ML17325A731

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SALP Board Repts 50-315/88-01 & 50-316/88-01 for Oct 1986 - Feb 1988
ML17325A731
Person / Time
Site: Cook  American Electric Power icon.png
Issue date: 02/29/1988
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML17325A732 List:
References
50-315-88-01, 50-315-88-1, 50-316-88-01, 50-316-88-1, NUDOCS 8805250231
Download: ML17325A731 (43)


See also: IR 05000315/1988001

Text

SALP

BOARO REPORT

U.S.

NUCLEAR REGULATORY COMMISSION

REGION III

SYSTEMATIC ASSESSMENT

OF LICENSEE

PERFORMANCE

50-315/88001

50-316/88001

Inspection

Report

Indiana Michi an

Power

Com an

Name of Licensee

Oonald

C.

Cook Units

1 and

2

Name of Facility

October

1

l986 throu

h Februar

29

1988

Assessment

Period

SS05250231

SS0516

PDR

ADOCK 050003i5

O

DCD

TABLE OF CONTENTS

~Pa

e No.

I.

INTRODUCTION...........................

II.

CRITERIA....

III. SUMMARY OF RESULTS

IV.

PERFORMANCE ANALYSIS............

A.

B.

C.

D.

E.

F.

G.

H.I.

J.

K.

L.

Plant Operations.............

~ ..............

Radiological Controls................

Maintenance

.

S urvei llance................................

Fire Protection.................,.

Emergency Preparedness......................

Security ...........

4

~

~ t

~

~ t

~

~

~

~

~

~

~

0utages.

~ ...................................

Engineering/Technical

Support

Licensing Activities................,.......

Training and gualification Effectiveness....

guality Programs

and Administrative Controls

6

8

10

12

14

16

18

20

21

24

26

28

V ~

SUPPORTING

DATA AND SUMMARIES

32

A.

Licensee Activities....

B.

Inspection Activities

C.

Investigations

and Allegations Review.......

D.

Escalated

Enforcement Actions........

E.

Licensee

Conferences

Held During Assessment

F.

Confirmatory Action Letters (CALs)..........

G.

A Review of 10 CFR Part 21 Reports

and Licen

Event Reports

Submitted

by Licensee ...

~ ..

H.

Licensing Activities ..............

Period..

see

32

34

36

36

36

37

37

38

I.

INTRODUCTION

The Systematic

Assessment

of Licensee

Performance

(SALP) program ts

an

integrated

NRC staff effort to collect available observations

and data

on

a periodic basis

and to evaluate

licensee

performance

on the basis of

this information.

SALP is supplemental

to normal regulatory proces'ses

'sed to ensure

compliance with NRC rules

and regulations.

SALP 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 operation

and maintenance.

An

NRC SALP Board,

composed of the staff members listed below,

met on

April 20,

1988, to review the collection of performance

observations

and

other related

data to assess

the licensee's

performance

in accordance

with the guidance

in

NRC Manual Chapter 0516,

"Systematic

Assessment

of

Licensee

Performance."

A summary of the guidance

and evaluation criteria

is provided in Section II of this report.

This report is the

SALP Board's

assessment

of the licensee's

safety

performance at the Donald C.

Cook Nuclear Generating

Plant for the period

October I, 1986,

through February

29,

1988.

SALP Board for Donald C.

Cook Nuclear Generating

Plant:

  • C. E. Norelius

"E.

G.

Greenman

"H. J. Miller

  • M. J. Virgilio

D. Wiggington

W.

L. Axelson

  • W. G.

Guldemond

J. J. Harrison

G.

C. Wright

BE

L. Burgess

R.

N. Gardner

D.

H. Danielson

F. J. Jablonski

L.

R. Greger

M,

C.

Schumacher

W.

G. Snell

"B. L. Jorgensen

J.

K. Heller

J.

E. Foster

D.

M. Galanti

C.

F. Gill

R.

B. Holtzman

SALP Board Chairman, Director, Division of

Radiological Safety

and Safeguards

Director, Division of Reactor Projects

(DRP)

Director, Division of Reacto~ Safety

(DRS)

Acting Deputy Director,

DRP

Licensing Project Manager,

NRR

Chief, Technical

Support Staff

Chief, Projects

Branch 2,

DRP

Chief, Engineering

Branch,

DRS

Chief, Operations

Branch,

DRS

Chief, Reactor Projects Section

2A,

DRP

Chief, Plant Systems

Section,

DRS

Chief, Materials

and Processes

Section,

DRS

Chief, Maintenance

and Outage Section,

DRS

Chief, Facilities Radiation Protection Section,

Division of Radiation Safety

and Safeguards

(DRSS)

Chief, Radiological Effluents and Chemistry

Section,

DRSS

Chief, Emergency

Preparedness

Section,

DRSS

Senior Resident

Inspector

Resident

Inspector

Emergency

Preparedness

Specialist

Security Specialist

Radiation Specialist

Radiation Specialist

R.

C.

Kazmar

L. Kelly

T. J.

Madeda

J.

M. Ulie

project Inspector

Licensing Engineer,

NRR

Security Specialist

Fire Protection Specialist

"SALP Board voting members.

II .

CRITERIA

The licensee's

performance is assessed

in selected

functional areas,

depending

on whether the facility is in a construction,

preoperational,

or operating

phase,

The functional areas

normally represent

areas

significant to nuclear safety

and the environment

and are

normal

programmatic

areas.

Some functional areas

may not be assessed

because

of little or no licensee activity or lack of meaningful observations.

Special

areas

may be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess

each

functional area:

A.

Management

involvement in assuring quality.

B.

Approach to resolution of technical

issues

from a safety standpoint.

C.

Responsiveness

to

NRC initiatives.

D.

Enforcement history.

E.

Reporting

and analysis of reportable

events.

F.

Staffing (including management).

However,

the

SALP Board is not limited to these criteria and others

may

have

been

used

where appropriate.

On the basis of the

SALP Board assessment,

each functional

area

evaluated,

is classified into one of three

performance

categories.

The definition

of these

performance

categories

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

so that

a high level of, performance with respect

to operational

safety and/or

construction quality is being achieved.

~Cate or

2:

NRC attention

should

be maintained at normal levels.

Licensee

management

attention

and involvement are evident

and are

concerned with nuclear safety;

licensee

resources

are adequate

and are

reasonably effective

so that satisfactory

performance with respect

to

operational

safety and/or construction quality is being achieved.

~Cate or

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

so that minimally satisfactory

performance with respect

to operational

safety and/or construction

quality is being achieved.

Trend:

The

SALP Board may decide to include

an assessment

of the

performance

trend of a functional area.

Normally, this performance

trend

is used only where both

a definite trend of performance is discernible

to the Board

and the Board believes that continuation of the trend

may

result in a change of performance level.

The trend, if used,

is defined

as follows:

a.

