IR 05000382/1987032

SALP Rept 50-382/87-32 for Period Feb 1987 - Jul 1988

ML20195D873
Person / Time
Site:	Waterford
Issue date:	07/31/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20195D871	List: IR 05000382/1987032 ML20195D869
References
50-382-87-32, NUDOCS 8811070174
Download: ML20195D873 (37)

Text

.--

. .

,

,

li SALP REPORT U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report Number 87-32 Louisiana Power & Light Compary Waterford Steam Electric Station Unit 3/ Docket Number 50-382 February 1,1987, through July 31, 1988

,

g O

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

. .

A. ~ INTRODUCTION The Systematic Assessment of Licensee Perfor. nance (SALP) program is an

, integrated NRC staff offort to collect available observations and data on a periodic basis and to evaluate licensee performance on the basis of this information. The program is supplemental to normal regulatory processes used"to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide.a rational basis for allocasing

.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 are An NRC SALP Board, composed of the staff members listed below, met on September 7, 1988, to review the observations and data on performance, and to assess licensee performance in accordance with Chapter NRC-0516,

"Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this repor The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuanc This report is the NRC's assessment of the licensee's safety performance at Waterford 3 Steam Elr.ctric Station (W3 SES) for the period February 1, 1987, through July 31, 198 The SALP Board for W3 SES was composed of:

A. B. Beach, Deputy Director, Division of Reactor Projects J. L. Milhoan, Director, Division of Reactor Safety R. E. Hall, Deputy Director, Division of Radiation Safety and Safeguards J. A. Calvo, Director, PWR Project Directorate No. 4, Office of Nuclear Reactor Regulation (NRR)

D. D. Chamberlain, Chief, Project Section A, Di,ision of Reactor Projects D. L. Wigginton, Project Manager, NRR W. F. Smith, Senior Resident Inspector, W3 SES The following personnel also participated in the SALP Board meeting:

J. M. Montgomery, Deputy Regional Administrator L. J. Callan, Director, Division of Reactor Projects W. C. Seidle, Chief, Technical Support Staff, Division of Reactor Safety R. E. Baer, Chief, Facilities Radiological Protection Section, Division of Radiation Safety and Safeguards J. E. Gagliardo, Chief, Operational Programs Section, Division of Reactor Safety R. J. Everett, Chief. Emergency Preparedness and Safeguards Programs Section, Division of Radiation Safety and Safeguards A. T. Howell, Project Engineer, Project Section A, Division of Reactor Projects T. R. Staker, Resident inspector, W3 SES N. M. Terc, Emergency Preparedness Specialist, Division of Radiation Safety and Safeguards

..- .

,_

.

i i; .

.-

R. A. Caldwell, Physical Security Specialist, Division of Radiation Safety

>

and Safeguards l B. Murray, Chief, Reactor Programs Branch, Division of Radiation Safety [

and Safeguards '

Licensee Activities At the beginning of this NRC assessment period, the licensee had just l completed the first refueling outage and on February 4, 1987, achieved post-refueling initial reactor criticalit By February 20, 1987, the plant was at full power. .and for over 70 percent of the  ;

assessment period, was operated at full power. The plant's overall '

availability factor was 77.3 percent during this SALP assessment  !

period. In September 1987, the plant was shut down for an 18-day outage to replace a leaking shaft seal assembly on Reactor Coolant Pump 2 Replacement with a like design (Type SV) seal was c unsuccessful. The replacement seal exhibited pressure staging problems when the plant was pressurized. The licensee then installed '

a new improved (Type N) seal provided by the vendor, Byron-Jackson Pump Company. On April 1, 1988, the licensee commenced the second refueling outage, which was scheduled to span 60 days. In the face of several major setbacks, the licensee managed to complete the

-

i outage in a few hours less than the scheduled 60 days. The plant was -

restarted on May 31, 1988, and operated at mostly full power except for about a week in July 1988 when power had to be reduced to  !

,

65 percent to allow carrective maintenance on Main Feed Pump A.

.

Some of the more significant modifications made during this

assessment period (most during the refueling outage) were:  ;

,

,

) Replacement of the Containment Hydrogen Analyzers with an  ;

d improved desig . Replacement of the Gas Decay Tank Hydrogen and Oxygen Analyzer

, with a unit of more reliable design (the old equipment had been i

'

out of commission since 1985). l I Installation of a permanent narrow and wide range reactor vessel  ;

water level indicating system.

• Replacement of three radiation monitors with new and more  !

reliable unit ,

4 Installation of new Type N reactor coolant pump shaft seals in j the three remaining reactor coolant pumps.

j L 1 Partial installation of Reactor Containment Building Air

'

Conditioning so that during the second and third refueling outages, temporary chillers could be connected to the existing f l component cooling water supplies for the containment cooling

,

fans.

j

I  !

c

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

m >> ,0

• m ,(

' ?.. j 9-

.-

I

'

. Replacement of-the remaining two of.three low p*issure main turbine rotors with w new . heavier lWestinghours design that reducet. susceptibility to stress corrosion-tnduced crackin In addition, during this ass nsment ported, there were 28 Operating License Amendments. Most of t5co consisted of minor instrument setpoint changes, surveillance changos, or fire protection requirement change Some of the,mure:sigr.ificant amendments were:

, Reductions in Emergency Diesal: Generator (EDG) surveillance tests to improve reliability puestlant to Generic Letter 84-15,

"froposed Staff Actions to Imorove and Maintain Diesel Generator

Reliability." ,

i The number of Containment Cooling Fans required to be operable in e&ch train.of the Containment Cooling System was reduced from ;

two to one.

] Direct Inspection and Review Activities .

'

The total NRC inspection effort during this SALP assessment period consisted of 49 inspections, including resident inspector activitie !

A total of 4189 direct inspection hours were expende [

j Four major inspections and reviews were conducted as follows: ;

j During the periods December 7-11 and 14-18, 1987, a team of four '

1 inspectors from the Vendor Inspection Branch conducted reviews i of the licensee's implementation of programs for vendor !

interface, procurement of items for safety related applications, (

and resolution of issues pursuant to 10 CFR Part 2 >

i During the period February 1-12, 1988, a team of six inspectors j  ::enducted a quality verification func'. ion inspection (QVFI).

The inspection focused on the effectiveness of the licensee's quality verification organizations in identifying, reporting.

4 resolving, and preventing the recurrence of safety-significant

'

technical deficiencie . During the first 2 weeks of April 1988, and the period May 23-?6, 1988, a diesel generator specialist from the Office of Nuclear Reactor Regulation (NRR) cc ducted inspections of the licensee's performance of major maintenance on the emergency diesel generator . During the period July 6-14, 1988, a special emergency operating procedure (EOP) inspection was conducted by a team of seven inspectors. The inspection team revi ~ ed pertinent records and procedures, and observed two operato .tatch sections utilizing

_

_ _ _ - _ _ _ _ - __. ._ _ - _ _ _ _ _ _ _ - __ - _ _ _ .

.

.. .

l

.

I f

.the E0Ps in accident scenarios conducted at the control room simulator. The team also conducted human factors walkdowns of-the E0Ps in the simulator and in the actual plan II. SUMMARY OF RESULTS Overvieg This SALP period brought about many improvements in terms of physical plant condition.' Nuclear Operations performance as indicated by management involvement, good refueling outage planning and execution, excellent housekeeping and decontamination efforts, and improved plant availability are indications ef.these improvements. The licensee's efforts to improve communications with the NRC staff as part of an improved approach to the regulatory process have also yielded positive result The SALP Board concluded, however, that there were areas where improvements were needed. The licensee has not demonstrated the capability to be self-critical, that is, the ability to identify, report, and promptly correct potentially safety-significant problem The several independent verification groups available to the licensee do not appear visible, as evidenced by inadequate corrective actions, inadequate root cause analyses, and sometimes shallow presentations made by licenseo management to the NRC staff. The apparent unwillingness to be self-critical has been manifested in several areas, including examples of failure to report events to the NRC and delays in making operability determinations. These weaknesses are also evidenced by the number of examples of the failure to follow procedures discussed throughout this report and by the potential loss of shutdown cooling event. Efforts on the part of management to improve in this area appear to have been less than fully successful as of the end of this assessment perio The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation perio Rating Rating Last Period This Period (01/01/86 to (02/01/87 to Functional Area 01/31/87) 07/31/88) Plant Operations 2 2 Radiological Controls 2 2 Maintenance / Surveillance N/A* 2 Emergency Preparedness 2 1

-

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

.

