IR 05000346/1989001
| ML20245G267 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/25/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20245G242 | List: |
| References | |
| 50-346-89-01, 50-346-89-1, NUDOCS 8905030105 | |
| Download: ML20245G267 (32) | |
Text
_ _ ___ ___________ __ _
.
.
,
.
SALP 7
.
SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-346/89001 Inspection Report No.
Toledo Edison Company Name of Licensee Davis-Besse Name of Facility January 1, 1988, through February 28, 1989 Assessment Period l
HPinn!?nlB6 g
_ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _.
l
..
.
.
TABLE OF CONTENTS
-
Page No.
l
I.
INTRODUCTION........................
I
II.
S UMMAR Y O F R E S U LT S......................
l A.
Overview.
......................
B.
Other Areas of Interest.
...............
III. CRITERIA..........................
IV.
PERFORMANCE ANALYSIS....................
A.
Plant Operations
...................
B.
Radiological Controls.................
C.
Maintenance / Surveillance
...............
D.
................
E.
Security
I
.......................
F.
Engineering / Technical Support.
l
............
G.
Safety Assessment / Quality Verification
........
V.
SUPPORTING DATA AND SUMMARIES
...............
A.
Licensee Activities..................
B.
Inspection Activities.................
C.
Escalated Enforcement Actions..
...........
D.
Confirmatory Action Letters (CAls)
..........
E.
License Amendments Issued...............
F.
Review of Licensee Event Reports Submitted by the Licensee...................
i l
,
I
,
l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _.
_ _ _ _ _ _ _ _ _
._
J
.
..
.
l I.
INTRODUCTION
'
The Systematic Assessment of Licensee Performance (SALP) program-is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this i
information.
The program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
-
April 12, 1989, to review the observations and data on performance, and to assess licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this i
report.
The Board's findings and recommendations were forwarded to the j
NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance i
at Davis-Besse for the period January 1,1988, through February 28, 1989.
!
l SALP Board for Davis-Besse was composed of:
Name Title
!
A. B. Davis Regional Administrator i
- H. J. Miller SALP Board Chairman; Director,
Division of Reactor Safety (DRS)
l
- J. Hickey Acting Director, Division of Radiation l
Safety and Safeguards (DRSS)
- J. N. Hannon Director, Project Directorate III-3, Office of Nuclear Reactor Regulation (NRR)
- W. L. Forney Deputy Director, Division of Reactor l
Projects (DRP)
'
- R. C. Knop Chief, Reactor Projects Branch 3, DRP
- * *L. R. Grege r Chief, Reactor Programs Branch, DRSS
- R. W. Cooper Chief, Engineering Branch, DRS
- * * *G. C. Wright Chief, Operations Branch, DRS W. G. Snell Chief, Emergency Preparedness and Effluents Section, DRSS J. R. Creed Chief, Safeguards Section, DRSS
- R. W. DeFayette Chief, Reactor Projects Section 3A, DRP M. C. Schumacher Chief, Radiological Controls and l
,
Chemistry Section, DRSS T. E. Ploski Emergency Preparedness, DRSS
- T.
V. Wambach Project Manager, NRR
- P. M. Byron Senior Resident Inspector, Davis-Besse
_ _ _ _ _ _ _
._
..
.
.
!
-
D. C. Kosloff Resident Inspector, Davis-Besse
'
R. K. Walton Resident Inspector, Davis-Besse i
W. J. Kropp Reactor Inspector, DRS'
T. E. Vandel Reactor Inspector, DRS H. A. Walker Reactor Inspector, DRS A. Dunlop Reactor Engineer, DRP J. Clifford Regional Coordinator, Office of the
!
Executive Director for Operations l
- Denotes voting members.
'
- Denotes voting members for Maintenance / Surveillance area.
- Denotes voting member for Radiological Controls, Emergency Preparedness, and Security areas.
- Denotes voting member for Engineering / Technical Support area.
,
l l
)
_ __ _ ______.
,.
.
II. SUMMARY OF RESULTS
.
A.
Overview This assessment period is from January 1,1988, through February 28, 1989.
During the first 2 1/2 months of the period, the reactor operated at power to finish out the operating cycle. On March 10, 1988, it was shut down for a refueling / maintenance / modification outage which lasted until December 5, 1988. During this time, 186 modifications were made to the plant. The reactor then was taken critical and operated at power until the end of the assessment period. There were two reactor trips during this last 2 month period.
The licensee's performance generally remained about the same in this assessment period as in the previous period.
It received i
five Category 2 ratings and two Category 1 ratings.
Emergency l
Preparedness improved from Category 2 to a Category 1, but
'
Radiological Controls decreased from Category 1 to Category 2.
This decrease was exemplified by:
failure to fully implement a post-accident sampling system; higher than normal (for Davis-Besse)
yearly doses; and frequent inoperability of effluent monitors.
Although the rating for Plant Operations remained a Category 2, it was
" low" 2 based in part upon the performance in December which leo to a potential escalated enforcement issue for loss of
!
'
control of licensed activities in the Control Room.
In the area of Safety Assessment / Quality Verification, the NRC believes that management at times is slow to react to events and condition: which can impact personnel performance.
In the previous SALP report, the NRC stated it would continue to monitor the licensee's performance with respect to management changes and staff morale.
This was done and as is noted in the report staff morale is not the concern it was during the previous assessment period.
There also were no identifiable problems which may have occurred from the changes in middle and upper level managers.
The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
i
- _ _ _ _ _ _ _ _ - _ _ _ _.
.
..
.
.
'
Rating Last Rating This
.
Functional Area Period Period Trend Plant Operations
2
,
Radiological Controls
2 j
Maintenance / Surveillance 2/1
1 Security
1 Engineering / Technical Support
2 i
Safety Assessment / Quality Verification NR
NR - Not Rated B.
Other Areas of Interest i
None i
!
..
_ _ - _ _ _ _ _ _ _ _ _ _ _
..
.
.
)
.
III. CRITERIA
-
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:
I.
Assurance of quality, including management involvement and control; 2.
Approach to the resolution of technical issues from a
)
safety standpoint; 3.
Responsiveness to NRC initiatives; 4.
Enforcement history; 5.
Operational events (including response to, analyses of,
,
reporting of, and corrective actions for);
{
l 6.
Staffing (including management); and 7.
Effectiveness of training and qualification program.
l However, the NRC is not limited to these criteria and others may have been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definition 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 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 performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regu'latory 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.
