along

j with maintenance procecures and post-maintenance testing, provided

{

adequate assurance tnat the selected safety-related components were

i operable wher, called upon.

I

! Surveillance procedures were properly followed. Tests were performed

) in a deliberate manner ensuring that each step was completed prior to

l

proceeding to the next step. l

l Records were well kept. For a surveillance test of frequency of

i ninety days or longer, a hard copy record of the last completed test

j was maintained in the control room. Once a test was completed, the

j newer test was placed in the file and the older test was sent to

4 plant records for microfilming. This system enabled technicians or

operators good access to the most recently completed tests, if neces-

sary. In addition, extensive test records were reviewed by NRC and

found to be complete with one exception, discussed below.

!

I

l

i

.

4

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

l

1 . ,

) .

!

'

20

!

4

Of particular concerr. during this period were the circumstances that

i ceveloped during anc after a routine surveillance test of the

pressurizer power operated relief valve (PORV). The issues of con-

) cern included: (1) a routine test that could not be completed be-

] cause a portion of the test was not conducted correctly, (2) the

-

unnecessary creation of both a deficiency sheet and an exception

! sheet as a result of that test and, subsequently, thro ing these

1

sheets away and (3) the confusing documentation used to substantiate

the shift supervisor's determination g(psperability of the PORV.

l There was prompt involvement by senior management in the retest when

j operability questions arose. However, the NRC staff's early involve-

-

ment in this process led to discovery of the exception and deficiency

sheets that had been thrown away and the identification of the poor

instructions for handling exceptions and deficiencies. This records

I

handling problem was considered uncharacteristic of the licensee's

! records management program. It did point out a need for additional

attention to detail on the part of licensee personnel in handling

J

these particular records. Further, the licensee's review and approv-

! al process could have developed better instructions for the handling

] of test problems.

) Although other mistakes were made by personnel, in general, licensee

1

'

suoervision caught them before any adverse condition resulted. A

number of examples were noted in which supervision or senior person-

,

nel corrected errors made by junior personnel. This was especially

i

evicent in tne I&C area. Because of supervisory presence, corrective

actions were appropriate to satisfactorily complete tests and avoid

challenges to safety systems.

Staffing was ample in this area along with good interdepartment in-

i terfacing. A specially assigned staff representing the maintenance

and operations department assured overall good coordination of sur-

j veillance test implementation and records. Personnel, in general,

were qualified to perform surveillances but as noted above, some in- ,

l experience was evidenced by a few individuals. None of the unplanned

l reactor trips during this period were caused by surveillance tests. I

4

! Overall, the licensee has a strong surveillance program. Management

i and QA department involvement in this area is evident. The problems .

j observed were few in number and did not adversely affect plant safe-

ty. The licensee safely conducts surveillance tests during plant '

operations.

Conclusion

i

j Category 1

! Recommendations

l

1 None

,

i

!

.

.

~

21

E. Startup Testirc (561 hours0.00649 days <br />0.156 hours <br />9.275794e-4 weeks <br />2.134605e-4 months <br />, 14',)

. During this SALP period, the licensee performed an extensive power

j escalation test program over a three-month period. This program was

successfully completed with only minor performance problems noted.

Testing was performed at predetermined power levels from 0 to 100

percent power for both transient and steady-state conditions and in-

cluded tests of reactor physics performance, natural circulation,

integrated control system, feedwater system, emergency feedwater sys-

tem, plant performance during reactor trips, and measurements of re-

actor coolant system and steam generator leakage. NRC inspectors

witnessed all scheduled plant transients and portions of selected

steady-state tests, and reviewed all licensee test data and resolu-

tions to all test exceptions and deficiencies.

Overall test performance by licensee personnel, including plant oper-

ators, reactor engineers, test engineers, and supporting personnel

from the headauarters safety analysis group, was very good. Opera-

tors always remained in control of the plant during special and in-

tensive test periods. The reactor engineering group, which performed

the physic testing, was well prepared in this aspect of the startup

test program. Tne licensee assured that am;19 supporting specialists

from the fuel vendor and corporate fuel groups were present. In

addition, innovative sof tware programs were employed to monitor and

predict core status on a real time basis. With proper interfacing

with the licensec operators, this resulteo in tests Deing completed

in an effective and well-controlled manter. Although reactor engi-

neers initially were aggressive in sneir requests to operators to

establish plant test conditions, plant operators were always in

control of plant operations.

