IR 05000341/1990001
| ML20012C206 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 03/12/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20012C203 | List: |
| References | |
| 50-341-90-01, 50-341-90-1, NUDOCS 9003200293 | |
| Download: ML20012C206 (36) | |
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SALP~11
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n INITIAL SALP REPORT.
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION'III h
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE in L
50-341/90001 j,
Inspection Report No.
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E-Detroit Edison Company (DECO)
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Name-of Licensee i
h Fermi-2 Name of Facility
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January 1 -1989-through December 31, 1989 l
Assessment Period e.
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SUMMARY OF RESULTS
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A.
Overview-During the SALP assessment period, the overall quality of activities for the safe operations of brmi 2 was adequate. The licensee, in most cases, had made an overall improvement in the management and operation of the facility.
The plant operations organization was well staffed and trained to
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support plant operations.- A professional environment was maintained in the control room. The staff exhibited excellent and timely--
responses to operational events.
However, there were some operators who periodically lacked awareness of plant status. Also during the L
final months of the assessment period there was a decline in performance during outage, pre-startup and startup activities.
Radiological control programs were good and had improved during this assessment period.
The staffing levels, qualifications and training of radiation protection and chemistry continues to be good. Good ALARA performance was noted.
The only detractions from overall excellent performance was procedure adherence and litter in the Radiological Control Area during the outage.
In the maintenance / surveillance area there were several strengths in the programs, but there were also many weaknesses which detracted from the overall improvement in this area.
Among the strengths were improved maintenance procedures, increased management involvement, reduction in the number of engineered safety features (ESFs)
actuations and the implementation of an Accountability Action Plan.
Examples of weaknesses were the lubrication program, outage planning, training for system engineers, supervision of safety related maintenance' activities. There was a marked decline in performance in this area at the end of the assessment period.
The emergency preparedness organization was well staffed and trained. There was good enforcement history and good management involvement contributed to good performance in the identification and resolution of technical issues.
Security force staffing was a major strength.
Managers were well qualified and the uniformed force was well supervised. Good management involvement included in-depth self-inspections and audits. The only detractions from the overall good security program was occasional lack of attention.
Engineering and technical support pe-formance has been adequate.
Improvements had been made in the dedication of commercial grade equipment.
The staffing was a strength which included the doubling of the size of system engineering staff. The allocation of
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resources for plant problems was good.
The weaknesses that detracted from the overall strengths in this area was the system
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engineering program implementation, weaknesses in interdepartmental communications, and weaknesses in the training programs for engineers.
Safety _ assessment and quality verification performance has been adequate.
Staffing and training ir this area was a strength. The licensee has made progress in performing performance-based audits and surveillances.
The licensee has made substantial progress in the implementation of human performance evaluation system (HPES).
Some of the weaknesses in this area were review of events, quality assurance (QA) involvement in safety system functional inspection (SSFI) findings, licensing submittals, and planning and scheduling.
The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
Rating Last Rating This Functional Area period Period Trend Plant Operations
2 Radiological Controls
1 Maintenance / Surveillance 3/2
Improving Emergency Preparedness
1 Security
1 Declining Engineering / Technical Support
2 Safety Assessment / Quality Verification 2-
Startup Testing
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- NA - not applicable B.
Other Areas of Interest None,
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III, CRITERIA.
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Licensee performance is assessed in selected functional areas.
Functional areas normally represent areas significant to nuclear safety and the environment.
Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful. observations.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used to assess each functional area:
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Assurance of quality, including management involvement and control; p
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Approach to the identification and resolution of technical issues fram a safety standpoint; 3.
Responsiveness to NRC initiatives;
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Enforcement history; 5.
Operational events (including response to, analyses of, reporting i
of, and corrective actions for);
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Staffing (including management); and 7.
Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been used where appropriate.
i 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 1:
Licensee management attention and involvement _ are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and
- j effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention may be appropriate.
Category 2:
Licensee management attention to and involvement in the i
performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved.
NRC attention may be maintained at normal levels.
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Cateoory 3:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed
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that needed to meet minimal regulatory requirements.
Licensee resources appear to be-strained or not effectively used.
NRC attention should be increased above normal levels.
The SALP Report may include an appraisal of the performance trend in a functional area for use as a predictive indicator.
Licensee performance during the assessment period should be examined to determine whether a trend exists, Normally, this performance trend should only be used if both a definite trend is discernable and continuation of the trend may result in a change in performance rating.
The trend, if used, is defined as:
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Improving:
Licensee performance was determined to be improving during the assessment period.
Declining:
Licensee performance was determined to be declining during
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the assessment period, and the licensee had not taken meaningful steps to address this pattern.
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IV.
PERFORMANCE ANALYSIS
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Plant Operations 1.
Analysis The functional area of Plant Operations was evaluated on the basis of one special and eight routine inspections conducted by the resident inspectors, one special and one routine inspection
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conducted by regional inspectors, and one followup inspection by the Office of_ Nuclear Reactor Regulation of emergency operating procedures (EOPs).
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Enforcement history in this functional area was comparable to
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the previous assessment period and was not good.
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violations (six Severity Level IV violations and one Severity Level V violation) were issued.
Two of the violations resulted in potentially safety significant conditions: one involved
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rendering a division of the standby liquid control system
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inoperable and the other involved not using the appropriate limiting condition for operation (LCO) action statement for an inoperable reactor water-level transmitter. The violations occurred throughout the assessment period.
In general, licensee responses and corrective actions to the violations were adequate and timely. Generally, the programmatic weaknesses of the last assessment period were resolved, but inadequate communications and inattention to detail persisted. This was evidenced by violations that involved inadequate implementation of established administrative controls.
Several operational events occurred during this assessment period that led to the submittal of Licensee Event Reports (LERs) and of which five were caused by personnel error. The most_significant LER was a scram of the reactor from power when three main steam isolation valves were closed through operator inattention to detail. Also of concern was that all five of the personnel errors occurred during the last three months of the period, with four occurring in December 1989.
These problems appear to indicate that the operations staff may not have been paying close attention to details as the plant was preparing to return to operation after the refueling outage. Numerous design problems contributed to operational problems, but the licensee is making steady progress in operating the plant within its constraints. Overall, these errors represented essentially the same performance as exhibited in the previous assessment period.
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Four reactor scrams from full power occurred during the assessment period.
Other than the one caused by personnel error (noted in the previous paragraph) the other three were related to problems with the main turbine generator. One was automatic and was caused by a design deficiency in the turbine
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. ere conservatively-initiated when high vibration occurred in w
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" lagging." Two of the scrams occurred early in the assessment period following which the plant ran for a 168 day period.
