IR 05000458/1987008

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SALP Rept 50-458/87-08 for Feb 1986 - Mar 1987
ML20214W327
Person / Time
Site: River Bend Entergy icon.png
Issue date: 06/09/1987
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20214W322 List:
References
50-458-87-08, 50-458-87-8, NUDOCS 8706150211
Download: ML20214W327 (40)


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 ~SALP BOARD REPORT U.S. NUCLEAR REGULATORY COMMISSION REGION-IV

, SYSTEMATIC ASSESSMENT'0F LICENSEE PERFORMANCE

'NRC Inspection Report 50-_458/87-08 Gulf States Utilities River Bend Station February 1, 1986, through March 31, 1987 y
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, 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. The SALP program is supplemental to the normal regulatory processes used to ensure compliance with NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operatio An NRC SALP Board, composed of the staff members listed below, met on May 7, 1987, to review the collection of performance observations and data and to assess licensee 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 repor This report is the SALP Board's assessment of the licensee's safety performance at River Bend Station for the period February 1, 1986, through March 31, 198 SALP Board for River Bend Station: E. H. Johnson, Director, Division of Reactor Safety and Projects, RIV R. L. Bangart, Director, Division of Radiation Safety and Safeguards, RIV J. A. Calvo, Director, Project Directorate IV, NRR J. E. Gagliardo, Chief, Reactor Projects Branch, RIV J. P. Jaudon, Chief, Project Section A, RIV S. Stern, Project Manager, NRR D. D. Chamberlain, Senior Resident Inspector, RIV Other persorr.5; who participated in all or part of the SALP Board were: W. C. Scidle, Chief, Technical Support Staff, RIV W. R. Bennett, Project Engineer, Project Section A, RIV W. B. Jones, Resident Inspector, RIV D. H. Moran, Project Engineer, NRR B. Murray, Chief, Facilities Radiological Protection Section, RIV J. A. Kelly, Senior Physical Security Specialist, RIV J. R. Boardman, Reactor Inspector, RIV II. Criteria t Licensee performance was assessed in 11 functional area Functional t areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little i or no licensee activities or lack of meaningful observation Special l areas may be added to highlight significant observation One or more of the following evaluation criteria were used to assess each , functional area: l Management involvement and control in assuring quality.

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   -2 Approach to the resolution of technical issues from a safety standpoin Responsiveness to NRC initiative Enforcement histor Operational events (including response to, analyses of, and corrective actions for). Staffing (including management).

The SALP Board is not, however, limited to these criteria, and others may have been used where appropriat Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie The definitions of these performance categories are: Category 1: Reduced NRC attention may be appropriate. Licensee 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 quality is being achieve Category 2: NRC attention should be maintained at normal level 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 operational safety and construction quality is being achieve Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction quality is being achieve III. Summary of Results The SALP Board concluded that the licensee's most significant strength was the continuing involvement of senior management in the operation of the facilit This was very evident in areas where problems had surface The licensee generally had moved descisively to identify root causes of problems and to penetrate issues for generic implications. The one area in which this decisive management style did not appear to produce quick results was security. The apparent problem in security was not specifically with the security staff, which appeared to be a competent and professional organization, but lay with the cooperation of other departments in implementing security. The strength demonstrated in operations, quality programs, and training are noteworthy. The strong

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   -3-commitment to training was evident, and this is probably related to the excellent performance of the operations staff. In quality programs the QA organization has been very effective. Especially noteworthy were the audit and quality surveillance programs. The licensee's condition report system for documenting problem areas, performing root cause analysis, and causing corrective action is considered to be a significant strengt Although the engineering organization experienced difficulty in assuming responsibility for the design control program from the architect engineer, management involvement was evident. The reorganization of engineering and the establishment of task priorities were manifestations of this involvement. Additionally, the turnover in engineering personnel was a concern. Although maintenance was rated as a Category 2, a strong and positive trend was note The SALP Board concluded that the licensee oversight of contractor activities in the fire protection area had been weak outside of this SALP period. This was not detected by the licensee until this assessment perio The licensee's performance is sumarized in the table below, along with the performance categories from the previous SALP evaluation perio Previous  Present Performance Category Performance Category Functional  (1/1/85 to 1/31/86) (2/1/86 to 3/31/87)

A.- Plant,0perations 2 1 Radiological Controls 2 2 Maintenance 2 2 Surveillance 2 2 Fire Protection 1 2 Emergency Preparedness 2 2 Security 2 2 ' Outages Not Assessed Not Assessed Quality Programs and 2 1 Administrative Controls Affecting Quality Licensing Activities 2 2 ! Training and Qualification 2 1 l Effectiveness i

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  -4-Thirty nine NRC inspections were conducted during this SALP evaluation period, involving a total of 4713 direct inspection manhour Overall plant availability for the SALP period was 61.5 percen Following the outage completion on November 29, 1986, River Bend achieved a plant availability of 90.7 percent and a capacity factor of 87.8 percen IV. Performance Analysis Plant Operations Analysis The assessment of this area consists chiefly of the activities of the licensee's operational staff (e.g., licensed operators, shift technical advisors, and auxiliary operators). It is intended to be limited to operating activities such as: plant startup, power operation, plant shutdown, and system lineup Thus, it includes activities such as reading and logging plant conditions, responding to off-normal conditions, manipulating the reactor and auxiliary controls, plant-wide housekeeping, and control room professionalis This area has been inspecteri on a continuing basis by the NRC resident inspectors and on several occasions by NRC regional inspectors. Specific areas inspected included operational safety verifications, safety system walkdowns, review of licensee event reports (LERs), followup on significant events / problems, review of licensee plans for coping with strikes, and review of emergency operating procedure Managenent involvement in assuring quality was evident in this functional area. One violation was attributed to this functional area, and while it indicated some additional management oversight was needed, thorough corrective action was initiated to resolve the problem. No pervasive breakdown in quality was indicated by the one violation. Several LERs were issued by the licensee in this functional area. The majority were because of equipment problems during startup and shakedown of balance of plant (B0P) equipment. These B0P equipment problems appear indicative of a boiling water reactor (BWR)

startup because B0P equipment cannot be fully tested prior to fuel load as can be done during hot functional testing of a pressurized water reactor. The equipment problems identified were aggressively solved by licensee management and staff as indicated by few repeat problems. All of the equipment-related operational events were handled well by operations personnel, which indicates an experienced, well trained and professional staff. The few personnel and procedure-related events were

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  -5-promptly and aggressively addressed by licensee management and did not appear to indicate any pervasive quality breakdow The operational staffing, including management, is an area of strength, in that, positions and responsibilities are well defined, vacant key positions are filled on a priority basis, experience levels are high, and staffing levels have been maintaine The general conduct of operations was observed to be well coordinated and efficient and good control room professionalism was evident. During plant tours, the plant wide housekeeping was observed to be goo While management involvement in this functional area was considered very strong, two specific areas are deemed to require continuing aggressive management oversight. These areas are:

