IR 05000266/1990001
| ML20058D793 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 10/30/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20058D786 | List: |
| References | |
| 50-266-90-01, 50-266-90-1, 50-301-90-01, 50-301-90-1, NUDOCS 9011060274 | |
| Download: ML20058D793 (31) | |
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SALP 8 o.
. INITIAL SALP REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III
o SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE I
Inspection Report Nos. 266/90001; 301/90001 Wisconsin Electric Power Company
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Point Beach Nuclear Plant-
- April 1,1989 through-August 31, 1990
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9011060274 901030
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PDR ADOCK 05000266 P
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TABLE OF CONTENTS Page No.
LI ST ' 0 F I NI T I AL I SMS.........................,.................
ii I.
INTRODUCTION............................................
I I
. S UMMARY O F R E S U LT S......................................
A.
Overview..........................................
B.
Other Areas of Interest...........................
III.' CRITERIA...............................................
IV.
PERFORMANCE ANALYSIS...................................
A.
Plant-Operations..................................
B; Radiological. Controls.............................
C.
Maintenance / Surveillance...........................
D.
- Emergency: Preparedness.............................
E.
Security..........................................
- F.
Engineering / Technical Support.....................
G.
. Safety! Assessment / Quality Verification............
V.
' SUPPORTING DATA AND SUMMARIES..........................
A.
Licensee-Activities...............................
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B.
- I n specti on Acti v i ti e s.............................
C; Escalated Enforcement Actions.....................
27-D..
Conf.i rmatory Action Letters (CAls)................
'E.
Review of Licensee Event Reports...................
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TABLE OF CONTENTS Page No.
LIST OF-INITIALISMS..........................................
I,
' INTRODUCTION............................................
II.
S UMMARY O F R E S U LT S.....................................
A.
Overview..........................................
B.
O the r - Are a s o f I n te re s t...........................
III. CRITERIA...............................................
IV.
PERFORMANCE ANALYSIS...................................
A.
Plant Operations..................................
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B.
Radiological Controls.............................
C.
Maintenance / Surveillance..........................
D.
Emergency Preparedness............................
E.
Security..........................................
F.
Engineering / Technical' Support.....................
G.
Safety Assessment / Quality Verification............
V.
SUPPORTING DATA AND SUMMARIES..........................
A.
Licensee Activities...............................
B.
Inspection Activities.............................
C.
Escalated Enforcement Actions.....................
27-D.
Confirmatory Action Letters (CALs)................
E.
Review of Licensee Event Reports...................
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INITIALISMS AFW auxiliary feedwater
'ALARA as-low-as-reasonably-acheivable ANSI American National Standards Institute ATWS anticipated transient without scram CAL Confirmatory Action Letter CFR Code of Federal Regulations CHAMPS Computerized History and Maintenance Planning.ystem DC direct current DRP'
Division of Reactor Projects DRS Division of Reactor Safety
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DRSS Division of P.adiation Safety and Satequards EDG emergency diesel generator EDSFI ElecM ical Distribution System Functiona; Inspection E0P coergency operating procedura ESF engineered safety feature FSAR Final Safety Analysis Report HP health physics HRA high radiation area I&C instrumentation and control KV kilovolt LER licensee event report
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NRC Nuclear Regulatory Commission NRR Office of Nuclear Reactor Regulation-
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OSC Operations Support Center PWR pressurized water reactor QA quality assurance-QA/QC quality assurance / quality control RCS reactor coolant system REMP Radiological Environmental Monitoring Program e
SALP Systematic Assessment of Licensee Performance SSFI Safety System Functional Inspection TLD thermolun.inescent dosimeter-
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TMI Three Mile Island'
TS Technical Specifications VA vital area
~VDC volts-direct current
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INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this-information. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of the facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on October 10, 1990, to review the observations and data on performance, i
and to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
The guidance and evaluation criteria are summarized in Section III of this report.
The Board's findings and recommendations were forwarded i
to the NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance at the Point Beach Nuclear Plant for the period April 1,1989, through August 31,-1990.
The-SALP Board for the Point Beach Nuclear Plant was composed of the f, '
following individuals:
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Board Chairman C.~E. Norelius, Director, Division of Radiation Safety and
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Safeguards (DRSS)
u Board Members H. J.. Miller, Director, Division of Reactor Safety (DRS)
W. L. Forney, Deputy Director, Civision of Reactor Projects (DRP)
J. N. Hannon, Project Directorate III-3 Director, Nuclear Reactor
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Regulation (NRR)
I. N. Jackiw, Chief, Reactor Projects Section 3A, DRP C. L. Vanderniet, Senior Resident Inspector, Point Beach, DRP R. B. Samworth, Project Manager, NRR
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Other Attendees at the SALP Board Meeting L.
R~. Greger, Chief,-Reactor Programs Branch, DRSS W. G. Snell, Chief, Radiological Controls.and Emergency Prepardness, DRSS.
J. R. Creed, Chief, Physical Security Section, DRSS
J. Gadzala, Resident Inspector, Point Beach, DRP
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C. F. Gill, Senior Reactor Programs Specialist, DRSS
A. W. Markley, Radiation Specialist, DRSS L
J. L. Belanger, Physical Security Inspector, DRSS D. S. Butler, Reactor Inspector, DRS
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11. SUMMARY OF RESULTS A.
Overview This assessment period was from April 1,1989, through August 31, 1990. The licensee improved to a Category 1 performer in the Operations area partially as the result of knowledgeable and experienced operators who kept abreast of plant conditions.
Further contributors were the " black board" condition maintained on the annunciator panels, the quiet and professional atmosphere in the control room and an improvement in the use and control of procedures and procedural changes.
The performance in Radiological Controls
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area declined during this assessment period to a Category 2.
The i
licensee experienced repetitive failures of high radiation barriers, which also indicated a weakness in the health physics training program. A further training weakness was discovered during the evaluation of a potential personnel overexposure during retrieval of a loose fuel fragment.
The Maintenance / Surveillance area continued to be a licensee strength.
The licensee has maintained high standards in the quality of work performed by technicians which is reflected in the operational performance of the facility. One
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concern identified during this rating period, however, is the apparent lack of attention to detail by instrumentation & control technicians evidenced by are increase in the number of reportable events.
The licensee performance in the Emergency Preparedness area improved
. slightly during this period.
Improvements were identified in the conduct of the annual exercise, drills, and drill critiques.
However, some weaknesses and concerns continued to exist regarding the organization and layout of the 0perations Support Center.
Performance in the Security area remained the same for this assessment period.
