Text

SALP Rept 50-247/85-98 for Aug 1985 - Jul 1986
	ML20214D235
Person / Time
Site:	Indian Point
Issue date:	07/31/1986
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
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ML20214D224	List: IR 05000247/1985098; ML20214D221;
References
	50-247-85-98, NUDOCS 8611210424
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{{#Wiki_filter:e %' ENCLOSURE SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-247/85-98 CONSOLIDATED EDISON COMPANY, IN INDIAN POINT STATION - UNIT 2 ASSESSMENT PERIOD: AUGUST 1,1985 TO JULY 31, 1986 BOARD MEETING DATE: SEPTEMBER 23, 1986 hDR DO Sbb247 G PDR ,

P s SUMMARY . . . . . . . . . . . . . . . . 42 Table 3 ENFORCEMENT SUMMARY . . . . . . . . . . . . ...... 43 Table 4 INSPECTION REPORT ACTIVITIES . . . . . . . . . . . . . . 46 Table 5 LISTING OF ALL AUTOMATIC TRIPS AND UNPLANNED SHUTDOWNS . . 49 Table 6 NRR SUPPORTING DATA AND SUMMARY . . . . . . . . . . . . . 52 FIGURES Figure 1 NUMBER OF DAYS SHUT DOWN . . . . . . . . . . . . . . . . . 54

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s I. INTRODUCTION Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an inte-grated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this informatio The SALP program is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources ana to provide meaningful guiaance to the licensee's management to promote quality and safety of plant construction and operatio An NRC SALP Board, composed of the staff members listed below, met on September 23, 1986, to review the collection of performance observa-tions and data and to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at the Indian Point Station, Unit 2 for the period August 1, 1985 through July 31, 198 SALP Board Members W. F. Kane, Director, Division of Reactor Projects (DRP) W. V. Johnston, Deputy Director, Division of Reactor Safety S. J. Collins, Deputy Director, Division of Reactor Projects R. M. Gallo, Chief, Projects Branch No. 2, DRP L. J. Norrholm, Chief, Reactor Projects Section 28, DRP S. A. Varga, Director, PWR Project Directorate #3, NRR

J. D. Neighbors, Licensing Project Manager, NRR L. W. Rossbach, Senior Resident Inspector, Indian Point 2 C. J. Cowgill, Acting Chief, Emergency Preparedness and Radiological Protection Branch Other NRC Attendees M. M. Shanbaky, Chief, Facilities Radiation Protection Section W. J. Lazarus, Chief, Emergency Preparedness Section R. R. Keimig, Chief, Safeguards Section G. C. Smith, Safeguards Specialist D. P. LeQuia, Radiation Specialist P. W. Kelley, Resident Inspector, Indian Point 2

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s C. Backoround Licensee Activities The unit set several station performance records in 1985. These included the highest capacity factor (88.8%) and most days of continuous operation (156). The unit shut down automatically on January 13, 1986 when a main boiler feedwater pump tripped due to the failure of a hose in its high pressure oil system. The unit remained shut down and began the cycle 7/8 refueling outage. The low pressure turbine rotors were replaced during the outage and tests of the main electrical generator revealed a number of shorts. The rotor was J pulled and extensive examination and repairs to the stator coils were begun. Although the electrical generator remained out of service, the refueling, rotor replacement, and other scheduled maintenance items were completed on schedule and the unit was brought critical for zero power physics testing on March 12. The unit was then shut down while the electrical generator repairs continue Plant heatup was begun on May 3, however, reactor criticality was delayed until May 25 due to several component failures. The unit reached 100% power on June 2 During this assessment period, the unit tripped twelve times and had two unplanned shutdowns, giving a trip rate of 2.32 trips per 1000 hours critica This is higher than the average trip rate of 1.04 for all Westinghouse units in 1985. These trips and shutdowns are described in Table 5 and are discussed in Section I The licensee made several organizational changes during this SALP assessment period. The managers of Quality Assurance and Nuclear Training, the Instrumentation and Control Engineer, and the Maintenance Engineer were newly assigned. The Major Projects Manager was given increased planning and materials control responsibilities under the title of Planning and Projects Manager; and, now reports to the Nuclear Power Generation Manager. The position of Manager - Fire, Safety and Security was created and filled. This position provides for additional management oversight of the security program and incorporates supervision of the security, safety, and fire pro-tection programs under one administrator. The licensee also created a Records Management Cente On August 1, 1986, the licensee began the onsite consolidation of several engineering support groups previ-ously located at corporate headquarters. A new General Manager of Technical Support began his duties on August I as part of this consolidatio . Inspection Activities Two NRC resident inspectors were assigned to the unit throughout the entire assessment perio _ . _ . _ _ _ ._ - _ _ _ _ _ . _ . _ _ _ _

s Special team inspections were conducted as follows:

* Appendix R Safe Shutdown, September 16-20, 1985
* Environmental Qualification, May 12-16, 1986 Health Physics Appraisal, June 16-20, 1986
* Probabilistic Risk Assessment Based Inspection, July 21-August 1, 1986 The scope of the probabilistic risk assessment team inspection was formulated based on a review of the Indian Point Probabilistic Safety Study and an NRC sponsored peer review by Sandia Laboratory (NUREG/CR-2934). The risk significant accident initiators, equipment failures, and operator errors contained in the top twenty four dominant accident sequences were studied. Major areas selected for review included recovery actions from a loss of offsite power, as well as from a loss of coolant accident. Assessments were made of the ability of the operations staff to respond to events, of the reliability of plant hardware, and of the effectiveness of management controls in areas such as maintenance, testing, and quality assuranc The overall results showed an experienced and knowledgeable staff. A number of weaknesses in Emergency Operating Procedures were identified, as discussed in Section I Several hardware discrepancies relating to configuration management were identi-fied, as discussed in Sections IV.A and Inspection hours are summarized in Table 2 and total 4241 hours for the assessment period. lable ' lists specific enforcement data. Inspection report activitter. are summarized in Table This report also discusses " Training and Qualification Effectiveness" and " Assurance of Quality" as separate functional areas. Although these topics, in themselves, are assessed in the other functional areas through their use as criteria, the two areas provide a synopsis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resident inspectors and as an integral aspect of specialist inspections. Although quality work is the responsibility of every employee, one of the management tools used to measure Quality Assurance effectiveness is reliance on quality inspec-tions and audits. Other major factors that influence quality, such as involvement of first-line supervision, safety committees, and worker attitudes, are discussed in each are _

- I CRITERIA Licensee performance is assesssed in selected functional areas. Each functional area represents areas significant to nuclear safety and the environment and are normal programmatic area The following evaluation criteria were used to assess each functional area: Management involvement in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Reporting and analysis of reportable event . Staffing (including management). Training effectiveness and qualificatio However, the SALP board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The definitions of these performance categories are: Category 1: Reduced NRC attention may be appropriat Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety and construction quality is being achieve Category 2: NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are con-cerned with nuclear safety; licensee resources are adequate and are rea-sonably effective such that satisfactory performance with respect to operational safety and construction quality is being achieve Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear strained or not effectively used such that minimally satisfactory performance with respect to operational safety and construction quality is being achieve __ - - o . The.SALP Board has also categorized the performance trend over the last quarter of the SALP assessment period. The categorization describes the general or prevailing tendency (the performance gradient) during the last quarter (May - July 1986) of the SALP period. The performance trends are defined as follows: Improving: Licensee performance has generally improved during the last calendar quarter of the current SALP assessment perio Consistent: Licensee performance has remained essentially constant during the last calendar quarter of the current SALP assessment perio Declining: Licensee performance has generally declined over the last calendar quarter of the current SALP assessment perio , ..

III. SUMMARY OF RESULTS 3.1 Overall Facility Evaluation The major site management changes made during the last assessment period have contributed to improved performance in several area The leadership of the Vice President, Nuclear Power was instrumental in bringing about these improvements and is continuing to have a positive impact on overall performanc Management effectiveness has improved as noted in the recent program inspection for Appendix R and also, in the control of outage activi-tie Program changes in the Radiation Protection area have been effectively implemented resulting in an improved program and SALP rating. Based on inspections conducted during this assessment period, the terms of the September 27, 1984 Order Modifying License were determined to have been satisfactorily completed. Some recent organizational changes have not been in effect for a sufficient time, however, to adequately assess their impact, such as your recent security initiative Despite the overall improvements noted during this assessment period two areas warrant specific attention. Our review notes that reactor trips occurred at a rate higher than the industry average. Previous efforts to reduce this rate have not been effective. We acknowledge that a response team was recently initiated to provide a more in-depth investigation of trips. Our analysis indicates to us a need for additional operator training dedicated to normal evolution Correspondingly, your actions should assure that the simulator upgrade is properly and expeditiously completed, so that such training will be available to provide a more accurate simulation of those evolution Secondly, the amount of maintenance remaining to be completed is of concern to u Your actions should consider the review of maintenance staffing and prioritization including efforts to integrate probabilistic risk assessment into the maintenance program to provide a work prioritization system based on ris "

. 3.2 Facility Performance Category Category Recent Functional Area Last Period This Period Trend *

 (August 1, 1984 to (August 1, 1985 July 31, 1985) to July 31,1986) Plant Operations  2  2 Consistent Radiological Controls 3  2 Consistent and Chemistry Maintenance  2  2 Consistent Surveillance  1  1 Consistent Fire Protection  2  1 Consistent Emergency  1  2 Improving Preparedness Security and  1  2 Improving Safeguards Outage Activities  2  1
    ** Training and Qualification Not Evaluated 2 Consistent Effectiveness Assurance of Quality Not Evaluated 2 Consistent Licensing Activities 2  2 Improving
* Trend during the last quarter of the assessment perio **No basis to determine a performance tren .

