IR 05000313/1987041
| ML20154J749 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 09/16/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154J747 | List: |
| References | |
| 50-313-87-41, 50-368-87-41, NUDOCS 8809230126 | |
| Download: ML20154J749 (32) | |
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SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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50-313/87-41 50-368/87-41 Arkansas Power & Light Company Arkansas Nuclear One Units 1 and 2 January 1,1987, through June 30, 1988 l
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I. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulation It is intended to be su/ficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their facility's performance in each functional are An NRC SALP Board, composed of the staff members listed below, met on August 16, 1988, to review the observations and data on performance, and to assess licensee performance in accordance with NRC Manual Chapter 0516,
"Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this repor "Se Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuanc This report is the NRC's assessment of the licensee's safety performance at Arkansas Nuclear One for the period January 1,1987, through June 30, 198 The SALP Board for Arkansas Nuclear One was composed of:
L. J. Callan, Director, Division of Reactor Projects R. L. Bangart, Director, Division of Radiological Safety and Safeguards J. A. Calvo, Director, Project Directorate IV D. D. Chamberlain, Chief, Reactor Project Section A J. E. Gagliardo, Chief, Operational Programs Section W. D. Johnson, Senior Resident Inspector C. C. Harbuck, NRR Project Manager The following personnel also participated in the SALP Board meeting:
A. T. Howell, Project Engineer L. Rubenstein, NRR Assistant Director, Region IV and Special Projects j
R. E. Farrell, Senior Resident Inspector
> V. Miller, Acting Deputy Director, Division of Radiological Safety and Safeguards R. C. Haag, Resident Inspector T. R. Staker, Resident Inspector R. E. Baer, Chief, Facilities Radiological Protection Section J. A. Kelly, Security Inspector R. J. Everett, Chief, Security ano Emergency Preparedness Section W. C. Seidle, Chief, Test Programs Section
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J. L. Milhoan, Director, Division of Reactor Safety
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2 Licensee Activities Major Outages
Unit I was shut down from January 9-19, 1987, to repair a steam generator tube lea *
Unit I was shutdown from October 16, 1987, until November 14, 1987, for a scheduled mid-cycle outage for ;
maintenance and surveillance test j
Unit 2 was shut down from April 24, 1987, until May 27, i 1987, to repair a pressurizer heater penetration leak caused by a failed pressurizer heate *
Unit 2 was shut down from July 7-16, 1987, to repair a 1 leaking pressurizer heater dummy plug seal wel Unit 2 was shut down for refueling outage 2R6 from February 12, 1988, until May 23, 198 . License Amendments t
Unit 1 Amendment 107 - Use of auxiliary building crane to move DGE cask containing six fuel rod :
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Unit 1 knendment 108 - Change RCS pressuie setpoint for HPI ;
and LPI initiation ;
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Unit 1 Amendment 109 - Reorganization of Nuclear Operations !
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Unit 2 Amendment 82 - Change boron concentration in storage (
tanks and safety injection tank
- Unit 2 Amendment 83 - Main steam safety valve testing
- Unit 2 Amendment 84 - Change maximum control element assembly drop time
- Unit 2 Amendrent 85 - Reorganization of Nuclear Operations
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Department Major Modifications Unit 1
- Installation of seismic condensate storage tank
- Installation of security turnstiles :
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Installation of pressurizer spray valve isolation valves Replacement of Potter Brumfield MDR relays
Installation of RCS refueling level indications Replacement of segments of carbon steel service water piping and valves with stainless steel
Replacement of a station battery
Contro? room panel surface enhancement
Installation of security turnstiles
Replacement of two battery chargers
Pressurizer heater penetration permanent repai Direct Inspection and Review Activities NRC inspection activity during this SALP evaluation period included 56 inspections performed with approximately 7567 direct inspection can-hours expended. The inspections included a quality verification functional team inspection and an emergency operating procedure team inspectio II. SUWiARY OF RESULTS Overview Licensee management attention and involvement have been evident and emphasis has been placed on superior performance in the areas of plant operations, radiological controls, and emergency preparednes Continued improvement was noted in the area of plant operations and it is evident that the licensee is striving for excellence in this are Significant improvement was noted in the licensee's performance in the areas of emergency preparedness, and securit While performance in the training and fire protection areas were considered to be excellent, the area of engineering and technical support was judged to have weaknesses in root cause evaluations, corrective actions, and in communications between maintenance and engineering. Recent changes in the design change process and in the condition reporting and corrective action programs remain to be evaluated for long term effectivenes .
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The licensee's performance in the area of responses to NRC initiated safety and regulatory issues and licensee submittcls for license amendments declined during this evaluation period. Many of these responses and submittals were deficient in technical content, completeness, and/or timeliness. Significant improvement is needed in this are The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period:
Previous Present Performance Performance Category Category Functional Area (07/01/85 to 12/31/86) (01/01/87 to 06/30/88) Plant Operations 1 1 Radiological Controls 1 1 Maintenance 2 H/A* Surveillance 2 N/A* Maintenance / Surveillance N/A* 2 Fire Protection 1 N/A* Emergency Preparedness 2 1 8 Security 3 2 Engineering / Technical N/A* 2 Support 10. Outages 1 N/A*
11. Safety Assessment / N/A* 2 Quality Verification 12. Quality Programs and 2 N/A*
Administrative Controls Affecting Quality 1 Licensing Activities 1 N/A*
14 Training and 1 N/A*
Qualification Effectiveness
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- NRC Manual Chapter 0516 was revised on June 6, 198 This evaluation was performed in accordance with the revised manual chapter. The major change involved restructuring of the functional area III. CRITERIA Licensee performance was assessed in seven selected functional area Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observaticn The following evaluation criteria were used, as applicable, to access each functional area: Assurance of quality including management involvement and contro Approach to the resolution of technical issues from a safety standpoin Responsivene's to NRC initiative Enforcement histor Operational events (including response to, analyses of, reporting of, and corrective actions for). Staffing (including management). Effectiveness of training and qualification progra However, the NRC is not limited to these criteria and others may have been used where appropriat On the basis of NRC's assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:
Category 1 - Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and effectively used so that a high level of plant and personnel performance is Sing achieved. Reduced NRC attention may be appropriat Category 2 - Licensea management attention to and involvement in the performance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant anc personnel performance is being achieve NRC attention may be n.aintained at normal level __
