IR 05000267/1986012
| ML20207F075 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/17/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20207F055 | List: |
| References | |
| 50-267-86-12, NUDOCS 8607220476 | |
| Download: ML20207F075 (36) | |
Text
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SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report 50-267/86-12 Public Service Company of Colorado Fort St. Vrain Nuclear Generating Station March 1, 1985 - May 6, 1986
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I.
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated Nuclear Regulatory Commission (NRC) staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information.
SALP is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations.
SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operation.
An NRC SALP Board, composed of the staff members listed below, met on June 10, 1986,-to review the collection of performance observations and data and to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at Fort St. Vrain Nuclear Generating Station (FSV) for the
period March 1, 1985, through May 6, 1986.
The SALP Board for FSV met June 10, 1986; it was made up of the following individuals:
E. H. Johnson, Director, Division of Reactor Safety and Projects (DRSP) RIV R. L. Bangart, Director, Division of Radiation Safety and Safeguards, RIV H. Berkow, Project Director, Standardization and Special Projects, Directorate NRR J. E. Gagliardo, Chief, Reactor Projects Branch, RIV R. E. Ireland, Chief, Engineering Section, RIV J. P. Jaudon, Chief, Project Section A, RIV i
K. Heitner, Project Manager, NRR R. Farrell, Senior Resident Inspector, RIV Other personnel who participated were:
W. C. Seidle, Technical Assistant, DRSP, RIV C. S. Hinson, Project Manager, NRR j
L. A. Yandell, Chief, Emergency Preparedness and Safeguards Safety
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Section, RIV B. Murray, Chief, Facilities Radiological Protection Section, RIV J. R. Boardman, Reactor Inspector, Operations Sections, RIV II. CRITERIA Licensee performance was assessed in 11 selected functional areas.
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l Functional areas normally represent areas significant to nuclear safety
and the environment.
One or more of the following evaluation criteria were used to assess each
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functional area.
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Management involvement and control in assuring quality 2.
Approach to the resolution of technical issues from a safety standpoint 3.
Responsiveness to NRC initiatives 4.
Enforcement history
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5.
Operational events (including response to, analysis of, and corrective actions for)
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Staffing (including management)
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definitions of these performance categories are:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and construction quality is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety and construction quality is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory perform-ance with respect to operational safety and construction quality is being achieved.
III. SUMMARY OF RESULTS In plant operations, licensee performance generally improved. Adherence to procedures, operating logs and control room formality improved during this SALP assessment period. The overpower event at the end of SALP period indicates that further work with individual operators is needed.
In areas of maintenance and licensing activities an improving trend in performance at the end of the SALP period was noted.
Performance in physical security declined early in the SALP period. As a result of an NRC enforcement conference in December to discuss deficiencies in the physical security program, significant improvements were committed t.
-3-A recent inspection, outside the time frame of this assessment has established that these improvements are underway and on schedule.
Performance in the area of emergency preparedness declined during this period, and it is apparent that a similar commitment to correcting deficiencies will be needed.
Performance'in_the functional area of quality programs and administrative programs affecting quality continued to be rated in Category 3.
Staffing levels need to be increased and leadership improvements must be made in the quality assurance organization so that the capability to identify and get corrective actions for deficiencies is strengthened.
Immediate and effective action is needed to upgrade this program to correct past deficiencies.
The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period.
Previous Present Performance Category Performance Category Functional Area (10/1/83 to 2/28/85)
(3/1/85 to 5/6/86)
A.
Plant Operations
2 B.
Radiological Controls
1 C.
Maintenance
3 (with a positive trend)
D.
Surveillance
2 E.
Fire Protection
1 F.
3 G.
Security
3 H.
Outages
I.
Quality Programs and
3 Administrative Controls Affecting Quality J.
Licensing Activities
3 (with a positive trend)
K.
Training and Qualification
2 Effectiveness Forty-six NRC inspections were conducted during this SALP assessment period, involving 3645 direct inspection man-hours.
- No assessment this perio,
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-4-IV. PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis This area has been inspected on a continuing basis by the NRC senior resident inspector and on many occasions by NRC regional inspectors.
Specific areas included operating procedure reviews, Technical Specifications (TS) compliance, operational safety verifications, safety system walkdowns, licensee event report l
reviews, and plant tours.
Three violations of NRC regulatory requirements were identified in this functional area as listed below:
Violation of a TS LCO involving differential helium pressure.
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(Severity Level IV, 50-267/85-17)
Failure to report nonemergency event within 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />.
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(Severity Level IV, 50-267/85-25)
Power in excess of authorized operating limit (Severity
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Level III, 50-267/86-16)
There were 31 licensee event reports (LERs) issued that were associated with plant operations as listed below:
LER Number Event 85-007 Discovery of blocked prestressed concrete reactor vessel penetration pressurization supply lines85-008 Reactor scram on high count rate, startup Channel 1 85-009 Loop I automatic shutdown initiated by plant protective system 85-010 Reactor scram on high moisture indication and automatic shutdown of Locp I
- 85-011 Loop I shutdown due to loss of bearing water indication i
85-012 Moisture ingress resulting in reactor scram on high moisture, Loop II shutdown l
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- 85-013 Loop II steam generator penetrations
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not pressurized above cold reheat pressure with reactor pressure greater than 100 psia 85-014,85-015, Helium circulator trips (some circulator trips are no longer reportable)85-016,.85-023,85-026, 85-031,86-001, 86-002,86-003,.86-007*
- 85-017 Unplanned actuation of the Plant Protective System scram circuitry during surveillance testing
- 85-018 Unplanned actuation of scram circuitry during investigative testing 85-019,85-025, Actuations of the rod withdrawal
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i 85-015,85-024, prohibit system (These are no longer
,86-004, 86-012 reportable.)85-020 Reactor shutdown in accordance with
.TS LCO 4.1.9
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- 85-027 Loop I shutdown due to operator error 85-030
"A" helium circulator trip on negative i
buffer-mid-buffer
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- 86-009 Operation in violation of LC0 4.4.1
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- 86-010 Loop II shutdown on loss of bearing water
- 86-013 Operation prohibited by TS
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- Indicates events attributed to personnel error.
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j There were two events late in the appraisal period that i
illustrate inconsistent licensee performance. On April 3,
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1986, there was a major snowstorm in the eastern Colorado area.
j The heavy, wet snow caused several intermittent losses of
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individual offsite power sources. At no one time were all five offsite power sources lost simultaneously. The intermittent
power failures did cause the intermittent loss of helium
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circulator auxiliary components, such as bearing water pumps and
l buffer helium compressors. The reactor was critical and at i
approximately 26 percent power.
