Text

SALP Repts 50-220/88-99 & 50-410/88-99 for Mar 1988 - Feb 1989
	ML17055E733
Person / Time
Site:	Nine Mile Point
Issue date:	05/22/1989
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
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ML17055E734	List: ML17055E733;
References
	50-220-88-99, 50-410-88-99, NUDOCS 8906010219
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SALP

BOARD REPORT

U.S.

NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT

OF LICENSEE

PERFORMANCE

INSPECTION

REPORT

NO. 88-99

NIAGARA MOHAWK POWER

CORPORATION

NINE MILE POINT UNITS

1

AND 2

DOCKET NOS.

50-220

and 50-410

ASSESSMENT

PERIOD:

March 1,

1988 to February

28,

1989

BOARD MEETING - April 13,

1989

85'060i0219

890522

PDR

A1iOCK 05000220

il

PDC

I

TABLE OF

CONTENTS

I

~

INTRODUCTION

Page

A.

Licensee Activities

1

B.

Direct Inspection

and

Review Activities ..............

3

II.

SUMMARY OF RESULTS ...........

5

A.

Overview ..

~

'

~

B.,

Facility Performance

Analysis

Summary .. ~.....,.........

6

C.

Unplanned

Shutdowns,

Plant Trips,

and

Forced Outages

.

7

III. CRITERIA

IV.

PERFORMANCE ANALYSIS

~

10

A.

B.

C.

D.

E.

, F.

G.

Operations

Radiological

and Chemistry Controls

.

Maintenance

and Surveillance

.

Emergency

Preparedness

Security

and Safeguards

Engineering

and Technical

Support

Safety Assessment/Quality

Verification

10

15

19

25

27

29

32

V.

SUPPORTING

DATA AND SUMMARIES

36

A.

B.

C.

D.

E.

Enforcement Activity

Confirmatory Action Letter

Inspection

Hour Summary ..

Licensee

Event Report Causal

Analysis and

Summary ..

Other

~

36

39

40

41

44

I'.

INTRODUCTION

The. Systematic

Assessment

of Licensee

Performance

(SALP) program is an

integrated

NRC staff effort to collect the available observations

and

data

on

a periodic basis

and to evaluate

licensee

performance

based

upon

this information.

The

SALP program is supplemental

to normal regulatory

processes

used to ensure

compliance with NRC rules

and regulations.

The

SALP program is intended to be sufficiently diagnostic to provide

a

rational basis for allocating

NRC resources

and to provide meaningful

guidance to the licensee's

management

to promote quality and safety of

plant construction

and operation.

An

NRC

SALP Board,

composed of the staff members listed below, met on

April 13,

1989, to review the collection of performance

observations

and

data

on. performance,

and to assess

licensee

performance

in accordance

with the guidance

in Chapter

NRC-0516,

"Systematic

Assessment

of Licensee

Performance."

A summary of the guidance

and evaluation criteria is

provided in Section III of this report.

The Board's findings and

recommendations

were forwarded to the

NRC Regional Administrator for

approval

and issuance.

Licensee Activities

Unit

1

The assessment

period

began with Unit

1 shut

down and defueled.

The

reactor

was shut

down in December

1987 as

'a result of a feedwater

system

induced t'ransient.

Following the shutdown, significant deficiencies

in

the licensee's

Inservice Inspection (ISI) and Fire Protection

Programs

were identified, thus requiring the unit to remain shut

down pending

resolution.

Throughout the assessment

period,

the majority of the activities at Unit

1 involved resolution of the ISI and Inservice Testing (IST) Program

concerns, fire barrier penetration

concerns,

operator requalification

and

Emergency Operating

Procedures

(EOP) training issues,

and resolution of

additional specific issues

outlined in the Restart Action Plan.

These

issues

are discussed

in further detail elsewhere

in this assessment.

NRC

Confirmatory Action Letter (CAL) No. 88-17 was issued to summarize

the

NRC's overallconcerns

with Unit

1 performance

and to formalize the

licensee's

corrective action commitments prior to Unit 1 restart.

The

CAL was issued

on July 24,

1988 and confirmed three requirements

which the licensee

has committed to meet before restart authorization

will be granted

by the

NRC.

Item one of the

CAL called for Niagara

Mohawk management

to determine

the root causes

of their problems.

Item

two called for the licensee

to develop short-term

and long-term

corrective actions to prevent recurrence

of these

problems.

To address

these

elements

of the

CAL the licensee

developed

and provided to the

NRC

on December

22, their Restart Action Plan

(RAP)

~

The

RAP was submitted

to the

NRC for review and approval

and delineates

short-term corrective

actions which the licensee

must take prior to Unit

1 restart.

The NIP

was

made available for review on site

and contains

long-term corrective

actions

and additional

programmatic

changes

needed.

At the

end of the

'assessment

period.

The

RAP was still undergoing

NRC review,

The third

item requires

the licensee

to conduct

and document, for NRC staff review,

a self-assessment

of their readiness

to restart Unit 1.

During the assessment

period,

major changes

in the licensee's

station

organizational

structure

were made,

as well as several

key personnel

changes.

Additionally, the

new position of Executive Vice President-

Nuclear was created

towards the

end of the assessment

period.

The

majority of the other changes

were at the site staff level

and took place

throughout the assessment

period.

Unit 2

Early in the assessment

period,

the licensee

completed the last phase of

the

Power Asension Test

Program

and declared

the unit available for

commercial

operation

on March 11,

1988.

The unit operated at power

until April 29,

1988,

when it was

shutdown to support

a three

week

planned

outage.

During power operations prior to the outage,

the unit

experienced

two scrams,

one of which was caused

by personnel

error.

The

three

week outage

was completed

and the unit was returned to power on May

22,

1988.

On Nay 23,

1988,

a recirculation

pump seal

leak caused

a forced plant

shutdown.

The seal

was repaired

and the unit was returned to power

on

May

30,

1988.

During power operations

through

September

2,

1988, the reactor

scrammed five times.

Two scrams

were the result of problems with the

Feedwater

Control

System,

two were caused

by deficiencies

in the Electro-.

hydraulic Control

(EHC) system,

and. personnel

error resulted

in one

additional

scram.

On September

2,

1988, the licensee

shut the plant down

due to missed

snubber surveillance testing

and

a leak in the cooling coils

of the main generator.

The unit was returned to power on September

15,

1988 on single recircula-

tion loop operation

due to binding of the "B" loop recirculation

pump

discharge

valve.

The unit operated at power until September

22,

1988,

when

a reactor

scram resulted

from a loss of Reactor Building Closed

Loop

Cooling due to an inadequate

plant impact assessment

for surveillance

testing.

The unit was returned to power and operated at power until the

start of a planned mid-cycle outage which commenced

on October

1,

1988.

, ~

The mid-cycle maintenance

and surveillance

outage

was scheduled

to be

completed

by December

1,

1988.

Outage activities continued through the

end of this assessment

period

on February 28,

1989.

The outage

was

extended primarily due to containment isolation valves fai ling Appendix J

leakage testing criteria and also

due to problems with the service water

system cross-connect

valve actuation logic not meeting the single failure

criterion.

B.

Direct Ins ection

and

Review Activities

Units

1 and

2

An

NRC Senior Resident

Inspector

was assigned

for the- entire -assessment

period.

Previously assigned

Resident

Inspectors

were reassigned

and

replaced

in June

and November

1988.

During the

12 month assessment

period,

the

NRC expended

a total of 7756

inspection

hours;

5250 hours0.0608 days 1.458 hours 0.00868 weeks 0.002 months at Unit

1 and

2506 hours0.029 days 0.696 hours 0.00414 weeks 9.53533e-4 months at Unit 2.

Functional

area distribution of inspection

hours is documented

at the

beginning of each individual. functional

area

and tabulated

in Table

2 in

Section

V.C.

During the period,

several

major

NRC team inspections

were conducted,

most focusing

on Unit

1 as noted below:

4

During the month of March,

1988,

an inspection of outage activities

at both units was conducted.

The inspection

involved

a

comprehensive

look at plant maintenance,

modifications

and

surveillance

at Unit 1, observation of a

100% load rejection startup

test for Unit 2,

and the procurement

program for both units with

emphasis

on purchase

and dedication of commercial

grade

items.

In June,

1988,

an in-depth review of the implementation

and

use of

Emergency

Operating

Procedures

(EOPs)

was conducted

by

NRC license

examiners

and by

NRC -contractors.

The inspection

focused mainly on

Unit

1 EOPs,

but as

a result of significant deficiencies identified

in Unit

1

EOPs,

the inspection

was

expanded to include Unit 2,

as

well.

For three

weeks in September

and October,

1988,

a Safety

System

Functional

Inspection

(SSFI) was conducted

by

NRC inspectors

and

contractors.

The inspection

involved an in-depth examination of the

Core Spray

System

and High Pressure

Coolant Injection (HPCI) mode of

the feedwater

system.

In November,

1988,

a one week inspection

was conducted

to determine

the status. of implementation of Regulatory

Guide

1.97 "Instrumenta-

tion for Light Water Cooled Nuclear

Power Plants to Assess

Plant

and

Environmental

Conditions during and following an Accident", at both

units.

In December,

1988,

a two week Maintenance

Team Inspection

was

conducted

at both units by

NRC inspectors.

The inspection

focused

on all aspects

of maintenance activities ranging from engineering

support to observation

of activities in the field.

In December,

1988,

a team inspection

was performed to examine the

status

of the licensee's

Inservice Inspection (ISI) program at Unit

1 to determine if corrective actions

were satisfactory in response

to previously identified deficiencies.

At the

end of the assessment

period,

a Special

Team Inspection

(STI) comprising

NRC personnel

and contractors

was conducted

on

site

and at the corporate

engineering office.

Overall focus of the

inspection

was to assess

the effectiveness

of management

controls

and oversight

mechanisms

in various

key functional areas.

Various other inspections

were conducted

throughout the assessment

period by

NRC 'resident

inspectors,

Region I and Headquarters

personnel

and by

NRC contractors'ost

of these

were combined

inspections

of a more routine nature

as

opposed to the comprehensive

team inspections.

