IR 05000298/1986008
| ML20197B106 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 10/21/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20197B104 | List: |
| References | |
| 50-298-86-08, 50-298-86-8, TAC-61808, NUDOCS 8610280017 | |
| Download: ML20197B106 (45) | |
Text
SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report 50-298/86-08 Nebraska Public Power District Cooper Nuclear Station February 1,1985 through July 31, 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 September 9, 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 Cooper Nuclear Station for the period February 1, 1985, through July 31, 1986.
SALP Board for Cooper Nuclear Station:
E. H. Johnson, Director, Division of Reactor Safety and Projects, RIV J. E. Gagliardo, Chief, Reactor Projects Branch, RIV W. L. Fisher, Chief, Radiological and Safeguards Programs Branch, RIV D. Muller, Director, BWR Prcjects Directorate No. 2, NRR J. P. Jaudon, Chief, Project Section A, RIV W. O. Long, Project Manager, NRR D. L. DuBois, Senior Resident Inspector, RIV Other personnel who participated in all or part of the SALP Board were:
W. C. Seidle, Chief, Technical Support Staff, RIV L. A. Yandell, Chief, Emergency Preparedness and Safeguards Program Section, RIV R. Baer, Reactor Inspector J. Kelly, Security Inspector E. A. Plettner, Resident Inspector, RIV C. K. Chen, Observer II.
CRITERIA Licensee performance was assessed in 11 selected functional areas.
Functional areas normally represent areas significant to nuclear safety and the environmen.
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One or'more of the following evaluation criteria were used to' assess'each~
functional area.
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A.
Managementinvolvementandcontrolinass'uringqualit['
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Approach to the resolution of technical-issues from-a safety
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standpoint
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C.
Responsiveness to NRC initiatives y
D.
Enforcem. int history E.
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 is being
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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 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 performance with respect to operational safety is being achieved.
III. SUMMARY OF RESULTS Overall site operations were well managed, with the exception of security.
Plant operations, licensing and outage control were noteworthy strengths.
Good individual performance was the apparent key element in most functional areas.
Programmatic infrastructure is generally weaker than observed performance.
The potential hazard of this situation is that the
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loss of a few key individuals could result in a drasticLreversallof performance. The area of security needs continuing: attention as'does.
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emergency preparedness training.
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The licensee's performance is summarized in the table below, along with
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the performance categories from the previous SALP evaluationJperiod.~
Previous
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Present
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Performance Category Performance Category Functional (7/1/83 to 1/31/85)
(2/1/85 to 7/31/86)
A.
Plant Operations
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Radiological Controls
2 C.
Maintenance
2 D.
Surveillance 2-
E.
Fire Protection
2 F.
2 G.
Security
3 H.
Outages
1 I.
Quality Programs and
2 Administrative Controls Affecting Quality J.
Licensing Activities
1 K.
Training and Qualification
2 Effectiveness Forty-nine NRC inspections were conducted during this SALP assessment period, involving 4929 direct inspection man-hours.
NRC inspection reports issued during this assessment period were:
85-05 through 85-33
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86-01 through 86-22
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IV.
PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis-This area was inspected on a continuing basis by the NRC _
resident and regional inspectors.
Those inspections included operational safety verifications, safety system walkdowns, plant startups and shutdowns,' plant-wide housekeeping, licensee events, operating procedure reviews, and plant tours. ~There was one violation, listed below, identified in the functional area of Plant Operations:
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Failure to review and to evaluate Technical Specification
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required daily surveillance test results data adequately.
(Severity Level IV, 85-24)
The Licensee Event Reports (LER) listed below were considered significant to activities in the functional area of Plant
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Operations:
An actuation of an engineered safety feature occurred when the main steam line isolation valves automatically closed
as a result of steam line pressure decreasing to the low pressure' isolation setpoint.
This occurred because an i.
operator did not change the mode switch position following a reactor trip.
(85-10)
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l A.dechanneled fuel assembly was transferred in the fuel j
pool with the fuel assembly bail resting on an outside corner of :the fuel grapple. rather than being properly i
l latched by the grapples internal engagement mechanism.
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(85-21)
' An~ actuation of an engineered safety feature occurred when
the Reactor Water Cleanup (RWCU) system isolated because of a high system flow condition.
This was caused by a control
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I room operator attempting to correct a low system flow
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(86-04)-
c b'I A reactor protection system scram actuation occurred
!S because of a reactor low water level condition.
The low
level resulted from the removal of one reactor feedwater
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pump from service and the inability of the remaining feedwater pump to maintain adequate flow for a reactor
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i power of approximately 72 percent.
(86-06)
l With one emergency diesel generator declared inoperable for la an inspection, equipment in the division supplied by the
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other emergency diesel generator, was removed from service for maintenance.
This violated the Technical Specification minimum operable equipment requirements.
(86-08)
Management involvement in overall plant operations was evident.
Improvemc'its were made to operating procedures, policies, and standing orders.
New plant equipment was installed and declared operational including a new plant computer.
The symptomatic-emergency procedures were developed, tested, and implemented during this appraisal period.
Management frequently toured and inspected the control room and operating spaces. Watchstander attention to detail was evident, and watchstander professionalism improved. When an occasional operational weakness was identified by licensee personnel, NRC inspectors, or quality assurance, it was resolved in a timely manner.
Corporate and site management were visible onsite by tours of the operating spaces.
The decision making responsibilities of shift supervisory personnel was emphasized by management.
The licensee actively recruited operations personnel during this appraisal period.
Six operating crews were established.
The increased staffing was accomplished despite the transfer and promotion of numerous experienced personnel to management positions or other support groups.
After the plant completed post outage startup testing, availability was very high (approximately 99 percent) for the remainder of the assessment period.
Formalized classroom training and simulator refresher training increased in both quantity and quality.
Familiarity with the Technical Specification limiting conditions for operation and definitions indicated occasional weakness.
Operations personnel contributed to problems in other functional areas in that they did not forsee all potential consequences of the acts of personnel in other groups.
2.
Conclusion Management has emphasized and supported the activities in the area of plant operations.
Improvements to plant hardware and procedures were evident.
Licensee response to NRC initiatives improved.
Issues were identified and resolved in a timely manner.
Responses were technically sound and met established guidelines.
There were no major violations attributed to this functional area, but operations personnel occasionally contributed to enforcement issues in other areas because of inexperience.
The licensee has achieved six shift operations.
The experience
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level of these six shifts is increasing.
The licensee achieved high availability with minimum operational challenges after a long outage.
The licensee is considered to be in Performance Category 1 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this functional area should be
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maintained consistent with the inspection program requirements.
b.
Recommended Licensee Actions Licensee management should continue to emphasize this area while the experience level of newly qualified personnel increases.
Also, the installation of a plant specific simulator would further enhance operator performance.
Additional licensee attention is warranted in correctly assessing all potential consequences in selecting the best resolution o' technical issues.
B.
Radiological Controls 1.
Analysis Eight inspections regarding radiological controls were conducted during the assessment period by regional-based radiation specialist inspectors.
These eight inspections covered the following areas:
occupational radiation safety; radioactive waste management; radiological effluent control and monitoring;
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and transportation of radioactive material. Seven violations l
were identified:
Failure to properly calibrate radiation survey meter.
(Severity Level V, 85-14)
j Failure to calibrate gaseous radioactivity monitors.
(Severity Level IV, 85-26)
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Failure to notify radiation protection before performing test.
(Severity Level IV, 85-26)
l Failure to obtain special work permit for work in high l
radiation area.
(Severity Level IV, 85-26)
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Failure to perform adequate transportation surveys.
(Severity Level IV, 86-19)
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Failure to identify shipment of radioactive mattrials.
(Severity Level IV, 86-19)
Unauthorized transfer or licensed material.
(Severity Level IV, 86-19)
The LER listed below was attributed to activities in this functional area:
Release of radioactive material to unrestricted area, due to a radiation protection technician not performing an adequate survey of the material immediately before release of the equipment.
a.
Occupational Radiation Safety This area was inspected three times during normal plant operations.
The Cooper Nuclear Station, a 764 MWe BWR, started commercial operation in July 1974.
Since 1975, the Cooper Station average occupational dose per unit electrical power production has been approximately 1.2 person-rem per MW year, significantly lower (by approximately 50 percent)
than other operating BWRs.
However, since 1983, the average total yearly dose at Cooper has increased.
A large portion of the additional dose at Cooper resulted from the recirculation pipe replacement project completed in 1985.
This activity led to a dose of 1636 person-rem for the year.
Since replacement projects of this type normally require about 1800 person rem to complete, the Cooper total of 1636 person-rem is considered acceptable.