The licensee chose to scram the i
reactor manually and put it in a safe, shutdown condition until
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the grid stabilized.
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-6-In the second event on May 6, 1986, a reactor overpower condition occurred for approximately 45 minutes.
The reactor had been limited to 35 percent power by a Commission Memorandum and Order dated November 26, 1985. During maintenance to correct an oil leak on a hydraulically operated block valve, a steam bypass control valve, which was being used temporarily as a block valve for the maintenance activity, leaked and passed steam around the high pressure turbine to the cold reheat line (i.e., helium circulator steam supply line). This caused an increase in reactor power up to a maximum of 42.6 percent.
The licensee failed to take effective action to rapidly reduce the power to the authorized level.
In one instance, plant operators chose a conservative course of action, but in the second event, the operators did not make a conservative choice. As a result, an enforcement conference was held and escalated enforcement action taken.
The reactor was not critical during most of the assessment period because of ongoing activities related to the control rod drive refurbishment project and the licensee's effort to meet the environmental qualification of equipment requirements of 10 CFR 50.49. The plant shut down after the assessment period to make necessary equipment qualification modifications.
A major water ingress into the reactor (i.e., approximately 300 gallons) occurred when a bearing water system for a helium circulator was being restored to service.
The actual cause was opening of valves in an incorrect sequence.
Licensee management reacted quickly to this event by temporarily removing the responsible operating shift from licensed duties for retraining.
The retraining was accomplished effectively and the details of the event, including its analysis, were promptly promulgated to all shifts.
The licensee has revised and improved operating logs.
This process is continuing to assure that these records are effectively used.
The licensee is maintaining a third licensed operator in the control room during operations. This is beyond TS requirements, and it appears to be a key factor in the improved performance noted. When the plant returned to operation, a significant improvement in operator self esteem was evident.
The licensee has improved control room demeanor and has restricted access to the control room in response to NPC
initiatives. Management involvement is evidenced by the observed increase in the presence of senior licensee personnel in the control and operating spaces.
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-7-The amount of overtime worked by the licensed reactor operators and senior reactor operators has been high but within the TS limits.
There are no new operators in the training pipeline.
2.
Conclusion Management has been increasingly inv 'ved in day-to-day operations.
This has improved the quality of operations and the shift performance has r;enerally improved.
The licensee's responsiveness to NRC initiatives has significantly improved and event reporting has become more l
complete and more timely.
I While licensee performance in operations has improved, the events of April 3 and May 6,1986, lead to differing conclusions concerning the licensee's understanding of the relative impor-tance to safety of various transients and operating events.
It appears that this is the result of individual differences in operators and not a pervasive problem of attitude.
The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this functional area should remain at its current level.
b.
Recommended Licensee Actions Licensee management attention in this functional area should remain at a high level.
The licensee should take action to increase the number of licensed reactor operators and senior reactor operators.
The licensee should also take steps to evaluate critically the performance of all shift supervisors and senior reactor operators and take appropriate corrective measures as indicated.
Specifically, knowledge of TS and other requirements should be assessed.
B.
Radiological Controls 1.
Analysis Five inspections concerning radiological controls were conducted during the assessment period by region-based radiation specialist inspectors.
These inspections involved the following areas:
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occupational radiation safety, radioactive waste management,,
radiological effluent control and monitoring, and transportation
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of radioactive materials.
Two violations were identified:
o Transfer of radioactive material to an unauthorized location
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(Severity Level IV, 86-02)
Failure to report an unplanned liquid radioactive release
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(Severity Level IV, 86-07)
a.
Occupational Radiation Safety This area was inspected twice during the assessment period.
The licensee maintains an adequate staff of well qualified
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health physics personnel to support plant operations. A turnover rate of about 30 percent was experienced among the health physics technicians on the permanent plant staff;
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however, it was noted that these vacancies were filled in a
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timely manter with qualified personnel.
In the previous SALP assessment, a concern was expressed regarding the.
increased workload for the Support Services Manager who is also the designated Radiation Protection Manager (RPM).
Observations during this assessment period did not identify any decrease in the effectiveness of the radiation protec-tion program because of the increase in the duties of the RPM.
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The licensee completed the control rod drive refurbishment project during this assessment period. The licensee main--
tained a comprehensive, aggressive radiation protection
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program during this project.
The licensee has not estab-lished written procedures which outline their ALARA program for ongoing routine work activities or action levels when special ALARA considerations are to be initiated for nonroutine work. The radiation controls placed in effect during the control rod refurbishment project included most of the features in Regulatory Guide 8.8, but a comprehensive
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ALARA program has not established procedures to assure that j
future activities comply with the recommended guidance.
The licensee's administrative procedures do not specify that senior health physics technicians have independent, step-work authority for matters involving radiation protection.
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Management oversight is provided by the RPM and the onsite
- O supervisory personnel in the radiation protection department.
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Corporate and onsite audits are also performed.
It was s.
noted that the checklists used during the onsite audits need to be expanded to assure that program areas such as t
regulatory requirements, ALARA activities, and personnel dosimetry receive a thorough review.
The licensee's corporate organization does not provide technical support or oversight of the onsite radiation protection program, although there is appropriate expertise a
on the Nuclear Facility Safety Committee.
The person-rem values at FSV continue to be well below the national average when compared to light water reactors.
The
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collective dose at FSV during 1985 was 35 person-rem.
This low exposure level is attributable to the low
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radiation levels inherent in the high temperature, gas cooled reactor design and also to the strength of the licensee's radiation protection program. The exposure at FSV for 1986 has been less than 1 person-rem.
No problems were identified concerning the radiological aspects of general employee training, radiation worker training, and training for the radiation protection staff.
b.
Radioactive Waste Management The licensee's program involving processing and onsite storage of gaseous, liquid, and solid waste was inspected
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i once during the assessment period. No problem areas were identified. This area was inspected during the early part of the assessment period and the licensee was in the process of establishing their solid radwaste program to comply with the requirements of 10 CFR 61.55 and 61.56.
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c.
Radiological Effluent Control and Monitoring The areas involving gaseous and liquid effluent controls and nionitoring, offsite dose calculations and dose limits, and radiological environmental monitoring were inspected once during the assessment period.
The need to install beta monitoring for the liquid effluent release pathway was discussed in the previous SALP report.
The licensee is continuing the review of this item. The liquid and gaseous
effluent sampling and analysis program are well defined with only minor program changes occurring during this assessment period. The turnover rate has been low among personnel responsible for performing radiochemistry analyses of effluent samples.
i No significant problems were identified during the
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inspection of the offsite radiological environmental i
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monitoring program.