Category 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 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 if near-term performance is of interest.
Licensee performance during the last quarter of 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:
_ Improving:
Licensee performance was determined to be improving near the close of tSe assessment period.
Declining:
Licensee performance was determined to be declining near the
!
close of the assessment period, and the licensee had not taken meaningful
steps to address this pattern.
i I
l i
!
!
,
)
l
_ _ _ _ _ _ - _ _
.
..
.
.
IV Performance Analysis I
I A.
Plant Operations
)
-i 1.
Analysis I
. Evaluation of this functional area was based on the results of nine routine inspections by the resident inspectors, four'
'I inspections by regional inspectors, and two team inspections.
.)
~
Comparisons of the results of this 14-month assessment period with the previous 12-month assessment period must be tempered, however, because of a 9-month maintenance and refueling outage that occurred during this assestment period. The plant operated nearly continuously during the previous assessment period.
Enforcement history in this functional area for this assessment period generally was adequate. There were'three. Severity i
Level IV violations compared with four Severity Level IV violations and one Severity Level V violation during the
'
previous assessment period.
However, shortly after the end of this assessment period, an enforcement conference was held with the licensee to discuss an event related to loss of control of-licensed activities in the control room that occurred shortly before the end of this assessment period.
This is being considered for escalated enforcement.
The plant experienced two reactor trips during the 5 months of operation during this assessment period, compared with six reactor trips during the previous 12-month assessment period.
One of the two trips was attributed to the plant operations area and resulted from high flux'that occurred while the operators were manually controlling feedwater and power demand i
with the reactor at 28% power. The other reactor trip occurred from 100% reactor power and resulted from a component failure during the performance of a surveillance test.
Fourteen events attributed to activities in this functional area required the submittal of licensee event reports (LERs) during this a_ssessment period.
Nine of these are related to fire protection issues and will be discussed later in this section.
Four of the remaining five involved, at least in part, personnel error.
The fif th LER was for the reactor trip caused by the component failure.
Of the ~four LERs submitted during the i
previous assessment period, three involved, at least in part, i
personnel errors.
The operating personnel generally demonstrated good control room professionalism. Morale has improved and is'not the significant-
,
!
issue that it was previously. The personnel generally supervised and cor. trolled plant activities during routine operations, the major outage, and off-normal events.
They
,
- _ ___________
___
__ ___
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _.
_
i'
- ..
.
.
displayed a high degree of attentiveness, good knowledge of.
J
.
plant status and regulatory requirements and appeared to have l
positive safety attitudes. 'However, vertical communications
,
within the Operations Department has shown signs of weakness.
)
.
.
.
.i There was one significant event, however, soon after the restart'
i from the extended outage, when the operating crew attempted to withdraw a dropped group of control rods.without fully recognizing the status of-the plant. This 1s the' event'being i
considered for escalated enforcement and is of concern because-
it represented a.non-conservative approach to operations, lack'
i of communications in the control room, and failure of: the crew to adequately analyze the situation. Also near the..end of.~the assessment period, there appeared to be an adverse trend in operations' staff performance as documented in.the licensee's
potential condition adverse to quality (PCAQ) reports. After reviewing such reports for the November-December time frame, the PCAQ review board directed quality assurance (QA) management-e to issue a management corrective action report.(MCAR) because of.
concerns related to judgmental errors by the operations staff
.
and by shift supervisors.
The,0perations Department response; to the MCAR was twice rejected by the QA management for inadequacy. At the close of the assessment period a third response had not yet been submitted.
The total number of licensed staff is excellent. The licensee has 20 reactor operators (R0s) and 52 senior reactor operators (SR0s). This allowed.the licensee to initiate a six-shift rotation, which allows one shift to be in training at all times.
During this assessment period, 8 RO examinations were administered with 3 failures, and 29 SRO examinations were' administered with 5 failures.
However, the failure trend increased near the end of the assessment period when 3 of 6 R0 candidates and 2 of 10
SR0 candidates failed.
Three shift supervisors and the Operations
!
Superintendent were among those licensed during the assessment-
,
period.
]
The licensee has embarked upon-a program to provide depth and experience in its management and professional staff by J
encouraging selected individuals to attain a SRO license.
The Plant Maintenance Manager and the System Engineering Manager entered the SRO licensing program near the end of the assessment period. All shift technical advisors (STAS) now have SRO
,
l licenses.
l
'
With the exception of the rod pull event discussed-previously,.
!
management generally addressed safety problems aggressively and conservatively.
For example, the licensee voluntarily shut the plant down during a reactor startup from'the extended outage-when an instrument valve was found out of position'and not included on a valve lineup.
The plant was down for about two
j
_ _ _ - _ _ _ - - - _ _ _ _ - - _ - _ - _ _ _ _ _ - _ _ _ _.
_ _-.
.
-- -- _ -
- _ _ _ _ _
-
.
,.
.
weeks while a complete walkdown of all similar valves was i
-
conducted. Another example is the rapid assembly (within 30
minutes) of transient assessm nt teams to evaluate and analyze i
significant events.
Still another example was the licensee's thorough investigation of the circumstances that caused a small piece of metal to fall into the reactor vessel.
Management was involved in assuring quality in plant operations.
Site managers and supervisors performed frequent control room i
observations and plant tours; attended " plan of the day" (P00)
)
meetings; and met with operations staff after events to discuss-
" lessons learned." Communications were improved during this assessment period by the use of two-way radios, and implementation of shift meetings and more formal shift turnover
,
l meetings.
Plant procedures was an area in which management's initial involvement was inadequate in that there was ample evidence
that problems existed with procedures, yet timely corrective l
actions were not initiated until the licensee was pressed by
the NRC.
For example, as a result of identified problems with quality control (QC) procedures, a' management meeting was conducted between the licensee and the NRC. As a result of that meeting, and at the instigation of the NRC, the licensee performed a site-wide audit of all procedures and identified
generic problems with the procedures.
It then issued two MCARs, i
one addressinc operations procedures and one addressing all other procedures. As a result of the MCARs, the licensee initiated an upgraded program to validate and reverify selected operations procedures prior to reactor startup from the outage.
Several problems were found and corrected during this process, j
although the problems did not appear to be safety significant.
One reason this prcblem existed was that mansgement apparently l
failed to comprehend the magnitude of the effort required to incorporate into the procedures the changes resulting from the 186 modifications made during the outage.
Two NRC team inspections relating to procedures occurred during i
this assessment period.