An exception to this was

a special

inspection

by

the resident

inspectors

of wiring problems associated

with the

Automatic Depressurization

System

(ADS) at Unit 2.

This report is the

NRC's assessment

of the licensee's

safety performance

at

Nine Mile Point Units

1 and

2 for the period of March 1,

1988 through

February

28,

1989.

The

SALP Board for Nine Mile Point Units

1 5 2:

NAME

TITLE

W.

Kane (Chairman)

R.

Capra

R.

Conte

W.

Cook

J.

Johnson

W. Johnston

M. Knapp

M. Slosson

E. Wenzinger

Director, Division of Reactor Projects

(DRP)

Director, Project Directorate

No. I-l, NRR

Chief, Boiling Water Reactor Section, Division of

Reactor Safety

(DRS)

Senior Resident

Inspector,

Nine Mile Point

1 and 2,

DRP

Chief, Projects

Section

2C,

DRP

Deputy Director,

DRS

Director, Division of Radiation Safety

and

Safeguards

(ORSS)

Project Manager,

Nine Mile Point

1 and 2,

NRR

Chief, Projects

Branch 2,

DRP

Attendees

(non-voting)

R.

A.

D.

J.

W.

R.

V.

W.

R.

Banerjee

Barkley

Bellamy

Finkel

Florek

Furia

Hunemiller

Lancaster

Laura

Loesch

McCree

Pasciak

Shanbaky

Temps

Project Engineer,

Projects

Section

2C,

DRP

Reactor

Engineer,

Projects

Section

2C,

DRP

Chief,

FRSS Branch,

DRSS

Senior Reactor

Engineer,

DRS

Senior Operations

Engineer,

DRS

Radiation Specialist,

DRSS

Project Engineer,

NRR

Physical Security Inspector,

DRS

Resident

Inspector,

Nine Mile Point

1 and

2," DRP

Radiation Specialist,

DRSS

Project Engineer,

NRR

Chief,

ERPS,

DRSS

Chief,

FRPS,

DRSS

Resident

Inspector,

Nine Mile Point

1 and 2,

DRP

II.

SUMMARY OF RESULTS

Overview

Overall licensee

performance

during this assessment

period has not shown

significant improvement.

Even though the functional areas

of Security

Safeguards

and

Emergency

Preparedness

continue to be rated highly, the

remainder of the functional areas

have

shown marginal, if any,,improvement,

or have declined

In the area of Unit

1 Operations,

early in the assessment

period the poor

performance

by licensed operators

as reflected in their understanding

and

ability to implement the

new Emergency Operating

Procedures

indicated both

poor training and

a complacency with respect

to the adequacy

of the

training received.

Evidence of a strained relationship

between

the Operations

and Training Departmen

s also

was acknowledged

during the previous

assessment

period.

Actions taken during this assessment

period to remedy the situation

were not successful.

This lack of effective change in operator attitudes

toward training and the ineffective station

management initiatives to deal

with this situation continue to be significant concerns

to the

NRC.

In the areas

of Unit 2 Operations,

and Maintenance

and Surveillance,

the

high rate of personnel

errors

by both the licensed

and unlicensed staff

and maintenance

and testing

personnel

continued during this assessment

period.

Station

and corporate

management efforts to reduce or minimize

the frequent safety

system challenges

and plant transients

have not been

effective.

Likewise, the direct support to the station provided by the

Engineering'Department

staff has

been inconsistent

and not reflective of

an overall goal to improve performance

and enhance

long term station

reliability and safety.

This appears

to be reflective of low performance

expectations

in that it is

a newly licensed facility.

Corporate

and station

management

should assure

that the current level of performance for Unit 2

is not acceptable

in light of the large

number of unplanned trips and

shutdowns.

The

NRC acknowledges

the licensee's

commitment to a comprehensive

Nuclear

Improvement

Program which addresses

the root causes

and provides the

essential

elements

to effect overall

performance

improvements.

The

NRC

also acknowledges

the licensee's

recent

management

changes

made to provide

the necessary

leadership

to the Nuclear Division to ensure

a thorough

and

successful

implementation of this Program.

These

changes

are viewed as

, significant,

however,

because

they were

made late in the assessment

period

their effectiveness

has not been reflected in this assessment.

B.

Facilit

Per'formance

Anal sis

Summar

Last Period Dates

Unit

1

11/1/86 - 2/29/88.

Unit 2

2/1/87

- 2/29/88

Present

Period

Dates

Unit

1

3/1/88

- 2/28/89

Unit 2

3/1/88

- 2/28/89

Functional

Area

category

in the near future.,

For example,

a

classification,, of "Category 2, Improving" indicates

the clear potential

for "Category

1" performance

in the next

SALP period.

It should

be noted that Category

3 performance,

the lowest category,

represents

acceptable,

although minimally adequate,

safety performance.

If at any time the

NRC concluded that

a licensee

was not achieving

an

adequate

level of safety performance, it would then

be incumbent

upon

NRC

to take prompt appropriate

actions in the interest of public health

and

safety.

Such matters

would be dealt with independently

from, and

on

a

more urgent

schedule

than,

the

SALP process.

It should also

be noted that the industry continues to be subject to rising

performance

expectations.

NRC expects

licensees

to use industry-wide

and

plant-specific operating

experience

actively in order to effect performance

'mprovement.

Thus,

a licensee's

safety

performance

would be expected to

show improvement over the years in order to maintain consistent

SALP

ratings.

IV.

PERFORMANCE ANALYSIS

A.

Operations

l.

~Anal sis

(2274 hours0.0263 days 0.632 hours 0.00376 weeks 8.65257e-4 months ,

29.3%)

Unit

1

(1464 hours0.0169 days 0.407 hours 0.00242 weeks 5.57052e-4 months ,

18.95)

In the last assessment

period,

performance

in this area

showed little

improvement

and was rated Category

2.

Contributing to that rating was the

noted complacency of operator s with respect to overall station quality of

operations.

During the last assessment

the

NRC staff identified the need

for corporate

and station

management

to provide positive incentives to

revitalize, motivate

and better integrate

the Operations staff with other

departments.

11

During this assessment

period,

the unit remained

shut

down

and defueled,

thereby prohibiting assessment

of operators'erformance

for at-power

operations.

However, observations

of Operations staff support of major

maintenance,

modification and testing activities (including defueling of

the vessel)

indicated technical

competence

and

a good level of knowledge

of systems

operation during the plant shut down.

This was particularly

evident during the Safety

System Functional

Inspection

conducted

in

'eptember

1988 in the operators'upport

provided to the inspection

team.

Personnel

errors

by Unit

1 operators

were infrequent

and isolated this

assessment

period.

Efforts by management

to better integrate

the Operations staff with other

departments

have

been

made during this assessment

periods

These efforts-

included; initiation of the Operators Training Program Advisory Committee

(OTPAC) and interface meetings

between

the Operations

and the Training

departments;

assignment

of

oversight responsibility for the Licensed

Operator Requalification Training Program to the Operations

Superintendent;

rotational

assignments

of Reactor Operators

(RO) and Senior Reactor

Operators

(SRO) to the Training Department;

and special

assignments

of

licensed operators

to the Maintenance

and Engineering staff,

as

needed

during outages.

V;",ile several

of these efforts have not been in place

long enough to provide evaluative results,

the

OTPAC was viewed

as

a

positive step to resolve

longstanding

problems

and

has

been generally well

received

by the operators.

One area requiring continued

management

attention

was the matter of

operators'ttitude

towards continued training as demonstrated

by their

behavior during training sessions.

Specific instances

of abusive

and

disruptive behavior

by licensed individuals during requalification training

were noted

by the

NRC,

as well as

NMPC management.

There continued to be

resistance

by some operators

towards integration with the training depart-

ment.

In addition, station

management's

efforts to improve

operators'ttitude

and performance

were ineffective.

This concern

was identified

in the previous

SALP and continues

to be

a significant concern to the

NRC.

During this assessment

period,

the

NRC identified that Unit

1 operators

were not attending

the requalification classes

as required.

Senior

management

was not ensuring that all requalification requirements

were

completed prior to submitting licensed operator

renewal applications.

A

review of the Licensed Operator Requalification Training Program revealed

that

39 licensed

operators

had not completed the required training prior

to the

end of the annual requalification period.

In addition, deficiencies

were noted in the facility senior

management

involvement in the requalifi-

cation program,

in that the operator

renewal

license applications

contained

inaccurate

information concerning

the completion of the requalification

12

program requirements.

These deficiencies

led to the issuance

of Confir-

matory Action Letter (CAL) 88-13 which identified actions that were to be

taken to correct the deficiencies.

Subsequent

inspection

showed that the

licensee

had completed

the immediate actions

necessary

to comply with

CAL 88-13.

During the inspection of the Unit

1 Emergency

Operating

Procedures

(EOPs),

the

NRC observed that the more experienced'o'perators

were not able to

adequately

use the

EOPs.

The operations

crew observed

could not properly

implement the

EOPs

and lacked

an understanding

of the basis for the

EOPs.

Specific

EOP training deficiencies

included:

a fundamental

understanding

of the

EOPs,

the understanding

of the accident'itigation

strategies,

the

ability to implement the

EOPs,

poor

team work and communications,

and the

recognition of emergency

system status

and degraded

plant conditions.

The

inspection

determined that the

EOPs were generally well written and

useable'he

lack of operator familiarity of the

EOPs

was

due to inadequate

training

during requalification

and the lack of operations

management

involvement

'in assuring

the training was effective.

It was subsequently

identified

that licensed

operators

had expressed

concerns

to station

management

about

the quality and quantity of training on the

new EOPs.

However, neither

the operators

or station

management

pursued

these

concerns

to appropriate

resolution until it became

a regulatory concern.

In summary,

the Unit

1 Operations

concerns

raised during the previous

assessment,

with respect

to operator

complacency

and the strained

relationship with the Training Department,

were not adequately

addressed

this assessment

period

and continue to be of major concern to the

NRC.

Operators'ttitude

have not significantly changed

and station management's

efforts have

been

unsuccessful

in dealing with these

concerns.

