IR 05000213/1988099
| ML20055F608 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 07/09/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20055F607 | List: |
| References | |
| 50-213-88-99-01, 50-213-88-99-1, NUDOCS 9007180152 | |
| Download: ML20055F608 (36) | |
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U.S. NUCLEAR REGULATORY COMMIS$10N
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REGION I
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SYS?tMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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O FINAL REPORT-i
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REPORT NUMBER 50-213/88-99
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ASSESSMENT PERIOD:.AVGVST 1, 1988, TO FEBRUARY 15,~1990.
j-BOARD MEETING-DATE: ' APRIL 2, 1990
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l l-SUMMARY OF RESULTS II.A Overview The SALP results reflect a sustained high level of licensee performance.
Site management continues to promote and encourage critical self assessment of work activities.
Early assessment of safety impact and guidance for problem resolution were provided. The licensee continued to be responsive to technical issues as evidenced by the' attitudes towards procedure compliance and the findings of an interfacing system loss of coolant accident event audit.
It has been successful in promoting a questioning attitude of its staff and in insisting on-good communications.
All-seven SALP areas were rated as Category One.
Significant improvements were noted in the area of maintenance and surveillance, raising the ratings from a category two~ to a category one. This resulted from improvements in procedural adherence, technical training, communications between working groups, organizational response to problems, and control of contractors. Balance-of plant maintenance has also' improved as evidenced by plant performance.
Licensee performance in the area of plant operations continued to be a strength.
Operators were professional and they displayed a questioning attitude. There were no plant trips. The licensee promptly analyzed off-normal conditions and
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took effective corrective actions.
Although there continues to be a high level of performance in radiation protec-tion due to outstanding performance of the station staff, there appears to be a noteworthy reduction in corporate resources being applied to support continued good performance in this area.
Station-security also continues to be highly effective.
However, its future-performance may be impacted by a high turnover of personnel in the contract guard force.
-Further, during this assessment period, two significant material failures occurred;-
both concern previous modifications to the reactor vessel thermal shield attachments. These failures reflect on the effectiveness of past modification and debris control practices. Although the nature of the failures appeared minor, they resulted in dignificant consequences. NRC review of.the recovery efforts noted improvemov.s in the debris control processes and safety evaluations associated with thermal shield removal activitie ________ ___
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II.B Facility P,erformance Tabulation
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Rating Rating Last This Functional Area Period Period Trend A.
Plant Operations
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' Radiological Controls
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Maintenance / Surveillance
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Engineering / Technical Support
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Safety Assessment / Quality
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Verification
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III. PERFORKANCE ANALYSIS
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l III.A Plant Operations (HfJ Hours, 36.5%)
III.A,1 Analysis Plant operations was' rated as C ttegory 1 in the previous assessment period.
Command, control, and performante in this area was noted to be strong and licensed operators were professi'nal, knowledgeable, and thorough. Station I
directors and denartment managert were aware ol' plant status and actively involved in operations through plint operations review committee participation and normal activities.
Strong em,hasis was placed on personnel and reactor safety.
The refueling outage was much improved over previous outages with
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thorough preplanning and preparati1n prior to shutdown. The SALP recommended that the licensee consider using q;ality services division audits to aid in maintaining emergency operating procedure quality.
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This assessment is based on resident inspections, a special audit of interfac-
-ing system loss of coolant accident events, licensed operator examinations and an evaluation of the station fire protection program. The plant operated for 461 continuous days prior to the fifteenth refueling outage with no regulatory or safeguards equipment problems. The refueling outage began on September 2, 1989. This SALP period encompasses six months of this outage which has been extended for removal of the reactor vessel thermal shield and for inspection
.and reconstitution of reactor fuel.
There were no reactor trips during this SALP period.
Several unplanned power reductions were made in response to equipment failures and to support critical maintenance activities. By error, an operator manipulated an incorrect control switch which deenergized a safeguards electrical bus and caused an emergency diesel generator to automatically start and load. Operator response to off-normal plant conditions was very good.
Potential reactor trips were averted on several occasions: following charging pump and circulating water pump shaft failures, a feedwater regulating valve failure, and rod control system failures.
Operators were kr.owledgeable of plant equipment condition and status of work activities. Communications were good during off-normal plant conditions.
. Staffing remained stable with a full complement of operators for the six-shift rotation. A senior licensed operator was reassigned to a new Operations
. Assistant position to promote better scheduling and coordination of activities with other departments. Operator professionalism and conduct of control room activities continues to be a strength.
Overall, operator performance and effectiveness were considered excellent.
-Shift Supervisors maintained authority and control over operations activities.
A professional atmosphere with minimal distraction existed in the control room at all times. Despite extensive control room modification work at the end of
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the operating cycle, potentially distracting conditions were adequately con-
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trolled through cooperation between building tradesmen and shift personnel.
There were no main control board annunciators continuously illuminated during power operation.
Twr' ~ instances of manual valve misalignment were identified during the assessment pe loo.
Licensee engineering personnel found a one-half inch valve unlocked and open within the containment boundary of a demineralized water supply to containment. The volve had been incorrectly labelled and therefore was not adequately controlled as a containment boundary valve. A violation was issued because this event shoulc have been prevented by corrective actions for several violations in 1986 involving control of containment isolation valves. The second event involved the routine surveillance test identification of a mis-positioned diesel generator emergency fuel cutoff valve. The licensee's response and corrective actions to both incidents were prompt and thorough.
Four licensee event reports in the operations area were attributed to personnel error.
Two events were previously discussed; an operator error in switch manipulation and an uncontrolled containment boundary valve.
The two other errors involved an improperly secured fire watch and a degraded fire area barrier. These were isolated events and not indicative of large scale problems with personnel errors.
Corrective actions were prompt and thorough and the events did not recur.
Station directors, department managers, and corporate officers made frequent inspections of the plant and were responsive to NRC concerns. Management was closely involved in operational activities. Through use of duty officers, plant information reports, and morning planning and management meetings; operational and safety issues were effectively and expeditiously communicated.
Prompt reportability evaluations were made during the morning management meetings, Management provided early safety impact assessment and effective management guidance for problem resolution.
Plant operations review committee (PORC) performance continued to be effective.
PORC maintains a fixed routine meeting agenda and-is available whenever neces-sary for review of nonroutine items.
These practices effectively control the length and focus of routine meetings and promote prompt PORC evaluation of safety issues and temporary procedure changes. The committee maintains consis-tently high quality and critical reviews of complex issues. This was especial-ly apparent in the thorough reviews given to preoperational tests of the modified electrical distribution system and also to the design change engineer-ing ana'
is and procedures associated with the removal of the reactor vessel therma'
ield.
