IR 05000322/1986099
| ML20236W206 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 12/01/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236W156 | List: |
| References | |
| 50-322-86-99, NUDOCS 8712070328 | |
| Download: ML20236W206 (54) | |
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ENCLOSURE 1 U. S. NUCLEAR REGULATORY COMMISSION
REGION I
l SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT 50-322/86-99 LONG ISLAND LIGHTING COMPANY
, SHOREHAM NUCLEAR POWER STATION ASSESSMENT PERIOD: MARCH 1, 1986 - JULY 31, 1987 BOARD MEETING DATE: SEPTEMBER 13, 1987 l
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s o SUMMARY OF RESULTS Facility Performance Functional Category Category Trend Area Last Period * This Period ** If Assessed Plant Operations 2 1
& Startup Testing Radiological 3 1 Controls l Maintenance 2# 2 Improving l Surveillance 2# 2 E Engineering and *** 2 Corporate Technical Support Emergency Preparedness 1 1 Security and Safeguards 1 1 Training and 3 2 Improving Qualification Effectiveness Licensing Activities 3 1 Assurance of 2 1 Quality Outage Management, 2 ***
Modifications and Technical Support Activities
March 1, 1985 through February 28, 1986
March 1, 1986 through July 31, 1987
- Not evaluated as a separate functional area
- Maintenance and Surveillance were previously assessed as a combined functional area
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8' OVERALL FACILITY EVALUATION In this seventeen month evaluation period, the Shoreham Nuclear Power Station staff and management has maintained the high performance levels for areas previously assessed as strengths and effected improvements in other area Plant operations and the conduct of startup testing ' during two low power test intervals was found to be well executed, with intensive management involvement, good procedural compliance and performance-oriented Quality Assurance audits and checks. A notable decrease in personnel errors, particularly in operations and surveil-lance activit4es, was observed. Several areas discussed in detail in this evaluat.on showed considerable improvement as a result of management attention and expenditure of resources; these areas include radiological controls, training and qualification effective-ness and licensing activitie While improvements were achieved in maintenance, surveillance and technical support, some performance shortcomings were noted. In the mainte-nance area, it was determined that first line supervisors are limited in the amount of time spent at work sites; one resulting symptom is poor housekeeping following maintenance work. Corrective action to reduce the number of challenges to the Reactor Building Standby Ventilation and the Reactor Building Closed Loop Cooling Water systems has been slow. The loss of offsite power event resulted from a weakness in technical review of a modification involving safety-related electrical buses, for which corrective action has been take The weaknesses noted in the previous Systematic Assessment of Licensee Performance regarding chemistry and radiochemistry staffing, training and performance have been addressed, but warrant continued management attention to ensure long-term effective performance. The licensee maintains the station and staff to support site operatio In the future, this readiness must be maintained to sustain the same levels of high performance and effect ongoing improvements.
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IV. PERFORMANCE ANALYSES Plant Operations and Startup Testing (1144 Hours, 32.29 Analysis During the previous assessment period, the area of Plant Operations and Startup Testing was rated a category 2. The recommendation of the board was to focus greater attention on personnel adherence to procedure Startup Testing In this assessment period startup testing activities were conducted during two periods of low power operations over a period of approxi-mately seven weeks. Although the majority of the low power testing program was completed during the previous assessment period, exten-sive retests were conducted on the Reactor Core Isolation Cooling, High Pressure Coolant Injection and Reactor Vessel Level Instrumen-tation Systems to sati sfy the requirements of the Startup Progra Inspection coverage of the Startup Program by the QA/QC department was evident at all levels from direct inspection of testing to review of test -results. QA/QC personnel covering startup activities were well trained in the activities under surveillance and were effective in identifying problem areas and following proposed resolution The planned QA/QC coverage for the remainder of the Startup Program is scheduled to include surveillance coverage and test result revie Plant Operations During this assessment period, the bulk of activities conducted by operations personnel involved the support of maintenance, modifica-tion, and outage activities. For approximately seven weeks the facil-ity was operated at power levels not exceeding five percent power primarily for the conduct of low power testin Management involvement has been evident in all areas of plant opera-tions during this inspection period. At all times during major evolutions including startups and major tests, at least one member of senior management has been present in the control room. Plant tours by operations management are made on a daily basis and the interface between management and staff is good. It is also signifi-cant to note that senior management presence on site extends beyond normal working hours. The licensee Vice President Nuclear, Assistant Vice President Nuclear, and the Plant Manager routinely made back-shift tours of the facility. The licensee initiated this program of backshift monitoring following notification of NRC identified prob-i lems at other operating facilities. This program demonstrates sen-l sitivity to NRC concerns and has enhanced management oversight of plant operations during off-normal hours.
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Operations personnel performance has been. effective and professiona Personnel errors attributed to operations ' have been greatly reduced during this assessment period as evidenced by the reduction in LER's
- from twelve in the previous assessment period to four. during this period. Of these four errors, all occurred while the facility was in a cold shutdown condition, and one was attributed directly to . an error on the part of a licensed. individual. This reduction in'per-sonnel errors can be directly attributed to-increased diligence on the part of operations personnel and to increased emphasis placed by plant management on quality of operation and adherence to procedure Operations personnel response to plant operating transients and ,
equipment problems has been very good throughout this assessment period. During the loss of offsite power event on March 18, 1987, the onshift personnel quickly analyzed _ the problem, restored offsite power, returned plant systems to normal, and completed emergency plan
, actions in a timely manne Operator ' procedural' compliance has been good' throughout this perio Use of alarm response procedures when reacting to infrequently re-ceived. alarms has also been good and- operator feedback has been ef-
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fectively used to : improve procedure quality and usabilit A major revision of the Residual Heat Removal system operating procedure and revisions to numerous surveillance and alarm response procedures resulted from operator feedback. Technical Specification interpreta-tions by 1.icensed personnel have been accurate throughout this assessment perio Formality in the control room has been enhanced during this assess-ment period. Interactions between plant staff and startup personnel are. currently. on a more professional level than previously noted and effective use of two. Day Watch Engineers in interfacing with support staff has reduced traffic in the control room. Improvements made to the Control Room decorum have been particularly effective in reduc-ing traffic in the Controls Area and reducing distractions to the licensed operator These initiatives included movement of plant drawings from the Controls Area to a backpanel area, restructuring the process by which work authorization paperwork is processed, and placement of a first line supervisor directly in the Controls Are Staffing levels of licensed and non-licensed operators increased dur-ing this rating period as the licensee continued to hire and train operator Although there was some attrition in the non-licensed area, these losses were offset by individuals who had recently com-pleted the required training programs. Additional licensed personnel became available through the completion of a license class in January when all ten candidates who underwent NRC license examination were successful and received their licenses. As noted elsewhere in this
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l-assessment report, performance of these individuals during the NRC licensing process was found to be exceptional, with no outstanding generic weaknesses noted. The licensee plans to complete two replace-ment licensing classes during the next year. These actions demon-strate a commitment on the part of licensee management to maintain the current staffing level of five licensed personnel on each of six shifts in the foreseeable future. It is also significant to note that although Shoreham Technical Specifications do not require five licensed personnel on shift during shutdown conditions, the licensee has made a practice of maintaining a full complement of licensed personnel on shif t regardless of the mode of operation. This factor coupled with the recent acquisition of a site specific simulator facility contribute greatly to the operational readiness of the licensed staff despite prolonged periods of cold shutdow While the plant was not operated at greater than 5 percent power, operations continued for approximately seven weeks total over two separate occasion Plant activities at low power included all phases of operation up to rated reactor pressure and temperature conditions along with the completion of various system startup test Additionally, on two occasions during the assessment period, the main generator was placed on line supplying power to the Long Island Gri Reactor operations at low power for extended periods of time can be de nanding, from an operational standpoint, providing substantial opportunity to assess operating performance and capabilities. This is due in part, to the fact that many of the automatic control fea-tures available at higher power levels are either unavailable or in undesirable ranges or conditions while at low powe Plant operations during these periods were consistently conducted by the operations staff in a highly proficient manner resulting in no inadvertent trips or significant operational problem Equipment problems with feedwater pumps, Automatic Depressurization System valves and the main turbine which required relatively prompt response were all handled in a prompt and prudent manner which resulted in continued plant operations uninterrupted by forced or automatic shutdown The quality of LERs submitted during this assessment period has been evaluated by the NRC and the results indicate that overall LER qual-ity has improved and is above the industry standard. The quality of text discussions concerning root cause, safety consequences, person-nel error, and operator actions has improved over previous evalua-tions. While the quality of the text discussions improved substan-tially, the quality of the abstracts remained virtually unchange The primary weakness in the abstracts is that the causal analysis and corrective action information are not being adequately summarize .
