Text

SALP Repts 50-313/89-34 & 50-368/89-34 for Jul 1988 to Sept 1989
	ML19332E625
Person / Time
Site:	Arkansas Nuclear
Issue date:	11/28/1989
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML19332E623	List: IR 05000313/1989034; ML19332E622;
References
	50-313-89-34, 50-368-89-34, NUDOCS 8912080102
	Download: ML19332E625 (33)
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INITIAL SALP REPORT

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SYSTENATIC ASSESSMENT OF LICENSEE PERFORMANCE

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50-313/89-34

uc 50-368/89-34 i

Arkansas Power & Light Company

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Arkansas Nuclear One

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Units 1 and 2

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July 1, 1988 through September 30, 1989

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-INTRODUCTION s

l The Systematic Assessment of Licensee Performance (SALP) program is an i

p integrated NRC staff effort to collect available observations and data on

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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 to NRC rules and regulations.

It is intended to

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D be sufficiently. diagnostic to provide a rational basis for allecating NRC resources and to provide meaningful feedback to the licensee's management r

regarding the NRC's assessment of their facility's performance in each

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f functional area.

L-An NRC SALP Board, composed of the staff members listed below, met on November 2,1989, to review the observations and data on performance, and

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to assess-licensee performance in accordance with Chapter NRC-0516

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" Systematic Assessment of Licensee Performance." The guidance and

evaluation criteria are sunnarized in Section III of this report. The

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Board's. findings and recommendations were forwarded to the NRC Region IV

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Regional Administrator for approval and issuance.

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This report is the NRC's assessment of the licensee's safety performance atArkansasNuclearOne(AN0)fortheperiodJuly1,1988,through

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September 30, 1989.

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The SALP Buard.for ANO was composed of:

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A. B. Beach, Director, Division of. Radiological Safety and Safeguards, Region IV L. J. Callan, Director, Division of Reactor Safety, Region IV T. P. Gwynn, Deputy Director, Division of Reactor Projects, Region IV F. J. Hebdon,(Director, Project Directorate IV, Office of Nuclear Reactor

Regulation NRR)

D. D. Chamberlain, Chief Project Section A Division of Reactor

Projects Region IV-R; C. Haag, Resident Inspector, Region IV-C. C.'Harbuck, Project Manager, Project Directorate IV NRR C. Poslusny, Project Manager, Project Directorate IV, NRR

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The following personnel also participated in the SALP Board meeting:

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G. G. Zech, Chief, Incident Response Branch, Office for the Analysis and Evaluation of Operational Data

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! C. C. Warren Senior Resident Inspector, Region IV j

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n A. T. Mowell, Project Engineer, Region IV r-B.' Murray, Chief. Facilities Radiological Protection Section, Region -IV E

. D. A; Powers, Chief. Security and Emergency Preparedness Section, i

Region IV j

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J. P.'Jaudon, Deputy Director DRS, Region IV'

J.' M. Sharkey, Regional Coordinator, Office of the Executive Director for '

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P. J. Prescott, Reactor Engineer.. Performance and Quality Evaluation

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~ 'o Branch. NRR l

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II.- SlM ARY OF RESULTS

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Overview

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During this SALP period, the perfomance category ratings were l

lowered in four out of seven functional areas compared to ratings

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assigned in the previous SALP period. '.This was partially attributable i

to a change in.our understanding of your performance, primarily 65 a '

result of several major operational events and problems experienced early in the SALP period which revealed significant weaknesses in management. involvement with plant activities, including corrective

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action' and other major programs.

Subsequent licensee actions to'

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address these weaknesses included a_ major organizational and personnel

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realignment implemented toward the end of the SALP period. These

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changes have shown positive results in licensee responsiveness and ability to react to recent significant issues. Long-term improvement

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.in perfomance including the ability to~ aggressively self-identify

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L assessment by the licensee of program adequacies, priorities, and i

resource allocations.

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The licensee's ability to identify problems has greatly improved with

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the new condition reporting system, but limitations on the licensee's ability to disposition and correct identified problems has created a p

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L significant backlog in this system. Problems with the timeliness of

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corrective actions continued toward the end of the SALP period. The

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licensee has begun to take action in several areas such as interdepartmental interfaces and the adequacy and timeliness of operability deteminations. These efforts have resulted in L

short-term improvements.

Licensee efforts to shift emphasis from a h

compliance emphasis to a nuclear and personnel safety emphasis have L

produced some positive results, but integration of this " safety f

culture" throughout the organization remains a licensee goal not yet demonstrated by the end of the SALP period.

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.0ther Areas of Interest >

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'A' diagnostic evaluation of ANO was-conducted by NRC in August and

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September 1989.: ; NRC Region ~IV personnel followed up on the most

' significant technical. findings that were. identified by the diagnostic

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evaluation team-(DET). 'The findings'of the DET were considered in

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the assessment of 11censee perfomance during this'SALP period. NRC-

Region IV williperform further followup on the DET findings after

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issuance of the DET report.:

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i Additionally, the licensee's performance will be discussed at an NRC

' senior, mana0er's meeting that is scheduled to be held :in

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s January 1990.

Further NRC initiatives affecting the regulation-of

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-ANO may be implemented as'a result'of this meeting.

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The licensee's performance category ratings are sumarized in the.

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etable below, along with = the perfomance categories from the previous l',

s SALP.. assesment-period:

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' Functional: e 4:.1 Previous Performance.

Present Performance Category (01/01/8/ to Category (U//U1/56 to

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06/30/88)

09/30/89)

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Emergency.

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Engineering /

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Technical Support

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17.., Safety Assessment /

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Quality Veri.fication-

=III.' CRITERIA k

, Licensee performance was assessed in seven selected functional areas.

Functional areas normally represent areas significant to nuclear safety

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and the environment.

Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.

c Special areas may be added to highlight significant observations.

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' The' following evaluation criteria were used, as l applicable, to assess each =

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. functional' area:=

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{1.: : Assurance ofLquality, including management involvenent and control; s.

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' : Approach;to the resolution of' technical issues from a safety

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standpoint;'

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Responsivenebs}toNRCin'itiatives; S

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Operationa1> events (including response to, analyses of, reporting of,

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'andcorrectiveactions:for);.

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6.4 Staffing l(including managemenk);' and

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' Effectiveness of training. and qualification program.

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However, the NRC_ is not limited to these' criteria and others.may have been

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used'where appropriate.

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OnLthe basis of.the NRC assessment, each functional area evaluated is

, : rated 'according to three performance' categories. The definitions of these

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perfonnance categories are as follows:

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Ca'tegor d - Licensee management attention and involvement are readily

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evident and place emphasis on superior performance of nuclear safety or safeguards activities,_with the resulting performance substantially

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exceeding regulatory requirements. Licensee resources are ample and effectively used so that a high level of plant and personnel performance L

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Qy-is being achieved. _ Reduced NRC attention may.be appropriate.-

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Category 2 - Licensee management attention to, and involvement in, the s

i perfonnance of nuclece safety or safeguards: activities is good. The

1icensee has: attained _a level of performance.above that needed to meet

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L'a J reguintory requirements. Licensee resources are adequate and reasonably t

allocated so that good plant and personnel performance is being achieveo.

~ NRC' attention may be' maintained at normal levels.

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Category 3 - Licensee management attention to and involvement in the Te'rformance of nuclear safety or safeguards activities are not sufficient.

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The-licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be i

strained or not effectively used. NRC attention should be increased above normal-level s.

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The SALP is not intended to beta substitute for NRC's enforcemnt policy.

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Enforcement action should not' await the outcome of a SALP, but should be

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taken at the time the unacceptable action (s) or event (s) occurs.