Problems with vital area barriers were experienced again this period but improvements were noted in management involvement, resolution of technical issues, and security training.
The Engineering / Technical Support area continued to show adequate performance, however, several concerns were identified.
The principal concerns were sic,, ness in
resolving identified deficiencies and staffing levels.
The engineering staff did show a significant improvement in communications with both the NRC and plant personnel.
The' performance in the Safety Assessment / Quality Verification area decreased slightly mainly due to
.a programmatic breakdown involving the licensee's followup of
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deficiencies. The root cause of the deficiencies was failure to effectively establish priorities and a lack of resources in selected
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areas.
It was also noted that during this period the quality and'
completeness of several licensee responses has decreased. The
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licensee has enacted several programs to correct weaknesses identified in this area. These are generally long-term programs.that will continue to be evaluated.
Performance of in-depth technical auditing is a program strength.
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' 'l The. performance ratings ~during_-the previous assessment period.and l
this' assessment period according to functional areas are given below:
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s-Rating Last Rating This-
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Period Period Trend
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Plant Operations-
1 Radiological Cor.trols
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= Maintenance / Surveillance 1-
2 Security ~
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Engineering / Technical-Support 2L
Safety Assessment / Quality Verification-
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Other Areas of Interest None -
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III. CRITERIA Licensee performance is assessed in-selected functional areas.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some functional areas may not be assessed because l
of_ little or no licensee activities or lack of meaningful observations.
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Special areas may be added to highlight significant observations, j
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The following evaluation criteria were used to assess each functional area:
1.
Assurance of' quality, including management involvement and control; 2.
Apprcach to the identification and resolution of technical issues from a safety standpoint; y
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Enforcement history; i
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Operational events (including response to, analyses of, reporting of, and corrective actions for),
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5.
Staffing (including management); and 6.
Effectiveness of training and qualification program, i
However, the NRC'is not limited to these criteria and others may have
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been used where appropriate.
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l On the basis of the NRC assessment, each functional area evaluated is
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rated according to three performance categories.. The definitions of these performance categories are as follows:
Category 1:
Licensee management attention and involvement are readily
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evident and place emphasis on superior performance of' nuclear safety or
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safeguards activities, with the resulting performance-substantially j
exceeding regulatory requirements.
Licensee resources are ample and j
effectively used so that a high level of plant and personnel performance
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is being achieved.
Reduced NRC-attention may be appropriate,
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e Category 2:
Licensee management attention to and involvement ~in the l
performance of nuclear safety or safeguards activities-are good.
The licensee has attained a level of performance above that needed to meet
- i regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being-(
achieved. NRC attention may be maintained at normal levels.
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Category 3:
Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficient.
The. licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements.
Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal levels.
The SALP Report may include an appraisal of the performance trend in a functional area for use as a predictive indicator.
Licensee performance during the assessment period should be examined to determine whether a trend exists.
Normally, this performance trend should only be used if a definite trend is discernible.
The trend, if used, is defined as:
Improving:
Licensee performance was determined to be improving during the assessment period.
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Declining:
Licensee performance was determined to be declining during the assessment period, and the licensee had not taken meaningful steps %
address this pattern.
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e IV. PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis
Evaluation of this functional area was based on the results of-11 routine and 2 special inspections conducted by the resident and regional inspectors.
Enforcement history in this functional area declined slightly from the previous assessment period.
Three Severity Level IV violations were issued, one involved the inadvertent. isolation of Unit 1 auxiliary feedwater (AFW) flow instrument transmitters while personnel prepared for testing on Unit 2 AFW.
This personnel error was quickly recognized and the systems were restored to normal.
The other two violations were procedural deficiencies.
There were few incidents requiring the submittal of licensee event reports (LERs) attributable to this functional area.
One incident involved personnel error and three were caused
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During this assessment period several informational LER notifications were made which was an improvement in the communication of issues compared with previous rating periods, Root cause analysis, safety analysis, and corrective actions were adequately
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addressed in the LERs.
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This two-unit facility had only one reactor trip from power during the 17-month assessment period, compared with-four reactor trips during the previous 18-month period. The-trip occurred on Unit 2 and was caused by equipment failure. The
. low trip rate was due in part to the diligence of its operational staff during startup, shutdown, and normal facility operations.
Plant management personnel continued to be actively involved in matters relating to the. operation of the facility and regularly visited the control room. -Senior corporate management personnel also routinely-toured-the facility and the-frequency of visits to the site by personnel from the licensee's corporate offices increased noticeably.
Management's approach to-the identification and resolution
of technical issues was excellent. Operations in conjunction with Engineering pursued a one quarter gallon per-minute leak in the reactor coolant system even though this leak was well below
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the Technical Specification (TS) limit.
After determining its
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location and nature, the licensee shut down the unit to repair the leak. The control room operators trended plant chemistry and coolant leakage data with daily updated graphs.
This.
graphed data allows rapid identification of any trends that
could be symptomatic of a material degradation. A new shutdown status board was installed to allow operators to rapidly assess and keep abreast of changing plant conditions during outages.
The licensee's communication with the NRC has improved in general from the previous period.
Operations personnel were more open in their communications and routinely inform the.
resident inspectors of noteworthy changes in plant conditions.
Additionally, management maintained an effective dialogue with NRC which contributed to a better understanding of emergent issues.
The operations group responded to identified procedural problems quickly and provided several status updates to the residents that demonstrated the improved communications.
Staffing of licensed operators remained stable during this period. The licensee has continued to be selective in the hiring of new operations employees.
Licensed operators were on a six-shif t rotation for this period. Use of overtime was limited and remained controlled.
Inspectors noted only a few cases in which operators exceeded NRC guidelines, and these occurrences were properly approved by plant management.
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number of qualified duty technical assistants dropped from 15 to 10 because 5 individuals left the utility.
Although no detrimental effect on plant operations was noted, the loss of experienced personnel remains an area of concern, t
The effectiveness of the training and qualification program for licensed operators has improved and was determined to be satisfactory as discussed in the Engineering / Technical Support-area,. During this period, 2 of 3 operators passed initial licensing examinations and 20 of 21 operators passed requalification examinations.
Activities in the control-room were controlled to provide a distraction-free environment; only industry-related reading material was allowed and nonbusiness conversations or discussions were infrequent. Operations personnel were alert, exhibited a high degree of professionalism in all facets of control room operation, responded to all alarms.immediately, and were knowledgeable of the status of the plant. The lack of incidents or plant trips resulting from operations personnel errors was evidence of the good control room atmosphere.