.. .

.

6 Security 2 1 Engineering / Technical N/A* 2 Support Safety Assessment / N/A* 2 Qcality Verification Maintenance 2 N/A* Surveillance 1 N/A*

1 Fire Protection 1 N/A*

11. Outages 1 N/A*

12. Quality Programs and 2 N/A*

Administrative Controls Affecting Quality 1 Licensing Activities 1 N/A*

1 Training and Qualification 1 N/A*

Effectiveness

• The notation "N/A" represents that the functional area was not assessed during the period indicated. In comparison with previous SALP Reports, it should be noted that functional areas have been redefined pursuant to NRC Manual Chapter NRC-0516, revised June 6, 1988, entitled, "Systematic Assessment of Licensee Performance."

Consequently, most of the ratings tabulated in Section II below do not correlate directly between the last period (January 1,1986, through January 31,1987) and this period (February 1,1987, through July 31, 1988). Licensee Self-Assessment During the SALP P,oard's evaluation of the Safety Assessment / Quality Verification functional area, there were considerable discussions involving the licensee's ratings in this are Enforcement history in this area combined with observations made by the NRC staff appear to indicate weaknesses in the licensee's abilities for self-assessment. In addition, there have been specific instances where plant personnel, including Quality Assurance (QA), failed to document deficiencies as required by the QA Programs outlined in the licensee's Nuclear Operations Management Manual. As such, it is not apparent as to how the licensee effectively performed critical self-assessments, particularly when plant personnel were reluctant to identify and document deficiencie .

.. .

.

On the basis of reviews of the licensee's potentially reportable event reports, the staff has notec a general lacking in root cause analyses and correctio Independent review resources did not appear to be utilized to the extent expected to provide self-critical analyses. Such resources included Plant Operations Review Committee, Safety Review Committee, Nuclear Operations Support and Assessment Group (which included the Independent Safety Evaluation Group), QA, and Events Analysis Reporting and Respons III. CRITERIA Licensee performance was assessed in seven selected functional area Functional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functional area:

Assurance of quality, including management involvement and control;

Approach to resolution of technical issues from a safety stanopoint;

• Responsiveness to NRC initiatives;  ;

'

Enforcement history;

Operational events (including response to, analyses of, and corrective actions for);

Staffing (including management); and

Effectiveness of training and qualification progra ,

'

However, the NRC was not limited to these criteria, and others may have been used where appropriat On the basis of the NRC assessment, each functional area evaluated was rated according to three performance categories. The definitions of these performance categories are as follows:

'

Category Licensee management attention and involvement are

, readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially 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 appropriat ,

. , - - . , - - - - .

,n , _ -

- - - - - - - - - .

4 .

.. .

.

l Category Licensee management attention to and involvement in the '

performance of nuclear safety or safeguacds activities is good. The licensee has attained a level of perfora ,ce 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 level Category Licensee management astention 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 level IV. PERFORMANCE ANALYSIS Plant Operations /.na ly s i s The assessment of this functional area encompassed the control and execution of activities involving plant operation This assessment included activities such as plant startup, power operation, plant shutdown, and system lineups. Thus, it included activities such as monitoring and logging plant conditions, normal operations, response to transient and off-normal conditions, manipulating the reactor and auxiliary controls, plantwide housekeeping, control room professionalism, and interface with activities that support operation These areas were inspected on a continuing basis by the resident inspectors for the entire perio At the beginning of this assessment period, the licensee had just completed its first refueling outage and was in the process of plant startup. The NRC resident inspectors observed the initial approach to criticality and other startup test Startup testing following the refueling outage was also observed by NRC regional inspector An experienced staff of well trained startup and reactor engineers had been assigned by the licensee to this plant startup. Plant startup procedures provided a clear outline of the startup process and adequately covered plant startup requirements. Startup test results were considered satisfactory and appeared to meet acceptance criteria. Test deficiencies were properly identified and resolutions were stated with appropriate references to dispositioning documents. Resolutions were timely and appaared to be conservative from a safety standpoin .- _ _ _ _ _ _ _ _ _ _ _ _ - _ . . _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _

..

m ,

..-

e

^, There were nine automatic reactor trips and one manual trip during this period. The. manual trip was in response to a rapidly increasing upper thrust bearing temperature.on reactor

'

'_

coolant pump (RCP) 28. The operators had watched the slowly increasing-temperature and had planned a normal shutdown for repairs. However, the change in the rate of increase of the-upper thrust bearing temperature necessitated a rapid shutdow Of the nine automatic trips, four were due to hardware failure One was due to improper maintenance and one to a design proble The remaining three were due to procedural and/or training deficiencies. As a result of good operator. training and appropriate responses to the scrams, the plant was efficiently and safely shut down. During the previous SALP, there were positive comments on the large decrease ic reactor trips in 1986. The NRC staff noted that.the number of trips in 1986 and 1987 did not change significantly. However, in 1988, the number has decreased to two as of July 31, 1988, which shows an improvement. This appeared to be the result of specific station modifications designed to reduce the hardware problems that led to reactor trips. The licensee also established a Reactor Trip / Root Cause Determination Program which should continue to reduce avoidable reactor trip Throughout this assessment period, there were instances where operations personnel demonstrated an inappropriate attitude toward following procedures. Procedures were sometimes misleading or contained minor errors that were ignored when the operators, through experience and training, knew what needed to be done regardless of what the procedure specifically state On the basis of NRC observations and operator interviews, it appeared that procedures were being used as a "guide."

Examples of such indicators were documented in several NRC Inspection Reports. There were Engineered Safety Feature (ESP)

System walkdowns conducted by the resident inspectors where labeling and equipment status were repeatedly found incorrect in the operating and surveillance procedures. There were cases where clearance procedures were not fully implemented as prescribed, surveillance procedures were not followed '7 the intended sequence, or actions were not taken as required when acceptance criteria were not me In a letter transmitting NRC Inspection Report 50-382/87-22, the NRC Director, Reactor Projects, Region IV, expressed concern to the licensee that while the safety significance of each of these violations may have been considered minor, they collectively represented weaknesses in the adequacy of the management controls that should ensure that proceduros were written so that they could be followed. In response, the licensee counseled the individuals involved, plant operators were required to review

n-

.