In this regard, the SALP process can assist NRC management by providing l

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Where licensees are incapable of meeting minimal regulatory requirements, the affected plants will be shutdown.

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LIV; ' PERFORMANCE' ANALYSIS A.;

Plant Operations i

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Analysis

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, The assessment of this functional area consisted chiefly of the

control;and execution of-activities directly related to

. operating a plant.

It is intended to include activities such as

. plant startup,. power operation,' plant-shutdown, and system lineups. Thus,-it included activities ~such as monitoring and logging plant conditions, normal operations. response.to.

transient 'and off-normal conditions, manipulating the reactor

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and auxiliary ' controls, plantwide housekeeping, control room professionalism, and interface with activities that support operations.

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This area'has been inspected on a continuing basis by the resident _ inspectors and on several occasions by regional inspectors;. A diagnostic evaluation of overall. plant operations was performed near the end of the assessment period.

In

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addition :an-augmented inspection team (AIT) reviewed the Unit 1 reactorcoolantsystem(RCS)backfloweventthatoccurredon January 20, 1989, following'a reactor trip with equipment complications.

The licensee's performance in the plant operations area declined noticeably during the SALP period. Management involvement was

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weak and-slow'in response to identified deficiencies.during the early portion of the SALP period.

In recognition of these-

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= problems-and the need to provide dedicated managenent resources for each unit, the licensee implemented a major organizational change in the middle of 1989.

Individual plant managers with a

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staff comprised of operations, maintenance,.and outage coordination personnel were assigned.to each unit. However, a significant amount of time lapsed from the identification of problems in plant operations until corporate management reacted to'the problems and initiated these changes. The initial assessment of the organizational changes indicated that

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management is more responsive and supportive of operations.

Sufficient time was not available, however, after the implementation of these organizational changes to assess its

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effectiveness fully.

The decline in noted performance is supported by the enforcement history and other identified problems.

Inadequate control of safety-related equipment because of interface problems between

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problem area. The failure to recouple a turbine-driven

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emergency feedwater pump prior to Unit I heatup, and the failure L.

to.retighten the packing of a high pressure injection (HPI)

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Leontrol'of: safety-related equipment that resulted in escalated

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enforcement-action. ' Other examples of inadequate control of safety-related equipment and numerous operator' error related

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deficiencies were evidence of ineffective.managementL

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involvement.- The use of uncontrolled 11ogs by operations s

personnel and:the lack of effective guidance for the valve f',

lineup and independent verification policies were'further

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examples ~of program' weaknesses.'and management's lack-of

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involvement..

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.An additional. area that received untimely management attention

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Jw involved operability determinations for condition reports (CRs)

that identified equipment or system deficiencies. NRC expressed concerns regarding the brief-and frequently incomplete

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- justifications provided for CR operability determinations. On the basis of these concerns and the licensee's recognition of s

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the weaknesses, a new operability procedure was implemented towards. the end of the assessment period. The process is now more formalized with greater input required by the_ shift -

technical advisors and by management.. The implementation effectiveness has not been fully assessed as of the end of the

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SALP. period.

0)erational events for both units provided significant a

cla11enges to operations personnel. This was the result of the

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nature and complex circumstances associated with several plant trips and-transients. These events included an unisolable RCS

. leak when the packing blew out of an HPI piping valve (Unit 1).

a plant trip which included RCS backflow through HPI-

. piping (Unit.1), an unisolable RCS leak due to a partial failure of a reactor coolant pump seal (Unit 2), and a plant trip caused i

by the rupture of a high pressure steam extraction line

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(Unit 2). While one of these events involved operator action

.that contributed to the event, the overall efforts of the

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' operations staff in dealing with those challenges were very

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e good. The professional attitude that was displayed during

. normal operations was also maintained during the transient

responses.

During its review of the RCS backflow event, the AIT'

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also noted effective and timely operator action when responding

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L to-the transient.

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Management's commitment to the annunciator panel " black board" l

b concept has been very successful in the Unit 2 control room, but

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several Unit I control room annunciator alarms remain illuminated. These alarms have been reviewed by the licensee,

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but planned corrective actions have not been completed.

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A large number of minor equipment problems identified by

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1-deficiency tags continue to exist 'in both control rooms. While

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most of the equipment problems are not significant and many are:

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iassociated with nonsafety-related; equipment, they do represent a;

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b-distraction to the operators. Management is aware of this

problem.and has been providing resources to correct'many of the

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'deficienciesi However -new deficiencies _ continue to be-

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identified and the backlog has not been reduced significantly.

.The backlog issue is an example of-past management's willingness

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",1 to live with-~ identified problems and of a lack of a self-critical

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approach to problem resolution. The issue of control room deficiencies wasfaddressed in the last SALP report and continues to be:a concernLof NRC.

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ThelicenseEhascontinuedtheplant-widehousekeepingupgrade

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n program; however, it does not appear that several areas in the plant haveireceived this upgrade.' An example is the Unit 2 upper north piping. penetration' room.

In addition the poor i

' material conditions noted inside the control room cabinets I'

indicated that the-upgrade program is-not addressing all areas

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'of the plant.

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The licensee's response-to NRC initiatives concerning improvements in. plant operations was; viewed as weak.

Problems

continued to occur in maintaining decay heat removal (DHR) flow

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and RCS level indication during plant shutdowns despite the increased emphasis of this subject that was.provided in~ Generic

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Letters 87-12. " Loss'of Residual Heat. Removal (RHR) While the

Reactor Coolant System is Partially Filled,'.' and 88-17. " Decay t

Heat Removal." During the Unit-1 refueling outage, DHR flow was -

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. inadvertently lost three times. Also, the remote RCS level a

i indication in the Unit I control room did not provide ~ accurate level indication during the early-stages of the outage because

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of calibration difficulties. The Unit 2 control room remote level indication'and the tygon tubing level indication have

i experienced problems in providing consistent measurements since the' remote' indication was installed in 1987. This problem

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occurred again'during the Unit 2 shutdown in June '1989 even

though the licensee had identified corrective action that would

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have resolved the difference in RCS level indications. These i

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examples' indicate that licensee" management has not been fully-

consnitted to resolution of problems associated with DHR flow and

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RCS level indication.

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>At the end of the~ assessment period, the licensee had a total of y

57 licensed reactor' operators or senior operators for Unit I and

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54 for Unit 2. - This large number of licensed operators combined

with the college' degree program for shift supervisors and

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control room supervisors is indicative of management involvement

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and support in operator training. The operator training program j'

' continues to make a positive contribution to overall plant

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knowledge and responsiveness of'the operators.. This was ' evident

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by the response to plant transients during the SALP period,

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As a result'of the reorganization. two individuals from the

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college degree program were promoted to management positions.

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_The assignment' off a shift supervisor from each uni.t as a-

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planning and scheduling liaison is viewed by NRC as-a' positive

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j action;to improve the interface between operations and:other a

1 departments.; Theso-individuals review daily work schedules 1and

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prioritize workL to ensure-that operational needs are fully _

-represented.L Currently four shift; supervisors have completed

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. Although the operator-training program is viewed as historically

strong, some weaknesses were noted towards the end.of the SALP g

Lperiod in-operator's performance on.NRC administered tests.

(Operators also exhibited weakness in the knowledge of equipment

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. operability requirements that are not specifically contained in Technical Specifications (TS).-

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-Performance Rating l

The licensee is considered to be in Performance Category 2 in.

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Recommendations-l

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NRC Actions

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NRC inspection effort should be consistent with:the

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"fundamantal inspection program, augmented by an emergency

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operating procedures team inspection for Unit 2.

Regional

' initiative: inspections'should be conducted in the areas of

operations department-interface with other departments and

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m operability assessments.