The licensee has implemented a compre-hensive~ audit program for the environmental monitoring area to assure that a high quality program is maintained by the offsite contractor responsible for conducting the program.
The radiochemistry confirmatory measurement portion of this program area was not inspected during this assessment period.
A high quality program has existed in this area during the past several years.
d.
Transportation of Radioactive Materials This area was inspected once during the assessment period.
The inspection identified two violations involving the failure to perform quality assurance inspections required by 10 CFR 71. About 70 radioactive material shipments were made during the assessment period of which 40 shipments involved spent fuel.
No problems were identified in the areas of selection of packages, preparation of packages for shipment, delivery to carriers, receipt / acceptance of shipments, periodic main-tenance of packages, and records.
Position descriptions and implementing procedures had been established for transportation activities. No problems were identified concerning the training and qualifications of personnel responsible for the transportation program.
e.
Water Chemistry Controls This area was not inspected during this assessment period, but an inspection is scheduled during the next assessment period.
2.
Conclusions The licensee maintains on.Igressive radiological control program.
However, a writter ^> ! A > < > gram has not been established which includes the essei.t j :n 4 Ud program elements addressed in Regulatory Guide 8.8.
The radiation staff consists of an adequate number of well qualified personnel.
The licensee maintains high quality programs in the areas of radiological environmental monitoring, exposure controls, radio-active waste management, radiological effluent controls and monitoring, and transportation of radioactive materials.
Management oversight of the various radiological control program areas was evident by the performance of quality assurance (QA)
audits and program reviews; however the audit program did not s
identify that the licensee had failed to perform the necessary QA reviews for certain transportation activitie _
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-11-The licensee is considered to be in Performance Category 1 in
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this functional area.
3.
Board Recommendations a.
Recommended NRC Actions Consideration-should be given to reducing the NRC inspection effort in this area.
b.
Recommended Licensee Actions A permanent ALARA program should be established that includes the recommendations in Regulatory Guide 8.8.
The audit program for transportation activities should be reviewed to assure that all requirements are evaluated.
C.
Maintenance 1.
Analysis This area was inspected by region-based NRC inspectors and on a continuing basis by the NRC senior resident inspector.
Eight violations of NRC regulations were identified in this functional area as listed below:
Failure to follow maintenance procedures (Severity Level IV,
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50-267/85-07)
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Inadequate maintenance procedures (Severity Level V,
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50-267/85-07)
Failure to follow maintenance quality control (QC)
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procedures, violation of hold points (Severity Level IV.
50-267/85-07)
Failure to follow maintenance procedures, steps improperly signed off as properly completed (Severity Level IV, 50-267/85-07)
Failure to follow maintenance procedures requiring
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authorization signature (Severity Level V, 50-267/85-12)
Failure to follow maintenance procedures (Severity Level IV,
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50-267/85-14)
Inadequate maintenance procedures (Severity Level IV,
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50-267/85-14)
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Inadequate maintenance procedures (Severity Level IV,
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50-267/85-31)
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-12-There were five LERs issued in this functional area as listed below:
LER Number Event 85-021 Equipment deficiencies discovered during field inspections85-022
"B" circulator trip while draining buffer-mid-buffer knockout pot 85-028 Air flow in fuel storage facility did not meet TS requirements86-005
"B" circulator trip while draining buffer-mid-buffer knockout pot 86-008 Inoperable mechanical snubbers j
The licensee appears to have an acceptable maintenance program.
Maintenance management personnel appear knowledgeable, motivated, and committed to improving the maintenance program.
Although there is not an effective preventive maintenance program in all areas, the licensee is initiating one. The preventive maintenance goal appears to be the assurance of component reliability.
There were several violations in the maintenance area; however, these primarily occurred early in the assessment period.
Specifically, the licensee was able to utilize the experience gained early in the control rod drive mechanism refurbishment to improve the work procedures and quality of craftsmanship on this task.
The licensee has instituted a computerized program for the generation and tracking of maintenance work.
This facilitates more timely and 6ccurate maintenance performance.
This system will also enhance the licensee's records of equipment history.
The Performance Enhancement Program (PEP) includes a task to rewrite all maintenance procedures and to develop a preventive maintenance program. The licensee has made significant progress on this. The completion of the rewrite should enhance licensee performance in this functional area.
PEP has also resulted in improving craftsmanship.
2.
Conclusion There were many violations, but a strong management involvement to rectify the underlying causes of problems became evident in the latter part of the assessment period.
Remedial action is not yet complete, but it appears to be well directed.
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-13-t The licensee is considered to be in Performance Category 3, with a strong positive trend in this functional area.
3.
Board Recommendation a.
Recommended NRC Actions NRC activity in this area should remain at the current level until the licensee has completed the maintenance procedure rewrite effort and installed a preventive maintenance program.
Upon completion of the procedure rewrite and installation of the preventive maintenance program, a team inspection in this functional area is recommended.
b.
Recommended Licensee Action The licensee should maintain a high level of management involvement in this functional area to assure that adequate resources are available to complete the procedure rewrite and install the preventive maintenance program in a timely manner.
O.
Surveillance
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Analysis This area has been inspected on'a continuing basis by the NRC
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senior resident inspector and once by regional based inspectors.
There was one violation of NRC regulations identified in this functional area as listed below:
Failure to follow surveillance procedures (Severity Level IV,
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50-267/85-07)
There were six LERs issued in this functional area as listed
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LER Number Event 85-003 Battery cell failure identified during loss of outside electrical power test
- 85-006 Visual inspection of fire barrier seals not performed following maintenance.
- 86-006 Reheat steam temperature scram while performing surveillance test
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- 86-011 Loop II shutdown during performance of SR 5.4.1.2.8b-M
,86-016 Hydraulic power system surveillance not completed within specified time interval 86-018 Scram during surveillance, inadvertent reactor pressure scram actuated due to channel deficiency
- Indicates events due to personnel error.
During the assessment period, the licensee conducted surveillance testing required by the TS.
The TS are being revised and upgraded. This should result in significant changes in surveillance requirements.
The licensee's administrative means of tracking surveillance requirements are out of date in that the log has not been purged of requirements that are no longer valid.
Thus, the tracking system was somewhat confusing and had the potential to result in tracking errors.
Non-TS surveillances are also carried on the same log. On two occasions, reactor startup was delayed when operations personnel identified that a surveillance requirement, necessary for startup, had not been completed in a timely manner.
2.
Conclusion The licensee has a weak tracking system but has done an
acceptable job of maintaining surveillance tests current.