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Category 3 - Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirement Licensee resources appear to be strained or not effectively used. NRC attention should be increased above 1ormal level I PERFORMANCE ANALYSIS Plant Operations Analysis The assessment of this area consists chiefly of the control and execution of activities directly related to operating a plan It is intended to include activities such as: plant startup, power operation, plant shutdown, and system lineups. Thus, it includes activities such as monitoring and logging plant conditions, normal operations, responding to transient and off-aonnal conditions, manipulating the reactor and auxiliary controls, plant-wide housekeeping, control room professionalism, and interface with activities that support operation This area has been inspected on a continuing basis by the NRC resident inspectors and on several occasions by NRC regional inspectors. Specific areas inspected included operational safety verifications, safety system walkdowns, followup on significant events / problems, and review of Licensee Event Reports (LERs). In addition, a special team reviewed the Unit 1 emerger.cy operating procedures. While the operating procedures were of generally good quality, procedure deficienc'es were a root cause or contributing cause for most of the violations and LERs in the plant operations area. These violations and events are considered to be isolated cases of inattention to detail by operators or support staff ptesonnel. The violations identified in this functional area involved failure to perform a safety evaluation prior to operating systems in temporarily mcdified configurations, int' equate locking of manual valves or inconsistent procedures relating to locking manual valves, failure of operator s to follow procedures, inadequate procedures for testing high/ low pressure interface check valves, and missing plugs f rom emergency diesel generator coolant drain lincs. Two LERs addressed subcritical reactor trips on Unit 2 due to inadequate procedures and operator errors. Another LER discussed failure to n.aintain a manual containment isolation valve shut as require in 1987, the licensee developed a procedure writer's guide for the operations department end initiated a project to rewrite the emergency, a' o normal, and system operating procedures. At the end of this assessment period, the emergency operating
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procedures (EOPs)foreachunithadbeenrewritten. The special team inspection of Unit 1 E0Ps concluded that they were adequate
, for continued operation of the facility. Of the 140-150 other procedures per unit,17 for ANO-1 and 43 for ANO-2 had been rewritten. The licensee has assigned additional staff, supplemented by contract personnel, in order to complete rewriting the procedures by mid-199 No significant system misalignments were identified during system walkdowns performed by the resident inspectors. However, a misalignment of a valve associated with the Unit 2 containment integrated leak rate test was identified as discussed in the Maintenance / Surveillance section of thio report. During this assessment period, the licensee essentially completed the plant relabeling project. The major effort not yet completed was the '
independent verification of proper tagging on Unit 2. However, at the end of the assessment period, some cases of errors on component labels or component identification in system lineup procedures were identified by resident inspectors. System lineup procedures are being revised to include a check of proper component labeling during system lineups. This should help maintain proper component tagging in the futur At the end of the assessment period, the licenseo had a total of '
l 62 person 1ei licensed as reactor operator or senior reactor
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operator for ANO-1 and 54 for ANO-2. Having this large number of licensed personnel has allcwed the use of licensed personnel in non-watchstanding roles such as special projects or transfer to departments other than operation ;
Plant operations personnel were on a six-shift rotation. Their morale and professionalism both appeared to be high. They were .
caieful in the conduct of their duties, including proper use of plant procedures. Within the control rooms, restricted areas have been marked and personnel requiring access to these areas must first obtain the permission of the plant operator. No distractions such as music or extraneous reading material have been observed in the control rooms. A standardized dress policy for licensed operators on shift was implemented in early 198 l
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This has enhanced the operators' professional appearance. A program of observation of operations watchstanders by senior operations department personnel has been continued. This program has resulted in comments and suggestions leading to improved procedures and standardized watchstanding practice The number of annunciat'r alarms which are illuminated in the control rooms due to improper logic, instrumentation calibration, or abnor'nal equipnv nt conditions continns to be excessive. Licensee representative have stated a goal of power operations with a "black board," but progress toward this goal has been slow. These illuminated annunciator alarms make an
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additional alarm condition more difficult to identify and place an extra burden on the operators. An additional complicating factor for operators to overcome is the excessive number of
, minor equipment problems represented by deficiency tags in th control rooms. Most of the equipment problems are not significant and many are associated with nonsafety-related equipment, but an undesirable backlog has been allowed to accumulate. Licensee management is aware of this problem and is addressing it through a special tracking system for control room ,
deficiencies and by giving increased visibility and priority to repair of control room deficiencies. These efforts have not been fully effective as evidenced by the excessive number of deficiencies represented by deficiency tags remaining in the Unit 2 control room at the end of its refueling outag During refueling outage 2R6, the Unit 2 control room control panels were r:nhanced for human factors using improved labels,
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color codinc, 6nd system boundary lines. A similar effort had previously been e mpleted on Unit 1. The safety parameter display systems and the inadequate core cooling monitoring ,
systems have been well-received by the operators. These systems should enhance operator effectiveness in both routine and abnormal condition The licensee initiated a Transient Reduction Program in 1985 in ;
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an aggressive attempt to reduce the number of plant trips and transients. The following table indicates an improving trend in
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the number of reactor trips from powe (1st half)
Unit 1 6 2 2 1 Unit 2 10 5 2 0 Each ANO unit has a plant specific simulator located at the training facility near ti;e plant. These have been used extensively for operator requalification training and for training of operator license candidates. Plant design changes ,
have been incorporated into the simulators in a timely manne The licensee's shift technical advisor (STA) program was strengthened during this assessment period. Seven of the twelve STAS received operating liceases for their assigned units. The STAS are on watch for 12-hour shifts. Their assigned duties include perfomance of plant tours and system walkdowns. One walkdown per unit per week was being performed by STAS at the end of the assessment period. Discrepancies identified during these walkdowns have been documented in job orders and/or condition report _, - - - - - - _ _ _ _ , _ _ - .
