IR 05000483/1986002

SALP Rept 50-483/86-02 for June 1985 - May 1986.Category 1 Ratings Assigned in Areas of Surveillance Testing,Fire Protection,Security,Outages & Training

ML20209J131
Person / Time
Site:	Callaway
Issue date:	05/31/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20209J101	List: IR 05000483/1986002 ML20209J097
References
50-483-86-02, 50-483-86-2, NUDOCS 8609160164
Download: ML20209J131 (33)

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SALP 6 SALP BOARD REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-483/86002

Inspection Report

Union Electric Company Name of Licensee Callaway Plant Name of Facility June 1, 1985 - May 31, 1986 Assessment Period

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e 8609160164 860911 gDR ADOCK 05000483 PDR

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j I. INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be t sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management 4 to promote quality and safety of plant construction and operation.

, An NRC SALP Board, composed of staff members listed below, met on August 8, 1986, to review the collection of performance observations

! and data to assess the licensee's performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is i provided in Section II. of this repor This report is the SALP Board's assessment of the licensee's safety performance at Callaway for the period June 1, 1985 through May 31, 1986.

j SALP Board for Callaway:

NAME TITLE

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J. A. Hind Director, Division of Reactor Safety and Safeguards i C. E. Norelius Director, Division of Reactor Projects

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R. M. Lerch Project Inspector, Reactor Projects 1A j B. H. Little Senior Resident Inspector i W. L. Forney Chief, Reactor Projects Section 1A

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N. J. Chrissotimos Deputy Director, Division of Reactor Safety L. R. Greger Chief, Facilities Radiation Protection Section j M. C. Schumacher Chief, Independent Measurements and Environmental

Protection Section

! P. W. O'Connor Project Manager, Division of Licensing, Office

! of Nuclear Reactor Regulation l J. R. Kniceley Safeguards Inspector

E. R. Schweibinz Chief, Technical Support Section M. P. Phillips Chief, Operational Programs Section C. F. Gill Reactor Inspector, Facilities Radiation Protection j Section

J. P. Patterson Emergency Preparedness Analyst i

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II. CRITERIA Licensee performance is assessed in selected functional areas, depending upon whether the facility is in a construction, preoperational, or operating phase. Functional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be assessed because of little or no licensee activities, or lack of meaningful observation Special areas may be added to highlight significant observation One or more of the following evaluation criteria were used to assess each functional are . Management involvement and control in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Operational and Construction events (including response to, analyses of, and corrective actions for) Staffing (including management)

However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categorie The definitions of

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these performance categories are:

Category Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and construction quality is being achieve Category NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety and construction quality is being achieve Category Both NRC and licensee attention should bc increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used so that minimally satisfactory performance with respect to operational safety and construction quality is being achieve .

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III. SUMMARY OF RESULTS The regulatory performance of the Callaway Plant is very good. Although the ratings in Surveillance and Security improved and the rating for Licensing Activities declined, performance improved to some extent in most area Rating Last Rating This Functional Area Period Period Plant Operations 2 2 Radiological Controls 2 2 Maintenance 2 2 Surveillance 2 1 Fire Protection 1 1 Emergency Preparedness 2 2 Security 2 1 Outages 1 (Fuel Loading) 1 (Refueling)

I, Quality Programs and Administrative Controls Affecting Quality 2 2 Licensing Activities 1 2 Training and Qualification Effectiveness NR 1

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O IV. PERFORMANCE ANALYSIS Plant Operations Analysis Portions of seven inspections were performed in this area by the resident inspectors and region based inspectors which included direct observation of operating activitie Extensive inspections were performed during the seven week Cycle 1 refueling outage which included assist inspections by NRC resident inspectors from the Byron and Wolf Creek Plants. The operations portions of these inspections focused on overall control room discipline and specifically on shift crew performance during normal and off-normal conditions and shift relief and turnover activities. The inspections included a review of logs and records, interviews with plant personnel and followup of significant operating events to ascertain facility operations in conformance with the Technical Specifications and administrative procedures. One violation was identified as follows:

Severity Level IV - Failure to operate within the Axial Flux Difference target band as required by Technical Specifications.

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(Inspection Report No. 50-483/85016).

The violation involved operating the reactor beyond the allowable Axial Flux Difference (AFD) limits allowed by Technical Specification (TS). Technical Specifications require that with the indicated AFD outside of the above required target band and with thermal power greater than or equal to 90% of rated thermal power, within 15 minutes, either restore the indicated AFD to within the required target band limits, or reduce thermal power to less than 90% of rated thermal powe Although there are four channels of power range flux difference indication, an NIS Recorder, and a CRT display provided on the control room " front panel" to indicate AFD conditions, the allowable AFD band was exceeded by approximately 1% for 135 minutes before an operator noted and corrected the conditio This event indicates a lack of operator attention which resulted in exceeding the allowable Axial Flux Difference. NRC inspection determined that the event posed no technical safety problem; however, the event was considered significant as it resulted from a lack of operator attention to plant parameters

, and condition Escalated enforcemert is being considered involving two examples of the licensee's failure to maintain plant / instrumentation systems operable as required by Technical Specifications and one example of failure to meet NRC reporting requirement (1) The Intermediate Head Safety Injection System was

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inoperable for approximately six hours. The event resulted from a combination of procedural and personnel performance errors. (2) The Auxiliary Feedwater Pumps (AFPs) Engineered Safety Features Actuation System (ESFAS) blocking switches were in " block" position for approximately 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, which defeated the automatic start feature of the AFPs upon loss of the main feedwater pump (3) The licensee failed to notify NRC within four hours of a condition which rendered the Intermediate Head Safety Injection System inoperabl NRC inspections determined that the two events posed no significant threat to public/ plant safety; however, escalated enforcement action is being considered to emphasize the importance of conducting activities in full compliance with the facility license, and to underscore the importance of procedural discipline and operator attentivenes The licensee's initial evaluation of reportability by the operating crew classified the event as a 30 day Licensee Event Report (LER). Licensee's followup review process failed to identify the appropriate reportability of the even Although the above violations directly involved plant operations, other violations which indicate direct or indirect involvement by plant operations are discussed in Sections IV.B., Radiological Controls, and IV.I., Quality Programs. In addition, NRC inspections determined that plant operations personnel were involved in procedural and Technical Specification violations for which Notices-of Violations were not cited because the violations were of lesser safety significance, and the licensee identified, thoroughly evaluated, factually reported, and provided prompt corrective measure Overall, the number of LERs issued during the assessment period indicate a downward trend. However, the number attributed to personnel error is greater than expected. For example, during the last three months of this assessment period, 12 of the

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20 LER events which occurred are attributed to personnel performance problems. Of those attributed to " personnel",

seven events relate to containment / control room ventilation isolations involving inoperable radiation monitors.