However,

it is noted that subsequent

to the

end of this assessment

period discip-

linary action

was taken against certain individuals in the Operations

Department indicating that certain patterns

of behavior

would no longer be

tolerated.

Unit 2

(810 hours0.00938 days 0.225 hours 0.00134 weeks 3.08205e-4 months ,

10.4%)

This area

was rated Category

2 (Improving) in the previous

assessment.

During that asessment

period,- the licensee

had

pt ogressed

through initial

criticality and the majority of Test Condition

6 of the

Power Ascension

Testing

Program.

Minor weaknesses

were noted in the control

room environ- .

ment,

the control of operator aids,

the lack of familiarity of operators

with emergency

equipment location, the lack of emergency diesel

generator

operating

logs and the lack of an efficient method of tracking the

operating

time on special filter trains for the purpose of meeting

Technical Specifications

sampling requirements.

A more significant

13

weakness

was identified in the area of operator attention to detail

as

demonstrated

by numerous

personnel

errors

and procedural

compliance

violations.

Improvement

was noted in the area of operations

management

oversight of day-to-day activities,

communications

and responsiveness

to

identified concerns'n

addition, Operations

Department

support of the

Power Ascension

Test

Program

was both enthusiastic

and professional.

Operator

conduct of testing

was cautious

and response

to testing

anomalies

was prompt and conservative.

Personnel

errors continued to occur at

a high rate during this assessment

period.

The majority of these

errors

were caused

by inattention to

detail or failure to follow procedures.

An inadequate

plant impact

assessment

for the performance of a loop calibration

on

a feedwater flow

transmitter resulted

in the 3/21/88

scram.

Improper operator control of

steam

loads during start-up

resul,ted in the 6/28/88 reactor

scram.

Improper assessment

of the impact of cycling of a service water alternate

cooling outlet valve

on

a spent fuel pool cooling heat exchanger

resulted

in

a loss of Reactor Building Closed

Loop Cooling water and

a manual scram

on 9/22/88.

Several

personnel

errors

were

made during the work release

process,

which

resulted

in inadvertent

Engineered

Safety Features

actuations,

a spill of

1000 gallons of acid,

and

a temporary loss of shutdown cooling.

Although

these

personnel

errors relevant to the work release

process

resulted

in

events of relatively minor safety significance,

the potential effects of

these

types of errors could result in more serious

problems.

Other miscellaneous

personnel

errors occurred during this assessment

period.

For example,

during the performance

of a monthly surveillance

test,

an operator

performed

a switch line-up incorrectly which resulted

in

a

Low Pressure

Coolant Injection to the reactor vessel.

Another error

occurred while securing

from an

Emergency Diesel Generator

(EDG)

surveillance test.

An operator inadvertently

opened

the offsite power

breaker

instead of the

EDG output breaker.

This broad

spectrum of personnel

errors exemplifies the lack of attention

to detail

and failure to follow procedures.

As noted in the previous

assessment

period

and

as discussed

above,

numerous

personnel

errors

continue to be experiended

by the licensee.

Corrective actions, to date,

have not been effective in reducing the

number of errors.

This lack of

, effective corrective action to reverse this trend indicates

inadequate

management

response

to an identified concern

and inadequate

assessment

of

the root causes.

More significantly, these continuing personnel

errors

represent

station

and corporate

management's

low expectations

and

acceptance

of the present

level of employee

performance.

Other observations

of control

room activities indicate that the operators

are experienced,

knowledgeable

and alert to off-normal indications or

potential

problems.

An example of this was the performance of Automatic

Depressurization

System

(ADS) testing during this assessment

period.

The

control

room operators

and technicians

conducting the test identified a

significant system wiring error that effectively disabled

the Division I

ADS and which had

gone undetected

since initial fuel load.

Control

room formality was observed

to be satisfactory;

however,

there is

a la'rge

number (approximately

50-60) of lit annunciators

in the control

room that exist during normal plant operations

and which could mask

a

potential

problem.

This also reflects

an environment that accepts

a low

standard.

The licensee

does

have

a program to reduce

the

number of

normally lit annunciators,

but progress

to date

has

been

slow.

More

emphasis

should

be placed

on this item'y station

and Engineering

Department

management.

Evidence exists to demonstrate

that Operations

management

has

become

more

involved and aggressive

in improving the operations staff training,

professional

development,

and working environment.

Examples include:

minimization of overtime;

successful

negotiation for five additional

SRO

positions;

approval

of an

SRO inter-departmental

rotation policy for

career

development;

increased

training for non-licensed

operators,

including simulator training;

and the development of an improved equipment

markup instruction for the Operations

Department.

An example of the

Operations staff being proactive involves the implementation of

BWR

Owners'roup

recommendations

for actions to take

when experiencing

power

oscillations

subsequent

to

a recirculation

pump trip.

Procedures

were

~ revised

and operators

trained well in advance of the

NRC Bulletin being

issued.

The concern identified at Unit I regarding operators'nability

to

understand

and adequately

use the Emergency Operating

Procedures

(EOPs)

did not exist at Unit 2 when the Unit 2 operators

were subjected

to the

same type of scenarios.

The major difference

was determined to be that

the Unit 2 operators

were accustomed

to the

EOPs

as part of their initial

license training and conduct

more frequent training on

EOPs in the

Requalification Training Program.

In summary,

the Unit 2 Operations

Department is staffed with experienced

and competent

personnel;

however, closer attention to detail

by operations

staff and licensed operators

is needed to stem the

numerous

personnel

errors.

More importantly, station

and corporate

management's

performance

expec-

tations were too low and

have resulted

in complacency

as exemplified by

the overall poor performance

trend during this assessment

period.

15

2.

Performance

Ratin

Category:

Unit 1-

3

Unit 2-

3

3.

Board Recommendations:

NRC:

Restart

Panel

continue to monitor licensee

performance

and assist

in directing

NRC inspection

efforts at

NMP ~

Licensee:

Unit

1 - (See

note below)

Unit 2 - Raise

performance

expectations

of the Unit 2

Operations

Department

and closely monitor

progress'

Develop

and implement

a detailed

and timely

plan to reduce

the

number of lit

annunciators

on the main control panel.

Note:

No specific recommendations

have

been

made for this or any

other functional area, if it is addressed

in the licensee

corrective actions

documented

in the Restart Action Plan

and Nuclear

Improvement

Program which have

encompassed

the

major areas

of concern to the

NRC.

B.

Radiolo ical

and Chemistr

Controls

(513 hours0.00594 days 0.143 hours 8.482143e-4 weeks 1.951965e-4 months ,

6.6%)

l.

~Anal sis:

The combined Radiological

Control

Programs at Nine Mile Point Unit

1 and

Unit 2 were rated

as Category

2 (Declining) during the previous

assessment

period.

Program weaknesses

identified last period indicated

a need to

.improve supervisory oversight of ongoing work activities; personnel

attention to detai 1; the corrective action program to ensure

personnel

are

adhering to good radiological control practices

and procedure

requirements;

contamination control; ongoing job ALARA reviews

and non-radiological. water

chemistry.

During this assessment

period,

region-based

inspectors

performed

seven

routine inspections.

Radiological controls were also

examined during

a

Maintenance

Team Inspection.

The resident

inspectors

reviewed this area

on

an on-going basis.

16

Radiation Protection

The radiation protection

program is

common to both units and is implemented

through two separate

radiation protection groups reporting to

a

common

manager

~

During this assessment

period, the licensee

implemented

several

personnel

and organizational

changes,

the most significant being the

replacement

of the Unit

1 Radiation Protection

Supervisor

and the creation

of a dedicated

Site

ALARA Coordinator.

NRC observations

late this assessment

period indicated that first line

supervisory oversight of,ongoing work activities

has

improved with the

addition of several

new Chief Technicians.

However, the licensee failed

to identify, over

an extended

period of time,

a situation where permanently

installed ladders

allowed unauthorized

access

to the Radwaste

Sample

Tank

Room,

an area controlled as

a Locked High Radiation Area.

In addition,

the Radiation Protection

Manager

and the Supervisor of Radiological

Support

had infrequently entered

the Reactor Buildings indicating

a continuing

need for additional

management

oversight.

An adequately

defined personnel

training

and qualifications program is

maintained

and implemented.

For contract health physics technicians,

the

licensee verifies experience,

administers

a screening

exam to evaluate

technical

background

and provides additional site specific training as

necessary.

The program to maintain radiation protection

personnel

cognizant of new procedures

and procedure

changes,

a weakness

identified

in the previous

assessment

period, is adequate.

The appropriate

personnel

were trained

on the required

procedures

in a timely manner

and procedure

adherence

has

improved.

The licensee's

ALARA program

management

has

shown

improvement during the

current assessment

period.

The use of detailed isometric diagrams of the

'drywell helped

reduce

exposures

associated

with locating individual

components.

In addition,

improvements

were realized

by the use of a

mockup at Unit 2 in planning corrective maintenance

on the recirculation

loop isolation valve.

In response

to

NRC concerns,

the site

ALARA program

respon-sibi lities were transferred

from the Respiratory Protection

Coor-

dinator to

a dedicated

Site

ALARA Coordinator.

To strengthen

and upgrade

the site

ALARA program,

a consultant is currently assessing

the program's

effective-ness

and

recommending

improvements.

Improvements

included

changes

to the Radiation

Exposure Monitoring System

(REMS), the addition

of hold points

on jobs not initially requiring

an ALARA review,

and methods

to reduce

the person-rem

exposures

associated

with miscellaneous

RWP's.

In addition, to improve corporate oversight of the program,

a Health

Physicist

from the site organization

was transferred to the corporate staff

to coordinate

ALARA improvements.

17

Licensee

exposure for 1988 totaled approximately

804 person-rem for Unit

1

(outage year)

and

85 person-rem for the startup year at Unit 2.

Although

above

the industry's

annual

BWR average of approximately

500 person-rem,

the extended

outage

at Unit

1 and significant ISI rework contributed to

the higher exposures.

Licensee

performance

during

1988 was adequate

given the additional

work scope

and high inplant source

term and

showed

improvement during the

second half of the

SALP period.