During the assessment period, the licensee completed the upgrade of all station procedures.
Detailed graphics and manual drawings have been added to further enhance procedure content and clarity.
Extensive procedure validation by walk through and simulator verification has proven beneficial for all station
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procedures. The attention devoted to procedure quality has continued to
promote very good procedure adherence. Station management encourages continual upgrade of procedure details. This is apparent in the positive attitude and
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enthusiasm displayed by PORC members during procedure review.
Procedure adherence and quality are a significant strength and were critical in the successful elimination of operational incidents.
An audit of emergency operating procedures (EOPs), which was recommended by the last SALP report, has teen performed by the licensee quality services division, This audit followed a third party audit conducted by the nuclear steam supply vendor and included verification of previous findings in addition to the normal scope of the E0P audits.
NRC examiners administered one requalification and four initial examinations during this assessment period.
Some weaknesses observed in one examination were corrected prior to the subsequent requalification examination.
Licensee management supports the training process and actively participates in operator qualification and requalification.
For example, the operations manager and unit director frequently monitor training and participate in candidate evalua-tions. The training staff presented a positive attitude during the preparation for, and participation in the conduct of the NRC examinations. Operator licensing candidates exhibited an excellent knowledge of plant equipment and crews communicated well with each other during the simulator scenarios.
A requalification program has been instituted for simulator instructors and experiences are communicated between the training center's four simulator staffs, Plant design change modifications were promptly reflected by modifica-tions to the simulator.
For example, the simulator presently reflects the plant configuration following extensive outage modifications to the reactor protection, electrical distribution, emergency core cooling, and nuclear instrumentation systems. These are positive initiatives which improve training effectiveness.
-A special NRC audit was conducted to identify plant equipment and procedural controls which have an important influence in interfacing system loss of coolant accident (ISLOCA) events. The team observed training strengths including instructor participation in procedure validation and simulator.
training for plant equipment operators.
However, training on ISLOCA events is lacking and the simulator is incapable of adequately representing ISLOCA scenarios.
The audit team evaluated E0P quality as good with some specific minor points for improvement noted. The licensee incorporated the appropriate procedure changes and is evaluating training program improvements and simulator modifications.
The fire protection program continues to receive firm management support.
Significant improvements have been made in the cable vault fire suppression system through tests and modifications.
This was a plant staff initiative because of the lack of original design basis and acceptance testing informa-tion. The fire detection system has been enhanced with comprehensive replace-
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ment of detectors in safeguards equipment areas. Other weaknesses in station fire barriers have been identified and rectified following an extensive survey.
Adequate program administration is provided by a full time fire protection engineer.
The licensee developed an ambitious schedule for the fifteenth refueling outage. Major planned activities included: core support barrel thermal shield modification inspection, steam generator tube inspection and plug repair, reactor protection system upgrade, new nuclear instrumentation system installation, emergency core cooling system modification, and new switchgear building integration into operating plant systems. Outage preplanning and preparations were extensive. During power operations, monthly meetings were hela with-site and corporate personnel to develop and coordinate pre-outage activities.
In summary, operator professionalism and conduct of control room operations continue to be a strength. There were no reactor trips and few operator errors.
Station directors, department managers, and corporate officers were involved in station activities, provided early safety impact assessment of events, and responded to NRC concerns.
PORC reviews continue to be thorough and attentive to reactor and personnel safety.
The operator training and fire protection programs received strong management support.
Completion of the station procedure upgrade effort is a significant acenmplishment.
III,A.2
' Performance Rating:
Category 1 III.A.3 Recommendations: None i
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r III.B Radiological Controls (295 Hours, 6.8%)
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III.B.1 Analysis
The previous SALP Report rated Radiological Controls as Category 1. Strengths included substantial involvement of site management in outage planning, promo-tion of radiological-contrcis awareness on site, and an increased emphasis on procedural compliance. Other strengths included good job control, accurate radiation exposure estimates and completion of outage work at or below those estimates; development of high proficiency in underwater work involving highly
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radioactive components; extensive use of~ robots, mock-ups and closed circuit television to reduce exposure; and a good program for corporate assessment of-
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the radiological controls program on site. Weaknesses included poor quality control and outdated equipment in the counting room, and a slow response by corporate staff to specific requests for technical assistance by the site, particularly in the area of sof tware support.
Radiological Controls:
As in the previous SALP period, management involvement in the planning of major work, and in the review and monitoring of site activities, continue to be strengths in the radiological controls program.
For example, when it became necessary to perform maintenance inside containment during power operation, planning meetings were held that included all departments involved along with station management.
Personnel exposure estimates accounted for different levels, shielding, and other relevant variables.
The calculations, together
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with operacional considerations, led to the optimum decision to perform the-work at reduced power levels with temporary shielding. The job was successfully completed without incident and with relatively low personnel exposure.
Records are well-maintained and analyses of past performance, particularly in the area of ALARA, are consistently objective and of high quality.
The technical staff consistently demonstrated a thorough understanding of technical issues that arose, and took conservative approaches'in selecting a course of action. As an example, when the National Council on Radiation Protec-tion and Measurements (NCRP) published a report indicatt19 that the radiation damage due to neutrons may have been underestimated by a factor of ten, the licensee. reduced the allowable neutron dose accordingly, even though the NRC had not adopted the NCRP guidance.
Responsiveness to NRC initiatives continues to be prompt, thorough, and well-considered. As an example, the NRC had expressed concern over the quality control program in the counting room-and the use of relatively unsophisticated
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instruments and techniques. The licensee subsequently developed a new quality
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control program under the supervision of the site health physicist; the program was-reviewed and found to be good Counting equipment has been upgraded to state-of-the-art, sophisticated, computer-controlled counting routines that substantially improve speed, ease and accuracy of counting work, and allow-
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additional quality control monitoring functions that were previously not
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possible.
The procedure revision project, started during the last assessment period as a result of NRC concerns over procedure quality, is near completion.
- The new procedures represent a substantial improvement in quality.
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There was one significant operational event involving the discovery of
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radioactivity originating from the site beyond the radiological controls area (RCA). Corrective actions were prompt and thorough. The manner of discovery of
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the activity is indicative of the high auality of the radiological controls technicians in the program. The activity was discovered during a routine survey-of the RCA perimeter. The radiation field registered only about 0.2 mR/hr on the survey. instrument. This indicates attentiveness, ability to interpret instrument response, and conscientiousness of the technician involved.
Staffing levels and personnel have not changed significantly during this assessment period. There were no vacant key positions, and the staff remains i
capable of addressing any technical problems that arise.
The stability of L
the site radiological controls and management staff is considered a strength, p
Corporate support staff has decreased and has resulted in curtailment of some
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site support activities.
l-The-training program continues to be effective and the training material continues to be comprehensive. The retraining frequency for technicians is
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somewhat less than current industry practice.