This period of uninterrupted operation reflected improved plant
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performance and that many original plant design and construction deficiencies had been corrected.
Operator response to the off-normal events was generally good.
Conservative operational practices were followed as exhibited by the decision to manually scram the reactor due to the fire in the turbine lagging.
Responses to other off-normal and unplanned ESF actuations were also proper as evidenced by operators identifying and rectifying a tripped relay in the o
start logic for emergency equipment coeling water / emergency equipment service ~ water pumps in less than one hour. A
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contributing factor to the good operator performance was the high level of training that was provided to the operators, including a substantial amount of simulator training.
Staffing in the area of plant operations continued to be good.
All key positions were filled, and the experience level for management personnel exceeded regulatory requirements. The number of personnel on each operating shift during the
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assessment period exceeded the Technical Specification (TS)
j minimum staffing requirements.
For the first three quarters of l
the period, six full-shift complements were employed, and one
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shift was always in training.
The use of overtime was
controlled to ensure it was kept within TS requirements l
throughout the assessment period. An extra licensed operator
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was assigned to some shif ts to monitor the reactivity control panel and nearby panels during power operations.
During the last quarter of the assessment period, the licensee initiated a trial 32-hour, five-shif t rotation for all licensed operators, partially to reduce the number of shift turnovers per day.
Some of the licensee's communication deficiencies had
_3 occurred at shift turnover. However, nonlicensed operators had i
not yet changed to the 12-hour rotation by the end of the l
assessment period.
Since this was implemented near the end of the assessment period, its effects have not yet been fully
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evaluated by the licensee or by the NRC.
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Plant housekeeping was generally good, but weaknesses were noted during the refueling outage in the control of material in the
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drywell and the refuel floor. Tools, tape, gloves, and plastic were lef t in the drywell after work activities were completed and tool control on the refuel floor was poor at the beginning of the outage.
Once the weaknesses were identified, individual supervisors were held accountable for
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' training and counseling was given to involved personnel to
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apprise them of management expectations in this area.
Combustible materials were generally properly controlled.
140 generic fire problems were identified but when isolated problems occurred, the fire brigade responded quickly and effectively.to all fire alarms and indications of fire. A contributing factor to this performance was the substantial-amount of training devoted to this area.
Management involvement in assuring quality was generally adequate. The managers kept informed of plant status and operator performance by attending daily plant status meetings held in the control room area and by direct oversight and involvement during major plant evolutions such as reactor startups and shutdowns.
Fire watch rounds were periodically computer checked to assure the rounds were being performed.
As a result, management identified some fire watches that were not being performed and quickly rectified the situation.
It continued to enhance E0Ps by rectifying minor weaknesses identified during:the last assessment period and continued efforts to develop E0P flow charts. The administrative controls for licensed and non-licensed activities were generally well stned and defined, except for LCO tracking during the refueling outage; the LC0 tracking system was not capable of handling the large increase in LCOs associated with the outage.
Shif t personnel performed their duties in a professional manner and control room decorum was maintained at a high level.
Shift logkeeping practices were generally satisfactory.
Duties and responsibilities, though generally understood, were occasionally not properly carried _out.
The most significant problem was the occasional f ailure to follow administrative controls and know the status of the plant.
Occasionally key shift-turnover information was not disseminated and operator awareness of plant status was periodically lacking. These communication problems were especially evident during the startup from the refueling outage. Occasionally, administrative controls were not followed as evidenced by returning a division of standby gas treatment to service without all testing documentation complete, not controlling ESF cabinet keys contributing to an ESF actuation, and improperly documenting tagging records on a reactor sampling--
modification.
This is a problem which dates back to the previous assessment period; management is aware of it; actions are ongoing to resolve it.
These administrative control problems did not cause any major plant perturbations.
The licensee's approach to the resolution of technical issues in the operations area was generally satisfactory once the individual issues were identified.
Examples included corrective actions to a weeping safety relief valve, a
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'drywell-to-torus vacuum breaker indication-problem, and a _ low
power range monitor string which was improperly stored during
~the refueling outage.. However, two issuet have been outstanding since the previous assessment period that still have not been adequately resolved. The first issue involves weak implementation of administrative controls in this' area. The
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second involves the continuing lack of understanding by operations personnel of the necessary TS support systems.
This issue is more fully discussed in the Engineering / Technical Support section of this report.
In response to these weaknesses, in part, plant managemen_t continued to utilize accountability meetings and instituted a system of formalized critiques to aid in determining root cause of significant events and to prevent recurrence. Additionally, actions were necessary and were underway at _the end of the
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assessment period to upgrade the LCO tracking system and to assure greater attention to detail by plant personnel by
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implementing an " Accountability Action Plan."
Management was responsive to NRC initiatives during the assessment period.
The licensee continued an aggressive communication posture and routinely met with the NRC-to keep
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'it informed on important. issues. All NRC concerns were dealt j
with in a timely and technically competent manner. Weekly meetings were held between the resident inspectors and the plant manager, and licensee responses to questions and concerns were adequate. Concerns with secondary containment administrative controls, derived from observations made during ESF walkdowns were especially well received and adequately resolved.
2.
Performance Rating The licensee's performance is rated Category 2 in this area.
j The licensee's performance was rated Category 2 in the previous
assessment period.
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Recommendations None.
B.
Radiological Controls I
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~ Analysis
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Evaluation of this functional area was based on four routine inspections and one special team inspection performed during
this assessment period by regional inspectors and on routine observations by resident inspectors.
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' Enforcement. history in this functional area was generally good, with one example of a violation involving failure to follow
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radiation work permit requirements identified by the NRC during the maintenance team inspection (MTI).
The staf fing -levels, qualification, and training of radiation
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protection and chemistry personnel continue to be good. All technicians are qualified in accordance with American National Standards Institute standards -- ANSI-N18.1-1971. Two members of the health physics staff are certified by the American Board
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of Health Physics, and a recently hired health physicist has significant reactor health physics experience. The experience level of the staff continues to increase owing to
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low staff turnover. The licensee continues to rotate health physics -personnel within the department to broaden their experience.
No significant weaknesses were noted in the.
training and testing program for contract radiation protection technicians used to supplement the station staff. The chemistry staff is competent and adequate for the existing workload.
Cross-training of management personnel within this department appears to have contributed to improved performance.
Management involvement-in assuring quality in both health physics and chemistry was evident. Good support was given to contamination control and to the radiation occurrence report system including corrective and disciplinary actions where needed.
