IR 05000334/1987099

Forwards SALP Repts 50-334/87-99 & 50-412/87-99 for Period Mar 1987 - May 1988 & List of Attendees from 880831 Meeting. No Mod to SALP Rept Deemed Appropriate,Based on Util

ML20206G059
Person / Time
Site:	Beaver Valley
Issue date:	11/02/1988
From:	Russell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	Sieber J DUQUESNE LIGHT CO.
References
NUDOCS 8811220022
Download: ML20206G059 (3)

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NOV 021988

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Docket Nos. 50-334 f 50-412 i

Duquesne Light Company f ATTN: Mr. ' J. D. Sicber I

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Vice President  !

, Nuclea Group t

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Post Office Box 4  !

Shippingport, Pennsylvania 15077  !

Gentlemen:

! Subject: Systematic Assessment of Licensee Performance (SALP) Report Numbers 50-334/87-99 and 50-412/87-99 l

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This refers to the evaluation of the Beaver Valley Power Station, Units 1 and :

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2, operated by Duquesne Light Compai/ conducted by the NRC staff on !

July 15.-1988. This report, a copy of which is attached as Enclosure 1, was ;

discussed in a meeting conducted on August 31,1988, at the Duquesne Light

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Simulator Building, Shippingport, Pennsylvani l A list of attendees at the August 31, 1988 meeting is provided as Enclosure .

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Our letter of August 7,1988 (Enclosure 3) for-arded the SALP report and !

solicited your comments, particularly with respect to the functional area of ?

Training Program Your letter of September 14,1988 (Enclosure 4) provided i that response. This latter has been reviewed by the staff and, based on that l response and your comments during the August 31, 1988 meeting, no modification to the SALP report is deemed appropriate. The effectiveness of your corrective i

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actions will be assessed during our ongoing inspection and assessment programs, t

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We consider that our meetings and interchange of information have been bene- !

ficial and have improved our mutual understanding of your activities and the ;

regulatory progra !

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. No reply to this letter is required. Your cooperation is appreciate [

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Sincerely, f

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Oricinal Signed By i WILLIM

T. RUSSILL i I' William T. Russell l

, Regional Administrator l

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Enclosures:

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' 0FFICIAi, RECORD COPY LIMROTH 364 10/27/88 - 0001. \

8811220022 SC1102 ' (

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PDR ADOCK 05000334 10/28/88 f g !

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, Duquesne Light Compan '

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REGION I==

SYSTEMATIC ASSESSEENT OF LICENSEE PERFORMANCE REPORT 50-334/87-99 REPORT 50-412/87-99 DUQUESNE LIGHT COMPANY ECAVER VALLEY POWER STATION, UNITS 1 AND 2 ASSESSMENT PERIOD: Unit 1: March 16, 1937 - May 31, 19S8

'Jnit 2: March 1, 19E7 - May 31, 19ES BOARD MEETING DATE: July 15, 1983 J

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SUMMARY OF RESULTS Overview Continued overall improvement in the level of performance was demonstrated during this assessment period despite increased pressures of starting up Unit 2. The licensee successfully integrated Unit 2 into the site secur-ity plan while maintaining program quality and effectivenes Startup testing at Unit 2 was accomplished during this period in a well control-led, systematic manner with excellent interfaces between test and opera-tions personnel, in particular, the performance of the operations staffs at both units throughout this period was strong in that it was nearly error free with timely appropriate actions on several occasions that pre-vented additional plant :hallenges and trips. Continued strong perform-ance was observed in the area of Emergency preparednes A high level of management involvement in day-to-day activities was evi-dent. Weekly Unit 2 onsite meetings were attended by the Chairman of the Board through the completion of startup testing demonstrating active involvement of senior corporate managemen Further, several licensee initiatives have been effective in addressing or anticipating problem These initiatives included a task force to modify / replace the Unit 2 MSIVs, a task force to address Unit 2 recirculation spray system heat ex-changers' fouling, and the Unit 2 self assesseent during startup testin In addition, a program to conduct safety system functional evaluations (SSFE's) was initiated on Unit 1. The Auxiliary Feedwater System SSFE was completed and the preliminary results were reviewed near the end of the perio Notwithstanding the generally strong overall performance, some areas where improvements are needed were evident. More management attention to the ALARA program including increased staffing has the potential to reduce exposure for major tasks in high radiation fields. Also, better configur-ation control during high activity periods and improvements in post-main-tenance testing are needed in order to achieve consistent high performance levels. Procedural deficiencies and weaknesses were noted in several areas and represent a generic problem. They contributed to a reactor trip, inadvertent ESF actuations and failures to return systems to the proper alignment following surveillances. Numerou.- deficiencies and inconsistencies including human frctors deficiencies were evident in emergency operating procedures. Finally, performance of candidates in operator requalification examinations administered by NRC represented a significant weakness during this perio Overall, although there were some noted wtaknesses that require prompt Itcensee management attention, the performance of both units was con-sidered good. Performance is especially noteworthy given the stress pre-sented to the licensee by the completion of startup activities for Unit The programs in place have set the stage for continued improvement in the overall operation of the facilit _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

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B, Facility Performance Analysis Sur. mary Last Period This ,

Functional Area Unit 1 Unit 2 Period Trend '

Plant Operations 2 -

Radiological Controls 2 -

2 t Maintenance 2 -

Surveillance 2 -

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Emergency Preparedness 1

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Security 1 -

Engineering / Technical Support 2 -

Safety Assessment / Quality Verification 2 2 2 Preoperational and Startup Testing -

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Training Programs - -

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The following were not treated as separate functional areas in this l assessmen Relevant insights have been included in the above area [

Fire Protection and Housekeeping 2 2 t

l Refueling and Outage

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Management 2 -

i Licensing Activities 2 1

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Training and Qualification Effectiveness 2 2 Construction -

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Operational Readiness

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. . Unplanned Shutdowns, Plant Trips and Forced Outages Power Date Level Root Cause Functional Area Unit 1 6/1/87 9 5'.' Material Failure Maintenance Description: During the performance of a surveillance test to troubleshoot a low EHC control oil pressure, oil leakage past a cup valve and trip latch resulted in reaching the low control oil pressur Autcmatic turbine / reactor tri /9/87 3 3'. Material Failure Engineering / Tech Support Description: Wnile initiating a power ascension af ter completing feed regula-ting valve repairs, several control rods dropped into the reactor core, resulting in a high negative neutron flux rate autematic reactor / turbine tri The rod drop was due to a failed electronic card in the rod control syste The root cause of the f ailure was recurrent overheating of the rod con-trol cabinets due to inadequate cooling air flo /19/5B 0 '. Procedural Inadequacy Surveillance Description: Reactor trip on low-low steam generator water level due to the failure to return the reactor trip breakers to the as-found positio Operator error contributed in that "dummy" level signals were not inserted to block a trip signa Unit 2 8/5/87- A total of 16 trips were experienced between initial criticality 11/17/87 and commercial operatio Six trips were the result of equip-ment failure; five occurred during testing, some of which were not unexpected; three were attributed to design problems; one to personnel error and one to procedural deficiency. Only one recurrent trip cause (equipment failure) led to two trip /17/87 9 8*. Personnel Mair,tena nce Description: An automatic turbine / reactor trip and brief loss of of f-site power occurred due to a voltage spike to the turbine thrust bearing wear trip circui Tne spike was the result of an inadvertent bump of a turbine rotor position module power supply switch by a technician performing work on adjacent equip en _ _ _ _ _ _ _ _ _ _ _ - -

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Unplanned Shutdowns, Pl ant Trips and Forced Outages (Continued)

Power Date Level Root Cause Functional Area 1/27/88 100% Random Material Failure --

Description: An automatic reactor / turbine trip occurred due to low RCS flo Within milliseconds af ter securing a service water system pump, a 4 kV bus overcurrent trip occurred which resulted in the loss of the "A" reactor coolant pum /4/83 100% Material Failure --

Description: An automatic reactor trip occurred due to low RCS flow when a reactor coolant pump auto-tripped during the performance of a balance of plant surveillance tes During the test, a relay failed to block an undervoltage signal resulting in several motor loads (including the "A" RCP) isolating f rom the 4-kv bus.