Standardized training for both of the licensee's nuclear facilities may weaken training effectiveness because t
of differences in site equipment and programs. Until recently, there was no j
formally required continuing training for the site radiological controls supervisory and management staff. Such training was being provided, but on an informal, case-by-case basis. A requirement for minimum continuing training has been adopted, l
ALARA measures continue to be aggressively pursued by site personnel.- The use L'
of robots and remote television cameras for high radiation work has been
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expanded.
New equipment to reduce personnel handling of radioactive waste has been installed and proven effective.
Primary coolant system chemistry is maintained within recent industry recommendations to effectively reduce system
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activity. The improved plant labels have reduced time spent to locate components in radiation areas.
Effective ALARA reviews and health physics controls of-work planning and performance continue to be a strength.
Although >ite initiatives in ALARA are good, corporate support has decreased
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Lthe radiological controls program were suspended and corporate ALARA initiatives were slow in implementation. The reduction in annual exposure has been relatively small in comparison with previous assessment periods.
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source reductions effork's are necessary to achieve lower personnel exposures commensurate with industry goals.
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e Effluents, Environmental Monitoring, Confirmatory Measurements. Radioactive
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Waste and Transportation:
The previous SALP noted significant improvements in the transportation program, together with continued good performance in the radioactive waste and effluents programs. During the current assessment period, inspections in the areas of liquid and gaseous effluents, radiological environmental m;nitoring, confir-matory measurements, radioactive waste and transportation programs were conducted.
No deficiencies were identified and no enforcement action was taken.
The licensee maintained excellent programs within the quality assurance area, i
through the use of audits, surveillances and quality control techniques.
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example, within the radiological environmental monitoring program, tFr !icensee conducted weekly surveillances of the meteorological tower instrumentation, and took irmediate corrective actions whenever instrumentation was de. ermined to be
outside specifications, j
The licensee has taken prompt action in response to NRC concerns.
For example, the licensee changed its counting geometries for the evaluation of
. charcoal cartridges in both the chemistry and health physics counting labs based upon an inspector's evaluation. This change was completed promptly after careful evaluations were conducted by the licensee.
The licensee has promptly and completely evaluated and reported NRC operational l
events involving radiological releases. Most notably, upon shutdown for the
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refueling outage, unexpectedly high reactor coolant system (RCS) gaseous activity was-experienced. The licensee delayed opening of the RCS for two weeks and carefully tracked isotope activity as gradual noble gas releases were made. A prompt report was made to the NRC when the noble gas releases were projected to exceed'the Radiological Effluents Technical Specification reporting levels.
Staffing levels remain good, positions were filled by experienced personnel
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who were provided training in a well defined and implemented program. The j
training program for radioactive waste workers,-both initial and periodic
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Summary:
performance in the area of radiological controls continued to show many strengths that were observed during the previous assessment period. However, some areas have declined, such as corporate support of the radiological controls program and reduction in occupational exposure.
Licensee responsiveness has resulted in all previously identified weaknesses being corrected.
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III.B.2 -Performance Ratino: Category 1 III.B,3 Recommendations Licensee:-Within six months, meet with NRC to discuss the plans for long term corporate support of health physics.
NRC:-
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III.C Maintenance / Surveillance (714 Hours 16.4%)
III.C.)
-Analysis Maintenance / Surveillance was rated as Category 2 in the previous SALP with evidence of improvements and increased management attention. Contractor work control problems indicated a need for more supervisory and quality services-attention. Balance of plant maintenance effectiveness netn d improvement to eliminate avoidable reactor trips. The procedure upgrade program was ongoing and observed to be a positive initiative. Management emphasis was placed on critical projects and rectifying continuing containment isolation valve leakage problems.
During this assessment period, there were no reactor trips over thirteen months of plant operation.
In contrast, in the previous SALP period, two trips occurred during seven months of operation due to weaknesses in balance-of plant equipment maintenance. There were seven unplanned power reductions for equip-ment corrective maintenance;- two involving primary plant systems, and five for secondary systems, Major work activities included containment air recircula-tion heat exchanger cleaning and service water and circulating water pump overhauls.
Repairs were effected expeditiously and with minimal impact on plant operations.
Control of contractor work has improved significantly.
During this assessment period, several major plant modifications were made using contractor support; including completion of the new switchgear building construction, steam generator. inspection and tube plug repairs, and reactor vessel thermal shield removal. Management controls have been strengthened and include significant improvements =in job supervision. Quality assurance surveillance activits..
have provided detailed oversight of the maintenance and modification process.
There were no incidents indicative of previous work control problems.
The attention applied to secondary and balance-of plant systems has improved
.their performance significantly. This is evidenced by their availability and
- absence of problems during this SALP cycle in comparison to previous cycles.
The licensee has completed the upgrade of all station procedures which began in 1987.
Procedures are clear, concise, and technically adequate.
Enhancements-to'the maintenance and surveillance procedures include detailed graphics, vendor manual drawings and instructions, and clearer presentation of data tables and acceptance criteria information.
Procedure validation by-pre-implementation walk-throughs and mock-up simulation continue to be an effective means of ensuring procedure quality.
Station management continues to promote the. commitment to procedure adherence and quality.
Surveillance testing was scheduled and tracked using the production maintenance management system (PMMS). With one exception, surveillances were performed within the required-frequencies. A supervisory review identified that the interval for the auxiliary feedwater initiation test was overdue by eight days l
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due to personnel error. Thorough internal audits identified two deficiencies C
which existed prior to this SALP period; an inadequate functional test proce-dure for the refueling water storage tank level instrumentation and missed
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surveillance of the fire suppression system carbon dioxide bottles in 1987.
One minor personnel error and the identification and correction of previously existing program deficiencies does not indicate program implementation problems; rather, this indicates a well-controlled testing program which is carefully scrutinized during self-assessments.
Sixteen licensee event reports (LERs) were submitted involving maintenance and surveillance of plant equipment.
Eight LERs were associated with component failures which occurred during plant operation or were identified by the surveillance program.
Four LERs involved personnel errors; two missed surveil-lances (one during this assessment period and one during the previous period)
and two inoperable fire barriers.
These errors were isolated and unrelated and not indicative of weaknesses in the maintenance and surveillance programs. Two defective surveillance procedures and one defective maintenance procedure resulted in LERs. One-LER involved a previous error in fire barrier installa-tion. Overall, reporting requirements were adhered to and corrective actions were appropriate to prevent recurrence.
The licensee maintenance organization has promptly responded to evidence of degraded safety-related equipment. The service water (SW) system performance study defined stringent SW pump performance curves and containment air recircu-lation (CAR) heat exchanger flow requirements.
