IR 05000334/1988099

SALP Repts 50-334/88-99 & 50-412/88-99 for June 1988 to Aug 1989.Category 1 Assigned in Areas of Plant Operations, Emergency Preparedness,Security & Preoperational & Startup Testing

ML19332E176
Person / Time
Site:	Beaver Valley
Issue date:	11/24/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19332E174	List: IR 05000334/1988099 ML19332E173
References
50-334-88-99, 50-412-88-99, NUDOCS 8912060331
Download: ML19332E176 (35)

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U. S. NUCLEAR REGULATORY COMMISSION n

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REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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REPORT 50-334/88-99

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REPORT 50-412/88-99

DUQUESNE LIGHT COMPANY

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BEAVER VALLEY POWER STATION, UNITS 1 AND 2 ASSESSMENT PERIOD: JUNE 1, 1988 - AUGUST 31, 1989 BOARD MEETING DATE: OCTOBER 17, 1989

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8912060331 891124 ADOCK0500g4 PDR Q

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NOV 211989

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

~ J. O. Crockett, General Manager, Corporate Nuclear Services

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W. S. Lacey, General Manager, Nuclear Operations N. R. Tonet, Manager, Nuclear Engineering T. P. Noonan, General Manager, Nuclear Operations S. C. Fenner, QA Manager

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K. D. Grada, Manager, Nuclear Safaty

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b H. R. Caldwell, General Superintudent, Nuclear Operations Public Document Room (PDR)

local Public Document Room (LPDR)

Nuclear Safety Information Center (NSIC)

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NRC Resident Inspector

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i Commonwealth of Pennsylvania

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Chairman Carr

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. Commissioner Rcberts Commissioner Curtis Commissioner Rogers

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Region I Docket Room (with concurrences)

Management Assistant, DRMA (w/o enc 1)

W. Russell, RA'

T. Martin, RA D. Holody, EC

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-W. Kane, DRP W. Hodges, DRS M. Knapp, DRSS J. Stolz,-NRR E. Wenzinger, DRP C. Cowgill, DRP P. Tam, NRR

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J. Beall, DRP

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J. Lieberman, OE J. Taylor, Acting DEDO

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PA0 (10) SALP Reports Only J. Dyer,- EDO

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l SUMMARY OF RESULTS A.

Overview During tne assessment period both units operated for the majority of time at power.

Unit 1 shutdown for approximately nine weeks to repair reactor coolant

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system and steam operator leaks and Unit 2 under went its first refueling outage.

In September 1989, Unit I bepn a : ore life extension program designed to move the scheduled refoeling outage in order _to establish a

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_ seperation from the Unit 2 scheduled refueling outage. A nigh number of trips and transients were experienced by both units throughout the period as a result of various personnel errors and component failures.

In operation, the organization performed well and management involvement and operator response to plant transients were identified strengths. The performance of the balance of plant equipment was improved based on the reduced number of secondary components failures resulting in power reductions or trips.

However, the incidence and impact of personnel errors by operators increased.

The radiological controls, chemistry, and effluent controls programs were well defined and effectively implemented.

The routine radiation protection organi-zation was reorganized which strengthened the ALARA group and established an industrial-safety and health group.

The licensee was generally responsive to NRC concerns, however, the previously identified concern of a need to improve contamination control, and supervisory oversight of signihcant radiological

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work activities was not resolved, l.

The maintenance program was well controlled, with improvements in post

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maintenance testing and trending.

The surycillance program implementetion resulted in a high number of unnecessary challenges to safety systems due to

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personnel errors.

Housekeeping and overtime control during outages were areas

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identified as needing improvements.

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The emergency preparedness program was effectively implemented. The response i

of key decision makers during exercises of the emergency plan and the close working relationship between the licensee and local c,.aunities were strengths. Good initiatives were clearly demonstrated and a substantial

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effort was made to ensure all programmatic areas were well maintained.

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The security program was effective and performance oriented with management

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attention clearly evident in all aspects of program implementation. The efforts expended to maintain an effective program were commendable and demonstrated a commitment to the establishment a hinh quality security program.

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The engineering and technical support programs incorporated management initiatives which improved plant safety and performance.

The engineering and technical support response to NRC initiatives was timely and thorough in most cases. The response to plant events and technical issues continued to improve.

The licensee demonstrated a positive attitude towards compliance with NRC safety initiatives and often went beyond mere compliance to achieve a higher level of safety and quality.

The programmatic root cause analysis program and proactive licensing staff were examples of the licensee's positive attitudes.

Significant improvements were made in the area of licensed operctor training.

All management positions in the training department were filled and Emergency Operating Procedures identified deficiencies were corrected. Nonoperator training activities were effective throughout the period.

The challenge'for the licensee is to reduce the number of unplanned trips and transients by reducing the number of personnel errors. Also, the licensee needs to strengthen management oversight and self-assessment capabilities in the area of radiological controls.

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Facility Performance Analysis Summary l

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J Rating Rating

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Functional Area Period period Trend

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Plant Operations

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B.

Radiological Controls

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Maintenance / Surveillance *

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Emergency Preparedness

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Security

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Engineering / Technical Support

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Safety Assessment /

Quality Verification

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Training Programs

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Preoperational and l

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Startup Testing

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previous period.-

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. Training Programs is not generally a' separate functional area,

but was rated separately in the previous period-due to problems

in that specific area.

Improvements were noted in this period L

and it is not expected that this will be a separate functional

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area in the next SALP report.

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• • • -This area not rated during this period.

Preoperational and Startup-Testing for Unit 2 was completed in the previous period.

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i III, PERFORMANCE ANALYSIS

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A.

Plant Operations (1975 hours0.0229 days <br />0.549 hours <br />0.00327 weeks <br />7.514875e-4 months <br />, 50%)

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Analysis The previous assessment, evaluated as Category 1, was based on sound f

operational performance with few reactor trips and forced power reduc-

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tions. Notable strengths were observed in management involvement, operator event response and problem solving.

Special note was made of the absence of plant trips or significant operational events due to personnel error. A decrease in power reductions caused by BOP components was also observed from earlier SALP periods.

During the current period, management oversight and control of operations was generally good.

Overall, operators exhibited good con. mand and

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control and were knowledgeable and competent.

However, the incidence and

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impact of personnel error by operations personnel increased from the previous period. Good performance and reliability were observed in

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Balance of Plant (BOP) equipment.

The quality of operator performance in response to plant transitats remained high.

The involvement of management in providing oversight and control of operations was evident on a daily basis during planning meetings, inter-departmental interface meetings, and management plant tours.

Emphasis was consistently given to improving procedures and determining and addressing root causes of events. Operating procedures were generally cood and

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operations personnel were instructed to initiate engineering review l

requests for repetitive component probicms.

Management support for the

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attainment of degrees by licensed operators has remained good.

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Attention to personnel safety by all levels of management was high.

Some unsafe personnel practices were identified in the performance of work in containment, but at the end of the period the site had completed over two

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and one-half million consecutive man hours without a lost time accident.

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A decline in performance was observed in the area

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personnel during the period. Two reactor trips were experienced during

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t.he power operation due to licensed operator e.vor reading the wrong procedure step, and not resetting a feedwater isolction (during a busy startup).

Errors by operations per:,onnel were also the cause of four other events during operations.

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The four events during c,perating activities included a mistake during river water flow adjustment which led to the automatic start of the i

standby pump, and an automatic feedwater isolation after operators lef t

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steam dump control in manual vice automatic during turbine startup

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activities.

The other two events involved AFW automatic starts during the same busy Unit 2 cooldown.

During the previous assessment period, no

reactor trips and three operational events were caused by operations personnel error. All of the errors involved tagging out or restoring equipment, j

~In the previous SALP periods, Unit I had a consistent decrease in signi-i ficant forced power reductions caused by balance of plant (BOP) components from twelve to nine to four. There were three such forced reductions during the current period.