~im rovin

Licensee

performance

was determined to be improving near

the close of the assessment

period.

b.

~Declinin:

Licensee

performance

was determined

to be declining near

the close of the assessment

period.

III. SUMMARY OF RESULTS

Functional

Area

A.

Plant Operations

B.

Radiological Controls

C.

Maintenance

D.

Surveillance

E.

Fire Protection

F.

Emergency

Preparedness

G.

Security

H.

Outages

I.

Engineering/Technical

Support

J.

Licensing Activities

K.

Training and Qualification

Effectiveness

Rating

SALP

6

Rating

This

Period

2 (improving)

2 (improving)

L.

Quality Programs

and

Administrative Controls

Affecting Quality

"New area for SALP 7.

IV.

PERFORMANCE ANALYSIS

A.

Plant

0 erations

l.

~Anal sls

The licensee's

performance

in the functional area of plant

operations

was evaluated

by considering the results of

14 routine inspections

and two special

inspections

by the

resident inspectors,

and part of a quality verification and

implementation

(QVI) team inspection.

Enforcement history in this area during the 17-month assessment

period was good;

however,

a Severity Level

IV and

a Severity

Level III violation were issued.

The Severity

Level III

violation involved the fai lure to maintain adequate

safety

injection flow paths, for which a $ 50,000 civil penalty was

imposed

and paid.

This event occurred late in the previous

assessment

period and was discussed

in the

SALP 6 report.

The Severity Level IV violation, which occurred during this

appraisal

period,

involved not keeping the Unit

1 primary system

pressure/temperature

within specified limits during an April

1987 cooldown.

Although it lacked direct safety significance,

the event indicated inadequate shift direction and coordination

during the cooldown.

No violations were identified in the

QVI

team inspection.

Enforcement history in this functional

area

compares

favorably to that during the previous

assessment

period when two Severity Level IV violations were issued,

and

a Severity

Level III violation occurred.

Inspector eva'luations

and direct observations

noted that

operator

knowledge

and coordination

were

good in response

to

operating transients

and events.

A review of licensee

event reports

(LERs) identified 13 reactor

trips, ll of which are applicable to this functional area.

Six

were at power (above

15 percent) while five were nonpower trips.

The two additional trip actuations

(one nonpower

and one at-power

trip) are covered in the Surveillance

section of this report.

Of the

11 trip signals attributable to this functional area,

9 resulted primarily from various equipment, failures,

1 involved

personnel

error,

and

1 was

a combination of the two causes.

The number of reactor trip signals

(13 in 17 months)

improved

from the previous

SALP period (16 in 12 months).

In addition,

the causes

of the trips were not typical of past problems;

those

had included startup

steam generator

level control

and

poor coordination of maintenance

and/or testing.

This shows

positive effects of the licensee's trip reduction program.

There were four other

LERs, not pertaining to reactor trips,

applicable to this functional area.

Two of them were the

result of personnel

error and the remaining

two resulted

from unanalyzed

system configurations,

one in the safety

injection flowpaths (noted in the Severity Level III violation)

and

one in the residual

heat

removal

f1owpaths.

Reportable

events

were reduced

in frequency

by about

50 percent compared

to that in the previous

assessment

period, with human factors

problems declining over 60 percent.

This is reflective of

the effectiveness

of the feedback

mechanisms

employed

by the

licensee

in addressing

causes

of reportable

events.

Management

involvement to ensure quality in this functional

area

was

good throughout the assessment

period.

Existing

programs for monitoring performance of personnel

and equipment

and for keeping

management

informed were continued or expanded.

New initiatives included

a reformalized "problem alarm"

resolution

program and an "outage avoidance" daily staff

meeting notesheet.

Material upgrading at the plant continued.

Examples

included

human factors modifications to control

room

panels,

panel painting and lighting changes,

and reduction

of standing

alarms.

Licensee initiatives for upgrading the

secondary

side included drawing verification, labeling, color

coding,

and operator aids activities.

A professional

atmosphere

is maintained

in the control

room.

The gVI inspection indicated that increased

attention

should

be paid to the

human element in the area of error prevention.

While errors in system lineups

and clearances

were infrequent

overall, they were more

numerous

in 1987 than they had been in

1986.

More effort is needed

in searching for common elements

among these errors to assure

corrective actions

are not too

narrowly focused.

The licensee consistently

took a conservative

approach

to

technical

issues

from a safety standpoint,

not hesitating to

commence

or complete

a unit shutdown

when necessary.

Both

units were operated

cont'inuously derated

throughout this

SALP

period

as

a precautionary

measure

to preserve

steam generator

tubes.

Such conservatism

was evident at all levels of management

from the Shift Supervisor to the Plant Manager.

As an example,

the licensee voluntarily shut

down Unit 2 in August 1987 to

investigate

questions

about the strength of reactor coolant

pump

hatch cover studs.

Management

involvement was highly visible

during planned

and unplanned

shutdowns

and during startups.

Management's

conservative

approach

was further evidenced

by

a

decision to delay simultaneous

startup of both units in April

1987, which could have diluted supervisory/managerial

attention.

There were

no specific

NRC initiatives related to this

functional area;

however, the licensee

was typically responsive

and candid in day-to-day interactions with the resident

inspectors.

Staffing in this functional area

was maintained at ample levels

including five shift teams,

each with substantially

more than

the minimum staffing required

by technical

specifications.

2.

Conclusions

The licensee's

performance is rated Category

2 in this area,

with an improving trend.

The licensee's

performance

was rated

Category

2 in this area during the previous

SALP period.

3.

Board Recommendation

None.

B.

Radiolo ical Controls

1.

~Anal sis

The licensee's

performance

in the functional area of

radiological controls

was evaluated

by considering

the results

of six inspections

performed during this assessment

period by

regionally based specialists,

routine observations

by the

resident inspectors,

and part of a /VI team inspection.

While enforcement statistics

in this area indicated

some

improvement with five Severity

Level IV violations in the

current

17-month assessment

period as

compared to six Severity

Level IV violations and

one Severity Level

V violation identified

during the previous

12-month assessment

period,

the violations

indicate continuing weaknesses

in licensee

performance

regarding radiological

surveys,

radioactive material control,

and procedural

adherence.

No

LERs were identified relating directly to performance

problems in this functional area.

This generally reflects

good performance.

Staffing was adequate,

with chemistry staffing better than

radiation protection (RP).

A high turnover rate continued

for the

RP technician

and professional

staff; however,

the

licensee's criteria for replacement

has

been

adequate,

and the

licensee

expects overall staff performance to improve because

of the higher quality performance

expected

from the staff

replacements.

Late in the assessment

period, the licensee

began to emphasize

a higher level of performance

from its

RP

technicians

and less reliance

on contract-provided

RP technicians

for significant-job coverage

and outage

supervisory duties.

The Chemistry staff was reorganized

during this assessment

period to more efficiently handle the work.

Management

involvement in this functional area

was adequate.