During plant operation, SW pump overhauls and CAR heat exchanger cleaning were critical maintenance efforts.
Other priority maintenance was performed on an auxiliary feedwater pump and the feedwater regulating valves. Maintenance activities were well-coordinated and performed with minimal impact on safe plant operations.
A predictive maintenance program has been in place to supplement scheduled periodic preventive maintenance actions. Overall performance of those pro-grams, evaluated by their results, appears to be very good.
Detailed preoperational tests were performed for the new reactor protection systems and nuclear instrumentation systems equipment.
Several design deficiencies were discovered and were subsequently corrected. Their discovery was-due to the quality of the tests. The modifications made to these and other systems during the current refueling outage have been extensive. The licensee has developed a series of special tests, similar to preoperational facility hot functional tests.
The testing will be performed once to demon-strate safeguards equipment operability and power supply independence.
Detailed and repetitive test validation was performed on the plant simulator.
These tests are recognized as being a valuable tool in assuring the r;uality and completeness of a modification.
Station management's requirements for the conduct of this testing is viewed as a notable strength.
Following inspection of the reactor vessel thermal shield support structure modification-made during the previous refueling outage, the licensee elected to
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remove the reactor vessel thermal shield. The removal was in progress at the 4-end of this assessment period. The scope and complexity require close coopera-tion between site departments, corporate personnel, contractors, and project managers.
Personnel involved have performed very well.
Licensee management has stressed procedure adherence with good results.
The site chemistry department has developed an augmented fuel integrity moni-toring program based on research results of the unique fuel cladding failures experienced during the last operating cycle. An extensive surveillance program has been implemented to maintain the high quality and accuracy of chemical and radiochemical measurements at the station. Areas included are: controls over reagents, standards, the sample process, instrumentation and analysis.
The reactor containment systems have historically performed poorly during leak rate testing due to valve leakage. The licensee has continued to improve containment performance through valve modifications.
The next containment-integrated leak rate test is to be performed prior to-startup from the current refueling outage.
Extensive work was performed within the steam generators during this refueling outage.
In addition to routine tube inspections, all mechanical plugs installed in hot leg tubes were modified with a device to prevent plug intergranular stress corrosion cracking failures. The steam generator activi-
-ties were performed by a contractor using robotic equipment.
Substantial-equipment qualification and personnel training was conducted on the steam generator mock-up. Management attention to this activity was evident and contractor control was good.
Station management has strongly supported technical training programs offered by the licensee's training center.
Significant efforts have been made to improve the effectiveness of technical training. The training staff has conducted learning studies which address both the students' short-term perfor-mance and long-term retrieval of information.
Changes were made within the classroom and laboratory environment based on the results of university studies and professional evaluations of licensee programs. Techniques were implemented to further motivate students, improve retention, and improve instructors'
teaching skills. These changes have resulted in a 15% improvement in test scores. The licensee is presently evaluating student long-term information retention.
Training has been conducted on equipment for plant design changes prior to installation in the plant including; chemistry laboratory equipment, electrical-static inverters, and reactor protection system equipment. A special class was conducted using the plant's new nuclear instrumentation at the training center
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prior to its delivery to the site.
Laboratory classes are offered using-equipment with installed faults. A data link to the nuclear plant reliability data system and PMMS provides student interaction with the systems and training in administrative controls. The site chemistry manager has been a guest lecturer in gamma spectroscopy courses. Quality services division personnel
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have been included in technical training skills classes. These initiatives
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are characteristic'of an innovative and progressive training program.
In summary, overall performance-in work quality and effectiveness have improved significantly. This is due.to management attention, procedure adherence, quality assurance surveillance, application of resources, and development of technical training programs. -Management continues to monitor the performance in this area as well as provide the motivation for continued improvement.
Supporting groups such as engineering and quality assurance are involved with maintenance activities and are providing support. The organizations performing maintenance and surveillance activities provide quality services which support highly reliable plant operations..
III.C.2 performance Ratino:
Category 1 III.C.3 Recommendations: None
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III.D Emergency Preparedness (222 Hours. 5.1%)
III.D.I Analysis During the previous SALP period, this area was rated Category 1.
This rating was based on excellent performance during a partial-participation exercise.
-No exercise weaknesses were identified. No deficiencies in the emergency plan were identified during routine inspections. The licensee had developed and maintained a strong emergency preparedness program.
During this inspection period four inspections of emergency preparedness activities were conducted. Two inspections were routine evaluations of the emergency preparedness program, follow-up of licensee response to previously identified items, and changes to emergency plans and implementing procedures.
The other inspections were the observation of full-and partial participation emergency exercises.
Management involvement in emergency preparedness is effective and extensive.
Corporate and station managers maintain emergency response organization position qualification, review and approve plan and procedure changes,
. participate in drills and exercises, resolve audit noncompliance issues, exercise oversight functions, and interface with Connecticut state and town governments.
Emergency preparedness policies and procedures are clearly delineated in corporate administrative procedures which assign the emergency preparedness program services and tasks. These procedures adequately ensure corrective actions are taken, response to reportable events is prompt, and the findings of the 10 CFR 50.54(t) audits are addressed.
There are numerous examples where resolution of technical issues continues to be very good and demonstrates a commitment to quality.
Emergency plan imple-menting procedures were revised to reflect human factor engineering principles.
A statistical performance basis was developed for the field collection of iodine. Adoption of procedures based on this methodology reduces collection time and minimizes emergency worker exposure while ensuring adequate sample activity.
The licensee reviewed default iodine-to-noble gas ratios as a function of release pathway and determined the values were consistent with accident data and emergency off gas system design and specifications. Personal computer software has been developed for the thermal-hydraulic analysis of severe accidents.
Effective use of this software was demonstrated during the exercises.
The' licensee has been responsive in resolving NRC concerns. Although not yet completed, the licensee will be relocating the mock control room used during exercises to a room adjacent to the c, 'rol room, but outside the vitsi area.
This new mock control room will provide niore space and corrects wea',nesses regarding status boards, reference material, and control room noise and conges-tion.
In addition, the licensee has committed to use the Haddam Neck simulator, located at the Millstone Training Center, to further enhance the training effectiveness during emergency exercises beginning in 1991. The licensee has also been responsive in adapting a two-hour default release duration in the dose assessment procedures.
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Staffing of the emergency preparedness organization is stable with a
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well qualified staff available to maintain an effective emergency preparedness i
program.
Personnel with operations backgrounds needed to develop scenarios are drawn from the station staff on a temporary duty basis. The Haddam Neck senior site nuclear emergency preparedness coordinator maintains a very effective site emergency preparedness program. He maintains an ongoing liaison'with the station nuclear services director, maintains the site emergency operations facility in a state of readiness, and participates-in scenario development.