.. . ,

• l

directives that addressed procedure compliance, a series of I meetings was held between plant staff and the Plant Manager, and '

the Operations and Maintenance Departments employed the services of a Human Factors Consultant to review existing plant procedures and procedure writing guideline l However, these efforts, though positive, did not appear to have been fully effective as of the end of this assessment perio This was clearly exemplified during a May 12, 1988, event when the Reactor Coolant System (RCS) was drained to approximately mid plane in the hot leg piping during the refueling outage and the operating shutdown cooling pump experienced cavitation, a precursor to a loss of pump suction and flow. Prompt action by the operators averted a total loss of shutdown cooling flo The immediate cause was improper RCS level indication from the tygon tube level indicato However, one of the root causes of the event was the failure of the operators to follow the appropriate procedures while placing in operation u.d using the RCS level indicators. Had the operators followed the appropriate procedures, the near loss of shutdown cooling, a significant avent, might not have occurred. Another root cause was failure of the licensee to take adequate cor'ective action when shutdown cooling was actually lost in 1986 cue, in part, to improper level indication. The May 12, 1988, incident resulted in escalated enforcement action followed by a proposed civil penalt Though not fully successful as of the end of this period, the licensee has continued efforts to ensure procedures are appropriately followe The licensee has announced implementation of a positive program called "Operation ZERO Deviations." This program will be directed to adherence to requirements, procedures and work instructions, and is designed to appeal to the competitive spirit of plant staff to eliminate procedural violation The program was scheduled to become effective on September 1, 198 Other weaknesses identified in the operations functional area involved RCS leak rate problems. On March 30, 1988, the licensee determined that RCS unidentified leakage had exceeded Technical Specification (TS) limits. A second test determined a satisfactory leak rat The licensee explained that the disparity may have been caused by motor operated valve testing (MOVATS), and committed to detarmine the leak rate again after M0 VATS was completed to verify tnat the RCS leak rate was satisfactor If unsatisfactory, the licensee advised that they would shut down and start the refueling outage scheduled for April 2, 1988, a day early. The results were unsatisfactory; however, the licensee requested enforcement discretion to allow continued operation beyond the TS time limit of 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> so that

~_

.

<

.. ,.

.

searches for. leakage could continue. The enforcement discre san was not granted by. Region IV management because there was insufficient' justification to remain at power in this condition which was prohibited by the TS. While reducing power to shut down, the leakage was found. isolated, and then plant operation resumed with a satisfactory RCS leak rat During the appraisal period, licensee efforts to reduce the  !

number of illuminated control room annunciators continued with *

good results. At the beginning of this period, there were 67 illuminated annunciators. At the end.of this period, the resident inspectors observed the number had_been reduced to 16, of which 11 were valid indications. Five were not appropriate, and thus candidates for continued reductio ;

Efforts to reduce the number of temporary alterations were evident on a continuing basis. During plant operation in 1987, '

there were as many as 42. As the second refueling outage was approached, the licensee had reduced that number to 15, and after the outage, had further reduced the number to 1 During the period of July 6-14, 1988, an NRC team conducted a comprehensive inspection of the licensee's Emergency Operating  ;

Procedures. The NRC Inspection Report was not issued as of the end of this assessment period; however, the results were discussed with the licensee on July 14, 1988. The inspection team identified suggested improvements in a number of human factors elements in the plant simulator, the control room, and in the plan There were also some problems associated with ,

utilization of the Safety Function Recovery Procedure, OP-902-008. During the loss of feedwater accident scenario, the operators had some difficulty getting into the correct recovery path, had problems controlling plant cooldown pursuant to that procedure, and demonstrated reluctance to use this particular  :

procedure. Besides some minor ambiguities of the procedure  !

itself, it was evident to the team that considerably more training should be allocated to the Safety Function Recovery Procedure. The licensee committed to commence this training in August 198 Management involvement in plant activities was normally observed during routine operations. Key managers met routinely at a daily morning Plan-of-the-Day meeting where operating problems and planned activities were discussed. The reetings were conducted by the planning organization and chaired by the Plant Manager and his two Assistant Plant Managers. Plant management was involved with plant problems and involved in the decision making ,

process for problem resolution. Control room visits were i frequent, as well as tours of the rest of the plan During i off-hcurs and weekends, a duty manager was assigned to ensure  ;

that management support was readily availabl l P

l L

!

. _ _ _ _ - _ _ _ _ _ _ _ _ _ ___ _ - __

o 8 ,

o

L During this assessment period, licensee management has changed the positions of key personnel in an effort to achieve a balanced, broadly experienced management team. In December 1987, the Nuclear Operations Training Manager was appointed Assistant Plant Manager, Operations and Maintenance. The incumbent Assistant Plant Manager became Manager of Nuclear Operations Engineering. The Operations Superintendent became Manager of Nuclear Operations Support and Assessments. These changes provided promotion paths for operators and, at the same time, inserted some operations perspective in supporting organization Operator retention and morale appeared to be excellent. Only one operator was lost during this assessment period. The licensee's programs for self-development, salary bonus incentive plan, and apperent~ opportunities for advancement appeared to contribute to this as well as the positive examples set by operations management i- che areas of dedication and professionalism. In Ma; 1987, authorized staffing levels in Nuclear Operations were increased from 654 to 936, and by the end of this period, 863 of the authorized positions had been filled. Most of the increased staff was to replace contract persennel who have been release Some were hired as permanent employee In the area of operator qualification and training, the Plant Simulator was placed in service in June 1987. Since then, licensed operators have been through six training cycles. Each cycle amounted to about 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> on the simulator. There were no new NRC operator license e..aminations during this assessment period; however, there were 57 requalification exams conducted by the licensee and 56 operators passed, and the individual who failed passed his reexamination. In December 1987, LP&L announced that all ten of basic training courses received INP0 accreditatio In the area of Fire Protection, there were some instances where fire doors and fire seals were found impaired but not identifie This was largely due to inattention to detail on the part of individuals on their tours of the plant. During the period August 3-7, 1987, Region IV conducted a routine, unannounced inspection of the licensee's fire protection / prevention program, with satisfactory results. The review verified that the licensee had technically adequate procedures and fire brigade equipment, and that training records were in good order. A Quality Assurance (QA) Audit of Fire Protection conducted in March 1987 appeared comprehensive and responses to discrepancier were adequately resolved. Fire impairments are a subject of routine discussion at the plant and it is evident that there is a continual effort to keep them at a minimu __

.

.. r p,

Housekeeping has been monitored by the resident inspectors on continuing basis, and during plant operations, has been found to be oxcellent with few exceptions. As might be expected, the course of events during the 60-day refueling outage brought about minor housekeeping problems. However, within an extremely short time period after the outage, plant cleanliness was brought to an excellent level and has since been kept that way.

,. The licensee has instituted an "area manager" concept that W designates specific senior individuals responsible for the upkeep of equipment condition and area cleanliness. This concept appeared to be working well and had an apparent positive impact on the plant staff's pritie in their workplac . Performance Rating There is an improving trend in the operations are The operations department is becoming sensitized to the importance of following procedures. A satisfactory procedure writer's guide has become available such that operations procedures are trending toward improvemen The licensee is assigned a performance rating of 2 in this a e . Recommendations NRC Actions NRC inspection effort in this area should be consistent with the Fundamental. Inspection Progra In addition, selected Regional Initiative Program inspections should be conducted during the next SALP period in the area of Plant procedure Licensee Actions Licensee management should continue to place priority on the importance of following procedures by taking actions which will ensure that operating personnel utilize procedures that are appropriate to circumstances and required by Technical Specifications. The licensee should utilize independent organizations as needed to provide a more visible self-critical assessment of operations procedure The licensee should promptly implement corrective actions and recommended improvements that were identified as a result of the Emergency Operating Procedures team inspectio ______________

.

- *. f

.

B. Radiological Controls Analysis The assessment of this functional area consisted of activities directly related to radiological controls including occupational radiation safety (e.g., occupational radiation protection, radioactive materials and contamination controls, radiation field control, radiological surveys and monitoring, and as law as is reasonably achievable (ALARA) programs), radioactive waste management (i.e., processing and onsite storage of gaseous, liquid, and solid waste), radioiogical effluent control and monitoring (includino gaseous and liquid effluents, offsite dose calculations, radiolvgical environmental monitoring, and confirmation measurements), and tran;portation of radioactive materials (e.g., procurement of packages preparation for shipment, selection and control of shippers, receipt / acceptance of shipments, periodic maintenance of packagings, and point-of-origin safeguards activities.)