In the last several years the nuclear power plant industry has made a commitment to the NRC to reduce occupational exposures.
In the past three years (even excluding the exposures from the pipe replacement project) Cooper has
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demonstrated no significant progress in reducing l
occupational exposures and has shown significantly higher occupational exposures than that recorded in their previous operating history.
Additional effort by plant management l
may be required to further reduce occupational doses at the Cooper Station.
Radiation protection program requirements are the
responsibility of all assigned personnel, both contractor and licensee.
The failure to adhere to radiation l
protection procedures, exemplified by the above listed violations, reflects on the overall effectiveness of the i
radiation protection program.
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The licensee's radiation protection staff of 18 individuals is considered to be adequate to support normal plant operations.
A well defined training and qualification program still has not been established for the radiation protection staff.
The licensee experienced a turnover of approximately 40 percent in the radiation protection technician area during the past year and has had difficulty in obtaining qualified, experienced replacement personnel.
The ALARA in effect during the recirculation pipe replacement has not been maintained at the same degree of effectiveness for routine plant operations.
The ALARA committee was no longer functional and the dose tracking system was not in use.
b.
Radioactive Waste Management The licensee's program involving processing and onsite storage of gaseous, liquid, and solid waste was inspected once during the assessment period.
One violation was identified where waste gas radioactivity monitors were not being calibrated at a quarterly frequency.
The licensee's past performance had been consistently high in this area.
A well defined training program does not exist for the radwaste utility operators.
c.
Radiological Effluent Control and Monitoring This area involves gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiC ogical environmental monitoring, and chemistry / radiochemistry and confirmatory measurements.
The programs in this area were inspected twice during this assessment period.
The inspection of chemistry / radiochemistry and confirmatory measurement activities performed during the assessment period involved onsite confirmatory measurements with the Region IV mobile laboratory.
The results of this inspection indicated a percentage of agreement below the value expected for an effective radiochemistry program.
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The licensee's results of analyses performed on a sample prepared by the Radiological Environmental Services Laboratory were in 100 percent agreement with the certified activities in the sample, except for the tritium results.
The chemistry / radiochemistry staff has experienced a low turnover rate during the past several years.
As a result,
i a stable program exists with an adequate number of experienced technicians.
A well organized training program
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has not been developed for the chemistry / radiochemistry area.
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The environmental monitoring program was inspected once during the assessment period.
No significant problems were identified during the inspection.
The licensee amended their radiological effluent Technical Specifications in July 1986, to be in agreement with the format in NUREG-0473.
d.
Transportation of Radioactive Materials This area was inspected twice during the assessment period.
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Three violations were identified regarding a radioactively contaminated sandblaster,'which the licensee had failed to identify as radioactive material before returning to a vendor.
In the past several years, there has been little turnover of persons involved with transportation or solid radwaste activities.
The licensee had established an adequate quality assurance / quality control program for both
low-level radioactive material and spent fuel shipments.
e.
Water Chemistry Controls This area was inspected once during the assessment period in conjunction with the licensee's radiochemistry and confirmatory measurements program.
2.
Conclusions On the basis of the licensee's radiation exposure history since 1975, the staff concludes that the occupational exposures are significantly lower than most BWRs currently operating. No progress is noted since 1983 in reducing occupational exposures at the plant.
The licensee had an effective ALARA program during the recirculation pipe replacement program and completed the project with a lower than average radiation exposure. The licensee has demonstrated a strong management commitment to good water chemistry and fuel performance, thus contributing to low exposures, but has not pursued an aggressive ALARA program during routine plant operations.
The size of the permanent radiation protection staff is considered adequate to support plant operations.
However, a strong management commitment to ensure quality in this staff was not evident when the licensee replaced radiation protection technicians with persons having little or no prior radiation protection experience.
The licensee's program is considered adequate regarding major program activities; however, inattention to program details has resulted in several violations.
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No significant problems were identified in the functional areas
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of chemistry / radiochemistry and confirmatory measurements; radwaste management, effluent releases, and effluent monitoring; and transportation activities and solid radwaste. The licensee's program for these areas was adequate regarding management oversight, resolution of technical issues,
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' enforcement history, and staffing.
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A well defined training program had not been established for any
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of the_ functional areas included in radiological controls.
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The licensee is considered to be in Perforwence Category 2 in
this area.,
3.
Board Recommendations a.
Recommended NRC Actions
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The level of NRC inspection effort in this area should be consistent with the routine inspection program.
b.
Recommended Licensee Actions
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Increased management attention is reeded to ensure that
adequate technical expertise is maintained in the radiation protection staff. Management should ensure that the ALARA
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program implemented for the pipe replacement outage is continued during normal plant operations. Management
- attention is needed to ensure that adequate training programs are developed and implemented for all segments of the functional area of radiation protection, C.
Maintenance i
1.
Analysis This area was inspected on a continuing basis by the NRC resident inspectors and periodically by NRC regional inspectors.
Those inspections included preventive and corrective naintenance activities in the' mechanical, electrical, and instrument and
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control disciplines.
The three violations listed below were identified in the functional area of Maintenance:
Failure to adhere to the requirement in CNS procedure,
" Work Item Tracking - Corrective Maintenance," that states that Maintenance Work Request (MWR) be written and approved rior to commencing corrective maintenance activities.
p(Severity Level IV, 85-15)
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Failure to follow a maintenance procedure requirement to contact health physics personnel prior to commencing maintenance activities in a high radiation area.
(Severity Level IV, 85-26) (also listed in paragraph IV.2 and counted there for statistical purposes).
Failure to provide preventive maintenance procedures for all safety-related equipment.
(Severity Level IV, 86-01)
.The two LERs listed below were attributed to activities in the functional area of Maintenance:
An actuation of an engineered safety feature occurred when the RWCU System isolated as the result of an I & C technician inadvertently bumping the high system temperature trip switch during instrument rack decontamination operations.
(86-01)
A breach of primary containment integrity occurred when both doors of the drywell personnel airlock were partially open at the same time.
The cause can be attributed to a failure of the doors' mechanical interlocks and to personnel error when the doors were previously secured.
(86-13)
Management has emphasized the necessity to repair deficient equipment expeditously.
Maintenance records contain necessary approvals, identify plans and procedures necessary to correct known equipment deficiencies, and provide quality checks and post-mair.tenance surveillance tests prior to returning the system or component to an. operable status.
Corrective actions, including responses to NRC initiatives, are thorough and timely.
Maintenance personnel did not always follow procedural requirements, particularly in the areas of prerequisites, precautions, and limitations.
The licensee halted the previously identified practice of using surveillance in lieu approved maintenance documents to investigate erratic equipment performance.
One of the LERs listed above indicated that the licensee recognized that care needs to be exercised when performing non-related tasks around sensitive, safety-related systems or components.
The previous SALP report had identified weaknesses in the areas of the training program for maintenance personnel, lack of procedures for performing safety-related work activities and equipment calibrations, procedure adherence, I & C Department staffing losses, and control of vendor documents and shop guides.
Improvements have occurred during this assessment period in all the listed areas.
The licensee has categorized and~ updated safety-related vendor manuals and applicable
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Shop guides and other troubleshooting and ~
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maintenance-aids are being converted to formalized, approved procedures.
The need for additional procedures was identified,.
and procedures are being developed and approved for useein the
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performance of preventive and corrective maintenance; activities.
The I & C Department experienced.a high turnover rate during the assessment period, and the overall experience level of I & C technicians has therefore remained low.
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Conclusion
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Management involvement in the area of maintenance improved significantly during the later part of this assessment period.
Major improvement projects were initiated in the areas of procedure development, procedure updating, and departmental staffing.
Maintenance performance is stronger than the formalized program.
This is attributed to excellent individual craftmanship and the low turnover rate in the mechanical and electrical areas.
The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendation a.
Recommended NRC Actions The NRC inspection effort in this functional area should remain high until the licensee has completed the maintenance procedure and program development and implementation.
b.
Recommended Licensee Action Licensee management should continue attention in this functional area to assure adequate training of maintenance personnel and completion of the procedural development and rewrite project.
D.
Surveillance 1.
Analysis This area was inspected on a continuing basis by the NRC resident inspectors and periodically by NRC regional inspectors.
Those inspections included equipment and systems operability checks, instrument calibrations, procedures, surveillance
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scheduling, local leak rate testing, primary containment integrated leak rate test, primary system hydros, pump and valves performance tests, and other inservice inspection activities.
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The six violations listed below were identified in the functional area of Surveillance:
Failure to establish secondary containment integrity during reactor defueling operations as a result of not demonstrating operability of the Standby Gas Treatment System.
(Severity Level III, 85-11)
Failure to follow the procedure for calibrating an extender probe radiation survey meter.