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III. CRITERIA Licensee performance is assessed in selected functional areas, depending on whether the facility is in a construction or operational phas Func-tional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functionil area: Assurai.cc of quality, including management involvement and control; Apprcach to the resolution of technical issues from a safety stancpoint; Responsiveness to NRC initiatives; 4 Enforcement history; Operational and construction events (in:luding response to, analyses of, reporting of, and corrective actions for); Staffing (including management); and Effectiveness of training and qualification progra On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories are as follows:

Category Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially ex-ceeding regulatory requirement Licensee resources are ample and ef fec-tively used so that a high level of plant and personnel performance is being achieve Reduced NRC attention may be appropriat Category Licensee management attention to and involvement in the per-formance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources art adequate and reasonably allocated so that good plant and personnel perfernance is being achieved. NRC atten-tion may be maintained at normal level . _ _ _ _ _ ________ _ _____________ _ _ _ _ _ _

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Category Licensee management attention to and involvement in the per-formance of nu; lear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal level The SALP Board may assess a functional area to compare the licensee's performance during the last quarter of the assessment period to that during the entire period in order to determine the recent trend. The SALP trend categories are as follows:

Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Li c e r 1. 4 perforrance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this patter A trend is assigned only when, in the opinion of the SALP Board, the trend is significant enough to be considered indicative of a likely change in the performance category in the near future. For example, a classifica-tion of "Category 2. Improving" indicates the clear potential for "Cate-gory 1" performance in the next SALP perio It should be noted that Category 3 performance, the lowest category, represents acceptable, although minimally adequate, safety performanc If at any time the NRC concluded that a licensee was not achieving an ade-quate level of safety performance, it would then be incumbent upon NRC to take prompt appropriate action in the interest of public health and safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP proces It should also be noted that the industry continues to be subject to rising performance expectations. NRC expects licensees to use industry-wide and plant-specific operating experience actively in order to effect performance improvement. Thus, a licensee's safety performance would be expected to show improvement over the years in order to maintain consistent SALP rating Further, in this assessment, Training Programs is evaluated as a separate functional area instead of combining its assessment with engineering activities. This approach was agreed in by the SALP Borrd in order to more clearly focus licensee attention toward needed improvements in the licensed operator training are * a

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I PERFORY.ANCE ANALYSES Plant Operations (3388 hours0.0392 days <br />0.941 hours <br />0.0056 weeks <br />0.00129 months <br />, 32*.) Analysis The previous assessment for Unit 1, evaluated as Category 2, noted ie-proved performance in the overall conduct of operations with good and improving professionalism, active first-line supervision, and senic. naa-egement involvement. There were seven plant trips during the previous period. Recurrent electronic equipment problems led to two plant trips due to vital bus losses and nine shutdowns or power reductions were caused by balance of plant (BCP) pump or feedwater control valve (FCV) problee Unit 2 was not previously rated in this area. The current assessment includes Unit 2 operations since entering commercial operations.

Continued improvement was observed in this area for Unit I during the perio Two reactor trips were experienced during power operation, both

caused by hardware failures. Another trip occurred while the unit was shut down during the refueling outage caused by a procedural deficiency and a weakness in configuration control. Unit 1 experienced both trips from power in early June during the first 10 days ef ter startup follo.ing con-

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trol room codifications. The first trip was caused by an EHC valve leak which dropped EHC turbine oil pressure and caused a turbine trip. The second trip was due to an electronic card failure which caused multiple dropped rods and a negative flux rate reactor tri Three reportable events wers attributable to Operations personnel during the period (in-cluding Unit 2 following commercial operation), all of which involved tag-ging out er restoring equipment to service. The absence of plant trips or significant operational events due to personnel errors is attributed to increased licensee emphasis on problem analysis and management attention to identification of root cause Unit 1 experienced four power reductions caused by BOP components, two from feedwater centrol valve (FCV) problems and two from feedwater heater drain system rcpairs. This represents a significant improvement from nine such reductions last period and twelve the period before and reflects in-creased licensee attention to BOP maintenance and reliability. Histori-cally, the FCVs have exhibited substantial noise, vibration and displace-ment during power operation, and FCV problems have caused many of the past power reductions. Modifications completed late in this period appear to

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have nearly eliminated these visible indications of accelerated FCV wear and no FCV problems occurred during the three months of sustained power operation after the sixth refueling outage, Unit 2 entered co mercial operation on November 17, 1937; operational experience prior to that cate is assessed in the Preoperational and Start-up Testing functional ares (IV.I). An NRC Special Assessment was conduc-ted f rom August 4,1957, to September 11,19S7, which concluded that the licensee had demonstrated very good operatienal performanc _ - - - - - - - - - - - _ - _ _ ___

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I Five hours af ter entering commercial operation, Unit 2 experienced a tur-bine trip from full power due to a spurious signal generated by a voltage I spike fellowing a technician's inadvertent toggling a turbine rotor posit-ion powcr module switch. The trip initiated a complex sequence of events which led to a 17-second loss of offsite power. Licensee management was closely involved with the troubleshooting and corrective action plannin The licensee's staff demonstrated excellent knowledge of the complex tech-i nical issues and design changes needed to prevent recurrence. A strong safety emphasis was evident as the licensee methodically and unhurriedly studied the event and completed necessary design modifications prior to restar Unit 2 experienr.ed two additional reactor trips both caused by the loss of a 4-kv bus (and attendant loss of a RCP) due to unrelated hardware fail-ures. The first occurred on a spurious overcurrent signal af ter securing a service water ou p; the licensee was urable to reprocuce the event and elected to replace the candidate relays and sent them to an offsite labor-atory for further study. The second bus loss was due to a contact failure during a BCP surveillance tes Operator responses to the trips were excellent and the licensee's post-event troubleshooting thoroug On January 28, 1955, erratic control room visual wiadow display and horn operation occurred while Unit 2 was snut down for a planned maintenance outage. The operators irnediately ciagnosed the annunciator problem to be originating in specific remote cabinets and, within three minutes, re-sponded to the correct location. A small fire was found in one cabinet and promptly ex;inguishe The li.ensee's actions during the event, especially the performance of the operators, was considered to be a not-able strengt Prompt and accurate operator response to plant transients during this period avoided several safety system challenges or plant trips, especially during Unit 2 startup testing, Control room professionalism and operator attitude were very good, even during high activity periods such as startup testing and major outages. Early in the period, prior to Unit 2 license receipt, Unit 1 entered a five-week outage to f acilitate removal of a con-struction wall within the Control Building which divided the control room into separate areas for each uni This activity was well planned and resulted in a control room facility with safety grade ventilation avail-able from either uni The licensee's fire protection program was considered adequate with good site fire brigade training and off-site backup capabilit In surmary, continued sound performance in Unit 1 operations was observed with few reactor trips and poner reduction Unit 2 operational perform-ance was also very qood, especially in comparison with other first cycle units. Notable strengths were observed in management involvement, oper-ator event resp 3nse and problem solving. Tne absence of any significant operational problems attributed to personnel performance difficulties demonstrated the effectiveness of licensee controls in this are . . _ _ _ - - _ _ _ _ _ . _ _ _ _ . . _ _ - _ _ - . . .-_ _ _ _

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2. Conclusion:

Category 1 3. Board Recommendations:

None

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. . Radiological Controls (874 hours0.0101 days <br />0.243 hours <br />0.00145 weeks <br />3.32557e-4 months <br />, 8%)

1. Analysis The Unit 1 Radiological Controls and Chemistry Program was rated Category 2 last period. A need for improvement in management oversight of activ-ittes and improvement in the corrective action system was identified. The Unit 2 program evaluation was included in the Operational Readiness func-tional area last assessment period and was rated Category 2 with no radio-logical controls weaknesses. Ongoing licensee efforts to extend the radt-ation safety program to support combined unit operations were good, Radiation Protection

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Licensee efforts to ensure acceptable transition from singie to dual unit l

operation was apparent, well planned and implemented. These efforts included appropriate increases in staf fing and comprehensive training of personnel on differences between the two stations. Staffing was adequate to support routine radiation protection activities. The licensee also

, purchased and placed in service several whole body contamination monitors and whole body counters to enhance capabilities in this area.

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Ov e ra'il communications (e.g., between operations and radiation safety I

personnel) were good; however, some communications weaknesses between the radiation safety and security organi:atiens at the beginning of the Unit 1 outage resulted in an initial shortage of contractor radiation protection j technicians to support the outag Some deficiencies observed during the i outage (e.g., poor radiological posting and labeling and poor house-keeping) were attributed, in part, to this shortage.

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A well defined and adequate training and qualification program for radia-tion protection personnel and radiation workers was established and imple-i mented. The contractor technician training program was of good quality. A continuing training program was in place and implemented. Management at-tention to this training was esiden Licensee audits of program implementation examined all appropriate areas;

however, audits were ccmpliance oriented in nature. Technical specialists

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were rarely used. QA personnel experience in the area of radiation safety 1 was minimal. Consequently, evaluation of radiation safety program adequacy and performance relative to industry standards and performance was limite Weaknesses in the routine internal self assessment program identified last

' period (e.g., lack of formalization, trending, and evaluation) remain. An additional concern identified this period was lack of long term corrective actions on sove self assessment finding AlthougS self identifying of problems by this routine program was an excellent licensee initiative, j lack of long-term corrective actions on self-assessment findings limited the value in contributing to long-term program enhancement.

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Weaknesses in the area of self assessment were compensated for this assessment period by the licensee's performance of an in-depth self assessment using INPO evaluation criteria. Items for improvement were included in a corrective action plan. The licensee's offsite review com-mittee also reviewed recent inspection findings in the area of radiation protection to identify areas for improvement. These actions were con-sidered good licensee initiatives, a High Radiation Area key control weaknesses identified last period were l corrected. Radiological surveys to support on going work were comprehen-

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sive. A need for more aggressive oversight and control of major exposure tasks and inprovement in the quality of procedures contro' ling these tasks was identified by NRC during review of outage activitie There were

lapses in control of diving operations in that no one had been clearly as-signed specific responsibility for monitoring the diver's position. Also, i weak procedures for control of steam generator entry coupled with poor j cversight by supervision resulted in an individual's 1000 mR dosimeter going off-scale during a poorly controlled entry. Although no regulatory l overeuposure resulted, the indivioual exceeded his allowable ad?,inistra-l tive exposure limit by 500 mR. Diving procedures for the reactor vessel

were improved to address NRC concerns. These weaknesses indicated the i need for additional licensee attention to control of perscnnel exposure, i

A defined Internal Exposure Control Program was in place and implemented.

1 No significant individual intakes of radioactive material by personnel l

occurred. Previously identified weaknesses with whole body counting equip-rent were corrected by licensee purchase and placesent in service of state-of-the-art whole body counting equipment. A program to select per-

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sonnel f rom among these working on jobs with the potential for airbcrne j radioactivity intake for whole body counts in order to provide a second

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prograts was not in plac Lack of confirmatory termination whole body counts was not in consonance

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] not provided confirmatory exit whole body counts as recommended by station

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procedure <. Licensee control of contamination and efforts to minimize contaminated areas were good.

