ML20138C399

SALP Rept 50-219/85-99 for May 1984 - June 1985

ML20138C399
Person / Time
Site:	Oyster Creek
Issue date:	10/11/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20138C391	List: ML20138C388 ML20138C399
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.3, TASK-TM 50-219-85-99, GL-83-28, IEB-79-02, IEB-79-14, IEB-79-2, NUDOCS 8510220423
Download: ML20138C399 (61)

See also: IR 05000219/1985099

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U.S. NJCLEAR REGULATORY COMMISSION i

REGION 1

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE ,

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INSPECTION REPORT 50-219/85-99 )

GENERAL PUBLIC UTILITIES t40 CLEAR CORPORATION

OYSTER CREEK f40 CLEAR GEtiERATING STATION

ASSESSMENT FERIOD: MAY 1, 19a4 - JUNE 30, 1985

BOARD MEETita3 OATE: AUGUST 20 & 30, 19c5

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8510220423 P51011

PDR ADOCK 05000219

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TABLE OF CONTENTS

Page

I. INTRODUCTION . . .. ................. 2

A. Purpose and Overview . .............. 2

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

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

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

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

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

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

IV. PERFORMANCE ANALYSIS .

............... 10

A. Plant Operations . . . . ............. 10

B. Radiological Controls ........... ... 16

C. Maintenance . .

................. 21

D. Surveillance / Inservice Testing . . . . . . . . . . 25

E. Fire Protection / Housekeeping . . . . . . . . . . . 28

F. Emergency Preparedness ... .......... 30

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G. Security anc Safeguards .......... ... 32

H. Outage Management / Refueling ........... 35

.I. Technical Support ... ..... ........ 38

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J. ' Licensing Activities . . . . . . . . . . . . . . . 42

V. SUPP0;T!NG DATA AND SUMMARIES . . . .......... 44

A. Investigations and Allegations Review ...... 44

B. Escalated Enforcement Actions .......... 44

C. Management Conferences . . ......... ... 44

D. Licensee Event Reports . . . . . . . . . . . . . . 45

TABLES

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

Table 2 - LER Sureary . . . . . .

................ T2-1

Table 3 - Enforcement Sut. mary . .

................ T3-1

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

Table 5 - Inspection Report Activities. . . . . . . . . . . . . . T5-1

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

Table 7 - Plant Shutdowns . . . . . . . . . . . . . ...... T7-1

Figures

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

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1. 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 sampling and periodic basis and to evaluate licensee performance

based upon this information. The SALP is supplemental to normal

' processes used to ensure compliance to NRC rules and regulations. It

is intended to'be sufficiently diagnostic to provide a rational basis

for allocating NRC resources and to provide meaningful guidance to

the licensee's management to promote quality and safety of plant

operations and modifications.

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

August 20 and 30, 1985, to review the collection of performance ob-

servations and data to assess the licensee's 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 the Oyster Creek Nuclear Generating Station for the

period May 1, 1954 through June 30, 1985. The summary firdings and

totals reflect the twelve month assessment period.

B. _SAlc E:ard Perbers

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Chairran

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R. Starostec61, Director, Division of Reactor Projects (ORD)

Yembers

W. Bateman, Oyster Creet Senior Resident inspector

S. Ebneter, Director, Division of Reactor Safety

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R. Gilbert, Oy:ter Crael Licensing Project Manager ( A: ting, Part Time)

J. Joyner, Chief, hMS$ Branch, DRSS (Part Time) i

W. Kane, Deputy Director, Division of Reactor Projects (Part Time)

H. Kister, Chief, Projects Branch No. 1, ORP 1

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

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(Part Time)

J. Zwolinski, Chief, Operating Reactors Branch No.5, Division of

Licensing (Part Time)

Other Attendees

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

J. Wechselberger, Oyster Creek Resident inspector

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C. Background

1. Licensee Activities

The originally scheduled 12 month outage that started in

February 1983 for refueling and plant modifications and repairs,

ended 20 months later on October 29, 1984 when post-outage

criticality was achieved. Major outage activities completed

during this evaluation period included replacement of SRM/lRM

drytubes, refueling, final repairs to isolation condenser piping

welds, reactor coolant system hydrostatic testing, and Appendix

J leakage testing. A major restart certification program was

completed prior to starting up the plant.

Startup testing commenced following reactor criticality and

continued until December 12, 1984 at which time the plant was

of ficially placea on line with the Pennsylvania-Jersey-Maryland

system. During the startup phase, three reactor trips occurred; [

two were unexpected and involved a combination of equipment

problems and operator error and the third was a planned scram

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discharge volume scram test. In addition two unexpected

shutdowns were made to repair electromatic relief valves.

From December 12 until the end of the evaluation period, the

plant experienced two additional reactor trips due to operator

error and equipment problems and had to shut down four times for

various equipment problems. In addition to the four total

shatdo.ns, other rajor power reductions were re0uired to male

equipment repairs. In general plant operations was faced almost

continuously with equipment problems. Despite the continuing ,

problers, honever, the plant did succeed in safely generating

po er at or near full capacity for substantial periods of time.

(See Figure 1.)

Two annual emergency drills were conducted during this

evaluation period. Both were observed to be satisfactory.

Snipmt cf st ent fuel asser.blies f rc,n West bile,, two York

back to Oyster Creek was started and completed without

significant incident. The Post Accident Sampling System was

completed and partially tested,

licensee pipe support inspections resulting from NRC inspection

findings to close IE Bulletins 79-02 and 79-14 continued and

were planned to be completed in October 1985. The licensee's

progra.t to update as-built drawings continues but is anticipated

to take at least two more years to complete.

The licensee completed construction of the new Technical Support

Center, continued construction of a low Level Padwasto Storage

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Facility, and continued with plans to construct an Engineered  ;

Safety System Facility to house additional diesel generators,  :

electrical equipment, control room heating / ventilating i

equipment, and other future safety. systems.  !

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GPUN is upgrading items considered more critical to reliable

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plant operation in a quality control program. Based on QC l

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problems that arose during the past outage, QC is making efforts j

to upgrade their in-house training and to. improve the i

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understanding of Maintenance and Construction personnel as to

OC's function. Additionally, ef forts are underway to understand

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and address problems experienced with subcontractor QC programs. [

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Licensee operator training has been effective as indicated by i

' the high percentage of R0 and SRO candidates who passed the NRC

licensing examinations. Examinations were taken by 8 RO and 3 [

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S D candidates in April 1985 and all passed. To help improve

training, a Basic Principles Simulator was purchased and was [

j being installed at the end of the evaluation period.

2. Inspection Activities

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Two NRC resident inspectors were assigned to the site throughout [

the assessment period. The total NRC inspection hours for the

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14 month period were 3880 (resident and region based) with a l

! distribution in the appraisal functional areas as shown in Table i

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4 This equates to 3326 hours0.0385 days <br />0.924 hours <br />0.0055 weeks <br />0.00127 months <br /> on an annual basis. Tabulations  !

of Inspection A:tivities and violations are presented ir. Tables  !

i 5 and 6, respectively. No team or special followup inspections

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were conducted by NRC inspectors during this assessment period. {

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II. CRITERIA

Licensee performance is assessed in selected functional areas, depending

j whether the facility is in a construction, preoperational, or operational

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' phase. Each functional area normally represents areas significant to

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nuclear safety and the environment, and are normal programmatic areas.

Special areas may be added to highlight significant observations.

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

a functional area:

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1. Management involvement and control in assuring quality

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

3. Responsiveness to NRC initiatives

j 4. Enforcement history

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l S. Reporting and analysis of reportable events

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6. Staffing (including management)

j 7. Training effe:tiveness and qualification

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

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classified into one of three performance categories. The definitions of

j these performance categories are:

I. Category 1. Reduced NRC attention may be appropriate. Licensee

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nuclear safety; licensee resources are ample and effectively used so that

} a high level of performance with respect to operational safety or

l construction is being achieved.

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

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Licensee canagement attention and involvement are evident and are

{ concerned with nuclear safety; licensee resources are adequate and

i reasonably effective so that satisfactory performance with respect to

j operational safety or construction is being achieved.

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

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Licensee management attention or involvement is acceptable and considers

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

be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety or construction is being

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i The $ ALP Board has also assessed each functional area to compare the

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

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

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

follows:

Improving: Licensee performance has generally improved over the last

quarter of the current SALP assessment period.

Consistent: Licensee performance has remained essentially constant

over the last quarter of the current SALP assessment period.

Declining: Licensee performance has generally declined over the last

quarter of the current SALP assessment period.

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! III. SUMMARY OF RESULTS '

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i Functional Category Category Recent i

Area Last Period This Period Trend i

} (February 1, 1983 - (May 1, 1984 - l

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i April 30, 1984) June 30, 1985)

1. Plant Operations 1 2 Consistent

j 2. Radiological Controls 1 1 Consistent !

! 3. Maintenance 2 3 Consistent

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4 Surveillance / Inservice 1 2 Consistent

! Testing

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Housekeeping

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6. Eeergency Preparedness 2 1 Consistent 1

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2 Improving [

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i Refueling

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• 9. Technical Support 2 2 Consistent

10. Licensing Activities 2 2 Consistent

These two functional areas were ccmbined fcr the previous SALP. 1

j E. Overview

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} D4 prier asse:,5 ent period essentially revie ed licensee  !

performance during an entended outage. Management controls and

} performance were focused on plant maintenance and modifications. As

such, the prior SALP reviewed licensee performance under circum-

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stances normally associated with construction activities. This i

j assessment period encompassed the last few months of the outage

transition to start-up activities and about eight months of plant 7

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controlled throup a formal restart certification program.

Nonetheless, several problems occurred during the startup ,

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period and resulted in four unplanned shutdowns. '

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In reviewing overall performance there appear to be several examples

of a lack of effective communication within and among the various

divisions (i.e., operations, engineering support and maintenance).

Although each individual problem may not be an example of poor

communications, it is the cumulative history of problems and our

assessment of the underlying reasons that lead us to conclude that

these problems are not random. Furthermore, several problems

manifested two basic deficiencies: first, although individual

problems were resolved when clearly identified and defined, there

appeared to be a lack of an objective, collective self-assessment

process on-site to analyze the day-to-day activities and to focus

attention on identifying / resolving the underlying causes of problems

and not just the symptoms; secondly, some problems were noted with

technical support activities (e.g. specification preparation,

pre-engineering reviews and vendor design reviews), and this

aggravated the repetitive equipment problems.

As noted above, four unplanned shutdowns occurred. Three were the

result of inadequate maintenance and post maintenance testing, and

one was due to operator error. Equipment problems, generally

reflective of poor maintenance or inadequate engineering analyses,

continued to occur throughout the operating period and resulted in

four additional shutdc.ns. The plant operations staff operated the

plant satisfactorily, in spite of the persistent equipment

problems.

The above problems were more readily manifested as the plant changed

phases since the degree of participation of each crganizational

element was more clearly observed. The coordination and communica-

tion among the various groups during plant operations is not as

effective as when the plant was shutdosn for the outage.

Training and Quality Assurance are specific attributes considered in

the assessment of each functional area. Accordingly each of the

performance analysis addresses them; an overview of these programs

is provided below.