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. IV. FUNCTIONAL AREA ASSESSMENTS Plant Operations (23%, 981 Hours) Analysis The previous SALP determined the operations area to be Category 2. Nine trips occurred during the previous SALP period and it was recommended that the licensee review the causes of trips to reduce their frequency. It was also recommended that the integration of the shift technical advisors (STAS) on shift be evaluated and that the quality of written and verbal reports be improve During this assessment period, the unit was critical for approximately 5175 hours (216 days) and had twelve trips. These trips were distributed as follows: ten automatic trips while critical, one manual trip while critical and one manual trip while subcritical. Two other unplanned shutdowns also occurred during this assessment perio Four trips can be attributed to operator errors, three by licensed operators, one by a nonlicensed operator. The three errors by licensed operators occurred during normal operations and indicate a need for additional training time dedicated to the conduct of evolutions such as power escalation and a need for increased accuracy in the simulation of these evolution The error by the nonlicensed operator was due to failure to follow procedures. Other instances of operators failing to follow procedures have not been identifie One trip occurred due to a drawing not being updated following plant constructio The licensee's corrective actions in this area are being followed by the inspector In March 1986, at the end of the refueling outage, the licensee initiated a trip response team whose goal is to reduce the number of trips. The group investigates the event, determines root causes, and recommends and tracks corrective actions. The trip response team leader is also an active participant in the Westinghouse owners group trip reduction and assessment progra The effectiveness of this effort has not been assesse In October 1985 the licensee implemented symptom-oriented Emergency Operating Procedures (EOPs). All licensed operators received six weeks of training in their use prior to implementa-tion. Operators have been observed to use the E0Ps proficiently during actual events. General simulator performance and exami-nation results of SRO classes in this assessment period and the previous assessment period were above average. Operators have

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D accepted the E0Ps and appear to be well trained in their us All six SRO candidates examined during this assessment period received license E0Ps were not being evaluated and updated in a timely manne Apparently, due to a cumbersome change process in place for E0Ps, changes were being accumulated for single revision Also, the E0Ps were not being thoroughly reviewed as evidenced by several procedure inadequacies identified by the PRA team inspectio The control room environment is a strength, consistently neat and orderly. Operators conduct themselves in a professional manner. Shift turnovers are thorough and effectiv Daily morning meetings chaired by the operations manager, are used to coordinate each day's activities in the areas of maintenance, surveillance, rad waste and modification construction. In addition to a representative in each of these areas, the meetings are attended by QA, health physics, and securit There are currently 43 licensed Senior Reactor Operators (SR0s) and 14 licensed Reactor Operators (R0s). The shift staffing consists of two SR0s and two R0s. One of the R0s is a roving RO who can perform duties outside of the control room as long as he is not more than ten minutes away. There are a total of six shifts with the above manning. Starting at the end of the refueling outage the licensee changed to twelve hour shift The overtime usage is kept to a minimum and well within the limits of NRC Generic Letter 82-1 The licensee has evaluated how to provide better shift integra-tion of STAS as recommended in the previous assessment. Assess-ment of study findings and scheduled implementations are under consideratio The quality of the Station Nuclear Safety Committee (SNSC) and the Nuclear Facilities Safety Committee (NFSC) reviews of events and other items remains good. As discussed in Section 4.10, a new SNSC Chairman was appointed effective August 1, 1986 as part of a consolidation of Corporate office engineering personnel with the onsite organizatio The licensee has been responsive to several NRC findings during this assessment period, taking prompt corrective action However, one area that has been a continuing problem since the previous assessment period is in making prompt notifications by

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the Emergency Notification System. Instances were identified in , which the required notifications were not made, were made late or were incompleta. Required corrective actions are currently being developed by the licensee in this are The four operations training programs (NPO, R0, SR0/SWS, STA) were submitted to INPO on schedule during this SALP perio Management attention to housekeeping has been evident by the emphasis given to housekeeping at morning planning meetings and by frequent plant tours by management. Despite management attention, performance in this area has been inconsisten Control of contamination has improved, and as a result of a large effort by the licensee, contaminated areas have been reduced by 50% since January 1985. The licensee continues to demonstrate a resolve to maintain a clean plant through programs to decontaminate the Maintenance and Outage Building and utility tunnel. Control of trash has generally been good, however, various inspections have identified construction debris in the pipe penetration area and containment building and trash in the fuel storage building. Contrary to administrative control measures, unsecured gas cylinders have been observed during NRC inspection Loose gas cylinders were also identified in a QA surveillance report but no effective actions were taken to resolve the findin In summary, plant operations are well managed. However, trips are occurring at a rate higher than the industry averag Emergency operating procedures were implemented well but need to be thoroughly reviewed and updated in a timely manne . Conclusion Rating: Category 2 Trend: Consistent 3. Board Recommendations Licensee: None NRC: None i

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. B. Radiological Controls and Chemistry (21%, 903 Hours) Analysis On September 27, 1984, an Order Modifying License was issued due to programmatic deficiencies in the licensee's radiological controls progra During the previous SALP assessment period, the licensee developed a completely revised radiation protection program and trained personnel in the implementing procedure Full implementation of the revised program occurred one month prior to the end of the previous SALP assassment period. During the current SALP assessment period, the NRC conducted several inspections to verify the licensee's program improvements and to evaluate the effectiveness of program implementatio There were nine inspections and a Health Physics Appraisal by radiation specialists of areas affecting radiological controls during this period. Resident inspectors also monitored radio-logical controls related activitie Radiation ; otection The licensee has demonstrated timely an6 thorough development of program elements, including: effective communication and dis-semination of radiological controls information to the site staff; establishment of cooperative working relationships with all plant groups; initiation of strong ALARA incentives; and development of concise health physics procedures. The licensee has also demonstrated aggressive action and strong management oversight in implementing the program element The licensee has a sufficient number of well qualified and trained individuals functioning at all levels within the radiation protection organization. There were, however, some changes within the organization during this assessment perio Specifically, the Radiation Protection Oversight Committee was dissolved. This committee had been chartered to provide oversight of the Radiation Protection (RP) Program following issuance of the Order Modifying License in 1984. The respon-sibilities previously delegated to this committee have been reassigned to the Radiation Safety Committee, a subcommittee of the Nuclear Facilities Safety Committe In addition, the position of Radiological Assessor, which had been vacant for several months, was filled through the promotion of a plant radiological engineer. This is a high visibility position, and a key link to help assure the continued quality of the RP progra , -

An effective RP training program has been established for plant Health Physics (HP) personnel. This program includes the use of mock-ups as practical learning aids. In the area of contractor HP technician training, apparent weaknesses were identifie Specifically; formal lesson plans had not been established, written performance tests were technically shallow, and management eversight was not sufficient to assure that contractor technician training was adequately prepared and planned. Upon NRC identification of these weaknesses, licensee management immediately committed to rectify them prior to implementation of the contractor technician training progra Subsequent re-inspection of this area verified that the licensee had taken timely and effective action to correct program weaknesse External radiation exposure controls were well established and effective as evidenced by clear administrative and physical controls of High Radiation Areas, Radiation Areas and Airborne Areas. An effective Radiation Work permit (RWP) system, supported by adequate radiological assessments and measurements is now in place. Improvements continued in the personnel dosimetry program, with the purchase of a new TLD dosimetry system and proposal for additional training of dosimetry technicians and supervisory personnel. However, some weaknesses in the implementation of the radiation protection program during the outage were note Specifically, a high radiation area was not posted or barricaded and several instances of failure to follow RWP requirements occurred. The additional workload associated with the outage appeared to stress the newly upgraded program. The licensee is aware of this and it will be the subject of further NRC review Internal radiation exposure controls were well established as evidenced by: ongoing efforts to minimize contamination of areas and components; adequate air sampling and evaluation of airborne hazards; use of engineering controls; and use of respiratory protection equipment. In addition, the licensee has established an acceptable bioassay program. Minor program weaknesses were noted which impact on program effectiveness: a limited supply of high volume air samplers which reduced the effectiveness of the licensee's ability to evaluate airborne hazards; a poor maintenance program for self-contained-breath-ing-apparatus; and poor whole body counting facilities. Whole body counting facilities were not sufficiently environmentally controlled to limit radio-signal interference with counting equipmen In addition, high temperatures cause counting system errors. A potential also exists for losing all whole body countir.g capability during an emergency, since the same facili-ties are used for worker decontamination. Once identified, the licensee was responsive to these issue .