(Severity Level V, 85-14)
Failure to perform a nuclear instrumentation surveillance test according to procedure.
(Severity Level IV, 85-24)
Failure to meet the calibration test frequency for numerous gaseous radiation monitors.
(Severity Level IV, 85-26)
Failure to remove test jumpers following completion of a surveillance test and failure to have an adequate procedure for determining the operability status of safety-related snubbers.
(Severity Level III, 35-31)
Licensee personnel failed to follow procedures during the performance of surveillance testing. Three separate occurrences were identified.
(Severity Level IV, 86-14)
The LERs listed below were considered significant to activities in the area of Surveillance:
Secondar3 containment integrity was not established and maintained prior to and during defueling operations because operability of the Standby Gas Treatment System (SGTS) was not adequately demonstrated.
(85-01)
Local leak rate testing of primary containment isolation valves and penetrations identified that total "as found" leakage exceeded Technical Specification limits.
(85-05)
The High Pressure Coolant Injection (HPCI) System was declared inoperable after the drive motor for the system suction valve burned out because of a misadjusted torque switch.
(85-06)
The HPCI System was rendered inoperable as a result of the licensee's failure to reopen the HPCI pump low suction pressure trip switch isolation valve following completion of a surveillance test.
(85-07)
The capability to actuate a containment Group VI isolation (e.g., secondary containment isolation and start of the SGTS) on a reactor building ventilation exhaust high
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radiation signal, was rendered inoperable wl'en test jumpers were not removed from the affected radiation monitors following completion of a surveillance test.
(85-15)
Safety-related snubbers were declared inoperable when numerous mounting and support discrepancies were discovered.
The cause was determined to be weaknesses in the snubber inspection program including inadequate inspector training and inspection procedures.
(85-16)
The HPCI System was declared inoperable when a HPCI injection testable check valve disk position indicator switch was found out of adjustment.
This prevented control room operators from confirming the actual disk position.
(85-17)
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An Average Power Range Monitor (APRM) System surve'illance test frequency was exceeded because of a scheduling error '
by the surveillance coordinator.
(86-03)
During this assessment period, the licensee completed major.
periodic surveillances such as local, leakage rate tests (LLRT),
Primary Containment Integrated Leakage Rate Test (ILRT), Reactor Vessel In-Service Leak Test, Reactor Recirculation System '
Inservice Inspection (ISI), and diesel generators; sequential
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load test.
These tests were performed in conjunction with the normal refueling outage surveillance program and also to verify systems readiness for operation following completion of the reactor recirculation system piping.
Management oversight in the functional area of Surveillance was evident.
Planning and scheduling were well coordinated and executed as evidenced by a smooth, relatively trouble-free startup from a major 12 month outage.
However, the enforcement actions and events listed above indicated a weakness in the performance of some regularly scheduled surveillance tests.
There have been instances of failure to perform procedures as written or to meet raquired surveillance schedule frequencies.
As a result of the procedural violations, three safety systems were rendered inoperable in whole or in part.
The previous SALP report indicated unsatisfactory LLRT test results.
Excessive primary containment local leakage was discovered during this reporting period as well.
However, the licensee's leak reduction program consisting of trend analysis, valve modification, and valve replacement, reduced the "as found" total leakage by a factor of 6 from the previous SALP period total.
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2.
Conclusion Management has been iniolved in day-to-day surveillance activities.
Tests are generally performed as written and results are reviewed in a timely and thorough manner, but the program was weaker than the measured performance. Adequate manpower was available to perform the tests when required to meet surveillance schedule frequencies.
Isolated breakdowns are evident in the areas of test procedure adherence and surveillance scheduling.
Corrective action was promptly taken once problems were identified.
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 focus on adherence to procedures and on evaluating procedure effectiveness.
b.
Reconnended Licensee Action Licensee management attentior,in this functional area should increase.
Specific attention should be devoted to reducing the number of procedural adherence violations and to assuring that the surveillance schedule is met.
The licensee is encouraged to continue their aggressive primary containment leak reduction program and to evaluate the effectiveness of surveillance procedures.
E.
Fire Protection 1.
Analysis This area was inspected on a continuing basis by the Resident Inspectors and periodically by region-based NRC inspectors.
The inspections included observation and review of the fire protection / prevention program, housekeeping /cleanliress controls, storage and protection of quality station documents, training of the fire brigades,.and implementation of 10 CFR 50, Appendix R.
Four violations listed below were attributed to activities in this functional area.
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i Failure to maintain good housekeeping practices and to
record monthly and annual Fire Protection Systems inspection discrepancies in the Shift Supervisors Log.
(Severity Level IV, 85-31)
Failure to establish a continuous fire watch while the
locking mechanisms were removed from the access doors.
(Severity Level IV, 86-15)
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Failure to implement Technical Specification requirements
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for the Fire Protection Program.
(Severity Level V, 85-15)
Failure to have an adequate work control procedure for a
fire penetration.
(Severity Level IV, 86-15)
No LERs were identified in this functional area.
During this assessment period the licensee continued the efforts
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to upgrade.the fire protection systems to meet station needs and
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10'CFR Part 50, Appendix R requirements.
Improvements completed
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lthe Serv. ice water pump room and computer room and the upgrading
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' of'some fire doors to increase the level of fire protection in specified areas.
>The multiple minor violations listed above indicate that there were some deficiencies in the fire prevention program. A review of the previous SALP report and the licensee's response to that report indicates that management took corrective action for
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similar problems. The Appendix R implementation inspection i
revealed that the licensee had many items to complete in the areas of procedures and analysis.
Staffing is ample as indicated by surveillances, and training is being performed in a timely manner. The fire prevention and protection training program is defined and implemented for all personnel. Training and surveillances records for fire
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prevention and protection are well maintained and available.
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2.
Conclusicns The licensee has implenented an acceptable fire prevention and protection program. There are, however, several noted weakness.
Specifically, Appendix R implementation is on schedule but not yet complete, and violations of requirements persist, as a
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result of ineffective corrective actions.
The licensee is considered to be in Performance Category 2 in this functional area.
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3.
Board Recommend 6tions
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a.
Recommended NRC Actions The level'of NRC inspection should be consistent with the normal inspection program. requirements.
i b.
Recommended Licensee-Action
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Licensee management should increase attention to assure that the root cause of deficiencies in the fire prevention program are correctively identified and corrected.
Licensee
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management should as'ure that Appendix R implementation is s
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completed on schedule.
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Analysis This area was inspected on a periodic basis by region-based NRC inspectors and contract personnel.
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i The two violations listed below were identified in the functional area of emergency preparedness:
Failure to submit changes to the Emergency Procedures.
i (Severity Level V, 86-04)
Inadequate operator training.
(Severity Level IV, 85-22)
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The deficiencies listed below were also identified in the functional area of emergency preparedness:
Emergency procedures did not identify nondelegatable
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authorities and responsibilities.
(85-09)
Licensee personnel lacked familiarity with emergency procedures, and protective action decision making.
(85-09).
- Emergency procedures did not address notifying state in 15 minutes.
(85-09)
During the annual emergency exercise, the licensee demonstrated the ability to evacuate the EOF and to relocate to the alternate EOF' located in Auburn, Nebraska. The move was conducted with minimum impact to the exercise. The licensee did not achieve initial accountability within 30 minutes during the exercise nor was continuous accountability in the protected area achieved during the exercise; however, overall performance during the emergency exercise was an improvement over previous exercises.
It was determined that operations shift personnel were not familiar with the notification time limits for state officials.
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It was also found that the E0F had become crowded by stored manuals and personal equipment and that the emergency training program had be n changed but not documented in the emergency plan.
During walk throughs of emergency scenarios with operations personnel, it was determined that on shift personnel were waak in their ability to use EPIP's and to classify simulated accidents correctly.
It was further noted that operators were not familiar with notification forms and procedures.
The emergency plan implementing procedures had not been submitted to the NRC within 30 days as required.
It was also found that pagers were not always carried by key personnel nor were backup personnel assigned pagers in the absence of the principal assignee.
The licensee's records of tone alert radio distribution and maintenance were handwritten and not kept up-to-date.
The licensee had, however, conducted unannounced drills to call out emergency response drills for site personnel and had sent an information brochure to local residents.
This brochure included a telephone number to call for information, but this number was only useable during normal working hours.
The general office had not conducted any emergency response drills.
2.
Conclusions The licensee's annual exercise demonstrated an apparent improvement and a satisfactory state of emergency response readiness.
Detailed inspections, however, revealed significant deficiencies in training.
There is also a sense of complacency toward emergency response, especially with regard to having backup personnel on call.
The licensee has shown improvement in the emergency preparedness program since the previous assessment period.