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Licensee Actions

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Licensee management should consider the following actions

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to improve performance in this functional area:

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Provide management guidance to operators and establish

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consistent policy on. logs, valve lineups, and independent verification requirements;

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Improve operations department interface with other

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departments;

. Increase the reliability of the decay heat removal F

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! Improve the quality of operability determinations by..

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improving operator knowledge of equipment / system

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Establish' higher btandards for station material

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condition and houskeeping;,

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~ Continue efforts to reduce the backlog of minor

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deficiencies, particularly control; room deficiencies;

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Continue:the aggressive " black board" concept.

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' Improve control of safety-related equipment status.

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Radiological ' Controls

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Analysis-

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The assessment;of this functional area consisted of activities

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directly related to; radiological controls, including

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' occupational-radiation safety (e.g., occupational radiation y

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- protection,; radioactive materials and contamination controls, radiation field control.. radiological surveys and monitoring.

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and as low as is reasonably achievable programs), radioactive'

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- waste management 1(i.e., processing andconsite storage of-d.

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' gaseous, liquid, tand isolid wastes), radiological effluent control w

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and monitoring (including gaseous and liquid effluents, offsite

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dose calculations, radiological environmental monitoring, and

confirmatory' measurements), water chemistry controls, and 2'

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transportation of radioactive materials t(e.g., procurement of

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shippers, receipt / acceptance of shipments, periodic maintenance

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. of packagings, and point-of-origin safeguards activities).

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!! i The occupational radiation safety program was inspected five

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times,' including two reactive team inspections.:during this assessment period by NRC region-based radiation specialist

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'J inspectors, in. addition to.the routine-inspections performed by-NRC resident inspectors. ' Five violations were identified,

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including three 1dentified by the licensee. An enforcement

_e conference was ' held in the NRC's Region IV office on

A December 21, 1988, to discuss three violations identified during

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two November 1988 reactive inspections.

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' One of the-violations involved a whole body overexposure from t

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' 1, hot particles. The investigation of'the root cause for the overexposure identified several problem areas including failure

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to conduct proper surveys, inadequate information on the

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, radiation work permit, and lack of coordination of work-activities.

As a result of these events, special training was

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conducted for radiation protection personnel'on how to monitor.

for hot' particles. improved : survey techniques were initiated,

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and additional sensitive personnel monitoring instrumentation f

was obtained.

In addition, the licensee also revised their

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radiation work pennits.

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The overexposures and. hot particle problems. during 1988 had a

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. noticeable impact'on the licensee's radiation safety program.

.

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As a result, management is now actively-involved in the I

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prevention and resolution of radiological problems.- Contracted

. work group managers have also been involved with the licensee in

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. correcting poor radiation work practices. Communications between a11Elevels of: management and plant personnel have

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, improved and a> good working relationship has been developed

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between.the radiological controls group'and other departments.

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Access. to the Unit 1~ emergency diesel generator (EDG) rooms:

.

required; passage through a radiation area because of >the close

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proximity of the makeup tank; This situation was unusual'as most EDG rooms are.not posted as radiation areas. Operations s

= personnel have lived with this condition instead-of requesting

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-the necessary shielding to reduce < radiation levels..

The licensee.had an excessive ' number of skin and clothing m'

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contamination-incidents in 1988, but there has been a decrease

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p min 1989. The licensee has also installed additional' sensitive-

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monitoring equipment for the detection'of personnel

. contamination.

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i The : licensee has maintained a stable, experienced staff. The F

personnel turnover rate within the radiological. controls area

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was.below-10; percent.' In addition, the size of the staff was

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l increased byl13 members during the assessment period,

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n The311censee completed a review and update of station f *~

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. radiological control procedures in early 1989. 'The training

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department which is staffed by technically qualified trainers, provided training to personnel prior to implementing these new

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procedures. The training and qualification program contributed H,

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to an understanding of work and adherence to procedures, as indicated by a reduction in the number of personnel errors

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- towards the-end of the SALP period.

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- The licensee's radiochemistry and water chemistry programs were y

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inspected once during the assessment period. No violations were identified. Confirmatory measurements were performed on water

chemistry samples and the licensee's results were found to be

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within the expected industry performance levels.

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I" The licensee's transportation program was inspected twice during

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this. assessment period. One violation.was identified which

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g 31nvolved the failure to secure a lid on a box of equipment being.

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. returned to a vendor.. In general', the licensee maintained an

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adequate program during this ' assessment period. +

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. during this assessment period. One licensee identified

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violation was reported which involved an operator error that" C

resulted in' two liquid effluent releases that exceeded TS

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limits. -In general,; the licensee's control of. liquid and:

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gaseous effluents and solid waste is a well. managed program, y+

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3-The 11censee's quality assurance program has been maintained'at a' high 1evel and is: implementing #fective perfonnance-based ~ ?

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audits"and surveillances'in this area.. The licensee 1has brought

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--in technical specialists to perfonn audits of selected'

.i radiological. safety functional areas following the U

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implementation.of corrective actions for the two-1988~ hot'

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particle ' overexposures.

Overall.. corporate and plant management attention to the

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concerns identified in this functional area has been evident.

The licensee is generally identifying;their own problems and l'.J initiating proper. corrective actions. The resolutions of

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Etechnical. problems are generally-timely and improvements are eW generally sound. However, performance decline in this-

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'affecting radiation protection organization from extended outages during this.SALP: period.

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performance Rating

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L The licensee is co'nsidered to'be in Perfonnance Category 2 in

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'this area.,

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3.-

Recommendations

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NRC-Actions L

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.

NRC inspection effort should be consistent with the a

'

fundamental inspection program.

In addition, NRC regional

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initiative inspections should be conducted to review the

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effectiveness of the hot particle and personnel

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contamination programs.

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TLicensee Actions

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Licensee: management should consider the following actions

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to improve perfonnance. in this functional area:

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Continue, ongoing efforts to improve the radiological li

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controls area and-stress continued improvement in

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_ procedural compliance and self-identification off

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problems;'

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Reduce radiation area access restrictions for areas-b O'

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that require routine access by operations personnel; e

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Continue e'fforts to reduce-overall exposure and the l

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- number of skin contaminations.

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Maintenance / Surveillance:

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- Analysis ~

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i zThe assessment of;this functional area included all activities

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-_ associated with either' diagnostic, predictive, preventive, or

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components; procurement.. control,'and storage of. components.-

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Lincluding qualification controls;; installation of plant e3 modifications; and maintenance of the plant physical c.ondition.

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It: included conduct of:all surveillance (diagnostic) testing

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i activities as well as all inservice inspection ~end testing.

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- activities.

Examples of activities included are instrument

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calibrations; equipment operability tests; postmaintenance,

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postmodification,'and postoutage testing; containment leak. rate

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_ tests; special tests;' inservice _ inspection and performance tests w

of. pumps and valves; and all other inservice inspection 9.

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activities.

This area was ins'pected on a routine basis-by the resident inspectors, periodically by regional inspectors,-and by.a'

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maintenanceteaminspection(MTI).

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Weaknesses were noted in_ management's involvement and oversight e

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?oO maintenance.and, in particular, there was little evidence of a

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management consnitment to identify problems in this area. When problems were identified, resolutions were often incomplete or

_ untimely. Additionally, surveillance program weaknesses

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resulted in a large number of missed surveillances with the

. initial corrective actions,being ineffective.

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One of the major goals of the licensee's restructuring of the q;

ANO. organization was to establish separate maintenance departments for each unit to provide increased management

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-involvement and dedicated maintenance personnel with specialized

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m unit knowledge. Although new maintenance managers and-a small s

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Rsupport group were assigned to each unit, other significant-

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changesLin the maintenance organization remained outstanding at W

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the end of the assessment period.