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Early in this assessment period the licensee implemented a college degree program for shift supervisors and control room supervisors. Twenty-five personnel have been attending Arkansas Tech University on a 6-month rotating basis. Each of these participants is expected to have earned a degree by 1990. The degree to be earned is a Bachelor of Science in Physical Science (Nuclear). This degree was developed by the licensee and Arkansas Tech University and is oriented toward nuclear plant operations and engineering. The licensee has efforts underway to allow other plant operators to gain college degree credit In addition, the licensee is attempting to recruit degreed personnel for entry level operator position Other positive developments in the plant operations crea included:
. Establishment of written Control Room Standards to supplement procedural guidance. These standaros are used both in the control rooms and during simulator evaluations and are intended to standardize operations for all shifts and for both units. The standard, address such topics as professional appearance, conduct, attentiveness, division of responsibilities, teamwork, and comunication . Development of a Professinral Nuclear Operator Code by a committee of operators. This code is displayed in the control rooms and in the simulator . Establishment of the operations support facility. This structure is located or, the main turbine deck across from the control rooms. :: has served to reduce congestion in the control rooms by providing a working space for auxiliary operators, support crew operators, operators with special tasks during outages, and operators providing interface with the work control cente . Upgrading of plant-wide housekeeping. During this assess.aent period, most of the entire plant, includi equipment, floors, and walls, was repainte . Performance Riting The overall assessment of this area indicates an improvement in performance. While there have been instances of personnel error and procedural inadequacies, these have been isolated and have been resolved appropriately. There are many indications that the licensee is striving for excellence in this functional are The licensee is considered to be in Performance Cttegory 1 in this are '
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10 Reconsnendations NRC Actions The NRC inspection of this functional area should remain consistent with the fundamental inspection program with emphasis on technical support for operations, Licensee Actions Licensee management is encouraged to continue improvement efforts in this functional area, including:
. Reduction of nuisance alarm . Revision and improvements of plant and system operating procedure !
. Reduction of the backlog of deficiencies indicated by the high nuaber of deficiency tags in the control room . Aggressive pursuit of resolution of deficiencies identified by operator t B. Radiological Controls Analysis, ,
The assessment of this functional area consists.of activities directly related to radiological controls including occupational radiation safety (e.g., occupational radiation protection, radioactive materials and contamination controls, radiation fleid control, radiological surveys and monitoring, and as low as is ,
reasonably achievable programs;, radioactive waste management (i.e. processing and onsite storage of gaseous, liquid, and solid waste),, radiological effluent control and monitoring (including gaseous and liquid effluents, offsite dose calculations, radiological environmental monitoring, ated confirmatory measurements), and ;
transportation of radioactive materials (e.g., procurement of packages, preparation for shipment, selection and control of ,
shippers, receipt / acceptance of shipments, periodic maintenance of packagings, ano point-of-origin safeauards activities.) ;
Eight inspections in the general functional area of radiological controls were performed during this assessment period by regional .
radiation specialist inspectors in addition to the resident inspectors' routine inspections. There were seven violations and one deviation identified in this functional area. The violations and
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deviation reflect minor problems and are not an indication of major breakdowns within the radiological controls area, but rather the occasional lack of attention to detail in implementation of the progra Management involvement within the radiological controls area was evident by the performance of comprehensive audits / reviews by both corporate and onsite groups. The audit / review teams usually included a team member with expertise in the assigned speciality area being reviewed which contributed to the quality of the evaluation Management support was also evident by the issuance of policies and directives requiring worker adherence to radiological control procedures. The licensee assigned a health physics supervisor to the radioactive waste group to enhance radiological controls in this are The licensee has maintained a stable, experienced staff. The personnel turnover rate within the radiological controls area during this assessment period was below 10 percent. Vacancies were filled in a timely manner with qualified personnel. The resolutions of technical issues were almost always accomplished on the basis of sound technical judgemen The collective radiation exposures, per reactor, for 1986 and 1987 were 571 and 191 person-rem, respectively, which compares to the national average of 390 and 371 person-rem, respectively. The higher person-rem values for 1986 appear to be the result of two refueling and one major maintenance outage and was not an indication of poor occupational radiation safety practic The licensee has taken aggressive action to reduce the square footaga of contaminated areas within the radiologically controlled area. The licensee is maintaining contaminated areas where protective clothing
- is required to less than 10 percent of the total area outside of the reactor containmen The licensee ALARA program includes a Program Management Review Conmittee which provides for program oversight, review of radiological events, and development of solutions to programatic problem The radioactive w ute reduction program has resulted in a substantial i reduction in the volume of waste generated. The volume generated in ,
1987 was approximately one-fifth of the 1985 level, j
No significant problems were identified in the radiological controls l area. The increased number of violations indicate a decrease of I licensee attention to the detailed conduct of day-to-day operatio The licensee continues to maintain effective programs in the area of
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.12 management oversight, resolution of technical issues, responsiveness to NRC initiatives, personntl training and qualifications, procedures, and staffin . Perfonnance Rating The licensee is considered to be in Performance Category 1 in this are . Reconsnendations NRC Actions The level of NRC inspection in this functional area should he consistent with the fundamental inspection progra Licensee Actions The licensee should continue to make improvements in the existing program. Supervisory attention should be increased in the detailed conduct of day-to-day operation of the occupational radiation safety progra C. Maintenance / Surveillance Analysis This fune.tional area includes all activities associated with either diagnostic, predictive, preventive or corrective maintenance of plant structures, systems, and components; procurement, control, and storage of components, including qualification controls; installation of plant modifications; and maintenance of the plant physical l condition. It includes conduct of all surveillance (diagnostic)
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testing activities as well as all inservice inspection and testing activities. Examples of activities include 1 are instrument ;
calibrations; equipment operability tests; postmaintenance, l
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postmodification, and postoutage testing; containment leak rate tests; water chemistry controls; special tests; inservice inspection and performance tests of pumps and valves; and all other inservice :
inspection activitie :
This area was inspected on a routine basis by the NRC resident inspectors and periodically by NRC regional inspector ;
It is evident that licensee management has given additional attention to the maintenance / surveillance area during this asset sment perio Several long tenn improvement projects were either conpleted or were nearing completion at the end of the period. Other programs initiated during this assessment period indicate management support for program improvement and for upgrading the overall material condition of the pl. int. The licensee has maintained a satisfactory
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13 i level of performance in this area. The licensee's program for scheduling, tracking, and performing surveillance tests has been adequate, with a low error rat Several cases of missing or deficient seismic supports were ;
identified by NRC inspectors during the assusment period. Two of these were cited as violations and the other two were considered -
additional examples of the violations. In addition, one LER discussed an improperly installed seismic support. The cause of these seismic support deficiencies could not always be determined, but in some cases it was the failure to properly reinstall a seismic support af ter removal for maintenance. One violation involved work being performed without an approved job order. One violation identified inadequate preventive maintenance program coverage of pump coupling lubricatio Four LERs reported reactor trips or safety i
system actuations in which improperly performed maintenance or ,
inadequate preventive maintenance was a facto ;
The licensee discovered a primary system safety valve with an elevated lift setpoint in December 198 This issue was mentioned in the previous SAlp report. During this assessment period a Notice of
- Violation was issued and a civil penalty was imposed for this violation. It was detennined that personnel errors and/or procedural
, inadequacies during pressurizer code safety valve maintenance and testing in September 1986 contributed to plant operation for about
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one year with ar. inoperable pressurizer code safety valv Two other violations we.e identified during this assessment period, one involving fai!ura to sign a calibration sheet during a nondestructive examination and one involving valve lineup errors during preparation for a containment integrated leak rate t test (CILRT). The valva lineup errors were caused by operators
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failing to properly verify the lineup and by the failure of the
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controlling procedure to adequately address the requirements of the
- ANO independent verification polic I One LER reported the failure to perform a surveillance test on the standby penetration room ventilation system as required prior to a Unit 1 startup because of personnel erro !