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Licensee events receive a high level of management attentio In addition to disciplinary action / supervisory consultations, management holds bi-monthly " fire-side" chats with the

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operating crews. These meetings focus on increasing operator awareness of LERs and reactor trips and have stressed personal accountability. LER/ reactor trip performance trends are posted on plant status boards. To reduce performance errors the licensee has added sign-off action steps to I&C and maintenance procedures, placed warning signs at radiation monitors and electrical controls, and conducted special training sessions i

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on radiation monitors. Written LERs, received during this assessment period, are summarized further in the " Supporting Data and Summaries,"Section V.G.I. of this repor There were no events during this assessment period which were classified as an " Unusual Event." There were four unusual events during the previous assessment perio A total of 83 events were reported to the NRC Operations Center via telephone. Of these, 42 were non-security events reported under the requirements of 10 CFR 50.72 and 41 were LER notifications made per 10 CFR 50.73. Review of the LERs indicates that about half of them involved minor technical specification violations and were not significant enough to be reported to the Operations Cente There were fourteen (14) reactor trips which occurred during the period from June 1, 1985 through May 31, 1986. Twelve were from power levels greater than 15% power and 2 were from less than 15% power or during shutdown conditions. Of these, nine were related to equipment deficiencies and five resulted from personnel errors. The NRC and the Licensee consider this number of reactor trips to be excessive. The Licensee has established a set of goals for seven reactor trips between the period January 1 through December 31, 1986. If the plant has seven trips their performance goal will be met; if there are five trips their performance will be considered excellent by the licensee, and if there are three or fewer trips their performance will be considered outstanding by the license Of the 42 non-security events reported per 50.72, 22 events involved actuations of engineered safety features. A large number of these events involved spurious Containment Purge Isolation (CPI), Control Room Ventilation Isolation (CRVI),

and Fuel Building Ventilation Isolation (FBVI). Two events were caused by personnel error. A number of events were due to spurious signals generated during gas sampling evolution In 1985 (note the SALP period is 6/1/85 through 5/31/86), the reactor critical hours of operation were 8,161, the forced outage rate was 6.4% or 536.8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, and the unit had 20 scrams which is equivalent to 2.45 scrams per 1000 critical hours of operation, which is much higher than the industry average of 1.47 scrams /1000 critical hours in 1985. However, the plant availability factor for 1985 was 90% which is much higher than the 61% national average availability factor for 1985. This high availability factor in spite of the high number of scrams is because the plant was not refueled during 1985, the outages

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that occurred were of fairly short duration, and plant staff performance was goo .

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NRC inspection of licensee events has found that " event reduction" has been given a high level of management attention and support. This includes the implementation of a Plant Trip /

Incident Reduction Program which is discussed in more detail in Section I., Quality Programs. The licensee has provided prompt and thorough evaluation of causal factors and prompt implementation of corrective measures. Corrective measures specified by the licensee usually include performance goals such as the attainment of main control panel " black boards" for example. Operational improvements attributable to management atteni. ion include reductions in the number of reactor trips and reportable events, and reduction in the backlog of work items including the reduction of alarming control room annunciators. Management attention to operating events is evident in the quality of LER report An evaluation of LER reports by the Office for Analysis and Evaluation of Operational Data found the content and quality of a sample of LERs to be higher than the industry average. See the summary in Section V.G.1 of this repor Inspection of licensee performance relating to control room behavior was performed routinely by the resident inspectors and Region III inspectors. The extended coverage during the refueling outage provided observation of the licensee's shift crew performance during days, off-shift, and weekends, including shift turnover The control room operators and supervisors were attentive to plant conditions'and displayed a professional attitude toward the control and operations of the plant. Plant alarms, and both planned and unplanned events were promptly responded to, appropriately communicated, and logged. The operating logs, status boards, and equipment out of service logs were being maintained and reflected current plant and system condition Administrative and operating procedures were adhered t Crew shift relief and turnovers were performed in a thorough manner and included discussions of past, current, and planned activities, the review of logs, and panel walkdowns. Control room access is limited and enforced. The inspectors noted that licensee management and quality assurance personnel provided frequent in plant observations of the shift crews'

performanc During site visits on June 24, 1985, August 28, 1985 and April 29, 1986, headquarters staff toured several plant areas including the reactor building, turbine building, auxiliary building, radwaste building, and the control room. The staff found that the plant was in good order with respect to cleanliness and housekeeping. Activities in the control room were observed to be conducted in a professional manner with assigned personnel appearing to be alert and attentive to dut __ -_ __ _- - - - - -_-. ---

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~ Conclusion The licensee is rated Category 2 in this are This is the same rating as the previous assessment perio . Board Recommendations Non B. Radiological Controls Analysis Four inspections were conducted during this assessment period by region based inspectors. These inspections included radiation protection, radioactive waste management, TMI Action Plan Items, chemistry / radiochemistry, confirmatory measurements, and environmental monitoring. The resident inspectors also reviewed this area during routine inspection Four violations were identified as follows: Severity Level IV - Failure to follow procedures for sampling the unit vent radioactive gaseous effluent, resulting in failure to identify inoperability of the unit vent gaseous monito (Inspection Report No. 50-483/85017)

- Severity Level IV - Failure to implement specified actions (alternate sampling and report to NRC) required due to inoperability of unit vent gaseous monito (Inspection Report No. 50-483/85017) Severity Level IV - Failure to leak test two sealed sources at required frequenc (Inspection Report No. 50-483/85017) Severity Level IV - Failure to implement specified actions (auxiliary sampling or termination of releases) required due to isolation of the radwaste building vent iodine and particulate sampler. (Inspection Report No. 50-483/86014)

Violations a. and b. resulted when, due to personnel error, a sample line was not reconnected following maintenance on the unit vent sample pump. Due in part to another personnel error, the disconnected sample line was not detected for thirteen days, during which time required gaseous monitoring or alternate sampling was not performed. Violations c. and d., although identified by the licensee, were cited because licensee corrective actions were inadequate. The violations appear to reflect minor programmatic failures of licensee personnel and administrative systems to effectively recognize and implement oporational requirements. At the end of this SALP assessment period, the plant had been operational for approximately