Continued emphasis to clear local and control room alarm The licensee has made significant progress in clearing alarms and adding reflash capability to alarms that remain lighted during normal plant operation, but there are still several alarms which may require design changes to correc Continued emphasis to assure that piping and instrument drawings (P& ids) and other operator aids are accurate references for operating personne . Conclusions The overall assessment of this area indicated a strong plant operations program at River Bend Station. The licensee's approach to the resolution of technical issues from a safety standpoint indicated a clear understanding of issues, routine conservatism, technically sound approaches, and timely resolutions. The licensee's responsiveness to NRC initiatives was also strong with timely and acceptable resolutions. The licensee has been very effective in identifying and solving , problems associated with startup and initial operation of a new L boiling water reactor plant. The experience level and effective training of operations personnel is deemed to be a major ' contributor to the strong operations progra The licensee is considered to be in Performance Category 1 in this functional area.

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  -6- Board Recommendations Recommended NRC Actions The NRC inspection effort in this functional area can be limited to the minimum progra Recommended Licensee Actions The licensee should continue strong management attention in this area in order to maintain a high level of performanc Management oversight in areas which require long term solutions (e.g., clearing control room / local alarms and assuring P& ids and other operator aids are accurate references f or control room personnel) should also be continue B. Radiological Controls Analysis Five inspections in the radiological controls area were performed during the assessment period by regional-based radiation specialist inspectors. These inspections included the following specific areas: occupational radiation safety, radioactive waste management, transportation of radioactive materials, water chemistry / radiochemistry and confirmatory measurements, and radiological environmental monitoring. Three violations and one deviation were identified: Occupational Radiation Safety This area was inspected twice during the assessment perio These inspections included one inspection during routine operations and one inspection during the licensee's first major maintenance outage. Concerns were identified regarding the lack of an effective ALARA program. The licensee took action to resolve these concerns.

l ' The licensee had experienced a large turnover among the health physics staff during the early part of the assessment period. This appears to have stabilized during the last 4 months of the appraisal period. The licensee has placed less reliance on contractor health physics technicians to supplement the permanent plant staff by reducing from 25 to 11 the number of contractor technician The exposure for 1986 was 83 person-rem as compared to an expected BWR national average of about 700 person-rem;

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 -7-however, there was not a refueling outage conducted during this perio The licensee has established a well defined program for general employee training, radiation worker training, and training for the health physics staf The health physics staff exhibits the necessary qualifications and levels of experience. Management oversight was evident by the performance of comprehensive audits / reviews. The audit / review teams have included a team member with experience in radiation protection matter No significant problems were identified in the areas of internal and external exposure controls, control of radioactive materials and contamination, and surveys and posting. The licensee's responsiveness to NRC initiatives has been timely and the resolution of issues has been based on technically sound j .gemen One violation was identified in this assessment perio Procedures are well written and implemente b. Radwaste Management This area was not inspected during the assessment perio c. Radiological Effluent Control and Monitoring The confirmatory measurements and radiochemistry programs were inspected once during the assessment period. One violation and one unresolved item were identified. This inspection included an onsite radiochemistry and confirmatory measurement of gaseous and liquid samples with the Region IV mobile laboratory. The results of these measurements indicated 96 percent agreement. These results showed a marked improvement from the previous measurement of 82 percent agreement and were above the expected industry average of 90 percen No problems were identified concerning management oversight, resolution of technical issues, and responsiveness to NRC initiatives. The chemistry / radiochemistry staff and contractor supplied technicians consist of well qualified and experienced personne The staff has experienced approximately a 25 percent turnover during the assessment period. The training program for chemistry / radiochemistry personnel had not been fully implemented. Procedures with the exception of training and surveillance concerning the post-accident sampling system (PASS) were adequat . .   . - -- - - . _ .

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   -8-The radiological environmental monitoring program was inspected once during the assessment period. No violations or deviations were identified. The licensee has implemented a well-managed, comprehensive program. The program is considered adequate in the areas of management oversight, staffing, training and qualifications, procedures, resolution of technical issues, responsiveness to NRC initiatives, reports and QA audits. All previous NRC identified concerns for this area have been resolve Transportation / Solid Radwaste This area was inspected once during the assessment perio ~

One violation and one deviation were identified. The violation indicated a programatic breakdown in the solid , radioactive waste quality control _ progra This program ~ area is staffed with qualified personne Personnel turnover has been low for this area. The licensee's responsiveness to NRC initiatives and resolution of technical issues have been technically sound and thorough.

Water Chemistry This area was inspected once during the assessment period in conjunction with the radiochemistry program. The inspection included water chemistry confirmatory measurements analyses on metal ions, cations, and anion . Conclusions Steady improvement was noted in the radiological controls, confirmatory measurements, water chemistry, and environmental monitoring area The PASS program exhibited weaknesses in the areas of surveillance and training.

< The licensee is considered to be Performance Category 2 in this are . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection progra ._ _

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o , _ Recommended Licensee Actions Management attention is needed to ensure that a proper QA program is implemented for the radwaste solidification proces Management should also review the PASS training and surveillance program C. Maintenance Analysis The assessment of this area includes all licensee and contractor activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical system This area has been inspected on a continuing basis by the NRC resident inspectors and on one occasion with a NRC regional tea The team inspection found that the licensee had a strong and aggressive maintenance program and that the licensee appeared to be striving to meet both the literal requirements of NRC Generic Letter 83-28 and the implied spirit. Although additional licensee effort is required to develop fully a preventative maintenance program which incorporates all available vendor technical and industry experience, it was apparent that the licensee was moving strongly in this direction. The team inspection also identified that licensee staffing was strong throughout the maintenance organization and that an excellent attitude prevaile The enforcement history for this functional area includes four violations with one problem area (two violations cited) involving escalated enforcement actio The escalated enforcement action did not result in a civil penalty because of prompt and extensive corrective action taken by the licensee and because there was no previous history of serious problems in this functional are During this assessment period, the licensee has taken effective measures to reduce the overall maintenance backlog of significant items. Additional aggressive management oversight will be required to further reduce the backlog of low priority maintenance item The licensee has taken some steps in this area toward the end of the SALP period by removing individual systems from service and working all related corrective and preventative maintenance items. This program may prove to be one effective way to address the low priority maintenance backlo __ __ __

