IR 05000206/1984032
| ML16341C237 | |
| Person / Time | |
|---|---|
| Site: | San Onofre  |
| Issue date: | 11/09/1984 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341C236 | List: |
| References | |
| 50-206-84-32, 50-361-84-31, 50-362-84-32, NUDOCS 8411140319 | |
| Download: ML16341C237 (62) | |
Text
SALP BOARD REPORT U.S.
NUCLEAR REGULATORY COMMISSION
REGION V
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORfAMCE Report Nos:
50-206/84-32 50-361/84-31 50-362/84-32 SOUTHERN CALIFORNIA EDISON COMPANY SAN ONOFRE UNITS 1-3 ASSESSMENT PERIOD:
June 1,
1983 - September 30, 1984 84lii40319,841109.,%,
PDR *DOCK":05000206,'
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INTRODUCTION The Systematic Assessment of Licensee Performance (SAIP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information.
SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations.
SALP 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 construction and operation.
A NRC SALP Board, composed of the staff members listed below, met on November 15, 1984, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at the San Onofre Nuclear Generating Station (SONGS) for the period June 1,
1983 through September 30, 1984.
SALP Board for San Onofre, Units 1-3:
D. F. Kirsch, Acting Director, Div. of Reactor Safety and Projects, RV P. H. Johnson, Chief, Reactor Projects Section 3, RV A. E. Chaffee, Chief, Reactor Projects Branch, RV D. P. Haist, Project Inspector, RV J.
P. Stewart, Resident Inspector, RV A. J. D'Angelo, Resident Inspector, RV J.
Tatum, Resident Inspector, RV D. Schaefer, Physical Security Inspector, RV H. North, Senior Radiation Specialist, RV R. Fish, Senior Emergency Preparedness Analyst, RV H. Rood, Project Manager SONGS-2/3, NRR E. McKenna, Project Manager SONGS-l, NRR II.
CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction, preoperational, or operating phase.
Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas'
Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each functional area.
1.
Management involvement and control in assuring quality 2.
Approach to resolution of technical issues from a safety standpoint
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Responsiveness to NRC initiatives 4.
Enforcement history 5.
Reporting and analysis of reportable events 6.
Staffing (including management)
7.
Training effectiveness and qualification
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However, the SALP Board is not,limited to these criteria and others may have been used where appropriate.'
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories.
The definition of these performance categories.is:
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~Cate or 1.
Reduced NRC attention may be "appropriate.
Licensee management attention and involv'ement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to, operational safety or construction is being achieved.
Cate or 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety or construction is being achieved.
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 achieved.
III. SBiMARY OF RESULTS Overall the board finds that licensee performance is acceptable and directed toward safe facility operation.
In addition, the board finds that the licensee's overall performance has improved since the last SALP evaluation period.
Individual areas which contributed to this overall improvement are radiological controls and security.
The board found aggressive management attention and a high level of performance in the areas of quality programs and administrative controls and SONGS-3 startup testing which were not specifically addressed in the previous SALP evaluation period.
The licensee's performance in the area of plant operations is unchanged and requires additional attention to minimize instances of personnel error and inadvertent compromises of engineered safety feature availabilit ~ 4 (
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Functional Area 7/1/82-5/30/83 6/1/83-9/30/84 Trend A.
Plant Operations
B.
Radiological Controls
C.
Maintenance
D.
Surveillance
E.
Fire Protection
F.
G.
Security
H.
Refueling
I.
(}uality Programs and N/A Administrative Controls (includes Unit-1 modifications)
J.
Iicensing Activities
K.
Startup Testing (Unit 3)
N/A IV.
PERFORMANCE ANALYSIS
2
2
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N/A
No change Improvement No change No change No change No change Improvement N/A N/A No change N/A A.
Plant 0 erations l.
~Anal sis.
During the current SALP assessment period, 3924 hours0.0454 days <br />1.09 hours <br />0.00649 weeks <br />0.00149 months <br /> of direct inspection effort were applied in the area of plant operations at San Onofre Units 1,
.2 and 3.
These inspection activities resulted in the issuance of 4 notices of violation and 3 civil penalties totaling
$ 165,000.
The summary assessment of individual unit operation, overall conclusion as to site performance category and board recommendations are discussed below.
With regard to the assignment of an overall site performance category,. it should be noted that more emphasis was
- placed on Unit 2/3 performance than on Unit 1, which was shut down during the entire assessment period.
Unit 1 0 erations During this SALP period, Unit 1 has remained in Mode 5 for the completion of seismic modification activities.
No violations were issued during this period in the area Unit 1 operations.
f Management has emphasized the use of prior planning and assignment'f priorities for the control of activities.
Conservatism is routinely exhibited by management at the Onsite Review Committee meeting in that, references are made to the standard technical specification and any differences which exist with the San Onofre technical specification.
Licensee responsiveness is usually technically sound and thorough as exhibited by recent actions such as the addition of temporary diesel generators onsite during the Transamerica DeLaval (TDI) diesel generator inspection effort.
A total of 3 Iicensee Event Reports (LER) were issued during the period applicable to plant operations.
All LER's were reported in a timely manner and adequately described the even I I
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Staffing for the period was adequate and appears to be well controlled.
Backlog work activities and overtime by the operations staff has been infrequent and does not appear to be degrading their performance.
In this regard, no serious operator errors have occurred.
The training and qualification program appears to be adequate.
It has been noted, however, that,a weakness existed in recent training activities in that some Unit 1 design changes had not been distributed to training.
This error was promptly corrected by the licensee and the operations staff will receive necessary additional training prior to leaving lfode 5.
Units 2/3 0 erations Site management has been actively involved in Unit 2/3 operations.
They have been aggressive in their pursuit of the underlying causes of plant problems and they have been thorough and innovative in addressing proper and effective corrective actions.
Plant managers are frequently involved in site activities and key evolutions.
Frequent NRC resident interface with all levels of plant supervision and management has consistently demonstrated a clear understanding of technical issues involving plant safety.
The Onsite Safety Review Committee has been active and effective.in providing conservative and technically sound resolution.of plant problems affecting safety.
The licensee has been responsive to and straightforward in-their dealings with the NRC at all levels of interface.
Staffing for the period was adequate and appears to be well controlled.
Backlog work activities and overtime-by the operations staff,ha's been infrequent and does not appear to be degrading their. performance.
In this regard, no serious operator errors have occurred.