) Weakness in control of air samples continue There was a failure of a i technician to notify supervision of unexpectedly high airborno radio-activity concentrations during clean up of the Unit I reactor cavit Although licensee identified, there was a lack of timely corrective action

! reflecting weaknesses in the pre; ram for corrective action and a lack of appreciation of the significant airborne radioactivity levels identified I (100 times maximum permissible concentration). Of particular concern was the fact that multiple supervisory personnel later signed of f acknowled-ging the air sarple results witnout taking any action on them. This vio-I lation was symptematic of weaknesses in the prograt for review of airborne

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survey result In addition, it reflected continuing weaknesses in the j control of air sa ples which was icertified last period.

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Station aggregate exposure for the past five years compares favorable with i industry averages. This however is attributed to the licensee's lack of

performance of significant steam generator work. Followup of previously

identified weaknesses in the ALARA area continue to indicate a need for

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i additional oversight and emphasis on ALARA. Observations during the Unit 1 outage identified lack of ALARA reviews for some steam generator work, .

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i lack of attendance at ALARA Review Committee n'eetings, weaknesses in ALARA goals due to lack of accurate person-hour estimates to perform work, lack of a defined program to perform review of on going work from an ALARA e perspective and lack of sensitivity to ALARA by worker General area radiation levels associated with steam generator work con-tinue to be some of the highest in the industry indicating some weaknesses

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Scre weaknesses in licensee planning for emergent work was also identi-  !

fied. Licensee ALARA planning for steam generator work only considered

inspection of a single generator. The planning did not consider potential  ;

emergent work on other steam generators. Additional steam generator work l I subsequently was require .

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on 50me ma,ior tasks (e.g. , reactor vessel flow baf fle work and thermal shield work). This work involved significant in vessel work. The licen-i

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! see also removed a significant number of unnecessary snubbers thereby 1 reducing the need for performance of surveillances in radiation areas.

. i Staf fing in the ALARA area is considered weak. Although some individuals  !

j provided technical support, one individual was assigned responsibility for i

evaluating work pacnages, performing ALARA reviews, and performing in-  ;

plant ALARA functiers (e.g., worker briefings). This represents a weak- ;

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ness in the staf fing level to support activities in this area for two j unit .

Licensee corrective action on NUREG-0737 post-accident sampling findings [

were technically sound indicating a good understar. ding of the technical issue [

Radioactive Effluent Controls and Radwaste Systems

The preoperational test programs for the Unit 2 effluent monitoring,  !

4 process sample stations, and radwaste systems were based on the F5AR and i f appropriate procedures and were good. Staffing was tieely and generally  !

complete with little reliance on contractor personne The licensee !

developed an adequate progra* for control of radioactive effluent frcm the l 1 site (Units 1 and 2) which cc onstrated a viable and sound technical  !

, approac Also, the preoperaticnal testir; of the radiation monitoring i

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system was well planced with priorities assigned to support preoperational l and operational milestone I t

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Numerous minor abnormal gaseous and liquid releases of radioactivity occurred early in the assessment period due to operator, surveillance, and maintenance errors. The need for greater attention to detail during oper-ation of radsaste equipment was indicate The Radiological Controls group demonstrated the capability to comply with the Technical Specifica-tion requirements during these abnormal release Radiological Confirmatory Measurement A confireatory measurement inspection was performed using the NRC Region I Mcbile Laboratory. All split sample results were in agreement between the licensee and the NRC. The licensee had state-of-the-art gamma and liquid scintillation counting systems which indicated management support. Pro-cedures were gererally adequate; however, the licensee did not implement certain aspects of the Laboratory Quality Control Program (comparisons of inter- and intra-laboratory blind samples). Audits by QA group were tho-rough and tecnnically sound but one weakness noted was that audit person-nel did not track the previously identified follow-up items thoroughl These problems were minor; the licensee had a generally sound program in this are Transportation The position of Transportation Supervisor was assigned the responsibility for the maintenance of licenses and permits, co?pliance with applicable procedures, regulations related to the receipt and shiptent of radioactive materials, and review and revision of the Process Control Program. How-ever, this position, which was created in August 1986, had not been filled at the end of this assessment period. Two violations were identified dur-ing this period that might have been avoided had the position been fille Although the licensee had an adequate transportation program, attention should be focused on filling needed position Sum-ary Although scme new equipment was purchased and placed in service, perform-ance in the area of radiation safety and transportation continued at es-sentially the same level as last period. Licensee radiological control personnel performance in the area of radioactive effluent controls was generally strong. Station total personnel exposure has shown a decline over the past several years consistent with overall industry performanc However, continued enhancement of worker consciousness of ALARA and pro-gram improvements in this area was warranted. Improvement in management and supervisory oversight of major exposure tasks was similarly warrante Tne corrective action system, a previously identified area for improve-ment, continued to need additional management attentio _ _ _ _ - _ _ _ _ _

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2. Conclusion:

Category 2 3. Board Recommendations:

Licensee:

Strengthen supervisory and managerrent oversight and procedural controls for significant radiological task Additional efforts are needed to reduce personal exposure during future steam generator work, NRC:

None

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. . Maintenance (742 hours0.00859 days <br />0.206 hours <br />0.00123 weeks <br />2.82331e-4 months <br />, 7*.) Analysis During the previous assessment period, Maintenance and Modification was evaluated as Category 2 for Unit 1. Generally good control of preventive and corrective maintenance activities was noted. This current assessment

. includes Unit 2 maintenance activities which were incorporated into the common site programs when initial criticality was achieved (August 4, 1987).

Maintenance procedures and policies were typically followed well by sta-tion personnel. Maintenance goals had been established and the dates were beirg met within the tolerances established by the progra The backlog

, of maintenance tasks was well managed, in particular, it was noted that j the licensee had developed a thorough maintenance and test program for electrical equipment, including battery chargers, batteries, circuit

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breakers and transformer l Considering the tire period covered, there was a relatively low number of

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problems attributable to personnel erro Three Unit 2 reactor trips occurred due to error; one was attributed to failure to perform adequate p:st-caintenance testing, another involved inadequate jcb preplanning and j the lack of attention to detail, and tne third was caused by an accidental

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bump of nearby equipment. Four ESF actuations occurred during maintenance i activities due to various causes, including improper use of available t

equienent, technician failure to note the effect of work activities on i associated plant equipment and deficient procedures. Generally, mainten-ance procedures were found to be ttrchnically sound but required improved i human f actors censicerations, especially those that involve activities that can result in plant trips or E5F actuation Maintenance personnel were trained to work on both units and were found

' to be knoi<ledgeable of station procedures and the tasks to which they were assigne Toward the end of the sal.P period, tne mechanical and elec-trical maintenance training programs were accepted and accredited by INDO.

The previous assessment noted that a list of personnel qualified to per-

form certain jobs was not maintained by the individual departeents, and personnel were selected on an as-available basis by supery' sors who were j f amiliar with the individual's qualification A minimum job training J concept was teplemented. Although the minimum job training lists were not i complete, updated lists were periodically distributed to supervisors to a

nsist them in selecting personnel to perform maintenance activities. The current program appeared to be functioning properly in that the quality of maintenance was generally good and in accordance with site procedures.

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_ _ _ - - _ - _ _ _ _ _

= .

.

.

Quality control involvement in maintenance activities was adequate. Qual-ity control inspectors were usually present during significant activities and were performing in process inspections of ongoing maintenance work activitie They were knowledgeable of the activities observe j Day-to-day preventive and corrective maintenance of safety related com- l ponents received adequate preplanning and supervisory oversight. Daily reetings provided a good rechanism through which proper coordination and interfaces were established with the various station groups. Proper use of clearances and adequate interface among the various station groups [

(radiological control, quality control, etc.) necessary to accomplish [

maintenance activities were observed in the fiel *

Previous assessments identified weaknesses in complying with administra-tive requirements associated with complete maintenance work requests (RWR) l documentatio Improvements in this area occurred during this period,  !

with the exception of post-eaintenance testin The required post- ,

maintenance testing or reason for not performing testing were not always

'

identified on the VdR. In one example, a manual reactor trip was required t due to a Unit 2 rod control system problem. The failure to test the sys-  ;

tem properly following the associated maintenance troubleshooting activ-  :

ities resulted in a second manual reactor trip due to drcpped control  ;

roos. A similar example was the f ailure to tett 3 liquid waste motor-  ;

operated valve properly following maintenaice resulting in an inadvertent l'

liquid release. Root causes for the second event included improper main-tenance and a breakdown in communication among the responsible station groups. Additional rnanagement attention will be necessary to acnieve a i better post-rnaintenance testing progra Historical information in the maintenance database was very good. How- 6 ever, preventive maintenance trending at the site needs to be improved, i in that trending was found to be performed on a reactive rather than sys-  !

tematic b, sis. Management did not provide the staf fing necessary to pro- [

vide a thorough trending program even though plant perfomance personnel had identified valuable information during several reactive trending analyse I l

For the majority of the period, plant housekeeping during and following  !

the conduct of maintenance was weak. Areas were littered with tools, com-ponent parts and debris. Additionally, unrestrained equipment, such as ,

ladders, gas bottles, and large tool cabinets on rollers were of ten ad-  ;

jacent to equipment important to safet The licensee developed detailed ,

guidance in the Maintenance Manual in an attempt to resolve the concern '

t While insprcvements were continuing, individual deficiencies continued to be identifud to the licensee for resolution. Aggressive reanagement over-  !