Administrative controls in the

RP program were weak, especially

early in the assessment

period with many poorly stated

and poorly

understood policies.

The conduct of licensee

audits of the

RP

program

improved significantly this assessment

period,

and more

aggressive

and thorough corrective actions

have generally

been

required

by the auditors.

A licensee-NRC

management

meeting

was held

on December

10,

1987, to discuss

NRC concerns

over=.

continuing weaknesses

in management

control that affect the

radiation protection

program.

The licensee

presented

a program

to resolve the weaknesses,

including having the Assistant Plant

Manager

assume

personal

direction of the Technical-Physical

Science

Department for an interim period.

As a result of this.

tenure,

the licensee

implemented

a comprehensive

RP action

plan to address

existing programmatic

weaknesses.

Management

involvement in the chemistry program was evident; for

example,

most of the laboratory chemistry instrumentation

is

state-of-the-art,

improvements

were

made with regard to the

quality and reliability of the makeup water system

and the

in-line process

monitors.

Also, efforts by management

had

begun

to control

and reduce the chloride concentration

in the secondary

systems.

The licensee is developing

a good water quality program

consistent with the guidelines established

by the Electric Power

Research Institute.

Licensee

responsiveness

to

NRC issues

has

been

adequate,

demonstrating

occasions

of weak as well as

good responsiveness.

Responsiveness

was generally weak early in the assessment

period, particularly with regard to correction of NRC-identified

problems in the

RP program.

These

problems

included staffing,

radioactive material control,

management

controls,

and procedural

adherence.

A training module was developed that aimed at

improving radiations workers'nowledge

of health physics

and

practical

knowledge of radiation protection problems.

Licensee

responsiveness

improved significantly late in the assessment

period

when the licensee

implemented

a comprehensive

RP action

plan to address

programmatic

weaknesses.

Another example

of good performance

included improvements

in the quality

assurance/quality

control

(QA/QC) of chemistry laboratory

instruments.

The licensee

approached

resolution of technical

issues

adequately,

with performance

weaker in

RP than in chemistry.

The approach

to resolving

RP technical

issues

sometimes

lacked

thoroughness,

which often delayed resolution

because initial

corrective actions

were ineffective.

The licensee

had been

slow to adequately

resolve technical

issues

raised in internal

QA audit and consultant reports with regard to the

RP, AlMA,

and radwaste

programs.

Personnel

radiation exposures

of

670 person-rem for 1986

and

1987 were about equal to the

licensee's

average for the previous

5 years.

It is noted,

however, that significant unplanned

outage work involving

potentially high radiation dose

was accomplished

in Unit 2

during 1987.

The licensee's

recent

dose history is acceptable

and improvements

have

been

made to the

ALARA program.

The

licensee

needs to emphasize

the

ALARA program in order to

complete identified program improvements.

The number of

unidentified personnel

contaminations

increased

significantly

in 1987, apparently

because

of the more sensitive portal

monitors.

Late in the assessment

period, the licensee

arranged

for full-contract anti-C laundry services

as

one element in

reducing personnel

contaminations.

Gaseous

radiological

releases

decreased

while liquid effluent showed

no discernible

trend

during this assessment

period.

The licensee

continues to make

progress

in reducing the volume of solid radwaste

generated.

Two sets of radiological confirmatory measurements

were taken

during this assessment

period.

The licensee

showed

improved

analytical results in the most recent

set of measurements

when

74 agreements

were achieved in 75 comparisons;

the earlier set

had yielded

67 agreements

in 76 comparisons.

The results of

the nonradiological

confirmatory measurements

were generally

good:

there were

25 agreements

with the

NRC values in 30

initial analyses.

The results did demonstrate

some problems

related to weaknesses

in instrumentation

and lack of independent

control standards.

The licensee is in the process of correcting

the problems.

2.

Conclusion

The licensee's

performance is rated Category

2 in this area.

The licensee's

performance

was rated Category

2 in this area

during the previous

SALP period.

3.

Board Recommendations

None.

C.

Maintenance

1.

A~oal sis

The licensee's

performance

in the functional area of

maintenance

was evaluated

by considering

the results of

14 routine inspections

by the resident

inspectors

and part

of a /VI team inspection.

Enforcement history in this area

was quite good in that the

two Severity Level IV and two Severity Level

V violations

issued all involved events that occurred early in the 17-month

assessment

period.

This compares

favorably to the one Severity

Level III violation, one Severity Level IV violation, and

one

Severity Level

V violation that were identified during the

previous

12-month assessment

period.

A weakness,

though not

chronic,

was the performance

of unintentional

modifications

during maintenance.

This was evidenced

by one Severity Level

V

violation that involved replacing

a valve with a similar valve

from another manufacturer

without performing

a prior evaluation

to demonstrate

that the substitution

was acceptable.

In another

instance for which a Severity Level IV violation was issued,

material substituted

during welding should

have

been

handled

as

a modification.

The licensee

also identified occasional

similar

10

problems.

These

included the use of steel bolts in place of

aluminum in terminating

a power cable to a safety injection

pump motor,

and

use of a standard-grade

part in a nuc1eay-grade

flowmeter.

The remaining

two violations involved the failure

to complete

post-maintenance

testing

on an "A" train valve

before beginning "B" train repairs

and failure to return or

dispose of excess

weld rods

as required

by procedure.

Both

violations had minimal safety significance

and lacked generic

applicability.

Two LERs were issued during this assessment

period, neither

of which involved a regulatory violation.

One concerned

valve

setpoint drift; the other involved

a personnel

error

on the

part of an instrument technician

and resulted in a safety

injection actuation during non-power operations

The subject

of technician errors is discussed

in the Surveillance

section

of this report,

as it relates to licensee

responsiveness

to

NRC concerns.

The fact that neither of these

events

was of

safety significance is indicative of continuing

good performance

in the area.

Management

continued to be extensively involved in ensuring

quality.

The plant staff used thorough evaluation

and tracking

processes

to generate

a broad range of subjective

and statistical

reports to management.

As

a result of management

review of

this information,

ample equipment,

parts

and materials,

and

adequate

staffing (discussed

further below) were provided to

ensure

excellent major equipment material condition.

This

has contributed significantly to an historically low forced

outage rate

and high unit productivity.

During this appraisal

period, despite

two outages

to perform

100 percent eddy-current

inspection of all four Unit 2 steam generators,

Unit 2 was

available

80 percent of the time.

For this period, which

included

a major refueling, maintenance,

modification,

and

testing outage,

Unit I was available about

77 percent of the

time.

Among the initiatives expanded

upon during this period

were:

computerized "repetitive" clearances;

component

coding

and labeling;

computerized

Equipment Data Base,

and consolidation

of personnel

and offices.

New initiatives included

a computerized

Material Management

System

and

a "guality Maintenance

Teams"

concept involving a multi-discipline, employee-oriented,

quality

assurance

approach to maintenance.