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During this assessment period the licensee has made significant improvements in its maintenance / surveillance progra Some of these :
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- The corrective maintenance and surveillance procedure upgrading project was continued with the rewriting of procedures in accordance with a writer's guide. Most procedures which are used frequently, and those expected to be used during the next '
- refueling outage, have been completed. Project completion is
- expected by the end of 198 .
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The preventive maintenance program overhaul was continued. Most engineering evaluations have been completed, all required preventive maintenance procedures have been drafted, and about half have been approved. Project completion is expected in Decenber 1988. A new section in the plant engineering department is being organized to provide continuing technical support for preventive maintenanc *
The project of updating and cataloging vendor technical information was recently completed. Plant engineering will provide continuing support to maintain this information in a current statu *
Useofthestationinformationmanagementsystem(SIMS)was expanded to track preventive maintenance. Development work is underway to better use this system to coordinate corrective maintenance, preventive maintenance, and surveillance testin *
Maintenance training has been improved and oral boards have been established to verify a craftsman's competence and readiness to be promoted to the level of journeyma *
Planning and coordination of maintenance and surveillance has improved. The work control center started publishing a 5-day rolling maintenance schedule. T'1e work control center also started providing evening coverag Management involvement has been more evident than in the pas Planning reetings are held each morning. In these meetings, department managers discuss plant status and ongoing and upcoming maintenance activities and coordinate the required suppor Maintenance supervisors and superintendents have been observed in the field at job locations more than in the past. Quality control coverage of maintenance and surveillance has also been observed at an increased level compared to past SALP cycles. A maintenance oversight team has been established. This aroup reets regularly to review maintenance performance indicators and goals. The team consists of maintenance department, work control center, and corporate personne A material deficiency identification program was initiated and was nearing completion at the end of this assessment period. Two teams of four persons each have been systematically wal(ing down the plant, room by room, identifying material deficiencies and housekeeping problem The NRC inspector's continuing review of the ANO surveillance program indicated that the components and systems reviewed had been tested in accordance with controlled procedures and that testing had been completed on schedule, with the exception discussed in one LER mentioned above. Numerous survelliance tests were witnessed during
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this assessment period. The tests observed were completed properly using adequate and controlled procedures, within the required interval, by qualified personne ,
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Two cases were identified in which surveillance testing did not '
adequately demonstrate that the system met its technical specification requirements or design basis. A Unit 2 LER discussed one case involving control element assembly drop times. Another case was identified as an unresolved item. In this case, the penetration .
, rooir ventilation system surveillance testing was considered ,
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inauequate to demonstrate that the systems were capable of drawing flow from and producing a vacuum in each of the Unit 1 penetration ;
rooms, although the testing met the technical specification l requirement The licensee handled the control element assembly drop
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time issua responsibly, providing timely analysis, applying it in a conservative manner, and keeping the NRC fully informe Progress ,'
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toward resolution of the penetration room ventilation system functicnal capability issuc has been slo . Performance Rating The licensee is considered to be in Performance Category 2 in this [
are . Reconnendations I NRC Actions
The NRC inspection effort in this area shimid be consistent with the fundamental inspection program, augmented by a maintenance team inspection, while monitoring the progress of the licensee's improvement pregram Licensee Actions
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Licensee management should continue its emphasis on upgrading l
performance in the maintenance and surveillance areas. The licensee should continue upgrading maintenance and surveillance procedures to a standardized format including appropriate human ,
factor considerations. During this process, consideration !
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should be given to system testing to prove functional capability i in addition to meeting technical specification requirement ;
. D. Emergency Preparedness Analysis The asscssment of this area included the licensee's preparation for radiological emergencies and response to simulated emergencies
(exercises). This assessment encompassed: emergency plan and implementing pru.edures; emergency facilities, equipment, l r
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instrumentation, and supplies; organization and management control; training; independent reviews / audits; and the licensee's ability to implement their emergency pla During the assessment period, region-based and NRC contractor inspectors conducted si' emergency preparedness inspections. Two of these inspections cent 1sted of the observation and evaluation of annual emergency response exercises. During the March 18, 1987, exercise, the inspectors identified two deficiencies, and closed five deficiencies from a previous exercise. During the 1988 exercise, the inspectors ider.tifiod two additional deficiencies and closed one from the previous (1987' exercise. Four routine inspections resulted in the closure of thre.e violations, one deviation, and 17 deficiencie In summary, the inspectors identified four deficiencies during this SALP period. The two deficiencies identified during the 1987 exercise concerned Emergency Action Level procedure The two deficiencies occurring during the 1988 excrcise involved human errors and weak performance of some emergency responders during the exercise. However, these deficiencies are not indicative of progrannatic breakdow Management involvement has increased in this area as noted by the licensee's complete review and revision of Emergency Action Level Another example of positive management action resulted in an excellent self-critique of their performance during the 1988 exercise. The absence of violations, the small number of deficiencies observed during the inspections denote a responsive posture to NRC findings. Clear understanding of issues and technically sour.d resolution of technical issues was evidenced by the corrective actiers taken by the 1;censee (e.g., complete review and revision of the Emergency Action Levels). These factors indicate that the licensee has a:hieved considerable improvement in their emergency preparedness progra . Performance Rating The licensee is considered to be in Perfor ance Category 1 in this are . Recomyndations c NRC Actions The NRC inspection effort in this area should be consistent with the fundamental inspection program, Licensee Actions The present le w' of management attention to the implementation of the emergency preparedness program should be raintaine _ , _ _ - _ _ . . ._ - . - - - _ - -
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E. Security Analysis The category of security includes all activities whose purpose is to ensure the security of the plant. Specifically, it includes all aspects of the security program including ancillary efforts such as fitness for duty, fingerprint backgrcund investigations, and the QA audit progra The category also includes iilanagemer.t effectiveness in developing, implementing, and supporting security program s area was inspected on a continuing basis by the NRC resident inspectors and six inspections were conducted by region-based security inspectors. The licensee had previously identified one of the seven violations ident.ified during these inspections. Between January and June 1987, a consolidated violation identified by the NRC security inspectors resulted in an escalated enforcement action. A civil monetary penalty was assessed. Although four of the seven violations were identified since June of 1987, these four are considered minor isoleted problem The 11censeo restructurec the security management organization and elevated the level of senior security manager and added additional security management positions at the site and corporate level. These initiatives have resulted in a positive enhancement to the ANO security progra The licensee's fitness-for-duty anti errployee-assistance-program appears to be effective and consistent with the NRC Policy Statemen The licensee has significantly reduced the number of personnel whn are granted unrestricted access to vital area The licensee budgeted for new security equipment in 1988 and has been systematically upgrading the security system. The licensee is currently improving the protected area perimeter detection aids and closed circuit television syste A new perimeter security system is being constructed and installe The licensee has had programmatic difficulties with er :nd physical controls of the lock and key program as demt.is ' W by two separate violations. These ev'nts were unrelated but wer; thin t%
same program area. This continuing problem with the lock and key program may indicate a need for more rigorous root cause determinations for security violation . Performance Rating The licer.see appears to have an adequate staff and fully qualified 50curity personnel to support the cortmitments of the security pla . .