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17 months. The number of personnel and administrative system failures in this functional area during this initial operational period has been typical for new plant Staffing continues to be a licensee strength. The number of technician and supervisory personnel is ample, with essentially all positions filled and has been very stable with losses generally limited to internal promotions. This stability should enhance the staff's performance as experience is gained. Additionally, an adequate number of well qualified contract radiation protection technicians were utilized during the extended maintenance outag Positive management involvement in this functional area continued to be demonstrated. There is consistent evidence that supervision is directly involved in day-to-day activitie A radiation protection representative attends all outage planning meetings. Plant work group managers are utilized to support correction of radiation protection infractions by their workers. The radiation work violation reporting system for documenting and correcting problems appears to be working wel Quality assurance auditors are well qualified and have performed timely and thorough audits of this functional are Responsiveness to the audit specific findings has been goo However, an improved system is needed to obtain timely responses to programmatic weaknesses identified by audits and evaluations. Management shortcomings in this functional area were evidenced in continued delays in resolution of ventilation system filter housing drain problems and certain TMI Action Item analysis issues. The filter housing drain issue was resolved near the end of this assessment period; however, the TMI Action Item issue remains open from the previous SALP assessment period. An additional recurrent

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problem area requiring licensee attention was radioactive effluent leakage from piping systems, which was straining the decontamination work force; many of these leaks were repaired during the refueling outage near the end of this assessment perio Responsiveness to NRC issues was acceptabl The licensee has resolved or initiated actions for several NRC concerns, including fuel manipulator crane area monitors, ventilation system deluge and drain provisions, painting of concrete surfaces in potentially contaminated areas, control room ventilation charcoal desorption potential, fluid calibrations of liquid and gaseous effluent monitors, radon levels, and sample line iodine plateou Additional licensee actions are needed concerning TMI Action Items and contaminated leakage from piping system Generally, a conservative approach to resolution of technical issues continues to be exhibited. Personal radiation exposures for the first eighteen months of operation were about 240 person-rems which is consistent with early PWR operation .

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The licensee's ALARA program is well organized and amply staffe Plant and work group goals have been established in numerous areas and have been updated, as necessary, to reflect existing conditions. Additional work requests for repair of contaminated system leakage necessitated upward revision of the ALARA goal for the total contaminated plant are The ALARA program places emphasis on contaminated area controls. The decontamination work force appears well organized under the Radwaste Superintendent but suffers somewhat from understaffing and inexperience. Several noteworthy ALARA improvements were implemented during this assessment period including expanded use of temporary, job-specific air filtration equipment and use of temporary shielding during reactor head gasket replacemen Liquid, airborne, and solid radioactive releases during this assessment period were consistent with early PWR operatio No transportation problems were identifie The licensee has performed and implemented a satisfactory water chemistry control program for the primary and secondary system chemistry which addresses the major elements of the PWR Owners Guidelines designed to minimize localized corrosion in the steam generators and turbine The Radiological Controls Technicians demonstrated satisfactory capability for collecting samples and analyzing them for key chemical parameters. The licensee also has adequate capability to monitor conductivity, pH, sodium and dissolved oxygen through on-line monitors on different plant systems to ensure the appropriate water quality is maintained. The licensee maintains awareness of the water quality through trend plotting of analytical data over time and will impose action levels if necessary when monitored chemical parameters are confirmed to be outside normal operating value The licensee has demonstrated a satisfactory QA/QC program through control charts on chemical parameters and on counting data using performance check sources. Licensee participation in an interlaboratory cross check program involving radiological and nonradiological sampics has been satisfactory. The licensee's results in the confirmatory measurements program are excellent with all agreements for the comparisons mad Conduct of the Radiological Environmental Monitoring program during this period is satisfactory with no significant discrepancies noted during the review of the Annual Operating Repor .

' Conclusion The licensee is rated Category 2 in this area. Although the rating for the last SALP was Category 2 also, overall performance this assessment period was better than the majority of SALP Category 2 plant . Board Recommendations Non C. Maintenance Analysis Inspections in this functional area were routinely included in seven inspections performed by resident inspectors, region based inspectors, and a resident inspector from another sit The inspections included a review and observation of the maintenance programs, staffing, staff training, and record In addition to selected preventive and corrective maintenance and system modifications surveyed to verify that these activities were completed in accordance with Technical Specifications and the licensee's quality assurance program requirements, followup inspections were performed on significant equipment problems. Discussions were held with craftsmen, maintenance supervision, and plant managemen The following items were also considered during these inspections: the limiting conditions for operation were met while components or systems were removed from service; approvals were obtained prior to initiating the work; activities were accomplished using approved procedures and were inspected as applicable; functional testing and/or calibrating were performed prior to returning the components or systems to service; parts and materials that were properly certified; radiological controls were implemented as necessary; and, fire prevention controls were in plac No violations or deviations were identifie One LER was issued relating to instrumentation & control maintenance during the assessment period. This event involved troubleshooting that resulted in a signal being injected into the incorrect Reactor Protection System trains which

- caused an inadvertent reactor tri An inspection assessed the licensee's programs for equipment classification, vendor interface, and post maintenance testing and found them to be adequat An inspection was conducted to perform an in-depth evaluation of maintenance related events. The maintenance program was

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determined to be basically sound with the licensee addressing some minor weaknesses. The licensee management has shown an aggressive posture in dealing with the maintenance program and the implementation problems including a thorough evaluation of root cause Maintenance scheduling and performance consistently shows improvement and evidence of good planning and assignment of priorities. This was evident during the outage when a large effort was incorporated in the maintenance program to reduce the number of backlogged items as well as during routine operations. The corrective actions performed appear to be effective as indicated by the lack of repetitive work order Management involvement is also evident in the concern placed on the reduction of work order items backlo The maintenance records were found to be clear and retrievable.