Technical

issues

are routinely approached

from a conservative

safety standpoint.

They are thoroughly handled

and in most

cases,

are resolved

in a timely manner.

As an example,

when

NRC review showed

a valve

had required repetitive maintenance,

further review found that the licensee

had already included the

valve and other valves

as candidates

for the "live load" packing

program being developed.

In another instance,

when

a charging

pump power cable shorted out, the licensee

found that fuel oil

had apparently

intruded into embedded

conduit.

The licensee

initiated generic corrective actions that included

a study,

a

followup surveillance,

and relocation/replacement

of several

other cables in addition to the affected

one.

11

The licensee

was generally responsive

to

NRC initiatives and

proposed

acceptable

resolutions that'were technically

sound

and timely.

The

NRC staff reviewed the licensee's

program for

testing m'otor-operated

valves with regard to compliance with

IE Bulletin 85-03 pertaining to improper switch settings

on

action operated

valves.

The licensee

has

a good start in

implementing the requirements

of the Bulletin, and demonstrated

evidence of prior planning

and assignment

of priorities.

Adequate staffing was maintained to accomplish the previously

noted

good condition of major equipment

and good percentage

of

plant availability.

Concurrently,

preventive maintenance

was

routinely performed

as scheduled,

except for non-safety-grade

instrument calibrations.

The scope

and frequency of the

non-safety-grade

instrument

program was being reassessed

at

the

end of the assessment

period.

Maintenance

backlogs varied

at times over the period,

and in some instances

were substantial.

No significant backlog reduction

was accomplished

over the

course of the assessment

period.

2.

Conclusion

The licensee's

performance

is rated Category

2 in this area.

The licensee's

performance

was rated Category

2 in this area

during the previous

SALP period.

3.

Board Recommendations

Nonce

D.

Surveillance

l.

~Anal sin

The licensee's

performance

in the functional area of surveillance

was evaluated

by considering the results of 14 routine inspections

performed

by the resident

inspectors,

two in-service inspections,

a reactor physics inspection,

and

a snubber observation

and

functional testing inspection

performed by regionally based

inspectors.

Enforcement history in this area

was good; only two Severity

Level IV violations were issued during the 17-month assessment

period.

This compares

very favorably to the

seven violations

noted during the previous

12-month assessment

period.

Neither

item (a test procedure

lacking adequate

acceptance

criteria

and

a failure to record data

as specified)

had major safety

significance or generic implications.

The first item was not

repetitive of previous violations, but shared

a trait (lack of

proper specificity in establishing

acceptable

performance)

with

a violation from the previous

SALP.

Though different systems

were involved, the licensee

approached

the question of

acceptance criteria generically.

12

Nineteen

LERs were identified as being associated

with this

functional area.

This compares

favorably to the

28

LERs

identified in the previous

12-month assessment

period.

In

contrast to previous

SALP periods,

most of the error-caused,

reportable

events

were administrative

(wrong limit, missed or

late testing) in nature, without "active" consequences.

Only

two examples

were noted that involved unnecessary

challenges

to systems

because

of inadvertent

safety feature actuations.

An IEC technician's

error (selecting

the wrong component during

a nuclear instrument test)

caused

a non-power reactor trip in

the middle of the period,

and

an operator error (selecting

the

wrong component during

a reactor trip breaker test) resulted in

an "at-power" reactor trip late in the assessment

period.

None

of the

LERs indicated

a programmatic

weakness.

Hanagement

involvement in ensuring quality of performance

in this functional

area

was broadly evident.

Management

has

supported

a wide range of procedural

upgrades

to minimize

errors

and confusion,

has provided specialized training and

dedicated staff to support infrequent or unique testing,

and

has reassigned

some testing responsibilities to sharpen

the

technical

focus.

A substantially

increased guality Control

group presence

in observing testing activities

has evolved over

the past year.

This has provided

an independent

emphasis

on

complete

compliance with procedures

in this functional area.

First line supervision is routinely and directly involved in

testing,

but senior

management

presence

is rare.

The licensee's

approach to technical

issues

and

NRC initiatives

typically placed primary emphasis

on safety considerations.

The licensee's

historical

tendency to deal with issues

and

events

as isolated

occurrences

has

shown

some

improvement during

the assessment

period.

This was evidenced

by the thorough

approach

taken in evaluating

an apparently ordinary Severity

Level IV violation (noted above) concerning

a component cooling

water test procedure that lacked adequate

acceptance

criteria.

The generic

approach

taken allowed the licensee

to discover that

the essential

service water pressure

drop across

the containment

spray heat exchangers

had increased

substantially.

Corrective

actions

were performed in a timely manner.

Engineering

evaluations of snubber surveillance,

when required,

were found

to be conservative

and thorough.

Two other areas of historical

NRC interest in the surveillance

functional area

have

been

procedure quality and personnel

errors

the latter especially

focused

on IEC technician errors.

The quality of surveillance

procedures

(accuracy, clarity,

achievability, etc.)

has

improved sufficiently, as

a result of

management-supported

upgrades

already mentioned, that this is

no longer

an area of specific concern.

This is exemplified by

the fact that

10

LERs involved deficient

18C test procedures

during the previous

SALP, but only 2 occurred during the current,

longer period.

I&C errors,

however,

though statistically

13

improved,

remain

something of a concern to

NRC.

The licensee

has

focused its attention

on this issue

and the functional

superintendent

is monitoring progress closely.

One instance

was identified where the licensee's

responsiveness

was poor.

In the area of reactor physics testing,

the licensee

emphasized

a narrow focus

on compliance

issues

and

on corrective

action.

This contributed to communication

and coordination

weaknesses,

and to delays

in resolving questions

during and

following the inspection.

Staffing was ample during this appraisal

period to perform

all required testing without delay,

and still support procedure

enhancement

reviews,

special

compensatory

testing

(when required),

and various augmentations

in training and record-keeping.

Reassignment

of some tests

improved focus

and resulted

in new

viewpoints.

Three full sections

in the Technical - Engineering

Department,

including Mechanical

and Electrical

Performance

and

the nuclear engineering staff,

have testing

as their major area

of focus.

2.

Conclusioh

The licensee's

performance is rated Category

2 in this area

with an improving trend.

The licensee's

performance

was rated

Category

2 in this area during the previous

SALP period.

3.

Board Recommendations

E.

Fire Protection

l.

~Anal ala

The licensee's

performance

in the functional area of fire

protection

was evaluated

by considering the results of one

routine inspection

by regional

inspectors

and

a consultant,

a

NRR Safe

Shutdown preliminary assessment,

and

on routine

observations

by the resident inspectors.

Enforcement history was good in this area.

Three Severity

Level IV violations were issued.

Two of these

three violations

involved events that occurred before this

SALP period.

These

two violations involved different fire protection technical

specification

ACTION requirements.

Specifically,

each resulted

in fire watch patrols being implemented late or not at all.