. Considerable improvement has occurred in the ALARA program due to good management support and worker involvement. The program is well staffed with qualified radiological engineers. ALARA procedures and policies are well documented to implement the program. Significant exposure reductions were achieved in the early stages of the improved program; however, the collective exposure at Indian Point-2 remains higher than the average for pressurized water reactor Subsequent exposure reductions, as the ALARA program matures, may require a substantial commitment of resources to address the higher than normal source term at the plant, and the less than optimum equipment shield desig Licensee management was aware of this situation and is considering alternate routes to reduce exposur The licensee's internal audits and assessments of the radio-logical control program have substantially improved. However, some weaknesses were identified in this area. Specifically, Radiological Occurrence Reports (ROR) were not actively used to address deficiencies; no generic reviews of RORs were performed to determine if any commonality existed in deficiencies; and the independent radiological assessor did not have a system to track his findings to resolution. The licensee corrected this situa-tion by broadening the previously narrow scope of deficiencies documented in ROR Transportation The licensee is implementing an effective radioactive waste transportation program. Licensee personnel at all levels in radwaste transportation are very knowledgeable with regard to their functions and responsibilities. On going training is eviden The licensee performed several QA Dapartment audits of the transportation program during the period. The audits were performed in accordance with the requirements of 10 CFR 50, Appendix One concern was identified, in that the licensee did not ade-quately communicate to the department responsible for implemen-ting the radwaste program, that their responsibility includes performing the quality control function associated with their activitie This was corrected through comprehensive training and procedure Effluent Control and Post-Accident Sampling A review of the licensee's effluents program indicated it was generally being effectively implemented; however, it was noted that QA involvement was not evident in observing Technical

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Specification required surveillances on plant ventilation system A follow-up review of the licensee's Post-Accident Sampling Systems indicated that the systems remain operative, well-maintained, and that the licensee has adequately addressed several of the concerns identified in the previous inspection in this are Water Chemistry Controls The licensee's nonradiological water chemistry program has been upgraded with state of the art laboratory equipment and procedures. They have initiated an effective QC progra In summary, the licensee has made significant improvements in the Radiation Protection Program since the Order Modifying the License. A health physics appraisal team found all facets of the program to be acceptable for routine and outage radio-logical control activities. Management attention has been appropriately focused toward continued improvements to the progra . Conclusion Rating: Category 2 Trend: Consistent 3. Board Recommendations Licensee: None NRC: Conduct a review of site radiochemistry program.

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, Maintenance (13%, 550 Hours) Analysis During the previous assessment period, the maintenance program was recognized as strong with capable management and a large, experienced staff. A large maintenance backlog had developed and was a concer Licensee management was taking steps to improve the physical condition of the plan A total of four reactor trips were attributed to inadequate maintenance during this assessment period. Two of these trips occurred due to the loss of main boiler feed pumps and two occurred due to capacitor failures. One of the feed pump trips occurred when a high pressure oil hose failed. The hose failed one day before a scheduled outage, during which it was to be replaced. The other feed pump trip occurred due to the bearing oil trip setpoint screw being turned after maintenance. This is one of several examples of inadequate job site restoration which is discussed later in this section. One trip occurred due to a capacitor failing in a reactor coolant flow trip circuit. The capacitor failed before its scheduled replacement. One trip occurred due to the failure of the steam dump controller. A failed capacitor contributed to the controller failure. As a result of this failure, the licensee extended the capacitor replacement program to control circuit Several instances were noted where maintenance work was considered complete but the job site was not completely restored to its original condition. One reactor trip resulted from not returning a boiler feedwater pump trip setpoint to its correct position after mainte-nance. Other instances of incomplete post-maintenance job site restoration include: failure to replace a seismic restraint on a reactor coolant pump; improperly reinstalling the reactor coolant
: pump oil collection system; improperly reinstalling the recirculation l sump grating; and, cutting away portions of the service water pump seismic restraints to simplify replacement of the pumps. Also, tools, removed parts, trash, and leaked oil were observed to remain at work sites after jobs were complete Procedural inadequacies for job site restoration and inadequate post-maintenance job site walk-downs contributed to these events. Also, in the service water pump seismic restraint event, the licensee identified that these restraints were degraded but they were not repaired due to improper prioritization of the work order. Upon identification of these concerns, the licensee took prompt and effective corrective actio However, proper completion of the job restoration phase of mainte-nance requires increased management involvement.

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A large work order backlog continues to be of concern. The licensee > has taken measures to reduce this backlog. Additional maintenance staff have periodically been assigned to the station from the Power Generation Maintenance department and Electric Construction Bureau to support the increased workload. The major projects manager was given increased maintenance planning and materials control responsibilities under the title of planning and projects manager. Senior plant management actively assesses progress on a station goal to reduce work order backlogs. The work order backlog, however, was about the same at the end of this assessment period as it was at the beginnin The backloo appears to be due in part to an increase in worker awareness and responsibility for reporting equipment deficiencie Staffing level appears sufficient so that there is a decreasing trend in the number of backlogged work orders although increased staff or , worker efficiency would further help to lower the backlo The licensee filled promptly and effectively the vacancy left by the maintenance engineer who left the company at the end of the 1986 refueling outage. The current maintenance engineer was promoted to the position from within the licensee's organization. The overall

personnel turnover rate is minimal at both the laborer level and management level. The staffing level remains fairly constant throughout, with the exception of outages when the licensee's offsite maintenance personnel come to the sit The licensee plans to use the probabilistic risk assessment to aid in prioritizing work orders. Although this effort is not yet underway, the licensee is planning to transfer the probabilistic risk assessment staff to the site, where they will be available to support this effort which should result in a reduction in risk from inoperable equipmen Due to difficulty in retrieving completed work ,,ackages, the licensee is reducing the number of status changes the package goes through during its life. The work packages will also be kept in one place rather than distributing the packages to the various reviewing organizations. The licensee's actions to resolve this problem appear to be workin Positive elements noted in the previous assessment period continue to be exhibited. The maintenance staff is experienced. Management in-volvement in the maintenance program is evident and generally effec-tive from preplanning to work completion, except as noted abov Overall maintenance records and work packages are complete and accu-rate. Maintenance procedures are, overall, adequate to perform wor Work steps are listed in order of performance and sign-off steps are well defined. Work orders are tracked using the computerized power plant maintenance information system (PPMIS). With PPMIS, all work order status, priority and post-maintenance testing requirements are assigned. The licensee is continuing the effort to increase the utilization of PPMIS capabilities for tracking purposes. QC hold _-

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. points were established in most work activities inspected. Quality related maintenance records reviewed were complete. QC involvement was appropriate for the work activities. QC performs rando.n sur-veillances of the job site During this assessment perica, the licensee developed training pro-grams for Mechanical, Electrical and Instrumentation and Control staff. The training is adequate for the staff to perform its routine duties. No training-related problems were evidenced by the main-tenance staff's performance. Self Evaluation Reports (SERs) for these programs were submitted to INPO for accreditatio In summary, the maintenance function is being performed satisfac-torily by competent and skilled personnel. A considerable amount of maintenance remains to be done. It is not known what system inter-actions could result or what operator needs would go unmet in an event due to the outstanding maintenance activities. The licensee's efforts to integrate probabilistic risk assessment into the mainte-nance program to reduce the risk from inoperable equipment is therefore encouraged. Additional staffing and improved efficiency would aid in working off the maintenance backlog. Increased atten-tion to post-maintenance job site restoration is neede . Conclusion Rating: Category 2 Trend: Consistent 3. Board Recommendations Licensee: Integrate the probabilistic risk assessment into the maintenance progra Increase efforts to reduce maintenance backlog, including review of staffing levels and work prioritizatio NRC: None _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _

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. Surveillance (14%, 585 Hours) 1. Analysis During the previous assessment period, this area was identified as a strength, Category 1. During this assessment period, surveillance activities were routinely observed by the resident inspector Region-based inspectors also reviewed surveillance activitie In general, the licensee's surveillance program is well defined utt-lizing computerized schedules and technically adequate procedure Management conducts reviews of completed surveillances to ensure the results are acceptable and meet Technical Specification requirements, records are complete, and the necessary follow-up is complete Surveillance procedures are well maintained and easily retrievabl Technical Specification - limited conditions for operation entered for testing purposes are tracked by Senior Reactor Operator and Senior Watch Supervisor log book The licensee has upgraded surveillance procedures during this assess-ment period. Included in the upgrade were generic statement changes, format changes, personnel notification changes, and procedure clari-fications. The surveillance test writing staff consists of knowledgeable people with a strong background in test writing. The testing is performed by members of the operatior.s, performance, and I&C department The test documents and test document changes are strictly controlle During the assessment period, there were three separate cases of minor surveillance performance problems. One case was a late daily heat balance check due to the operators being preoccupied with a plant transient. The second case was an incomplete surveillance test due to the I&C technician omitting the source check of a radiation monitor in the field. The third case was an incomplete surveillance due to operations personnel omitting one control rod from the rod exercise test because it had an inoperable position indicator. All three of these cases were identified by the licensee while reviewing completed test results and they were promptly reported and correcte Except for these three cases, the licensee completed surveillance testing in a timely manne One subcritical reactor trip occurred due to a personnel error during surveillance testing. While performing the reactor protection logic functional test, a technician tripped reactor trip breaker A instead of B as required by the test procedure. This is considered an iso-lated instanc The staffing of the Test and Performance department has remained relatively constant throughout the assessment period. The department writes the majority of the surveillance tests and post-maintenance

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tests. The tests are performed by members of the operations, I&C, l and the Test and Performance departmen Staffing is adequate to perform this function. Based on the performance of the Test and Performance personnel, training appears adequat QA/QC personnel review a sample of completed tests. QA/QC also performs certain hydrostatic test inspections in which certified inspectors are require In summary, surveillance tests are well written and easy to follo Test data is in tabular form for ease of review. Reviews of completed tests are effective in identifying problem areas. The program is adequately staffed and effectively manage . Conclusion Rating: Category 1 Trend: Consistent Board Recommendations

, Licensee: None i NRC: None ..