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The licensee is considered to be in Performance Category 2 in this functional area.
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3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program.
b.
Recommended Licensee Action Licensee management should improve the surveillance tracking system.
The licensee should also develop and validate surveillance requirements to implement the revised TS.
E.
Fire Protection 1.
Analysis i
This area was inspected by region based NRC inspectors as well as by the NRC senior resident inspector.
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-15-There was one deviation identified in this functional area as listed below:
Failure to meet fire protection rating for door of records
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storage area (Deviation, 50-267/85-16)
There were two LERs 'ssued in this functional area as listed below:
LER Number Event
- 85-029 Impaired fire barrier penetrations86-017 Impaired fire barrier
- Indicates event due to personnel error.
The licensee has substantially improved general housekeeping during this assessment period.
There was no accumulation of-combustibles noted during plant tours.
Control of combustible fluid leaks has been very good.
Observed fire drills did not indicate any problems, and fire prevention surveillances were conducted in a timely manner.
The licensee's plans to comply with the requirements of 10 CFR 50, Appendix R, are under staff review.
Some plant modifications may result from this review. As an interim measure, the licensee has established a program of roving fire watches as a compensatory measure.
The licensee is reevaluating fire hazards. This work-is being done by a consultant.
2.
Conclusions The licensee management has been responsive to NRC initiatives.
The improvement in general housekeeping has been impressive.
The licensee is considered to be in Performance Category 1 in
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this functional area.
3.
Board Recommendations a.
Recommended NRC Actions
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The NRC inspection effort in this area should be maintained consistent with the routine inspection program until completion of the review of the licensee's fire protection program.
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b.
Recommended Licensee Action Licensee action in this area should continue to focus on housekeeping, especially during the large construction effort to make modifications to comply with 10 CFR 50.49 requirements.
F.
Analysis During the assessment period, two emergency preparedness inspections were conducted by region-based and NRC contractor inspectors.
One was a routine, unannounced inspection of personnel proficiency, training, and audits which identified a violation:
Failure to provide adequate training to staff who may be called
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on to assist in an emergency (Severity Level IV, 8529-01)
The other inspection was an NRC team observation of the implementation of the emergency plan and procedures during the annual emergency
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preparedness exercise.
Ten deficiencies were identified as follows:
The exercise scenario was inconsistent and incomplete.
(8518-01)
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Controller and player exercise conduct training was inadequate.
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(8518-02)
Habitability surveys were not conducted in the control room.
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(8518-03)
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Habitability surveys in the TSC were inadequate.
(8518-04)
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Information flow in the TSC was inadequate.
(8518-05)
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Field monitoring results were not properly logged.
(8518-06)
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Training of personnel in radiological control procedures was
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inadequate.
(8518-07)
Site accountability was not adequately demonstrated.
(8518-08)
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Training of personnel to handle injured and contaminated persons
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was deficient.
(8518-09)
Direction and control of emergency response activities at the
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Forward Command Post were deficient.
(8518-10)
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~ The number and type of deficiencies identified indicated that the licensee's preparation for and conduct of the emergency preparedness exercise was not sufficiently effective in training emergency response staff and demonstrating the capability to meet all of the objectives established for the exercise. A large measure of improvement in the training of personnel and conducting exercises appeared to be needed.
During the period, the public alert and notification system which was found to be deficient by the' Federal Emergency Management Agency as a result of a survey conducted August 15, 1984; was again tested on June 18, 1985, and found to be improved but not up to an adequate level of effectiveness.
Because of this, the licensee continued to provide supplemental means for alerting and notifying the public'as identified in their let.ter to the NRC dated April 4,1985.
2.
Conclusions The licensee's performance during this assessment period appeared to decline significantly from that observed previously. The primary NRC concerns are focused on the licensee's weak performance during the annual emergency preparedness exercise and management response to the deficiencies identified during the exercise, as well as the lack of
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responsiveness to NRC findings indicated in the responses to the violations identified during the period.
While the findings of the NRC inspections during the assessment period indicate that, overall, the licensee's emergency preparedness program was adequate to protect the health and safety of the public, the NRC observations also indicate that management's commitment to a
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quality program was not demonstrated.
The licensee is considered to be in Performance Category 3 in this area.
3.
Board Recommendations
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a.
Recommended NRC Actions The NRC inspection effort should be increased to determine the root cause for the program decline and should be maintained until the quality of the licensee's program is improved.
b.
Recommended Licensee Actions The level of management attention to the implementation of the emergency preparedness program should be increased through increased emphasis on demonstrating preparedness during exer-cises, the use of the audit function to determine program adequacy in addition to conformance with requirements, and responding to NRC-identified items.
-
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-18-
G. Security
!
1.
Analysis
'
Five inspections were conducted by region based NRC physical security inspectors during the assessment period.
Twelve
violations and one deviation were identified. Two of the violations were identified as potential escalated enforcement and are currently under review at NRC headquarters.
Inadequate compensatory measures (Severity Level IV,
.
50-267/85-25)
Inadequate physical barriers protected areas (fences)
.
(Severity Level V, 50-267/85-28)
Inadequate. physical barriers protected area (isolation
.
zone) (Severity Level IV, 50-267/85-28)
,
Inadequate physical barriers protected area (bullet
.
res'istant glazing).
(Severity Level IV, 50-267/85-28)
l Inadequate assessment aids / lighting.
.
l 50-267/85-28)
Inadequate security program audit.
.
50-267/85-28)
,
j Inadequate security organization.
.
50-267/85-28)
i Inadequate testing and maintenance.
(Severity Level IV, 50-267/85-28)
,
'
Inadequate lock and key control procedures.
(Severity
'
.
Level V, 50-267/85-28)
!
Inadequate records and reports.
.
'
50-267/86-11)
i Inadequate physical barriers protected area (Severity
.
Level II, 50-267/85-28)
Inadequate physical barriers protected area (Severity
.
Level III, 50-267/85-32)
Failure to meet commitment for repairing intrusion
.
,
detection system (Deviation, 50-267/85-28)
'
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.
-19-Because of deficiencies in the protected area barriers, closed circuit television system, and the microwave detection system, the licensee has been using security personnel as compensatory measures for over a year.
2.
Conclusion
.
The licensee has demonstrated a lack of attention and appears to be less than dedicated, at the corporate and site management level, to promoting an adequate security program. While expertise and staffing in the security department appear to be
<
adequate, there appears to be an inability to gain management support for correcting potentially serious security deficiencies.