The modifications completed late in the previous _ period appear to have eliminated the accelerated wear of the feedwater control valves which was the root cause of many Unit 1 forced

power reductions.

No such reductions were experienced during the period

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at Unit 1.

Two Unit 1 trips were caused by BOP hardware failures: tiw spurious opening of a main feedwater valve motor breaker and the failure of an electro pneumatic transducer in the feedwater control system.

Unit 2 experienced five significant, unrelated forced power reductions

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caused by BOP components.

In all cases, the unit remained at reduced power and returned to full power after completion of repair activities.

Unit 2 experienced one at power trip related to BOP hardware failure.

The trip followed a mechanical failure in the internals of a feedwater control valve.

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The component-caused trip rate at Unit I was low, consistent with the previous period and the Unit 2 rate showed a decrease. The low incidence of BOP caused events and outages is indicative of good senior management attention to B0P equipment and the potential for impact on plant opera-tions and safety.

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The prompt and accurate operator response to plant transients hoted as a strength in the previous assessment continued to be evident during this period. Control room professionalism and operator attitude were very good.

Both units have operated on a six shift rotation since January, 1988. The staffing levels of operators on each shift were adequate, but showed a steady decline during the period. This decline was caused by attrition and the absence of any classes of operators being awarded licenses. At the end of the period, there were no individuals in the training system being prepared to receive operator licenses, so the downwad trend in shift staffing is expected to continue. The presence of extra licensed and non-licensec: operators on shift was previously a strength and the reduction was a potential contributor to the increase in operator error, especially during busy periods.

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Particularly notable at Unit I were the responses to the scram and safety injection (SI) caused by de-energirt tion of the auxiliary scram panel. At Unit 2, good operator actions allowed a controlled power reduction and

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turbine unicading in response to main vacuum degradation without requiring a reactor trip. Also notable at Unit 2 was the stoppage by operations personnel of an RCS leak in containment, thus preventing the need to complete a forced shutdown.

Licensee management was closely involved in the troubleshooting and corrective action planning. This was evident in

• he identification and resolution of the design flaws which caused the SI after de-energizing the backup scram system at Unit I and the mechanism involved in an expansion joint failure on a Unit 2 component cooling water pump.

Licensee event report (LER) root cause analysis was generally good

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with weaknesses identified by the NRC in only 2 of the 45 LER's reviewed.

In summary, an increase was noted in the incidence and impact of personnel errors by operations personnel.

Good performance in BOP hardware was evident with relatively low impact on operations. Trips due to component failures remained at a low level at Unit I and decreased at Unit 2.

Notable strengths were observed in management involvement, operator event response and problem solving.

The NRC observed a declining staffing level of licensed operators with no replacement classes in progress.

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Conclusion Category - 2 BOARD RECOMMENDATION Licensee: None NRC: None B.

Radiolooical Controls and Chemistry (9%, 338 hours0.00391 days <br />0.0939 hours <br />5.588624e-4 weeks <br />1.28609e-4 months <br />)

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Analysis The Units 1 and 2 Radiological Controls and Chemistry Programs were rated Category 2 for the last assessmant i eriod.

The NRC found that overall licensee efforts to trar. sit from single to dual unit operations were wc11 managed. These efforts included increases in staffing of the radio-logical controls organization to support dual unit operations and compre-hensive training of personnel on the differences between the two units.

However, weaknesses were identified in the ALARA program and in supervisory and management oversight of significant radiological tasks, and the self-identification and corrective action system.

Radiation Protection A generally well defined occupational radiation protection program was implemented during this assessment period.

Management was involved in

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setting and monitoring performance goals for this functional area.

Radiation protection program performance indicators were routinely provided to management for review.

The enforcement history in this area has been good with only one licensee identified violation noted.

This violation involved inadequate

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radiological controls for steam generator work. The licensee took extensive corrective actions for the problem.

The licensee reorganized the routine radiation protection organization during this assessment period.

The reorganization was a good licensee.

initiative that strengthened the ALARA group and established an industrial safety and health group. The overall radiction protection organization for routine operations was well defined and adequately staffed.

NRC observations during this assessment period found that the augmented radiation protection organization (i.e., licensee plus contractor personnel), established to support the Unit 2 outage, was not well

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Proolems such as poor coordination and control of steam generator work, identified during review of Unit 2 outage activities, and discussed later in this assessment, were attributed in part to the lack of a well defined outage radiation protection organization and associated responsibilities.

A well defined and adequate initial training and qualification program was implemented for contractor and permanent radiation protection personnel-and radiation workers. The training and qualification resulted in personnel having a good understanding of work, and performing their tasks with few personnel errors. An adequate continuing training program was also implemented.

Overall, management attention to training was evident.

Inter-and intra-departmental communications (e.g., between operations and radiation safety personnel) were considered good. A communication problem between the radiation protection and security organizations identified during the last assessment period was corrected during the present period and ample staffing was available to support the Unit 2 outage.

Quality assurance (QA) audits of program implementation examined all appropriate areas. However, the audits were compliance oriented in nature. This weakness had also been observed during the previous assess-ment period. Outside technical specialists were rarely used to examine functional program areas. QA persoanel experience in the area of radia-tion safety was minimal. Consequently, evaluation of radiation safety program adequacy and performance relative to industry starlsrds and performance continued to be limited. The licensee has not uden responsive to this concern.

Review of the routine radiation protection self assessment program during this period continued to indicate the need for improvement.

Corrective actions continue to be incident or observation specific, rather than generic, i

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A number of weaknesses were observed in various areas during this

assessment period. These included use of drinking fcuntains in the t

radiological controlled area (RCA), placement of frisking stations outside the RCA, improper passing of documents across RCA boundaries, identification of candy wrappers in the RCA (indicating ingestion of food

in the RCA), improper use of radioactivity sample counting equipment, and weak procedures for hot particle exposure controls.

Licensee QA and

self-assessment programs were not effectively used to improve the radiation protection program, j

Reviews of the external and internal exposure controls program during this assessment period found that radiological surveys to support on going work

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were comprehensivt. Significant improvements were made to steam generator work control procedures to address NRC concerns identified during the last assessment period.

Internal exposure control concerns identified during

the last assessment period were also addressed by the licensee this l

period. There were no internal exposure concerns identified this i

assessment period.

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Licensee control and minimization of contaminated areas and contamination wa., good. A small percentage of the station's radiological controls area is contaminated and housekeeping has improved. However, significant

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problems were noted during the outage, prompting NRC discussions with station management and subsequent action by the licensee to further improve housekeeping.

• The aggregate average occupational personnel exposure at the station for the past three years (1986-1988) compared favorable with industry

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averages. The licensee aggressively pursued resolution of ALARA concerns

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identified during the last assessment period.

Reviews during this

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assessment period found that the licensee was taking action to reduce the source term and general area dose rates in containment by use of shielding and primary system decontamination. Also, cobalt-containing equipment (e.g., fuel grid straps and fuel debris screens) was being removed and replaced with non-cobalt materials. The licensee was also removing

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i unnecessary snubbers to reduce surveillance related personnel exposure.

In the area of staffing, the licensee also provided additional staff te l

perform ALARA reviews of on going work. ALARA exposure goals were

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generated for each station department and monitored by the ALARA committee. ALARA goais for work were reasonable and were compared to actual accumulated exposures.

Although the licensee responded to the majority of ALARA concerns identified during the last period, weaknesses in the ALARA area continued l-this assessment period in the area of coordination, control and supervisory oversight of significant radiological tasks (e.g. steam generator work).

For example, reviews during this period found that poor communications and failure to check equipment resulted in unnecessary personnel exposure due te equipment such as airlines and communication headsets not operating properly.

In addition, coordination delays resulted in contractor radiation protection personnel waiting for extended periods of time in radiation areas to support workers.

