IR 05000440/1986001
| ML20206P593 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 06/27/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206P571 | List: |
| References | |
| 50-440-86-01, 50-440-86-1, NUDOCS 8607020163 | |
| Download: ML20206P593 (39) | |
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SALP 6 i
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SALP BOARD REPORT U. S. NUCLEAR REGULATORY' COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i
50-440/86001
Inspection Report
Cleveland Electric Illuminating Company
Name of Licensee
-Perry Nuclear Power Plant, Unit 1
Name of Facility
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July 1, 1985 through April 30, 1986
Assessment Period
S887RBheaSt8obo
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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 based upon this
information. SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations.
SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
An NRC SALP Board, composed of staff members listed below, met on June 20,
1986, to review the collection of performance observations and data to
assess the licensee's performance in accordance with the guidance in NRC
Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II
of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Perry Unit 1 for the period July 1, 1985, through April
30, 1986.
SALP Board for Perry 1 :
Name
Title
J. A. Hind
Director, DRSS
C. J. Paperiello
Director, DRS
C. E. Norelius
Director, DRP
R. F. Warnick
Chief, Reactor Projects
Branch 1, DRP
Walter R. Butler
Project Director, NRR/BWD-4
R. C. Knop
Section Chief, DRP
D. H. Danielson
Section Chief, M&PS, DRS
E. R. Schweibinz
Chief, Tech Support Staff, DRP
W. G. Snell
Section Chief, DRSS
G. L. Pirtle
Section Chief, Safeguards
Section, DRSS
L. G. McGregor
Chief, FRPS, DRSS
M. Schumacher
Chief, RECS, DRSS
John J. Stefano
Project Manager, NRR/BWD-4
J. A. Grobe
Perry Senior Resident
Inspector, DRP
K. A. Connaughton
Perry Resident Inspector, DRP
J. E. Foster
EP Analyst, DRSS
J. W. McCormick-Barger
Project Inspector, DRP
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II. CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or
operating phase.
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.
One or more of the following evaluation criteria were used to assess each
functional area:
1.
Management involvement and control in assuring quality.
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2.
Approach to the resolution of technical issues from a safety
standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Operational and Construction events (including response to, analysis
of, and corrective actions for).
6.
Staffing (including management).
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1:
Reduced NRC attention may be appropriate.
Licensee
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management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety and
construction is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
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operational safety and construction is baing achieved.
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Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
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be strained or not effectively used so that minimally satisfactory
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performance with respect to operational safety or construction is being
achieved.
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III. SUMMARY OF RESULTS
Overall, the licensee's performance was found to be acceptable. The
licensee was found to have aggressive management attention and a high
level of performance in the assessment areas of Electrical Power and
Instrumentation and Control Systems, Licensing Activities, Emergency
Preparedness, and Security. All other assessment areas were found to
be adequate and represented a licensee management team that was
sufficiently staffed and appropriately involved and concerned with
nuclear safety. The highly transitional stage that the plant is
undergoing as it moves from construction and preoperational testing to
icw power testing and eventual full power operation will require
increased management attention. Management involvement in assuring safe
operation must continue to be present with a particularly keen sense
of awareness of weaknesses that are identified through implementation of
their operational program.
Rating Last
Rating This
Functional Area
Period
Period
A.
Containment and Other
NR
Safety-Related
Structures
B.
Piping Systems
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and Supports
C.
Heating, Ventilating,
NR
NR
and Air Conditioning
(HVAC)
D.
Electrical Power
NR*
and Instrumentation
and Control Systems
E.
Quality Programs and
2
Administrative Controls
Affecting Quality
F.
Licensing Activities
1
G.
Preoperational Testing
2
H.
Startup Testing
NR
NR
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I.
Radiological Controls
2
J.
Fire Protection
2
K.
1
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L.
Security
1
M.
Maintenance / Modifications
NR
N.
Surveillance and Inservice
NR
Testing
O.
Fueling
NR
P.
Operational Readiness / Plant
NR**
Operations
Q.
Training and Qualification
NR
Effectiveness
- The licensee was rated in the two areas separately during the last
assessment period. A Category 2 was given for Electrical Power and a
Category I was given for Instrument and Control Systems.
- The licensee was rated a Category 2 in Operational Readiness during the
previous assessment period but not rated in Plant Operations.
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NR = Not Rated
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IV.
PERFORMANCE ANALYSIS
A.
Containment and Other Safety-Related Structures
1.
Analysis
The work activities in this functional area are essentially
complete.
Inspection activities by Region III inspectors
were limited to portions of seven inspections. Areas examined
included a review of activities related to the drywell
structural integrity test (SIT), structural steel as-built
drawing verifications, and allegations concerning the
misapplication of coatings in the containment, containment
iiner weld quality, voids in bioshield concrete, fuel transfer
pool integrity, Polar Crane box girder weld quality and
containment piping penetration seal defects.
For the areas examined, the inspectors determined that
activities were generally controlled through the use of well
stated and defined procedures. The approach used to conduct
the SIT was generally conservative, technically sound, and
thorough.
Records were found to be generally complete, well
maintained, and available.
Inspections into the concerns
contained in the allegations did not disclose any issues for
which the licensee had not already taken suitable corrective
actions.
No violations or deviations were identified.
2.
Conclusions
Due to the limited inspection activities performed in this area,
the licensee was not rated.
The licensee received a rating of
Category 1 during the last SALP period.
3.
Board Recommendations
None.
B.
Piping Systems and Supports
1.
Analysis
The inspection activities in this area were, for the most part,
limited to observation of completed work and a selected review
of records because construction was essentially complete at
the beginning of the assessment period.
Examination of this
functional area consisted of portions of ten inspections by
Region III inspectors. Areas examined included (1) visual
examination of selected piping welds and piping spools;
(2) review of radiographs and related reports for selected
field welds; (3) testing of pipe support and restraint systems;
(4) the inadvertent overpressurization of some non safety-related
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High Pressure Core Spray pump test return line piping during
system vibration testing; (5) review of selected licensee " Call
for Quality" investigations and engineering technical evalua-
tions; (6) examination and field walkdowns of selected as-built
safety-related piping systems and supports; and (7) licensee
actions related to previous inspection findings, IE Bulletins,
IE Circulars, IE Information Notices, and 10 CFR 50.55(e)
deficiency reports.
One Severity Level IV violation was identified for
failure to adequately control the design of pipe
supports. The licensee's written response and
implementation of corrective actions were reviewed
and found to be acceptable. This violation is not
repetitive of violations identified during the
previous assessment period and it did not appear
to have generic or programmatic implications
(Inspection Report 50-440/85016).
For the areas examined, the inspectors determined that
activities were generally controlled through the use of well
stated and defined procedures. Visual observations indicate
personnel had an adequate understanding of work practices and
that procedures were generally adhered to.
The licensee's
actions in response to previous inspection findings, NRC
initiatives,10 CFR 50.55(e) deficiency reports, were generally
timely, thorough, and technically sound. With the exception
noted above, the control of design was viable, generally sound,
and thorough.
Their approach used to evaluate and analyze
piping system vibration and thermal expansion preoperational
testing was generally conservative, technically sound, and
thorough. The " Call for Quality" investigations and resulting
technical evaluations were technically sound and acceptable
resolutions were generally implemented. Records were found
to be generally complete, well maintained, and available.
2.
Conclusions
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last SALP period.
3.
Board Recommendations
None.
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C.
Heating, Ventilating, and Air Conditioning (HVAC)
1.