The training and qualification program appears to be adequate.
In spite of an aggressive pursuit of excellence by site management, as noted above, a review of enforcement history and reportable events during the current assessment period reveals a significant failing in the ability of site management to effectively implement and achieve the operational goals which they have set.
As, noted above, the NRC has issued 4 Notices of Significant Violations involving 3 civil penalties during the current assessment period.
The following is a summary of enforcement items and reportable events occurring this period.
Enforcement Items l.
Improper isolation of charging pump rendered Unit 3 Emergency Core Cooling System inoperable on 9/29/83.
Level IIIviolation.
Civil penalty
$20,000.
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Failure to follow operating instruction S023-0-36, Control of System Alignments, associated with the above. item.
Level IIIviolation.
Civil penalty
$20,000.
3.
Improper isolation of Unit 3 containment spray system on March 4, 1983, which was not discovered until March 17, 1984. ',evel III, violation.
Civil penalty
$ 125,000.
4.
Improper Mode 1 operation of Unit 3 with a diesel generator inoperable and the redundant ESF train degraded due to the inoperable containment spray system.
Level III violation.
Reportable Events Reportable events involving Unit 2 and 3 operations during this SALP period resulted in the issue of 115 LER's.
A review of these LER's shows that 23 are the result of personnel error, of which 20 are repetitive in nature.
The repetitive events appear to fall into 4 major areas:
l.
I,ack of valve control - 9 IER's (Unit 2 83-118, 84-13; Unit 3 83-44, 83-46, 83-63, 83-73, 83-78, Unit 2/3 Operations 2.
Lack of breaker control - 4 LER's (Unit 2 83-49, 83-85, 83"100) 84-29).
3.
Lack of proper control of reactor coolant temperature
- 4 LER's (Unit 2 83-46,83-119, 83-151; Unit 3 83-80).
4.
Lack of proper manual control of steam generator water level at low power - 2 LER's (Unit 2 84-20; Unit 3 84-32).
The most significant weakness is in the area of valve control.
The underlying cause for this weak area appears to be a basic failure in the ability of site management to detect and correct weaknesses in the following areas:
a)
Inadequate administrative controls to ensure independent verification of all critical valving evolutions.
b)
Inadequate administrative controls to ensure.
continuous operator understanding of the status of critical plant valves.
c)
Inadequate monitoring of plant status changes by operation supervision.
d)
Incomplete system knowledge by operators.
The inability of licensees to control critical plant valves is a problem nationwide.
In particular, several
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plants have inadvertently defeated their containment spray systems.
In spite of aggressive licensee attention to these problems, numerous enforcement conferences with the NRC and seemingly effective corrective action programs, the same types of problems continue to occur.
For example, as recently as August 21, 1984, both trains of Unit 3 HPSI were rendered inoperable for 18 minutes as a
result of loss of control of valve status on one train in conjunction with an outage on the other redundant train.
2.
Conclusion Although the licensee has made significant changes to improve the area of control, of'ritical valves, significant compromises of safety system integrity continue to occur.
Accordingly, licensee performance in this area is considered as Category 3.
3.
Board Recommendation The licensee should reevaluate the administrative controls for repositioning valves critical to plant safety from the standpoint of the continuity and visibility of valve status in the control room.
B.
Radiolo ical Controls l.
A~nal sis A total of 29 inspections (Unit 1, 6; Unit 2, 12; and Unit 3, 11) were conducted by the Reactor Radiation Protection Section during the appraisal period.
A total of 385 inspection hours were expended in the areas of:
a.
Radiation Protection b.
Environmental Protection c.
Waste Management d.
Confirmatory Measurements In addition, the resident inspectors provided continuing observations in these areas.
During the appraisal period, two Severity Level III violations were identified regarding the failure to conduct surveys necessary to assure that contaminated materials were not transferred or disposed in an unauthorized fashion.
One Severity Level IV violation was identified regarding failure to properly classify and declare in a timely fashion an Unusual Event in response to a plant vent monitor alarm.
No deviations or unresolved items were identified in these areas during the appraisal perio \\
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The preceding summary of enforcement history in this appraisal area represents a significant. reduction in the number of violations identified when compared with the last SALP cycle (2 level III's, 4 level IV's and 3 level V's).
In addition, the two level III violations resulted from activities which antedated this SALP cycle.
The enforcement history supports the previous SALP conclusion that,
"While the items of noncompliance are individually important, they are not so closely related so as to conclude that a serious breakdown of the licensee's
'radiological control'esponsibility has occurred."
The inspection activities during this SALP cycle indicate that the area of radiological controls has received strong and continuing management support.
This support has been evidenced in the areas of radwaste shipping, audit program with resultant prompt corrective actions and health physics reorganization to provide for better outage support.
The licensee has demonstrated a positive approach to the resolution of technical issues from a safety standpoint.
The extensive and aggressive program to identify and recover conta'minated materials released from Unit l, the improving quality of environmental reports and the prompt action to correct the degraded Unit 2/3 personnel decontamination facilities are examples of the licensee's approach to such issues'enerally, the licensee has been responsive to NRC identified issues, such as support of ALARA, and procedural compliance as evidenced by the audit program.
However, the licensee has lagged in implementation of commitments with respect to upgrading monitoring systems and implementing NUREG-0737 mandated PASS and monitoring system changes, particularly with respect to Unit l.
Reportable events have been reported in a timely fashion and have provided adequate analysis of the events.
L'icensee management support'of staffing and training in the radiological controls area has been both apparent and adequate.
The licensee has developed a well-qualified radiation protection staff and a good radiation protection training program.
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'The continued high Unit 3 primary system activity coupled with
'resent waste management practices, operational errors and equipment problems has resulted in a significant number of airborne radioactive material releases.
The level of liquid releases, while far above those proposed in the CESAR, have remained within regulatory limits.
Licensee efforts to identify root causes and take effective corrective actions to minimize releases should be aggressively pursue Ih
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Conclusion The continued improvement in the areas of radiation protection, radiological environmental monitoring and overall radiological controls program supports an increase in the overall performance classification.
The delays in meeting Unit 1 commitments with respect to PASS and monitoring system modifications; in improving Unit 2/3 effluent monitoring system performance; and in limiting Unit 2/3 radioactive effluents are negative factors.
An overall performance classification of 2 is warranted in this functional area.
3.
Board Recommendation The licensee should be encouraged to continued the past strong support of programs in this area which has been in evidence during this appraisal period.