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Interface; problems between main' tenance personnel and 'other j

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departments continued to negatively affect overall performance

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of the, maintenance department.- Ineffective comunication

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<between. maintenance and operations resulted in the blowout of

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the. packing:of the: HPI valve that oce.irred after repairs, and

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'two events involving the loss of DHR llow. The failure of'

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maintenance personnel to recognize the need:for engineering

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. involvement when problems were identified was an additional e

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. interface problem. One example. involved the repair of a leak on

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the> Unit 2. reactor' head vent flange.; During the repair efforts,

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y maintenance; personnel identified that the mating flanges were of n

idifferent types and tthat'the replacement gasket was. smaller than

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the original; however, maintenance did not notify engineering of v'

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this until the work was completed. A contributing factor to the

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L t interface. problem was the slow responses that engineering x

generally provided to maintenance. 'While the engineering

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' evaluations:in the maintenance area were. generally adequate. the

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issue of timeliness appeared to detract from the effectiveness.

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of the maintenance:and engineering interface.

During the last

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SALPiperiod,Lineffective communication between maintenance and

' engineering was also identified.. Little progress was achieved

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this' assessment period.in improving communications between these 9"

m, idepartments.

It is not clear that the organizational changes

,noted above will improve the interface problems.

'

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.

."E The 11censee's failure to perform eight TS surveillances within the required intervals,during this SALP period indicated,

-

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continuing problems in the surveillance program.. Even with five a

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of the' initial missed surveillances attributed to personnel

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errors,-management was slew to recognize the problem and

1mplement corrective action. Additionally, during a'4-month

,

span, a 14-day surveillance test of the containment cooling

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? units was missed twice.- Part of the: licensee's corrective action was to convert surveillance tracking from a manual to a

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computerized system. However, the occurrence of an additional s

a missed surveillance after the tracking program conversion

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. indicated that problems with the surveillance program have not

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been fully resolved. Weaknesses in the inservice inspection and

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testing program were further evidence of a lack of management i

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involvement in the surveillance program.

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In addition to the scheduling problems that have caused TS

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surveillances not to have been performed within the required l

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interval, there have been several instances in which TS surveillance requirements were not met because of inadequate j

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! procedures.: In one instuce, the Unit 1 power range amplifiers

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were not calibrated at the required frequency during nonsteady

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W state, conditions because of a lack of procedural guidance.

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cAlthough the licensee has corrected the procedures associated

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with the specific problems noted during the SALP period it-i L

1 appears that the root cause of this problem has.not been

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determined and corrected. The problem of inadequately performed

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TS surveillances resulting from procedural weaknesses was still

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occurring late in the assessment period.

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(The fact that the equipment-failure trending and analysis:

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efforts have not~been fully implemented also reduced the.

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M effectiveness of the licensee's root cause analysis program.

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Root cause determination of equipment failure.was also a

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weakness.- Examples of; recurring equipment problems in'which

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f failure trending and root cause analysis eppeared weak included

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Unit 2 charging pumps. service water pumps,' Unit 1 makeup s

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' pumps, instrument air compressors, and motor operated valves in

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various systems. -

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'The lack of spare parts contributed to a significant portion of

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the maintenance backlog and was a source of: frustration to the

maintenance craftsmen'and technicians in their efforts to

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troubleshoot and resolve plant problems. The unavailability of

spare-parts was attributed, in part, to a weak system of

.

~ 1nventory control,' which did not<1dentify the need-for an adequate supply of spare parts, and a cumbersome spare parts

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release. program.

,

Several'long-term improvement projects in the maintenance area continued, or were started, during the assessment period. These projects generally addressed the issues for which the projects

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-were originally initiated. : However, a drawback of these.

-long-term projects, as well as with earlier projects, is the

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. licensee's frequent failure to meet projected completion dates.

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This was indicative of insufficient management connitment and

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oversight in implementing and assessing the effectiveness of the

.

projects.

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Thepreventivemaintenanceimprovementprogram(PMIP)isagood example of the licensee's long-term projects. The licensee s

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failure to meet the connitment date of October 1988 for the

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completion and implementation of the PMIP resulted in a

-

i

-

deviation. The revised completion date is October 1990. The PMIP program has been reviewed during several NRC inspections

.

with the overall conclusion that the PM procedures currently

,

being. implemented are generally adequate. Yet the licensee's failure to implement the program in a timely manner has negatively affected' the overall effort of the PMIP project.

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N The' licensee's' current staffing in this area was generally

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edequate.: - However, after the full implementation of the PMIP.

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and the resulting increase in workload, the existing maintenance

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staff may.not be sufficient to perform all C icheduled

'

preventive maintenance activities.- Key pos1t.ons were

identified and vacancies were usuallyjfilled within-a reasonable

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' time.;: The turnover rate was low during this assessment' period, J

"

and most of'the vacancies which existed were created by the

-

movement of maintenance personnel to other parts of the

organization. The overall experience level of the startup i

,P

' testing group was lowp but this did-not appear to have been a o:-

.

detriment to their overall performance. - There was occasional

'

use of contractors for: maintenance activities, and the>

-

licensee's control of the contractors was generally adequate, j

.;

The licensee's training efforts in this area were considered a defini.te strength. = The training program was well defined.and N

'1 was implemented with a-dedicated training staff. There was also

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evidence that the mechanism for the feedback of experience at '

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the. plant was being: incorporated into maintenance training.

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Performance Rating The licensae is considered to be in' Performance Category 3 in

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f this area.

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'3i

- Recommendations

.

-

a.

'NRC Actions-

'

.

NRC inspection effort.should be consistent with the

.

fundamental. inspection program. Regional initiative inspections should be conducted in the areas of maintenance

?

,

department. interface,: preventive maintenance, materiai control, and~ equipment failure trending and equipment

'

,

failure analysis.

In addition, an inspection should also be conducted in the area of TS surveillance and testing-in i

'

.

order to determine the cause(s) of the declining trend in E

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this area.

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Licensee Actions M

'

. Licensee management should consider the following actions

'

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'to improve performance in this functional area:

I y

h Establish effective corrective actions for declining

'

trend in TS surveillance performance. These actions L

should be effective in significantly reducing the

,

numbers of missed surveillances, as well as ensuring that procedures and personnel are sufficient for b

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adequately implementing surveillance requirements.

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Improve interface between maintenance and other i

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Implement effective' equipment failure trending and f*"'

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improve equipment failure analysis capabilities;-

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Improve the materisl control program;'

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Reduce the backlog of maintenance work;-

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Complete the maintenance organizational restructuring;

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' Complete the PMIP.

'

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'D.

Emergency Preparednessi

,

.1. >' Analysis-

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y sw The assessment of this functional area included activities'

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related to the establishment and implementation of the emergency

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. plan.and -implementing procedures, such as~ onsite and offsite

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plan development and coordination; support and training ofL t

,

onsite and offsite energency response organizations; licensee

performance during exercises!and actual. events that test emergency plans; administration and implementation of the plan (both'during drills and actual events); notification; 3 radiological exposure control; recovery; protective actions; and interactions with onsite and offsite emergency. response

,

.-

organizations during exercise and actual events.

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During the assessment ' period, region based and NRC contractor

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.

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-inspectors conducted;two emergency preparedness inspections.

f One of these11nspections consisted of the observation and-

-

' evaluation of the annual emergency response exercise. During the March.I5,'1989,< exercise, the inspectors identified four

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exercise weaknesses and closed one deficiency from a previous

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. ; exercisen ' 0ne routine inspection of the: operational status of b,.4

' ;the' emergency: preparedness. program, which was held at a later r

/ ate, identified no adverse-findings. - During the operational d

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' status inspection, changes to the emergency plan were found to

,

have been well documented, reviewed, approved, distributed, and

L submitted to NRC in accordance with the licensee's procedures

-

E and'NRC requirements.