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Since June of 1987, the licensee's management attention, initiatives -
and involvement with security matters has improved and perfo.mance was observed to begin an improving trend.
- The licensee is considered to be in Performance Category 2 in this are . Reconnendations NRC Actions NRC inspection effort should be consistent with the fundamental inspection program. That effort should be supplemented by regional initiatives and reactive inspections that will review and evaluate the security program changes to determine if real improvement has been accomplishe Licensee Actions The licensee should probe the root causes of security viola'. ions and audit findings for broad implications. Determinations should provide guidance to adjust security policy and procedures. Corporate and high level site management oversight should continue until a high level of security awareness is pervasive throughout the ANO f'cilit F. Engineering and Technical Support 1. Analysis The assessment of this area includes all licensee activities associated with the design of plant modifications; engineering and technical support for operations, outages, maintenance, testing, surveillance, and procurement activities; training; configuration management; and fire protection / preventio In order t nors . trly define the specific strengths and weaknesses noted in . ,nal area, the analysis is divided into four areas, as discussed belo En,gineering and Technical Support for Outages This area includes engineering and technical support for major outages. This area was inspected on a continuing basis by the NRC resident inspectors during the outages which were conducted during this assessment period. NRC regional inspectors also cond".ted inspections during the outage Three violations were identified in this area during the appraisal period. One violition involved excessive debris and loose tool:; on the fue' handling bridge during the Unit 2 refueling outage. Two
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3 other violatior.s in this area identified inadequate material control and drawing control in the modification process. An LER wss submitted for each unit which reported design defit.iencies resulting in incorrect installation of solenoid valves and the degradation of containnent isolation capability. Another LER reported the inoperability of a Unit I reactor building hydrogen monitor due to a drawing error and inadequate testing after a modification was g completed in December 198 Extensive planning and preparation for outages by the licensee were evident. The licensee has formed an outage planning and cont ol group in the work control center, consisting M five full-time employee There was a well organized outage management systen, using temporary assignments of personnel to key positions such as w hge coordinatt , reactor building coordinator, and various project coordinators. An outage handbook was published prior to the Unit 2 refuel . E outag This handbcok established the outage organization, identified personnel respcasibilities for various tasks and projects, described various outage projec.s. and established lines of conmunii w tions. Maintenance and design change activities were planned in advance, prioritized, and coordir.ated with each other and with plant system conditions. Li ensee personnel resources were
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supplemented with centracter personnel as needed during the outage Although most of the available management attention and licensee ,
resources were directed to the unit which was in an outage, required l surveillance tests and priority maintenance activities were performed on the cperating uni The post modification testing program a1d the process for turning over modified systems to operations were significantly improved during this asse:strent period. New procedures required pre;aration of an installation plan for each modificatio The plan identified required post modification testing and required system walkdowns by engineering and operations prior to system turnover. Any minur p en items existing at the time or system turnover were tracked on a punch lis The liceisee's perfornance in the area of outages could be iraproved by significantly reducing the number of minor equipment deficiencies which continue to exist when a unit starts up af ter a major outag The number of outstanding deficiencies indicated by deficiency tags I on the main control panels of the Unit 2 control roe-' was excessive following the Unit a refueling outage. Since some o' hese items O require plant shutdown conditions or procurement of parts for
< J ., correction, it appeared that thej would continue until at least the
.d/, next major outage.
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20 Engineering and Technical Support for One_ rat on, Maintenancex Testing, !
Surveillance, and Procurement Activities
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This area includes the engineering and technical support related to the day-to-day operation, maintenance, surveillance arsd testin :
j The findings from the continuing inspection efforts of the resident t inspectors and periodic region-based inspections provided insights 4 into this aspect of the licensee's support programs. The SALP
! Board's review of these inspection findings indicate weaknesses in the engineering / technical support functio l The corrective actions taken to fix the specific problems identified ,
by the LERs that were reviewed for this area were generally sound and j
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thorough. However, the licensee's stated corrective action often <
concentraced on the specific event being reported, with inconsistent !
root cause determina+. ions, i
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There were indications of a lack of effective communication between I engineering and the maintenance staffs. Examples of these indicators '
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The fact that the rr; placement keys for Limitorque valve [;
operators which were procured in response to Inspection and
) Enforcement Notice 81-07 had not been installe j
The naintent. ace practice of reroving one of the shields from '
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double shielded Searings qualified for use in the containment j cooling fan motor !
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The practice cf repairing stator insulation with Glyptol in lieu !
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of the varnish qualified for the containment cooling fan motor l
The failure to incorporate vendor recommendations into the !
repair procedures for the containment cooling fan notors, j
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l These practices suggest that th. maintenance staff may be assuming a., [
i engineering function in their actempt to solve operational problem ;
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There were also indications of inattention to detail on the part of ,
' the engineering / technical support staffs. Examples of this 1 tv ttention to detail were-1 i j
' The failure to cdequately document the evaluation of the laminar
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indications on the Unit I reactor coolant system hot le i j
The initia'l errors in the calculations for the fasteners used on
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the support brackets for the high pressure injection :
i recirculation valve and the subsequent use of inappropriate ;
- fasteners for the opplicatie l
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The failure of the licensee to effectively address diesel generator fuel oil issues following the event reporte1 in
, LER 86-014 (Unit 2). After the issue was raised in NRC i Inspection Report 87-23, the licensee began to effectivel c review this issue, i i
The failure to have analyzed the adequacy of the body-to-body bolted joint for the Unit 1 pressurizer code safety valves until ;
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the question was raised in NRC Inspection Report 87-2 ,
The failure to evaluate the adequacy of the Combustion ;
Engineering repair of the Unit 2 pressurizer heater dumy plug '
welds which led to a subsequent seal weld failur The inattention to detail on the part of the engineering and technical support staffs was a concern raised during the previous "
l SALP period. The licensee has not been fully effective in correcting .