Efforts to resolve the Unit 2/3 effluent monitoring problems and to limit effluent releases should be continued.
With respect to Unit 1, timely resolution of PASS and monitoring system problems is needed to support the return to service effort.
C.
Maintenance A~nal sls During the current, SALP assessment period 143 hours0.00166 days <br />0.0397 hours <br />2.364418e-4 weeks <br />5.44115e-5 months <br /> of direct inspection effort were applied in the area of plant maintenance at San Onofre Units 1, 2 and 3.
These inspection activities resulted in the issuance of 1 notice of violation.
The summary assessment of individual unit maintenance activities, overall conclusion as to site performance category and Board recommendations are as follows.
Unit 1 Maintenance A large number of maintenance activities have taken place during this period even though the plant has remained in Mode 5.
Some of the significant activities include the following:
RHR system outage CCW system outage TDI=diesel inspection and repair DC battery gl replacement These activities are not routine or normal plant evolutions, however, all activities appeared to be properly controlled and explicit procedures were generated for the control of each activity.
In instances where technical problems were evaluated, the results appeared to be technically sound and thorough approaches were used in all cases.
A notice of violation was issued in the housekeeping area involving foreign material exclusion (FME)., There were no
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apparent indications'f a p'ro'grammatic breakdown of FME control however, the need for additional management involvement was indicated.
Corrective action by the licensee was prompt and effective.
Four Licensee Event Reports were submitted by the licensee during this period, of which only two involved personnel error.
The reports were made in a timely manner with appropriate analyses performed when required.
Corrective action appears to be effective to prevent recurrence.
Unit 2/3 Maintenance The growth of the license's maintenance organization stabilized during the period and is developing into a more efficient work group.
However, the maintenance organization still includes a
large contractor work force, made up principally of Bechtel and Catalytic personnel.
The difficultyof properly managing such a large and complex organization involving approximately 2000 engineers and maintenance craftsmen has been a contributing factor to the following program weaknesses:
a)
Inadequate housekeeping
, b)
Lack of strict procedure compliance c)
Inadequate documentation of maintenance work.
Housekeeping in radiologically controlled areas, in which a majority of the safety-related equipment is located, declined during the second half of the SALP evaluation period to the point where the issuance of a housekeeping violation was warranted (this violation was combined with that noted for Unit 1).
The underlying cause for the degrading trend was the lack of adequate direction by the licensee's management as to which organizations were responsible for housekeeping in the radiologically controlled areas.
The licensee is in the process of developing additional long term corrective actions, and has currently implemented interim measures to upgrade housekeeping to a satisfactory level.
Other examples of the weaknesses in verbatim compliance, which occurred during the last two months of the evaluation period were; the failure to turn in an out-of-calibration instrument for recalibration and the flooding of a Unit 3 boric acid makeup tank pump room when the maintenance person disassembled a safety-related pump on the wrong unit.
The licensee's program to increase management involvement in monitoring maintenance activities should improve housekeeping to the quality which existed in the first half of this assessment period.
The large turnover of contractor personnel and informal communication practices will require additional licensee management involvement to ensure procedure compliance and proper documentation of maintenance wor I
Although the above noted weaknesses in the maintenance program indicate a need for continuing management attention, significant improvements have been made in several safety-related maintenance activities.
These activities include maintenance of reactor trip breakers, reactor coolant pump seals, and steam generator repairs.
Also, a review of the Licensee Event Reports for Units 2 and 3 indicate that significant improvements have been made.
Fourteen Licensee Event Reports were issued on Units 2 and 3 in the maintenance area.
This is an improvement from the last SALP period.
2.
Conclusion Category
3.
Board Recommendation D.
SURVEILLANCE l.
A~nal sis a
During the current SALP assessment period 205, hours of direct inspection effort. were applied in the area of surveillances at San Onofre Units 1, 2 and 3.
One item of noncompliance was identified:
Failure to. assure that equipment made inoperable by planned surveillance activities is returned to service in an operable status with required test procedures completed (Inspection Report 84-11, Ievel IV).
The summary assessment of individual Unit activities is as follows:
Unit 1 Unit 1 was in Node 5 for the entire assessment period and the surveillance program requirements were therefore minimal.
No significant failures or errors in the program were noted.
Units 2 and
Although only one violation was identified on Units 2 and 3, the following five major program weaknesses were identified in the licensee's surveillance programs:
Inadequate formal communications within the instrumentation and control (IRC) maintenance organizations.
Inadequate knowledge of equipment control requirements by IGC technicians.
Poor procedure compliance by ISC technicians.
Inadequate surveillance procedures in that:
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Procedures lacked detailed steps to properly restore the system under test to an operable status.
2)
Procedure failed to provide a second independent verification of actions requiring independent verification.
The licensee's management has pursued the completion of several programs to eliminate the above noted weaknesses.
The licensee dedicated considerable resources to complete review of safety-.related surveillance procedures on all three units in order to include proper restoration steps and independent verification requirements in the procedures.
The licensee responded aggressively in communicating to all station personnel each individual's responsibility to strictly adhere to procedures and require formal communications in the performance of all procedures.
The licensee completed training on equipment control requirements and has already demonstrated improvements in this area.
These corrective actions were timely, well planned and appear to be effective based on licensee performance during the last four months of the evaluation period.
The licensee surveillance program was successful in properly identifying reportable events which, with few exceptions, were promptly reported.
A total of 89 Licensee Event Reports
{LER's) on Units 2 and 3 were submitted during this period.
Of these, 20 represented errors which occurred in the implementation of the surveillance program.
Most of the errors were due to technician errors during the performance of the surveillance activities.
Overall, the surveillance program has shown an improved effectiveness over the previous SALP evaluation period'in the area of reducing technician errors during the performance of the surveillance activities.
Roughly the same number of errors were made, however, the number of surveillances performed during the period was more than double that of the previous SALP period due to the fact that Unit 3 did not'achieve initial criticality until this evaluation period.,
The scheduling anB tracking of the surveillance program by the Operations department has been'xcellent and the proper assignment of priority items has been consistent.
Technician staffing for the period was supplemented by contracted technicians to complete the large workload for 3 units.
The licensee's training programs for technicians have become more specialized with four distinct groups of technicians within the licensee's staff.
The four groups which include approximately 200 technicians are:
Instrumentation and Control, Computer, Radiological Monitor and Electrical Test.
