IR 05000458/1987032
| ML20236A902 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/09/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20236A880 | List: |
| References | |
| 50-458-87-32-01, 50-458-87-32-1, NUDOCS 8903200204 | |
| Download: ML20236A902 (60) | |
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' FINAL-SALP. REPORT.
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U.S. NUCLEAR REGULATORY COMISSION
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d" SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE.
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(h Inspect' ion Report _No.'87-32 Gulf. States Utilities._ Company cn ,
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River Bend Station . Docket No.L 50-458-
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April 1,1987, through September 30, 1988
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f 1. INTRODUCTION i 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 program is supplemental to normal regulatory processes used to ensure compliance with NRC rules and regulations. It is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful feedback to the licensee's management regarding the NRC's assessment of their facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on November 15, 1988, to review the observations and data on performance, and to assess licensee performance in accordance with NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance." The guidance and evaluation criteria are summarized in Section III of this report. The Board's findings and recommendations were forwarded to the NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety perfonnance at River Bend Station for the period April 1,1987, through September 30, 1988.
The SALP Board for River Bend Station was composed of:
A. B. Beach, Deputy Director, Division of Reactor Projects R. L. Bangart, Director, Division of Radiological Safety and Safeguards J. A. Calvo, Director, Project Directorate IV G. L. Constable, Chief, Reactor Project Section C W. A. Paulson, Project Manager, Project Directorate IV J. P. Jaudon, Deputy Director, Division of Reactor Safety W. B. Jones, Resident Inspector The following personnel also participated in the SALP Board meeting:
J. M. Montgomery, Deputy Regional Administrator B. Murray, Chief, Reactor Programs Branch W. C. Seidle, Chief, Test Programs Section R. J. Everett, Chief, Security and Emergency Preparedness Section E. J. Ford, Senior Resident Inspector G. L. Madsen, Project Engineer I. Barnes, Chief, Materials and Quality Programs Section J. A. F. Kelly, Senior Physical Security Inspector
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-2-A .- Licensee Activities 1. Major Outages o River Bend Station was shut down from June 18-28, 1987, for equipment maintenance and to repair sources of leakage in the drywell, o The first refueling outage was conducted September 15 through December 26, 1987. Activities performed included refueling,18-month surveillance testing, and integrated leakage testing.
2. License Amendments During the assessment period, there were 25 operating license amendments. Some of the more significant amendments were:
o liquid control system Modified specifications for standby for compliance with 10 CFR 50.62. (ATWS) - Amendment 13 o Provided surveillance requirements for modified ultimate heat sink temperature monitoring system. - Amendment 20 o Revised the security plan. - Amendment 21 o Revised Technical Specification to add additional ACTION requirements if SCRAM dishcarge volume vent / drain valves become inoperable. - Amendment 26 3. Major Modifications o Installation of alternate rod insertion system.
o Installation of cascading inoperability status lights in accordance with Regulatory Guide 1.47.
o Annunciators in the main control room were rearranged in accordance with human factors recommendations.
o Installation of interlocks between the Low Pressure Coolant Injection Suction Valves 1E12*M0V004 and 1E12*M0V006 to prevent inadvertent draining of the reactor vessel to the suppression pool.
o Installation of additional antisiphon holes to the upper fuel pool and lower spent fuel pool cooling and purification suction lines.
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-2-Licensee Activities 1. Major Outages o River Bend Station was shut down from June 18-28, 1987, for equipment maintenance and to repair sources of leakage in the drywell, o The first refueling outage was conducted from September 15 through December 26, 1987. Activities cerformed included efueling, 18-month surveillance testing and integrated akage testing.
2. License gendments During the essment period, there were 25 Operating License Amendments. ome of the more significant amendments were:
o Modified s liquid control system for complian cifications for standby with 10 CFR 50.62. (ATWS) - Amendment 13 o Provided survel ance requirements for modified ultimate heat sink temper ture monitoring system. - Amendment 20 o Revised the securit glan. - Amendment 21 o Revised Technical Spec fication to add additional ACTION requirements if SCRAM d'scharge volume vent / drain valves becomeinoperable.-Amehment26 3. Major Modifications o Installation of alternate rod nsertion system.
o Installation of cascading inopera' ility status lights in accordance with Regulatory Guide 1.42.
o Annunciators in the main control room were rearranged in accordance with human factors recommen tions.
o Installation of interlocks between the to Pressure Coolant Injection Suction Valves 1E12*MOV004 and 1 2*M0V006 to prevent inadvertent draining of the reactor essel to the suppression pool, o Installation of additional antisiphon holes to t e upper fuel pool and lower sper.t fuel pool cooling and purification suction lines.
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-3-B. Direct' Inspection and Review Activities J
< NRC inspection activity during this SALP evaluation period included {
41 inspections performed with approximately 5160 direct inspection , i hours expended. The inspections included an environmental I qualification team inspection by region-based and contract l inspectors. 4 II. SUMMARY OF RESULTS Overview ,
i This SALP period brought about many improvements in physical plant condition and programmatic controls at RBS. Only the highlights of these improvements are addressed in this report. The licensee's efforts to improve timeliness of responses to condition reports appears to have i improved during the latter part of the SALP period. Good refueling outage planning and execution, excellent housekeeping and decontamination efforts, improved plant availability, and management involvement in overall nuclear operations performance are all indications that RBS was striving to achieve excellence.
The SALP Board concluded, however, that there were areas where improvements were needed. The licensee did not always demonstrate the attention to detail required of the operations and maintenance / surveillance organizations throughout all plant operating modes. Operating and surveillance procedure inadequacies resulted in challenges to plant systems and engineered safety feature actuations. The licensee failed to ensure proper implementation of the security plan and procedures. Problems were identified in security training, disciplinary actions, and the maintenance of security equipment. Continued licensee management attention is needed to assure timely response to condition reports.
The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation period.
Previous Present Performance Performance Category Category Functional Area (02/01/86 to 03/31/87) (04/01/87 to 09/30/88)
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Plant Operations 1 2 1.
2. Radiological Controls 2 3. Maintenance 2 N/A*
4. Surveillance 2 N/A*
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, -4-Previous Present 4 Performance Performance Category Category Functioral Area (02/01/86 to 03/31/87) (04/01/87 to 09/30/88)
5. Maintenance / Surveillance N/A* 2 6. Fire Protection 2 N/A*
7. Emergency Preparedness 2 1 8. Security 2 3 9. Engineering / Technical N/A* 1 Support 10. Safety Assessment / N/A* 1 Quality Verification 11. - Quality Programs and 1 N/A* ,
Administrative Controls Affecting Quality 12. Licensing Activities 2 N/A*
13. Training and 1 N/A*
Qualification ;
Effectiveness
- NRC Manual Chapter 0516 was revised on June 6, 1988. This evaluation was performed in accordance with the revised manual chapter. The major change involved restructuring of the functional areas.
III. CRITERIA Licensee performance was assessed in seven selected functional areas.
Functional areas normally represent areas significant to nuclear safety and the environment. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
The following evaluation criteria were used, as applicable, to assess each functional area:
A. Assurance of quality including management involvement and control; i
B. Approach to resolution of technical issues from a safety standpoint; C. Responsiveness to NRC initiatives; I
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'I-D. Enforcement history;
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E. Operational events (including response to, analyses of, reporting.of, )
and corrective actions for);
F. Staffing (includingmanagement);and G. Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been ;
-E used where appropriate.
Ba' sed on the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these
. performance categories are as follows:-
1. Category 1. Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear
. safety 'or safeguards activities, with the resulting performance
- substantially exceeding regulatory requirements. Licensee resources are. ample and effectively used so that a high level of plant and
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personnel performance is being achieved. Reduced NRC attention may be appropriate.
2. ' Category 2. Licensee manageme'nt attention to an'd involvement in the-performance of nuclear' safety or safeguards activities is good. :The licensee-has attained a level of performance above that needed to
' meet regulatory requirements. Licensee resources are adequate and-
--reasonably allocated so that good plant and personnel performance is ;
being achieved. NRC attention may be maintained at normal levels.
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3. Category 3. Licensee management attention to and involvement in the performance of nuclear safety or. safeguards activities are not sufficient. ~ The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal levels.
IV. PERFORMANCE ANALYSIS
A. Plant Operations 1. Analysis The assessment of this area consists chiefly of the control and execution of plant operations activities at the River Bend Station. It is intended to include activities such as: plant startup, power operation, plant shutdown, and system lineups.
Thus, it involves activities such as monitoring and logging plant conditions, normal operations, responding to transient and
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! .off-normal conditions, plant-wide housekeeping.: control room L professionalism, and interface with activities that support'
operations.
This area has been inspected on a continuous basis by the NRC
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resident inspectors and on severa1' occasions by NRC regional-inspectors.- Specific areas inspected included operational.
safety verifications, safety system walkdowns, followup'on
.significant events / problems and review of licensee event !
reports (LERs). During this assessment period, the licensee completed a continuous run of 151 days prior'to the first ,
. refueling: outage and a continuous run of 164 days'during this H '
second fuel cycle.
The licensee presently has 34 licensed senior. reactor operators j
- and.- 21 reactor operators. Five operating crews have been 1-established with additional personnel available to. fill.in for expected and unexpected absences. A sixth operating crew'is being developed.to reduce overtime requirements which have been experienced especially during plant outages. Each operating crew usually consists of at least one. additional ' licensed operator than is required by the Technical Specifications (TS).
z This allows-licensed operators to perform some nonlicensed operator duties, out in the' plant, which is beneficial. in.
maintaining operator awareness of plant. systems.
The plant operations staff exhibited a professional attitude'in the operation of River Bend Station throughout this assessment period. Reading materials and radios which are not directly .