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The above problems appear to be due, in part, to the extensive use of contractor radiation protection personnel to oversee' radiological i

significant tasks with minimal involvement and direct oversight by l

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Radioactive Effluent Monitoring and Control

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The licensee has in place an effective program for control of liquid and gaseous effluents. A radiological controls group reorganization during this assessment period centralized the organizational responsibilities for

this functional area. This has resulted in a clearly defined management

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structure with responsibilities clearly assigned. This is considered a good management initiative.- QA audits were thorough and of excellent technical depth to identify programmatic problems. Technical specialists

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were used where appropriate.

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The licensee demonstrated viable approaches to technical issues as

.vidu ced by the preparation, te!.ing and implementation of software used in assessing radioactive effluents. No deficiencies or unacceptable

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practices were observed during this assessment period. Overall licensee performance in this area was good.

Environmental Monitoring NRC review during this assessment period found that the licensee had implemented an adequate Radiological Environmental Monitoring Program (REMP). The results of QA audits of the program and REMP quality control programs were effectively used by the licensee to monitor and evaluate the performance in this area. The audits also provided effective oversight of contractor activities.

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NRC review this period found that the licensee was implementing an effective radwaste and transportation program. QA audits of this area were comprehensive. Radwaste was properly stored. Overall performance was good.

Summag In summary, the licensee is implementing a generally well defined radio-logical controls program. The training program contributes to a good understanding of procedures with few errors.

The licensee has been generally responsive to NRC concerns as evidenced by the actions taken for the weaknesses identified during the last assessment period. However, there continues to be a need to improve coordination, control and super-visory oversight of significant radiological work activities, in parti-cular, work being done by contractor personnel. This concern was identi-fied during the last assessment pariod. Also, there continues to be a need to improve housekeeping and contamination control during outages.

The internal audits of the environmental monitoring, radwaste, and transporta-tion programs were comprehensive, and of good technical depth.

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There is a need to improve the quality of audits of the in plant radiation-

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protection program to provide for additional technical review of program

adequacy. Also, the in plant radiation protection self-assessment program

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needs to be improved to focus corrective actions on the generic root cause

of identified concerns.

The chemistry, effluent monitoring and control,

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and radwaste transportation programs continued to be effectively imple-i mented, j

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Conclusion

Category - 2 l

BOARD RECOMMENDATION Licensee: Strengthen supervisory and management oversight and procedural controls for significant radiological tasks. This is a repeat recommendation from the last SALP.

NRC: None C.

Maintenance / Surveillance (455 hours0.00527 days <br />0.126 hours <br />7.523148e-4 weeks <br />1.731275e-4 months <br />, 11%)

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Analysis During the previous assessment period, Maintenance and Surveillance were each evaluated separately as Category 2.

Generally, good control of

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maintenance and surveillance activities was noted with a relatively low

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number of unnecessary challenges to safety equipment.

In maintenance, concerns were identified in the area.of post maintenance testing, trending, and procedural inadequacies.

In surveillance, configuration

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control and procedural inadequacies were identified as areas needing improvemant.

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l Maintenance procedures and policies were typically followed well by

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L station personnel. Maintenance program goals'were established and schedules were met. The backlog of outstanding maintenance items was well managed.

Day-to-day preventive and corrective maintenance of safety L

related components received good preplanning and supervision.

The pre-

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ventive maintenance program was well developed and implemented.

During this assessment period, the licensee has been developing an innovative predictive maintenance program utilizing such technology as infrared thermography. The proper use of clearances and well coordinated interface among the various disciplines (Health physics, Quality Control, etc.)

necessary to accomplish maintenance activities were observed in the field.

The licensee had a strong calibration program for measuring and testing equipment (M&TE), however, weaknesses were identified in the control of M&TE including the issuance of M&TE past due for calibration for safety l

related work and the failure to properly segregate M&TE past due for calibration from calibrated M&TE.

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Maintenance personnel are trained to work on both units and were found to be knowledgeable of station procedures and their assigned tasks. The licensee maintained a streng maintenance training program which was enhanced by the use of several training mockups, including breakers, vaives, reactor coolant pump seals, snubbers, and steam generator manways.

Quality Control (QC) involvement in maintenarce activities was very good, Quality Control inspectors were present during significant activities and s

performed in process inspections on ongoing maintenance work activities.

Discussions with QC personnel found them to be knowledgaable of activities observed.

During the current period, the licensee formalized post-maintenance testing into a station precedure which details testing requirements following corrective maintenance.

This has resulted in a consistent and standardized post-maintenance test program.

In the period, there were no observed instances of inadequate post-maintenance testing compared with two in the previous period.

Also during this period, the licensee developed and formalized a mainte-

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nance trending program. Where repeated corrective maintenance was noted, a multidisciplinary group (Maintenance, Instrumentation and Control, Operations, Engineering, etc.) determined whether a design change or increased preventive maintenance was appropriate.

This multidisciplinary review is a notable strength and has led to a number of design changes.

The quality of maintenance and surveillance procedures has improved.

l Ongoing review has improved human factors considerations and the level of detail in many of the procedures.

In the last assessment period, several events were attributed to procedure deficiencies.

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none of the challenges to safety systems was evaluated to have been caused by procedure inadequacies.

Maintenance activities were generally well planned and organized. During outages, frequent meetings were held with the various departments to ensure that the maintenance and surveillance activities were well coordi-nated. The skill of the permanent maintenance technicians and contracted craft was evident by a low number of repairs that required rework. One maintenance activity that was particularly noteworthy was the repair of a tube leak in a Unit 2 steam generator (SG) caused by a foreign object.

The licensee organized a Foreign Object Search and Retrieval (FOSAR) team and brought in a full-size SG mockup. Use of the mockup allowed the FOSAR l

team to develop the necessary tools and techniques necessary to dislodge l

and remove the object with minimal radiation exposure.

Conversely, errors

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I made by maintenance technicians delayed the recovery from the Unit 2 first

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refueling outage. An unaccounted for seal pressure ring on the Reactor Vessel Level Indicating System rendered that system inoperable and required that the unit be shut down and cooled down.

Shortly thereafter, the discovery of an incorrect flow orifice and a lack of a required orifice in the resistance temperature detector manifold required Unit 2 to be shut down and cooled down again.

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During power operation, plant housekeeping improved as compared to the

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previous period. However, during the Unit 2 refueling outage, house-

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keeping was weak.

Excessive numbers of tools and parts and various other

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debris were observed in the radiologically controlled areas. There was also a continuing problem with unrestrained equipment such as ladders and

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large tool cabinets being left adjacent to equipment important to safety, i

Additional management oversight and training for outage personnel

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concerning site housekeeping requirements is required to improve

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housekeeping during optages.

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Of the several thousand surveillance tests performed at both units during

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the period only three technical-specification-required surveillance tests

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-were missed due to administrative / personnel errors. The license maintained

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a very good program to ensure that surveillance tests were performed as scheduled.

There were sight challenges to safety systems caused by personnel errors i

during surveillance testing, including two reactor trip and one safety i n.1ecti on.

Five events were caused by operators and three by maintenance I & C technicians. The too reactor trips and three inadvertent Engineered Safety Feature (ESF) actuations occurred due to failure to follow the surveillance procedures as written. The SI resulted when licensed operators failed to proparly assess plant conditions prior to authorizing c surveillance test to be performed. An emergency electrical bus was inadvertently de-energized by electricians due to an inadequate review of

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electrical schematic diagrams. An automatic feedwater isolation occurred

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due to insufficient preplanning.

Licensee senior management recognized the increase in personnel errors and conducted comprehensive event root i

cause analyses.

Implementation of corrective actions commenced late in the assessment period. Two additional events were caused by mistakes made i

by operators during the conduct of post maintenance tasting.

Combined with the events during surveillance testing, this is indicative of a

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weakness in attention to detail by operations personnel during the conduct

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of routine tests.

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Weaknesses were identified in management oversight of worker and operator overtime during the Unit 2 outage such that licensee procedures and

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L Technical Specification limits were exceeded.