Another factor is the continued aggressive response to operational conditions' relating to instrumentation and component. malfunctions, thereby averting challenges to.
automatic protective systems.
For example, the operators placed the electrohydraulic control system in manual upon a control circuit failure to prevent a turbine load reject
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The operations personnel attention to detail, a concern addressed in the previous assessment period, has
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improved significantly, The licensee was proactive in maintaining a " black board" condition in the control room. The operations staff promptly initiated actions to repair malfunctioning alarms which received a-high priority. Additionally, the licensee did not tolerate plant conditions that cause even low priority alarms to remain locked in or to annunciate too frequently, A specific area of NRC concern during this assessment period involved the licensee's use and implementation of procedures.
The concern centered on an inadequate use of temporary changes to procedures and the use of cautions and notes, Management meetings were held with the licensee regarding these problems and the licensee subsequently committed to a program to improve changes to, and controls of, procedures, This effort remains ongoing and improvement in this area has been noticed at the end of the assessment period, Housekeeping conditions within the facility continued to be good, with the exception of the lower level turbine building
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and the radioactive waste treatment area. -A noteworthy
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improvement in plant configuration control was the completion of an extensive = labeling program. All valves had large
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standardized, color-coded labels and pipes were marked with -
flow arrows and system identifiers along their lengths.
The fire protection program was excellent and responses to observed fire drills were timely. Typically, more than the minimum number of personnel responded to these drills for. training purposes, and management critiqued these drills well,
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Performance Rating The licensee's performance is rated Category 1 in this area.
.The licensee's performance was rated Category 2 with an improving
trend in the previous assessment period.
The improvement in the performance rating is based upon the knowledge and experience of operators, " blackboard" condition, professional atmosphere in the control room, and an improvement in the use and control of procedures and procedural changes.
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Recommendations None,
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Radiological Controls 1.
Analysis i
Evaluation of this functional area was based on the results of six inspections by regional inspectors and observations made by the resident inspectors.
Enforcement history in this functional area declined during this assessment period with four Severity Level IV violations issued.
Three violations involved a programmatic weakness, which was also identified during the previous assessment period, regarding high radiation area (HRA) access control.
The fourth violation concerned a failure to adequately evaluate radiation hazards associated with an individual handling a highly radioactive fuel fragment. Although the unplanned extremity exposure associated with handling of the fuel fragment was within regulatory limits,
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the incident revealed' inadequacies concerning trair.ing, j
procedures, communications, and delineatien of organizational
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responsibilities. 1hese violations were the subject of two
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enforcement conferences.
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Staffing and qualifications remained good, with low staff turnover.
The radiation protection staff was reorganized
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under a new Health Physics (HP) Superintendent into technical and operational groups. The chemistry staff has
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also been reorganized, and both the HP and chemistry s
superintendents report directly to the Plant Manager.
l Staffing levels and qualifications were adequate to implement f
the routine chemistry / radiochemistry and radiation prmtection programs.
However, the licensee has not established an ALARA
organization to focus resources on the implementation of-(
exposure reduction practices and technology.
Rather, ALARA f
coordination is delegated as a collateral duty to a nuclear
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specialist in the licensee's radiation protection staff. Of the licensee's 23 HP technologists, 21 are qualified under ANSI.
N18.1-1971, which reflects i.mproved staff stability.
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Training weaknesses were ider.tified during two unplanned J
extremity exposure events' that occurred early in the assessment f
period.
In both events the individuals involved were not i
sufficiently trained to recognize:the radiological hazards
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present.
Near the e_nd of the assessment period, the licensee completed corrective actions intended to preclude recurrence.
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Training weaknesses were also identified regarding the f
recurrent HRA access control problems.
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Management's involvement in assuring quality was mixed and declined from the previous assessment period. Management attention was ineffective to identify, address, and correct some significant programmatic weaknesses in a timely manner; for example, those associated with the unplanned extremity exposure events and the recurrent HR'. access control problems.
However,
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Radiological Controls 1.
Analysi,s Evaluation of this functional area was based on the results of six inspections by regional inspectors and observations made by the resident inspectors.
Enforcement history in this functional area declined during this assessment period with four Severity Level IV violations issued.
Three violations involved a programmatic weakness, which was also identified during the previous assessment period, regarding high radiation area (HRA) access control.
The fourth violation concerned a failure to adequately evaluate radiation hazards associated with an individual handling a highly radioactive fuel fragment. Although the unplanned extremity exposure associated wi.th handling of the fuel fragment was within regulatory limits, the incident revealed' inadequacies concerning training, procedures, communications, and delineation of organizational responsibilities. 1hese violations were the subject of two enforcement conferences.
Staffing and qualifications remained good, with low staff turnover.
The radiation protection staff was reorganized under a new Health Physics (HP) Superintendent into technical and operational groups.
The chemistry staff has also been reorganized, and both the HP and chemistry superintendents report directly to the Plant Manager.
Staffing levels and qualifications were adequate to implement the routine chemistry / radiochemistry and radiation protection programs.
However, the licensee has not establishad an ALARA L
organization to focus resources on the implementation of exposure reduction practices and technology.
Rather, ALARA coordination is delegated as a collateral duty to a nuclear specialist in the licensee's radiation protection staff.
Of the licensee's 23 HP technologists, 21 are qualified under ANSI N18.1-1971, which reflects improved staff stability.
Training weaknesses were identified during two unplanned extremity exposure events that occurred early in the assessment period.
In both events the individuals involved were not sufficiently trained to recognize the radiological hazards present.
Near the end of the assessment period, the licensee completed corrective actions _ intended to preclude recurrence.
Training weaknesses were also identified regarding the recurrent HRA access control problems.
Management's involvement in assuring quality was mixed and declined from the previous assessment period. Management attention was ineffective to identify, address, and correct some significant programmatic weaknesses in a timely manner; for example, those associated with the unplanned extremity exposure events and the recurrent HRA access control problems.
However,
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management support for facility improvements was evidenced by an upgraded makeup water system, a new cold chemistry laborttory with state-of-the-art instrumentation, and plans to install ar.
inline ion chromatograph for better monitoring of secondary system chemistry parameters. Management also supported a quality water chemistry program that conforms to industry guidelines.
In addition, the licensee has developed an extensive program to trend environmental TLD data in the Radiological Environmental Monitoring Program (REMP).
The licensee's approach to identification and resolution of technical issues was mixed.
The licensee upgraded the physical and administrative controls for under-vessel access, improved air sampling for fuel transfer canal work, and upgraded HRA
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barriers. The licensee also improved the chemistry laboratory QA/QC program and the semiannual REMP reports. The latter was improved by including individual analyses in the report.