'
Security program audits have failed to identify many of the deficiencies in the security program and there has been little effort to implement corrections to those areas that were
'
identified during audits. The licensee appears to be slow in correcting basic security component deficiencies and instead relies on compensatory measures that have been in place for an excessive time period. While there has been an indication of some recent novement to correct these long term deficiencies, it has come only after being informed of escalated enforcement action.
The licensee is considered to be in Category 3 in this functional area.
-
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in security should be increased due to programmatic deficiencies and violations identified
during this assessment period.
,
b.
Recommended Licensee Actions The licensee should increase management attention to resolve
'
the weaknesses identified in the security area.
The following areas should be of particular concern:
An integrated system approach to fix or replace
.
security systems should be developed.
Until improvement is indicated, the security program
.
j should be frequently audited.
l Long standing deficiencies should receive management
.
attention.
The perimeter systems are especially in need of attention as indicated by the violations.
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!
H.
Outages
,
1.
Analysis A significant portion of this assessment period was spent in outages. Outages were essentially the result of these two
.
causes: NRC limitations resulting from the June 1984 control rod drive incident and the inability to meet limiting conditions of operation (usually high moisture levels in reactor coolant).
Design change control, previously evaluated separately, is included in this category.
There were five violations or deviations identified in this functional area as listed below:
>
Failure of diesel generator breakers to meet single failure
.
F criterion (Deviation, 50-267/85-20)
Failure to perform safety evaluation for installed
.
temporary gauges (Severity Level IV, 50-267/85-33)
Failure to review design change for suitability (lubricants)
.
(Severity Level IV, 50-267/85-33)
I Failure to maintain record of change (Severity Level IV,
.
50-267/86-06)
Failure to control design changes (Severity Level IV,
'
.
50-267/86-08)
The Control Rod Drive Mechanism refurbishment was completed during this assessment period.
The licensee also did a major
walkdown to verify equipment qualification status.
Some equipment qualification modifications were made with the plant operating. A major outage is currently underway to complete equipment qualification modifications. The licensee has completed some planning for this outage.
Past outage planning has demonstrated that there are problems in this process, i
However, planning for this outage was generally acceptable.
Outage scheduling has been a problem.
There was no group with specific scheduling responsibility.
Subsequently, both nuclear engineering and nuclear production undertook the scheduling task.
Past schedules have been optimistic and apparently not based on reasonable job definitions. Although " optimistic scheduling" is an often used management tool, it was not evident tnat it was being used in this context by the licensee.
'
The licensee has not chosen to utilize an outage manager system for outage planning.
The licensee has had difficulty in obtaining necessary repair parts in time to support plant work.
There have also been problems with providing work instructions
,
in a timely manner.
i
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__ _ _._ _ -. _..- _ _ _ _ _
_..,. _ _ _.. _ _. _ _ _, _. _ _ _.. _ _ _. _ _. _ _.. _ _. _ _ _. _, _ _ _,. _. _ _ _ _..
.
.
-21-The licensee also has a large backlog (approximately 800) of open design changes.
There is an internal commitment to reduce this backlog significantly during 1986.
It was not always evident that the licensee was in full control of the design change process.
For example, the nuclear engineering department developed plans for installing a steam line detection and isolation system to resolve equipment qualification concerns.
After an extensive NRC review of this change, the licensee's nuclear production department reviewed the design and significant changes were required as a result of these reviews.
Late changes of this type affect material procurement, work instructions, and licensee's final approval.
The process for 10 CFR 50.59 review utilizes licensing personnel. This has resulted in at least one case of a bad analysis being completed.
Specifically, when a 400 amp fuse in an inverter failed, and the licensee did not have a spare fuse available, a 10 CFR 50.59 review was completed which permitted the use of a 300 amp fuse. This analysis only considered the question of inverter protection and did not address the issue of whether the inverter could have performed its function under accident conditions while effectively derated by the smaller fuse.
In this instance, both plant management and the Senior Resident Inspector detected the error in the safety analysis before the small fuse was used during operation.
The PEP has addressed many of these problems and resources have been committed in an attempt to resolve the problems delineated.
,
2.
Conclusions Licensee management control has shown that they can concentrate resources on specific major problems, such as equipment qualifi-cation. There are, however, programmatic weaknesses in scheduling, planning, coordinating, and design change control.
The effectiveness of the PEP in this area has not been fully established. The safety evaluation process needs improvement.
The licensee is considered to be in Performance Category 3 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC should conduct an indepth team inspection of design change contro...
i-22-b.
Recommended Licensee Actions The licensee should focus additional management attention on design change control to reduce the large number of open design changes.
Licensee management should also focus on improving the planning, scheduling, and coordination of outages.
The 10 CFR 50.59 safety evaluation process should be critically reviewed.
I.
Quality Programs and Administrative Controls Affecting Quality 1.
Analysis This functional area includes all verification and oversight activities which affect or ensure the quality of plant activities, structures, systems, and components. This area can be viewed as the comprehensive management system for controlling the quality of work performed and for controlling the quality of verification activities that are intended to confirm that the work was performed correctly. Appraisal in this area is based on the results of management actions to ensure that the necessary people, procedures, facilities, and materials are provided and used during the operation of the plant.
Emphasis in the appraisal of this area is placed on the effectiveness and involvement of management establishing and ensuring the implementation of the QA program. Also considered in this area is the licensee's performance in the areas of committee activities, design and procurement control, control of design change processes, inspections, audits corrective action system, and records.
This area has been inspected on a continuing basis by the NRC senior resident inspector and on several occasions by NRC regional inspectors.
Specific areas included:
procurement, control of nonconforming items, procedures, maintenance inspection, audits, change control, and safety committees.
Fourteen violations and one deviation of NRC regulations and licensee commitments were identified in this functional area as listed below:
Improper control rod drive and orifice assembly (CRD0A)
.
parts procurement (Severity Level IV, 50-267/85-03)
,
i
.
.
-23-Failure to take timely corrective action to revise
.
administrative procedures (Severity Level IV, 50-267/85-06)
Failure to take prompt corrective action (Severity Level IV,
.
50-267/86-02)
Failure to follow procedures for Plant Operations Review
.
Committee (Severity Level IV, 50-267/86-08)
Failure to follow TS requirement for Plant Operation Review
.
Committee (Severity Level V, 50-267/86-08)
Failure to submit annual design change report within
.
required time (Severity Level IV, 50-267/86-08)
Failure to identify QC inspection points (Severity Level IV,
.
50-267/85-07)
Failure to control nonconforming item (Severity Level IV,
.
50-267/85-07)
Failure to follow procurement procedures (Severity Level IV,
.
50-267/85-11)
Failure to conduct QA receipt inspection (Severity Level IV,
.