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Quality Assurance organization activities in the operations areas have included routine performance based audits of operator perform-ance, monitoring of startup terts and reviews of the test result In conclusion, during this assessment period, which involved limited operational activities, management involvement has been extensive and effective in improving quality of Plant Operations and Startup Test-ing. Overall performance has improved. Management involvement in the startup program was evident throughout the period. Senior management presence in the Control Room during major evolutions has been a ,
positive influence on Control Room formality and demonstrates a t commitment on the part of the licensee to ensuring senior management involvement in plant operations and testin Rating: Category 1 While the operations area was rated as Category I, NRC as a matter of policy will not reduce inspection effort in this area because of- ;
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8. Radiological Controls (299 Hours, 8.4%)
Anclysis In the previous assessment period, the licensee conducted an ef fec-tive radiation scfety program with a fully qualified staf Minor veAnesses were observed in regards to the control of beta radiation exposures, ensuring that the staff was aware of all significant pro-cedure changes, and oversight of radwaste shipping activities. How-ever, as a result of serious weakness in the licensee's chemistry and radiochemistry programs, particularly in the areas of staffing, qualification and laboratory QC, the licensee received en overall ,
SALP category 3 rating in this are l During the current assessment period, the licensee made substant,ial effort to understand and effectively address deficiencies in program performance. This assessment is based upon observations of ongoing plant activities and evaluations of programs. Since radio-logical conditions were limited, this assessment enphasized program-matic and operational readiness considerations, rather than demon-strated implementation of radiologicci controls. While not signifi-cantly challenged operationally, a meaningful evaluation is possible based upon observed activities such as source replacement and con-trols in plac Occupational Radiation Safety During the assessment period there were three detailed radiation pro- '
tection specialist inspection Areas reviewed included audits, internal and external dosimetry, staffing, ALARA, training, routine surveys and recordkeeping. The resident inspectors also routinely reviewed selected program area No violations were identifie There were five minor radiological Licensee Event Reports (LER) all attributable to errors by techniciaris: four instances involved fail-ure to take acceptable samples and one instance involved failure to make periodic neutror, source leak checks. These events were of min-imal safety significance and to a large extent reflected the develop-ment of the staff in gaining experience with operating conditions and requirement The radiation protection program has not yet faced significant opera-tional challenges, since plant operation has been minimal and limited to 5% power. However, management has continued in efforts to achieve excellence and prepare for full power operation. In addition to up-grading supervisory oversight of the radiation protection program, reviews conducted by the Quality. Assurance 6 organization have stressed performance assessmen Indepth and comprehensive audits by knowl-edgeabie personnel were completed of the ALARA, training and radwaste
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areas The reports of these audit; identified to licenser, ranagement other performance weaknesses and area 3 deservir.g improvement., initi-ating an additional round of corrective actiens and perforanance enhancement Weak areas were subsequently reaudited at 6 month
. intervals until inanagement _was satisfied with the performance of the radiation protection progra The Quality Control department has also developed a series of check-lists for review of routine radiation control activities. Teams con-sisting of knowledgeable and experienced QC and radiation protection personnel conduct weeu y checks of routine activities using these checklists. Discrepancies are transmitted to management and formally tracked until findings are completely resolve Management response to these findings, as well as those identified by the NRC, has been excellent. The technically sound resolution of the issues irdfcates a good understanding and technical competence of the staf The radiation protection departinent remains fully staffed with higbly
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experienced contractors used for certain supervisory positions. Re-quired procedures are fully developed with esitensive detail and instructions, providing valuable aids to minimally experienced staf To buildup staff experience, technicians and supervisors are sent to other facilities to participate in outages at operating station The licensee's commitment to trsining is substantial as evidenced by the construction of a large modern training cente Of particular note, the inplant laboratories and radiatien protection equipment are I duplicated in the training center laboratorie Minor weaknesses were ob:erved by NRC during routine activities at-tributable to lhek of technician field experience during the ext,anded licensing delays. Workers did not aiways receive adequate briefing regarding the Radiation Work Permit (RWP). The Whole Body Counter (WBC) operator did not maintain charts to trend equipment perform-anc Pumps used for air sampling were inadequately calibrated at low flow rate Maps used to record routine radiation survey d&ta were confusing and inconsisten Exposure records did not have pro-visions to record multiple special dosimetr In each case, the licensee took prompt and effective action to resolve these issues during the assessment pertod. In addition, excellent radiation pro-tection p'rogram performance was noted in regards to the maintenance of instruments and use of automated systems and computers for pro- j cessing TLD Dosimetr Licensee initiatives in the ALARA area have corrected previously identified weaknesses. The ALARA program policies are particularly good with followup provided by a competent corporate staff of radio-logical engineer Of note, various plant equipment changes were made to minimize buildup of future radiation exposures; including elimination of crud traps, reduction of stellited surfaces and enhanced equipment reliability and maintainabilit l
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~i 15 4 lL Chemistry and Radiochemistry .j l There was one special team inspection of the licensee's radiological
- and nonradiological chemistry programs during the assessment period.
i The inspection examined organization ana management, techincian j trainbig and qualification, radioactive effluent contrei program, and l ranrediologic:1 waar. chemittr The findings indicated that the licensee has made significant organization and nianagement changet to j address identified problem Aggresstve recruitment resulted in l almost complete staffing of the chemi'.try denartment management and '
L professional positions 'oy lir.er.see personnel . This c6n be compared l ~to the previous assessment pariod when approximately 40% of the chem-istry staff were contractor imployees. In addition, a Radiochemistry 4
?mponment Task Force was formed which reports directly to the plant manage The organizational changes as well as the recruitment actions demonstrate management involvement in correcting previously identified deficiencies in the chemistry progra Training and qual-ification of chemistry technicians, a central area of inadequate performance during the previous assessment period, also improved during the assessment period. The licensee has initiated an aggressive and effective program, conducted by the Radiochemistry Improvement Task Force, to requalify all chemistry technician The licensee has also improved their nonradiological water chemistry p rog ra In the area of 'f aboratory quality asrurance, the licensee is now using two. independent standard solutions (instead of one) for calibration and measurement control in order to cross-check and verify the integrity of the standard solution Draft procedures have been generated for quality control (QC) in the nonradiological and radiological laboratories which show significant improvement over past QC practice They are also revising appropriate analytical procedures to include a statistical curve fitting method for calibratio The licensee has implemented an effective radioactive effluent con-trol progra All Technical Specification limits for sampling, analysis, use of radioactive waste treatment systems, and reporting are being me The implementation of the laboratory QA/QC program, particularly as it relates to meaturing radioactivity in effluents, has improved as a result of management attention to this area. All licensee aialytical results of spiked NRC radioactivity standards, submitted to the licensee for analysis, were found to be in agreement with expected value Because of the low source term present, it ;
should be noted that this area has also not been fully challenge ]
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Conclusion
, in cor.clusion, the licensee implemented an effective radiation pro-I tection program and substantially corrected all previous concerns for the past deficiencies in their chemistry program. This cutcome has been the direct result of significant senicr management involvement in oversight, prcblem discovery and corrective actions. It is clear that programmatic changes have been implemented to correct deficien-cies in the. training, qualification and staffirg in the chemistry are The positive contribution of aggressive and knowledgeable quality assurance and quality control steffs, to the enhancement of this program area, is clearly evidant. Although the "unctional aren was not significantly challenged by pi ar't operations during the assessment period, levels of planning, preparation, staff and program development were those of a plant ready for operation. Performance observed and assessed during this period indicates that site radio-logical, effluent control and chemistr/ programs have the capabflity to support piant operations. Management efforts should continue to ensure programmatic improvements remain effectiv Rating: 1 Wnile the radiological controls area was rated as a Category I in performance, NRC as a matter of policy will not reduce the inspection effort in this area due to the unique licensing status of Shoreha !