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The staffing appears to be sufficient for routine work demand During the evaluation period, contractors were onsite working to reduce the number of backlogged work orders. During this period, the number of work orders were reduced from over 5000 to approximately 200 The events and occurrences in this functional area have received a high level of management involvement. " Crew chats" have been used and procedures have been revised (with additional action step signoffs) to reduce performance error Specialized training in specific areas has also been incorporated to reduce the number of events. The maintenance area is also included in the " Plant Trip / Incident Reduction Program." Conclusion The licensee is rated Category 2 in this are The rating for the last SALP was Category . Board Recommendations Non D. Surveillance Analysis Inspections were routinely performed in this functional area during five inspections by the resident inspectors and two inspections by regional based inspectors. No violations were identified in this are The resident inspectors reviewed or observed selected portions of Technical Specifications required surveillance testing during power operations and mode changes during startup from

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the refueling outag Items which were considered during the inspections included whether adequate procedures were used to perform the testing, test instrumentation was calibrated, test results conformed with Technical Specifications and procedural requirements, and the test was performed within the required time limits. The inspectors determined that the test'results were reviewed by someone other than the personnel involved with the performance of the test, and that any deficiencies identified during the testing were reviewed and resolved by appropriate management personne Two inspections were performed by regional based inspectors to review the calibration and surveillance testing programs. The programs were found to be sound and well implemented. A regional based inspector performed a review and evaluation of the in-service inspection of the piping system components. The activities were controlled through the use of well stated procedures. The review showed that the activities had received good planning and priorities had been assigned. Observation of the in-service inspection activities indicated that personnel have a good understanding of work practices and that procedures were followe Records were found to be essentially complete, well maintained, and available. The records also indicated that equipment and material certifications were current and complete and that the personnel performing nondestructive examinations were trained and certified. Discussions held with personnel performing the examinations indicated they were knowledgeable of their jo Three reportable licensee events, which included two reactor trips were classified in this area. This number of events is considered acceptable in relationship to the number of surveillances that were performed during this perio Technical Specification requirements have been converted to verification test requirements and the schedule placed on the computer. Only two tests were tardy this period. These occurred during unusual conditions that had not been factored in from the Technical Specifications and,

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therefore, are not a programmatic problem. These deficiencies, and others that have been identified, have been promptly documented, evaluated, and correcte The program was considered to be fully implemented on June 1, 1985, and it appears that the planning and scheduling portion of the program has been very effectiv The computerizing of the surveillance schedule and designating a group to followup performance of the surveillance tests has essentially eliminated missed or late performance of the test Review of individual procedures has shown these to be quality procedures, which include the appropriate acceptance criteri The test results were reviewed and evaluated in a timely manne . _ __ - .- --- - -- - .. . - ._ . _

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The planning and scheduling group also schedules maintenance on equipment at the same time as the surveillance is to be performed. This feature helps keep safety-related equipment out-of-service to a minimu In response to comments provided in the previous SALP report, improvements were implemented in the field performance activitie The NRC inspections determined that the licensee has implemented a comprehensive surveillance program in which identified deficiencies are evaluated and corrected promptl The licensee has been very receptive to comments and suggestions by the NRC and demonstrated a conservative and conscientious attitude toward maintaining a quality surveillance testing progra The licensee's staffing levels have been adequate to perform and followup in the area of surveillance tests. The management involvement in this area has been consistently evident in planning and the assignment of priorities. The LERs classified in the area of the surveillance program are included in the

" event reduction" study which has received a high level of management attentio . Conclusion The licensee is rated Category 1 in this are The rating for

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the last SALP was Category . Board Recommendations Non E. Fire Protection Analysis The inspections in this functional area were conducted during the six routine inspections performed by the resident inspector The inspections did not include the verification of conformance to Appendix R requirements. The inspections did include observation of the on shift fire brigade training drills, housekeeping, storage, and control of flammable liquids and combustibles, status and condition of manual fire fighting equipment, and the condition of the emergency breathing equipment and " turn out" gea No violations or deviations were issue Nine LERs were issued in this functional area. Seven involved improperly stationed fire watch patrols. One LER reported missing conduit smoke and fire seals due to a construction installation inadequacy. The remaining LER identified a number of fire dampers that may not have had the necessary clearances

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had a fire occurred. Licensee reviews of the reportable events were timely, thorough, and technically sound, and the corrective actions appear to have been timely and effectiv The improperly stationed fire watch patrols were of minor significance to safety-related equipment. The patrols were tardy due to misunderstanding or misinterpreting the requirements or the patrols were simply late at a checkpoin The five dampers that were reported were of minor safety significance due to associated fire sensing and/or suppression systems. The licensee implemented appropriate temporary controls until the fire dampers are correcte The fire protection / prevention equipment and procedures have been found to be maintained at an excellent level. Two drills and portions of other exercises were observed. The fire brigade performance during the drills was noted to be business-like and the functional performances were very professional. The inspections showed that housekeeping in the plant had been maintained at a high level. During the outage, the licensee utilized additional personnel to maintain the cleanness of the plant. The inspectors' walkdowns performed during the outage indicated that housekeeping was maintained at a very good level throughout the outag . Conclusion The licensee is rated Category 1 in this area. This is based on operational inspections and not an inspection of 10 CFR Appendix R implementation. The rating for the last SALP was Category . ' Board Recommendations Non F. Emergency Preparedness Analysis Two inspections were performed during the assessment perio One of these was an evaluation of the annual emergency preparedness (EP) exercise conducted on June 5, 1985. The other was a routine inspection which included a review of emergency detection and classification, protective action decisionmaking, notifications and communication, changes to the emergency program, shift staffing and augmentation, training, and licensee audits. No violations were identifie Two weaknesses were identified during the exercis One was lack of a health physics (HP) control point for radiological

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self-monitoring at the Technical Support Center (TSC),

Maintenance Operational Support Center (OSC), and the HP Access Control Point. The other weakness was inadequate communications in the OSC, e.g., telephone reception interference, poor audibility of Gaitronics, and ineffective use of radios for contacting in plant teams. Correction of these two weak areas was successfully demonstrated and reviewed during the July 30, 1986 annual emergency exercis The routine inspection included a thorough review of the