A Region III team reviewed and verified the licensee's actions for the revalidation.and reverification i-of the selected operations procedures noted above. Another I
team reviewed the emergency operating procedure (EOP) and the ancillary abnormal procedures and their implementation.
Both teams determined that tne licensee's actions and procedures were acceptable.
Region III personnel also observed licensee
requalification exams at the Babcock and Wilcox (B&W) simulator in Lynchburg, Virginia and concluded that the operators were knowledgeable and capable.
l The licensee's fire protection program in the area of operations has been fraught with problems during this assessment period.
9
- - __ - - - - -__
,.
..
-
Previously, the licensee was granted an extension until the end of the sixth refueling outage (about mid 1990) to be in compliance with 10 CFR 50, Appendix R.
As a result, it is required to establish and maintain various compensatory measures.
This causes an added burden on the operations staff which must determine the need for the proper measure and verify that it is.
implemented.
This implementation has resulted in many errors as evidenced by the 11 LERs (of a total of 32).and by.the high numoer of PCAQs attributed to fire protection.
Nine of the 11 LERs were attributed to the Plant Operations functional area and the other two were attributed to the Maintenance / Surveillance functional area. Eight of the nine in Plant Operations'were attributable to personnel error as was one of the two attributed to Maintenance / Surveillance.
One area that improved was that the licensee established a fire brigade training center with the City of Oregon Fire Department and also signed a working agreement to use the fire training facilities of a local refinery.
Housekeeping conditions within the plant were good throughout this assessment period.
It was noted during the outage that the operators were instrumental in assuring that support organizations maintained good housekeeping. Zone engineers also are assigned specific areas to ensure good housekeeping.
Control of combustible material was good. The licensee also established and implemented an effective program to control scaffolding.
The licensee has been responsive to NRC initiatives and communicates openly with the NRC. As an example, the resident inspectors observed during the first part of the assessment period that there was an increasing trend of errors caused by lack of atVtion to detail. After the resident inspectors discussed this with the licen:;ee, the licensee increased its efforts to make the operators aware of the problem.
The number of events attributable to lack of attention to detail has decreased.
,
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
.
l
,
_-___-____ _ __a
- _ _ _ _ - _ _ _ _ _ -
,
i
,
,.
.
.
B.
Radiological Controls
1.
Analysis i
Evaluation of this functional area was based on'the results of
!
three routine inspections and one team inspection by regional
-)
inspectors, and on observations made by resident inspectors.
'
Enforcement history in this functional' area was essentially the I
same as for the previous assessment period.
There was one Severity Level IV viole f on in the current assessment period as compared with no violations identified during the pravious period.
The violation was for failure to identify and quantify I
an abnormal gueous radioactive effluent release in'the semiannual radioactive effluent release report.
It was.not
~
indicative of a significant programmatic weakness.
Three events which attributed to activities in this functional
area required the submittal of LERs during this assessment l
period; each had a different causal factor.
)
l Staffing in this functional area was ample.
No significant
)
.
adverse long-term affects appear to have resulted from the major staffing and organizational changes discussed in the previous SALP report.
Satisfactory progress was made-in the planned hiring and training of additional qualified health physics technicians.
I Management involvement in assuring quality was generally good
'
with some exceptions.
In response to previous audit and assessment findings, the licensee continued its program to further formalize and standardize the radiological control program..The licensee effectively used its Radiological Awareness Reporting System to record and investigate radiological problems identified by station personnel, and to initiate corrective measures. However, the licensee's management controls with regard to effluent monitoring systems were weak. The effluent monitors were frequently inoperable due in part to unreliable equipment, poorly defined and understood interdepartmental interactions, and failure to aggressively pursue and resolve problems identified with the radiation monitoring systems.
The licensee's responsiveness to NRC initiatives has generally l
been good with the exception of slow progress regarding needed
~{
modifications to the post accident noble gas high range detector
,
l system.
Examples of good performance include completion of a new radwaste handling building, improved technical review'of I
radiological analyses, and associated improvement in radioactive materials storage capability and improved laundry monitoring capabilities.
The licensee's ALARA task management program for high dose rate / total dose and actual path radiological work i
l I
_
,
..
..
i appeared good. However, scheduling / planning for other radiological
.I
.
work was frequently performed without advance coordination with other departments which.could result in inefficient work and a
possible receipt of unnecessary radiation dose.
{
The licensee's approach to resolving technical issues was generally good as evidenced by the installation-and operation of a new contaminated water cleanup system. Total station dose for 1988 was about 308 person-rem, significantly above the 1986 total dose of 124 person-rem and 47. person-rem in 1987. -The i
1988 total dose, which resulted from an' extensive extended I
outage and unplanned work on high pressure injection nozzles,
remained below the average for pressurized water reactors (PWRs).
Liquid and gaseous radioactive effluent releases are only a small fraction of Technical Specification limits and show a downward trend. Although' total volume of solid radioactive-waste is relatively low, it was higher than what would be expected by current industry standards.
No transportation incidents occurred during this assessment period.. The quality of radiological confirmatory measurements improved and was excellent (110 agreements out of 113 comparisons); licensee personnel were effective in identifying causes of initial disagreements and effecting immediate corrective actions when possible. The Radiological Environmental Program has been satisfactorily implemented.
2.
performance Rating l
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 1 in the previous assessment period.
3.
Recommendations I
None l
C.
Maintenance / Surveillance 1.
Analysi s Evaluation of this functional area was based on results of' ten
,
routine resident inspections and six regional inspections
!
including a team inspection.
Maintenance and surveillance were separate functional areas in the previous assessment period but
!
have been combined as one functional area for this assessment period.
,
h Enforcement history during this assessment period indicated a slight decline in performance.
Four Severity Level IV
.
!
violations and one Severity Level V violation were identified l
,
i
..
..
'
as compared with two Severity Level IV violations (two in l
-
maintenance and none in surveillance) in the previous assessment period.
Two of the violations were the result of personnel error.
Operational events in this area did not indicate the existence of any pervasive weaknesses in the licensee's control of maintenance activities affecting plant operations.
Seven events attributed to activities in this functional area required the submittal of LERs during this assessment period compared with eight during the previous assessment period (four in maintenance and four in surveillance).
Three of the current LERs were related to surveillance, three were related to maintenance, and one was related to a vendor deficiency.
Four of the LERs were j
due to personnel error, one of which resulted in a dropped control rod group that resulted in subcriticality.