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Effective management involvement was evident in this functional I.

li, area.

Policies are well stated, disseminated, and understandable.

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Facilities and equipment were=found to be well maintained, and emergency supplies were readily available. The number and

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L qualifications of the emergency preparedness staff was found to l:

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be satisfactory. The recent' reorganization of AP&L was found.

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not to' adversely impact the emergency preparedness coordinator

'

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and his staff, and the. licensee is actively pursuing the training

x>

needs that arose as the result of the reorganization. Training

'

. interviews with teams consisting of first-line emergency responders '

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i in the control" room.showed that their level of training was E

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' adequate and that_they were proficient in their emergency-i Mn ' ~

. response' duties. Training programs'are well. defined and

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implemented in this area. A review of the licensee's independent d

audit. program'showed that independent audits conducted by their-g

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quality assurance program.were enhanced by using emergency.

F.

preparedness expertise from other licensees, m

i In summary lthe inspectors identified four exercise weaknesses!

>

i during this SALP period.- These weaknesses involved an instance i

of delayed notification to state authori, ties, poor radiological-

,

. practices by the medical response team, deviations from the a

internal organizational scenario-related' problems that detracted,

'

j

-

to some extent, from the. realism and free play of the exercise.

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The exercise weaknesses identified were not indicative of a

'

programmatic ' breakdown. Approaches to resolution of exercise

y'n weaknesses'and other-issues demonstrated a clear. understanding

'

-

y by the licensee and: approaches were technically sound and.

'

.W thorough-in almost all' cases.

,,

,

Assertive and effective management involvement-is shown by the

,

absence of violations, the small number of exercise weaknesses.

,

.and the maintenance of La qualified staff for administering and

-

x implementing the emergency plan. The' absence of any significant (

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inspection findings shows an effectivefapproach to. resolving.

~

progransnatic weaknesses, and makes it clear that theilicensee

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E has achieved and maintained an' excellent emergency preparedness j

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program. Licensee corrective actions for previous exercise i-f weaknesses'have been. effective as evidenced by no repeat

'

weaknesses and no, violations.

,

w 12.. -Performance Rating

.

UI The licensee is considered to be in Performance Category 1 in

'

-this area..

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-Recommendations b4 a.

-NRC Actions J-n P

HRC inspection effort should be consistent with the

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fundamental inspection program.

.

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License + Actions

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The present' level of management attention to the

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implementation of the emergency preparedness program should

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be maintained.

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' The assessment of this functional-area included all activities

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' that ensure the' security ofithe plant, that is, all aspects of

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access control security ch'ecks safeguards, and

.

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fitness-for-duty. activities and controls.

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. Five physical security inspections were conducted by Region IV

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inspectors during this assessment period. During the t~

'

inspections, the inspectors noted that several major security

,

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- program areas were being upgraded. Thel licensee has been relatively successful in the correction of problems.

'

' Additionally, the structure of. the current organization is

.

,

W iviewed as: having enhanced the-overall capabilities of. the'

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O security department as well as= improving the' security

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department's interface. with other. departments. The violations

-

identified %in this area involved an inadequate assessment aid,

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an inadequate compensatory measure, and two inadequate vital area > barriers.= The large number of activities impacting on the security' organization that are attributed to the licensee's

. security perimeter 3 mprovement project (SPIP) contributed to the

aause of the inadequate assessment aid'and-inadequate

_

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compensatory measures violations. Specifically, deficient i

security management oversight of the SPIP implementation was the

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root'cause for these two violations. The two inadequate vital

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area barrier violations occurred when access portals were

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~ altered without security management being given notification

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and being afforded input to the adequacy of the~ alterations.

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Hence, the root causes for these two violations were a failure

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- of maintenance / operations management to effectively coordinate H

the modifications with security management..

,

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Interim immediate corrective action was adequate after each of

,

the above violations was identified. The licensee has increased vigilance and oversight of the SPIP while extensive perimeter modification is underway. The long-term corrective action for vital area barriers requires extensive coordination between maintenance, operations, and security. The licensee has not been fully successfu1~1n this endeavor. This is evident in that the

,

'

first vital area barrier violation occurred in September 1988 N

and the second-vital area barrier violation occurred in

-

August:1989.

The!11censee's independent,-annual audit of the security program continued to improve in quality and is further enhanced by the conduct of various surveillances during the calendar year.

These surveillances were focused on select issues. Upper management also placed special emphasis on early detailed y

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the security-program.-

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! As part of the'overall upgrade program, the licensee has

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conducted aggressive physical security equipment system

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' upgrades. lThis effort exhibited good prior engineering, and the

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redesigns are being completely installed. 'The installation

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f schedule has been maintained, and the effort should be completed within the first quarter of 1990, including the additional

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Tdesign of new alarm stations. The' licensee developed a system

"of accountability for the conduct'of the project, which was y

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responsive to NRC initiatives. This indicates. effective

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management involvement and strong comitment to this area.

-

Since the protected area perimeter upgrade has been underway,

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_ ' segments of the security system have been inoperable.

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~ Thereforei a number of security officers have been placed on compensatory posts; The contract security force seems to have

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. authorized sufficient personnel.to. carry out all-their

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. functions'. The: security officer and supervisory training l

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programs have also been targeted for upgrading.. A more accurate assessment of the training program will be possible following the. completion of. that' upgrade effort.

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Critical positions were vacated in the security organization 4that will require replacements in the near future. One of the eF, Lspecific management vacancies occurred as a result of an

p individual being: detailed to fulfill increased staff.

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h requirements to meet the new fitness-for-duty regulation.- The

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operational; decision-making burden placed on the understaffed

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middle management positions led' to some inappropriate judgements-l; being made about the implementation of compensatory measures.

-

The pressures of control of the daily security operations have t

l not provided sufficient opportunity for. comprehensive; planning.

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-This was,due, in part, to a management vacancy and, therefore, a lack 'of. operational oversight of the security program;.

,

2.-

Performance ~ Rating

,,

.

The licensee.is considered to be in Performance Category 2 in

,

this area.

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-3.

Recommendations

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NRC Actions

.

NRC inspection effort should be consistent with the fundamental inspection program.

Regional initiative inspections should be conducted to ensure satisfactory

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completion of the security program upgrade efforts and the elimination of long-term compensatory measures. Special

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attention should be given to the licensee's security-

personnel development training program, i

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Licensee Actions

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Licensee management should consider the following actions

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to improve' performance in this functional' area:

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Provide strong support-to)the reconstituted security

.

program,

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Review the overall security force staffing to ensure

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' that current staffing-is adequate for implementing

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- additional requirements such as the new fitness for

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Ensure that a strong maintenance program is= developed

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to support the.new physical security systens.

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Engineerino ano Technical Support-

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' Analysisi

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e-The purpose of this' functional area is to address the. adequacy

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E of technicalL and engineering support' for. all plant activities.

.

. The assessment of this area included all' licensee activities

'

..'

associated with the ' design of; plant modifications;. engineering

.

and' technical support for operations, outages, maintenance,

'

.

ms testing.: surveillance; and procurement activities; training; and

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configuration' management.-

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.n-This functional; area'wasiinspected on an ongoing basis by the m

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- NRC resident inspectors and: periodically by NRC region-based.

'

personnel. Also, a diagnostic evaluation and a maintenance team inspection assessed portions of the engineering and technical

'

-support area.

During the assessment period, the licensee's engineering and

,

technical support groups were involved with. challenging and complex. issues. When issues had the potential for affecting plant operations, management's involvement and oversight of

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these highly visib'le issues were effective in providing adequate resolutions. With the majority of these issues being self-identified, the engineering organization appeared to take a

..