The shortage of technicians in the industry has been recognized by the licensee and management has aggressively pursued obtaining the best qualified technicians available throughout
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Turnover of technicians is beginning to stabilize and this should result in additional improvement in the surveillance program with improved work task efficiency.
Overall, the training and qualification program for technicians is adequate, but requires continuous attention and evaluation by management until technician experience levels are improved.
2.
Conclusion Category
3.
Board Recommendation The licensee should continue to closely monitor and enforce formal communications and procedural adherence by the working level technicians, and to continue efforts to stabilize the turnover of technicians and gradually eliminate the reliance on large numbers of contract technicians.
.E.
Sire,Protection
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~Anal sis Unit l For Unit No.
1, the licensee demonstrated satisfactory safety performance in this area.
The licensee has had no violations in the fire protection area this year.
Even though the unit.
has been in a construction phase during this period, station housekeeping appeared adequate and when fire detection and suppression systems had to be disabled, the proper compensatory measures were taken.
Units 2/3 For Unit No. 2, fire protection activities appear to be adequate.
This unit had one Severity Level IV violation involving failure to provide indication of reactor cold leg temperature on the non-safety related instrument panel in the electrical penetration, area.
This item has since been satisfactorily resolved.
Twenty-one LERs were reported in the fire protection area, of which three were caused by personnel error, three were caused by defective procedures, three were caused by component failure, seven were caused by design, manufacturing, or installation error and five had some other cause.
For Unit No. 3, fire protection activities appear to be adequate.
During the year, this unit had three Severity Level IV violations involving:
(1), failure to provide indication of reactor coolant cold leg temperature
'on the non-safety related instrument panel in the electrical penetration area; (2)
failure to wrap redundant equipment power cables found to be within 20 feet of each other with a one-hour rated fire
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resistant material; and (3) -failure to provide required fire protection for safe shutdown equipment.
The above violations were all corrected in a timely manner and have been closed out.
Three IERs were reported in the fire protection axea.
Two were due to personnel error.
For all units,'raining was adequate and the fire watch personnel appear alert, knowledgeable and responsible.
The-station has its own fire department which has been at the station all year.
The licensee's reporting of fire protection system discrepancies'appears adequate.
Conclusion Category 2.
Board Recommendation Haintain current inspection level.
F.
Emer enc Pre aredness l.
A~nal sis During the appraisal period, Region V conducted a routine inspection. of the SONGS emergency preparedness program, an appraisal of the Units 2/3 Emergency Response Facilities (ERF)
and observed an emergency preparedness exercise that involved the Units 2/3 facility as well as areas common for the site.
This inspection effort totaled 599 hours0.00693 days <br />0.166 hours <br />9.9041e-4 weeks <br />2.279195e-4 months <br /> onsite (Unit 1-54 hours, Unit 2-344 hours and Unit 3-201 hours).
No violations of NRC requirements or'ignificant deficiencies were identified.
The licensee's management has continued its support of the emergency preparedness program.
When asked, management readily volunteered to be the first facility to have an NRC Emergency Response Facilities (ERF) Appraisal.
The inspection effort confirmed the licensee's ability to adequately address technical issues related to emergency preparedness and provide a sound solution.
SCE's response to NRC initiatives was clearly shown by'their timely evaluation of the items suggested during the ERF appraisal for improving the program and subsequent action deemed necessary.
The staff assigned to the emergency preparedness program and those persons filling positions in the emergency response organization are ample in numbers and these positions are well defined.
The licensee has a well defined emergency preparedness training program that has been implemented and appropriately documented.
During this period there was no opportunity to evaluate the reporting and analysis of reportable events from an emergency preparedness standpoin f F
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Conclusion Category 1 - No change from previous SALP period 3.
Board Recommendation None G.
~Geeurit A~nal sis From June 1,
1983 through September 30, 1984, Region V
conducted six Safeguards inspections at San Onofre Nuclear Generating Station for a total of 244 hours0.00282 days <br />0.0678 hours <br />4.034392e-4 weeks <br />9.2842e-5 months <br /> of inspection effort.
One inspection was a Material Control and Accounting inspection and the, remaining five inspections were in the Physical Security area.
Throughout the reporting period, all three units at SONGS were inspected and no violations were identified.
Of the total'inspection effort (244 hours0.00282 days <br />0.0678 hours <br />4.034392e-4 weeks <br />9.2842e-5 months <br />),
173 hours0.002 days <br />0.0481 hours <br />2.86045e-4 weeks <br />6.58265e-5 months <br /> were devoted to routine inspection activities and
hours were devoted to reactive effort.
a Physical security inspections during this SALP period showed licensee management to be actively involved in the overall security program.
The entire management staff worked steadily to improve the Security Plan. 'his effort resulted in a complete rewrite and approval of the station Security Plan, together with rewrite and approval of all implementing procedures.
,Staffing of the security organization was judged by NRC to be very adequate.
SONGS continued to effectively utilize a uniformed security force comprised of both proprietary and contract personnel.
The security management staff was responsive to NRC initiatives, demonstrated an understanding of safety/security issues, and actively supported the total Safety/Security Interface Program.
The individual Security Officers demonstrated a thorough understanding of security requirements and a desire to comply with these requirements.
An effective program for the reporting and analysis of reportable events was in place.
2.
Conclusion Category
3.
Board Recommendations Maintain current inspection level.
H.
R~efuelin A~nal sis
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No refueling activities were conducted during the assessment periods 2.
Conclusions Not applicable 3.
Board Recommendation Not applicable ualit Pro rams and Administrative Controls (Includes Unit 1 modifications)
l.
~Anal sis Management involvement in quality programs and administrative controls has been apparent with substantial progress being made during the assessment period to implement a unified and consistent quality assurance program applicable to all three units at SONGS.
The SONGS-1 and SONGS-2/3 site quality assurance groups were reorganized under the common control of the site equality Assurance Manager which has improved communication and control.
Various initiatives such as June 1984 Unit-1 return-to-service audit, a special quality assurance Construction Surveillance Program, a
Retrofit/Startup/Outage and Maintenance quality assurance group upgrading of procedures, twenty-four hour quality control coverage, and quality assurance involvement in a SONGS-1 technical specification surveillance requirement review demonstrate a strong commitment to prior planning and the assignment of priorities.
The SONGS-1 quality assurance organization manning level was increased above the previous manning level for Mode 5 operation and maintenance, and experienced quality assuran'ce organization individuals were assigned to SONGS-1 during modification activities.