Gascous and liquid radioactive effluent releases continued to be maintained well within TS limits. While the annual cumulative dose' remained below the average for U.S. PWRs, the licensee has not' aggressively pursued a proactive ALARA program with a-permanent ALARA staff dedicated to the implementation of innovative, state-of-the-art dose reduction practices and techniques.
The average annual doses for U.S. PWR have declined significantly over the last 5 years; however, the licensee's annual cumulative exposure has remained essentially unchanged
.with' a total station dose of 474 person rem for 1989 and an
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' average.of 435 person-rem for the-previous 4 years.
The-licensee ~also experienced a radwaste shipping problem concerning n
the inadequate solidification _of materials that was identified by a waste burial site facility.
The,results of the nonradiological confirmatory measurements program were good with 25 of 27 comparisons in agreement. The radiological confir_matory measurements program continued to be adequate with.46 agreements-in 51 comparisons.
The REMP appeared
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to conform to-TS requirements and to be operating satisfactorily, except,that an auditing period was delayed beyond TS. requirements.
2.
Performance Rating-The=' licensee's performance is rated Category 2 in this area.
'The licensee's performance was rated Category 1 in the previous assessment period.
This decline in performance rating was reflected in the recurrent HRA.and unplanned exposure problems, as well as training and management weaknesses. associated with these problems. The lack of an aggressive ALARA program is also a-weakness.
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.Recommendaticy None.
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Maintenance /Surveillanc=
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Analysis Evaluation of this functional area was based on the results of 1 special and 11 routine inspections performed by resident and regional inspectors.
Enforcement history in this functional area was excellent during this assessment period, with no areas of significant regulatory concern being identified.
There were numerous incidents requiring the submittal of LERs attributable to this functional area.
Five incidents were caused by personnel error. This is a notable increase over the previous assessment period and appears to be primarily attributable to a lack.of attention to detail on the part of instrumentation & control (I&C)-technicians performing surveillances.
Two incidents resulted from procedural inadequacies, which are being addressed by.a new procedure correction program. The remaining eight' incidents were caused by equipment failure or malfunction.
The majority of these resulted from age degradation problems.
None were of any major safety significance. Safety analysis and corrective actions were adequately addressed in the LERs. However, the repeat occurrences of personnel errors during surveillances indicate a potential inadequacy in identification'of' broad scope root cause and corrective actions.
Management involvement in ensuring quality in this functional cp '
area-remained a strength.
Senior personnel were involved in
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the conduct of maintenance and surveillance at the facility and routinely visited job sites. Refueling outages performed.
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during this assessment period were.well managed, and all three outages were completed close to the original estimated:
completion date. A special maintenance outage-on Unit I to
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repair two leaks in-the reactor coolant system (RCS) was properly planned and corrected in an appropriate manner despite
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complications that arose while performing the work. -The-licensee also initiated a pilot reliability centered maintenance
program at the end of this period; this is an important W
initiative given the age related problems that are being observed.
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Plant management's approach to the identification and resoluti
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on of technical issues remained good.
Maintenance activities wtre closely followed by first-line supervisors, and upper managtment
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was informed of work progress on a daily basis.
Problems encountered during the performance of maintenance or surveillance
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activities were quickly communicated to management pernnnel, which resulted in orompt and effective resolution of issues.
This process was demonstrated during the Unit 1 outage to repair a leak in the RCS when a second leak was identified, evaluated, and repaired without causing an extension of the outage.
Management effectiveness was also demonstrated by the rapid restoration of the 125 VDC distribution system after the discovery of a design deficiency that rendered the entire
system inoperable under certain fault conditions, thereby requiring enforcement discretion.
Corrective actions addressing-safety issues, such as augmented inspection of reactor vessel
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embedded flaws to assure degradation is monitored and centrolled, were also prompt and thorough.
Staffing in this functional area continues to be a licensee strength.
This was largely attributable to the low turnover rate and the high level of experience of maintenance personnel.
Near the end of this assessment period, a change was made in the_ Superintendent of Maintenance position. This. transition-was made smoothly. The quality of work' performed by-the maintenance department was excellent, as-evidenced by the low forced outage rate and the operational condition of the facility.. Although.
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overtime was controlled, personnel were periodically authorized by plant management to exceed NRC guidelines, especially during outage periods. A few cases were noted in which authorization was not properly obtained and appears to be a negative trend; however, the licensee took prompt corrective action to rectify the issue, Effectivenest of the_ training and qualification program.is t
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considered _ adequate based on the operational condition of.the-
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facility.. Formal training, self-study, and on-the-job; training
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are qualified. The utility's nondestructive examination training and qualifAcation programs comply with applicable code. requirements.
The maintenance work backlog was maintained at a manageable level.
Maintenance work was well controlled, and rework was very seldom needed.
The plant's Computerized History and-
Maintenance Planning System (CHAMPS) database is a very useful
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tool for tracking maintenance activities.. Preventive. maintenance i.E was routinely completed on schedule, and the work was done properly. One indication of the effectiveness and quality of the work performed was the low forced outage rate. The inservice inspection program was also considered to be adequate.
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.I&C technicians maintained good communications with operations i
personnel during the performance of tests, thus allowing the operators to closely follow the testing and to remain cognizant of its status.
Procedures were in evidence at_the job site.
Unexpected equipment' responses were immediately brought to a
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. supervisor's attention.
Surve111ances were routinely completed on schedule and in a thorough and professional manner. One area of concern regarding the performance.of surveillances was an increase in the number of personnel errors by I&C technicians.
These errors appeared to be directly attributable to a lack of attention-to detail.
i Several major evolutions were performed at the facility that required extensive preparation, coordination, and management involvement.
These included two containment integrated leak rate tests, replacement of the A and 8 station batteries, 10 year _ inservice inspection of the core barrel, and extensive work and testing on the gas turbine generator for station blackout qualification. All these activities were carried out in a well controlled and deliberate manner.
2.
performance Rating
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.The. licensee's performance is rated Category 1 in this area.
' The licensee's performance was rated Category 1 in the previous-
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assessment period.
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3.
Recommendations None.
1.
Analysis-
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Evaluation of this functional area was based on'the results o'f four inspections. conducted by regional. inspectors and observations rade by resident inspectors, o
Enforcement history in this> functional area was adequate.
One
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Severity Level IV violation was identified during this assessment
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period concerning the deletion of a TMI. task action requirement.
