IR 05000220/1986099
| ML20150F003 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/01/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20150E938 | List: |
| References | |
| 50-220-86-99, 50-410-87-99, NUDOCS 8807180087 | |
| Download: ML20150F003 (131) | |
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l ENCLOSURE 1 U.S. NUCLEAR REGULATORY COMMISSION REGION I'
i SYSTEMATIC ASSESSMENT GF LICENSEE PERFORMANCE REPORT N0. 50-220/86-99 and 50-410/87-99 (AMENDED)
NIAGARA MOHAWK POWER CORPORATION NINE MILE POINT UNITS 1 AND 2 ASSESSMENT PERIOD: UNIT 1 - Novembe'r 1,1986 to February 29, 1988-UNIT 2 - February 1,1987 to February 29, 1988
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BOARD MEETING DATE: March.28, 1988
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1 l SUMMARY FUNCTIONAL AREA HOURS % OF TIME Operations (3307) (50.4) Unit 1 1147 1 . Unit 2 2160 32.9 Rad Protection 625 9.5 Maintenance 718 10.9 Surveillance (1054) (16.1) Unit 1 163 . Unit 2 891 13.6 Engineering /
Technical Support 418 6.4 Security and Safeguards 256 3.9 Emergency Preparedness 182 2.8 Assurance of Quality * Training and Qualification Effectiveness * Licensing **
Total 6560 100 %
Hours expended in the areas of assurance of quality and training are included in other functional areas, therfore, no direct inspection hours are given for these area Operator licensing activities are not included with direct inspection effort statistic **
Hours expended in facility licensing activities are not included in direct inspection effort statistic T2-7 A
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TABLE 3 LICENSEE REPORTABLE EVENTS Cause Determined by SALP Board An assesment has been conducted to determine the root cause of each event from the perspective of the NRC. The causes fell into the following categories and sub-categorie Personnel Errors (PE] Lack of Knowledge (LK) - the individual was not properly trained or provided with instructions from supervisio . Inattention to Detail (10) - the individual failed to pay proper attention to a task and was careles . Poor Judgement (PJ) - the individual failed to make the correct assessment with the proper amount of training and attention to fact Equipment Malfunction / Failure (EM/EF) Random (R) - isolated component problem not of generic concer . Design Deficiency (00) poor design was the cause of the malfunction / failur . Construction Deficiency (CD) - improper installation during construction / modification caused or could have caused the malfunction / failur . Maintenance Deficiency (MD) - improper preventive or corrective maintenanc Procedural Error (PROE)
The procedure failed to provide adequate instruction, was poorly worded 1
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or was not properly reviewed for us l Ineffective Corrective Action (ICA)
Action was not taken by management or the action taken on a previously identified item was not timely or did not correct the root cause and allowed thi> occurenc T3-8 l
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Causes As Determined By the Licensee The licensee is required to include cause codes in the write-ups for event These codes are only required when equipment malfunction or failure is determined to be the cause of the occurenc The following codes are used:
A- Personnel Error 8- Design, Manufacturing, Construction or Installation C- External Cause 0- Defective Procedures E- Component Failure X- Other T3-9
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SALP TABLE Unit 1 Summary of Causes Determined by SALP Bor.-d by Functional Areas CAUSE OPS RAD MAINT SURV ENG/TS SEC TOTAL PE/LK 1 1 PE/ID 4 1 1 6 5 1 18 PE/PJ 1 1 2 EM/F/R 1 2 3 EM/F/DD 1 2 4 7 EM/F/MD 3 3 PROE i 1 ICA 2 2
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TOTAL 5 3 9 7 12 1 37*
S_ummary of Causes of Equipment Malfunctions / Failure Determined bj ucensee AREA A B C D E X Total RAD 1 1 1 3 1 MAINT 2 2 2 6 i ENG/TS 3 3 l
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Totals 3 5 3 1 12 l I
Three LERS were assigned two separate cause codes, i
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SALP TABLE Unit 1 Summary of License 9 Reportable Events Event LER Number / Cause Determined Functional Date_ Cause Code * Description SALP Board Area 11/21/86 86-33 TS Violation: PE/PJ - Engineering ENG/TS B Rx Building failed to perform a Closed Loop proper evaluation of Cooling Heat significance of the Exchanger not RBCLC heat exchanger declared lea inoperable after failing ISI Hydro test.
12/06/86 86-34 TS Violation: EM/00 - Equipment RAD A Loss of Stack self-mon: w !.9 gas sample flow program did not due to software function properly, problem.
12/10/86 86-35 TS Violation: PE/IO - Security guard SEC Secondary . 'mproperly responded Containment to an alarm on air integrity due to lock door simultaneous opening of air lock doors.
01/09/87 87-01 TS Violation: PE/ID - APRM rod SURV Failure of the Rx blocks and flow bias Manual Control trip functions not System design to clamped at 100% flo meet T Surveillance test was inadequate.
01/26/87 87-02 Agastat GP Series PE/LK - Relays MAINT A relay installation improperly installed deficiency and because of lack of potential failur sufficient guidance.
02/06/87 87-03 Secondary EM/R - detector RAD l E Containment determined to have a I Isolation / Auto faulty sensor and Start RX Building converter car emergency l ventilation:
Spurious trip of radiation monito *
Indicates licensee's Cause Code for equipment failures onl T3-11 l
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SALP TABLE Unit 1 Sumary of Licensee Reportable Events Hvent LER Number / Cause Determined Functional 9 ate _ Cause Code * Description SALP Board Area 02/10/87 87-04 TS Violation: PE/ID - Responsible SURV Failure to supervisor did not perform ensure 3.25 times the surveillarce the specified interval tesuing within was adhered t required interval.
03/13/87 87-05 TS Violation: PE/ID - Stack sample RAD Failure to was lost at the testing perform analysis lab due to apparent due to lost stack carelessnes Composite Particulate Sample.
03/24/87 87-06 TS Violation: PE/ID - Fire Department OPS Failure to supervisor improperly perform dails revised the surveillance starting air test procedure, tank pressure readings for the diesel firepump.
03/27/87 87-07 TS Violation: PE/ID - Site personnel OPS Failure to meet failed to recognize the requirements for the proper fire seal fire rated requirements for these penetrations, penetration PROE - The SURV surveillance procedure ommitted several l
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penetrations for inspections, l
05/12/87 87-08 TS Violation: PE/ID - Numerous fire- ENG/TS !
Fire -rated rai.ed penetrations I barrier inadequate, discovered l containing during comprehensive
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nonqualified engineering revie piping.
06/04/87 87-09 Te> Violation: PE/ID - Personnel SURV
'. 'ation improperly implemented Instrumentation the ASME Code act in compliance requirements, with ASME Section X T3-12 i
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l SALP TABLE Unit 1 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 06/12/87 87-10 TS Violat!on: EM/MD - Sample pump MAINT X Stack gas sample failure due to aging /
pump failure due wear, to deteriorated component /03/87 87-11 TS Violation: PE/ID - Technician SURV Failure to failed to perform perform surveillance and surveillance inadequate supervisory testing within oversigh required interva /24/87 87-12 Temporary loss of EF/D0 - Excessive MAINT B both Emergency vibration of EDG Diesel Generator caused governor solenoid to fai PE/ID - Licensee MAINT failed to include vendor maintenance recommendation.
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08/02/87 87-13 Rx Building EF/R - Timing relay MAINT E emergency failed due to aging ventilation resulting in initiation caused instrument trip, by relay f ailur /16/87 87-14 Rx Scram: HPCI EM/MD - Servo-valve MAINT A and MSIV closure malfunctioned because due to electrical of dirty control oil, pressure regulator preventive maintenance servo-valve was inadequat malfunctio /17/87 87-15 Rx scram, turbine EM/DD - Spurious ENG/TS l B trip and HPCI neutron monitoring initiation system spike due to I signals due to nois spurious trip of neutron monitor caused by noise (while S/0). )
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SALP TABLE Unit 1 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code,* Description SALP Board Area 10/19/87 87-16 Rx Scram, Turbine EM/00 - IRM coike ENG/TS B Trip, and HPCI due to noise initiation signals due to spurious trip of neutron monitor caused by noise (while S/D).
10/20/87 87-17 TS Violation: PE/ID - Engineering ENG/TS Incorrect system incorrectly classified piping design the piping design specification specifications in a resulted in a 1983 modification, portion of the raw water core spray intertie piping receiving hydro test at incorrrect pressure.
10/22/87 87-18 TS Violation: PE/ID - Special CPS Inappropriate Operating Procedure procedure N1-50P-5 deleted from deletio Master File without appropriate administrative review.
10/21/87 87-19 TS Violation: PE/ID - Numerous fire ENG/TS Failure to rated penetrations identify were not identified unacceptable during an earlier fire rated 1984 review conducted penetrations, by contractors.
10/27/87 87-20 TS Violation: PE/ID - The firewatch OPS !
Missed firewatch overlooked the required patro patrol listed on the the Patrol Status Shee !