During this assessment period, the licensee demonstrated mixed I
results in attending to the backlog of corrective and preventive
!
work orders.
The maintenance team inspection conducted in September and October 1988 assessed the backlog of non-outage-related corrective maintenance work orders (MW0s) and determined i
that the backlog was at a reasonable level. The backlog remained I
essentially constant over the year; a small increase in l
non-outage MW0s since January 1908 was attributed to the extended outage.
Reporting practices provided high visibility for both preventive and corrective maintenance backlogs.
However, the method of grouping components for the same preventive maintenance (PM) action made it difficult to determine the actual number of components past due.
Surveillance work for safety-related systems and components was well planned and professionally performed.
However, maintenance planning was inadequate in some instances and immediate action maintenance was used excessively.
Except for immediate action maintenance, work packages with detailed instructions, and drawings were used at the job site. The work performed, post maintenance testing, and problems identified were well documented.
The same controls used for safety-related equipment MW0s were also used for balance-of plant equipment.
The licensee maintained a.well-trained and qualified maintenance and surveillance staff. Training was not a root cause in plant events.
The licensee has integrated licensed SR0s and R0s in planning and scheduling, outages and maintenance, and surveillance teams.
The licensee's staff demonstrated a positive safety attitude.
Two new senior personnel were assigned to the Maintenance Department during this assessment period, one as Maintenance Manager and the other as Instrument and Control (I&C)
Superintendent.
These changes occurred during the latter part
- _ _ _ _ _ _ _
_ _ _ _ _ _ ______ -_ _ _ _ _ _ _.
..
.
.
of the assessment period. The stability of the I&C organization is a concern given the large backlog of work.
Staffing levels and qualifications were adequate to implement the routine chemistry analyses. The Chemistry Department was reorganized; its Superintendent reports to the Operations Department.
Management involvement to ensure quality in this functional area was mixed. Management involvement in the maintenance program was evident during plant outages and refueling activities and it continued to stress the importance of the surveillance program which continues to be well run.
Surveillance tests are tracked on a computerized tracking system that is reviewed daily and lists an early date, a scheduled date, and a late date. The licensee's staff is held accountable for meeting the given dates. Only two surveillance during the assessment period were missed and both occurred at the end of the period.
One resulted in discretionary enforcement action because the surveillance test could not be performed when required.
Further evidence of management involvement included a comprehensive planning and scheduling program; improvement of PM and equipment reliability; phasing in a predictive maintenance program; a manageable level of the backlog of MW0s; and water chemistry parameters that were generally well within Electric Power Research Institute (EPRI)
guidelines.
In several areas, there was evidence that management involvement was not at a level to effect good performance.
During the performance of the containment integrated leak rate test, several anomalies were identified, which included improper valve lineups and documentation of retests.
The maintenance team inspection identified.several weaknesses that included examples of failures to assess and trend component failures; weaknesses in the PM program including inadequate scope, deferments of work, and backlog tracking; root cause analyses that were too narrow in scope; excessive use of immediate action maintenance; parts unavailable (note:
improved since the previous assessment);
and the threshold for identifying required maintenance too high in some instances (e.g., service water pump leaking excessively).
Management involvement was also weak in the area of calibration of protective relays which traditionally had been the responsibility of the licensee's corporate organization.
The station assumed responsibility for calibrating these relays before it had qualified personnel and appropriate equipment to perform maintenance on the relays.
As a result, the calibration of protective relays was not adequately controlled. Other l
weaknesses were noted in needed integration into the overall schedule of modifications, surveillance and PM activities, and lack of tool lists in maintenance and surveillance procedures.
These weaknesses could also result in inefficient work and unnecessary radiation dose.
!
_ - _ _ _ - _ _ _ _
i
.
.
.
'
The planning program is computer based and provides scheduling
_l
-
and tracking. - PM activities are integrated into a 52 week rolling schedule..The program also provides a detailed schedule in a 6-week cycle.
Performance and surveillance tests i
are integrated into a 28-day rolling schedule. Work to take
.i place during forced outages is planned and scheduled. The licensee has embarked upon a program to reduce the MWO backlog and control room equipment deficiencies and maintain control room annunciator " black board" status. These items are highlighted on the daily status sheets.
The aesults of the nonradiological confirmatory measurements progtim were adequate with an initial 19 of 27 results in agreeaent (70*4).
The comparisons improved (21 of 27 or 78%)
after the licensee corrected deficiencies in the analytical l
procedures.
The li ensee responsiveness to NRC initiatives _was generally timel) and had technically sound corrective actions.
The licent.ee's'recent responses to inspector concerns were' good.
,
The licensee was receptive to the NRC's nonradiological j
confirmatory measurements program and is improving the laboratory
'
QA/QC program.
The licensee's approach to the identification and resolution of i
technical problems was considered mixed. On the positive side, the licensee's programs were generally effective in identifying and correcting unacceptable test results.
Systems engineers are located in the plant and provided fast response to technical issues identified during maintenance. Maintenance work requests are routinely routed through the systems engineers for evaluation. before an MWO is written.
On the negative side, technical evaluations for equipment failures need improvement.
For example, the evaluation of a 4.16-kV breaker that failed to close identified the root cause as a failure of a part due to " normal wear."
No technical evaluation was initially performed for operability of other 4.16-kV breakers which could fail for the same reason and the need to change.the scope of the 4.16 kV breakers in the PM program. This was i
subsequently done.
]
l 2.
Performance Rating
!
.
The licensee's performance is rated Category 2 in this area.
!
The licensee's performance was rated Category 2 in maintenance l
and was rated Category 1 in surveillance in the previous
.)
assessment period.
!
l 3.
Recommendations i
i None
)
l
_ _ _ _ _ _ _ _ _
j
.e
.
.
D.
-
1.
Analysis Evaluation of this functional area was based on two inspections conducted by regional inspectors and two by the resident inspector.
These inspections consisted of an' exercise observation, two medical drills, and a routine inspection.
Region-based staff also met formally with the licensee on two occasions to discuss current program activities.
No violations were identified during this or the previous assessment period.
Management involvement in ensuring quality in this functional area was good. Tracking systems were effectively used to better ensure that timely corrective actions were taken on NRC-and licensee-identified items and that periodic tasks were completed on schedule.
The licensee continued to assist State and county officials in providing annual emergency preparedness training to hundreds of persons having roles in the county-level response plans for the Davis-Besse station.
The licensee has continued to work with the State's Citizens Advisory Committee on action items that evolved from the earlier Emergency Evacuation Review Team's findings.