50-267/85-11)
Failure to follow procurement procedures, received item not
.
put on hold until documentation complete (Severity Level V, 50-267/85-15)
Inadequate audits of emergency preparedness (Severity
.
Level IV, 50-267/85-29)
Inadequate audits of security (Severity Level IV,
.
50-267/85-28)
Inadequate procurement QA (Severity Level IV, 50-267/85-31)
.
No continuity of personnel on the Plant Operations Review
.
Committee (Deviation 50-267/86-08)
_,-- -.
,- - - - -
-
.
O-
-24-Individual performance by members of QA often showed a high degree of technical competence. A sample of high energy piping was inspected to the ASME B&PV Code,Section XI, prior to the plant restart. NRC inspectors monitored this activity very closely and identified no violations of NRC regulations.
The inspection team was very impressed with the performance of the inspections.
Management direction and support are very weak.
For example, the audit area was staffed with a supervisor and two or three full time auditors.
Other auditors, with particular specialized areas of expertise, were assigned to other work groups within QA.
The other auditors were often not available to conduct audits, even when their areas of special expertise were clearly required. Audits in Emergency Preparedness, Security, and Health Physics were not conducted with appropriate expertise.
As a consequence, subsequent NRC inspections identified violations which should have been found by the licensee. Also, QA management independence has not been fully demonstrated in practice, although organizationally, such independence exists.
The licensee is currently revising the audit program to strengthen and improve the quality of audits and is also in the process of developing a QA monitoring (surveillance) program.
The audit group is, however, seriously undermanned and technical expertise in areas audited is often nonexistent on the audit team.
QA is reviewing the plant surveillance records for procedure adherence and TS compliance.
Procurement and maintenance QC activities have been strengthened and increased, and show improved performance.
The effect of the PEP program at enhancing performance in QA was not evident.
This department appeared to have low self esteem as a group, despite the fact that some individuals were apparently dedicated.
This has not necessarily been a deficiency of the PEP, but may reflect management's implementation of the PEP in this area.
For the latter third of this assessment period the position of Vice President of Power Production was vacant.
Executive level oversight of nuclear activities was carried out by the President. Although he carries numerous additional duties, it was apparent that some of the plant activities, such as physical security, have benefited from this.
In the management and
,
supervisory levels of the organization effective control and
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-25-2.
,
J coordination of nuclear activities was hampered by poor
!
communications between departments.
The licensee's PEP is addressing this issue and providing individualized training l-to improve the supervisory and management ability of the staff.
Late in the SALP period a network of." quality circles" was formed to define areas needing improvement and recommend fixes, j
2.
Conclusion The QA department has been understaffed in some areas, has not
been well coordinated, and has not produced uniformly.
I i
The licensee has demonstrated a commitment to improving the company's nuclear activities and oversight of these activities
through the PEP. Although this is a long-range program (3 to 5
years), the licensee has achieved some success in improving
~
performance in this functional area since the beginning of the assessment period.
,
The licensee is considered to be in Performance Category 3 in i
this functional area.
3.
Board Recomn;endations
'
e i
a.
Recommer.ded HRC Actions i
Inspection activity in this functional area should be i
increased.
Team inspections of procurement, auditing, design control, QC, and QA administration should be i
performed during the next assessment period.
l l
b.
Recommended Licensee Action t
!
The licensee should critically evaluate the QA department j
to assure that it is properly staffed and effectively directed.
This should include absolute verification of i
the independence of QA.
The PEP should be aggressively pursued and its results periodically measured against the original goals to i
'
determine that its objectives are being achieved.
J.
Licensing
1.
Analysis
'
$
The licensee's performance evaluation is based on consideration i
!
4
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.
-26-of six of the seven attributes specified in NRC Manual Chapter 0516.
Those considered are:
Management Involvement and Control in Assuring Quality
.
Approach to Resolution of Technical Issues from a Safety
.
Standpoint
.
Responsiveness to NRC Initiatives
.
Staffing (of Licensing Actions)
.
Reportable Events
.
Training Effectiveness and Qualification
.
a.
Management Involvement and Control in Assuring Quality PSC's management has shown attention to planning and prioritization in the conduct of its licensing activities and has been able to prioritize and schedule many of its licensing submittals effectively. Major submittals scheduled well in advance, such as the final draft of the TS Upgrade Program and the preventive maintenance program for the control rod drive mechanisms, have been submitted on time. However, coordination between PSC's licensing, production and engineering divisions remains weak.
For example, a large number of spurious control rod withdrawal prohibits occurred and were reported in the October 1985 plant startup and have continued to occur since then. Although this is not a major safety issue, it is extremely undesirable from an operational perspective, and the staff has indicated this to PSC repeatedly.
Resolution of this problem has been slow. While PSC has finally eliminated.he overcurrent trips, the high rate-of-change prohibits persist.
Since there are no technological barriers to resolving the problem, we can only conclude that it reflects a lack of management interest and attention.
PSC has demonstrated a capability for high quality work that is timely, thorough and technically sound.
PSC's submittals supporting many elements of the technical basis for operating FSV at 35 percent power during the extension for equipment qualification were comprehensive.
However, in too many cases, management establishes overly optimistic schedules that result in slippages or quality being compromised. As an example, inspection of high energy piping was a confirmatory action for the 35 percent power approval.
PSC initially proposed an inspection based on only four locations in the piping system.
The staff found this proposal totally inadequate because it did not address
,
.
-27-the variety of pipe sizes, materials of construction and types of welds in the piping systems. Many more locations were required to_obtain a suitable sample. PSC management must emphasize more indepth planning in approaching problem resolution even if implementation of such plans and production of quality products require more time and effort than the " quick fix" path frequently chosen.
PSC has had difficulty in some areas such as equipment qualification because of poor historical records..However, PSC has been willing to put forth the extra effort needed to compensate for such problems and improve its record keeping ability.
PSC's Performance Enhancement Program emphasizes greater management involvement and is indicative of its recent internal efforts to address these problems. The PEP program plan and progress to date have been favorably reviewed by the staff.
On the basis of the above observations, a rating of 3 is assigned to this attribute.
b.
Approach to Resolution of Technical Issues From a Safety Standpoint The PSC licensing staff appears to have a general understanding of most licensing issues.
However, the initial PSC approach to resolution of many licensing issues is to meet only the minimum requirements. While this approach is generally viable, it results in a lack of thoroughness in addressing the basic safety problems. Too often, PSC relies on the general perception that Fort St.
Vrain is inherently more safe than light water cooled plants.
Also, PSC is overly concerned about delaying plant operation.