Effective ALARA radiation exposure efforts included use of shielding, use of remote welding and tool handling equipment, and cobalt reduction initiatives.
The ALARA organization is well staffed and' participated effectively in the planning of radiological work. The water quality program E
is consistent with the Electric Power Research Institute l
Owners Group Guidelines (OGG) and considerable effort is being devoted to solving a recurrent problem with condensate filter demineralizers.
Laboratory and counting room QA' programs
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appeared well managed and implemented with a senior technician assigned to monitor quality control (QC).
These chemistry-parameters were maintained within the OGG for the assessment i
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period despite problems with the condensate filter demineralizers.
Intercomparison cross-check programs with an outside vendor
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have increased to almost 100*i; agreements.
Responsiveness to NRC initiatives was good.
Improvements were made in both OA and in performance of the radiological and nonradiological measurements.
The licensee responded well to NRC concerns regarding a hot particle incident, a problem identified with the reactor fuel inspection process, calibration standards for non-TS related area radiation monitors, valve leak-off control, and planning and scheduling weaknesses identified during the MTI.
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p The-licensee's approach to_ resolving technical issues appeared i
. enerally sound. Several weaknesses were evident during the g
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licensee's first major refueling outage; all except one were identified by the licensee. Weaknesses involved procedural adherence by first' time outage workers, tool control, failure
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. fuel pool, and administrative overexposure.
Corrective actions were prompt and comprehensive.
Also, during the outage, an NRC inspector ' identified some litter. from eating and smoking in the radiological controlled area; this was brought to the licensee's attention and corrected.
There were no' measured internal doses during the period.
During the first refueling there were a number of personnel contaminations; however, the number of personnel contaminations (153) did not_ appear excessive for. the year. Total station dose in'1989 was 235 person-rem, including 200 during the refueling-outage, indicating good proactive ALARA performance.
There were no unplanned gaseous or liquid releases, nor were there any transportation incidents.
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The.results of both the radiological and nonradiological I
comparisons were very good with agreements in 50 of 53 and 27_
i of 30 comparisons,-respectively. The radiological
environmental monitoring program was well implemented.
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. Performance Rating
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The licensee's' performance is rated Category 1 in this area.
The licensee's performance was rated Category 2 in the previous assessment period, j
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Recommendations j
None.
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Maintenance / Surveillance 1.
Analysis
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Evaluation of this functional area was based on the results of
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l nine routine and two special inspections by resident inspectors,
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and five regional inspections including a MTI.
Maintenance and
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Surveillance were considered separate functional areas in the previous assessment period, but have been combined into one.
functional area for this assessment period.
Enforcement history during the assessment period declined and was not good.
There were six violations issued for surveillance
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deficiencies and six violations issued-for maintenance activities
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during this assessment period. One of the violations (Severity
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r Level III) was issued for the failure of a recirculation pump-field breaker to trip due to mechanical binding attributed to
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failure to lubricate the breaker during preventive maintenance-(PM) and the misalignment of contacts. Most of the violations.
were significant:
one resulted in two inoperable safety systems; another reflected a partial breakdown of the independent verification process; three were implementation errors indicative of a programmatic breakdown when the plant was ascending
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operational modes; one was a safety significant breakdown of
the. design change implementation process; and one involved ten
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examples of failure to follow procedures.
Most of the violations occurred late in the assessment period and although the-immediate corrective actions appeared to be timely and adequate, none has l
been fully evaluated by the NRC.
Management involvement in the assurance of quality was evident throughout the assessment period but did not meet the needs of the increased complexities of the outage, pre-startup, i
and startup activities. The established maintenance program i
was appropriately balanced between corrective and preventive-maintenance. Most of the licensee-established goals related
'to maintenance were achieved, including reducing the number of automatic reactor trips caused by maintenance activities.
Some balance-of plant equipment that previously had caused reactor trips was modified during the outage. Maintenance and surveillance program policies were clearly established and maintenance procedures were adequate and had improved since-the previous assessment period.
Particularly, in the area of motor-operated valves, procedures significantly improved and provided excellent guidance and criteria for post-maintenance testing.
Surveillance procedures were appropriate, except'in rare instances; only one unplanned ESF actuation was caused by an inadequate procedure. During the first half of the assessment period, implementation of the surveillance program was excellent with no unplanned ESF actuations attributable to perNnnel error.
During the second half of the assessment period, however, maintenance / surveillance' personnel errors accounted for a significant number of the LERs generated by the licensee and for an increase of unplanned actuations of ESF equipment.
Positive involvement by management resulted in a substantial reduction in the number of jumpers and lifted leads,.a 50%
reduction in outage related corrective maintenance (CM) work requests, establishment of area coordinators, performance of mechanical stress improvements, and piping inspections for erosion and corrosion. This involvement also was instrumental in the generally adequate implementation of the CM program, which resulted in a reduction of alarming annunciators, reductions in out-of-service control room instruments, and repairing of numerous transient-inducing feedwater system leaks.
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' Backlogs of CM work requests were not excessive and were within
'the capabilities of the staff. The nonoutage CM work requests,
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awaiting parts, decreased considerably from the previous assessment period indicating an improvement in this area.
A-considerable l improvement was also noted in the PM program, including a reduction of the backlogs, Neither the CM nor PM backlogs were considered significant.
One main reason backlogs
were not significant is that deferral of the PM items was based
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on the evaluation of failure history, past performance, and
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possible impact on-operability and thus ensuring that they were not _ safety significant.
The licensee's previous PM program included only safety-related and portions of balance-of plant equipment that 'can affect safety systems items; but the licensee
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was making good progress in reviewing and incorporating other equipment that is not safety related into the PM program.
Overall, the licensee's PM improvement program appeared to be-progressing well.
Conversely to the positive involvement, management was not effective in outage planning and scheduling, specifying responsibility for establishirig pcst-maintenance testing I
requirements and in supervision of the implementation of
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safety-related maintenance and surveillance testing
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implementation.
In addition, marginally acceptable maintenance support for some security equipment had detracted from the
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o high quality of performance for which some of the equipment was designed. Although housekeeping and material conditions of i
the plant were acceptable during the outage, precautions were not taken to protect installed equipment from work in
progress.
Furthermore, first-line supervisors failed to ensure
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the proper cleanup of an oil spill on the turbine, which caused a fire. Mechanical maintenance supervisors, even though frequently present at the -job site, were not always effective in supervising work in progress.