Some areas identified during this evaluation period have been identified in previous assessment periods.
The licensee is considered to be in performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Action The level of NRC inspection in this functional area should continue at the normal level.
b.
Recommended Licensee Action The level of management attention to the implementation of the emergency preparedness program should be increased.
The licensee should implement the emergency preparedness
.
.
training and retraining program that has been in the planning stage.
The training program should include both station and general office emergency response team members,
!
and its effectiveness should be independently verified.
l The licensee should establish a pager roster system and
'
assure discipline to pager requirements.
G.
Security
.
!
1.
Analysis This area was. inspected on'a continuing basis by the NRC
,
Resident Inspectors and periodically by region-based NRC inspectors.
The 17 violations listed below were identified in the functional area.of Security:
Inadequate Secu'rity System Maintenance.
(Severity Level-IV,85-10)
Inability to Demonstrate Weapons Qualification.
(Severity Level IV, 85-10)
Approved Lock for Safeguards Drawing Cabinet.
(Severity Level IV, 85-19)
Vital Area Barriers.
(Severity Level III, 85-23)
Access Control - Personnel.
(Severity Level III, 85-23)
-
Inadequate Security Organization.
(Severity Level IV, 85-23)
Plan Change Notification.
(Severity Level IV, 85-23)
Contractor Audits.
(Severity Level IV, 85-23)
Shift Supervisor Security Training. (Severity Level IV, 85-23)
,
.
Failure to Demonstrate Security Related Tasks. (Severity Level IV, 85-23)
Unattended and Unlocked Security Records Storage Container.
(Severity Level IV, 85-24)
,
Locks, Keys, and Combinations.
(Severity Level IV, 86-03)
,
Physical Barriers - Protected Area.
(Severity Level IV, 86-03)
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- Lighting.
(Severity Level IV, 86-03)
Assessment Aids.
(Severity Level IV, 86-03)
Detection Aids - Protected Area.
(Severity Level IV, 86-03)
Failure to Positively Control Access to Vital Areas.
(Severity Level IV, 86-16)
The deviation listed below was identified in the functional area of Security:
Lack of Contingency Equipment. (86-14)
Toward the end of the SALP evaluation period, some positive-corrective efforts were initiated, but little was accomplished.
The NRC RIV physical security staff performed five inspections during this assessment period.
Three of these five inspections included following up on allegations.
Seventeen violations, two of which involved escalated enforcement, and one deviation were identified.
The state of readiness and proficiency of'the security program had decreased during the early part of this evaluation period, and appeared to lack management attention.
The security force was understaffed, causing excessive overtime, and security guards were not well prepared because of weaknesses in training and supervision.
The access control and intrusion detection equipment was difficult to maintain, due to aging and lack of an effective surveillance and preventive maintenance program.
Corrective maintenance was sporadic.
During this evaluation period, an incident of aberrant behavior that occurred offsite with a contractor employee was brought to the attention of station management.
The handling of this matter, and the subsequent granting of unescorted vital area access to this person again raised several questions regarding the licensee's on going screening program.
Offsite aberrant behavior might indicate potential onsite behavior that could adversely effect plant safety and security.
An immediate action letter was issued and an enforcement conference was held during this appraisal period.
In response to the problems identified, the licensee formed a special Quality Assurance Task Force.
The Task Force engaged outside consultants to examine the issues and make recommendations.
As a result of their efforts, major personnel changes were made, and an effective avenue of communication between the site security management and the regionally based NRC inspectors has developed.
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2.
Conclusion The licensee's program, in the early portion of the assessment period, was in'a deteriorated and neglected state and it appears that the licensee is now committed to actions that enhance the effectiveness of the program and assure compliance with requirements in this area.
Other steps are planned for the correction of physical protection deficiencies and the overall development of the physical security program.
Extensive changes in command personnel, security organization functions, written procedures, and training have been included in the current development of security practices.
The renewal of the physical security hardware and supporting systems is being researched and a lengthy installation schedule has been presented to the NRC.
The licensee is considered to be in performance category 3 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort in this functional area should be increased because of the programmatic deficiencies and violations identified during this assessment period.
b.
Recommended Licensee Actions The licensee should take appropriate steps to accelerate the resolution of these matters.
Care must be taken to ensure quality in personnel selection-and in staff training techniques within the new security organization.
Positive interfacing with the other elements of the plant staff should be given special attention.
Management should ensure that in designing the new protective system each affected discipline will be involved in considering the impact of implementation.
The licensee is encouraged to utilize objective expertise to support the planned security development effort.
The licensee should evaluate employee behavior in a broader context and consider the impact of offsite behavior on plant safety and security.
H.
Outage 1.
Analysis This area was inspected by the NRC resident and regional inspectors.
An inspection was also conducted by NRC Region I personnel utilizing the NRC mobile nondestructive examination van.
The inspections included refueling activities, outage
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management, planning and scheduling, staffing, mehr components and systems repairs and modification, reactor recirculation system piping replacement, and preoperational startup testing.
.The five violations listed below were identified in the functional area of Outages:
,
,
Failure to Record or Disposition Unacceptable Linear
'
Indications in Radiographs. The proper disposition of linear indications that exceed code requirements is repair
,
of the affected area.
(Severity Level IV, 85-12)
Failure to Instruct Welders in Implementation of Welding
~ Procedure Specifications.
(Severity Level V, 85-13)
.
Incomplete Radiographic Test Records.
!
- 85-16)
Failure to meet an NRC reportability requirement, (e.g.
Licensee Event Report) when an event occurred while moving irradiated fuel that placed the plant in a condition not covered by CNS operating and energency procedures.
(Severity Level IV, 85-24)
Failure to Fully Implement the Station Design Change
Procedure.
(Severity Level IV, 86-13)
There were six LERs, listed below, in this functional area:
The HPCI was declared inoperable due to a failure in the
,
!-
motor starter of the HPCI pump minimum flow bypass isolation valve. The cause was determined to be a manufacturing assembly problem.
(85-11)
i The HPCI was declared inoperable'due to a failure of the HPCI turbine auxiliary lube oil pump. The cause was determined to be an end-of-life failure of the oil pump bearing.
(85-12)
j
The HPCI System was declared inoperable because of tripping
on overspeed during the initial plant startup following an
,
extended outage. The cause was a wiring installation error I
that was performed during EQ modification activities relating to the HPCI turbine Woodward governor system.
(85-08)
The HPCI System was declared inoperable when the turbine
steam supply inlet valve failed to open. The cause was not definitely determined. However, contributing factors includ2d the fact that the valve disc had been previously stellited and the valve control circuitry had been i
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temporarily modified to allow corrective maintenance of the problem identified above in LER 85-08.
(85-09)
.
,
The HPCI System was declared inoperable because the turbine
- *
overspeed trip auto reset control valve diaphragm failed because of a manufacturing flaw.
(86-02)
,
,
l
^
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- .The HPCI System was declared inoperable because the HPCI gland steam concenser to head gasket failed because of an inadequate. condenser design.
(86-05)
,
_
There were two major outages during this SALP period. The first outage began on September 15, 1984, and was still in progress
'
during this evaluation period. This scheduled outage was completed on August 20, 1985. Outage activities included removal and replacement of all reactor recirculation system (RRS) piping and other attached piping that fonned an integral part of the primary system boundary, inspection of the main turbine and generator, diesel generators annual. inspection, i
replacement of RRS flow nozzles with venturi flow elements, installation of RRS discharge valves jogging circuitry,
equipmentqualification(EQ) upgrade,replacementofsome
,
extraction steam piping, and completion of the Plant Management l
Information System (PMIS).
Other activities included nondestructive examinations and l
hydrostatic testing of the new RRS piping, refueling, performance of a systems orientated startup test program, and a
,
,
core physics evaluation.
The second outage was from October 5,1985, through November 22, 1985. This outage was unscheduled and resulted from high vibration on the main turbine. Outage activities included inspection of the main high pressure turbine and both low pressure turbines. As a result of those inspections, one low pressure turbine rotor was replaced and the second was repaired.
A high level of management attention was dedicated to the RRS pipe replacement project. A special licensee management team was formed that was specifically assigned to and responsible for all activities in that area.
Emphasis was strong in the areas of program development, procedures, ALARA controls, quality assurance, piping replacement, and special tests and inspections. Additionally, the licensee's overall outage programs for EQ upgrade, main turbine rotor maintenance, plant modifications, refueling, preoperational startup testing, surveillances, and systems restoration prior to plant startup were found to be well organized, planned, executed, and documented. Staffing for both outages was adequate.
Preoutage training of licensee and contracter personnel included formalized classrcom, in-field observation, and mockups.