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licensed operators worked overtime in excess of Technical Specification

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limitc. The licensee limits on overtime for personnel not covered by NRC requirements were often exceeded.

In many cases first line supervisors of safety related work were on shift for five or more weeks, seven days a

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I week, 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> a day. Two events during the outage (e. safety injection i

and a reactor trip) were directly attributed to decisions made by a supervisor who worked over 60 consecutive 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> days. The authorization of overtima in excess of Technical Specification limits was pervasive and

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not limited to unusual circumstances.

The assignment to work on activi-

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l ties perceived to be on the outage critical path was felt to be sufficient l

justification for all necessary overtime. As mentioned above, mistakes during two maintenance activities directly caused the extension of the

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outage by approximately three weeks.

Senior site management did not approve the excessive overtime and, in the case of the plant manager, was not aware of the authorization of the use of overtime in excess of Technical Specification limits.

In summary, _ licensee activities associated with maintenance were well controlled.

Improvements in post maintenance testing, trending, and i-procedures were noteworthy. However, the high number of. unnecessary challenges to safety systems during surveillance testing due to personnel error indicates need for further improvements. Continued emphasis on

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' housekeeping during outages is needed. Management oversight and control of overtime during outages also requires improvement.

,

2.

Conclusion Category - 2 Board Recommendation Licensee: None NRC:

None D.

Eiargency Preparedness (296 hours0.00343 days <br />0.0822 hours <br />4.89418e-4 weeks <br />1.12628e-4 months <br />, 7's)

1.

Analysis During the previous assessment period the licensee was rated Category I based upon the strong performance of the emergency response organization during the partial participation exercise, the licensee's positive, timely I

and_ technically correct approach to the findings of the Emergency Pre-paredness Implementation Appraisal (EPIA), and the continuing close

!

relationship with offsite agencies.

During this assessment period, a partial _ participation and a full parti-cipation exercise were conducted in October 1988 and August 1989, respectively. In addition, a routine safety inspection of program

,

l activities was performed. This included a comprehensive review of revi-sions to the emergency action levels (EAL) and walkthroughs of several shift operating staffs to demonstrate use of new EAL's in classification of events.

No violations were issued this SALP period.

,

In both exercises it was noted that positive command and control of all emergency response facilities (ERF) was demonstrated by the respective managers, communications and notifications between the ERF's were effi-

,

!

cient, staff members demonstrated good use of implementing procedures and l

recordkeeping, and accurate and timely protective action recommendations were issued to offsite authorities.

The licensee's ability to implement the Emergency Plan and Implementing Procedures was effectively I

demonstrated.

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The new EAL's, which were developed in response to NRC initiatives provide the operations staff with a straightforward approach to event classifi-cation.. Accurate and consistent demonstrations to :lassify emergency

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conditions, formulate protective action recommendations, perform dose calculations based upon source term information, and immediately= notify offsite authorities were' observed among all shifts. Also Region I

'

determined-that audits had been thorough, adequate.in scope and in

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accordance with regulations. The licensee's implementation of corrective

- actions has been timely and effective, consistently meeting schedules, j

!

i Appropriate management involvement in the EP program is provided at'the corporate and site levels.

Change made to the Emergency Plan and proce-dures received proper manegement attention and did_ not decrease the omr-all effectiveness of the program.

Further, corporate management is frequently involved.in those emergency preparedness activities relating to coordination with offsite support groups.

This includes. interfaces on a

'

regular basis with officials from the States of Pennsylvania, Ohio, and West. Virginia as well as meetings with members of the local community.

. Corrective actions in response to plant events consistently have been

- effective.

For each degraded plant-condition requiring use of EAL's, the onshift staff promptly and properly made the Unusual Event (UE) classi-fication.

In all cases' notifications of offsite organizations were also prompt. Operators were very conservative in evaluating events.

For example, a fire at a nearby industrial facility triggered one LC due to

. possible toxic gas release.

In two other instances, the onsite release of

- a flammable or toxic gas initiated a UE classification based on conser-vative estimates of potentiel concentration. Similarly, the control room staff's response to other initiating conditions during the period (also classified as Unusual Events) showed timely resolution and the same conservative philosophy.

All positions within the emergency response organization are identified and authorities and responsibilities well defined. A viable training program is also defined and implemented with dedicated resources.

N rsonnel are well trained and qualified for the positions to which they are assigned.

Criteria for pers..nnel to qualify as members of the response organization includes classroom instruction as well as perfor-mance-based training.

It was noted during the exercises and conduct of

. walkthroughs that personr:ei demonstrated a thorough knowledge of imple-mer. ting procedures, and these procedures and established policies were rigidly followed.

In addition to the Director, Emergency Preparedness, eleven (11) full-time site and contractor staff were assigned to maintain

,

routine activities and efficiently implement the program. The training department staff is also actively involved in the program by providing support dLring exercise scenarios and qualification of response personnel.

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Emergency response facilities were appr:priately maintained throughout the period and were effectively used'to support exercise response. A new Joint Media Center was designed and constructed. During the 1989 exercise it provided improved capability for the licer ee in dealing with media and outside pubite relations personnel.

-In summary, the licensee has provided the resourr.es, staffing, and leader-

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ship necessary to effectively implement a quality emergency preparedness program. Demonstration of emergency response b,'r key decision makers during actual events, exercise scenarios, and walkthroughs continues to be strong. The close-working relationship between-the licensee and local communities was evident.throughout the period. The licensee has clearly demonstrated good initiatives and made a substantial effort to ensure all programmatic areas.are well maintained.

2.

Conclusion Category - 1 BOARD RECOMMENDATION Licensee: None NRC: None

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E.

Security (236 hours0.00273 days <br />0.0656 hours <br />3.902116e-4 weeks <br />8.9798e-5 months <br />, 6%)

1.

Analysis During the previous assessment period, the licensee's performance was rated as' Category 1 and no major regulatory issues or violations were identified by the NRC.

Some startup problems were encountered with.new

- systems and equipment,' largely as a result of integrating Unit 2 with Unit H

1 and implementing the established physical security program for both

units. Maintenance of security systems and equipment was also found to.be-

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sparse early in that assessment period. More aggressive management.

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attention to the security program occurred during the later portion of the period and that concern was resolved.

During this assessment period there was one routine unannounced physical

'

security' inspection conducted by region based inspectors.

Routine

inspections by resident inspectors continued throughout the period. No-regulatory issues or. violations were identified and a continuation of aggressive management attention to the program was apparent.

The licensee developed and implemented an excellent screening program to expedite the plant access authorization process for contractor employees during this period.' The screening program is carried out by security l

I personnel and was particularly helpful in processing the large number of L

contractor personnel who were needed for the outage during this period.

I The licensee also modified the fitness-for-duty program, adding a require-'

l ment for chemical testing of all-personnel prior to granting unescorted

access to the site protected area.

In conjunction with the fitness-for-l; duty program, the licensee also conducts periodic onsite searches for I

drugs with drug detecting dogs.

Further program modifications are in L

progress to conform to the NRC's new rule.

Staffing of the licensee's. proprietary organization remained consistent

.

with the previous period and was adequate to carry out program needs as

,

l evidenced by the licensee's performance during the period. The four

L proprietary shift supervisors who were hired and placed onshift during the last period to provide contractor oversight in response to an NRC' concern appear to be very effective.

They conducted frequent post checks to reduce personni related deficiencies, provided fecdback to the training program to stre gthen potentially weak areas and maintained continuity.on program ar.J equipment status to preclude potential problems from becoming major issues.

Security management also remained active in Region I

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l Nuclear Security Association and other organizations engaged in nuclear plant security matters which demonstrates program support from senior licensee management.

Staffing of the contract security force was ample as evidenced by the limited use of overtime. Morale was ve y good cnd the turnover rate in the force remained low (about 12%).

Member: of the force were very

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professional in appearance and demeanor, especially the dedicated response force. The training program continued to be administered by four, full-

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time, experienced instructors.. Lesson plans were current and accurately

- reflected the-commitments in the NRC approved security program plans.