In several instances there appeared to be a casual work attitude by both supervisors and
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journeymen.
l Outage planning suffered from weak scheduling and integration of emergent work. An example of this was that anticipated l
transient without scram (ATWS) modification activities were not properly controlled, resulting in considerable delays, and post-maintenance / modification testing was inefficiently sequenced. Occasionally, safety-related maintenance activities were inadequately accomplished.
Examples were the upside down installation-of a reactor water level transmitter and placement of double gaskets on a safety relief valve. Weaknesses were evident in shift turnovers, and in troubleshooting documentation and methodology.
Some surveillance testing activities were not
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completed when required because of personnel oversight.
Examples include the secondary containment damper stroke test, missed post-modification testing on ATWS, and a missed primary containment valve stroke test.
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Some of:the events during the second half of the assessment 4 -
period were caused by contractors which indicated a continuing problem of inadequate contractor control. However, a comparison between 1988 and 1989 deviation event reports (DERs), associated with instrumentation and control personnel, indicated a significant reduction of inadvertent ESF actuations caused by instrumentation and control _ personnel.
The approach to resolution of outage weaknesses generally appeared adequate. An outage critique was underway at the end i
of the assessment period to determine scheduling and program weaknesses associated with the refueling outage. An i
Accountability Action Plan was initiated to review past activities for other implementation errors, enact actions to improve the lack of attention to detail and personnel accountability throughout the organization, and to change policies and procedures where necessary.
However, these weaknesses and management's response to the weaknesses occurred late in the assessment period, so it was not possible to assess the quality and effectiveness of the refueling critique or the Accountability Action Plan.
The licensee's approach to resolution of technical issues from a safety standpoint was mixed.
Resolutions were sound and viable as evidenced by development of a corrective action program for lubrication deficiencies, the continued development
of the performance evaluation program, and targeting design changes to improve surveillance testing implementation.
However, recurring difficulties encountered with maintenance activities were not always evaluated for trends, and no ccrrelation was performed between failed surveillances and corrective maintenance; consequently, generic failures were not always identified.
Equipment failure trending was a weakness from the previous assessment period.
Root cause evaluations of equipment failures were generally adequate, but slow in some instances,.as evidenced by the months it took to determine.a control room ventilation fan failure and relay failure in the reactor water cleanup logic. The fan failure was~especially important 'because it was indicative of the extent and significance of the lubrication program problems.
The licensee's responsiveness to NRC initiatives was generally adequate. The licensee took steps during this assessment period to correct the problems identified earlier, making improvements in maintenance procedures, work planning, PM programs, spare parts, and system engineering.
However, instances of inadequate procedures and several problems with poor implementation of procedures persisted.
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\\L Staffing in this area was adequate.
Key positions were
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actions to resolve strained resources in the inservice test review, surveillance scheduling, and maintenance areas that were identified during the previous assessment period were adequate.
Overtime work was controlled and was not excessive ~.
A weakness identified during several planning / scheduling meetings and-in the field, was a lack of teamwork among members of the different maintenance groups, and between part-of the maintenance, operations, and engineering departments which detracted from cooperation among these groups and departments.
A second weakness was a high turnover of maintenance management personnel.
Personnel in maintenance and surveillance positions were adequately qual 1fied except for technical engineering personnel who had not been trained to ensure independent verifications of test activities.
Some of these personnel participated in local leak-rate test and filter testing activities and. signed as independent verifiers when in fact they did not fulfill the requirements of the independent verification concept.
This also contributed to a discrepancy in which a door to a standby gas treatment filter bed was not properly secured.
Training of maintenance and surveillance personnel was adequate.
Training programs for craft personnel were revised to ensure that contract maintenance personnel were familiar with the plant.
Training for the containment integrated leak-rate test was excellent; the licensee held. numerous meetings between test personnel and operations personnel to ensure that the operator *.
were aware of the test requirements. Use of qualified
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-contractors for motor-operated valve. work was evident.
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Performance Rating The licensee's performance is rated Category 3 improving.
The licensee's performance was rated Category'3 in the area of
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maintenance and Category 2 in the area of surveillance in the previous assessment period.
3.
Recommendations Licensee management attention is required to ensure adequate implementation of improvements in the mechanical maintenance area and to ensure that any observations from the licensee's outage critique are implemented during subsequent outages.
D.
Analysis Evaluation of this functional area was based on one routine inspection and one annual exercise evaluation conducted by regional inspectors, and the resident inspectors' follow-up of events.
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'No violations were identified during this or the previous assessment period. However, one weakness for a failure to meet assembly / accountability-timeframes was identifie'd during the evaluation of the June 1989 annual exercise.
The licensee's identification and resolution of technical
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issues has been good.
The Radiological.-Emergency Response Plan was activated five times in response to actual events during the assessment period.
These events were properly classified, and notifications were made to offsite agencies and to the NRC within prescribed times. - Documentation for each event was
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precise and well organized; Activation summaries, critiques, reviews, and any recommended corrective actions were a part of each documentation package.
Management involvement in assuring quality has remained strong.
The emergency preparedness program continued to be well maintained and implemented, with continual program enhancements.
For example, a new personal computer based dose assessment
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program-has been developed, which incorporates human factors improvements and is similar to the Emergency Response Information System mainframe dose projection system.
In addition, the quality of the emergency response training remains high as demonstrated by good performance in the above average difficulty exercise.
0ffsite training, as demonstrated by performance during a medical drill with two local hospitals, had been well conducted.
Minimum shift staffing and emergency response capability has been well maintained as demonstrated in an augmentation drill that.was evaluated as part of the routine inspection.
In addition, an individual with chemistry experience has been added to the Radiological Emergency Response Program staff, which will enhance the staff's overall expertise.
In all cases, the licensee has been responsive to identified concerns by providing viable, sound, and thorough responses in a timely manner.
This responsiveness was exemplified in the corrective actions initiated in response to the failure to meet assembly / accountability timeframes.
These actions' included
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the installing of card readers and speaker systems at key locations and conducting practice drills.
The licensee has continued to maintain a good relationship with the State and the two counties within the emergency planning zone.
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Performance Rating The licensee's performance is rated Category 1 in this area.
The licensee's performance was rated Category 1 in the previous assessment period.
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3.
, Board' Recommendations
,.
The Board noted that, during the exercise subsequent to the SALP assessment-period, exercise weaknesses existed for the-medical drill _and for missed emergency action levels.
This appears to warrant increased management attention.
,
E.
Security
'
1.
Analysis This functional area was evaluated on the basis of two safeguards inspections and two allegation review inspections conducted by regional physical security inspectors and routine observations by the resident inspectors to evaluate security activities.