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i C. Maintenance (528 Hours, 14.8%) f Analyd s This area was rated category 2 during the previous assessment perio l No major concerns were identified during that assessment period and the maintenance programs were judged to be performing well.
l A number of initiatives were undertaken to address areas of concern identified in the previous assessment period. These initiatives have 1 been successful with one exception, the amount af time spent in the field by first-line maintenance supervisors. Preparation of work packages is currently the responsibility of the appropriate first-line supervisor. Although job planning has been complete and accur-ate, placing this planning workload upon the first-line supervisors redu:es the time spent in the field. A symptom of this lack of field supt:rvi sion has been noted in the area of. post-maintenance house-keeping. Instances have been noted when work areas have not been returned to their original condition upon completion- of maintenance activitie Tools and loose debris have been left behind at job sites, and scaffolding has not always been removed when work was complete. This may be attributed to a lack of attention to detail on the part of firct-line supervision and is an area of weakness that warrants additional management attentionz It should be noted that although this problem has not been a deterrent to qus11ty workman-ship, increases in maintenance workloads will further dscrease direct supervision and could result in more significant manifestation The large backlog of evaluations needed to address industry problem notifications was an area of concern in the previous SALP assessmen The licensee has instituted an aggressive prog ram to reduce this backlog as evidenced by a steadily decreasing number of items' await-ing resolution. Currently there are no item's awai t.i ng disposition ,
which are greater than sixty days ol Implementation of a Material Management Information System and other enhancements to the material control program has improved the avail-ability and retrievability of spare parts. This previous area of con-cern appears to be functioning well and the licensee is continuing to make improvements in this are The well controlled maintenance program has produced quality work during tnis assessment period. Program challenges have been met by maintenance personnel as demonstrated by the absence of equipment deficiencies and no backlog of safety related riiaintenanc Mainte-nance supervision demonstrated ef fective work planning, resconded capably to contingencies, and rnaintained a well trained and staffed organizatio _-__--- -___ - _ -
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Upper management scheduling has been a strength during this assess-l ment period. Schedules have been well conceived and realistic in
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goal In very few cases were schedules not met due to problems internal to the Maintenance Divisio Significant demands for maintenance were met during the neutron source replacement outage and during major equipment repairs such as:
overhaul of "D" RHR pump, inspection and repair of the RHR heat exchangers, circulating water pump overhauls, and emergency diesel generator disassembly for inspectio Craft training programs have been submitted to INPO for accreditation during this assessment period. Completion of the new Corporate Training Center has made available a valuable training tool. In addi-tion to formal classroom and on the job training provided by the licensee, laboratories and mock-ups are available at the training center. Also, vendors are used u provide specialized training, when necessary, as part of the craft training program. The licensee ulti-mately intends to implement a full scope training program whereby individuals with little or no experience will start as apprentices
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and proceed through the journeyinan level. This demonstrates a commit-ment on the part of the licensee to maintain a qualified work forc The current level of knowledge and abilities of craft personnel has been good. Evidence of this has been shown by a lack LER's resulting from craft personnel errar and minimal rework items caused by inade-quate craft skills or technician error In conclusion, maintenance programs during this period were performed in a manner which provided excellent equipment availability for the limited plant operatio Safety related work was properly prior-itized and planned and no instances of improper aiaintenance were identified which caused equipment or system inoperability. Quality Assurance Division was involved in all sa'aty related activities and Engineering support of maintenance was good. f.fficient use of craft personnel by management resulted in an adequately implemented main-tenance program. Furttier management attention should be directed to ensuring adequate first-line field supervision; housekeeping and job followup problems have been noted and increases in maintenance work-load can exacerbate these problems, !
Rating: Category 2, Improving i
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D. Surveillance (509 Hours, 14.2%)
Analysis This area was rated a category 2 during the previous assessment period. Personnel errors resulting in challenges to ESF systems were noted as a weakness. The board recommended increased management attention to corretting this deficienc Surveillance attivities during this assessment period involved normal l- Tecnnical Specification surveillance, weekly and monthly, and also included a large num5er of eighteen month surveillance that were l necessary to support plant operating cycle Management oversight of surveillance programs has been evident throughout the period. Surveillance required prior to mode changes remained highly visible through scheduling meetings which were always attended by plant management. The Review of Operations Committee meetings reviewed all surveillance procedure changes prior to imple-mentation and performed these reviews in a timely manne The major eighteen month surveilknces were performed prior to August 1986 startup. Conduct of these surveillance generally was performed without difficulty; however, a number of procedural revisions were necessary during the performance of various test Procedural changes were developed, reviewed and approved in a timely manner and were not a major factor during the performance of these tests. Major testing conducted to return EDG 103 to service efter the second phase of the Colt Diesel Generator Tie-In was successfully completed without inciden Challenges to ESF equipment due to routine surveillance activities have decreased significantly since the last assessment period (down from 24 LERs in the last assessment period to 12 in this period).
The reduction can be generally attributed to increased attention to detail on the part of the technicians performing the surveillance and increased emphasii placed on quality workmanship. Challenges to equipment during performance of surveillance on Reactor Building Standby Ventilation / Control Rt,om Air Conditioning (RESV/CRAC) and Reactor Building Closed Loop Cooling Water (RBCLCW) have occurred at a relatively high rate with nine ~tERs during this period. This high number of challenges can be attributed to a number of causes; pro-cedural deficiencies, technician error, and design deficiencie While licensee awareness of this problem is apparent, progress to implement effective solutions has been slo _ _ _ _ _ _ _ _ - - _
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Overall surveillance program activities have been conducted in an effective manner. Quality Assurance activities in support of sur-veillance has been extensive, including program review, direct obser-vation of work and results review. The containment integrated leak rate test was highly successful, passing in the as-found conaitio Generally, the surveillance program is highly successful. However, the licensee failure to promptly correct identified problems in specific areas such as RBSV/CRAC and RSCLCW cor.tinues to be a weaknes Rating:. Category 2
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21 Engineering and Corporate Technical Support (186 Hours, 5.2'4)
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This area has not been rated in previous assessments. During this i assessment period the inspectors revieweo the plant modification and {
design change process and assessed the quality of engineering support for plant operations, maintenance, QA and trainin Licensee management is dedicated to maintaining timely and effective engineering support. The Nuclear Engineering Department (NED) report-ing directly to the Vice Dresident, Nuclear Operation is responsible for providing technical ano engineering support as requestea foe all aspects of the nuclear plant. NED responsibilities are clearly estao-11shed in the department procedure NED is located at the facility which enhances communications and coordination with plart staf The Nuclear Engineering Department staffing is almost at full comple-ment with an everage nuclear experience of 9.6 years. The licensee is actively recruiting qualified personnel to fill existing vacan-cie The licensee maintains a pool of dedicated engineering per-sonnel to assist Shoreham site at the Office of Engineering at Melville, New York and at its Architect-Engineer. Additionally, six NED engineers are on call to provide around-the-clock coverage at the plant. These on-call engineers provided good support coverage during the plant evolutions and transients. Thus, the licensee management has provided a complement of well qualified and trained engineers to provide timely and effective support to tne plan To ensure continued high level of engineering support to the plant, the licensee committed in the USAR to implement an Interim Station Modification Program using the Services of the Architect-Engineer (A/E). This program has been implemented effectively and will con-tinue through the first refueling outag During the Interim Pro-gram, the A/E retains verification authority for safety related design, maintains the design bases for the facility and provides assistance for engineering support to the plan The licensee has developed a Technology Transfer Program to assure effective transfer of engineering and design responsibility from the A/E. This program is well on its way to completion. Towards the end
_of this SALP period about one third of the Work Packages and one fourth of the documents were transferred. Engineering personnel have been hired and trained and implementing procedures were being writ-te Tne licensee was independently performing about fifty percent of the fa~cility design changes. This is another example of licensee management support to engineering activities at the sit _ _ _ _ - _ _ - _ _ _ _ - _
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An . effective use of probabilistic risk assessment (PRA) techniques was evident at the site. The licensee recognized the importance of PRA in. the design process and initiated a study in 1981. The engi-neering insights gained from the use of PRA have already been applied to emergency procedure development, training, containment design and detailed system design. PRA techniques were used to support licen-see's request to the NRC dated April 14, 1987 for authorization to increase power to 25% at the station, to independently verify the results of the Independent Plant Evaluation (IPE), and to analyze the performance of the licensee's supplemental containment design. PRA techniques were effectively used to justify (1) the use of 90%
i enriched Boron-10 in the Standby Liquid Co_ntrol System, (2) raising
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- others. A good understanding of PRA application in design was evident among engineering, maintenance and operating personnel. The recom-mendations resulting from PRA were implemented, with good management and staff support.
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Division (EA). EA manors routinely the work performed under the I Interim Station Modification Program, work performed to support such l license related activities as plant Technical Specification related
, set point development, license prueedings, 10 CFR 50.59 safety l- evaluations, 10 CFR 21 evaluations, equipment qualificaticas, fire protection, security and emergency planning.
