ML15261A337

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Discusses Mgt Meeting Conducted at Plant on 941220 for NRC to Present SALP of Facility During Period of 930502-941029. List of Attendees Encl
ML15261A337
Person / Time
Site: Oconee  Duke Energy icon.png
Issue date: 02/21/1995
From: Ebneter S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Hampton J
DUKE POWER CO.
References
NUDOCS 9503080231
Download: ML15261A337 (26)


Text

February 21, 1995 Duke Power Company ATTN:

Mr. J. W. Hampton Vice President Oconee Site P. 0. Box 1439 Seneca, SC 29679

SUBJECT:

MEETING

SUMMARY

- OCONEE NUCLEAR STATION SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

(INSPECTION REPORT NOS. 50-269/94-99, 50-270/94-99 AND 50-287/94-99)

Gentlemen:

This refers to the management meeting conducted at Oconee Nuclear Station on December 20, 1994. The purpose of the meeting was for the Nuclear Regulatory Commission to present the SALP of the Oconee facility during the period of May 2, 1993, through October 29, 1994. The SALP report was issued on December 13, 1994, and covered the performance of Plant Operations, Maintenance, Engineering and Plant Support activities at your Oconee facility.

A list of attendees and a copy of our slides are enclosed.

We have reviewed your response of January 17, 1995, which requested changes be made in the Plant Operations section to our SALP report. Based on our review, we have changed the SALP report with respect to your requests to include examples supporting our general comment on procedure adherance, as well as modifying our chairacterization of a reactor coolant pump ground and post-trip review. Accordingly, a revised SALP report has been enclosed. Regarding your comment that you had not restarted a unit with a significant safety question outstanding, the SALP report did not make that declaration. Rather, the report referenced an instance where your post-trip review did not adequately investigate/explain a power increase just prior to the trip or an excessively high main steam pressure following the trip. Whether or not they are later determined to have no safety significance, any anomalous indications should be aggressively investigated and explained to the fullest extent possible.

In accordance with Section 2.790 of NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

9O3F8F231 950221 pDR ADOCK 05000269 FDR OFFICIAL COPY

DPC 2

Should you have any questions concerning this matter, please contact us.

Sincerely, Original signed by Stewart D. Ebneter Regional Administrator Docket Nos.:

50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and DPR-55

Enclosures:

1. List of Attendees
2. SALP Slides
3. SALP Response
4. Revised SALP Report cc w/encls: Mr. J. E. Burchfield Compliance Duke Power Company P. 0. Box 1439 Seneca, SC 29679 Mr. A. V. Carr, Esq.

Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 Mr. Robert P. Gruber Executive Director Public Staff - NCUC P. 0. Box 29520 Raleigh, NC 27626-0520 Mr. Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, MD 20852 Mr. J. Michael McGarry, III, Esq.

Winston and Strawn 1400 L Street, NW Washington, D. C. 20005 cc w/encls: (cont'd -

See page 3)

DPC 3

cc w/encls: (cont'd)

Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Mr. Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 County Supervisor of Oconee County Walhalla, SC 29621 Manager, LIS NUS Corporation 2650 McCormick Drive Clearwater, FL 34619-1035 Mr. G. A. Copp Licensing - EC050 Duke Power Company P. 0. Box 1006 Charlotte, NC 28201-1006 Ms. Karen E. Long Assistant Attorney General N. C. Department of Justice P. 0. Box 629 Raleigh, NC 27602 INPO 700 Galleria Parkway Atlanta, GA 30339-5957 Distribution w/encls:

Chairman I. Selin Commissioner K. C. Rogers Commissioner E. G. de Planque J. M. Taylor, EDO J. L. Milhoan, EDO H. L. Thompson, Jr., EDO G. M. Tracy, Regional Coordinator, EDO W. T. Russell, NRR R. P. Zimmerman, NRR A. C. Thadani, NRR J. Lieberman, OE S. A.

Varga, NRR Distribution w/encl:

(Cont'd on page 4)

DPC 4

(distribution w/encl:

cont'd)

J. Zwolinski, NRR H. Berkow, NRR L. Wiens, NRR D. L. Gamberoni, NRR/ILPB (2 copies)

R. W. Cooper, RI E. G. Greenman, RIII A. B. Beach, RIV J. P. Jaudon, RH B. S. Mallett, RII J. R. Johnson, RH G. A. Hal1strom, RII S. J. Vias, RII K. M. Clark, RII R. E. Trojanowski, RII R. Carroll, RII NRC Resident Inspector Document Control Desk Mr. John C. Heard, Jr.