4 the problam, 1'
During this assessment period, i special team inspection was a
conducted to examine the implementation of and compliance with the j safe shutdown requirements of 10 CFR 50, Appendix Although one t violation was identified, the overall results of this inspection were !
positiv ; Configurf, tion Management / Design Change Process During the last SALP period, it was noted that improved performance a was needed in the areas of design change control, configuration 1 control, accuracy of drawings, quality of safety evaluations, and reduction of backlog in closing out cutstanding items. During this
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reporting period, a civil penalty was imposed for operating Unit 1 '
for 13 y 3rs with temperatures in some parts of the Unit 1
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i containment building higher than specified in the plant's Safety t Analysis Report. In response to the civil penalty, the licensee noted the principle deficiency in this matter resulted from a weskness in its design process and that previously existing administrative programs governing design interfaces was the root cause which resulted in failure to integrate the containment building temperature anomaly into all phases of the design control program.
! To improve the efficiency of interfaces, the majority of corporate engineering has been reassigned to Nuclear Operations, reporting directly to the Vice President, Nuclear; engineering diaciplines havn !
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undergone some consolidation to reduce the number of interfaces required; and nuclear engineeMng has been relocated into the design ;
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engineering organization in order to ensure that safety analyses are in the mainstream of design engineering efforts. The engineering organization located onsite has been restructured as a major department in an effort to maximize the efficiency of that interface :
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into the design engineering organizat. ion. These efforts have been aimed at correcting those weaknesses which were attributed to poor intraorganizational comunications and interface Building upon the organization realignment, programatic changes in
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the design process have been initiated concerning the development of design change packages (DCP).
Supporting these improvements to the design process are efforts to develop individual design engineering personnel via a customized training program utilizing INPO criteria for job task analysis based trainin As integral to those efforts in improving the design process, AP&L has evaluated the plant modificetion process to deterrine where improvements can be made to this function. Steming from this effort, and in conjunction with organizational changes made to the design engineering organization, a reorganization of Nuclear
- Operations resources created an onsite Plant Modifications Department. As with the other changes to the nuclear organization, these realignments wore aimed at resolving past concerns related to ,
effective interface and comunications. In this case, the objective
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was to improve this aspect where it involved design development and
, installation of a design into the plan The major programatic improvements which have accompanied the ;
- arganizational realignment include the development of a Plant
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.4odification Manual, the development and approval of a Plant Modification Process Implementation Plan and the development of implementing procedure To address concerns relating to internal as well as external reporting of significant items. AP&L has implemented a central .
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corrective action system (alled the Ccadition Reporting System. This system fosters an integrated approach to reporting deficiencies at .
ANO. The Condition i<eporcing System specifically provides for the identification and disposition of deviations from design '
documentatio M part of the Condition Reporting System project, a control system for Condition Reports has been developed to provide further assurance
t3dt corrective actions are tracked until closeout, and that historical documchtation is properly retaine [
A number of other programs rthted to this area have also been initiated:
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- Safety System functional Inspection Self-Assessment
- Design Bases Documentation Consolidation
- Computer-Aided 0*afting
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- Industry Experience Feedback Program for Design Engineering Isometric Update Project
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d. Training ano Qualification Effectiveness The assessment of this area includes all activities of the initial training and the requalification training programs conducted by the i licensee's staff. This area was inspected on a continuing basis by
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the resident inssectors. This area was also the subject of two inspections whic1 were performed during the appraisal period to look into the training of both the licensed and nonlicensed staff, i During the appraisal period, licensing examinations were administered
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by the NRC for both units. For Unit 1 six senior reactor
operators (SRO) were given the written examinations, and only one
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applicant failed. At the close of the evaluation period, he had not been retested. For Unit 2, thirteen SR0 license examinations were u administered with all applicants passing the written and operating examinations. Six reactor operator (RO) written and operating l
examinations were administered to applicants from Unit 2. One
applicant had to retake the written examination. . After the retake all R0s had passed the examination, j At the end of the appraisal period, the licensee h d 47 SRO and 15 R0 1 licensees for Unit 1 and 40 SR0 and 14 R0 licensees for Unit 2. The
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training inspection early in the appraisal period identified several
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weaknesses, some of which were crested in the implementation of the revision to 10 CFR Part 56. The weaknesses were promptly corrected
- and resolved as determined by the training inspection conducted ac l the end of the appraisal period.
> + The licensee has maintained a wel! qualified training staff. A 2 majority of the licensed operator instructors had been previously l licensed or curreely maintained a license at AN .
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inspections into nonnicensed 1.taff training indicated excellept coordination between the plant organizations and.the training
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I departmen Excellent use was made of on-the-job training to provide experience j and familiarity to employee Overall, the training program was well defined and implen.ented.
l Means had been established to provide for feedback of experience fron
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both within and outside the utility. The training department had an j attitude for self-improvement, and had implemented lessons lea-ned j from the feedback mechanism.
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2. Performance Rating The licensee is considered to be in Performance Category 2 in this are The licensee has demonstrated significant improvement in the area of licensed operator training, and the area of design of plant modifications has shown indications of improving. The area of engineering and technical support is in need of further improvemen . Recommendations NRC Actions ,
The NRC inspection effort in this area should be consistent with the fundamental inspection program, augmented by a special team inspection devoted to the areas of engineering and technical suppor Licensee Actions Licensee management is encouraged to continue the improvements evidenced in the design of plant modifications areas. Management needs to review the engineering and technical support areas to determine the root cause for tne weaknesses in these areas and
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whether recent improvements will correct identified problem G. Safety Assessment / Quality Verification Analysis This functional area includes all licensee review activities associated with the implementation of licensee safety policies; licensee activities related to amendment, exemption and relief requests; response to generic letters, bulletins, and infomation ;
notices; and resolution of THI items and other regulatory 1 ini'4atives. Also included are licensee activities related to t
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- esolution of safety issues, 10 CFR 50.59 reviews, 10 CFR 2).
assessments, safety comittee and self-assessment activitie l analysis of industry's experience, root cause analyses of plant events, use of feedback from plant quality assurance / quality l control (QA/QC) reviews, and participation in self-improvennt i programs. It includes the effectiveness of the licensee quality
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verification function in identifying and correcting substandard or !