! A sati sf actory assess. tent by EA is required before any division I assumes design responsibility from the A/E. EA's assessments appear l effective in identifying problem areas and corrective actions. EA's assessment of the Instrument and Control Section's readiness to assume design responsibility identified a lack of clear interfaces with other organizations, absence of a permanent section head, and a lar.k of backup engineers. In another assessmert of the Engineering Mechanics Section's readiness to assume design responsibility, EA identified that the concern of cenbustion in the off gas system was not discussed by the A/E. The satisfactory solution to these problems has demonstrated EA's effectiveness. The licensee has established a Reliability Group within the QA Department which is functioning effectively. For example, reliability analyses were developed for the Low Pressure Coolant Irtjection System, Reactor Water Cleanup System, Control Rod Drive System, and the Standby Liquid Control System. The reports were well received by the organizations requesting the stud _ _ _ _ - _ _ _ _ _ _ - _ _ - _ _ _ _ - _ _ _ - - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
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The licensee has established the Independent Safety Engineering Group (ISEG) required by' Technical Specifications, as a dedicated full time organization within the QA organization. The ISEG is staffed . with qualified personnel. This dedicated staff may be augmented, on an as needed basis, by borrowing personnel from other licensee organiza-tions or contractors. The ISEG routinely examines plant operating characteristics and industry and NRC issues. ISEG evaluations of HPCI check valve failures, response time of scram instrument volume level detectors, Radution Monitoring System, and isnproper installation of heat shrinkable tubing were well planned with clear statements of purpose and work scope. The final reports contained details of the methodology, a discussion of the concern and available solutions, good discussions of the findings, conclusions, and observation Specific recommendations were also provided in the report when appro-priate. Open items resulting from the ISEG reviews are tracked by the group to closure. The ISEG is functioning effectively in accord-ance with its charter and the Technical Specification requirement During this assessment period problems were. identified in the follow up actions for NRC Information Notice 86-03 to address concerns regarding Limitorque P.otor Operated Valves, These actions were slow and not geared to identify all deficiencie As noted in section D of this assessment, procedural and design deficiencies have con-tributed to repeated ESF actuations during surveillance. Although l
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the frequency of these actuations has decreased during this assess-ment period, they continue to occur. Further, these types of actua-tions will .likely persist until system hardware modifications are completed. Engineering evaluation required to implement these modif-ications has been slow. Additionally, an erroneous assumption incor-porated into a modification procedure resulted in an isolation of the Station Reserve Transformer and a loss of offsite powe In summary, the licensee has established a strong engineering support organization to provide effective support to site organizations. The Interim Station Modification Program is functioning well as evidenced by the support from operations, maintenance, QA, training and other site organizations. Communications and interactions with plant staff have been effective. The quality and timeliness of designs and engi-neering support are steadily improving; however, improvement effori;s should be concentrated in this area. Continued licensee attention is required to assure effective engineering support during full power operation of the facilit i l
Rating: Category 2 l
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During the previous assessnIf period *he licensee performance in
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this area was rated Categor91 (consistent), based upon performance during the first annual exercise, and a high degree of management involvement in emergency preparedness as evidenced by responsiveness to identifying and correcting program deficiencies., and in response to actual emergencie During the current assessment period, two routine safety inspections we-re conducted, and changde to emergency plans and procedures were reviewed. .The two routine safety inspections performed in February anc June, 1987, related to new emergency response facilities and follow up of corrective actions takin as a result of previous inspec-tions ano' n:sintenance of the emergeacy preparedness progra During the assessment period, the licensee completed the construction of an E'nergency Operations Facility (EOF) and Eraergency News Center (ENC). These facilities are large, well eculpped, anc' designed to enhance the effectiveness of personnel util'fzing the '
The licensee has been responsive to NRC initiatives as evidenced by the training of all Watch Supervisors in the duties of Emergency Directo The drill program tests each emergency team every quarte Additionally, the drill and training program is structured to enhar.ce personnel effectiveness during different types of events, such 6s sabotage or other security events and events that develop quickly, y and to test the on shif t operatirg crews prior to activation of the emergency responsa faciliti9 )
The licensee has reacted quickly and correctly to several events dur" ing the assessment period, most Mtab1) threats against the statio ;
Assessment actions, notifications, and communication have been pro-per and torservative. Actions taken were with due rugard to safet l R%blems encountered were analyzed and prompt corrective actions )
taken to prevent recurrence. During the Loss of Offsite Power event,
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not'fications were found to be itss timely Nban during previous event Although the licensee completed these/ notifications within the required time, corrective actions were impleme.rt E io improve the notification process following complex plant t ransicnt This ,
demonstrates a continued commitment on the part of the licensee to ' !
sel f-a s ses s its potential faults and impiement cerr+ctive actions without regulatory prompting, s i
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sf Insombry,$helicenseecontinuestoexhibitthequalitiesnecessary to ensure excellence in their emerge'ncy preparedness program. Train-ing of all levels of personnel is extensive. Programs and facilities
- are continually analyzed: and upgraded as appropriate to maintain a high level of preparedness. It is evident that the high degree of management atten tion and commitment to emergency preparedness' has resulted in a high degret of performance 'in all areas of the onsite organizpio Rating: Cateaory 1 s
While the emergency preparedness area was rated Category I, . NRC insor.ction efforts will not be reduced in this area due to the uniqu6 licensing status of Shorehaih
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g Security'and Safeguards (104 Hours, 2.9*4)
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[' Analysis During the previous SALP period, the licensee was found to be imple-menting an effective program and received a Category 1 rating. Spec-
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, if f.c strengths were identified by audits and self appraisals that
)resulted in improvements and enhancements, prompt .and effective response to events, and an effective training program. A minor prob-leg. with clerical support for the program was identified. No viola-
,tions wers identifie D/ ring the. current assessment ~ period, three unannounced ' routine
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physical secur.ity program inspections were performed by region based
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) inspector Routine inspections were conducted throughout the essessment period. One Severity Level IV violation was identifie The violation was-not indicative of programmatic problem The licensee's involvement in support for and oversight of the security program remained evident. and resulted in highly effective
,. program implementation. Management oversight of the contract secur-ity force provided the licensee with the necessary and current know-ledge of program implementation -to preclude significant problem The licensee continued to utilize its audit and appraisal programs to indicate areas where changes would benefit program implementatio e Program improvements and enhancements are evident in systems opera-tions and reliability, testing and maintenance, and facilitie The licensee initiated the inclusion of safeguards contingency events in its emergency preparedness exercises in December 1986. h a such exercises have been conducted since, requiring the active participa-tion of both the security and the operations organizations for their execution and successful completio The licensee found those exercises very effective in surfacing organizational interface prob-lems that had previously been overlooke The licensee is also active in industry organizations formed to enhance nuclear power
, plant security and to discuss issues of mutual interes These initiatives are evidence of the licensee's interest in developing and maintaining an effective security progra Program implementing procedures and instructions were updated and l iiproved, as necessary, to provide the security force with current, i clear and concise directions in carrying out its duties. The effec-l tiveness of the procedures and instructions, and also the training l program, which is administered by the security force contractor, is I
apparent by the relatively small number of personnel errors identi-fied during the perio ,
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Both the licensee's and the contractor's staffing levels for the pro-gram are appropriate to ensure proper program implementation. The l minor problem with clerical support, which was identified in the pre-l vious assessment period, has been . corrected. All members of the
. security organization appear to be well qualified and exhibit high
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l morale and a professional demeanor. Additionally, the turnover rate in the force is relatively low, which is indicative of a well run l organization and job satisfactio There were five events that required reporting in accordance with 10 CFR 73.71 during the ' assessment period. Three of the events involved bomb threats, one event involved a computer failure, and one involved the degradation of a vital area barrier. The response by the security force to each of the events was prompt and appropriate for the circumstances, indicating a well disciplined and knowledge-able organization and an effective program. The event reports sub-mitted to the NRC were clear, concise and adequate for NRC analysi The quality of the event reports is indicative of thorough management revie Three incidents involving security guards sleeping on duty occurred late in the assessment period. The licensee aggressively implemented corrective actions to prevent future occurences. These included new disciplinary rules along with staffing changes intended to enhance the first-line supervision of the security guard forc During the assessment period, the licensee submitted four revisions to the Securi ty Plan under the provisions of 10 CFR 50.54(p) and provided its response to the August 4,1986 Miscellaneous Amendments to 10 CFR 73.55 codified by the NRC. The plan changes were of high quality and indicative of management's continuing oversight of the program to ensure it is consistent with NRC performance objectives and to achieve consistency. Security personnel involved in maintain-ing plans current and consistent with NRC objectives are knowledge-able of NRC requirement In summary, the licensee has sustained a high level of performance ;
during this assessment period. Minor problems occurred, but were '
promptly corrected effective with actions to prevent recurrence. It is evident by this performance that the licensee is determined to implement and maintain a high quality security progra Rating: Category 1 While the security area was graded as Category I, the inspection effort will not be reduced in this area due to the unique licensing status of Shoreham.