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SALP TABLE Unit 1 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 10/27/87 87-21 TS Violation: PE/PJ - Licensee OPS Failure to reduce failed to take power below TS conservative action limit prior to when in doubt of TS isolating interpretatio recirculation loo /15/87 87-22 TS Violation: PE/ID - Responsible SURV Failure to reduce reacter analyst rod block and missed the requirement scram setpoints, to take corrective action for MTPF /22/87 87-23 Rx Building PE/10 - Technician SURV emergency inadvertently grounded ventilation a control circuit initiation and causing a fuse to blow and failure to resulting in the RBEV properly report actuution, the event per 50.7 PE/10 - Licensee failed ENG/TS to properly track and report the event per 50.7 /07/87 87-24 Rx scram on low EM/MD - Feedwater MAINT E reactor water control valves did level, not properly respond to level control signal and attempted corrective actions resulted in scra l 12/10/87 87-25 Rx Scram (while EM/DD - Spurious ENG/TS 8 S/0) due to instrument (IRM)
spurious trip of trips due to noise, neutron monitor caused by nois .
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SALP TABLE Unit 1 Summary of Licensee Reportable Events l
Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 10/30/87 87-26 TS Violation: PE/IO - Engineering ENG/TS perform ASME Code failed to identify examination Code requirements requirements for a pipe restraint prior to modificatio placing component restraints in service.
12/09/37 87-27 TS Violation: 'JA - Management ENG/TS ISI Program ineffectiveness in deficiencie implementing and overseeing the ISI Program.
12/19/87 87-28 Manual Rx scram EF/00 - Feedwater MAINT E initiated due to control valve 13A ENG/TS feedwater piping stem to disc vibration, separated due to fatique failure.
01/15/88 88-01 TS Violations: ICA - Management ENG/TS ISI program ineff ctivenesi in deficiencie impleme. "ng and overseeing he ISI progra i
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SALP TABLE Unit 2 Summary of Causes Determined by SALP Board by Functional Areas CAUSE OPS RAD MAINT SURV ENG/TS TOTAL PE/LK 3 1 4 2 10 PE/ID 30 2 3 10 5 50 PE/PJ 6 2 8 EM/F/R 1 2 2 5 EM/F/DD 1 1 35 37 EM/F/CD 2 2 PROE 5 8 1 14 ICA 3 1 5 9 TOTAL 47 3 6 25 54 135 *
Summary of Causes of Equipment malfunctions / Failure Determined Licensee AREA A B C D E X Total OPS 2 3 5 RAD 1 1 MAINT 1 1 2 ENG/TS 2 2 Totals 1 2 1 6 10
Multiple cause codes assigned; 85 total LER T3-17
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 02/02/87 87-06 Partial Primary PROE - Procedure for SURV X Containment checking reverse flow Isolation: check valves did not MSIV closure specify to reset during possible isolation surveillance signals that could testin have been generated by the testin /02/87 87-07 Secondary PE/ID - A MAINT A Containment technician bumped a Isolation / Auto control relay while Start of SBGT: working in a normal Low reactor reactor building building normal ventilation cabinet ventilation flow causing a supply fan (RBV). tri /02/87 87-10 Spurious Rx PE/ID - A SURV scram, HPCS start technician opened an signal,(no isolation valve on an initiation) isolated detector HPCS diesel start: when he was to Reactor vessel check the valve shu Level 2 and Level 3 instrument tri l EM/DD - The reactor ENG/TS l vessel level detectors l are too sensitive to !
pressure spikes on l instrument lines.
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02/07/87 87-11 Spurious Rx EM/DD - The reactor ENG/TS l scram, turbine vessel level detectors and feedwater are too sensitive to l pump trip signal pressure spikes on (no trip) Reactor, instrument line In vessel Level 3 this case, flexible and Level 8 tri instrument tubing was bumpe *
Indicates licensee's Cause Code for equipment failures onl Note: LERs 87-08 and 87-09 covered in the previous SALP perio T3-18
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Function >il Date Cause Code * Description SALP Board Area 02/08/87 87-12 Inadvertant PE/ID - Senior OPS MSIV closure Reactor Operators during allowed a surveillance surveillance test to be conducted testing on Turbine Stop Valve which caused the closure of the MSIV PROE - The SURV surveillance procedure being used did not contain information on resetting the turbine for testing with the turbine output breaker closed for station backfeed.
02/09/87 87-13 Secondary PE/ID - Reactor OPS X Containment Operator opened the Isolation / breaker that was Auto Start of actually supplying power Control Room to the bus due to burnt Emergency out. breaker position Ventilation: lights and an Loss of Division unexplained breaker 2, 600V load repositioning, cente PE/ID - The alternate OPS supply breaker was shut aid the normal open by a person unknow T3-19
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 01/29/87 87-14 TS violation: PE/ID - The TS OPS Gaseous Effluent required flowrate Radiation Monitor meters were System (GEMS) declared operable instruments with work requests inoperable without outstanding on the proper instruments, compensating action take PE/ID - The instrument RAD used to calibrate TS required flowrate meters was not properly calibrated, so the instrument was not properly calibrate PE/ID - Inadequate RAD oversight by chemistry department supervisor PE/ID - Lack of OPS questioning attitude by SS /22/87 87-15 TS violation: PE/PJ - Fire watch OPS missed fire watc personnel split up '
fire patrol work load without fully
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briefing the other i personnel on special '
instructions given by superviso /26/87 87-16 TS violation: PE/PJ - Engineering ENG/TS inoperable fire judged the wall due to penetration at first improperly sealed to be operable and penetratio then inoperable.
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 02/24/87 87-17 Partial Primary PE/LK - Reactor OPS Containment Operator opened a Isolation a : . breaker during Auto Start of troubleshooting-and SBGT: Loss of did not know what power to RPS components would be Division 2 affected by operating loads simulated this breake a LOCA signal.
03/16/87 87-18 TS violation: PE/ID - Floor ENG/TS Inoperable fire penetration was not rated floo properly resealed after a temporary line was removed.
04/18/87 87-19 Partial Primary PE/PJ - Reactor OPS Containment Operator, while Isolation: performing a tagout, Instrument air, isolated the battery RBCLC, and from the bus prior to recirculation returning a battery hydraulics charger to operation, isolated on loss Power was lost when of Division I neither battery charger Emergency DC or the battery was Powe aligned to the bus.
04/22/87 87-20 Spurious Rx scram, EM/DD - The reactor ENG/TS turbine and vessel level detectors feedwater pump are too sensitive to trip (no trip) pressure spikes on during instrument line In surveillance this case, a detector testin Reactor was being returned to vessel Level 3 service, amd Level 8 trip.
04/30/87 87-21 Potential failure EM/DD - Valve stem to ENG/TS of Clow butterfly operator linkage set {
valves due to screw loosened during i movement of spline valve operation, adapto I T3-21 l
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 05/02/87 87-22 Partial Primary PROE - The procedure SURV Containment for recharging the Isolation and battery was not clear Auto Start of as to how the charger Control Building should be placed onto special filter the battery, trai Instrument Air, RBCLC and PE/LK - Personnel SURV Recirculation returning the battery Hydraulics to service were not Isolated; loss properly trained in of Division 11 the operation of the Emergency DC battery charge Powe /09/87 87-23 Partial Primary PE/LK - The person SURV Containment isolating the Isolation: detector was not Shutdown Cooling properly trained in isolation while the method to use, isolating a High Rx pressure detecto PROE - The procedure SURV for isolating the detector was not specific as to the order in which to shut the isolation valve /17/87 87-24 Two Secondary EM/DD - Flow switch ENG/TS Containment retpoints were set to Isolations/ close to normal air Auto Starts of flow allowing unwanted SBGT: Low system isolations when i Reactor Building switching exhaust fan normal ventilation flo l l
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 05/19/87 87-25 Secondary PE/ID - A lifted lead SURV Containment was reconnected before Isolation during it was required to be during by the procedur This surveillance was due to a testing: Low communication breakdow reactor building normal ventilation flow.
05/25/87 87-26 Partial Primary PE/ID - Reactor OPS Containment operators allowed a Isolation: RWCU detector to be vented isolation which caused: a during venting detector in parallel cf letdown flow with the detector being detector, vented to initiate a high differential pressure isolatio EM/0D - The RWCU ENG/TS letdown flow transmitters were located downstream of the flow control valve, this causes flow indication instabilities.
05/25/87 87-27 TS Violation: EM/DD - The monitor ENG/TS SBGT drywell sample pump was not vent and purge designed to radiation monitor automatically start operable, when SBGT flow bega l
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 05/22/87 87-28 TS Violation: PE/ID - When SURV DW personnel air preparing the test lock inter door procedure and review equalizing valve leak test results, it was not properly results, it was not leak teste discovered that the interdoor equalizing valve was not being teste EM/DD - The inter ENG/TS door equalizing valve could not be tested from outside of the drywell.
06/03/87 87-29 Secondary EM/R - Use of hand ENG/TS Containment held radios near Isolation /SBGT circuitry caused a Auto Start: Low reactor building low Reactor Building flow instrument to normal ventilation spuriously isolate flow, the normal ventilation and the start of SBGT.
05/28/87 87-30 Numerous Partial PE/LK - A modification MAINT Containment was installed forcing Isolations: the sample pump to Drywell purge operate at all times, and vent valve The modifications isolation due to caused temperature loss of SBGT problems within the radiation radiation monitor monitoring cabinet. This caused capabilit See the monitor to fai LER 87-2 The cabinet modification did not receive a safety evaluation before it was installe T3-24
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 06/12/87 87-31 Rx Scram: High EF/DD - The feedwater MAINT X IRM Flux Scram level control valve due to failed mechanical position feedwater control feedback arm valve causing a disengaged causing the cold water valve to fail open, injection transient 06/12/87 87-32 Partial Priamary EM/DD - The RWCU ENG/TS Containment letdown flow Isolation: transmitters located RWCU isolation downstream of the flow while removing control valve, this a filter causes flow indication demineralizer instabilitie from service, EM/DD - Sensing Lines ENG/TS and valves were oriented to allow air trappin /15/87 87-33 Automatic Rod EM/R - A spurious SURV Insertion and signal was generated Reactor Scram during surveillance during testin Redundant i Reactivity PROE - The SURV Control System
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(RRCS) testing, required an elapse i Spurious RRCS time which was too high pressure long prior to
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signals and )
resetting a trip i subsequent scram signal, 1 discharge volume high level scram, !