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. Fire protection (6%, 234 Hours) Analysis During the previous assessment period, satisfactory performance was evident in the fire protection progra During this period, a team inspection was conducted of fire protect-ion and alternate safe shutdown modifications required by 10 CFR 50, Appendix R. The team included specialists in fire protection, mechanical and electrical systems from NRR and Brookhaven National Laborator The inspection focused on the plant's safe shutdown capability. In particular the team reviewed the plant's fire protection measures which ensure that one train of equipment necessary to achieve and maintain safe shutdown remains available in the event of a fire at any location within the plan The review included an inspection of the fire barriers separating redundant safe shutdown components and miscellaneous fire protection systems. A review of the safe shutdown systems, safe shutdown methodology and the emergency safe shutdown procedures was also performe The safe shutdown analysis performed by the licensee was comprehen-sive. The established emergency procedures are clear and easily implemented, although a large number of operators is required for this task. The licensee demonstrated that this crew is always available and is well trained in these procedure The licensee's associated circuit analysis also adequately addressed the regulatory concerns such as common bus, spurious signals, current transformer secondaries and high-low pressure interfaces. All of the above are indications of strong management involvement in fire protection issue The licensee also routinely exhibits conservatism in areas of safety significance and is innovative in the use of Unit 1 equipment, such as the gas turbine, to provide backup power to the emergency diesel The fire protection program was also included in routine inspections by the resident inspector The fire protection program was found to be effectively implemented during this assessment period. Frequent plant tours are made by fire protection staff and supervisio Transient fire hazards 3re kept to a minimu Fire protection staff exhibited a good understanding and effective implementation of procedures for control of the removal and reinstallation of fire barriers.

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Fire brigt de drills were promptly responded to by the brigade. The brigade ' der gave clear instructions to the brigade and good com-munications were maintained with the control roo During this assessment period, the licensee assigned the additional responsibilities of managing the security program to the person in charge of the fire protection program. Although no degradation in the management of the fire protection program has been observed, the effects of this change will be evaluated during the next SALP perio In summary, the implementation of Appendix R and the routine conduct of the fire protection program show that the fire protection program , is well organized and effectively implemented.

i 2. Conclusion ' Rating: Category 1 Trend: Consistent 3. Board Recommendations i Licensee: None NRC: None I E

T l

-- - - . . . - -- --# ._,-r _ . _ . _ , , _ . -zm.- .--,__.~._____-__.-,--.__,.,.-_._,--,_-m- . . . . _ . , _ , - , - _ _ _

__ _ _

' Emergency Preparedness (6%, 265 Hours) Analysis

During the previous assessment period, licensee performance in this area was rated as Category 1, based on performance during the annual exercise, and management involvement in emergency preparedness as evidenced by staffing levels, training, and responsiveness to identi-fying and correcting program deficiencie ' During the current assessment period, one full participation exercise was observed, changes to on and offsite emergency plans were re-viewed, and NRC staff attended meetings called by the Chairman of the Regional Assistance Committee (for FEMA Region II) to resolve offsite emergency planning issue During the full participation exercise conducted on June 4,1986, the licensee demonstrated a strong emergency response capability. Per-sonnel were well trained and qualified in their emergency response roles. In particular, emergency action levels were 1dentified , promptly and the re entry and recovery planning was unusually thor-ough and complete. No significant deficiencies were identified re-lating to onsite activities. Performance remained at the previously noted high levels. One onsite issue that has remained unresolved, is the question over whether the size of this EOF is adequate to

allow an effective onsite NRC presence during an emergency. The licensee contends-that it is adequate, and plan no changes. The issue will be addressed during an upcoming ERF appraisa J Some significant deficiencies identified in the offsite portion of the exercise will necessitate a remedial exercise. A partial failure of the Alert and Notification System (ANS) occurred when fourteen sirens failed to function due to "co-channel interference" which occurred, blocking the activation signal. The interference occurred because the frequency employed for siren activation is also used by the New York State Department of Transportation, Rockland County Highway Department and the Town of Clarkstown Highway Departmen The licensee has taken administrative steps (broadcasting a message to clear the frequency prior to siren activation) to avoid a repeti-tion, and satisfactorily tested the system on June 28, 1986.

, Although this action was the fastest way to correct the deficiency, more effective solutions are available, but would involve hardware

changes. Several offsite issues have persisted for a number of year Licensee participation with FEMA and the State and four ' Counties in resolving these issues could have been more aggressive, and has shown dramatic improvement recently (although outside the assessment period).

i i I w , - .,. - - - , - . .~a-~e,wy , ------,----,---e,- -> . - . - - - - . - - , , , - - . ~ - ,+ e, ~.-- -,

_ . _ . . I

4 In addition, the licensee failed to make the one hour notification required by 10 CFR 50.72 (Loss of significant alert / notification capability) due to a lack of licensee guidance in defining a

 "significant" loss of capability to the operators. A Notice of Violation was issued covering this and several reporting violations.

' The licensee's onsite emergency response capabilities remain excellent, however more direct involvement in resolving offsite deficiencies would have resulted in more timely resolution of those prcblem . Concl.sien Rating: Category 2 Trend: Improving 3. Board Recommendations Licensee: None

NRC: None '

i

.
   . _ _ . . _ ._____-. - ..

_ _

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

.

. Security and Safeguards (2%, 86 hours) 1. Analysis The previous SALP rating was Category 1. Strengths were identified as: some increase in management attention to the program; improve-ments in the training program; and no violations. Weaknesses in-cluded: maintenance and testing program; security training for contractors; audits; and program managemen Two unannounced physical protection inspections were performed during the assessment period by region-based inspectors. Routine resident inspections continued throughout the assessment perio In December 1985, at the licensee's initiative, members of the licensee's new plant management team met with NRC Region I represen-tatives to discuss weaknesses in the security program that they had recognized and to describe the actions they had taken and planned to take to correct the A routine, unannounced physical security inspection was conducted in January 198 During that inspection several examples of ineffective access controls and vital area barriers were identified. Also during that inspection, the licensee's resolution to several findings of the Regulatory Effectiveness Review (RER) conducted in May 1985 were reviewed and found to be ineffective. These findings indicate the following program weaknesses: security was not properly integrated with other plant groups; there was a lack of program management direction and coordination; and there was a poor understanding of NRC program objectives. Some of these program weaknesses were identified by the licensee in the December 1985 meeting but the licensee's corrective action plan had not yet taken effec As a result of the inspection an enforcement conference was held in February 1986, at which time the licensee's senior management rep-resentative outlined planned corrective actions to effect improve-ments on an expedited basis. Significant among these was the immediate assignment of an individual, on site, as program manage The absence of such an individual to provide oversight and direction to the program had previously been brought to the licensee's attention on several occasions by NRC. Also discussed were the corrective actions that had already been initiated and commitments for an even more comprehensive review of the program to identify other potential problem A followup inspection in June identified that the licensee promptly implemented actions to correct the specific violations identified in the January inspection and those actions were effective. In addition, several program improvements and enhancements had been implemented and others had been initiated as a result of the

~

> licensee's comprehensive program review. Noteworthy among these was an ongoing major revision to the security program plans to improve their comprehensiveness and usability. The revisions are scheduled for submission to the NRC by the end of 198 Licensee management also instituted the following changes to improve coordination, communication and interface among the plant organiza-tional units: key security supervisors have been directed to attend all significant plant meetings and to conduct weekly security super- ' visors' review meetings, in an effort to improve both internal security and interdepartmental communications; the proprietary and contractor security management, supervision and records have been consolidated in a central, onsite location; and, more active involve-ment of corporate security management in site activities was initiated, and a well qualified security specialist from the corporate staff was assigned to conduct periodic announced and unannounced audits of the security progra The licensee submitted a total of 11 event reports, in accordance with 10 CFR 73.71, that pertained to the security program. Four of the events were attributable to the lack of a quality maintenance and surveillance program for security related equipment. Three events involved failure to follow procedures, one by a member of the se-curity force and two by other plant workers. One event resulted from a human error by a member of the security force. The remaining events involved contractors who had not complied with the licensee's personnel screening program requirements and were identified by the licensee's routine and aggressive audit program of this aspect of the security program. The event reports sentrally contained sufficient information to permit adequate NRC assessment. In a few cases, however, telephone contact with the licensee was necessary to de-termine the root cause of the event. The quality of event reports showed notable improvement toward the end of this assessment perio Compensatory actions implemented as a result of the events were found to be prompt and appropriate in all case The licensee's program for identifying and reporting security events is considered adequate but could be strengthened by providing better documentation of the analyses of the root causes of events, which could assist the li-censee in earlier identification of potential problem area As a result of an NRC-identified weakness in the security force training and qualification (T&Q) program, and in an effort to enhance the administration of training, the licensee initiated the develop-ment of comprehensive lesson plans about mid-way during the assess-ment period. The effectiveness of this effort has not yet been assessed by NR This effort, in conjunction with the major revision to the physical security program plans previously addressed, repre-sent a substantial resource expenditure on the part of the licensee and demonstrates a recent initiative by management to implement a high quality progra . - -. ._ -. -. . - . - -