" Classification of Emergencies" procedure including the Emergency Action Level (EAL) classification criteria. The inspectors recommended that certain EALs be modified, revised or restated to more accurately identify emergency plant operating conditions. Proper management attitude and involvement was demonstrated by the licensee's commitment to review the EALs and consider changes to the EAL forma A new computerized dose assessment program has been initiated by the licensee. This program, Radiological Release Information System (RRIS), while functional, appeared to have been designed to run with current meteorological data only, and was unable to use forecast meteorological data. As evaluated by the inspection team, the program needed several software changes to make it function as a predictive device for calculating projected releases of radioactivit Management's response to the EAL and dose assessment issues has indicated an understanding of the issues, and a willingness to address NRC Concern To correct a shift augmentation drill which failed to obtain minimum required responses, an additional drill was successfully performed in April 1986, and monitored by the NRC Senior Resident Inspector. Additional drills will be monitored for assurance that reliability has been developed in the shift augmentation are Independent audits of the program have been timely and thorough, with the findings needing corrective actions being identified by Quality Assurance (QA) auditors. Follow-up corrective actions were taken and upper management was made aware of the findings. Responsiveness to NRC initiatives and other issues has been viable, generally sound, and thorough in most instances. Enforcement history has been very good, Corrective actions have been timely and effective in most cases. The training program has steadily improved. EP training has now been incorporated into simulator training for control room personnel with emergency response functions. A Job Task Analysis has been developed by the Training Department to better define the objectives and responsibilities of each emergency response position. As a result, three lesson plans have been established for each of the 55 emergency response

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4 position The Emergency Preparedness Required Reading i

Procedure has been revised to make the supervisor accountable for assuring that the procedure is adhered to by those with

emergency preparedness responsibilities. The training program is well defined and implemented with dedicated resources and a means for feedback experience.

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1 Two activations of the Callaway Radiological Emergency Response Plan (RERP) were identified during this SALP-6 period. Both events were categorized correctly and proper notifications were

made in a timely manner to State, local agencies, and the NR With the addition of the ring down phone in the control room

and emphasis on correctly completing the notification form, l this aspect of communications has improved from the previous j SALP period.

1 Conclusion

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The licensee is rated Category 2 in this are Licensee I performance was determined to be improving near the close 1 of the assessment period. The rating for the last SALP was Category 2.

• Board Recommendations Non Security Analysis One routine inspection and one reactive inspection were

conducted by regional based inspectors during this assessment i period. The resident inspectors also made periodic inspections

! of security activities assessing routine program implementation and providing initial response to security events. One j violation was identified as follows:

Severity Level IV - The licensee failed to have a fully

adequate barrier from the owner controlled area to the I protected are (Inspection Report No. 50-483/86005)

During the assessment period, the region received allegations of security improprieties and communicated telephone threats

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to the plant. The allegations were not substantiated. The l

- licensee's investigative actions and increased security

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measures pertaining to the security related telephone threats

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were comprehensive, timely, and adequately reported, although

initial evaluation of the significance and reaction to the very l

first event required regional management discussions with the l security organization.

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The licensee's senior management demonstrated an awareness of security issues and has been effective and responsive to identifying, resolving, and recommending solutions for security issue Concerns and observations receive the same exceptionally high level of management attention normally associated with violation The security management is responsive to all NRC initiatives and suggestions that can strengthen their program, rather than concentrating on just minimum compliance required by the security plan. Full management support has been demonstrated by site management, and the security organization operates in a highly supportive environment. The weaknesses identified during the previous SALP period were adequately corrected. The lack of significant violations is attributable to the security force's high caliber of performance. Weaknesses identified by the licensee were not repetitive and not indicative of a programmatic breakdown. Corrective actions were prompt and effectiv Management has established policies and procedures that are well written and effectively enforce The licensee's staffing levels are adequate to fulfill security plan commitments. Positions within the security organization are identified and authority and responsibilities are well define Training policies and procedures have ensured that all security personnel are trained and qualified to perform assigned security related tasks or dutie There were no technical security issues with respect to plant safety that required resolution during this assessment perio Additionally, no regulitory issues which required a licensee response were identified during the assessment perio Security events were properly and accurately reported to the NRC under 10 CFR 73.71(c). There have been eight such events during the assessment period. These events pertained mainly to computer hardware problems which were adequately resolve The licensee properly analyzed the events and initiated appropriate corrective actio The licensee's Quality Assurance Department, which conducts independent security program audits, has been effective in identifying security program weaknesses and has been instrumental in strengthening the security progra In summary, the licensee's security staff has been highly effective in the operation and implementation of the security program. The security staffing is adequate and departmental support for the security program has been effectiv Supervision of the security force is aggressive which results in a stable, well trained security forc .

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. Conclusion Because of the excellent enforcement history and management l'

involvement in problem resolution, the licensee is rated Category 1 in this area. The rating for the last SALP was Category ,

, Board Recommendation Non / Outages ,

, Analysis Three inspections were performed in this functional area by regional based and resident inspectors. Only one major outage occurred during this period, the first refueling and maintenance 2 outage. The inspections included the receiving inspection of new fuel assemblies, defueling and refueling, various maintenance and surveillance activities, radiological protection, and plannin No violations were identifie Extensive management involvement was evident several months prior to and during the initial refueling outage. The personal involvement of management was observed at advanced planning and y daily planning meetings and frequent in plant tour The outage was well planned and administered. The licensee has a permanent outage group that schedules the outages. The *

outage group held twice daily meetings with all concerned i groups for problems and information dissemination. The detail i of jobs to be performed during the next three days was issued at this time. Outage coordinators were onsite around the clock to make any schedule changes that were found to be necessar The licensee provided additional staffing and supervision, special equipment checkout, and training. Advanced planning also provided detailed / integrated subnets for major work and activities and assignment of task performance responsibilitie Personal accountability was evident during the outage meeting and was effective in resolving technical problems. The need for increased plant security was recognized in the planning and was subsequently provide The refueling operations were performed by licensee personnel with contracted fuel loading supervisio Refueling operations were performed smoothly with only minor equipment problems occurrin The radiological controls were enhanced with the advanced

> planning and the hiring of the contract rad technicians that J provided sufficient personnel to cover the jobs in progress.