Training

A new Basic Principles Trainer was purchased and installation was

in progress at the end of the assessment period. Initial control

room operator training is offective based on the very successful

results during the NRC licensing esaminations. New training

programs for instrument technicians, equipment operators, startup

test and maintenance personnel have been initiated to address

weaknesses and to upgrade skills of the personnel. Additional

training is also being implemented for fleid and support radcon

technicians as well as the radiological engineering staff. The

degree to which this training is effective will be determined by

observing performance in the forthcoming period. The licensee hat

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not yet completed a self-evaluation of its training program, the

first step in the INPO accreditation process.

Quality Assurance

QA audi' schedules are established and adhered to. QC inspectors

also perform their required inspections. However, although QA/QC

findings are generally perceptive and informative, it appears that

the QA organizational responsibility is perceived to be limited to

the identification of problems. Followup by either QA/QC or manage-

ment is needed to ensure that adequate ard timely corrective action

is taken. Accordingly, QA effectiveness is not being fully realized.

prcblems need to be highlighted and pursued, such that appropriate

and timely resolution can be achieved.

In this regard, for example. 0A audits that focus on very narrow ,

issues detract from management's ability to be aware of broader

problems such as inter-disciplinary communication. Similarly, QA/QC

findings that do identify problems need to be brought to management's

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attention quickly and pursued aggressively.

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IV. PERFORMANCE ANAt.YS!$ j

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A. Plant Operations (31%,1218 hours0.0141 days <br />0.338 hours <br />0.00201 weeks <br />4.63449e-4 months <br />)

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1. Startup Activities i

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Evaluation in this area is based on the licensee's activities

which were witnessed following the completion of outage tasks up

to the point at which startup was completed and the plant was

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operational at essentially full power. Expanded NRC inspector

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coverage was provided during periods of initial reactor

operation.

Management involvement in the preparation for startup was  !

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exceptionally strong. A restart certification process was i

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conducted which verified plant readiness for operation. All

aspects of facility readiness were reviewed, including i

i surveillances, maintenance, n:odif teations, restart I

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certifications, valve checkoffs, plant walkdowns, tagging ,

reviews, etc. Management involvement in the preparation and '

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completion of this program to verify plant readiness for j

j operation was excellent. t

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The licensee developed a " Plant Startup Sequence" designed to

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period. The startup activities were originally planned to occur

over a 24 day period. However, a ramber of unforeseen and un-

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planned problems developed which *engthened the everall startup

I cycle. Ogerator performance wat especially closely observed by

l NRO inspectors during the restart to ensure operator skill had

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not degraded during the 20 m nth outage. No se*ious concerns

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were observed due, in part , to planned operator training during

the startup. The operators n.ade good use of their procedures,

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tions in accordance with procedures. Prior to the performance '

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of certain evoluttens, the procedure that was to be used was  :

reviewed, as were other procedures that might have to De used '

i should any equipment failures occur. The one scram which was

attributed to operator error was not indicative of poor per- i

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i formance and a minor procedure change should prevent a [

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A significant event which occurred during the startup was a I

containment entry without the Group Shift Supervisor's knowledge

or permission. During this entry higher than expected radiation

! levels were encountered. These high radiation levels were due

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' to nitrogen-16 radiation from the main steam Ifnes. The reactor

should have been taken subcritical prior to the entry. This

event resulted from a failure to follow procedures because of a

communications problem between radiological control and plant '

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operations personnel. No overexposure resulted from this event;

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however, licensee management recognized the potential for

personnel overexposure and initiated a detailed review which

included engaging a consultant to assist in the evaluation.

Procedure changes and personnel training were among the

corrective actiens taken.

The operator response to abnormal conditions and adherence to

procedural and Technical Specification requirements were also

verified to be very good. For example, proper operator actions

were taken when the rod worth minimizer malfunctioned, IRM

channels could not be adjusted to meet acceptance criteria, and

electromatic relief valves (EMRVs) failed their operability

test.

Numerous equipment problems made the startup much more difficult

for the operators than it would have been had equipment

performed as erpected. A sampling of the more prominent

equipment problems encountered by the operators which directly

af fected their actions were dif ficulties with the reactor water

cleanup system pressure control valve, problems with all three

feedwater pumps which contributed to a reactor scram, problems

with the mechanical vacuum pump which persisted for several

days, and the failure of two EMRVs to cpen which necessitated a

reactor shutdown. All this equipment was raintained during the

outage and should have been operable.

On many occasions, delays were encountered during the startup

which were due, in large part, to scheduling prcblems, in

particular, scheduling of prerequisites to support testing did

not exist. This resulted in an overall startup test coordina-

tion problem that was exacerbated by lack of management direc-

tion to the shift on watch. On a positive side, management

foresight was evident in assuring operator competence when

training criticalitie; were scheduled for all available opera-

tors. A number of these criticalities were observed by the NRC

and no deficiencies noted.

2. Post Startup Activities

The assessment of post startup plant operations is based on

resident and region based inspection activities. Plant

operations staff performance was observed to be very good.

Plant management, as well as pla:,t staf f, demonstrated awareness

of day-to-day activities and plant status and were involved in

the solution of problems that occurred. Operations management

continues to be a strong attribute. The licensee conducted

daily meetings during which the previous day's events were

discussed. Management personnel are in the plant frequently.

Plant appearance was excellent and reflected a strong commitment

to maintain plant cleanliness on the part of the operations

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department. However, other areas of this report do address

working conditions in the plant. Other significant initiatives

in the Operations area during this assessment period included

improving control room professionalism, reducing control room

nuisance alarms, changing from a five to a six shift rotation,

and aggressively responding to INPO " good practices."

Operations personnel performed periodic reviews of procedures

they use to ensure the procedures reflect current operating

philosophy, recent Technical Specification changes, and design

modifications. This review was in addition to other required

reviews and was a good example of operations management's

concern for quality procedures. The licensee has changed the

onsite safety review process since the last evaluation period.

The present process employs responsible technical reviewers and

independent safety reviewers performing individual reviews to

assess the adequacy of proposed procedures or changes. This

type of safety review process has eliminated the synergistic

effects that result from a group type process, such as the old

p0RC, and does not appear as effective. During the last

assessment period, it was noted this review process took a

significantly long time. Since that assessment the Technical

Specifications were changed requiring a 14-day review period for

temporary changes. NRC review of procedures did not disclose

any major discrepancies; however, one violation was identified

wherein temporary changes to procedures were not reviewed within

time limits specified by the Technical Specifications. In

addition, the inspectors questioned the validity of two changes

that appeared to be beyond the definition of a temporary change.

The licensee is making an effort to minimize the number of

temporary changes to avoid future problems. A problem discussed

in the last $ ALP involved control and accountability of changes

to procedures. This problem was satisfactorily addressed by

requiring that all temporary changes be logged by the control

room group shift supervisor. Three violations for not following

procedures were identified. One involved fa11ere to take the

reactor subtritical during a containment entry (discussed above

under startup activities); the second involved failure to insert

a reactor protection trip signal af ter an associated instrument

had been valved out of service for more than one hour; and a

third involved failure to perform a valve lineup of a portion of

the Core Spray System after modifications were completed. In

all instances, prompt corrective action was taken to address the

concerns and there were no recurrences. Detailed safety system

lineup walkdowns by the NRC resident inspectors disclosed minor

valve and equipment lineup discrepancies involving confusing

electrical equipment terminology and inconsistencies between the

required valve Ifneup position and the valve position shown on

plant P&lD's. The licensee also submitted LER's reporting

several other incidents of failure to follow procedures. These

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procedural violations may be indicative of an adverse trend

regarding compliance with procedures and requires licensee

analysis to determine the validity of the trend.

Some improvement in log keeping was made over the assessment

period but more is needed. Entries are generally sketchy and

instances have occurred where required entries were'not made.

Operations personnel continue to plot and trend various plant

parameters to predict plant performance and problems. This has

proven to be a useful management tool.

Control room behavior and appearance are generally satisfactory,

although the use of the control room as a focal point for taking

lunch orders appears to be a distraction from normal duties and

coald be more appropriately accoraplished by some other means.

Control room professionalism has been upgraded by limiting

control room access, use of dress code to identify key

personnel, and overall management upgrading of control room

behavior.

During this assessment period the plant experienced 5 reactor

trips (one was a planned trip as part of startup testing) and 6

shutdowns (see Table 7), In addition at least 3 major power

reductions were required. These transients were generally the

result of equipment problems and operations personnel generally

performed very well during these periods. One common problem,

however, was control of reactor water level. A review of the

scrams and licensee's post reactor trip review reetir.gs

indicates that feedwater control problems have resulted in two

scrams and complicated the recovery from a third. The licensee

should review operator training and assure reactor water level

control is appropriately addressed.

The licensee's program for conducting post reactor trip reviews

was found to be thorough and effectively implemented. The

program includes shift debriefings, review of various logs and

computer printouts to determine proper operation of equipment,

and tracking of all scram open items. A detailed summary is

prepared by an STA after each scram. The operations department

changed from a five shift to a six shift rotation during this

evaluation period. This has greatly enhanced the ability to

train control room operators and has afforded the day shift

rotation backup support when needed.

Control room operators are confronted with equipment and

instrument problems both outside and inside the control room. A

significant number of deficiency tags are visible in the control

room and serve to indicate problems with both old and new

control room instruments. Many old problems remain unsolved,

e.g., electromatic relief valve operation, inadequate control

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room instrumentation, drifting instrument setpoints, erratic

nuclear instrumentation, cooling water intake problems during

both the winter and summer, erratic Augmented Offgas System

operation, tripping mechanical vacuum pump problems, and various

HVAC problems. Inadequate benchmarking of the Power Shape

Monitoring System used to determine core thermal parameters

resulted in the plant exceeding MAPLHGR limits. In addition,

the facility Technical Specifications have, on a number of

occasions during the assessment period, been noted as being

difficult to interpret or ambiguous. Examples are diesel

Technical Specifications during shutdown, EMRV testing pressure,

and EMRV accoustic monitoring criteria.

The ability of plant operations to safely operate the plant and

respond to plant transients in light of the many problems they

face is indicative of good management screening to select

capable individuals as control room operators and a good

training program. This is evidenced by the results from the

last NRC Operator Licensing Examination in which 8 R0 and 3 SRO

candidates were successful. Continued mantgement attention is

' needed to upgrade plant equipment and to upgrade the quality of

procedures and personnel involved in modifications, repairs,

maintenance, and surveillances.

Summa ry

All facets of plant operations have performed well during this '

assessment period. An otherwise. excellent startup was marred by many

equipment problems due, in part, to inadequate licensee supervision

of contractor maintenance activities and management's failure to

prepare and provide clear instructions to operations personnel as to

what was to be accomplished during each shift. Training is a strong

point and needs to be used to improve operator control of reactor -

water level during transient events. Efforts must continue to s

replace or repair defective plant equipment' items to minimize operator

distractions. Control room log entries need to be improved ~both in

quantity and quality. Efforts to improve clarity of, and adnerence

to, procedures should continue. Improvement in assignment of respon-

sibility and in communication between operations and the other divi-

sions of GPUN would significantly contribute to improved account-

ability.