Eight inspections in the functional area of radiological controls were performed during this assessment period by NRC regional radiation specialist inspector In addition, assessments were made by the NRC resident inspectors during routine inspections. There were two violations identified in this functional area that reflected minor problems and were not considered an indication of major breakdowns within the radiological controls are The licensee has reduced the day-to-day problems with airborne and liquid releases from in plant valves and fittings. The licensee has taken aggressive action in this area to ersure that areas were maintained to contamination levels that did not require the use of protective clothing. Less than 10 percent of the licensee's facility, outside of the reactor containment, required protective clothing.

l The licensee implemented a comprehensive hot particle control and skin dose evaluation program. However, the licensee still i experienced hot particle exposure incidents due to less than l adequate attention to detail by radiation protection technicians i and workers.

t Radiological control personnel turnover has been reduced to very manageable level Previous employee turnover'of radwaste personnel in the Nuclear Training Department has resulted in deterioration of the training programs for the radwaste grou The licensee has been requested to respond in writing to improvements that will be taken to ensure radwaste personnel training is properly maintaine The radiochemistry group has also experienced a relatively high turnever rate during this

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

-.

.. ,

.

assessment period. Apparently, most personnel movements were due to promotional opportunities. However, the licensee should monitor this area for indicators of weakening performance due to the lower experience level of the technician In response to the NRC concern regarding establishment of a permanent low-level radioactive waste storage facility, the licensee was still evaluating the need for building a storage facilit Existing onsite storage facilities (trailer vans and concrete storage vaults) were marginal but adequate for short term storage of radioactive materials and waste. The licensee implemented an aggressive waste reduction program and it has had such a positive impact on reduction of unnecessary radioactive waste that sorting of low level radioactive waste was no longer necessary to achieve reductions in waste generation due to the inclusion of clean wast The licensee's preplanning for the 1987 refueling outage showed a high degree of senior management attention to ensuring the outage was properly supervised and controlled. The licensee's computerized dosimetry program for outfitting personnel with multiple dosimetry for exposure to nonuniform radiation fields showed a high degree of technical ability on the part of the dosimetry staf The outage was completed ahead of schedule without sacrificing radiological control j ihe licensee implemented a major rotational management program in an effort to promote professional growth and best apply each manager's technical attributes. Management of the Radiological i Controls program was reassigned to a person with previous,

'

though limited, radiological experienc The licensee's radiation protection staff still does not aggressively critique personnel on poor work practices when they are observe The ALARA staff was aggressive in the areas of job preplanning, initiating special mock-up training and the elimination of radiation het spots throughout the plan Senior plant managers were active in the ALARA program and station personnel were ALARA consciou The licensee continued to be below the national average regarding personnel exposures. The person-rem exposure for 1986 was 223 as compared with the PWR national average of 390, and for 1987 was 156 compared to the PWR national average of 37 Confirmatory measurements on the radiochemistry and water chemistry programs were found to be above average in  ;

radiochemistry and satisfactory in water chemistry. The results .

of analyses performed on samples prepared by the Radiological Environmental Sciences Laboratory were in 100 percent agreement with the certified activitie The licensee's level of '

__-.

- _ _ _ -._______________------- --__

.

.. ,

.

performance in this area during the assessment period a;peared to be at about the same level as during the previous assessment perio Weak assessment areas noted in the last SALP period concerning excessive airborne radioactivity areas, supervisory oversight of work operations and excessive turnover in the technical staff of the radiation protection group were addressed by the licensee and improvement has been note The licensee has also made improvements in reliability of the plant radiological process and effluent monitors as discussed in the Maintenance / Surveil'ance sectio . Performance Rating

,

Currently the trend is an improving one due to management's desire to make the radiation protection program a model on The licensee is assigned a performance rating of 2 in this functional are . Board Recommendati_on Recommended NRC Action Inspection activities should be maintained consistent with the Fundamental Inspection Program. In addition, selected Regional Iaitiative Program inspections should be conducted during the next SALP perio Recommended Licensee Action The licensee should take action to improve poor radiological work practices by aggressively critiquing personnel when they are observed. The turnover rate and staff efficiency of the Radiochemistry group should be monitored. The training program for radwaste personnel should be brought up to the same level, and maintained, as other technical training programs at the plan C. Maintenance / Surveillance Analysis The assessment of this functional area included activities associated with diagnostic, predictive, preventive, or corrective maintenance of plant structures, systems, and components. Also included were procurement, control, and storage of components, including qualification controls. The assessment included conduct of all surveillance (diagnostic)

testing 0'tivities as well as all inservice inspection and testing activitie Examples of activities included were

__ __ - _ _ _ - _ _ _ - _ _

.. .

,4

.. .

.,

instrument calibrations; equipment operability tests; post-maintenance, post-modification, and post-outage testing; containment leak rate tests; water chemistry controls; special tests; and inservice inspection and performance tests of pumps and valve The Maintenance / Surveillance functional area was inspected routinely by the. resident inspector In addition, a Quality Verification Function Inspection was performed during the period February 1-12, 1988, by a team of six NRC inspectors from )

Region IV and NRC Headquarters in Bethesda, Maryland. This inspection evaluated the licensee's quality verification activities in the area of maintenance by direct observation of work in progress and review of records. A special inspection of the Emergency Diesel Generator (EDG) major maintenance was also 4 conducted by a specialist from NRR during April and May 1988.

l In the last SALP, the SALP Board recommended that the licensee I work to reduce the outstanding routine maintenance backlo Licensee initiatives were effective in accomplishing a significant reduction in that the corrective maintenance backlog I was reduced from 685 items in December 1986 to 470 items by the end of this SALP assessment period. The preventive maintenance backlog was similarly reduced from over 1000 tasks in December 1986 to about 244 at the end of this period. Finally.

l the number of repetitive maintenance tasks was reduced by

! 26 percent (from about 20,000 to 15,000 by the end of this appraisal period).

The SALP Board also recommended that the licensee work toward implementation of the Station Information Management System (SIMS). SIMS is a state-of-the-art information management system and is used to initiate, process, monitor, and close a wide range of tasks. The licensee has implemented SIMS and it has assisted the planner to develop better work packages, the system engineer to perform timely and accurate analyses of equipment failures, the design engineer to develop better design packages, and maintenance schedulers to better define system and subsystem outage Routine inspections indicate that the licensee appears to have maintained an adequate maintenance staffing level of training technicians, as evidenced by the significant reduction in work backlog, ability to respond the maintenance problems during the assessment period, and by the ability to avoid excessive overtim A significant effort was implemented, particularly during the second refueling outage, to eliminate oil, steam, and water leaks in the Reactor Containment Building. Makeup water needs

-.

._ _ _ _ _ _ _ _ _ .

.

.. ,

.

were about 9000 gallons per day at the beginning of this assessment period. By the end of the period, the demand was reduced to about 3000 gallons per da A station modification was partially installed so that during the refueling outage temporary chillers were connected to the containment cooling fans. These fans are normally supplied by Component Cooling Water which is usually over 90*. This action improved working conditions in the containment during the 1988 refueling outage. The licensee plans to install permanent chillers for this system by 1990. This could reduce the operating ambient temperature in the containment at all times, thus prolonging the operating life of environmentally qualified (EQ) equipment and instrument During the Q"FI the NRC inspectors observed ongoing maintenance activities, had discussions with Maintenance and QA personnel, and reviewed related work packages and QA documentation. On the basis of their observations of work in progress and a review of about 40 Quality Notices (QNs) initiated between 1986 and 1987, the team concluded that in the area of procedure compliance, the licensee's corrective actions have not been fully effective in ensuring that maintenance personnel were complying with procedures. The team found that licensee management was aware of the problem and had been addressing this issue in frequent communications to the plant staff. However, the team observed additional instances in which operations and maintenance personnel were not complying with procedures, as documented in NRC Inspection Report 50-382/88-20 Throughout the assessment period, there were NRC Notices of Violations and Licensee Event Reports which supported the conclusions reached by the QVFI team. Though the maintenance crew appeared to be dedicated and highly competent, there was a need for a changt in attitudes toward procedures such that they will be followed or changed. The licensee's latest programs to accomplish this are addressed in the Operations Functional Area of this SALP Repor As a result of the inspection of the licensee's maintenance activities on Emergency Diesel Genuators (EDGs) A and 8 performed by the specialist from NRR, it was concluded that the licensee had an excellent predictive maintenance program and was setting a good example for the industry. Details on the results of these inspections were discussed in NRC Inspection Reports 50-382/88-08 and 88-1 In late 1987, the licensee implemented several effective and decisive actions to put an end to the long history of nagging reliability problems with the plant's radiation monitor In August 1987, during a radiological waste management inspection,

. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _

.-

.. ,

.

a Region IV inspector raised concerns over this issue. The licensee formed a task force chaired by the Radiation Monitor System (RMS) engineer and consisting of three contract engineers and three RMS Instrumentation and Controls (I&C) technicians from the Maintenance Department. Since the RMS task force was implemented and I&C personnel responsible for the RMS have been to vendor training, the number of technical specification radiation monitors out per week has averaged one to two. The  !

resident inspectors noted recent occasions when no radiation monitors were out of service. With the license's continuing commitment to the RMS system, out of service radiation monitors have become an infrequent occurrenc The second refueling outage (RFO-2) started on April 1, 198 In spite of a number of major technical problems (listed below),

the outage was completed on May 31, 1988. The Plant Manager assumed the position of Outage Manager and there was a well defined outage plan with tasks well scoped, responsibilities well defined, and an obvious involvement by key manager Problems encountered during the outage included:

'

Steam generator primary tube eddy current inspection results required inspecting 600 additional tube (See Special Report to the NRL SR-88-004-00 dated May 4, 1988.)

• Main Steam Isolation Valve (MSIV) internal parts were found in a main turbine stop valve resulting in extensive design, analyses, and rework of both MSIVs. (See NRC Inspection Reports 50-382/88-08 and 88-13).

Reactor Vessel ISI revealed weld defect indications in a hot leg nozzle. This required engineering analyses and NRC reviews. (See LP&L letter or NRR dated May 16, 1988, and NRR response dated May 27, 1988).

The thimbla for the incere nuclear instrument (ICI) at position A-14 failed. The ICI was removed and a dummy ICI installed. (See NRC Inspection Report 50-382/88-13).

,

Significant plant ss.:1 efforts complimented by extensive management involvement enabled the licensee to promptly address these problem The surveillance test program has been accomplished in a timely and correct manner. With the large amount of complex surveillances scheduled during the refueling outage, the licensee's problems in this area were few in numbe There were isolated, minor instances where surveillance procedures were incorrect or were not followed, and more

.

D ...

.i * ,

.

significantly, a small number of surveillances were missed. The t licensee's Health Physics and Chemistry Departmer.ts were held responsible for missing a number of nonroutine surveillances such as gas decay tank grab samples due to monitoring equipment -

being out of service. Weaknesses in the administrative controls in this area were corrected by the licensee and some of the equipment, such as radiation monitors and other process monitors (discussed above in the maintenance area), have been repaired or replaced. These actions appeared to be achieving satisfactory result Except for minor problems noted above, surveillance procedures were found to be adequate in most instances. They clearly stated the purposes of the tests to be performed with appropriate references to the requirements to be satisfie Acceptance criteria were generally well define On May 22, 1988, the licensee conducted the Containment Integrated Leak Rate Test. The resident inspectors witnessed the test and reviewed the data. In addition, a regional inspector subsequently reviewed the test result The test was conduett:d in a professional and well-coordinated manner. There were no deficiencies identified as a result of test result reviews conducted by the NRC inspector Few performance problems were identified in the surveillance test records. This indicated that they were performed by experienced personnel with effective training in performing these procedures. Test deficiencies were identified and resolutions were stated with appropriate references to disposition'ng documents. Resolutions appeared conservative from the safety standpoint and were resolved in a timely manne Appropriate technical reviews were documente Adequate staffing and training of personnel has been evident throughout this assessment period. There were no significant surveillance missed or errors resulting from insufficiently trained personne . Performance Rating The licensee has been establishing a good balance between the resources expended, the quality achieved, and the availability of safety-related equipment and equipment important for the production of electricity. As experience was gained through the first two fuel cycles, and tracking and scheduling became more manageable through such initiatives as SIMS, the maintenance area continued to improv However, the attitude of maintenance personnel toward following procedures requires improvemen ,

l

. .

. l

.

i Surveillance has had a relatively steady performance trend until the end of this assessment period where improvement was eviden This appeared to be the result of management involvement over the few missed surveillances and elimination of some of the nonroutine surveillances caused by monitoring equipment being out of servic The licensee is assigned a performance rating of 2 in this are . Recommendations NRC Actions NRC inspection effort in this area should be consistent with the Fundamental Inspection Program. In addition, a maintenance team inspection should also be conducte Licensee Actions ,

licensee management should take actions as necessary to ensure that improved procedures are provided as appropriate >

to circumstances and that current procr. dural problems are correcte D. Emergency Preparedness Analysis This functional area included activities related to the establishment and implementation of the emergency plan and implementing procedures, such as onsite and offsite plan development and coordination; support and training of onsite and offsite emergency response organizations; licensee performance during exercises and actual events that test emergency plans; administration and implementation of the plan (both during drills and actual events); notification; radiological exposure control; recovery; protective actions; and interactions with ,

onsite and offsite emergency response organizations during exercises and actual event Five emergency preparedness inspections were conducted by NRC region-based inspectors and NRC contract personnel during the assessment perio One inspection involved the cbservation and evaluation of an annual emergency response exercise. One minor violation and four deficiencies were identified during the assessment perio ;

!

The licensee has made significant improvements in the Emergency Preparedness area during this assessment period. These improvements are, in part, due to active management involvement l

i

>%

. _ _ _ _ _. _ _ - _

..

• e' )

.

by the corporate and onsite. organizations. The licensee has implemented an aggressive and comprehensive internal audit program to identify potential problem area Thorough training of emergency response personnel and providing adequate staffing were contributing factors in the licensee's successful completion of the annual emergency response exercis Management has provided the necessary support to ensure that adequate facilities, equipment, and resources are maintained in this area. The licensee has demonstrated that their personnel have a good understanding of emergency response matters. The licensee has made timely improvements in order to maintain a high quality emergency response program. Considerable effort has been expended by th? licensee to ensure that the Emergency Plan and related implementing procedures are maintained in a proper state of readines The licensee has developed and maintained excellent working relationships with federal, state, and local emergency support agencie These arrangements with offiste agencies have proven to be an important contribution to the overall success of the emergency response progra . performance Rating The licensee has demonstrated a steady, continuing improvement in this area. Much of the success is due to a commitment by licensee management to establish and maintain a high quality emergency response progra The licensee is considered to be in performance Category 1 in this are . Recommendations NRC Actions The NRC inspection effort in this area should be consistent with the Fundamental Inspection program, Licensee Action Licensee management should continue its emphasis on upgrading the emergency response program.

!

_ _ . _ . , _ _ . _ . _ _ _ . . _ _ _ _ . _ , _ . _

.

.." s

.

E. Security Analysis This functional area included all activities that ensure the security of the plant including all aspects of access control, security checks, safeguards, and fitness-for-duty activities and control This area was inspected four times by region-based inspectors and on a continuing basis by the resident inspectors. No violations or deviations were identified during the assessment perio The licensee continued to maintain and implement an excellent security program. The licensee has an aggressive, well structured program, that received strong support from corporate and onsite management. The licensee has also provided good technical and administrative supports for the security progra Much of the progr&m success was attributed to professional attitude exhibited by security force personne The security organization received strong support from other onsite department The licensee maintained an excellent training and qualification program. The capabilities of the security force were successfully demonstrated twice during contingency drills conducted during this assessment perio The security program had well-defined functional areas with enough staffing to carry-out the assigned responsibilities. A good testing and maintenance program was in place to er.sure that security systems and equipment were tested in a timely manner and maintained in a proper state of readines The licensee's access control program is a model for NRC Region IV facilities. The licensee employs a manual and electronic key control system limiting personnel access to vital areas to those with a need rather than generalizing a potential nee The licensee has established excellent procedures for the evaluation, resolution, and reporting security event The licensee has demonstrated the ability to properly classify events and submit good quality Licensee Event Reports. On several occasions, the licensee has developed innovative solutions to difficult security problem .