Various computer tracking systems were developed to enhance the quality assurance organization's ability to status activities.
Corporate management was found to be frequently involved in site activities. and special corporate quality assurance audits were performed on SONGS-1 material/equipment supplier qualifications and the interface aspects of SCE/Bechtel/Impell design/analysis activities.
Inspections in 'the areas of design, design changes and modifications revealed strengths in administrative controls, procedures and implementation,
Discussions with onsite engineering personnel revealed that they had undergone training and indoctrination in the engineering and gA procedures applicable to the work to which they were 'assigne W e
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During the special team inspection the inspectors examined the Station Orders and selected Administrative, Engineering, General, Emergency, Abnormal and Alarm response procedures applicable to Unit No. 1.
The emergency and abnormal operating instructions had been written following the Westinghouse post TMI guide lines for such procedures.
The examined procedures were found to be detailed and consistent with industry and regulatory guidelines as to format, scope, and content The most significant weakness was that several procedures permit omission of steps as "N/A" with subsequent approval of the Shift Superintendent and definitive criteria had not been promulgated to define the use of "N/A" or to identify all optional steps in procedures.
The licensee is very responsive to NRC concerns in the area of quality assurance.
Investigations of quality assurance concerns are thorough and timely when the potential for safety significance exists.
Corrective actions are generally conservative reflecting consideration of the root and contributing causes.
These attributes were clearly demonstrated recently when the NRC identified the installation of some potentially nonconforming fittings of which the licensee was not aware.
The effectiveness of licensee event review groups and independent offsite review committees was examined during this assessme'nt period.
Post trip/transient reviews were conducted in accordance with applicable procedures with the cause of the event and proposed corrective actions to prevent recurrence identified in all cases.
Station incident reports were well written, accurate descriptions of the events with causes, corrective actions, and reportability clearly identified.
Management review of station incident reports was prompt and well documented.
Proposed corrective actions were entered on a tracking system to ensure resolution.
The Independent Safety Engineering Group (ISEG) is physically located onsite and functions to examine plant operating characteristics, NRC issuances, industry advisories, Licensee Event Reports and other sources of plant design and operating experience information which may indicate areas for improving plant safety.
ISEG activities are reported offsite by the ISEG supervisor to the Manager of Nuclear Safety.
The licensee has divided ISEG responsibilities into two programmatic areas:
surveillance of plant activities and review and analysis of operating experience reports.
Since the ISEG is a relatively new organization and concept, the methods of operation and responsibilities are still evolving.
ISEG surveillances were well researched and the findings or recommendations well documented.
The quality of the surveillances reflected the high experience level (20 years average)
of the ISEG engineers.
The surveillances were directed towards and appeared to be contributing to the goal of
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enhancing plant operations and nuclear safety by recommending solutions to existing or potential'problems.
ISEG personnel initially at'tempted to resolve actual or potential problems at the individual station engineer level.
Cooperation between station operations and engineering and ISEG appears satisfactory.
Where disagreements have developed, appropriate management involvement by the ISEG Supervisor and Manager of Nuclear Safety was apparent.
The independent offsite review groups (Nuclear Safety Group and Nuclear Audit and Review Committee)
appear to be effectively assessing the safety implications, of station events.
Individual safety reviews are adequately documented and checklists used in the reviews are well developed and comprehensive.
Programs to quantify and improve nuclear safety, which exceed technical specification requirements, are underway and demonstrate aggressive action by the Nuclear Safety Group and Licensee Management to enhance nuclear safety.
Licensee event review groups and independent offsite review groups demonstrate conservatism and a clear understanding of safety issues in their reviews.
Staffing is ample and experience levels exceed technical specification requirements in all cases.
Monthly management reports do not adequately reflect the independent conclusions or judgments which have been arrived at during the individual safety reviews but the licensee has agreed that corrective action in this regard is necessary and will be taken.
Unit 1 Modifications During the current SALP assessment period, 982 hours0.0114 days <br />0.273 hours <br />0.00162 weeks <br />3.73651e-4 months <br /> of direct inspection effort were applied in the area of plant modification effort.
This inspection effort resulted in the issuance of one notice of violation.
The major plant modification effort for the period involved the return to service effort for Unit. l.
Extensive field inspections were performed by the NRC during this period, including a large effort by Lawrence Livermore National Laboratory (LLL) and a
Region V team inspection.
Findings as a result of the above effort identified a in the Quality Control inspection effort used for the modifications work in that minor welding deficiencies being properly documented.
The licensee responded to finding by forming a reinspection task force in order discover if any additional deficiencies existed.
All identified deficiencies have been corrected.
weakness seismic were not this to In the area of environmental qualification, a notice of violation was issued against the design of the reactor head vent system because SCE engineering had fai3.ed to specify on the installation drawings the conduit fittings needed for sealing of the electrical conductors where they enter the valve
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solenoid operator.
The licensee took immediate corrective action and was responsive to NRC concerns.
Three Licensee Event Reports (LER) were received during this period.
The areas addressed by the LER's were as follows:
Modification to existing plant system.
Delinquent temporary change notice approvals.
Corrosion of reinforcing steel.
The IER's submitted were reported in a timely manner with events adequately identified.
Analysis of the intake structure event was described in detail and provided valuable information to the NRC.
2.
Conclusion Category
3.
Board Recommendation Maintain current inspection effort.
J.
Licensin Activities l.
A~nal sis Unit 1 This evaluation represents the integrated inputs of the Operating Reactor Project Manager (ORPM) and those technical reviewers who expended significant amounts of effort on SONGS-1 licensing actions during the current 'rating period.
The basis of this appraisal was the licensee's performance in support of licensing actions that were either completed or active during the current rating period.
These actions, consisting of amendment requests, exemption requests, responses to generic letters, TMI items, and other actions, are classified as follows:
13 completed Multi-Plant Actions included in this category are:
Decay Heat Removal Capability Technical Specifications Radiological Effluent Technical Specifications Containment Purge and Vent Reactor Vessel Cavity Seal Ring Missile Potential Automatic Actuation of Shunt Trip Attachment Thermal Mechanical Report Potential for Voiding in RCS Containment Pressure Instrument Containment Mater Level Monitor Containment Hydrogen Monitor
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Automatic PORV Isolation Report on PORV's ECCS Outages 7 completed Plant-Specific Actions included in this category are:
Two revisions to station physical security plan Technical Specifications on Coolant Activity Sampling Evaluation of Spent Fuel Pool Racks Steam Generator Inspection Program and License Condition Revisions to Appendix B (Environmental) 'Technical Specifications Revision to Boron Concentration Limits in Cold Shutdown and Refueling Other major activities during the review period were the seismic reevaluation program and SEP.