The one violation that occurred during the current appraisal

period involved fai lure to perform several

required monthly

checks of fire extinguishers

on schedule

in February

1987.

The

individual responsible for performing these

checks apparently

documented

them as complete

when they had not been

done.

He

was fired and his responsibilities

were reassigned

under

improved administrative controls.

14

One

LER was issued for this functional area,

which compares

very favorably with the

17 events of the previous,

shorter

period.

This single event,

which was caused

by personnel

error, involved inspecting

a sample

(10 percent) of rated

assemblies

and dampers

rather than all of them.

Several

"special" reports

were also issued in which the events

were

accurately described.

Most involved preplanned

maintenance

that required fire hydrants to be isolated.

Housekeeping

was examined with a focus

on control of

combustibles

and maintaining continuous

ready access

to fire

fighting equipment

and material.

Housekeeping

has continued to

improve; for example,

an extensive painting effort was initiated

in the auxiliary and turbine buildings.

The licensee

maintains

an appropriate attitude toward minimizing combustibles

and

"clutter" in all parts of the plant.

Management

involvement in ensuring quality in the decision

making process

has usually appeared

to be at

a level that

ensures

adequate

management

review.

This was evident during

the regional inspectors'ite visit and in discussions

between

the licensee's

corporate

management

and in the interface with

NRC Region III.

A Plant Manager's

Standing Order

(PMSO .095)

was issued requiring proposed

new technical

specifications

to be implemented

as if they were in effect.

The resident

inspectors

found personnel

knowledgeable

about these

requiremepts.

This should minimize transition errors

when

the technical

specifications

take effect.

The licensee's

approach

to resolution of technical

issues

from

a safety standpoint

appears

generally viable and

sound.

For

example,

the licensee

has undertaken

extensive

revision of the

primary, safe-shutdown

emergency

operating

procedure

(EOP).

This results in a basic

change

in philosophy from the previous

safe-shutdown

EOP

so that priority is given to utilizing as

much of the fire-affected unit's equipment

as possible before

proceeding to cross-tie to the other unit.

At the beginning

of the

SALP period,

NRR performed

a site evaluation of the

safe-shut

down procedures

including

a walk-thru simulation

~

to determine

the adequacy

an ease of application during

a

postulated fire.

The licensee

had previously contracted with

a consultant

(IMPELL) to assist in procedure

preparation.

IMPELL along with licensee

management

were present at the site

meeting

and were responsive

to

NRC questions

and concerns.

The

procedures

were determined to be adequate

although there were

some minor changes

and one concern relating to the installation

of jumpers

needed for hot shutdown.

The licensee

adequately

addressed

these

concerns.

The simulated walk-thru uncovered

few

problems all of which were properly addressed.

The meeting

concluded with every expectation that the licensee

would be

fully prepared for the fire protection inspection that had been

anticipated

in 1987

and which was later postponed.

15

The licensee

was receptive to information concerning

ideas

and

problems at other plants,

and is implementing

an innovative

"bar code" automatic reading/recording

system for performance

and documentation

of routine surveillance of fire protection

components.

The licensee's

responsiveness

to

NRC initiatives was acceptable.

The adequacy

of resolutions generally

proposed is demonstrated

by the large

number of outstanding

NRC issues

closed during the

regional site visit.

Numerous fire protection

and safe

shutdown

issues

remain to be reviewed

by

NRC including

a recent revision

to the licensee's

"Safe-Shutdown"

document

submitted during

this assessment

period.

On

a day-to-day basis,

the licensee's

responsiveness

to resident inspector questions

or problems

was

typically thorough

and timely.

Staffing in this functional area

was ample to accomplish the

routine fire protection workload.

Plant staff were responsible

for all the routine technical

specification

survei llances;

a

contractor performed compensatory

surveillances.

Organizational

changes

during the period consolidated

the fire protection

activities performed

by these

plant personnel

into a

new Safety

and Assessment

Department

under the Assistant Plant Manager for

Organization

and Administration.

The size of the contracted

force maintained to perform fire tours

and firewatches

was

continuously scaled

back as material

improvement to barriers

and penetrations

permitted.

This crew had

been

reduced to

about

40 persons

(from more than

50 during the previous

SALP)

late in the current assessment

period.

A strong corporate

technical/engineering

staff, including several

degreed fire

protection engineers,

supports

the plant in this functional

area.

2.

Conclusion

The licensee's

performance is rated Category

2 in this area.

The licensee's

performance

was rated Category

2 in this area

during the previous

SALP period.

3.

Board Recommendations

None

F.

Emer enc

Pre aredness

l.

~Anal sis

The licensee's

performance

in the functional area of emergency

preparedness

was evaluated

by considering

the results of

four inspections

conducted

by regionally based

inspectors

during this assessment

period, including observation of a

1986

remedial drill and the

1987 annual

emergency

preparedness

exercise.

16

Enforcement history in this area indicated

a slight decline

in licensee

performance

during this assessment

period;

a

Severity

Level IV violation was identified, whereas

no

violations were identified during the previous

assessment

period.

The

1986 drill and

1987 Exercise

scenarios

were considered

complex

and challenging, fully testing licensee

personnel

and

procedures.

Exercise

performance

in 1987

showed

improvement

over the

1986 Exercise in that the problems evident in the

1986

Exercise (requiring

a remedial

Exercise) did not recur.

The Emergency

Plan Implementing Procedures

were rewritten

during this period,

and were significantly improved.

However,

the last routine inspection disclosed that the administrative

procedures

for maintaining the emergency

response

program

had

not been

completed,

and

no tracking system existed to track

unique

and repetitive items.

A commitment

was received to have

these

in place within ninety days of the inspection.

With this

exception,

routine inspection results

were generally positive,

and the

number of outstanding

open items steadily declined during

the assessment

period.

Independent

audits of the program

have

been

conducted

in a timely and thorough manner,

and corrective

actions

have

been properly initiated on audit findings.

Staffing of emergency

preparedness

positions

and training of

involved personnel

were considered

adequate.

Interviews and

walkthroughs with plant personnel

indicated effective training

in emergency

procedure utilization and protective action

decisionmaking.

The training procedure for Emergency

Plan Overview for

managers

and technical staff training, including related

handouts,

was found acceptable.

Also, the minimum shift

staffing and functional capabilities

met the guidelines of

NUREG-0654 for emergency

response

organization.

Management

involvement in ensuring quality in this area

was adequate,

as evidenced

by the participation of Corporate

personnel

and plant management

in exit meetings following each

inspection

and their response

to identified

NRC concerns.

The

Emergency

Response

Coordinator position

now reports to the

Assistant Plant Manager - Technical

Support,

providing more

direct management

attention for the emergency

preparedness

function.

The licensee

has

been responsive

to

NRC concerns

by providing

viable and thorough

responses

and expending efforts to

adequately

close out identified items.

17

Conclusion

The licensee's

performance is rated Category

2 in this area.

The licensee's

performance

was rated Category

2 in this area

during the previous

SALP period.

3.

Board Recommendations

None.

G.

~Securi t

A~nal els

The licensee's

performance

in the functional area of security

was evaluated

by considering

the results of four inspections

(three routine

and

one reactive)

by regional security

specialists.

The resident

inspectors

also routinely observed

security activities.

Enforcement history in this area

represented

a decline in

the licensee

performance

during the assessment

period.

Two

Severity

Level

IV and three licensee-identified violations were

identified, compared with the three violations that

NRC staff

identified during the previous

assessment

period.

No major

safety concerns

were identified.

One of the violations pertained

to

a fai lure to adequately

implement required compensatory

measures.

This violation resulted

from ineffective licensee

measures

to correct

a previous licensee identified problem.

The other violation pertained to an isolated

problem in the

personnel

access

control program.

In addition, four NRC identified weaknesses

were identified

in the security program in the area of management

effectiveness.

These

weaknesses

pertained to

a lack of adequate

procedural

guidance

in some areas

and to correcting adverse

trends.

Some

of these violations and weaknesses

identified during the

assessment

period could have

been

recognized

and should

have

been corrected

before the

NRC became

involved.

The most notable finding that required resolution during this

assessment

period pertained to an inattention-to-duty

issue

involving the contract security force and licensee

security

management's

inability to implement adequate

corrective measures.

Although the licensee

and the security contractor

have tried to

correct the problem,

the resul'ts

have not been satisfactory.

Management

involvement in assuring quality in this functional

area is generally at

an acceptable

level, except for the

inattention-to-duty

issue

noted above.

During this assessment

period,

the licensee

has

been in the process

of constructing

18

a

new protected

area

access

control building, which,

when

completed,

should

improve personnel

and vehicle access,

particularly during

a major outage that is planned for mid-1988.

The

new facility will be equipped with state-of-the-art

access

control equipment.

Seven security event reports

(SERs)

were submitted during

this assessment

period:

Two were equipment related,

two were

personnel

errors,

two pert'ained to inadequate

compensatory

measures,

and the last pertained to an information protection

'roblem.

One of the

SERs required

an

NRC followup and resulted

in a notice of violation being issued.

In the previous

assessment

period, five events

were reported.

Although the total

number of SERs is not significant,

SERs

do

indicate that occasional

licensee identified implementation

problems exist that

need to be resolved.

This was supported

by the licensee's

safeguards

event logs which showed that

approximately

70 percent of log entries

involved personnel

access

control errors.

The previous

SALP report identified the licensee's

development

and implementation of a security Performance

Improvement

Program (PIP) intended to correct potentially significant

problems

in the security program

and improve the effectiveness

of the security organization.

Inspection activities during

this assessment

period confirmed that goals/objectives

in the

PIP have

been adequately

completed within the required time

period

and that success

has

been demonstrated.

In addition,

licensee

management will continue to implement

many of the

programs that were stated

in the PIP.

However,

on the basis

of inspection activities during this

SALP period,

licensee

action to improve the effectiveness

of the security program

has not been fully effective, particularly as it applies to

attention-to-duty

issues

and personnel

access

control program

errors.

Staffing in this functional

area

appears

ample.

Licensee site

security

management

has

a staff of six individuals assigned

to

overview and monitor the contract security force.

During this

assessment

period,

a licensee training specialist position was

developed

and filled.

This position will provide attention to

the contractor's training program.

With the resources

available,

the licensee

should

be able to provide closer

and more thorough

management

attention to the security program to identify and

correct potential

problems before they become significant.

The

contract security force was adequately

supervised

and trained.

The licensee's

responsiveness

to

NRC initiatives was generally

adequate.

When violations and weaknesses

were identified, the

licensee

usually took corrective action in a timely and effective

manner.

19

2.

Conclusion

The licensee's

performance is rated Category

2 in this area.

The licensee's

performance

was rated Category

2 in this area

during the previous

SALP period.

3.

Board Recommendation

None

H.

~outa

es

A~nal el s

The licensee's

performance

in the functional area of outages

was evaluated

by considering

one inspection

by a regional

inspector

and routine observations

of outage-related

activities

by the resident inspectors.

Enforcement history was excellent,

and

no violations were

identified in this functional area.

Two LERs were noted in resident

inspector

reviews

as associated

with this functional area.

Each involved procedures

inadequate

to ensure literal technical specification

compliance:

one

involved calibration checking of the manipulator crane

load

cell

and the other involved completing all required actions

when reducing residual

heat

removal

(RHR) flow.

The items

were not repetitive of previously identified problems,

safety

significant, or generic in nature.

Management controls in ensuring quality in this functional

area

were broadly evident.

A high degree of prior planning

was

exhibited,

as were proper understanding

and implementation of

procedures

and thorough verifications and reviews.

The licensee

generally kept projects

on or near schedule,

but showed

a

willingness to adjust

schedules

when appropriate

to optimize

material conditions or foreclose safety or regulatory concerns.

As part of an internal reorganization,

personnel

dedicated

to forced outage

contingency planning were reassigned

to the

Operations

Department to improve access

to and communications

with licensed staff "experts" concerning prioritization,

configuration

and technical specification

requirements,

and

activities coordination.

The forced outages that occurred

during this assessment

period 'were all begun with a timely

(updated weekly), pre-packaged

outage

plan already available.

Necessary

revisions to the plan were considered

and approved at

the proper management

level.

Material resource

constraints

were

not a significant factor in determining the

scope of work.

20

The voluntary shutdown of Unit 2 in August

1987 to investigate

reactor

coolant

pump hatch cover studs,

and the two-week Unit 2

outage in July 1987 to reduce within-limit leakage,

both exemplify

a positive and conservative

approach to technical

issues

from a

safety standpoint.

The licensee

was responsive

to

NRC Region III and resident

inspector requests

involving the upcoming major Unit 2 outage

for steam generator repair,

and provided briefings on topics of

interest both at the site

and at the

NRC Region III

offices'taffing

in this functional area

was adequate

to perform all

required work, and sufficient flexibilityexisted to address

newly identified jobs in a reasonable

time.

Many activities

were performed

by contractors,

over whom the licensee

continued

to exercise

a generally effective set of controls,

As with

material

resources,

staffing resources

were not

a dominant

constraint

on decisionmaking.

The licensee

conducted

post-outage

system

and plant

testing effectively, pursuant

to integrated

schedules

that

comprehensively

and effectively controlled plant conversion

from outage to operating conditions.

As a result, after its

refueling outage

ended

on October 4,

1987, Unit

1 produced

power daily through the remaining five months of the

SALP

period.

2.

Conclusion

The licensee's

performance is rated Category

1 in this

area.

The licensee's

performance

was rated Category

1 in

this functional area during the previous

SALP period.

3.

Board Recommendations

None

I.