Program staff regularly meet with state and town officials to ciscuss emergency preparedness issues including emergency action levels, protective action recommendations and posture codes. These officials have also been appropriately trained in their emergency response roles.
Frequent drills are held with offsite organizations. The public alerting.
system is well-maintained with 97% availability, a value which exceeds Federal Emergency Management Agency standards.
l A very effective emergency preparedness training program has been implemented and is maintained by the training department, as was amply demonstrated by the performance of the Haddam Neck Plant and Northeast Utilities corporate person-nel during the two evaluated exercises and by response to a real fire within the protected area. The basis for the training is clearly described in the recently approved Nuclear Training Manual which delineates policy, specifies the training matrix, lists course content, and states requalification policy.
In summary, the licensee maintains a strong and effective emergency prepared-ness program. Management remains involved with a demonstrated commitment to quality. Technical issues are promptly resolved and appropriate response is given to NRC concerns.
The emergency preparedness program staff is stable and well-qualified to maintain an effective program. Training is well-developed and is effective as demonstrated by exercise performance and response to a fire within the protected area.. A good working relationship is maintained with the state and towns with regular meetings, training and frequent drills.
III.D.2 performance Rating: Category 1 III.D.3 Recommendations: None
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III.E Security (95 Hours, 2.2%)
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III.E.1 Analysis I
During the previous assessment period, the licensee's performance in this y
are:. was rated as Category 1.
This rating was based upon the licensee's good
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onforcement history, implementation of a high quality self-appraisal and audit program, excellent responsiveness to the NRC, continuing corporate and plant management support, and effective management attention to the implementation i
of the security program.
!
During this assessment period, two routine inspections were performed by region-based inspectors.
Routine inspections by resident inspectors were conducted throughout the period.
The licensee continued to implement a high quality and effective program and no violations were identified.
The corporate security organization continued to be actively involved in the.
site security program. Nuclear security expertise was apparent in both the L
corporate and onsite security organizations.
The continued effectiveness of L
this program is attributed to the knowledge, experience and professionalism of site security management who implements the program and to the plant manage-l-
ment involvement in and support for the program.
Corporate and site security management continued to actively participate in the Region I Nuclear Security Association and other groups engaged in nuclear plant security matters. This demonstrated continued corporate and plant management support for and attention to nuclear security.
Plant security management maintained excellent rapport and effective communications with other plant groups and plant personnel displayed a very professional attitude toward the program and members of the security force.
Near the end of the previous assessment period, a new security manager was appointed. During this assessment period, the security manager and s
his staff continued to seek ways to improve and enhance the security program.
l As a result, potential problems were identified and corrected before they l-became regulatory issues. The effectiveness of the program can be directly attributed to this aggressive approach. The security manager and his staff
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also continued to demonstrate excellent responsiveness to NRC concerns.
This was evident by the licensee's prompt correction of minor problems identified by the NRC during inspections.
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The plant security manager and his staff are well-trained and qualified securi-ty professionals who were vested with the necessary authority and discretion to ensure that the security program was carried out effectively and in compliance with NRC regulations.
Corporate support for security program needs continued to'be aggressive.
This was demonstrated by the licensee's upgrading of the main. access center, the protected area intrusion detection equipment, assess-r I
ment system and barriers, vital area doors, the procurement of new search equipment for use in the main access center, and new, more effective response
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force weapons. These upgrades represent a prognosticative management approach
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to plant security and are indicative of a licensee with a commitment to a'high quality, effective program.
The security force training and requalification program was well-developed and administered by an experienced contractor staff of two full-time and four-part-time (shif t assigned) instructors, and a full-time supervisor. Training facilities are provided onsite and were considered to be adequate.
In addi-tion, the licensee budgeted resources for special, offsite training courses for members of its proprietary security ttaff during this period. Weekly contingen-cy drills were effectively used for security force training purposes including comprehensive critiques that were fed back into the formal training and requalification program. The plant operations department participated monthly in contingency drills with postulated events that could have an effect on plant operations, These efferts to provide effective training for both plant operations and the security force are further indications of a licensee that is intent on implementing a high quality security program.
The licensee event reporting procedures were found to be clear and consistent with the NRC reporting requirements.
Eleven event reports were-submitted to the NRC during the assessment period. Three of the events involved security force personnel errors; two involved inattentive security force personnel; and three involved the loss of power to security systems The remaining three events were not attributable to the security organization or equipment. All of the events were properly reported to the NRC, While the licensee's corrective actions for each event were timely and proper, the events involving personnel error and inattentive personnel raised NRC's concern over security force performance. This concern was further validated by review of the licensee's safeguards event logs for this period, The review indicated a number of events, although minor, arising from security force personnel errors, The licensee is sensitive'to the problem and has initiated actions to determine the cause.
While the licensee is focusing on improving first-line supervision by conduc-ting supervisory evaluations and providing special supervisory training in an attempt to correct the problem. Training personnel have also been assigned to each shift to monitor performance, and an attitude evaluation by a certified psychologist s being carried out to determine if some other problem may exist.
These actions f urther illustrate the licensee's attention to the program and responsiveness to NRC concerns.
Staffing of the contract security force was consistent with program needs as evidenced by the limited use of overtime during the period, The security force was supplemented by additional contract watchpersons during plant outages to oreclude stress and fatigue on the regular force.
However, the contractor encountered an attrition rate of about 50% during this period. Almost all of the attrition involved personnel with less than two years of service leaving for other employment.
The. licensee is working with the contractor to explore ways to reduce the attrition rate.
The NRC is concerned that the high attri-tion rate may impact on the performance of the security force.
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During the assessment period, the licensee submitted three revisions to the
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security program plans under the provisions of 10 CFR 50.54(p). These revi-sions were well-prepared, technically sound and well-coordinated with the NRC.
These plan changes reflected a comprehensive understanding of NRC requirements.
Summary The licensee continued to maintain a very effective security program that exceeded regulatory requirements.
Significant enhancements were made to the program during the assessment period which demonstrated corporate and plant management attention to and interest in the program. The licensee's initiative in identifying and correcting potential weaknesses in systems and equipment during this period are commendable and demonstrated the commitment to maintain an effective and high quality program. Additionally, management's responsive-ness to NRC-identified concerns regarding. personnel error and inattentive personnel demonstrated a positive commitment to an aggressive and effective program. However, a high turnover rate within the security force may have an adverse impact on performance in the future and must be closely monitored by the licensee.