Goals for 1989

have

been

set aggressively

at

509 person-rem for Unit 1 and

128

person-rem for Unit 2 (its first full operating year).

Unit

1 continues

to suffer from a high inplant source

term.

Chemical

decontamination

efforts originally planned for 1988

have

been delayed

and is currently

under consideration

for the

1990 refueling outage.

These

delays

are

contributing to the continued

high person-rem

exposures

at Unit 1.

Adequate internal

exposure controls

and contamination controls were

provided for ongoing work.

Licensee corrective actions

and assurance

of

quality were generally

adequate

although occasional

weaknesses

were

exhibited.

For example,

a review this period of corrective actions

associated

with a workers ingestion of a hot particle indicated

an

aggressive

approach

to both the worker's concerns

and the technical

evaluation of the existence

of a discrete particle

and its characteristics.

In contrast,

the licensee

incorporated

a

new type of respiratory protection

equipment into the emergency kits without first establishing

and imple-

menting the necessary

procedures.

The licensee

took actions to improve intra-departmental

coordination of

work activities.

A Work Control Center

was established

at Unit

1 for the

processing

of all work requests

and

a dedicated

Health Physics

Planner

provides

a single interface with the Radiation Protection

(RP) department

in the processing

of required Radiation

Work Permits

and pre-job

ALARA

reviews.

In addition,

two

RP liaisons were assigned

to the Unit

1

Maintenance

department

to coordinate on-the-job support of work

activities.

These

licensee initiatives have

improved the coordination of

work activities with the

RP group during the Unit

1 extended

outage.

Radioactive Effluent Controls

The program for Unit

1 was evaluated

in the areas of instrument calibration,

release

permits,

the Off-Site Dose Calculation

Manual

and the semiannual

effluent reports,

and found to be effectively implemented.

The program

for Unit 2 has

shown improvement

from the last assessment

period.

As

identified in the previous

SALP, operability of the Gaseous

Effluent.

Monitoring System

(GEMS) has

been

a continuing problem at Unit 2.

Further, alternate

methods for gaseous

effluent monitoring when the

GENS

was inoperable

had been lacking.

The licensee

has taken action to

improve the operability of the

GEMS and

has developed

and implemented

I

'I

18

procedures

for alternate

monitoring methods

when the

GEMS is inoperable.

During the assessment

period there

were

no unplanned effluent releases,

and planned

releases

were at levels

normal for a Boiling Water Reactor

site.

~di

i

E

i

'

N~ii ~~

The licensee

has contracted with a vendor laboratory to perform the

analysis of environmental

samples

required for the Radiological

Environmental

Monitoring Program

(REMP).

The licensee's

environmental

dosimetry

program results

show good agreement

with both the State of New

York and

NRC environmental

dosimeters.

Audits in this area of both the

vendor laboratory

and the

REMP were found to be thorough, with all

recommendations

addressed

in a timely manner.

The transportation

program is conducted

by

a site Materials Shipping group

which has

shown significant improvement since the hiring of a group

supervisor during the

second half of the

SALP period.

Filling of this

position

has

led to additional

management

review of shipments prior to

leaving the site,

which reduces

the chances

of errors while shipping.

There were

no major problems

noted during this period.

The licensee is in

the process

of implementing the

use of a computer

code for the purposes

of

determining transportation

and waste classification which will further

enhance this program by reducing calculational errors.

Solid Radioactive

Waste

Each unit at the site continues

to maintain its own program for the

processing

and packaging of radwaste.

Although these

two programs utilize

separate

vendors

and processes,

each

has continued to improve its program.

Continued developments

by both units in the area of waste solidification

wi 11 further

enhance

these programs.'udits

by the licensee's

quality

assurance

department

were thorough, with all recommendations

addressed

in

a -timely manner.

During this assessment

period the licensee

could not account for several

small, non-irradiated,

local

power

range monitor fission chambers.

The

licensee identified that this small

amount of special

nuclear material

was missing

as

a result of an annual audit,

and believes that the fission

chambers

were disposed

of with radioactive waste.

The discovery of the

missing material is commended;

however,

the loss is reflective of a

previously ineffective special

nuclear material control program.

19

Overall

~Summar

r

.I

The licensee

made

several

enhancements

to address

previously identified

weaknesses

and the overall

program

has

shown steady

improvement over the

SALP period.

Observations

indicate that although supervisory oversight

of ongoing work has

improved,

RP management

oversight is weak.

In

addition, significant licensee initiatives which began late in the assess-

ment period are expected

to improve accountability

and oversight of ongoing

work.

2.

Performance

Ratin

Category:

2

3.

Board Recommendations:

NRC:

None

Licensee:

Place

more emphasis

on Unit

1 decontamination

C.

Maintenance

and Surveillance

(2639 hours0.0305 days 0.733 hours 0.00436 weeks 0.001 months , 3')

l.

~Anal sis

During the previous

assessment

period, the maintenance

and surveillance

areas

were evaluated

separately

and each

area

was rated Category

2.

For

this assessment

both functional areas

have

been

combined

and one category

rating is assigned.

During this assessment

period the licensee

transferred

the responsibility

for the Instrumentation

and Controls

(18C) organization

from the Technical

Superintendent

to the Maintenance

Superintendent

as part of a station

reorganization.

The Unit

1 and Unit 2 Maintenance

Superintendents

and

Unit Supervisors

presently

have

a dual reporting responsibility to the

Site Superintendent

of Maintenance

and the Station Superintendents

of

'nits

1 and 2.

Maintenance - Unit

1 and

2

During the last assessment,

improvement in first line supervisory oversight

and higher visibility and interaction of senior maintenance

management

in

the field were noted.

Root cause

evaluations

and attention to detail in

maintenance

implementation

were noted

as weaknesses,

but were showing

signs of improvement.

20

Improved management

involvement in housekeeping,

selective

observation of

work in progress

and interface

and feedback

meetings with craft personnel

indicated

management's

contribution to an overall effectively implemented

maintenance

program this assessment

period.

Maintenance

Department

management

benefits

from experienced

and knowledgeable

personnel

who

provide continuity by their long term involvement

and low turnover rate.

Contractor maintenance

work was effectively controlled;

however,

weaknesses

existed in the type of checklist

used for the surveillance of

the contractors.

A system for maintenance

trending

and performing root

cause

analysis

has

been established

with both corporate

and site

personnel

trained in the analysis

techniques.

The Nuclear Engineering

Organization

has established

a central

program to evaluate

the

effectiveness

of the maintenance

program,

In addition to

a

sound corrective

and preventive

maintenance

program the

licensee

has initiated the increased

use of predictive

and diagnostic

techniques.

A rotating equipment vibration analysis

program

and

use of

infrared thermography

techniques

are

among the

new techniques

being used.

An additional initiative developed

is the functional work control program.

Work is being planned, prioritized and scheduled

in accordance

with

directives.

Backlog monitoring has

been established

through the

use of

maintenance

performance

indicators

and the work tracking system.

Despite these initiatives, weaknesses

in procedural

adequacy

and

compliance

were observed this assessment

period.

The written periodic

maintenance

program did not appear to include all vendor recommendations

and

some of the periodic maintenance activities were being performed

without the benefit of written guidance.

A review of Unit

1 waste

surge

tank

pump and diesel fire pump and Unit 2 emergency diesel

generator

maintenance

indicates

procedures

were either not being complied with or

were poorly written.

Some maintenance

personnel

appeared

to be

insufficiently trained to properly implement these

procedures

or change

them if necessary.

The maintenance

personnel

continuing training program

was also

found to be lacking and inconsistently

implemented.

Concerns

regarding procedural

compliance

were brought to the licensee's

attention

early in the assessment

period and periodically thereafter.

However,,the

licensee

did not take prompt and effective action to reverse this trend.

Another weakness

that continues to exist is in the area of followup and

correction of previously identified problems.

An example

was

poor

followup on the maintenance

self-assessment

performed in 1987.

A

licensee

audit identified that

no program or responsible

organization

was

made accountable

for reviewing maintenance

self-assessment

item

resolutions

and

recommending corrective actions.

21

In contrast to the weaknesses

addressed

above,

the repair of the

recirculation

loop isolation valve at Unit 2 was

an example of a well

planned

and executed

maintenance activity.

The licensee utilized a

mock-up to ensure proficiency during the actual

maintenance

and to fine

tune the work instructions.

No significant problems were encountered

physically or procedurally.

During, the last assessment,

problems in the

area of repetitive equipment failure due to inadequate

root cause

determination

were documented.

In this assessment

period,

no problems of

this nature

were observed.

During this assessment

period several deficiencies

were noted with

housekeeping,

in particular with the material condition of the HPCI/FW,

shutdown cooling

and core

spray

systems at Unit 1.

In addition, the

237 foot elevation of Unit

1 reactor building including the entrance

to

the drywell and the

CRD hydraulic control units area

were in poor

condition and inhibited routine tours

by plant personnel.

Typically the

remote

areas

of the plants

and the high work areas

have

been of concern;

however, overall

improvements

in housekeeping

were observed

during this

assessment

period.

For example,

the condenser

bay and refueling floor

areas

were

much improved.

Increased

management

and station

employee

attention to this area

was evident.

Surveillance - Unit

1

During the previous

assessment

period,

the Technical Specification

surveillance testing

program

was determined to have

been effectively

implemented with only minor problems identified.

However,

numerous

problems identified in the Inservice Inspection

( ISI) Program

demonstrated

the

need to strengthen

corporate

and station

management

oversight of the program.

During this assessment

period,

missed

surveillance

tests

and surveillance

remained at

a low levels

Licensee corrective actions for

the

known ISI problems resulted in the identification of more ISI Program

deficiencies.

Additionally, problems

were identified by the licensee

in

the Inservice Testing

( IST) Program this assessment

period.

Problems in

the ISI and

IST Programs

are attributed to past

management

ineffectiveness

in the oversight of these

programs.

Followup

NRC inspections early in the assessment

period identified additional

ISI weaknesses

in the area of licensee

overview of contractor activities

involving thickness

measurements

of piping systems

and the torus shell.

Additionally, the licensee's

own. Quality Assurance

(QA) Department

issued

a Stop Work Order

on contractor's

ISI activities because

of the poor

quality of examination

documentation

and result evaluation.