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  -10-Aggressive management involvement in this functional area is evident when major problems are identified, but additional management oversight is indicated for routine. program implementation. _ The licensee has recently placed maintenance personnel on the same work schedule as operations personne The licensee believes that this will provide more effective coverage by maintenance and a reduced daily work load for operations. The effectiveness of this work schedule has not been assessed by the NR . Conclusions The overall assessment of this area indicated a strong maintenance program at River Bend Station with.some significant problems occurring early in the assessment period. . Although these problems have not been pervasive, the need for additional aggressive management oversight is indicated. Some recent licensee actions have not been in place long enough to determine how effective they will be, but it does indicate that management-is taking steps to improve performanc The licensee's approach to the resolution of technical issues from a safety standpoint indicates an understanding of issues with routine conservatism and generally sound and timely resolution of issues. The licensee responsiveness to NRC initiatives is considered strong in this' functional are The lice ~nsee is considered to be in Performance Category 2 in this functional area with an increasing tren . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program. Licensee staffing and maintenance backlog should be monitored for early indication of problem area Recommended Licensee Actions The licensee should continue management oversight of routine program activities to assure the current upward trend is maintained. The maintenance backlog of low priority items should be aggressively pursued so that the backlog will be reduced. The licensee should evaluate new program effectiveness and continue to look at innovative ways to improve performanc _ - _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ -

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  -11-D. Surveillance Analysis The assessment of this area includes all surveillance testing activities as well as all inservice inspection and testing activities. Examples of activities included are: instrument i

calibrations, equipment operability tests, performance tests of pumps and valves, and all other inservice inspection activitie This area was inspected on a routine basis by the NRC resident inspectors and by NRC regional inspector The enforcement history for this functional area includes five violations. Several LERs were issued by the licensee in this area. The analysis of enforcement history and operational events indicates that personnel errors predominate. However, further analysis reveals that procedural inadequacies were also an important contributor. Licensee administrative controls have been slow to incorporate temporary procedure changes into revisions. The comments of technicians on procedures were not factored into procedure revisions in a timely manne This administrative control problem is discussed in detail in the quality programs and administrative controls affecting quality SALP category. Since procedures were not being updated, technicians were apparently forcing the procedures to work as written. The personnel error problems occurred primarily in the middle of the SALP period with none occurring during the last 4 months of the period. This was apparently because of strengthened management oversight and increased personnel attentiveness. The licensee's program for scheduling and , tracking surveillance requirements has been very effective with only one missed surveillance reported because of a scheduling or ; tracking proble Licensee staffing in this area has apparently been adequate with - some use of contractor technicians and craft personnel. Key positions are identified and vacant _ key positions are filled on a priority basi . Conclusions The overall assessment of this functional area indicates that the licensee has a strong program for scheduling and tracking surveillance test requirements. Some procedural and personnel i related problems with surveillance test performance have detracted from an otherwise strong program. The apparent - absence of personnel-related problems during the last 4 months of the SALP period indicates that licensee actions have had an effect on reducing personnel error . - - - -.- - -- - - - - . _ - _ .- .

* B-12-The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program. The continued effectiveness of licensee actions to control procedural and personnel related problems should be monitore Recommended Licensee Actions The licensee is encouraged to maintain the strong program for scheduling and tracking surveillance test requirement Management oversight of surveillance test performance should be maintained to control procedural and ,

personnel-related problem E. Fire Protection Analysis The assessment of this area includes routine housekeeping (combustibles, etc.) and fire protection / prevention program activities. Thus, it includes the storage of combustible material, fire brigade staffing and training, fire suppression system maintenance and operation, and those fire protection features provided for structures, systems, and components important to safe shutdow This area has been inspected on a continuing basis by the NRC resident inspectors and on one occasion by a NRC regional inspecto The enforcement history for this functional area includes ~ one violation for failure to identify an inoperable fire doo Several LERs were issued by the licensee in this functional area. The analysis of the enforcement history and operational events indicates that during the construction phase fire barrier installation was poor. It also indicates that the general plant staff awareness of fire protection requirements is wea The licensee's programs for fire brigade training and drills were found to be effective, and training and drills were being > conducted at required intervals. Fire brigade equipment was , being properly stored and maintained. General plant housekeeping has been good throughout the SALP period. While no specific problems with control of combustible materials has been identified in safety-related areas, problems have been

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  -13-identified in other plant areas. Additional management oversight is needed to further strengthen the control of combustible materials in all plant areas. Fire protection systems and equipment have been maintained and tested as require The responsibility for all phases of the fire protection program was divided among several groups (e.g., operations, projects, training, and engineering). Based on discussions with plant management at the end of the SALP period, the licensee was instituting a program to centralize plant fire protection activities under the plant manage Licensee staffing in this functional area has relied heavily on licensee contractor personnel. Management has apparently placed too much dependence on the licensee's contractor for fire barrier assemblies, and until the end of the SALP period, management oversight of this area was weak. This is further-evidenced by extensive use of fire watches rather than by aggressively solving identified problem . Conclusions The licensee's performance in this functional area has declined from the previous SALP assessment period. The overall assessment of this area indicates that general plant staff awareness and understanding of fire protection requirements is wea While important areas of the fire protection program (e.g., fire brigades, fire drills, housekeeping, etc.) have been effectively implemented, licensee management oversight has not been effective in promptly identifying and correcting fire barrier-related assembly problem The principal problems occurred during construction (prior to this SALP period) with a poor contractor quality control program during fire barrier installations. The licensee had some early indications of fire barrier and penetration seal problems, but the corrective actions apparently did not identify the poor installation controls of the contractor until late in the SALP perio The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The NRC should devote additional inspection effort to this area to assure that the licensee promptly and effectively corrects the fire barrier-related assembly problem The
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  -14-NRC should also monitor the licensee's effectiveness in improving general plant staff awareness of fire protection requirement Recommended Licensee Actions The licensee should provide aggressive management oversight of licensee contractor activities. The licensee should institute programs to improve general plant staff awareness of fire protection requirements. The licensee should monitor and assess the effectiveness of centralizing responsibility for fire protection activities under the plant manage F. Emergency Preparedness Analysis This area was inspected on a periodic basis by NRC region-based inspectors and contract personnel. During the assessment period, four emergency preparedness inspections were conducte Two of these were routine, unannounced emergency preparedness inspections encompassing the following major areas: emergency notifications and communications, shift staffing and augmentation, dose calculation and assessment, emergency detection and classification, protective actions decisionmaking, and public information program. The other two inspections involved observation and evaluation of emergency preparedness exercises. During these exercises, the licensee demonstrated adequate resolution of prior deficiencies, and demonstrated adequate management involvement in preparing, coordinating, and conducting the exercise Corporate management is frequently involved in onsite activitie The resolution of most NRC findings was timely, thorough, and technically sound. Corrective actions were, on the whole, effective, and resolution by the licensee was adequate for all violations and deficiencies identified during the SALP period. Corrective actions proposed to resolve one deficiency identified in NRC Inspection Report 50-458/8580-02, however, took considerable time. This deficiency pertains to potential delays due to the flow chart used for making protective action recommendation The violation identified during the February 1987 exercise indicated that more management attention was needed in training emergency response personne The three new deficiencies found in the 1987 exercise indicated that the licensee needs to refine further their emergency preparedness program.