Training facilities were well maintained and instructional aids were-utilized extensively. A proprietary training coordinator was assigned to oversee _ the contractor's training program and to ensure it is maintained current. This is evidence of the licensee's inter:t to maintain an

_

effective and professional training program.- Program implementing proce-

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dures and instructions-continued to be updated, when required, based on

'feedbar.k from training and security operations supervirion to provide the security force with current,~ clear and concise directions. Members of the security force were found to be very knowledgeable of thet/ duties and:

!

responsibilities when interviewed by NRC personnel. Contractor super-visory and administrative staffing was also sufficient for the work load.

During the period, the licensee conducted a security related Emergency-Drill which included a response from the local law enforcement agencies

_,

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(LLEA). The drill _was conducted in a very professional manner and the security force and LLEA response was exemplary. The drill scenario was very realistic and well developed. The. post drill critique was very professional and provided meaningful training for the security force and I

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the LLEA. The' training.and qualification program is very effective as i

indicated by the small_ number of personnel errors that occurred during the

'

period and the excellent performance of the force during the emergency drill'.

The NRC required annual audit of the security program, performed by the licensee's quality assurance, group, was comprehensive in scope and depth.

'

In addition to the NRC required audit, the licensee also continued to

L

. conduct self assessment of_the program utilizing security management, L

proprietary shift supervisors and onsite QA personnel. Corrective actions

,

L on findings and recommendations, identified during audits and self assess-ment, were promptiand effective, with adequate follow-up to ensure their proper implementation. The NRC believes that the licensee's commitment to implement a high quality and effective security program coupled with a

. comprehensive audit and self-assessment program are major contributing

,

factors in the licensee's excellent enforcement history.

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The number of security related events during this period decreased signi-ficantly compared to previous periods. With Unit 2 now operational and fewer contractor personnel on site, security related problems have also decreased.

The NRC believes that the decrease is also due to a very capable and well qualified proprietary organization and a strong training program.

l Three security event reports were submitted to the NRC in accordance \\;ith 10 CFR 73.71 during the period. One event involved a sectrity officer who was inattentive on post, another involved a vital area barrier that had been degraded because of maintenance and the third involved the failure to reactivate an intrusion detection system zone after a test. All events i

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. were ' identified by routine security patrols or checks withir. a reasonable

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time,and did not result in significant security vulnerabilities. However,

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.each evant was.similar to those that had occurred in previous' assessment-periods. This area requires management-attention to ensure that correc-

.tive actions implemented for an event are sufficiently comprehensive to appl / to similar evolutions and address the root cause of the event.

.

The licensee submitted three :,ecurity plan revisions under the provisions of 10 CFR 50.54p during this period. The revisions were minor in nature and did not decrease the overall effectiveness of the plan.

In summary, the-licensee continues to maintain a very effective and per-formance oriented security program. Management utention to end support of the program is clearly evident in all aspects of prorram implementa-ti ori. The efforts' expended to maintain an effective program during this period-are commendable and demonstrate the licensea's commitment to a high quality security program. ' An area that requires ~ additional management

. attention is the comprehensiveness of corrective actions for security events.

2.

Conclusiou Category - 1 s

BOARD RECOMMENDATION

~'

Licensee: None NRC:.None L

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(472 hours0.00546 days <br />0.131 hours <br />7.804233e-4 weeks <br />1.79596e-4 months <br />, 12%)

F.

Engineering / Technical Support

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Analysis L

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During the pt evious SALP assessment period, the licensee's performance.in i

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the Enginee:ing Support area was rated as a Category 2.

The primary

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weakness cited.in the previous SALP report was the lock of a' program for

's the prompt resolution of. the deficiencies and incensistencies in the

..

Emergency Operating Procedures-(EOPs). This was attributed to site management's inattention to detail in validation, verificttion and implementation of high-quality E0Ps.

~

The Nuclear Engineering Departmen' provides engineering support to the plants. The staffing of the engineering group was good.

Contractor personnel were assigned to provide services on a task basis and each task

is supervised by the cognizant engineering group supervisors. The licensee does not use contractors for most of the required engineering.

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By performing 80% to 90% of the engineering work "in house,"~ the licensee has built a stable engineering force and a high level of plant specific

_ experience.

The increasing demands for engineering support due to Safety

'

System-Functional Evaluations (SSFE) for updating Unit I design basis. and

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licensing documents has caused t.he licensee to authorize 25 additional J

engineering' personnel to support this task. Thfr._ initiative is viewed as I

a positive managerent commitment to engineering and plant safety.

!

An effective interface between engineering (onsite) and plant personnel-exists in Beaver Valley Units 1 and 2.

The lead engineers on a project.

I are responsible not only for the design and the installation but also for the ongeing operation of the affected equipment / system. This provides a

~, _

clo w ' working relationships between engin(ering and 4 erations personnel.-

The' licensee site management's initiatives to improve the plant safety and performance was evidenced by the following examples:

1) The licensee has a

established an erosion / corrosion inspection program based on industry l

information and the plant operating experience; and 2) The licensee, has

!

developed a SSFE team approach to update the design basis and licensing documents for Unit 1.

The SSFE reports were found to'be thorough and complete. and the system studies are progressing aggressively.

Another signif'icant initiative includes the initiation of a full scale

' Probabilistic Risk Assessment (PRA) for each unit (exceeding the scope of i

Generic Letter 88-20). The PRAs are planned to be maintained current and-

-i-used as in engineering tool.

In addition, the licensee constructed a working mockup of applicable charging system piping to study the pheno-

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menon of hydrogen.' buildup in charging pump suction lines. These initia-

tives are indicativs of a commitment to long-term, strong performance in

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engineering and technical support.

i The licensee has been generally responsive.and continues to demonstrate j

sensitivity to implementing NRC initiatives during this assessment period.

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For example:

1) The E0P deficiencies identified during the previous SALP

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. period were corrected in a timely manner _ during this assessment period.

j 2) The licensee's review and evaluation of NRC Information Notice 86-53 regarding " Improper Installation of Heat Shrinkabla Tubing" were timely, thorough an't technically sound 3) In a recent heightened NRC effort to obtain-implementation status on all TMI actions, the licenses fully cooperated-and provided a timely and accurate response.

Furthermore, the licensee has also responded properly to a large number of bulletins.

Major responses inclwie those addressing fatigue cracks in steam generator tubes, pressurizer surge line thermal stratification, uolded case circuit breakers and thermal stresses in pipes connected to the reactor coolant system.

The licensee has established a viable system for controlling the engineer-ing~ workload, for establishing and revising priorities, and controlling the activities of the engineering organization to nieet current plant requirements. Good site management overview of the engineering activities is provided through periodic reviews of project status.

Priorities are i

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formally established through a set of weighting factors that include

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nuclear safety significance,. regulatory requirements, indurtrial saf aty,

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cost / benefits, efficiency.and other management considerations. The priority system generally has been effective in the performance' of

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engineering activities in a timely manner to support plant requirements; l

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however,.a few exceptions have been noted.

These included the following:

1) The engineering evaluation and submittal of an amendment request regarding ultimate heat sink temperature took almost a year to complete.

This resulted in the issuance of an amendment under emergency circum-stances by the staff. 2) The engineering staff took ten months to evaluate a vender identified valve probSm

'otentially impacted conta';i.m.it

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isolation capability.

-The engineering suppor'

iant events and technical i>.oes

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continues to improve i ror ex a ple:

1) In October 1988,

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problems were iden+ <

s.ironmental <1ualification of gaskets

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l-in the Unit 2 cmwe, y-

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% 11mi' switch position

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indicators, ga-41aceo wit ne, ines af ter c vful

analyses wit irt operationr

' the time v the North C-Anna steam g <

riu9 tert, Ur the first icfueling

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r-outsge.