.related to plant operations are prohibited from the main control room. Additional access controls for station personnel have been implemented which have.been effective in keeping personnel not directly required for plant operations out of the main control room. Station personnel must receive permission from an on-shif t licensed operator prior to entering the main control area. Plant management was frequently observed in the main control room and on tours throughout the plant. 1 A program has been implemented to extinguish annunciators which l do not indicate an abnonnal condition for the given plant !
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status. The NRC inspectors have noted that the number of j annunciators that are lit has been significantly reduced from ,
t the previous SALP period as recommended by the previous SALP Board. The licensee's goel is to attain a black board status l during normal full power operation. l
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Several plant transients were observed and others reviewed by !
the NRC inspectors to assess operator response to the events.
The operators have demonstrated an increased knowledge of plant l
systems and familiarity with station operating procedures since the previous assessment period. For each transient observed j i
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. . 4-7-I and/or~ reviewed, the operators have responded in a professional'
manner to maintain the reactor plant in a safe configuration.
An example of the operators knowledge and professionalism was illustrated by their response to several unexpected events-following the August 25, 1988, main turbine trip and reactor SCRAM. The shift superv.sor (SS) and control operating foreman (C0F)prioritizedrestorationofsystemsanddirected the licensed and nonlicensed operator activities so that normal system configurations were restored in a timely manner. The'
licensed and nonlicensed operators responded quickly to restore the systems to their normal standby lineups. In addition, the senior reactor operators, particularly the SS and C0F, have demonstrated a good understanding of the River Bend. Station TS.
Although the licensee has demonstrated-their ability to effectively operate the plant during this assessment period, there are four areas which the licensee should continue to devote attention so the highest operating standards are maintained. These areas are: communications with other departments, attention to detail during shift turnovers and-plant operations, configuration control, and procedural adequacy.
The operations staff improved communications to ensure the operators are cognizant of activities being performed with the plant in power operation and during shutdown conditions. Four events occurred during this first half of the assessment period which demonstrated the need for continued vigilance in this area. The most significant event involved the partial draining of the upper spent fuel pool to the condensate storage tank.
The operators were following the procedure to add water to the upper fuel pool, however level indication was offscale low.
Communications were not established with personnel at the pool nor was an operator dispatched to the pool to monitor pool water level to ensure pool level was actually increasing. The three remaining events resulted in the generation of reactor SCRAN signals. Two of the events occurred during maintenance
- activities on an inverter and reactor protection system bus.
l The final event occurred when a suction line to the control rod I drive system was isolated inadvertently from the condensate storage tank. For each of the above events, the licensee has j taken extensive corrective actions to ensure that the events do not occur again.
l Although the operating staff performed well during aff-normal l and transient events, there were six examples where inattention l
I to detail resulted in missed TS ections or directly affected equipment status. The most significant event in terms of operator awareness occurred at the end of the assessment period, when the fuel building ventilation charcoal filtration heaters were deenergized for several days. Although status light l
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s I-8-indication is provided on the main control. board, this condition was not identified during six shift turnovers. -Additional examples ' involved an automatic reactor SCRAM from low power .
tripping of the residual heat removal (R,HR) pump while in shut down cooling and missed TS action statements. The reactor SCRAM occurred from low: power when the turbine's first. stage' pressure was allowed to increase to greater than 40 percent indicated.
power during turbine she11Lwarming activities. Another event'
occurred when the: plant was in refueling and one.RHR pump was'in operation for. shutdown cooling. The RHR pump automatically-tripped when the leak detection sjstem sensed high differential temperatures in the associated RHR cubicle. The pump had been started without. ensuring the associated ventilation system was in operation.- Indication that.the ventilation system was not.
. operating-was provided on the main control board by a red status light. Finally' three TS action statements were missed when
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conditions were identified but.not recognized.as requiring
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action. These. involved annulus pressure, SCRAM discharge volume level and the_ standby gas treatment system.
An additional-area which the licensee' management must closely 3 monitor is configuration control. Controls in this area have !
been substantially strengthened within the last 18-months. 'A :
lack of. configuration. controls over the.antisiphon plugs installed in the upper fuel pool purification and cooling lines allowed for the partial draining of the upper spent fuel pool.
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The licensee also identified that one division of the leak detection rystem for the reactor core isolation cooling system was disable.d because the associated instrument isolation root valves.were closed. During the first refueling outage, a 100 percent verification of all safety-related valve positions was conducted.. Two licensed operators identified that an instrument root valve for the high pressure core spray system actuation on high drywell pressure was isolated. This condition was promptly reported to their management and to the NRC. An enforcement conference was held because of this event. In ;
consideration of the licensee's prompt identification and i i
reporting of the violation, and the unusually promot and extensive corrective actions and detailed evaluation, the NRC staff issued an enforcement action at Severity Level III with no '
civil penalty. A cooling line to a radiation monitor was later {
found isolated, which resulted in even further corrective actions. The licensee's configuration control program now requires verifying all valves within a clearance boundary, and a 100 percent review of all safety-related valve lineup sheets prior to completion of each refueling outage. The licensee's configuration control program, if properly implemented, should assure proper system lineups.
Finally, procedural inadequacies contributed to at least four events. The most significant event involved the station
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operating procedure for controls ^ over the spent fuel system.
This procedure' allowed for a system lineup which resulted.in the partial draining of the upper spent fuel pool. The remaining events-included tripping of the RHR pump in shutdown cooling,
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' isolating of the condensate storage tank from the control rod
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drive system.and mispositioning of the inverter maintenance.
switch.
'During this SALP. period, the licensee experienced seven-.
automatic. scrams. Three of the scrams were-attributed to equipment-related' failures and problems, one to licensed q operator error,;and two to nonlicensed operator error along with '
inadequate procedures guiding the activities they were performing. The' remaining reactor scram occurred when an animal contacted two phases of a normal station. grounding transformer.
.resulting in a main generator trip and subsequent reactor scram.
An.important aspect in assuring the plant is operated-in a safe and responsible manner is that the operators are aware of plant ,
indications and that any actions they may take will not '
adversely affect plant operations.
'2. , Performance Rating
'The operations staff exhibited the high level'of professionalism 1 which is required to safely operate River' Bend Station. It was this. attitude that led to the prompt reporting of the drywell pressure instrument being isolated. The operators have demonstrated a good overall understanding of plant systems and operations. Transients were handled in a professional and systematic manner, ensuring plant integrity was maintained at-all times. There were several instances where plant indications required action by the operators to comply with the TS but these actions were not innediately taken.
The licensee is assigned a performance rating of 2 in this area.
3. Reconnendations a. NRC Actions NRC inspection effort in this crea should be consistent ;
with the Fundamental Inspection Program. In addition, selected Regional Initiative Program inspections should be i conducted during the next SALP period in the area of preparation for refueling and refueling activities.
i b. Licensee Actions
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The licensee should continue to stress attention to details throughout the upcoming assessment period. Means of l
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. organizations should be reviewed.to ensure that all responsible groups;are aware of' plant status'and-activities. Attention must be focused on procedures and, procedural compliance. Procedures must be adequate to direct an activity, however the consequences for a given -
action must be fully understood before.the action is taken.
. Finally, the licensee should continue to~ stress adherence
_to their configuration control programs. Management .
. attention should be directed to this area, particularly
'during the second refueling outage,to ensure required systems and personnel safety is not compromised.
.B. . Radiological Controls 1. . Analysis The assessment of this functional area consists of activities directly related to radiological controls including occupational i
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radiation safety (e.g., occupational radiation protection,.
radioactive materials and contamination controls, radiation ifield control, radiological- surveys and monitoring, and as. low
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as is reasonably. achievable programs), radioactive waste
> management'(i.e., processing and onsite storage of gaseous.
-liquid, and solid waste), radiological effluent control and monitoring (including.gaseousandliquideffluents,offsitedose calculations, radiological environmental monitoring, and i
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confirmatory materials e.g., (y measurements)
procurement of packages, -and transportation preparation;for of radioactive- .,
i shipment, selection and control of shippers, receipt / acceptance of shipments,~ periodic maintenance of packagings, and.
point-of-originsafeguardsactivities).
The occupational radiation safety program was inspected three- ,
times during the assessment period by region-based radiation specialist inspectors in addition to the resident' inspector's routine inspections. Two violations were identified during the assessment period involving the occupational radiation safety program.' The violations reflect minor problems and are not an indication of a programmatic breakdown within the occupational radiation safety area but rather the lack of attention to detail in implement 6 tion of the program.
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The collective radiation exposure for 1987 was 378 personrem which compares to the national boiling water reactor average of-515 personrem. The licensee performed the first refueling of the reactor during this period. An aggressive ALARA program contributed to the lower radiation exposure level. The plant
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goal for 1988 is to keep the collective exposure at'or below 100 personrem. Through July 1988, the total was 46.7 personrem.
The 1988 goal for personnel contaminations is less than 130.
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-11-As of July, 45 contamination events had been identified. Two incidents occurred during the assessment period that indicated the lack of initiative and control by the radiation protection department. The first involved the failure to identify a hot article embedded on the shirt of a worker. The worker took the irt home and the particle was not detected until several days la er when the worker wore the shirt again and the particle was det ted during later routine personnel survey. The second invol ed the failure to initiate timely actions to decontaminate a vent ation duct in the fuel building which resulted from an overflow of the back-wash tank. This condition was known to exist for everal months, but no action was taken until loose contaminate n caused downstream effluent monitoring to alarm.
The licensee's biochemistry and water chemistry programs were inspected once ring the assessment period. Confirmatory measurements per ,ed on the radiochemistry and water chemistry samples were foun ,be above expected industry averages in 97 percent agreement fr biochemistry) and 93 percent agreement (water chemistry). T. licensee's level of performance in this area during the assessm t period appeared to be at about the same level as during the ious assessment period.
The licensee's transportation r gram was inspected once during the assessment period. The 1 e see continues to maintain a high level of performance in th's area.