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., : 4 28 Training and Qualification Effectiveness (586 Hours,16.5%)
Analysis The various aspects of this functional area have been considered and discussed as an integral part of the other functional areas and the respective inspection hours have been included in each one. Conse-quently, this discussion is a synopsis of the assessments related to training conducted in other areas. Training effectiveness has been measured primarily by the observed performance of licensee personnel and, to a lesser degree, as a review of program adequacy A special team inspection to evaluate training and qualification programs was completed late in the assessment period. This discussion addresses three principal areas: licensed operator training, non-licensed staff training, and the status of INP0 training accreditatio During the previous assessment period, training and qualification effectiveness was considered as a separate functional area for the first time and rated Category 3. The previous assessment was highly critical of the licensee's training program in the area on non-licensed personnel training, and direct management attentien to improve this arca was recommended by the Board. The current assess-ment is based on resident and specialist inspector observations, as well as two specific inspections into the training are Initiatives by the-licensee to improve training effectiveness within this assessment period were extensive. Weaknesses identified in the previous assessment period have been largely addressed as the forma-tion of the Office of Training has evolved, Record keeping defici-encies have been corrected, formal training for non-licensed person-nel is now conducted primarily by Office of Training staff, and the reliance on plant staff for training activities other than on the job training has been greatly reduced. The development and implementation of forrra l , structured training courses for Chemistry Technicians, Health Physics Technician and non-licensed operators has been com-pleted and appears to be effectiv Efforts to increase staffing levels within the Office of Training have generally been successful, plant staff department head involve-ment in training plan development and implementation is very good and overall program implementation is now uniform in all facility division Completion af the corporate training center and procurement of a plant specific simulator were both accomplished during this assess-ment period and are indicative of corporate commitment to a quality training program. Completion of the transfer of training records onto a computer tracking system will enhance the quality and availability of those record _ _ _ _ _ _ _ _ _ _ _ -
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The number of reportable events attributed to personnel error is down significantly when compared to the previous assessment period, espec- 3 ially'in the operations, maintenance, and surveillance area This reduction may be attributed to increased management attention an increased training effectiveness. Improvement in the performance of Control Room personnel can be attributed to an effective requalifica-tion training program which stresses " lessons learned" from previous l event Use of the Quality Assurance department to monitor training has been particularly effective in identifying problems and effecting change Training of auditors and inspectors from the QA/QC department was extensive and has been particularly effectiv The increased level of knowledge in the QA department has led to an increased number of technically significant findings and better acceptance of QA findings by plant staf During this assessment period the NRC administered one set of license examinations with five candidates participating in the R0 exam and five candidates participating in the SRO exam. All candidates were successful in their attempts and were especially proficient in the use of plant drawings and Technical Specification The success of the plant staff in this area indicates that the licensed operator training program is performing wel INPO accreditation of Shoreham training programs continued through the assessment period. Development and implementation of training programs are in varying stages of completion. The licensee has sub-mitted, and INPD has accepted, Self Evaluation Reports (SER) for several of the training programs. An INP0 Accreditation Team Visit is scheduled early in the next assessment period (October 26 - 30, 1987).
In summary, senior management involvement in resolving training deficiencies identified in the previous assessment period have yielded positive results. Training programs appear to be effectively implemented at all levels and positive results can be seen in the reduced number of LERs and personnel errors. Full implementation of all training programs is still in a transitional status. A,s such, an accurate assessment of the effectiveness of these' programs cannot be made until this transitional period is complete. The commitment to quality training on the part of senior management should continue to provide improved staff performanc j Rating: Category 2, Improving
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30- Licensing Analysis For the previous assessments period, this area was rated Category It was noted that the licensee's analysis accompanying its requests for license amendments were perfunctory and with a minimal amount of bases. It was also noted that the licensee's responsiveness was slow on issues not on the critical path for full power licensin Those concerns were attributed to two fundamental cause Fi rs t , the licensee had an overly cautious attitude about formal submittals to the NRC because of the atmosphere of litigation that surrounds this project. A second cause appeared to be understaffing in the licen-see's licensing organization. Since the beginning of this evaluation period, the licensee has taken aggressive actions for improvemen Although the atmosphere of litigation has not abated, the corrective actions taken by the licensee's senior management produced notable improvements in tho area of licensing activitie During this SALP evaluation period, the licensee performed two rounds of low power testing. The reactor was critical for a total period of about seven weeks. Except for issues related to emergency planning, all pre-full power licensing issues have been resolved. During this period, two important issues; compliance with Appendix R and the Anticipated Transient Without Scram Rule were reviewed and approved by the NRC. On April 14, 1987, the licensee submitted a request before the Commission for authorization to operate Shoreham at 25%
powe The request was accompanied by an extensive analysis on severe accidents at 25% power level and the demands on emergency planning under those circumstance Although the .NRR technical review was subsequently suspended, the licensee's interaction with the NRR staff during the review demonstrated that its staff has significant technical capability and a thorough understanding of the Shoreham plant and its safety system Management involvement in the licensing area has been extensiv Progress in licensing activities was not inhibited by the effort necessary to support two Licensing Board hearings related to emer-gency planning contentions. The Licensing Division management met with the NRR Project Manager and technical reviewers on a regular basis to discuss the status and progress in the resolution of open licensing actions. These meetings were often attended by represent-atives from intervenor group In these meetings the discussions were open, non-inhibitive, and extremely productiv In addition, .
the licensee's Licensing Division issued weekly summa'ry reports and !
held scheduled weekly briefings with the licensee's technical depart-ment managers. This close coordination enabled the licensee to sub- ,
stantially improve the quality of analysis that accompanied the sub- I mittals for licensing actions. In general, these submittals were timely, thorough and of high technical qualit _
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The licensee's responses to address safety issues continued to be technically sound. During this SALP evaluation period, the NRR staff completed its review of the outstanding fire protection issues re-lated to the control of the Automatic Depressurization System and the controls of high-low pressure systems interfaces in the event of a severe fire in the Control Roo The approach by the licensee to resolve these issues showed a clear understanding of the plant sys-tems and the analyses were realistic and yet allowed for substantial safety margins to exis There were, however, some cases where the licensee's initial submittals appeared to be superficial and required additional information to enable the NRC staff to complete their review. Two of those cases were issues related to quantification of post-accident effluents and the surveillance requirements of the Reactor Coolant System Leakage Detection Systems. However, it should be noted that those two issues were initiated prior to this SALP evaluation period and do not fully reflect the recent efforts for improvement The licensee made good progress in responding to NRC initiated ac-tions. The much improved capability of the Standby Liquid Control
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System, the change of the Main System Isolation Valve set point and the improved reliability of Alternate Rod Insertion are some examples of these accomplishments. In . addition, the licensee has initiated the conceptual design of a filtered containment vent for enhancement of containment integrity in the event of a severe accident. The staff's initiatives for containment enhancement were primarily directed at Mark I containments and the licensee recognizes that a number of areas the staff has suggested for possible improvements were already satisfied by the Shoreham Mark II containment configura-tio The licensee's commitment to this major effort demonstrates its willingness to exceed the minimum regulatory requirement in responding to NRC's initiatives to enhance safet During the previous SALP evaluation period, the licensee appeared to be overly cautious in its interactions with the staff because of ongoing litigations; this resulted in ambiguities and delays. The licensee has since made substantial progress to be more direct and j responsiv This was demonstrated during the discussions the NRC staff had with the licensee on the analysis related to the 25% power reques During the period the licensee has increased staff to strengthen its Licensing Division staf The Licensing Division is staffed with personnel who are technically competent and knowledgeable about the Shoreham facility. The group does an outstanding job in coordinating the efforts required frorr other technical departments. As a result, licensing activities were timely and of high technical quality. Con-sidering the increased workload for the 25% power request and the licensee's ability to cope with it, it appears that the Licensing Division is adequately staffed for operations exceeding the present 5% power level.
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In summary, the licensee has made substantial improvement in licen-sing activitie This resulted from a number of factors; intense involvement by the management, strengths in its technical capability, effectiveness of its licensing group and improvements in its training program Rating: Category 1 I
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33 Assurance of Quality Analysis i
h Management involvement and control in assuring quality was initially considered as a separate functional area in the previous SALP, in addition to being one of the evaluation criteria in the other func- J tional areas. The various aspects of Quality Assurance program re-quirements have been considered and discussed as an integral part of each functional area and the respective inspection hours are included in each area. This discussion is therefore a synopsis of the assess-ments relating to quality work conducted in all areas but it is not solely an assessment of the QA/QC Division. The previous SALP Assess-ment rating in this area was a Category 2 with a declining trend. A declining trend in this functional area can be a precursor to an overall decline in plant performance and therefore places additional emphasis on NRC assessment ef forts in this area. In assessing how the licensee assures quality, the attributes considered are implementa-tion of management goals, planning and control of routine activities, worker enthusiasm and attitudes, management involvement, sta f fing, training, and the use of QA/QC as a management too Throughout this assessment period, there has been evidence that the work in the facility was performed to high quality standards at the operator-technician-mechanic level. This high quality work can be directly attributed to a positive attituoe on the part of the first-line personnel, the quality of training they have received, a strong QC presence at the individual job level and increased management involvement and presence in the day-to-day activities of the plan Quality Assurance involvement in plant activities has been extensive throughout this assessment. The coverage typically consists of hold points on all safety related work requests, and physical coverage is i given to items such as terminations, closure of mechanical components )
and paperwork reviews. In addition to safety related coverage, a j greater percentage of important nonsafety related items are receiving i QA/QC coverage. The QA/QC Department also conducted 46 performance j based audits during the assessment period expending 15,330 man hour !