Chief, Tech. Hazards Branch Federal Emergency Management Agency Suite 706A 1371 Peachtree Street, N.E.

Atlanta, GA 30323 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29672 SEND TO PUBLIC DOCUMENT ROOM?

YES NO OFFICE Rll:DRP

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LIST OF ATTENDEES Nuclear Regulatory Commission:

S. Ebneter, Regional Administrator, Region II (RII)

A. Gibson, Director, Division of Reactor Safety, RII H. Berkow, Director, Project Directorate 11-3, Office of Nuclear Reactor Regulation (NRR)

L. Wiens, Project Manager, Project Directorate 11-3, NRR P. Harmon, Senior Resident Inspector - Oconee, DRP, RII L. Keller, Resident Inspector - Oconee, DRP, RII K. Poertner, Resident Inspector - Oconee, DRP, RII R. Carroll, Project Engineer, DRP, RH K. Clark, Public Affairs Officer, Office of the Administrator, RII R. Trojanowski, State Liaison Officer, Office of the Administrator, RII Licensee Attendees:

R. Priory, President and Chief Operating Officer, Duke Power Company (DPC)

M. Tuckman, Senior Vice President, Nuclear Generation Department, DPC J. Hampton, Vice President, Oconee Nuclear Site (ONS)

B. Peele, Station Manager, ONS J. Davis, Engineering Manager, ONS Other Licensee Attendees ENCLOSURE 1

UNITED STATES NUCLEAR REGULATORY COMMISSION OCONEE NUCLEAR STATION May 2, 1993 - October 29, 1994 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

MEETING December 20, 1994 ENCLOSURE 2

ReidntPrgrmNEW SALP PROCESS

'Resident Program Inspection Region Based Inspection SALP REGIONAL SSALP ucnns---

BOAR D/)

ADMINISTRATOR SALP initiatives Event Reviews MIP

FUNCTIONAL AREAS FOR OPERATING REACTORS

1. PLANT OPERATIONS
2.

MAINTENANCE

3.

ENGINEERING

4.

PLANT SUPPORT

- Radiological Controls

- Emergency Preparedness

- Security

OCONEE NUCLEAR STATION SALP BOARD MEMBERS Albert F. Gibson Director (Chairperson)

Division of Reactor Safety Region II Bruce A. Boger Acting Director Division of Reactor Projects Region II J. Philip Stohr Director Division of Radiation Safety and Safeguards Region II Herbert N. Berkow Director Project Directorate 11-3 Office of Nuclear Reactor Regulation

PERFORMANCE CATEGORY RATINGS Category 1.

Licensee attention and involvement have been properly focused on safety and resulted in a superior level of performance.

Licensee programs and procedures have provided effective controls.

The licensee's self-assessment efforts have been effective in the identification of emergent issues.

Corrective actions are technically sound, comprehensive, and thorough. Recurring problems are eliminated, and resolution of issues is timely. Root cause analyses are thorough.

Category 2.

Licensee attention and involvement are normally well focused and resulted in a good level of safety performance.

Licensee programs and procedures normally provide the necessary control of activities, but deficiencies may exist.

The licensee's self assessments are normally good, although issues may escape identification. Corrective actions are usually effective, although some may not be complete. Root cause analyses are normally thorough.

Category 3.

Licensee attention and involvement have resulted in an acceptable level of safety performance. However, licensee performance may exhibit one or more of the following characteristics.

Licensee programs and procedures have not provided sufficient control of activities in important areas.

The licensee's self assessment efforts ma not occur until after a potential problem becomes apparent. A clear understanding of the safety implications of significant issues may not have been demonstrated.

Numerous minor issues combine to indicate that the licensee's corrective action is not thorough. Root cause analyses do not probe deep enough, resulting in the incomplete resolution of issues.

Because the margin to unacceptable performance in important aspects is small, increased NRC and licensee attention is required.