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06/17/87 87-34 Recirc pumps EM/R - During SURV trip during troubleshooting i RRCS testing, energizing and deengergizing the system caused spurious signal T3-25
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 06/18/87 87-35 TS Violation: PE/ID - Fireman secure OPS Firewatch a watch prior to suspended when restoring a detector still require to service.
07/25/87 87-36 Two Secondary PE/ID - !&C techncian SURV Containment grounded a jumper Isolations/SBGT during a normal PB auto start signal ventilation radiation Low normal monitor surveillance, reactor building causing a damper to ventilation flow, reposition and a low flow conditio ICA - The licensee ENG/TS failed to correct the problems with the use of jumpers during these surveillance test PE/ID - Nonlicensed OPS operator started RBV. exhaust fans, as specified in system oc, rating procedure PROE - The procedure OPS for operating RFV is not as clear as possible when describing the need to start exhaust and supply fans simultaneously.
06/22/87 87-37 Main steam EM/DD - Two of the ENG/TS tunnel four ventilation inlet differential temperature detectors temperature were not properly isolation located to give proper instrument delta T indication and inoperable, isolation function T3-26
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 08/07/87 87-38 Partial Primary EM/DD - Setpoint was ENG/TS Containment found to be restricted isolation: since it allowed RCIC isolated pressure isolations, on spurious steam caused by RHR steam line high condensing mode to differential to cause an RCIC pressure during isolatio RHR steam condensing mode testing.
06/30/87 87-39 TS Violation: PE/ID - Senior OPS Emergency Diesel Licensed Operator Generator removed one of the two inoperable due 50's capacity Otesel to removal of room fans from service diesel room with a tag out and did ,
ventilation fan not realize that by from servic Technical Specifications, the diesel would have to be declared inoperable.
07/03/87 87-40 Secondary EM/00 - Design ENG/TS containment assumptions for SBGT l integrity not draw down time were met due to never incorporated inconsistent into operating assumptions used procedures, when calculating SEGT drawdown time.
07/11/87 87-41 TS Violation: PROE - The shif t check OPS Failure to procedure did not increase contain the requirement j surveillance that when service water ;
frequency temperature reached 74 of service degree F, the water inlet temperature monitoring 1 temperature, frequency be increased 1 to once every two hour T3-27
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 06/14/87 87-42 Partial Primary PROE - The procedure OPS Containment being used was not Isolation: RWCU clear as to how to isolation due to control reactor vessel flow oscillation leve while adjusting letdown flow to EM/DD - The RWCU ENG/TS the condenser, isolation instruments are too sensitive to flow instabilitie /11/87 87-43 Rx Scram: High EF/DD - EHC tubing was ENG/TS X Reactor Pressure not designed to take Sc ram, the vibratory stresses that were imposed. The tubing ruptured and bypass and turbine stop valves shu /25/87 87-44 Plant shutdown PE/PJ - The licensee ENG/TS required by Tech did not expect lake Specs: Service temperature to go above water temperature 77 degree F when the exceeded the TS emergency TS change to limit for greater raise the limit from than 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> to 77 was proposed,
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07/29/87 87-45 Two Secondary PE/PJ - A Senior OPS '
Containment Reactor Operator failed Isolations/ to realize that two Auto Start of surveillances he SBG allowed to be performed concurrently were not compatibl PE/IO - Reactor OPS !
Operator did not follow !
operating procedures when returning normal l ventilation to service.
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 07/29/87 87-46 TS Violation: PROE - The procedure SURV APRM testing not for APRM surveillance completed prior did not include the entering Mode surveillance on the APRM flow b upscale trip and mod block PE/ID - Supervisory SURV I&C personnel allowed these steps to be removed during earlier testing, but did not ensure they were put back prior to entry into Mode 1.
08/06/87 87-47 Two Partial EM/0D - The RWCU ENG/TS Primary letdown flow Containment transmitters were isolations located downstream of RWCU isolation the flow control valve, due to flow this causes flow oscillations indication instabilitie EM/DD - The flow ENG/TS element was located in a section of pipe that was sensitive to flow differences depending on where reject flow was was being sen EM/DD - Sensing Lines ENG/TS and valves were oriented to allow air trappin EM/00 - The RWCU ENG/TS isolation instruments are too sensitive to flow instabilitie T3-29
SALP TABLE ,
Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 08/09/87 87-48 Partial Primary PROE - The procedure OPS Containment for transfering Isolation: control of R Shutdown cooling from the remote isolation, shutdown panel to the Control Room did not specify resetting the high pressure 50C isolation signal.
08/25/87 87-49 Two Secondary PE/IO - Reactor OPS Containment Operator failed to Isolation / Auto follow operation Start of SBGT procedures when returning normal reactor building ventilation to servic EM/R - Normal reactor ENG/TS building exhaust fan trip with no apparent cause.
08/29/87 87-50 Auto Start of PE/ID - Reactor OPS SBG Operator failed to ensure that SBGT was placed in PTL prior to ,
authorizing l surveillance on normal '
RB rod monitor,
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 08/13/87 87-51 TS Violation: PE/LK - Operators did OPS X Failure to restore not know that shutdowr, shutdown cooling cooling was designed to the core to isolate on loss of within one hour either divisional after loss of Reactor Protection circulatio Nuclear Supply (RPS/NS4) shutoff system power supplie PE/PJ - Operators OPS tried to restore power supply, which was not done within one hour, and did not take action to manually open SDC isolation valves to reestablish core cooling within one hou EM/00 - RPS/NS4 ENG/TS divisional power supplies must be deenergized to allow testing of the power supply's Electrical Protection Assemblies.
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 09/02/87 87-52 TS Violation: ICA - The licensee was OPS SBGT train told of a problem with surveillances for calculating the run filter times for 3BGT filter sampling was not trains during the taken at the Readiness Assessment required Team Inspection. No frequency, action was taken causing the train allowing this violatio to be inoperable and required PE/LK - Senior License SURV plant shutdow Operator did not have the knowledge of the of SBGT train and was relying on the trains operablility to satisfy another TS requi'ed LC0
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for diesel generator operablility.
09/03/87 87-53 Partial Primary EM/DD - The RWCU ENG/TS Containment letdown flow Isolation: transmitters were RWCU isolation located downstream due to spurious of the flow control high flow valve, this causes differential flow indication signal, instabilitie EM/DD - The flow ENG/TS element was located in a section of pipe ;
that was sensitive to !
flow differences
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depending on where j reject flow was was i being sen j
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EM/DD - Sensing Lines ENG/TS and valves were oriented to allow air !
trappin !
EM/DD - The RWCU ENG/TS i isolation instruments are too sensitive to flow instabilitie T3-32 i
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SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 09/09/87 87-54 Partial Primary PROE- The surveillance SURV Containment procedure did not Isolation: MSIV ensure that operators Trip Signal were told to clear any generated during generated isolation surveillance signals after testin performance of stop valve testin ICA - The licensee did SURV not review other procedures which cycle turbine when this first of event occurred on 1/26/87 (LER 87-09) in the previous SALP perio EM/DD - There are no ENG/TS annunciations in the control room to inform the cperator of an isolation signal.
09/16/87 87-55 Primary PE/ID - The I&C Tech SURV Containment lifted the wrong lead isolation, due while performing high to a mistaken area temperature lead during system isolation surveillance function testing, testin i
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I SALP TABLE l Unit 2 Summary of Licensee Reportable Events l
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Event LER Number /- Ccuse Determined Functional Date '
Cause Code * pescriptio SALP Board Area
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09/25/87 87-56 TS Violation: EH/00 - Annunciators ENG/TS ,
Gaseous Effluent were not designed to '
Monitor Control have reflash Room annunciators capabilities as do not have r,equired by Tech Spec reflash ca.pability for system trouble condition /21/87 87-57 Primary PE/ID - I&C SURV Containment technicians failed isolation, to follow surveillance shutdown cooli y test when performing isolation and high area temperature signal during system isolations, by surveillance not bypassing the testing, isolation signal prior to generating another
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isolation signa /01/87 87-58 Rx Scram: PE/LK - Operator tried OPS X High IRM flux to use feedwater pump scram due to bypass valve to excess cold feed throttle flow to the water injectio vessel level. This valve is not a throttle valve and when opened, caused a cold water power excursio /30/87 87-59 13 Violation: PE/ID - The operator OPS Nine TS required shift check procedure shift checks not did not include these not performed nine items which are since license specified in TS issu because they were left out or deleted from the procedur T3-34
._. - _ - _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ ____ - -
_ _ _ _ _ _ _ _ _ _ _ _ _ _
,
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional-Date Cause Code * Description SALP Board M 10/22/87 87-60 TS Violation: PE/ID - Reactor *0DS Missed TS Operator failed to required shift complete twelve checks, required channel checks for various radiation monitoring instrument PE/IO - Senior OPS licensed operator failed to properly review surveillan:e test results prior to concluding that the surveillance had been successfully complete /01/87 87-61 TS Violation: PE/ID - Chemistry RAD Failure to take Department did not proper take the proper compensatory samples, '
action when primary containment leak rate monitoring systems were inoperabl l 10/03/87 87-62 TS Violation: PE/ID - Reactor OPS Rx mode change Operator performing with LPCS the LPCS pump inoperabl surveillance did not properly record test dat PE/ID - The OPS 3 surveillance test '
results were reviewed by a Senior Operator i and Operations documented as acceptabl /13/87 87-63 Partial Primary ICA - Previous actions ENG/TS Containment takcn to prevent these
'
!