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. The advanced planning / scheduling set the outage at 42 days and I ,A.; -

the actual outage was completed in 49 days. The licensee b stated that this was the shortest initial refueling outage for

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i a Westinghouse four-loop plant to date. The outage schedule ( was developed with no contingency time built in. The seven day-

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outage extension was the accumulation of delays in the critical path items due to equipment failures, jobs taking longer to

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complete than historical information indicated, and other

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miscellaneous reasons. The major projects completed during

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the outage were inspection of main turbine and generators, i local leak rate tests of containment valves, steam generators 23 tube inspection, secondary side inspection of steam generators, and maintenance on reactor coolant pumps and feedwater pump No major spills or contamination occurred during the outage

,0 and housekeeping was maintained at a high level of cleanlines , 1:

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The commitments for the Safety Parameter Display System (SPDS)

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to be operable were completed during the outage and the Reactor

'.> Vessel Level Indicating System was made functional. The

/l modifications to reduce the number of alarms lit continued

, and reduced the number to less than ten. (This program remains

',.- ahead of schedule.) There were 103 modifications performed during the outage with the majority being considered in the operational upgrade categor NRC inspections during the Cycle 1 refueling outage determined

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that the licensee had provided adequate staffing, supervision, and training for the outage activitie Procedures were detailed and adhered to by the performing groups. Exceptional performance was noted by the operating crews' conduct and control of the outage activities, health physics, controls and practices, and overall maintenance. Subsequent startup testing was also conducted with no significant problems. Plant-wide maintenance and housekeeping control / practices and conditions were exceptionally well maintaine . Conclusion The licensee is rated Category 1 in this functional are This is the first SALP rating of this are . Board Recommendations Non I. Quality Programs and Administrative Controls Affecting Quality Analysis The licensee's Quality Assurance (QA) Program, including quality verification and oversight activities, was routinely assessed in six inspections by the resident inspectors during

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observations of plant activities in the areas of testing, operations, maintenance, and surveillance. The licensee's implementation of its Quality Assurance / Quality Control (QA/QC)

Administration and Audit Programs was also the subject of two inspections by region based inspectors. No violations or deviations were identifie Escalated enforcement is being considered for failure to environmentally qualify electrical equipment. The violation involved two examples of the use of non-environmentally qualified (EQ) electrical connectors on the Reactor Vessel Head Vent Valves, and the Containment Isolation Valve for the Chemical Volume and Control Syste NRC inspection determined that the licensee's use of the non-EQ connectors resulted from deficient oversight of a modification and a design change. Upon discovery, this matter received a high level of management attention. Licensee corrective actions included a re-review of EQ documents and a 100% in plant inspection of all valves and limit switches requiring EQ (Conax) connectors. No additional deficiencies were identifie In the areas of QA/QC administration, the licensee developed new procedures to address the preparation and control of quality assurance planning guides and the parts Q-list data bas Another procedure was revised to accommodate the SNUPPS computer program requirements. The licensee made good progress in addressing thes In the area of audit implementation, the licensee proceeded with their audit programs in four separate areas: Operations, Operations Support, Technical Support, and Quality System These audits were conducted in accordance with their program schedules, by certified auditors, using approved plans and checklists, and with proper attention to corrective action requirement The NRC expressed minor concerns regarding the flexibility granted to the auditors to vary from the planned checklists, the lack of auditor identity on all the certification papers, and the similarity between the 1985 and 1986 overall audit schedules. The licensee promptly responded to these items and committed to a thorough review of their practices. There was adequate evidence of management involvement in planning and assignment of priorities for the control of these activitie Management's high degree of attention, frequent site visits, and personal involvement in quality programs has been continually evident at Callaway. Both corporate and site management frequently met with the resident inspectors. During these meetings, the licensee has been open and forthright in

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discussing events, problems, corrective actions, and enhancement program Management's influence in this area is evident throughout the licensee's staf The effectiveness of the licensee's quality programs during this assessment period, has been demonstrated by the favorable reduction in the number of reactor trips and reportable events, and the reduction in the backlog of work items including alarming control room annunciators. Other favorable indicators include the licensee's achievement of a fully accredited training program and operator's performance on licensing exam The operating crews demonstrated a high degree of professional conduct during routine operation and the ability to effectively control unplanned event Inspection results and the licensee's good performance during the refueling outage demonstrated that administrative controls were well applied to outage activities including training, staffing, supervision, and plannin A major strength relates to the licensee's selection and staffing of operations and support organizations including key advisory personne Oversight functions have been adequately staffed and effectively utilized in the evaluation process of operational activities and plant events. These activities include: Onsite Review Committee (ORC), Independent Safety Engineering Group (ISEG), Senior Operations Advisory Panel (SOAP), Operating Advisors (0A), Compliance, and Quality l

Assurance (QA). Observation of group performance and individual discussions with group members show them to be dedicated and capable people who are responsive to industry and NRC activities.

! During the previous assessment period (SALP 5) NRC expressed concerns regarding the excessive number of reactor trips and other reportable events. The licensee has been responsive in this matter. Inspections have found that the licensee has continually provided a high degree of attention and resources to the area of unplanned events, not only in evaluating them but also in instituting corrective and preventive measures to preclude their recurrence. In September 1985, the licensee implemented a Plant Trip / Incident Reduction Program. This program included a seven member team to assess plant events, determine root and contributing causes, and recommend corrective measure An overall reduction in both the number of events and reactor trips indicates that the licensee has been effective in this effort, most notably during the last half of this assessment perio Notwithstanding the favorable trend, the number of recent events attributed to personnel errors is considered high resulting in LERs and in the Technical Specification violations discussed in Section A., Plant Operations.

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The licensee's Site QA Organization is professionally organized and staffed. The QA audit and surveillance programs are well defined and effectively implemented. QA engineers provided extensive surveillance coverage (including off-shifts and weekends) during the refueling outage, startup, and power ascension period NRC inspection has determined that the site QA is functionally independent and assertive and has been effective in the identification and resolution of quality concerns. Management's support of QA activities has been eviden . Conclusion The licensee is rated Category 2 in this are This area was rated Category 2 in the previous assessment perio . Board Recommendations Non J. Licensing Activities Analysis During the current rating period, the primary licensing activity involved the resolution of license conditions which remained from the full power license issuance and the completion of licensing actions relating to first cycle operations and the approval of Reload 2 for cycle 2 operatio The licensee's management has participated in licensing activities and has assured timely response to the staff's requirement In particular, the UE management has been actively involved in major licensing activities such as the Cycle 2 reload that they considered to be a critical path item for the UE operational schedul UE is generally aware of NRC requirements and usually provides the staff with adequate technical information to resolve staff concerns. However, on two occasions during the first half of this rating period licensing actions were delayed by deficient

"no significant hazards considerations" analyses provided by UE in support of amendment request ..