'

sight was not apparent in this area for the majority uf the assessment perio :

,

i

,

, _ _ - _ - _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _

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. -

In sue. mary, licensee activities associated with preventive and corrective maintenance were generally well controlled. The relatively low number of ennecessary challenges to safety equipment reflected overall satisfactory technician training and adequate procedures. Improvements in the areas of housekeeping, post-maintenance testing, and procedures are necessary if improvements are to be achieved in the maintenance progra . Conclusion:

Category 2 Board Recommendations:

Li c e n s_e_e :

Implement a program to improve procedures, post-natntenance testing and trendin tim:

None

, - - - - - - - - -

l s s

,.

,

. Survet11ance (790 hours0.00914 days <br />0.219 hours <br />0.00131 weeks <br />3.00595e-4 months <br />, 7*4) Analysis

' During the previous assessment period, Surveillance was evaluated Category 2 for Unit 1. Operational Readiness Category 2, Improving was evaluated for Unit 2. While a surveillance program that was generally functioning well was noted, concerns were identified with respect to reviews of test data for reasonableness, several missed surveillance tests, and the con-tinued need to strengthen the 18-month operations surveillance test system alignment methodolog This current assessment includes Unit 2 surveil-lance activities which were incorporated into the common site programs when initial criticality was achieved (August 4, 1987).

The last assessment noted that Unit 2 operational surveillance tests were incorporated into the routine surveillance schedule once a system was turned over to the station to maintain operabilit This process was continued and was a licensee strength, demonstrating that the licensee olaced considerable effort in preserving plant equipmen There was one reactor trip and about 15 additional reportable events that occurred during surveillance testing activitie The majority of the reportable esents were due to inadequate procedure The nutber of missed surveillance tests occurred at about the same rate as during the last SAlp perio The licensee maintained a strong reliance on individua'l surveillance test coordinators who were accountable for the administrative inplementation of the progra Each station group that performs surveillance tests was responalble for the overall coordination and control of their respective portions of the surveillance program. The licensee maintained an informal Technical Specification (TS) and procedure matrix which was a computerized cross reference of plant procedures and T The matrix was revised annually and provided a mechan'sm through which identification and Cross referencing of procedures could be acconitsbed and was generally used ef fectively for a variety of administrative purposes. At the end of the period, licensee efforts were initiated to provide a more current matrix for use by surveillance test coordinator The four missed Technical Specification-required survetilance tests were all caused by different types of administrative / personnel error In-creased attention to detail with respect to communication among the var-ious departments may be necessar Staffing for each of the surveillance programs and the training and quul-ifications of radiological control, operating and test personnel with respect to survtillance testing performance were adequat Preservice (Inservice) Inspection staffing was improved by the addition of a Level I!! and t.o N>n-Cestructise Examination (NDE) tecnnicians. This permitted the licensee to take over review responsibilities for NDE result Inser-vice testing of pumps and valves was performed adequately although NRC identified some minor problems concerning procedural details, s

, .

_

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One programatic area needing further management attention was the control of surveillance activities and adequacy of the associated procedures which iepact operability or challenge safety system Three separate but similar events occurred when surveillance activities were performed which did not adequately return the systems to required positions or did not verify Technical Specification requirement Prior to initial entry into Mode 4 (Hot Shutdcwn), the operational surveillance test procedure failed to identify that the Unit 2 control room emergency bottled air pressuriza-tion system actuating circuit was disabled. While Unit I was in a cold shutdown condition following completion of a surveillance test, the tech-nlcians f ailed to return the reactor trip breakers to the as-found po-sitio Subsequent drain down of a steam generator resulted in a low -

low level reactor trip signal and automatic open;ng of the reactor trip breakers. The third event involved the performance of a surveillance activity which left two high-high containment pressure bistables in a different configuration than as-found rencering two out of the four auto-matic actuation channels for the containment spray system incperabl For the last two events, operator error and human factor deficiencies were contributing factor Site management has recognized human factors con-cerns to be a pecblem; however, aggressive resolution was not apparent as a relatively large number of events were attributable to deficient procedure The edcy-current testing of the steam generators during the Unit 1 refuel-ing outage implemented an inievative approach in the dati analysis in that indeperdent reviews were ptrformed by different vendor However, one weakness in this method was that the dif ferent vendors did not use ti e same terminology in reporting the results although this did not lead to any problems. The licensee vas responsive to the concerns associated with the North Anna steam generater tube rupture. Special eddy-current inspec-tions were performed and preventive tube plugging was implemented. To provide a mechanism through which the failure of a tube susceptible to the North Anaa type failure could be identified (even if plugged), six tubes were plugged with a standard plug in one erd and a sentinel plug designed to limit a leak to 300 gallons per day in the other end. 'With this tech-nique, if any of these six tubes ruptured, the leak rate would increase by 300 gallons per day (below emergency shutdown limits) and allow an orderly plant shutdown. Another example of the licensee's response to recent industry experience was the performance of eddy-current testing of all 50 in-core instrumentation thimble tubes. Indications were evaluated and appropriate corrective actions were implemente These actions repre-sented good safety perspective and initiative The results of secordary water chemistry control during the majority of the period were excellen Sodium chloride, sulfates and silica were generally belcw the values that could be determined by the on-line, stato-of-the-art equipment used for the analyses, The mercholine additions the licensee perfortred appeared to mane the bicwdowa process more effective in sludge removal. Close attention to secondary water chemistry as cemon-strated by the licensee shculd help to recuce steam generator tube degra-dation and i;preve plant safet i e s

'

.

[

l

, .

l 1 In summary, the relatively low number of unnecessary challenges to safety L

"

equipment reflected overall satisf actory technician tr:ining and adequate i i

'

procedures, The surseillance programs functioned adequately. Configura- !

tion control, particularly during high activity periods, and procedural !

l adequacy were areas which required further management attention if the i surveillance test program implementation is to be strengthened. Manage- ;

ment commitment to address potential safety issues f rom a technically

,

l I sound perspective was eviden , Conclusion:

i Category 2 i

j 3. Board Recorrendations:  ;

i i a

-

Licensee:

s l

Complete review of procedures for human factors deficiencies, especially I j tnose associated with outage recover I 1 i

!  !!EE: t

'

'l None

!

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i i

$

!

,

1

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I

)

I

!

!

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1 ,

I

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. . .. ..

_

$ ,- +

,

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-

• 24 (9 '

'a Emergency Preparedness (447 hours0.00517 days <br />0.124 hours <br />7.390873e-4 weeks <br />1.700835e-4 months <br />, 4'4)

1. Analysts-During : the previous assessment period, licensee performance in this area was ratea Category 1. This was based upon exercise performance and the licensee's, own initiatives in routine emergency preparedness activitie Inspections. cf emergency preparedness activities included the Emergency Preparedness Implenentation /ppraisal (EPIA) and three followup inspec-a tions prior to Unit 2 licensing. The annual emergency exercise (partial-participation) for both units was observed, and ch ,es to emergency plans and iciplementing procedures were reviewed. Response to the January 28,

,

l L 1988 loss'of annunciator event was also evaluate .4 The EpIA neriormed on March 2-6, 1937, about 10 weeks prior to license

! receipt, focused on the readiness to integrate the Unit 2 p sgram into the overall site a nu' corporate emergency preparedness p rog t .:m. The EPIA identified s9veral program areas as incomplete or in need of currection before readiness to receive the low power and full power license Followup inspections conducted in April through June 1987 tracked licensee progress in completing open items prior to full power licensin By June '1987, all items had been adequately addressed, an indication of positive response-to NRC initiative Emergency response facilities were common to both units with the exception of the cor. trol rooms. As a result of EPIA findings, Unit 2 control room upgrades were made in communications capaoility, addition of protective clothing, and improvements in security arrangements. Other changes to f acilities included enhancement of onsite and remote (offsite) assembly areas, and enlargement of the Radiologica Operations Center (ROC). Capa-bility of other facilities which include the Emergency Operations Facility (EOF), Technical Support Center (TSC), and Operations Support Center (OSC)

were demonstrated in routine drills conducted at di"erent times through-out the period and deemed effective as emergency response facilities. Full time site support staffs were adequate to maintain effective onsite and of f site activities associated with the progra This included permanent emergency preparedness staff with additional support from the Operations, Health Physics, and Training Department During the partial participation exercise conducted on September U,1987, the 11cer,see again demonstrated an aggressive approach toward implementa-tion of the Emergency Plan and implementing procedures while maintaining a high level of emergency preparedness. NRC identified only minor exercisa def.iciencies in the areas of TSC information flow, handling of the contaminated / injured individual, anct functioning of the plant paging syste The licensee conducted an adeauate self-critique by identifying oeficiencies which occurred during the exercise and committed to take

'

actions to correct the deficiencie ____ - _ - _ _ _

____ __ ___________ __ _ _ _ _ _ _ _ _ ___ __________-____

s .