For example, the licensee developed and implemented a computer link that provides State officials with current values of selected plant and meteorological data, j
The licensee's approach to resolving technical issues from a
!
safety standpoint was generally good.
Onshift personnel activated the emergency plan on three occasions during 1988.
Offsite officials were adequately notified of each situation in a timely manner.
The licensee thoroughly evaluated its records of each emergency plan activation. As a result, training and procedural guidance was adequately revised for situations in which an emergency action level's criteria would only be momentarily satisfied.
The licensee proactively worked with Federal, State, and local officials when false activations of the Emergency Planning Zone's sirens randomly occurred in June and July 1988.
The licensee effectively modified the sirens after the Federal Communications Commission had identified the cause of the inadvertent siren activations.
The licensee's emergency response organization has remained well staffed. On-call responsibility has been rotated among three teams of trained personnel on about a weekly basis.
The emergency planning staff has remained well managed to fulfill its onsite and offsite responsibilities, and has developed and implemented an effective training program for the emergency
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
!
..
...
.
e'
l
'!
organization.. The practice 'of rotating selected personnel
-
through exercise participant, controller / evaluator, and scenario
' development roles has further increased-personnel understanding of the licensee's program.
The November 1988 exercise scenario was very challenging.
Exercise participants were largely different from those who-had successfully demonstrated their capabilities during the previous two exercises. Overall exercise performance was very good.
Participants overcame.several discrepancies in
'
pre programmed scenario' data, and a controller error which delayed their activation. However, minor improvements were recommended in the control room and three response facilities.
2.
Performance' Rating
,
The licensee's performance is rated Category 1 in this, area.
I
.
The licensee's performance was--rated Category 2 with an improving trend in the previous assessment period.
3.
Recommendations None.
E.
Security 1.
Analysis Evaluation of this functional area was based on the results of six security inspections (three routine, three special).
conducted by regional specialists, headquarters personnel assisted by members of the U.S. Army Special Forces, and routine.
observation of security activities by'the resident inspectors.
An improvement in enforcement-related performance was noted.
One Severity Level IV violation and one Severity Level V violation were identified during this assessment period.
.
The violations were not indicative of a programmatic breakdown.
i A special Regulatory Effectiveness Review (RER) was conducted.
,
by a team composed of NRC personnel assisted by members of the U.S. Army Special Forces. The purpose of the RER program is to ensure that safeguards implemented at licensed power reactors i
meet NRC performance objectives and that NRC safeguards.
,
regulations adequately support those objectives.
No potential
.
vulnerabilities were identified.
Less significant findings of
!
the RER team were addressed by the licensee and reviewed by..
j Region III personnel.
Four events involving this functional area were reported under 10 CFR 73.71 during this assessment period.
The licensee's reporting of events continues to be a strong point. All reports
. _ _ _ _ _ _.
___._____._________________._._U
_ _ _ - _ _ _ _ _ _ _ _ _ _ - _ _ _
_ - _
,.
.. -
-
i were submitted on time and their content has been good..The u
.
licensee kept regional security personnel and the resident i
inspectors well informed of the events. -Its records are complete and accurate.
Management's involvement in ensuring the quality of the security
)
program is excellent. This involvement was demonstrated by I
i
!
purchasing state-of-the-art search equipment, approving I
personnel changes within the security management in order to strengthen security performance, allowing members of security management to attend specialized human relations training, and
_
continuing the site security' awareness program.
The licensee's responsiveness to NRC initiatives was generally-good. The Security Department's reviews and actions were.
consistently thorough. However, the licensing organization did not always process security program changes in a timely manner;
~
The-Security Department maintained excellent communication with j
the Region III Safeguards Section as well as with the resident inspectors.
The licensee's approach to the resolution of technical security'
]
issues is generally a strength. The program for upgrading
.
search equipment has involved thorough research and is continuing.
The licensee continues to review systems'
l efficiency and effectiveness with the goal of technical
)
upgrades to enhance performance.
Staffing levels were ample.
The security training and j
qualification program was adequate.
The positions'were.
.
identified, authorities and responsibilities were well-defined.
'j Security personnel were knowledgeable and competent in the-
'
execution of their duties.
2.
Performance Rating The licensee's performance is rated Category 1 in this i
area. The licensee's performance was rated Category 1 i
in the previous assessment' period.
]
3.
Recommendations
.
i None.
F.
Engineering / Technical Support
!
1.
Analysis
)
Evaluation of this functional area was based on the results of 10 routine inspections by regional inspectors, several (
inspections by the resident inspectors, and an indepth
'
i
!
i i
'
_ _ _ _ _ - _ - _ _ _ _ _ _
.
..
assessment of engineering efforts on modifications including
-
design bases 50.59 reviews and calculations.
A decline in enforcement-related performance in this functional area was noted. There were six Severity Level IV violations and one Severity Level V violation during this assessment period compared with no violations during the previous assessment period.
Eight events attributed to activities in this functional area-required the submittal of LERs during this assessment period.
Six of these were related to design deficiencies and the remainder to procedural weaknesses.
Two were related to the l
area of fire protection.
Management involvement to ensure _ quality in this functional area was mixed during this assessment period. On the positive side, management improved the quality of engineering efforts by _
forming an' engineering assurance group within the Engineering l
Department'which appeared to be effective in identifying and obtaining resolution of problems. The performance engineering group initiated predictive maintenance activities in the areas of inservice testing, vibration analyses, lube-oil analyses, and thermography. Data from these activities will be used to identify any adverse trends in equipment performance.
l l
Overall engineering support to maintenance activities was considered adequate. The Engineering Department was aggressive in identifying and resolving safety issues as evidenced by the testing programs established for air-operated valves, and a l
vibration testing program for pumps and valves.
Engineering personnel identified and corrected design errors for the safety features actuation system (SFAS) and anticipatory reactor trip systems. Management's policy of holding personnel accountable for their work was clearly communicated to the engineering personnel.
Engineering management and staff participated in daily planning and work meetings, and systems engineering management personnel were generally knowledgeable of developing plant problems.
On the negative side, the engineering organization did not provide appropriate outage support as evidenced by the numerous-incomplete modification packages at the beginning of the refueling outage. Also, the Regulatory Guide 197 equipment lists contained incorrect information apparently because of-the lack of communications between the equipment qualification (EQ) group and the engineering group.
Furthermore, during reactor startup from the outage the licensee discovered a mispositioned instrument valve.