Conclusion

Category 2 - Consistent

.

.

Board Recommendations

Licensee:

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' Licensee should condact reviews of the control room environment

4 and procedural adherence.

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Administrative controls should be established to specify proper

control room job performance.

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An evaluation should' be conducted to review procedural

adherence. ,

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Evaluate effectiveness of the'new onsite safety review process

as compared to the old.

-

NRC:

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The NRC will schedule a meeting with the utility to discuss

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adverse trends and licensee' evaluation of these areas.

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The staff will conduct a review of the safety review function,

QA interface, and other third party audits.

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16

B. Radiological Controls (11*., 424 hours0.00491 days <br />0.118 hours <br />7.010582e-4 weeks <br />1.61332e-4 months <br />)

The licensee's performance has remained consistent relative to the

previous assessment period. Three violations were identified during

this assessment period, two of which resulted from insufficient

communications between dep'artments and a lack of procedural guidance.

However, the licensee promptly responds, evaluates and resolves

problems with generally effective actions.

There were seven inspections performed in the area of Radiological

Controls during the assessment period by region-based inspectors.

Licensee activities in Radiation Protection, Radioactive Waste

anagement, and Effluent Monitoring areas were inspected. The

resident inspectors reviewed ongoing Radiological Control activities,

including receipt of spent fuel in the TN-9 Cask from West Valley,

New York.

1. Radiation Protection

Inspections of the Radiation. Protection area focused on the

licensee's organization, personnel selection, qualification and

training, external and internal exposure control, and facilities

and equipment. The organization and staffing review indicated

that the licensee's radiation protection organization provided

effective control of radiation protection activities. Licensee

management is committed to effectively reducing radiation

exposure. This is evidenced, for example, by the licensee's own

report, " Review and Report of Rad Control-Experience During the

Oyster Creek Outage." The licensee's management provided

recommenda.tions on methods that should be implemented during

subsequent outages to conform with the corporate ALARA program.

Also the l_icensee's action taken to investigate and resolve

.

issues related to an event in which two individuals made

apparent false statements to NRC inspectors indicated effective

management oversight. Licensee management-took swift action,

conducted two extensive investigations, and provided the results

of their ef forts within four business days. The licensee's

responsiveness to NRC concerns in this area has been prompt and

thorough. Final NRC action relative to this event is still open

pending completion of a NRC investigation.

A review of the personnel selection, qualification, and training

activities indicated that formalized training programs are being

implemented for Field Radcon Technicians, as well as Support

Radcon Technicians. The licensee has also implemented a

formalized training program for the Radiological Engineering

Staff-members. Positions were adequately staffed and vacancies

were filled with experienced individuals in a timely manner.

Significant effort is devoted to' filling vacancies. For

example, thirty candidates were interviewed for a radiological

engineering position.

( _ _

_ _

.

.

17

The licensee's internal and external exposure control programs

reflect licensee management's commitment to effectively reduce

'

radiation exposure. The licensee has installed a computer based

system to track real time exposure status which will prevent

entry into an area if available exposure limits would be

exceeded. Computer assisted records management systems are used

to track calibration data for all Health Physics site instru-

mentation. Although this SALP assessment period included an

extended outage, no overexposures were incurred and no indivi-

duals received a maximum permissible concentration that required

tracking or any further action. The licensee has implemented an

adequate whole body counting program. The licensee made accept-

able measurements of the NRC whole body counting phantom con-

taining radioactive sources traceable to the National Bureau of

Standards. The licensee also has an effective whole body

counting QA program.

Two violations were identified in this area: failure to follow

procedures with regard to wearing the correct range self reading

dosimeters and entry into containment while at power. The entry

into containment resulted from poor communications between

operations, radcon, and maintenance personnel. The licensee's

,

'

responses to these items were timely. The communications and

coordination problem is, however, representative of the type of

interdepartment problem discussed in Section III, Paragraph B of

this assessment.

The licensee's incicent reporting system' receives senior level

management concurrence. Corrective actions include a critique

of the incident with all personnel involved. The licensee

corrects these' program weaknesses in a timely manner to enforce

strict conformance to radiation protection procedures.

The licensee's respenses to an increase in skin contamination

incidents was thorough. The licensee surmised that the increase

in skin contaminations was caused from insufficiently laundered

protective clothing. By instituting surveys of all protective

clothing and routine sampling of clothing storage bins, as well

as an audit of the laundry vendor, the problem was resolved.

Another exemple of the licensee's radiation protection control

and timeliness was evidenced in the handling of-the Augmented

Offgas Building sump pump pipe leak. Onsite excavation included

removing contaminated soil and preventing an environmental

,

' release during the excavation. Comprehensive _ radiological

controls of the area were immediately established, including

changing the boundary of the Radiation Controlled Area (RCA).

The contamination was' identified and packaged as low level solid

radioactive waste. Failure of the scram dump volume discharge >

valves to isolate during a scram from full power operation  ;

resulted in airborne and surface contamination in a limited

l

!

1

_. . - .-

.

. 18

i

portion of the reactor building. 'Radcon personnel reacted I

quickly and effectively to control reactor building access, l

evaluate the extent of the contamination, and clean up after the

event. ' Management dedication to maintaining radiological

cleanliness is emphasized by a program whereby an independent 6

onsite radiation protection auditor continuously inspects radcon

activities and reports results of these inspections to the Vice i

President of Radiological Controls. .This program audits various

aspects of onsite radiological controls and-is not limited

specifically to cleanliness. It has proven to be an effective

management tool in maintaining high levels of performance in the

radcon department.

2. Radioactive Waste Management

The licensee is implementing an effective radioactive waste

management program. - The. responsibilities and functions of the

radwaste organization are adequately described in a licensee

administrative procedure. Licensee personnel at all levels in

the radwaste organization are very knowledgeable with regard to

their functions and responsibilities within the organization.

This appears to be the result of a good training program which

is applied to all the staff and results in a clear understanding

of work responsibilities.

'

A review of lic'ensee audits of the ra'dioactive waste management I

area indicated that appropriate radioactive waste management

program elements were audited ~and timely action was taken by the

licensee to resolve most audit findings. '

Major efforts and progress have been made in the'radwaste volume

reduction area during this assessment period. Significant

reductions in compactible and liquid-waste have been made by the l

use of an ensite mobile decon lab and a program to make onsite

-

personnel aware of the radwaste disposal program and to educate

them in work practices th'at create less radwaste. Accurate

tracking of su p and storage tank levels has also contributed to '

reducing liquid radwaste.

The licensee has also~ initiated a dry active waste (DAW) sorting I

program to minimize solid radioactive waste. This program may

reduce the licensee's radioactive waste shipments by one half.

Licensee attention ~is needed in the area of correcting or

removing older radwaste equipment which is inoperable or no

longer in service. For example, radwaste operators had been i

recording' erroneous data from tank level indicators that were

out of service, even though the tank level was controlled -

procedurally,

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.

, 19

No routine transportation inspections were conducted during this

assessment period. Detailed inspections were conducted to

observe and review licensee actions taken upon arrival of TN-9

casks containing spent fuel from West Valley, New York. The

licensee was unsure about the use of smear efficiency procedures

to inspect for surface contamination upon receipt of the TN-9

'

cask both at West Valley and Oyster Creek. This caused problems

with initial shipments in that smear surveys indicated high

levels of contamination that. required NRC notification. Another

utility had developed smear efficiency procedures to a_ddress the

problem. Oyster Creek management was aware of these procedures

before their shipments started but did not utilize this

experience.

The licensee should net be reluctant to benefit

from other industry experience.

Two significant events occurred during TN-9 ha'ndling operations

at Oyster Creek. One involved accidental spraying down of

personnel with contaminated water and the other inadvertent

contamination of the TN-9 cask cooling fins. Both of these

events resulted from worker inattention to details of their job.

Corrective action to prevent recurrence of the. individual events

was prompt and effective, however, the licensee needs (o address

the issue of worker inattention to job details. Two violations

were identified during TN-9 inspections and involved failure to

maintain removable contamination on the external surface of the

i

cask to less than 220,000 dpm/100 cm2 These violations were of

niinor sa f ety significance and not indicative of a programmatic

breakdown and, to some extent, these violations were outside the

direct control of the licensee. The licensee's response to

these vio1ations was viable and thorough.

3. Effluent Monitorinc and Controls

During the assessment period the inspections of the effluent

monitoring and controls program focused on the licensee's

chemical and radiochemical measurements program and effluent

monit: ring, cor. trol, and release reporting.

The chemical and radiochemical measurements program reviqw

indicated the licensee's commitment to maintain a strong

chemistry department. The licensee is maintaining excellent

management control over this program area through the use of in

house audits, daily inspection of the chemistry laboratory,

management observations of sampling and analyses, and daily

review of chemistry data. Licensee action on previous NRC

findings in this area has been viable and thorough.

Capitol improvements were made in the chemistry department and

include a new chemistry laboratory and new instrumentation'and

analytical equipment. Part of the improvements include the

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.

.

. 20

Post-Accident Sampling System and the stpport equipment

required to analyze associated samples. Reviews of rewritten

chemistry procedures determined them te be high quality.

Completion of these major improvements demonstrates manascments'

commitment to upgrade a significant area of plant operations

that was previously weak.

The licensee has a good laboratory QC m 3nm, both for

radiological and nonradiological cheatstry This ensures that

the licensee not only adequately quantifies effluent releases,

but controls the quality of these ef fluent measurements. The

licensee's program for monitoring and control of effluent

releases is effective. The licensee has met all Technical

Specification sampling and analysis requirements as well as

effluent release requirements and all reporting requirements.

The problem discussed in the previous SALP involving a need for

increased attention to the overall integrity of the Standby Gas

Treatment System (SGTS) was partially addressed by the licensee.

Based on a LER review, the licensee still has problems.in this

area but has made some improvement. No unplanned releases to

the environment were made.

Summary

The radiation protection organization provides an effective control

of radiation protection activities and has taken a number of measures

to ensure high levels of performance. The training program continues

to be a positive aspect of the radiological controls organization.

The licensee has implemented a computer based system for exposure

control and an effective whole body counting and QA program.

Corrective action to identified problems has been timely and

effective. An effective radwaste management and radwaste volume

reduction program have been implemented. Some problems arose from

the TN-9 transportation activities resulting in violations. The

chemistry program continues to be a positive contributor. Major

efforts to upgrade the chemistry facilities serve to demonstrate

management initiative to continually improve Oyster Creek. The

radiological controls organization continues to perform well despite

adverse conditions.

Conclusion

Category 1 - Consistent

Board Recommendation

None

b

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

.

. 21

C. Maintenance (12%, 481 hours0.00557 days <br />0.134 hours <br />7.953042e-4 weeks <br />1.830205e-4 months <br />)

This area was under review by the resident inspector throughout the

assessment period. In addition region based inspection was conducted

to examine post maintenance testing and licensee' response to Generic

Letter 83-28, Salem ATWS. Also, significant information was obtained

during a review of maintenance activities which was conducted as a

result of numerous equipment failures during the startup.