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anomalous performance, in identifying precursors of potential problems, and in monitoring the overall performance of the plan '
During this '79 period, the licensee has demcnstrated the capability to respond to significant safety and regulatory issues with adequate mana3ement invol'!cment, sound technical analysis, and responsiveness to NRC concerns. This capability was evident in the actions taken to resolve the ANO-2 pressurizer heater penetration leak repair and in the AN0-1 reactor building high temperature f-N , - . - - - , . - - - - ., - - - _
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justification for continued operation (JCO) submittal and the associated followup on action The initiative demonstrated by the licensee to resolve these issues was understandably driven by their impact on plant o)eratio However, the licensee did not always demonstrate suc1 initiative for safety and regulatory issues which had no short term impact on plant operation. The licensee's initial response to NRC concerns about the reactor building temperaturo issue was untimely and superficia Uhen it became clear that continued plant operation was being challenged, the licensee responded rapidly with a massive effort that enab'ed resolution of the issue in a short time. The JC0 walkdown effort conducted during the ANO-1 midcycle outage was outstandin Additionally, the licensee was responsive to subsequent staff qucstions concerning the surveillance and maintenance of the containment building tendons. The licensee should adjust their priority to resolve outstanding safety and regulatory issues in the same expeditious manner derr.onstrated during the resolution of issues that challenged continued plant operation The overall quality of licensee responses to NRC initiated sefety and regulatory issues and licensee submittals for license amendments has declined during this rating period. The technical content and completeness resultant requests of many licensee submittals for additional informationwere inadeq)uate (RAls were rarelyand the responded to on tim Some responses were received over a year after the date requested by the staff. Examples of issues where the licensee's submittals were either late and/or inadequate follow:
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5atety Parameter Display System. An RAI response was received after 18 months; additional information was still neede * Generic Letter 83-28 Item 2.2, "Equipment Classification and Vendor Interface for Safety Related Components." RAls sent in March and July 1987 were not responded to by the end of the rating perio * Generic Letter 83-28 Item A.3, "Automatic Actuation of Shunt Trip on Reactor Trip Breakers." This item applied to Unit 1 and required submission of a license amendment to revise the Technical Specifications. The submittal was received 22 months af ter it was requeste * Relief Yalve and Safety Valve Testing. The staff learned of licensee identified pipe support deficiencies which imoacted the accuracy of the information contained in their submittal. An RAI was necessary to prompt the licensee to revise their previous submittal. The RAI response was lat ___ _ _ - - _ _ _ _ _ _ _ _ _ ___
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Seismic design of the seismic condensate storage tank. An R ,
sent in June of 1987 was not responded to until the end of the i rating perio !
Technical Specifications one-time exemption to allow s7ent fuel cask handling with the auxiliary building crane. The iicensee's safety evaluation was incomplete and cursory. The supplemental '
submittal allowed barely sufficient time for staff revie i
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Technical Specification change submittals to revise the -
membership of the Safety Review Committee and the duties of the Plant Safety Comittee were largely unacceptable to the staff.
License amendment required by the 10 LFR 73.55 rule change
- dealing with the physical security plan. The licensee's ,
. submittal evidenced little management involvement, and was not ;
technically sound, thorough, or consistent. Several RAls and extensions of time were needed to resolve staff concern l
Technical Specifications change to reflect the Unit 2 battery upgrad The licensee took 6 months to respond to an RA :
Technical Specification changes to increase the boric acid l concentration in the Refueling Water Storage Tank and the Safety injection Tanks. Enclosed data tables discussed in the licensee's safety evaluation were not directly comparable; .
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discussions with the licensee were needed to allow completion nf staff revie ;
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Emergency Technical Specitications change to increase the control rod drop time limit. Subsequent to issuance of the j license amendment, the licensee reported a nonconservative error i in their safety analysi (However, it had no impact on the I conclusion of the safety evaluation.) !
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Generic Letter 87-12. "Loss of Residual Heat Removal (RHR) While '
the Reactor Coolant System (RCS) is Partially Filled." Although the response was relatively good com)ared to other licensees, many technic ' 'ncerns were raisad >y the senior res ident inspector a' .: by the staf These examples indicate that licensee procedures and policies [
governing licensing activities were either inadequate or ..ere not ;
consistently followed. As noted e3rlier, the licensee's policies for -
prioritizing efforts to respond to safety and regulatory issues should be addressed by management. Additionally, the quality and tireliness of submittals needs improvement. Management should review i the adequacy of the current level of staffing and the assignment of j technical resources in the licensing area, as they may impact the assignrrent of priorities for responding to safety and regulatory i issues and the quality and timeliness of associated submittal '
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. lot all licensee resporses to safety issues during this rating period
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were deficient. Responses to NRC Bulletins and to most Generic Letters (GLs) were usually timely and complete. When a due date could not be met, the licensee initiated negotiation of a later date with the staf During this rating period, three NRC Bulletins were issued which were
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applicable to ANO. The licensee's response to Bulletin 87-01,
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"Erosion / Corrosion Pipe Wall Thinning," was followed up by an onsite audit by the staff; no significant concerns were identifie Fasterer sampling required by Bulletin 87-02, "Fastener Testing," was monitored by an NRC inspector who verified the requirements of the Bulletin were met; the sampling and test report in response to the Bulletin was adequate and timely. The licensee's timely response to l
Bulletin 88-01, "Defects in Westinghouse Circuit Breakers," was
! reviewed onsite by the staff. A comprehensive search had been done
! in response to the bulletin, which concluded that ANO had .1one of the l breakers of concern installed or in storage. The licensee's
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l l responsiveness to NRC Bulletins was a strong point during the rating !