 -    .   .
~

..

i During the assessment period, the licensee submitted one revision to the security force training and qualifications (T&Q) plan. The changes were responsive to NRC comments on a previoas revision and

were found acceptable under 10 CFR 50.54(p). In an effort to improve the quality of the security plan, licensee representatives, on their own initiative, visited the Region I office during this period to discuss the major plan revisio The licensee has provided all functions of the security program with adequate staffing to meet program requirements. The assignment of a program manager should continue to strengthen the management of resources and the effectiveness of the progra In summary, the effectiveness of the security program, in general, and the performance of the security force have improved during the latter portion of this assessment perio The improvement is attributed to implementation of the new commitments by licensee management. However, the full effect of the implemented changes cannot yet be completely assessed, and will be monitored during the next SALP perio . Conclusion: Rating: Category 2 Trend: Improving 3. Board Recommendations Licensee: None NRC: None , J

 ,. - - - - . - . . . , - , y -, , . . - . -. -- -. ---. -,... n . . - . - , - , - - . -, - . _ , - ,

. Outage Activities (15%, 637 Hours) Analysis During the previous assessment period, this area was evaluated as Category 2 on the basis of observing the cycle 6/7 refueling outage completion. Strengths included reorganization of the planning effort and sound startup test procedures. Weaknesses included high man-rem exposure and inaccurate drawing The unit was shut down from January 14 to March 12, 1986 for its sev-enth refuelin Several inspections were performed to examine the preparation for and execution of the outage health physics program. The Environmental Qualification program was reviewed by a team inspection and by the resident inspectors. Startup physics testing, outage and modifica-tion activities, and the licensee's response to Inspection and Enforcement Buller.in 80-11 regarding masonry walls were also inspecte Major preplanned activities during the outage included refueling, steam generator examination, replacement of the turbine generator low pressure rotors, replacement of condenser tube inserts and installa-tion of a new control system for the main boiler feed pumps. In ad-dition, many smaller maintenance and modification activities were complete The refueling, steam generator examination and turbine rotor replacement were performed by Westinghouse. Refueling activi-ties were monitored by Westinghouse QC inspectors with licensee QC inspectors overseeing the activitie Extensive preplanning and man- } agement oversight were provided by the licensee for these major projectr As discussed in the previous SALP, licensee management has aggres-sively pursued improvements in outage management. A projects plan-ning group was created and applied modern planning and scheduling techniques to the outage. Outage coordinators were appointed for major projects and work areas and provided effective oversight, coor-dination, and feedback to uoper management. The institution of the project resource evaluation and management information system (PREMIS) and improved maintenance management had positive effects on communication, planning, and control of outage activities. The re-sults of the extensive preplanning and strong, effective, day-to-day management of outage activities was evident, enabling management to focus their attention during the outage on major activities and unanticipated problem During the previous assessment period, problems with radiological controls during an outage led to an Order Modifying License. During this assessment period, radiological controls were found to be

. significantly improved although some weaknesses were noted (see Section IV.8).

During this outage, the licensee completed the installation of several self-initiated modifications which were to improve plant safety and performance. These included a new control system for the Main Boiler Feedwater System, a new dryer system for the Instrument Air System, and replacement of the cooling coils in two Containment Fan Cooler Unit There are, however, examples of inadequate and untimely resolutions to technical issue In July 1984, Indian Point Unit 3 tripped due to an electrical fault caused by salt spray from the main condenser lifting jet exhaust. As a result, the lifting jet exhaust was planned to be rerouted at Unit 2 but this modification was not implemented before Unit 2 tripped on September 20, 1985 due to a transformer short from salt buildup from the lifting jet exhaus Increased management attention is needed to improve the timeliness of the resolution of technical issue A lack of effective primary containment closeout was observed during several inspections. Problems, including missing seismic supports and poor housekeeping, that should have been identified by the licensee prior to closeout have already been described in Sections IV. A. and IV. C. of this repor The Cycle 8 startup physics tests were performed in accordance with approved test procedures by highly qualified personnel. The Reactor Engineering staff is small, but highly qualified with reactor engi-neering activities always performed in a highly professional manner and well documented. The licensee's performance of startup physics testine during the approach to criticality and subsequent zero power physics tests and power ascension tests was deliberate and carefully controlled. At each power level, all test results were analyzed and thoroughly understood prior to raising power to the next leve QA/QC involvement in startup physics testing was consistently visi-ble. During the startup period, a QA auditor was present to witness zero power physics testing and, at the conclusion of the testing, a thorough and comprehensive audit was performed by the same QA audi-to These examples are indicative of the involvement of management in assuring quality programs are adequately performe Inspections were conducted of the licensee's Environmental Qualifi-cation (EQ) program. Some problems were identified with activities relating to the assurance of quality of the EQ program and these are described in Section IV. J. Overall staffing was adequate to properly administer the progra Licensee response to the major inspection issue (potentially unquali-fied Lewis Cable) was prompt and effective. The response included an evaluation of potential failure modes, a temporary operating in-struction, a justification for continued operations, the replacement

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

of Lewis cable in the Hydrogen Recombiner thermocouple circuit prior to startup from the refueling outage, and performance of testing on the removed cabl Management responsible for EQ maintained a file of related NRC initiatives including records of licensee actions and final resolu-tion Licensee response to the most recent NRC initiatives relating to issues of particular concern, such as the Limitorque wiring defi-ciencies identified in Information Notice 86-03, were prompt and gen-a erally thorough. The field execution of some of these corrective actions was inadequate in some cases such as poorly sealed conduit and unqualified splices. The licensee identified several deficien-

'
.

cies in the implementation of the EQ program including unqualified terminal blocks. Corrective actions were prompt and effective and included extensive direct involvement by top management in investigating the root cause of the deficiencie Licensee responsiveness to NRC initiatives was also evidenced by Con Edison's response to IE Bulletin 80-11. The response was adequate, in that appropriate action was taken in a timely manner to assure that those masonry walls in close proximity to or attached to safety-related piping or equipment were independently identified and evaluated for modificatio The licensee's initiatives to establish a program to repair cracked

, mortar joints and evaluate the cause, adequacy of repair, and need

- for a surveillance program is another example of the licensee's re-sponsiveness to NRC concern In summary, improvements in outage management were evident and resulted in effective outage contro Startup testing continues to be performed well. The licensee's implementation of Environmental

Qualification requirements and response to masonry wall issues were effective.

i ~ 2. Conclusion Rating: Category 1 Trend: No basis for trend assessment 3. Board Recommendations Licensee: Assess effectiveness of prioritization of proposed design changes and modification NRC: None f ,

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

. Training and Qualification Effectiveness (N/A) 1. Analysis During this assessment period, training and qualification effective-ness is being considered as a separate functional area for the first time. Training and qualification effectiveness continues to be an evaluation criterion for each functional are The various aspects of this functional area have been considered and discussed as an integral part of other functional areas and the re-spective inspection hours have been included in each one. Conse-quently, this discussion is a synopsis of the assessments related to training conducted in other area Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy. The dis-cussion below addresses three principal areas: licensed operator training, nonlicensed staff training, and status of INPO training accreditatio During the assessment period, inspections routinely reviewed training effectivenss. A programmatic nonlicensed training inspection was conducted and radiological training effectiveness was examined during the health physics appraisal. The plant radiological training program was found to be effective; however, NRC identified weaknesses in contractor HP technician training for which the licensee took appropriate action. Non-licensed technician training has resulted in some improvements, especially in the identification of equipment deficiencies; in the conduct of surveillance activities; and in the effective response by the fire brigad The performance of nonlicensed staff, indicates that the training and qualification program contributes to an adequate understanding of their work and adherence to procedures. The one instance of per-sonnel error related to surveillance activities which resulted in a reactor trip is considered an isolated cas The licensee is proceeding on schedule with INPO accreditation of training programs. To effectively manage the activities for seeking full INP0 accreditation the licensee has newly established and staffed the position of Project Manager - INPO Accreditation. All Operations Training programs have been evaluated by INP0. All other training programs have been submitted for INPO evaluation except for the Management and Technical Staff program which was submitted September 1, 1986. The licensee training staff has been increased to develop and teach these new program _ = -