OCONEE NUCLEAR STATION SALP RATING

SUMMARY

FUNCTIONAL RATING RATING AREA LAST PERIOD THIS PERIOD PLANT OPERATIONS 2

2 MAINTENANCE 2

ENGINEERING 2

2 PLANT SUPPORT N/A 1

EMERGENCY PREPAREDNESS 1

RADIOLOGICAL CONTROLS 1

SECURITY 1

SAFETY ASSESSMENT/

2 QUALITY VERIFICATION

OCONEE - PLANT OPERATIONS CATEGORY 2 STRENGTHS:

OPERATOR PERFORMANCE CHALLENGES:

TOLERANCE OF EQUIPMENT PROBLEMS CORRECTIVE ACTIONS PROCEDURE ADHERENCE

OCONEE - MAINTENANCE CATEGORY 2 STRENGTHS:

CORRECTIVE MAINTENANCE PREDICTIVE MAINTENANCE INSERVICE INSPECTION CHALLENGES:

PREVENTIVE MAINTENANCE CORRECTIVE ACTIONS PROCEDURE ADHERENCE

OCONEE - ENGINEERING CATEGORY 2 STRENGTHS:

SUPPORT ON EMERGENT ISSUES SELF-ASSESSMENT CHALLENGES:

BACKLOG MANAGEMENT OPERATIONS AND MAINTENANCE SUPPORT DESIGN CONTROL

OCONEE - PLANT SUPPORT CATEGORY 1 STRENGTHS:

SECURITY AND EMERGENCY PREPAREDNESS:

- AUDIT AND SELF-ASSESSMENT PROGRAMS

- TRAINING PROGRAMS

- EQUIPMENT ALARA PROGRAM CONTAMINATION CONTROLS RADIOLOGICAL EFFLUENTS AND ENVIRONMENTAL MONITORING PROGRAMS CHALLENGES:

CONTROL OF SAFEGUARDS INFORMATION CORRECTIVE ACTION - RADIOLOGICAL CONTROLS CONTROL OF COMBUSTIBLE MATERIALS

Duke Power Comanl I W HuiWM Oconee tuiear e Vice aenw P.0. Bar 1439 (803)885-3499 Office Seneca SC 29679 (803A564 Far DUKE POWER January 17, 1995 U. S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555

Subject:

Oconee Nuclear Station Docket Nos. 50-269, 50-279, 50-287, 72-4 NRC Inspection Report 50-269,-270,-287/94-99

Dear Sir:

By letter dated December 13,

1994, you transmitted the SALP report for the Oconee facility for the period from May 2, 1993 through October 29, 1994. A verbal presentation of that report was conducted in a public meeting on December 20, 1994 at the Oconee site.

I would like to thank you for the feedback provided in the SALP report. After reviewing the report, the Licensee has some comments we feel should be considered in the assessment of Plant Operations. These comments are provided in Attachment 1.

Please contact me, or members of my staff, if further information is needed.

Very truly yours, J. W. Hampton Site Vice President Oconee Nuclear Station cc:

Mr. Stewart D. Ebneter Regional Administrator, Region II U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323 Mr. L. A. Wiens, Project Manager Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, DC 20555 P. E. Harmon Senior Resident Inspector Oconee Nuclear Site ENCLOSURE 3 A~~~~ owap.aw m

U. S. Nuclear Regulatory Commission January 17, 1995 Page 2 cc:

Mr. R. E. Carroll, Jr.

U. S. Nuclear Regulatory Commission 101 Marietta Street, N.W., Suite 2900 Atlanta, GA 30323 Plant Operations The Plant operations section of the SALP report states "problems in procedure adherence outside of the Control Room continued from the last two assessment periods; these problems resulted in an inadvertent boron dilution and associated reactor

trip, a

subcritical reactor protection system actuation, and (in part) a reactor trip from flux to flow imbalance".

Although some examples of procedure adherence problems existed in Plant Operations during this SALP period, the events cited in the above statement are not entirely consistent with our records. For example, Oconee did not experience an inadvertent dilution event that resulted in a reactor trip. Also, the reactor trip from flux to flow imbalance resulted from spiking on the RCS flow transmitters. A planned boron dilution contributed to this trip in that it caused a slight increase in reactor power. Inspection Report 93-30 does not identify procedure adherence as a contributor to this trip. The Licensee requests that the NRC consider revising this statement to include examples which more accurately support your general comment on procedure adherence.