This action,

although indicative of good

QA oversight,

indicates

weak oversight

by the

Engineering staff who were responsible

for revising and implementing the

ISI Program

and associated

corrective actions.

22

Throughout the assessment

period,

licensee

management

devoted considerable

resources

to resolve

the issues

related to ISI on Unit 1.

NRC reviews

near, the

end of the assessment

period determined that the licensee

had

established

satisfactory control

systems

and

a

new organization staffed

with appropriately qualified individuals to effectively implement the

new

ISI Program.

The Unit I Safety

System Functional

Inspection

(SSFI)

team found

some

examples

where the surveillance testing data collection, results

review

and acceptance

criteria would not adequately

suoport

system operability

decisions.

This weakness

appeared

to be

a direct result of poorly

defined

system design

requirements.

A subsequent

team inspection

identified examples of poor procedural

compliance

and adequacy.

Frequently

performed surveillance tests

were not followed step-by-step

and in some instances

the attached checklists

were

used without reference

to the written procedure.

Surveillance

Unit 2

During the previous

assessment

period,

several

surveillance tests

were

missed

because

of inattention to detail

and .insufficient supervisory

oversight.

In additi'on,

numerous

unanticipated

events

occurred during

the performance

of surveillance testing.

These

events

were generally the

result of test procedure

inadequacies

or personnel

errors.

The

implementation of the Surveillance

Testing

Program

was found to be

adequate

during the initial phase of power operations;

however, closer

management

attention

was needed.

During this assessment

period, the licensee's

failure to perform required

surv'ei llance tests

was again

a concern.

Examples of missed tests

included: failure to record surveillance

data during reactor

cooldown

subsequent

to

a reactor

scram due to operator error; failure to perform

a

surveillance

test

on

a primary containment penetration

due to personnel

error; missed

snubber surveillance tests

due to an inadequate list of

snubbers;

and missed

Average

Power

Range Monitor surveillance

due to

programmatic deficiencies.

As in the previous

assessment

period, this

high 'number of missed surveillance tests

indicates inattention to detail

and insufficient supervisory oversight.

The missed surveillance tests

were spread

between

the different station departments

and the Engineering

staff.

The unit again experienced

many unanticipated

events during the p'erfor-

mance of surveillance

testing during this assessment

period.

The pre-

ponderance

of these

events

was caused

by procedural

inadequacies

or

personnel

error.

I

23

Examples of events

caused

by procedural

problems include

an inadvertent

actuation of the standby liquid control

system

(SLS) discharge

valves

during

SLS surveillance testing

and

a temporary loss of shutdown cooling

during leak detection

surveillance testing.

These test procedure

inadequacies

were not considered

to be

a significant problem,

but indicate

technical

procedural

development

could be improved.

Examples of events

caused

by personnel

errors include

a high pressure 'core

spray

(HPCS)

system .initiation during surveillance testing

when

an

I8C

technician failed to follow the procedure

by measuring

resistance

across

an open contact vice measuring

voltage

as specified in the procedure,

'and

a reactor

scram which resulted

from an inadequate

plant impact assessment

before performing loop calibrations

on feedwater flow transmitters.

These

procedural

problems

and personnel

errors collectively indicate poor station

management

oversight, especially

since the

same

concerns

were identified

during the last

assessment

period.

Corrective actions to address

these

concerns

include the development of a

more formalized tracking system,

the implementation of an Engineering

Department control

program for Technical Specification

equipment

surveillance lists,

and

( subsequent

to the

end of the assessment

period)

the clarification of, and training on, the procedural

compliance policy

and requirements

documented

in Station General

Order 89-03.

NRC review of the Unit 2 ISI Program identified that staffing was

adequate

and personnel

were experienced

and knowledgeable.

Examination

data

were well documented,

licensee

reviews were thorough

and

professionally

done.

The disposition of results

was technically

justified and the closeout of findings was based

on sound engineering

analysis.

Implementation of the Unit 2 ISI Program

was considered

good.

The Power Ascension Testing

Program

(PATP) was completed during the

assessment

period.

The results

indicated that the testing occurred

= without major exceptions

and

was consistent with the good quality of the

PATP as discussed

in the previous

assessment.

The minor exceptions

were

adequately

analyzed

and resolved.

The program

was closed with no major

technical

problems.

Fire Protection - Units I and

2

During the. previous

assessment

period frequent

and recurring personnel

errors were noted in the implementation of the station Fire Protection

Program with an improving trend at the conclusion of the assessment

.period.

This trend did not continue throughout this assessment

period as

similar personnel

errors occurred.

In addition, the licensee identified

a significant breakdown in their Technical Specification fire barrier

24

penetrations

surveillance

program which led to the discovery of a

multitude of improperly designed

and/or installed fire barrier penetra-

tion seals at Unit 1.

Further, this Unit I penetration

surveillance

problem,

was identified to the licensee

in 1985 as the result of a

contractor audit;

however,

comprehensive

corrective action was not taken

until this assessment

period.

Although, personnel

errors

have persisted

and management

followup of

previously identified concerns

was inadequate,

the licensee's

Fire

Protection/Prevention

Program for both units was observed

to be generally

adequate.

The deficiencies identified during this assessment

period by

the licensee

and

NRC inspectors,

and inspector's

review of the licensee's

corrective actions indicated that the Fire Protection/Prevention

Program

requires

improved overall day-to-day coordination

and management

guidance.

Overa'll

~Summer

The licensee

has

implemented

an effective maintenance

program.

The

material condition of the plant,

the experience

and knowledge of onsite

personnel,

the controls for the performance of maintenance,

the interaction

between

Maintenance

and Operations staffs,

and the documentation

of main-

tenance activities were considered

adequate.

However, corporate

and station

management

attention is required to address

improved oversight of per-

formance,

effectiveness

and timeliness of corrective actions,

and adequacy

and compliance with maintenance

procedures.

The surveillance

program at Unit I is adequate.

The ISI program which

was considered

poor at the beginning of the assessment

period

shows sig-

nificant improvement,

thus demonstrating

that the licensee's

management

is

capable

of ensuring correction of identified problems

once their attention

is focused

on it.

This

same

focus by management

needs to be applied to

ensure

the

IST program is properly implemented

and that surveillance

procedures

are

adequate

and adhered

to by station

employees.

Implementation of the Unit 2 surveillance

testing

experienced

various

procedural

and personnel

deficiencies

during this assessment

period.

Followup of technical testing

problems

has generally

been

good.

The

licensee

has

implemented

more stringent control in the surveillance

testing area,

effectiveness

of which has not been fully determined.

In

summary,

performance

in the surveillance,.area

was minimally acceptable.

Overall, performance

in the fire protection area

has declined over this

assessement

period.

25

2.

Performance

Ratin

Category:

3

3.

Board Recommendations:

NRC:

None

Licensee:

None

D.

Emer enc

Pre aredness

(224 hours0.00259 days 0.0622 hours 3.703704e-4 weeks 8.5232e-5 months ,

2.9%)

l.

~Anal sis

During the previous

assessment

period,

licensee

performance

in this area

was rated Category

1.

This assessment

was based

upon

good exercise-

performance

and the licensee's

own initiatives in routine emergency

preparedness

activities.

During the current

assessment

period,

one partial-participation

emergency

exercise

was observed,

a routine safety inspection

was conducted,

and

a

special

Emergency

Response

Facility (ERF) Appraisal

was conducted to verify

licensee

implementation of NUREG-0737,

Supplement

1 orders.

In the partial-participation exercise

held

on August 2,

1988,

the primary

objective of the scenario

was to test the interface

between

the licensee's

Emergency

Plan

and Security Contingency

Plan.

The licensee's

execution

and participation demonstrated

thorough response

and

a strong

commitment

~to emergency preparedness'he

NRC team found that personnel

demonstrated

complete

knowledge of procedures

under

emergency

conditions,

interfaced

well with the security force,

and implemented the emergency

plan

efficiently.

Analysis and classification of events

were timely and

command

and control exhibited by managers

of each

emergency

response

facility were effective.

No significant deficiencies

were identified and

only minor facility and performance

weaknesses

were noted.

The licensee

concurred with the NRC-identified findings and initiated appropriate

'corrective action.

In conjunction with the annual

exercise,

the

ERF Appraisal

was also

performed.

Results of the appraisal

identified certain programmatic

areas,

which were either incomplete or in need of increased

licensee attention.

Of primary concern

was the licensee's

dose

assessment

model.

The'RC team

found that

improvements

were

needed

in all aspects

of the dose

assessment

program including undefined isotopic distributions

and release

rates

associated

with all Unit 2

FSAR accidents

and post-accident

sample results

not properly incorporated into dose calculations.

Other identified

26

deficiencies

were found in the storage

capacity of the Unit I Plant

Computer

System to report pre-event

and post-event

plant data,

and Emer-

gency Operations Facility habitability.

In response

to

NRC initiatives

the licensee

addressed

all appraisal

findings and committed to resolving

each

item to the next scheduled

refueling outage.

Following the

appraisal,

on September

25,

1988,

a separate

concern

was identi'fied with

Techni'cal

Support Center habitability

when dampers within the

TSC

ventilation system failed.

This problem was not corrected

unt'i 1 the end

of the period.

During the routine safety inspection

conducted in February

1989, all

major areas

of the licensee's

emergency

preparedness

program including

program changes,

emergency

equipment,

organization

and management

control,

training,

program audits,and

follow-up of open items were reviewed.

No

significant deficiencies

were found regarding the programmatic

changes

or

walkthroughs (training) of key emergency

response

personnel

with the

exception of licensed operator

knowledge of the operation

and capability

of the

Tone Alert System.

Minor concerns

were identified with the

licensee's

recent revisions to and distribution of the

Emergency

Plans

and

Implementing

Procedures,

personnel

used to conduct

independent

program

reviews,

and information provided in general

employee training.

Coordination of onsite

and offsite emergency

preparedness

activities are

administered

by the

Emergency

Coordinator

from the site.

The training

department

is responsible

for instruction of most emergency

response

personnel

and scenario

develoment

and preparation

is provided through

contract support.