III.E.2 performance Rating:
Category 1 III.E.3 Recommendations: None
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III.F Engineering / Technical Support (644 Hours. 14.8%)
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III.F.1 Analysis This area was rated as category 1 in the last SALP period. There were many strengths noted in the previous SALP, and problems identified were relatively minor in relation to the many positive engineering factors.
Several design projects have been completed during this SALP period which l
required effective corporate engineerir.g planning, design and implementation.
This work included the reactor protection system (RPS) and nuclear instrumen-tation system (NIS) replacement, completion of the new switchgear building, compit: tion of the high pressure safety injection (HPSI) recirculation modifi-cations, containment cooler cleaning, design basis effort to increase the allowable service water temperature and the correction of single failure vulnerabilities related to the charging pump. The licensee's efforts in these areas have demonstrated their knowledge of the design and capabilities of the plant and the equipment to be installed. The RPS and NIS modifications made this outage were licensee initiated projects and demonstrated the licensee's efforts to maintain plant reliability and safety. The licensee's program for control of minor modifications was determined to be adequate and included appropriate safeguards to prevent misuse of the system. Corporate review of minor modification packages is an added safeguard for assuring all requirements are met.
Quality assurance personnel were effectively involved in the design and modification process. Management support and involvement was evident by the audit si the plant design change process requested by the vice president of nuclear operations, The results of this audit indicated that the design
. engineering was functiodng well, only two minor findings related to documentation were identified.
An inspection was conducted to review the licensee procurement and vendor interface programs.
Deficiencies in dedication and documentation, prior to June, 1988,.were identified in the procurement of commercial grade items intended for safety related applications. This resulted in the safety related application of certain components of unverified quality. Since June, 1988, the licensee's procurement and dedication programs have. improved significantly with the implementation of procedures for procurement, upgrade, and dedication of commercial grade parts. This procedure provides reasonable assurance that parts procured and dedicated under its provisions are suitable for safety related applications.
The licensee has established a separate section within the engineering department for procurement control of safety related materials.
This group is also performing reviews of the deficiencies identified by the team inspection. Weaknesses were also identified in assessment and disposi-tioning of vendor technital communications which describe changes in equipment maintenance and potenti'al safety concerns.
The licensee has instituted a procedure for review of this information.
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The licensee has performed comprehensive reviews of the safety. significance of o.
modifications prior to initiating their design and installation. Modification packages to eliminate water hammer in the service water system and the HPSI pump minimum flow line were of. good quality, There is a good working. relation-ship between the plant and corporate engineering staffs. During modification installation, the corporate engineers frequently were at the plant to answer questions and monitor work activities. These engineers were also present-during testing to assure the installations worked as designed.
Thirteen LERs involved engineering and technical support; ten were attrit'uted to design, manufacturing, and installation errors; the remaining three involved personnel errors and component failures. The design errors were identified through surveillance testing and corporate and site engineering personnel reviews. The identification of these errors indicates thoroughness and a prevalent questioning attitude. These problems were quickly elevated to station management attention and evaluated for safety significance and report-ability by the plant operetions review committee.
Preliminary information was provided to the resident inspectors and timely notification was made to the NRC.
During this assessment period the licensee resolved several long-standing issues including 10 CFR 50.62, " Anticipated Transients Without Scram",10 CFR 50.44, " Combustible Gas Control",10 CFR Appendix R " Fire Protection Program for Nuclear Power Facilities Operating Prior to January 1,1979" and Generic Letter 83-37, "NUREG 0737 Technical Specifications". The closure of these items required meetings, conference calls and requests for additional informa-tion.
In all cases the licensee provided the appropriate analysis and informa-tion to substantiate their positions.
Licensee management attention and
. involvement have been evident in their continued attention to reducing the licensing backlog.
In addition, the licensee has completed several reviews including the control room design review summary report, fire hazards analysis and the Appendix R compliance report.
The corporate engineering department was actively involved in the control, evaluation and performance of the in-service inspection (ISI) program. Active participation by the corporate engineers was evident and.they were on site on a regular basis.
Engineering demonstrated a good perspective and knowledge of the completed and scheduled inservice inspection testing. Good management control systems, which assure that modifications are incorporated into the ISI program and which control nonconforming items, are evident in this area. The use of unresolved indication reports and nonconformance reports assures that
'ISI findings are documented, tracked, and properly dispositioned.
Development of an easily removable, leak-tight plug-a plug to prevent release of the steam generator tube plug top in the event of.circumferential cracking,.
indicates that the licensee is planning for the future when tubes in the steam
. generators will require removal of the plugs and sleeving of tubes to maintain the heat transfer capability of these steam generators. Development of the photographic means for verifying proper plugging of the steam generator tubes indicates the licensee's desire to maintain positive control of the condition of the' steam generators.
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The licensee has implemented several innovations to provide more accurate and
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better analysis of the condition of the steam generators. These include extensive training of the contractor eddy current operators and analysts for plant specific-. information including the steam generator mock-up, computer-screening as a secondary analysis, and multiple reviews for date, questioned by the analyst.
Review of water chemistry data shows that the licensee is main-taining good primary and secondary water chemistry. These actions indicate that the licensee is using the latest technology to assure the integrity of the steam generators.
During the outage, debris-induced fuel damage and damage to the reactor vessel thermal shield supports were identified.
Extensive fuel inspection, cleaning, and reconstitution were necessary.
Ninety-two fuel assemblies were reconstituted with no major incidents. Approximately 1.4% of the reactor fuel rods suffered through-wall cladding damage during the last operating cycle due to long-term fretting of the metallic debris. The debris is believed to be stainless steel, I
m; chine chips which escaped the controls for their capture and cleaaup during
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the last outage's modifications to the reactor vessel thermal shield supports.
The licensee elected to remove the thermal shield; this work was in progress at the end of the assessment period.
Previous efforts to control debris were not successful. However, the recovery efforts from fuel and thermal shield support damage which includes improved debris control processes and safety evaluations are indicative of a strong engineering / technical support program.
During this SALP period the licensee has maintained the strengths identified in the previous SALP. :The plant design change and minor modification programs have been effective and several major modifications have been installed.
Several long standing licensing issues were resolved during this period and support to plant operations has been good. The procurement and vendor interface programs have significantly improved. The ISI program centinues to be effectively implemented. Although the previous thermal shield modification was unsuccessful,-the recovery effort was well-planned and thoroughly analyzed.
Overall the quality of engineering activities has remained high.
III.F.2 Performance Rating:
Category 1 III.F.3 Recommendations: None i-h,
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III.G Safety Assessment / Quality Verification (787 Hours, 18.2%)
r III.G.1 Analysis This functional area evaluates the licensee's performance in activities such as safety reviews, responses to NRC generated initiatives such as generic letters,
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bulletins, information notices, and resolution of TMI items, and provides a broad assessment of the licensee's ability to identify and correct problems related to nuclear safety.