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On January 28, 1933, a loss of Unit 2 control room innunciators res,:f red declaration of an Alert emergency classification. Onshift staff promptly recognized the event, end af ter review of EAls, correctly classified the event as an Alert. Notifications vi oiisite authorities were performed within the 15 minute requirement. The emergene, response organization was also rotified while activation of the TSC, OSC, and ROC occurred. Af ter activation of local Emergency Operations Centers (EOC), coordination with state and county representatives was closely maintaine Foilowing event termination, the licensee reviewed the event to assess the response and identify actions to be taken to prevent recurrence. Overall, the licensee accurately and effectively implemented the site Emergency Preparedness Plan in a timely manne Furthermore, the licensee recognized the un-realistic conservatism in the EALs associated with this event and appro-priately revised the Emergency Plan prior to plant restar The interface between the emergency preparedness staf f and licensee man-agement was noteworthy. Upper le/cl managemert was supportive in expe-diting correction of weaknesses identified during the EPIA. This was evi-denced by prompt resolution of all 26 EPIA concerns within approximately 4 months of initial NRC identification. The relationship between the licen-see and off site authorities contirued to be strong. Notification and co-ordination with the States of Pennsylvania, Ohio, and West Virginia, and counties of Beaver and Columbiana during the loss of annunciatcr event allowed the response to be carried out effectivel In su mary, the licensee successfully integrated Unit 2 into the site Emergency Preparedness Plan in a timely manner to support l i c e n s i r.g .

Excellent personnel attitude, management involvement a r.d organizational respon:iveness continued to be demonstrated in day-to-day activities and drill Licensee overall performance was noted to be strong during the January 28, 1935 Aler . Conclusion:

Category 1 Board Recommendations:

None

_ _ . . _ _ _ . , . - _ _ _ - .

. .

-

,

-

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F. Security (433 hours0.00501 days <br />0.12 hours <br />7.159392e-4 weeks <br />1.647565e-4 months <br />, 4%)

1. Analysis This is the first SALP of the combired Unit 1 and Unit 2 security progra The two programs were integrated early in this assessment perio During the last assessment period, no major programmatic weaknesses were identified for Unit 1 and a C:tegory I rating was assigned. The func-tional area of Security and Safeguards was included in the Operational Readiness portion of the previous Unit 2 S.1P and that portion was as-signed a Category 2 rating. A common concern in both the Unit 1 and Unit 2 assessment 3 for the last period was the adequacy of the licensee's pro-prietary security staffing level, consisting of three full-time positions at that time, to provide the necessary effective oversight and control of the contract security force for a two unit site, especially considering the problems inherent with the startup and integrating of the systems and equipmen The licensee recognized and responded to the NRC concern about the poten-tial for problems with the then-existing proprietary staff and expanded the staff from three to eight full-time positions over this assessment perio A training coordinator and four security shif t supervisors were added to the per.e-ietary staf f. The security shif t supervisors provided around-the-clock shift oversight of th* :urity contracto The expan-sion of the proprietary staff demonst management support and atten-tion to the security program. The shi oversight function was imple-mented toward the end of the assessment period and its effectiveness has not been assessed by the NR At the staet of the assessment period, the licensee experienced several problems inherent with the startup of the new systems and equipment, in-ciuding new security computers installed as part of combining Unit 1 and Unit Contributing to the problems was the fact that there were more than 3000 construction workers onsite completing work on Unit 2 at the time the combined security program was being made operational. The con-tract security force was also working a larger amount of overtime at that time to support Unit 2 construction activities and the preoperational testing and calibration of the new security equipment and systems. Towards the end of the assessment period, most of the integration, construction, and new equipment problems had been resolved, the proprietary security staff had been expanded and the security force overtime had been reduced to a minimum. Management's prompt action to resolve the problems encoun-tered demonstrated the licensee's intent to maintain an effective security progra Security management personnel continued to be actively involved in industry groups engaged in nuclear plant security matter This also demonstrated program support from upper level managemen ___ ____

• 6

,

,

-

.

About midway through the assessment period, the NRC identified concerns about the sparse maintenance support being afforded to Unit 1 security equipment and the use of long-term compensatort measures ?cr inbperative equipment. The majority of the maintenance resources were being utilized

'or overall Unit 2 preoperational activitie Senior management promptly committed to review all the Unit 1 security maintenance concerns and to have all inoperable equipment repaired within 60 days. This was acccmp-lished in the committed time period and the long-term compensatory meas-ures were terminated. Subsequent inspections indicated that the mainten-ance work wc.s very ef fective and thct increased maintenance support was continuin This demonstrated senior management's responsiveness to NRC findings; however it also indicated a previous lack of appropriate atten-tion to corrective maintentnce or escalation of maintenance problems to proper management levels to effect resolution. In either case, upper level management should have been alert for compensatory measures which resulted from untinely corrective maintenanc The training program was administered by four full-time, experienced in-structor In-depth lesson plans had been developed, were current, and reflected the commitments in the NRC-approved security program plan Training facilities were professional and instructional aids were utilizeJ extensively. All security-related facilities, e.g., guard house, alarm stations and of fice areas, were well maintained, oruerly and clean. Licen-see oversight of the training program was provided through a proprietary training coordinator and demonstrated the licensee's ittent '.o maintain an effective and professional training recoram. Program implementing proced-ures and i; > : ructions continued to be updated when required, based on feedback from training and security operations supervision, to provide the security force with current, clear and concise directions. Members of the security force were knowledgeable of their duties and responsibilitie The high quality of the training program and the procedures and instruc-tions was apparent from the relatively few personnel errors during the assessment period and was further evidence of management support and at-tention to the progra The turnover rate in the contractor security force remained low and staff-ing appeared to be sufficient, as indicated by the limited amount of over-time being worked at the end of the assessment period. Contractor super-visory And administrative staffing was also sufficient for the current work load. The licensee's oversight of the contract security force was adequate to provide the licensee with necessary and current knowledge regarding program implementation. This was apparent by the licensee 5 self identifying several program deficiencies throughout the perio _ _ .... . ... ..

a o j

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The licensee submitted 30 event reports under 10 CFR 73.71(c). This relatively large number of reports was due to several factors: (1) a revision to the NRC reporting requirements in October 1987: (2) very con-servative reporting practices on the part of the licensee, (3) the startup of new systems and equipment; and (4) the integration of the Unit 2 sys-tems with Unit 1. A detailed review of the event reports by NRC indicated that only ten of the events had to be reported under the current NRC reporting requirements. Of these ten events, three involved guards who were inattentive to duties. These events occurred during the period when large amounts of overtime were being worked by the security force to sup-port Unit 2 construction activities and the installation and testing of new security equipment. None of the events constituted a security vulner-abilit Immediate and appropriate compensatory measures were implemented in each case and corrective rctions appear to have been effective. There were no such incidents during the last half of the assessment perio During the assessment period, the licensee transmitted four revisions to the Security Plan under the provisions of 10 CFR 50.54(p). Two of these revisions were found acceptable, the others are currently under revie The revisions were adequately summarized, appropriately marked to f acil-itate the NRC review, and of good quality. This was indicative of work b/

personnel who were knowledgeable of NRC security requirements and program objectives and management attention to submittals to the NR In sunmary, the licensee has continued to implement an effective and qual-ity security progra The proprietary security organization has been expanded and significant capital resources have been expended to upgrade security systems and equipment. Problems with the integration of Unit 1 and Unit 2 encountered early in the assessment period received management attention and were resolved effectivel The licensee continues to be respon-4ve to NRC initiatives, hovvever, better long-range planning is war-rante . Conclusion:

Category 1 3. Board Recommendations:

None

!

_ ______

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G. Engineering / Technical Support (1065 hours0.0123 days <br />0.296 hours <br />0.00176 weeks <br />4.052325e-4 months <br />, 10%)

1. Analysis s

During .the previous assessment, Unit I received a Category 2 rating in Engineering Support. Strengths were noted in the on-site location, l

day-to-day involvement and increasing emphasis on problem investigation; ,

.

weaknesses were identified in timeliness to respond to station requests,

! corrective actions to long-standing problems and program oversight.

! During this period, this functional area addresses design of plant I modifications, training and engineering / technical support for all plant activitie Training programs which would no,mally be usses sed within this functional area has been addressed separately in Section i The licensee was in a transition period in an effort to combine the engi-neering functions for both Units 1 and 2. At the end of the assessment period, engineering effort was about equally divided between licensee personnel and the original Architect / Engineer for the station, Stone and Webster Engineering Corporation (SWEC). The SWEC personnel were primarily working on engineering projects concerning Unit 2 since much of the work-ing knowledge for this unit still rested with the contracto However, the SWEC organization was considered much the same as another section of the licensee's engineering organization except that a licensee engineer was assigned to monitor each project performed by SWEC. SWEr used the same procedures as the licensee in controlling work performe The overall resources for engineering support greatly diminished during the current assessment period as the licensee completed construction and startup on Unit Unit 2 completion led to a large reduction in resources (from 6000 to 2000 workers) with the support responsibility being assumed by the licensee on-site engineering department as augmented by SWE In recognition of the increased work load reesented by two operational units, the licensee added twenty additiona' asitions in the NED to staff for Unit 2 operations and ensure adequate support for both unit Multiple or complex events appeared to challenge available resources, but in general, the existing manpower was sufficient to meet deman Procedural control of work in the engineering department was good Records of implementation of engineering work including task specifications, pro-curement controls, safety evaluations and project documentation were read-ily available as part of the design control packages. The procedures were adequate and, in all cases observed, were being implemented. The observa-tions included both short and long term projects. Active projects were discussed in daily meetings to assist in preventing problems. Plant staff participated with engineering management in establishing project prior-ities thus ensuring timely resolution of significant operational problem _ _ _ _ _ _ _ _ _ _ _ _ _ _