Further investigation revealed
that this valve and all similar valves were identified on i
'
_ _ _ _ _ - _ - _ _ _
..
..
isometric drawings but not on the piping and instrument drawings
-
(P& ids).
Configuration management walkdowns, which had been completed previously, should have identified this discrepancy.
The licensee's approach to resolution of technical issues from a safety standpoint was adequate. Although two violations were identified, the team's review of engineering calculations indicated that the violations were not safety significant and i
the licensee took effective corrective action.
10 CFR 50.59 safety evaluations were generally good, and the continuing implementation of the motor-operated valve (MOV) reliability i
program and MOVATS testing were positive steps in the resolution I
'
of MOV problems.
In response to Generic Letter 83-28, the licensee developed a comprehensive program to ensure that planners determined post-maintenance testing requirements before work was performed. A good working relationship also seemed to exist between engineering personnel and other work groups on site.
However, this relationship was occasionally strained because of delays and untimely design changes that occur as a result cf the large amount of design engineering work. There also was evidence of in-depth design analyses and review to meet these requirements; however, there were
indications that these analyses and reviews were not always
)
comprehensive as evidenced by an unidentified single failure j
in the steam and feedwater rupture control system (SFRCS)
l analysis.
Many PCAQ reports have been written as a result of a i
concentrated effort to meet fire proter. tion requirements.
This i
effort identified numerous deficiencies which were being adequately
)
addressed and corrected.
l The licensee's responsiveness to NRC initiatives was adequate as evidenced by improvements made in the facility change request i
closeout program and reduction of the previous large backlog.
The licensee has mounted a concerted effort to come into compliance with its overall fire protection and safe-shutdown commitments. The licensee provided acceptable and timely responses to NRC regarding EQ issues.
The job performance measures for operator licensing requalification exams followed the NRC guidelines very closely.
However, the licensee's progress toward implementing the dynamic simulator portion for the new operator licensing requalification program was slow.
Simulator scenarios were inadequate in regard to the number and quality of malfunctions, component failures, and major plant transients.
Shortly after the close of the assessment i
period and at the request of the licensee, a management meeting was held between the licensee and Region III to discuss the requalification program.
The licensee's explanation of its program and corrective actions were acceptable to the NRC and alleviated most of NRC's concerns about this issue.
_ - _ -
..
.
.
Design staffing at the end of this assessment period improved
'
in the design change closecut and fire protection areas and appeared adequate.
The Design Engineering Department has provided adequate technical support for plant operations as shown by its recent redesign of the operating mechanism for the pressurizer spray valve.
Improvements noted during this assessment period included more in-depth procedures, better coordination between participating design organizations, and better training.
Training and qualification effectiveness was mixed. On the positive side, the program for training maintenance and technical personnel to ensure that persons performing safety-related activities were qualified to perform those activities was good. Another example was the procurement
,
and fabrication of training aids within the training sections.
)
Periodic communications with vendors was used to ensure that technical information was applicable and current.
On the negative side, personnel responsible for and affected by Regulatory Guide 1.07 had not been trained.
Similarly, fuel i
handling personnel were not appropriately trained, which l
resulted in the issuance of one of the violations, j
l 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.
G.
Safety Assessment / Quality Verification 1.
Analysis Evaluation of this functional area was based on the results of l
routine inspections performed by the resident and regional inspectors.
Enforcement history in this functional area for this assessment period consisted of one Severity Level II violation and four Severity Level IV violations.
The Severity Level II violation was issued for employment discrimination against a QC inspector for raising a safety issue. This is a new functional area and consequently no enforcement history is available from the previous assessment period.
The licensee's response to NRC initiatives and concerns was mixed.
Its response to the issue of questionable fasteners, fittings and flanges was excellent, as was its safety system
t-_--_--_---.-------
_
i I
!
..
.
l outage modification inspection (SSOMI) for a modification to j
the auxiliary feedwater system. Also, early in the assessment
.j period, the resident inspectors discussed with the licensee j
if criteria other than 10 CFR 50, Appendix B were used for the i
basis of audits. As a result of this discussion, the licensee
'
evaluated its program and determined that it was too narrowly based.
It then developed a program that was more broadly based and included the use of notices, bulletins, and regulatory I
concerns. The licensee also responded well to all generic, j
letters and bulletins and has been equally responsive to both its own Technical Specification amendment and' relief requests and to NRC questions resulting from reviews of 10 CFR 50.59 evaluations. All responses were acceptable.
I The licensee initially responded poorly to NRC concerns related, to plant pro'cedures.
It was only after a meeting with Region III management that the licensee appeared to grasp the significance j!
of the problem and agreed to conduct an in-depth audit of a sample of all procedures.
However, after the licensee's I
initial review of plant procedures had determined the extent of the problems, the licensee expanded the scope and formulated an aggressive action plan to correct'the immediate problems
prior to plant startup.
This program became the critical path item for reactor restart following the extended plant outage.
The NRC also was concerned about the morale of the QC inspectors; the licensee did not address this issue in a timely manner.
Once the licensee understood the significance of the problem,.
I however, it focused sufficient attention and resources to i
resolve it.
l Management's involvement in ensuring. quality programs has been mixed. Management gave a great deal of support to the PCAQ program by placing managers on the PCAQ review board and
'l emphasizing the need for licensee staff to use the PCAQ program.
The PCAQ program is an effective program. Management continued to demonstrate a high level of attention and commitment in'the area of training and qualification.
Its involvement in training was evident in the large number of non-operational personnel enrolled in the SR0 license program and in the assignment of the Plant Maintenance Manager and the System Engineering Manager to the SR0 license program.
It appears that senior management does not always become
,
involved with issues in a timely manner before they have an i
adverse effect on personnel and plant performance.
Examples of this are:
the premature transfer of responsibility for protective relays from corporate Control Systems to the site;.
iriterdivisional communication problems; quality control personnel morale problems; procedure issues; and inodequate response by the Operations Department to an MCAR.
_ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ - _ _ - _ _ _ _ - _ _ _ _ _ _ _ _ _
-_-_
..
.
The licensee's safety review functions (station review board
-
[ SRB], corporate nuclear review board [CNRB], and independent I
safety engineering group [ISEG]) appeared to provide both j
comprehensive and critical self-assessments.
The ISEG performed comprehensive causal evaluations, reviewed the QA procedures audit, and performed a SS0MI of an auxiliary feedwater system modification.