Isolation: RWCV flow oscilations from due to high from causing isolations differential flow. were not adequat T3-35
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area i 10/23/87 87-64 Rx scram: PE/ID - Licensed OPS Turbine trip operator did not caused by loss properly review of condenser tagouts allowing work vacuum, to cause loss of vacuu /15/87 87-65 Failure to EM/DD - The ENG/TS maintain .25 differential pressure inches of vacuum instruments which water gauge on control SBGT and Normal Reactor Buildin Reactor Building ventilation to maintain the required differential pressure were located such that pressures were sensed low in the Reactor Building. Given a low outside temperature, i
the difirence in air density inside and outside the Reactor Building could cause an actual positive pressure near the top of the Reactor Buildin /20/87 87-66 TS Violation: PROE - GE documentation ENG/TS Rx mode change for SLC fuses specified with SLC improper replacement inoperabl fuses for SLC piping circui PE/ID - Reactor OPS operator did not properly verify that the fuses installed were of the same amp ratings as the blown fuse T3-36
SALP TABLE 3. Unit 2 Summary of Licensee Reportable Events
,'
Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 10/23/87 87-67 TS Violation: PE/PJ - Senior Reactor OPS B Limiting Operator failed to condition for realize that when one operation of NS line rod monitor of main steam became inoperable TS line radiation required action to be monitors taken, misinterprete /20/87 87-68 Partial Primary ICA - Action taken by ENG/TS containment licensee, based on isolation - RWCV LER 87-57, was not isolation due to adequate to prevent surveillance this occurrence, t e s t i r.g .
PE/ID I&C technician SURV failed to follow surveillance test when performing high area temperature system isolation, by not passing the isolation signal prior to generating an isolation signa /23/87 87-69 Secondary and PE/LK - Licensed OPS B partial primary Operator was not containment familiar with the iselation: SBGT operation of the autostart, SDC nontlass IE interruptable isolation and power supply and caused l inboard group transfer to a dead
'
2 thru 4 and alternate power suppl thru 9 isolation l due to loss of
'
< RPS/NS4 Divisior, 2 power suppl l
!
I T3-37
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-_ _ ._ ,
SALP TABLd Unit 2 Summary of Licensee Reportable Events
"
" LER Number / Cause Determined Functional Cause Code * Description SALP Board Area 87-70 TS Violation: EM/00 - The outer door EWG/TS Prima ry equalizing valve containment positioning mechanism emergency escape allowed the valve to be airlock outer open when it should door inoperable have been shut, and proper TS required action not followed.
11/12/87 87-71 Partial Primary PE/10 - During SORV Containment performance of isolation: RCIC surveillance test of isolation and high area temperature signal during system isolations, a surveillance technician bumped testin an instrement and caused the isolation signa EM/DD - The area in ENG/TS which this test is performed is cramped and.does not lend itself to easy performance of lead lifting as required by the procedure.
10/28/87 87-72 Secondary PROE - The procedure OPS Containment for DC power isolation and SBGT distribution did not Auto Start, during provide instruction ground isolatio on what would be affected by a ground isolation procedur PE/ID - Licensed OPS operators failed to make a determination of what components would be affected when DC power was isolate T3-38
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_ _ _ . . _ . . ._ -__ . _ .._ _ _ . .-. _ . _ . - - -- -
SALP TABLE Unit 2' Summary of Licensee Reportable Events Event LER Number / _
Cause Determined Functional Date Cause Code * Description SALP Board Area 11/24/87 87-73 Partial Primary PE/IDT- Licensed OPS'
Containment Operator bypassed the Isolation. RWCU wrong isolation signal isolation: when told to bypass '
during _
both divisions of RWCU differential differential flow, he flow detector ~ bypassed only one maintenanc division of RWCU and one division of RCI The operator did not
- verify that the expected computer-alarms-had occa re /19/87 87-74 Appendix R EM/DD - The ENG/TS Violation:
~
cortr actor -
Inoperable fire installation failed rated floor plug to meet fire rating in Division 2 - requirement Ventilation Roo PE/ID - The plug had ENG/TS been breached _since initial installation and not properly-
.
reseale /28/87 87-75 Rupture of "A" EF/CD - The -fiberglass ENG/TS condensate -tank was constructed storage tank and on a'nonlevel floor, and failure of such that it was no reactor building set on a. foundation as-penetration sea designe This caused high stresses in the area where the break occurre EF/CD - The boot type ENG/TS
. seal was apparently damaged by personnel working in the are This lead to the failur T3-39
.
-r- , ,ew t , n -wen,r,,- ,-,+www ,,--,[, r#-,.,,,..-#wv, ,w+ ,.,4- i. em, ,w.,-mem... ,,m,% , -. . . y w e r
-
,-+# e, m. y - , ,-,--w,em,y,.,.,e, - - , - ,~+,E,
i
l
)
i l
l SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area I 12/12/87 87-76 Potential EM/DD - The floor drain ENG/TS Radioactive system in the Main Release path Steam Tunnel was through floor interconnected with drain system, other area drains such !
that if a MS break developed, radioactive steam and water could be forced through the drain system and potentially effect safety related equipment in the cross-connecting areas.
12/14/87 87-77 LPCS and LPCI PE/ID - I&C technician MAINT spurious operated a wrong valve l injection and after trying to drain j Oivision I a section of instrument l diesel start, tubing during j maintenanc EM/00 - Instrumentation ENG/TS drain valves are in poor locations and are not easily identifie ]
l EM/00 - Instruments are ENG/TS -
too sensitive to short pressure spikes in l instrument line .
I
,
T3-40
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 12/20/87 87-78 Two Secondary PE/ID - Operator failed OPS Containment to properly position isolations and normal RB vent for SBGT Auto Start switch durirg starting signal, operations. This caused a supply fan to not start simultaneously with sn exhaust fa The operator then tripped all fans causing the isolation signal to be generate PE/ID - Operator failed OPS to use indication to verify that a supply fan had started and was running concurrent with an exhaust fan. The running exhaust fan caused a RB pressure fan trip which caused the isolation signal and SBGT auto star ICA - The licensee OPS failed to implement design modifications outlined in LER 87-49, to prevent these l occurrence ;
T3-41
SALP TABLE Unit 2 Summary of Licensee Reportable Events j l
Event LER Number / Cause Determined' Functional Date Cause Code * Description SALP Board Area 12/20/87 87-79 Secondary PE/ID - During SURV Containment surveillance cesting isolation and of normal RB rad Auto Start of monitors, a technician SBG dropped a jumper causing a short, a spurious high rad signal and secondary containment isola' ion and SBGT autost ICA - The problem with ENG/TS jumper installation during this surveillance has happened before and the licensee has been enable to prevent further occurrence Not Issued.
12/26/87 87-81 Rx Scram: EF/00 - Feedwater ENG/TS Turbine trip due heater drain line to loss of penetration into the ,
condense vacuu condenser cracked due l to hydraulic transients on the lin l 12/29/87 87-82 Rx Scram: PE/IO - While trying OPS 3 MSIV closed to place the reactor j during startu mode switch to the startup position, a licensed operator put the switch in the run position causing the MSIVs to close as designed on low steam pressur EM/DD - The Reactor ENG/TS mode switch', due to the number of switches ganged is difficult to operat T3-42
.-
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 12/30/87 87-83 TS Violation: PE/ID - Operator OPS Missed failed to take data surveillance en reactor heatup during vessel during plant startup heatu due to not following plant procedure PE/PJ - Licensed OPS operators did provide proper oversight of surveillance operations in the Control Room.
12.'30/87 87-84 Auxiliary EF/00 - Sample pump RAD C Gaseous Effluent return line has the radiation monitor potential for inoperable when obstruction due to required by T moisture causing sample pump to trip on high discharge pressure.
01/20/88 88-01 Rx Scram: PE/ID - Nonlicensed OPS Rx vessel low operator failed to level due to properly verify that loss of one train of instrument feedwater, air prefilters was Subsequent inservice prior to vessel isolating a prefilte overfil PE/ID - Operators OPS failed to verify that actions being taken to shut feed control valve actually stopped flow to the vesse PE/PJ - Licensed OPS operators failed to provide adequate oversight and direction of actions being taken during the vessel overfill l even l
T3-43 i
i
SALP TABLE Unit 2 Summary of Licensee Reportable Events Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 01/20/88 88-02 Partial Primary ICA - The licensee has ENG/TS Containment established a task Isolation on but has not been able high differential to correct the problems flo with RWCU differential flow isolations.
01/21/88 88-03 TS Violation: PE/LK - The requirement ENG/TS Failure to make to submit a special a special report report in TS was not within 90 days known to exis after LPCI injection.