-

~1i more proactive initiative in the identification and resolution of" issues versus the limited reactive efforts previously

,,

exhibited.- The approaches taken by the licensee to address the g-technical implications and to define the overall scope of the issues were sound and exhibited the conservatism needed for complex safety-related problems. This was evident during the NRC review of the licensee's actions.

In particular, the

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systems demonstrated this encompassing style of resolution. The..

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. licensee's management > presentation at the enforcement conference l

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for the.HPI system " piggy-back" mode of operation demonstrated a A ' *c

, clear, understanding of the issue.,

'

.

While the' engineering staff aggressively pursued the few highly -

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- complex and visible issues, similar efforts were not taken for-

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the: numerous smaller and less visible problems. Management,-

"y while knowledgeable of the problems, provided little oversight s

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i or prioritization for these issues. ; The number of-problems has

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strained engineering resources..The untimely resolution of less m'

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significant issues has been an ongoing problem at AN0; however, i

' the new: condition reporting system may have the-potential to

y ensure' that issues receive timely and effective resolutions.

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c Numerous-examples of incorrect as-built drawings or incorrect

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~ piping configurations were identified.

In recognition of the

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large number of deficiencies, the licensee had previously-

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established the -isometric drawing update program. This program i

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" wasLexpanded to allow validation of the applicable! design

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calculation after'the verification'of the as-built piping i

configuration. L Additionally, during this assessment period, a j'

large number of electrical. drawing errors were discovered by

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- both NRC and the licensee. =During followup of. these electrical

,

' drawing errors, the licensee discovered that a-wiring

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discrepancy in the Unit 1~ service water pump control cabinets rendered two service water pumps inoperable for a specific event

'

scenario.

'

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. A recent inspection to review licensee actions associated with IE: Bulletin 79-14' identified numerous other discrepancies:

e

'

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between'the piping design analyses and the field piping N

. arrangement, as1well-as. nonconservative modeling practices and lack of certain design analyses. On the basis of previously F

- identified deficiencies and the findings of this inspection, NRC

,

-

determined that!the actions specified in I&E Bulletin 79-14 had not been adequately conipleted. NRC viewed the isometric drawing-update program as an effective method for' design validation of

'

piping systems.. However, a significant concern-identified by t

this inspection involved the progress and schedule for completion of the program which was initiated in 1986 but is only 10 percent

'

l complete.

Currently, the licensee has not committed to a firm

completion'date. This lack of progress to date is indicative of

..

insufficient management oversight and connitment to this program.

.The overall quality of technical support in response to NRC initiatives was generally adequate, with untimely responses for

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3.

several issues being the most prevalent weakness. The delays, for the most part, were a result of engineering failing to

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meet commitment dates.

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The technical support provided by the plant modification

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department for both outage and nonoutage work improved during this assessment period. Outage preplanning' efforts have increased the number of design change packages that were s

,

- approved prior to the outage as compared to previous efforts.

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. The only_ major. violation in the engineering' and technical'

-

support area involved the modifications department and its role

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.

M in allowing an emergency feedwater pump (EFW) to remain

&

uncoupled.during a Unit I heatup.' One of_ the root causes for

'

this, event was indicative of a major weakness of the engineering l-department because the engineers lacked adeqdate, knowledge of TS

.in that they failed to recognize that the pump was required to

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be operable prior to initial plant startup. This event was

,

indicative of continuing communications:and interface problems

'

between<the engineering department and other ANO departments.

'

.

The remaining violations in this4 area were minor, or in the case of: the' violations involving environmental equipment Jqualifications, were the result.of inspection efforts prior to

,

_,e tthis SALP period.

.

'

The size of the engineering staff, both onsite and offsite,

'

remained essentially the same'during the assessment period;

,

however, an increase in,the turnover rate in the engineering

department has reduced the overall experience level. One-potential concern with this-relatively high turnover rate is

,

that the resulting loss of engineering talent may negatively

-

affect the licensee's ability to adequately-perform and support

'long-term improvement programs, such as the design bases

-'

,

-

configuration documentation project. The system engineer

,

program which has been an ongoing effort, made no progress on-

'

-implementation of the program during the assessment period.

'

However, the system engineer program plan'was considered a positive initiative.

,

The condition ' reporting system identified'a large number of p

. deficiencies and concerns during'the assessment period. The

~ technical support required to resolve these deficiencies has greatly increased the workload of the' engineering department.

~ With the. implementation of the condition reporting system, the v'

. majority of engineering. department resources has been dedicated to the dispositioning of open condition reports. With this

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shift in emphasis and workload distribution, combined with the reduction in experience level and an unimplemented system

'

engineer program, NRC is concerned that sufficient resources may not:be available'for plant support and design efforts. This

.,

concern is compounded given that engineering support to other departments has been historically weak.

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The-licensee continued to maintain and implement an effective g

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training program for both licensed and nonlicensed personnel.

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The program is well; defined with sufficient resources available.

4T Feedback of plant axperience into the various training a

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-

disciplines was also evident. The excellent pass ratio for

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initial licensing examinations; indicated an effective training-program for individuals entering'the licensed operator program.

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c iHowever there was a persistent indicator of reduced system

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1-knowledge at the senior reactor operator (SRO) level in the last two SR0 written examinations.

It appeared that requalification

. training may be'less effective than initial licensing training.

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-2-Performance Rating

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The licensee is considered to be in Performance Category 2 in this.

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area.

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Reconenendations

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NRC Actions'-

NRC inspection effort should be consistent with the fundamental

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11nspection program..: Regional initiative inspections should be conducted in the areas of motor-operated valve and check valve

,

performance programs.- In. addition, an inspection should be

-

-conducted in the area of safety-related piping and pipe support

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. design and' modification in order!to assess the adequacy of licensee corrective actions.in this area. PeModic plant K

performance meetings should be conducted with '.;censee '

-

management, with particular emphasis on monitoring the. progress

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of engineering and technical support related plant improvement

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my, programs.

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Licensce Actions p,,:

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Licensee management should. consider the following actions to e

improve performance in this functional arent Prioritize efforts to ensure that improvement-programs that

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-

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will make the greatest contribution to safety will be-implemented first;

,

Establish realistic schedules for improvenent programs; i

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Assess the adequacy of engineering department. resources to l

perform.the routine workload as well as support the various

'

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plant improvement programs; Continue to improve engineering department interface; and

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. Fully implement the system engineer program during the next SALP period.

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G.

Safety Assessment / Quality verification n

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'1.

Analysis'

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i The assessment of this functional area included all licensee review activities associated with the implementation of licensee policies;

.. licensee activities related to amendment, exemption, and relief

requests; response to generic letters,-bulletins, and information-

-

notices;. arid resolution of Three Mile Island items and 'otherz

.

' regulatory xinitiatives.< The assessment of this functional-area also.

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included licensee activities related to resolution of safety issues,

,

10 CFR 50.59 reviews,:10;CFR Part 21 assessnents, safety committee

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and self-assessment' activities, analyses of industry's operational

. experience, root cause analyses of plant-events, use of feedback from-

-

.plantiquality asssurance/ quality control (QA/QC) reviews, and-participation in self-improvement programs. The assessment included the' effectiveness of the licensee.'s quality verification function in

,

.

identifying;and correcting' substandard or anomalous performance, in

>

l-identifying precursors of potential problems, and in monitoring the overall performance.of the, plant,

,

This functional area was assessed-on a: continuing basis throughout the1 period.- The111censee's performance in the safety

- assessment / quality verification area declined significantly during the SALP period, and can be attributed to weak.self-assessment capabilities and a lack of effective management involvement and

..

oversight.fWhile'the licensee made improvements in the ability.to identify problems and react to significant events, they were not fully

,.