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The licensee contracted to have the overhaul of the main turbine and High Pressure Coolant Injection turbine and pump done.
Both of these jobs resulted in post overhaul problems, whereas availability after other overhaul tasks was excellent.
The licensee did not have its own independent quality control group to monitor the contract services.
2.
Conclusions The licensee has consistently displayed a strong management commitment to a well organized and functional outage prcgram.
Staffing and training needs were established commensurate with the quantity and depth of activities that were planned.
The licensee provided technically sound and timely responses to NRC initiatives.
The licensee's lack of a formal, independent quality control program resulted in the second outage.
The licensee is considered to be in Performance Category 1 in this functional area.
3.
Board Recommendations
'
a.
Recommended NRC Actions The NRC inspection effort in this functional area should be reduced, b.
Recommended Licensee Actions Licensee management should continue attention in this functional area, since each major outage presents a unique set of challenges.
Licensee management should consider programmatic options to assure quality control of contracted work.
I, Quality Programs and Administrative Controls Affecting Quality 1.
Analysis This area was inspected on a continuing basis by the NRC resident inspectors and periodically by NRC regional inspectors.
The inspections included management oversight and administration of quality assurance (QA) and quality control (QC) activities, operations QA program, QC program, safety review committees, document control, records, procedures, licensee audits, surveillance, IE Bulletin followup, corrective action' system, TMI Action Plan implementation, allegations review, facility design changes and modification, procurement controls, and quality materials receipt, inspection, handling, and storage.
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-
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2 The violations listed below were considered significant in this functional area:
A licensee procedure for equipment clearance and release orders was inadequate because it only required independent verification of manual valves located in the main flow path of safety-related systems and did not address associated switches, breakers, and other support components.
(Severity Level V, 85-08)
The licensee failed to perform a review to determine if the safety question was an unreviewed safety issue for installed temporary jumpers.
(Severity Level V, 85-15)
Superceded procedures were found in the control room.
(Severity Level V, 85-15)
The licensee failed to have procedures for maintenance of safety-related equipment.
(Severity Level IV, 85-15)
Licensee QA department personnel failed to fol_ low procedure for recording and reporting " Findings," (e.g.
nonconformances).
Thus, the "."indings" did not receive an adequate level of management review attention.
(Severity Level V, 85-16)
No station procedure existed to prevent or to control the use of voided, deleted, or superseded safety related drawings.
(Severity Level IV, 85-19)
- Failure to specify on purchase orders that provisions of 10 CFR Part 21 were applicable.
(Severity Level V, 85-20)
No licensee procedure existed to assure the inclusion of engineered preload torques in accordance with ASME Boiler and Pressure Vessel Code,Section III (Nuclear), nor did l
procedures exist to verify that nonconforming material was
'
not installed or that as built design changes met the specified design criteria.
(Severity Level IV, 85-21)
,
A licensee procedure was inadequate in that the affected procedure required operations shift supervision to verify that reactor water chemistry was adequate for startup but did not include criteria for making that determination.
l (Severity Level V, 85-24)
Failure to take adequate corrective action for deficiencies involving safety-related equipment.
(Severity Level IV, 85-27)
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- Licensee QA department personnel failed to follow procedure for recording and reporting " Findings".
(Severity Level IV, 85-30)
Licensee test equipment calibration procedures were inadequate because they did not identify and include certain test gauges that are used surveillance test activities.
(Severity Level IV, 85-32)
Failure to Include Quality Assurance Requirements in Purchase Orders.
(Severity Level V, 86-11)
The licensee's as-built drawings failed to label, number, or otherwise identify valves associated with instrument detectors.
(Severity Level IV, 86-14)
Licensee procedures were changed in technical content without being reviewed and approved by the originating reviewing organization.
(Severity Level IV, 86-15)
Failure to have a procedure for ensuring what revisions to the Technical Specification are incorporated into station procedures.
(Severity Level IV, 86-21)
The LERs listed below were considered significant to activities in this functional area:
Standby Gas Treatment System Desigr. Deficiencies.
The deficiencies included expansion sleeves, bracing for the crossover duct, and filter housing drains.
(85-02)
The APRM flux trip and rod block monitor trip settings were set less conservatively than required for single loop operation. This resulted from the licensee's failure to revise applicable calibration procedures following approval of a Technical Specification amendment for single loop operation.
(85-14)
An actuation of an engineered safety feature occurred when the RWCU System isolated because of a high area space temperature condition caused by the failure of a RWCU pump mechanical seal.
The seal failure resulted from a seal assembly procedure inadequacy.
(85-18)
A completed Automatic Depressurization System (ADS)
surveillance test was declared invalid when the licensee determined that the test could not have been successfully completed as written.
The event was attributed to personnel error and the failure to identify and list the affected surveillance test procedure as requiring revision
.,
in an ADS design change package that was completed during a previous outage.
(85-20)
The licensee identified a main steam line high flow setpoint anomaly when it was, determined that the setpoint was based on design steam flow rather than rated flow.
(86-07)
This functional area may be viewed as the comprehensive management system for controlling the quality of work performed as well as the quality of the verification activities that confirm that work was performed correctly.
Also included are the management actions to ensure that necessary staffing, procedures, facilities, and materials are provided.
While management involvement in assuring quality was evident, some repetitive problems occurred, which indicated an occasional failure to identify and to correct the root cause of generic problems.
For example, after the HPCI overhaul problems were identified by testing.
There was no independent quality control organization to inspect this job.
The enforcement history in this functional area indicated programmatic weaknesses in the areas of documentation review, results evaluation, corrective actions, design deficiencies, manufacturing and installation flaws, procedure adherence, and inadequate procedures.
On the other hand, QA review disclosed a problem with the standby gas treatment system, which had been missed on surveillance testing.
Operational events were properly identified, analyzed, and reported in a timely manner. The licensee proposed some changes to Technical Specifications to clarify or to improve them.
The permanent plant staff level increased from approximately 250 to greater than 300 during this assessment period.
Much of that increase was used to increase the number of operations crews, and to provide more administrative support in the areas of procedure revisions and design changes. Management was visible onsite. This included members of corporate management.
The visibility of quality personnel onsite also increased.
The licensee expanded its nuclear management structure during this period.
The NPPD president appointed a nuclear management consultant to oversee CNS operations.
A Senior Nuclear Advisor position was created at the CNS and was filled by the former Division Manager of Nuclear Operations.
Contractors were hired to develop new procedures and to modify existing procedures used for maintenarce, operations, and surveillance.
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2.
Conclusion The licensee management is knowledgeable, visible sad effective in controlling site operations.
Performance on an individual basis is very good, but programs are less effective.
The lack of a formal, independent quality program is an example of this.
Strengthening programmatic aspects should also improve the licensee's ability to deal with the resolution of technical issues effectively.
The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection activities in this functional area should remain at the current level.
b.
Recommended Licensee Action The licensee should closely strengthen the programmatic aspects of all site areas and work to improve the resolution of technical issues.
J.
Licensing Activities See attachment 1.
K.
Training and Qualification Effectiveness 1.
Analysis This area was inspected on a continuing basis by the NRC resident inspectors and periodically by NRC regional inspectors.
The inspections included plans and procedures, licensed operator training, operator requalification training, and training of non-licensed personnel including shift technical advisors (STA),
contract personnel, administrative, maintenance, engineering, site and corporate personnel.
One violation listed below was identified in this functional area.
Failure to follow the Requalification Training Plan.
(Severity Level IV, 86-06)
Several violations (particularly in outages) that are listed in other sections of this report had inadequate training listed as a contributing cause for the violation.
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One deviation listed below was identified in this functional area.
Failure to document training.for site engineer and senior general office engineers.
(86-07)
No LERs were identified in this functional area.
During this assessment period the licensee has expended considerable effort to upgrade training and qualification effectiveness.
Improvements included the construction of a new training facility.
The training facility has space allocated for a plant specific simulator, additional office space, and classrooms for instructional presentations.
The licensee is preparing for final accieditation by the Institute of Nuclear
'
Power Operations (INPO).
Final INP0 accreditation for operations training is scheduled to occur during 1986 and for other training programs in 1987.
The licensee has continued efforts to fill key positions in the training department organization However, several key positions are still staffed by contract personnel.
Operator licensing examinations were administered in June 1985, March 1986, and June 1986.
Five Senior Reactor Operator (SRO)
upgrade examinations were administered with all five candidates being issued SR0 licenses.
Sixteen Reactor Operator (RO)
candidates were examined with 13 candidates being issued R0 licenses.
The SR0 pass rate in the preceding SALP period was 50%; this SALP period the passrate was 100%.
The R0 pass rate in the preceding SALP period was 75%; this SALP period the pass rate was 81%.