During the recent reorganization

of the Nuclear

Services Division, two additional full-time equivalent staff members

were authorized for the emergency

preparedness

program.

In addition,

the

Emergency Coordinator position has

been

upgraded to

a manager

level

with direct access

to the Manager,

Nuclear Services.

Such changes

are

an

indication of strong

program support

from upper-level

corporate staff.

Each calendar quarter the licensee

coordinates

with the State of New York

and other power reactor licensees

w'ithin the State

concerning offsite

e'mergency

preparedness

issues.

The

EP staff also maintains

membership

on the

Oswego

County Planning

Committee

and is currently assisting

the

State

and local authorities in the development of procedures

for meteoro-

logical forecasting.

During an accident, this process

would ensure that

inputs into the dose

assessment

model are identical at each jurisdictional

level.

Prompt notification (siren)

system capability was degraded

on

several

occasions

during the period and the licensee notified NRC

immediately after identification of these

problems.

1

27

In summary,

the licensee

has demonstrated

a positive continued

commitment

to emergency

preparedness.

The relationship

between

the licensee

and

offsite authorities

continues

to be strong.

Training of all levels of

emergency

response

personnel

was effective

as evidenced

by exercise

performance.

Although items identified during the

ERF Appraisal

remain

incomplete,

responsiveness

to

NRC initiatives has

been timely and the

licensee

has

made progress

in correcting

most

NRC concerns.

Management

involvement is of the level 'necessary

to ensure that the emergency

preparedness

program

can

be efficiently implemented.

2.

Performance

Ratin

Category:

1

3.

Board Recommendation:

NRC:

Hone

Licensee:

None

E.

Securit

and Safeauards

( 137 hours0.00159 days 0.0381 hours 2.265212e-4 weeks 5.21285e-5 months ,

1.8%)

l.

A~nal sis:

During the previous

assessment

period,

the licensee's

performance

was

rated

as Category

1.

No regulatory issues

were identified by either

region-based

or resident

inspectors.

During the assessment

period the licensee

continued to demonstrate

a

thorough understanding

of NRC security objectives

and maintained

an

excellent

enforcement history.

One unannounced

routine security

inspection

was performed

by region-based

inspectors.

Routine inspections

by the resident

inspectors

continued throughout the period.

Corporate

management

involvement

and interest in the security program

remained evident during this assessment

period by the continued on-site

presence

of the Security Manager

who reports directly to the corporate

Executive Vice President for Nuclear Generation.

The Security Manager

and his supervisory staff are well-trained and

qualified security professionals

who are vested with the necessary

authority and discretion to ensure that the station's

nuclear security

program is carried out effectively and in compliance with NRC regulations.

Security management

also continues to actively participate in the Region I

Nuclear Security Associatio'n

and in other groups

engaged in nuclear plant

security matters.

28

The licensee

continued to enhance

the security program during this

assessment

period.

All search

equipment

in both access

control portals

was upgraded,

vehicle barriers

and double fences

are being erected at the

protected

area

boundary,- the Unit

1 intrusion detection

system

was upgraded

and plan's

have

been

developed to upgrade

the Unit 2 instrusion detection

system.

Security

systems

and equipment

are tested

and maintained

by

dedicated

instrumentation

and controls

( I8C) and maintenance

groups

(a total of 22 personnel).

These

are indications of the licensee's

commitment to maintain

a quality and highly effective program.

To ensure

a comprehensive

annual

audit of the security program,

the

licensee's

Safety

Review and Audit Board

used the services

of nuclear

security consultants.

The licensee

continued to implement the Commitment

to Excellence

Program in security.

The program centered

around three

areas:

1) performance testing of security force members;

2) conducting

an

in-house regulatory effectiveness

style review;

and 3) daily audits/

survei llances of security posts

including at least twenty-percent

inspections

on backshifts.

These

are further indications of the licensee's

commitment to the program.

A review of the licensee's

security event reports

and reporting procedures

found them to be consistent with NRC regulations

(10 CFR 73.71).

There

were two security event reports

submitted during the assessment

period.

One event involved the loss of offsite local

law enforcement

communica-

tions capabilities

and the other,

the discovery of drugs on-site.

The

licensee

took prompt and effective compensatory

and/or corrective

measures

for each event.

Staffing of the proprietory security force continues

to be adequate

as

evidenced

by

a limited use of overtime.

The security force training and

qualifications

program is well-developed

and is administered

by an

experienced staff of five, full-time individuals (including the

supervisor).

Facilities for training and requalification are available

on site or on adjacent,

owner -controlled property.

These facilities are

well-equipped

and maintained.

Security contingency

response drills are

conducted

at least

once

each

month.

These drills are effectively used for

training purposes

and the drill critiques are integrated into the formal

training program.

The licensee instituted

a procedure during this

assessment

period to ensure

the participation of the operations

organization during contingency drills if the scenario

could affect. plant

operation.

During the assessment

period, the licensee

submitted

one revision to the

Physical Security Plan under the provisions of 10 CFR 50.54(p).

This

revision was of high quality, technically sound,

and reflected

'ell-developed

policies and procedures.

Security personnel

involved in

maintaining the program plans

are very knowledgeable of NRC requirements

and objectives.

29

In summary,

the licensee

continues to maintain

a very effective and per-

formance-oriented

security program.

Significant enhancements

to the

program continued during this assessment

period which is indicative of

management

attention to and support for the program.

The efforts to

upgrade

the operation

and reliability of systems

and equipment during this

period are

commendable

and demonstrate

the licensee's

commitment to

maintain

an effective

and high quality program.

2.

Performance

Ratin

Category:

I

3.

Board Recommendations:

NRC:

None

Licensee:

'one

F.

En ineerin

and Technical

Su

ort (523 hours0.00605 days 0.145 hours 8.647487e-4 weeks 1.990015e-4 months , 6.7/)

1.

~Anal

si s

During'the previous

assessment

period,

the licensee's

performance

was

rated Category

2 in this functional area..

Problems

were identified in the

following areas:

insufficient station-to-engineering

department interface;

inadequate

involvement of engineering

in the resolution of ISI program

concerns;

and,

inadequate

control over contractors.

In order to improve station-to-engineering

department

interfaces,

the

Engineering

Department

now includes

a permanent site engineering

group

that reports directly to the Yice President

of Nuclear Engineering

and

Licensing.

This group

was established

during the middle of the

SALP

cycle and is responsible

for coordinating andimplementing engineering

modifications

and expediting corporate

engineering

support for plant

operations.

Greater engineering staff participation in routine station

meetings

was evident

and appears

to have

a positive impact on the

assignment

and accountability

for Engineering

Department action items.

One area of particular concern during this

SALP period was the reverifi-

cation of the first 10 years of the Inservice Inspection (ISI) Program for

Unit l.

Early in the

SALP period numerous deficiencies

were identified in

the program involving many required inspections

which had not been per-

formed because

of improper, development

and implementation of the ISI

Program

by a contractor

and insufficient licensee

oversight of that

contractor.

However,

an

NRC team inspection

conducted

near the end of the

SALP period concluded that the licensee

has effectively corrected defic-

iencies previously identified in the ISI Program.

As a result of

30

increased

management

attention to these deficiencies,

the program is

presently defined,

structured

and adequately

staffed with qualified

individuals to effectively implement the

new program.

Problems previously identified regarding

the adequacy

of the licensee's

control over contractors

were also noted during this period.

Specific

problems

noted during this period included:

weaknesses

in the licensee's

review of contractor

procedures

and inspection results; deficiencies

regarding contractor dedication of commercial

grade

items for Unit 2 and

oversight of Unit

1 ISI program contractors.

These deficiencies

indicate

poor engineering

management

oversight to assure

adequate

control of

contractors.

To enhance

plant safety

and provide better direct plant support,

the

licensee

has established

a priority system whereby all safety significant

projects

are Priority

1 and other work which affects safety

systems

are

Priority 2.

All Priority

1 and

2 projects

are

on schedule.

Additionally,

the Vice President,

Engineering

and Licensing holds

a weekly staff meeting

to discuss

the status

of each project.

This system is effective

as

evidenced

by all priority safety significant projects

being

on schedule

and the observa'ion

that there

was

no appreciable

backlog of projects

during the Unit 2 and ongoing Unit

1 outages.

The licensee's

Engineering

and Technical

Support staff were generally

effective in resolving engineering

concerns

at both units with notable

improvement in design

change activities.

However, during this period,

performance

by the Engineering staff was inconsistent

and is a matter of

concern to the

NRC and merits attention

by management.

While a number of

activities

and specific projects for which the engineering staff had

control over were conducted

in

a professional

manner,

weaknesses

in other

areas

were detrimental

to the overall

assessment

of the engineering

support function.

Examples of both are discussed

below,

The licensee

has developed

a detailed

commercial

grade dedication

program

to upgrade

equipment to safety-related

status.

This program was

developed

based

upon discovery

by the licensee of weaknesses

in the

General Electric commercial

grade

items dedication

process

and the

necessity

to resolve potential electrical

equipment safety concerns prior

to Unit 2 initial licensing.

The licensee's

program

employs the

EPRI

guidelines

and the documented

engineering

evaluations

were determined to

be thorough

and technically sound.

Several

design

and replacement activities were performed well including

the replacement

of the Unit

1 feedwater

check valves,

the Unit 1 Antici-

pated Transient Without Scram

Alternate

Rod Injection modification, and

the upgrade of the Unit

1 Mark I containment to meet the acceptance

criteria of NUREG 0661.

The licensee

addressed

all of the significant

4

31

technical

aspects

of the Bulletin 85-03, "Motor Operated

Valve

Common

Mode Failures

During Plant Transients

Due to Improper

Switch Settings" at

both units.

The necessary

cor'rective actions

were properly coordinated

with the maintenance

and operation staffs.

However,

poor performance

in other areas

indicates

an inability of the

engineering

department

to consistently deliver quality work.