The startup test engineers had the largest portion of the program;

directing test evolutions from natural circulation testing through

the final reactor trip at 88 percent power, to subsequent steady-

state testing at 100 percent power. Except for the first part of the

natural circulation test, plant testing was well-coordinated with

good interface with the plant operators. Data were properly taken,

data stations were adequately manned, and data reduction was per-

formed properly. Test exceptions and deficiencies (E&Ds) were pro-

perly resolved and all data along with test problems were reviewed by

the Test Acceptance Group in formal meetings conducted periodically

during each test phase. In spite of some minor delays during the

program, all testing was completed within the scheduled time frame of

the test program.

The extensive pre-test training of reactor engineering and test engi-

neering personnel was evident in the overall lack of personnel prob-

lems during test performance. Test briefings for major evolutions

were thorough and extensive. Problems noted during earlier tests,

where applicatie, were factored into briefings for later tests.

Quality assurarce inv;1vement in startup testing was extensive in

1

4

.

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

-

i

.

~

-

22

,

,

l that GA monitors were on shift for all testing. In addition, QA had

'

prepared a detailed test monitoring plan and documentation of QA mon-

itoring activities was comprehensive. Licensee management attention

I and involvement were very evident in that top management was present

and witnessed major test evolutions and power escalations.

I Generally, in handling technical problems, licensee management did

! exhibit conservatism. During the initial startup, licensee manage-

! ment ordered the reactor to be stabilized high in.the source range

unti! one of the two instrument channels for the intermediate range

+

'

neutron power was fixed. While performing an all-rods-out boron mea-

surenent test during zero power physics testing, too much boron was

added to the reactor causing subtriticality. This " boron overshoot"

condition was promptly noted and the reactor engineers and operators

displayed a cautious approach in the boron dilution needed to correct

the problem. The licensee was responsive to staff concerns on the

emergency feedwater system turbine relief valve inadvertent actuation

problem and to the interaction problem between the steam generator

safety valves and the turbine bypass valves. Adequate interim

corrective action in terms of procedural guidance was provided to the

i operators for both of these technical problems. Overall, licensee

!

management competently resolved their technical problems. '

, Based on staff review, the startup test procedures were comprehensive

i and accomplished the desired test objectives with some minor problems

as discussed below. Procedures were followed completely during the

test. All test data reviewed by the NRC staff were correct, and E&Ds

I

were properly resolved.

! Notwithstanding the positive aspects of the test program, some

problems with procedures and personnel were observed. During the

j first part of natural circulation testing, test engineers did not

apoear to be fully organized. This problem was recognized by manage- '

i ment and was quickly corrected. The test could have been better

i planned to instruct the operators how to recover from the unique p' ant

! conditions. As a result, at initial restoration of forced circul: tion

flow, a steam generator safety valve lifted. Other procedure deft-

, ciencies were noted with respect to clarity of instructions. Test

management took corrective actions to improve these situations. At

'

i the conclusion of the test program following the reactor trip at 88

j

'

percent power, one further test deficiency was noted in that the

reactor trip test failed to document the reset function of the let-

down isolation valve MU-V3 following the reactor trip. The adequacy

j of MJ-V3 to open after a trip was subsequently demonstrated through a

! separate retest after NRC staff prodding on the issue.

In summary, the licensee performed very well during the TMI-1 restart

startup testing program. Aggressive management attention and involve-

ment at the upper and middle management levels contributed to the

i

!,

t

i

.

.

23

.

effe:tive p-cgram. The startup p cgram was effective in identifying

equipme" preclems, especially f rom the vienpoint of integrated

system operations. The test program was thoroughly planned, accom-

plished on a realistic schedule, and provided ample time for operator

training and familiarization. Licensee initiatives having generic

B&W applicability in this area were noteworthy. Although they

constituted unique tests, more comprehensive reviews should have

been considered by the licensee before implementation.

Conclusion

Category 1

Reconmendations i

None

i

I

.

I

_:

_____ ____ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ . _ . _ . _ _ _ __ .. _ _ _ - _ _ _ . _ _ _ _ _ _ _ __

-

-

! .

i

.

24

:

F. Traf-ine ard Nalification Effectiveness (NA)

! Analysis f

! l

l' The various aspects of this functional area have been considered and '

discussed as an integral part of the other functional areas and the

respective inspection hours have been incorporated into the respec-

l tive functional areas. Consequently, this discussion is a synopsis

i of the assessments conducted in other areas. Training effectiveness

is measured primarily by the observed performance of licensee per-

! sonnel and, to a lesser degree, as a review of program adequacy.

4

This discussion addresses three principal areas: licensed operator

j training, non-licensed staff training, and the status of INPO

training accreditation.