. Maintenance at Oyster Creek is performed by the Maintenance and

Construction (M&C) Division which reports to the Vice President M&C

located at the corporate office. Plant operations initiates

maintenance requests to the onsite M&C organization to have repairs

made. This'provides plant operations an input into setting the

priorities for equipment 'to be repaired. The functional organization

present at Oyster Creek requires close coordination and communication

between M&C, plant operations, plant engineering, and technical

' functions to be effective. In an effort to achieve this

communication and coordination, daily planning meetings among the

various functional groups present onsite are conducted to review

. plant problems and review the status of plant maintenance items. On

occasion during the plant startup, it appeared that this close

coordination between M&C and plant operations was lacking. This

became evident during the electromatic relief valve (EMRV) repair

activities.

The Maintenance and Construction division reorganized in October 1982

and continues to change to respond to identified needs. The job i

supervisors were recently organized to allow them to more closely

follow contractor activities during an outage. A management task

force had identified contractor performance and other outage problems

as a result of their evaluation of outage activities. One. ,

significant area of management concern has been the number of

maintenance tasks requiring rework. Significant problems have been  ;

' experienced with the electromatic relief valves (EMRVs), a manual

feedwater isolation valve located in the drywell, and the feedwater ,

pumps, all which were worked during the outage and subsequently

reworked after the outage. The amount of rework to maintenance

tasks is indicative of the need to improve the general quality of '

work and knowledge of maintenance mechanics and the direct field

observation and verification of work activities by first line ,

'

' supervision. Three LER's were reported during the assessment period i

that reflected poor workmanship. Management has failed to take

adequate corrective action in addressing these problems as they were ,

also identified as concerns in 1982 in the Syttematic Assessment of

Licensee Performance.

The licensee is presently developing a training program for

maintenance mechanics to improve their skills. Inadequate drawings 3

and technical manuals have been a hinderance to the maintenance

work-force's ability to accomplish a job in a knowlegeable and timely

- -

. . _ - . . _ ,-.-

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

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

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22

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. manner. The licensee is attempting to solve this problem and has

.

formed a vendor manual and documentation group to correct this

deficiency.

,

, Control and planning of maintenance activities.are conducted in

!

!

accordance with detailed procedures. However, plant administrative

, controls place *.he responsibility for post-maintenance and functional

j

operability testing on the job supervisor and the Group Shift

j Supervisor, respectively. In both cases there is no procedure to

provide generic guidance on what appropriate testing should be. The

j. licensee has recognized this problem and, in conjunction with their

. ATWS task force findings, are developing a program to strengthen the

, post-maintenance functional and operability testing programs.

!

! Post-maintenance testing is being addressed as a high priority item

i

by the M&C and plant operations divisions at Oyster Creek.

Inadequate. post-maintenance testing has been a=significant problem

i impacting plant operations. The initial plant startup experienced

significant delays as a result of EMRV problems which could have been

,

avoided if the proper post-maintenance. testing had been conducted.

Additionally, feedwater pump problems resulted.in a reactor scram

i during the initial plant startup period and a gland exhaust discharge

[~

valve was installed 90 degrees of.f normal resulting in the valve

being shut when it indicated open. These events also were attributed

-

to inadequate post-maintenance testing. Some of these-problems could

'

have been avoided had steps beer: incorporated in the procedures that

had been previously accomplished by experienced personnel but not l

) proceduralized. For example, in the past, experienced mechanics '

}* conducted a leak / actuation test of the'electromatic relief valves

(EMRV's) with nitrogen, but this test was not proceduralized. Had

j

'this been incorporated into the EMRV maintenance procedure,

significant EMRV problems could have been identified and corrected

1

prior to plant operation.

The licensee investigated a problem with the feed flow

l instrumentation and concluded that troubleshooting of the

instrumentation was not conducted exactly in accordance with plant ~

,

procedures, that~ technical guidance could be improved, and that

j post-maintenance testing was inadequate. 'Also, during this period a

number of instrumentation problems were experienced in the control

i

' room, including reactor vessel level instrumentation, recorder

overheating, and intermediate range monitoring (IRM) nuclear '

I: instrumentation problems. IRM spiking problems have been experienced ,

<

1

by the facility since the initial reactor startup following the i

outage without resolution. Half-scrams have occurred as a result of  ;

i

IRMs spiking, the most significant occuring when ranging from Range

j 6 to Range 7. The licensee has been investigating this generic

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.

23

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problem but without resolution. Based on this and many other

instrument problems, the licensee has initiated an extensive training

program for its instrumentation and control technicians. The program

consists of classroom instruction and on-the-job training.

,

The electromatic relief valves (EMRV's) have been noteworthy during

this assessment period as a significant contributor to plant shutdown +

time. (See Table 7) During the initial plant startup after the 20

month outage, the EMRV caused numerous delays in the plant startup

schedule. The licensee's investigation of the EMRV inoperability

revealed that steam leakage past the retainer threads caused the

valves to malfunction. This problem had been experienced by other

nuclear utilities and seal welding of the retainer. resolved the

problem. Had industry problems with EMRV's been evaluated prior to

the EMRV overhaul conducted during the outage and had an adequate

diagnosis of the problem been performed, two facility shutdowns could

have been prevented. Also, during the Feb.ruary shutdown period,

EMRV flange leakage was discovered to be a significant

contributor to high drywell unidentified leakage. After several

attempts to correct'the leakage by changing gaskets and varying

torque values on the flange bolts, the problem was finally corrected

three weeks later when corrosion of the gasket seating surfaces was

removed by machining. This is significant considering that the

EMRVs were overhauled during the cycle 10 outage and may indicate .

lack of contractor control during the outage. On March 5 the EMRV's

were successfully tested af ter a month shutdown. The EMRV inlet

flange leakage problems were indicative of a lack of structured

evaluation and poor communications.

Preventive Maintenance (PM) is managed by a separate group from '

Maintenance and Construction Division under the cognizance of the

Plant Materiel Department in the plant Operations Division.

Administrative controls are well defined and provide acceptable

controls for the conduct of the PM program. There is a full time

dedicated manager with a staff. Personnel are assigned from M&C to

perform preventive maintenance and surveillance on electrical, '

rechanical, instrumentation and control, and fire prot ction systems. '

Significant ef fort has been expended on the snubber ard plant

equipment oil sample PM programs. ~Among the documentacion reviewed '

for failure trends are short forms (work requests) and equipment

history cards. Failure trend reports provide a statistical listing

of problems and provide recommendations where appropriate. A

comprehensive vibration monitoring program for various pieces of

rotating equipment other than that covered by the IST program is also

being conducted. In addition the licensee is currently evaluating

' the implemqptation of an extensive computer based maintenance '

tracking system.

Quality Assurance involvement in the maintenance process was.

_

demonstrated by quality control hold and witness points of in

,

,

,

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

.

. 24

progress work and quality assurance department observation of various

maintenance activities. A concern did develop during the assessment

period with M&C bypassing QC holdpoints and performing safety-related

work prior to QC awareness of the work activity, thus precluding QC

from establishing holdpoints. This was the subject of a Quality

Deficiency Report (QDR). M&C's lack of responsiveness to the QOR was

the cause of an NRC violation. Management attention appears

warranted to improve responsiveness to QA/QC program requirements.

Summary

In general, considerable improvement has been made by the licensee

during the last several years in the conduct of maintenance as

regards documentation reviews and the establishment and performance

of preventative maintenance. Hosever, based.on significant amounts

of rework, conduct of maintenance in the areas of workmanship, first

line supervision, feed back to engineering, knowledge of the job,

contractor supervision, and post-maintenance testing needs

significant management attention to correct declining trends in these

important areas. In addition communication with and responsive to

QA/QC requires improvement at all levels of onsite M&C management.

Conclusion

Category 3 - Consistent

,

Board Recommendations

NRC:

Establish a formal action plan to verify progress / status in the

mairtenance area. Schedule a management meeting to review results

of licensee assessment.

Licensee:

Cerduct an assessment of the maintenance area and dis;uss results

with NRC.

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

-- -

..- . - . _.

.

.

25

t

D. Surveillance / Inservice Testing

This assessment is based primarily on the inspection of the

surveillance test program by the resident inspectors and. inspection  ;

of the Containment Integrated Leak Rate Test by a region based '

inspector.

The routine observation and review of surveillance test

activities has determined that, generally, surveillance tests are

performed at the required frequency and in accordance with approved

,

procedures.

The scheduling of Technical Specification surveillances is governed

by a Master Surveillance Schedule. The surveillance test program i

specifies responsibilities of individual departments for performance ,

and review of surveillance tests and test data. Operability criteria

are not specified in the Technical Specifications but are included in

i

the plant surveillance-procedures. The criteria specified in the

i

.

procedure sometimes includes additional criteria that would not.  !

, normally be considered for acceptance. This has led to applying.

ambiguous operability requirements to equipment. . Additional licensee

,

attention in defining acceptable operability criteria in the

i surveillance procedures appears warranted,

j

During this assessment period the facility status changed from being

in a prolonged maintenance and refueling outage to again becoming an

operating plant. .The preparation for startup and the startup

activities were closely monitored with extended NRC inspection

coverage. During this extended coverage, the satisfactory

performance of many surveillance tests was witnessed. With few

-

exceptions, the surveillance test procedures were noted to be  !

l sufficiently detailed to provide an adequate test. In addition, test

'

l personnel performance was good.

'

The licensee is generally responsive to NRC concerns. During a fire

protection inspection conducted prior to startup, it was noted there

,

was no program to inspect and test heating, ventilating, and air

conditioning duct work fire dampers. The licensee developed a .

!

! program, prior to startup, for surveilla ae testing and inspection of

3

the dampers. {

i

1

During this assessment period an-inspection was performed of the

1 I

Containment Integrated Leak Rate Test (CILRT). This inspection

determined the licensee had made.a concerted effort to improve all

,

,

!

i

aspects of the containment leakage testing program in response to

previously identified NRC concerns regarding test control and

procedural compliance. The procedure was vastly improved as compared ,

to procedures used during previous CILRT's. The licensee has also  :

made a number of changes to existing containment isolation valve

penetrations to allow proper Appendix J leak testing of these valves.

Upper management and QA have paid particular attention to the

,

}  ;

improvement of the containment leakage program over the past two  !

years. QA input to the program is both technically and t

I

!

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

__- , , , . - ,

--

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

.

. 26

administratively comprehensive. The licensee has also resolved

previous NRC concerns regarding the proper reporting of leak rate

testing results which exceed Technical Specification acceptance

criteria.

One violation was identified during the assessment period and

resulted from maintaining a reactor low water level instrument out of

service during the performance of a surveillance test for greater

than one hour per month as limited by the Technical Specifications.

The violation was attributed to personnel error on the part of both

control room personnel and instrument technicians. The licensee has

taken thorough corrective action which includes pursuing a Technical

Speci.fication change permitting more instrument out-of-service time.

Also, an " Equipment-Out-of-Service Sheet" has been incorporated into

each applicable procedure. This violation could have been avoided

had adequate corrective' action been taken in a previously reported

event of similar circumstances.