Analysis
Examination of this functional area consisted of one inspection
during which the Region III inspector reviewed the HVAC
contractors installation activities. Areas examined included
(1) a review of the design specification and applicable
installation and quality control procedures; (2) a review of
certification and qualification records for selected QC
technicians (inspectors) and welders; (3) a walkdown of
portions of selected systems which included examination of
installations for conformance to design drawings, fabrication
sketches and duct installation procedures, and (4) a review
of selected installation packages and testing records.
For the areas examined, the inspector concluded that activities
were generally controlled through the use of well stated and
defined procedures. Observations of HVAC activities indicate
the personnel had an adequate understanding of work practices
and that procedures and drawings were adhered to.
Records were
found to be generally complete, well maintained, and available.
The records also indicated that personnel performing welding and
QC inspection activities were trained and certified. No
violations or deviations were identified.
2.
Conclusions
Due to the limited inspection activities performed in this
area, the licensee was not rated. The licensee was not
assessed in this area during the last SALP period.
3.
Board Recommendations
None.
D.
Electrical Power and Instrument and Control Systems
1.
Analysis
The examination of this functional area included portions of 25
inspections by Region III inspectors. The inspections included
(1) examination of control of activities involving the
installation of materials and components including direct
inspection of in process and completed work; (2) walkdown
inspection of instrumentation systems and electrical circuits;
(3) review of welding processes; (4) inspection of instrument
and electrical cable terminations; (5) examination of quality
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assurance records including equipment and materials qualifica-
tion; (6) as-built drawing verification; and (7) examination of
quality control activities.
No violations of NRC requirements
or deviations from commitments were identified in this functional
area.
The inspectors identified no programmatic or procedural
weaknesses in this functional area during the appraisal period.
With one minor exception, issues identified by the inspectors
and/or licensee were promptly and adequately resolved. The
single exception involved incomplete evaluation of susceptibility
of installed plant instrumentation to radio frequency
interference as recommended by IE Information Notice 80-09.
Once this matter was brought to the licensee's attention,
additional actions were implemented in a thorough manner and
resolution was achieved prior to operating license issuance.
Significant deficiencies were promptly reported in accordance
with 10 CFR 50.55(e). Analyses were thorough and included
comprehensive corrective actions.
The Perry construction quality assurance organization was
adequately staffed with well qualified personnel as
demonstrated by the quality of their overview inspections,
surveillances, audits of contractor activities,
and their responsiveness to regulatory issues. The
inspections, surveillances, and audits were timely, thorough,
and in-depth to determine the root cause(s) of identified
problems.
Corrective actions were timely and directed toward
preventing the recurrence of problems.
Management involvement in assuring a high degree of quality was
evident throughout the assessment period. An example of this
was reflected in their final inspections /walkdowns of systems
prior to turnover. These activities were found to be thorough
and served to present the carry over of construction
deficiencies into the testing and operating phases of the
plant.
In addition, outstanding licensee performance was
evident from the lack of violations or deviations issued
during this rating period and the quality of the overview
provided by the licensee's quality assurance organization.
2.
Conclusions
The licensee is rated a Category 1 in this area.
The licensee
was rated separately a Category 1 in Instrument and Control
Systems and a Category 2 in Electrical Power Supply and
Distribution during the previous assessment period.
3.
Board Recommendations
None.
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E.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
One region based inspection was performed to determine the
adequacy of the Operational Quality Assurance Program in the
following areas:
safety committee activities; tests and
experiments; operating staff training; surveillance testing;
and calibration control.
No violations or deviations were
identified.
Another region based inspection consisted of an NRC Augmented
Investigation Team (AIT) and a support team walkdown inspection
following the January 31, 1986, earthquake to determine its
effect on the Perry plant.
Following the January 31, 1986, earthquake, a Confirmatory
Action letter (CAL-RIII-86-01) was issued on January 31, 1986,
to document an agreement to maintain all affected equipment in
the "as found" condition until the NRC AIT could jointly with
the licensee evaluate any evidence to determine the effects of
this event. The AIT inspection included confirmation of the
data gathered by the Perry staff during their plant walkdowns,
the review and the validation of the data captured by the plant's
seismic instruments, and conduct of a detailed inspection of
selected safety-related systems including piping and associated
mechanical and electrical support systems.
Based on AIT observations, it was determined that activities
were generally controlled through the use of well stated and
defined procedures and that personnel demonstrated a general
understanding of the actions required to respond to an off-
normal event.
The licensee's approach to evaluating the event
was conservative, technically sound, and thorough. The
licensee's actions in response to the CAL were prompt and
effective.
Records were found to be complete and reasonable
steps were taken to preserve and validate the data.
Considerable resident inspection effort was expended to examine
licensee activities in this functional area in the course of
fourteen inspections. This inspection effort focused upon (1)
development and staffing of the plant operating organization;
(2) development and implementation of administrative procedures
required for plant operation; (3) implementation of
administrative controls for the tracking and resolution of
outstanding construction items and establishment of equipment
operability; (4) independent review programs; (5) procedures
and activities addressing housekeeping and care and preservation
of safety related components; (6) implementation of the
licensee's program for the handling of employee concerns and
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allegations; (7) review and investigation of~ allegations dealing
with employee fitness for duty; (8) development and implementa-
tion of the licensee's program for the tracking and resolution
of NRC inspector-identified items; (9) the licensee's program
for performing evaluations required by 10 CFR 50.59; and (10) the
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processing of FSAR changes prior to operating license issuance.
Two violations were identified, as follows:
a.
Severity Level IV - failure to establish and implement
adequate administrative controls for housekeeping and
material control (Inspection Report 50-440/86006).
b.
Severity Level IV - failure to develop and implement
adequate procedures for establishing and documenting the
operating status of plant instruments (Inspection Report
50-440/86008).
The housekeeping violation resulted following a turnover of
housekeeping responsibilities from the construction
organization to the operating organization. Corrective actions
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in response to earlier violations involving housekeeping were
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not adequately translated into the administrative procedures
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governing housekeeping for the facility operating phase.
Licensee response to this violation was prompt and thorough.
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Interim and permanent corrective actions taken included
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training of responsible personnel to revised administrative
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procedures.
The violation concerning plant instruments represented a
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breakdown in administrative controls which, had it gone
undetected, would have seriously threatened the operability
of a number of safety related instruments.
Following
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identification of this deficiency by the licensee, a program
of corrective action was formulated in consultation with NRC
Region III management. This program was formally submitted
to the NRC and incorporated as a condition of the Perry
operating license.
Followup inspections by the resident
inspectors confirmed, prior to fuel load and initial
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criticality, that required portions of the corrective action
program were acceptably completed.
Licensee actions in
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response to this matter were generally timely and thorough;
however, the corrective action plan initially formulated by
the licensee was deficient in a number of respects.
It did
not include evaluation of the effects of mispositioned
instrument valves on preoperational and surveillance test
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results nor did it include review to determine if instrument
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valves were mispositioned by unauthorized personnel (i.e.
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tampering).
Finally, the schedule for providing valve
identification tags was untimely.
Following discussions among
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the licensee, Region III management, and inspection personnel,
the deficiencies were resolved and incorporated into the
licensee's formal submittal.
The significance of this matter was mitigated by the fact that
a licensee initiative to assess operational readiness had
identified the problems and corrective actions were accomplished
before plant operating conditions required operability of
affected instruments.
Throughout the assessment period licensee management
involvement in the implementation of quality programs and
administrative controls has been highly visible. This
involvement was evidenced by the establishment of a formal
and comprehensive program for the completion of plant licensing,
construction, testing, and operational program development
activities. The program was well formulated and provided a
high level of assurance that these activities were completed in
a thorough and timely manner to support plant operations.