01/21/88 88-04 TS Violation: PROE - The setpoints SURV Primary specified in the containment instrument calibration isolation procedures were actuation incorrec instrument for reactor vessel PE/IO - The contractor ENG/TS level isolations who calculated the were not set amperage trip setpoints conservatively with for these detectors made respect to TS a calculational erro required setpoint PE/ID - Licensee ENG/TS personnel did not adequately review the data provided by the contractor.
01/26/88 88-05 Auxiliary Gaseous PE/ID - Sampling pump MAINT effluent radiation tripped because the monitor was filter on the outlet inoperable when clogged and was never required by T cleaned as recommended by the manufacture l T3-44 <
l l
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SALP TABLE l Unit 2 Summary of Licensee Reportable Events '
Event LER Number / Cause Determined Functional Date Cause Code * Description SALP Board Area 02/15/88 88-06 Partial Primary PE/ID - Senior Reactor OPS Containment Operator allowed the Isolation: MSIV turbine to be reset closure during and turbine stop surveillance valves open causing testin MSIV closure signa ICA - Operators did OPS not receive effective training on these types of closures, after previous occurrences.
02/01/88 88-07 Partial Primary EM/R - Detector tripped MAINT Containment during backfill of Isolatio Shut sensing lines, down cooling isolation while backfilling a detector sensing line.
02/19/88 88-08 TS Violation: PE/LK - The data used ENG/TS Main steam line to calculate the radiation monitors settings was not set less conservative, conservative than the actual l 100% power readings.
01/29/88 88-09 TS Violation: PE/ID - The contractors ENG/TS The setpoint for work for calculating the CST low level this setpoint was never i section transfer completely checked by )
to the the licensee, i suppression pool for HPCS was set below the TS I limi T3-45
l TABLE _ Unit 1 Enforcement Activities Violations Versus Functional Area By Severity Level
_____________________________________________________________________________
Functional No. of Violations in Each Severity Level Area LI * V IV III II I Total
______________________________________________________________________________
Plant Operations 8 1 9 Radiological Controls 3 1 1 3 Maintenance O Surveillance 0 Emergency Preparedness 0 Security & Safeguards 0 Assurance of Quality 0 Licensing 0 Engineering and 7 1 1 9 Technical Support Training and/ 0 Qualification Area _ _ _ _
j i
TOTAL 18 2 1 2 23 !
l
_____________________________________________________________________________
LI - Licensee Identified Violations (No Notice of Violation issued I because the five criteria of 10 CFR 2, Appendix C were satisfied.) i
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l T4-46
(TABLE 4.1. CONTINUED) Summary Inspection Severity Functional Brief Number Requirements Level Area Description 86-26 TS 3. LI Engineering -RBCLC Heat Exchanger TS 3. Technical Inoperabl See LER 86-33 Support 86-26 TS 3.6.14 b LI Rad Control Failure to continuos 1y See LER 86-34 monitor radioactive release from the stac TS 3. IV Operations Reactor Building See LER 86-35 integrity violated by having both doors at an access point open at the same tim TS 3. LI Engineering APRM rod block and See LER 87-01 Technical upscale flow based Support trips did not have a fixed clam TS Table LI Rad Control Analysis not performed 4.6.15.b (1) on stack composite See LER 87-05 sampl CFR 7 III Rad Control Inadequate preparation for shipment of Radio-active materia TS Table LI Operations haKly surveillance 4.6.2.a.(9) (b) testing for APRM See LER 87-04 misse TS 4.6.7. LI Operations Missed daily check of See LER 87-06 diesel fire pump air tank pressur TS 3.6.1 LI Operations Failure to v.cet i See LER 87-07 requirements for a fire rated penetratio TS 3.6.1 LI Operations Fire rated barrier See LER 87-08 contained nonqualified l piping, j 87-10 TS 3. LI Engineering / Vibration instrument !
See LER 87-09 Technical not in compliance with Support ASME Section I ,
T4-47
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(TABLE 4.1. CONTINUED) Summary Inspection Severity Functional Brief Number Requirements Level Area Description 87-10 TS Table Li Radiation Failure to continously 4.5.1 Protection monitor radioactive See LER 87-10 releases from stac TS 4. LI Engineering / Failure to perform See LER 87-11 Technical daily fuel Sepport surveillanc CFR 50.55 V Engineering / The required experience Technical level for a Level 2 Support visual examiner onsite were not per ANSI 45. TS 6.11 V Radiation Whole Body count intake
?rotection quantity not properly calculate TS 3. LI Engineering / Failure to properly See LER 87-17 Technical hydrostatically test a Support a modification due to improper drawing TS LI Engineering / Procedure removed from See LER 87-18 Technical master file without Support proper revie TS 3.6.1 LI Operations Failure to identify See LER 87-19 unacceptable fire rated penetration TS 3.6.10. LI Operations Missed firewatc l See LER 87-20 87-21 TS 3.1. LI Operations Failure to reduce See LER 87-21 reactor power prior to isolating a recirculation loo TS 3.2. III Engineering / Various violations of See LER 37-27 Technical the ISI Progra ;
and LER 88-01 Support l l
l l
T4-48 ;
(TABLE 4.1. CONTINUED) Summary Inspection Severity Functional Brief Number Requirements level Area Description 87-21 TS 3.2.6.a (1) LI Engineering / Proper preservice see LER 87-26 Technical inspection of piping Support restraints not performe TS 2. LI Operations LSSS violated See LER 87-22 operations total core peaking facto .
j i
)
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T4-49 I
I
.
TABLE _ Unit 2 Enforcement Activities Violations Versus Functional Area By Severity Level
.
Functional No. of Violations in Each Severity Level l Area LI * V IV III II I Total
______________________________________________________________________________
Plant Operations 10 3 5 18 Radiological Controls 2 2 Maintenance 0 l l
Surveillance 1 1
)
Emergency Preparedness 0 Security & Safeguards 0 l
Assurance of Quality 0 Licensing 0 Engineering and Technical Support 2 1 2 5 Training and/
l Qualification 0 TOTALS 15 4 7 0 0 0 26
_____________________________________________________________________________
LI - Licensee Identified Violations (No Notice of Violation issued because the five criteria of 10 CFR 2, Appendix C were satisfied.)
T4-50
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I 1
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(TABLE'4.2. CONTINUED)
s Summary 4 Inspection- ' Severity Functiona .Brief-Number Requirements Level -Area Description - o 87-02 10 CFR 21- V Engineering / Failure to notify NRC Technical within 5 days.of Support determining a '
substantial safety
., ha z a rd .
87-08 TS V Operations Failure to. follow see LER 87-14 operating procedure TS 3.3.7.11 LI Rad Control Four hour flow estimates not performed
.on effluent radiation monitor Fi re LI Operations CO2 System rendered Protection inoperable without Program a fire watch and a missed fire watc CFR 50 IV Operations Failure to perform Appendix B a safety evaluatio TS 3.8. LI 0perations . Emergency diesel see LER 87-39 generator ~ inoperable due to removal of ventilation fari from sourc TS 3.3.7. V Operations Failure to perform 3.7. hourly fire watches see LER 87-15 when fire detection zones were inoperabl ,
87-20 TS 4.7.1.1. LI Operations Failure to increase see LER 87-41 surveillance frequency of service water inlet temperatur CFR 50 IV Engineering / Improper review of Appendix B Technical radiographic film and Support documentation and dispostionin T4-51
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(TABLE 4.2. CONTINUED) Summary Inspection Severity Functional Brief Number Requirements Level Area Description 87-29 TS 3. LI Surveillance APRM flow bias upscale See LER 87-46 trip function surveillance not performed 87-29 TS 3.4. IV Operations Failure to restore See LER 87-51 forced core circulation within one hou N2-FDP-7, V Operations Oil rags and oil Section puddles in Emergency Diesel Generator room TS 3.8.1. IV Operations SBGT train operated See LER 87-52 greater than 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> without samplin CFR 50 IV Operations Management knew of Appendix B problems with tracking See LER 87-52 SBGT run times but failed to correct the Fire Protection IV Operations Failure to deenergize Program valves that were required to be due to ;
Appendix R l determinatio Various TS LI Operations Various shift See LER 87-60
,
surveillance checks '
missed due to a l procedure proble TS 3. LI Rad Control Grab samples not taken See LER 87-59 of drywell when other leakage monitors were inoperabl Various TS LI Operations Various shift See LER 87-60 surveillance checks misse T4-52
. _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _
i l
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(TABLE 4.2. CONTINVED) Summary Inspection Severity Functional Brief Number Requirements Level Area Description 87-39 TS 3. LI Operations Mode change with LPCS See LER 87-62 inoperable.
87-39 TS 3. LI Operations Mode change with SLC See LER 87-66 inoperable.
87-39 TS 3.6. LI Operations Primary containment See LER 87-70 emergency escape air
'
lock outer door inoperable.
87-39 TS 3. LI Operations Failure to realize the See LER 87-67 number of main steam line radiation monitors that were required to be operable.
87-42 Fire Protection LI Engineering / Inoperable fire rated -
Program Technical floor plu Support 87-45 TS 4.4.6. LI Operations Missed surveillance on TS 4.4.6. vessel temperature See LER 87-83 during heatup.
87-45 TS 3. IV Engineering / Inoperable level TS 3. Technical instrumentation due to See LER 88-04 Support improperly performed LER 88-09 calculations.
87-45 TS 3.5.1 ( f) LI Engineering / Failure to make a See LER 88-03 Technical special report within Support 90 days of LPCI injectio i I
T4-53
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ENCLOSURE 3
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MEETING ATTENDEES I
um .c Mm.