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  -15-The licensee's performance in this area has been average. The licensee's enforcement history in this area has been satisfactory. The licensee generally has been responsive to NRC initiatives, and their corrective actions have been acceptabl This was evident in their handling of Unresolved Item 458/8635-01, which pertains to the omission of the effects of radiation in the emergency planning information booklet distributed annually to the population in the EPZ. The licensee took steps to review and upgrade their 1987 booklet to include information on the effects of radiatio . Conclusions The findings of the NRC inspections conducted during this evaluation period indicate that for the most part the licensee's emergency preparedness progra:n is satisfactor The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection progra Recommended Licensee Actions GSU management should continue to review areas in which weaknesses were identified (e.g., training of emergency response personnel) in order to identify underlying cause GSU management should review, revise, and implement procedures for classifying emergencies and making protective action decisions to ensure that under all circumstances a General Emergency class is promptly identified and declared, and that protective action recommendations are made within 15 minute G. Security Analysis Eight inspections were conducted by region-based NRC physical security inspectors during the assessment period. Seven violations were identified during this perio There is evidence of prior planning and assignment of prioritie Policies and procedures are well stated, appropriately disseminated, and understandable. Decisionmaking is usually at a level that should ensure adequate management
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 -16-review. The security section restructured the command structure and task distribution. Currently, it appears that this has improved the tracking of security systems maintenance. The corporate security unit and ge111ty assurance efforts continue to maintain an independent and effective oversight of security-related matters. Management reviews of security matters are timely, and usually thorough and technically soun Security incident analysis is sometimes performed without a sufficient data base, thus impacting management judgemer Records are generally complete, well maintained, and availabl Procedures and policies are generally followed. Corrective action is not always effective due to an apparent lack of support by the management of other divisions. This is indicated by repeat occurrences of a similar natur A clear understanding of security issues by management is not always demonstrated, but conservatism is usually exhibited when the potential for a security risk exist The approaches to the resolution of protective issues are technically sound and thorough in the majority of the cases. The resolutions of issues tend not to be timel The licensee is usually responsive to NRC initiatives, and technically sound and acceptable resolutions are eventually i proposed in most case However, two long standing issues
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concerning the use of radios and access authorization are attributable to the license Some major violations have been directly attributable to the security organization. A number of minor procedural mistakes by security personnel (and other personnel) have occurred, and some of these are repetitive. These mistakes appear to be indicative of a weakness in the program, and in some instances, corrective action for some problems created new problem Occasional, significant computer-related events, construction and design error holdovers, personnel actions, and maintenance activities are attributable causes under the licensee's control that have adversely impacted the planned security progra These events are identified, but not always reported, in a timely manner and some information may be lacking. Particular events are sometimes isolated for special study and analysi The quality of these studies varie Security organization positions are identified, and authorities and responsibilities are define Key positions are usually filled in a reasonable time utilizing the expertise within the GSU staff. Staffing is adequate. Midway through this rating period, the security systems compliance group was reorganized to reduce problems of tracking and testing defective equipment which required excessive compensatory measure The experience

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  -17-levels of the key personnel in the security organization, and those groups that support security, meet commitments made by the licensee at the time of licensin The security officer training and qualifications program, as committed to by separate security plan, contributes to an adequate understanding of the protective function. There is a fair adherence to procedure with a modest number of errors by the security personnel. General employee training inadequacies could occasionally be traced as a root cause of events or

, problems occurring during the rating period. Examples are the improper use of card readers and vital area doors. An effective disciplinary program for non-security personnel who violate security procedures appears to be lackin . Conclusions The licensee has an ample number of' qualified and cedicated personnel assigned to the security organization to implement the several security plans. Some procedural errors and violations , by security personnel, and_others impact.in0 security, persist and thus detract from the otherwise gooo protective performance.

. ' Involvement by the licensee's plant management personnel has not always been supportive as evidenced by the nature of the outstanding issues and violation The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection progra Recommended Licensee Actions

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The licensee should review the causative factors of security events for broader implications, such as , t weaknesses in: interdepartmental cooperation, elementary security training for all employees, and the disciplinary actions for deliberate or negligent security violation The incident analysis process should be reviewed to ensure that each incident is being thoroughly examine Corrective measures should have a strong relationship to those precipitating factors as identified by the event , evaluatio . - - . ._ _ _ _ . . _. . _ _ _ . - - . _ _ _ . -

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  -18-H. Outages Analysis The assessment of this' area is intended to include all licensee and contractor activities associated with major outages. Thus, it includes refueling, outage management, major plant modifications, repairs or ~ restoration to major components, and all post-outage startup testing of systems prior to return to servic Although the licensee has had no major outages during this SALP period, there was an extended outage of approximately 2 months-duration. The work completed during this outage included removal of main turbine screens, local leak rate testing, surveillance testing, and completion of preventive and corrective maintenance item Post-outage testing of systems prior to return to service was well controlled and the plant startup following the outage was smoot The licensee has a full-time outage manager and appears to be dedicated to a strong outage program. The resident NRC inspectors attended outage meetings and monitored outage activities during the extended outage and no problems were identifie There is no enforcement history or operational events attributed to this functional are . Conclusions t The limited assessment of this area indicates that the licensee is dedicated to a strong outage program. This is evidenced by the assignment of a full-time outage manager and by the controls

! exhibited during the extended outage. However, because of !. limited data for analysis, no Performance Category is assigned in this functional area.

( j Board Recommendations l [ Recommended NRC Actions l l The NRC inspection effort in this area should be consistent with the routine inspection progra Recommended Licensee Actions The licensee is encouraged to continue the apparent dedication to a strong outsge program. ihe licensee should , evaluate plans for the first refueling outage scheduled for ! fall of 1987 for manpower and program needs.