By management direction, operational administrative controls
and procedures were implemented on November 1, 1985. This has
proven to be invaluable in that it resulted in the early
detection of programmatic weaknesses, inconsistencies and areas
where additional personnel training was needed. By the time of
operating license issuance, the licensee had demonstrated the
capability to implement a viable system of operational programs
and administrative controls to support plant operations.
Throughout the assessment period the licensee exhibited a high
level of responsiveness to NRC identified concerns and their
resolution of technical issues were generally found to be
adequate. This was evidenced by numerous refinements to
operational programs and procedures, enhanced personnel
training, and self assessments of operational readiness
conducted to resolve NRC identified weaknesses.
Staffing
was found to be ample and well trained.
In summary, quality programs and administrative controls
affecting quality were determined to be adequate and acceptably
implemented throughout the difficult pre-licensing and initial
operations phases included in this assessment period.
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
was rated Category 2 in this area during the previous
assessment period.
3.
Board Recommendations
None.
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F.
Licensing Activities
1.
Analysis
Evaluation of the licensee's performance for this rating
period was predicated on how the licensee fared in the
areas of management involvement and control in assuring
quality; how the licensee approached the resolution of
technical issues; the licensee's responsiveness to NRC
initiatives; and project staffing in the emergency planning,
licensing, and plant operating organizations.
During this review period, the licensee's management
demonstrated an active participation and thorough working
knowledge of the technical issues involved in licensing
activities, and has kept abreast of current and anticipated
NRR licensing actions. This was especially evident by actions
taken by the licensee's management in directing his staff to
ensure that the physical plant was designed and built in
conformance with regulatory requirements, and in the finaliza-
tion of plant technical specifications. With respect to the
NRC technical concerns over the use of silicone sealants on
HVAC ductwork, it is the staff's opinion that the licensee's
management enabled its technical personnel to institute a
comprehensive testing program to address long-standing generic
NRC staff concerns relative to the integrity of silicone
sealants used in HVAC ductwork under postulated accident
environmental conditions. This testing program is unique in
the industry and has the potential for solving this long-standing
generic issue. More recently, the licensee's management
direction and direct involvement in assessing the effects of
the 1986 Ohio earthquake on the plant design, as well as in the
re-review of the site area geology / seismology design bases, was
instrumental in obtaining the Perry Unit I low power operating
license in March 1986. Wecknesses reported for the last SALP
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period in the area of the licensee's management involvement and
control in assuring quality with respect to plant test and plant
operation organizational interfaces, control and overview of FSAR
amendments, the oversight of in-house and Architect Engineer
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engineering work to preclude deficiencies found during the
Independent Design Inspection (IDI) Team audit of the licensee's
technical documentation file, and the workload problems in the
Licensing organization which resulted in missed commitments,
have all been corrected to the NRR staff's satisfaction. On
being notified of these performance weaknesses, the licensee's
senior management took prompt remedial action and instituted
more rigorous controls and made personnel changes which corrected
problems in the oversight of engineering work and organizational
interfaces.
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The licensee's understanding of technical issues, which needed
to be resolved prior to obtaining an operating license for
Perry 1, and their approach to resolving technical issues was
found to be thorough and competent.
Performance of the
licensee's technical staff was better than average in
addressing such difficult SER open issues as:
reliability of
TDI diesel engines; the detailed control room design review;
Reactor Coolant Pressure Boundary (RCPB) leak detection design;
Mark III (Humphrey) containment design issues; completion of
the fire protection program; use of silicone sealant in HVAC
ductwork; post accident sampling system design; and the
completion of plant equipment seismic / dynamic qualifications.
It is particularly noted that the work performed by the
licensee contributed to making Perry the only Mark III plant to
date which has satisfactorily resolved every containment design
issue, alleged by John Humphrey (a former GE engineer) at the
time the initial SER was issued in May 1982.
Responsiveness to NRC initiatives has been most satisfactory in
that the licensee is always ready to meet with the staff (often
generating meetings themselves) to ensure a correct response to
NRC needs. Examples of this were most evident from the
licensee's performance in the resolution of the technical issue
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discussed above, responding to TMI Action Items, requests for
additional information, and NRC Generic Letters during this
performance appraisal period.
The licensee's staffing for the operation of Perry 1 is
considered by NRR to be qualified and adequate for Perry 1
operation. At the time of Perry I licensing, there was a
sufficient number of licensed SR0s, R0s, and STAS to man six
operating shifts. The licensee has chosen to operate the
facility with four rotating shifts throughout the startup
test program. The licensee's plan to have every General
Engineering Supervisor licensed as SR0s as a matter of policy
is a distinctive plus.
An inspection was performed by region based personnel to
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determine the level of consistency and compatibility between
plant Technical Specifications (DRAFT), Final Safety Analysis
Report (FSAR), Safety Evaluation Report (SER), as-built
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configurations, surveillance requirements, and preoperational
test acceptance criteria. The inspection revealed no
violations of NRC requirements and documents reviewed exhibited
a high degree of consistency.
2.
Conclusions
An overall Category 1 rating is assigned for the licensee's
performance for this rating period. The licensee was rated
Category 2 in this area during the previous assessment period.
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3.
Board Recommendations
None.
G.
Preoperational Testing
1.
Analysis
During this assessment period six inspections were performed
in this functional area. The inspection effort included:
(1) review of administrative controls and implementing
procedures; (2) detailed reviews of preoperational test
procedures and results; (3) preoperational test witnessing;
(4) verifications of preoperational test procedures and results;
(5) independent inspection; and (6) followup of previous
inspection items.
Six violations were identified as follows:
a.
Severity Level IV - Preoperational Test Procedures TP
1C71-P001, " Reactor Protection System (RPS)" and TP
IC71-P002, " Reactor Protection System Motor-Generator
Sets" were inadequate because they did not adequately
test design features.
Preoperational Test Procedure
TP 1M51-P001, " Combustible Gas Control System" was
inadequate because it was inconsistent with the
licensee's administrative requirements (Inspection
Report No. 50-440/85042).
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b.
Severity Level IV - Inadequate measures to ensure
that the System Test Engineer is aware of the status
of his system with respect to temporary alterations
while undergoing testing (Inspection Report
No. 50-440/85042).
c.
Severity Level V - Inadequate measures to indicate
jurisdictional status of equipment in the control
room (Inspection Report No. 50-440/85042).
d.
Severity Level IV - Preoperational Test Procedure
TP IP57-P001, " Safety-Related Instrument Air," was
determined to be inadequate for not properly
controlling the sequence of testing (Inspection
Report No. 50-440/85053).
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e.
Severity Level IV - Testing was not accomplished in
accordance with applicable procedure requirements for
TP 1R76-P001, "ECCS Initiation / Loss of Offsite Power,"
TP 1C71-P001, " Reactor Protection System," and TP
1M51-P001, " Combustible Gas Control System" (Inspection
Report No. 50-440/85053).
f.
Severity Level V - Resolutions of failures to meet
acceptance criteria in Preoperational Test Procedures
TP 1G43-P001, " Suppression Pool Makeup (SPMU) System"
and TP 1C71-P002, "RPS Motor Generator Sets" represent
inadequate documentation and evaluation to assure test
requirements had been satisfied (Inspection Report
No. 50-440/85081).
These violations can be categorized into four general areas of
(1) inadequate administrative controls, (2) inadequate documen-
tation and evaluation of failures to meet acceptance criteria,
(3) inadequate test procedures and (4) failure to follow
procedures.