The training department was staffed with knowledgeable and experi-

i enced personnel. The lesson plans, specialized manuals and courses,

I

hands-on experience, and/or extensive use of simulator and basic

! principles simulater training provided meaningful and practical

training not only to licensed operators but also to other operator

,

technical personnel. This was evident in the performance of new

candidates for operator licenses. All candidates for licenses or

! instructor certifications passed. They included four SRO candidates,

! one RO candidate (on retake), and one instruction certification can-

I

didate.

l

,

As noted in the plant operations section, observations of licensed

j operator personnel by shift inspectors produced a good deal of infor-

! mation relative to their level of knowledge and performance skills.

The results of that review were favorable. The special interviews and

)l

discussions on shift confirmed a high level of knowledge of facility

design with only minor weaknesses observed. Operators were well pre-

'

pared for restart and demonstrated especially strong skills in manip-

ulating the integrated control system in the manual mode. The

l training for the non-licensed staff consisted of both formal and

j on-the-job training. Based on NRC observations, this program was

also effective in producing performance-oriented personnel.similar to

! the licensed operator program. During the implementation of work ,

l activities, in general, non-licensed personnel were appropriately ,

knowledgeable in the requirements of the procedures and plant design. '

, Experienced personnel provided adequate guidance to less experienced

! personnel.

,

No plant trips occurred due to personnel error. However, inspectors

3 saw a persistent problem with workers in various plant areas having

3 the potential to cause a trip or a challenge to a safety-related

system. Personnel (licensed operators included) were also involved

in the problem with the proper implementation of administrative

, controls for procedure implementation. There seemed to be a dis-

j connect between the wel'-stated management policies in these areas

I and the understanding of those policies by certain individuals,

f

4

.

-_ ---- .

-

.

.

.

25

.

'

.

Even with the corrective action initiated before the end of the power

escalatier. program, licensee management had not completely reached-

all plant workers and corrective action is not yet complete.

The licensee received training program accreditation from INPO in the

'

following five areas: control room operators; senior reactor opera-

tors; shif t technical advisors; auxiliary operators; and radiological

l

control technicians.

In summary, the licensee's training program is effective and is ori-

ented toward improving on-the-job performance. The program has the

support and commitment of management. The QA department is actively

involved in training. In general, personnel are knowledgeable of

work and procedural requirements, and conduct activities with care.

Wnen faced with problems, personnel take conservative measures and

seek help.

Conclusion

Category 1 (based on functional areas addressed)

Recommendations -'

None

.

]

l

I

s

&

'

.

o

e

J"

e ,

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

'

.

I .

26

1' .

,

j G. Assurance of Quality (NA)

Tne various aspects of quality assurance program requirements have

i been considered and discussed as an integral part of each functional

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

1 Consequently, this discussion is a synopsis of the assessments

I conducted in these areas.

j

j The quality assurance department continued their aggressive involve-

j ment in oversight activities. This was reflected in their unique

a three levels of review along with a substantial resource initiative

, --24-hour QA shift monitors. Licensee management continued their

l orientation in staffing the department with experienced personnel

! along with providing career enhancement positions for licensed (or-

1 formerly licensed) TMI-1 operators. This had the added benefit for

j licensee management of enhancing the operational expertise of the QA

j department to fulfill its responsibilities in the oversight of

operations.

i

l' Tnere was a cefinite QA presence and involvement in the various fac-

ets of field activities. The monitoring level of review was effective

! in i::entifying tne procedure implementation problems later noted by

) the NRC staff. As a result of successful monitoring, the audit group

! more effectively used their time in reviewing programs and program

l implemertation. However, licensee management apparently did not

effectively respond to the QA departraent for the procedure implemen-

'

tation problem, which was highlighted in the QA department's annual

effectiveness review.

I In summary, there was management and quality assurance (QA) depart-

ment presence and involvement in all facets of activities at the site.

, Licensee management may need to provide additional attention to the

j QA department's effectiveness reviews.

Conclusicn

i

Category 1 (based on the functional areas addressed)

!

I

!

!

l

l

2

4

i

!

!

.

'

27

Re:ce encatien

Licensee: None

NRC: PAT look at the effectiveness of the QA review process.

.

1

,

1

e

- - . - - -

.

.

.

28

V. Supcorting Data arc Summaries

A. Investications and Allegations Review

There are no open investigations for TM1-1. The investigation on the

environmental equipment qualification apparent material false state-

ments was completed during this period and it is being reviewed by

Region I staff.

There were no allegations received during this assessment period.

B. Escalated Enforcement Actions

None

C. Management Conferences

None

D. Licensee Event Reports

Only three licensee event reports were submitted during this period.