The enforcement history declined somewhat during this assessment period, although is still considered generally adequate. Three-Severity Level IV violations were noted.
The violations were issued for a management error, an equipment deficiency, and a personnel error.
Management involvement to assure the quality of the security program has generally been good. Aggressive self inspections, t
excellent performance-trend analyses, and extensive QA audit efforts have contributed significantly to the quality of the
.
security program. A strong root-cause analysis effort has generally been effective in preventing repetitive enforcement issues and programmatic weaknesses. Aggressive management actions have resolved the personnel screening and security computer' concerns identified in-the previous SALP report.
The quality of licensing related activities, such as changes to the security plan, has generally been excellent. However, a need for more attention to detail in some ' cases was noted.
A security plan revision had to be resubmitted because the original revision contained too many errors to allow a licensing analysis to be performed. Additionally, a security plan commitment pertaining _to the continuous behavior observation program was inadvertently deleted during a security plan revision and was reinstituted when the error was noted
~
during an NRC inspection.
Both of the incidents were identified by the NRC rather than the licensee's security organization.
Identification and resolution of technical issues continues to be a strength of the security program.
Licensing-related issues and allegations of a security nature are consistently evaluated in a competent manner.
Investigations completed by the security staff are generally thorough and sufficient in scope and depth, and the conclusions are adequately supported by the investigation results.
.
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Responsiveness-to NRC findings was mixed.
Enforcement issues
and_ inspection findings were generally addressed in a very timely.
manner and resolved in a-technically competent fashion.
Generally, licensee communications with NRC's Region III and the resident inspectors are frequent and effttive. However, the problems relating to maintenance-support for security equipment were not resolved during this assessment period.
This adverse trend was initially identified by the NRC during an April 1989 inspection and the trend had continued to worsen as noted_ during an NRC inspection analysis completed in December 1989.
Effective coordination between security and maintenance managers appeared weak.
The security-related event trend has improved during this assessment period.
The only security event that' required telephonic notification to the NRC was adequately analyzed, and corrective actions for this event were timely and technically correct. A conservative security reporting and logging program has continued.
Staffing continues to be a major strength of the security program.
Section managers are well qualified in their areas of expertise and have filled various positions within the Security Department. Day-to-day supervision of the uniformed force is strong and aggressive.
Planning for a potential security force strike in December 1989 was thorough and timely.
Resource allocation for nonshift positions is sufficient to assure adequate investigative capability, effective security _ plan and program evaluations, and aggressive self-inspections.
Security procedures are adequate in scope and provide detailed guidance to security personnel.
The security force training and qualification program continued
<
to be effective. However, a violation pertaining to the methodology used for requalification was noted and additional requalification training was required to resolve the issue.
Corrective actions to resolve:the issue have further strengthened the program.
The effectiveness of the training and qualification program is evident in that no personnel performance-related inspection findings were directly attributed to training or qualification weaknesses.
2.
performance Rating The licensee's performance is rated Category 1 declining in this area. The licensee's performance was rated Category 1 in the previous assessment period.
3.
Recommendations None.
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'F-E,ngineering/ Technical Support
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1.
Analysis This functional area was evaluated on the basis of one routine, i
one special, and two team inspections by regional inspectors, several inspections by the resident inspectors, a Safety System Outage Modification Inspection (SS0MI) team inspection, NRR interactions with the licensee, and NRR review of licensee submittals, One Severity Level III violation, four Severity Level IV violations, and one deviation were issued in this assessment period.
In two of the five violations, including the Severity-Level III violation, root causes occurred during the initial
>
design of Fermi 2 and are not attributable to the current engineering organization.
The Severity Level III violation dealt with the inadequate reactor building railcar door design at initial construction.
Corrective actions for these s
violations were generally prompt and comprehensive.
Virtually all of the events that resulted in LERs during this assessment period (13 out of 15 associated with this functional
.
area) were due to initial construction design weaknesses
'
including those events that caused two of the four reactor scrams. Another of these resulted in a plant shutdown, Management involvement to ensure quality has improved but is still considered mixed.
On the positive side, significant improvements were noted in the program for the dedication of commercial grade ~ equipment for safety-related applications which meets the guidelines of Generic Letter 89-02 " Actions to Improve Detection of Counterfeit and Fraudulently Marketed Products"; the licensee's actions to ensure quality in the environmental qualification (EQ) area; and in the engineering organizations, which are now well defined and staffed.
Examples of these improvements included the permanent appointment
.
of individuals to key positions within the engineering departments, i
the doubling of the system engineering staff, and the allocation of resources to ensure prompt and acceptable solutions to the EQ issues.
On the negative side, weaknesses were noted in communications-between different departments, about the lack of acceptance criteria for several postmodification tests, the drawing control system, and temporary modification programs.
Exunples of these weaknesses included potential design changes being initiated by both systems engineers and design engineers i
,
(neither group was aware of the other's actions); changes to the temporary modification control procedure, which, in error, did not include drawings at the tagging center from being updated (that has been corrected); drawings at the emergency response facilities that had not been incorporated into the as-built
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drawing program; and the-lack of post-modification testing-
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..*-
- acceptance criteria in some engineering design packages (EDPs)-
awaiting installation. However, the lack of explicit post-modification testing. requirements and acceptance criteria on several design packages was identified by the licansee and corrective action was initiated.
The effect of these corrective actions had not been assessed at the end of the
'
assessment period.
The licensee's approach to identifying and resolving technical
'
,
issues was mixed. On the positive side the licensee adequately l
demonstrated the concept of " critical characteristics" for safety-related applications of commercial grade equipment.
In the EQ area, the resolution of technical issues was conservative. The licensee continues to maintain the required
post-fire safe-shutdown capability which includes adequate procedures and equipment. labeling.
Review of the E0Ps scheduled for implementation during the first refueling outage led to the conclusion that the engineering work had been performed in a l
L generally satisfactory manner.
Additional evidence of good f
performance in this area included resolving the problem of the seals on the railcar door, resolving the problem of an inadequate diesel fire pump alternator upgrade review, interim resolution to moisture separater reheater / seal tant inadequacies, and resolving uncertainties associated with control rod drive pump venting under emergency conditions.
On the negative side, the licensee did not fully understand the external flood design bases for the railcar doors and provided incorrect input to the shift supervisor from a flooding perspective. The evaluation of a high amperage-condition on a control room fan was non-conservative.
Resolution of criteria for the emergency conditions criteria for restoration of drywell cooling and drywell venting was slow.
Also, the licensee was slow.in acquiring the data for the analysis of the residual heat removal system vibration.