In addition, the licensee has remodeled the simulator building to provide a training library, four classrooms and additional office An upgrade of the licensee's non-licensed training center has been budgete Training in the use of Emergency Operating Procedures (EOPs) appears to be effective as evidenced by their use following unit trips. The licensee provided six weeks of classroom and simulator training on E0Ps before they were implemented. Operators have accepted the E0Ps and have performed well while using them in licensing exam Two areas in wnich trair.ing effectiveness appears weak are in security and operations. The NRC identified a weakness in the sccurity force training and qualification program. The effectiveness of the licensee's improvements has not yet been determined. In addition, some enhancements are not yet in effect due to an outstanding plan revisio Several inadequacies exist in the plant simulator which is considered marginally acceptable for examinations. In the past, the licensee has not been aggressive in updating the simulator. Although, the licensee recently decided to upgrade the simulator, management attention is warranted to assure that the upgrade is properly and expeditiously completed or the upgrades may take several years to complet ' Operator licensing candidates have been well prepared as evidenced by all six license candidates passing their exams and being issued licenses. However, three plant trips occurred which may be attri-i buted to licensed operator training. Two trips occurred when gen-erator load was increased too quickly resulting in a high level Steam Generator trip. One trip occurred on plant startup when the operator failed to block the low setpoint high flux trip signal quickly enough. These events occurred during normal evolutions. Insuffi-cient training dedicated to normal evolutions and inaccurate simula-tion of these evolutions may have contributed to these event In summary, shortcomings exist in the plant simulator. E0P training was effective and operator training in general is a strength although isolated examples of ineffective operator action were identifie The INPO accreditation program is on schedule. Non-licensed training is adequat . Conclusion . Rating: Category 2 Trend: Consistent

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,
.

. Board Recommendations Licensee: None NRC: None i

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.

. J. Assurance of Quality (N/A) 1. Analysis Management involvement and control in assuring quality continues to be an evaluation criterion for each functional area. During this assessment period, assurance of quality is being considered as a sep-arate functional area. The various aspects of the programs to assure quality have been considered and discussed as an integral part of each functional area and the respective inspection hours are included in each one. Consequently, this discussion is a synopsis of the assessments relating to ar,surance of the quality of work conducted in all area The enhancement of design change / modification procedures to step-by-step detailed instructions; a " traveler" type work control method; and the allocation of human resources for effective work planning indicates an increased involvement by senior management in assuring efficient plant operations and better control over the work proces The day-to-day involvement of QA and QC in the overview of ongoing activities has been expanded and is under improved administrative control. Completed work packages demonstrated that the QA and QC functions were being properly implemented. For example the licensee's QA/QC during masonry wall repairs in response to IE Bulletin 80-11 was thorough. Hold points were established for review and verification of work by Con Edison's Site Power Generating QA engineers and for witnessing and verification of specific tests by QC. The overall acceptability of the wall modification work was au-dited by Con Edison's corporate quality assurance and reliability organization. This involvement is not as evident in the areas of operations and surveillance activitie Assurance of quality is achieved by the craft worker's supervisors through the supervisor periodically checking the work site and verifying worker compliance with the procedure. The supervisors, QA, and QC also review completed work packages for procedure complianc If, in the opinion of QA or the maintenance department, an indepen-dent inspection is required to satisfy requirements, QC will perform the independent inspection and these inspections are documented in the work procedure. This approach appears to be effectiv Surveillance test procedure results are reviewed by the operations department for acceptability requirements and then finally reviewed by the test engineering department. The test procedures themselves are reviewed by the test engineering department and the Station Nuclear Safety Committee (SNSC) for safety considerations, ease of _ . . _ _ _ __ _ _ . . __ ___ . . _ . _ _ . _ _ . . _ _ . .__ . . performance, and meeting Technical Spe~cification requirements. The performance of tests is monitored as necessary by the test engineers to verify compliance with the written test procedure QA is responsible for the proper performance of material receipt inspection. Written instructions are used by receipt inspectors to check the materials for damage, conformity to procurement documents and the level of quality of the vendor's material prior to the inspector accepting the materia The licensee has revised and updated QA and corporate engineering procedures to include Environmental Qualification (EQ) program implementation. However, only one QA audit of the EQ program was conducte The QC outage surveillance program, which has provisions to increase surveillance frequencies in areas of high unsatisfactory performance and to decrease surveillance frequencies for areas with acceptable performance, was effectively implemented during this appraisal period. The NRC found during a review of this program that the licensee effectively prioritized their work load so that areas (or work items) demonstrating poor performance, received a greater amount of surveillanc There was no apparent QC involvement in initial field work done to implement the EQ program except for modifications involving the replacement of non-EQ equipment. Deficiencies in the application of sealants were identified by NRC EQ inspections and resulted in a large effort to reinspect and reapply seals. Also in the QC area, weak-nesses in performing close out inspections of the Containment Building and other areas after outages were apparent. One additional concern was identified dJe to inadequately establishing and executing the QC program for radwaste. The licensee's corrective actions were res-ponsive to this concer The quality of the SNSC review of events, procedures and other items continues to be good although in one instance, the plant trip on June 9, the committee did not identify a root cause for the trip and focused their review almost exclusively on a safety injection actu-ation which followed the trip. On August 1, 1986, the SNSC chairman and General Manager of Technical Support transferred within the company. The SNSC chairman had a major impact on improving the quality of the SNSC reviews. The Nuclear Engineering group at cor-porate headquarters has now been consolidated at the site with the Technical Support Department as of August 1. The Chief, Nuclear Engineering, is now General Manager of Technical Support and the new SNSC chairma __

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

.

. The Nuclear Facilities Safety Committee (NFSC) reviews of licensee activities have been thorough. NFSC discussions of operational events and equipment failures have focused on evaluating their safety significance, root causes, and corrective actions. The use of sub-committees contributed to the thoroughness of these evaluation In summary, the attention of management appears to be focused on quality. Quality programs are generally effective although their involvement in operations and surveillance is not as evident as in other area . Conclusion Rating: Category 2 Trend: Consistent 3. Board Recommendations Licensee: None NRC: None

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s Licensing Activities (NA) Analysis During the SALP evaluation period, the licensee has shown good man-agement overview in the area of licensing activities. This was evi-dent through the timely submittal and subsequent approval of several license amendments aimed at improving the cycle 7/8 refueling outage which occurred during the rating period. The licensee's management demonstrated active participation in licensing activities and kept abreast of current and anticipated licensing actions. All open li-censing actions are scheduled and tracked through use of the licensee's Regulatory Action Tracking System. During the rating pe-riod, a system for identifying both licensee and NRC priority items was initiate The licensee's submittals are most often timely. However, in many instances, additional information or revisions are necessary before review can be completed. This occurs most often in the area of plant-specific licensing action The licensee's treatment of the no significant hazards standards of 10 CFR 50.92 has shown some im . provement, however, further improvement in this area is neeoed. The licensee tends to provide too little detail in most discussion There were several instances during the period when submittals were made following their scheduled submittal date. These submittals were, in all instances, required because of NRC requests for infor-mation. In most instances, the original schedules were set by the licensee after receipt of the information request, and, in most cases, the licensee informed the staff that the submittals would be lat The schedular delays are usually limited to one or two weeks and seem to be more a management problem that a respoasiveness problem. The fact that schedule dates were not arbitrarily imposed by the staff, but instead agreed upon or set by the licensee, and that the licensee appears to be more responsive to those items for which it has placed a high priority rather than those for which the NRC had indicated a high priority demonstrates need for more

' management attention to ensure prompt resolution of safety issues. A naw policy has been initiated whereby both the licensee and the NRC will agree on prioritization of certain licensing action This

should belp alleviate some of the past problems in this are The licensee maintains a significant technical capability in almost all engineering and scientific disciplines necessary to resolve items

, of concern to the NRC and the license In addition, the licensee , utilizes the services of other nuclear support groups to assist in the resolution of technical problems or to utilize new and proven

techniques that will enhance the operation and safety of the Plan .

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The licensee's extensive and improving technical capability is re-flected in the submittals made in support of, or in response to, licensee or NRC initiated actions. Although, as discussed above, the licensee is not always forthcoming with all of the information neces-sary to complete a review without requests for additional informa-tion, few licensee responses to NRC requests for additional information require subsequent question It should be noted that during the assessment period the licensee was requested to provide a detailed submittal concerning the alternate shutdown capabil f ty of Indian Point 2 in the remote chance of loss of certain capabilities due to high winds at the site. The information was requested w1e. a fairly short turnaround time. The licensee provided a timely and thorough submitta The licensee's licensing activities are conducted by a well staffed and well trained group resulting in an overall efficient operatio Management overview is evident in that the licensing group is well integrated into other plant activities and licensing activities re-flect a uniform approach. Upper management becomes involved in li-censing actions when necessary to assist in resolving potential deadlock The licensing group has exhibited a high degree of cooperation with the NRC staff. The good communication between the licensing group and the NRC has been beneficial to both in the processing of licens-ing actions. Areas of expertise are well defined within the grou In addition the group does an excellent job of coordinating the ef-fort when input is required from the different groups within Consoli-dated Edison. However, the group could be more effective if management would emphasize to all Consolidated Edison supporting organizations the need for meeting committed licensing schedules for responding to the NRC. The licensing group holds informal training sessions on topics of current and future interes The group also participates in corporate-wide training programs and participates in industry-wide training programs provided by various organizations.