It includes the effectiveness of the licensee's quality verification function in identifying and correcting substandard or anomalous performance and precursors of potential problems, and in monitoring the overall performance of the plant.
In the last SALP, Safety Assessment / Quality Verification received a Category I rating.
Strengths were the continued corporate and station management commit-ment to plant safety, the procedure upgrade program, management emphasis on procedural compliance, maintenance and use of the "living" probabilistic safety study, and improved ALARA program.
Untimely transmittal of licensing submit-tais to NRC remained a weakness.
This assessment is based on resident inspections, a team inspection of the licensee vendor interface and procurement orograms, and three technical audits.
The audits concentrated on information collection in the areas of hydrogen gas distribution in vital areas, interfacing system loss of coolant accident (ISLOCA) events, and reactor protection system replacement. The licensee was cooperative during the audits and demonstrated an excellent knowledge of plant operation and configuration. Observations made during the ISLOCA audit and the licensee response are discussed in the Plant Operations area.
Station management has encouraged all personnel to maintain a questioning attitude during routine activities in an effort to reveal previously unidenti-fied conditions which are adverse to safety.
During this assessment period, plant personnel have continued to critically evaluate plant conditions for safety concerns.
Several problems were identified including the unmonitored release path from the spent fuel building floor drains, the uncontrolled containment boundary valve, and potential single failures in the auxiliary feedwater and charging pump lubricating oil systems.
The conscientious plant staff has significantly contributed to plant safety.
During this assessment period, plant operations review committee (PORC)
performance continued to be effective. Dissenting opinions were encouraged and resolved to committee member satisfaction.
In particular, the committee assured clarity and consistency among procedures. The thoroughness and consid-eration for personnel and reactor safety were characteristic of PORC perfor-mance.
For example, the reviews of the special tests for preoperational
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testing of the new switchgear building were especitlly thorough.
PORC members reviewed safety evaluations for the procedures and requested additional reviews prior to procedural approval.
Particular attention was given to the condition of the reactor fuel and plant systems during testing.
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- Licensing activity during the SALP period remained high.
Forty-five licensing actions were completed during this 18-month period.
In addition to routine actions, major activities completed included several long-standing NRC concerns such as hydrogen control, TM1 Technical Specifications (TS), and Regulatory Guide 1.97.
In addition the NRC technical review for several major licensing projects such as ATWS exemption, degraded grid, RPS replacement and the standard format TS (STS) upgrade have been completed. The staff has found the licensee submittals to be technically sound and to reflect good engineering practices.
The numerous follow-up requests for information reflect the complexity of the issues under review rather than inadequate submittals.
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The licensee responses usually reflect an excellent understanding of the regulatory and technical issues.
The licensee has continued use of the integrated safety assessment program (ISAP) and integrated implementation schedules.
The staff is reviewing the
' integrated implementation schedule amendment. The high conformance rate
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with the proposed integrated implementation schedules verifies that the ISAP methodology and integrated schedules are working.
However, the scheduling of several ISAP projects seemed to be biased because of economic considerations.
It should be noted that the weighting has manifested disagreements in priority in about five of 80 issues.
In response, the licensee has increased the weight of the public safety benefit.
This is a positive step in providing a schedule that will help maintain or improve plant safety, reliability, and availability.
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The previous St.LPs noted that several licensing submittals were untimely.
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While the integrated schedule is met about 90*4 of the time, the licensee was
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several months late with submittals regarding the Appendix R compliance report, the standard-format TS submittals, hydrogen control, large break LOCA and control' room design review human engineering deficiencies review schedules.
The large break LOCA submittal was delayed because the licensee experienced technical problems.
The licensee has been overly ambitious in p.oviding
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schedules and determining the resources necessary to meet the proposed schedules.
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The licensee has submitted a series of requests for amendment to their l
operating license TS.
When approved, an entirely new document will follow the i
standard' format of NUREG-0452, Revision 4.
Significant improvements will be l
- gained in specifications for core cooling.and emergency power systems.
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accommodate.the need for procedural implementation of the new TS, an entire set h
of procedures was written, reviewed and approved in parallel with the normal
. procedure review process. To differentiate beti;een the two sets of procedures,
the new procedures are printed on distinctively colored (pink) paper. They l'
have been validated, and will be simultaneously implemented with the new TS.
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During this SAlp period, the staff evaluated the 10 CFR 50.59 reviews for the
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thermal shield removal, fuel reconstitution, and the reactor protection system E
(RPS) upgrade. These reviews included meetings, conference calls and written requests for additional information. Generally, the licensee made conservative assumptions in determining the existence of unreviewed safety questions.
Overall, the plant design packages were found to be appropriately detailed i
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and technically. complete. NRC questioned the upgrade of the RPS because the technology inherent in the new software-controlled system could present possibilities for malfunctions of a different type than previously analyzed.
The safety evaluation was under review at the end of this assessment period.
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In summary, corporate and plant management has maintained the strengths identified in the previous SALP. The licensee has closed several long-standing NRC concerns.
In addition, the licensee has completed several major modifica-tions which have been planned for several years. These items improved plant safety and represent engineering and corporate involvement to resolve regulatory.
and plant initiated safety concerns. The licensee has been untimely with several licensing submittals due to an overly ambitious work schedule.
III.G 2 Performance Rating:
Category 1 III.G.3 Recommendenons: None
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REFERENCE INFORMATION
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A.
SALP CRITERIA
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Licensee performance is assessed in selected functional arm s significant to nuclear safety and/or the environment. The following criteria were used as appropriate to assess each functional area.
1.
Management involvement and centrol in assuring ruality.
2.
Approach to resolution of w chnical issees fror,a safety standpoint.
3.
Responsiveness to NRC inittstivess 4.
Enforcement history.
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Reporting and analysis of reportable events.
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6.
Staffing (including management)
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Training effectiveness and qualification.
Based upon the SALP Board assessment, each functional area was classified into one of three performance categories.
Those categories are:
Category 1.
Licensee management attention and involvement are readily l
evident and place emphasis on superior performance of nuclear safety or
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safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriate.
Category 2.
Licensee management attention to and involvem6nt in the
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performance of nuclear safety or safeguards activities are good.
The licensee has attained a level of perfcrsance above that needed to meet regulatory requirements.
Licensee renurces are adequate and reasonably allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at no: 441 levels.
Category 3.
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements.
Licensee resour:es appear to be.
strained or not effectively used. NRC attention should be increased above normal levels.
The SAlp Board also considered categorizing performance trends over the SALP assessment period. A trend was assigned only if a definite trend of perfor-mance was discernible and continuation of the trend may result in a change in performance rating. The SALP trend categories are:
Improvino: License"e' performance was determined to be improving during the assessment period.