Most post-modification testing was adequate. When the licensee identified problems which were due to lack of explicit acceptance criteria, an additional review of the criteria was performed to
,
ensure that the testing was adequate and to determine that the design requirements had been met.
In the case of the main
'
steam isolation valve (MSIV) control manifold replacement modification, the testing recommended by the vendor was neither specified nor performed.
In addition, the drawings used to implement the MSIV modification were incorrect, indicating a weakness in engineering oversight of installation activities.
Several cases were found where-the plant configuration was not consistent with the associated design documents. These cases involved pipe hanger configurations that were not consistent
q ) }..
.
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with the pipe-stress calculations for hanger-to pipe gaps; four
' cases where small bore pipe supports had not been installed as
depicted on the piping isometric; and a case where a support was installed but had not been analyzed.
These situations <
raised a concern with respect to the performance of the as-built
+
plant walkdown verifications to ensure that the design had been properly translated into plant hardware.
This issue was also identified in the previous SALP report. Additional walkdowns were planned by Detroit Edison Company to determine the extent of the problem.
Responsiveness to NRC initiatives was good.. Subsequent to the NRC's Diagnostic Evaluation Team (OET) inspection conducted during the previous assessment period, the licensee developed a comprehensive training improvement program to address the specific issues of the inspection.
NRC follow-up inspection found that all of these had been acceptably corrected. However, programmatic weaknesses still existed for ensuring that training was conducted on procedure revisions.
Concerns addressed in the previous SALP report regarding engineering management and supervisory positions and material management problems with the procurement and dedication of commercial grade equipment had been effectively addressed.
Timely and technically sound responses were given to many other NRC concerns.
'
Staffing levels were considered adequate.
A number of staffing weaknesses from the previous assessment period were resolved.
Training Department instructors were well trained.
Instructors had been evaluated by the licensee both in the classroom and on the simulator, and no deficiencies had been found.
Licensed operators universally stated that training had improved substantially in the last six months of the assessment period.
A particular strength in staffing was the average of greater than eight years experience level of the system engineers.
While general experience is a strength, the training program designed for the systems engineers is not scheduled to be completed for three years.
In addition, no priority is given to training individual system engineers on their primary systems. Weaknesses were evident in the licensee's training program for engineering and operations personnel.
The training programs failed to incorporate an understanding of the design-bases of safety related systems and components.
This weakness ultimately _resulted in the operations personnel making non-conservative operability decisions.
The general lack of understanding of design bases has been a problem discussed in the Operations section of the last two SALP reports. The licensee has established a design bases task force to address the problem, but the effectiveness of the program has not yet been assessed. A further training weakness dealt with the failure to establish a continuing training program for safety
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evaluations (10 CFR 50.59) preparers and reviewers.
In
-
addition, communications between system engineers and maintenance departments was a weakness.
System engineers were not fully aware of the-status of, or ongoing work on, their systems, and were not actively involved with trending and root cause analysis.
There were indications of a lack of ownership for the design packages for their systems.
2.
Performance Rating The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 3 in the previous assessment period.
3.
Recommendations l
None.
G.
Safety Assessment / Quality Verification 1.
Analysis This functional area was evaluated on the results of'16 routine and special inspections by resident and regional inspectors, and one SSOMI.
The activities examined included QA audit functions, conduct of the onsite and offsite review committees, i
conduct of the independent safety engineering group (ISEG),
licensee safety evaluations, NRC issuance reviews, and the licensee's internal corrective action system.
In addition, NRR staff reviews of license amendment requests were considered.
Enforcement history in this area consisted of seven violations (five 3everity Level IV and two Severity Level V violations)
and one example of a Severity Level III violation (discussed in the Maintenance / Surveillance section).
The example from the Severity Level III violation was indicative of a safety significant breakdown in the review of operating experience reports. Three of the Severity Level IV' violations reflected weaknesses in the' corrective action system to provide adequate or timely resolution to identified conditions adverse to quality.
Another Severity Level IV violation reflected numerous weaknesses in the safety evaluation (10 CFR 50.59) process.
- Corrective actions completed during this assessment period were generally timely and adequate.
Staffing of the licensee's QA/QC department was substantial.
The staff was composed of technically oriented individuals who had adequate plant experience.
These staff resources were appropriately used to perform audits and surveillances.
In addition to its normal QC tasks, the QC group performed almost
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200 performance-based surveillances of work in progress. The
' plant safety group, which provides coordinators and reviewers
'
for the-licensee's internal corrective action system, was well
'
e staffed. Attendance at offsite and onsite review committee meetings was always well above minimum TS requirements. A staffing weakness in ISEG noted in the previous assessment period improved with the TS minimum membership tequirement maintained throughout the assessment period.
,
-Substantial progress was made in training and qualifying plant staff.
For example, nearly all of the QA staff was trained on performance-based inspections; over 100 members of the licensee's organization received root cause training (lack of such training was identified as a weakness in the previous SALP report); and leadership training of some form was provided to approximately 140 personnel.
Management involvement in the assurance of quality continued to-be evident and effective in a number of the licensee's independent quality oversight activities.
The Nuclear Safety
'
Review Group (NSRC) (which is the offsite review committee)
continued as a strength through effective independent reviews.
This was evidenced when ISEG, which is a part of NSRG, identified potential design capacity deficiencies in proposed decay heat removal methods to be used during the refueling outage. The NSRG continued to be actively involved in the audit
'
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process.
Both onsite and offsite committees met significantly more than required by TS and generally reviewed the appropriate subjects ascribed to that committee's function.
Management continued to improve quality oversight capability throughout the assessment period.
Substantial progress was made in the implementation of the HpES with 15 additional people trained as HPES reviewers.
Also, a full-time coordinator was assigned to the-HPES effort to ensure the success of the program.
Accountability' meetings continued and were supplemented with
'
critiques to further derive the root cause of errant performance.
Licensee SSFIs were continued, with the low pressure coolant injection system reviewed during the assessment period. The only weakness noted in the SSFI program was a lack of QA involvement in the corrective actions for SSFI findings. As a further aid to improving quality, the licensee requested, and the NRC gave, a presentation to Fermi employees on generis refueling / outage problems that the NRC had observed at other facilities throughout the Midwest.
The quality of 10 CFR 50.59 safety evaluations improved during the assessment period with involvement from the NSRG and ISEG which reviewed and graded the quality of all safety evaluations and rejected substandard ones.
Initially, the decision making
.