Tney are listed below instead of being taculated in a separate table.

.

--

LER 85-002, dated October 3, 1985, for the manual reactor trip

(from hot shutdown condition) that occurred on September 7,

1985, due to operator action in response to a fire in the rod

control system. The root cause was an equipment / component mal-

function (re: PLANT OPERATIONS AREA).

--

LER 85-003, dated December 31, 1985, for the reactor trip from

75 percent power that occurred on December 1, 1985, due to a

proximate cause of high pressure in the RCS. The root cause was

an equipment / component malfunction with a main generator relay

that caused a main turbine rejection which caused the transient

in the RCS (re: PLANT OPERATIONS AREA). '

l

--

LER 85-004, dated December 26, 1985, for inoperable fire barri-

ers found on November 26, 1985, to a makeup pump cubicle without

a fire watch during modification work. This was due to person-

nel error (re: PLANT OPERATIONS AREA).

In summary, all LERs were listed in the plant operations area; two

with component failure causes and one with a personnel error cause.

No casual link can be inferred among the three LERs. However, LER l

85-003 and an LER to be submitted outside this assessment period re-

flects a possible need for improvement in the design of secondary

trip function logic in which a one-out-of-one malfunction caused a tran-

sient on the RCS.

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

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

.

,

29

LER E5-004 was indicative of the worker in the spaces problem identi-

fied in the maintenance area. a

E. Reactor Trips / Forced Outaces

i

'

Table 5 reflects the unplanned reactor trips and reactor shutdowns

along with root causes. Also, the main turbine was taken off-line

4

with the reactor critical at low power during October 13-18, 1985,

for turbine steam inlet drain line repairs, as discussed in paragraph

I.C.I.

1

j The following reactor trips that occurred during this period were

r planned par the licensee' test program:

l

' --

October 15, 1955, Manual PLANNED in accordance with

j startup test procedures

--

October 21, 1955, Loss of PLANNED in accordance with

l Feedwater power escalation procedures

l --

January 2,1986, Turbine Trip PLANNED in accordance with

power escalation procedures

F. Planned / Unplanned Releases

} Table 6 is a summary of the more significant unplanned releases for

the period, along with a summary of the routine releases from the

plant on a montniy casis. i,o regulatory limits were violatec,

i

i

,

e

i l

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

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

-

!

! .

T1-1

-

1

1

TABLE 1

1 INSPECTION REPORT ACTIVITIES

TMI-1 NUCLEAR GENERATING STATION

l

l REPORT PC./ PERIOD AREAS

AREA INSPECTED INSPECTOR TYPE HOURS INSPECTED

i

85-22 SHIFT 683 Power Operations <

9/16/85-10/11/85 RESIDENT / PROJECT Startup Testing

STARTUP TESTING

ENGINEERING SPECIALIST

85-24 SHIFT 369 Power Operations

10/11-18/85 RESIDENT / PROJECT Startup Testing

STARTUP TEST Licensed Operator

!

RADIATION SPECIALIST Training

Radiological

,

Effluent Control

85-25 SHIFT 352 Plant Operations

! 10/18-25/85 RESIDENT / PROJECT Startup Testing

i STARTUP TEST

85-26 SHIFT 501 Plant Operations

10/25-11/12/85 RESIDENT / PROJECT Startup Testing

j RADIATION SPECIALIST Radiological

Effluent Control

85-27 SHIFT 603 Plant Operations

'

11/12-27/85 RESIDENT / PROJECT Startup Testing

STARTUP TESTING Radwaste Management i

85-28 SHIFT 540 Plant Operations

11/27-12/13/85 RESIDENT / PROJECT Startup Testing

STARTUP TEST Radiological

RADIATION SPECIALIST Effluent Control

85-30 SHIFT 888 Plant Operations

. 12/13/85-1/10/86 RESIDENT / PROJECT Startup Testing

STARTUP TEST Radiation Protec-

i RADIATION SPECIALIST tion

!

tNGINEERING SPECIALIST

.

I

- , , . . _ ~ . . - . _ , . . , , , __ , ., _ , . _ . .______.,..,_.r..__.-. . . _ _ , ,,

.

T2-1

TABLE 2

INSPECTION HOURS SUMMARY (9/16/85 - 1/10/86)

TMI-1 NUCLEAR GENERATOR STATION

HOURS  %' 0F TIME

Plant Operations 974 25

(Shift Inspection Hours) 1617 41

Radiological Controls 244 6

Maintenance 288 7

Surveillance Testing 252 7

Startup Testing 561 14

Training anc Qaalification Effectiveness (included in above)

Assurance of QJal'ty (included in above)

Total 3936 100

l

l

.