The licensee's performance evaluation is based on a consideration of seven evaluation criteria given in the NRC Manual Chapter.
For most of the licensing issues considered in this evaluation, only four of the evaluation criteria were of significance.
Therefore, the composite rating is based on the following evaluation criteria:
Management involvement Approach to resolution of technical issues Responsiveness to NRC initiatives Staffing Mith the exception of Enforcement History, for which there was not bases within NRR for evaluation, the remaining evaluation criteria below were judged to apply only to a few licensing activities.
Reportable events Training a.
Mana ement Involvement and Control in Assurin ualit San Onofre 1 has remained in the cold shutdown mode throughout the evaluation period.
During the first several months'of this period, a general slowdown of licensee activity, both in plant modifications and in licensing, was in effect.
Meanwhile, SCE management was developing plans and schedules for plant restart and -for long-term plant, retrofit.
t Management involvement over 'the last several months has
'been'ery apparent; particularly with respect to issues directly related to restart.
There is evidence of planning and assignment of priorities and that
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decision-making is generally handled at the appropriate level of management.
The licensee has proposed an "Integrated Living Schedule" to establish priorities for plant backfits and to track progress in completing these actions.
This system should be of benefit to both the NRC and the licensee.
As a result of the long shutdown, uncertainty about the schedule for return to service and the resultant reduction in effort during the beginning of the review period, many licensing issues are not yet resolved.
Increased management attention should continue in the next evaluation period to minimize schedule slippages such that these issues can be completed.
On the basis of these observations, a rating Category of 2 is assigned to this attribute.
b.
A roach to Resolution of Technical Issues from Safet
~Stand oint In the approach to safety standpoint, sound and viable.
Effluent Technical good understanding resolving them.
resolution of technical issues from a the licensee's responses are generally For example, for the Radiological Specifications, plant personnel showed of the issues and were cooperative in In the area of seismic reevaluation, the licensee is using state-of-the-art analysis methodology and criteria; the licensee has demonstrated clear understanding of the issues.
For responses to generic letters, the licensee has generally followed the guidelines provided with exceptions dictated by unique features of the plant design.
For the SEP Integrated Assessment, the licensee has provided responses to support the adequacy of the existing plant design in many areas and, where warranted, has proposed evaluation programs or other corrective measures to resolve the open issues.
These proposals are generally sound and reflect an adequate degree of conservatism.
The overall. rating for this category, based on inputs from twelve subject areas, is Category 2.
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Res onsiveness to NRC Initiatives During the first several months of the review period, licensee efforts to resolve outstanding licensing issues were, minimal for the reasons described above.
However, beginning in early 1984, the licensee has made great
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f strides in reducing the backlog of actions.
This is demonstrated by the large number of actions that have been closed out and by the eleven license amendments that have been issued since December.
In addition to the completed actions listed abov'e, the licensee has submitted license amendment applications for technical specifications on NUREG-0737 items (Generic Letters 82-16 and 83-37),
Reportable Events (Generic Letter 83-43), Auxiliary Feedwater System (TMI II.E.l.l and II.E.1.2) and dc Power Survei'llance.
These submittals generally proposed resolutions which were acceptable to,the staff, but in several instances, it was necessary',to request further information to support some of the requested changes.
The licensee has been generally responsive to NRC requests for information either by conference calls, meetings or by letter,'lthough schedule slips have occurred.
Although overall responsiveness has been good, delays for
"some TMI Action Plan items will result in San Onofre
being one of the last plants to resolve these issues.
Most of these delays arise from the slowdown period mentioned above and from the licensee devoting attention to issues required for plant restart.
The overall rating for this criterion is Category 2.
d.
Enforcement No basis exists for an NRR evaluation of this attribute.
e.
Re ortable Events Only one topic was evaluated with regard to reportable events.
This one evaluation (Category 1) was judged to be too limited a sample to provide an overall rating.
f.
~Staffin A rating of Category 2 was assigned to this attribute.
The level of staffing is considered adequate, with some delays of submittals that could be attributable to staffing levels.
g.
Trainin and ualifications This attribute was judged to apply to only a few actions.
A rating of Category 1 was assigned for those instances where a rating was applied.
h.
Assessment of Performance Attributes - Maintenance Activities The licensee's performance evaluation in this functional area is based on three of the evaluation criteria, management involvement, approach to resolution of
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technical issues, and responsiveness to NRC initiatives.
The other criteria were not deemed applicable.
As a result of the long shutdown, the decay heat level of the core is low.
The licensee has used this opportunity to perform maintenance on common portions of the residual heat removal system and the component cooling water system.
Prior to each of these maintenance outages, the licensee submitted proposed plans including compensatory measures such as enhanced surveillance, for staff approval.
In addition, battery no.
1 was replaced during the rating period.
The licensee kept the staff well-informed of its plans, and provided temporary batteries as an alternate
'source of dc power.
These activities reflected evidence of prior planning and good understanding of the associated safety issues.
The licensee was cooperative in answering staff questions and in implementing staff recommendations.
Units 2/3 The overall rating for this functional'area is Category 1.
I 2.
Conclusion In summary, licensee performance in the areas of management involvement and responsiveness has improved over the rating period.
As a result the backlog of items has been substantially reduced.
Although some Category 1 ratings were assigned, the majority were Category 2.
Therefore, an overall licensing performance rating of Category 2 has been judged.
In the functional area of maintenance, a rating-of Category 1 is assigned.
Board Recommendation Continued management attention is recommended to ensure timely completion of the remaining outstanding licensing issues.
K.
STARTUP TESTING (UNIT 3)
l.
A~nal sis During the current SALP assessment period, 233 hours0.0027 days <br />0.0647 hours <br />3.852513e-4 weeks <br />8.86565e-5 months <br /> of direct inspection effort were applied in the area of startup testing.
The resident inspectors observed startup tests performed by the licensee on Unit 3 from initial criticality on August 29, 1983 through the completion of testing on March 27, 1984.
No violations were identified in this area.
One Licensee Event Report (LER) was submitted in this area.