Page 2 of the SALP report states "examples of a non conservative safety approach included: delayed resolution of a reactor coolant pump ground, which masked further ground conditions and alarms on all three units for nearly one month; and a post-trip review which did not adequately assess or explain some anomalous plant responses".

The Licensee asks that you reconsider characterizing the DC ground and post trip review as examples of a non-conservative safety approach. We feel they would be more properly labeled as corrective actions that were not sufficiently aggressive in your view and not "examples of a non-conservative safety approach".

As you know, our DC power system is, by design, extensively cross-connected among units. Isolating portions to investigate grounds can place us in an LCO, and some troubleshooting steps can increase the risk of unit trips or transients.

It is occasionally a judgement call as to the relative risk of operating with a known ground versus finding and repairing the ground.

In the area of post-trip assessment, we are not aware of a case, including the cited example, where we have restarted a unit with a significant safety question outstanding. Given the comprehensive nature of the assessment procedure, it can be a judgement call as to how much research and documentation is necessary on a given piece of data, to give a clear basis for restart.

REVISED SALP REPORT ENCLOSURE 4

[REVISED FEBRUARY 21, 1995]

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT OCONEE NUCLEAR STATION 50-269/94-99, 50-270/94-99 AND 50-287/94-99 BACKGROUND The SALP Board convened on November 17, 1994, to assess the nuclear safety performance of Oconee Units 1, 2 and 3 for the period of May 2, 1993, through October 29, 1994. The Board was conducted per Management Directive 8.6, "Systematic Assessment of Licensee Performance."

Board members were A. F. Gibson (Board Chairperson), Director, Division of Reactor Safety; B. A. Boger, Acting Director, Division of Reactor Projects; J. P. Stohr, Director, Division of Radiation Safety and Safeguards; and H. N. Berkow, Director, Project Directorate 11-3, NRC Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by S. D. Ebneter, Regional Administrator, NRC Region II.

PLANT OPERATIONS This functional area addresses the control and execution of activities directly related to operating the plant. It includes activities such as plant startup, power operation, plant shutdown, and response to transients. It also includes initial and requalification training programs for licensed operators.

During the assessment period, there were nine reactor trips (two of which involved dryout of a steam generator), six unanticipated power reductions (including an automatic runback and taking a unit off line for a day), and four forced outages. Operator performance was considered to be very good in all of the above transients and other off normal conditions, including the startups and shutdowns associated with them and the three refueling outages conducted during this period. An excellent level of performance was apparent in the results of licensed operator examinations. Additionally, midloop operations in support of the Unit 2 steam generator tube leak repair and other steam generator inspection and repair activities throughout the period were well implemented and accomplished without incident. The licensed operator requalification program was adequate to provide for safe plant operations but, some weaknesses were observed in the program and its implementation.

Operator performance during routine power and refueling operations was satisfactory. While effective control room operator response and accurate diagnosis prevented, respectively on two separate occasions, a reactor trip and a turbine runback, problems in procedure adherence inside and outside of the control room continued from the last two assessment periods. These problems resulted in an inadvertent boron dilution, mispositioning a fuel assembly, a reactor trip Endlosure

2 pulling the wrong unit's turbine generator transformer drawers, and operation of a Keowee hydro unit above established load limits. In addition, operator inattention to detail also resulted in a subcritical reactor protection system actuation and, during routine dilution, contributed to a reactor trip from flux to flow imbalance.

Performance in safety assessment was also satisfactory. A conservative safety approach was exhibited in the decision to shut down Unit 2 and repair a steam generator tube leak that was well below Technical Specification and administrative limits. Another conservatively addressed issue was the Unit 1 assessment and justification for continued operation that was made with respect to the slow control rod drop times found in Unit 2. On the other hand, corrective actions for a reactor coolant pump ground (which masked further ground conditions and alarms on all three units for nearly one month) were not sufficiently aggressive and a post-trip review did not adequately assess or explain some anomalous plant responses. The implementation of a Plant Operations Review Committee in the latter part of the assessment period appeared to have had a positive impact on the thoroughness and outcome of post-trip reviews and other assessments affecting plant safety.

Corrective actions were not effective in preventing recurrence of the challenges identified in the previous assessment period concerning procedure-related problems (i.e., adequacy and adherence) including wrong unit and other configuration control errors. In addition, the challenges to the plant and operators from equipment-related failures continued throughout the period. The operator challenges and workarounds stemming from procedural inadequacies and equipment-related failures, as well as those resulting from poor fuel pool water clarity and ground detection system limitations, were reflective of Operations' tolerance of such conditions. Toward the end of the period, licensee efforts were appropriately directed toward addressing operator workarounds.