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' ysty Haughey NRC Robert Capra Project Manager NMP-2 NRC W1111am A. Cook NRC Director Project Directorate I-1 Jon R. Johnson SR Resident Inspector NRC Projects Section Chlef Wjl11am P. Kane NRC William T. Russell NRC Director Div. Reactor Projects gdward C. Wenzinser, S Regional Administrator NRC Chief, Reactor Projects Br2 Wayre L. Schmidt NRC Resident Inspector Charles S. Marshall NRC Robert A. Benedict NRC Senior Resident Inspector, Cinns Joseph P. Beratta Project Mn5r , NMP-1 NMPC MCR. Nuc. Security Richard 8. Abbott NMPC Thomas W. Roman Statlon Supt. NMP-2 NMPC Station Supt. NMP-1 C. V. Mangen NMPC C. D. Terry Sr. NMPC V.P. NUc. Eng, & Li W. J. Donlon NMPC John M. Endries Pres. N.M. NMPC J. A. Perry NNPC Exec. VP and Pres.-Elect T. J. Perkins VP-QA NNPC VP-Nuclear J. L. Willis NNPC John T. Conway Cen'2 Supt. NMP NMPC Supv. Mr. Analyst J. R. Spadsfore NMPC R. E. Jenkins Tech $srvices NMPC Tech support W. C. Drews NMPC James Kuznl ar Techn! cal Sup K. F. Zo111tsch NMPC Main NMPC Supt. Tralning C. P. Larlzza RC&R X3m A. Dahlberg Director, CPS Assessment -
'
, NMPC Site Maint. Sup Charles L. Stuart '
NMPC Robert C. Randall Mgc Nuc. Dly. Projects MMPC Cperations supt. Unit 1 Robert C. Salth NMPC Pat Volza Cps Supt, NMP2 NMPC Edward Cordon Radiation Protection Mg NMPC Supv. Rad. Support Don Wilcox NNPC Trelning sup Randy Selfried NMPC Doug Pike Asst. Supv. Tralnlag NMPC Mgr. - Audits & Reports S, W. Wilczek, J NMPC C. D, Wilson NMPC Maneser Nuclear Technology Mark J. Wetterhahn System Attorney -
Greg Cresock Conner & Wetterhahn Attorney NMPC Manager Nuclest En M. C. Pace NMPC Richard Nelld Nanager Materlels Eng NMPC R. A, Cushman NMPC Tech. Asst, to station Sup. U-2 A. S. Xovac NMPC Sr. En5 3 Pec.-Nuc. Consulting Mitch Bullis M5 r. QIP NMPC Joe Snyder Aast. Supv. Radweste CPS II NMPC D. E. Sandwick NMPC Construction Unit II J. J, Bebko Mgr. Engineering Services NMPC A. P. Za11 nick NMPC Mgr. Nuc. Comp. & Veriflestion Asak. to the Senior VP Nuclear
, _ . , _ _ . , _ , _ _ _ - - _ _ _ _ _ _ _ --_ - -- -- - - - - - - - -
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ATTENDKK LIST (Cont'd)
! NSit & PRP John Lasky NMPC Unit I P!re Pro l T. Caney NMFC Unit 1 & 2 Fire Dep Andrew R. Andersen hWPC Site Supervisor Fire Pro l Jim Xinsley hWPC Unl t Supv. I&C at U-2 l
'
I Louis Lagos hWPC Site Supervisor I&C H. J. Fallse hWPC Supt. Hech. Malo P. Massaferro hWPC Asst. Supy, Tech Support R. Devendorf NMPC Alt. Steward & Foreman Paul C. Mangano NMPC Supervisor, Computer Hike Randall NMPC CSO l
,
i 8. R. Quinn NMPC CSO Unit i I S. H. Brown NNPC CSO Unit 1 Ed teach NMPC Prine, Cen. Spee. RP & Che Al Smith hWPC Const. Supt. Unit 3 Jesn DeSantis NMPC Admin. Services channel 9 News
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po, ,
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S ATTENDEE LISI (Cont'd)
l DEP HAMI
$25 NYPSC Stat!
M. P. Clnadr NMPC Mgr. Corporate QA W. A. Hansen NNPC Bldge. & Crounds A, J. Comba Chemistry & Radiochemistry NMPC John Woods Chemlstry & Radlochemistry NMPC Chemistry & Radiochemistry John Lawton NMPC John Coates NMPC Mn5mt. Effect. Pro 5. Mng MaryAnn Bitmente CET Trainin5 NMPC John M. Sovie NYSPSC 9 Mlle Site Re Paul D. Eddy Elect. Maint. Unit 1 NMPC Scott C. Peer NMPC Elect. Maint. Unit 2 Dave Barrett Nuclear Security NMPC Cary C11mer Site Re NYs2C P. D. MacEwan NMPC Unit II Cpe Joe Manaeuso NMPC Asst. To V.P.-Nuclear John T. Pavel NMPC I&C Trns. Sup Charles Cary NNPC Comp. & Verlf. Lead Manfred Brause Nuclear Can. Spe NMPC Robert E. Coon NMPC I&C/Unlt 1 Ed Schaperjahn Cost Dep Y. Coyal NMPC f NMPC Site Services R. J. Cohen Mgr. Qual. & Rel. En NNPC J. Krochler NMPC Asst. Mgr. Mech. Desl6D U-l T. D. Lee station Shift Sup I NXPC B. J. Hertha NMPC QA Audit Supervisor J. L. Dillon NMPC Admin. Services J W. A. Mosher 3. D. Lilly ,
NNPC
'
cps Unit #1 NMPC J. C. Aldrich NMPC Prog. Mgr. Root Cause/ Tren H. T. Barrett NMPC SSS Unit #1 Coo. S. Shellin5 NNPC Emergency Plannin5 Coor Thomas J. Chwalsk NMPC Unit II Cperatlona Alan Decracts Unit II Op NMPC I James Burr Unit II Cp Edward Delaney NMPC Unit II Op NMPC Robert Bu11uck NMPC Staff Ser '
Mary L. Hujer Unit #2 Mech,., Design NMPC Mary Kohlbronner NMPC Unit #1 Stru. Design Donald Cameron Unit #2 Records Mst.-Steward NXPC Linda Edwards Unit 2 Racd's Mgmt Marcla Hagen NNPC NMPC securlty Charles Sonit! NMPC Nuc. Engr. & Li J. Beijen-Lukens Nuc, En5 Jim Bunyan NMPC Nuc. En NMPC Joe Messlaa M5r. Nuo. QA Cperations NMPC C. C. Beckham NNPC Security P. J. Carroll NNPC Unit #1 Mech. Design Floyd Harry NMPC Unit Supv. Fire Prot.-Unit 2 Dennis McNally Unit #1 P!re Pro NMPC Tom Perkins NMPC Unit #2 Flre Pro William Hopper t
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ENCLOSURE 5 SALP bs'RD REPORT ERRATA SHEET Page Line Board Report Amended Report 25 41 and review by the deleted Engineering staff Basis: The licensee did not commit to have all valve packing adjustment work requests reviewed by the Engineering staf Page Line Board Report 42 3-9 One notable exception was the failure of the licensee ,
to discuss the significance of the May 18, 1987 _
>
letter on non-1E devices in Class 1E systems with the new Project' Manager when it was submitted. Failure to emphasize the significance of this issue during the high activity period immediately before Unit 2 full power locensing, ultimately led to postponing the Commission Briefin '
Amended Report However, the licensee needs to ensure that the NRC staff is alerted to items that require immediate attention. On May 18, 1987 the licensee submitted a-failure modes and effects analysis for non-1E devices in IE systems. While the NRC recognizes the licensee's initiative concerning the self-identification of this issue, the licensee should have discussed the significance of the issue with the new Project Manager when it was submitted. Failure to emphasize the significance of the issue during the high activity period immediately before ,
Unit 2 full power licensing, delayed the identification of this issue as an item that needed to be resolved before full power licensing. This late identification led to a two week postponement in.the issuance of the full power licens Basis To provide more background on licensee responsiveness to this critical licensing issue, but to also credit the licensee for their self-identification of the 1 issue.
1
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l ENCLOSURE 5 (continued)
l Page Correction T1-2 through T2-7 Due to a data entry error for the inspection hours for Inspection Report 50-410/87-16 in Table 1, several dependent inspection hour totals and percentages in Table 2 required correctio P_ age Correction Various Various typographical, spelling and grammatical errors were corrected throughout the report, but are-not specifically annotate I l
l
ENCLOSURE 2
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- % UNITED STATES
/
j 'k NUCLEAR REGULATORY COMMISSION
'
. j REGION I -
t 475 ALLENoALE ROAD l KING OF PRustl A, PENNSYLVANIA 194o6
O: / PR 988 l Occket No. 50-220 Docket No. 50-410 Niagara Mehawk Power Corporation ATTN: Mr. W. Donlon President 301 Plainfield Road Syracuse, New York 13212 Gentlemen:
Subject: Systematic Assessment of Licensee Performance (SALP): Report No. 50-220/86-99 and 50-410/87-99 The NRC SALP Board conducted a review on March 28, 1988 to evaluate the performance of activities associated with Nine Mile Point Unit I and The results of this assessment are documented in the enclosed SALP Board Repor A meeting will be scheduled to discuss this assessment. This meetinq is intended to provide a forum for candid discussions relating to your performance during the perio '
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As discussed in the current SALP Report and the prior separate Unit 1 and
) Unit 2 SALP Reports, Niagara Mohawk's initiatives to improve performance have j met with limited success in some functional areas but have not been sustained in cthers. We believe that the examples, cited in this report, of lack of positive motivation and worker attitude, and the lack of effective coordination 1
and cooperation between various station and corporate departments, have been
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significant contributing factors to your inability to sustain improved overall performance. At other Region I nuclear power plants, these symptoms have been ;
precursors to more 1erious regulatory concern l
Your recent actions to strengthen site management and build teamwork are '
positive steps; however, we remain con:erned about leadership weaknesses and your staff's ability and propensity to seek out and correct technical and ,
management problems before they become regulatory concern !