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e The Engineering Department had a strorg training program for maintaining individual engineers' knowledge curren The Nuclear Engineering and Records Unit maintains training records of engineering personnel, including required reading checklists, which require engineers to review various engineering, administrative and quality assurance procedures, Regulatory Guides and the relevant parts of the Code of Federal Regula-tions, Title 1 Supplemental Nuclear Engineering Department management, technical and professional development training classes, seminars and lectures taken by the staf f also were trackeo on a computer data base for each employee. To ensure knowledge of changes to engineering procedures, the Nuclear Engineering Department routed a copy of the procedure with an acknowledgement signature required to each section member for review of the revisio Technically sound support was provided to resolve, at least particily, the long-standing problems with the Unit I feedwater control valves, rod con-trol cabinets, and vital bus No. 3 by harcaare design modifications. Time-ly support to operational events allowed Unit 2 to complete electrical modifications following the complex loss of off-site power event on November 17,1987 and start up five days late Responsiveness was also exhibited following the identification that certain required Unit I con-trol room indicators had been inadvectently deleted in 1980, such that proper indication capability was restored days after discover Just aftar the close of the period Unit 1 experienced a trip due to personnel error. A second trip cccurred during restart that required engineering support and engineering personnel, including mechanical, electrical and II,C specialists, to be called in on the third shift for support. Overall, support in response to events was very good and improvements in resolving long-standing problems were note Engineering support was complete and adequate with respect to procurement activities, potential inter-system LOCA (Event V) review, reactor trip breaker modifications, outage activities, and NUREG 0737 post accident sampling system issue Further, tne licensee developed an extensive engineering program to address the equipment environmental qualificaiton requirements imposed by 10 CFR 50.49. A Unit 2 team inspection verified that a sound program had been developed and was being impicmented to ensure that environmentally qualified equipment was being properly l maintained. No significant concerns were identified during the inspection

'

indicating that a comprehensive and technically thorough effort had been I

mounted. An extension of this program was the inspection effort to deal with Limitorque valve actuator problem The program was found to be thorough and in depth; hewever, an inspection of Unit . immediately

.

fol lowi.ig the assessment period identified problems in the use of

' unqualified wirenuts and unqualified wire in Limitorque operators which may raise significant concerns with the EQ program.

I

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The technical content of the licensee's emergency operating procedures was adequate; however, a number of deficiencies and inconsistencies were iden-tified, particularly in the Unit 1 procedure These deficiencies indi-cated a weakness in site management's attention to detail in validation, verification and implementation of high quality emergency operating pro-cedure Procedural human factor deficiencies were compensated by opera-tor experience; operator performance during plant events was excellen In summary, improvements were noted in engineering support for long term problems and plant events. These improvements were achieved during a time of transition with good evidence that licensee senior management was in-volved in matching staf fing to site need Continued senior management attention is needed to assure that engineering / support resources are ade-quate for the increased demands inherent in two unit operation, especially in support of the back-to-back refueling outcges planned in the next perio . Conclusion:

Category 2 3. Board Recommendations:

Licensee: Implement a program to resolve the deficiencies existing in the Emergency Operating Procedures in a timely manne . s

.

c

. Safety Assessment /Ouality Verification (729 hours0.00844 days <br />0.203 hours <br />0.00121 weeks <br />2.773845e-4 months <br />, 7'J)

1. Analysis Management involvement in assuring quality has been considered as a separate functional area in past SALPs in addition to being one of the evaluation criteria in each functional are This area has been expanded to encompass activities previously evaluated in Licensing, including safety evaluations. This discussion is a synopsis of quality and safety evaluation philosophies reflected in other fuo-tional area In assessing this area, the SALP Board has considered at -

tributes which are tey contributors in assuring safety and verifying qual-it Implementation of management grals, planning of routine activities, worker attitude, management involvement, and training are examples. This area received a Category 2 rating for both Unit 1 and Unit 2 in the last assessment pcriod. Strengths were identified in worker attitude, first line supervision, QC aggressiveness and management involvement. A weak-ness was identified in the overemphasis by QA on documentation complete-ness rather than on assessment of the technical adequacy of the area audite Significant resources continued to be dedicated to the assurance of qualit The recent licensee commitment to procuring a new simulator for Unit 2 represents a significant capital investment in enhancing the quality of Unit 2 operator train:ng. Manpower and analysis resources were also allocated to the licensee's recentlj completed Safety System Functional Evaluaticn (SSFE) of the Unit 1 APd syste The SSFE was a broad-based technical audit involving over 3000 man hours of effort and was modeled af ter the NRC Safety System Functional Inspection. The SSFE was used to reconstitute the design bases of the much-modified Unit 1 AFW system and reconcile differences between the two units as well as provide enhanced assurance of APd operabilit The licensee plans to conduct SSFEs on other Unit I safety systems after reviewing the results of the APd SSF In the licensing area, the licensee demonstrated a good working knowledge of applicable regulations, guides, standards and generic issues during the period, in particular, during the final licensing stages for Unit The licensee was generally responsive in addressing unresolved issues; this was especially notable during the completion of the Unit 2 Technical Specification Licensee preparedness, technical competence and ef fec-tively proposed resolutions were evidence of the licensee's commitment to resolve safety issues in a timely manner. Over 100 licensing actions were completed including application of leak-before-break technology (Unit 1),

ATWS rule implementation (Unit 1 and 2), and inservice testing of pumps and valves (Unit 2). Conservatism was consistently exhibited with sound technical judgement provided for most deviations from NRC guidanc _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ _ _ -

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Prior to receipt of the Unit 2 full power license, the licensee conducted a self-assessment of startup testing and power operations at the 50% pnwer testing platea Good agreement was noted between the licensee's self-assessment and the independent assessment made by the NRC staff. The licensee's self-assessment was noted to be strong on root cause analysis, to be self-critical where warranted, and to use existing management infor-mation systems. The use of already in place resources instead of a unique task force approach was a notable strength since it indicated that the analysis tools are consistently available to licensee managemen This self-assessment and the ongoing use by senior management of the contribu-ting reports and trending / tracking documents were positive initiati :?

Utilizing the evaluation methodology presented in NUREG-1022, Licensee Event Report System, the overall quality of LERs exhibited weakness in that they contained inaccuracies, and overall weaknesses in report com-pleteness, root cause determinations and safety significance evaluation The licensee was responsive to these concerns as demonstrated by the significant improvements in LER quality noted during the last quarter of this assessmen A formal and systematic approach to root cause analysis was implemented later in the assessment period which forced a broad-based approach to event review and which led to higher Quality analysis. The ISEG developed a computer progran which compares Unit 2 trip response to a standard trip without other failure The program flags which of over 100 computer address data points do not appear within the expected time "window" and will greatly facilitate the identification of equipment failures or unexpected component response following an event. The program also establishes a database which can be analyzed for trending studies. This program is a notable initiative which, when fully implemented and extended to Unit 1, will enhance the licensee's ability to assess plant response to event Management oversight has generally been effective, considering the in-creased demands the Unit 2 project placed on licensee resources. Senior management was involved in improving availability of safety related com-ponents and systems, promoted accountability and ownership among licensee staff, ensured participation in INPO audits to learn from other utilities

< and kept abreast of regulatory and industry initiatives to be aware of potential problems. Especially effective oversight was demonstrated at Unit 2 during MSIV replacement, recirculation spray heat exchanger flush-ing and startup testin Actions taken by management have achieved partial resolution of two long standing equipment problems at Unit 1; Vital Bus No. 3 inverter unreliability and FCV vibration-induced failure Vital Bus No. 3 inverter trips have continued to occur, but an automatic bypass circuit was installed which provides a backup power supply and has

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prevented the inverter failures from causing plant trips. Additional BOP modifications have greatly reduced FCV vibration durirg power operation, although the greater feed flow available post-modification has appeared to increase the severity of the transient following a plant trip during startup. Af ter the close of the assessment period, other Unit 1 feed-water, SG level control and RCS pressure problems indicate revised flow characteristics for the FW systems which may not have been fully antici-pated by the licensee. Additional attention appears to be required to fully resolve the problems with the inverter and FCV The various station safety committees functioned well during the perio The Of f site Revi!w Committee (ORC) included met.bers of senior corporate personnel and continued to be an ef fective and aggressive organizatio One example of the ORC's use as a management tool was the allocation of resources to cor.Juct Safety System Functional Evaluations (SSFEs) to assure safety system reliability and upgrade design basis documentatio The continued onsite location of senior corporate personnel and engineer-ing support groups enhanced the oversight and integration functions essen-tial to the solution of complex problems. The ORC, acting through sub-committees, acted to improve EDG reliability by installing air dryers in the starting air system, to improve fire damper reliability by implemen-ting a specific maintenance program and to reduce unplanned reactor trips by installing an inverter auto bypass circuit to prevent recurring inver-ter trips from causing reactor trip A major licensee reorganization was announced late in the assessment per-iod following Unit 2 commercial operation. The new senior onsite execu-tive, Vice-President Nuclear, began to restructure his staff to integrate the Unit 2 project personnel into the site organizatio The large QC staff, wnose thoroughness and aggressiveness was a notable strength during Unit 2 construction, was greatly reduced as the work for the group was complete The QA organization, previously roted to overemphasize

"paper", has been tasked with increasing technical assessment and quality enhancement. Audit results showed some improvements in quality and tech-nical depth near the end of the assessment period but further improvements appear to be warrante In summary, during this assessment period, very effective management was evident in achieving the licensing, testing and commercial operation of Unit 2. Partial resolution of longstanding Unit 1 problems was also achieved. Some areas were identified which need further management atten-tion, but notable initiatives such as the Unit 2 simulator commitment, the Unit 2 self-assessment, the Unit 1 SSFE program and programmatic root cause analysis improvements indicate a strong and long term management dedication to assuring qualit . . .