The licensee properly identified and reported events associated with

surveillance testing. During the assessment period, ten Licensee

Event Reports (LER's) associated with surveillance testing were

reported. Six of these occurred during the startup and operations

periods and the remainder during the outage. A number of the LER's

were attributed to personnel error. The most frequently noted cause

or contributing factor identified in the LER's was the interface

problems between various groups such as operations, maintenance,

surveillance, etc. Another contributor to the cause of the LER's

appeared to be a lack of detailed procedure reviews on the part of

individual reviewers. For example an extensively modified procedure,

consisting primarily of hand written steps in the margins, was very

difficult to follow and, as a consequence, led to inadvertent

initiation of the Core Spray system. In another case Technical

Specification changes were not incorporated into a surveillance

procedure to verify cegraded grid voltage protection. Management

makes detailed reviews and analyses of each reported event with the

more significant occurrences receiving formal critiques. Effective

and timely corrective action is taken as indicated by no repeat type

LER's having been noted during the assessment period.

Sufficient personnel are available to carry out the surveillance test

program and management responsibilities are clearly defined. In one

instance, during the review of a feed flow instrument calibration, a

lack of experience on the part of the I & C technican was noted. The

licensee is aware that the many new instrumentation technicians lack

the necessary plant experience to be totally ef fective. To improve

technician performance, on-the-job training has been initiated and a

formal training program developed where none previously existed.

The licensee has established an inservice test program which is

administered through a detailed procedure. This inservice test (IST) _

i

(

!

t

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

.

l

.

• 27

i

l

program was significantly delayed in its implementation and has been

the subject of previous NRC violations and extensive licensee

4

documentation describing the delay in implementation. Inservice

,

testing was initiated late in 1982, and delays in implementing the  ;

. program have limited the amount of inservice test data accumulated. '

, In one instance, more accurate data has not been obtained for the

, Emergency Service Water pumps due to delay in installation of IST

j flow instrumentation. In general IST data is accumulated and ,

evaluated; however . increased attention to the program is needed to 1

,

make it totally effective. Results of inservice testing has not'yet i

been incorporated into the preventive maintenance program.

Summary

f

l Several problems exist that have resulted in declined performance  !

-since the last SALP period. These problems include ambigous

operability criteria in surveillance procedures, weak communications l

.

interface between other supporting groups, inexperienced I&C

[ technicians, ineffective corrective action to address a NRC finding, i

,

j and inadequate procedure reviews.

1 It was also observed during this assessment period that the licensee [

continued to meet their master surveillance schedule and improved [

j both the CILRT test procedure and test' performance. '

.

Conclusion k

1

3

Category 2 - Consistent

I

9

Board Recommendations

!

(

The licensee should make an effort to clarify safety-related  !

i equipment. operability criteria contained in the surveillance

!

p*0cedures, take steps to assure correcthe action is permanent,

-

j i

. improve quality of procedure reviews, and continue with formalized i

training of I&C technicians.

5 {

'

,

i

b l

0

!

f i

I

.  !

l

.

I j

i  ;

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i

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!

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

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

.

' 28

E. Fire Protection / Housekeeping (3%, 104 hours0.0012 days <br />0.0289 hours <br />1.719577e-4 weeks <br />3.9572e-5 months <br />)

Fire Protection activities have' generally been effective at Oyster

Creek as evidenced by the small number of fires reported. The most

significant fire damage resulted from poor workmanship when

'

electricians neglected to remove grounding straps from inside a

breaker after completing their work. Minor fires from weld spatter,

a faulty portable heater, motor shorts, and other electrical i

grounding problems were promptly extinguished with no serious damage

to the plant. Problems with the. fire main occurred twice when an

i

4

underground pipe leaked and when a truck backed into and damaged a

post indicator valve. These problems were satisfactorily addressed  ;

' and the Technical Specification impact on the Core Spray System was  !

minimized. The fire diesels have experienced continuing mechanical r

problems and management action to address and correct the problems

has not been effective. L

3

ine licensee utilizes fire retardant lumber and other materials in

~t he plant to minimize combustible materials. The fire brigades are

4

well trained and periodic drills involving onsite participation from

community fire companies results in a high degree of readiness for

effective fire fighting. The in plant deluge system was activated  ;

' during a scram recovery when steam and smoke from blistering paint .

activated a smcke detector. Activation of the system resulted in '

i

spraying down safety-related equipment and the declaration of an

Unusual Event because the operability of the wetted down i

i safety-related equipment was in question. The fire protection system  ;

j

performed as designed but did have a potential impact on the  ;

operability of safety related-equipment,

i

Corrective action for a fire watch violation was prompt and '

effective. It involved both the restoration of the fire watch and

t

explanations to the responsible personnel of the need for effective

fire watches. Management was responsive to NRC initiatives as '

demonstrated by their willingness to revise or issue new procedures >

governing fire protection hardware and their prompt reaction to seal

peretrations when a problem was identified. Overall the licensee's  !

..

fire protection staff demonstrated a clear understanding of fire  !

protection issues and familiarity with plant fire protection systems,

t

i

.

Housekeeping was a problem during the outage. Upon completion of the [

outage, housekeeping drastically improved and remained at an

acceptable level throughout the assessment period. 'The improvement

,

!

can be attributed to a decrease in the amount of work activity in the

,

plant and a management commitment to clean up the plant and keep it  ;

! clean. The use of new high efficiency vacuum cleaners to remove con-

>

taminated dust from overhead pipe, cable, and ductwork are available l

.

to further improve plant cleanliness. Very little graffiti is  ;

4

evident in the plant. '

I

h

l t

i i

I

i

I

-

-_ _ - - . -_. _ _

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

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

_ _ _ _ _ _ _ ,

e

. 29

There is a problem with craft personnel in that they do not feel

cleanup is part of the job. This has resulted in occasional lapses

in housekeeping that were quickly identified by operations management

during their frequent tours of the plant.

Despite efforts to clean up the refueling floor area, it is still the

location of a lot of unused contaminated hardware. Some housekeeping

problems around the refueling bridge were noted during the outage.

Management should continue their refueling floor cleanup activities

and maintain the' area off limits for radioactive material storage.

Radiological housekeeping, as measured by the amount of recovered

contaminated surface area, has been effective in improving and

maintaining access to most areas of the plant.

Co~nclusion

Category 2 - Consistent

Board Recommendatiorj

Licensee:

Evaluate the conflict in fire protection and safety system

--

objectives especially as to the effectiveness of installed spray

shields and ability of safety-related equi; ment to operate when

wet.

--

Efforts should be made Ly all onsite management to make cleanup

a part of every craf tmun's job.

--

Continue refueling floor cleanup activities.

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

e

, 30

F. Emergency preparedness (15%, 571 hours0.00661 days <br />0.159 hours <br />9.441138e-4 weeks <br />2.172655e-4 months <br />)

J

During the assessment period there were four routine inspections of

'

the emergency preparedness program. On May 10, 1984 a full scale

exercise was observed by a NRC team which identified 16 areas

.

requiring additional licensee attention. These areas included

deficiencies in communication, EOF environmental data coordination

and presentation, and licensee / external agency interfaces.

On May 21-23, 1984 a review of the Emergency Plan was conducted to

determine compliance with 10 CFR 50, Appendix E requirements and

! NUREG-0654 criteria. The review identified deficiencies in the areas

of the licensee's onsite emergency organization, Emergency Action r

Levels (EAL's) for classifying emergencies, public information, and

accident assessment. The licensee committed-to making appropriate

changes to the Plan and Emergency Plan Implementing Procedures. On

February 4-8, 1985 an unannounced followup inspection was conducted *

to review the status of open items, inspect the emergency training

program, and determine the readiness of emergency response facilities

for appraisal. The inspection revealed adequate responsiveness to

NRC initiatives and acceptable resolutions of problem areas. The

inspection also revealed one deficiency in the emergency training

! program and one deficiency in the audit program which were to be

reviewed by the licensee for possible corrective action.

On June 4,1985 a partial participation excerise was observed by a

NRC team which revealed no recurrence of previously identified items

'

and only minor deficiencies for possible corrective action. These

deficicacies included weaknesses in the scenario, communications

problems' tetween the control room and the TSC and OSC, and lack of a

,

comorehensive understanding of plant conditions at the TSC. These

i

deficiencies were not unique to the June 4 drill and were also

l evident during prior practice drills. Observations of the critical  !

l

! areas of emergency preparedness indicated an adequate emergency

response by licensee personnel. Prior planning and assignment of

priorities were evident and controlled and explicit procedures for ,

1

,

contrcl of activities were implemented during the excer.ise scenario. '

1 i

The June 4, 1985 drill excerise objectives and scenario packages were  :

,

submitted in a timely manner allowing adequate time for NRC review. .

Appropriate changes were made by the licensee to satisfy NRC

! concerns. Throughout both excerises, corporate management was

involved.in site activities. Decision making and recommendations for

.

' I

protective measures to the public were appropriately channeled

through upper-level management. The NRC team noted that throughout {

the conduct of excerises, procedures and policies were adhered to, t

Protective action recommendations made during the simulated emergency  !

were accurate and exhibited conservatism when the potential for a '

degradation of safety existed.

t

>

!

l

{

i

I

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

, ._ - _ -

e

, 31

A major change took place in the licensee's emergency planning staff.

The position of Emergency Preparedness Manager became vacant and was

filled on a priority basis by a qualified individual. Another major

change involved activation of the new Technical Support Center (TSC).

The new TSC, although not within the site protected area during the

June 4, 1985 drill, was a big improvement over the old TSC. 'It has

more room and is more functional.

Summary

NRC inspections during this assestment period concluded licensee

performance was satisfactory and that, within the scope and

limitations of their accident scenarios, they are capable of

implementing their Emergency Plan in a manner that would adequately

protect the health and safety of the public.

Conclusion

Category 1 - Consistent

Board Recommendations

None

a

--

__ .

y ,

l

'

. 32

G. Security and Safeguards (5%,186 hours0.00215 days <br />0.0517 hours <br />3.075397e-4 weeks <br />7.0773e-5 months <br />)

j

One routine and one special unannounced physical security inspection -

were conducted during this assessment period by a region-based

inspector. Routine inspections by the resident inspectors continued >

throughout the assessment period. Six Severity Level IV violations

were identified. Three of the violations resulted from a regular

plant employee's failure to report the loss of his photo 10 badge and i

card key. The performance of the security force in dealing with the

incident indicated shortcomings in implementation of the access

control program. These shortcomings involved failure of security i

personnel to be attentive to their duties,'as prescribed by l

procedures, and reliance by the licensee on a customary practice '

which was not documented in a procedure. l

.

During the previous assessment period, instances of inattentive

guards were noted. An additional four instances of inattentive i

,

guards were identified by the licensee during the current assessment

period. The licensee took prompt, well publicized, action to correct

this situation, including disciplinary measures. However, the

continued identification of such instances, combined with security

force performance shortcomings identified in the access control

incident described above, indicate a need for further evaluation by

licensee management to identify and correct the root cause(s) 'of f

these problems.

Six security events were reported in a timely manner during this I

assessment period. Corrective actions to date appear to have been *

effective. ,

!

.

A management meeting was called by Region I to review the

circumstances related to the lost badge incident, including the

licensee's failure to report the security aspects of the incident.