At the meeting, you should be prepared to discuss our assessment and your plans to address those areas that require improved performance. In particular, you should be prepared to discuss your actions relative to the planned reorganization and management change Any comments you may have regarding our report may be discussed at the meeting. Additionally, you may provide written comments within 30 days af ter the meetin l
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Niagara Mohawk Power Corporatio i
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We appreciate your cooperatio
Sincerely,
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William T. Russell l Regional Administrator Enclosure:
NRC SALP Board Report No. 50-220/86-99 and 50-410/87-99 cc w/ enc 1:
C. Mangan, Senior Vice President J. Endries, Executive Vice President Connor & Wetterhahn John W. Keib, Esquire J. Perry, Vice President, Quality Assurance T. Perkins, Vice President, Nuclear Generation C. Terry, Vice President Nuclear Engineering and Licensing J. Willis, General Station Superintendent T. Roman, Station Superintendent, Unit 1 R. Abbott, Station Superintendent, Unit 2 W. Nansen, Manager Corporate Quality Assurance C. Beckham Manager Nuclear Quality Assurance Operations Department of Public Service, State of New York Public Document Room (POR)
local Public Document Room (LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York Chairman Zech Commissioner Roberts Commissioner Rogers Commissioner Bernthal Commissioner Carr K. Abraham (PAO)(14)
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Niagara Mohawk Power Corporation -3-Nb bcc w/ encl:
Region I Docket Room (with concurrences)
Management Assistant, ORMA (W/o encl)
ORP Section Chief Region I SLO W. Johnston, DRS Director, DRSS J. Allan, RI 0. Holody, RI Board Members R. Capra, NRR R. Benedict, NRR M. Haughey, NRR B. Clayton, EDO, Region I Coordinator G. Matakas, DRP File, RI E. Kelly, DRP, RI H. Eichenholz
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ENCLOSURE 4
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M Y NIAGARA
',- RUMOFAWK __
HlAGARA MoH AWK POWER CORPORATION /301 PLAINF!Et O ROAD, SYRACUSE, N.Y.13212/ TELEPHONE (315) 474 1511 June 9, 1988 NMPil 0266 l
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l U. S. Nuclear Regulatory Commission Attn: Document Control Oesk l Washington, DC 20555 l Re: Nine Mlle Point Units 1 and 2 Docket Nos. 50-220 & 50-410 l OPR-63 & NPF-69 l Systematic Assessment of Licensee Performance Gentlemen: j Attached are Niagara Mohawk's comments on the Systematic Assessment of l Licensee Performance (SALP) Report dated April 21, 1988. These comments were
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discussed with you during our meeting on May 10, 198 As indicated during the meeting, Niagara Mohawk generally agrees with your assessmen We have a number of programs in place to address the areas cited by you 4s needing improvement. These have been previously discussed with you. We are also taking additional actions as described in the attached. We recognize that some of these programs are long term in nature and will require continual management oversite to assure success. As you indicated in your report, some limited success has been achieved, but other areas still need ,
improvement. We are continuing our efforts in those area As we proceed through the next assessment period, we will be evaluating our performance utilizing our Self Appraisal Team effort and our ongoing Special Evaluations of our Long Tere programs. We would be pleased to meet with members of the NRC staff to discuss our findings relative to performance impro,v ent. An appropriate time period may be approximately midway through the current Assessment oeriod or September, 198
Sincerely, NIAGARA MOHAWK POWER CORPORATION MULAp%
C.V. Mangan Senior Vice President CVM/mjd/sym 1461W Enclosures xc: Regional Administrator, Region I Mr. R. A. Capra, Director Mr. R. A. Benedict, Project Manager Ms. M. F. Haughey, Project Manager Mr. W. A. Cook, Resident Inspector RJcords Management (f0b $' 0% ,
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NIAGARA MOHAHK POWER CORPORATION COMMENTS ON
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NRC SALP FOR NINE MILE POINT UNITS 1 AND 2 REPORT NO. 50-220/86-99 and 50-410/87-99
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JUNE 9, 1988 ,, ,
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. Summary
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As indicated during our meeting on May 10, 1988, Niagara Mohawk generally l agrees with your Systematic Assessment of Licensee Performance (SALP) j Report dated April 21, 1988. Provided herein are our comments on the l Report with emphasis on our plans for. improving overall performance in l those areas where recommendations were provided by the SALP Board. Also provided are our comments on several areas where we disagree with the Reports findings. These comments were discussed with you during the May 1 10 meetin II. Specific Comments and Response to Recommendations Summarized herein are our specific comments and responses to the SALP Report. Also, in several areas we have provided additional clarifications for your consideration. The comments are provided to correspond to each of the performance areas found in the Repor Operations Independence of Operations He recognize the need to eliminate complacency and the sense of independence from other departments. He are accomplishing this through our team building efforts within the Nuclear Divisio Various teams have been established to address items such as the development of an Operator Code of Ethics and an improved Operator Requalification Training program that incorporates the Operators specific needs. Operations personnel are also now part of the Work Control Center at Unit I which helps to improve the interface and communications between Operations and other group .
The Institute of Nuclear Power Operations (INPO) has been and will be used in the future to help improve our Operations interface. An INPO assist visit is scheduled for June to help identify additional methods to reduce Operator independence and strengthen teamwor . Housekeeping Several steps have been taken to improve housekeeping. Areas of the plant have been assigned to specific individuals who are responsible for housekeeping. These individuals are required to tour their assigned areas frequently and take action to correct noted housekeeping problem Weekly Superintendent and General Superintendent tours are conducted. Deficiencies noted are recorded and followed. Housekeeping has improved recently and we expect further improvement . Operating Logs A weakness was identified at Unit 2 in that Operating data logs were not maintained by the auxiliary operators who make rounds in the plan Operating logs on equipment such as diesel
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generators have been developed, however, in general, auxiliary )
' operators do not generate equipment operating logs on their l
l rounds. Unit 2 was designed for automatic recording of plant j data. Instrumented systems exist and data is collected via I trend recorders or computer log He are currently developing our system engineer progra System Engineers will participate in the analysis of system performance. One of the initial tasks of-the System Engineers will be to re-evaluate which equipment requires operations logs and trending. From this evaluation, operating logs and trending activites will be implemented accordingl . Procedural Compliance We are continuing our efforts to improve in the area of procedural compilanc Our Long Term program for improving procedures is in progress. Weekly meetings between the Operations Superintendent and shift personnel in requalification emphasize items such as procedure and Technical Specification compliance. Overall procedure rewrites are ongoing for both units. Major programs are underway to rewrite the Administrative Procedures and Radiation Protection Procedures to, among other things, make them more user friendly. We are also implementing nodifications, such as with the Standby Gas Treatment System, to reduce the potential for personnel erro B. Radiological Controls and Chemistry Review and Oversight of Radiological Hork Activities As indicated in the Report, we have made enhancements to address previously identified weaknesses. However we recognize, for the ,
reasons stated below, that further improvement is needed in the review and oversight of radiological work activitie The NRC observed that management oversight of ongoing work was inadequate during the refueling outage. These problems occurred during the Initial phase of the outage, because a significant effort was required for the On-The-Job Training (0]T) and qualification of contractor and temporary Radiological Technician These problems could not be anticipated because of the rescheduling of the outage. However, Supervisory Technicians (Chiefs) were assigned to major work areas, to ensure adequate oversight of oa-going work, and in 1987, plant supervisor tours were instituted in an effort to provide i oversight of work activities in both units. These supervisors 1 attended the INP0 Observer Training Program to better help the I perform this oversight function. As the early training and l qualification efforts were completed, additional emphasis was j given to oversight of ongoing work. This included daily ;
Radiation Protection supervisor tours, and weekly Radiological '
Support management tour !
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.- Alst the information gained during the plant supervisor tours
1s now teing trended in our Radiological Performance Monitoring '
Report.- This trending program will also allow us to track the effectiveness of our corrective action He are aggressively pursuing the timely implementation of corrective actions identified in the radiological are For examr'a, corrective action programs for internal dosimetry conciens, portal monitor concerns and hot particle programs have been reviewed and found acceptable to the NR . Unit 1 Non-Radiological Chemistry Area Improvements Improvements are being pursued in the area of non-radiological water chemistry. A Corporate policy regarding water chemistry was issued in February 1987. An INP0 Assist visit in 1988
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resulted in recommendations to improve our non-radiological chemistry op' rations philosophies. Recommendations, which resulted from a self-initiated Corporate Assistance and Svety Review and Aud)t Board review of plant lay-up and contre .f -
plant chemicals, have strengthened the program. Mods mica are currently underway at Unit 1 to replace conductis a instrumentation and dissolved oxygen instrumentatio Maintenance practicos are being revised to afjress temperature control features; if these prove inadequate, modifications will be made. Existing practices at Unit 2 will be reviewed to assess demineralizer capacity requirements.