The identified violations are in either random areas or areas
of the test program that have been corrected before the end of
this assessment period, and therefore do not appear to indicate
any significant problems.
As a result of 13 violations identified in the previous 18 month
SALP period, a management meeting was conducted on June 3, 1985,
to discuss NRC concerns.
The licensee was very responsive to
NRC initiatives and implemented aggressive corrective actions
to address those concerns. The licensee exhibited increased
initiative in identifying and implementing self-imposed
corrective actions. The effectiveness of those actions was
evaluated during this assessment period and found to satisfac-
torily remedy the concerns.
Five of the six violations
identified in this SALP period were identified in the first
three months of the period. These were primarily attributable
to causes which actually occurred prior to the management
meeting or prior to complete implementation of the resulting
corrective actions. Therefore, the six violations of this 10
month SALP period represent a substantial reduction in both
frequency and significance from the 13 violations of the
previous 18 month SALP period.
The licensee displayed evidence of prior planning and
assignment of priorities by forming a Management Procedure
Review Team (MPRT) to determine the extent of the problems and
to present recommendations for corrective actions, in that the
MPRT was well staffed technically and received upper management
support. Corporate management was involved with the creation,
_
.
recommendations, and other activities of the MPRT which ensured
adequate management review of site activities. Personnel
appeared to understand and be operating in compliance with
adequately stated policy.
In implementing the MPRT recommendations, the licensee
developed Special Project Plan 1102, " Test Procedure Assurance
Review." This plan ensured preoperational test procedure
adequacy by providing a generally sound review of all
preoperational and selected acceptance test procedures. The
plan's reinforcement of attention to detail to ensure technical
adequacy of test procedures was found to be effective.
At the time of the NRC review, the preoperational test
procedures TP IC71-P001, TP 1C71-P002 and TP IM51-P001 had not
yet received the MPRT additional review, therefore, violation
'
a. does not reflect on the corrective actions. The sequencing
'
problem of Violation d. identified in TP IP57-P001 (a
post-MPRT-reviewed procedure) probably would have been
corrected during performance of the test and was the only
procedure inadequacy identified in a post-MPRT-reviewed
procedure. Generally, the procedure review seemed to have
prevented recurrence of any procedure inadequacies due to
omission of design feature testing. The plan was eventually
effective in preventing failures to follow procedures by
increased supervisory involvement during the evolution and
conduct of test procedures and revisions and additional
training for test personnel.
The failure to fcilow procedures
documented in Violation e. occurred in the first three months
of this assessment period. No recurrences were identified in
the subsequent months and it appears the corrective actions of
additional training finally became ef fective. Violations b.
and c. document failure to meet administrative controls that
occurred before the corrective actions of June 3,1985, became
effective.
There were no subsequent administrative require-
ment violations identified in the following 11 months;
therefore, the corrective actions appear effective. The re-
review of licensee requirements was effective because no
omissions of required testing were identified subsequent to
MPRT review. Generally the licensee was very responsive to NRC
initiatives and the corrective actions took a long time to
manifest their effectiveness only because of the vast amount of
work undertaken by the licensee to ensure preoperational test
program adequacy. Therefore, in that context, the corrective
actions were generally timely and effective.
The licensee generally understood technical issues exhibiting
conservatism in the resolution of approximately 2000 problems
encountered during testing commonly called test exceptions.
I
Violation f. documented only two test exceptions that were
inadequately resolved.
Licensee management adequately resolved
i
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_m
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.
those after citation. Based upon the large sample determined
to be adequate, these are considered isolated occurrences and
represent no significant problem.
Occasional significant construction events attributable to
causes under the licensee's control, have occurred that are
relevant to preoperational testing but they were reported and
analyzed properly.
Staffing, including management, appears adequate.
2.
Conclusions
The licensee is rated Category 2 in this area. This is an
improvement from the previous SALP period rating of Category 3.
The improvement is largely attributable to the effective
management initiatives taken by the licensee following the
June 3,1985, management meeting with the NRC.
3.
Board Recommendations
None.
H.
Startup Testing
1.
Analysi s
Region based inspectors performed three inspections in this
functional area. The inspection effort included overall
startup test program review and startup test procedure review.
There have been no violations identified in this area.
The inspections showed that the overall program is comprehen-
sive and adequate.
In addition, the startup test procedures
are adequate in meeting administrative requirements and regula-
tory commitments and exemplify good technical methodology. The
inspectors feel that overall the procedures for control of
activities were well stated, controlled, and explicit.
The licensee has proved to be responsive to NRC initiatives in
that an additional final review by quality assurance was
provided to ensure correction of some minor procedural problems
and prevent recurrence. All startup test procedures are to be
revised under this modified review process prior to their actual
use. The licensee was not rated in this functional area during
the previous SALP assessment period because of no work being done
in this area.
Inspections in this assessment period have covered
a limited portion of this functional area.
i
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2.
Conclusions
No rating is recommended in this area due to limited licensee
and inspection activity. The licensee was not assessed in this
area during the previous SALP period.
3.
Board Recommendations
None.
I.
Radiological Controls
1.
Analysis
Five preoperational inspections were conducted during the
assessment period. These inspections covered radiation
protection, radwaste, chemistry, confirmatory measurements, and
environmental monitoring. No violations were identified.
The licensee has satisfactorily completed activities essential
to load fuel. Organization, staffing, and training meet FSAR
requirements. Capabilities of staff and technicians were
judged adequate to proceed with fuel load and startup, and the
qualified staff is large enough to provide coverage on all
shifts. The licensee is seeking to retain a qualified
chemistry consultant to assist the Plant Chemist during early
plant operation in accordance with their commitments.
Facilities
and equipment for health physics and chemistry were generally
satisfactory.
Overcrowded office space identified in the previous SALP was
alleviated and now appears adequate.
Laboratory and counting
room instruments are of good quality, adequate to perform the
required analyses, and have been calibrated in accordance with
approved procedures. The licensee established a water
chemistry control program addressing the important elements
l
presented in the BWR Owners Group guidelines with provision for
monitoring and trending important parameters and for suitable
administrative limits. The licensee has agreed to issue a
corporate policy on water chemistry control within six months
after issuance of the fuel load license. The licensee also
completed the preoperational requirements for the Radiological
Environmental Monitoring Program (REMP) and demonstrated
satisfactory capability in performing analyses of radiological
samples. Management involvement in these areas has been
evident during the assessment period.
.
,
, - -
.
Adequate management involvenent and technical issue resolution
has been exhibited by the licensee in assigning priorities for
completing critical preoperational activities and documenting
necessary deferrals. Several activities, not essential for
'
fuel loading, have been deferred with appropriate schedule
priorities. These activities include:
testing and correction
of deviations for the liquid radwaste processing, solid radwaste,
and offgas systems, which were deferred until initial
criticality; operability of the Post Accident High Range
Radiation Monitoring System, which has been deferred to five
percent power; investigation of use of silicone sealant on
certain HVAC systems and representativeness of gaseous effluent
sampling systems, which are scheduled for resolution by the first
refueling outage; work on the Turbine Plant Sampling System
(TPSS), including replacement of extraction pumps and calibration
of dissolved oxygen monitors, which is scheduled for completion
by turbine roll; and completion of a small tool decontamination
and storage facility, tentatively scheduled for mid-1986.
Management responsiveness and resolution of NRC identified
technical issues were adequate during this assessment period.