The audits were conducted in all plant areas and audit findings were j effectively used to improve plant programs. Auditor performance has
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been enhanced by increased training initiatives by QA/QC management personnel. Training programs for QA/QC personnel were greatly expanded during this assessment period and now include simulator training and visits to other site a
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Facility response to QA and Nuclear. Review Board Audit findings and QC deficiency reports had been previously identified as an area lacking sufficient management attention. This area has received extensive senior management attention during this assessment period and, as a result, there has been a significant reduction in the number of overdue responses. Improvement in the format of the QA/QC monthly report has made it a valuable tool for plant management in assuring that responses are made by the appropriate division managers has focused additional management awareness on QA/QC findings and has improved facility response to identified problem The facility Review of Operations Committee (ROC) was convened on _179 occasions and the Nuclear Review Board (NRB) was convened on 11 occasions during this assessment period. Both have been instrumental in maintaining plant safety as a priority. Reviews of station modi-fications and procedure changes by ROC have been thorough and con-ducted with safety impact in mind. NRB commissioned 18 audits during the assessment period and the results were valuable in assessing licensee program effectivenes Development of a Quality Assurance Hotline by which employees can voice. concerns anonymot. sly to the QA division has opened another line of communication between plant staff and upper management. The hot-line surfaced one valid safety concern regarding installed mechanical jumpers which was quickly resolved by plant management. Another initiative that upper management bas taken to assure quality was the formation of an Operational Assessment Group which analyses plant performance and reports findings to the Vice President, Nuclear Operation Management actions in response to SALP comments have been extensive and timely. Tracking of commitments was a function of the Nuclear Review Board and progress toward resolution of these issues was an agenda item at every NRB meeting. This closely watched agenda insured that extensive management attention was given to noted areas of weaknes In conclusion, the quality programs in effect at Shoreham have included QA/QC, NRB and ROC committees, ISEG and effective first line supervision of all discipline Senior management involvement in improving staff awareness of the importance attention to detail in improvement of quality has yielded positive results. The overall result has been an increase in manning levels, and decreases in
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Licensee Event Reports, ESF actuations, and personnel errors.
l Rating Category 1 f While the assurance of quality area was rated as Category I, inspection efforts will not be reduced due to the unique status of
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the Shoreham facility.
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35 Supporting Data and Summaries Investigation and Allegation Review During this SALP assessment period nine allegations were received and evaluated. Two licensee employee drug use allegations were received;
- however, these allegations were unsubstantiated due in part to a lack j of cooperation 'on the part of the allegers and have been close Two allegations concerning questionable practices in' the warehousing area.were received; one of these resulted in a specialist inspection which discovered no instances of noncot:pliance with NRC requirements and has been closed: the other is under review at this time and remains ope Three concerns alleging falsification of documents were received; two have been investigated, with no evidence of falsi-fication, and closed; one remains open while investigation continue One allegation was made in both the Radiochemistry and Training and Qualification areas, both have been evaluated, found unsubstantiated, and close During this assessment period the Office of Investigations conducted one investigation into the alleged falsification of documents by members of' the Radiochemistry Sectio These concerns were orig-inally surfaced during the previous SALP perio NRC action is pendin Escalated Enforcement Actions There was no escalated enforcement action taken during this assess-ment perio i
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C. Management Conferences NRR/ Licensee Meetings Licensing Status 08/01/86 09/04/86 10/16/86 11/25/86 01/13/87 j 02/19/87 04/22/87
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Fire Protection 10/02/86 Control Room Design Review 11/03/87 25% Power License Proposal 04/30/87 Supplemental Containment y
System Conceptual Design 07/21/87
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NRR Site Visits / Meetings Emergency Planning 05/29-06/05/86 Management Discussions 03/12/87 j
25% Power Proposal 05/12-05/13/87 1 Region I/ Licensee Meetings SALP Management Meeting 07/29/86 Review of Loss of Offsite Power Event 04/05/87
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D. ' Licensee Event Repcrts Tabolar Listing Personnel ' Error 16 Design Management 12 External 5 Defective Procedure ,
9 Component Failure 8 Other 10 Causal Analysis Personnel Errors There were 16 LERs generated this SALP period as a result of personnel errors. This number is a significant improvement over the previous assessment period when 32 LERs resulted from per-sonnel error. Of the 16 personnel errors,12 resulted in chal-lenges to ESF Systems. The ESF system challenge number is mis-leading in that over half of those challenges occurred during the performance of work on two systems: Reactor Building Standby Ventilation / Control Room Air Conditioning and Reactor Building Closed Loop Cooling Water. There does not appear to be a common factor which has resulted in the large number of LERs associated with these two systems, but rather a number of fac-tors appear to contribut Surveillance procedures in these areas are quite complex and require numerous lif ted leads and jumpers, access to terminal strips and relays are frequently in areas of limited visibility and accessibility and both systems are highly sensitiv Radiochemistry and Fire Protection
)
During this assessment period there were 6 LERs generated as a result of Radiochemistry problems. The majority of these LERs l'
resulted from personnel error, however, it is important to note that no LERs have occurred in this area since the last quarter j of 198 Six LERs can be directly attributed to the Fire Pro-tection activities and, in all cases, directly involved the inability to meet Technical Specification fire watch requirement j l
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i 38 Overall Analysis The number of LERs in this assessment period, 54, appears on the surf ace to be indicative of some performance problems, however, assessment of the types and frequency of LERs indicates other-wise. There has been a steady decline in the number of LERs per quarter since the last assessment period. There has also been a significant decrease in LERs when compared to the last rating period: 58 in 12 months for 85-98 ve sus 54 in 17 months for 86-99. Although there were 54 LERs in assessment period 86-99, 28 of those can be lumped into three discrete areas. Activities on Reactor Building Standby Ventilation System / Control Room Air Conditioning and Reactor Building Closed Loop . Cooling Water accounted for 14 LERs, Chemistry LERs totalled 8 and Fire Protection related LERs totalled The licensee is aware of these problem areas and is attempting to reduce the numbers of LERs by correcting root causes. The licensee has generally addressed the problems associated with activities on the above mentioned system No LER's have occurred in the radiochemistry area since the last quarter of 1986. This decrease in LERs can be directly attributed to the aggressive program that was undertaken by licensee management to improve the Radiochemistry program after the last assessment rating of Category The licensee is also making efforts at this time to reduce the. number of required firewatches, which should in turn reduce the number of LERS in the fire protection area. Licensee awareness and activities in these areas have significantly reduced the number of LER's i r> the last six month l
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i Licensing Actions License Amendments Issue:.