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process for what constituted a safety evaluation, called a
' preliminary safety evaluation in the licensee's system, did not
-
involve NSRG and the ISEG and resulted in certain changes not
'
being classified as needing a safety evaluation. Consequently,
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NSRG/ISEG overview of the preliminary safety evaluation process
,
was initiated midway through the assessment period.
QA audits continued to be effectively used to identify weaknesses.
The audit reports were of good quality and indicated that,a
. substantial portion of the audits were performance based; the reports documented QA findings and observations.
Management involvement in the corrective actions to QA findings / observations, however, was occasionally ineffective.
For example, a number of the deficiencies in the maintenance area such as, failure to follow procedures, inadequate first-line supervision, absence of pre-job briefings, and inadequate storage practices at the maintenance shop QA Class 1
..
storage case had been previously identified by the licensee and
'
corrective actions had been initiated.
However, subsequent NRC reviews identified the same concerns even after corrective action had been taken.
.
Management involvement continued to be ineffective.at managing certain aspects of the internal corrective action systems.
Furthermore, corrective actions occasionally were too narrowly focused. Also, resolving problems reported in DERs was occasionally slow.
This slow resolution also was a weakness reported during the previous assessment. period.
The procedure
. controls associated with the corrective action closure process were not followed.
Corrective action time tables were not being adhered to, and extensions to corrective action time tables were
being, inappropriately authorized.
The most notable example of this was the six month-delay in evaluating the improper installation of some monitoring equipment in the control room.
Management involvement was weak in two other areas. The first area was the untimely review and follow-up of operating experience reports (OER) where a safety-significant breakdown occurred. This breakdown was ' identified early in the-assessment period during a reactor recirculation pump breaker failure review at which time the lack of OER follow-up was identified as a significant contributor to the " causal factors" associated with the breaker failure; OER follow-up did not improve following the above events.
Later in the assessment period the second area of concern was the lack of a program for the receipt and evaluation of vendor service bulletins. As a result, the last seven service bulletins for the emergency diesel generators had
,
not been evaluated. The licensee's' approach to the resolution
af**
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i of this OER situation has subsequently been determined to be
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strong. Significant resources and management overview were
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provided to rectify ~ the OER review process.
In addition, current operational events information has become an integral
part of the daily management staff meetings. Adequate short-term corrective actions to DER extension deficiencies were immediately initiated. The long-term effectiveness to the extension of
deficiencies, the QA audit weaknesses, and the vendor manual control area has not been assessed.
Responsiveness to NRC initiatives was mixed. Responses to NRC generic communications such as bulletins and generic letters
,
were timely. and generally complete. The licensee demonstrated a
responsiveness, initiative, and cooperation in resolving other licensing issues such as those about the detailed control room design review, safety parameter display system and various TS changes. The licensee has provided acceptable schedules for completion of the Individual Plant Examinations. A Level I plant specific probabilistic risk assessment without external events or internal floods was completed near the end of the assessment period; however, revision to include modifications made during the refueling outage are planned. The licensee also committed to install a hardened wetwell vent by the end
,.
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of the third refueling outage in response to Generic l-Letter (GL)89-16 " Transmittal of NUREG-1262, ' Answers To Questions at Public Meeting Reimplementation of 10 CFR 55 on Operators Licenses.'" These intentions and associated schedules were acceptable.
However, on a few occasions the NRC staff required additional information obtained through repeated correspondence to support the review of these responses as exemplified in the reviews for GL-88-01 "NRC Position on IGSCC in BWR Austenitic Stainless Steel Piping," GL-88-12 " Removal-of Fire Protection Requirements from Tech Specs," and GL-89-21,
" Request for Information concerning Status of Implementation of Unresolved Safety Issues (USI) Requirements." For a few issues, reviews of licensee submittals were delayed because of
,
incomplete, inaccurate, or incorrect submittals. Also, the licensee was not forthright in initially informing the NRC, and subsequently justifying, the use of 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shifts.
A large number of license amendment applications were submitted to the NRC during this assessment period.
The majority of the amendment packages required additional information to allow the NRC staff to make a final decision on the applications.
In one case, the Cycle 2 Reload TS change,
,
the licensee failed to provide accurate TS pages, which led to the need for an emergency TS change.
The TS change was issued in such a manner that the plant would have been operated in an unanalyzed condition had it not been found by a nuclear engineer.
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'The licensee was responsive in sharing SSFI results with the NRC.
This same performance was present in responding to NRC surveys and special requests to conduct timely reviews of issues, such as those associated with fuel oil, local criticality during fuel loading and chlorine storage.
Responses to violations were generally adequate. Activities committed to in Confirmatory Action letters continued to be
implemented in a timely and adequate manner.
2.
performance Rating The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous assessment period.
3.
Recommendations None.
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V.
SUPPORTING DATA AND SUMMARIES
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A.
Licensee Activities Fermi 2 Nuclear Power Plant began the assessment period near 100 percent power and maintained power operation for the next eight months except for three short-duration forced outages.
The unit was shut down in early September for its first refueling outage.
Upon conclusion of the outage, the reactor was restarted on December 8, 1989.
Fermi 2 completed post refueling testing activities and was operating at approximately 100 percent power at the end of the assessment period.
Fermi 2 had 24 ESF actuations and 7 reactor protection system (RPS)
actuations during the assessment period.
Four of the RPS actuations resulted in reactor scrams above 16 percent power and three occurred during the refueling outages with'no rod movement.
Two of the four reactor scrams from greater than 15 percent power were automatic.
Two scrams were the result of design deficiencies and
,
two were related to inadequate personnel performance.
Significant outages and events that occurred during the assessment period are summarized below.
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Significant Outages and Events
.1.
On January 3, 1989, the unit was placed in cold shutdown due to excessive hydrogen leakage into the stator water cooling system.
During the plant. shutdown, a reactor recirculation pump field breaker failed to open.
Upon completing the hydrogen-leak repair activities and replacing of the field breaker, the unit was restarted on January 13, 1989.
2.
On January 26, 1989, an automatic reactor scram occurred, which was due:to a design deficiency in the reset mechanism of the turbine overspeed test device. The unit was restarted on January'27, 1989, upon completion of recovery activities.
'3, On March 7,1989, a manual reactor scram was initiated when high vibration in a low pressure stage of the turbine generator was experienced. Numerous balancing activities ensued with some success.
After receiving recommendations from the turbine manufacturer, the unit entered power operations on March 19, 1989.
4.
On September 4, 1989, the unit was placed in cold shutdown because of excessive hydrogen leakage into the stator water cooling system.
This was the same problem that caused the January 3, 1989, shutdown.
Once in cold shutdown, the licensee commenced the first refueling outage, a week early.