The SS0MI revealed that an approved design change, which had not yet been installed, would have rendered the auxiliary feedwater system inoperable under certain conditions. The licensee has an excellent program for root cause analysis although its implementation occasionally is weak.
i The licensee also had a " professionalism" audit conducted by l
'
personnel from the Perry nuclear plant. The audit concluded that all personnel at Davis-Besse recognize and support management's strong commitment to safety and compliance; they believe they have been well trained for their job; that they have been trained in root cause analysis; and that the PCAQ process is working. The weak points identified by.the audit were: most Davis-Besse personnel believe that improvements are needed in general management and supervision areas such as team work, coordination, communication, and feedback; career development planning is either not done or is not given a high priority; and many personnel believe their particular organization is understaffed.
The licensee also developed what it calls a " surrogate tour"
)
program to assist in planning work activities, especially in high radia'. ion areas by reducing personnel radiation doses.
The system consists of about 54,000 photos of the plant which are recorded on a computer disc.
It includes, for example, photos of equipment from several angles and therefore can be
used to " tour" the plant for planning of work. The system was
'
implemented shortly af ter the end of the assessment period.
l Management's support of QA activities is evident.
The licensee's QA organization operates in a professional manner
'
and is well staffed except that there were four management /
3upervisory vacancies which occurred in the QA organization at the end of the assessment period.
However, the QA organization had a large number of contract personnel and is increasing its hiring efforts to redute its dependence on these people.
The QA organization is recruiting a licensed SRO and has enrolled two members of its staff in SR0 license training.
The QA audit and surveillance programs were well defined and effectively implemented.
The QA staff provided extensive coverage during the outage and startup.
The licensee set up an engineering assurance (EA) organization within the Engineering Department i
during this assessment period and the engineering QA activities
'
were transferred to the new organization from QA during the
L -- --
.
.
latter part of this assessment period. QA was functionally
-
independent and assertive and was generally effective in the identification and resolution of quality concerns. One example is the MCAR discussed in the Plant Operations section of this report.
QA personnel were actively involved in plant operations.
They performed comprehensive and extended (backshift) surveillance of control room maintenance and refueling activities. The licensee plans to expand its surveillance program and is attempting to make the program more performance based. QA communications with the NRC resident staff were open and forthright. QA personnel were actively involved in the licensee's problem identification and resolution process.
A large number of technical issues were resolved during this assessment period:
24 license amendments were issued. An additional nine safety evaluations on other subjects were issued or performed. The licensee's technical support for these activities was mixed.
For example, the content of the licensee submittals for primary and safety valve testing indicated significant attention was given to the matter, but there appeared to be a lack of understanding or appreciation for the detail or nature of the needed information in the initial submittal.
Responses to two requests for additional information were required. The licensee provided a well-written and technically complete response for a Technical Specification change request to increase the allowed enrichment limit in the fuel storage racks. With regard to the reactor reload report, the NRC had granted the licensee an extension for submitting some confirmatory analyses based on the licensee's projected submittal of 6 months; however, it was not submitted for 13 months thus allowing minimum time for NRC review without
delaying reactor restart and the confirmatory analyses were not included. A further delay until the next reload was necessary.
This demonstrated a lapse in management judgement and responsiveness. On the other hand, the licensee's application for Technical Specification changes relating to a modification
,
on the SFRCS was excellent and indicated that the licensee I
'
understood the safety significance of the changes and demonstrated a conservative design approach.
2.
Performance Rating
,
The licensee's performance is rated Category 2 in this area.
This is a new functional area and the licensee's performance l
was not rated during the previous assessment period.
j 3.
Recommendations None
24
,
..
..
.
!
V.
SUPPORTING DATA AND SUMMARIES
'
A.
Licensee Activities j
Davis-Besse began the assessment period operating routinely at
!
administratively imposed restricted power levels.
There were no significant outages or power reductions until March 10, 1988, when the unit began a scheduled maintenance, modification, and refueling outage. The outage lasted until December 15, 1988. The plant then
,
operated at routine power levels up to 180% of its rated thermal-
i power through the end of the assessment period, Davis-Besse experienced three engineered safety feature (ESF)
actuations, and two reactor trips.
Both trips occurred while the reactor was operating above 15% power.
One trip occurred as a result
,
of personnel error, and the other was the result of equipment-i failure.
i Significant outages and events that occurred during the assessment
)
period are summarized below.
Significant 0.tages and Events i
!
1.
During March 10 through December 15, 1988, the unit was shutdown to perform scheduled maintenance / modifications / refueling outage activities. Approximately 180 modifications were made to the plant.
2.
On December 16, 1988, the unit experienced a short forced outage to repair steam leaks on the high pressure turbine shell.
3.
On December 17, 1988, the reactor tripped on a high flux condition caused by a combination of the reduced high flux
!
setpoint coupled with a 9% calibration error between heat.
i balance power and indicated reactor power.
4.
On December 18, 1988, the licensee attempted to restart the reactor by withdrawing control rods out of sequence.
5.
On January 18, 1989, the reactor tripped on high pressure.
It was caused when the main feedwater valves closed on an erroneous signal.
B.
Inspection Activities
'
Forty-four inspection reports are discussed in this SALP report (January 1, 1988, through February 28, 1989) and are listed in Paragraph 1 of this Section, Inspection Data.
Table 1 lists the violations per functional area and severity levels.
Significant inspection activities are listed in Paragraph 2 of this section, Special Inspection Summary.
>
. _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ - _ -
i
..
.
.
I 1.
Inspection Data I
'
Facility Name:
Davis-Besse Docket No.:
50-346 Inspection Reports No. 88002 through 88017, 88019 through 88029, 88031 through 88039 and 89002 through 89008. Two reports were issued as 88034.
TABLE 1 Number of Violations in Each Severity Level Functional Areas I
II III IV V
I i
A.
Plant Operations
-
-
-
-
-
B.
Radiological Controls
-
-
-
C.
Maintenance / Surveillance
-
-
-
1 D.
-
-
-
-
-
E.
Security
1
-
-
-
F.
Engineering / Technical Support
-
-
-
1 G.
Safety Assessment / Quality Verification
-
-
-
TOTALS I
II III IV V
-
-
3
Special Inspection Summary
.
a.
During February 22 - March 11, 1988, a team inspection was
conducted to review QA implementing procedures (Inspection Report No. 346/88006).
b.
During February 23 - March 11, 1988, a special team inspection was conducted to review operating radiological protection activities (Inspection Report No. 346/88008),
c.