Examples 'of

these

inconsistencies

include: the

numerous deficiencies identified in the

implementation of Regulatory

Guide 1.97 for Unit 1; the failure to report

the

125

Vdc design deficiencies

in a timely manner for Unit 1; the failure

to detect

and resolve

an automatic depressurization

system

(ADS) wiring

error which rendered

one division of ADS inoperable for Unit 2; inadequate

corrective actions to identify all improperly sealed

penetrations

and

conduits for internal flooding for Unit 2; and the inadequate

resolution

of post-accident

sampling

system divisional

power supply problems at Unit

2.

Slow resolution of design deficiencies

at Unit 2 have resulted in plant

transients

and unnecessary

safety

system actuations.

Examples

included

the reactor building ventilation problems,

reactor

vessel

instrumentation

common reference

leg sensitivity concern

and the feedwater control valve

problems.

A Safety

System Functional

Inspection

(SSFI) performed

by an

NRC team at

Unit

1 concluded that design

information for both the core spray

and

HPCI/FW systems

was not adequately controlled or supported

by

sufficiently detailed analysis.

This lack of defined .design analysis for

the core spray

and

HPCI/FW systems

degraded

the quality of system

operating

and surveillance

proc'edure

guidance.

A specific concern

was

the Appendix

K reload analysis.

Inadequate

analyses

led to operation of

the plant outside of the design basis

on two separate

occasions.

These

potential

problems

were

known by the licensee

in early 1987, but were not

'esolved until brought to the licensee's

attention

by the

NRC.

This was

another

example of inadequate

licensee

followup to identified

deficiencies.

The licensee

has developed

a comprehensive

training program for individuals

at all levels in the Engineering organization.

The permanent training

staff is supplemented

by individuals from various disciplines assigned

as

instructors.

If required,

consultants

are retained for specific courses.

At the

end of the

SALP period,

the

NRC identified significant deficiencies

in the implementation of the licensee's

engineering training program.

A

review of the training records

and licensee

gA audits revealed that most

of the engineers

were not receiving adequate

training according to the

projects training program.

While the licensee

has developed

a

comprehensive

training program,

the program

has not been effectively

implemented.

~ '

32

In summary,

the licensee

has

made limited progress

in addressing

engineering

and technical

support deficiencies that were identified

during the last

SALP period.

While some engineering activities exhibited

strong engineering control,

numerous

examples of poor performance of

engineering activities were identified.

These

examples,

collectively,

indicate poor control

and coordination of engineering efforts and

inadequate

management

oversight of the engineering

function to assure

consistency

of performance of the

on and off site engineering staff.

Performance

in this area contributed to the issuance

of Confirmatory

Action Letter 88-17

and continues to be of concern to the

NRC staff.

2.

Performance

Ratin

Category:

3

3.

Board Recommendations:

NRC:

None

Licensee:

Hone

G.

Safet

Assessment/(}ualit

Verification (1446 hours0.0167 days 0.402 hours 0.00239 weeks 5.50203e-4 months ,

18.7/)

).

~Anal sis

This

new functional

area

assesses

the effectiveness

of the licensee's

programs

provided to assure

the safety

and quality of plant operations

and

activities.

It is

a compilation of the Licensing

and Assurance of guality

functional

areas

provided in the previous

SALP reports,

but also incor-

porates

relevant indications discussed

in all other current functional

areas.

a

During the previous

SALP period,

the licensee

was evaluated

as Category

3

in the area of Assurance

of guality and Category 2, declining, in the area

of Licensing.

Performance

in the Assurance

of guality area

was noted to

be inconsistent.

Improvements

occurred in problem identification and

resolution,

effectiveness

of the guality Assurance

organization,

Unit 2

operations,

staff performance,

and Technical Specification interpreta-

tions.

Weaknesses

were identified in station

and corporate

management

oversight

and coordination,

radiological controls,

teamwork and communi-

cation,

and housekeeping.

In the licensing area it was noted that the

technical

approach to,

and resolution for issues

were generally

sound

and conservative;

however,

on occasions,

the licensee

demonstrated

a lack of understanding

of regulatory requirements

and

a reluctance

to

make independent

conservative

decisions

on issues

involving regulatory

compliance.

33

During this assessment

period the licensee's

performance

in correcting the

SALP identified weaknesses,

in responding

to plant events,

and in conduc-

ting other activities

and functions impacting quality and safety assurance

has

been inconsistent.

However, at the end,of the rating period, the

licensee

took significant action to demonstrate

senior management's

commitment to identify and resolve

long-standing

problems in the Nuclear

Division.

In 'response

to CAL 88-17,

a number of assessment

programs

and

corrective actions

were initiated includi.ng the Restart

Task Force,

the

Restart Action Plan

(RAP),

and the Nuclear Improvement

Program (NIP).

Particularly noteworthy is that the licensee

established

a

new position of,

Executive Vice President

Nuclear Operations.

The hiring of a senior

individual from outside

the organization

broke

a long-standing tradition

'of promoting from within and demonstrated

that senior management

is serious

about breaking

down the organizational

"culture" and correcting the leadership

deficiencies that

have contributed to many of the problems at Nine Mile

Point.

The licensee

has

made several

additional organizational

changes

in an attempt to strengthen

the organization

including the establishment

of

a Regulatory

Compliance

Group.

This group provides

a continuity to

the organization

which was not previously

observed.

It has facilitated

improvements

in:

1) tracking

and timely resolution of identified problems,

concerns

and commitments;

2) interdepartmental

communications;

3) defined

responsibilities

and accountabi lities; and 4) consistency

in operations

and administration

between Units

1 and 2.

The licensee

has also requested

.independent

organizations

to assist

them in evaluating

the effectiveness

of the Nuclear Organization

and has

scheduled

a self-evaluation

before restarting Unit 1.

These efforts

indicate that Niagara

Mohawk is making

a concerted effort to correct the

leadership

weaknesses

identified in the previous

SALP.

The effectiveness

of the above

changes

is still being evaluated.

Throughout the period the licensee

has demonstrated

increased

effectiveness

in problem identification, both programmatic

and technical.

However, corrective actions

in general

have not been properly implemented

to prevent recurrence.

This is evident for both units and is attributed

to the inability to clearly identify the applicable root cause

and the

lack of defined responsibility

and accountability within the organization.

In contrast,

the licensee's

recent corrective actions with respect to the

Unit

1 Inservice Inspection

Program deficiencies

represent

a true commit-

ment to develop

and maintain

an effective Inservice Inspection

Program.

Significant technical

manpower resources

have been dedicated to this effort,

increased

management

attention

and control

have

been

observed

and there is

evidence of a heightened sensitivity by all station

employees of the proper

implementation of the program.

The licensee's

actions concerning the

identification of the

ADS logic circuitry deficiencies,

and service water

system single failure corrective actions

were also

commendable.

34

The licensee's

approach to the resolution of technical

issues

from a safety

standpoint

has not always

been timely and conservative.

For example,

the

licensee

has not been effective at reducing the number of scrams,

Engineered

Safety Feature

(ESF) actuations,

and personnel

errors experienced

at Unit

2 following the completion of the

Power Ascension Testing

Program early in

the rating period.

This problem appe'ars'o

result from the licensee's

(inappropriate) willingness to accept

the high number of events

as being

normal

and acceptable

for a newly licensed facility.

In addition, the

licensee

has not always

been aggressive

in pursuing safety issues it did

not perceive

to be restart

issues

on Unit 1,

such

as resolution of a vital

area question

regarding the diesel

generators

and the development

and

implementation of a long-term program for the torus wall thinning issue.

The station Quality Assurance

(QA) Surveillance

Group is an aggressive

and thorough oversite

group.

It is particularly flexible and active in

responding

to recognized

independent

oversight

needs.

Corrective actions

resulting, from the

QA Surveillance

Group effort now appear to reverse

negative

trends prior to the development of major problems.

This represents

a measurable

improvement over previous

assessments.

However, weaknesses

have

been identified in the technical quality of the

QA audits performed

by the

QA Audit Group.

Audits have

been

noted to be weak and shallow despite

past

NRC criticism in SALPs.

The licensee is aware of this and is taking steps

to strengthen

the group's technical abilities.

Weaknesses

have also

been

identified in the threshold for highlighting QA identified deficiencies

and significant adverse

trends to senior station

and corporate

management.

Added corporate

management

attention

should

be given to ensuring that

significant findings are properly escalated

so that prompt and effective

action

can

be taken.

One instance

observed

during this assessment

period indicated

a reliance,

by the line organization,

on the

QA organization to identify problems.

Corrective actions

taken

by the Engineering staff to address

Unit I ISI

program deficiencies

were too dependent

upon the

QA staff to ensure

proper

implementation.

This ultimately resulted

in a

QA Stop Work Order because

of ineffective program implementation.'ncreased

Engineering

and contractor

supervisory oversight resulted.

Ouring the assessment

period,

the -Site Operations

Review Committee

(SORC)

and the Safety

Review and Audit Board

(SRAB) have not demonstrated

their

effectiveness

in overviewing station activities.

Observations

indicated

that these

committees

get bogged

down in too much detail.

Many of the

presentations

made to these

committees

have

been ill-prepared

and ineffec-

tive.

SRAB consultants

were observed to be very active

and provided

excellent input to the

SRAB meetings

and reviews.

Observations

made of

the Independent

Safety Engineering

Group (ISEG) indicated that this group

was also not fully effective.

Members of the group were too far removed

from day-to-day station activities and their assessments

appeared

to be

lost at too low a level in the organization.

35

A review of the Licensee

Event Reports

(LERs) submitted during the period

indicates that the reports

were= thorough, detailed,

well written and easy

to understand.

The root cause

of the event

was clearly identified in most

cases.

The

LERs presented

the event information in an organized pattern

that led to

a clear understanding

of the event information.

Significant weaknesses

in the area of reportabi lity were identified during

the Safety

System Functional

Inspection.

As an example,

delayed corrective

actions for an improper Technical Specification Limiting Condition for

Operation allowed the plant to be placed in an unanalyzed

condition and

resulted

in untimely reporting.

Additional corporate

management

attention

is needed to improve the prompt evaluation

and reporting of significant

potential

safety

is'sues.

Responses

to bulletins,

generic letters

and multi-plant action items

such

as Generic Letter 83-28,

and the

ATWS Rule ( 10 CFR 50.62),

have

been

generally timely and complete.