Excell-ering suppor e nal, _

fm epair of o e most susceptible Unit a v -m senerator tube p og, prior to issuance of NRC requirements, withei.

..;cting the cut %e schede'c,

3) High quality support was evident in the prompt e,gineering respe w to the m y 18, 1989 reactor. trip and safety injection at Unit 1.

Design changes and modifi-cations were completed in the ATWS mitigating system and the Unit was returned to power on May 21, 1989.

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In spite of the above good performance, weaknesses were noted in the-11<:ensee's ability to provide quality work for some activities.

For example:

1)'The licensee did not conduct an adequate engineering review for thermal overload relays and differential pressure testing requirements

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for motor operated valves in response to Bulletin 85-03.

2) Deficiencies-in procurement, review and classification of commercial grade items for

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Category I use led to the installation of an incorrect gasket in a Unit 1 steam generator manway. 3) Inadequate resolution of safety related cable

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separation'in Unit 1 led to repeat violations.

Corrective actions were a;

still in progress at the end of the period.

In acoition, as indicated in the sumary of unplanned shutdowns, plant trips and forced outages at the ene of this report, deficiencies in engineering activities resulted in a reactor trip at Unit 1 and two reactor trips and a forced shutdown at Unit 2.

Proper review and evaluation of vendor-supplied enginee,.ng details could have disclosed

errors in the Unit 1 backup se m system, the Unit 2 rod control system,

,1 and in the Unit 2 feedwater ntm. Wm which could have overted these events.

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Strengths were. identified in the licensee's Inservice Inspection (ISI)

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program. The'-licensee maintains a certified Level III examiner for review of vender data and oversight of,venpor activities in the area of nonde-E structive examination.

Improvements were noted in the ISIz vendor. training i

'and examination-program. A team oi engineers was formed during the Unit 2

'o first refueling outage dedicated to expedite:the disposition of ISI-

discrepancies.

.,

In summary, the licensee responded positively to the concerns identified

'

in the' previous SALP report, and the licensee's response to NRC initio-tives-has been timely and thorough in most cases. Management initiatives to improve plant safety'and performance were evident during this SALP period. The engineering support in response to plant events and technical issues continues to improve. However,. some areas were identified where the timeliness and quality of engineering support could be improved. Also, it

~

apnears that better attention to vendor-supplied engineering details with more emphasis on independent evaluations could reduce the number of plant transients. Although improvement has been observed $n some areas, continued management attention is warranted to achieve overall improved performance.

.i 2.

Conclusion.

Category - 2 BOARD RECOMMENDATION

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Licensee: None NRC: None G.

Safety Assessment / Quality Verification (192 hours0.00222 days <br />0.0533 hours <br />3.174603e-4 weeks <br />7.3056e-5 months <br />, 5%)

l '.

Analysis In assessing this area, the SALP Board considered attributes which are key contributors in assuring safety and verifying quality, for example-implementation of. management goals, planning of routine activities, worker attitude, and management involvement.

This area received a Category 2 rating in the last assessment period.

Strengths were identified in the Unit 2 self-assessment program, management oversight, safety committees and quality verification programs. Weaknesses were identified in the quality of LERs, and quality and technical depth of the QA organizatica.

Significant resources continued to be dedicated to the assurance of quality.

In the previous period, the licensee completed a Safety System Functional Evaluation (SSFE) of the Unit 1 AFW system. The SSFE was a-

broad based technical review involving over 3000 man hours of effort and was modeled after the NRC Safety System Functiont.1 Inspection. During this period, three additional SSFE's were completed on the Quanch Spray System, the emergency diesel generators and the River Water System, Two e

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'more SSFE's were in progress on the Recirculation Spray and Residual Heat Removal! systems. The licensee's program is a strong initiative to enhance

m Jrability of key safety systems and yield long-term improvement in

_

safety.

In the licensing area, the licensee demonstrated a good working knowledge of applicable regulations, guides, standards and generic issues, and has

=not exploited use of exemptions or reliefs as-convenient costcutting ineans. >The.11 cent,ee's pre,mpt and thorough responses to NRC safety initiatives (such as bulletins, generic letters, information notices) are

'

commendable. When' audits were performed b/ the staff on two bulletins and

,

two other plant specific _ issues, licensee personnel, with.the support of contractors, consistently demonstrated competence 4 the-subject matters, aggressiveness to resolve riisputes and openness to communication. Over 50 licensing actions were completed including several that required major NRC

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and licensee efforts such as natural circulation cooldown, increased limit of fuel enrichment, core design change, and schedular extension of several

"

license conditions.. The licensing staff maintains open and frank communication with the NRC on a day-to-day basis, and is sensitive to

.

NRC's safety concerns.

Such a proactive attitude is indicative of the licensee's emphasis on scfety.

A significant safety initiative is the licensee's decision to complete and maintain' current a Probabilistic Risk Assessment (PRA) on each unit.

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The Unit 2 PRA was nearly complete at the end of the period, and the Unit 1 PRA was scheduled for comletion in 1990. Upon completion, the PRA's

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.should significantly contr1oute to safety by enabling evaluation of the

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~ ffects of out-of-service equipment, proposed modifications and other e

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system changes.

The_ licensee continued to have in place a formal and systematic approach to root'cause analysis which forced a brosdbased approach to event review

,

L and which led to higher quality analyses. The ISEG (Independent Safety Evaluation Group) computer program compares reactor trip response to a i

standard trip without other failures.

The program greatly facili'.ates L

the identifie.ation of equipment failure or unexpected component response L-following a reactor trip. event and provides a database for trending l:

studies. This program is a notable initictive-which enhances the licensee's ability to assess plant response to events and during this

=pericd led to the rebuilding of all 18 Unit I steam dump valves, changes to some Unit 2 relay settings, and the replacement of certain fuse types.

The ISEG also initiated Formal Human Performance Evaluation System (HPES)

reviews of personnel error caused events. The HPES conclusions gave good indght into the contributory factors to perunnel error and led to

'

several. procedure enhancements. The use of ISEG to review trips, personnel errer caused events, and repetitive component problems gives

good evidence that ISEG is used as 6 management tool by senior site management.

Nanagement oversight varied in quality.

Strengths were noted in senior management involvement in improving availability of safety related y

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' components and~ systems, promoting accountability and sense of ownership,

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ensuring participation'in industry _ initiatives to learn from other utilities,

'and keeping abreast' of-regulatory-issues to be aware of-potential problems.

,

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Several programs such as the SSFE'and the Design Basis Reconciliation Program

!'

instituted by management have produced tangible results in safety and

' compliance.. Management performance was weaktin controlling overtime and p

maintaining oversight of work in radiologically controlled areas during the-L'

Unit 2 refueling outage..Prioritization and timeliness in addressing technical--

H issues were mixed.. Also, management did.not resolve the low-technical quality of QA audits of the radiation protection program noted in the previous SALP report. The increase in the incidence of personnel _ error caused events was identificd in the middle of the period, but corrective actions by management

, ere not successful in preventing additional such events in the final ~ months of w

,

.the period.

.The licenseets safety evaluations (SEs) under 10 CFR 50.59 were found to vary L

>

.in quality._-The SEs for permanent plant modifications were thorough and of i

l-high. quality while the SEs for sene temporary modifications exhibited weakness

with superficial evalu:tions. -In one instante a temporary mad;fication on a l

Unit 2 emergency diesel generator air start system involved an unreviewed ll safety question, in that it allowed the indefinite operation of the air

. compressor without the associated air dryer. However,_the licensee instituted

programmatic _ enhancements, including training for all personnel involved in

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approving SEs, and was successful -in improving SE quality by the end of the period.-

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The various station safety committees functioned well during the period. The

Onsite Revier Committee (OSC) adequately performed its assigned responsibi-o

!

lities.