This event involved a technician error while performing a
startup test procedure at 20 percent power when the technician
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erroneously interrupted power supply voltage to the Reed Switch Position Transmitters for 23 Control Element Assemblies (CEA)
associated with CEA Calculator No. 2.
With the exception of the technicians error, the startup test program implementation for Unit 3 went smoothly.
2.
Conclusion Category
3.
Board Recommendation None V.
SUPPORTING DATA AND SUMMARIES A.
Licensee Activities SONGS-1 has remained shut down during this assessment
'period to
.accomplish seismic upgrading and TMI action plan items.
The licensee has requested, by letter dated August 20, 1984, permission to restart the unit which is scheduled for late November, 1984.
During this assessment period both SONGS 2 and 3 completed power ascension on testing and began full power commercial operation.
A brief summary of key events is as follows:
Unit 2 Startu 80/
power testing 100$
power testing Warranty Run Unit 2 Outa es May
June 5, 1983 June 6 - August 8, 1983 June 16 - August 18, 1983 RCP seal replacement 18 month surveillance RCP seal repair Steam generator tube leak RCP seal replacement 24 days 28 days 28 days 20 days 11 days 6/16 - 7/10/83 11/15 - 12/13/83 1/13 - 2/10/84 6/19 - 7/9/84 7/11 - 7/22/84 Initial criticality Iow power physics testing August 29, 1983 August 29 - September 5,
1983 20~/
power 50%
power 80~/
power 100/ power Warranty run September 25-October ll November
November
March 18 October 9, 1983 October 31, 1983 November 15, 1983 January 6,
1984 March 27, 1984
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Mode 5 delay for Unit 2 RCP seal repair-18 mo. surv.
Scheduled outage Turbine generator balance RCP seal repair Steam generator tube leak 55 days 2 days 17 days 22 days 18 days 1/7
- 3/2/84 3/29 - 3/31/84 5/4
- 5/21/84 6/ll - 7/3/84 7/18 - 8/5/84 34 days 6/1
- 7/4/83 Significant licensee amendments are listed in Paragraph IV.J.l.
Major modifications took place on Unit-1 during the extended outage as follows:
1)
Seismic Upgrade - the licensee's restart plan provided for upgrading systems to assure a hot standby plant condition will be achievable following an earthquake of 0.67g.
Completed work activities include:
Structural Steel Members New Auxiliary Feedwater Tank and Piping Electrical Raceway Supports Piping Supports Backup N2 for Safe Shutdow'n Valves Cross-connect of Spent Fuel Storage Pool to Charging System for use as a Makeup Water Source.
2)
TMI - The return-to-service effort included completion of modifications begun during the 1982 shutdown.
To resolve TMI action items these modifications included:
Wide Range Stack Gas Monitor Containment H2 and Water Level Monitors Technical Support Center Saltwater Intake Structure - Underwater surveillances this summer by the licensee indicated the possibility of structural degradation of the walls.
Following examination of the dewatered structure modifications were completed to restore full structural integrity and repair degraded gate slots.
The intake has been refilled.
4)
The return to service effort included completion of tasks begun in 1982:
480V Halon System Drip Shields in 480V and 4KV rooms.
5)
In addition to the upgrades noted above, the licensee has included the following within the return to service scope and has completed all required actions.
PAID Drawing Verification Replacement of Efcomatic Valve Operators Replacement of No.
DC Battery
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Replacement of Saltwater Intake Gates Installation of Saltwater Pump Check Valves Waste Gas System Improvements Replacement of Safety Related Snubbers (Mechanical for Hydraulics)
B.
Ins ection Activities Inspection activities conducted during the assessment period are provided in Table l.
Xn addition to the routine inspection program, a special team inspection of mechanical, electrical, design and
'operations activities associated with hardware modifications, plant maintenance and performance of shift personnel was conducted in July, 1984.
The team inspection involved 688 hours0.00796 days <br />0.191 hours <br />0.00114 weeks <br />2.61784e-4 months <br /> by twelve NRC inspectors and 188 hours0.00218 days <br />0.0522 hours <br />3.108466e-4 weeks <br />7.1534e-5 months <br /> by three NRC consultants.
No violations of NRC requirements were identified within the scope of the inspection.
A number of perceived weaknesses were referred to the licensee for consideration.
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A substantial amount of inspection effort, including 230 inspection-hours by two NRC resident inspectors and 756 hours0.00875 days <br />0.21 hours <br />0.00125 weeks <br />2.87658e-4 months <br /> by NRC contract personhel, was devoted to the seismic modifications on SONGS-l.
C.
Investi ations and Alle ations Review Inquiries Closed:
1-Hardware deficiencies 1-Falsification of records Inquiries Open:
4-Falsification of records 2-Illegal drug use Cases Open:
1-False statements and/or documents All allegations associated with Unit 1 assigned to the Region V
staff are closed with the exception of the following:
RV-83-A-36 - Anchor Bolts It is currently believed that this allegation has a small probability for substantiation but it only applies to work performed from 1979-1981 which predates seismic upgrade work on SONGS l.
RV-84-A-94 - Reactive A
re ate in the Intake Structures Based upon concrete testing by the licensee during the investigation and repair of intake structure corrosion problems, the Region V staff has seen no evidence that'eactive aggregate was used in the intake structur HI a
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Escalated Enforcement Actions a
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Civil Penalties:
Three civil penalties totaling
$ 165,000 were issued as described individually below.
l.
Improper isolation of charging pump rendered Unit 3
, Emergency Core Cooling System inoperable on 9/29/83.
Level III violation.
Civil penalty
$20,000.
2.
Failure to follow operating instruction S023-0-36, Control of System Alignments, associated with the above item.
Level III violation.
Civil penalty
$20,000.
3.
Improper isolation of Unit 3 containment spray system on March 4, 1983, which was not discovered until March 17, 1984.
Level III violation.
Civil penalty
$ 125,000.
b.
Orders None relating to enforcement.
~ E.
Mana ement Conferences Held Durin A
raisal Period a.
Conferences September 7,
1983 November 21, 1983 May 9, 1984 SALP Management Meeting Enforcement Conference (Discussion of circumstances behind isolation of the discharge of the Unit 3 charging pumps from the Reactor Coolant System (Report No. 50-362/83-37)
Enforcement Conference (Discussion of licensee's enforcement history and the findings of'a special, inspection conducted on March 17-19,'984 of the improper isolation of the Unit 3 containment spray system (Report No.