Amendment N Title Date 2 Noble Gas Monitoring 03/04/86 3 Process Control Program, 11/03/87 Radwaste Management 4 Radwaste Sampling and 12/09/86 Milk Samples 5 Main Steam Isolation 05/04/87 Valve Setpoint Changes 6 Stand-by Liquid Control 05/18/87 System
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Post Maintenance Testing'(ATWS 3.1.3, 3.2.3) 04/09/86
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Analysis of Post Accident Radio-Chemistry Samples 05/20/86
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Qualifications of Backup STAS -05/07/86 12/09/86
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Post-Accident Effluents Monitoring 02/13/87
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Appendix R Compliance 02/25/87
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ATWS Rule Compliance 06/08/87 Orders Issued Numerous Commission Oraers related to EP Proceedings l
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TABLE 1 LISTING OF LERs BY FUNCTIONAL AREA CAUSE CODES AREA A B C D E X TOTAL
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OPERATIONS 4 2 1 1 1 9 RAD PROTECTIO MAINTENANCE 3 1 3 7 SURVEILLANCE 4 5 4 2 1 16 EMERGENCY PRE SECURITY / SAFEGUARDS 1 1 2 OUTAGES 1 2 3 TRAINING LICENSING 1 1 2
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QUALITY ASSURANCE TECHNICAL SUPPORT 2 1 3 6 FIRE PROTECTION-HK 2 2 1 2 7 OTHER 1 1 2
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TOTALS: 16 12 5 9 8 10 60 Cause Codes *: A - Personnel Error B - Design, Manufacturing, Construction or Installation Error C - External Cause D - Defective Procedure E - Component Failure X - Other
- Cause Codes in this table are based on inspector evaluations and msy differ from those specified by the licensee in the LER I
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., s Table 1 T1-2 LER SYNOPSIS
[ LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION l
l
'86-011 03/18/86 C ULTIMATE HEAT SINK, ACCUMULATION OF SEDIMENT 86-012 03/03/86 D FAILURE TO MEET ACTION STATEMENT FOR LOSS OF CONTINUQUS MONITORING OF THE STATION VENTILATION EXHAUST DU'E TO POWER LOSS TO SAMPLE PUMP 86-013 03/05/86 A CONTINUOUS FIRE WATCH IN RELAY ROOM NOT MET DUE TO FIRE WATCH PERSON BEING ASLEEP 86-014 03/05/86 B FULL REACTOR LOW LEVEL TRIP WHILE I&C TECHNICIAN WAS VALVING IN PRESSURE TRANSMITTE /10/86 X CONTINU0ltS FIRE WAT.CH MISSED DUE TO FIRE WATCH BEING STUCK IN ELEVATOR 86-016 03/04/86 X SEISMIC MCNITORING RECORDERS IN CONTROL BUILDING OUT OF SERVICE FOR MORE THAN 30 DAY /20/S6 0 SEALED SOURCE LEAK TEST NOT PERFORMED IN ACCORDANCE WifH TECH SPEC DUE TO PROCEDUkAL DEFICIENC /10/86 A UNMONITORED DISCHARGE OF NON-RAD 10 ACTIVE WATER (LESS THAN MINIMUM DETECTABLE ACl!VITY) FROM THE CONDENSATE STORACE TANK SUM /09/86 0 PROCEDURAL DEFICIENCY RESULTED IN A RBSVS/CRAC "A" INITIATION DUE TO LOW REAC10R BUILDING DIFFERENTIAL PRESSUR /12/86 A FULL REACTOR TRIP DURING AN
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OPERATIONS SURVEILLANCE TEST RESULTING FROM PERSONNEL ERRO /12/86 B FULL RPS ACTUATION WHILE I&C TECHNICIANS WERE VALVING IN A LEVEL TRANSMITTER AFTER A SURVEILLANCE TES _ _ _ _ - _ _ _ _ _ _
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I Table I TI-3 W
I LER NUMSER EVENT DATE CAUSE CODE DESCRIPTION
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86-022 05/15/86 A FAILURE TO RETAIN PARTICULATE FILTERS FROM THE STATION VENTILATION EXHAUST MONITOR DUE TO PERSONNEL ERRO /20/86 A MISSED NOBLE GAS GRAB SAMPLES REQUIRED BY ACTION STATEMENT 120 0F TECH. SPE .3.7.11 DUE TO PERSONNEL ERROR
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56-024 05/22/86 A RBCLCW "A" SIDE ISOLATION WHILE I&C TECHNICIANS WERE PERFORMING A SURVEILLANCE TES /11/86 A NOBLE GAS SAMPLES REQUIRED BY ACTION STATEMENT 120 GF TECH. SPEC.3.3.7.11 WERE DISCARDED PRIOR TO BEING ANALYZED FOR GROSS ACTIVITY.
'86-026 07/03/86 A UNPLANNED AUTCMATIC IhlTIATION OF RBSVS "A" TRAIN DdRING AN I&C SURVEILLANCE PROCEDURE'WHEN A TECHNICIAN DROPPED A SCREWDRIVER IN PANE /15/85 E REACTOR POWER EXCURSIONS AB0VE 5% DUE TO FAILURE OF MECHANICAL LINKAGE BETWEEN POSITION FEEDBACK ARM AND CONTROLLER ON STARTUP LEVEL CON /10/85 B NON ENVIRONMENTALLY QUALIFIED JUMPER WIRE INSTALLED IN MOTOR OPERATED VALVES86-029 07/18/86 X ESF ACTUATIONS DUE TO EPA BREAKER TRIPS WHILE RPd POWER WAS BEING SUPPLIED BY THE ALTERNATE FEED TRANSFORME /27/86 C UNPLANNED AUTOMATIC ACTUATIONS OF ESF SYSTEMS CAUSED BY POWER SPIKES ON THE GRID VOLTAGE DUE TO THUNDERSTORM /16/86 X SEISMIC MONITORING RECORDERS IN CONTROL BUILDING OUT OF SERVICE FOR MORE THAN 30 DAYS.
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Table 1 T1-4 ,
LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION
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86-032 07/28/86 X UNEXPLAINED RWCU ISOLATION WHILE PLACING THE FILTER DEMINERALIZERS IN OPERATIO /06/86 D EDG 101 MANUALLY $ HUT DOWN DURING SURVEILLANCE TEST DUE TO HIGH LUBE DIL TEMPERATUR /11/86 X REACTOR WATER LEVEL INSTRUMENT PROVIDING ERRONE0US LEVEL INDICATION DUE TO IMPROPER CALIBRATIO /28/86 A RWCU ISOLATION DURING AN I&C SURVEILLANCE TEST DUE TO TECHNICIAN ERRO /05/86 0 VIOLATION OF TECH. SPEC. 3.4.3.1 DUE TO THE HEAT TRACING TO PRIMARY CONTAINMENT LEAKAGE DETECTION RADIATION MONITORING PANEL TURNED OF /08/86 E MISSED CONTINUDUS FIRE WATCH IN RELAY ROOM REQUIRED BY TECH. SPEC. 3.7. DUE TO CO2 INJECTION IN THE NORMAL SWITCHGEAR ROOM,86-038 10/04/66 B RBSVS "A" SIDE INITIATION DURING AN I&C SURVEILLANCE PROCEDURE WHEN A i TECHNICIAN ACCIDENTALLY BRUSHED A RELAY f WITH A LIFTED LEA j 86-039 10/06/86 A RBSVS "B" SIDE INITIATION WHILE PERFORMING MAINTENANCE ON THE VALVE d ACTUATOR FOR THE RBNVS SYSTEM INTAKE VALV /07/86 E NSSSS INITIATION OF RBSVS/CRAC DURIk3 I&C SURVEILLANCE DUE TO FAULTY RELAY SOCKE ]
86-041 10/29/86 A UNCONTROLLED ACCESS TO THE PRIMARY CONTAINMENT OCCURtlED FOR APPROXIMATELY TWO HOURS DUE TO THE HATCH NOT BEING PROPERLY SECURED.
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.. .i-Table 1 TI-5 LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION
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86-042 10/09/86 0 FAILURE TO SUBMIT A COPY OF SHOREHAM NUCLEAR POWER STATION'S SPDES RENEWAL APPLICATION TO THE NRC AT THE TIME OF SUBMITTAL TO THE NYDE /10/86 E FMERGENCY DIESEL GENERATOR 103 FAILURE REACH RATED SPEED DUE TO P00R GOVERNOR OIL QUALITY 86-044 10/11/86 B NSSSS INITIATION OF RBSVS/CRAC "B" SIDE DUE TO WIRE SLIPPING OUT OF I&C-TECHNICIANS HANDS DURING A SURVEILLANC /27/36 A RBSYS/CRAC INITIATION WITH A 1/2 RPS ACTUATION DUE TO PERSONNEL ERROR WHILE AN EQUIPMENT OPERATOR REPLACIN RADIATION MONITOR SUPPLY BUL /21/86 B INADEQUATE BACKFLOW PROTECTION IDENTIFIED FOR EDG. ROOMS 101 AND 10 /13/87 A RBSVS INITIATION CAUSED BY I&C TECHNICIAN DURING SURVEILLANCE TES '87-002 01/13/87 0 SEISMIC MONITORING INSTRUMENTATION IN CONTROL AND REACTOR BUILDING OUT OF SERVICE FbR MORE THAN 30 DAY /18/87 D LOSS OF 0FFSITE POWER OCCURRED DUE TO A PROCEDURAL INADEQUACY IN A MODIFICATION WHICH CAUSED THE ISOLATION OF THE STATION SERVICE TRAN /02/87 C FIRE WATCHES REQUIRED BY TECH SP( WERE SUSPENDED IN THE REACTOR SUILDING DUE TO BOMB THREA /06/87 E METEOROLOGICAL AIR TEMPERATURE MONITOR 1kG INSTRUMENTATION INOPERABLE FOR MDRE THAN 7 DAY _ _ _ _ _ - _ _ _ - _ - _