,,< ,.

.

24 , Perft,rmance Rating The licensee continues to maintain a high quality security "

program. The licensee is considered to be in Performance Category 1 in this area, NRC Actions The NRC inspection effort should be consistent with the Fundamental Inspection Progra Licensee Actions Licensee managerrent shoulu continue to provide strong support to the security progra F. Engineering and Technical Support Analysis The assessment of this functional area included licensee activities associated with the design of plant modifications; engineering and technical support for operations, outages, maintenance, tasting, surveillance, and procurement activities; and trainin Design of plant modifications and associated Engineering support as well as engineering and technical support for operations, outages, maintenance, testing, surveillance, and procurement activities are provided from three principal groups: System Engineering, Maintenance Engineering, and the Nuclear Operations Engineering and Construction (NOEC) department. The system engineering group was formed during this SALP assessment period and consists of 20 engineers who are responsible for monitoring system performance and assisting the operations, maintenance and design staffs. The mainteaance engineering function is staffed with eight engineers who provide outage support, manage turbine repairs, and support the predictive maintenance and ASME Section XI progra The NOEC staff has assumed increasing responsibility for design development, and reliance on outside contractors has been reduced. The N0EC department consists of: (1) design engineering; (2) modification control; (3) programs and procurement engineering; (4) field engineering; and (5) safety ana', sis and engineering. The latter group was responsible for th, plant-specific severe core damage probabilistic risk assessment which the licensee has indicated will begin-Jevelopment before the end of 1988. The five groups also performed necessary engineering evaluations and safety analyses to support plant operation Design engineering performed

.

... .

.

.

,

station modification design and was engaged in a design basis documentation program. N0EC was reorganized during the assessment parfod to better define responsibilities and streamline the overall operation of the organization. By the end of the SALP period, the ricensee had made significant progress towards having a self-sustaining engineering organizatio The licensee's assurance d quality in the engineering and technical support area was satisfactory- The evaluation of the failure of Main Steam Isolation Velve B disc guide rails and the design changes instituted by engineering resulted in smoother valve operation and assurance of operability. Engineering support was responsive and appeared to consider the necessar; facts. Early in the assessmo..t period, howaver, NRC inspectors found that some evaluations for justifications for continued operations (JCOs) when questionable materials were discovered were lacking in sufficient detail,and analyse Some JC0 evaluations appeared to have been made on the basis of r satisfying reporting requirements and, to a lesser degree, on the basis of the safety significance of the potential proble !

Later in the evaluation period, NRC inspectors noted considerable improvement in the quality of JCOs, particularly in response to Generic Letter 88-05, "Fraudulent Material."

Additionally, the licensee's engineering staff developed the design for the modified Post Accident Sampling System and the r

Hydrogen /0xygen Analyzer System when outside support proved to 4 be incapable of timely resolutions to these issue However, some weaknesser, were demonstrated in the area of plant a

modifications. As discussed in the Operations Functional Area, Shut Down Cooling was nearly lost due to problems with the .

<

reactor vessel water level indication on May 12, 1988. A ;

similar event occurred in July 1986, and subsequently, Generic Letter 87-12 was issued by the NRC that required licensees to take actions to prevent such incidents. Although the licensee 6 responded with commitments to make certain procedure and hardware changes, these changes were not effectively implemented

to preclude the event of May 12, 198 Examples of inadequate engineering instructions have also been

{ noted during this assessment period. In one instance, a fire '

1 seal had not been installed because engineering had deleted the

location from a control list, probably during the latter phases !

of construction. In another instance, it appeared that ;

engineering issued confusing direction to installers of conduit ;

fire wrap that resulted in the conduit fire wrap not being *

l installed. In addition, an NRC inspector discovered that bolts i installed in the hub of a dry cooling tower fan were inadequat '

The oolts did not have an adequate thread length to develop full clamping force. Subsequent investigation indicated that in j I  !

,

&

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

.

..r- .

.

1983, a change had been made to the fans to require the addition of locking nuts on the bolts and at that time no consideration was given to whether the bolts had sufficient thread length to accept the nut Later, when the fan failed at the hub, new bolts were installed, again with insufficient thread length. It appeared that engineering should have established exactly what type of bolts were required along with the thread lengt During this assessment period, the licensee issued three l Licensee Event Reports (LERs) indicating problems with the engineering of instrumentation systems. In two separate instances, it was found that installed instrumentation was not -

of the correct range for the service intended. One instance involved measurement of containment air pressure with insufficient precision while the other involved a comparable situation with measurement of the amount of diesel fuel in the storage tanks. The remaining case involved a lack of understanding of how the axial shape index measurement equipment interfaced with the core protection calculator. It appeared that the engineering support function should have more carefully defined the technical requirements in each of these cases and '

provided proper guidance to maintenance and operating personne Another LER pointed to a certain lack of engineering expertis It appeared that through a misunderstanding of the criteria for

! isolation of safety and nonsafety electrical circuits, nonsafety

lighting panel and telephone service panels were connected to a i

safety-related power source with only one overload isolation device specified in the engineering chang A violation in this area was also identified during the 1 assessment period where two pipe supports, which were supposed to have double nuts installed did not. The licensee's

^,

subsequent investigation indicated that work instructions given maintenance workers were not sufficiently explicit and that the workers were not trained to recognize the proble Another inspection finding indicated a need for the engineering i i function to follow procedures applicable to their wor In this instance, engineering perscnnel performing a test were observed l to not have a procedure for performance of the test and were j using uncontrolled electrical drawing :

i

'

In regard to training activities, during this SALP period, the licensee completed the INPO accreditation of all ten technical training program The licensee continued to make effective use

of the plant specific simulator and skills training center in ,

the training of operations and support personnel. During this

'

'

appraisal period, several significant changes were made to upgrade the simulato .

!

t i

r

.

. . - .

.

The licensee's requalification program appeared to meet the requirements of 10 CFR Part 5 NRC inspections during this assessment period disclosed that the licensee was adequately modifying their training program on the basis of significcnt plant events, the results of their annuel requalification examination, and training requests (TRs), which were submitted by the plant staf The TR process was also utilized to incorporate industry operating experience into the training program. Incoming documents were assigned to a TR. The inspections did reveal, however, that there were open TRs dating back to 1985, and the documentation on the TRs did not always reference the affected lesson plan. In one instance the subject of a TR had been implemented into a lesson plan before the TR had been dispositione Management involvement in the conduct of the training programs and the quality of the training presented was evident. Upper level training department management provided prior planning and adequate review of the training to be presente Procedures utilized by the facility were in place and adequately described the requirements and policies necessary to conduct trainin Overall, the nuclear training department licensed operator training programs were in agreement with regulatory requirements. There were no significant operational events directly attributable to a weakness in training of personne However, the method used by the licensee to update their emergency operating procedures based on training and operating experiances exhibited some weakness. The TR program was not effectively utilized in this area. The special team inspection of the emergency operating procedures conducted in July 1988 identified a number of errors, which should have been corrected by an effective ongoing evaluation progra Inspections of nonlicensed staff training indicated excellert coordinktion between the plant organizations and the training departmen Licensee management had provided the training department with a separate training facility for nonitcensed personne The training facility included laboratories for electrical, I&C, mechanical, and health physics trainin Equipment in the laboratories included process flow instruments, pumps, valves, and a partial mockup of a steam generato Overall, the training program was well defined and implemente Means had been established to provide for feedback of experience from both within and outside the utility. The training department had an attitude for self-improvement, and had implemented lessons learned from the feedback mechanis l