These increases in SR0 and R0 candidate performances can be attributed to the training and qualification program for licensea operators. The NRC performed a requalification program evaluation by administering both written and oral operating requalification examinations.
Based upon the results of these examinations, the program was evaluated as satisfactory.
2.
Conclusion
.
.The licensee has a well defined and implemented licensed
,
'
operator training program. The licensee has many training programs which require implementation after INP0 accreditation.
Several key position in the training organization still need to be filled.
Inadequate training has been identified as a contributing cause of several events which occurred during this rating period.
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 functional area should be at the normal level.
Particular emphasis should be placed on monitoring training program development and implementation.
b.
Recommended Licensee Action The licensee is encouraged to expedite filling key training staff positions with permanent staff.
Management attention should continue in the area of training program development and implementation for non-licensed site and corporate personnel.
V.
Supporting Data and Summaries A.
Licensee Activities There were two major outages during this assessment period.
The first outage was scheduled and began on September 15, 1984, and ended August 20, 1985.
Major activities and modifications included reactor recirculation system (RRS) piping replacement, inspection of the main turbine and generator, diesel generators annual inspection, replacement of RRS flow nozzles with venturi flow elements, installation of RRS' discharge valves jogging circuitry, equipment qualification (EQ) upgrade, replacement of IGSCC degraded extrusion steam piping, completion of the Plant Management Information System and installation of the Safety Parameter Display System.
The second outage was unscheduled and lasted from October 5, 1985, through November 22, 1985.
The plant was shutdown due to high main turbine vibration and rapidly increasing condensate /feedwater conductivity.
Inspections of the main turbine high pressure and low pressure turbines identified missing blading from row L-1 of the No. 2 LP turbine and impact damage to rotating and stationary blading in the areas of rows L-0 and L-1 of both LP turbines.
The HP turbine did not appear demaged. The initiating cause of the damage was attributed to foreign objects that were apparently left in the internal LP turbine areas after reassembly of the turbines following the previous outage inspections. The No. 2 LP turbine rotor was subsequently replaced and the No. 1 LP rotor and stationary blading were repaired.
There were no reactor power limits imposed during this SALP period.
'Several important licensee amendments were issued during this period as noted in Attachment 1 of this report.
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The CNS Emergency Plan was activated four times during this appraisal period.
A brief summary of those events are listed below:
A Notification of an Unusual Event was declared on March 27, 1985, when a potentially contaminated injured person was transferred 4.0 a local hospital.
The event was terminated when the injured person's anticontamination clothing was removed at the hospital.
It was deterained that the injured person was free of contamination.
- A Notification of an Unusual Event was declared on July 19, 1985, as a result of a complete loss of power to all meteorlogical instrumentation.
The event was terminated when power was restored.
- A Notification of an Unusual Event was declared on August 24, 1985, because of a complete loss of meteorological monitoring system computer output data.
The event was terminated when the data acquisition and display functions of the computer were restored.
A Notification of an Unusual Event was declared on December 23, 1985, because the licensee entered a Technical Specification Limiting Condition for Operation (LCO) which required an immediate shutdown.
The event was terminated on December 23, 1985, when operating conditions removed the licensee from the LCO.
B.
Inspection Activities Major NRC inspection activity during this assessment period included 49 inspections performed with 4929 direct inspection manhours expended. These inspections included followup inspections to the performance appraisal team, emergency preparedness exercise evaluation, and NRC NDE van and personnel.
Also, special inspections were performed in the areas of fire protection (10 CFR Part 50, Appendix R), jet pump installation problems, and Technical Specification violations of emergency power switchgear cabinets seismic supports, simultaneous removal from service of components located in two independent safety-related trains, and refueling operations without secondary containment.
Table 1 provides a tabulation of NRC enforcement activity for each functional area evaluated.
C.
Investigations and Allegations Review One major investigative activity was conducted during this assessment period in the area of security resulting in the issuance of imposition of a proposed civil penalty.
Two allegations were examined in the areas of welder's procedures training and maintenance
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of personnel dosimetry records.
Both allegations were substantiated in whole or in part.
D.
Escalated Enforcement Actions Two civil penalties were imposed by the NRC during this assessment period.
The first penalty concerned a lack of management effectiveness in the oversight and control of the CNS security program (EA 86-44).
The second civil penalty applied to a violation of surveillance testing requirements as evidenced by a failure to install and to remove jumpers, and a failure to inspect snubbers correctly for operability (EA 86-03).
E.
Licensee Conferences Held During Appraisal Period There were three management conferences conducted with the licensee that dealt with regulatory performance as listed below:
Numerous violations of the Physical Security Plan.
The conference was conducted on May 2, 1985.
- Violations in different areas including jumper wire removal following completion of surveillance testing, inadequate snubber surveillance program, and security plan related discrepancies.
The conference was conducted on December 17, 1985.
Potential violations in the maintenance area including failure to have procedures for preventive maintenance and to establish a suitable training program for electrical and mechanical maintenance personnel.
The conference was conducted on March 26, 1986.
F.
Confirmation of Action Letters No confirmation of action letters were issued by the NRC during this
,
SALP evaluation period.
G.
Attachments 1.
Licensing Evaluation
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Table 1 Enforcement Activity FUNCTIONAL AREAS NUMBER OF VIOLATIONS IN EACH LEVEL OEVIATION V
IV III A.
Plant Operations
0
0 B.
Radiological Controls
1
0 C.
Maintenance
0 2*
D.
Surveillance
1
2 E.
Fire Protection
1
0 F.
Emergency Protection
1
0 C.
Security
0
2 h.
Outages
2
0 I,
Quality Programs and
7
0 Administrative Controls Affecting Quality J.
Licensing Activities
0
0 K.
Training and Qualification
0
0 Effectiveness Totals
13
4
One additional violation was considered in this area, but it is reported for statistical purpcses in the radiological controls area.
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ATTACHMENT 1 FACILITY:
Cooper Nuclear Station LICENSEE:
Nebraska Public Power District EVALUATION PERIOD:
February 1,1985 to July 31,.1986 PROJECT MANAGER:
William 0. Long 1. 0 INTRODUCTION This report presents the results of the Office of Nuclear Reactor Regulation (NRR) evaluation of the performance of Nebraska Public Power District (the District), licensee for the Cooper Nuclear Station.
The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, "NRR Inputs to SALP Process", dated January 3, 1984.
Office Letter No. 44 incorporates NRC Manual Chapter 0516, Systematic Assessment of.
Licensee Performance.
2.0 SUMMARY NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a composite of a number of attributes.
The performance of the District in the functional area of licensing is rated Category 1.
3.0 CRITERIA The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for l
Assessment of Licensee Performance.
4.0 METHODOLOGY This evaluation represents the integrated inputs of the Operating Reactor Project Manager (ORPM) and those technical reviewers who expended significant effort on Cooper Nuclear Station licensing actions during the rating period.
Using the guidelines of NRC Manual Chapter 0516, the ORPM and each reviewer applied specific evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assigned an overall rating category (1, 2 or 3) to each attribute.
The reviewers included this information as part of each Safety Evaluation Report transmitted to the Division of BWR Licensing.
The ORPM, after reviewing the inputs of the technical reviewers, combined this information with his own assessment of licensee performance and arrived at a composite rating for the licensee's performance in the functional area of Licensing Activities.
This rating also reflects the comments of the Senior Executive.
A written evaluation was then prepared by the ORPM and circulated to NRR management for comments, which were incorporated in the final draf..
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The basis for this appraisal was the District's performance in support of significant licensing actions that were either completed or had a substantial level of activity during the rating period.