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LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION
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87-006 04/10/87 A CONTINUOUS RELAY ROOM FIRE WATCH NOT MET DUE TO FIRE WATCH PERSON BEING ASLEEP 87-007 04/25/87 C BOMB THREAT 87-008 04/14/87 B SHUTDOWN COOLING PARTIAL ISOLATION DUE TO ISOLATION OF PRESSURE SWITC /27/87 X FULL RPS ACTUATOR WHILE AND I&C TECH WAS VALVING IN A LEVEL TRANSMITTER TO THE REFERENCE LEG AFTER MAINTENANCE HAD BEEN PERFORMED ON I /10/87 E VOLUNTARY REPORT ON FAILURE OF RHR CIRCUIT BREAKE /27/87 X LOSS OF POWER TO "A" RPS BUS DUE TO SPURICUS TRIPPING OF EPA BREAKER RESULTING IN ESF ACTUATION /04/87 X RBCLCW UNPLANNED AUTOMATIC SYSTEM-SPLIT WHILE INSTRUMENT &
CONTROLS TECHNICIANS WERE PERFORMING A SURVEILLANCE TES /05/87 A SHUTOOWN COOLING ISOLATION DUE TO HIGH REACTOR PRESSURE RESULTING FROM OPERATOR ERRO /07/87 A ESF ACTUATION DUE TO PERSONNEL ERROR:
RBSW SY3 TEM-SPLIT AND A START SIGNAL TO EDG 10 /15/87 8 CRAC "B" INITIATION SIGNAL RECEIVED CAUSED BY LOW REACT 0ft BUILDING DIFFERENTIAL PRESSUR /21/87 X UNSEALED HOLE THROUGH THE CONTROL BUILDING EXTERIOR WAL B REACTOR WATER CLEANUP ISOLATION ON A HIGH DIFFERENTIAL FLOW SIGNAL DURING NORMAL STATION STARTUP I
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, t Table 1 T1-7 LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION
.......... .......... .......... ...........87-018 06-29-87 E FAILURE OF SECURITY COMPUTER RESULTED IN A MODERATE LOSS OF SECURITY-EFFECTIVENESS WHICH'WAS NOT PROPERLY COMPENSATED FOR 87-019 07-04-87 C CONTINUOUS RELAY ROOM FIRE WATCH REQUIRED BY TECH SPECS NOT MET DUE.TO BOMB THREAT 87-021 07-15-87 B HVAC PENETRATION DESIGN DEFICIENCIES IDENTIFIED AFTER DETAILED REVIEW OF INFO NOTICE 83-69 RESULTING IN LICENSE VIOLATION 87-022 06-04-87 E VOLUNTARY REPORT ON MOV DYNAMIC TESTING FAILURE OF THE HPCI
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RECIRCULATION VALVES87-023 07-17-87 B RBCLCW SPLIT DUE TO A LOW "A" HEAD TANK WATER LEVEL 87-024 07/24/87 D I&C TECH SPEC SURVEILLANCE CALIBRATION AND RESPONSE TIME PROCEDURES FOUND TO NOT ADEQUATELY SATISFY TECH SPECS DURING PERIODIC REVIEW 87-025 07/25/87 X HOURLY FIRE WATCH PATROLS REQUIRED BY THE FIRE PROTECTION PROGRAM WERE NOT MET DUE TO PERSONNEL INJURY I
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TABLE 2 INSPECTION HOUR SUMMARY ( AREA HOURS % OF. TIME OPERATIONS 1144 3 RAD PROTECTION 299 MAINTENANCE 528 1 SURVEILLANCE 509 14,2 EMERGENCY PRE .3 SECURITY / SAFEGUARDS 104 TRAINING 586 1 LICENSING 0 0 QUALITY ASSURANCE 10 TECHNICAL SUPPORT 186 FIRE PROTECTION-HX 80 .....-- ---- -----
TOTALS: 3562 10 I i
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l TABLE 3 ENFORCEMENT SUMMARY l SEVERITY LEVEL AREA 1 2 3 4 5 DEV 10TAL OPERATIONS RAD FROTECTION _
MAINTENANCE 2 2 SURVEILLANCE 1 1 EMERGENCY PREP, SECURITY /SAFECUARDS 1 1 TRAINING LICENSING QUALITY ASSURANCE
- TECHNICAL SUPPORT' 1 1
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TOTALS: 3 2 5
NRC Action on a potential violation in this area has not been completed due to the environmental qualification issues involved, I
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Table 3 T3-2
INSPECTION VIO FUNCTIONAL REPORT REQUIREMENT LEVEL AREA VIOLATION
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4 322/86-08 TECH SPEC 5 MAINTENANCE FAILURE TO PROV!DE WRITTEN l 6. INSTRUCTIONS DESCRIBING MAINTENANCE ON EMERGENCY DIESEL GENERATOR 103 1 322/87-05 TECH SPEC 4 TECHNICAL LOSS OF 0FFSITE POWER DUE l 6. '
LUPPORT TO INADEQUATE PROCEDURE REVIEW 322/87-10 TECH SPEC 4 SURVEILLANCE FAILURE TO ANALYZE SLC B-10 4.1.5. ENRICHMENT PER TECH SPEC 4.1.5. i 322/87-10 E&DCR 5 MAINTENANCE INSTALLATION OF RAYCHEM END CAPS IN VIOLATION OF E&DCR 322/87-08 SHOREHAM 4 SECURITY ,
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PHYSICAL SECURITY PLAN
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l TABLE 4 INSPECTION REPORT ACTIVITIES REPORT / DATES INSPECTOR HOURS AREAS INSPECTED
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86-07 SPECIALIST 86 ROUTINE, UNANNOUNCED, RADIOLOGICAL 05/05/86 05/09/86 CONTROLS INSPECTIO SPECIALIST 27 ROUTINE UNANNOUNCED INSPECTION OF 03/24/86 03/27/86 LICENSEE ACTIONS ON PREVIOUS INSPECTION FINDING RESIDENT 192 ROUTINE RESIDENT INSPECTIO /16/86 05/31/86 86-11 SPECIALIST 181 SPECIAL ANNOUNCEO SAFETY INSPECTION OF 07/28/86 08/01/86 THE LICENSEE'S CHEMISTRY PROGRA RESIDENT 189 ROUTINE RESIDENT INSPECTIO /01/86 07/15/86 86-13 SPECIALIST 17 UNANNOUNCED INSPECTION OF LIMITORQUE 06/30/86 07/02/86 MOTOR VALVE OPERATOR INTERNAL WIRIN i 86-14 RESIDENT 297 ROUTINE RESIDENT INSPECTIO /16/86 08/31/86 86-15 SPECIALIST 38 ROUTINE UNANN0UNCED INSPECTION OF THE 08/25/86 08/29/86 RADIATION SAFETY PROGRA RESIDENT 370 ROUTINE RESIDENT INSPECTIO /01/86 11/15/86 86-17 SPECIALIST 51 NON LICENSED STAFF TRAININ .
09/08/86 09/12/86 86-18 SPECIALIST 31 ROUTINE UNANNOUNCED INSPECTION OF 09/29/86 10/03/86 LICENSEE ACTIONS ON PREVIOUS ItlSPECTION FINDINGS j 86-19 RESIDENT 76 ROUTINE RESIDENT INSPECTION 11/16/86 12/31/86
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REPORT / DATES INSPECTOR HOURS AREAS INSPECTED
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i 86-21 SPECIALIST 72 SECURITY PLAN AND IMPLEMENTING PROCEDURES 12/08/86 12/12/86 87-01 RESIDENT 118 ROUTINE RESIDENT INSPECTION, 01/01/87 02/15/87 87-02 SPECIALIST 34 ROUTINE UNANNOUNCED INSPECTION OF i 01/17/87 01/21/87 PROCEDURE REVIE !
87-03 SPECIALIST 38 ROUTINE ANNOUNCED EMERGENCY PREPAREDNESS 02/10/87 02/12/67 INSPECTIO RESIDENT 179 ROUTINE RESIDENT INSPECTION OF PLANT 02/16/87 03/31/S7 OPERATIONS, SEC., RAD CONTROLS SURVEILLANCE / LOSS OF 0FFSITE POWER EVENT WAS REVIEWED P
87-06 SPECIALIST 96 ROUTINE SAFETY INSPECTION OF RADIOLOGICAL 03/30/87 04/03/87 CONTROL RESIDENT 69 ROUTINE RESIDENT INSPECTION 04/01/87 05/15/87 87-13 SPECIALIST 35 ROUTINE UNANNOUNCED INSPECTION OF STARTUP V6/01/87 06/05/87 TEST PROGRAM 87-14 SPECIALIST 313 SPECIAL TEAM INSFECTION OF TRAINING AND 06/22/87 06/26/87 QUALIFICATION PROGRAl1 EFFECTIVENESS / REVIEW OF SELECTED LICENSEE'S CORRECTIVE ACTION i
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t s TABLE 5i-FORCED OUTAGES AND UNFL4NNb AUTOMATIC SCRAMb i
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POWER DATE LEVEL DESCRIPTION CAUSE* & AREA *
03/05/86 $/0 Inability to vant bourbon tube Design properly prior to riacing in
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Deficiencv ;-
service "
Area: Technical Support 05/10/86 S/D During restoration of a LOCA, Personnel Error LOOP surveillance test, Area:
personnel caus4d an inadvertent Operations reacte. trip 05/12/86 S/0 Valving in a level transmitter Design due to original ~ piping Deficiency arrangement,_ technicians could Area:
not adequateiy vent the Teuhn):al transmitter Support ,
03/18/87 S/D Loss of offsite power due to Personnel Error personnel isolating station Area:
service transformer Technical Support 04/27/87 S/D Valving in a level transmitter; '
Design due to original piping, Deficiency technictan could not adequately Area:
vent tne transmitter Technical Support I
- Note - the cause attributed to these shutdowns is the NRC assessment of the cause, and may not agree with the licensee's assessmen t
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