The licensee's initiation of a program to test silicone
sealants used in HVAC ductwork under postulated accident
environmental conditions is an example of good responsiveness.
Conversely, weaknesses are evident in laboratory Quality
Control (QC) where the program for testing of technician
proficiency with unknowns is limited to analyses required by
technical specifications; not included are sulfate, fluoride,
silica, and copper which are important for chemical control
<
and recommended by the BWR Owners Group. The licensee has
been reluctant to make specific commitments for improvements
in laboratory QC but has indicated a willingness to extend
the scope of the QC program at a later time. The licensee's
policy and plans for a quality assurance audit program for
radiological controls appears adequate.
2.
Conclusions
The licensee is rated Category 2 in this area. This is the
same rating as the previous assessment period.
3.
Board Recommendations
None.
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J.
Fire Protection
1.
Analysis
During this assessment period, two inspections by Region III
based inspectors and their consultants were performed to
determine the status of outstanding fire protection issues
including a continuing assessment of the licensee's fire
protection program implementation and a review of allegations
received by the NRC relative to penetration seals. No
violations or deviations from NRC guidelines or other
commitments were identified during these two inspection visits.
Based on these two regional inspections, it was determined that
the licensee was continuing to make satisfactory progress in
implementing the applicable fire protection requirements and
the fire protection preoperational test program. The outstanding
items remaining open from the initial fire protection team
inspection (Inspection Report 440/85015), discussed during the
last assessment period, were all addressed adequately by the
licensee's staff and the majority closed out in these two
inspection reports.
A review of three allegations concerning penetration seals was
completed. They were closed based on supporting test data and
the technical adequacy of procedures including an in-office
review of certain information provided by the licensee.
Management was found to be sufficiently involved in this
functional area as evident by the licensee's responsiveness in
addressing the inspectors' outstanding items.
Staffing
appeared to be adequate and personnel were found to be
knowledgeable and well trained.
2.
Conclusions
The licensee is rated Category 2 in this area. The licensee
was rated Category 2 in this area during the previous
assessment period.
3.
Board Recommendations
None.
K.
1.
Analysis
Four inspections were conducted during the assessment period to
evaluate the licensee's performance with regard to emergency
preparedness. These included a followup inspection to the
Emergency Preparedness Implementation Appraisal (EPIA) to
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assess the progress in addressing NRC concerns raised as a
result of the EPIA; observation of the annual emergency
preparedness exercise in 1985; an inspection to assess the
actions associated with the activation of the Emergency Plan as
a result of a January 31, 1986, earthquake; and an inspection
of the 1986 annual exercise. No violations or deviations were
identified during the SALP period.
No weaknesses were
identified during the 1985 annual exercise; no additional NRC
concerns were raised during the followup to the EPIA; only two
NRC concerns were tracked as open items as a result of the
licensee's performance in regards to activating their Emergency
Plan due to the earthquake.
The scenario for the 1986 exercise was considered challenging
and difficult, and adequately exercised all aspects of the
Emergency Plan. While three Open Items were identified as a
result of this exercise, the items were considered minor.
In almost all cases, the licensee has been responsive to NRC
concerns by providing viable, sound, and thorough responses in
a timely manner. When resolving weaknesses from a safety
standpoint, the licensee has demonstrated a clear understanding
of the issues involved.
Management involvement in emergency preparedness has been very
strong as evidenced by their participation in the exit meetings
following each inspection, and their timeliness in addressing
WRC concerns.
Staffing of key emergency response positions has been adequate,
with the authorities and responsibilities of personnel well
r
identified.
Knowledge and capability of personnel to carry out
their assigned emergency response duties and responsibilities
was demonstrated during both annual emergency preparedness
exercises and the actual activation of the Emergency Plan due
to the earthquake. The licensee's performance related to these
two items is indicative of an effective training program that
has adequately prepared personnel to carry out their emergency
response assignments.
2.
Conclusions
The licensee is rated Category 1 in this area, and was also
rated a Category 1 in this area in the last SALP period.
3.
Board Recommendations
None.
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L.
Security
1.
Analysis
Four preoperational safeguards inspections were conducted by
regional based inspectors during the assessment period and
one routine safeguard startup inspegtion was i,e! formed
subsequent to the assessment period to determine the licensee's
progress in implementing the security program. The resident
inspectors also made periodic inspections of security activities,
and assessed routine program implementation.
One Severity Level IV violation was identified
subsequent to the assessment period because
portions of the licensee's vital area barriers
were found unsecured (Inspection Report 50-440/86013).
The licenses's immediate actions resolved the issue
and a written response to the violations was not
required.
This violation is not included in Paragraph V.B.1, Table 1,
of this report, but is addressed here because it reflects on
performance during this assessment period.
The licensee's Physical Security Plan, Safeguards Contingency
Plan, and Training and Qualification Plan became effective
on March 18, 1986, upon issuance of their operating license.
Therefore, no violations were cited during the preoperational
security inspections. During the preoperational inspections,
numerous items were identified and were satisfactorily corrected
and/or resolved prior to issuance of the operating license.
The 1fcensee has been very responsive to the concerns identified
by the NRC and extremely aggressive in self-identifying and
correcting problems.
During the preoperational phase in anticipation of initial
activation of the security program needed prior to license
issuance, the licensee requested and received an extensive
security audit conducted by the security managers from nuclear
plants of another large Region III utility which assisted in
establishing priorities for implementation and problem areas.
The licensee's preoperational planning and scheduling program
was aggressive and proved effective, and as a result, all
preoperational inspection findings / concerns were resolved prior
to licensing.
The licensee's senior management appears to have an awareness
of security issues and are effective and responsive to
resolving security issues as demonstrated by the extensive
.
.
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resources devoted to completion of the background screening
program. The senior security personnel represent broad
technical disciplines, have a high degree of expertise, and
have been effective in identifying problem areas and
-
recommending solutions.
Concerns and observations receive the
same exceptionally high level of management attention normally
associated with violations. The security management is
responsive to all findings that can strengthen their program,
rather than concentrating on just minimum compliance required
by the security plan.
The licensee's staffing levels appear adequate to fulfill
security plan commitments. There have been no licensee reports
of Safeguards events and no known events that would require a
report. The licensee is fully aware of the reporting require-
ments and the importance of timely and detailed reports.
The licensee's training and qualification program is well
defined and implemented with dedicated resources which make a
positive contribution to overall implementation of the security
program. Understanding of and adherence to procedures resulted
in few personnel errors during the rating period.
The site Quality Assurance (QA) Department, which lacked
experience in the security field, will have to demonstrate
through involvement in site security activities, that they can
effectively audit the security program, and identify security
weaknesses.
In summary, the licensee's security staff has been effective in
the planning and implementation of the security program.
The
security staffing is adequate and departmental support for the
security program has been effective.
2.
Conclusions
The licensee is rated a Category 1 in this area. The licensee
was rated Category 2 in this area during the previous
assessment period.
3.
Board Recommendations
None.
1
.
M.
Maintenance / Modifications
1.
Analysis
The operational maintenance program was reviewed in detail in
portions of 10 inspections during this assessment period.
These inspections included the review of related IE Circulars
and Bulletins, maintenance procedures, staffing, work control,
work package implementation, and the overall effectiveness of
the maintenance program. One violation was identified in
this area as follows:
Severity Level IV - Work Order No. 86-2829 for
filling and venting the suppression pool level
instruments was not prepared, controlled, or
accomplished in accordance with instructions and
administrative procedures in that uncontrolled
non as-built drawings were being used to perform
safety related work; work was performed out of
required sequence; incorrect instructions were
not properly corrected; independent restoration
verifications were not properly accomplished; and
the work order did not include the purpose, as
required (Inspection Report 50-440/86006). Another
example of this violation is identified in Section P.