, In summary, the licensee's greatest strengths appear to be in its extensive technical capability that is reflected in its submittals and discussions with the NRC, and, in the continued upgrading of the experience, capability and effectiveness of the licensing group and the supporting administrative and technical personnel required to operate a good facility. More detail in submittals would require fewer iterations during the review process, and, closer attention to submittal schedules would avoid short term schedular slippage .

. 2. Conclusion: Rating: Category 2 Trend: Improving 3. Board Recommendations Licensee: None NRC: None

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*

V. SUPPORTING DATA AND SUMMARIES Investigation and Allegation Review No investigations were conducted during the assessment perio Four allegations were received during the assessment period:

improper ALARA performance;

individual disciplined for refusing to work in the containment building;

security guards discouraged from talking with NRC inspectors; .

radioactive spill released to river, inadequate radiation pro- ' tection for workers during spill cleanu All four allegations were inspected and closed out with no violations identifie Escalated Enforcement Actions No civil penalties, or confirmatory action letters were issue No orders were issued for enforcement action. One enforcement confer-ence was held on February 13, 1986 for security violation Management Conferences

* October 25, 1985: SALP management meeting;
*

December 17, 1985: 1986 refueling outage preparations and plans, review of maintenance related LERs for the previous SALP period, and analysis and corrective actions for reactor trip Licensee Event Reports (LERs) Causal Analysis : Thirty-five LERs, numbered 85-07 thru 86-24, were reviewed for this assessment period. These LERs are characterized in Table 1 by cause for each functional area. The following causally-linked event sets were identified: LER N Cause 85-10 These events are reactor trips due to personnel 85-12 erro These events are instances of instrument setpoint 86-09 dri f c-y-- -i---.i-.v- e - .y--- ,.. ,. ,.- ,.,...- ,--. ,, ,.-- ----v - y- - v

   --
   . . . . - . __ - .   . - .
*

2. AE00 Review The Office for Analysis and Evaluation of Operational Data (AE00) assessed a tFird of the LERs submitted during the assessment period using a refinement of the basic methodology presented in a report entitled "An Evaluation of Selected Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (DRAFT)," NUREG/CR-4178, March 1985. The results of this eval-uation were forwarded to the licensee on October 3, 1986, and indicate that Indian Point 2 LER's are above averag The principal weaknesses identified in the LERs, in terms of

safety significance, involve the requirement to provide identi-fication of failed components. The failure to adequately iden-tify the manufacturer and model number of the components that fail prompts concern that others in the industry won't have im-i mediate access to information involving possible generic problem Strong points for the Indian Point 2 LERs are the discussions of the mode, mechanism, and effect of failed components, and the discussion of personnel errors.

i ,

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

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TABLE 1

. TABULAR LISTING OF LERs BY FUNCTIONAL AREA INDIAN POINT STATION - UNIT 2 Area    Number /Cause Code  Total A B C D E X Plant Operations  7  1   8 Radiological Controls      0 and Chemistry Maintenance   2  1   3 Surveillance   2    2
 ~E~ . Fire Protection      0
' Emergency Preparedness      0 Security and Safeguards      0 Outage Activities      0 i Training and Qualification     0 Effectiveness i

! Assurance of Quality 1 1 f Licensing Activities 0 l l Other 2 1 1 15 2 21 TOT'iS 11 3 1 3 15 2 35 ! Cause Lcdes: A - Personnel Error B Design, Manufacturing, Construction, or Installation Error < C - External Cause D - L'efective Procedure

E - C)mponent Failure X - Other

' l

I

+ c --ge-' m - - - - -e- - -_--;--- n -w - *--**,w- --c y-

    -. _
..

f' TABLE 2 INSPECTION HOURS SUMMARY (8/1/85 - 7/31/86) UJDIAN POINT STATION - UNIT 2 Area Hours % of Time f Plant Operations ........................... 981 23 Radiological Controls and Chemistry......... 903 21 Maintenance ................................ 550 13 Surveillance ............................... 585 14 Fire Protection............................. 234 6 Emergency Preparedness ..................... 265 6 Security and Safeguards ................... 86 2 Outage Activities .......................... 637 15 Training and Qualification Effectiveness ** . N/A -- Assurance of Quality ** ..................... N/A -- Licensing Activities * ...................... N/A -- l TOTAL 4241 100%

* Hours expended are not included with direct inspection effort statistic ** Hours expended in training and assurance of quality are included in other i functional area P d
 , ,-. _ -- _y_.-_,_,._,, _

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TABLE 3 ENFORCEMENT SUMMARY (8/1/85 - 7/31/86)* INDIAN POINT STATION - UNIT 2 Severity Levels

AREA I II III IV V TOTALS Plant Operations 1 3 4 , Radiological Controls and Chemistry 2 2 Maintenance 2 2 Surveillance O Fire Protection 1 1 Emergency Preparedness 0 . Security and Safeguards 1 1 2 Outage Activities 0 Training and Qualification Effectiveness 0 Assurance of Quality 1 1 Licensing Activities 0 TOTAL 0 0 1 7 4 12

 *0oes not include Inspection Report 86-11
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. TABLE 3 (CONT'D) Inspection Severity Functional Report /Date Level Area Violation 86-01 IV Quality Inadequately established 1/6-10/86 Assurance and executed QC program to assure compliance with 10 CFR 61.55 and 10 CFR 61.5 III Security & Three instances of 1/13-17/86 Safeguards failure to control access to vital area V

Failure to perform an adequate search of contractor's vehicle entering protected are IV Radiological Failure to post high 2/24/86 Controls radiation boundarie IV " Failure to follow procedures for use of protective clothing, posting contaminated areas, and writing event report V Operations / Failure to submit Annual 4/1-30/86 Radiological Radiation Exposure Controls Report on time, failure to make telephone notificatio IV Maintenance / Unit brought out of cold 6/10-7/7/86 Outage shutdown with seismic restraint disconnecte IV Operations Failure to properly 7/2-8/1/86 establish and maintain Emergency Operating Procedures and Abnormal Operating Procedure _ -- -

TABLE 3 (CONT'D) Inspection Severity Functional Report /Date Level Area Violation 86-19 IV Maintenance / Recirculation sump 7/2-8/1/86 Outage grating not properly reinstalle IV Housekeeping Failure to follow house-keeping procedure V Operations Failure to notify the 7/8-31/86 NRC in accordance with 10 CFR 50.72 on three separate occasion V

Failure to perform required operability checks on a Control Rod Drive and Plant Vent Noble Gas Activity Monitor.

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TABLE 4 INSPECTION REPORT ACTIVITIES (8/1/85 - 7/31/86) INDIAN POINT STATION - UNIT 2 Report / Dates Inspector Hours Areas Inspected 85-21 Resident 51 Routine, daily inspections 8/1-31/85 and unscheduled backshift inspection Specialist 108 Special, announced safety 9/17-20/85 inspection of masonry wall design (Bulletin 80-11).

85-23 Resident 131 Routine, daily inspections 9/1-30/85 and unscheduled backshift inspection Specialist 201 Routine, announced safety 9/16-20/85 inspection of 10 CFR 50, Appendix Resident 208 Routine, daily inspections 10/1-31/85 and unscheduled backshift inspection ' 85-26 Resident 120 Routine, daily inspections 11/1-30/85 and unscheduled backshift inspections.

[ ' 85-27 Specialist 65 Special, unannounced 11/12-15/85 dosimetry inspection.

j 85-28 Specialist Licensed operator exam /10-13/85 85-29 Specialist 41 Routine, unannounced 12/2-6/85 inspection of design changes / j modifications and QA progra Resident 217 Routine, daily inspections 12/1/85-1/15/86 and unscheduled backshift inspections.

l 85-31 Specialist 46 Special inspection of 12/16-18/85 licensee's implementation of radiological controls j improvement progra . _ _ _ _ - - ~ . . - _ ._

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TABLE 4 (CONT'D) Report / Dates Inspector Hours Areas Inspected 86-01 Specialist 37 Routine, unannounced 1/6-10/86 inspection of transportation activitie Specialist 43 Routine unannounced 1/13-17/86 safeguards inspectio Cancelled 86-04 Specialist 141 Routine, unannounced 1/21-24/86 inspection of radiation , protection progra Resident 230 Routine, daily inspections 1/16-3/3/86 and unscheduled backshift inspection Specialist 132 Special, unannounced 2/10-14/86 inspection of maintenance, modifications, and outage control Specialist 30 Routine, announced inspection 2/10-13/86 of the nonradiological chemistry progra Specialist 128 Special, unannounced 2/24-28/86 inspection of radiological controls program.

i 86-09 Resident 184 Routine, daily inspections 3/4-31/86 and unscheduled backshift inspection Resident 148 Routine, daily inspections 4/1-30/86 unscheduled backshift inspection Specialist 142 Special, announced inspection 5/12-16/86 of environmental qualificatio Resident 280 Routine, daily inspections 5/1-6/9/86 and unscheduled backshift i inspection '

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TABLE 4 (CONT'D) Report / Dates Inspector Hours Areas Inspected 86-13 Specialist 242 Routine, announced emergency 6/2-5/86 preparedness inspection and observation of emergency exercis Specialist 50 Routine, unannounced 6/2-6/86 inspection of non-licensed staff trainin Resident 145 Routine, daily inspections 6/10-7/7/86 and unscheduled backshift inspection Specialist 25 Routine, unannounced 6/2-5/86 safeguards inspectio Specialist 241 Special, announced health 6/16-20/86 physics appraisal.