While the incident received reasonably prompt and comprehensive

attention by site and corporate security management after it was

brought to their attention, it was not reported to the NRC in

accordance with'NRC regulations. The licensee attributed the failure

to report to a misinterpretation of the reporting requirements. (

Based upon the licensee's previously good history in promptly ,

reporting security events and the circumstances of the incident, '

Region I considers the licensee's explanation to be plausible.  :

However, licensee management should be attentive to what may require .

reporting and to contact the NRC Regional Office when questionable  !

situations arise. ,

The incident described above not withstanding, the effectiveness of  !

the security program was significantly enhanced during this i

assessment period. This is attributed to increased site and  !

corporate security management involvement in the program. Corporate

management was noticeably more involved in planning, and worked i

n t

!

f

'

i

' I

'

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

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

. 33

closely with site management and security supervision to plan,

provide for, and improve the program.

Routine monthly meetings were held between corporate and site

management to discuss and resolve identified problem areas. In

addition, corporate management visited the site on several occasions,

-

including off shifts, to review security force activities. This

resulted in an effective demonstration of increased management

attention to the overall security program. A new corporate

position, Nuclear Security Director, was established a few months

before the beginning of this assessment period. Creation of this

'

position has narrowed the scope of the incumbent's responsibility to

that of nuclear security only, where as, previously, the individual

responsible for nuclear security also had several other duties. This

has had a noticeable positive effect on implementation of systems

upgradir.g and program effectiveness.

1

On site supervision has been increased by the addition of one

Corporal for each shift. The regular security force is supplemented

! by contract personnel as the need dictates. This staffing initiative

'

appears to have alleviated the problem identified during the last

,

assessment period when sufficient personnel were not available to man

i

' compensatory posts during equipment outages. This is further  !

evidence of the increased management attention being directed toward

i security. The new site Security Manager, hired during the latter

portion of the last assessment period, has become noticeably more

!

effective as he became more familiar with and knowledgeable of the

.

program. This also has increased the program effectiveness.

l

The training and qualification program is fully implemented and

i

professionally administered by two instructors. Both are also

certified as firearms instructors by the National Rifle Association.

,

An assessment by Region I of job knowledge on the part of security

!

perscnnel indicates that the training is generally effective.

4

The annual corporate security audit was complete and thorough. It

re-emphasized the need for a formal preventive maintenance program

for security equipment. This need was also identified in the

! preceding audit. At the conclusion of this assessment period, action

in regard to this matter had not yet been taken. Prompt management

i

attention to resolve conditions adverse to quality is a primary tenet

of 10 CFR 50, Appendix B, Criterion XVI. The lack of corporate

response to address this significant issue demonstrates a lack of

management commitment to upgrade the reliability of security

equipment.

In addition to the erratic equipment operability concern based, in

part, on the lack of a dedicated security PM program, there are other

weaknesses in the security system. For example, there are many

nuisance alarms associated i.'th vital area doors because differential

!

J

- .. . . - , - - . , n , - - - +- , -,---n.-- -.-- . . , , . _ . - . , , , .-- n - ,,- .- .,- -

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

.

e

.

.

34

!

pressure across the doors activates the door open limit switch even i

though a door remains closed. There are additional nuisance alarms

j

-

associated with the motion detection system, e.g., wind may cause a

fence to move which shows up as an alarm. These nuisance alarms have

the effect of de-sensitizing' security personnel to vital area door

, and motion detection alarms. .

j Conclusion '

i

Category 2 - Improving

Board Recommendation ,

>

!

l Licensee:

I

< --

Elicit commitment from licensee to establish and implement a

' security equipment preventive maintenance program.

.

l

i

i

j

4

--

Action should be taken to eliminate nuisance alarms.  ;

4  ;

!

i

'

I

,

i i

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i

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1 i.

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4  :

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

.

.

35

H. Outage Management / Refueling (6%, 242 hours0.0028 days <br />0.0672 hours <br />4.001323e-4 weeks <br />9.2081e-5 months <br />)

Analysis of this area includes direct observation of outage

activities by the resident inspector and region based inspectors.

Inspections were conducted to examine housekeeping, quality

assurance, corrective action systems, safety reviews and reporting

systems, and compliance with Technical Specifications and site

procedures.

During the assessment period, some improvement was noted in outage

control. Near the end of the outage the licensee assigned a senior

level manager in the Maintenance and Construction division to

coordinate outage activities. This management assignment provided

the necessary positive outage control and direction that had been

previously lacking. Increased cooper'ation was noted among the

various functional groups reporting to the six divisional vice

presidents. This close coordination among the functional groups was

necessary to complete the outage. Daily planning meetings were

conducted to control outage activities. A startup certification

procedure was developed and implemented to ensure all outage and

startup activites were complete prior to plant startup. Symptomatic

of divisional interface problems during the outage was the continuing

procurement problem of undelivered parts when required to perform

maintenance.

The licensee's planned workload for the outage was large with regard

to the number of licensee employees present onsite to supervise

contractor work. The number of major jobs planned to be accomplished

coupled with the number of unforeseen major maintenance actions

strained the contractor and subcontractor management capabilities of

GPUN. This was poignantly illustrated during the startup when major

equipment failed to perform its design function despite maintenance

conducted during the outage by contractor personnel. (Sections C and

I provide more detail of specific equipment. failure during startup.)

The licensee has recognized this deficiency and has taken actions to

reorganize onsite Maintenance and Construction personnel. Such

actions include the assignment of a job supervisor to every major

maintenance activity conducted by contractor personnel during the

next outage. In addition, the licensee is planning to sequence the

number of major modifications and job activities according to

maintenance assets during the next cutage. The effectiveness of this

licensee action will be evaluated during upcoming outages.

Management attention to divisional interface problems would eliminate

some of the following coordination and communications concerns. A

more concerted effort in design reviews and plant system walkdowns

would have reduced the number of field change notices and requests.

Another area where increased management attention would be beneficial

is system turnover following cc.npletion of maintenance or

modification activities. The number of items included on the

incomplete work list (IWL) should be reviewed and as.-built drawings

..

L

i

l

l

,

.

, 36

should be consistently updated before system turnover. Management

attention to this area should be considered.

The licensee has spent considerable high level management effort to

discover the problems experienced during the outage and possible

remedies. In addition to changes discussed above, an outage

coordinator with a small staff has been assigned in Technical

Functions to plan the next outage. Numerous plant engineering design

reviews (PEDRs) are being conducted to evaluate various modifications

prior to the next outage. Early identification of long-lead procure-

ment items has been incorporated into th4 pEDR process.

Refueling of the reactor was commenced on May 1 and completed on July

28, 1984. Various problems during the refueling process, such as

replacement of the SRM/IRM dry tubes and nuclear instrumentation and

control rod hydraulic problems, were experienced during the long

refueling period. Refueling outage planning, scheduling, and testing

were well controlled under formal plant procedures. Operations and

Core Engineering staffs were knowledgeable in their assigned duties

and the Core Engineering Manager personally verified core status

daily. All levels of the management were involved in procedure

reviews to ensure safe refueling effort. Refueling activities and

subsequent startup testing were conducted in a conscientious manner

and adequately monitored by operations QA. Fuel and control rod

movements were performed in a controlled, step-by-step manner. All

test results were properly evaluated and documented.

Sumnary

Overall this assessment notes some improvement in cutage control

which is directly attributable to an increased level of involvement

by senior management. The licensee has initiated a number of

self-assessment studies to improve performance and has made changes

that have already shown positive effects. The overall impact of

these changes, however, cannot be evaluated until the next outage.

Inadequacies in communication and coordination between divisions

inhibited optimum management of the outage. A more positive control

of contractor support is another area where continuing management

attention is required to effect improvements.

Conclusion

Category 2 - Improving (This trend reflects the improvement

during the last three months of the 20 month outage.

But is based only on outage activities during the 14

month SALP evaluation period.)

.

.

. 37

Board Recommendations

NRC:

Although improvement in coordination between divistor, was evident at

the end of the outage, communication and coordinat on for the next

i

major outage should be reviewed prior Le the outage. Schedule a

meeting with the licensee two months in advance af the next major

outage.

1

!

!

!

,

i

t

L

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

.

. 38

I. lechnical Support (9%, 353 hours0.00409 days <br />0.0981 hours <br />5.83664e-4 weeks <br />1.343165e-4 months <br />)

! This assessment is based on routine resident and region based

' inspections of Technical Functions and Plant Engineering activities.

It was not included as a unique functional area in thu previous SALP. 1

The majority of the technical support provided by Technical Functions  ;

is accomplished _in the Parsippany corporate office. Two inspections

were performed of corporate office activities and both identified

problems. One of the inspections followed up licensee action to  ;

address Generic Letter 83-28, " Generic Implications of Salem ATW5  !

Event." This inspection identified that the licensee had assembled a

task force to review the applicability of Generic Letter 83-28 to

Oyster Creek, that the task force had completed its review and made

recommendations, but that six months later, no action plans were

i

~

available to demonstrate licensee action or scheduled action to

implement the task force recommendations. .The lack of aggressive

,

I

follow-up of the task force recommendations is not responsive to NRC

initiatives and requires management attention. This is not the only ,

[

example of slow and inadequate responses to NRC items. During this

evaluation period, a najor effort was made by NRC inspectors to

address licensee action taken on old outstanding NRC inspection ,

(

findings. This effort resulted in the discovery that the licensee's

4

action item tracking system to address NRC items was incomplete and i

that inter- and intra-divisional responses to the Technical ,

Function's Licensing Division's action items were, in many cases,  !

"

late and superficial. In response to this NRC concern, the licersee i

implemented a task force to review the status of NRC open items and i

improve the adequacy of the responses. The licensee attributed a

major part of this problem to the inadequate action item tracking

'

system inherited from JCP&L. i

i

Another problem the licensee stated to have inherited from JCP&L was  !

identified during the other corporate office inspection. This  !

inspection, even though announced well ahead of time, found the [

licensee unprepared and without evidence they had adequately '

t

j addressed NRC Bulletins 79-02 and 79-14. One violation, two

deviations, and six unresolved items involving pipe supports and

,

base plates resulted. The major technical issues of concern were

1

lack of accurate as-built pipe support drawings, lack of technical .

! depth in pipe and pipe support design evaluations, and lack of design

f criteria. Management meetings between the licensee and NRC were held I

to fully develop the significance of the NRC findings and to i

,

establish licensee corrective action. The licensee was requested to  !

justify continued operation of Oyster Creek based on the many pipe  !

support discrepan-ies identified during subsequent reinspection

activities. This was well done. The licensee does have an ongoing  !

program to update as-built drawings that is anticipated to take at

,

least two more years to complete based on the poor condition of '

original plant drawings and weaknesses in their present configuration f

control program. Tt.e licensee is ale.o developing design standards [

t

i

. I

! I

I

y - - ~ - , e -, -

,-

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

. .

J

. 39

i

that were originally committed to be completed in Marcn 1985 but in

May 1985 the Itcensee requested they be delayed to December 1985.