<

eO' O i

i

In this functional area, the licensee has been responsive to NRC initiatives, except as noted earlier in this analysis in the response to Generic Letter 87-1 For example, in the las'. SALP report, the SALP Board made a number of recommendations that ,

were appropriately implemented as discussed belo ;

First, the Board recommended that additional efforts be focused on resolving outstanding issues associated with the Safety Parameter Display System (SPOS). In February 1987, the licensee established a task force of personnel from operations and engineering with the goal of resolving the concerns and deficiencies with the present SPOS system. By June 1987, a l functional design was developed. In August, the NRC issued a Safety Evaluation Report which approved the SPOS Enhancement Progra The licensee has indicated plans to make the improved system fully operational by October 198 Second, the Board recommended that lingering problems associated l with the plant computer be resolved. Much effort has been I expended during this SALP period to improve the reliability of the plant computer through design changes in hardware and software and the operational flexibility provided by a recent change to the Technical Specifications. With these l improvements, operational restrictions imposed by the plant computer have been greatly reduced.

l The SALP Board recommended that the licensee take steps to i reduce the backlog of station design changes. Licensee l management has applied significant resources to this issue. At l

the beginning of the SALP assessment period, the backlog of station modification packages (SMP) was 954 while at the end, it was only 348 with 271 SMPs having been generated during the assessment perio Finally, the SALP Board made two recommendations related to trainin These involved the simalator and non-licensed operator training and are discussed in the plant operations I section of this report. One additional recommendation related

! to training involved the correctior; of deficiencies in the l'

administration and documentation cf training. These j deficiencies were corrected.

i l P__erformance Rating The reorganization of NOEC and the more clearly defined responsibilities of the various en;ineering groups should yield improvements in the efficiency and timeliness of engineering l

l l

l l

.- - ,. --

,

.

,.4 r,

'O

support to other site organizations. Management involvement has y become more evident, and an improving trend was noted at the end of this assessment perio A performance rating of 2 is assigned to this functior.al are . Recommendations NRC Actions Inspection activities should be maintained consistent with the Fundamental Inspection Progra In addition, selected Regional Initiative Program inspections should be conducted during the next SALP period, Licens.ee Recommended Actions Implementation of the new station modification process should include reviews to ensure that lessons learned from design inadequacies, turnover problems, and procedure update problems are considere The determination of operability of safety-related components and systems by the Shift Supervisor should be promptly supported by engineering. Promptness should be defined as a function of the safety significance of the issue, and appropriate actions should be taken in accordance with plant procedure Engineering personnel should be train 2d in the importance of following procedures so that the technical direction which the engineering organization provides can be followed in a precise, logical manne Review the training request (TR) program and ensure that dated TRs are minimized or eliminated, and that the TR program is actively utilized, G. Safety Assessment / Quality 3 rification Analysis The assessment of this functional area included all licensee review activities issociated with the implementation of licensee safety policies; licensee activities related to amendment, exemption and relief requests; respeise to generic letters, bulletins ano information notices; and resolution of TMI items and othe' regulatory 'nitiative It also included activi, ties j related to the resolution of safety issues, 10 CFR 50.59 l

reviews, 10 CFR Part 21 assessments, safety committee and self-assessment activities, analyses of industr/ s operational l

l l

.

. _ _ _ _ _ _ _ _ _ _ _ _ _

t c" #

,

experience, r< causa analyses of plant events, use of feedback from plant quality assurance (QA)/ quality control (QC) reviews, and participation in self-improvement programs. It included the effectiveness of the licensee's quality verification function in identifying and correcting substandard or anomalous performance, in identifying precursors of potential problems, and in monitoring the overall performance of the plant, Licensing In the licensing area involving interface with NRR or Region IV, substantial progress has been made during the SALP period to close out license conditions, Safety Evaluation Report (SER) open items, and licensing concern Twenty-eight license amendments were issued which, among other things, closed out or corrected four license conditions. Closed were broad range toxic gas detectors (2.C.4), smoke detectors in the control room main control panels (2.C.9.d), reactor coolant system depressurization capability (2.C.12), and corrected was fuel movement in the fuel handling building (2.C.14). Two other license conditions were addressed by letter There were axial fuel growth or shoulder gap clearance (2.C.7) and basemat cracking (2.C.17). Of the 28 license amendments, only two were issued on an emergency basis during the 18-month '.

perio SER commitments and conditions continued to be implemented ,

or closed out during the SALP period. The boraflex  ;

'

surveillance program was found accertable and the SER condition on natural circulation and the control system single failure study were completed. Approvris wer1 also provided to allow reactor vessel surveillanct to the 1982 revision of ASTM E 185, continued operation with reactor  !

vessel nozzle flaws discovered during the 1988 refueling outage, reduced duration containment integrated leak rate test and continued Appendix J containment leak testing with known leak paths closed or flanged out. Approvals have also been provided for a number of Salem ATWS items (Generic Letter 83-28) and TMI Action Items. Although the licenses has completed many of these actions, Salem ATWS and TMI Action Items still remain outstandin l Throughout this essessment period, the licensee demonstrated adequate management, seund technical approaches to resolution of licensing issues, and generally responsive and timely resolutions to NRC concern Management involvement was evident in the planning and assignment of priorities and was frequently involved in <

coordinating site and licensing activitie The licensee

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

,

'

.

sc .

.

appeared to keep abreast of technical resolution of other lead plants in implementing requested changes and is frequently involved in owners group program During the SALP period, several bulletins were issued which required a response by the licensee. Bulletin 85-03, ,

"Motor-Operated Valve Common Mode Failures During Plant Transients Due to Improper Switch Settings," was complete The bulletins which required a response or involved significant work included Bulletin 87-01, "Thinning of Pipe Walls in Nuclear Power Plants;" Bulletin 87-02, "Fastener Testing For Determining Conformance With Applicable Material Specifications;" Bulletin 88-04, "Potential Safety-Rel.:ted Pump Loss;" and Bulletin 88-05,

"Nonconforming Materials Supplied by Piping Supplies In at Folsom, New Jersey and West Jersey Manufacturing Company at Williamstown, New Jersey " The licensee's submittals were provided near the due dates and were responsiv Bulletin 83-05 required extensive licensee effort to identify questionable flanges, obta h hardness readings, and provide justifications for continued operation for flanges failing the acceptance criteri The licensee established and maintained a well organized program to satisfy the concerns of the bulleti A number of generic letters were issued in the SALP period, but few required a response. Generic Letter 87-12. "Loss of Residual Heat Removal While the Reactor Coolant System is Partially filled," required a detailed response of the description of how the licensee will meet the licensing basis while operating with a partially drained reactor coolant system (RCS). Although the response of September 21, 1987, appeared adequate, the licensee failed to ensure that all the commitments were properly implemented through Quality verification. This appeared to contribute to the May 12, 1988, incident, discussed earlier in this report, where there was a pott.:tial loss of shutdown cooling. See NRC Inspection Report 50-382/88-16, and Enforcement Action 88-144 dated August 18, 198 The licensee has been generally responsive to industry operating experience and vendor information and takes timely actio However, during a vendor interface inspection conducted in December 1987, the team identified 16 vendor service bulletins for the emergency diesel ger.erator (EDG) that had not been promptly reviewed and dispositioned upon receipt. One of these bulletins reported a potential failure of turbo charger support bolts. Inspection of the EDG installation revealed that this problem existed. The licensee then took prompt action to evaluate and correct the problem. A comprehensive

._ -

e

.r" ,

.