The radiological waste management rea was inspected twice during the assessment period. One iolation was identified which involved the supporting proced es for the Offsite Dose Calculation Manual (00CM) not being re ised to reflect the conservative calculational methodology the ODCM.
The radiological environmental monitoring p ogram was not inspected during this assessment period.
The licensee has maintained a stable, experient staff. The personnel turnover rate within the radiological e ntrols area during this assessment period was below 25 percent. Vacancies were filled in a timely. manner with qualified person el. A well defined program for general employee training, radiat n worker training, and training for the health physics staff has been established and implemented.
No problems were identified in the radiological controls aregard and responsiveness to NRC initiatives.
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As of July, 45 contamination events had been identified. Two
incidents occurred during the assessment period that indicated the lack of initiative and control by the radiation protection department. -The first involved the failure to identify a hot particle embedded on the shirt of a worker. The worker may have taken the particle home in a shirt and the particle was not detected until several days later.when the particle was detected during a later routine personnel survey. The second involved the failure to initiate timely actions-to decontaminate a ventilation duct in the fuel building which resulted from an overflow of the back-wash tank. This condition was known to exist for several months, but no action was taken until loose contamination caused downstream effluent j monitoring to alarm.
The licensee's radiochemistry and water chemistry programs were -
inspected once during'the assessment period. Confirmatory measurements _ performed on the radiochemistry and water
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chemistry samples were found to be above expected industry 4
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averages in 97 percent agreement (radiochemistry) and 93 percent; agreement (water chemistry). The licensee's level of performance in this area during the assessment period appeared'to be at about the same level as during the previous assessment period.
The licensee's transportation program was inspected once during the assessment period. The licensee continues to maintain a high level of performance in this area.
The radiological waste management area was inspected twice during.the assessment period. One violation was identified which involved the supporting procedures for the Offsite Dose Calculation Manual (00CM) not being revised to reflect the conservative calculational methodology in the OCDM.
The radiological environmental monitoring program was not inspected during this assessment period.
The licensee has maintained a stable, experienced staff. The personnel turnover rate within the radiological controls area !
during this assessment period was below 25 percent. Vacancies 1'
were filled in a timely manner with qualified personnel. A_
well defined program for general employee training, radiation worker training, and training for the health physics staff has i been established and implemented.
No problems were identified in the radiological controls area l regarding management oversight, resolution of technical issues, and responsiveness to NRC initiatives.
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2. Performance Rating.
The licensee's performance in the area of radiological controls has shown an improving trend over the previous assessment period. No significant problems were identified in the )
radiological. controls area. The violations identified reflect a l lack of attention to detail in the radiological control area. !
The licensee is considered to be in performance Category 2 in
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this area.
3. Recommendations a. NRC Actions j
The level of NRC inspection in this functional area should I be consistent with the fundamental Inspection Program. ;
b. Licensee Action -
The licensee should continue to make improvements in the l existing program. Licensee attention should incrcise in l the detail of procedural compliance for the radiological !
control area.
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C. Maintenance / Surveillance 1. Analysis This functional area includes all activities associated with either diagnostic, predictive, preventive or corrective i maintenance of plant structures, systems, and components; procurement, control, and storage of ccmponents, including qualification controls, and installation of plant modifications; and maintenance of the plant physical condition. It includes I conduct of all surveillance (diagnostic) testing activities as well as inservice testing and inspection activities. Examples of activities included are instrument calibrations; equipment operability tests; postmaintenance, postmodification, and j postoutage testing; containment leak rate tests; water chemistry ]
controls; special tests; inservice inspection and perfonnance l tests of pumps and valves; and all other inservice inspection {
activities. ;
This area was inspected on a routine basis by the NRC resident inspectors. Inspections of the inservice program for pumps and valves, procurement, receipt and storage, and surveillance test records were conducted by region-based inspectors. ,
l One inspection of the inservice testing (IST) program for pumps l and valves was conducted. It was verified that the licensee has )
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established'an IST program in accordance with Section XI of the ASME Boiler.and Pressure. Vessel Code, 1980 Edition through '
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. Winter.1981 Addenda.- 1
.1 An inspection in the area of procurement, receipt. and storage :
of safety-related components indicated.that the licensee has an. m 1 effective system with well prepared. purchase orders. TM .;
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inspection also indicated that the receipt inspections are - 1 adequately documented with well maintained documentation'of the l component quality. . :The components were.-found to be properly '
identified while in the storage facility and that packaging, l where necessary, was as recommended or provided by the vendor. l
Onel additional-inspection of the licensee's TS required !
surveillance procedures and records was conducted by NRC
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. Region IV based inspectors toward the end of the SALP; period..
' Many of the procedures and records reviewed covered ; activities- !
s performed during the first refueling outage. * -l
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l The. licensee has improved the maintenance and surveillance !
programs at River Bend Station ~ since thellast SALP. assessment ' '
l period.' These improvements include refinement in the. i 1 maintenance and.. surveillance programs, improved communications ' a s
between the different-disciplines and an. improved level of performance from personnel performing the maintenance and '
. surveillance tasks.
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The backlog of maintenance work orders (MW0s) and preventive
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maintenance (PM) tasks has been. reduced during the past 18 months. Improvement programs including the development Lof 1
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generic maintenance job plans and optimization of preventive-maintenance by better defining the frequency at which equipment should be serviced has.apparently resulted in better; equipment
- reliability. The length of time the plant has operated in Technical Specification limiting condition for operation action statements because of equipment operability problems has I decreased since first fuel cycle operations. This is a strong j
- indicator that the maintenance program is becoming more .. 1 effective. "l l
The licensee has also completed the electrical load list for l plant equipment.as it is fed from the different electrical (
buses. This listing is proving beneficial for electrical troubleshooting and also in providing the plant operators with an easily referenced list of equipment that will be unavailable if'a bus were to be deenergized or fuse removed. j Communications between the different disciplines have improved during the past 18 months. The placement of personnel with operations backgrounds into positions of responsibility within the different organizations has been partially responsible for
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,c this.. Examples of this include the transfer of the General-
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Maintenance Supervisor to the Assistant Operations Supervisor
. position and the. addition of an Instrumentation and Control i Supervisor, who was previously-licensed as ~a senior reactor ,
operator..on this unit, and has a strong engineering and;
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operations background. Communications are also enhanced through ;
daily. meetings between the maintenance and operations- o departments to prioritize maintenance activities.1 Meetings are held' twice daily with representatives from all :the departments to discussLplant. status. g A quarterly system-outage schedule was developed during this 1
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SALP period which identifies.the' outage window a piece of equipment is scheduled to be out of service because of surveillance tests.or preventive maintenance requirements. This i outage , list is provided to the maintenance, operations, and the. 1 field and design engineering groups. This allows _ each group to schedule work, such as implementing modification requests and corrective maintenance, which requires the equipment to be out; of service. This planning schedule has greatly reduced the number of times' equipment isl taken out of service for ,
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. maintenance, modifications and testing. The licensee is .,
presently proceduralizing this program. Management attention:
should continue to be focused on this program.
Poor communications contributed to at least four events during this assessment period. The most significant eventsjinvolved maintenance activities on an inverter and reactor protection system bus, which resulted in reactor SCRAM signals being generated. The remaining two events resulted'in TS action statements being missed when'a' gas sample was not taken and a j fire watch not completed. The licensee has taken corrective actions to ensure that personnel required to' perform maintenance !
and surveillance activities are properly notified and that responsible operations personnel are informed of ongoing activities.
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The licensee has implemented addit 1unal system configuration controls partially because of events that occurred during this
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SALP period. The most significant event involved the lifted lead and jumper control program. An I&C technician failed to restore e SCRAM discharge volume level instrument following a
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surveillance test. This led the licensee to revise the independent verification process.
j The licensee's surveillance testing program appeared to be basically sound. There were a number of missed and inadequate l surveillance early in the operating cycle. However, recent j u
data indicates that problems were corrected. Management 1
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oversight in this area is evident. One example involved l untimely followup to offsite analysis of diesel fuel oil used in y
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. the. emergency diesel generators. The licensee'has modified the
. surveillance program.to formally.. track the analysis of the diesel fuel ~ oil samples. There were also' surveillance procedures which did not adequately document operability,per the ,
TS surveillance requirements. This is illustrated by the j
. failure to document the required:TS area temperature monitoring l around the reactor plant component cooling water heat exchangers and the omission of certain secondary containment doors and i hatches.
One. area of TS requirement implementation that.should receive further review' by the licensee involves a mechanism for ;
identifying:all applicable TS requirements for.a given piece of ;
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equipment or system failure. This need became' evident when a main turbine control valve failed during an operations I'
surveillance' test procedure (STP). The operators did not recognize that all the TS action requirements were not met. l This.resulted in all the actions required by the TS not
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'i immediately being taken. '
The' licensee conducted twice-per-day meetings to review required ,
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TS-surveillance tests. There was also a formal review of a limiting condition for operations report on Mondays,- Wednesdays, i and Fridays.
The staffing appeared to support the surveillance testing program. There was evidence that surveillance test personnel had been receiving appropriate training on test procedures they l were performing. However, there were some apparent deficiencies 1 in training effectiveness in that several of the test procedures were performed which contained errors that should have been identified by the personnel performing the STP but were not until after an engineered safety feature actuation occurred.
Two examples of this were isolation of.the residual heat removal j
system during shutdown (coling when alternate power was removed from a coil prior to reestablishing primary power and a reactor- .
core isolation because the STP sequence was given incorrectly. J l
Another aspect to the events which have occurred because of !
i procedural error is that the procedures are not field verified '
prior to being released for work. This has resulted in at least seven events, including the above two examples, where procedural inaccuracies have resulted in reportable events. One event-involving the alternate rod insertion system resulted in a j reactor SCRAM. Two terminal blocks within one cabinet were found to be similarly labeled. A field walkdown should have identified this condition and resulted in at least a caution statement'in the STP.