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Management involvement in assuring. quality was good throughout-the assessment" period.
The license. revised the emergency preparedness organization to improve the reporting chain.
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The Coordinator, Emergency Planning, now reports to the
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Superintendent, Regulatory and Support Services, who reports directly to the Plant Manager. _To ensure-that corrective actions would be initiated on emergency preparedness related concerns,_ the licensee used a tracking system to effectively follow the resolution of these concerns.
Early in_the assessment period, a concern was identified regarding the tracking and documentation of emergency response training.
The licensee convened a task force to address this problem and expended significant effort to identify and resolve deficiencies in training documentation. A comprehensive emergency preparedness training program and tracking system resulted from this effort, and most corrective actions are now complete or near completion.
The-layout and organization of the Operations Support Center (OSC) has been a weak area for some time, based on exercise observed. problems in the areas of facility management, activation,
team briefings / debrief _ings, and information flow.
In response
'
to these concerns, the licensee formed an OSC renovation committee, which is assessing options for revising the facility.
The' licensee's approach to the resolution of technical issues-was good.
The licensee extensively reviewed Emergency Plan
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. revisions, facilitating subsequent NRC review and approv'a1.
Maintenance of the emergency preparedness program and associated equipment was_ good, with only very minor problems identified.
The 1990 emergency exercise performance was considered good, with.no exercise weaknesses identified. Exercise. performance
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had improved considerably compared with the 1989. exercise, which took place in the previous assessment period.
The exercise scenario was considered challenging to all significant aspects of the Emergency Plan.
Staff observations of scheduled emergency drills indicated that participants took drills seriously, and performance was generally good.
The licensee conducted thorough dr.ill critiques.
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'The. licensee's response to operational events was good _ One-
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actual activation-of the Emergency-Plan occurred during the=
assessment period.
Licensee ~ records indicated that the-
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activation had been properly performed'per the Emergency Plan!
and Emergency Plan Implementing Procedures.
Internal evaluations of the activation were thorough and included documentation of any.
identified problems or recommendations for improvement as well as the associated corrective action.
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Staffing of emergency response positions'has' been adequate with~
the authorities and responsibilities of-personnel well defined.
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Knowledge and capability of personnel to carry out their
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emergency response duties were adequately demonstrated during annual emergency preparedness exercises. This indicated that the licensee's training program was successful in preparing
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personnel for their emergency response assignments.
Concerns-related to training were addressed early in the assessment period, and some actions are still in progress, with a second task force being proposed to review the overall structure of the emergency preparedness program and related training.
'2.
Performance Rating
,
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous assessment period.
-3.
Recommendations None.
E.
Security-1.
Analysis Evaluation of this functional area was based on the results of five inspections by regional inspectors and observations made
l by thetresident inspectors.
Enforcement history in this functional area continued to be
'
weak.
Seven Severity Level IV violations were identified during this assessment period, two of which related to vital area (VA)
'
barrier controls that were discussed in the previous SALP report.
A working meeting was held at the bSinning of the assessment period to discuss recurring VA barrier violations / problems over the previous 3 years.
The licensee's corrective actions involving the VA barrier issue were aggressiveLand' comprehensive; t
however, they were not totally. effective in that the licensee
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identified another degraded VA barrier in the last month of the N
assessment period.
The evaluation of'this latest incident will be. conducted in the next assessment period.
Since the previous assessment period. management's role in assuring quality improved and was considered good. A close.
working relationship has developed between site'and corporate
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security management in. identifying goals and objectives and
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actively, pursuing their fulfillment' ' Management's support for
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E improvements to the security system was good, as evidenced by the. procurement of new access control? security equipment.
Security management also included the contract security force in a series of plant leadership and team-building workshops i
designed to enhance. job satisfaction and to improve
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.4 communications. Management has taken a proactive security posture, increasing staff attention to security matters. The licensee made progress in increasing the security conscivosness
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of all plant employees.
The licensee also committed to a major security hardware upgrade program to be completed over the next 3 years.
Site and corporate security management have kept NRC regional personnel fully informed of security issues involving the site.
However, early in the assessment period the corporate security office failed to notify site personnel of NRC's acceptance of a significant security plan change.
This change required the posting of security personnel at the entrance to containment during outage activities.
Consequently, the site failed to implement this provision of the plan, resulting in a violation.
The licensee's approach to the identification and resolution of-technical security issues was good, as evidenced by the-comprehensive action plan to resolve problems associated with-the intrusion detection-system. The licensee hired a contractor to conduct a technical review of the system. The subsequent equipment upgrades significantly reduced system downtime and
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the high alarm rate.
The licensee's program for reporting security events was adequate.
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Required reports were generally accurate and timely, except for-
,a 1-hour report that was late because of a misunderstanding on the part of the-on-duty security shift supervisor.
There were seven 1-hour event reports made during this assessment period.
Three of the events related to failure of the alarm station operators to-adequately implement compensatory measures for.
failed intrusion Plarm zones. The last event occurred in the closing month of the current assessment period and related to.
s La degraded VA barrier.
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The' licensee's security organization was adequately staffed.
Positions and~ responsibilities ~within'the organization were-
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defined, and overtime was adequately monitored and controlled.
During-the current assessment period, the licensee permanently-filled the security supervisor's -position with an: individual whose sole responsibility -related to security. The contract security force experienced a 20% turnover rate for the--
assessment period, which was considered high. The experience level of non-supervisory personnel was consequently low.
The high turnover rate has negatively affected the morale of security force members because of-the frustration of continua 11y'
training new personnel on the job.
The licensee was reviewing this issue and was seeking ways to reduce the current turnover rate.
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.......,... -.... _. _., _.., ~, _.. _, _ _ _. -
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The training and-qualification program for the contract security officers continues to be a program strength. The use of: professional educators from a local technical training institute has helped to provide a professional, knowledgeable security force.
2.
Performance Rating The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous assessment period.
3.
Recommendations None.
F.
Engineering / Technical Support 1.
Analysis Evaluation of this functional area was based on the results of 11L routine and 2 special inspections by resident inspectors, 2-special inspections by regional personnel, and an Electrical Distribution System Functional Inspection (EDSFI) by headquarters and regional personnel.
The. enforcement history during this assessment period remained 1the same as the previous assessment period, with two Severity Level IV violations issued. One violation concerning procedure deficiencies was indicative of a programmatic weakness relating to temporary. procedure changes that the licensee is addressing with the procedure correction program.
In addition, enforcement actions resulting from the EDSF1 and a special followup inspection are still under review?