The licensee's

requests for amendments

and

reliefs

have

been

adequate

and indicate appropriate

planning

and assignment

of priorities.

The quality of the reviews performed

by the licensee

under

the requirements

of 50.59

has also

improved over the last rating period.

However,

the licensee's

analysis of industry operating

experience

has

been

slow and in

some

cases

inadequate.

In summary,

licensee

performance

in the areas

related to Safety Assessment

and Quality Verification has

been inconsistent.

Strengths

have

been

noted

in the areas of:

1) demonstration

by management

that it has

begun to

aggressively

pursue correction of identified leadership deficiencies;

2) increased

effectiveness

in problem identification; 3) establishment

of the Regulatory

Compliance

group;

4)

an aggressive

and thorough

gA

surveillance

group;

and 5) detailed

and thorough

LERs.

In contrast

weaknesses

have .been identified in the areas of:

1) defined,

responsibilities

and accountability;

2) implemenation of corrective

actions;

3) continuing high event rate at Unit 2 attributable to a

complacent attitude with respect

to new plant operations;

4) aggressiveness

in pursuing potential

safety issues;

5) shallowness

of

gA audits;

and 6) inadequate

review of industry operating experience.

2.

Performance

Ratin

Category:

3

Improving

3.

Board Recommendation:

NRC:

None

Licensee:

Management attention

should

be focused to ensure that the

increased

emphasis

on correcting deficiencies at Unit

1

does not result in insufficient attention to problems at

Unit 2.

36

V.

SUPPORTING

DATA AND SUMMARIES

A. Enforcement Activit

Table

1.1

Unit

1 Enforcement Activities

Violations Versus

Functional

Area

~B

~Severit

Level

Functional

Area

No. of Violations in Each Severity Level

V

IV

III

II

I

Total

Plant Operations

Maint/Surv

Eng/Tech Support

Emergency

Preparedness

Security

&

Safeguards

Radiological

Controls

1

3

0

Safety

A'ssessment

equality

Verification

0

TOTAL

1

6

0

Note:

There are five apparent violations pending final staff review.

~

e

a

~

37

Table 1.2

Unit 2 Enforcement Activities

Violations Versus

Functional

Area

~B

~Severest

Level

Functional

Area

No. of Violations in Each Severity Level

LI

V

IV

III

II

I

Total

Plant Operations

Haint/Surv

Eng/Tech Support

1

Emergency

Preparedness

Security

and

Safeguards

Radiological

Controls

Safety

Assessment/Quality

Verification

TOTAL

17

1

4

1

0

23

Escalated

Enforcement Action

An Enforcement

Conference

was held

on July 11,

198E for Unit

1 to discuss

an apparent violation of 10CFR50 Appendix

R "Fire Protection

Program for

Nuclear

Power Facilities Operating Prior to January

1, 1979".

Two severity

level IV violations were issued

on September

19,

)988 citing the licensee

against Appendix

R and Appendix B, "Quality Assurance Criteria for Nuclear

Power Plants

and

Fuel

Reprocessing

Plants".

An Enforcement

Conference

was held

on February 2,

1989 for Unit 2 to

discuss

a wiring error in the Automatic Depressurization

System Division

I actuation logic.

A Notice of Violation was issued

on Parch

13,

1989

citing an aggregate

severity level III violation with no civil penalty.

'38

An Enforcement

Conference

was held on March 30,

1989 for Unit

1 to discuss

Licensed Operator Requalification Training Program. deficiencies identified

early in this assessment

period.

Potential violations from the Safety

System Functional

Inspection,

and Inservice Testing deficiencies

and

125

VDC battery concerns

are being included in this action.

Enforcement

actions

are pending.

B.

Confirmator

Action Letters

CAL

On March 28,

1988,

the

NRC issued

CAL 88-13 which documented

the licensee's

commitment that Unit

1 would not restart until Operator Requalification

deficiencies

were corrected.

On July 24,

1988,

the

NRC issued

CAL 88-17 which documented

the licensee's

commitment that Unit

1 will not be restarted

unti l problems in several

areas

are resolved

and

NRC approval is obtained.

CAL 88-17 superseded

CAL

88-13.

~

39

C.

Ins ection

Hours

Summar

Unit

1

TABLE 2

Unit 2

Area

Hours

% of Time

Hours

% of Time

Plant Operations

1464

Radiological Controls

232

27.9

810

281

32.3

11.2

Maintenance

and

Surveillance

2041

38.9

598

23.9

Emergency

Preparedness

117

Security

and Safeguards

70

Engineering

and Technical

Support

413

2.2

1.3

7.9

107

67

110

4.3

2.7

4.3

Safety Assessment/

Quality Verification

913

17 '

533

21 '

TOTALS

5250

100.0

2506

100.0

'f

40

D.

LICENSEE EVENT

REPORTS

CAUSAL ANALYSIS

TABLE 3

Cause

Determined

~b

SALP Board

An assessment

has

been

conducted

to determine

the root cause

of each

event from the perspective

of the

NRC.

The causes fell into the

following categories

and sub-categories.

Personnel

Errors

~PE

1.

Lack of Knowledge (LK) - the individual was not properly

trained or provided with instructions

from supervision.

2.

Inattention to Detail

( ID) - the individual failed to pay

proper attention to

a task

and was careless.

3.

Poor Judgement

(PJ) - the individual failed to make the

correct

assessment

with the proper

amount of training and

attention to facts.

~Eui ment Malfunction/Failure ~EM/F

1.

Random (R)

isolated

component

problem not of generic

concern.

2.

Design Deficiency (DD) - poor design

was the cause

of the

malfunction/failure.

3.

Construction Deficiency (CD) - improper installation during

construction/modification

caused

or could have caused

the

malfunction failure.

4.

Maintenance

Deficiency (MD) - improper preventive or

corrective maintenance.

Procedural

Error ~PRDE

The procedure failed to provide adequate

instruction,

was poorly

worded or was not properly reviewed for use.

Ineffective Corrective Action CHICA

Action was not taken

by management

or the action taken

on

a

previously identified item was not timely or did not correct the

root cause

and allowed this occurence.

~

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

Unit I ~Summar

of Cause

Determined

~b

SALP Board

~b

Functional

Areas

CAUSE

PE/LK

PE/ID

PE/PJ

OPS

RAD

MAINT/SURV

ENG/TS 'P

SEC

SAFETY/(AV

TOTAL

EM/F/R

1

EN/F/DD"

EYi/F/CD

EH/F/MD

PROE

ICA

3

.3

7

TOTAL

9

0

Total is greater

than the

number of LERs since

some

LERs have

more

than

one cause

code assigned.

The licensee

issued

a total of 16

LERs

this assessment

period.

42

TABLE 3 (Cont'd)

LICENSEE

EVENT REPORTS

Unit 2 Summar

of Cause

Determined

~b

SALP Board

~b

Functional

Areas

CAUSE

OPS

RAD

MAINT/SURV

ENG/TS

EP

SEC

SAFETY/(AV

TOTAL

PE/LK

2

1

PE/ID

4

2

PE/P J

1

EM/F/R

1

EM/F/DD

EM/F/CD

EM/F/MD

PROE

ICA

16

18

19

TOTAL

10

3

35

23

0

71*

"Total is greater

than the

number of LERs since

some

LERs have

more

than

one cause

code assigned.

The licensee

issued

a total of 65

LERs

this assessment

Period.

43

E.

Other

Investi ations

and Alle ations

Summar

An Office of Investigation (OI) Review was prompted following a Region

1

inspection of the Unit

1 Licensed Operator Requalification Training Program

which identified potential material false 'statements

made

on License

Renewal

Form 398s.

The OI Report concluded that there were

no intentional

material false

statements

made

by licensee

management

or licensed

operators.

During this assessment

period,

a total of nine allegations

were received

and reviewed

by the

NRC.

Six allegations

were determined to be

unsubstantiated

and

one allegation

was

a valid concern.

The two remaining

allegations

were still under review at the

end of the assessment

period.

Kana

ement Conferences

On April 26,

1988,

the licensee

gave

a presentation

to

NRC Management

on

torus thinning and Inservice Inspection

issues for Unit 1.

On May 4,

1988,

a meeting

was held to discuss

the licensee's

approach to

issues

requiring resolution prior to Unit

1 restart.

On May 10,

1988,

SALP management

meeting

was conducted on-site.

It

On July 25,

1988,

the Regional Administrator, Executive Director of

Operations,

and the Associate Director for Projects,

NRR met with the

licensee on-site to discuss

NRC's concern

over the licensee's

continued

poor performance

and issue

Confirmatory Action Letter (CAL) 88-17.

On August 18,

1988,

the Regional Administrator was on-site to discuss

corrective actions

concerning

CAL 88-17 with site

and corporate officials.

On October

18,

1988,

a meeting

was held in Region I to review progress

in

resolving restart

issues.

On October 21,

1988,

NRC senior staff met with the licensee

to discuss

restart

issues for Unit 1.

On October 27,

1988, the licensee

made

a presentation

in Region I

concerning

the status

and scheduling of Unit 1 Inservice Inspection

Program.

On November 25,

1988,

a management

meeting with the Executive

Vice-President

was held concerning

the Restart Action Plan.

g ~

On December

6,

1988,

NRC management

met with the President of Niagara

Mohawk to discuss

the Restart Action Plan.

On Becember

20,

1988,

the licensee

gave

a presentation

to

NRC staff in

Headquarters

concerning

improvements

made in the Unit

1 Inservice Testing

Program.

On December

22,

1988,

the licensee

presented

the Restart Action Plan to

the

NRC for review in

a management

meeting in Region I.

On January

19,

1989,

the

NRC Restart

Panel

was on-site to present

the

licensee with comments

on the Restart Action Plan.

On January

31,

1989,

the licensee

made

a presentation

to the

NRC staff

regarding details

concerning

Conformance with Regulatory Guide (RG) 1.97.

On February

21,

1989,

the licensee

made

a second presentation

to the

NRC

staff in Headdquarters

concerning

RG 1.97.

ML17055E733

Text

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