During May 4 - September 2, 1988, a special inspection was conducted regarding a certified QC inspector and possible employee discrimination (Inspection Report No. 346/88012).
d.
During July 11 - December 2, 1988, a special safety inspection was conducted with respect to the licensee's corrective actions taken, as addressed in CAL-RIII-85-013 (Inspection Report No. 346/88019).
!
e.
During September 12 - October 19, 1988, a maintenance team inspection was conducted relating to management activities with respect to maintenance (Inspection Report No. 346/88029).
l
&
r
..
..
f.
During August 29 - September 16, 1988, a.special inspection was
-
conducted of activities regarding the testing of the SFRCS, and a review of PCAQ training and licensee actions on previous items-(Inspection Report No. 346/88031).
g.
During November 1-3, 1988, the annual emergency preparedness exercise was conducted (Inspection Report No. 346/88040).
h.
During January 31 - February 10, 1989, a special E0P team inspection was conducted (Inspection Report No. 346/89006).
.
C.
Escalated Enforcement Actions A Severity Level II violation, proposed imposition of civil penalty in the amount of 580,000, and an order to modify the licensee's operating license was issued during this assessment period. These enforcement actions were based on the actions of a former supervisor who deliberately laid off'a QC inspector for raising a safety issue.
Because of the NRC's concern regarding this individual's performance relative to the discrimination violation, an order modifying the license was issued-The licensee paid the 580,000 civil penalty on-
.
December 29, 1988.
(RIII Enforcement Case No. EA-88-234, Enforcement Notice No. EN-88-100, and Inspection Report No. 346/88012).
D.
Confirmatory Action Letters A few days after the close of this assessment period, a Confirmatory Action Letter was issued relating to the rod pull incident of December 18, 1988. The licensee will provide the NRC a written report describing.the basis for returning the shift supervisor to duty.
(CAL-RIII-89008)
E.
License Amendments Issued Amendments No.
Description Date 106 Revise Technical Specifications (TS)
February 25, 1988 regarding fire protection features.
107 Revise TS to extend surveillance February 29, 1988 date one month for 13.8 kV ac sources.
108 Revise TS requirements relating to March 2, 1988 reactor trip breaker diverse trip devices.
109 Revise responsibilities and March 9, 1988 authority of the SRB in the TS and adds a section on Technical Review and Control.
-
_ _ _ _ _ - _ _ _ _ _ _ -
__
1
. -.
..
Amendments No.
Description ~
Date
-
i 110 Revise TS on reactor coolant system March 14, 1988 I
pressure instrument, j
111 Revise TS on surveillance of May 25, 1988 snubbers.
112 Revise TS to delete SFAS signal for May 25, 1988 makeup system containment isolation valve (CIV).
]
113 Revise.TS relating to steam generator July 22, 1988 (SG) sample-selection and inspection.
114 Revise TS to delete SFAS signals and August-2, 1988 closure time requirements on certain valves on secondary side of SGs.
,
115 Revise.TS by deleting organization August 2, 1988 charts.
!
116 Revise TS for reactor vessel August 19, 1988 i
pressure / temperature limits.
I 117 Revises TS relating to main steam August 24, 1988 safety valve setpoints and ASME Code requirements.
118 Revises TS for SG low level SFRCS August 31, 1988 trip setpoint.
119 Revise TS for surveillance September 1, 1988 requirements for the main steam
'I isolation valves and the response
'
times for the SFRCS.
120 Revise TS for containment testing September 19, 1988 to be consistent with Appendix.J to 10 CFR Part 50 and ANSI N45.4-1972 Appendix C.
121 Revise TS by reducing the number of September 27, 1988 pressure switches used to initiate the SFRCS from 16 to 8.
<
l i
122 Delete License' Condition 2.C.(3)(t)
September 30, 1988
)
regarding the startup feedwater pump and incorporates Item 2 of that I
condition into the TS.
28
!
..
..
Amendments No.
Description Date
-
123 Revise TS to support. operation October 3, 1988 for Cycle 6.
!
,
124 Revise TS to reduce the number October 5, 1988 of pushbuttons for manual actuation of the SFRCS.
125 Revise TS by decreasing the maximum December 7, 1988 overall closure time for the turbine stop valves.
126 Revise TS to permit bypassing of December 19, 1988 main steam pressure low instrument
channel when steam pressure is j
below 700 psig.and automatic removal i
of the bypass at 750 psig.
127 Revise TS to delete the isolation December 27, 1988 times for certain CIVs.
128 Revise TS to permit raising the high December 28, 1988
!
pressure reactor trip setpoint and
.!
the power operated relief valve setpoint
'
and permits increasing the power level at or below which the anticipatory reactor trip system may be blocked.
129 Modifies Paragraph 2.D of the
' February 14, 1988 license to require compliance with the amended Physical Security Plan.
F.
Review of Licensee Event Reports Submitted by the Licensee
!
1.
Licensee Event Reports (LERs)
l Thirty-two LERs were issued during this assessment period.
Table 2 shows cause code comparisons of SALP 6 versus SALP 7 LERs.
An unusually large number of the LERs (11 of the 32)
.
involved the fire protection system such as. missed fire watches,,
fire barriers, and fire alarms. The LERs generally described all the major aspects of the events, were well written, and
provided sufficient information to readily understand the
!
events.
Root causes were identified.
LER Nos.:
88001 through 88029 and 89001 through 89003.
!
!
.I
)
_ _ _ - _ _ _ _ _ _ - - _ _ - _ _ _ _ - _ _ - _ _ _ _ _ _ - - - - _ - _ - _ _ _ _ - _
. _ _
. _ _. _
_
___
._
l
..
..
l i
TABLE 2 (12-MO)
(14-MO)
No. (Percent)
No. (Percent)
CAUSE AREAS SALP 6 SALP 7 Personnel Errors 10 (62.4%)
15 (46.9%)
Design Problems 1 ( 6.3%)
7 (21.5%)
External Causes 1 ( 6.3%)
0 ( 0.0%)
Procedure Inadequacies 2 (12.5%)
6 (18.8%)
Component / Equipment 2 (12.5%)
3 ( 9.4%)
Other/ Unknown 0 ( 0.0%)
1. ( 3.0%0 TOTALS
32 l
FREQUEl:CY (LERs/MO)
1.3 2.3 NOTE:
The above cause code analysis was derived from,
'
review of LER's performed by NRC Staff and may not completely coincide with the licensee's cause assignments.
_ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _