ML17255A422
| ML17255A422 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/05/1983 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17255A421 | List: |
| References | |
| NUDOCS 8309300232 | |
| Download: ML17255A422 (76) | |
Text
ENCLOSURE 2
U.S.
NUCLEAR REGULATORY COMMISSION REGION I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE ROCHESTER GAS AND ELECTRIC CORPORATION R.
ED GINNA NUCLEAR POWER PLANT JULY 5, 1983
$309300232 830926 PDR ADQCK 05000244I
,,8 PDR~
1
I.
INTRODUCTION.
- 1. 1 Purpose 8 Overview 1.2 SALP Attendees
1.3 Background
II.
SUMMARY
OF RESULTS I II. CRITERIA IV.
PERFORMANCE ANALYSIS,.
TABLE OF CONTENTS PAGE 3
3 8
1.
2.
3.
5.
6.
7.
8.
9.
Plant Operations Radiological Controls Maintenance Surveillance Fire Protection and Housekeeping.
Security 5 Safeguards Refueling Licensing Activities 9
11 14 15 17 18 20 22 23 V.
SUPPORTING DATA AND SUMMARIES 1.
2.
3.
TABLE 1 TABLE 2 TABLE 3 TABLE 4 Licensee Event Reports.
Investigation Activities Escalated Enforcement Actions Management Conferences
- TABULAR LISTING OF LER's BY FUNCTIONAL AREA
- INSPECTION HOURS
SUMMARY
INSPECTION REPORT ACTIVITIES.
VIOLATIONS (2/1/82 1/31/83) 24 25 25 25 26 27 28 30
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(See Supplemental Page 3a)
INTRODUCTION Pur ose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect observations on an annua basis and evaluate licensee performance based on those observ ions with the objectives of improving the NRC Regulatory Program nd Licensee performance.
The assessment period for this report is June 1,
1982 t rough May 31,
- 1983, and includes pertinent activities and NRC obser tion thru
- June, 1983.
The prior SALP period was July 1, 1981 through J e 30, 1982.
There is a one month overlap between current and the revious assessment period.
Significant findings from the prior sessment period are included in the applicable Performance Analy is Functional Areas (Section IV) to provide followup on past c
cerns and document if improvement has been observed.
Evaluation criteria used during this sessment are discussed in Section III.
Each criterion was'app ied using the Attributes for Assessment of Licensee Performance contained in NRC Manual Chapter
- 0516, Table 1.
SALP Board Members R.
W. Starostecki, Directo
, Division of Project and Resident
- Programs, (DPRP)
Region I T. T. Martin, Director, ivision of Engineering and Technical Programs (DETP)
H. B. Kister, Chief Reactor Projects Section, Division of Projects and Resident rograms J.
H. Joyner, Ch f, Nuclear Materials and Safeguards Branch, Division of Engine ing and Technical Programs (DETP)
G.
F. Dick, L censing Project Manager, Operating Reactors Branch No. 5, Nuclear Reactor Regulation (NRR)
R.
P.
Zim rman, Senior Resident Inspector, R.
E. Ginna Nuclear Power Pla Addit onal NRC Attendees D.
. Crutchfield, Chief, Operating Reactors Branch No. 5, NRR
. J.
- Pasciak, Chief, Radiation Protection Section, DETP
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3a INTRODUCTION Pur ose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect observations on an annual basis and evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and Licensee performance.
The assessment period for this report is June 1,
1982 through May 31,
- 1983, and includes pertinent activities and NRC observation thru
- June, 1983.
The prior SALP period was July 1, 1981 through June 30, 1982.
There is a one month overlap between the current and the previous assessment period.
Significant findings from the prior assessment period are included in the applicable Performance Analysis Functional Areas (Section IV) to provide followup on past concerns and document if improvement has been observed.
Evaluation criteria used during this assessment are discussed in Section III.
Each criterion was applied using the Attributes for Assessment of Licensee Performance contained in NRC Manual Chapter
- 0516, Table 1.
SALP Board Members R.
M. Starostecki, Director, Division of Project and Resident
- Programs, (DPRP)
Region I T. T. Martin, Director, Division of Engineering and Technical Programs (DETP)
H.
B. Kister, Chief, Reactor Projects
- Section, Division of Projects and Resident Programs J.
H. Joyner, Chief, Nuclear Materials and Safeguards Branch, Division of Engineering and Technical Programs (DETP)
G.
F. Dick, Licensing Project Manager, Operating Reactors Branch No. 5, Nuclear Reactor Regulation (NRR)
R.
P.
Zimmerman, Senior Resident Inspector, R.
E. Ginna Nuclear Power Plant Additional NRC Attendees D.
M. Crutchfield, Chief, Operating Reactors Branch No. 5, NRR M. J.
- Pasciak, Chief, Radiation Protection Section, DETP
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1.3
~Back round 1.3. 1 Licensee Activities The assessment period began on June 1,
1982 with the plant at about 88% power ascending to full power following completion of the 1982 annual refueling and maintenance outage.
With the below listed exceptions, operation continued at rated licensed power until September 24, 1982 when the unit was shut down for a scheduled steam generator inspection.
On June 17,
- 1982, the power level was reduced to 48% for several hours to isolate the 1-B Condenser to check on a rattling sound from the inlet water box.
A 3" long, 1" diameter carbon steel pipe nipple was removed.
On August 6,
- 1982, a reactor trip occurred while venting the reference leg of pressurizer level transmitter LT-428, which also serves as the sensing location for two pressurizer pressure transmitters.
During the venting operation, a low pressure condition was generated in the reference leg, resulting in a low pressurizer pressure reactor trip.
The unit was returned to power operation on August 7.
On August 17,
- 1982, a turbine runback to 95% power occurred during routine surveillance testing of Power Range Channel 44, when an operator inadvertently returned the dropped rod bypass switch to "normal" while simulating a dropped rod runback condition.
On September 16,
- 1982, a turbine runback to 95% power occurred when a dropped control rod channel was left in the tripped condition while reinstating Power Range Channel 44 after surveillance testing.
On September 24, 1982 reactor power increased to 102% when the
¹2 turbine control valve went wide open due to a malfunction of the impulse pressure signal to the electro-hydraulic control system.
Operator action quickly returned level to normal.
During the maintenance outage from September 24, 1982 through October 21,
- 1982, steam generator eddy current inspection of both steam generators was performed including 100% in the hot legs to the first support plate, 25% in the cold legs to the first support plate, and all periphery tubes.
As a result of the inspection, 33 tubes were plugged in the 'B'team Generator and one tube was plugged in the 'A'team Generator.
Video inspections of the 'B'team Generator secondary side periphery identified that a tube (R39, C69), previously plugged in 1976, had a fishmouth burst about 1~" in length and 3/8"
5 (See Supplemental Page 5a) wide, located 3~" above the tubesheet.
A wear mark at the location where the burst subsequently occurred was observed by video inspecti n
during the forced Minter/Spring, 1982 outage.
The wear mark was determined to have been caused by a loose foreign metal plate whi was removed in the same outage after initiating a tube rupture
- January, 1982 (NUREG 0909).
The tube was cut out below the fi st support plate and removed.
Additional maintenance activities accomplished included:
replacing a section of the 'A'ori Acid Storage Tank recirculation piping; replacement of the inte nals of Pressurizer Power Operated Relief Valve, PCV-431C; and r lacement of the containment air.sample return line check valve 1
9 with air operated valve 1599.
With the below listed exceptions, operation
'resumed on October 21, 1982 and continued at rated 1'nsed power until March 26, 1983 when the unit was shut down to commence the 1983 annual refueling and, maintenance outage.
On January 17,
- 1983, a reactor trip occurr d on low 'A'team Generator level coincident with steam fl
-feed flow mismatch.
Cause of the trip was a faulty steam ge erator programmed level setpoint module.
The unit returned to power operation on January 18.
On January 20,
- 1983, a frazil ice uildup at the intake structure resulted in low Screenhouse wate level.
Power was reduced to 26K for several hours to reduce condenser circulating water temperatures.
Full power oper tion was regained on January 21.
On January 24,
- 1983, power as reduced to 55K for replacement of the 'A'ain Feedwater ump impeller runner as a result of higher than normal vibra ion readings.
The unit was returned to full power on Januar 28.
The 1983 annual refueling and maintenance outage was nearing completion at the conclusion of th assessment period on May 31, 1983.
Major activities accomplishe included:
loading twenty fresh fuel assemblies and performing a core shuffle to maintain a low leakage loading pattrn for Cycle XI
- installation of two high pressure extraction steam moisture sep rators; seismic upgrade of piping system inside containment; deco tamination of 'A'
'B'team Generator channel
- heads, and ¹2 l pressure turbine swap to spare rotor.
Steam generator eddy current inspection, as required by Operating License Amendment 55 included 1005 in the hot legs to the first support
- plate, 25K the cold legs to the first support plate, and all periphery ubes.
As a result of the inspection, 23 tubes in
'B'team Ge rator showed greater than 40K defect in the hot leg crevice area du to intergranular attack.
Sleeves (22", 28" or 36" lengths) were i stalled in the above tubes as well as an additional 53 tubes in 'team Generator as preventive maintenance.
Four (4) tubes wer preventively sleeved in the 'A'team Generator.
All sleeves e installed in the hot leg side.
.A total of 21 sleeves had been nstalled in 'B'team Generator from prior outages in 1980 and 1981.
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sa wide, located 3~" above the tubesheet.
A wear mark at the location where the burst subsequently occurred was observed by video inspection during the forced Minter/Spring, 1982 outage.
The wear mark was determined to have been caused by a loose foreign metal plate which was removed in the same outage after initiating a tube rupture in
- January, 1982 (NUREG 0909).
The tube was cut out below the first support plate and removed.
Additional maintenance activities accomplished included:
replacing a section of the 'A'oric Acid Storage Tank recirculation piping; replacement of the internals of Pressurizer Power Operated Relief Valve, PCV-431C; and replacement of the containment air sample return line check valve 1599 with air operated valve 1599.
With the below listed exceptions, operation resumed on October 21, 1982 and continued at rated licensed power until March 26, 1983 when the unit was shut down to commence the 1983 annual refueling and maintenance outage.
On January 17,
- 1983, a reactor trip occurred on low 'A'team Generator level coincident with steam flow-feed flow mismatch.
Cause of the trip was a faulty steam generator programmed level setpoint module.
The unit returned to power operation on January 18.
On January 20,
- 1983, a frazi 1 ice buildup at the intake structure resulted in low Screenhouse water level.
Power was reduced to 26% for several hours to reduce condenser circulating water temperatures.
Full power operation was regained on January 21.
On January 24,
- 1983, power was reduced to 55% for replacement of the 'A'ain Feedwater Pump impeller runner as a result of higher than normal vibration readings.
The unit was returned to full power on January 28.
The 1983 annual refueling and maintenance outage was nearing completion at the conclusion of the assessment period on May 31, 1983.
Major activities accomplished included:
loading twenty fresh fuel assemblies and performing a core shuffle to maintain a low leakage loading pattern for Cycle KIII; installation of two high pressure extraction steam moisture separators; seismic upgrade of piping system inside containment; decontamination of 'A'
'B'team Generator channel
- heads, and ¹2 low pressure turbine swap to spare rotor.
Steam generator eddy current inspection, as required by Operating License Amendment 55, included 100% in the hot legs to the first support
- plate, 25% in the cold legs to the first support, plate, and all periphery tubes.
As a result of the inspection, 23 tubes in
'B'team Generator showed greater than 40% defect in the hot leg crevice area due to intergranular attack.
Sleeves (22", 28" or 36" lengths) were installed in the above tubes as well as an additional 53 tubes in 'B'team Generator as preventive maintenance.
Four (4) tubes were preventively sleeved in the 'A'team Generator.
All sleeves were installed in the hot leg side.
A total of 21 sleeves had been installed in 'B'team Generator from prior outages in 1980 and 1981.
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I 1.3.2 Ins ection Activities One NRC resident inspector was onsite for the entire appraisal period.
The total NRC inspection hours for the period was 1644 (resident and region-based),
with a distribution in the appraisal functional areas as shown on Table 2.
NRC inspection activities and violations issued during the period are tabulated in Table 3 and Table 4 respectively.
A special inspection was conducted on March 31 April 1, 1983 related to the radiological aspects of a serious personnel injury which occurred on March 31, 1983.
An enforcement conference concerning the performance of improper post maintenance testing of the containment personnel hatch was held on June 1,
1983.
II.
SUMMARY
OF RESULTS R.
E.
GINNA NUCLEAR POWER PLANT FUNCTIONAL AREAS CATEGORY 1
CATEGORY 2 CATEGORY 3 1.
Plant 0 erations Radiological Controls Radiation Protection Radioactive Waste Management Transportation Effluent Control 5 Monitorin Maintenance X
Sur vei 1 1 ance (Inc 1 uding Inservice Testin Fire Protection 5 Housekee in Emer enc Pre aredness Securit and Safe uards Refuel in Licensin Activities Overall Summar This is the third assessment of licensee performance by the NRC staff under the Systematic Assessment of Licensee Performance program.
It contains an assessment of licensed activities for both normal operations and outage activities.
In general, the licensee's performance in each of the functional areas evaluated was acceptable and reflected management's commitment to safety.
Administrative and procedural controls have been established and are well implemented by a
qualified and experienced staff.
The relatively low number of violations assessed in each of the functional areas demonstrates the licensee's regard for regulatory requirements and the success of the management control systems established to assure performance within set standards.
Operating shift personnel continued to show noteworthy performance during reactive situations which had potential to affect plant safety.
- However, an increase in personnel errors by operators during routine operation, and by station personnel performing surveillance testing, is a concern to which management attention 'should focus.
Additionally, two recent operational activities were not considered to have been implemented by supervision in the conservative fashion which has signified past licensee performance,
- however, it is believed that these are isolated cases.
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III. CRITERIA The following performance aspects were reviewed in each area:
1.
2.
3.
5.
6.
7.
Management involvement in assuring quality.
Resolving technical issues from a safety viewpoint.
Responsiveness to NRC initiatives.
Enforcement history.
Reporting and analysis of reportable events.
Staffing (including management).
Training effectiveness and qualification.
To provide a consistent evaluation, attributes relating each aspect to the characteristics of Category 1, 2, and 3 performance were applied as discussed in NRC Manual Chapter
- 0516, Part II and Table 1.
The SALP Board conclusions were categorized as follows:
~Cate or 1:
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety:
licensee resources are ample and effectively used such that a
high level of performance with respect to operational safety is being achieved.
~Cate or 2:
NRC attention shou'ld be maintained at normal levels.
Licensee management attention and involvement in nuclear safety are evident; licensee resources are adequate and reasonably effective such that satisfactory performance with respect to operational safety is being achieved.
Cateqaor 3:
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear
- safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety is being =achieved.
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IV.
PERFORMANCE ANALYSIS
- 4. 1 Plant 0 erations 55%
Plant operations, including design changes and modifications; quality control; committee activities; and reporting systems were under continuing review by the resident inspector.
A region-based inspection of the design change and modification area was also conducted.
Routine activities were generally performed by plant operators in an alert, well disciplined manner.
Plant evolutions were carried out with proper regard for regulatory requirements and safety in accordance with approved operating procedures.
The operating staff, both licensed and unlicensed, is well trained and remains a significant attribute.
Operator response to several plant transients during the assessment period was prompt and displayed good training.
Examples included:
RHR cooling was quickly restored when lost due to air binding. while performing steam generator decontamination; several power excursions, resulting from turbine EHC malfunctions, were swiftly terminated by operator action; rapid evaluation and performance of required actions on reactor trips and turbine runbacks was observed, and, actions taken in response to low water level in the Screenhouse resulting from ice blockage at the intake struc-ture were carried out efficiently.
Operator morale appears improved.
Enhanced communication between shift personnel and supervision has been evident.
Operatiops supervision is also more involved in reviewing daily operating activities and tracking routine shift problems through their solution than witnessed in prior appraisal periods.
Management has demonstrated an effective commitment to safety in its approach to plant operations.
PORC continues to be actively involved in examining safety issues, and remains a strong, dependable management resource.
The products derived from PORC meetings on technical issues with safety implications are usually well researched and conservative.
Corporate management and engineering personnel routinely visit the plant and are involved in ongoing plant activities.
There have been a number of substantive problems during the appraisal period which indicate the development of a negative trend in plant operations.
Additionally, there has also been a slight change observed in the usually high degree of conservatism associated with the performance and review of plant operations.
Examples follow:
A Control Room operator inadvertently disabled the automatic and manual start functions of a diesel generator for approximately two hours before discovery.
On two occasions, the failure to walk down fire systems and ensure all hold tags had been cleared resulted in declaring a system operable (and removing the fire watch) when it was still out of service.
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10 A steam generator tube pull from the primary side was not conservatively performed in that an apparently cut tube repeatedly sprang back l" following 2'," incremental pulls, and the job was not stopped to ensure the tube had been fully cut.
The containment air sample monitors were unknowingly taken out of service by Control Room operators when they were requested to issue hold tags for two manual valves whose number designation they were unfamiliar with.
The operating shift issued the hold tags without first reviewing valve indexes, piping diagrams, or questioning the hold requestor to determine the effect of closing the above valves.
Thirty hours elapsed before Operations became aware that the contain-ment air sample monitors were out of service.
Without inspector intervention, it appeared likely that a formal PORC meeting would not have been held to review the complicated circumstances surrounding a loss of decay heat removal prior to restarting the maintenance evolution which initially caused the loss of core, cooling.
Although communciation between plant personnel and the Project Group continued to be a problem, improvement was noted by the conclusion of the assessment period.
The licensee has instituted a modification follow group to assure a smooth turnover of systems to the plant.
This group is comprised of engineers who are assigned to various project modification tasks to oversee that installation is adequately coordinated with plant departments, and that plant personnel are properly trained and operating procedures completed and available for use at time of system turnover.
Quality Control (QC) personnel functioned effectively and were observed following operational activities on a routine basis.
QC supervisory personnel are newly assigned following a recent reorganization and were noted to lack experience and aggressiveness.
Notifications in accordance with 10 CFR S0.72 have been good with a low threshold used to determine reportabi lity.
Repetitive problems were experienced with regard to submitting reports in accordance with Technical Specifications.
The licensee's corrective action is expected to preclude further problems.
Conclusion Category 2
Board Recommendation:
Continue to maintain routine Senior Resident Inspection coverage and observe safety review committee activities.
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(See Supplemental Page lla) 4.2 Radiolo ical Controls 135 During the assessment period, three routine health physics (HP) inspecti s
and one special inspection were conducted by region-based inspectors of the radiation protection program, portions of the radioactive waste management
- program, and portions of the program for transportation o
radioactive materials.
The resident inspector also reviewed selec d
areas of the above programs on a routine basis.
The licensee has in place a management structure which provid multiple levels of supervision in radiological controls.
Management
- ontrols, including supervisory depth, outage staff augmentation and mprovements in HP technician training demonstrate the licensee's comm'ent to a strong radiation protection program.
The licensee's staff is pplemented by contractor HP technicians in preparation for, and duri g, major outages.
Contractor HP technicians are subject to the same per ormance standards as licensee HP technicians in the formal qualification
- program, including classroom, on-the"job training, and written perfo ance check-off.
General employee training has been improved by a dition of practical exercises.
Radiation Protection Posting of radiation and high radiation
- eas, compliance with Radiation Work Permits and Spec'ial Work Permits, nd observation of personnel frisking, practices were generally sou Periodic independent radiation and contamination surveys were cond ted and found in good agreement with licensee surveys.
Radiological co erns raised by the inspector during routine inspections were given pr mpt attention.
Housekeeping in radio-logical areas showed improvemen from the prior assessment period;
- however, strong management control app ently must be maintained in order to assure the proper degree of attenti n is afforded to housekeeping and cleanliness.
ALARA and external exposu e efforts have been improved although more attention should be giv to the completeness of documentation.
The licensee evaluated and performed chemical decontamination of the steam generator primary ch nel heads during the recent 1983 annual outage to reduce exposure to ersonnel during subsequent steam generator maintenance and nozzel dam in allation.
Although equipment problems occurred, the licensee extend the allotted time for the evolution to achieve significant man-rem reduct ns.
The license s use of extensive mock-up training to reduce exposures during st m generator work was again commendable.
Training included practice and evaluation of each function proposed or performed.
A suffic ntly large pool of trained personnel assured timely completion of work 'n the steam generators.
Good communication and control existed bet en the job work crew and the Health Physics Department.
Data available sh ed that while the national average PWR expended 593 man-rem for 1982,
. f. Ginna used 1140.2 man-rem.
These higher numbers are not representative
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4.2 Radiolo ical Controls 13%
During the assessment period, three routine health physics (HP) inspections and one special inspection were conducted by region-based inspectors of the radiation protection program, portions of the radioactive waste management
- program, and portions of the program for transportation of radioactive materials.
The resident inspector also reviewed selected areas of the above programs on a routine basis.
The licensee has in place a management structure which provides multiple levels of supervision in radiological controls.
Nanagement
- controls, including supervisory depth, outage staff augmentation and improvements in HP technician training demonstrate the licensee's commitment to a strong radiation protection program.
The licensee's staff is supplemented by contractor HP technicians in preparation for, and during, major outages.
Contractor HP technicians are subject to the same performance standards as licensee HP technicians in the formal qualifications program, including classroom, on-the-job training, and written performance check-off.
General employee training has been impr'oved by addition of practical exercises.
Radiation Protection Posting of radiation and high radiation areas, compliance with Radiation Work Permits and Special Work Permits, and observation of personnel frisking practices were generally sound.
Periodic independent radiation and contamination surveys were conducted and found in good agreement with licensee surveys.
Radiological concerns raised by the inspector during routine inspections were given prompt attention.
Housekeeping in radio-logical areas showed improvement from the prior assessment period;
- however, strong management control apparently must be maintained in order to assure the proper degree of attention is afforded to housekeeping and cleanliness.
ALARA and external exposure efforts have been improved although more attention should be given to the completeness of documentation.
The licensee evaluated and performed chemical decontamination of the steam generator primary channel heads during the recent 1983 annual outage to reduce exposure to personnel during subsequent steam generator maintenance and nozzle dam installation.
Although equipment problems occurred, the licensee extended the allotted time for the evolution to achieve significant man-rem reductions.
The licensee's use of extensive mock-up training to reduce exposures during steam generator work was again commendable.
Training included practice and evaluation of each function proposed or performed.
A sufficiently large pool of trained personnel assured timely completion of work in the steam generators.
Good communication and control existed between the job work crew and the Health Physics Department.
Data available showed that while the national average PWR expended 593 man-rem for 1982, R.
E. Ginna used 1140.2 man-rem.
These higher numbers are not representative
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12 of the licensee's commitment to ALARA, and include exposure incurred during extensive steam generator repairs following the tube rupture event and subsequent steam generator inspection and repair efforts performed in the Fall, 1982.
A special inspection was conducted to followup on an Unusual Event in March 1983 involving a radioactively contaminated injured person being transported to a hospital.
The licensee submitted a report in accord with 10 CFR 50.72 which requires notification of a serious injury requiring transport to an offsite facility for treatment.
The radiation exposure and contamination involved were of only minor significance.
The licensee needed multiple time extensions to complete a commitment in regard to job descriptions and responsibilities within the radiological controls organization.
An interim personnel dosimetry control method, used after resident and region-based inspector identification of a potential problem for misuse, worked for a time, but a subsequent failure resulted in identification of an individual performing work in a radiation area while inadvertently wearing another worker's dosimetry.
Management has
- sought, so far unsuccessfully, to resolve problems related to dosimetry control.
Improvement in this area is expected.
Improvements achieved as a result of the corrective actions taken on minor identified violations have proved to be acceptable and generally timely.
No programmatic deficiency was evident.
Acceptable interim and long-term corrective actions were proposed in response to a violation regarding assurance of egress from locked high radiation areas within the plant.
An error in semiannual reporting of personnel exposures was identified by the inspector, and the licensee submitted a corrected report.
Deficiencies identified in respiratory protection training and respiratory device servicing were corrected in an acceptable manner.
Radioactive Waste Mana ement Controls for processing of radioactive waste were adequately reviewed by the licensee prior to specific evolutions to assure radiological controls, including ALARA, were satisfied.
Storage space appeals adequate since completion of the Upper Radwaste Storage Building.
Effluent Control and Monitorin The licensee's controls for gaseous and liquid releases were acceptable.
Records of calibration for monitoring equipment, including verification of isolation signals to terminate releases, were complete and available.
Although the release path was monitored, the licensee failed to evaluate the radioactivity contributed from the steam generator blowdown sample line when reporting the total liquid effluent released from the site during 1982.
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13 Trans ortation The licensee continues to provide adequate controls associated with transportation activities.
(}uality Control personnel audit all radwaste shipments prior to release from the site.
Portions of several loading and final surveying operations were witnessed by the resident inspector.
Conclusion Category 2
Board Recommendations:
Schedule routine radioactive waste management, transportation, and radiation protection inspections during the next assessment period.
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14 4.3 Maintenance 8%
During the assessment period, the resident inspector reviewed maintenance activities on a routine basis.
One region-based inspection was also conducted of the steam generator sleeving repair technique and feedwater ring 'J'ube replacement.
Maintenance activities received appropriate management attention, with work performed in a competent manner.
The Instrument 8 Control and Maintenance Departments are staffed by experienced personnel and turnover has been low.
Supervisory monitoring and involvement in daily work activities remains a strength.
Craft and supervisory personnel demon-strated a good working knowledge of equipment within their job responsi-bility.
The use of Maintenance Work Orders and Trouble Cards is the predominant method for reporting maintenance related problems and in-itiating necessary repairs.
The system continued to function effectively, with good reporting practices and noteworthy responsiveness from the respective maintenance groups in expediting repair efforts.
In general, there is good regard for administrative and procedural require-ments.
On one occasion; however, it was noted that the work performed went beyond the scope of a procedure and its controls
- and, in part, contributed to the performance.of improper post maintenance testing.
In this specific instance, major maintenance was performed on the containment personnel hatch with a general, preventive maintenance procedure for the containment hatches.
Although a between-door-volume leakage test was actually required, only a door seal test was performed.
This resulted in the potential to violate containment integrity from October, 1982 through
- March, 1983.
An additional contributing factor in performance of the improper post maintenance test was poor communication between the Maintenance and Test Departments, who failed to discuss the maintenance performed prior to determining the appropriate post maintenance test.
Increased management attention if necessary to assure procedural controls bound the scope of planned work and interdepartmental communication regarding post maintenance testing is improved.
An enforcement conference was held on this issue in June, 1983.
The preventive maintenance program is well organized and implemented.
Records of inspection and preventive maintenance activit,ies are easily retrievable by each shop.
I 5 E Bulletins, Circulars, and Information Notices are routed promptly and receive thorough review for applicability.
When corrective/preventive actions are warranted on a generic i ssue, work requests are initiated.
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Conclusion:==
Category 2
Board Recommendations:
None
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15 4.4 Surveillance 7%
Operational and refueling surveillance testing activities were reviewed by the resident inspector during routine inspections.
Surveillance activities are primarily performed by the Operations, Results 8 Test, and Instrumentation 5 Control Departments.
Each group responsible for surveillance testing appears to be adequately staffed with qualified managers, supervisors, and technicians.
Results 5
Tests has added two additional technicians necessitated by an increasing workload over the past several years.
Pre-test discussions covering the scope of each surveillance test continued to provide for good communications with the Control Room operators.
Equipment malfunctions identified through testing were usually well documented, and event reports and maintenance trouble cards were completed promptly.
Surveillance scheduling by all departments continues to be tracked manually.
Four instances of missed surveillance testing have been identified since
- July, 1982.
Two of the four missed tests were due to the fai lure to incorporate recent Technical Specification amendments into the testing program.
The licensee has initiated corrective action through the review of Technical Specifications to assure that all required tests are covered by plant procedures and are included in the scheduling program.
Further management attention also appears warranted to assure that the existing scheduling program is properly implemented in the future.
Procedures used for surveillance testing and calibration provided detailed instructions with good clarity and precautionary information.
Although the procedures were generally adhered to well, a recent exception is discussed below with additional occurrences which have led to concern regarding the performance of the Results
& Test Department.
During safety injection functional testing, the failure to follow procedures resulted in actuation of the Overpressure Protection System.
Test personnel and supervision failed to identify that procedural acceptance criteria had not been satisfied.
An inexperienced technician, who was not adequately supervised, inadvertently actuated the Cable Tunnel fire suppression system during surveillance testing.
Test personnel performed the improper post maintenance surveillance test on the containment personnel
- hatch, due in part to not attempting to determine the scope of maintenance performed.
(An enforcement conference was held on this issue in June, 1983).
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16 A technician opened the containment personnel hatch outer door without knowledge whether the inner door was operable following maintenance; thus having the potential to violate containment integrity.
These deficiencies are indicative of lapses in attentiveness and require additional management attention.
==
Conclusion:==
Category 2
Board Recommendations:
None
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17 4.5 Fire Protection/Housekee in 3%
One inspection of the fire protection/prevention program was conducted by a region-based inspector.
The resident inspector observed fire protection controls during routine inspections.
Staffing levels were acceptable with a full time Fire Protection 4 Safety Coordinator and a full time Fire Protection Training Supervisor.
Both supervisors were experienced and knowledgeable of requirements.
The fire brigade consists of personnel from the Operations and Security Departments.
Licensee response to fire alarms was noteworthy.
Investigation of the suspected fire location was swift with good communication maintained with the Control Room.
Fire brigade training and drills were verified to have been conducted in accordance with the Fire Protection and Safety Plan.
Fire detection and suppression systems were well maintained and controlled.
Fire fighting equipment was in good working condition and adequate spares were available.
During modification of the Intermediate Building sprinkler system to install closed
- heads, poor communication between the Fire Protection Staff and the Operations Department resulted in repetitive fai lures to post fire watches when required.
A similar instance of poor communication resulted in posting an hourly patrol rather than a continuous fire watch.
Implementation of the program, including component maintenance and posting of necessary fire watches appeared better organized and implemented at the conclusion of the assessment period.
Plant cleanliness and housekeeping is considered a strength in the licensee's management control system.
Control of combustibles, ignition
- sources, and welding and cutting operations were verified to have been in accordance with plant procedures.
Improvements were noted in post outage housekeeping conditions as a result of increased management attention.
Each job foreman is held responsible for assuring good housekeeping controls at the work location.
General maintenance personnel are also made more readily available to the Health Physics Department, when necessary, to aid in cleanup activities in radiologically controlled areas.
==
Conclusion:==
Category 1
Board Recommendation:
None
18 (See Supplemental Page 18a) 4.6 Emer enc Pre aredness 3X Ouring the assessment
- period, one region-based follow-up inspection of emergency preparedness activities was conducted.
The inspection covere a review of open items identified during the Emergency Preparedness I
le-mentation Appraisal (EPIA) performed on November 2-13, 1981.
The r ident 1nspector also reviewed selected aspects of emergency preparednes and Emergency Plan implementation.
Subsequent to the appraisal peri d, in
- June, 1983, a region-based inspection of the licensee's Prompt otification System was performed.
Additionally, an NRC observation team itnessed a
full scale, emergency plan exercise on June 22, 1983.
Ther were no violations or reportable events involving emergency prepa dness during the assessment period.
The followup inspection to the EPIA revealed that a
gnificant number of issues had not been completed.
Twenty-three of th 32 Appendix A items requiring resolution rema1n open.
Eleven of the Appendix B items also require further action.
N'oteworthy corrective tions taken by the licnesee as a result of the EPIA included:
tr ining improvements for emergency response personnel, upgrading'f t e Technical Support Center 5 Emergency Operations Facility and their co unications equipment; and upgrading field radiat1on detect1on capa 11ty.
Among the items remaining open pending further licensee
- action, s the Post Accident Sampling System which was installed and proced es for its use were being developed, a program for high level waste mana ment was needed, and a technique for making initial protective action r commendat1ons was not finalized.
The emergency plan exercise de nstrated the 11censee's capability to implement their Emergency Pl in a manner to adequately protect the health and safety of the pu ic.
Areas which were noted to require improvement included:
th need for greater sharing of information between the Control Room, Techni al Support Center and the Emergency Operat1ons Fac1lity; and, survey earn training in the proper use of sampling and mon1toring equipment t
In a letter dated ovember 22, 1982, the licensee provided the corrective act1ons and/or aluat1ons performed in accordance with OperatiAg License Amendment 51 ich was issued to detail the short and long term requirements following t steam generator tube rupture event in January, 1982.
The requiremen s pertaining to emergency preparedness remain under NRC review to verif the acceptability of the licensee's actions.
A key ember of the licensee's Oose Assessment Group, which operates from the ergency Operations Facility, recently resigned.
The NRC will m
itor licensee actions to assure an adequate degree ef competency is aintained with regard to dose assessment projection.
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18 a 4.6 Emer enc Pre aredness 3%
During the assessment
- period, one region-based follow-up inspection of emergency preparedness activities was conducted.
The inspection covered a review of open items identified during the Emergency Preparedness Imple-mentation Appraisal (EPIA) performed on November 2-13, 1981.
The resident inspector also reviewed selected aspects of emergency preparedness and Emergency Plan implementation.
Subsequent to the appraisal period, in
- June, 1983, a region-based inspection of the licensee's Prompt Notification System was performed.
Additionally, an NRC observation team witnessed a
full scale, emergency plan exercise on June 22, 1983.
There were no violations or reportable events involving emergency preparedness during the assessment period.
The followup inspection to the EPIA revealed that a significant number of issues had not been completed.
Twenty-three of the 32 Appendix A items requiring resolution remain open.
Eleven of the 28 Appendix B items also require further action.
Noteworthy corrective actions taken by the licensee as a result of the EPIA included:
training improvements for emergency response personnel, upgrading of the Technical Support Center 8
Emergency Operations Facility and their communications equipment; and upgrading field radiation detection capability.
Among the items remaining open pending further licensee
- action, was the Post Accident Sampling System which was installed and procedures for its use were being developed, a program for high level waste management was needed, and a technique for making initial protective action recommendations was not finalized.
The emergency plan exercise demonstrated the licensee's capability to implement their Emergency Plan in a manner to adequately protect the health and safety of the public.
Areas which were noted to require improvement included:
the need for greater sharing of information between the Control Room, Technical Support Center and the Emergency Operations Facility; and, survey team training in the proper use of sampling and monitoring equipment.
In a letter dated November 22,
- 1982, the licensee provided the corrective actions and/or evaluations performed in accordance with Operating License Amendment 51 which was issued to detail the short and long term requirements following the steam generator tube rupture event in January, 1982.
The requirements pertaining to emergency preparedness remain under NRC review to verify the acceptability of the licensee's actions.
A key member of the licensee's Dose Assessment Group, which operates from the Emergency Operations Facility, recently resigned.
The NRC will monitor licensee actions to assure an adequate degree of competency is maintained with regard to dose assessment projection.
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']9 (See Supp1ementa1 Page 19a)
==
Conclusion:==
Category 2
Board Recommendations:
A followup inspection should be coordinated with licensee p
sonnel such that Outstanding EPIA issues be resolved in the near futur
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==
Conclusion:==
Category 2
Board Recommendations:
A followup inspection should be coordinated with licensee personnel such that Outstanding EPIA issues can be resolved in the near future.
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20
- 4. 7 Securi t and Sa fe uards 9%
During the assessment period, three routine physical protection inspections and one routine special nuclear material (SNM) control and accountability inspection were accomplished by region-based inspector s.
The resident inspector observed security activities on a routine basis.
Implementation of the security program remained noteworthy.
The licensee's security department is staffed by well trained and qualified personnel.
Management direction was effectively provided to the contract security organization (Wackenhut).
Contract security supervisors administered the security program in compliance with regulatory requirements.
Prompt corrective action was taken for the few problems which occurred during normal security operations.
Security force response to intrusion alarms were observed to be carried out in a swift, disciplined manner.
Compensatory measures taken in response to temporary degradation of the security system were in accordance with plant procedures.
In January, 1983 the licensee identified a misaligned, safety-related valve.
Following thorough PORC review of the circumstances, tampering could not be ruled out and the licensee took immediate action to verify proper valve and breaker positions of safety-related systems.
Although the licensee's followup actions were considered slow in developing an investigation was initiated and precautionary compensatory measures were implemented to enhance the surveillance of plant safety systems.
Investigators from corporate headquarters were dispatched to assist in the site investigation.
Interviews were conducted around the clock and continuing feedback was provided by operations and maintenance management personnel.
In substance, the event demonstrated the licensee's ability to effectively expand the scope of contingency planning to handle and resolve an emergency situation.
Corporate management involvement in site activities was also demonstrated by the annual corporate security audit.
The audit was a comprehensive and thorough review of security plan commitments.
Corrective actions were effective and timely.
The attrition rate for the security force during the appraisal period was 12%.
This rate has continued to drop dramatically since 1979 and is commendable.
All security personnel appeared to be knowledgeable in their assigned duties.
The Guard Training and gualification (T8g) program was progressing on schedule.
The program appeared well defined and effectively implemented.
The licensee submitted 2 Security Event Reports pursuant to the requirements of 10 CFR 73.71.
These reports included a description of the events and immediate corrective actions taken to prevent recurrence.
One violation resulted in the area of SNM control and accountability due to the failure to conduct a material inventory within the prescribed 12 month period.
An acceptable solution was proposed and implemented by licensee management.
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21 Conclusion Category 1
Board Recommendations:
None
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22
- 4. 8 Refue 1 i n 2%
This assessment period included a scheduled
- Fall, 1982 outage for steam generator inspection and repair, and a major refueling modification outage in the Spring, 1983.
Three region-based inspections of radiological controls were conducted; one region-based inspection of Startup Testing results for Cycle XII was performed;
- and, one region-based inspection of the steam generator repair technique was performed.
The inspector reviewed ongoing licensee activities, including refueling operations during the above outages.
The planning and control of refueling outage activities continues, in
- general, to be an element of strength in the licensee's management control system.
Detailed planning for outage activities is followed by appropriate levels of supervi sion.
Outage meetings were held twice daily, with representatives from each discipline present.
The meetings were well managed and provided good communication between departments, allowing for efficient short and long term scheduling, and early problem resolution.
During the assessment
- period, a computerized network scheduling program was used for outage planning for the first time.
This resulted in some scheduling and communication difficulties; however, improvement is expected with further use.
Refueling operations and related maintenance and surveillance activities were conducted by qualified, experienced personnel in accordance with approved procedures.
Mechanical problems with refueling equipment were
- minimal, and when problems arose, fuel movement was stopped immediately pending troubleshooting and effect of repairs.
Radiological controls governing outage activities were implemented effectively.
Details are documented in Functional Area 4.2.
==
Conclusion:==
Category 1
Board Recommendations:
Hone
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23 4.9 Licensin Activities In general, licensee management involvement continued to show consistent evidence of prior planning and assignment of priorities.
Decision making is consistently at a level that ensures adequate management review.
For
- example, questions relating to the radiological aspects of the steam generator tube sleeving were answered prompty and completely.
Reviews are generally timely, thorough, and technically sound.
The licensee's staff is sufficient in size and technical competence to carry out a wide variety of licensing functions'dditional technical competence is provided by the efficient use of consultants.
The licensee has exhibited a clear understanding in the resolution of technical issues.
A conservative approach is routinely employed when a
potential for safety significance exists.
Technically sound and thorough approaches are presented in almost all cases.
With respect to responsiveness to NRC initiatives, deadlines are met.
Responses are technic'ally sound and thorough in most cases.
Staff questions resulting from the licensee responses are usually resolved quickly by telephone followed by written documentation, if requested.
Acceptable resolutions were proposed initially in most cases.
With regard to the Operator Licensing
- Program, nine licensing examinations were administered during the period, all receiving passing grades.
This area continues to be commendable and is a result of a strong Training Department and selective hiring practices.
==
Conclusion:==
Category 1
Board Recommendations:
None
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24 V.
SUPPORTING DATA AND SUMMARIES 1.
Licensee Event Re ort LER's Tabular Listin Type of Events:
A.
B.
C.
D.
E.
X.
Personnel Error Design/Man./Constr. /Install External Cause Defective Procedure Component Failure Other
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Total 6
0 1
0 22 4
33 Licensee Event Reports Reviewed:
Report Nos. 82-14/3L through 82-28/3L and 83-01/3L through 83-18/3L.
Four sets of common mode events were identified:
LERs 82-21, 82-11, 82-15 and 82-19 reported that during surveillance testing the containment atmosphere radiation monitor return line check valve failed to seat properly due to dirt deposited on the seat of the valve.
The foreign matter is believed to have been from the carbon vanes of the monitor pump.
The check valve was replaced with an air operated valve; a filter was installed in the outlet from the sample pump; and a
Technical Specification change was issued to reflect the valve replacement.
Similar problems have not recurred since the licensee's corrective actions were implemented.
b.
LERs 82-14, 82-16, 82-21, 82-26 and 83-04 reported the apparent failure of the 'B'ontainment Spray Pump discharge check valve to display prompt closure during surveillance testing.
The licensee has spent considerable time and effort analyzing the fai lure mechanism of the check valve.
The valve has been disassembled and inspected numerous times, including vendor inspection, with no clear problems observed.
After each valve disassembly/
reassembly prompt closure has been observed during the subsequent surveillance.
The swing arm and disc have also been replaced with no effect noted.
The testing criteria for assuring prompt closure has been revised, as it was thought the testing method was unrealistic for determining prompt closure.
However, the performance of a leakage rate test on January 14, 1983 demonstrated that the valve was not fully shut, and the problem is not solely the test method.
Further licensee action may be warranted if additional problems verifying prompt closure are experienced.
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25 C.
LERs 81-06, 81-13, 83-27 and 83-16 reported the discovery of small leaks in the Boric Acid Transfer System.
The lines contain 12% boric acid and are heat traced.
The leaks have been attributed to intergranular stress corrosion cracking of the schedule 10 stainless steel piping.
The licensee has replaced leaking sections of pipe with schedule 40, or temporarily patched each leak after discovery.
During the 1983 annual
- outage, additional sections of suspect pipe were also replaced as preventive maintenance.
Further replacement is planned during the 1984 annual outage.
d.
LERs 81-09, 82-03, 82-22 and 83-13 reported steam generator tube degradation as identified through inservice inspection.
Intergranular attack in the tube sheet crevice area of the 'B'team Generator hot leg is the predominant area where indications of greater that 40% through wall defect have been detected.
All tubes have been plugged or sleeved in accordance with the Inservice Inspection Program.
2.
Investi ation Activiites:
none 3.
Escalated Enforcement Actions 3.1 Civil Penalties:
none
3.2 Orders
Order modifying license dated March 14, 1983, confirming licensee commitments and actions for TMI related requirements contained in NUREG 0737.(generic).
3.3 Confirmator Action Letters:
none 4.
Mana ement Confer'ences SALP Management Meeting at the R.
E. Ginna Nuclear Power Plant site on September 21, 1982.
Enforcement Conference held on June 1,
1983, in regard to the performance of improper post maintenance testing of the containment personnel hatch.
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26 Area TABLE 1 TABULAR LISTING OF LER's BY FUNCTIONAL AREA R.
E.
GINNA NUCLEAR POWER PLANT Number/Cause Code Total 1.
Plant 0 erations 1A 1C 3E 3X 2.
Radiolo ical Controls 3.
Maintenance 4.
Surveillance 5.
Fire Protection 6.
Emer enc Pre aredness 7.
Securit and Safe uards 8.
Refuelin 9.
Licensin Activities 1A 4A None None None None NONE 18E 1E TOTAL 1X 19 33 Cause Codes:
A.
Personal Error B.
Design/Man./Const./Instal.
C.
External Cause D.
Defective Procedure E.
Component Failure X.
Other Totals 6
0 1
0 22 4
33
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27 TABLE 2 INSPECTION HOURS
SUMMARY
6/1/82-5/31/83 R.
E.
GINNA NUCLEAR POWER PLANT Hours OF TIME 1.
Plant Operations 2.
Radiological Controls 3.
Maintenance 4.
Surveillance 5.
Fire Protection/Housekeeping 6.
Security and Safeguards 8.
Refuel ing 9.
Licensing Activities TOTAL 902 211 133 109 50 52 155 32 No Data 55 13 1005
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28 TABLE 3 INSPECTION REPORT ACTIVITIES R.
E.
GINNA NUCLEAR POWER PLANT REPORT
~82-12 INSPECTOR Resident AREAS INSPECTED Routine inspection of plant operations; surveillance testing
& calibration; main-tenance; radiological controls, and physical protection.
Additional areas inspected in-cluded final preparations for a radioactive waste spent resin shipment and TMI action plan items.
82-13 82-14 82-15 82-16 82-17 82-18 82-19 82-20 82-21 82-22 82-23 82-24 Specialist Resident Resident Specialist Specialist Resident Specialist Specialist Resident Resident Specialist Resident Post Refueling Startup Physics Testing Routine Routine and TMI Action Plan Items Modification and Design Change Program and Implementation Fire Protection/Prevention Program Routine; TMI Action Plan Item, and Licensed 8 Non-Licensed Employee Training Programs Radiation Protection Controls during a main-tenance outage Physical Protection
- Routine, and review of steam generator tube rupture procedure as revised in accordance with Operating License Amendment No. 51.
Routine; TMI Action Plan Items, and Secondary Chemistry Monitoring Program Special Nuclear Material Control and Accounting Routine and Fire Protection Program
- Included in previous SALP Assessment coverning the period from July 1, 1981 through June 30, 1982.
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29 TABLE 3 cont'd REPORT INSPECTOR AREAS INSPECTED 83-01 83-02 83-03 83-04 Specialist Resident Resident Specialist Physical Protection Routine Routine Radiation Protection Controls-preparations for annual outage 83-05 Resident Routine; Proposed Modification to the Con-tainment Equipment Hatch, and followup on Containment Personnel Hatch Post Maintenance Testing 83-06 Specialist Special Inspection of the Radiological Aspects of a Personnel Injury Event 83-07 Specialist Radiation Protection Controls during Annual Outage 83-08 83-09 83-10 Specialist Specialist Resident Followup of Emergency Preparedness Findings Physical Protection Routine; Steam Generator Tube Inspection Repair Technique; Steam Generator Channel Head Decontamination and Refueling Operations 83-11 Specialist NUREG-0737, Item II.B.2, Design Review of Plant Shielding 83-12 Special ist Steam Generator Tube Inspection 5 Repair Technique, and 'J'ozzle Replacement on Feed-water Ring 83-13 83-16 Resident Region I Management Routine Special Enforcement Conference-Improper Post Maintenance Testing on Containment Personnel Hatch
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30 TABLE 4 ENFORCEMENT DATA 6/1/82 - 5/31/83 R.
E.
GINNA NUCLEAR POWER PLANT A.
Number and Severit Level of Violations/Deviations Severity Level Severity Level Severity Level Severity Level Severity Level Deviation I
0 II 0
III 0
IV 7
V 8
B.
Violations Vs. Functional Area FUNCTIONAL AREAS 1.
Plant 0 erations 2.
Radiolo ical Controls 3.
Maintenance 4.
Surveillance 5.
Fire Protection/Housekee in 6.
Emer enc Pre aredness 7.
Securit and Safe uards 8.
Refuelin 9.
Licensin Activities I
II III IV V
2 3
1 1
2 2
1 1
Totals Violations/Deviations 0
0 0
7 8
31 TABEL 4 cont'd Summary Inspection Re ort No.
Ins ection Date Subject Require-ments Severity Area 82-12 June 1-June 30 Failure to maintain 10CFR50 adequate housekeeping in radiologically controlled areas.'2-14 82-15 July 1-July 31 Aug.
1-Aug 31 Failure to perform sur-TS vei llance testing within required frequency Failure to submit a thi r'ty TS day written report.
IV 82-19 82-23 Sept.
27-Oct.
1 Nov. 16-Nov. 19 Failure to provide egress 10CFR20 IV from high radiation areas Failure to conduct physical 10CFR70 inventories of SNM at required intervals 82-24 Nov.
1-Dec.
5 Failure to maintain a con-tinuous fire watch Failure to perform surveil-lance testing with required frequency.'S TS IV 82-03 Feb.
1-Feb.
28 Failure to submi t a report in accordance with 10CFR50.
59.
Failure to accurately deter-mine and document the total radioactivity of effluent released.
10CFR50 V
TS 83-05 Failure to submit a thirty day written report.
March 1-April 7 Failure to properly perform a safety analysis for a proposed modification.
TS 10CFR50 IV
,> J')
3Z (See Supplemental Page 32a)
Summary Inspection Re ort No.
Ins ection Oate Subject Require-ments Severit Area Failure to implement corn-NlA mitments.
Oevi tion N/A 83-10 Ap~il 8-May 7 Failure to perform surveil-TS lance testing.
Iv 83-13 May 8-June 16 Failure to follow operat-
'ing and surveillance test procedures.*
Failure to identify that surveillance test accept-ance criteria was exceeded.'S CFR50 IV 83-16 June 1
Failure to perform pr per 10CFR50 post maintenance te ing.'V Notes:
(1)
This violation was included in previous SAL assessment covering the period July 1, 1981 through June 30, 1982.
(2)
This item has been contested by the lic nsee and the matter is still under review by Region I management.
(3)
Thi.s violation has issued outside e assessment period and it will be subject to further NRC staff review pendi g receipt of the licensee's response.
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32a
'ummary Inspection Re or t No.
Ins ection Date Subject Require-ments Severity Area Failure to implement corn-N/A mitments.
Deviation N/A 83-10 April 8-May 7 Failure to perform surveil-TS lance testing.
IV 83-13 May 8-June 16 Failure to fol low operat-TS ing and surveillance test procedures.'V Failure to identify that 10CFR50 surveillance test accept-ance criteria was exceeded.'3-16 June 1
Failure to perform proper 10CFR50 post maintenance testing.'V Notes:
( 1)
This violation was included in previous SALP assessment covering the period July 1, 1981 through June 30, 1982.
(2)
This item has been contested by the licensee and the matter is still under review by Region I management.
(3)
This violation was issued outside the assessment period and it will be subject to further NRC staff review pending receipt of the licensee's response.