Several issues requiring the submittal of LERs were attributed to this functional area during this assessment period. Many of these were. identified during licensee review and all but one of
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theseLissues involved design inadequacies on either the part of the licensee or of theLyendors. Of the design-related events, only one was not attributable to the original facility design as discussed in more detail in the Safety Assessment / Quality Verification section. The licensee has initiated actions to reconstitute selected portions of the design bases and conduct additional-system design reviews. These initiatives are important given the findings from-design reviews completed to date.
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Management involvement to ensure quality in this functional area was mixed. On the negative side, corrective actions from a'self-initiated evaluation of the emergency diesel generators (EDGs) had not been initiated a year after the evaluation was
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completed. This delay was attributed to_ a lack of prioritization and a weak scheduling program for the correction of inspection
,
findings. Another example was the absence of a setpoint document supporting the emergency operating procedures (EOPs) in the
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plant-controlled document system.
Although this problem was corrected, problems were also found with the document itself, including erroneous or missing setpoints.
This indicated a lack of rigor in documenting engineering activities and independent verification of that documentation.
On the positive side, decisions were made at a level that usually ensured adequate review by management. Most of the' licensee's activities exhibited evidence of. prior planning and assignment of priorities._ Plant management demonstrated excellent coordination in arranging for and obtaining a custom-designed replacement fuel assembly to replace a once-burned assembly that was damaged during fuel transfer evolutions. This task was accomplished within a week, in-time to-meet the resttrt schedule.
The licensee's identification and resolution of technical issues remained mixed.
Positive performance was demonstrated by the identification of inadequately designed EDG~ exhaust stack supports and the subsequent modification performed. Other examples of the licensee's resolution of complex technical issues include rapid assessment of the heat flux peaking factor (F(q)) calculation error,125 VDC distribution bus breakers event, and response to an EDG fuel ~ oil piping seismic issue in arranging for and obtaining offsite fuel oil supplies, Additionally, the licensee initiated-and aggressively pursued a comprehensive program in-response to EDSFI findings.
"
On the negative side, the engineering staff-demonstrated inconsistencies in' evaluating design adequacy;or establishing adequate basis,for certain changes' or modifications to the plant. When the utility identified a problem with an original design, the full extent of the. problem or the possibility of other similar problems aere not-always addressed. ' Examples-include not developing a full load profile for sizing replacement batteries, not maintaining a current load. profile of emerger.;y loading on the EDGs, and not evaluating the effects on the EDGs of fuel oil that did not meet established quality requirements.
Engineering support provided for the E0Ps was also weak.
EDG accident loads-identified in the E0Ps were inaccurate and nonconservative and changes had been made to the'E0Ps without engineering review.
Additionally,.the licensee did not aggressively pursue a spent fuel rack design deficiency that caused damage to a fuel assembly.
Communication of engineering issues with the NRC has improved significantly during this assessment period.
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d The' licensee made several presentations to the NRC regarding initiatives which benefit safety that were informative and i
helped t.unvey an understanding of the work planned by the utili+;.
Examples of these initiatives included the proposals
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A
.for the installation of two additional EDGs, conformance to the
station blackout rule, and 13.8 KV modifications.
The licensee's
'
commitment to these efforts was demonstrated by proposed increases in the engineering and technical support staffs.
The licensee was also responsive to concerns regarding the reactor operator requalification program.
This was demonstrated by the licensee's response to an unsatisfactory rating:for its program at the end of the previous assessment period. The licensee aggressively'
,
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pursued corrective actions, and the program was subsequently evaluated as satisfactory.
Staffing has increased slightly during this assessment period.
A lack of personnel resources was identified as ~the principal
.cause of. inadequacies in the licensee's corrective action l
,
program.
The licensee committed to rectify this condition in its reply to a violation with an associated civil penalty and
.has begun the process of hiring additional personnel.
However, during this assessment period, the Superintendents of Technical
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Services and Training, as well as the Regulatory Engineer, i
resigned.
In view of the fact that much of the licensee's good
'
performance, despite a small staff, was directly attributable to-l the experience' level of its employees, the. loss of senior-t personnel gives cause for concern.
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- The training and qualification of the licensee's engineering
staff appears to be adequate, although no formal training i
program exists,for engineers.
The lack of a formal training program may be a contributing factor to some of-the problems set
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forth in this section._ The engineering staff at the corporate office had the necessary technical expertise to evaluate -
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discrepancies, and when outside consultants were used, the licensee
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.provided sufficient technical. oversight.
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l2.
Performance Rating.
- The licensee's performance is rated Category 2.in this area.
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- The 16esee's performance was rated Category 2 in the previous
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O assessmer period.
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Recommendations
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'None.
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G, Safety Assessment /(luality_ Verification 1.
Analysis
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Evaluation of this functional area was based on 2 special and 11 routine inspections performed by resident and regional inspectors.
In addition, NRR's review of licensee submittals i
and requests for amendments to the operating license were considered.
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The enforcement history during this assessment period declined with one Severity Level III violation and an accompanying civil penalty and two Severity Level IV violations issued. The violation with civil penalty resulted from a programmatic breakdown that showed a lack of management support for the correction of identified facility weaknesses and deficiencies, The breakdown was largely attributed to a lack of personnel resources _and is discussed throughout this section.
There were no issues requiring the submittal of LERs attributable to this functional area,
'
Management involvement in ensuring quality was mixed. A significant weakness was demonstrated by a breakdown in the licensee's followup and correction of self^ identified and i
contractor-identified deficiencies. Weaknesses related to this breakdown' included'an inadequate system for prioritizing identified deficiencies, failure to utilize the approved escalation process for delinquent open items, weak support by management for the closure of items (largely 0 result of constraints on resources), and a concern by QA personnel about
promoting a negative working rehtionship by pushing closure of items.
The licensee has initiated several corrective actions in response to these issues and appears to be aggressively pursuing them. One significant action taken in response to this deficiency is.the initiition of staffing increases in the Nuclear power Department.
On the positive side, good management involvement has been
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I demonstrated by ont,ite and offsite review committees, which
!
handle issues in an excellent manner, Review committee l
discussions were typically spirited and candid and have widespread
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management involvement.
Another positive action was tt'
establishment of an onsite QA group in April 1989, weating i
the QA group onsite improves the overall QA organization's
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effectiveness by providing day-to-day coverage of facility
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operations. This onsite group, augmented by corporate personnel, i
has already conducted several audits of the facility, Overall,
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audits' by the QA organization including performance of Safety System Functional Inspections (SSFIs) constitute a program j
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strength. A major audit of the E0P program identified many
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significant concerns.