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2. Conclusion:

Category 2 3. Board Reconcendations:

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I. Preoperational and Startup Testing - Unit 2 (2182 hours0.0253 days <br />0.606 hours <br />0.00361 weeks <br />8.30251e-4 months <br />, 21';)

1. Analysis During the previous assessment period, Preoperational Testing was assigned a Category I ratin The preoperational test program was identified as a notable strength, with well controlled tests and highly professional problem solving. The licensee successfully completed several major testing milestones on or ahead of schedule. Test data were of high quality with a conservative threshold for identifying potential deficiencies. Test results were reviewed in a thorough, well organized manne During this period, the licensee continued to demonstrate a high level of performance while completing the preoperational test program. Strong management oversight occurred at the twice daily planning meetings, test results review was very good and test deficiency resolution was technically sounr Good test personnel performance occurred during the preoperational loss of offsite power test, containment leak rate tests, retests of the reactor head vent system, ECCS flow and pressure drop testing, and testing for minimum continuous spray flow. In many of the large integrated tests, only minor test deficiencies were recorded indicating good planning. Test reports were well organized and complete. Justifications for all test completion deferrals (beyond core load) were valid. Most of the new start up schedule dates assigned for test deficiency completion were realistic and consistent with the work to be performe The licensee's letter requesting deferral of some operational tests was well thought out and technically soun Personnel with experiente gained from the preoperational test program were used in the development of the startup test program. Some problems oc-curred during the transition phase in that the initial procedures still reflected many of the controls, such as construction deficiencies, which were not consistent with the controls that would be required by an operating license. The licensee's performance in the preparation of the startup testing improved during the course of the program. Management was fully involved in the preparation and review of the procedures with completed procedures being approved by the Joint Test Group (JTG) and the On Site Review Committee orior to being issued. plant management tracked test procedure development status and test schedule, and were knowledge-able of the technical details of test conten Licensee performance throughout the entire fuel loading period was good, with activities being performed in a deliberate, and carefully controlled manner. Fuel loading activities were conducted by qualified personnel and interfaces among various groups were smooth. Problems identified were properly evaluated and resolved with management involvement and control evident. Licensee parformance during this evolution was enhanced by utilizing personnel experienced in loading fuel at Unit . ,

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Licensee performance during startup testing was also good. Management oversight and control of testing activities were observed to be good and ef fective with consistent monitoring of plant activities during major plant evaluations and test Strong management attention to the safety implice.tions of problems identified Ly startup testing was eviden Information and work status were presented clearly and objectively at the daily plant meatings. Management presence at these meetings helped in '

resolving schedule conflicts and assigning priorities among many activitie Equipment problems identified during startup testing were properly evaluated and followe Management attention to these problems was consistently evident and factored into later testin For example, a problem with the reactor coolant pump underf requency relays was identi-fied, but not fully resolved for several days. In the interim period, further testing was conducted using offsite power supplies so the problem ,

with the f ast transfer capabilities of these relays would not be a f acto Other instances of problems were identified in configuration control, information feedback and pretest briefing, but licensee corrective action ,

was effective in preventing repetition and these examples are considered isolated case The startup test administration program was logical and comprehensive. A change in the test plan was made toward the end of the 30*. power plateau to defer the MSIV closure test and the loss of offsite power test until after the 50*. power non-transient type test The change was properly reviewed by the appropriate licensee groups and NRC concurrence was

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obtained in a timely manner. This schedule change allowed the thorough exercise of BOP equipment prior to the plant challenging tests at 30*;

powe If a post-trip outage had been necessary, then any problems ,

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identified in B0P equipment could also have been addressed. In another case, the licensee was able to avoid an additional plant challenging trip test from 100*. powe The licensee elected to wait until an operational event resulted in a trip from full powe Until such time, recorders remained hooked up to record the necessary data and the plant was operated with conservatively reduced trip setpoints (Over Pressure Delta T and Over Temperature Delta T). These two examples demonstrated the strong, proactive involvement of licensee senior managemen Particularly effective interfaces were developed between the Operations and Test Groups. Prior to performing testing, pretest briefings were conducted by test personne Also before transient type tests, the

. Nuclear Shift Supervisor reminded the operation crews to monitor key parameters during the tes Test prerequisites, initial test conditions and plant responses were jointly monitored by operations and test persenne Test identified problems were correctly and promptly fed back

, to Operations and corrective actions were properly taken.

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The effective interface between the Nuclear Shift Supervisor (NSS) and test supervision was a notable strength. Prior to the MSIV closure test, the NSS discussed that he would wish to reopen the MSIVs as soon as feasible to restore the normal path of decay heat removal. The reactor tripped within ten seconds of MSIV closure; the NSS oversaw the accurate completion of immediate actions, asked the test supervisor about the i

MSIVs, and was able to quickly reopen them such that no steam generator relief valves we *e actuated. Excellent control of the loss of offsite l power (LOOP) test was also demonstrated. Af ter the plant was stabilized, l the NSS asked the test supervisor about reopening the MSIV In this l case, the test supervisor requested 30 minutes of data under the existing conditions to assure all data trends were capture This request was l

I accommodated by the Operations crew and the desired data was acquire These examples were indicative of the excellent control and cognizance of plant activities that the on shif t operations staf f exhibited throughout this period of numerous parallel on going activities, t

The NRC reviewed Unit 2 startup experience with emphasis on unplanned reactor trips and ESF functions during startup testing through commercial operatio Unit 2 had about an average number of unplanned trips and fewer than average ESF actuation, TS violations and LSSFs compared with similar facilities, as documented in NUREG-1275, "Operating Experience Feedback Report - New Plants" July 1987. Unit 2 completed the startup testing program in three months af ter initial criticality compared with the greater than ten-month average for NUREG-1275 unit The Unit 2 performance was comparable in scrams and substantially better than average in the startup testing program taken as a whole, and demonstrated a very good level of performance during that active period. The success of the startup program was also demonstrated by the high level of operational performance of Unit 2 during the first 180 days of commercial operation with a scram rate less than half the NUREG-1275 average, ESF rate less than one-fourth the average, and no TS violations or LSSFs. Effective senior management oversight, active day-to-day management involvement, and strong technical troubleshooting during the startup testing program were key factors in attaining a high level of performanc In summary, the licensee denonstrated a high level of performance in the area of Preoperational and Startun Testin A slow and deliberate approach to initial criticality was observed and initial low power physics testing was conducted in an almost error-free manne A strong and effective interface was maintained between the licensed operators and the test cre Both groups showed flexibility in cooperating with each other to acquire good test data while enhancing plant safet First hand observations of cont.rol room performance following trips from power showed excellent operator initial response and subsequent licensee problem solving effort ._

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2. Conclusion:

Category 1 3. Geard Recorrendations:

None

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. Training programs  !

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1. Analysis

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A similar area, Training and Qualification Effectiveness, was assessed as Category 2 for Unit I last perio Training was considered as part of Operational Readiness for Unit 2 which was assessed as Category 2. Ample resources were observed to be devoted to training and effectiveness was noted to be good as evidenced by low incidence of personnel error. The performance of license candidates on Unit 1 during the last period was relatively poor declining from the previous assessment period as 9 of 16 SRO and 5 of 17 RO candidates failed various portions of NRC administered exams. Weakened program effectiveness was considered to be indicative of decreased management oversight. The high success rate of license candi-dates on Unit 2 with 16 of 19 passing NRC administered exams is in part due to significant prior operating experienc During this assessment period, the performance of license candidates de-clined at both units as 5 of 6 SR0 and 4 of 6 RO candidates failed various portions of NRC administered exams for Unit 1, and 5 of 19 SRO and 4 of 11 R0 candidates failed various portions for Unit The Unit 1 failures all involved requalification exams and led to the NRC evaluation that the requalification program was unsatisfactory. The Unit 2 decline in candi-date performance was also substantial but was due, in part, to the un-usually high level of previous licensed experience of the initial group of candidates with the recent performance approximating the industry averag The knowledge and use of normal and abnormal procedures was a generic weakness affecting candidates of both units. Additionally, numerous human f actors deficiencies were identified in the Unit 1 emergency operating procedures as was a lack of quality assurance review. The decline in per-formance was indicative of poor management oversight of the training pro-gram and preoccupation with other issues such as dual licensing of opera-tors and Unit 1 simulator adequacy for Unit 2. Evidence of increased senior management involvement was noted late in the period with the

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l commitment to provide a new simulator specific to Unit 2 which should significantly enhance the quality of training available to Unit 2 operators. Similarly, the licensee is implementing commitments to revise the requalification program including learning objectives, lesson plans and examination developmen Training for maintenance personnel, (mergency preparedness personnel, the security force, and engineers was good. Train ug in the area of radiation protection was also good but there is a need fer additional emphasis on ALARA ,

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In summary, the significant weaknesses in the licensed operator training program noted during the period overshadowed the generally sound perform-ance of other training activities and indicated a need for more senior e3nacement attention. These weaknesses, when viewed with weaknesses in knowledge and use of E0Ps during examinations as well as the E0P proced-ural deficiencies and inconsistencies as discussed in the Engineering /

Technical Support functional area, raise a concern regarding the support provided the operators to er.able them to handle significant or unusual transients or event . Conclusion:

Category 3 Improvin . Board Recommendations Licensee:

Increase senior management attention to licensed operator training with particular emphasis on the requalification progra !S$:

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V. SUPPORTING DATA AND SUMMARIES Enforcement Activity No of Violations in Each Severity Level Functional Area V IV III II I Total Unit 1 Plant Operations 3 3 Radiological Controls 2 2 Maintenance 2 2 Surveillance 1 1 Emergency Preparedness 0 Security 0 Engineering / Technical Support 1 1 Safety Assessment / Quality 0 Verification Unit 1 8 1 9 Unit 2 Plant Operations 0 Radiological Controls 0 Maintenance 0 Surveillance 0 Emergency Preparedness 0 Security 0 Engineering / Technical Support 3 3 Safety Assessment / Quality Verification 1 1 Unit 2 Total 1 3 4 Two enforcement conferences were held with the licensee at the NRC Region

! Offices. On July 2,1937, an enforcement conference was held regarding the inoperability of the Unit 1 chlorine detection syste The March 24, 1988, enforcement conference was in regard to defeated containment high-high pressure bistables at Unit No civil penalties resulted frcA the associated violations, r

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B. Inspection Hour Summary Annualizej Actual Hours Percent olant Operations 3388 2756 32 Radiological Centrols 874 711 8 Maintenance 742 603 7 Surveillance 790 643 7 Emergency Preparedness 447 363 4 Security 433 352 4 Engineering / Technical Support 1065 866 10 Safety Assessment / Quality Verification 729 577 7 Preoperational & Startup Testing 2182 1775 _21

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Functional Area A B C D E X Total Unit 1 Plant Operations 2 2 2 6 Maintenance 1 3 4 Surveillance 2 8 1 11 Engineering / Technical Support 1 2* 3 Unit 1 Total 5 3 0 8 7 1 24

"LER 87-13 contained two related reportable event Number By Cause Code Func tional Area A B C D E X Total Unit 2 Plant Operations 1 3 2 1 1 8 Maintenance 4* 1 5

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Engineering / Technical Support 2 1 3 Preoperational and Startup Testing 5 4 3 3* 2 17 1 Other 1 3 4

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Unit 2 Total 17 9 2 6 8 2 44

• LER 87-12 contained two related reportable event Cause Codes:

Combined Total $

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A Personnel Error 22 32 B Design, Manufacturing, Construction '

or Installation Error 12 18 C External Cause 2 3 0 Defective Procedures 14 21 E Component Failure 15 22 X Other 3 4 The following cor. mon mode events ware identified:

Approximately one-third of the events are attributable to personnel error; surveillance activities accounted for the greatest fraction (36*.) of these event _ _ _ _ _ _ - _ _ _ _ _ _

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Licensee Event Report Causal Analysis (Continued)

While 12 events were attributed to design, manufacturizing, construction or installation errors, most were identified during pre operational and start-up test of Unit 2 as would be anticipate Inadequate procedures accounted for 14 events of which 9 were related to the surveillance progra '

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, 'E*puo # ENCLOSURE 3 UNITED STATES

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" ,4 - NUCLEAR REGULATORY COMMISSION g ..

REGION I

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• * 475 ALLENDALE ROAD

• • , KING OF PRUSSIA, PENNSYLVANIA 1940S

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AUG 7 W88 Docket Nos. 50-334 50-412 Ouquesne Light Con.pany ATTN: Mr. J. D. Siab Vice President Nuclear Group Post Office Box 4 Shippingport, Pennsylvania 15077 Gentlemen:

Subject: Systematic Assessment of Licensee Performance (SALP) Report No /87-99 and 50-412/87-99 The NRC SALP Board has assessed the performance of activities at the Beaver Valley Power Station, Unit 1, for the period March 16, 1987 - May 31, 1988 and Unit 2, fer the period March 1,1987 - May 31,198 The results are docu-mented in the enclosed SALP Board Repor A meeting at the Beaver Valley

. Emergency Response Center, Shippingport, Pennsylvania to discuss this assess-mett will be scheduled by separate correspondenc At the SALP meeting you should be prepared to discuss our assessment, particu-larly the area of Training Program Your discussion should specifically address your assessment of the root causes for deficiencies in the licensed operator training program and both short and long-term corrective actions planned or initiated to ensure permanent correctio Your cooperation with us is appreciate

Sincerely,

& Qh_= AS William T. Russell Regional Administrator Enclosure:

SALP Report Nos. 50-334/87-99 and 50-412/87-99 l

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Duquesne Light Company 2 i

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J. J. Carey, Executive'Vice President, Operations ,

_" J. O. Crockett, General Manager, Corporate Nuclear Services >

W. S. Lacey,' General Manager, Nuclear Operations N. R. Tonet, Manager, Nuclear Engineering T. P. Noonan, Plant Manager J C. E. Ewing, QA Manager X. D..Grada, Manager, Nuclear Safety  !

Public Document Room (PDR) .

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- Local Public Document Room (LPOR)

Nuclear Safety Information Center (NSIC) *

r NRC Resident Inspector Commonwealth of Pennsylvania Chairman Zech Commissioner Carr

. Commissioner Roberts

. Commissioner Rogers'

K. Abraham, PA0 (10 copies)

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,t o ENCLOSURE 4 1, M U,7 * S" SNgotgat, PA 15077m

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Pe Nuces Gme 44+ 64 Mas September 14, 1988 U. S. Nuclear Regulatory Commission Attn Document Control Desk - -

Washington, DC 20555 Reference: Beaver Valley Power Station, Unit No. 1 and No. 2 BV-1 Docket No. 50-334, License No. DPR-G6 BV-2 Docket No. 50-412, License No. NPF-73 Systematic Assessment of Licensee Performance (SALP) Report Nos. 50-334/87-99 and 50-412/87-99 -

Licensed Operator'Trai'ning Program Gentlemen: #

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The purpose of this letter is to dccument the actions that have been taken to improve the BVPS Licensed Operator Training Program as discussed during the site meeting on August 31, 1988. The systematic Assessment of Licensee Performance (SALP) Report Nos. 50-334/87-89 and 50-422/87-89 provided valuable insite on needed improvements in this are During the SALP period, we had initiated several program improvements directed toward upgrading the overall training program, and the actions taken are provided below. We believe that these actions, in concert with NRC initictives in this area, will result in significant improvements on future requalification examination In September of 1987, after extensive review of our Requalification Program, we committed to:

• Revise the format of the BVPS Requalification Program to reflect the subject areas defined in the K & A Catalog (NUREG 1122) as verified by the BYPS Job Task Analysi * Over a two year training program, we would produce a Boavor Valley Specific K & A Catalog for use by Duquesne Light Company and the NRC and produce learning objectives, lesson plans and examinations based on the K & A Catalo * Integrate training on knowledge in the classroom sotting with associated abilities on the simulato The Requalification Program has been rostructured to those commitments which are currently 60% complet k [ Of 2. $.O' WP ,

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Benvar VallOy Powar Station, Unit Nos. 1&2 s D6ck3t No. 50-334, Licsn00 No. DPR-66

. . Dockst No. 50-412, Licsnco No. NPF-73

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During March of 1987, we contracted the PQS Corporation to independently review our revised Requalification Program to determine the degree to which our program enhances the licensed operators ability to:

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Operate BVPS in a psfe and efficient manner, and prepared for success

Be on Duquesne Light and NRC administered requalification exam PQS determined that the licensed operator Requalification Program  !

had improvei over past programs and was adequate in scope and centent ,

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to enhance the operators' ability to meet these program object ive In addition, we determined that the program meets the requirements of present NRC re'gulations and policies, INPO guidelines and other industry standard .

The PQS Corporation was also contracted to administer the 1987/88 requalification written examination and to provide an independent evaluation of the result The results of the examination and the

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evaluation were very goo '

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During the time frame of our last requalification training cycle, "

the administration of the requalification process became an industry issu Since that time, DLCo has maintained a constant awareness of I the revised policies associated w8'h the revised requalification  :

proces Communications with utility and NRC personnel have been [

maintained to stay abreast of the new requirements. DLCo has been l represented at all scheduled meetings and workshops associated with the current requalification process.

! DLCo has been active in developmental work on the revised i requalification process, and has contracted with Westinghouse [

, Electric Corporation to assist in the development Of the required ,

materials. The status of the work is provided belo ,

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"Cenvar VcilGy Pow 3r Station, Unit Nos. 1&2 s* DDckat No. 50-334, LicGnco No. DPR-66 3 . Dockat No. 50-412, Lic;nso No. NPF-73

Page 3 Frozen Simulator Examinations Frozen Simulator Examinations were developed and used during the 1987/88 cycle for training purposes. Exams have been recently developed for our upceming requalification examinations. These examinations have a total of 94 questions for Section Section B Open Reference Questions 52 open reference exami6ation questions have been developed, reviewed, and are awaiting SRO validatio Additional questions are being develope Simulator Scenarios 15 simulator scenarios have been developed and validated by

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operating crew , ,

Job Performance Measures .

108 items, 47 of which are drafted, have been identified for;use as job performance measures. The drafted measures will undergo SRO validatio We have communicated with the BVPS Chief Examiner on two samples, and the feedback was goo Overall, we have expended considerable effort to ensure that our t Requalification Program exceeds industry and regulatory standard '

Wo believe that the proper revisions have been made to the program to ensure that our operators improve their performance on Requalification Examinations to complement their demonstrated abilitics in safely operating our plants.

If you have any questions about this transmittal, please contact my offic '

very truly yours, M

l . D. Sieber

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Vice President Nuclear Group

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I cc Mr'. J. Beall, Sr. Resident Inspector

- 49r. W. T. Russell, NRC Region I Administrator

Mr. P. Tam, Project Manager i

Director, Safety Evaluation & Control (VEPCO)

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