50-362/84-16)
August 8, 1984 Enforcement Conference (Discussion of licensee action following issuance of a Notice of Violation on May 16, 1984 involving improper isolation of the Unit 3 containment spray system (Report No. 50-362/84-26)
b.
Confirmation of Action Letters None F.
Review of Licensee Event Re orts (LER's)
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Analyses of significant LER's have been provided in the applicable functional area sections of this report.
A listing of LER's received during the assessment period is provided in Table 2.
Additionally, an analysis of LER's for the period of June 1,
1983 to Hay 31, 1984 was performed by the Office for Analysis and Evaluation of Operational Data.
The results of this analysis are presented below.
SAN ONOFRE UNIT 1 The licensee submitted 9 IERs, including revisions, for SONGS-1 during the period, June 1,
1983 to Hay 31, 1984.
In addition,
other reports were submitted by the licensee.
Based on the review of the available reports, the findings are as follows:
1.
LER COMPLETENESS a)
Mas the information sufficient to provide a good understanding of the event?
The LERs provided sufficient information to provide a
clear and adequate description of the occurrence, the direct consequences, and corrective actions.
b)
Mere the LERs coded correctly?
All of the entries reviewed appeared to be essentially correct and the system codes agreed with the information in the narrative descriptions.
One typographical error was found.
c)
Mas supplementary information provided when needed?
Supplemental information was usually provided for each of the LERs.
In two cases, supplemental information was provided in separate letters without an updated LER.
The licensee should be encouraged to submit an updated LER with supplemental information to ensure that all information pertaining to a reportable event is complete and referenced to an LER..
d)
When follow-up reports are promised, are they delivered?
The licensee generally provided promised follow-up information in a timely manner.
e)
Mere similar occurrences properly referenced?
None of the LERs referenced previous events.
2.
NKTIPLE EVENT REPORTING IN A SINGLE LER I
No 'LERs contained information in a single LER that should have been reported in separate LER a
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PROMPT NOTIFICATION FOLLOW-VP REPORTS Each of the prompt reports were followed-up by LERs or special reports.
It appears that LERs were also submitted for reportable occurrences identified in Preliminary Notifications.
In summary, our review indicates that based on the stated criteria, the licensee provided adequate event reports during the assessment period.
SAN ONOFRE UNITS 2 AND 3 The licensee submitted 237 reports, plus revisions, for the two units during the period from May 1, 1983 to April 30, 1984.
The review included the following LER numbers:
UNIT 2 UNIT 3 83-037 to 83-156 84-001 to 84-022 83-037 to 83-120 84-001 to 84-013 The LER review followed the NUREG-0161 and NUREG-1022.
and of their respective LER applicable to either unit.
findings follow.
general instructions and procedures of Because of the similarity of both units, preparers, this LER review would be THe specific review criteria and 1.
LER Com leteness a)
Was the information sufficient to provide a good understanding of the event'?
1983 LERs The LERs provided sufficient information to provide a
clear and adequate description of the occurrence, the direct consequences and corrective action.
Many LERs included specific details of the event such as the time of the event, duration of the event, valve identification numbers, ICOs that were violated, etc., to provide a more complete understanding of the event.
1984 LERs The abstract described the major occurrences of the event, including all component or system failures that contributed to the event and significant corrective action taken or planned to prevent recurrence as stated in NUREG-1022.
b)
Were the LERs Coded Correctly?
1983 LERs
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The codes the licensee selected were checked against the narrative description of the event for accuracy.
Except for a few i.nfrequent cases, AEOD agreed with the licensees selection for the coded fields.
When AEOD disagreed, it was in coded fields of lesser importance to the event described, and the disagreements occurred randomly, so no licensee misinterpretation of NUREG-0161 guidance was evident.
In addition, each coded entry was typed and centered within the code box.
There were no typos or omissions.
The form was neat in appearance and readable.
It was evident that care was used in preparation.
1984 LERs With the fewer code boxes there is much less chance for disagreement.
The only licensee error found was the omission of an event title and a typo in the event date for IER 84-06 for Unit'2.
c)
Was Su lemental.,Information Provided When Needed?
1983 LERs All of the reports that were required to be reported immediately contained the mandatory supplemental information.
In addition, a'significant number of reports contained voluntary additional supplementary information.
The attachments that were provided typically included specific information useful in assessing the full impact of the event.
However, the licensee's safety discussions were often not commensurate with our perceived potential consequences of the event, so it appeared that the safety analysis was briefest for the most potentially complicated events.
For instance, LER 83-37 reported that the feedwater logic circuitry resulted in an actual trip setpoint of 300 psid higher than assumed in the FSAR.
The licensee's safety explanation was that public health and safety were not affected.
However, it was noted that the licensee usually stated the number of available redundant systems and that reports without attachments did not need additional explanation.
1984 LERs The text of the LER satisfied the requirements of NUREG-1022.
The licensee's safety assessment of the event showed considerable improvement from the 1983 submittals but, in some cases, it still did not completely discuss the safety consequences and implications of the event.
d)
Follow-U Re orts 1983 LERs
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The licensee promised to update a significant portion of the IERs in this assessment period.
These reports were updated; they contained new information and they were updated correctly in accordance with the guidelines of NUREG-0161.
Many reports were promised to be updated by a specific date by the licensee; the updated reports were received by this date.
1984 LERs The same comments are applicable to the 1984 IERs.
e)
Were Similar Occurrences Properly Referenced'
1983 LERs Previous LER numbers of events of a similar nature appeared to be referenced correctly.
Because there were many repetitive events, the licensee would only reference the last few occurrences in lieu of all previous occurrences.
This is acceptable.
The licensee also freely referenced LER numbers of the other unit.
However, on LERs that did not reference a previous event, the licensee did not provide a statement to the effect that this is the first event of this type.
Without this statement, it is uncertain if this is the first occurrence of the event, or if the licensee failed to reference previous occurrences.
984 LERs The above comments are also applicable to the 1984 LERs, but the proportion of reports without references'seemed higher.
2.
Multi le Event Re ortin in a Sin le LER No reviewed LER contained information in a single LER that should have been reported in separate LERs.
3.
Prom t Notification Follow-U Re orts Eighteen PNs were issued in the SALP assessment period.
Eleven of these events resulted in an LER and the remaining seven events were clearly unreportable.
So, the licensee appears to be reporting all events that are required to be reporte ('
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