Reviews'were generally thorough'and in depth. Weaknesses identified

)

in the OSC review of temporary modifications showed improvement near the'end of E_

the assessment period. The Offsite Review Committee (ORC) includes members of

,

. senior corporate personnel and continued to be an effective and aggressive E

organization. Examples-of the ORC's management tools include the SSFE program-and the unit specific PRAs mentioned above. The onsite location of senior corporate personnel and engineering support groups continued to enhance the effectiveness of senior management-oversight and technical support.

,

' Prepared in accordance with the evaluation methodology presented in NUREG-1022,

" Licensee Event Report System," the overall quality of LERs was found to be very_ good. Weaknesses were found in only two of the IERs reviewed during the

. period. Generally the LERs provided goed documentation of even; analyses, root

'cause determinations and corrective actions.

In the previous report, the QA organi:ation was described as lacking depth in its audits, but was improving at the end of the period. The licensee has since then~ incorporated performance based attributes in the QA audit plans, and improvements were.noted in sampled QA audits.

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The perfermance in the area of Radiological Controls was mixed with good audits in effluent monitoring, transportation, and environmental monitoring-but weaker performance in QA surveillance and radiation

. performance.' -

The involvement of QC in day to day work activities continued to be a strength.

Field inspectors for QC continue to closely and independently monitor all work on safety related equipment.

The QC material receiving

ir,spection program was thorough and well implemented.

In summary, effective management was evident in promoting activities which would improve safety and quality. The licensee demonstrated a positive attitude to comply with NRC. safety initi cis

, and often went beyond e

. mere compliance to achieve a higher levei of /ety and quality on its

.

~

J own. The SSFE,. programmatic root cause ans..

program, and proactive licensing staff are examp_les of the licensee's positive attitude.

J i

I

'

. Weaknesses-were icentified in the resolution of the previously identified-low technical quality.of-QA~ audits in the radiation protection program,:

in the implementation of corrective actions-to prevent additional ' events

-

caused by personnel. error, and in management's oversight of overtime and

>

of work in radiologically controlled areas.

2:

Conclusion

,

Category - 2 BOARD' RECOMMENDATION i

Licensee: None

,

NRC: None-H.

Training Programs-1.

Analysis

,

In the previous period, the area of Training Programs was evaluated as

'

Category 3. 'Significant weaknesses were noted in licensed operator training with high examination failure rates and E0P knowledge j

weaknesses. These deficiencies ied to the NRC evaluation that the requalification program was unsatisfactory. Other training activities were found to be generally sound.

Significant improvements were noted durirg the current period and the =

licensee's requalification training program was assigned an overall program rating of satisfactory in December,1988. This rating was based

on the results of requalification examinations administered to twelve licensed operators (6 SR0s and 6 R0s) from Unit I during the week of December 12-16, 1988.

Eleven of the twelve operators passed these exams and there was close agreement between the NRC and the licensee on the l

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i grading of the exam. The individual who failed, subsequently passed a:

i requalification retake exam in July,1989. This overall-performance is indicative of increased emphasis in thr area of requalification training.which-is in sharp contrast to that demonstrated during'the previous SALP evaluation-i

_

period.

It was noted that in the previous SALP. period, management oversight J

-

and involvement was minimal, however towards the end of the period, an increase

,

'

.in management' involvement was apparent'. This continuation of management i

. attention and involvement is evidenced by the satisfactory training program evaluation results.

,

l Management involvement was also demonstrated by the commitment to have a Unit 2

,

simulator in place by March, 1991. Also, the vacant Manager of Training position was filled by a temporary employee familiar with the accreditation

.,

V

process ard other training: programs. This individual has brought"a reliable

'

e

~outside perspective to.the. licensee's training program.- Evidence of his and

other. managers' involvement during the requalification examination was noted

,L,

'throughout the week of-the examination.

Licensee preparation for the requalification exam was found to be very good.

Examination materials submitted to the NRC allowed the exam to be generated

.

with relative ease.- This-supported the licensee's previous commitment to l

upgrade the requrlificat on program, including 3 earning objectives, lesson plans and examination development. - There were, however, some problems identi-L fied with the materials submitted for the replacement examination administered L.

in August, 1988. However, the majority of these. problems dealt with editorial concerns-vice technical content. These identified problems were subsequently corrected as demonstrated by the materials submitted for the requalification

,

'.

examination fout months later. Again, this demonstrates management involvement

.

in the assurance of developing and maintaining a training program that meets

,

L high quality standards.

,

L The licenswe's training depertment adequately reviews LERs and industry eye o and incorporates them in the lesson plans. They provide sufficient trainin; to the station conlicensed staff in order to prevent the occurrence or mitigat:

-

the effects by recognition and proper operator actions. They are aggressively

,.'

' pursuing the goal of 100% training of all station nonlicensed staff during the current year.

The Training and Operations departments interact well in identifying training l.

~

-

^

needs. An Operations Training Committee, consisting of Operations and Training personnel, develop detailed training objectives.

In preparation for the NRC administered requalification examination, the Operations and Training personnel jointly developed Job Performance Measures cid training on the newly revised E0Ps. The E0Ps had undergone review and necessary revision as called for in a BVPS E0P Action Plan. Several human factors deficiencies had previously been

. identified in an E0P inspection during the ?revious SALP evaluation period.

These identified deficiencies had been attributed to a lack of quality

'

y assurance reviews and poor management,,versight. Based upon the usage of the

'

f E0Ps during the conduct of the requalification exam, which extensively utilizes l

the E0Ps, it was evidet that appropr'iate changes had been made to the E0Ps.

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,p Non-operator tvaining activities continued.to be effective.

Training for Oh maintenance personnel, emergency preparedness, the security force engineers

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Sand radiation protection was good..The team building training given to

'

q operators and maintenance personnelats> a noteworthy initiative.

,

'

fin--Lsummary, significant improvements have been made in the ' area of licensed

..

E operator. +. raining. All management positions have been filled and as a result, O'

l management 1nvolvement'and eversight of training program activities has

~

'

a

~

increased,'especially in'the~ area of the requalification program.

Previously

>

identified weaknesses dealing with E0P procedural deficiencies as well as

4'

licensed operatcr usage problems have been corrected. Corrections / improvements

.

,

to the'E0Ps and subsequent usage by licensed operators were demonstrated-

.

during the conduct:of the December, 1988 requalification examination, which

-

resulted inia satisfactory-programt evaluation.. Non-operator training.

l Lactivities continued to be effective throughout the period.

.

$

2.

Conclusion p

Category - 2

!

,

i

!

BOARD-RECOMMENDATION

Licensee: None NRC: None

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n-SUPPORTING DATA ~AND SUMMARIES

A.1 Licensee Activities

-

~

This assessment period started with both units operating at 100% power. A

' Unit I reac+.or trip and safety injection occurred on June 7,1988, when a

!

non-licensed operator inadvertently tripped a reactor coolant pump breaker

.instead of the intended air compressor breaker.

Two additional Unit 1

.

reactor trips. occurred'on June 9 and June ll, during plant startup evolu-

tions, due.to feedwater control problems which resuleed in low-low steam generator water levels. Operator error contributed to the June 9 trip,

.,

and.the June 11 trip resulted from :omponent failure.

A Unit 2 reactor trip occurred on July 27 on negative neutron flux when several control rods fell into the core _during maintenance troubleshooting activities due to component failure.

l

'

Both. units were taken off-line on August 23 following an apparent 04fsite chlorine release which caused the air bottles in the control room emer-gency pressurization system to partially discha ge and the declaration of-

-

an. Unusual Event. Units 1 and 2 returned to power operations on August 24 and 25, +espectively.

In September, Unit I began a core life extens;on L

program which would include limiting power to 90% with load swings to 50%

on weekends. The progrcm was designed to move the scheduled refueling outag': to Fs11,1989,. and thus establish separation from the Unit 2

'

refuel 1ng in Spring, 1989. Unit 2 experienced two additional trips on September 20, 1988, and Februtry 12, 1989, due to unrelated hardware

'

-

failures and shut down on March 17, 1989, for the first refueling outage.