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2. Performance Rating The licensee has improved the maintenance.and surveillance programs since the last SALP period. The backlog of ,
maintenance work orders and preventive maintenance tasks has 1 been effectively reduced. There appears to be a good balance between the resources' expended, the quality achieved, and the.
-availability of-safety-related equipment and equipment important for the production of electricity.
Personnel performing maintenance and surveillance activities generally complied with procedural requirements. There were ~ j several-examples where surveillance procedures were not adequate-to direct!the activity and resulted in engineered safety, feature (ESF) actuations. Errors were incorporated into the ';
procedure during the revision process.and.not identified until after the ESF activation occurred. These ESF actuations also indicate that personnel performing.the surveillance had not { '
considered the effect their actions would have on plant systems.
The licensee.is considered to be in Performance Category 2 in this area. .i 3. Recommendations ,
l a. NRC Actions NRC inspection in this area should be consistent with.the )
Fundamental Inspection Program. Additional inspection effort should be directed towards the maintenance program, and surveillance testing during the refueling outage. ,
b. Licensee Actions f
Licensee management should take actions as necessary to j ensure that technically adequate procedures are provided i for each maintenance and surveillance activity. The !
revision process must ensure that any errors made in the {
procedure revision process are identified and corrected I before the procedure is released for work.
Communications between the disciplines should also be .]
reviewed to determine where improvements can be made.
D. Emergency Preparedness 1. Analysis This functional area includes activities related to the establishment and implementation of the emergency plan and implementing procedures, such as onsite and offsite plan J
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-17-development and coordination, support and training of onsite and offsite emergency response organizations, licensee performance during exercises and actual events that test emergency plans, administration and implementation of the plan (both during drills and actual events), notification, radiological exposure ]
control, recovery, protective actions, and interactions with l onsite and offsite emergency response organizations during i exercises and actual events. !
During the assessment period, Region-based NRC emergency preparedness inspectors and NRC contractors conducted four routine emergency preparedness inspections. One of these inspections consisted of the observation and evaluation of an emergency exercise on February 23, 1988. During the exercise, only three minor deficiencies were identified. During the other inspections, one violation and two deficiencies were identified.
The violation pertained to training weaknesses identified during j walkthroughs and interviews with the emergency response staff. I Shift operations personnel were found to be weak in their understanding of certain emergency response concepts. In a later inspection, performed during September 12-14, 1988, the NRC inspector determined that substantial improvements had been made and that these weaknesses had been corrected.
During this assessment period, a strong management commitment and involvement in program improvement has been demonstrated by the completion of corrective actions for three violations and i seven deficiencies previously identified. The licensee has consistently demonstrated a good understanding of emergency response matters, and has made timely improvements in order to ,
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maintain a high quality emergency response program.
Considerable effort has been expended by the licensee to ensure that the Emergency Plan and related implementing procedures are maintained in a proper state of readiness.
The effectiveness of management involvement and control was observed during the February 23, 1988, emergency preparedness-exercise, which demonstrated their capability to respond to emergency events. A strong commitment to provide management support to the development of a quality emergency preparedness program during this period was also evidenced by the corrective actions implemented to overhaul their entire emergency preparedness training program after the violation in the training area identified in the December 7-23, 1987, inspection.
The licensee hired independent contractors to evaluate and '
improve their training program, retrained key emergency response personnel, and is presently engaged in a comprehensive review and revision of lesson plans. Licensee management is also committed to requalify their emergency preparedness staff
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through classroom training and drills. The' licensee maintains ,
an adequate staff necessary to. implement their emergency I response program. l I
Another example of the licensee's comitment to a strong j emergency program is shown by the academic background and )
experience of the emergency preparedness staff, and in'the I amount of resources invested in various emergency. preparedness J activities, such as quality assurance audits, state-of-the-art i '
facilities, equipment, and supplies. The licensee's continued improvement is demonstrated by the ongoing project to improve the reliability of their prompt notification system with the use of computerized equipment. In addition, the licensee has l implemented and maintained an active, supportive,.and excellent working relationship with federal, state, and -local support agencies. These arrangements with offsite agencies have proven- '
to be an important contribution to the overall success of the a emergency response program.
The licensee's performance since the last SALP period has been on a positive trend in the emergency preparedness area. ,
2. Performance Rating The licensee has made steady, continuous progress in this area.
Much of the success is due to a commitment by licensee management to establish and maintain a high quality _ emergency response program. j The inspection findings for this evaluation period indicate that the licensee's emergency preparedness program is excellent and meets the requirements to protect the health and safety of the public.
The licensee is considered to be in Performance Cateogry 1 in ;
this area. .
3. Recommendations a. NRC Actions The NRC inspection effort in this area should be consistent with the Fundamental Inspection Program, b. Licensee Actions Licensee management should continue its emphasis and involvement in the emergency preparedness program.
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E. Security 1. Analysis .
l l 'This functional area includes all activities that ensure the
! security of the plant including all aspects of access control, security checks, safeguards, and fitness-for-duty activities and controls.
l. This area was inspected six times during the assessment period L by Region-based security inspectors. . Ten violations were
! identified involving equipment maintenance, compensatory measures, access control, and failure to report security events.
The licensee has established a well written physical security plan along with good implementing procedures. The plan and procedures are site specific and include sufficient detail to 1 provide proper guidance and direction for personnel responsible for implementing the security program. The plan and procedures are two of the strongest aspects of the program. The security
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department recently reorganized their intradepartmental training program including the assignment of a training officer to each shift to ensure the implementation'of commitments in the security plan. The licensee has improved the working conditions for security officers assigned to compensatory posts. Two other strengths noted were the access authorization program and audit of contractors' programs which are conducted by the security department.
Routine audits and oversight reviews are conducted regarding security department activities by the corporate quality assurance department. However, the reviews and audits have not included personnel with expertise in the security area to assist in the identification of programmatic problem areas and recommend corrective actions. When security problems have been identified, these problems have not been brought to the attention of licensee management at the proper level to initiate the necessary corrective actions. Security personnel conducting ,
- the initial screening and evaluation of security events have not always properly classified events to ensure proper followup and reporting. In several cases, licensee management did not demonstrate that there was a good understanding of security ,
issues to correct the root cause of problem areas. Management !
did not always give prompt attention to the repair of security l j
equipment which resulted in an inordinate reliance on compensatory guards. Management-reviewed security problems were j
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not always timely, thorough, or technically sound. Security event records were not always complete, well maintained, or readily available. The licensee's corrective actions for r I
self-identified violations were not always effective and the
. response to NRC initiatives has been slow. Redirection was noted in the security officer training activities, but there
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continues to be a need to improve the selection process and training requirements for both licensee and contractor security supervisory personnel.
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2. Performance Rating q Even though the licensee has a high quality security plan and procedures, the failure to ensure that the program described in the-plan and procedures was implemented has resulted in several problems._ Inattention by licensee management has also' i contributed to failure to recognize and correct problem areas.
Many of the NRC concerns discussed in this assessment period have also been identified in previous SALP reports.
The licensee is considered to be in Performance Category 3 in i this area. !
3. Recommendations a. NRC Actions The NRC inspection effort should exceed the Fundamental Inspection Program with appropriate regional initiatives.
Special emphasis should be placed on the extent of; licensee management involvement in the security program and corrective action for identified violations, b. Licensee Actions The licensee should perform an indepth assessment of the entire security program. This assessment should include individuals who have expertise in the security area to ensure that problem areas are identified and the !
recommendation of appropriate corrective action. Licensee 'l upper management should take a more active interest in the security program.
F. Engineering / Technical Support 1. Analysis The assessment of this area includes all licensee activities associated with the design of plant modifications; engineering and technical support for operations, outages, maintenance, testing, surveillance, and procurement activities; training; configuration management; and fire protection / prevention.
During the assessment period, a large number of technical issues were resolved. Twenty-five license amendments were issued. An
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additional.11. safety evaluations'on other subjects were also issued. The most significant of these activities are discussed below. i-1 The staff. found that the information submitted by the l'icensee- 1 in support of these actions were'usually technically. sound and i comprehensive. For example, in their responses .on: Generic - {
' Letter 83-28, concerning . items on system functional and i
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.postma itn enance testing, the information considered possible failures, consequ'ences, and means to avoid these situations.
A change .to trip setpoints.'for high steam line flow was made to reflect preoperational: testing results. The submittal was ]
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. consistent with staff. guidelines and addressed items needed to -
p assure safe operation.
The staff completed the review of the licensee's submittals regarding compliance with 10'CFR 50.62, the rule on anticipated ;
transients without SCRAM (A N ). The licensee's submittals addressed alternate rod instrtion, standby liquid control system,*and recirculation pump trip. The information provided by the licensee showed.a, general, understanding of the technical o issues and the submittals demonstrated compliance with the rule. l During the appraisal period, the licensee submitted and the staff approved an amendment application relating to the first fuel reload and operation for Cycle 2. The licensee's initial submittal was not complete in that fuel assemblies were to be
. loaded with enrichments higher than those in the approved version of referenced General Electric Company standard reload report. A proprietary supplement to the application was subsequently provided'in response to the staff's request which provided the additional information that was needed.
Thelicensee's.first10-yearinserviceinspection(ISI) program through Revision 2 (including relief requests) was reviewed and approved during the assessment oeriod. The licensee provided access to the Unit 2 (cancelled) reactor pressure vessel, stored on site, to assist the staff in evaluating relief requests for pressure vessel welds. The staff concluded that the River Bend Station ISI program is acceptable and in compliance with the ,
appropriate regulations. The licensee demonstrated l j
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responsiveness to NRC initiatives.
The licensee's management has provided aggressive oversight of the engineering programs as evidenced by the program and organizational changes implemented during the previous SALP period and further refined during the past 18 months. Areas where improvements have been noted include outage support, maintenance and operations support, and control over modification requests.
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supervisor who has extensive design and outage experience. An activity schedule. composed of maintenance, surveillance, and ,
design changes which require a plant outage to implement ris i continuously updated in.the event an unplanned outage occurs.
The activities which may be performed are defined by required plant mode and outage length. This system has proven to be-effective during recent' unplanned outages. Several incidents occurred during the first refueling outage which resulted in equipment being returned to service and then additional work items identified which required the system to be taken back out of service. The addition of the experienced ' shift supervisor to .
the outage group should help.to alleviate this. type of 1
. occurrence during the refueling outage scheduled for March 1989.
The licensee demonstrated that they were able to address. ,
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technical issues within a short time span during the-first l refueling outage. Examples of this included rerouting the reactor core isolation coolant system line break detection instrumentation reference line, addition of antisiphon holes to the upper and lower fuel pool cooling and purification lines, l
and the analysis as reasonably needed achievable to hang)
(ALARA radiation conditions. shielding There were . for as low !
approximately 200 modification requests (MRs) completed during j the first refueling outage. Engineering personnel are providing l regular support to the maintenance and operations organizations.
This has usually resulted in timely responses to issues and events which have occurred. An engineer has been provided to operations on a full time basis to assist with daily operations.
This individual is a licensed senior reactor operator.
The licensee has also tasked several engineers with responsibility for specific plant systems. These system engineers are responsible for the design modifications and the inservice testing inspection program for their assigned system.
The use of system engineers has provided an additional level of expertise to ensure each system is maintained operable. The licensee is providing selected engineers with the training required to become senior reactor operators. This licensed operator training for the engineers is providing several benefits which enhance plant safety. These benefits have '
included better communications between operations and the engineering department as well as providing first hand knowledge of the types of operational problems that are experienced during normal operations. There are however, a few system engineers who do not fully understand the design and associated documents applicable to their system. Enhanced system training for these individuals would be appropriate.
During the SALP period, the licensee initiated approximately 600 modification requests (MRs) as compared to approximately
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! 2200 MRs during the previous SALP period. The number of MRs l which are generated each day has continued to decrease as lessons learned during the initial startup and first fuel cycle operations are incorporated into the plant physically or through
. document changes. In March of 1988, the licensee reviewed the i
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status of MRs which were open for work and that had been requested. At this time the MRs were prioritized to best .
reflect current plant design needs. A shift supervisor has been '
added to the engineering departmen.t and serves on the work scope I committee to provide an operations view of the necessity for
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each MR. !
Even though operations provided input'to the work scope committee, two instances involving the fuel and control building-emergency ventilation systems were identified where MRs were .
cancelled, even though adequate corrective actions for the event 1 '
had not been taken. This led to an apparent violation of NRC requirements which is presently being reviewed to determine the appropriate level of enforcement action.
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The licensee has improved their program for ensuring prompt MRs !
are completed by the cancellation date or extended engineering !'
. management personnel now review all PMRs periodically to ensure they are current.
In the area of engineering and technical support of procurement activities, an inspection indicated that both the engineering and quality organizations may be confused by definitions of what is safety grade versus non-safety grade of components purchased as commercial grade. The inspector found that there were conflicting definitions contained in procedures and subsequent discussions with engineering personnel did little to clarify the matter. It should be noted that the inspector did not identify any specific item affected by the confusion during the course of i the inspection.
I The environmental qualification (EQ) program was reviewed and the results indicated that the licensee has established an EQ program within the scope of 10 CFR 50.49. This program is well integrated into the EQ activities at.the plant. The four .
violations identified were related to supporting documentation and did not represent the use of unqualified equipment.
Several design and equipment problems were identified which required engineering support. The engineering staff has provided consistently good support to resolve identified problems. Examples include analysis for missile protection on the standby cooling water tower, modification to the stator cooling water system, reductions in radiation monitor spiking-and present analysis of problems with service water chemistry on heat exchangers.
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- The'NRC staff reviewed the licensee's fire protection program'on two separate occasions dur.ing this assessment period.. The licensee has developed an' effective program for fire protection.
Concerns which were, raised durin q
'have been adequately' addressed. g the initialdid The-licensee startup identifyperiod-
- several cases where fire seals were not installed as required.'
These fire' seal omissions occurred during'initialfplant- -
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construction and were not identified during that period because l of'an error inLidentifying .the need for. the fire seal. The-licensee relies on fire watches for TS compliance lin many cases. l This reliance on fire watches provided -the necessary personnel. !
coverage for the' areas where the fire ~ seals were .not installed- 1 l
prior to the_ missing fire seals being discovered..
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The licensee's ; training program for licensed and. non-licensed:
staff:was assessed on a' continuing basis by the~ resident
' inspectors and severa1' independent inspections by the NRC
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regional staff.
During the appraisal period, licensing examinations were administered by the NRC. Fourteen reactor operator-(RO)
examinations were administered with 10 passing. Eleven senior reactor operator (SRO) examinations were administered with-9 passing. This has resulted in a total of 21 R0 and 34 SR04 licensed individuals.
The licensee has maintained a well qualified training staff.
Many of the licensed operator instructors have extensive operations background with others being licensed on this plant.
Inspections into nonlicensed staff training indicated good coordination between the plant organizations and the training department. Excellent use of on-the-job training is utilized to provide experience and familiarity to employees._ Very few errors resulting from training deficiencies were noted during-this assessment period.
Training for engineering personnel was reviewed and an effective course on 10 CFR 50.59 reviews has been developed and provided to all engineers. Environmental qualification training in a formal classroom setting has also been provided. There were however weaknesses in the EQ training program in that some qualification records for personnel were not adequately _
-documented.
The training programs have generally been well defined and implemented. Means have been established to provide feedback of experience from both within and outside the utility. The training. department has demonstrated an attitude for self improvement and has implemented lessons learned back into the lesson plans.
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Full accreditation of the licensee's training program by the.
Institute of Nuclear Power Operation (INPO) was received during this SALP period.
2. Performance Rating The licensee has demonstrated an aggressive oversight of the engineering programs. Modification requests are being more effectively. prioritized.
The environmental qualification (EQ) program appears to have i i
been adequately implemented, however deficiencies in documenting EQ determinations were identified.
An effective training program has been implemented at River Bend Station. The' training and qualification effectiveness is evident with no trend of personnel-related problems and few reported personnel errors. .
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The licensee is considered to be in Performance Category 1 in i this area.
i 3. Recommendations
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a. NRC Actions The NRC inspection effort in this area should be consistent with the Fundamental Inspection Program. In addition, an
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cutage modification inspection should be scheduled during the second refueling outage. Special emphasis should be placed on the nonlicensed operator training programs.
b. Licensee Action The licensee should continue to provide the management oversight which has improved technical support for operations and maintenance. Modifications must be closely
- scrutinized to ensure that MRs are not cancelled which would enhance safety system reliability.
Management attention over the EQ program should be maintained to ensure EQ determinations are properly i supported and documented.
Continuing training for the technical staff should be provided to ensure that engineering decisions do not adversely affect safe operation of the plant.
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'G. Safety Assessment / Quality Verification 1. ' Analysis The assessment of this functional area included all. licensee
. review activities' associated with the implementation of. licensee.
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safety: policies; licensee activities related to amendment,
! exemption and relief requests; response to generic-letters, bulletins'and information notices; and resolution of TM1 items and other regulatory initiatives. .It also included activities related to the' resolution of safety issues, 10 CFR 50.59 6 reviews, 10'CFR 21 assessments, safety committee and .. ..
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self-assessment activities, analyses of industry's operational-experience, root _cause analyses-'of plant events, use of.-feedback-
'from plant QA/ quality control (QC)' reviews, and. participation in self-improvement programs. ..It included the effectiveness of the-licensee's' quality verification' function in. identifying and.
correcting substandard or anomalous performance, in identifying precursors of potential problems, and in monitoring .the 'overall performance of. the plant.
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A number of licensing actions were' completed during the assessment period on a variety.of subjects including several of
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the TS changes related to a one-time extension on-' surveillance interval tests. These changes were required since the T5 specified an.18-month, rather than a refueling cycle, interval and the. cycle length was extended. 1 Throughout this assessment period,' the licensee demonstrated adequate management, sound technical' approaches to resolution of
' licensing ~ 1ssues, and generally responsive and timely resolutions to NRC concerns. Management involvement was evident in the planning and' assignment of priorities. The licensee appeared to' keep abreast of technical resolutions of other lead plants in implementing requested changes and is frequently involved in owners group programs. 1 i
In the case of the diesel generator testing during limiting conditions of operation when one or both offsite circuits are 'i inoperable, the staff denied the changes requested by the licensee. However, their submittal did demonstrate understanding of the technical issues and licensee safety .
I perspective on possible problems relating to paralleling a diesel with an offsite source. ;
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During the rating period, the staff completed its review of the licensee's compliance with the anticipated transient without l SCRAM rule (10 CFR 50.62). The staff found that sound approaches were taken to ensure that applicable requirements were met. The licensee was also responsive to requests from the i I
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lDuring the rating period, the staff approved _ the first 10-year :
inservice inspection program (including relief , requests).
ManagementLinvolvement and control in assuring quality were apparent. The program submittals were technically sound and exhibited a conscientious effort to comply with the' regulations.
Responses to' staff questions were timely.
'The NRC staff has conducted several. reviews'of the licensee's program for-evaluating 10 CFR Part 21 reports, NRC information notices, NRC Bulletins,' and generic letters. It was found thatz reviews are being conducted in a timely manner.
The licensee has been responsive to generic letters and NRC-bulletins. 'The response.to Bulletin 88-01 indicated that the licensee did not' utilize any of the Westinghouse circuit breakers, subject to the bulletin, in Class 1E service. The licensee's 120-day response.to Bulletin 88-05 indicated that they have completed the hardness testing of the 535 installed
- and accessible flanges subject to the bulletin. The results of the tests are included with the response. Recent responses _were also received in response to Bulletins 88-04, " Potential 'j" Safety-Related. Pump Loss;" 88-07, " Power Oscillations in Boiling Water Reactors;"'and 88-08, " Thermal Stresses in Piping
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Connected to Reactor Coolant Systems." -These latter responses are under staff. review. In addition, the licensee has responded
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o to Generic Letter 88-01, NRC Position on intergranular stress corrosion cracking in BWR Austenitic Stainless Steel Piping.
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The licensee's submittals were provided near the due dates and a were responsive.. Bulletin 88-05 required extensive licensee effort to identify questionable flanges, obtain hardness readings, and provide justifications for continued operation for flanges failing the acceptance criteria. 'The licensee established and maintained a well organizeJ program to satisfy the concerns of the bulletin. !
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In the area of the effectiveness of the quality verification ,
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function in identifying and correcting substandard or anomalous performance, the licensee has developed and implemented an excellent system for reporting such conditions through
" Condition Reports." The licensee strengthened their corrective action program'in June 1988, by implementing an upper tier ;
document which describes the measures and delineates the requirements and responsibilities for implementing the River i Bend Station corrective action program. This action was taken
'following a violation issued on failure of timely followup review to verify corrective action completion.
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-28-The licensee's corrective actions are usually extensive and directed at identifying other conditions which may result because of the root cause. It was because of this extensive corrective action program that the drywell pressure instrument was found isolated during the first refueling outage. The licensee had committed to perform a 100 percent review of all safety-related valves in the plant prior to completion of the refueling outage. This action was taken in response to identifying the reactor core isolation cooling (RCIC) system leak detection root valves closed. Another example involved the corrective actions taken following identification that the fuel building ventilation charcoal filters were deenergized. The licensee developed an additional procedure for verifying proper control board lineup prior to a plant mode change. The licensee also documents proper system lineups on safety-related systems following system manipulation during operations.
An inspection of the licensee's corrective action program has indicated that additional licensee attention should be given to assure that timely corrective action is taken in response to reports.
The licensee's management has demonstrated the initiative to ensure the plant is operated in a safe manner. During the first refueling outage, the licensee recognized that all activities were not being co @ cted in a " safety-first" manner. The licensee stopped all refueling activities and functionally reorganized the outage department to ensure activities were coordinated through operations.
The resident inspectors have observed the Facility Review Committee (FRC) on several occasions during this SALP period.
It was noted that in each case the licensee reviewed the safety significance and directed the necessary resources to identifying the root cause for a given problem. Two of the FRC meetings involved reactor SCRAMS which were not completely understood initially. The FRC delayed startup on these two occasions until they were satisfied that they understood why the plant performed as it did and that any required corrective actions had been completed.
The NRC inspectors have reviewed several quality assurance (QA)
audits and found the audits to be complete and directed at safety issues. A design control audit was conducted by the licensee during the refueling outage which was in part, modeled after a safety system outage modification inspection (SS0MI).
One violation was identified regarding QA controls removed from a procurement document. This document had implemented required 10 CFR 50 Appendix B controls for procurement of diesel fuel oil used in the emergency diesel generators. An inspection of the
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' QA personnel: qualifications found the individuals- to.be a dequately qualified for the positions they, held.-
i The operations QA organization has been; improved through the.
. addition of personnel with operations experience. QA personnel'
have been and are presently participating,in the licensed -
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operator-training program and .one individual has been certified:
on this. facility. The operations QA organization'has been-effective in supplementing the .QA audit. program.
The licensee has made effective use of the Independent Safety Engineering Group (ISEG)'in evaluating in part,' industry
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operational events, licensee event reports, condition report trends, and SCRAM analysis.- The ISEG is. composed of individuals familiar with plant systems' and operations. Several individuals-
-have been licensed or are in train.ing to be licensed on this facility.
2. Performance Rating The . licensee has responded in a timely manner and utilized -
' technically-sound approaches to NRC staff concerns. . Management involvement has been apparent in' determining priorities.
Corrective. actions have usually been extensive and directed.at-i the root cause. ,
Quality, assurance (QA) audits have mo'stly been effective in identifying issues. Operations'QA has supplemented the QA audit program by ensuring that critical programs are reviewed on a more frequent basis. The surveillance'are based in part on previous findings. l The licensee is considered to.be in Performance Category 1-in this area.
3. Recommendations, a. NRC Actions Inspection activities should be maintained consistent with the Fundamental. Inspection Program. In addition, selected a Regional Initiative Program inspections should be conducted in the area of corrective actions, and event trending to identify potential problems.
J b. Licensee Actions Licensee management should continue to asses the corrective action ~ program to ensure'that timely corrective actions are i taken and the root cause identified for the conditiun or failure' described. The scope of quality assurance audits [
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V. Supporting Data and Summaries A. Enforcement Activity l The SALP Board reviewed the enforcement history for the period !
April 1,1987, through September 30, 1988. This review included the deviations, violations, and emergency preparedness deficiencies l
. tabulated by SALP category in Table 1. No civil penalty was issued with the one severity level 3 violation because of the-licensee's-extensive corrective actions. Special Inspection Report-50-458/88-22 was issued at the end of this SALP period and is being considered for potential enforcement action by the NRC staff.
B.- Confirmation of Action Letters None q C. 10 CFR Part 21 Reports Submitted by Licensee Three.10 CFR Part 21 reports were submitted by the licensee during j this SALP period. The 10 CFR Part 21 reports were:
o 11/16/87 - Failure of rotor winding on a Transamerica Delaval (presently IM0 Delaval)/NEI Peebles - Electric Products diesel generator.
.i o 12/23/87 - Defective wire terminations for heater circuit in Fuel Building Ventilation chercoal filters.
o 01/19/88 - Oversized lugs for motor leads identified in Limitorque SMB-4 operators.
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- TABLE 1.
ENFORCEMENT ACTIVITY NO. OF VIOLATIONS ENFORCEMENT.
FUNCTIONAL IN SEVERITY LEVEL ACTION AREA- DEF DEV V IV III II -NOT ISSUED A. Plant Operations 4(2) 1 (1)'
B. Radiological Controls 3 ,
C. Maintenance / Surveillance 4 2 D. Emergency Preparedness 2 1
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'E. Security 2 8 F. . Engineering / Technical Support -7 (1)
G. . Safety Assessment / Quality Verification 3 1(3)
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TOTAL 2 0 9 .24 1 0 Footnotes:
1.. Enforcement action for fuel building ventilation system inoperable under review by NRC staff.
2.- One'of three violations is also listed under Eng'ineering/ Technical' Support and is.therefore not included for enforcement activity total.
'3.: This violation is also listed for plant operations and is therefore not.
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g, ENCLOSURE 2
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SALP Meeting Summary ' ,
Date: January 11, 1989
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Licensee: GulfJStates Utilities. ,
Facility:- River Bend Station I License: NPF-47 Docket No.: 50-458 j
' Subject: SALP MEETING AT RIVER BEND ,
On January 11,-1989, the Regiohal Administrator, NRC Region IV, members of the Region _IV staff, and NRR representatives met with Gulf States Utilities-representatives in an open meeting at River Bend to discuss the SALP board i report covering the-period. April 1,1987, through September 30, 1988. The NRC j material presented at the meeting and a list of attendees are attached. The 1 '
meeting was held at the request of NRC Region IV.
After opening remarks by the'Regiona1' Administrator, the Deputy Director, Division of Reactor Projects, presented each of the functional areas evaluated in the SALP board report using Attachnent 1 as an outline.- The LP&L Senior Vice President for Nuclear Operations and other licensee representatives discussed planned actions to improve performance and/or respond to NRC recommendations in each of the SALP categories.
. Attachments: 1
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1. NRC Material Presented at Meeting 2. Attendance List
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- ATTACHMENT 1
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AGENDA-INTRODUCTION. ROBERT D. MARTIN, REGI0'ALN ARlINISTRATOR,-'NRC REGION IV SALP PRESENTATION BILL BEACH, DEPUTY DIRECTOR, DIVISION OF REACTOR PROJECTS,
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NRC REGION IV GULF STATES UTILITIES LICENSEE MANAGEMENT AND STAFF RESPONSE AND COMENTS CLOSING REMARKS ROBERT D. MARTIN
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' UNITED STATES NUCLEAR REGULATORY C0ffilSSION-
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SYSTEMATIC-' ASSESSMENT OF. LICENSEE PERFORMANCE
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EETING GULF STATES UTILITIES RIVER END-STATION .
APRIL 1,11987 - SEPTEMBER 30,1988
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AT-RIVER BEND STATION JANUARY-11,1989
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SALP PROGRAM OBJECTIVES
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IMPROVE LICENSEE PERFORMANCE PROVIDE A MECHANISM FOR FOCUSING ATTENTION
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PROVIDE A BASIS FOR ALLOCATION OF NRC RESOURCES IMPROVE NRC REGULATORY PROGRAM
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t PERFORMANCE ANALYSIS AREAS FOR RIVER EEND STATION ,
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- 1.. PLANT OPERATIONS ~
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3. MAINTENANCE / SURVEILLANCE
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5. SECURITY 6. ENGINEERING / TECHNICAL SUPPORT
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7. SAFETY ASSESSENT/0UALITY VERIFICATION
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FUNCTIONAL AREA PERFORMANCE CATEGORY CATEGORY 1-
-LICENSEE MANAGEMENT ATTENTION AND INVOLVEE NT ARE READILY EVIDENT AND PLACE EMPHASIS ON SUKRIOR KRFORMANCE OF NUCLEAR SAFETY OR SAEG'ARDS U ACTIVITIES, WITH THE RESULTING WRFORMANCE SUBSTANTIALLY EXCEEDING REGULATORY REQUIREMENTS.