This violation identified weaknesses in Instrumentation and
Control (I&C) implementation of the maintenance program.
In
addition, a major undertaking by the licensee to provide
controlled "as-built" drawings of instrument lines occurred as
a result of the identification of the lack of "as-built"
drawings used to perform the I&C Work Order. The licensee took
prompt corrective actions to assure that personnel were
counseled on the importance of following established
procedures. A site-wide compliance training program was also
established.
The licensee's program for implementation of maintenance
activities was found to be generally adequate and amply
staffed. Maintenance personnel were found to meet FSAR and
ANSI qualification requirements but did not always meet the
requirements specified by the licensee's more conservative
administrative procedures. The licensee has committed to
have these personnel qualified to their own program by
December 31, 1986.
Region III has found this implementation
schedule to be acceptable.
Management was four.d to be committed to improving their
established program as deficiencies are identified during
actual implementation. This was apparent when, during a recent
NRC review of their maintenance program, three weaknesses in
the licensee's program were brought to their attention, and
.
the inspector was shown evidence that the weaknesses had been
previously self-identified and procedural changes had already
been prepared and were being reviewed to correct the
weaknesses. Utilizing a state-of-the-art ccmputerized
information storage and scheduling system, the licensee's
periodic maintenance (PM) program appeared to adequately
identify and direct the conduct of safety related PM
activities.
As described above, management appears to be adequately
involved in assuring quality.
Their approach to resolving
technical problems, once identified, appears to be
comprehensive, and their responsiveness to NRC identified
concerns were found to generally be prompt and thorough.
However, weaknesses in the implementation of maintenance
activities as identified in the above violation, and licensee
self-identified maintenance discrepancies have required, and
will continue to require management attention and involvement.
2.
Conclusions
The licensee is rated Category 2 in this area. The licensee
was not assessed in this area in the previous SALP period.
3.
Board Recommendation
None.
N.
Surveillance and Inservice Testing
1.
Analysis
The examination of this functional area included portions of
twelve inspections by Region III inspectors. The inspections
included the review of Local Leak Rate Testing (LLRT),
applicable IE Bulletins, numerous surveillance instructions
(as part of the NRC's preoperational phase inspection program),
observations of surveillance test performance, and review of
programmatic aspects of surveillance testing including the
computerized scheduling system (r2petitive task program). No
violations of NRC requirements or deviations from commitments
were identified in this functional area.
During the review of LLRTs, procedures were generally
well-defined and accurate. Technical issues raised as a result
of an earlier Integrated Leak Rate Test inspection (conducted
during the previous SALP period) were found to have been
resolved satisfactorily. Management's responsiveness to
inspector identified concerns was excellent and staffing was
found to be well qualified and adequate for LLRT activities.
__,
.
Review of surveillance instructions (SVIs) revealed that, in
general, they were prepared in accordance with administrative
procedures, technically adequate, and met the requirements of
the initiating documents (i.e., Technical Specifications, FSAR,
etc.).
During the licensee's preparation of the SVIs, several
program actions were initiated by management to ensure quality
and technical adequacy. These actions included initial
development, SVI walkdown/dryrun, rewrite, and run for credit.
By performing these functions, many of the minor errors
associated with the development of this massive SVI program
were identified and corrected prior to the "run for credit."
However, problems were encountered during the "run for credit"
phase that could have been avoided had there been a trial run
of the SVIs prior to their run for credit. These problems,
which required initiation of procedure changes, may have resulted
in some plant delays, but did not have any direct safety
implications.
A sample review of surveillance procedures required by Technical
Specifications was conducted and found, in general, to be in
agreement with the Technical Specifications. However, when
reviewing the licensee's program for ensuring that non-routine
surveillances were conducted as required by Technical
Specifications, it was discovered that the SVI for determining
,
the shutdown margin prior to or during the first startup after
'
each refueling, was not included in their " repetitive task"
program or any other written program. Subsequently, the
licensee performed a review of all non-routine surveillances
specified in the Technical Specifications to ensure that they
were included in their operating procedures. No other examples
of SVIs were found t.o be missing from the licensee's operating
procedures.
During this assessment period, some SVI performance observations
were conducted which included SVIs associated with the fueling
activities. These observations determined that the SVIs were
being conducted as specified by administrative procedures and
those performing the work were knowledgeable and followed the
instructions as required.
Management's responsiveness to and resolution of NRC identified
issues were adequate during this assessment period. The
licensee's staff appeared to be adequate, knowledgeable and
well trained for both the preparation and implementation of the
SVI program.
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2.
Conclusion
The licensee is rated a Category 2 in this area. The licensee
was not assessed in this area during the previous SALP period.
3.
Board Recommendations
None.
O.
Fueling
1.
Analysis
The licensee received an operating license on March 18, 1986,
and fuel loading commenced on March 21, 1986.
Fueling was
completed on April 24, 1986, approximately two weeks behind
schedule.
Region III inspectors provided 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> / day coverage
of the initial fueling process and performed extensive
inspection activities associated with Technical Specification
compliance, nuclear instrumentation calibration, core physics
testing, shift turnover activities, refueling floor access
control, and other associated fuel loading activities. No
violations of regulatory requirements or deviations from
commitments were identified.
Fuel loading activities were suspended on several occasions
due to the refueling machine main hoist drive motor supply
breaker tripping on overcurrent on numerous occasions and
spurious high neutron flux signals due to electrically
induced " noise" on the intermediate range neutron flux
monitoring (IRM) system which resulted in trips of the reactor
protection system which were properly reported.
The licensee's
actions to repair the hoist included, among others, the
replacement of the supply breaker, fuses, power supply, and
control circuitry components.
Initially, licensee corrective
actions to resolve this equipment problem were slow to be
l
formulated and not well organized.
Late in the fueling process
l
it was determined that a silicon controlled rectifier (SCR) in
l
the power supply to the main hoist was the cause of the tr.ps.
l
This SCR had been previously replaced, and therefore, not
suspect.
Following re-replacement of the defective SCR, the
main hoist drive operated normally.
The refueling equipment
is non-safety related and the associated problem did not pose
a safety concern. The IRM noise problem was attributed to
i
grounding and/or cabling deficiencies which were identified
i
by exhaustive troubleshooting and corrective maintenance
t
activities.
l
Inspector observations indicated fuel loading activities were
well coordinated and that licensee personnel proceeded in a
i
cautious and deliberate manner.
I
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l
l
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.
Management was actively involved in assuring quality and
,
adequate but sometimes slow resolution of technical issues
during fuel loading activities. Management ensured that no
undue scheduling pressure, which may have resulted in opera-
,
tional/ technical specification errors, was placed on the
<
operators during this initial post license activity. There
were sufficient numbers of operators on duty and they appeared
to be well trained and performed in a professional manner
'
commensurate with the positions they held.
2.
Conclusions
The licensee is rated Category 2 in this area. The licensee
was not assessed in this area during the previous SALP period.
3.
Board Recommendations
None.
,
P.
Operational Readiness / Plant Operations
1.
Analysis
'
Inspection of this functional area during the assessment period
consisted of portions of ten inspections and one inspection
subsequent to the assessment period by the resident and project
inspection staff. These inspections included examinations of
(1) normal operating procedures; (2) abnormal operating proce-
dures; (3) emergency operating procedures; (4) annunciator
i
response procedures; (5) system status control; (6) operating
logs and records; (7) control of work activities; (8) rountine.
operations; and, (9) reportable events.