Subsequently, the inadequacy of PSC's approach becomes obvious to both the staff and PSC. When basic questions about the issue cannot be answered, the licensee must then expend additional effort to resolve the problem.
Tyoically, this lengthens the schedule for resolution of technic.l issues.
Clearly, PSC needs to refine its approach to resolving technical issues, with emphasis on assuring that problems are thoroughly evaluated and resolved prior to making licensing submittals to the NRC.
A current example of thfs type of problem concerns PSC's submittal on Appendix R, fire protection, and safe shutdown.
PSC's original analysis of the resolution of this problem was submitted over a period of several months in early 1985.
Now, PSC has notified the staff that a fundamental report which supports this analysis is not recoverable from files and will have to be redon.
.
-28-If PSC had planned methodically, the required analysis would have been available to resolve the staff's concerns, or PSC would have recognized earlier that the document was not available and taken the necessary steps to replace it.
Now, resolut:on of this major licensing action is seriously delayed while the supporting analysis must be redone.
A similar lack of thoroughness was found in PSC's submittals concerning the ability of the operators to function in high temperature environments using ice vests and air packs.
PSC's initial submittals merely asserted that this was possible.
It was only under prolonged inquiry by the NRC staff that PSC subsequently supplied more thorough documen-tation of this subject area and their preparations for implementation in the plant.
The staff further notes that the temperature ranges that were realistically supported by the more detailed data were smaller than PSC had originally asserted.
Based on the performance described above, the rating of 3 is assigned to this attribute.
c.
Responsiveness to NRC Initiatives PSC has generally provided timely responses to NRC initiatives.
Some of these responses have been adequate to resolve the issues; others have not. Where inadequate responses have been received, additional NRC effort and new submittals have been required to resolve problems.
For example, of the approximately 60 action items identified in the TS Upgrade Program, only about half were resolved in PSC's final draft submittal.
Considerable additional work remains to resolve these open items in order to complete this licensing action.
PSC has instituted a system for tracking licensing action requests and related commitments.
This has improved their ability to track the large number of open licensing issues on FSV.
Thus, PSC recently has been able to respond to most staff requests for additional information in a timely fashion or provide a letter indicating when the response would be submitted, It has also minimized the number of issues where extended resolution could be attributed to PSC inaction, that is, a greatly delayed response.
Following the recent accident at the Soviet Chernobyl nuclear plant, many questions were raised concerning design similarity between Chernobyl and FSV and continued safe operation of FSV.
PSC was very responsive to staff requests for information and produced high quality answers with supporting analyses on very short schedule..
._ -. -
_ -. -
b
.
-29-Based on the performance characterized above, the rating of 2 is assigned to this attribute.
d.
Staffing (Of Licensing Actions)
,
PSC's staffing of licensing action responses is adequate on most issues. At meetings with the NRC staff, PSC management, technical staff, and consultants usually are well organized and prepared.
This reflects a clear definition of roles and responsibilities on licensing issues.
PSC's licensing staff generally has handled the responses to licensing issues in a timely fashion. As noted earlier in the Management Involvement attribute, several major long-term submittals
!
have been on schedule.
However, considerable schedule
'
slippage has occurred in responding to other licensing actions.
For example, although the initial submittals on the Steam Line Rupture Detection and Isolation System
i (SLRDIS) were timely, PSC decided to redesign the system.
The submittal reflecting the changes to the design and the associated Technical Specifications were not timely and will likely be critical path items in completing the equipment qualification program.
Failure to coordinate the initial
>
design of SLRDIS with the plant operating staff in its early stages reflects both inadequacy of management controls and a lack of resources to get important work done correctly.
i Even when the problems were recognized and acted upon, limited staff resources delayed submittals to the NRC.
I On the other hand, PSC has acknowledged that its staffing was not adequate in many areas. Through the Performance Enhancement Program, PSC is taking measures to strengthen its staff.
The PEP includes efforts to build the PSC
nuclear staff and make the existing resources work more effectively.
PSC must continue to carefully monitor its allocation of resources to assure that licensing issues are addressed and resolved more efficiently and effectively.
I Based on the performance described above, the rating of 3 is
assigned to this attribute.
e.
Reportable Events
!
FSV has had some operational events where the NRR staff has requested informal discussions with PSC in order to more
'
fully understand the event.
PSC has reported these events in a timely manner.
In these cases, we have noted that the initial informal (verbal) event reports have not always been
complete or accurate.
Also, in general, the PSC licensing staff relies too heavily on the plant staff for explanations
of events rather than developing a sufficient understanding on their own.
Further, while the formal reports are more i
,
.i
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detailed, post-event analysis and corrective follow-through of events are sometimes weak.
Root causes for component or
"
system failures are not clearly identified and corrected.
,^
One example of this weakness is the persistent problem of
-
spurious control rod withdrawal prohibits noted previously.
A second is the continuing weakness in the circulator
,
support systems, most recently apparent in the April 3, 1986,
'
failures during and following the plant shutdown due to grid disturbance. Although FSV is a unique facility, and has
.
many complicated supporting systems, PSC should continue to
!
improve its ability to evaluate operating events both from a safety and operational (reliability) viewpoint.
Based on the performance characterized above, the rating of l
3 is assigned to this attribute.
!
f.
Training Effectiveness and Qualification
PSC has proposed comprehensive personnel training as part of
'
its PEP.
In an evaluation dated October 3, 1985, the staff i
found that the licensee's proposed efforts in this area were significant.
They included:
i
)
. Additional manpower to help meet INPO accreditation requirements
'
. Training to include nuclear licensing and fuels, i.e.,
areas outside of INP0's program
. Formal training for entry into new positions
. Other enhancements to the training program In addition, PSC has evaluated the effectiveness of these
programs through an independent consultant (S.M. Stoller i
Corporation). The consultant concluded that the approach l
embodied by the PEP was good, but it would take several I
years for the full impact of these changes to be realized.
Based on the performance described above, the rating of 2 is assigned to this attribute.
I 2.
Conclusions
!
PSC's licensing staff has demonstrated an improving ability to
'
work with the NRC in recognizing and resolving licensing issues.
Progress made in returning the plant to power operation and
-
closing some licensing issues indicates that the basic capabili-ties for effective licensing are present.
However, because of j
the number of major licensing issues still open, PSC must l
continue to upgrade and strengthen its licensing staff.
Fort
St. Vrain's licensing activities are anticipated to continue at
-
a very high level for some time in the future.
Emphasis should i
i
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.
-31-
,
)
be placed on understanding the NRC's safety perspective on licensing issues.
PSC should also work on a thorough review of
<
the approaches used to resolve licensing issues.