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  -19-I. Quality Programs and Administrative Controls Affecting Quality . Analysis   '

The assessment of this area includes all management control, verification and oversight activities which affect or assure the quality of plant activities, structures, systems, and component This area may be viewed as a comprehensive management system for controlling the quality of verification activities that confirm that the work was performed correctl The evaluation of the effectiveness of the quality assurance system is based on the results of management actions to ensure that necessary people, procedures, facilities, and materials are provided and used during the operation of the nuclear power plant. Principal emphasis is given to evaluating the effectiveness and involvement of management in establishing and assuring the effective implementation of the quality assurance program along with evaluating the history of licensee performance in the key areas of: committee activities, design and procurement control, control of design change processes, inspections, audits, corrective action. systems, and record In order to more clearly define the specific strengths and weaknesses noted in this functional area, the analysis is divided into three areas, as discussed below: , Engineering This area has been inspected on a routine basis by NRC resident inspectors and, on one occasion, by regional inspector The licensee staffing in this functional area-appears to be adequate, but personnel turnover in this area is a potential concern because of the loss of some key experienced personnel. The licensee relies on contractor support to supplement their permanent staff. The licensee is implementing a program for prioritizing engineering requests, and a review of work backlog indicates that aggressive management oversight is needed to further define engineering priorities. The licensee exhibits an understanding of technical issues, general conservatism and generally sound and timely resolution. However, some resolutions are dealyed because of the heavy engineering workloa The licensee is responsive to NRC initiatives with acceptable resolutions initially proposed in most case Licensee management was making program and personnel changes throughout the SALP period with a total reorganization implemented toward the end of the assessment

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  -20-period. The initial indication is that the reorganization has strengthened the engineering progra .

The enforcement history in this area includes five violations and one deviation. Two of the violations involved escalated enforcement action. Neither of the escalated enforcement actions resulted in a civil penalty because of prompt and extensive corrective action taken by the licensee and because there was no previous history of serious problems in these area Of the five LERs issued by the licensee in this area, two were because of existing design problems, one was the same as one of the violations, and two were because of design errors made by the licensee's engineering organization. The analysis of enforcement history.and operational events indicates that additional management oversight was needed to strengthen the engineering progra > Quality Assurance This area has been inspected on a routine basis by NRC resident inspectors and regional inspector The enforcement history-in this area includes one violation. No LERs were issued by the licensee in this area. The analysis of the enforcement history and operational events indicates that QA is effectively' implementing QA procedure Licensee management involvement in assuring quality is evident. The licensee had established an effective quality concern program to solicit and address employee concern The QA staffing is an area of strength with defined positions established and experienced personnel filling , these positions. The licensee has provided systems training for several QA personnel, and one QA engineer has , been licensed as a senior reactor operator. The licensee also makes effective use of consultants in' specialty areas where problems have been identifie The licensee approach to resolution of technical issues i from a safety standpoint has been strong with a clear understanding of issues exhibited, routine conservatism and generally sound and timely resolutions. The licensee . responsiveness to NRC initiatives has also been stron , A review of licensee audits and related findings indicates that the QA organization has been effective in identifying i quality problems. Most problems are promptly resolved, but ' in those few cases where differences of opinion exist,

     ,

! >

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

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

-. ,
           -21-

, effective management oversight is needed for timely resolutio The QA surveillance program was extensive and effective in monitoring all phases of operation. The licensee was aggressive in modifying surveillance activities to address new issues (e.g. , monitoring operator performance after the shutdown of Peach Bottom). Administrative Controls This area had been inspected on a routine basis by NRC resident ~ inspectors and regional inspector Licensee management has instituted a strong corrective action program with the use of condition reports. A condition report can be issued by anyone at River Bend Station to document and affect the resolution of any problem or issue. This has proven to be a very effective management tool to affect corrective actions and to determine root causes for problem The enforcement history in this area includes three violations and one deviation. These included failure to follow administrative procedures for document control and

issuing temporary procedure changes. Two LERs were issued by the licensee in this area caused by inadequate procedures. In addition, several related problems in other functional areas were caused by inadequate procedures.

! Licensee management oversight was weak in providing procedure updates and revisions in a timely manner. This was especially evident in surveillance test procedures where technician comments were not being factored into improved procedure Also, temporary procedure changes were not being incorporated into revised procedures in a timely manne Licensee committee activities were generally effectiv However, at least one significant problem was not identified during committee reviews and some administrative problems were not identified. The significant problem noted was the failure to identify that a control building ventilation modification involved an unanalyzed conditio . Conclusions The assessment of the engineering area indicaties that aggressive management oversight is needed to further refine engineering

programs and to further define engineering priorities. The program and organizational changes already implemented by ' licensee management is evidence of management involvement in , _e . _y .._,- _..--- -- ,c .

       .,..y   ,. - ._ _ . . . , , . - . , , , , , , _ _ . , , . _ _ , _ , , , _ , ,, , , , _ , . , . . _ _ _ _ _ _ , . .
- .
  -22-program improvements. An overall improvement in engineering programs and engineering responsiveness to problems was noted toward the end of the SALP perio The assessment of the QA area indicates a strong QA organization with experienced and aggressive personnel. QA procedures are being effectively implemented. The quality concern program has been an effective program for resolving a wide range of concerns and issues. Some additional management oversight is needed to effect timely resolution of quality issues where differences of opinion exis The assessment of the administrative controls area indicates that management oversight has not been fully effective in timely resolution of procedural inadequacies. Management involvement has, however, been very effective in implementing a strong corrective action program. Comittee activities have been effective in most cases (e.g., MOV bolting problem, Limitorque wiring, etc.), with some additional oversight needed in limited area The licensee is considered to be in Performance Category 1 for an overall rating of the SALP area of quality programs and administrative controls affecting qualit . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the routine inspection program with emphasis placed on monitoring licensee effectiveness in procedure updates and licensee effectiveness in defining engineering priorities, Recomended Licensee Actions The licensee should provide increased management oversight of administrative controls for procedural reviews and update The licensee should continue with emphasis on further defining and prioritizing engineering activities and should take action to stabilize personnel turnover in engineerin J. Licensing Activities Analysis The NRC Office of Nuclear Reactor Regulation has performed an i

evaluation of licensee performance in the functional area of Licensing Activities.

, Overall the licensee's strongest point is management. The licensee has responded very well to concerns enumerated in the i

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

 -    ,
         -23-last SALP on " lessons learned" from the experiences of other utilitie In fact during this SALP period, the licensee organized a conference of all recently licensed BWRs in order to assist in the transfer of " lessons learned" during the startup test program from experienced utilities to newly licensed power plant The staff finds licensee responses to NRC inquiries to have been generally viable with technically sound, conservative and thorough approaches in almost all cases. Tha licensee deserves praise for the aggressive attitude they displayed in remediating problems associated with operation of their feedwater system; including a major commitment of funds to remediate hardware problem During the SALP reporting period, the licensee reported 56 non-security events to the NRC Operations Center and submitted 57 LERs during the rating period. There were 6 events associated with River Bend Station presented at the Operating Reactor Briefings. Of those 6, 4 events were considered significant:
     *

FSAR/As built design discrepancy (3/11/86)

     *

Main Steam Line leakage control system inoperable (3/17/86)

     *

Non-operable control rod (5/12/86)

     *

Potential Loss of Control Building Ventilation System (10/27/86) River Bend Station also experienced 16 unplanned scrams during the rating period which corresponds to a scram rate of 2.35 scrams per 1000 full power hours. However, an evaluation of the scrams at River Bend Station show that the total number of scrams experienced by River Bend Station dropped considerably between first and second halves of the rating period. During the first 7 months of the rating period,13 scrams occurred with a scram rate of 3.96 per 1000 critical hours and 3 scrams occurred in the last 7 months with a scram rate of 0.86 per 1000 critical hours--a considerable improvemen Of the 16 scrams at River Bend during the rating period,10 were due to equipment failures; and 4 were due to procedure / personnel error. None of the scrams was considered serious enough to require detailed followup by the staff. An examination of these scrams shows no pattern of repetition. All of these considerations and the drop off in scram rate indicate the licensee's actions to control scrams were effectiv .. - . ._

            - - _ - . .