' 86-18 Specialist 42 Special, unannounced 6/16-20/86 inspection of sewage . l contamination.

l 86-19 Specialist 586 Special, announced l 7/21-8/1/86 probabilistic risk assessment based inspection.

l l 86-20 Specialist 40 Special, announced inspection 7/10-17/86 of post-accident sampling i and monitorin Specialist 30 Routine, unannounced radio-7/15-18/86 active effluents inspectio Specialist 35 Routine, unannounced 7/14-18/86 inspection of startup physics progra Resident 122 Routine, daily inspections 7/8- /86 and unscheduled backshift inspection hours

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TABLE 5 LISTING OF ALL AUTOMATIC TRIPS AND UNPLANNED SHUTDOWNS INDIAN POINT STATION - UNIT 2 Power N Date Level Description Cause (Note 1) 1 9/20/85 95% Reactor trip on turbine Modification generator trip. Turbine control. Untimely generator tripped due to correction of short on #21 main trans- design erro former. Brackish water drifting from lifting jet exhaust caused shor (LER 85-09) 9/23/85 Startup 2 9/23/85 12% Reactor trip on turbine tri Personnel error - Turbine tripped on high steam operations. Oper-generator leve Steam gener- ator failed to an-ator swell while picking up ticipate swel load after bus synchronization Simulator modeling caused high level. (LER 85-10) and training con-tributed to high rate of load pick-u /24/85 Startup 3 9/27/85 77% Tech. Spec. required shutdown Natural even due to hurricane Gloria.

i= 9/27/85 Startup 4 9/28/85 25% Reactor tripped on power range Personnel error - high flux-low level trip signa operations. Oper-The high flux level occurred ator failed to during power ascent. (LER 85-12) block trip signal as required by procedure due to high rate of load picku /28/85 Startup Note 1 - Determined by SALP Board, may not agree with LER Analysis __ .. _ __ _ _

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I l

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l TABLE 5 (CONT'D) Power No. Date Level Description Cause (Note 1) 5 10/24/85 13% Reactor trip on turbine tri Personnel error - Turbine tripped on high steam operations. Oper-generator level. Steam gener- ator failed to an-ator swell while picking up ticipate swel load after bus synchronization Simulator modeling caused high level. (LER 85-14) and training con-tributed to high rate of load pick-u /24/85 Startup 6 12/12/85 100% Reactor tripped on loss of flow Equipment failure signals from coolant loop #2 maintenanc The loss of flow signal was due A failed capacitor to-a bistable tripping in one caused a bistable channel and a separate flow to tri channel being previously placed in the tripped position due to a faulty flow transmitte (LER 85-16) 12/13/85 Startup 7 12/31/85 100% Reactor tripped on low pressur- Equipment failure - izer pressure when a pressurizer under review spray valve failed open. (LER A spray valve 85-17) pneumatic operator mal functione /1/86 Startup 8 1/13/86 94% Reactor tripped on low low Equipment failure - steam generator level. The mair.tenanc low level resulted frem low High pressure oil feedwater flow due to e + rip hose failed in of #21 Main Boiler Feec smp MBFP control (MBFP). (LER 86-01) 3/12/86 Startup (Reactor critical - zero power).

9 5/23/86 SD Subcritical trip of shutdown Personnel error - banks when reactor trip breaker Surveillance. Tech- ! was inadvertently opened during nician tripped the j a test. (LER 86-16) wrong breake /25/86 Startup __ _ _ _ _ . _ _ _ _ _ . - _

s

. TABLE 5 (CONT'D) 10 5/28/86 30% Reactor tripped on Safety Equipment failure - Injection: high steam flow / low maintenance Faulty Tavg signal. The high steam steam dump control-flow was caused by the steam le dumps opening. (LER 86-17) 5/30/86 Startup 11 5/31/86 0% Unplanned shutdown due to short Personnel error - in exciter, maintenanc Error in re-assembly by contracto /7/86 Startup 12 6/9/86 56% Manual rea: tor trip due to Equipment control - loss of M3FP. MBFP #21 operations and tripped while starting M8FP maintenance. High

  #2 (LER 86-19)  bearing oil trip setpoint; open oil bypass valv /11/86  Startup 13 6/25/86 43% Reactor trip on turbine tri Personnel error -

The turbine tripped due to design contro actuation of the independent Drawing was not electrical overspeed protection updated following system while a technician was plant constructio replacing relays in that syste (LER 86-21) 6/26/86 Startup 14 7/18/86 100% Reactor tripped when control rod Personnel error - motor generator set was tripped operations. Oper-while starting second motor ator failed to generator se (LER 86-24) properly synchro-nize motor generator /20/86 Startup

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s e TABLE 6 NRR SUPPORTING DATA AND SUMMARY INDIAN POINT STATION - UNIT 2 1. NRR/ Licensee Meetings Fuel Removal Time Constraints T.S. Application 7/9/85 IST 11/13-14/85 OCRDR 12/4/85 Organization 7/25/86 2. NRR Site Visits / Meetings Fire Protection Audit 9/16-20/85 PM/ Resident 11/18-21/85 Refueling Activities 12/17/85 EQ Audits 5/15-16/86 3. Commission Meetings None

4. Schedular Extension Granted None ,

5. Reliefs Granted ASME Section XI Relief 3/17/86 I 6. Exemptions Granted ! Appendix R 11/13/85 7. License Amendments Issued Amendment Numbers Title Date l i 97 Limiting Overtime, Audit Frequency 9/30/85 For EP Program and Safeguards Contingency Plan, Quality Assurance Record Retention Requirements 98 Fuel Removal Time Constraints 9/30/85 l

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. TABLE 6 (CONT'D) Amendment Numbers Title Date 99 Surveillance Interval Limit Extension 9/30/85 100 Initial Reactor Core Design 10/17/85 101 Decay Heat Removal, Number of Operating 10/23/85 Reactor Coolant Pumps, Over Pressure Protection 102 Generic Letter 83-36, 83-37 Tech. Specs. 11/13/85 103 Temporary Closure Plate 11/13/85 104 BIT Removal 12/05/85 105 Boric Acid Addition Capabilities 12/05/85 106 Organizational Changes 12/31/85 107 Anticipatory Reactor Trip on Turbine 1/13/86 Trip 108 CTMT Cooling, Iodine Removal, CTMT 1/27/86 Isolation 109 Total Nuclear Peaking Factor Limits 1/29/86 110 Part Power Multiplier 3/31/86 111 Increased Enrichment 4/21/86 112 Hydraulic Snubbers 5/19/86 113 Code Safety Valves 6/11/86 114 RV and SV Failures and Challenges, 7/22/86 Monthly Operating Report 8. Emergency Technical Specifications Issued: Amendment Numbers Title Date 113 Code Safety Valves 6/11/85 9. Orders Issued Revision of Supplement 1 to NUREG-0737 6/19/86

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FIGURE 1

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NUMBER OF DAYS SHUT DOWN INDIAN POINT STATION UNII 2

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August, 85 No Days Shut down September, 85 J5 Days Shut down October, 85 1 3 Days Shut down November, 85 No Days Shut down December, 85 [] 1 Day Shut down January, 86 19 Days Shut dowN Seventh Refueling Outage February, 86' 28 Days Shut down 1 March, 86 31 Days Shut down 1 April, 86 30 Days Shut down 1

May, 86 27 Days Shut down l

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June, 86 I 10 Days Shut down July, 86 [[] 2 Days Shut down }}

v t e Inspection Report - Indian Point - 1985098
80 \| 81 \| 82 \| 83 \| 84 \| 85 \| 86 \| 87 \| 88 \| 89 \| 90 \| 91 \| 92 \| 93 \| 94 \| 95 \| 96 \| 97 \| 98 \| 99 00 \| 01 \| 02 \| 03 \| 04 \| 05 \| 06 \| 07 \| 08 \| 09 \| 10 \| 11 \| 12 \| 13 \| 14 \| 15 \| 16 \| 17 \| 18 \| 19 \| 20 \| 21 \| 22 \| 23 \| 24 \|
1985 Quarterly Integrated 1Q (0) 2Q (0) 3Q (0) 4Q (0) Assessments Mid Cycle End of Cycle 14(0) 16(0) 28(0) 98(0) 99(0) Security Operator Exams Emergency Planning Other

IR 05000247/1985098

Text

REGION I

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