The basis for this appraisal was the licensee's performance in support of amendment requests and responses to generic letters which have been reviewed and evaluated by the staff during the rating period. The subjects involved include the following:

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Generic Reviews: Plant Specific Reviews:

Reactor Trip System Enrichment Increase in Spent Reliability (B-80) Fuel Pool (Amendment 12)

Detailed Control Room Fire pump Diesel Inspection Design (F-71) (Amendment 11)

Post-Trip Review (B-85) Surveillance Interval Safety Parameter Display Extension (Amendment 8)

System (F-09) Deletion of Fuse Testing (Amendment 9)

Low Temperature Overpressure Protection Organization Change (Amendment 10)

Revised Value of Pa (Amendment 13)

Quality Systems Department Change (Amendment 14)

Reload for Cycle 2 (Amendment 15)

Fuel Drop Accident Inside Containment Low Temperature Over Pressure Circuitry Use of Code Case N416 Extension of Performance on Type C tests During the present rating period the licensee's management demonstrated active participation in licensing activities and kept abreast of current and anticipated licensing action In addition, the management's involvement in licensing activities assured timely response to the requirements of the Commission's rules related to Environmental Qualification of Electrical Equipment and license conditions related to Detailed Control Room Design Review, Emergency Response Capabilities, and Regulatory Guide 1.97. The implementation schedules have been met by the licensee and their submittals have generally been of high quality and have not required significant rework to satisfy staff requirement UE management was particularly effective in assuring that high quality submittals were provided to the staff during the preparation and review of the UE's reload submittal for Cycle 2 operation. The submittal was timely and more than usually complete. UE requested a pre-review meeting with the staff in order to facilitate their submittal and our revie .

The licensee's management and its staff have demonstrated sound technical understanding of issues involving licensing action Their approach to resolution of technical issues has demonstrated extensive technical expertise in all technical areas involving

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licensing actions. The decisions related to licensing issues have routinely exhibited conservatism in relation to significant safety matters. The licensee's clear understanding of the staff's concerns assured sound technical discussions regarding resolution of safety issue UE is generally aware of NRC requirements and their licensing submittals usually provide the staff with the information needed to complete its review without extensive requests for additional informatio On two occasions the staff was unable to prepare a "no significant hazards consideration" (NSHC) finding related to a UE amendment request because the NSHC analysis provided by UE was deficien In both cases the required notice to the public was delayed while UE was requested to provide by A NSHC analysis that satisfied the requirements of 10 CFR 50.91(a)(1).

The licensee has been generally responsive to NRC initiative During the rating period, they have made efforts to meet the established commitments as illustrated by their response to TMI action items I.D.1.2, and to the rules related to environmental qualification of safety-related electrical equipmen In several subject areas the licensee responded in a timely and thorough manner. In response to NRC requests and suggestions related to the staff's review of generic issues and license amendment requests, the requested information was usually provided quickly and was adequate to allow the staff to resolve the issue promptl All scrams were promptly corrected and reported to the NRC Operations Cente . Conclusion

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l The licensee is rated Category 2 in this functional area.

! The licensee has been responsive and technically competent in pursuing its licensing activity during this SALP rating period.

Concerns relative to the "no significant hazards consideration" l

findings during the first half of this period appear to have i been resolve The rating for the last SALP was Category . Board Recommendations

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i K. Training and Qualification Effectiveness Analysis Resident and regional inspectors have evaluated training and qualification effectiveness during inspection of specific program area In addition, an inspection was conducted to

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evaluate the effectiveness of the licensee's licensed and 9'

non-licensed personnel training programs. No violations were identifie During inspections of licensee activities personnel were 4 knowledgeable and effective in implementing their dutie l Training appeared to be well planned and adequately presente In cases where abnormal incidents had occurred at the plant, the licensee prepared an Incident Report (IR). The licensee's review of the event in the IR not only evaluated whether personnel error contributed to the event, but in the cases where it did, the licensee also evaluated the cause of the personnel error. This evaluation included an assessment of whether the training program had been effective or could have contributed to the cause of the event. In all cases, completed irs were forwarded to the Training Department for independent evaluation to determine if the formal training program could be improved to prevent a recurrence of the incident. In addition, the Training Department was conducting evaluations of licensee LERs, INP0 SOERs, and NRC inspection report findings to determine if improvements could be made to the training progra The licensee had developed a program whereby personnel can suggest modifications to the training program based on their first hand field knowledg In addition, training department

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instructors conducting licensed operator training were required to stand one watch per month as part of their regular dutie Overall, the licensee appeared to have a good method for operational feedback into the training progra For the maintenance groups, the training program appears to have been well defined and implemented with dedicated resources and a means provided for feedback of experiences. Inadequate training could only rarely be traced as part of the cause of events occurring during this rating perio The licensee's training program provided several means of disseminating information related to incidents and recent events; however, the training program was not as effective in providing training on plant modifications prior to the modification being declared operational. In addition, the

licensee's recordkeeping of training related records was fragmented, with required readings and OJT completions being

documented in one department, formal classroom training was documented in the Training Department, and old test results l

i were microfiched and kept by the Document Control Department.

l During the assessment period, examinations were administered to six Senior Reactor Operator and one Reactor Operator applicant The overall pass rate was 86%. This passing rate exceeds the overall nc.tional average passing rate. During the last ,

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assessment period, the pass rate was also above the national averag Based on these results, the operator license training program at Callaway was very effectiv In addition to adequate technician and general employee training programs, radiological controls special radiation protection training programs were implemented for maintenance workers, contract radiation protection technicians, decontamination workers, and outage work group A 36-month apprentice training program was developed to allow plant helpers to qualify as Assistant Radiation-Chemical Technicians specializing in radiation protection, chemistry, or radwaste. The licensee's radiological training and qualification program is well defined and implemented and is comprehensive in terms of the workers encompasse The licensee has completed INP0 accreditation of all training programs subject to accreditation. These programs are non-licensed operator, control room operator, senior control room operator, shift technical advisor, instrument and control technician, mechanical maintenance personnel, electrical maintenance personnel, radiological protection technician, chemistry technician, and onsite technical staff and manager The licensee was the third utility in the nation to complete INP0 accreditation of all subject area In cases where the NRC recommended improvements to a training course, the licensee was very responsive in modifying the content of lesson plans to address NRC concern . Conclusions The licensee is rated Category 1 in this functional are This is based on the licensee's timely completion of INP0 accreditation in all training categories and the excellent feedback program setup to improve the training program based on operational events. This functional area was not rated separately in previous SALPs.

l 3. Board Recommendations l

l None.