The licensee also has an ongoing vertical slice audit program to review the plant's safety systems. These audits, which are viewed as proactive, are considered helpful in identifying safety significant issues, enhancing performance, and increasing system reliability.
The licensee's approach to the identification and resolution of L
technical issues also remained mixed.
Self-initiated audits and evaluations have produced numerous significant findings requiring corrective action. In general, the licensee promptly and thoroughly addressed those findings that were deemed by management of immediate operability concern. The safety significance of a number of other issues was not adequately addressed ind as a consequence tended to languish. The licensee was eifective in
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L identifying system deficiencies but was unable to address the issues in a timely manner.
Since the issuance of the civil penalty for this weakness, the licensee has made significant strides in improvement. Well over 50% of the overdue items have been resolved, and there has been a marked downward trend in the total number of delinquent open items.
The utility has also initiated a major design basis reconstitution program.
This multi year effort is intended to produce design basis documentation to enhance the licensee's ability to perform detailed design reviews and safe +v assessments. As discussed previously, design-related isse identified in licensee and NRC reviews doonstrate the importert of continuing these efforts.
Two technical issues evaluated by the utility during this assessment period resulted in requests for enforcement-discretion. Discretionary enforcement was requested in the fall of 1989 for problems associated with the 125 VDC distribution system. A waiver of compliance was requested
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in the spring of 1990 for problems associated with the EDG fuel oil system. Both issues required extensive work on the part of the utility to effect resolution of the problems.
This work was accomplished in a prompt and thorough manner that demonstrated the licensee's ability to deal effectively with complex technical issues.
A review of the licensee's evaluations of bulletins, information i<
notices, and'other communications with the NRC disclosed that
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the evaluations were generally proper and adequate. However, L
several past responses that were evaluated during this period,
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indicated a less than complete understanding of the associated j
technical basis or missed key elements of the generic communication.
Exampms included a 1987 letter to the NRC about
inservice testing requirements for the EDG fuel oil system.
This letter indicated that the diesel day tanks contained sufficient fuel to mitigate an accident, a position not consistent
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with the licensee's TS or FSAR. A further example was a response i
to a bulletin that stated no check valve existed in the flow path for cooling water to the EDGs. The licensee failed to consider the system's intake check valves, which the bulletin specifically listed as a concern. More recent responses appear
to be more complete indicating that changes made to the old i
review program have been beneficial.
On several occasions during snis assessment period, the licensee missed commitment dates for corrective actions in LERs and responses to violations.
For some of these occurrences, the licensee did not communicate the reasons for the missed dates
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nor when the actions would be completed.until prompted by inspectors.
Upon prompting, however, the licensee responded in a timely manner.
In the Radiation Controls functional area, some identified technical issues such as missed quality
'
assurance audits of the Offsite Dose Calculation Manual and the i
REMP, were dealt with in a timely and efficient manner.
However, the licensee failed to meet multiple committed action dates on other issues, such as revisions to radwaste procedures to correct technical deficiencies.
After improvement early in the assessment period, recent amendment applications submitted by the licensee have have not been of v
consistent quality. The arguments to support the determination of "no significant hazards" consideration-were particularly weak
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in three 1990 applications. One apolication included a request
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for a change that should have been included in an 1989 amendment
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application.
In contrast, the licensee's response to the station blackout rule t
and the anticipated transient without scram (ATWS) rule l
adequately addressed the issues and generally conformed and in some creas' exceeded the guidance provided.
The licensee was well prepared for addressing staff questions and requests for documents during site audits.
'.~
The licensee's procedure for perf6rming 50.59 analysis was
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determined to be adequate. The licensee has shown initiative in incorporating the recently developed industry guidelines into a
s their procedures.
The licensee recently completed an internal o
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audit of the performance of their 50.59 reviews and identified a l
number of reas where improvements could be made, oH L
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The licensee has demonstrated effective communication with j
the NRC at various management meetings.
These meetings have covered a wide variety of subjects, including programmatic I
and specific engineering and management topics.
The nature of these meetings has been open and informative.
Staffing in the QA area has increased slightly and the licensee intends to continue this increase as the hiring program continues.
i Several management changes and reorganizations have occurred at the utility.
These changes include the naming of a new Chairman I
of the Board of Directors, the inclusion of an Executive Vice President in the corporate structure, the naming of a Senior Manager of Nuclear Engineering, and a new Plant Manager, j
i Effectiveness of training and qualification was adequate.
j Although the licensee does not have a site specific simulator,
)
one has been ordered and scheduled for delivery in 1991. This
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simulator will-model the two-unit control room and will be the only dual-unit simulator in Region Ill.
The licensee has also undertaken a comprehensive cultural adjustment and team-building training program to identify any problems perceived within the organization. This program was intended to induce personnel to confront problems, and develop and implement the solutions necessary to overcome them. This program remains ongoing and appears to have had a positive effect on nuclear department personnel.
2.
performance Rating The licensee's performance is rated Category 2-in this area.
The licensee's performance was rated Category 2 in the previous assessment period.
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3.
Recommendations None.
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'o V.
Supporting _ Data and Summaries A.
Licensee Activities 1.
Unit 1 Unit 1 began this assessment period in coastdown operations and i
entered a refueling outage on April 2, 1989, after completion of l
a 316 day continuous run. The unit was returned to service on May 17, 1989, and continued full power operation except for several power reductions for a fuel conservation program and to perform routine surve111ances.
On February 21, 1990, the unit began coastdown operations and was removed from service'on March 31, 1990. This completed a 318 day continuous run and commenced a scheduled refueling and maintenance outage. The unit was returned to service on May 20, 1990, and remained at
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full power until July 20, 1990, when the unit was shutdown to
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repair two leaks in the RCS.
The unit restarted on July 28, l
1990, and continued at full power throughout the remainder of
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this assessment period.
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Unit 1 experienced one engineered safety feature (ESF) actuation t
and no reactor trips during this assessment period.
The ESF actuation was the result of personnel error during testing and resulted in an AFW pump start.
.
Significant outages and events that occurred during this assessment period are summarized below.
Siontficant Outaces and Events a.
From April 2, 1989, to May 17,_1989 Unit I was in a scheduled refueling and maintenance outage, b.
From March 31, 1990, to May 20, 1990, Unit I was in a l
scheduled refueling and maintenance outage.
c.
From July 20, 1990, to July 28, 1990, Unit I was~in a special maintenance outage to repair RCS leaks.
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2.