, , .

.

T3-1

.

TABLE 3

ENFORCEMENT SUMMARY (9/16/85 - 1/10/86)

TMI-I NUCLEAR GENERATING STATION

A. Number and Severity Level of Violations

Severity Level I -

Severity Level II -

Severity Level III -

Severity Level IV 6

Severity Level V 1

Deviations -

Total 7

B. Violations vs. Functional Area

Functional Are'a Severity Levels

I II III IV V Dev Total

Plant Operations 4 4

Radiological Controls

Maintenance 1 1 2

Surveillance Testing 1 1

Startup Testing

Training and Qualification

Effectiveness

Assurance of Quality

Tctals 6 1 7

l

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

,

.

i .,

1

T4-1

.

J

i

>

in:_E 4

ENFORCEMENT DATA

TMI-1 NUCLEAR GENERATING STATION

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

85-22 9/16-10/11/85 IV Maintenance Failure to

properly control

! scaffolding in

safety-related i

areas

l

,

85-25 10/18-25/85 V Maintenance Failure to

'

properly control

drawings inside

control room elec-

trical cabinets

85-27 11/12-27/55 IV Plant Failure to

i Operations establish or

properly change

procedures for

safety-related

,

activities

t

85-27 11/12-27/85 IV Plant Failure to

Operations completely rs,~ew

for adequacy proce-

dures for indepen-

dent verification

of safety-related

1

activities

l 85-27 11/12-27/85 IV Plant Failure to

,

Operations properly implement

j technical speciff-

cations and related

administrative con-

trol for indepen-

dent onsite safety

review group

,

'

(IOSRG) activities

l

I

t

.

9

.

T4-2

.

TABLE a (Continued)

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

85-27 11/12-27/85 IV Security Failure to

(Plant properly implement

Operations) security personnel

badge identifica-

tion control

measures

85-30 12/13/85 IV Fire Failure to

Protection properly inspect

(Surveillance) a fire door on

the specified

frequency

1

i

. -- . - _. _

.. - . - __ --

e

i

e

T5-1

4

4

!

TABLE 5

UNPLANNED REACTOR TRIPS

AND

SHUTDOWNS

vi

Unclanned Reactor Trips

.

Date Description Root Cause

i

December 1, 1985, The high RCS pressure resulted Secondary plant trans-

High RCS Pressure due to a load rejection with fent due to electrical

the tripping of the main grid transient

generator breaker. An over-

excitation protective relay

malfunctioned when a regional

grid voltage transient coupled

r with a relay setpoint drift

occurred

,

January 4, 1936, The turbine trip resulted Random equipment mal-

l Turbine Trip because of an abnormal high function in the second-

4

level in one of six moisture ary plant

i separators due to a level

'

controller malfunction in

<

the feedwater heater drain

collection tank

Unplanned Shutdowns

i

j None

l

I

4

i

1

- , ~_ . - , - - . - , _ - - - . _ - . . :,,..- . . . . . , - , - - _ . _ . , - , , , _ , , , . -, - . - . , _ .,_,,,,_,#.,- ,w

I N

l -

'

T6-1

d

,

s

TABLE 6

RADICLOGICAL EFFLUENT RELEASES

l

Anomalous Occurrences Resulting in Off-Site Releases of Noble Gases

% of Technical

Specifications

Component Release Activity Quarterly

Date Involved Point Released (Ci) Duration Limit, Gamma

10/21/85 Reactor Trip Main Steam 1.07E-6 10 sec 3.8 E-8

at 40% Relief Valves

(MSRV)

10/28/85 Makeup Pump Station Vent 0.7 42 min 0.0015

(SV)

11/2/86 Reactor SV 1.05 75 min 0.027

Coolant

Evaporator

11/19- Main Steam MSRV 1.6 E-7 5 sec 3.4E E-0

20/85 Valve Testing

12/1/85 Reactor Trip MSRV 7.32 E-6 7 min 1.5 E-7

at 75%

12/17/85 Waste Gas SV 1.4 54 min 0.001

Compressor

12/30/E5 Makeup Pump SV 46.3 274 min 0.07

Normal Operating Releases - Predominantly Noble Gases

October 0.15 (0.02% 0.00132

particulates)

November 18.8 (0.0003% tritium) 0.02

December 5.29 0.0076

Normal Operatir.; Releases - Licuid - Predominantly Tritium

. October 1.0 (0.03% non-tritium)

November 1.19 (0.01% non-tritium) I

December 5.99 (4.4 E-3% non-tritium)

l

l

l