~ successful at identifying precursors -to declining performance and,

"

-

onco identified, in implementing effective corrective actions.

In

the latter part of the SALP period,- however, the licensee implemented

'

a new organization'and filled all~ key management positions with

,

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-

current Arkansas Power & Light Company (AP&L)' employees as well as with managers from outside AP&L. While it is too early to have fully l'

assessed the effectiveness of the new organization's ability to improve plant perfonnance, some improvements have been noted, p

particularly the licensee's regulatory interface with NRC.

-.

During this assessment period, the licensee demonstrated the capability to resolve some significant safety and regulatory issues.

,

L This capability.was evident in the actions taken to resolve the.

r.

backleakage associated with a Unit 1-HPI check valve that failed to

'

reseat following a reactor trip in January 1989. Licensee actions to resolve this and all the other issues resulting from tho, trip were indications of adequate management involvement, sound technical

.

b analysis, and responsiveness to NRC concerns.

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l AP&L's responses to NRC Bulletins continued to be timely and

.

igenerally technically complete. Similarly. AP&L's responses to most

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- generic letters were also prompt and complete.. However, the response to Generic' Letter 88-17. " Loss of Decay Heat Removal." was misleading

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,

Jand found to be in violation of 10 CFR 50.9. Other inaccuracies were

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noted in the licensee's response to a violation associated with

environmental equipment qualification of motor-operated valve

-

components. These examples _are symptomatic of a. weakness in managenent review or oversight >of correspondence to NRC.

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D, 4~'~

'

Eighteen operating 111 cense amendments.were issued for Unit 1

(Nos.110-127);andf14 for Unit.2 (Nos. 86-99) during this period.

- '

'

i Many of the' examples of deficient submittals for licensing and-

'

,

~

regulatory issues. listed in the previous.SALP report were for proposed license amendments. The types of problems noted previously,

'

,

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continued to occur in this assessment period.

Examples of continuing problems' included inadequate supporting analysis for an emergency

'

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amendment-which proposed operation.at a maximum of 74 percent power

'

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for Unit 1 and untimely response to a request for additional-

,

infonnation regarding a TS change. to reflect the Unit 2 station

- battery upgrade (noted.in the pttvious SALP report). Despite the

'

problems noted above, the majority of the other amendment proposals were adequate.

Several amendments resulted from AP&L's initiative to'

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clarifyf and. improve TS^for both units.

LThere were also examples of other responses where extensions of. time

y-were frequently required or considerable NRC effort was needed to

,

obtain acceptable resolutions. These examples included issues

'

associated with control room habitability, service water flow L

-

deficiency (Unit 1), seismic condensate storage tank: design review,

"

,

and' commitnents made regarding the steam generator remedial action

.. plan (Unit 1),andsafety-relatednozzle_stressissue(Unit 1).

,'

There ' appears to be two underlying causes for the a'bove identified

1

. weaknesses.

First, these~ examples indicate that licensee-procedures

'

L land policies governing licensing activities were either inadequate or f

were not consistently followed. Second, missed consnitments, lengthy _

l

. submittal delays, and lack of technical detail appear to be caused by

.

'

" resource limitations and weaknesses in the licensee's commitment'

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tracking systems.

,

A < review of the enforcement history for this. functional area revealed

,

that both major and minor violations were-indicative of programmatic breakdowns in the areas of corrective action and reporting.

In the

.

. first half of the SALP period, the licensee was cited for several

..*

examples of potentially significant safety deficiencies in which the R

corrective actions were significantly delayed. Lack of timeliness in

.ineplementing corrective actions was also identified during the

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g previous SALP period.

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period. Some reportable events were either not reported or were reported significantly late to NRC. For example,' in the fist half of -

c the SALP period, the: licensee had not been; reporting Unit 2 control

,

i roomemergencyventilationsystem(CREVs)actuationsinaccordance

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with.10 CFR Parts 50.72 and 50.73.

This was' cited as a violation in

"

" January 1989., Subsequent to January 1989, the licensee reported

dozens of inadvertent'CREVS actuations. Additionally, the e

reportability determinations: for many past events (some as old as 2 s

-

to 4 years) were not made until this SALPiperiod. Many of these g

events were determined to be reportable in accordance with 1 _R, 10 CFR 50.72 and:10 CFR-50.73.

r In May and June 1989, a special team inspection was conducted to

-

review licensee event reports (LERs). The team found.that there

'

,

- continued.to be a large number of overdue LERs. Overdue LERs were attributedito a lack-of management oversight, lack of adequate m

resources to complete the LERs, interdepartmenta1' communication

"

. problems, delays in making reportability determinations, and

-

E weaknesses in the administrative processes for drafting LERs.

L Excessive tardiness in submitting LERs was noted in the previous SALP

'

"

period 'as welll as earlier in this period. Because of the magnitude

,

of the problem and a lack of responsiveness in correcting the problem a:

until late in the reporting' period this problem was considered to be

-

H-

- a programatic breakdown of the reporting system,c Since June 1989,

-the licensee,has eliminated the backlog:of overdue LERs, but has not

'yet fully implemented corrective actions in this area..

,

M-

.

many instances,.were limited to correcting the specific problem.

For

.

LER quality was generally good, but documented corrective actions, in example, many LERs were indicative of various weaknesses in the J

licensee!s program for performi_ng TS 'surve111ances' and tests, As of

,

the end of this SALP~ period, the licensee'had not determined the

,b-causes of these weaknesses.

.,

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During this SALP )eriod, there were many operational events, some of y

,

!

which might have 3een prevented if the, licensee performed more thorough root cause analyses or implemented extensive corrective

"

action in a timely manner. Although, the licensee has a

,._

f comprehensive program 1for determining the root causes of significant H

events", the program appeared'to be strained because of the number of adverse conditions that have required resolution.

Examples of repetitive events that might have been prevented include instances of

,

inadequate control of safety-related equipment status, several H

interruptions of decay heat removal flow (Unit 1), dozens of

.

inadvertent control room emergency ventilation system actuations, reactor coolant pump seal sensing line leaks (Unit 2), and several l

safety-related motor-operated valves not stroking upon demand.

Despite continuing problems in corrective action and reporting timeliness, AP&L made significant improvement in the ability to

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Y identify plant problems with the condition' reporting system. The-

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licensee's effectiveness in identifying plant problems can be

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attributed to the consolidation of old corrective action systems, enhancements to the nuclear quality department, encouragement of-

^ lant personnel to identify problems, and several plant improvement p

-

programs. -- Some examples of these improvement programs include the

- '

PMIP, theDisometric drawing update program, the design bases

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configuration-documentation. program, and safety. system functional inspections. While these programs have been effective;in identifying

-

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_ plant problems ~, they do not appear to have been given sufficient.

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priority. _ For many of these programs.; project scopes and schedules T have.'not been established or,:in the case of the' PMIP, are past due

'

for completion.c Some have been ongoing for'several years with only a=

,

fraction of the project scope accomplished to date.

If these

programs are to be completely effective, increased corporate

', -

management involvement and-oversight is needed.

-

,

.

'

During this assessment period, several significant enhancements.were noted within the licensee's nuclear quality department. The

.;

' licensee's nuclear quality department demonstrated the ability to identify plant" problems:and use of_ feedback from plant QA/QC reviews i as been apparent. However, it-is not apparent that the nuclear h

Equality department has been effective in identifying precursors to

.decliningiperformance; trends, such as~the implementation of the

-

.

Lsurve111ance program.

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In the first half of.this assessment period, maintenance team f;

L-inspectors) evaluated the licensee's analyses and use of industry omrating experience.- The maintenance team found that, prior to 1987, o

tie licensee performed little analyses of industry operating experience-

,

that was not required by NRC requirements or commitments made to NRC.