PSC should continue to work toward resolutions that clearly meet or exceed NRC standards and requirements, as opposed to attempting to do
,
only marginal or inadequate resolutions.
Continued emphasis
,
should be placed on understanding relevant generic and plant-specific issues for light water reactors as well as for FSV.
PSC should also continue to diligently resolve its outstanding
i licensing issues with the NRC.
PSC's efforts to develop its i
human resources are commendable and should continue, j
Based on the assessment described above, the SALP Board assigns
-
an overall performance rating of 3 to PSC. However, PSC's performance in this area has had an upward trend during the appraisal period. Although it is recognized that PSC's efforts
,
{
in this functional area are improving, FSV's future performance
will require a constant, high level of attention by both the licensee and the staff.
,
3.
Recommendations
'
'
!
!
Both NRC and PSC should continue to provide a high level of i
management and tectnical attention to the resolution of
licensing issues.
I K.
Training and Qualification Effectiveness l
}
1.
Analysis This area was inspected on a continuing basis by the NRC senior
resident inspector and on several occasions by NRC regional inspectors.
There were no violations of NRC regulations identified in this
functional area.
i The licensee, during this assessment period, has increased the I
training staff adding degreed, experienced, professional teachers i
as well as licensed reactor operators to the training staff. The l
licensee is actively pursuing INPO accreditation of all facets of j
the training program and expects the first INPO certifications shortly.
'
j The overpower occurrence of May 6, 1986, indicated a weakness of
,
licensed senior and operator training concerning the limitations I
under which the plant is to be operated. An assessment of the
}
requalification training program has found it to be a marginal l
,
program, t
!
i (
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.-,
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+
o-
-32-2.
Conclusion The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection activity in this functional area should be consistent with the routine inspection program except that it should be increased in the area of requalification training, b.
Recommended Licensee Action Management attention'should continue to pursue INP0 accreditation of all facets of the training program, with early emphasis on strengthening requalification training.
V.
SUPPORTING DATA AND SUMMARIES A.
Licensee Activities The licensee completed refurbishment of all control rod drive and orifice assemblies during the assessment period.
The reactor is currently shutdown for an extended environmental qualification modification outage. Planning and preparation for this outage have consumed substantial licensee effort throughout the assessment period. Additionally, the licensee has been working toward a complete revision of the TS.
The above activities have run concurrently with the institution of a wide ranging, long term Performance Enhancement Program.
The reactor achieved criticality in July 1985 for the first time since the control rod failure-to-bottom incident of June 1984.
The turbine generator was returned to the licensee's electrical grid in April 1986, under an exemption from 10 CFR 50.49 requirements. This exemption expired on May 31, 1986.
In November 1985, the Vice President of Power Production left PSC and the position had not been filled at the time of the SALP Board meeting.
The licensee's CEO has direct executive responsibility for the plant.
B.
Inspection Activities Major inspection activity during this assessment period included 46 NRC inspections involving 3645 direct inspection man-hours.
These inspections included the control rod drive orifice assembly refur-
,
.*
-33-bishment, performance appraisal team (PAT) inspection, a full state participation emergency response plan drill, QA team inspection, and a team inspection of maintenance.
Table 1 provides a tabulation of NRC enforcement activities for each functional area evaluated.
C.
Investigations _and A11egati'ons Review No major investigative activities were conducted during this SALP evaluation period.
D.
Escalated Enforcement Action Two enforcement conferences were conducted with the licensee during this assessment period.
An enforcement conference was conducted on April 25, 1985, concerning the results of NRC Inspection Report 50-267/85-07 covering maintenance and QC activities in supporting the control rod drive orifice assembly refurbishment.
An enforcement conference was conducted with the licensee on December 13, 1985, concerning NRC Inspection Reports 50-267/85-28 and 50-267/85-32 regarding security. Additional enforcement action resulting from these inspections is currently under evaluation.
An enforcement conference was held May 9, 1986.
This was outside the evaluation period, but the event which caused the enforcement confer-ence occurred May 6, 1986, within the evaluation period.
Escalated enforcement action for this event is under consideration.
E.
Licensee Conferences Held During Appraisal Period The licensee is currently under a PEP and makes a quarterly presentation to the NRC regarding their propress with this program.
An ACRS subcommittee meeting was conducted suring the assessment period to Feview the licensee's conduct of operations, control rod drive and orifice assembly refurbishment, PEP, and operating histo:y.
Additionally, numerous licensee conferences and meetings have been conducted with NRR, I&E, and Region IV regarding the TS upgrade program, environmental qualification of equipment, and PEP
,
activities.
F.
Confirmation of Action Letters During this assessment period, there were two Confirmation of Action letters and one Commission Order as listed below:
o
.
-34-July 19,1985 (R. D. Martin to 0. R. Lee) Confirmation of
.
Action letter authorizing operation of FSV at power levels not to exceed 15 percent power.
September 30,1985 (R. D. Martin to 0. R. Lee) Confirmation of
.
Action letter authorizing operation of FSV at a power level no greater than 8 percent for a period of up to 45 days, rot to extend beyond November 30, 1985.
February 7, 1986 (H. R. Denton to R. F. Walker) implementing the
.
Commission Order authorizing operation of FSV not to exceed 35 percent power through May 31, 1986.
G.
Licensee Event Reports There were 47 LERs during the assessment period.
Fourteen of these LERs were attributed to personnel error.
Circulator trips and rod withdrawal prohibits have been determined not to be reportable under 10 CFR 50.72 and 10 CFR 50.73. Of the 47 LERs submitted during the assessment period, 13 involved circulator trips and 7 involved rod withdrawal prohibits including 3 due to personnel error.
Consequently, there were 27 actual events requiring submittal of an LER.
Consequently, 41 percent of the LER events (11 of 27) involved personnel error.
This indicates a need for greater attention to detail on the part of personnel working in the plant, both licensed operators and equipment technicians.
See Attachment I for AE00 analysis of LERs.
H.
Violation Data FUNCTIONAL AREAS NUMBER OF VIOLATIONS IN EACH LEVEL DEVIAfl0N V
IV ITI 0THER
-
1.
Plant Operations
1 2.
Radiological Controls
3.
Maintenance
6 4.
Surveillance
5.
Fire Protection
6.
7.
Security
2
1
- 1
- (Level II)
o o
o
!
-35-FUNCTIONAL AREAS NUMBER OF VIOLATIONS IN EACH LEVEL DEVIATION V
IV III OTHER 8,
Outages
4 9.
Quality Programs and
2
Administrative Controls Affecting Quality 10.
Licensing Activities 11. Training and Qualification Effectiveness 4