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f';ey
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5.
From September 4 to December.8,~1989,.the first refueling
'
outage was conducte'd. Major activities included fuel offload / reload,- replacement of 20 control rods, local leak rate test / integrated leak rate test, 18-month surveillance tests, removal of the 5th-stage blaces from the main turbine generator and major modification to the ATWS/ alternate rod insertion system.
6.
On December 16, 1989, Fermi synchronized the turbine generator to the grid, thus ending its first refueling outage on day 98 of a-planned 56-day outage.
7.
On December 19, 1989, the reactor automatically scrammed from 25 percent power because of a personnel error; an operator accidentally closed three MSIVs during testing restoration activities. This resulted in a 44.5 hour5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> outage.
,
8.
On December.23, 1989, while at 40 percent power, a fire was discovered in the lagging of the main turbine; the operator manually scrammed the reactor.
This resulted in a 25.2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> outage.
8.
Inspection Activities Thirty-five inspection reports are discussed in this SALP Report and are listed in Paragraph 1 of this section, Inspection Data.
<
Table 1 lists the violations by functional areas and severity levels.
Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summary, 1.
Inspection Data Facility:
. Fermi 2 Nuclear Power Plant Docket No.:
050-00341 Inspection Reports No.:
89002 through 89031, and 89033 i
through 89036, and 90002 i
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ga, TABLE 1
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Number of Violations in Each Severity Level
FUNCTIONAL AREAS I
III IV V
L a.
Plant Operations
1 t
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b.
Radiological Controls
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c.
Maintenance / Surveillance
6
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d.
!
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-
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e.
Security
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f.
Engineering / Technical Support
4
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g.
Safety Assessment /Ouality
e
' Verification
2 i
-
-
-
i TOTALS
24 8
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2.
Special Inspection Summary L'
A list of significant inspections conducted during this assessment period are listed below:
'
a.
During January 5 - 25, 1989, a special safety team l
inspection was conducted relating to the failure to take'
appropriate actions and to follow procedures with respect'
to the lubrication of the CAM following slot of a AKF-225 breaker.
On. February 8, 1989, an enforcement conference
,
was held relating to these items (Inspection Reports i
No. 341/89003 and No.-341/89005; Enforcement Case
No. EA-89-006),
b.
During January 23 - February 3,1989, a special inspection of the licensee's inservice testing program, and a DET
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relating to motor-operated valves was conducted
(Inspection Report No. 341/89004),
c.
During February 3 - April 12,1989, a special inspection
!
associated with reactor building railcar door, design deficiencies and the improper translation off design basis
.'
(i.e., the door seal was not designed and installed as a safety-related seismic system) was conducted.
(Inspection Report No. 341/89006; Enforcement Case No. EA-89-106),
d.
During.ine 13 - 15, 1989, the annual emergency preparedness exercise was conducted (Inspection 6 eport No. 341/89019).
e.
During June 26 - July 20, 1989, a team inspection was conducted to review the implementation of the licensee's Por.t Fire Safe Shut Down Capability Configuration Management Program and Fire Protection Program (Inspection Report No. 341/89020).
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' f.
During July 17 - August 4,1989, a SSOMI team inspection was conducted (Inspection Report No. 341/89200).
l g.
During October 30 - December 30, 1989, a maintenance / engineering team inspection was conducted,
!
relating to previous diagnostic team findings, SSOMI findings, programmatic review of the maintenance, engineering, and procurement organizations (Inspection i
Report No. 341/89024).
C.
Escalated Enforcement Actions g
1.
On January 6, 1989, a Severity Level III violation and proposed
imposition of a civil penalty was issued to the licensee in the
'
amount of 550,000. This action was based on the licensee's
failure to establish adequate design measures to ensure that
,
motor operated valve torque switches were properly installed
,
and set. On February 7,1989, the licensee paid the $50,000
civil penalty.
(Inspection Report No. 341/88025; Enforcement Case No. EA-88-281; Enforcement Notice No. EN-89-001).
L Discussion for this violation was included in the previous SALP-Report No. 341/88001.
l 2.
On January 26, 1989, the licensee paid a $175,000 civil
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penalty.
This action was based on two items: (1) the discovery that the containment isolation provisions for the primary containment radiation monitoring system was not consistent with requirements of 10 CFR Part 50 General Design Criterion 56; and j
(2) Operation of the non-interruptible air system in a degraded i
mode, which resulted in the violation of two Technical
L Specifications (Inspection Reports No. 341/87048 and No. 341/88014; Enforcement Case No. EA-88-104; Enforcement Notices EN-88-052 and No. EN-88-052A).
3.
On May 23, 1989, a Severity Level III violation without a civil
!
penalty was issued to the licensee for inadequate maintenance
'
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i in March 1988, which ultimately led to the failure of the "B" J
"
reactor recirculation pump motor generator field breaker.
In
addition, the licensee _ failed to implement timely corrective actions in response to identified deficiencies, which included a personnel error.
(Inspection Reports No. 341/89003 and No. 341/89005; Enforcement Case No. EA-89-006).
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On November 14, 1989, a Severity Level III violation without a civil penalty was issued for failure to properly construct the reactor building railcar door system, which is needed to maintain
!'
secondary containment integrity and to provide flood protection in accordance with regulatory requirements.
(Inspection Report
No. 341/89006; Enforcement Case No. EA-89-106; Enforcement-
!
Notice No. EN-89-104).
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D.
Confirmatory Action Letters
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,
On January 4,1989, a Confirmatory Action Letter (CAL-Rill-89-001)
was issued to the licensee as a result of the failure of "B" train recirculation pump motor generator field breaker, and the failure to implement timely corrective action in response to identified deficiencies.
E.
Review of Licensee Event Reports (LERs)
Thirty-nine LERs were issued in accordance with NUREG-1022 guidelines during the assessment period.
Table 2 shows the cause-code comparison of SALP 10 and SALP 11 Cycles.
LER Nos.:
89001 through 89039.
-.
TABLE 2 SALP 10 SALP 11 (9 Mo.)
(12 Mo.)
CAUSE AREAS NO.
PERCENT NO.
PERCENT Personnel Errors
48.3
33.3 Design Problems
3.5
33.3 External Causes
3.5
0 Procedure Inadequacies 3 10.3
20.5 Equipment / Component
34.6
12.9 Other/ Unknown
0.0
0 TOTALS
100%
100%
FREQUENCY LERs/MO 3.2 3.3 NOTE:
The above LER information was derived from the review of LER5 performed by the NRC staff, and may not completely coincide with the licensee's cause code assignments.
33