_ _ - ,

  -24-An independent evaluation of the content and quality of a representative sample of 15 River Bend LERs during the rating period was conducted by the NRC Office for Analysis and Evaluation of Operational Data and forwarded to the licensee separately. Using the methodology presented in NUREG-1022, Supplement No. 2 the average LER received a score of 8.1 out of a possible 10 points compared to the current industry average of 8.3 for those unit / stations that have been evaluated to date using this methodology. The principal weakness identified in the River Bend LERs involves the requirement to adequately identify failed components in the text of the LER, which might preclude prompt identification of generic problems by others in the industry. A strong point is the licensee discussion of failure mode, mechanism and effect of failed componen However, in the area of license amendments, the licensee's provisions of complete and timely information on significant hazards considerations requires remedial action. Most license amendment requests required multiple filings, specifically for significant hazards considerations, and often resulted in very tight review schedules for the staff. However, during the -

review period, the licensee has worked with the staff and has significantly improved the quality of their amendment application . Conclusions The licensee's perfonnance in the functional area of Licensing Activities is rated in Performance Category 2 with a strong positive trend attributed primarily to improved performance within the latter half of the appraisal perio . Board Recommendations Reconinended NRC Actions The NRC should continue timely processing of licensing action Recommended Licensee Actions Licensee management should continue to be highly involved in licensing activities. They should improve the quality of their LERs and consider remedial actions to improve the timimg and quality of licensee amendment submissions including the assignment of a supervisor with direct responsibility for preparation of license amendments within the licensee's licensing organizatio _ _-

~
, -
     ,
     -{
.

.

.
  -25-K. Training and Qualification Effectiveness Analysis The assessment of this area includes all activities relating to the effectiveness of the training / retraining and qualifications program conducted by the licensee's staff and contractors for non-licensed operators, control room operators, senior control room operators / shift supervisors, shift technical advisors, instrument and control technicians, electrical maintenance personnel, mechanical maintenance personnel, radiological protection technicians, chemistry technicians, and technical staff and manager This area has been inspected on a routine basis by the NRC resident inspectors and on several occasions by NRC regional inspectors. The operator licensing section of NRC Region IV also administered reexaminations and scheduled examinations during February and November of 1986, and conducted an audit of the licensee requalification program in November 198 Three reactor operator (RO) and two senior reactor operator (SRO) candidates were administered the reexaminations with two R0s and one SR0 passing. Seven R0 and ten SR0 candidates were administered scheduled examinations with all ten SR0s and five R0s passing. The audit of the River Bend requalification program was conducted with six SR0s and three R0s taking NRC written and operating examinations. All SR0s passed, but one R0 failed a portion of the written examination and was reexamined in accordance with the River Bend requalification program. The requalification program was evaluated to be satisfactor There were no violations or operational events directly attributed to training or qualification effectiveness. While several violations and events were personnel related, there was no trend in any particular area and few repeat error Management involvement in this functional area was evident with a strong commitment to training. Training facilities are excellent including a plant-specific simulator. Technical staff and managers are routinely provided systems and simulator training with several staff and management personnel being operator certified or NRC licensed operator Lessons learned are routinely factored into requalification training programs, and individual departments also provide training where problems are identified. The plant simulator is routinely used for requalification trainin . . . . ,

o-26-

.

2 .' - Conclusions' The 'overall assessment of this functional area indicates that' the licensee has made a strong comitment to training. The training and qualification effectiveness is evident with no 3

  - trend of personnel related problems and few repeat error The licensee is considered to be in Performance Category 1 in this functional are . Board Recomendations Recomended NRC Actions
'

The NRC inspection effort in this functional area can be-limited to the minimum program, Recomended Licensee Actions The licensee is encouraged to continue the strong . commitment to training and continue increasing their base 3 of qualified personne V.- Supporting Data and Sumaries - Licensee' Activities Major licensee activities during this SALP evaluation period included achieving 100 percent power operation on May 7,1986, completion of the startup test' program, and declaration of comercial operation on June 16, 1986. .The licensee also entered an extended plant outage

  ~
 -(approximately a 2-month duration) on October 4, 1986. The activities completed during the outage included removal of the main turbine screens, surveillance testing, local leak rate testing', and miscellaneous preventive and corrective maintenance activitie Inspection Activities f  NRC. inspection activity during this SALP evaluation period included

! 39 NRC Region IV inspections performed with 4713 direct inspection

manhours expended. .These inspections included a major team inspection of maintenance activities and a major team evaluation of a licensee conducted emergency. preparedness drill. The NRC also closed

, l

out the startup test program inspection activities during this ,

. , evaluation perio Table 1 provides a tabulation of NRC enforcement activity for each ! functional area evaluated. Table 2 provides a listing of inspection

findings in each SALP Category.

L t I.

l ( L

, . -  __ _ ~ . _ . _ _  _ __. . . . .- . _ ___ _  .
~
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, t. - ,

.

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     -27-
 .
" Investigations and Allegations Review
 '
  .No major investigation activities were conducted during this-assessment perio _

D. . Escalated Enforcement Actions Civil Penalties A Notice of. Violation and ' Proposed Imposition of Civil Penalty

  .was issued on August 7, 1986. A $65,000 civil penalty was

'

        '

assessed for two Severity. Level III violations in the area of -

  -security for failure to adequately control the access of
  . personnel to vital areas and failure to provide adequate vital area physical barrier . Enforcement Orders None.

iL . Management Conferences Held During Assessment Period Conferences Three enforcement conferences were-held at the NRC Region IV , office during this assessment period. The dates of the meetings and subject.for each conference 'are listed below: April-10, 1986: Inoperable Emergency Diesel Generator Because of a Misaligned Fuel Oil Strainer Valve

  *

June 10, 1986: Failure to Adequately Control the Access of i' Personnel to Vital Areas and Failure to Provide Adequate Vital Area Physical Barriers

  *

November 10, 1986: Inadequate Safety Evaluation for a ' Plant Modification of the Control Building Ventilation System In addition to the above conferences, an oversight committee made.up of personnel from NRC Region IV, Nuclear Reactor

Regulation, and Inspection and Enforcement' met with the licensee on two occasions (but only one of these, July 1986, was within Lthis SALP period) to discuss licensee performance and problems.