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V. SUPPORTING DATA AND SUMMARIES Licensee Activities During SALP 6, assessment period June 1, 1985 through May 31, 1986, the following significant licensee activities occurre The plant was in its first refueling starting on February 28, 198 The plant resumed operation on April 15, 198 The Linion Electric Company training program became the third utility to become fully accredited by INP On May 19, 1986 the plant was shutdown to repair a S/G feedwater check valve and was restarted on May 25, 198 Inspection Activities The inspection program at Callaway consisted of routine resident and region based inspections including inspections of the outage activities of the first refuelin Inspection Reports Nos. 85015-85019 Inspection Reports Nos. 85021-85024 Inspection Reports Nos. 86001-86010 Inspection Reports Nos. 86012-86014 Table 1 Enforcement Activity Number of Violations in Each Severity Level Functional Areas I II III IV V l Plant Operations -- -- --

1 -- Radiological Controls -- -- --

4 --

-- -- -- Maintenance -- --

i Surveillance -- -- -- -- -- Fire Protection -- -- -- -- --

-- -- --

' Emergency Preparedness -- -- Security -- -- --

1 --

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-- -- -- -- -- Outages

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Functional Areas I II III IV V Quality Programs and Administrative Controls -- -- -- -- -- Licensee Activities -- -- -- -- -- Training and Qualification Effectiveness -- -- -- -- --

TOTALS 0 0 0 6 0 C. Investigations & Allegations Review There were four allegation files opene Subsequent inspections of the allegations did not identify any violations or deviation . An anonymous allegation was received that several improper security practices were being allowed. Inspection did not substantiate any of the allegation . A former contractor employee alleged that some magnetic particle tests were improperly performed. Inspection could not substantiate the allegatio . An anonymous allegation was received by the Office of Inspection and Enforcement regarding drug use by specific names of prior employees of a licensee contractor. This information was forwarded to the licensee to investigat Followup inspection determined that the licensee received the information and reviewed it in the context of their drug policies and construction programs, and concluded there was no evidence to substantiate the allegations against individuals or to question the integrity of safety-related constructio . An anonymous letter was received by the Office of Inspection and Enforcement with concerns over new security restriction The licensee was notified of a concern received from an employee, and review by safeguards inspectors found that the security actions referred to were appropriat D. Escalated Enforcement Civil Penalties

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No civil penalties were issue . Orders No orders were issue i

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E. Management Conferences Held During the Appraisal Periods August 28, 1985, Management meeting with representatives of the Union Electric Company to present the Systematic Assessment of Licensee Performance Report (SALP 5) for the Callaway Plan February 5,1986, Licensee presentation on trip reduction program and Quality Systems Departmen April 9-10, 1986, Management plant tour and meeting with licensee management regarding actions which were taken as a result of the recent threat against the plan Region III management toured the plant and met with licensee personnel before the conclusion of the first refueling outag In addition, potential violations regarding equipment not environmentally qualified were discusse June 3, 1986, Management meeting and enforcement conference to discuss the inadvertent isolation of the intermediate head injection syste June 10, 1986, regional managemer.t toured the site. The licensee presented their findings and actions regarding an error which blocked auxiliary feedwater initiation signals on main feedwater pump tri F. Confirmation of Action Letters (CAls)

There were no Confirmatory Action Letters issued during this assessment perio G. Review of Licensee Event Reports, and 10 CFR 21 Reports Submitted by the Licensee Licensee Event Reports During SALP six assessment period, June 1, 1985 thru May 31, 1986, there were 45 Licensee Event Reports submitted. These events constituted LERs 85-25 thru 85-54; 86-01 thru 86-1 An evaluation of the content and quality of a representative sample of the Licensee Event Reports (LERs) submitted by Callaway 1 during the June 30, 1985 to May 31, 1986 Systematic Assessment of Licensee Performance (SALP) period was performed using a refinement of the basic methodology presented in NUREG/CR-417 The results of this evaluation indicate that Callaway 1 has an overall average LER score of 9.0 out of a possible 10 points, compared to a current industry average

. score of 7.8 for those units / stations that have been evaluated to date using this methodology. NRC rated Callaway LERs as the best in the nation.

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A A strong point for Callaway 1 LERs is that the root cause information for most events is discussed very well as is the mode, mechanism, and effect of failed component Callaway's LER scores are indicative of an apparent commitment to provide LERs that meet the requirements of 10 CFR 50.73(b).

LERs BY CAUSE Total June 1, 1985 Cause* to May 31, 1986 Personnel Error 26 Equipment Failure 15 Design 2 Procedure _2 TOTAL 45

• Cause assigned by the licensee The total of 45 LERs is an improvement over the 74 LERs issued in the previous SALP period; however, the proportion of LERs attributed to personnel errors went from 33.7% to 57.7%. This resulted mostly from a corresponding reduction in equipment failure LERs from a proportion of 54% to 33%. Overall, continued reduction in the number of LERs appears feasible with most improvement to be made in reducing personnel error . Part 21 Reports There were no 10 CFR Part 21 reports submitted by the licensee in this assessment perio H. Licensing Activities NRR/ Licensee Meetings To Discuss Reload 2 12/05/85 To Discuss low-temperature over pressure protection system 11/07/85 NRR Site Visits / Meetings Training to obtain unescorted access and 06/24/85 &

meeting with resident inspector 08/28/85 Site Tour with regional personnel to discuss SALP report and meeting with resident inspector 04/29/86 Commission Meetings NONE

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4. Schedular Exemptions Granted NONE 5. Reliefs Granted NONE 6. Exemptions Granted NONE 7. License Amendments Issued Amendment 8 Extension of initial 18 month 10/03/85 surveillance interval Amendment 9 Deletion of resistance testing of 11/19/85 certain fuses Amendment 10 Revision to unit organizational 11/19/85 chart Amendment 11 Revision to fire pump diesel engine 01/22/86 surveillance requirement Amendment 12 Spent fuel pool enrichment limit 01/24/86

. Amendment 13 Revised value of Pa 03/04/86 Amendment 14 Quality Systems Department 03/04/86 organization Amendment 15 Reload 2 04/04/86 8. Emergency Technical Specification Changes NONE 9. Orders Issued NONE 10. NRR/ Licensee Management Conferences NONE

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