En ineerin /Technical

Su

ort

1.

~Anal sis

The licensee's

performance

in the functional area of

engineering/technical

support

was evaluated

by considering

the results of eight regional inspections,

observations

during

the routine resident inspections,

and evaluation of licensee

technical

submittals

by

NRC Headquarters

technical

reviewers.

Activities examined during region-based

inspections

included

the following:

repair of component cooling water piping cracks;

pipe support design discrepancies;

various modifications;

response

to IE Bulletin 82-02 (Threaded

Fasteners);

response

to

IE Information Notice 87-01 (Thinning of Pipe Walls); containment

hatch cover bolting deficiencies;

polar crane structural

deficiencies;

steam generator

snubber inspections

(IE Information

Notice 86-102); electrical

design control, and;

10 CFR 50.59

safety evaluations.

21

Enforcement history consisted of one Severity Level IV violation

involving poor electrical

engineering

design control.

A

determination

has yet to be

made

as to whether there is

a

generic

weakness

in this area;

however,

one of the examples

in

the violation involved implementing engineering

judgment before

completing

a thorough documented

engineering

design review.

This

same description applies to a piping system repair (discussed

above

under Maintenance)

performed without a thorough engineering

evaluation.

Plant staff-has historically relied

on systems

engineers

in the corporate office for advice

and consent

on

engineering/technical

matters.

A verbal authorization is often

viewed as sufficient.

The communication of complex technical

matters

by phone (as

sometimes

occurs)

can increase

the chance

that the question or the answer

may be misunderstood.

Six

LERs were identified during resident

inspector

reviews

associated

with this functional area.

The six events

included two caused

by personnel

errors,

two

apparent

design deficiencies,

an intergroup coordination

problem

following a design

change,

and one voluntary report concerning

apparent

biased

instrument drift.

None were individually safety

significant nor did they repeat previously identified problems.

Management

involvement in this functional

area

was mixed.

With

respect

to safety evaluations,

an example of strong

management

involvement was the recent decision to require formal training

of plant personnel

performing

10 CFR 50.59 applicabi lity checks.

Another example

was the decision to request

the nuclear

steam

supply system

(NSSS)

vendor to perform

a complete safety analysis

addressing all applicable

areas

of the final safety analysis

report

(FSAR) in support of a special test (turbine volumetric

flow test).

The extent

and effectiveness

of management

involvement with respect

to quality verification was usually

good in that independent verification of the design

process

through in-depth technical

reviews

was generally accomplished.

However,

improvements

can

be

made in prior planning

by

conducting

more thorough predesign

walkdowns.

Two weaknesses

involving management

involvement were identified

in the area of design control.

The first was evidenced

by the

implementation of a design

change

on shutdown

and indication

panels without verifying the adequacy of the design before

declaring the

system fully operable.

The

second

concerns

the

availability of documentation

on design

bases.

This was

seen

in the equipment qualification'inspection.

As a result,

the

licensee

put several

programs into effect to update

the

documentation

of the design

bases

of the plant.

22

From

a safety standpoint,

the approach to technical

issues

was also mixed.

Though

a strong engineering

and technical

orientation to the study of problems

and questions

was typical,

the mixed results

involved whether

an adequately

generic review

was undertaken,

especially in reviews to address

an immediate

hurdle.

When the engineering

evaluations

are not under

a time

constraint,

such

as planned design

changes

and studies that are

under licensee

schedule control, results

are usually broadly

based

and well documented.

When time pressures,

plant

availability questions,

or other outside influences exist,

the

focus can narrow and documentation quality and review processes

weaken.

This applies to both violations discussed

above

and to

an "emergency" design

change

involving replacement

of battery

charger automatic timers, which contained discrepancies

in the

documentation

package.

Examples of high quality performance

on

licensee-identified

and controlled activities .included design

and installation of the

new control

room instrument distribution

(CRID) panels,

the replacement

of the

2CD battery

and rack, the

study of boron-10 depletion effects

on shutdown margin,

and the

final resolutions

on problems involving component cooling water

degradation,

fuel oil intrusion into embedded

conduit,

and

containment

spray heat exchanger fouling.

In addition, the licensee

has

shown strong engineering

and

technical

support in the area of licensing.

This was especially

evident in the

steam generator

repair project where the licensee's

staff thoroughly researched

industry experience

before the

project started for lessons

learned

and the best approach for

the plant.

The

steam generator repair report submitted to the

staff for review and approval

demonstrated

a clear understanding

of both the technical

and regulatory issues

involved in replacing

the

steam generators.

The licensee

was generally cooperative with the

NRC staff

and responsive

to staff questions

and concerns.

The licensee

provided technical

information and performed adequate

reviews

on potential

issues relating to items

such

as ice condenser

containment design,

Barton brand transmitters,

auxiliary

feedwater

system design

and

pump thrust bearing lubrication,

main steam safety valve orificing, Tube Turns brand penetration

cooling assemblies,

and IE Bulletin 82-02 concerning

degradation

of threaded fasteners.

However, after three pipe supports with

deficiencies

were discovered

in the component cooling water

system, it was found that IE Bulletin 79-14 (Seismic Analysis

For

As Built-piping Configurations)

data

were retrievable for

only one of the three

supports

and as-built drawings could be

found for only two of the supports.

In addition, the drawings

did not include the identified discrepancies.

A review by the office of Nuclear Reactor Regulation

(NRR) of

the licensee's

10 CFR 50.59 process

found it to be thorough,

technically sound

and well documented.

A conservative

approach

is normally taken in response

to 10 CFR 50.59 questions.

23

Training and qualification effectiveness

in this area

was good.

Although staffing in the Nuclear Safety

and Licensing Section

appeared

good and improving on the basis of the quality of the

safety review memoranda

reviewed,

one indication of a potential

weakness

in tracking staff qualification was identified.

In one

instance,

an

un qual ified member of the plant staff performed

a

safety evaluation of a temporary modification.

The licensee

maintains

an ample engineering staff (several

hundred people),

who have

a broad range

and depth of technical

capability.

Though rarely necessary,

the licensee

has not

hesitated,

when appropriate,

to contract highly specialized

experts.

The vast majority of the licensee's

engineering staff,

however,

wor ks out of the corporate office in Columbus,

Ohio,

about three

hundred miles from the plant.

Although there

have

been

improvements

in getting corporate

system engineers

out to the site for certain projects,

both time and expense

continue to mitigate against

the degree of involvement that

would be possible with more engineers

on site.

The site

organization

and management

have fostered

an improving system

engineering

approach within the constraints

of site resources.

2.

Conclusions

The licensee's

performance is rated Category

2 in this area.

Because this is

a new area,

no rating is available for the

previous

SALP period.

3.

Board Recommendations

None

J.

Licensin

Activities

1.

~Anal sl s

The licensee's

performance

in the functional area of licensing

activities was evaluated

by considering

the support of licensing

actions that were either completed or had

a significant level

of activity during the assessment

period.