'The team attributed this lack of analyses to insufficient resources

'

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-

to accomplish thist task. During the previous SAlp period, rescurces lwere provided and improvement'has been noted.

-

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-2.

Performance Rating The. licensee is considered to be in Perfonnance Category 3 in this E

area.

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3.

Reconsnendations a.

NRC Actions y

,

J NRC inspection effort should be consistent with the fundamental

"

~ inspection program.

Regional initiative inspections should be conducted in the areas of plant support resource allocation, root cause analysis and corrective action, QA/QC effectiveness,

-

industry operating experience utilization, and self-assessment

-

capabilities.

In addition, an inspection should be conducted

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'for followup onithe large number of open items, particularly

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LERs. Periodic plant performance review meetings should be

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conducted with licensee management, with particular emphasis on

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y the: progress;of: plant improvement programs.

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Licensee Actions-(

-

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' Licensee.managemen't should consider,the following actions to i

improve-pepformanceinthisfunctional: area:

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Reduce the condition report backlog =while improving.the-

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condition reporting system, with' emphasis on thorough root'

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cause-determinations and thorough corrective actions for

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-

significant events ' defined in the licensee's program; q*

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Improve site-departmental interfaces;,

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-Improve the ability to track and meet internal and external d

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commitments;

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i Continue to improve'the review of industry events and

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'

provide timely implementation of lessons learned;

Prioritize plant improvement programs.fincluding the

i

' establishment of realistic' schedules; and w

-

Improve the quality (technical content-scope, and I

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accuracy) of submittals made to NRC. Management involvement in licensing activities should be assessed to ensure that adequate levels of staffing and technical

!

-

,

-

resources are assigned to assure high quality _ responses to

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a NRC initiatives.

q Vi SUPPORTING D'ATA AND SUMMARIES j-A.

Licensee' Activities

--

1.

Major Outagest j

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,

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-a.:

Unit 1 The unit was shut down for Refueling Outage IR8, repairs and

,

modifications associated with a plant trip and subsequent RCS i

~

i backflow event,t and the repair of leakage from an RCS drain

"m valve weld and= from'the reactor vessel level detector flange.

b.

' Unit 2

'

The unit was shut'down for the repair of a pressurizer flange leak, the ' replacement of a reactor coolant pump (RCP) seal and s

'

repair of RCP seal pressure sensing line, the replacement of an

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3: TRCP seal due to a. crack-in a weld for the seal pressure sensing

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..line,1the repair of a ruptured high pressure steam line, the

-

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repair of flange leakage from a reactor head vent line, and

,

.

Refueling Outage 2R7..

< a..

-2.

Power Limitations

.

,s

,

_

Unit 1? License Amendment 119,1 dated March 29, 1989,' limited

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reactor-power to 50. percent of rated thermal power for 50

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g e

.

,

y'

effective-full power' days. The power limitation was due to -

.

,

~

,

the licensee's identif.ication of-a more limiting small

~

break loss ~of coolant ' accident (LOCA) scenario than had

'

e

'

been previously; analyzed..On the basis of the new scenario,

-

qi-ehigh pressure injection flow into'the reactor. core would be

<

significantly reduced;from values used in previous LOCA

'

m.

<.

pW'

? analysis. Unit 1-License Amendment 120, dated May 16, c)

p 1989.11ncreased reactor powersto 80 percent. The increased

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power' authorization was made'on the basis of results of a'

-

..'

N

,

' plant' specific LOCA analysis:that was performed in accordance

'l '

.t with'10 CTR Part 50.46 and Appendix K.-

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,As of July 19, 1989, Unit 1~has been limited to 74-percent

'

T

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'gower because.of operation with three of four RCPs..The

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D" RCP was secured because of leakage of the upper motor -

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bearing lubrication oil.

,

b 3.-

License Amendments-

.

"l During the: assessment period, there were ~18 Unit I and 14 Unit 2 o

operating -licenseiamendnents,

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14.

Significant Modificaticns t

,

l a.

Unit 1

'

L'

. Installation:of new style reactor coolant pump seal

-

and flexible. hoses in pressure sensing lines; m

Cleaning-and coating service water return line:to

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emergency cooling pond;..

m

.

Installation of new stop check valves in the high E

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p.

pressure injection lines.

b.

Unit 2

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,

.

Installation of new core protection calculator

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L preparation for tie-in during upcoming refueling

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.

outage.

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c.

. Common' Modifications:

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Several security' perimeter upgrades were. started at the end

-

of'the assessment period, t..

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,*

,

.

..

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pp

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. Direct Inspection and Review Activities j

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..

"49 NRC. inspection activity during'this SALP evaluation period included y 3:

55 inspections and>1Ldiagnostic evaluation performed with.

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"

U approximately 4,298 direct inspection hours expended for Unit I and-l

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c:2,608 directtinspection-hours expended for Unit 2.

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,

.

,

$. < #

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,C.;

Enforcement Activity

v n)g.

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'S

, - The SALP. Board reviewed the enforcement history for the period-

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July 1,1988,: tnrough September 30. 1989. This review included the

,

.

'

' deviations.. violations, and-emergency preparedness weaknesses

'

' tabulated by SALP Category.in the enclosed table. A footnote is y' ' J,,

, provided to. identify any functional. areas associated with civil

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penalties or orders.-

c

,

[*

iD Confinuation of Action Letters

,

.

Confirmation of Action Letter (50-313/ CAL 88-19) was forwarded to

,

AP&L;on November 7,.1988.- The purpose of the CAL was to document

'.i m

that AP&L would: address'four~ corrective action issues-prior to the

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,

restart; of. ANO - Unit 1.

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- $

TABLE r

ENFORCEMENT ACTIVITY i

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(IncludesBothANO1andANO2)

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g

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h i

FUNCTIONAL.

NO. OF VIOLATIONS IN

>

,

l AREA EACH LEVEL

'

,

'

WEAKNESS DEY V,

IV

!!!

EQ Cat.C 11 I

.

A.

Plant Operations-

3 1(I)

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B.

Radiological

5 1(2)

'

Controls

.

II)

C.

' Maintenance /

I Surveillance

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.D.

Emergency-

Preparedness

E.

Security

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!

F.

Engineering /

6 I

'

~ Technical Support

)

Assessment /

2.

.10

SafetfityVerification G.

Qua-TOTALS

2

33

1

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(1)- A civil penalty of $75,000 was paid on May 5,1989, for a Severity Level III problem in a Notice of Violation and Proposed Imposition of a

,

Civil Penalty dated April 7,1989. The first two exanples involved a Unit 1 plant heatup above 280*F with the turbine driven emergency

.

'feedwater pump uncoupled. The third and fourth examples involved the inadequate repair of two high pressure injection system manual isolation valves.

,,/

(2)'Acivil:penaltyof$25,000waspaidonApril3,1989,foraSeverity

Level 111 violation in a Notice of Violation and Proposed Imposition of a

'

Civil Penalty dated March 2,1989. This violation dealt wit 1 a whole body

exposure of a maintenance worker in excess of the quarterly limits, and

, r inadequately perfonned surveys.

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(3)/Acivilpenaltyof$75,000wascontestedonJune 22, 1989. for en environmental qualification Category C violation in a Notice of

Violation ~ and Proposed Imposition of a Civil Penalty dated April 24, 1989.

I

!

This violation dealt with inadequate qualification of Limitorque notor

[L operated valve components that were identified in 1986,

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(4) A civil penalty of $100.000 was paid on May 5,1989, for a Severity Level !!! violation in a Notice of. Violation and Proposed Inposition of a j

Civil Penalty dated April 7, 1989. This violation dealt with several

[

examples of failure to take prompt corrective action.

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IR 05000313/1989034

Text

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