Unit 2 Unit 2 began this assessment period in a shutdown condition as
the result of a genierator lockout / turbine trip / reactor trip
'
resulting from equipment failure in the main transformer.
The unit returned to full power on April 2,1989,- and operated v
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routinely until August 20, 1989, when another generator l
lockout / turbine trip / reactor trip occtrred.
This trip was the result of a nitrogen sudden-pressu'e trip on_the main transformer. The unit was returned to ervice on August 21,
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1989. The unit began coastdown operatio,' on September 8, 1989 L
and was shut down, for refueling outage #15 on September 22.
On November 24, 1989, the unit was returned to service and remained at full power throughout the remainder of the
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i assessment period.
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Unit 2 experienced two ESF actuations (both generated during i
maintenance activities) and two reactor trips during this
)
assessment period. One reactor trip, with no rod motion,
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was_the result of procedural deficiencies. The other trip,
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.from greater than 15% power, was the result of equipment failure.
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Significant outages and events that occurred during this
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assessment period are summarized below.
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,$1onificant Outages and Events i
a.
On August 20, the unit experienced a nitrogen sudden
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pressure trip on the main transformer resulting in a i
generator lockout / turbine trip / reactor trip. After t
troubleshooting the trip, the unit was returned to service August 21, 1989.
b.
_From September 22, 1989, to November 24, 1989 Unit 2
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was in a scheduled refueling and maintenance outage.
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-B.
Inspection Activities Forty four inspection reports are discussed in this SALP 8 report (April 1,_1989, through August 31,1990) and are listed in Paragraph.1 ot'this section, Inspection Data.
Table 1 lists-
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the violations per functional area and severity level.
Significant
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inspection activities are. listed in Paragraph 2 of_this section, Special Inspection Summary.
1.
Inspection Data a..
Unit 1 Docket No.:
50-266.
- Inspection Report Nos.:
89009, 89011 through 89033, j
90002 through 90018, and 90201
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b.-
Unit 12
' Docket No.:- 50-301 i
Inspection Report Nos.:
89009, 89011 through 89033, 90002-
through 90018, and 90201
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'c TABLE 1 Number of Violations in Each Severity Level Unit 1 Unit 2 COMMON Functional A,eas III IV V III IV V III IV V A.
Plant Operations
1
B.
Radiological Controls
C.
Maintenance / Surveillance D.
E.
Security
6 F.
Engineering / Technical
Support
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G.-
Safety Assessment /
2 Quality Verification Unit 1 Unit 2 COMMON III IV V III IV V III IV V TOTALS
1 1 16
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2.
Special Inspection Summary
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Significant inspections conducted during this SALP 8 assessment period are listed below:
a.
From March 1, through May 5, 1989, a special inspection regarding the testing ard design of the A and B station batteries was conducted (Inspection Report Nos. 266/89016; 301/89015).
b.
From May 22, through June 14, 1989, a special inspection of the emergency preparedness program was conducted (Inspection Report Nos. 266/89013; 301/89012).
c.
From June 19, through-June 30, 1989, a special team-inspection of the emergency operating procedures was Leonducted (Inspection Report Nos. 266/89019; 301/89018).
d.
From November 7, through December 22, 1989, a special inspection of the design of the DC distribution system
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was conducted (Inspection Report Nos. 266/89033;
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301/89033).
e.
From March 13, through 16, 1990,- an emergency preparedness exercise was conducted (Inspection Report Nos. 266/9000;-
301/90006).
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From March 12, through April 13, 1990, a headquarters EOSFI team' inspection of the electrical distribution system was conducted (Inspection Report Nos. 266/90201; 301/90201).
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C.
Escalated Enforcement Actions 1.
An enforcement conference was held with the licensee on May 10, 1989, to discuss security issues. No escalated enforcement action resulted from this conference.
(Enforcement Case No. EA-89-074, Inspection Report Nos. 266/89014;301/89013).
2.
An enforcement conference was held with the licensee on June 2, 1989, to discuss issues involving station batteries. No
escalated enforcement action resulted from this conference.
(Enforcement Case Nt., EA-89-117. Inspection Report Nos. 266/89016; 301/8W15).
3.
An enforcement conference was h31d with the licensee on September 6, 1989, to discuss several-issues pertaining to radiation protection. No escalated enforcement action resulted resulted from this conference.
(Enforcement Case No. EA-89-174, Inspection Report Nos. 266/89022;301/89021)-,
4.
An enforcement conference was held with the licensee on January 16, 1990 to discuss ~ concerns with corrective action and commitment tracking programs. A civil penalty in the amount of
$87,500 was issued on April 17, 1990, based en the untimely correction of identified deficiencies.
(Enforcement No. EN-90-45 Enforcement Case No. EA-8:s-254, Inspection Report Nos, 266/89033; 301/89033).
5.
An enforcement' conference was held with the licensee on May 25, 1990, to discuss several issues pertaining to radiation protection.
No escalated enforcement action resulted from this conference.
!
(Enforcement Case No, EA-90-099, Inspection Report Nos. 266/90012; 301/90012).
D.
Confirmatory Action Letters None.
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E.
Review of Licensee Event Reports (LERs)'
Co11ectively, 27 LERs were issued during this SALP assessment period, in accordance with NUREG-1022 guidelines.
Unit 1 LER Nos.:
89001 through 89010 and 90001 through 90009.
Unit 2 LER Nos.:
89003 through 89009 and 90001.
Table 2 below, shows cause area counts by units:
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... __. - _ _ _ _ _ _ _ _ - _ _ _
_ _ _ _.
_ _.
. _ _ _
. _ _ _ _ _ _ - _ _ _ - _ -
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TABLE 2 Number of LERs by Cause
.Cause Areas Unit 1 Unit 2 Personnel Errors
1 Design Deficiencies
0 External Causes
0 Procedure Inadequacies
2 Equipment / Component
5 Other/ Unknown
0
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TOTALS
8 Table 3 below shows a cause code comparison of SALP 7 and SALP 8 TABLE 3
,
18-Month 17-Month-Cause Areas SALP VII SALP VIII Personnel Errors 3 16.7%
5 18.5%
Design. Problems 3 16.7%
6 22.2%
External Causes-
-0 0.0%
0.0%
Procedure Inadequacies 4 22.2%
7.4%
Component / Equipment 8 44.4%
14 51.9%
Other/ Unknown
0.0%
0.0%.
~ TOTALS,
.
27 FREQUENCY (LERs/MO)
1.0 1.6.
. NOTE:: The above information was derived from a review of LERs performed by the NRC Staff and may not completely coincide with the-licensee's cause assignments.
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