LICENSEE RESOURCES ARE AMPLE AND EFFECTIVELY USED S0 THAT A HIGH LEVEL OF PLANT AND W RSONNEL WRFORMANCE IS BEING ACHIEVED. REDUCED NRC ATTENTION MAY BE APPROPRIATE. j
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i CATEGORY 2
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LIENSEE MANAGEENT ATTENTION TO AND INVOLV9ENT IN THE i
- E RFORMANCE OF NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES ARE :
GOOD. THE LICENSEE HAS ATTAINED A LEVEL OF RFORMANE ABOVE
THAT NEEDED TO MEET PEGULATORY REQUIR9ENTS, LICENSEE RESOURES ARE ADEQUATE AND REASONABLY ALLOCATED SO THAT GOOD PLANT-AND ERSONNEL KRFORMANCE IS BEING ACHIEVED. NRC ATTENTION MAY BE
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MAINTAINED AT NORMAL LEVELS.- )
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LIENSEE MANAGEMENT ATTENTION TO AND INVOLVEMENT IN THE PERFORMANE OF NUCLEAR SAFETY OR SAFEGUARDS ACTIVITIES-ARE NOT SUFFICIENT THE LICENSEE'S PERFORMANE DOES NOT SIGNIFICANTLY EXCEED THAT NEEDED.T0 MEET MINIMAL REGULATORY REQUIREMENTS. LICENSEE RESOURES APPEAR-TO BE STRAINED OR-
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NOT EFFECTIVELY USED, NRC ATTENTION SHOULD~BE INCREASED AB0VE NCRMAL LEVELS, i
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EVALUATION CRITERIA 1. ASSURANCE OF. QUALITY, INCLUDING MANAGEE NT INVOLVETf6 AND CONTROL 2. APPROACH TO IDENTIFICATION AND RESOLUTION OF TECHNICAL ISSUES FROM A SAFETY STANDPOINT ,
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3, RESPONSIVENESS TO NRC INITIATIVES j q
4.- ENFORCEN NT HISTORY 5, O ERATIONAL EVENTS (INCLUDING RESPONSE T0, ANALYSIS OF, REPORTING OF, AND CORRECTIVE ACTIONS FOR)-
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6. STAFFING (INCLUDING MANAGEENT) !
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7. EFFECTIVENESS OF TRAINING AND QUALIFICATION PROGRAM l
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STPENGTHS ,
- p STRONG MANAGEMENT INVOLVEMENT THAT HAS RESULTED IN: !
EXTENSIVE CORRECTIVE ACTIONS AND ROOT CAUSE ANALYSIS'
WHEN PROBLEMS ARE IDENTIFIED
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STRONG' COOPERATIVE SPIRIT.IN' APPROACH T0, PROBLEMS
EXCELLENT SAFETY ATTITUDE EXHIBITED BY OPERATIONS PERSONNEL INDIVIDUALS WITH OPERATIONS AND MAINTENANCE EXPERIENCE PLACED IN OTHER ORGANIZATIONS TO PROVIDE OPERATIONS EXPERTISE-THROUGHOUT THE-ORGANIZATION EXCELLENT ENGINEERING AND TRAINING PROGRAMS EXCELLENT EfERGENCY PREPAREDNESS PROGRAM-STRONG ALARA PROGRAM OPERATIONS TRAINING PROVIDED TO SEVERAL INDIVIDUALS IN THE ENGINEERING AND CUALITY VERIFICATION ORGANIZATIONS j
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, LWEAKNESSES JJ
SECURITY PLAN NOT PROW RLY IMPLEENTED INCLUDING: {
SECURITY TRAINING
REVIEW AND' CLASSIFICATION 0F EVENTS
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LACK OF EFFECTIVE AUDIT OF' SECURITY PROGRAM
MAINTENANCE OF SECURITY EQUIPENT
. SURVEILLANCE TEST PRCCEDURE REVIEW PROCESS IS-SCETIES WEAK, LEADING-TO UNNECESSARY SYSTEM CHALLENGES AND ESF ACTUATIONS AN EXCELLENT SAFETY ATTITUDE BY 0WRATIONS WRSONNEL
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OCCASIONALLY MARRED BY A LACK 0F AR ENTION-TO DETAIL DURING PLANT 0 RATIONS u
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PLANT OPERATIONS CATEGORY 2 THE LICENSEE HAS DEMONSTRATED ITS ABILITY TO EFFECTIVELY OPERATE E E PLANT DURING THIS ASSESSENT PERIOD HIGH LEVEL OF PROFESSIONALISM EXHIBITED BY PLANT OPERATIONS STAFF OPERATORS HAVE DEMONSTRATED AN INCREASED OVERALL UNDERSTANDING OF PLANT SYSTEMS AND PROCEDURES l
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TRANSIENTS OBSERVED OR REVIEWED BY NRC HANDLED IN A PROFESSIONAL, SYSTEMATIC MANNER BY PLANT OPERATORS i PLANT MANAGEMENT FREQUENTLY OBSERVED BY NRC THROUGHOUT PLAfff FOUR AREAS, HOWEVER, WHERE ADDITIONAL MANAGEMENT ATTENTION IS REQUIRED WERE IDENTIFIED IN THIS ASSESSMENT PERIOD:
C0 mVNICATIONS WITH OTHER DEPARTMENTS
ATTENTION TO DETAIL DURING SHIFT TURNOVERS AND PLANT l
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' OPERATIONS
CONFIGURATION CONTROL
PROCEDURAL ADEQUACY l
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fEC.0 MENDED LICENSEE ACTION THE LICENSEE SHOULD PEVIEW METHODS FOR IMPROVING COMMUNICATIONS 1
BEThEEN THE PLANT OPERATIONS AND THE SUPPORT ORGANIZATIONS TO ENSURE
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BAT THE RESPONSIBLE GROUPS ARE AWARE OF PLANT STATUS. THE LICENSEE l
IS ALSO ENCOURAGED TO STRESS THE IMPORTANCE OF ATTENTION TO DETAILS AND THE IMPORTANCE OF HAVING ADEQUATE PROCEDURES TO DIRECT AN l '
ACTIVITY, THE CONFIGURATION CONTROL PROGRAM SHOULD ALSO CONTINUE TO t
EE CLOSELY MONITORED TO ASSURE PROPER IMPLEMENTATION FOR PLANT SYSTEM CPERATION LINEUPS. [
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RADIOLOGICAL CONTROLS
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CATEGORY 2 LICENSEE'S PERFORMANCE IN THIS AREA HAS SHOWN AN' IMPROVING TREND, AND AN AGGRESSIVE ALARA PROGRAM WAS IMPLEEtHED STABLE, EXPERIENCED STAFF HAS BEEN MAINTAINED, AND'A'WELL- 1 DEFINED TRAINING PROGRAM HAS BEEN ESTABLISHED AND IMPLEE NTED TWO INSTANCES IDENTIFIED THAT INDICATED A LACK 0F ATTENTION TO ,
DETAIL IN IMPLEE NTATION OF THE OCCUPATIONAL RADIATION SAFETY l PROGRAM
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CONTROL OF CONTAMINATION NOT ALWAYS EFFECTIVE OR TIMELY AS l INDICATED BY TWO CONTAMINATION EVENTS 1
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REC 0 MENDED LICENSEE ACTION 1 1 '
THE LICENSEE SHOULD CONTINUE TO MAKE IMPROVEE NTS IN THE
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EXISTING RADIOLOGICAL CONTROL PROGRAM.. LICENSEE MANAGEENT SHOULD INCREASE ITS ATTENTION.TO DETAIL TO ENSURE PROCEDURAL i COMPLIANCE AND THE CONTROL OF CONTAMINATION FOR THE RADIOLOGICAL l CONTROLS FUNCTIONAL AREA, ;
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MAINTENANE/ SURVEILLANCE CATEGORY.2 l
' PROGRAMS-AND PERFORMANE HAVE IMPROVED SINCE LAST SALP PERIOD', AND d MANAGEMENT OVERSIGHT IS EVIDENT j u
BACKLOG OF MAINENANE WORK ORDERS AND FREVENTIVE MAINTENANE TASKS HAS BEEN REDUED
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EFFECTIVE PROCUREENT SYSTEM INCLUDING REEIPT AND STORAGE ADDITIONAL CONFIGURATION CONTROLS IMPLEENTED IN RESPONSE TO !
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EVENTS POOR C0ft1UNICATIONS CONTRIBUED TO AT LEAST FOUR EVENTS IN THIS FUNCTIONAL AREA !
FOOR REVIEW PROCESS FOR REVISING SURVEILLANCE PROCEDURES LED TO UNNECESSARY SYSTEM CHALLENGES AND ESF ACTUATIONS. IN ADDITION, THE FAILURE TO FIELD VERIFY THE PROCEDUPES PRIOR TO BEING RELEASED
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REC 0ft1 ENDED LIENSEE ACTION 1 LICENSEE MANAGEMENT SHOULD TAKE ACTIONS, AS NECESSARY, TO ENSURE 1 THAT TECHNICALLY ADEQUATE PROCEDURES ARE PROVIDED FOR EACH !
MAINTENAN E AND SURVEILLANCE ACTIVITY. THE REVISION PROESS i MUST ENSURE THAT ANY ERRORS ARE IDENTIFIED AND CORRECTED BEFORE 1
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THE PROCEDURE IS PELEASED FOR WORK.
COMMUNICATIONS BETWEEN THE DISCIPLINES SHOULD ALSO BE REVIEkED TO DEERMINE WHERE' IMPROVEMENTS CAN BE MADE.
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EMERGENCY PREPAREDNESS jj CATEGORY 1
. STRONG MANAGEENT-COMITENT- i INDEPENDENT CONTRACTORS USED TO EVALUATE AND IMPROVE TRAINING EXPERIENCED EERGENCY PREPAREDNESS STAFF LARGE INVESTE NT IN STATE-0F-THE-ART FACILITIES AND EQUIPE NT
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EXCELLENT WORKING RELATIONSHIP WITH FEDERAL, STATE, AND LOCAL SUPPORT AGENCIES !