2 Confirmation of Action Letters (CALs) None.

, . l

  ,

o m g - W -i-***r- T14+r g - - - -+b = -g y -- -+- a-g-* -- -

,
'
. ..
   -28- Review of Licensee Event Reports and 10 CFR Part 21~ Reports Submitted by the Licensee Licensee Event Reports (LERs)

The resident inspectors and project inspector reviewed LERs submitted by the licensee throughout the assessment period an noted corrective actions. During a management conference conducted on November 10, 1986, NRC management expressed concerns to licensee management regarding content and timeliness-of LERs. During this conference, the licensee outlined steps being taken to improve the content and timeliness of LER Improvement was noted with LER submittals after this conferenc In addition, a SALP Review Panel was convened in the NRC ' Region IV office on April 7, 1987, to review inspection findings and LERs.for proximate causes and trends. The review panel inputs were factored into the analysis of SALP area Table 3 provides a = listing of LERs by SALP category and subjec ' Part 21 Reports

 ~

There were no 10 CFR Part 21: reports submitted by the licensee during this SALP assessment-perio *

  ,

L I l o I; p i ! I-l ! i ,

_ - __

   .
. -,    <

TABLE 1 ENFORCEMENT ACTIVITY: SUMMARY-

Functional No. of Violations In Each Severity Level Area IV III II I Deviations /

,

Deficiencies Plant Operations ~ 1 Radiological Controls 2 1 1/0 Maintenance 2 2*

- Surveillance  5 Fire Protection  1 Emergency Preparedness 1 1  0/10 Security  1 4 1 1- Outages Quality Programs and_ 2 5 2*  2/0 Administrative Controls Affecting Quality Licensing Activities

- Training and Qualification Effectiveness Total ** 4 21 6* 1 3/10

*: The two Level III violations noted in maintenance and one of the Level III violations in quality progrdms were all related to the same proble These violations were collectively deemed a Level III proble **: The ~ totals may be slightly higher than the actual number of violations issued because some violations are listed in more than one SALP area. See Table 2 for listing.

i I l I l i l ! \

, . -.- _

_- -. . . . - . . . - .. . -

. .

TABLE 2 ENFORCEMENT ACTIVITY TABULATION OF VIOLATIONS, DEVIATIONS, AND EMERGENCY PREPAREDNESS DEFICIENCIES BY PERFORMANCE CATEGORY A .- Plant Operations Violations

*

Failure to maintain system configuration per piping and instrument diagrams (P& ids) (e.g., pipe caps, valve positions, locked valves)

 (Severity Level IV, 8620-02) (also listed in QA Programs and Maintenance)

Deviations None Radiological Controls Violations

*

Failure to demonstrate operability of Post-Accident Sampling System (Severity Level IV, 8703-01) Solidified radioactive waste shipment containing excess liquid (Severity Level III, 8622-01)

"

Inadequate procedures for control or radioactivity - personnel exiting radiation portal monitors (Severity Level IV, 8702-01) Deviations l

*  stem not in operation per Final Safety Analysis Radioactive waste Report description sy(8622-02)

l l l Maintenance l Violations ! ' * Failure to maintain system configuration per P& ids (e.g., pipe caps, valve positions, and locked valves) (Severity Level IV, 8620-02) (also l listed in Operations & Quality Programs) Failure to implement procedures for conduct of maintenance on diesel generator fuel oil strainer valve handle (Severity Level III, 8614-018)

*

Inoperable Division II diesel generator because of a misaligned fuel l oil strainer valve (Severity Level III, 8614-01A) t i ! <

'.- , . .
*

Inadequate procedural controls of torque wrench calibration - removed by memo from Measurement and Test Equipment Program (Severity Level IV, 8616-01) Deviations

 :None Surveillance Violations Failure to follow administrative procedure for issuance of Temporary Change Notice (TCN) - did not use previous TCN for new TCN (Severity Level IV, 8620-01) (also listed in QA Programs)

Failure to utilize proper revision of surveillance test procedure (Severity Level IV, 8639-02) Failure to follow a surveillance test package - selected wrong battery pilot test cells (Severity Level IV, 8627-02) Failure to follow surveillance test procedures (Severity Level IV, 8639-01)

*

Failure to follow surveillance test procedure (Severity Level IV, 8640-01) Deviations

*

None Fire Protection ! Violations ' Failure to identify an inoperable fire door and establish the , required fire watch (Severity Level IV, 8630-02)

Deviations None

!
. Emergency Preparedness i Violations

' Failure to provide training for First Aid personnel per the emergency i plan (Severity Level IV, 8706-01) { ? l t

- .

. <.    ,
  -3-
*

Failure to review personnel listing for Emergency Telephone Book (Severity Level V, 8625-01) Deviations None Deficiencies

*

Control- of personnel at the Evacuation Assembly Area (8609-A)

*

Personnel in the Operations Support Center not trained in card reader system (8609-B)

*

Radiation protection coverage and contamination control training not adequate (8609-C) Training in use of message forms by offsite agencies weak-(8609-D) Radiological assessment was-weak due to the staffing for this function (8609-E) Dose assessment calculators not' maintained operable (8625-A) Failure to demonstrate proficiency in backup manual dose assessment calculations (8625-B)

"

Failure to sample control room during exercise-for radioactive contamination (8706-02) Operations Support Center coordination of in plant teams (8706-03) Delay in notifying parishes after declaring General Emergency (8706-04) G. Security Violations Vital area hatch unlocked with officer asleep (Severity Level IV, 8631-01) Failure to control access to vital areas (Severity Level IV, 8613-01) Failure to adequately control access of personnel to vital areas (Severity Level II, 8611-01A) Failure to provide adequate vital area physical barriers (Severity Level III, 8611-018)

- ,
  -4-Failure to promptly report a major loss of security effectiveness (Severity Level IV, 8611-02)

Inadequate lock and key control (Severity Level V, 8610-01) Inadequate Safeguards Contingency Plan implementation (Severity Level IV, 8629-01) Deviations None H. Outages Violations

*

None Deviations None I. Quality Program Violations

*

Improper disposition of startup test deficiency based on unverified engineering analysis (Severity Level IV, 8608-01)