One violation and one example from a violation contained in
section M were identified, as follows:
a.
Severity Level IV (one of two examples) - System Operating
Instructions (SOIs) were found to be technically inadequate.
j
This example is part of a violation identified in
Section M (Inspection Report 50-440/86006).
b.
Severity Level V - Inadequate review of a tag-out prior
to authorization and attempted performance of associated
work (Inspection Report 50-440/86008).
Subsequent to the assessment period, we issued Report
No. 50-440/86011, which identified three additional violations
,
as set forth below. While these violations are not included
.
in Paragraph V.B.1, Table 1 of this report, they are addressed
here because they reflect on performance during this assessment
period.
1
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a.
Severity Level IV - Failure to suspend containment /drywell
purge with inoperable plant vent radiation monitor
(Inspection Report 50-440/86011).
.
b.
Severity Level'IV - Two examples of failure to maintain
containment integrity during core alterations (Inspection
Report 50-440/86011).
c.
Severity Level IV - Failure to take compensatory actions
for inoperable carbon dioxide fire suppression system
(Inspection Report 50-440/86011).
Licensee management has been actively involved in adequately
resolving technical issues and assuring quality. As a result
of the violation concerning SOIs, the licensee proposed a
program of detailed re review to assure technical adequacy.
The licensee committed to conducting re-reviews and making
necessary corrections prior to the use of each SOI under the
operating license.
Followup inspections of S0Is subjected to
the re-review prior to fuel load and initial criticality
determined that the licensee's corrective actions were
responsive and effective in resolving the identified concern.
The other four violations all resulted from personnel errors,
including failures to comply with established administrative
controls. While these violations were licensee identified, and
corrective actions were taken to address each occurrence, they
collectively suggested a need for further evaluation to
determine whether or not they resulted from a lack of
understanding of administrative controls, excessive workloads,
or inattention to detail by operating personnel. These matters
were discussed with the licensee in a management meeting
conducted subsequent to the assessment period on June 5, 1986.
Licensee management personnel exhibited an understanding of the
significance of these items and informed NRC management that
additional evaluations of the events had resulted in changes to
personnel work assignments. The licensee also indicated that
future performance would be closely monitored such that any
need for additional actions would be promptly identified and
acted upon.
Licensee management, supervisory and non-supervisory operating
personnel have exhibited an understanding of the high level of
performance which must be achieved and maintained in this
functional area. Throughout the approach to operating license
issuance the licensee exhibited a good deal of caution in
assuring the readiness of personnel, equipment, procedures, and
programs for plant operations. Concerns identified by licensee
self-assessment as well as NRC inspection personnel were
responded to in a thorough and timely manner. Following
operating license issuance, the licensee continued with this
same caution and responsiveness to identified concerns.
. _.
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A single programmatic concern remained at the close of the
assessment period. Based upon inspector review of the
licensee's response to a number of technical problems which
arose following operating license issuance, it appeared that
operating management personnel had neither demanded nor
received rigorous and coordinated technical support.
Subse-
quent to the assessment period the licensee made a number
of personnel and organizational changes intended, in part, to
address this identified weakness.
Notwithstanding the identified violations and concern, the
conduct of day-to-day activities under the operating license
has been generally found to be well controlled by knowledgeable
operating personnel and in accordance with technically adequate
procedures.
2.
Conclusions
The licensee is rated Category 2 in this area. The licensee
was rated Category 2 in the Operational Readiness assessment
area during the last SALP period but was not assessed in the
Plant Operations area.
3.
Board Recommendations
None.
Q.
Training and Qualification Effectiveness
1.
Analysis
Evaluations of the licensee's training and qualification
effectiveness has been and is an ongoing activity by Region III
inspectors in all areas of the plant's construction,
preoperational, and operational phases.
No violations were
identified in this assessment area.
Specific training programs reviewed included observations of
the general employee training program, the radiological
controls training course, and portions of maintenance and
operating personnel training programs. These reviews indicated
that the instructors followed prescribed training plans and met
the training objectives.
In addition, the training courses,
attended by inspectors, appeared to adequately cover the subject
matter in sufficient detail to ensure co-the-job training
requirements were being met.
'
.
During an inspection, a deficiency was identified concerning
the untimely distribution and training for temporary changes to
plant procedures. Procedure changes were being issued without
providing training to plant personnel. To resolve this issue,
the licensee changed applicable procedures to require training
of appropriate personnel when a temporary change to a Plant
Administrative Procedure is issued.
During the review of FSAR Chapter 13 " Conduct of Operations,"
specifically, the licensee's staff qualifications and training,
several discrepancies were identified where the qualifications
of incumbent operational staff did not agree with the
requirements delineated in ANSI N18.1 and/or Regulatory Guide 1.8.
To resolve these discrepancies, the licensee undertook a
comprehensive review of their operational staff qualifications
and requirements and subsequently amended (Amendment 21) the
FSAR to update and clarify the plant organization.
In
addition, the licensee replaced one individual with one that
met qualification requirements and provided additional
information for the other individuals that had discrepant
qualifications. The amendment and additional information
resolved the discrepancies.
As identified above, management is very responsive to NRC
identified issues and generally resolves them with comprehensive
corrective actions. When deficiencies are either NRC or self-
identified in various areas of the plant organization, enhanced
training is a method often incorporated into their corrective
actions to ensure that plant personnel are informed of the
deficiencies and management's planned and implemented
resolutions. Generally, plant staff training and qualifications
have been found to be above average; however, due to the change
from the construction and preoperational phases to the plant
operattsnal phase, increased management attention to training
is warranted to ensure that all personnel are kept abreast of
plant procedures that are undergoing fine-tuning as a result of
implementation experience.
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The licensee is currently planning to achieve full INPO
accreditation of their training program by October 1987. This
is an approximate one year slip from their previous estimate of
October 1986. However, if accomplished as currently scheduled,
this will comply with industry commitments.
2.
Conclusions
The licensee is rated a Category 2 in this area. The licensee
was not assessed in this area in the previous SALP period.
3.
Board Recommendations
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None.
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V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
For the first nine months of the assessment period, Perry Unit I was
considered to be in the construction /preoperational testing phases.
On March 18, 1986, a low power operating license was issued by the
NRC.
Initial fuel loading began on March 21, 1986, and was completed
on April 24, 1986.
Fueling progressed slower than anticipated due
to recurring problems with the re-fueling machine and associated fuel
bundle lifting hoist.
During and subsequent to fuel loading, a
number of operational events occurred, including some which required
NRC notifications per 10 CFR 50.72 and 50.73. These events have
required and are requiring extensive licensee investigation as to
their causes and development of adequate corrective actions.
Initial
criticality occurred on June 6, 1986. For the remainder of the time
prior to issuance of this report, the unit has operated at less than
5% power with the low power testing portion of the startup program
continuing.
B.
Inspection Activities
1.
Inspection Data
Facility Name:
Perry Nuclear Power Plant, Unit 1
Docket No. 50-440
Inspections:
No. 50-440/85016; No. 50-440/85027;
No. 50-440/85031; No. 50-440/85034;
No. 50-440/85040 through No. 50-440/85042;
No. 50-440/85044; No. 50-440/85047
through No. 50-440/85051; No. 50-440/85053
through No. 50-440/85085; No. 50-440/85087
through No. 50-440/85090; No. 50-440/86001;
50-440/86002; No. 50-440/86004 through
No. 50-440/86010; No. 50-440/86011* and
No. 50-440/86013*.