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REC 0 MENDED LICENSEE ACTI0ff l
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LICENSEE MANAG9ENT- SHOULD CONTINUE ITS EMPHASIS AND l
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l l: ~ SECURITY l CATEGORY-3 l
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DECLINE IN OVERALL PERFORMANCE DURING THIS RATING PERIOD HIGH QUALITY SECURITY-PLAN'AND PROCEDURES, BUT POOR-IMPLEMENTATION OF PROGRAMS AND PROCEDURES l FAILURE OF MANAGEMENT TO RECOGNIZE AND CORRECT PROBLEMS IN A l TIELY. MANNER FAILURE OF MANAGEMENT TO GIVE PROMPT ATTENTION TO THE REPAIR OF .
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SECURITY EQUIPfENT WHICH RESULTED IN AN INORDINATE RELIANCE ON COMPENSATORY-GUARDS I REVIEW AND CLASSIFICATION OF EVENTS BY SECURITY MANAGEENT NOT ALWAYS APPROPRIATE j REVIEWS AND AUDITS HAVE NOT INCLUDED PERSONNEL WITH SECURITY EXPERTISE MANY OF THE PROBLEMS IDENTIFIED HAVE BEEN DISCUSSED IN PREVIOUS SALP REFORTS REC 0 WENDED LICENSEE ACTION THE LICENSEE SHOULD PERFORM AN INDEPTH ASSESSENT OF THE ENTIRE SECURITY PROGRAM. THIS ASSESSMENT SHOULD INCLUDE INDIVIDUALS !
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WHO HAVE EXPERTISE IN THE SECURITY AREA TO ENSURE THAT PROBLEM-AREAS ARE IDENTIFIED AND THE RECOWENDATION OF APPROPRIATE .j CORRECTIVE ACTION, j l
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CATEGORY 1
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AGGRESSIVE MANAGEMENT OVERSIGHT OF ENGINEERING PROGRAMS HAS RESULTED IN IMPROVE E NTS IN OUTAGE SUPPORT, MAINTENANCE AND OPERATIONS SUPPORT, AND CONTROL OVER MODIFICATION REQUESTS j IMPROVED OUTAGE ACTIVITY SCHEDULE i I
DEMONSTRATED-ABILITY TO PROMPTLY AND COMPETENTLY ADDRESS 1 TECHNICAL ISSUES IN A SHORT PERIOD OF TIE THE USE OF SYSTEM ENGINEERS HAS PROVIDED-AN ADDITIONAL LEVEL OF EXPERTISE TO ENSURE EACH SYSTEM IS MAINTAINED OPERABLE AND HAS IMPROVED C0FNUNICATIONS BETWEEN OPERATIONS AND THE ENGINEERING STAFF. l TRAINING FOR ENGINEERING PERSONNEL HAS BEEN DEVELOPED AND PROVIDED WELL QUALIFIED TRAINING STAFF WITH LICENSED OPERATOR INSTRUCTORS WHO HAVE E)GENSIVE OPERATIONS EXPERIENCE l ENVIRONMENTAL QUALIFICATION (E0) PROGRAM ADEOUATELY IMPLEENTED, lI ALTHOUGH SOE DEFICIENCIES IN DOCUE NTING EQ DETERMINATIONS WERE IDENTIFIED.
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RECOMTNDED LICENSEE ACTION I
THE LICENSEE SHOULD CONTINUE TO PROVIDE THE MANAGENNT OVERSIGHT WHICH HAS IMPROVED TECHNICAL SUPPORT FOR OPERATIONS AND MAINTENANCE.
l MANAGEMENT ATTENTION OVER THE EQ PROGRAM SHOULD BE MAINTAINED l
TO ENSURE E0 DETERMINATIONS ARE PROPERLY SUPPORTED AND DOCLPENTED.
CONTINUING TRAINING FOR THE TECHNICAL STAFF SHOULD BE PROVIDED l i
TO ENSURE THAT ENGINEERING DECISIONS DO NOT ADVERSELY AFFECT SAFE OPERATION OF THE PLANT. !
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, SAFETY-ASSESSMENT /0UALITY VERIFICATION
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CATEGORY'l l
STRONG' SENIOR MANAGBENT INVOLVEMENT IN NURTURING A SAFETY ATTITUDE j EXCELLENT SYSTEM FOR IDENTIFYING AND CORRECTING PROBLEMS
' CORRECTIVE ACTIONS USUALLY ESTENSIVE AND PROKRLY FOCUSED ON IDENTIFYING.
AND CORRECTING ROOT CAUSES OA AUDITS ARE EFFECTIVE AND DIRECTED AT SAFETY ISSUES QA W RSONNEL PARTICIPATING IN LICENSED OPERATOR TRAINING PROGRAM EFFECTIVE USE OF ISEG - COMPOSED OF INDIVIDUALS FAMILIAR WITH PLANT SYSTEMS AND OPERATIONS j
LICENSEE REC 0ftENDED ACTION LICENSEE MANAGEMENT SHOULD CONTINUE TO ASSESS THE CORRECTIVE ACTION PRCGRAM TO ENSURE THAT TIELY CORRECTIVE ACTIONS ARE TAKEN AND TE ROOT CAUSE IDENTIFIED FOR THE CONDITION OR FAILURE DESCRIBED. -THE SCOPE OF QUALITY ASSURANCE AUDITS AND SURVEILLANCE SHOULD BE REVIEWED TO ENSURE THAT WEAKNESSES IN AREAS'SUCH AS SECURITY ARE IDENTIFIED AND PROMPTLY CORRECTED, i
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' ATTACHMENT 2 ATTENDANCE LIST
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.R. NRC - RIV R. L. Bangart =NRC - RIV 1 A.;B. Beach NRC'- RIV !
J. A. Calvo NRC - NRR-J. P. Jaudon NRC - RIV l J. T. Gilliland NRC - RIV.
W. A. Paulson NRC - NRR ;
G. L. Constable NRC - RIV E. J. Ford NRC - RIV W. B.' Jones NRC - RIV G..G. McNamee- NRC - RIV-J. C. Deddens GSO.
J. E. . Booker GSU i T. F. Plunkett
GSU W. H. Odell GSU T. L..Crouse CSU M. F._Sankovich GSU K. E. Suhrke GSU L. A.' England GSU 4 Gen.R.H.Berrow,USMC(Retired) GSU J. J. Pruitt GSU W. L. Benedetto GSU L. F. Gilbert GSU T. H. Pigford GSU Consultant GSU Consultant j
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H. H. Woodson J. E. Smith GSU Consultant'
L. G.-Johnson Cajun Electric J. M. Miller Cajun Electric J. Minton Capital City Press H. A. Plettinger Public Citizen
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i i :: x_ ~4 ENCLOSURE 3
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~py GULF STATES UTILITIES COMPANY mn enwuo w4 - .. e -
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February 10, 1989 l RBG- 30026 . 1 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U. S. Nuclear Regulatory Commission t Region IV. ,
611 Ryan' Plaza Drive, Suite 1000 .)
Arlington, TX 76011
Dear Mr. Martin:
River Bend Station - Unit 1 Docket No. 50-458 This letter represents Gulf States Utilities Company's (GSU) response'to the !
Systematic Assessment of Licensee Performance (SALP) Inspection Report ;
50-458/87-32 covering the period April 1, 1987 through September. 30, 1983. j GSU appreciates the NRC's comments on the .SALP process. and the insights provided into your assessments given at the meeting held January 11, 1989 at i River Bend Station. l l
As the executive in charge of River Bend Station, I find the Category 3 1 rating in Security to be unacceptable. I will assure that appropriate corrective actions are taken to restore and maintain a high level of performance in this area.
GSU has started an indepth assessment of Security utilizing outside persons with nuclear-security expertise. This assessment was planned. prior to the
- SALP report and has been strengthened as a result of meetings with your i staff. The assessment will not be limited to the areas indicated in the SALP report but will also include any area of security program implementation which the audit team feels should be examined.
In addition, I have directed executives of Burns International Security, our _,
security contractor, to conduct an independent assessment of the security j program operations and report to me their findings and recommendations, i Based upon all of these reports, in addition to those actions already taken, l I will formulate and implement appropriate actions necessary to improve this l functional area. l Corrective action and management attention has been directed toward the repair of security equipment in a timely manner. Steps have been taken to ensure that repairs to security equipment are completed on a high priority basis when compensatory officers are necessary or compliance with the security plan is affected. These actions include placing modifications in ,
" fast-track" and the assessment and assignment of the proper priority for )
maintenance actions. g n _.7 n s j
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l As soon as the details can be worked out, we are planning to assign maintenance technicians. directly to Security so that Security may direct the efforts in prioritizing work with dedicated maintenance personnel.
Security personnel training and qualification requirements continue to be- 1 reviewed for improvement. Recent improvements include a revision to the training schedule for all security officers, with more training provided in the classroom environment before conducting the on-the-job training. Also, a complete managerial assessment / proficiency program was provided to both l licensee and contractor supervisors. As a result of this assessment, additional supervisory training will be conducted. To ensure security personnel are performing the proper classification of events and their deportability, additional training will be conducted on security procedures which contain deportability determination matrix.
With regard to the statement made on page 11 of the report concerning the hot
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particle, GSU's investigation could not substantiate that the hot particle .
[ left the facility. We believe the statement should read, "The worker may j have taken the particle home in a shirt and the particle was not detected *
until several days later when the particle was detected during a later I routine personnel survey".
GSU appreciates the recognition of our commitment to excellence by the Category I ratings received and the positive observations and recognition in the report of the many other areas of strength in our programs. GSU is fully committed to safe, reliable and efficient operation of RBS. We take all the SALP Board recommendations seriously and will use this information in the .
continuing process of improving performance and attention to detail.
Sincerely, 44~
J. C. Deddens Senior Vice President River Bend Nuclear Group l J L ch
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