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3. Restore GEMS at Unit 2 He have in place a project team to address the problems associated with the Unit 2 Gaseous Effluent Monitoring System (GEMS). The system has been pre-operationally tested, however, '
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software changes are needed to make all' aspects of the system functional. These are currently being addressed. He anticipate the system will be operational by July 31, 198 . ALARA Review Program We agree with the assessment of the ALARA Review Progra He are working to develop improved dose tracking systems to better ,
identify the status of work in progres Increased management attention will be directed to the ALARA program in an effort to provide heightened ALARA awarenes Improvements will be made in our tracking and reporting techniques to keep all workers and supervisors informed of site and task related ALARA performanc The current Site Respiratory Protection Coordinator is also
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responsible for oversight of our ALARA Program. He plan to separate these two functions so that oversight of both programs will receive increased attentio . Performance Trends As indicated above, we have in place programs to address the l concerns outlined in the Report. Additionally, we have been i
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aggressive in addressing other radiological and chemistry area
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concerns. For example, due to our demineralizer operating practices, Unit I has an exceptionally low reactor water conductivity. The radwaste volume generated at Unit 1 in 1987 was 5769 cubic feet compared to the BHR Average of 20,000 -
25,000 cubic feet. He have significantly reduced the man rem exposure required for Control Rod Drive work from approximately 1900 mrem per drive in 1986 to approximately 1500 mrem per drive during the current outage at Unit 1. A "zero discharge" for liquid effluents at Unit I has been maintained. . Pipe and tank replacements have helped to reduce Radwaste Operations exposure. An ta-reactor stress corrosion cracking water chemistry test was performed at Unit 1 in 1987. Data generated will be used to develop a permanent Hydrogen Water Chemistry program for Unit 1. He have developed an aggressive "Hot Particle" progra He believe these examples provide an indication that our Radiological Controls and Chemistry program is not declining in overall performance and we request that this assignment of a declining trend be reconsidere C. Maintenance Root Cause Evaluations As indicated in your Report, this area shows signs of improvement. The root cause evaluation area is one of our ongoing Long Term Program Initial program accomplishments include the development and implementation of Root Cause Determination Procedures. Lessons Learned books are updated to reflect root cause evaluation results. Analytical troubleshooticg training is planned for first-line supervisor .
Continuation of our Long Term Program is expected to further improve our root cause evaluation capabilitie . Feedwater Control Valve Failure The report indicates that the sticking feedwater control valve problem experienced earlier in the cycle at Unit 1 was a precursor to the failure that occured with the same valve shortly thereafter. However, as outlined in our report to you dated Marcn 1, 1988, we have determined that these events were not relate . Engineering Review of Work Requests The Report at Page 25 indicates that the Work Requests for future safety related valve packing adjustments will be reviewed by the engineering staff to ensure proper post-maintenance testin However, to clarify this point, this review is only equired for post-maintenance testing for certain containment isolation valves. A!so, this review may not be required on each post-maintenance testing requirement if there exists a prior applicable generic revie l
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D. Surveillance
- Strengthen Corporate Managenent oversight of the Surveillance Program Improvements have been adde and will continue to be made in the surveillance area. For example, in the case of the Stendby Gas Treatment System missed surveillances, procedures have been revised to reduce the potential for personnel erro Design changes have been implemented to improve record keeping and surveillance compliance. Use of task teams has helped to solve the problems identified in the syste As indicated in Section II.A.3, we are currently developing the responsibilities for System Engineers. It is anticipated that the System Engineers will review surveillance data and trend key parameters to predict and prevent problem With regard to Unit 2, personnel changes have been made in our Operations Departmen Weekly shift meetings between the Operations Superintendent and Operations staff has improved communication with regard to surveillance activitie A work control center is planned for Unit 2. This work control center will be similar to Unit I and will help to reduce the potential for missing surveillance Further design changes are being considered to reduce the potential personnel errors during surveillance testin INP0's Human Performance Evaluation System methodology is being implemented. Approximately 501. of the Technical Support Staff has been trained on this methodology. Further training is planned in the third quarter of 198 A Niagara Mohawk Staff member is chairman of the INP0 Maintenance Human Performance Evaluttion System Committee and a member of other Human ',
Performance Evaluation System action committees. A full time Human Performance Evaluation System Coordinator will be part of the reorganized Technical Departmen In summary, the unit surveillance programs and procedures have been strengthene Surveillances.are both verified and tracked independently by individuals other than the action pcrty assigned the surveillance. A Quality Assurance Ope n tions Surveillance Program oversees both units. Enginee ig reviews at Unit 2 are identifying improvements that can be made to address human factor concern E. Engineering Inadequate Involvement of Engineering in the Resolution of ISI Program Concerns As outlined in our letter of April 13, 1988, several concerns have been identified by Niagara Mohawk in our Unit 1 Inservice Inspection (ISI) program. He are aggressively pursuing resolution of these concerns and will resolve them prior to startup from the current outag __ __
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He have already made several changes in the ISI program area,
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including reassignment of ISI personnel, identification of an ISI program manager, establishment of a multidisciplinary task
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force to support specific ISI areas, increasing oversight of contractor activities, and tracking of non-conformances by an independent grou . Contractor Oversight He are improving our oversight of contractors in the ISI Program and ather areas during outages. As part of our current reorganization, an Outage Projects Group will be established
, with specific responsibilities for oversight of outage activitie . Station-to-Engineering Interface As part of the current reorganization, a permanent Site Engineering Group will be established at the Station. This group will be the primary interface between the station and Engineering for the resolution of day-to-day problem Sufficient staffing will be provided to ensure resolution of problem Face-to-face communications between Station personnel and Engineering will improve the overall interfac System Engineers will te primarily located in this grou F. Security and Safeguards He have no additional comment G. Emergency Preparedness He have no additional comment ,.
H. Licensing Additional Management Attention is Needed to Improve Licensing Performance A senior level manager has been assigned to manage Niagara Monawk's Licensing group. He reports directly to the Vice President Nuclear Engineering and Licensing. As part of tne l Nuclear Division reorganiza;1on, a Site Regulatory Compliance I group has been established to improve the coordination of Licensing activities onsite. A Nuclear Olvision Commitment
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Tracking System is currently being implemented. The Nuclear Commitment Tracking System is designed to provide better control, accuracy and more timely responses to NRC related commitments. Finally, plans are currently being developed to improve the overall interface and communications between Niagara Mohawk and the NR . Use of Non IE Devices in Class IE Systems The Report indicates that Niagara Mohawk failed to recognize the significance of this issue during the Unit 2 fitli power hearings-6-
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and this ultimately led to postponing the Commission briefin ** As indicated during the SALP meeting .we feel we have been proactive in resolving this generic issu '
The initial problem was identifled by Niagara Mohawk Engineers and immediately elevated to senior management and NRC. He are continuing to pursue resolution of this generic issue. He feel that the SALP report does not properly reflect these action I. Trainina Audit the Requalification Training Program and Revise as Needed As summarized in our letter of April 21, 1988 and our response to the confirmatory action letter, Niagara Mohawk has evaluated its requalification training program. Improvements have and will be implemented to enhance its overall effectivenes The requ&lification documentation has been reviewed and discrepancies have been corrected. A computer based record keeping system will be in place by the end of 1988 to better track training activitie In addition, a future Quality Assurance followup audit has been scheduled to assess the effectiveness of our activities to solve the identified documentation problems in this are . Examine Training Needs and Incorporate Operator Needs A joint Operations and Training team has been established to ass % ; and evaluate Operator training needs. Several recommendations are currently being reviewed by managemen The Self Assessment Team (SAT) findings also identified training related issues. These are also being evaluated by management for possible utilizatio ,,
J. Assurance of Quality Complete the Reorganization and More Clearly Define Staff Responsibilities and Accountability We are aggressively pursuing our reorganization of the Nuclear Olvision. A major effort has been in place to clearly define departmental roles and responsibilities as well as to identify volds and overlaps in group functions. This has been an ongoing part of cur Long Term Program in the Management _ Effectiveness Are ;
Several management changes have taken place over the past yea i A new General Superintendent of Nuclear Generation has been i hired from outside of Niagara Mohawk. He brings new perspectives and motivation to the Nuclear Division. Two new i Superintendents of Operations are in place at Unit 1 and )
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These changes will help to strengthen management oversight, l Improve station teamwork and address leadership concern Additional improvements include:
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J* - The implementation of Technical Specifications
, interpretation book The utilization of INPO peer evaluation Establishment of Nuclear Division goal l
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- Senior level management meetings ("People to People").
- Management tours to address housekeeping concern Relocating the Senior Vice President to the Sit In addition, we are looking into ways to strengthen Site Operations Review Committee and Safety Review and Audit Board review All of the above actions will result in better oversight and management of Nuclear Generation and Nuclear Engineering activitie III. Conclusions As indicated during the meeting, Niagara Mohawk generally agrees with your assessment. He have in place a number of programs to address the areas cited by you as needing improvement. These have been previously disct:: sed with you. He recognize that some of these programs are long
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term in nature and will require continual management oversite to assure success. As you indicated in your Report, some limited success has been ,
achieved, but other areas still need improvement. He are continuing our efforts in those areas. As we proceed through the next assessment period, we will be evaluating our performance utilizing our ,.
Self-Appraisal Team effort and our ongoing Special Evaluations of our Long Term Programs.
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