The above examples demonstrate that the technical support groups are  ;

capable of addressing problems once identified but that they are weak

in identifying and/or correcting problems on their own. Additionally,

management has no program for reviewing previous Bulletin responses

for accuracy even though two examples of inadequate responses were

identified by the NRC. Although the licensee feels they inherited

these problems from JCP&L, they did not have an effective program for

integrating JCP&L documentation into the GPUN system and do not

presently intend to utilize resources to address this weakness even

though it has caused and most likely will continue to cause problems.

-Inspection activities have shown that generally adequcte technical

support is provided to plant operations, although corporate

engineers' responsiveness to operating problems is of concern due to

their inconsistent sensitivity for timely support. However, in the

design of the new scram discharge volume drain valves, the incorrect

specification of.the valve operator closing spring caused the valve

{~ to reopen following a MSIV closure scram. Additional problems have

been experienced in the installation of modifications resulting from

poor designs, design evaluations, specifications, and as-builts.

Examples include drywell equipment drain tank heat removal, control

i

room instrumentation, recirculation pump seal flow switches,

Radioactive Gaseous Effluent Monitoring System, and sequence of.

events recorder. Additional effort is needed to improve overall

.

technical support performance to eliminate inadequate designs.

A review of Licensee Event Reports (LER's) shows that the technical

quality of these reports is acceptable. The LER's are generally

timely. This is noted improvement from the previous SALP evaluation.

Thirteen of the 40 LER's submitted during the period were submitted

' late. However,12 of these were only 7 or less days late. Improved

effort is needed to assure reports are submitted within the 30 day

,

requirement.

l

Problems involving failure of technical support groups to meet

commitments were identified. For example an issue dealing with the

i-

differential pressure between the Emergency Service Water and

Containment Spray Water was first indentified in 1978. When the

issue was. reinspected in 1983, the licensee stated that Technical

Functions had been tasked with the completion of an engineering

2

evaluation. This was never completed according to commitment and

resulted in a NRC violation during this assessment period.

Addtionally, there are other examples where commitment dates in

,

response to NRC violations were not met. A corollary to the

commitment problem involves failure of the technical support groups

to respond to internal tracking systems in a timely manner. This

i

!

i

i

. _ . . - ___ ,_ _ ._

. .

.

, 40

results in failure to meet commitment dates to the NRC. For example,

an' internal procedure governing responses to action items was

violated by Plant Engineering on several occasions and resulted in

delays up to seven months. One of the problems associated with the

commitment control program appears to be difficulty in achieving a

timely resolution to items as a result of the lack of cooperation

from the different groups or divisions. A group initiating an action

item, work request, or in any other way requiring input from a

different group or division, has no effective mechanism for assuring

the requested action is completed within the time specified. The

lack of timely responses to interdivisional or intergroup actions is

an area which requires attention.

Other weaknesses in technical support manifested themselves when a

time . lag in information flow between Technical Functions and Plant

Engineering resulted in an incorrect valve lineup in a station

procedure and in the plant. The problem was identified by NRC

inspectors and resulted in a violation. Another problem arose when

Technical Functions performed a detailed evaluation which allowed

plant operation at an increased drywell temperature of 150 F. During

this evaluation it was not recognized that the 135 F was used as a

starting condition in the updated FSAR. This was identified to the

licensee by a NRC in'pector as an unreviewed safety question that

shculd have been submitted to NRC Licensing for approval. This

served to demonstrate that at least some of the key reviewers in the

l

'

technical support area are not sensitive to or familiar with NRC

regulations regarding unreviewed safety questions. These examples

again demonstrate the need for licensee action to establish open and

effective inter- and intra-department communications.

Significant improvement was r.oted in two areas that included

reduction of backlogged open NRC items and establishment of a new

department to gather missing vendor documentation.

Summary

Technical support at Oyster Creek has several key problem area's that

need management attention. They include meeting commitment dates,

addressing identified and yet unidentified problems inherited from

JCP&L, self-identifying problems, and improving inter- and

intra-division communications.

Good technical work was performed when problems were identified and

ultimate solutions were satisfactory although not always timely.

Technical quality of LFRs was good. The backlog of open NRC items

was significantly decreased.

Although QA was not specifically mentioned in the analysis, the fact

that the problems exist and remain uncorrected reflects inadequate QA

performance.

t

r,.

s

.

. 41

,

Conclusion

Category 2 - Consistent

Board Recommendations

s

. .

.

' 42

'

,

J. Licensing

The basis of this appraisal was the licensee's performance in support

of licensing actions that were either completed or remained active

during the current rating period. Licensing a-tivity during this

rating period has been at a high level. In addition to routine and

SEP items, major activities included a fuel reload, the updated FSAR

Report, the Expanded Safety System Facility proposal, emergency

actions, spent fuel pool expansion, exemption requests, responses to

Generic Letters, TMI items, multi plant actions and the establishment

of a monthly progress status review meeting on licensing actions.

Management involvement in licensing activities is evident in that

reviews have been generally timely, thorough, and of a good quality.

One exception to these generally good quality reviews was the

proposed amendment on water quality studies in the Appendix B

Technical Specification. Prior planning and the assignment of

priorities by management is also evident except for 1) the

implementation of the Post Accident Sampling System, 2)'the request

for the schedular extension to 10 CFR Part 50, Appendix H, and 3) the

delay in the documentation of work that the licensee believes should

be deferred.from the Cycle 11 refueling outage to the Cycle 12

!

refueling outage. An area for improvement is that in some instances

more management involvement is needed in the decision.on the dates to

l respond to licensing actions and in meeting these dates. This is a

repeat concern of the previous SALP and should be effectively

4

corrected by the licensee.

Within the licensee organization, licensing positions are identified,

authorities and responsibilities of the licensing group are well,

defined; however, the licensing staffing is at best adequate because

there are dif ficulties with' the backlog and with timely responses .

from the licensee to the staff. Also, there is a need to strengthen

the authority of the licensing staff within the licensee's corporate

organization to improve timeliness of responses to GPU Licensing and-

in turn to the NRC.

The licensee generally exhibits a good understanding of technical

issues and generally provides resolutions with a sound, thorough and

conservative approach. For example, the information submitted in '

conjunction with the alternate safe shutdown capability, emergency

amendment on relief valve position indication, and TMI Items II.F.2.3

and-II.B.3 displayed a c. lear understanding of staff concerns. This,

' however, was not true for the schedular exemption request for 10 CFR

50.48 (C) (4) and the significance of Core Spray distribution in the ,

Cycle 10 reload.

The GPUN management and staff demonstrate a dedicated and independent

interest in the safety of the Oyster Creek plant. .The establishment

of the monthly status review meeting'should improve the' understanding

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of licensing actions.

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During the assessment period the licensee transmitted to Region I

four revisions to,the Security Plan. Three of the four plan

' revisions were reviewed. The fourth revision was received June 25,

1985, and its review was not complete. The third revision submitted

included resolution of items which were considered unacceptable under

10 CFR 50.54(p), in the two previous submittals. The licensee's

-changes were indicated throughout the page revisions to

' highlight and facilitate the review. However, summary of changes to

ensure clarity of intent was not provided. -This substantially

hindered Region I's timely review.

Conclusion

Category 2 - Consistent

.

Board Recommendations

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Licensee:

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Management involvement is needed in deciding on dates to respond

to licensing actions and in meeting those dates.

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. 44 .

V. Supporting Data and Summaries

A. Investigations and Allegations Review

One investigation was conducted to followup a. licensee investigation

that was initiated after two licensee employees lied to a NRC

inspector. The NRC investigation was in progress at the end of the

SALP period.

Several allegations were reviewed and investigated. The majority

were not substantiated. Those few that were at least in part

substantiated, were determined not to impact safety-related activites

at Oyster Creek.

B. Escalated Enforcement Actions

None

C. Manacement Conferences-

I Date Subject

6/18/84 Emergency Preparedness Interface

j 7/23/84 SAlp (2/1/83 - 4/31/84)

i

9/05/84 -Licensee training in relation to facility

modifications and preparations for startup after

the extended outage

11/14/84 Licensee plans for a new emergency service

building at Oyster Creek

6/13/85 Investigation into false statements made by

licensee employees to a NRC inspector

6/13/85 Licensee inspection and evaluation of systems

important to safety as a followup.to NRC

Inspection 85-14

6/17/85 Licensee response to security violations

identified in NRC Inspection 85-16

6/28/85 Review licensee controls and documentation for

IE Bulletins 79-02 and 79-14 reinspection

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D. Licensee Event Reports

Tabular Listing

Type of-Events:

,

A. Personnel Error . . . . . . . . . . . . . . . . . 19

, B. Design / Man./Construc./ Install. . . . . . . . . . . 8

C. External Cause . ................. O

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j D. Defective Procedures ............... 5

E. Compon e n t Fa i l ure . . . . . . . . . . . . . . . . . 7

X. Other . . .. ... . . . . . . . . . . . . , , . _1

"

Total 40

1

Licensee Events Reports' Reviewed:

Report Nos.84-006 through 85-011

Causal Analysis

No trends were identified during the analysis performed-on the

Licensee Esent Reports (LERs) although five areas revealed some

commonality. The five areas are:

i

1. 84-09, 84-21, 85-01 and 85-02 involved reports of personnel

error; 84-09 and 21 were contractor's errors;

2. 84-11, 84-16, 84-29, 85-04, 85-08, and 85-10 were related to

management oversight;

3. 84-06, 84-23, 85-03, and 85-09 are indicative of licensee

, ef forts to identify design deficiencies;

i

4. 84-34, 85-05, and 85-11 were reports concerning instrument

,

drift (the licensee indicated plans to replace the instruments

in two of the LERs); and

5. 84-30. 84-33 and 85-06 reported reactor scrans related to

,

operator error and/or procedural deficiencies.

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TABLE 1

LISTING OF LERs BY FUNCTIONAL AREA

OYSTER CREEK NUCLEAR GENERATING STATION

AREA NUMBER /CAUSE CODE TOTAL

Plant Operations 8A, 18, 30, SE 17

Radiological Controls

Maintenance 2A, 10, IE 4

Surveillance /Inservica 9A, ID 10

Testing

Fire Protection / Housekeeping 18 1

Emergency Preparedness

Security and Safeguards

Outage Management / Refueling

Technical Support

Licensing

Other [ 6B, IE,1X _8

TOTAL 40

Cause Codes:

A - Personnel Error

B - Design, Manufacturing, Construction, or Installation Error

C - External Cause

0 - Defective Procedures

E - Component Failure

X - Other

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TABLE 2

LER SUMMARY (5/1/84 - 6/30/85)

OYSTER CREEK

LER Number Summary Description

84-006 Torus corrosion pitting and missing structural welds.84-007 Failure to test a standby gas treatment system train

within required time.84-008 Degradation of neutron monitoring instrument dry tubes.84-009 Degradatier, of secondary containment -- both doors of a

reactor building personnel access airlock were opened

simultaneously.84-010 Fuel pool gate movement above irradiated fuel.84-011 Both trains of the standby gas treatment system

inoperable.84-012 Both emergency diesel generators simultaneously

inoperable,84-013 Loss of primary fire water suppression system.84-014 Reactor low water level surveillance performed late.84-015 HFA relay window fogging with undetermined substance.84-016 Failure to functionally test all excess flow check valves.84-017 Inadvertent repositioning of primary containment isolation

valves.84-018 Standby gas treatment system flow below Technical

Specification limit.84-019 Scram discharge volume drain valve closure failure.84-020 Loss of power to 480 volt unit substations.84-021 Unplanned automatic actuation of diesel generator due to

loss of p6wer on 4160 volt bus caused by energizing ESW

pump motor while grounding straps were installed.84-022 Scram discharge volume vent and drain valves exceeded

allowable closing time.