L On November 25, 1988, Unit 1 shut down for approximately nine (9) weeks I

due to RCS and steam generator manway. leaks. Unit 1 tripped on January 17. 1989, due to licensed operator error during post-maintenance testing.

?

Another Unit I trip was experienced on February 13, due to component failure.

The last Unit I trip in this period occurred on May 18. A design flaw in the recently added backup scram system caused the steat dump valves to open when the system was de-energized..The excess steam-i

,

L flow initiated at 89% power caused both a reactor trip and safety injec-

'

tion. The design was corrected and Unit 1 operated without further incident-for the rest of the assessment period.

Unit 2 experienced problems curing recovery from the first refueling outage. A small gasket-left in a sensing line endered the reactor vessel indicating systen inoperable and orifices were mis-insta14d or omitted in u

the RCS.

In both cases, the unit was returned to cold shutdown to effect repairs; Unit 2 was returned to power operations on June 3.

No additional trips were experienced in the 1ssessment period, although Unit 2 did declare an Unusual Event and shut down on June 21 for about three weeks in response to a steam generator tube leak.

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'

A.2' Direct Inspection and Review Activities Two NRC resident inspectors were assigned.to the site throughout the assessment' period. -The total inspection time for the period was 3,964 hours0.0112 days <br />0.268 hours <br />0.00159 weeks <br />3.66802e-4 months <br /> (resident and region based inspectors) for an annualized inspection time;of 3,172.beurs.

The distribution of inspection activities is presented in w tton E below. Team inspections were conducted to assess the licensee'

m rgency preparedness program (May'-31 - June 2, 1969) and the annual emergency prepars.dness exercises (October 24-26,.1988 and

August 1-3,1989).

'

- B.

Criteria Licensee performance is assessed in selected functional areas, depending.

on whether the facility is in a construction, preoperational or operating c

phase.

Each functional area normally represents areas significant'to

'

nuclear safety and the environment, and-are normal programmatic areas.

,

l_

Special areas may be added to highlight significant observations.

.

i One or more of the following evaluation criteria were used to assess each functional area.

1.

Management involvement and control in assuring quality.

-2.

Approach to resolution of technical issues from ?. safety standpoint.

3.

Responsiveness to NRC initiatives.

l 4.

Enforcement history.

,

!

5.-

.. Reporting and analysis of reportable events.

,

6.

Staffing (including management).

7..

Training and qualification effectiveness.

,

i Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories. The definitions of these performance categories ara:

Category 1:

Reduced NRC attention may be appropriate.

Licensee manage-ment attention and involvement are aggressive and oriented toward nuclear

!.

L safety; licensee resources are ample and effectively used so that a high level of performance.with respect to operational safety is being achieved.

'

Category 2:

kRC attention should be maintained at ncrmal levels.

Licensee management attention and involvement are evident and are con-L

'cerned with nuclear safety; licensee resources are adequate and reasonably effective so that satisfactory performance with respect to operational

,

j safety is being achieved.

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Category 3: Both NRC.and licensee attention should be increased.

Licensee management attention er involvement is acceptab'e and considers nt. clear w

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safety, but weaknesses are evident; licensu resources appear to be

,

strained or not effe:tively used so that minimally sat isfactory perfor-mance with respect to. operational safety is being act aved.

The SALP. Board may assess a-functional area t> compare the licensee's.

i

• j performance ~during the last quarter of the asse=tment period so that

during-the entire period in order to determine the recent trend. The SALP trend categories are as follows:

I The trend,-if used..is defined as:

.

Improving:- Licensee performance was determined to be improving near the close of the essessment period.

.

Declining:- Licensee performance was determined to be declining near the cl ose of the assessment period and the licensee had not taken meaningful

. steps to address this pattern.

C.

Unplanned Shutdowns, Plant Trips and Forced Outages Powei Root Functional Date.

Level Cause Area Description

' Unit'l

,

6/07/88 100 Personnel Maintenance / Nonlicensed operatcr Error Surveillance tripped wrong breaker

"

(RCP) during a surveillance test which caused low RCS flow trip and low pressurizer level SI.

6/09/88-17 Personnel Operations Licensed operator did not Error reset feedwater isolation

-

signal during startup which led to icw steam generator level reactor trip.

6/11/88 13 Cor.ponent N/A Spurious trip of oreaker Failure to motor of discharge valve of main feedwater pump led to low steam generator level reactor trip.

1/17/89

Personnel Operations Licensed operator read Error and gave orders to perform wrong step in post maintenance test.

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2/13/89 90. Component N/A Failure ~of electro-Failure pneumatic transducer in feedwater controlz system caused

'feedwcter control valve to fail partly closed leading to low steam

,

generator level reactor trip.

.

~5/18/89

Design Engineering / Error'in wiring logic of

~ Er-ar Technical recently installed backup i

Support-scram system caused, upon

!

,

energization,-steam dumps to go open leading to. scram.and SI.

Unit 2 7/27/88 100-Design Engineering / Trip occurrsd during Error Technical attempts to troubleshoot'

Support failed card in rod control system. Vendor misunderstanding of

'

own wiring logic led to wrong recommendation for licensee course of action.

~'

9/20/88 100 Component. Maintenance / Trip oc urred during Failure Surveillance surveillance test due to card failure in,one channel while one other channel tripped for test L

2/12/89

Component Engineering / Internals failure of a Failure Technical main feedwater control Support valve led to high steam L

generator level, turbine trip and reactor trip.

• l 5/17/89

Fersonnel Maintenance / Improperly installed l

Error Surveillance pressure seal ring in l

reactor vessel level L.

indicating system led to return to

.

cold shutdown for repairs.

5/27/89

Personnel Maintenance / Performance of i

, _

Error Surveillance surveillance test despite ll not meeting required initial conditions caused los

pressure trip.

6/03/89

Personnel Maintenance / Incorrectly installed and Error S eveillance missing RCS manifold L

orifices led to shutdown for L

resolution.

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k 1 /21/89.100 Component' Engineering / Steam generator tube leak

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due to part from failed

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s Support feedwater valve caused

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shutdown-'for. repair.

,

...

- D.

Enforcement' Activity :

.m No. of Viclations in Each Severity Level Functional Area V

IV III II I

Total A.. Plant Operations

1

B... Radiological Controls C.. Maintenance / Surveillance

3 D. -Emergency Preparedness

-

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E.

Security

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F.

Engineering / Technical

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Support 3-

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Safety Assessment /

.

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Quality-Verification

1

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-E.

Inspection Hour Summary

~

Actual Annua 11 zed percent Plar.t_0perations 1975 1580

Radiological Controls 338 270 9-

,

Maintenance / Surveillance 455 364

.

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Emergency Preparedness 296 237

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L Security 236 189

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Engineering / Technical Support 472 378

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Safety Assessment / Quality Verification 192 154

L TOTAL 3964 3172 100 i.

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Licensee Event Report Causal Analysis

-

Number By Cause Code

_. _

Functional Area A-

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C-

'D E

X Total

'

Unit i Plant Operations -

4

Maintenance / Surveillance 1-

1

2

4;

. Radiological Controls

-

- Engineering / Technical y

Support

-

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Safety Assessment /-

Quality Verification.

Unit 1-Total

1

1

2 16-Number By Cause Code Functional Area A_

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D E

X Total Unit 2 Plant Operations

1

4

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Maintenance / Surveillance

2

15

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Radiological Control

2 3-

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t Engineering / Technical'

1-

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Support u

Safety Assessment /

'

Quality Verification Unit 2 Total

2

E

29 l

Cause Codes:

Combined Total i

A.

Personnel Error

B Design, Manufgacturing, Constructit.n or Installation Error

s C

External Cause

D Defective Procedures

E Component Failure

.X.

Other

7

The following common mode events were identfled:

Approximately one-third of the events were attributed to personnel error:

N/A is used to indicate that the cause of the event could not be clearly assigned to particular SALP functional area.

SD/S-6

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