The Plant Operations area was rated Category 2.

III. MAINTENANCE This functional area assesses activities associated with diagnostic, predictive, preventive and corrective maintenance of plant structures, systems and components. It also includes all surveillance testing, inservice inspection and other tests associated with equipment and system operability.

Predictive maintenance and equipment monitoring were effective in identifying several potential equipment malfunctions. The licensee effectively utilized thermography, vibration monitoring, acoustic monitoring, and oil analysis programs to identify potential problems.

Enclosure

3 There were several instances where the licensee's predictive maintenance program identified incipient failures of critical equipment, thereby averting failures and resultant system challenges, as well as permitting orderly and well-planned repairs.

The licensee took actions to address previously-identified challenges.

Improvement was noted in developing and implementing integrated system testing, which was identified as a challenge in the last assessment period. The licensee also implemented several initiatives intended to improve maintenance work management. These initiatives appeared to be directed appropriately and, if properly implemented, should effectively address the problem.

Reliability of equipment continued to be a challenge. A number of equipment-related failures occurred during this period, some due to maintenance errors. Several of these failures resulted in plant transients. Equipment-related failures encountered during this period included:

failures of the Keowee generators due to voltage regulator and field flash breaker failures; a low pressure service water pump motor failure due to insulation breakdown; several failures of inverters due to old, obsolete equipment; significant leaks in letdown coolers; and several failures of main feedwater pumps and supporting equipment.

These reliability problems continued even though the licensee maintained an aggressive preventive maintenance program, expending 70 percent of the maintenance resources in the area of preventive maintenance.

The licensee's inservice inspection program was effectively implemented. Personnel were knowledgeable and well-trained in their areas of responsibility. The procedures, examination techniques, and documentation of results were generally good. Non-destructive test indications were thoroughly investigated.

Licensee personnel who performed steam generator tube inspection activities were adequately trained and performed in a professional mar-er.

A number of problems continued to occur relative to not following procedures, making inappropriate changes to procedures, and making errors due to incorrect or inadequate procedures. The licensee's corrective actions were not effective in resolving these problems.

Conduct of major work activities during outages improved during the period and was considered good overall. This was best demonstrated by the effective work planning and execution during the four forced outages. However, maintenance errors did occur as a result of poor work processes, particularly in the area of lifted lead controls. Corrective action had been ineffective in addressing this deficiency. Examples noted during this period included thermocouple leads being crossed when reinstalled on a low pressure injection cooler and inadequate planning for work on main steam stop valve circuitry, resulting in deenergization of the Unit 3 main feeder busses.

Enclosure

The licensee's independent self-assessment group was utilized primarily for reactive audits. Although there was no formal program for routine self-assessment audits of the maintenance program, the quality of the audits performed was very good.

The Maintenance area was rated Category 2.

IV. ENGINEERING Engineering and technical support for plant activities is assessed in this section. Design control as well as support for operations, maintenance, testing, and licensing activities are included.

Engineering support to operations and maintenance was satisfactory.

System engineers maintained good knowledge of the condition of their assigned systems and provided valuable support to operations.and maintenance on high-priority emerging issues. However, support in resolving some longer-standing issues was not as effective. Examples included turbine bypass valve logic discrepancies (which led to dryout of a steam generator before being corrected) and ground detection problems. Several of these issues were identified as operator workarounds and were receiving increased attention by Engineering late in the SALP period.

In general, the backlog of engineering work was managed satisfactorily.

The backlog of Problem Investigation Process Reports assigned to Engineering was small and appropriately prioritized. The backlog of drawing changes was reduced substantially from previous years and drawings supporting recent modifications were revised before the modified systems were placed into service. However, the backlog of Work Orders assigned to Engineering was not effectively managed. Many open Work Orders were over two years old. Steps were being taken late in the SALP period to prioritize and schedule resolution of these Work Orders.

Engineering performance in the area of design control was adequate.