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TABLE 2 (Continued)

LER Number Summary Description

84-023 Orywell vent and purge valve design deficiency.84-024 Reactor low-low water level sensor were inadequately

surveilled.84-025 Inadvertent initiation of Core Spray system during reactor

low-low sensor calibration.84-026 Emergency Service Water-Containment Spray negative delta

pressure.84-027 Standby Liquid Control system concentration below

required.84-028 Failure of B and E electromatic relief valve to open.84-029 Cask lift with unadjusted crane vertical limit switches.84-030 Reactor scram on low water level.84-031 Failure of main steam drain valves to operate.84-032. Missed acoustic valve monitoring system surveillance.84-033 Reactor scram on low condenser vacuum.84-034 Two of four main steam line low pressure sensors out of-

spec.85-001 Reactor low-low-low ' level sensor out of service longer

than permitted.85-002 Two inoperable containment isolation valves in a single

penetration.85-003 Design deficiency in Core Spray pump logic.85-004 Violation of ApLHGR limit.85-005 Six of eight isolation condenser pipe break sensors

out of spec.85-006 Reactor scram due to low water level.85-007 The required sample and analysis of the floor drain waste

tanks was not done as specified in the Technical

Specifications.

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TABLE 2 (Continued)

L{RNumber Summary Description

85-008- 4160 volt emergency bus Technical Specification violation. [

85-009

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480 volt unit substation overload.85-010 IRM setpoints exceeded Technical Specification limits.

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85-011 Three out of four isolation condenser actuation pressure ,

sensors out of spec. '

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TABLE 3

ENFORCEMENT SUMMARY 5/1/84 - 6/30/85)

OYSTER CREEK NUCLEAR GENERATING STATION

A. Number and Severity Level of Violations

Severity Level I O

Severity Level II O

Severity Level III 1

Severity-Level IV -15

Severity Level V 4

Deviations _3

Total 23

B. -Violation vs. Functional Area

Functional Area. .

. Severity Levels

I II. III IV V Dev

Plant Operations 2 2

Radiological Controls 1 1 1

Maintenance 1 2

Surveillance / Inservice Testing i

Fire Protection / Housekeeping 1

Emergency Preparedness

Security and Safeguards 7

Outage Management / Refueling-

Technical Support 2 1 2

Licensing

Totals 1 14 6 3

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TABLE 4

INSPECTION HOURS SUMMARY (5/1/84 - 6/30/85)

OYSTER CREEK NUCLEAR GENERATING STATION

HOURS  % OF TIME

Plant Operations 1218 31

Radiological Controls 424 11

Maintenance 481 12

Surveillance / Inservice Testing 301 8

Fire Protection / Housekeeping 104 3

Emergency Preparedness 571 15

Security and Safeguards 186 5

Outage Management / Refueling 242 6

Startup' Activities 206 5

Technical Support 353 9

Licensing No data available

Total 3880 100

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TABLE 5

INSPECTION REPORT ACTIVITIES

OYSTER CREEK NUCLEAR GENERATING STATION

REPORT NO. AND

INSPECTION DATES INSPECTOR AREA INSPECTED

84-11 Resident Routine

5/1-31/84

84-12 Specialist Refueling activities

4/30-5/4/84

84-13 Specialist Emergency preparedne .s and observation

5/9-11/84 (Team) of emergency exercise

84-14 Specialist Whole body counting program

5/11/84

84-15 Specialist Emergency Plan

5/21-23/84

84-16 Specialist Report of operator licensing

4/10-13/84 examinations

84-17 Specialist Chemistry and radiochemistry programs

6/4-8/84 ,

84-18 Resident Routine

6/1-30/84

84-19 SALP

84-20 Resident Routine ar.d review of aspects of the

7/1 - 8/3/84 maintenance program

84-21 Specialist Fire Protection / Prevention Program

7/23-27/84

84-22 Specialist Isolation condenser piping replacement

7/27,30,31 -8/1,3/84

84-23 Specialist Security

8/6-10/84

84-24 Specialist Startup testing following refueling

9/10 - 11/30/84

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84-25 Resident Routine

8/4 - 9/5/84

84-26 Specialist Containment integrated and local leak

8/21-24 and rate testing

9/7-14/84

84-27 Specialist Report of operator licensing

8/20-23/84 examinations

84-28 Resident Routine

9/5 - 10/15/84

84-29 Cancelled

84-30 Specialist Radiation protection program

9/18-21/84

84-31 Specialist NRC Generic Letter 83-28

11/26-30/84

84-32 Resident Routine

10/15 - 11/17/84

84-33 Specialist Nonradiological chemical program

11/13-16/84

84-34 Resident Routine

11/18'- 12/31/84

85-01 Resider.t Routine

1/1 - 2/3/85

85-02 Specialist Security

1/7-11/85

85-03 Specialist Design review of plant shielding

1/8/85

85-04 Specialist Radioactive waste management and

1/28-2/1/85 radiological controls

85-05 Specialist Emergency Preparedness

2/4-8/85

85-06 Resident Routine

2/4 -3/3/85

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85-07 Specialist Licensee's receipt of spent fuel

1/31 - 2/6/85

85-08 Specialist Procurement, receipt, storage and

2/28- 3/5/85 handling of safety-related items

85-09 Resident Routine

3/4-31/85

85-10 Cancelled

85-11 Specialist Licensee Event Reports

3/20-29/85

85-12 Specialist Report of operator licensing

4/8-12/85 examinations

85-13 Resident Routine

4/1 - 5/5/85

85-14 Specialist Bulletins 79-02 and 79-14

5/14-17/85

85-15 Resident Routine

5/6 - 6/2/85

85-16 Specialist Security

5/14/85

85-17 Specialist Emergency Preparedness

6/4-7/85

85-18 Specialist Radiological Controls

6/3-7/85

85-19 Resident Routine

6/3-30/85

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Table 6

ENFORCEMENT DATA

OYSTER CREEK NUCLEAR GENERATING STATION

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

84-18 6/1-30/84 IV Security Failure to search

package entering

protected area

84-20 7/1-8/84 V Maintenance Failure to adhere

to maintenance

procedure

84-21 7/23-27/84 Dev Fire Unsealed

Protection penetration in

stairwell

84-23 8/6-10/84 IV Security Insufficient

protected area barrier

84-23 8/6-10/84 IV security Unarmed site

protection officer on

duty

84-28 9/5 - 10/15/84 V Maintenance Pressure gauges

valved out following

maintenance

84-34 11/18 - IV Plant Containment entry

12/31/84 Operations without making

reactor suberitical

85-01 1/1 - 2/3/85 IV Technical Failure to take

Support prompt corrective

' action to correct a

condition contrary to

that described in the

FSAR

85-01 1/1 -2/3/85 IV Surveillance RPS sensor valved

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out for over I hour

85-02 1/7-11/85 IV Security Portions of isolation

zones not monitored

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TABLE 6 (Continued)

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

85-06 2/4 -3/3/85 V Plant Failure to fully

Operations implement leak

reduction program

85-06 2/4 -3/3/85 IV Plant Failure to perform

Operations a valve lineup

85-07 1/31 -2/6/85 IV Radiological Failure to conduct

Controls contamination

surveys within time

specified

85-07 1/31 -2/6/85 III Radiological Cask contamination

Controls exceeded limits

85-13 4/1 -5/5/85 IV Maintenance Failure to follow

procedure controlling

quality deficiency

report responses

85-13 4/1 -5/5/85 V Plant Temporary changes to

Operations procedures not reviewed

within the time

specified

85-14 5/14-17/85 IV Technical Procedures and

Support instructions not

prepared

85-14 5/14-17/85 IV Technical Records not maintained

Support

85-14 5/14-1'7/85 Dev Technical Insufficient anchor

Support bolt testing

85-14 5/14-17/85- Dev Technical Inadequate

Support documentation to verify'

certain commitments had

.been . met'

85-16 5/14/85 IV Security Security not notified

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of lost key card as

required by procedure

85-16 5/14/85 IV Security Key card not voided

within time specified

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TABLE 6 (Continued)

Inspection Inspection Severity Functional

Report No. Date Level Area Violation

85-16 5/14/85 IV Security Lost badge and key card

not reported to NRC

85-18 6/3-7/85 V Radiological Failure to follow

Controls a RNP requirement

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TABLE 7

PLANT SHUTDOWNS

Date Description Cause

Oct. 29 - Nov. 1 Initial startup following outage

Oct. 30 Reactor scram due to low reactor Feedwater pump

vessel water level during problem resulting

plant startup from lack of adequate

maintenance and

post-maintenance

testing

.

Nov. 1 Startup

Nov. 4 .8 Shutdown due to "B" and "E" Inadequate post-

EMRVs failure to open maintenance testing

.

Nov. 8 Startup

Nov. 10 - 22 Shutdown: "B" EMRV ' ailed Inadequate post-

to open; "E" EMRV opaned maintenance testing

but did not reseat properly and engineering

evaluation of problem

.

Nov. 22 S ta rtu,p

Nov. 30 Manual scram for scram discharge

volume test

Dec. 3 Startup

.Dec. 3 Scram: low condenser vacuum Operator error

trip not clear prior to

exceeding 600 psi

Dec. 3 Startup

Feb. 2 - 14 Shutdown to repair Core Spray Design. deficiency.

design deficiency- High drywell

' ' unidentified leakage

resulting from improper.

. maintenance

Feb. 14 Startup

Feb. 15 - 17 Shutdown due to V-2-36 bonnet Improper maintenance

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leakage and "A" EMRV and inadequate EMRV

inlet flange leakage engineering evaluation

Feb. 17 Startup

Feb. 18 - 23 Shutdown due to "C" EMRV Inadequate engineering

flange leakage evaluation

Feb. 23 Startup

Feb. 24 Reactor scram on vessel Operator error; non-

low water level indicating feedwater

flow recorder

contributed

Feb. 25 Startup

4

Feb. 25 - Mar. 4 Shutdown due to "A" and Inadequate engineering

"C" EMRV flange leakage evaluation

Mar. 4 Startup ; completed machining

inlet flange surfaces on

EMRV's "A", "C", "0", and "E"

June 12 - 17 Reactor scram as a result Equipment failure

of the electric pressure regulator failure

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June 17 Startup

' Recovery f rom shutdown

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Figure 1

NUMBER OF DAYS SHUT 00WN

OCT l]l(1 day)

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NOV l 3 Shutdowns l(17)

DEC ll __

T i(3 days)

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JAN l

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FEB l 5 Shutdowns l(26 days)

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PAR l l(4 days)

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APR l

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PAY l

l

JUN l 1 l(5 days)

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5

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10

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15 20 25 30

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