These actions, consisting of amendment requests, responses to generic letters, TMI (NUREG-0737) items, and other actions, are listed below:
HULTIPLANT ACTIONS A-17 INSTRUMENTATION TO FOLLOW THE COURSE OF AN ACCIDENT A-19 HYDR 0 GEN RECOMBINER CAPABILITY - RESPONSE TO GENERIC LETTER 84-09 B-24 CONTAINMENT VENT & PURGE B-76 SALEM ATWS - POST-TRIP REVIEW PROGRAM DESCRIPTION AND PROCEDURES -
COMPLETED - LETTER TO PILANT DATED MAY 6, 1985 B-77 SALEM ATWS - EQUIPMENT CLASSIFICATION AND VENDOR INTERFACE - REACTOR TRIP SYS COMPONENTS B-78 SALEM ATWS - POST-MAINTENANCE TESTING PROCEDURES / VENDOR RECOMMENDATIONS -
REACTOR TRIP SYSTEM COMPONENTS B-79 SALEM ATWS - POST-MAINTENANCE TESTING - CHANGES TO TECH SPECS - REACTOR TRIP SYSTEM - COMPLETED - LETTER TO PILANT DATED MAY 23, 1986 B-84 INSPECTION OF STAINLESS STEEL PIPING ACCORDING TO GENERIC LETTER 84-11 -
COMPLETED - LETTER TO PILANT DATED JULY 31, 1985 B-85 SALEM ATWS - POST-TRIP REVIEW - DATA AND INFORMATION CAPABILITY - COM-PLETED - LETTER TO PILANT DATED JUNE 10, 1985 B-86 SALEM ATWS - EQUIP CLASS & VENDOR INTERFACE - ALL SAFETY RELATED COMPONENTS B-87 SALEM ATWS - POST-MAINT TESTING PROCEDURES & VENDOR RECOMMENDATIONS B-88 SALEM ATWS - POST-MAINTENANCE TESTING - CHANGES TO TECH SPECS - ALL SAFETY-RELATED COMPONENTS - COMPLETED - LETTER TO PILANT DATED MAY 23, 1986 B-92 SALEM ATWS - REACTOR TRIP SYS FUNCTIONAL TESTING - DIVERSE TRIP FEATURES B-93 SALEM ATWS - REACTOR TRIP SYS FUNCTIONAL TESTING - ALTERNATIVES AND TEST
INTERVALS D-19 DIESEL GENERATOR RELIABILITY TECHNICAL SPECIFICATIONS - RESPONSE TO GENERIC LETTER 84-15 (SEE PLANT-SPECIFIC ACTION BELOW - AMENDMENT 95)
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D-20 DRYWELL VACUUM BREAKERS RESPONSE TO GENERIC LETTER 83-08 E-04 SINGLE-LOOP OPERATION (SEE PLANT-SPECIFIC ACTION BELOW)
F-05 PROCEDURES GENERATION PACKAGE F-09 SAFETY PARAMETER DISPLAY SYSTEM F-26 NUREG 0737 ITEM II.F.2.3 INADEQUATE CORE COOLING INSTRUMENTATION -
GENERIC LETTER 84-23 - COMPLETED - LETTER TO PILANT DATED AUGUST 21, 1985
' F-55 NUREG 0737 ITEM II.K.3.28 - VERIFY QUALIFICATION OF ACCUMULATORS ON ADS VALVES - COMPLETED - LETTER TO PILANT DATED AUGUST 9, 1985 F-71 DETAILED CONTROL ROOM DESIGN REVIEW PLANT SPECIFIC ACTIONS DRYWELL/WETWELL PRESSURE DIFFERENTIAL AND LEAKAGE MONITORING TECH SPEC CHANGES - COMPLETED - LETTER TO PILANT DATED MAY 13, 1985 (AMENDMENT 91)
SNUBBERS AND RECIRC BYPASS - GENERIC LETTER 84-13 - COMPLETED - LETTER TO PILANT DATED MAY 20, 1985 (AMENDMENT 92)
CYCLE 10 RELOAD AND HYBRID CONTROL R0D ASSEMBLIES - COMPLETED - LETTER TO PILANT DATED JUNE 3, 1985 (AMENDMENT 93)
SINGLE-LOOP OPERATION TECH SPECS - COMPLETED - LETTER TO PILANT DATED SEPTEMBER 24, 1985 (AMENDMENT 94)
DIESEL GENERATOR TECH SPEC CHANGES - COMPLETED - LETTER TO PILANT DATED NOVEMBER 21, 1985 (AMENDMENT 95)
MAIN STEAMLINE HIGH FLOW ISOLATION TECH SPEC CHANGE - COMPLETED - LETTER T0.PILANT DATED MARCH 17, 1986 (AMENDMENT 96)
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TECH SPEC CHANGE TO CONSOLIDATE REFUELING REQUIREMENTS AND SPECIAL TEST REQUIREMENTS - COMPLETED - LETTER TO PILANT DATED APRIL 9, 1986 (AMENDMENT 97)
HALON FIRE SUPPRESSION SYSTEM TECH SPECS - COMPLETED - LETTER TO PILANT DATED APRIL 10, 1986 (AMENDMENT 98)
APRM FLOW BIAS, ADS LOGIC, DEFINITION OF OPERABILITY, MISC. TECH' SPEC CHANGES - COMPLETED -LETTER TO PILANT DATED MAY 19, 1986 (AMENDMENT 99)
ORGANIZATIONAL CHANGES, TURBINE STOP VALVE SCRAM, LIMITING CONTROL R00 PATTERN, INSTRUMENTATION TABLES, JET PUMP FLOW MISMATCH, TESTABLE PENETRATIONS, ISOLATION VALVES, AND WATER LEVEL FIGURE TECH SPEC CHANGES
- COMPLETED - LETTER TO DILANT DATED tiAY 20, 1986 (AMENDMENT 100)
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STATION BATTERY SURVEILLANCE PROPOSED TECH SPEC AMENDMENT - APPLICATION DATED APRIL 26, 1985 APPENDIX "R" EXEMPTION REQUESTS - COMPLETED - LETTER TO PILANT DATED AUGUST 21, 1985
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EMERGENCY PLAN EXERCISE - REQUEST FOR SCHEDULAR EXEMPTION _- LETTER.T0 PILANT DATED APRIL 1, 1985 EXTENSION OF DEADLINE TO COMPLY WITH 10 CFR 50.49 - COMPLETED - LETTER TO PILANT DATED MARCH 26, 1985 SECOND TEN-YEAR INSERVICE INSPECTION PROGRAM - COMPLETED - LETTER TO PILANT DATED JANUARY 27, 1986 SECOND TEN-YEAR INSERVICE TESTING PROGRAM - SUBMITTAL DATED APRIL 3,1984 -
STANDBY GAS TREATMENT SYS, CONTROL ROOM VENTILATION, WATER LEVEL TRIP, E.Q., AND MISC TECH SPEC CHANGES - APPLICATION DATED APRIL 26, 1985 STATION BATTERY SURVEILLANCE TECH SPEC CHANGES - APPLICATION D'ATED APRIL 26, 1985 RECIRCULATION PIPING REPLACEMENT. RADIATION PROTECTION PROGRAM - COMPLETED
- LETTER TO PILANT DATED JULY 31, 1985 HIGH RADIATION AREA TECH SPEC CHANGES - APPLICATION DATED FEBRUARY 10, 1986 RESPONSE TO GENERIC LETTER 85-07 " IMPLEMENTATION OF INTEGRATED SCHEDULED
FOR FLANT MODIFICATIONS" - LETTER TO H. THOMPSON DTD JULY 8, 1985 OTHER ACTIONS RESPONSE TO NRC REQUEST - CONTROL ROOM SURVEY BY ARGONNE NATIONAL LABORATORY - OCTOBER 3-4, 1985 RESPONSE TO NRC REQUEST - STATUS LISTING 0F MPA'S - LETTER FROM PILANT DTD MAY 30, 1986 RESPONSE TO NRC REQUEST - ONE-YEAR HOURLY METEOROLOGICAL DATA ON MAGNETIC TAPE - LETTER TO PILANT DTD MAY 21, 1985 5.0 ASSESSMENT OF PERFORMANCE ATTRIBUTES The licensee's performance evaluation is based on a consideration of the seven attributes specified in NRC Manual Chapter 0516.
These are:
Management Involvement and Control in Assuring Quality Approach to Resolution of Technical Issues from a Safety Standpoint
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Responsiveness to NRC Initiatives Staffing Enforcement History Reporting and Analysis of Reportable Events
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Staffing In addition, this evaluation includes an assessment of the District's housekeeping practices.
5.1 Management Involvement and Control in Assuring Quality The licensee's nuclear organization consists of three functional divisions reporting to the Vice-President-Nuclear.
The three functional divisions are Operations, Services, and Quality Assurance (QA is a division-level organization reporting directly to the VP-Nuclear).
The VP-Nuclear has a technical staff manager and senior nuclear advisor to assist in his overview of nuclear activities.
The senior nuclear advisor maintains offices at both the site and general offices.
During the rating period, licensee management maintained a high level of involvement and attention to quality in issues of major safety significance.
The licensee-operates only one nuclear plant and has none under construction.
The licensee's design staff is therefore relatively small and contractors are used extensively fer engineering and maintenance activities.
The licensee maintains blanket contracts with General Electric, Burns and Roe, and Stone and Webster to provide technical services,-and calls in other contractors as necessary.
Licensee personnel thus devote most of their time to planning and to quality overview of contracted activities.
This has resulted in a high level of performance.
In particular, the licensee has been relatively strong in the area of implementing plant modifications on an expeditious schedule.
The licensee's management personnel continue to maintain close contact and participation with nuclear industry groups involved in issues of safety significance.