*

Inadequate corrective action for misaligned fuel oil strainer valve - Division II diesel (Severity Level III, 8614-01C) Failure to maintain system configuration per P& ids (e.g., pipe caps, valve positions, locked valves) (Severity Level IV, 8620-02) (also listed in Operations and Maintenance) Failure to schedule an audit early in the life of an activity: Facility Review Committee - Startup Review of S/U test results (Severity Level IV, 8608-02) Failure to have certain maintenance procedures - incorporation of vendor technical information, prescribing preventive maintenance intervals and root cause analysis (Severity Level IV, 8606-01)

*

Failure to follow procedures - used modified report for identifying , outstanding changes to support drawings (Severity Level V, 8616-02) ! Failure to follow procedures for Station Manual Document Transmittal updates (Severity Level V, 8616-03) ! ! ! l l l

. .,
   -5-L  Failure to_ follow administrative procedures for issuance of TCN - did'

not use previous TCN for new TCN (Severity Level IV, 8620-01) (also listed in Surveillance)

*

Inadequate safety evaluation for control building ventilation system modification - disable auto start of redundant train (Severity-Level III, 8636-01) Deviations SKEW Sheets not being updated for Environmental. Qualification Master List (8619-01)

*

Abnormal. operating procedures not verified and validated - incorporated portions of generic guidelines (8624-01)

- Licensing Activities Violations None Deviations None Training and Qua ipation Effectiveness Violations
*

None Deviations

'

None

r ! ! t

      ~
.%h x
,
;q  . ..

TABLE 3

'

OPERATIONAL EVENTS TABULATION OF. LICENSEE EVENT. REPORTS-BY PERFORMANCE CATEGORY Plant Operations

 *
  . Reactor trip resulting from feedwater heater level problems (86-019)
 *

Transformer fault results in high pressure core spray injection - feedwater pumps tripped (86-021) Engineered safety feature actuations due to an electrical protection V assembly breaker failure - Reactor Protection System breaker trip (86-024)

:
'

Reactor scram due to loss. of RPS power - Elgar power line conditioner blown fuse (86-027)

 * Reactor scram on reactor water level 8 - flow controller problem (86-032)

Reactor scram on high pressure due to low setpoint - stator cooling temperature switch setpoint drift (86-037)

 * Reactor scram because blown fuse in Reactor Protection System - cause unknown (86-033)
 *

Fuel building filtration train "B" automatic start - radiation monitor failed (86-034) Reactor scram on turbine trip due to high vibration signal - unexplained fire deluge operation (86-039) ' * Control room charcoal filtration system actuation - spurious radiationmonitorchanginglightbulb(86-040) MissedTechnicalSpecification(TS)actiononfuelbuildingradiation

.

monitor (86-046) Reactor scram on Intermediate Range Monitor upscale - opening steam drainsduringstartup(86-042)

 * Reactor scram due to high steam seal evaporator tank level (86-045)

( Trip of EJS*SWG2A due to a faulty output transistor in containment unit cooler breaker (86-047) Fuel building filtration start on spurious radiation monitor spike - failedvoltagesuppressor(86-049) ! l i

 . - , . - . - , -. ,  .__,--.g .y,.., .m ,,,,,4- -, _ .
       . - -.---_y3, ,-- ,- -- . - - -
  ,_, . -. - -#. , , .
. .. ..
 - - - - _ _ - - - _ _ - _ _ - _
. . .
. ...
    -2-
 *

Reactor water cleanup unit failure to isolate due to a faulty bypass switch (86-050) Spurious control room ventilation isolation - radiation monitor spike (86-052) Reactor scram due to faulted transformer - RPS bus plus backup scram relay failure (86-055)

 *

Failure to declare high pressure core spray system inoperable - level 2 instrument placed in trip also made level 8 inoperable (86-054)

 *
 ' Automatic start of standby service water pumps - wrong breaker opened during electrical lineup (86-058)

Automatic initiation of standby gas treatment system due to a radiation monitor spike (86-062) Reactor core isolation cooling isolation due to a failed pressure transmitter (86-068)

 *

Reactor scram due to high stator cooling temperature - control valve sticking (86-069)

 *

Missed sample collection required by TS - sample realigned to clear alarm (87-001) Manual reactor scram due to high unidentified drywell leakage (87-002) Reactor scram due to a feedwater valve misoperation - operator error (87-003) Radiological Controls None Maintenance Automatic initiation of standby gas treatment system - spurious noise interference (86-020)

 *

Reactor scram due to pressure spike in instrument line (86-022) Diesel generator fuel oil valve misalignment (86-023) Main steam positive leakege control system inoperable due to improperly landed electrical lead (86-026) _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _

.
..a-3-
*

Inadvertent auto start of standby service water post-maintenance energizing (86-029)

*

Reactor scram on excessive flow transmitter noise (86-035) Standby gas treatment start due to opened breaker - breaker adjustment problem (86-043)

*

Reactor scram due to entrapped air in instrument sensing line (86-056)

*

Residual heat removal isolation due to a grounded power supply inadequate isolation (86-064) D. Surveillance Residual heat removal (RHR) isolation due to shorted jumper (86-025)

*

Reactor scram-turbine bearing high vibration - transient during control valve testing (86-041)

*

Missed control rod block surveillance (86-048)

*

Spurious reactor water cleanup (RWCU) isolation during temperature reading surveillance - failed to bypass trip (86-051) RWCU isolation from grounded jumper (86-057)

*

Loss of sample flow on radiation monitor grab sample not taken (86-061) RHR isolation due to a grounded lead (86-063) Failure to adequately perform main steam isolation valve leak rate test - improper TS interpretation (86-065)

*

Division I diesel generator output breaker failure - loose bolt in charging spring motor (87-04) E. Fire Protection Fire watch inadvertently cancelled (86-031)

*

Penetrations with inadequate fire barriers (86-036)

*

Unsealed fire barrier penetration (86-038)

*

Thermolag material removed for maintenance without a fire watch (86-053) i

  - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _-_______ _ __ ______ _
         ,

)

....
    -4-Missed fire door surveillance - surveillance test procedure did not require inspection of latches / closing mechanisms (86-066)
*

Inoperable fire barriers found during surveillance testing - Quality Control identified installation problem (87-005) Emergency Preparedness

*

None Security

*

None Outages None Quality Programs

*

Unqualified tubing installed due to procedural error: non-seismic installation (86-017)

*

Reactor core isolation cooling (RCIC) system isolation on main steam tunnel differential temperature - inadequate area cooling (86-018) Incorrect transformer tap settings - did not implement design calculations into drawings (86-028)

*

Reactor trip due to moisture separator reheat drain tank gasket failure (86-044)

*

Heating and ventilation inadequate design review - inadequate safety evaluation control building ventilation modification (86-060)

*

Surveillance test procedure not performed at high point vents - failure to update procedure (86-059)

*

RCIC isolation on apparent high steam flow - instrument offset from water column formation (86-067) Licensing Activities

*

None Training and Qualification Effectiveness

*

None f

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

}}