Reviews by system engineers were effective in revealing longstanding design deficiencies, including discrepancies between the as-built plant, the design basis drawings, and procedures. For example, system engineers discovered a failure mode in containment isolation valves that could have caused loss of containment integrity, and piping interactions that could have caused a loss of post accident cooling following a seismic event. The licensee corrected each of these problems.

Engineering evaluations supporting licensing submittals were satisfactory. However, several engineering evaluations related to service water systems were not thorough. For example, an analysis that predicted two-phase flow in the low pressure service water system failed to assess the effects of piping vibrations caused by this flow. In addition, system design and performance information was not always properly translated into operations and maintenance procedures. For example, the failure to include information on a circuit breaker Enclosure

5 modification in a maintenance procedure caused an emergency AC power pathway to be inadvertently removed from service and the failure to include a design limit for the differential temperature between steam generator tubes and shell in station procedures resulted in the limit being exceeded. Deficiencies in the documentation and understanding of the Oconee design bases contributed to problems in this area.

A comprehensive self-assessment conducted late in the assessment period by the site engineering staff provided a candid assessment of engineering performance and the causes for performance deficiencies.

The Engineering area was rated Category 2.

V.

PLANT SUPPORT The Plant Support functional area addresses all activities related to radiological controls, emergency preparedness, plant chemistry, security, fire protection and plant housekeeping.

Performance in the radiological control area continued to be excellent during this period. The as low as reasonably achievable (ALARA) program was effective in achieving low collective total doses during both normal operation and outage periods. The collective site dose for 1993 was approximately 240 person rem. Although higher than 1993 due to the increased outage work, the collective dose for 1994 was well within the site goal of 592 person rem. ALARA activities that resulted in reduced doses included good outage planning with utilization of mockups, use of remote monitoring techniques, piping replacement, and hot spot removal.

The internal exposure control program was effective in minimizing intake of radioactive material. An aggressive area contamination control program which placed emphasis on personnel awareness and thorough decontamination methods was effective in maintaining a minimum contaminated area. The environmental monitoring program, supported by a well maintained meteorological system, was effectively implemented during this period. A program enhancement during this period was in the area of groundwater monitoring near the onsite chemical treatment ponds.

Environmental and effluent monitoring program results indicated that control measures were effective such that releases and resultant offsite doses were only a small fraction of established limits. The chemistry control program was adequately implemented, with coolant chemistry levels being maintained well within limits. Self-assessment audits in this area were thorough and effective in identifying problems. However, corrective actions for audit findings were not always adequate or timely, nor were completed actions always documented appropriately.

Performance in the emergency preparedness area continued to be a strength. A strong level of management support and involvement in the program was indicated by the level of participation in numerous drills, the well-maintained facilities and equipment, and continuing emergency preparedness program improvements. The emergency response facilities Enclosure

6 were well-supplied to support a response. Training programs were effective, as demonstrated by the excellent performance during the 1993 and 1994 exercises and walk-through evaluations with control room personnel.

The licensee's self-assessments during exercise critiques and audits were thorough, resulting in the identification of issues for improvement. Corrective actions for items identified in critiques and audits were prompt and effective. An exercise weakness related to internal communications was identified in each of the last two exercises. Appropriate corrective actions were taken by the licensee to correct the identified weakness.

With the exception of a failure to adequately protect safeguards information early in the assessment period, the performance of the security program continued at a high level during this period.

Appropriate corrective action was taken for this failure and there were no additional findings or problems in this area during the latter portion of the period. Security training was aggressive, with numerous enhancements made during the period such as special training courses, procurement of additional training aids, and additional certification in specialized areas. Audits of the security program were thorough and effective in identifying problems.

Identified problems were promptly resolved. Equipment testing and maintenance programs were effective in ensuring reliability. Compensatory measures, when necessary, were implemented in a timely and appropriate manner. Assessment aids, alarm stations, and communication equipment performed effectively, and the assessment capability was enhanced during this period by the installation and use of a video capture system.

In the fire protection area, there were instances involving lack of control over combustible materials in the Unit 2 electrical penetration room and reactor building. Procedural controls were strengthened and some improvement in the control of combustibles was noted. During the period, there was one small fire (caused by turbine honing oil being spilled onto a steam line) for which an appropriate response was made.

Overall, plant housekeeping was good. Post-outage cleanup activities were effective, as evidenced by the appropriate removal of work materials and no remaining debris in containment.

The Plant Support area was rated Category 1.

Enclosure