These include the BWR Owner's Group, Atomic Industrial Forum, Institute of Nuclear Power Operations, Seismic Qualification Utility Group, Nuclear Transportation Group, Utility Nuclear Waste Management Group, Nuclear Fire Protection Owners Group, and Region IV Utility Group and Western Regional Utility Audit Group.
The licensee's nuclear management team has been effective in bargaining with the Board of Directors for allocation of funds to support, activities which assure quality.
For example, during the rating period, the Board questioned j
the expense of INP0 support.
The licensee's management staff was effective in convincing the Board of the possible detrimental effects on safety and quality of withdrawal from INP0.
In order to further improve top management's involvement and control in nuclear matters, the District has hired a highly experienced consultant as special advisor to the chief executive officer.
The licensee is rated Category I for this attribute.
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5.2 Approach to Resolution of Technical Issues from a Safety Standpoint In resolving technical issues relating to plant modifications, the licensce frequently adopts the industry position.
For example, in the case of ATWS (10 CFR 50.62) modifications, the District will perform the "Monticello" modifications on Cooper.
However, in the case of plant specific Technical Specifications amendment requests, the licensee frequently requests clarifying changes which do not follow the Standard Technical Specifications (STS)
-guidance. In most cases, the existing level of safety would be retained or somewhat improved, but not to the extent as would be if the STS was adopted.
An example is the licensee's application of February 10, 1986, relating to high radiation area administrative controls.
The licensee is rated Category 2 for this attribute.
5.3 Responsiveness to NRC Initiatives The licensee has consistently been responsive to'NRC-initiatives, from minor staff questions to implementation of major plant modifications.
The licensee tracks all NRC initiatives and responds or complies within the requested due date, or identifies and negotiates with the NRC as necessary when unable to comply.
Timely responses to NRC initiatives is considered one of the licensee's strengths.
The licensee's response to our May 30, 1986, request relating to MPA status is an example.
The licensee is rated Category 1 for-this attribute.
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5.4 Enforcement History
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No basis exists for a rating for this attribute in the functional area of licensing activities.
5.5 Reporting and Analysis of Reportable Events The Cooper Nuclear Station (CNS) was shutdown for scheduled refueling and maintenance outage for the first 7 months of the reporting period.
It operated _at power from August 1985 through July 1986 except for a shutdown of about 1 months from October 5 to November 22, 1985, due to high vibrations of the main turbine and for short periods at other times for other causes.
Not counting the period of scheduled refueling outage, the plant operated with a Reactor Service Factor (Hours of Critical Operation / Total Hours) of approximately 85% during a period of about 10 months (from August 20, 1985, to June 30, 1986).
During the 18 months covered by this SALP evaluation, the licensee reported 24 nonsecurity occurrences, of which 18 were reported under the provisions of 10 CFR 50.72.
The licensee also submitted 34 LERs (under 10 CFR 50.73) during this period.
Eleven of these LERs related to the events reported under 10 CFR 50.72.
Of the 24 occurrences of reportable events, only two events related to scrams, eight to engineered safety feature (ESF) actuations and nine to events in which an LC0 was not met, requiring entry into a Technical Specification Action Statement.
Four of the events were classified as unusual events and five events were caused by
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Only two scrams occurred from the last week of August 1985 to the last week of July 1986.
This reactor trip frequency of two during about 12 months of actual operations of the plant is much lower than the national average of 5.9 scrams per reactor year.
Three of the eight events involving ESF actuations were caused by mechanical and electrical-failures and the remainder were due to personnel error and other miscellaneous causes. Of the 34 LERs received during the report period, nine dealt with the inoperability of the high pressure coolant injection system, and four dealt with the reactor water cleanup system problems.
Two of the 34 LERs were received late by about 3 months beyond the permissible 30-day period prescribed in 10 CFR 50.73.
Only one event was considered significant for discussion at the NRR Operating Reactor Events Briefing (OREB).
The event occurred on June 16, 1986 and related to an excess unidentified reactor coolant system (RCS) leakage.
The event was of interest because the plant operated for nearly 37 hours4.282407e-4 days <br />0.0103 hours <br />6.117725e-5 weeks <br />1.40785e-5 months <br /> in a deinerted condition.
The leakage was readily identified and repaired.
Availability During this SALP period the plant reported an overall availability factor of 51.~ 6L This result was arrived at by including approximately 7 months of scheduled refueling outage and about 1 months of plant shutdown caused by the problem of high vibrations of main turbine, The plant capacity factor for the year 1985 was only 15'.7% using the design electrical rating (DER) net capacity.
The Year-to-Date Unit Availability Factor is 98.6L 5.6 Staffing During the major portion of the rating period the licensee maintained an enthusiastic, experienced licensing staff.
However, toward the end of the rating period several experienced personnel were lost from the Nuclear Licensing and Safety Department, and the forthcoming loss of the Technical Staff Manager was announced.
These losses could have a detrimental effect on the next period, however, the licensee is taking actions which should have a beneficial effect.
These actions include recruitment efforts and the possible physical relocation of part of the Nuclear Licensing and Safety staff to the site.
In addition, the District is actively reviewing its salary and compensation practices for its nuclear personnel relative to those of other utilities.
The licensee is rated Category 1 for Staffing in the area of Licensing Activities.
5.7 Housekeeping The NRR P nject Manager participated in an unannounced plant tour with the R-IV Branch and Section Chiefs on April 16, 1986.
The piant was in power operation at the time.
Housekeeping was observed to be above average.
The licensee is rated Category 1 for this attribut.
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6.0 CONCLUSION
. An overall performance rating of Category l'has been assigned for the functional area of Licensing Activities.
Section 042 of Manual Chapter 0516 defines the meaning of rating _a licensee's-performance Category _1 as follows: " 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 such that a high level of performance with respect to operational safety or construction is being achieved."
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Since the District was rated Category 1 in this area previously we plan no change in the-less attention given by NRC to the District's licensing submittals. We believe that no less management effort on the part of the-licensee should be exerted in licensing activities.
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SUPPORTING DATA AND SUMMARY 1.
NRR Site Visits / Meetings (Names refer to NRR participants)
Control Room Survey by NRR/Argonne Nat'l Laboratory (J. Hayes),
October 3-4, 1985 Emergency Preparedness Exercise, October 16, 1985 (E. Sylvester)
InserviceTestingMeeting(W.Long&H.Shaw), April 14-lh,1986 Appendix R Audit (D. Notley and J. Kudrick), April 21-25, 1986 DCRDR Meeting (W. Long & D. Serig), May 12-16, 1986~
2.
Commission Briefings None 3.
Schedular Exemptions Granted Annual Emergency Preparedness Exercise, Schedular Exemption, Letter from D. Vassallo to J. Pilant dated April 1, 1985.
4.
Relief Granted Extension of Deadline for Environmental Qualification of Electrical Equipment, Letter from H. Denton to J. Pilant dated March 26, 1985.
Temporary Waiver, Diesel Generator Annual Inspection, Memorandum from R. Martin to H. Denton dated May 29, 1986.
5.
Exemptions Granted None 6.
License / Technical Specifications Amendments Amendment 91, Letter from E. Sylvester to J. Pilant dated May 13, 1985 Amendment 92, Letter from E. Sylvester to J. Pilant dated May 20, 1985 Amendment 93, Letter from E. Sylvester to J. Pilant dated June 3, 1985 Amendment 94, Letter from E. Sylvester to J. Pilant dated September 24, 1985 Amendment 95, Letter from E. Sylvester to J. Pilant dated November 21, 1985 Amendment 96, Letter from W. Long to J. Pilant dated March 17, 1986
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Amendment 97, Letter from W. Long to J. Pilant dated April 9, 1986 Amendment 98, Letter from W. Long to J. Pilant-dated April 10,.1986 Amendment 99,-Letter from W. Long to J. Pilant' dated May 19, 1.986
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Amendment 100, Letter from W. Long to J. Pilant dated May 20,' 1986 7.
Emergency / Exigent Technical Specifications Changes
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Single-Loop Operation, Amendment 94, Letter from E. Sylvester to'
J. Pilant dated September 24, 1985.
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- Main Steamline High Flow Sensor Setpoint, Amendment 96, Letter from W. Long to J. Pflant dated March 17, 1986.
8.
Orders Issued
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" Order Modifying, License Confirming Additional Licensee Commitments on Emergency Response Capability," Letter from D.B. Vassalic to J.M. Pilant dated August 29, 1985.
9.
NRR/ Licensee Management Conferences BWR Project Directorate #2 and Utilities, Licensing Issues Meeting, Bethesda, April 10, 198 NRC FbM 708 '
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