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Seven Generic Letters were issued which were applicable to ANO, and when required, had response dates requested which were within the present rating period. Except for the GL 87-12 submittal noted
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earlier, the licensee's responses to Generic Letters were adequat The licensee's reviews for applicability, assignment, and completion of responsive actions for NRC Information Notices were generally timely and comprehensive. For some Information Notices, t%
documentation of the review and actions taken could Iave been more descriptiv The Plant Safety Comittee (PSC) was evaluated during this rating
?eriod. A coment was made that the effectiveness of the PSC was 11ndered by the review of a significant number of documents which had not been properly acreened and contained numerous minor technical and editorial errors. Consequently, these documents had to be returned for correction and subsequent re-review by the PSC. This consumed an appreciable amount of PSC discussion time better spent on more safety significant issues, in the area of 10 CFR 50.59 reviews, the licensee has revised and upgraded his program. This prograia now includes special training and certification of reviewers. The quality of 10 CFR 50.59 reviews has noticeably been improved since implementation of the revised progra The NRC Office for Analysis and Evaluation of Operational Data (AEOD)
conducted an evaluation of Licensee Event Reports (LERs) submitted by the licensee during the SALP assessment periot. The LER quality wcs described as thorough, detailed, organized, and comprehensive. The narrative sect. ions were exceptionally conplete and included specific
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details of the event such as valve identification numbers, number of operable redundant systems, the date of completion of repairs, et Many of the LERs included diagrams or sketches which enhanced the readers' understanding of the event. The licensee's safety analyses were detailed, relevant, and meaningfu ;
In the area of assessment of reportable events, the licensee has ex,.erienced excessive tardiness in arriving at a determination of reportability of some abnomal events. In one identified case, several months elapsed from the time o4 the occurrence of the event and the determination that it was repor table. It was also identified that supplemental reports related to previously submitted Licensee Event Reports were long overdue in some case Inspection of the quality verification function, was included in many of the NRC inspections conducted during the assessment period. Three of the inspections were entirely dedicated to performance of the quality verification function. These inspections indicate that the l licensee has implemented an audit program covering nearly all operational activities that is detailed and comprehensive and has l identified significant issue It also appears that, in some cases, corrective actions on the part of the grups being audited have not met the established response due dates. The lack of response on occasion has oeen excessively lang, in one identified case, more than l
3 months had elapsed at the time of the NRC observation and final l
corrective action still had not been determined. The corrective
' actions, when taken, have been generally effective in resolving the original issue. During the NRC quality verification inspection, the team found that the licensee had accomplished perfomance oriented surveillance type audits of most operational areas that are considered effective in identifying operational problems. It was noted, however, that surveillances during the latter part of 1987 were scheduled only about one-third as frequently as they previously had been and that nearly all were accomplished on the day shift. The reduction in scheduled activities in the QA surveillance of operational activities may be indicacive of some understaffing within the QA omup. It is understood that the QA group has been authorized to employ an additional nine inspectors as part of the licensee's pennanent organization. These additional personnel, however, are also underst od to be replacements for an equal number of contract employees who previously were accomplishing QA function The NRC quality verification inspection team found examples which indicated that thorough root cause analysis and corrective actions to ensure that affected equipment would perform their safety-related functions were not performed in som instances. Improvement may be expected in this area due to the recent implementation of a neri condition reporting and corrective action procedure. This procedure requires a formal root cause analysis of significant events and in9 pendent reviews of other root cause analyse _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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The NRC quality verification team also noted that while the licensee has established a mechanism for irientifying quality trends, no rnechanism was apparent for analyzing the root cause of adverse trends and effecting corrective actions. The above mentioned revised condition reporting procedure also addresses actions to be taken in regard to identified trends adverse to qualit In the area of QA/QC varification of the design change / modification process, it appears that the licensee's QA engineering staff has the necessary expertise to effectively evaluate the technical adequacy of proposed changes prior to issuance of the change packages. There is evidence that this level of review has prevented later operational problems from occurring and is, therefore, a substantial strengt During installation and testing of an approved chanp/ modification, the licensee's QC organization has been observed or otherwise verified to have performed detailed inspections of craft activitie It was also noted that the licensee has established a small, but knowledgeeble, group of QC inspectors substantially dedicated to following modification activities. The group is augmented during major outages when the modification workload generally becoaes more intensiv In sunmary, the licensee's quality verification function is, in general, staffed with well qualified personnel and in sufficient ,
quantity except possibly in the surveillance of day-to-day operational activitics. The lack of timely response to QA/QC
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findings in some instances does indicate a lack of management :
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attention but, overall, it appears that licensee management has been
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effective and responsive to both self-identified problems and problems identified during NRC inspection In the area of 10 CFR 21 assessaents, onc; NRC inspection identified that a number of assessments had not bcen done in a timely manner. It ,
appears that the reason for the lack of timeliness was that reports ;
had not been entered into a computerized data base system used by i i
licensee managenent to assign work priorities and track completion tne rer,f. The NRC inspector also noted that there vas no clear assignment of responsibility for assessing Part 21 reports to ,
determine applicability to the ANO facilitie l
. Perfomance Rating 1he licensee is untidered to be in Performance Category 2 in this are _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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30 Recommendations NRC Actions The NRC inspection effort should he maintained consistent with the fundamental inspection program. An additional inspection should be conducted ir the area of corrective action Licensee Actions Licensee management should assess the effectiveness of the newly issued condition report progra Management should evaluate increasing the level of QA surveillance activit Management involvement in licensing activities should be increased to insure adequate levels of staffing and technical resources are assigned to assure high quality responses to NRC initiative The licensee should evaluate the policies for prioritizing regulatory and safety issues to avoid unjustified delays in responding to longer term issue V. SUPPORTING DATA AND SUMMARIES Enforcement Activity The SALP Board reviewed the enforcement history for the period January 1,1987, through June 30, 1988, lhis review included the deviations, violations, and emergency preparedness deficiencies tabulated by SALP Category in Table Footnotes are provided to identify any functional areas associated with civil penalties or order Confirmation of Action Letters None
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TABLE 1 l
ENFORCEMENT ACTIVITY (INCLUDES BOTH ANO 1 AND AN0 2)
Number of Violations FLNCTIONAL In Each Level AREA DEFICIENCIES DEVIATIONS V IV-~' III Plant Operetions 1 9 Radiological Controls 1 2 5 Maintenance /Surveillanca 1 1 7 I II) Emergency Preparedness 5 Security 6 1(2) Engineering / Technical Support 1 7 I I3) Safety Assessment / Quality 2 2 Verification TOTALS S 5 4 36 3
Footnotes:
(1) A civil penalty of $25,000 was paid on February 25, 1988, in a Notice of Violation dated June 25, 1987, dealing with an inoperable Unit 1 pressurizer safety valv (2) A civil penalty of $100,000 was paid on April 28, 1988, in response to a -
Notice of Violation dated July 2,1987, dealing with security violation '
(3) A civil penalty of $100,000 was paid on April 28, 1988, in response to a Notice of Violation dated March 14, 1988, dealing with failure to correct a condition adverse to quality (Unit 1 elevated reactor building >
temperature) .
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