Declining: Licensee performance was determined to be declining during the assessment period and the licensee had not taken meaningful steps to address this pattern.
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B.
Licensee Activities The station operated at power for the first thirteen months of this assessment period. During operation there were several unplanned power reductions in response to equipment failures and to perform critical maintenance. These activities centered primarily on secondary plant equipment with the exception of cle:ning of the containment air recircula-tion heat exchangers and fan motor coolers and repair of containment isolation valves in the heating steam system.
The reactor was shut down for the Fifteenth Refueling Outage on September 3,1989 after having operated for 461 days. hjor outage activities included core support barrel thermal shield modification inspection, steam generator tube inspections and plug repairs, reactor protection system up-gradt. new nuclear instrumentation system installation, emergency core cooling system modification, and Appendix R switchgear building integra-tion into operating plant syssems. During the core barrel thermal shield inspection, the licensee identified vibration-induced damage to the modification performed the previous outage. The licensee elected to remove the thermal shield; this work was in progress at the conclusion of this assessment period. Additionally, large amounts of debris-induced fuel damage were identified. This necessitated extensive fuel inspec-tion, cleaning and reconstitution efforts which were concluding at the end of the assessment period. The licensee projected that the thermal shield removal and fuel reconstitution will extend the outage approximately 30 weeks, C.
Direct inspection and Review Activities Two NRC resident inspectors were assigned to the site throughout the assessment period. Total NRC inspection ef fort was 4,344 hours0.00398 days <br />0.0956 hours <br />5.687831e-4 weeks <br />1.30892e-4 months <br /> (2,818 hours0.00947 days <br />0.227 hours <br />0.00135 weeks <br />3.11249e-4 months <br /> per year).
Special team inspections were made of the Procurement and Vendor Interface Programs (January 30 - February 10,1989) and the annual Emergency Plan-ning exercise (April 22,1989).
A special audit of Interfacing System Loss of Coolant Events was conducted on July 24 - August 4, 1989, D.
Unplanned Trips and Forced Shutdowns There were no reactor trips or forced plant shutdowns during this assess-ment period.
E.
A11ecations There was one allegation received during this assessment period.
It concerned an individual's fitness for employment (RI-89-A-0065). The allegation was investigated and closed in NRC Inspection Report 50-213/89-10.
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F.
Management Conferences
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On August 20, 1988, a meeting was held at NRC Headquarters Offices to discuss potential fire protection exemptions resulting from plant modifi-cations.
On October 27, 1988, a meeting was held at the Haddam Neck site to discuss the previous SALP report.
A meetir.g was held at the Northeast Utilities Corporate Offices on Febru-ary 13, 1989 to review the status of TMI Action Plan Items.
On February 27, 1989, in the Region 1 Office, the licensee presented the Preoperational/Startup Testing for the New Switchgear Modifications to meet 10 CFR 50, Appendix R.
A meeting was held at the Region 1 Office on March 9, 1989, to discuss the Licensed Operator Requalification Examinations.
The Annual Facility Status Presentation was given by the licensee on July 21, 1989 in the Region I Office.
The conversion to zircaloy clad fuel was discussed with the licensee at NRC Headquarters Offices on August 10, 1989.
On October 25, 1989, at the NRC Headquarters Offices, the licensee de-scribed the discovery of degraded reactor fuel during the refueling.
Licensee actions regarding the degraded fuel and thermal shield supports were discussed at NRC Headquarters Offices on December 21, 1989, outage On February 22, 1990, a meeting was held at NRC Headquarters Offices to discuss the conclusions of the Interfacing System Loss o Coolant Event Audit.
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G.
Licensee Event Reports (LERs)
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LISTING OF LERs BY FUNCTIONAL AREA
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ARL A
B C
D E
X TOTA' $
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ant Operations
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Quality Verification
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Totals:
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Cause Codes A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error
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C - External Cause 0 - Defective Procedure
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E - Component Failure X - Other i
- Cause' codes in this table are based on inspector evaluation and may differ from those specified in the LER t
G.1 Report Quality
LERs adequately described all the major aspects of the events, including all contributing component or system failures and significant corrective
actions taken or planned to prevent recurrence.
Narrative sections were r
well-written and typically included detailed information pertinent to the event.
Root causes and previous similar events were identified.
System and component diagrams were provided for more complex events to enhance clarity.
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G.2 Causal Analysis Thirty-four LERs and eleven safeguards event reports were submitted.
Thirty-one events were classified as errors; 15 personnel, 12 design and installation, and four defective procedures.
Twelve events were related to equipment failures.
Within the group of errors, 16 reports describe conditions which were undetected prior to this SALP period. Ten have existed since initial power operation in 1968.
The identification of these deficiencies indi-cates that the licensee continues to critically examine existing plant systems and equipment against the design basis and regulations.
Five LERs related to deficiencies in the service water (SW) system were identified as part of the continuing effort to verify the SW design basis.
Eight LERs concern the Fire Protection Program.
Four discuss inoperable or degraded fire area barriers and two relate to fire protection system design deficiencies which have existed since initial installation.
The discovery of these is attributable to an increased plant staff awareness and appreciation for fire barrier locations and requirements.
The twelve corrponent f ailures reported were n.4..anical equipment failures which necessitated repair and some adjustment to the maintenance program for each component such as preventive maintenance of the post accident sampling system.
Of the eleven safeguards event reports; six were attributed to personnel error.- These events raised NRC concern over security force performance.
The licensee is sensitive to this concern and has initiated actions to determine the cause and develop corrective actions.
With the exception of the personnel errors in Security, there was no indication of common causes and recurrences in the LERs. This suggests that the licensee root cause analyses and corrective actions were-effective in preventing event repetition. A relatively large number of reports described plant design deficiencies which existed since initial plant operation and were identified and corrected during this assessment period.
Their identification represents critical self-assessments and the questioning attitude of the staff.
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TABLE 1
Enforcement Summary
ENFORCEMENT / SEVERITY LEVEL
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AREA
2
4
DEV TOTAL
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Plant Operations
1-i Radiological Contrnis
1 Maintenance / Surveillance Emergency Preparedness Security Engineering / Technical Support
1
Safety Assessment /
.
Quality Verification
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Totals
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TABLE 2
!
IN$pECTION HOUR $ SUMMARY AREA HOURS
% OF TIME Plant Operations 1587 36.5 Radial: vical Controls 295 6.8
,
Maintenance /Surve111thee 714 16.4 l
Emergency' Preparedness 222 5.1 Security
2.2 Engineering / Technical Support 644 14.8 Safety Assessment / Quality Verification 787 18.2 Totals 4344 100.0
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