,

program to re-review hundreds of vendor bulletins and other operatin; experience documents which were initially deemed as not requiring special technical reviews was implemente No sisnificant problems were revealed as a resul The licensee has made considerable progress in resolving the remaining longstanding safety issues. Approval of the Safety Parameter Display System (SPDS) redesign, licensing of the Broad Range Toxic Gas Detection System, approval of the confirmation analysis and monitoring programs associated with basemat cracks, and implementation of improvements resulting from control room design reviews have occurred during this period, Corrective Actions There were a number of instances during this SALP period where the licensee had exhibited marginal performance in taking corrective actio There were cases where the actions were not timely with respect to the safety significance. Sometimes the symptoms were corrected rather than the root causes. It was not readily apparent that the independent assessment groups that were in place to provide critical self-evaluations had any significant impact on plant optrations. However, discussions with QA and Nuclear Operations Support Assessment groups held at the end of the SALP period providea encouragement that these groups were becoming more recognized as an important and constructive part of the organizatio Some examples of inadequate or untimely corrective actions were:

• Repeated instances of component labeling and procedure l vrrors in ESF systems found during bimonthly I walkdown * Repeated instances of the failure to follow I

procedures.

• Administrative discrepancies in Temporary Alteration ,

• Repeated (three) shutdowns due to clogged reactor coolant pump 2B '.ubricating oil strainers.

l l

Eight QNs were issued due to expansion of work scope I by unauthorized maintenance department personnel between 1986 and 1987.

I l

.

_ . - _ . - _ __ __

__..__ _ .-- .. _

_ _ _ _ _ _ _ _ _

.

.e<- .

.

Undersized wiring found in the A Shield Building Ventilation System heater control in 1985 not corrected until 198 *

A wiring error in the transfer trip circuitry for pressurizer heater backup overload protection discovered on May 21, 1988, was corrected during the refueling outage but was not retested, apparently due to schedule constraints, until September 14, 1988, more than 3 months after the feature was required to be operabl *

On June 20, 1988, QA identified a possible failure to perform NDE (dye penetrant test) on primary instrument tubing which cannot be isolated. On June 27, a QN was initiated by QA. On July 15, the QN was answered by responsible Nuclear Operations Construction personnel, and by July 28, they initiated a nonconformance condition identification repor It was not until August 2, 1988, that engineering identified the event as potentially reportable as a condition outside the plant's design basis. The LER described the "event date" as August 2, 198 On a number of occasions, the resident inspectors and the Region IV staff noted a lack of sense of urgency on the part of this licensee to take prompt and timely corrective action on the basis of the relative safety significance of

'

the event, particularly when correction was not required to support startup or remaining at power. On several occasions, this was brought to the attention of plant managemen c. Independent Verification Organizations

,

The plant Operations Review Committee (PORC) was evaluated during the Quality Verification Function Inspection (QVFI)

early in 1988, During the QVFI, the inspectors attended two PORC meetings and reviewed PORC meeting minutes. The

'

inspectors noted that the PORC meeting minutes were of a checklist type with little, if any, substantive information provided as justification for particular PORC actions taken on decisions and recommendations mad This same cencern was identified by the Safety Review Committee, which recommended that the meeting minutes be upgrade One of the PORC's functions was to review each potentially reportable event (PRE) and provide an independent verification of the proper classification, either reportable or nonreportable. In this manner, the initial decision mada by the Manager, Events Analysis, Reporting

- _ _

G

.o- .

.

and Response group was given an independent chec Deficiencies that were not classified as reportable appeared to get less thorough and less timely attention than items that were classified as reportable. Review of the PRE summary index for 1987 showed much more timely reviews (always well within 30 days) for reported PRES than for PRES deemed not reportabl The inspectors noted that, of 11 reportable failures, 5 events had been reviewed and approved by the PORC as not reportable. In one instance, the PORC meeting minutes stated that the PORC had been assured by the PRE reviewer that the event was not reportable. That statement was an indication that the PORC needed to provide more independent review During a review of Plant Operations Review Committee meeting minutes, the resident inspector noted that a nonvalid failure of Emergency Diesel Generator (EDG) "A" was presented and approved as a nonreportable even Technical Specification 4.8.1.1.3 required a special report to the NRC within 30 days for all EDG failures, valid or nonvalid. Regulatory Guide (RG) 1.108 defined what is valid and what is nonvalid. The licensee explained that some of the nonvalid failures listed in RG 1.108 were not reportable if the test causing the failure was nonvali Such a situation would render the failure nonexistent, and thus nonreportable. Upon review of the licen,ee's disposition of other such failures, a total of 13 were found unreported ber.ause of a rimilar rationale. After some discussion between the resident inspectors, NRC Region IV NRR, and the licensee, the licensee submitted a special report summarizing all the unreported failures on March 18, 1988. There were also a few other cases where events that should have been reported pursuant to 10 CFR 50.73 were not, due in part, to inadequate PORC review There were some indications that communication between the verification function and other groups, particularly Licensing, is less than fully satisfactory or perhaps the i procedures for doing certain review analysis functions were

! less than clear. An example of this concern was the I evaluations performed by Licensing for 10 CFR Part 21

,

reportability were poorly documented.

l l The analysis of this area indicates weaknesses in plant I safety committee reviews, corrective actions, and I

self-assessment capability. These weaknesses have been manifested in several areas, including examples of failure to report events to the NRC, delays in making operability i

_ _ _ _ _ - - - .

.

'e" *

O

determinations, and inadequate root cause determination For example, following the May 12, 1988, potential loss of shutdown cooling event, the licensee's independent safety organizations were not effectively utilized for a critical self-assessment and to assist with corrective action determinations. There has also been instances noted where the Quality Assurance group failed to document deficiencies and cause corrective actions to be implemented. This indicates weaknesses in the licensee's ability to perform critical self-assessments, that is, the ability to identify, report, and promptly correct potentially safety-significant problem Several improveacnts to the licensee's QA program have occurred, however, centering around the integration of QA support within plant operations activitie Significant changes to the QA organization occurred near the end of the SALP perio Since most of these improvements and organizational changes occurred late in this assessment period, their implementation effectiveness has not been evaluate . Performance Rating The licensee is assigned a 2 in this performance are . Recommendations NRC Actions The NRC inspection effort should be consistent with the Fundamental Inspection Program. In addition, selected Regional Initiative Program inspecticns should be conducted during the next SALP perio Licensee Actions The licensee should make every effort early in the following SALP period to complete and implement the remaining Salem ATWS and TM1 action item The licensee should continus efforts to raise the quality of safety assessments and submittals and, thereby, reduce further the need for supplemental responses. While management attention to assessment efforts has been adequate, improvements in initial submittals would be to the licensee's benefit.

l l

l l

l

,

e s ee .

o

All organizations, particularly QA, need to support the recently improving trend of willingness to document deficiencies, such that they can be trended and critical self-assessments can be mad Licensee management should work to instill an improved staff willingness to be self critica The independent assessment groups within the licenseq's organization need to become more visible with the positive support of those organizations being assesse V. Supporting Data and Summaries Enforcement Activity See Table Confirmation of Action letters None

( _ - _ _ _ _ _ _ _ _ .

, . + - c, O

TABLE 1 f-

-

ENFORCEMENT ACTIVIlY FUNCTIONAL NO. OF W OLATIONS IN SEVERITY LEVEL AREA V IV III II I Plant. Operations 1 2 1(I) Radiological Controls 1 2 Maintenance / Surveillance 10 Emergenc> Preparedness (2) 3 Security Engineering / Technical Support 5

. Safety Assessment / Quality 1 6 Verification TOTAL 4 25 1 0 0 Footnotes:

(1) A Notice of Level III Violation and proposed imposition of a civil penal +y of $50,000 was issued to the licensee on August 18, 1988. The violation involved several examples of inadequate ccrrective actions and failures to properly implement precedures causing a loss of control of reactor coolant system water level with a consequence of near loss of shutdown cooling flow on May 12,1938 (see NRC Inspection Report 50-382/88-16).

(2) Durirg the annual emergency response exercise of October 14, 1987, four deficiencies were identified requiring a 30-day response f rom the licensee (see NRC Inspection Report 50-3P2/87-23).