- Inspections performed subsequent to this assessment period
but included in the assessment.
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TABLE 1
ENFORCEMENT ACTIVITY
This table includes those violations issued during the
assessment period. Not iacluded are the violations
discussed in Paragraphs IV.L and IV.P which occurred
after the assessment period.
No. of Violations in Each
Severity Level
Functional Areas
I
II
III
IV
V
DEV
A.
Containment and other
Safety-Related Structures
B.
Piping System and Supports
C.
Heating, Ventilating, and
Air-conditioning
D.
Electrical Power and
Instrument and Control
Systems
E.
Quality Programs and
Administrative Controls
Affecting Quality
F.
Licensing Activities
G.
Preoperational Testing
2
H.
Startup Testing
I.
Radiological Controls
J.
Fire Protection
K.
L.
Security
M.
Maintenance
N.
Surveillance
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Functional Areas
I
II
III
IV
V
DEV
0.
Fueling
P.
Operational Readiness /
Plant Operations
Q.
Training and Training
Effectiveness
TOTALS
3
2.
Inspection Summary
Throughout the assessment period, NRC Region III conducted
inspections to assess the readiness of Perry Unit 1 for power
operations.
Included were reviews of the plant fire protection
program, procedures, Technical Specifications, Final Safety
Analysis Report (FSAR) and as-built configuration comparison,
adequacy of operating shifts, preoperational testing, startup
testing, and adequacy of management and engineering support
activities.
In addition, an Augmented Investigation Team and
support team walkdown inspection was conducted to assess the
effect of the January 31, 1986, earthquake.
C.
Allegation Review
Region III received 18 allegations during the assessment period that
resulted in inspections by resident and/or region based inspectors.
None of the findings involved significant safety issues.
D.
Escalated Enforcement Action
None.
E.
Management Conferences Held During the Appraisal Period
1.
September 12, 1985, Perry plant site - Meeting to discuss the
NRC fuel load requirements.
2.
September 26, 1985, Perry plant site - Meeting to discuss the
SALP 5 results.
3.
October 11, 1985, Perry plant site - Meeting to discuss items
required for fuel load.
4.
November 6, 1985, Perry plant site - Meeting to discuss
Preoperational Test Program problems and items required for
fuel load.
5.
December 3,1985, Perry plant site - Meeting to discuss the
status of items required for fuel load.
.
6.
December 17, 1985, NRC offices, Bethesda, Maryland - Meeting to
determine readiness of Perry Unit 1 for operating license.
7.
February.11, 1986, Perry plant site - Meeting to discuss review
of the January 31, 1986, earthquake and operational readiness
to load fuei.
F.
Confirmatory Action Letters
On January 31, 1986, Region III issued a Confirmatory Action
Letter (CAL-RIII-86-01) to document an agreement with the. licensee
for them to maintain all affected equipment in the "as found"
condition until the NRC Augmented Investigation Team (AIT) could
examine any evidence.which would be needed to evaluate the effects
of the January 31, 1986, earthquake that occurred near' Perry.
Licensee's cooperation with the NRC in response to the earthquake
event and their own immediate and subsequent followup of the event
were found to be excellent. Their response to the CAL provided the
NRC with valuable data that enabled the staff to better evaluate
the impact of the earthquake on the plant.
G.
Review of Licensee Event Reports, Construction Deficiency Reports,
and 10 CFR 21 Reports Submitted by the Licensee
1.
10 CFR 50.55(e) Reports (Construction Deficiency Reports)
During this SALP period, three 10 CFR 50.55(e) items were
reported by the licensee. The formal reports were timely,
well stated, and complete.
Corrective actions were promptly
initiated and all were documented as closed.
2.
10 CFR 21 Reports
There have been five 10 CFR 21 reports received concerning the
Perry plant. All but one of these reports have been reviewed
~
by the licensee and no modifications to the plant were necessary.
Only one, concerning Kaman high voltage power supply in the post
accident monitoring system, appears to have safety significance,
and it must be resolved prior to exceeding 5% power.
3.
Licensee Event Reports (LERs)
.
The licensee received their license on March 18, 1986, which
!
requires them to submit LERs to the NRC in accordance with
!
10 CFR 50.73. Subsequently, three LERs were received from
'
the licensee by closure of the SALP assessment period. The
i
reports were found to be complete, well written, and followup /
i
corrective actions were generally adequate. The events were
j
found to be primarily caused by hardware and/or design problems.
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H.
Licensing Activities
1.
NRR/ Licensee Meetings
November 12, 1985 -
NRC Management visit to Perry plant
site to discuss readiness for
licensing.
December 17, 1985 -
NRC/CEI meeting in Bethesda to discuss
Perry I readiness for licensing.
February 11, 1986 -
NRC visit to plant site during which
CEI presented earthquake findings -
plant readiness for licer. sing.
March 12/13, 1986 -
NRC/CEI presented details of
evaluations of findings on
January 31, 1986, earthquake.
2.
Commission Meetings
None.
3.
FSAR Amendments
July 19, 1985
October 4, 1985
November 20, 1985
November 22, 1985
December 17, 1985
4.
NRR Issuance of SER Supplements
November 20, 1985
NRC issued SER Supplement No. 7
January 15, 1986
NRC issued SER Supplement No. 8
March 4, 1986
NRC issued SER Supplement No. 9
5.
Other Activities
July 17, 1985
NRC Commissioner Asselstine toured
plant.
September 3, 1985
ASLB concluded partial initial
decision on Emergency Planning,
Hydrogen Control, and TDI Diesel
Generator Issue.
.
September 20, 1985
NRC accepts CEI schedule for meeting
the Hydrogen Control Rule - 10 CFR 50.44(3)(c)(vii)(A).
October 29, 1985
CEI requested extension of CPPR-148 to
December 21, 1985.
NRC Chairman Palladino toured plant.
October 31, 1985
NRC transmitted the draft low power
operating license for Perry 1 to CEI
for comment.
November 13, 1985
NRC Commissioner Zech toured plant.
November 19, 1985
NRC issued final draft of Perry 1
technical specifications for CEI
certification.
November 29, 1985
CEI requested extension of CPPR-148 to
January 31, 1986.
December 27, 1985
CEI requested extension of CPPR-148 to
March 3, 1986.
January 30, 1986
NRC Commissioner Bernthal toured
plant.
January 31, 1986
Magnitude 5.0 earthquake occurs near
Perry plant site. As a result of the
earthquake, a Confirmatory Action
Letter (CAL) 86-01 was issued.
CEI requested extension of CPPR-148 to
April 15,1986.
February 6,1986
Board Notification 86-03 issued
regarding Perry earthquake.
I
February 12/13, 1986
NRC/CEI briefing of ACRS on
preliminary findings regarding the
January 31, 1986, earthquake.
l
March 10, 1986
CEI formally certified Perry 1
technical specifications.
March 14, 1986
CEI requested extension of CPPR-148 to
May 15, 1986.
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March 17, 1986
ACRS report to Chairman NRC on NRC
findings and confirmatory action items
regarding the January 31, 1986,
,
March 18, 1986
NRC issued a low power operating
license for Perry 1.
March 20, 1986
ASLAB ordered exploratory hearings
on seismic event.
March 21, 1986
Fuel load commenced.
April 15, 1986
Full Scale Emergency Plan Exercise was
conducted.
April 18, 1986
Commission Order vacated ASLAB Order
cancelling exploratory hearings.
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April 24, 1986
Fuel load complete.
June 6, 1986
Initial Criticality achieved.
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