During the assessment

period, the licensee

made conscientious

efforts to meet commitments.

Responsiveness

by the licensee

facilitated timely completions of staff review of a large

number of licensing actions, i.e. 65,

and thus reduced

the

licensing backlog.

The quality of license

amendment

requests,

especially the "no significant hazards

considerations

determination,"

improved.

The licensee

responded

promptly

and accurately to various

surveys

conducted

during the

assessment

period.

In addition, the licensee,

at NRR's request,

provided submittals for NRR in a very short turnaround time.

This was especially evident in the licensee's

response

to NRR's

request

for additional information concerning

steam generator

24

repairs,

where the licensee

was required to review a vast amount

of documentation

in a very short period of time.

The licensee's

response

was timely and of high quality.

For the most part,

the licensee

submitted license

amendment

applications

in a timely manner to prevent hardship

on staff

resources.

In one instance,

the licensee

submitted

a request

for a change to the technical

specifications

concerning testing

surveillance

extensions

and did not allow adequate

time for

the normal

30-day

comment period.

The staff had to process

the change

as

an emergency.

The problem was brought to the

attention of the licensee's

management

and resolved quickly.

The licensee's

management

has demonstrated

a very active role

in assuring quality in licensing-related activities.

Strong

management

involvement was especially evident where issues

had

potential for substantial

safety impact and extended

shutdowns.

Licensee

management

actively participated

in an effort to work

closely with NRR to promote

a good working relationship.

The

majority of submittals

were consistently clear

and of high

quality.

Licensee

management

frequently participated

in meetings

in Bethesda

on short notice.

Management

kept abreast

of current

and anticipated licensing

actions.

In this assessment

period, the most notable

areas

were the efforts related to steam generator

replacement,

the

surveillance

extension

associated

with reduced

power to prolong

the

steam generator life, and the completion of longstanding

TMI

and Salem

ATWS action items.

The management

continues to be directly instrumental

in the

licensee

focusing

on the major safety issues

and

on placing the

safety aspects

of reviews in the forefront of concerns.

The licensee's

approach to resolution of technical

issues

from a safety standpoint

was technically

sound

and very

thorough.

The licensee

demonstrated

a strong understanding

of the technical

issues

involved in licensing actions

and

proposed

sound

and timely resolutions.

This was evident in

several

areas,

including steam generator repair, fire protection,

and technical

specifications.

Conservatism is being exhibited

in relation to significant safety issues

on

a routine basis.

Consistently

sound technical justification is provided by

the licensee for deviations

from staff guidance.

The good

communications

between

the licensee

and

NRC staff have

been

beneficial in the processing

of licensing actions.

The licensing staff is ample to assure

timely response

to

NRC needs.

Positions

are identified and authorities

and

responsibilities

are well defined.

NRC considers

the licensing

staff and the quality of the support engineers

is a strength

for the licensee.

25

2.

Conclusions

The licensee's

performance

is rated Category

1 in this area.

The licensee's

performance

was rated Category

2 during the

previous

SALP period.

3.

Board Recommendations

None

K.

Trainin .and

uglification Effectiveness

1.

~Anal sis

The licensee's

performance

in the functional area of training

and qualification effectiveness

was evaluated

by considering

a requalification training effectiveness

inspection,

special

NRR team inspection,

snubber

maintenance

and functional testing

inspection,

emergency

preparedness

inspection,

observations

by resident

inspector s,

and the results of licensed operator

examinations

and associated

observations,

Although no violations and

no reportable

events

were identified

specifically associated

with this functional area,

some

violations assigned

to other functional areas

had training or

qualification effectiveness

implications:

incorrect limiting

condition for operation

(LCO) was applied

due to the failure to

integrate available information; reactor coolant

system pressure

and temperature

limits were violated as

a result of poor shift

teamwork;

inadequate

survey or control of contaminated material;

maintenance

procedure

was mis-coordinated

involving redundant

trains;

and other procedure violations identified.

Two Confirmatory Action Letters

(CALs) were issued to specify

actions to correct unsatisfactory requalification program

implementation.

CAL-RIII-87-012 was issued

as

a result of the

June

1987 requalification examination

(47 percent

pass rate)

and CAL-RIII-87-012, Amendment

1,

was issued

as

a result of

the August 1987 requalification examination

(53 percent

pass

rate).

As noted below, followup inspection

in this area

identified

a number of weakness

in the requalification program

A review of LERs involving personnel

errors

suggested

the

errors

were not attributable to programmatic training program

deficiencies.

The operational

events attributed to personnel

error by the licensee

in

LERs included five technical

specification violations

and four safety features

actuations.

In only one of these

nine events did the licensee

require

training as

a corrective

measure.

None of the remaining eight

appeared

to be

a result of inadequate

training'.

26

Management

involvement in ensuring quality in this functional

area

was mixed.

Resource

investments

included

a

new training

complex

on site with a state-of-the-art,

plant-specifjc, control

room simulator; classrooms;

shops;

laboratories;

a functioning

Technical

Support Center .simulator;

and associated

support

facilities.

One positive result was improved maintenance

training.

For example,

mock-up training on pressurizer

spray

valve repair resulted in improved valve performance.

On the

other hand,

even though the training facility was fully staffed,

the licensee

did not dedicate sufficient instructors to the

licensed operator requalification program.

Management

ensured that the skill and experience

levels of

training department

instructors

were appropriate

by transferring

experienced

personnel

from other plant departments

into the

training group.

All ten training programs

subject to INPO

accreditation

have

been accredited.

Additional programs

(technical

engineering,

safety evaluation)

were developed

by

similar means

and to similar standards

as those

used to achieve

accreditation.

Management

assurance

of quality was further

indicated

by the lack of differentiation in training, retraining,

and qualification of both licensee

personnel

and contractors,

with identical job requirements,

The licensee

evaluates

the effectiveness

of the training

programs

by an interactive trainer/trainee

dialogue involving

trainee-produced

appraisals;

by interaction

between

the

Training Department

and various plant functional departments

under

a Plant Manager's

procedure;

and by continuous critical

evaluation of corrective action program items involving

personnel

error.

In addition, the Training Department is

itself required to produce

an annual

performance

report for

evaluation

by the Plant Nuclear Safety

Review Committee.

Notwithstanding these activities, the licensee

neither

identified the problems associated

with the licensed operator

requalification program,

nor took effective corrective action

for problems identified as early as

1984,

when the

NRC

substituted

NRC questions for 75 percent of the licensee's

exam and only 29 percent of the operators

who took the

exam

passed it.

The licensee'

response

to

NRC initiatives and resolution of

technical

issues

was adequate.

In September

and October of

1987, the licensee requalification program was inspected

as

a result of the unsatisfactory rating previously achieved.

Weaknesses

were identified in the program,

such as:

only

25 percent of the available training time was spent in

structured

license training; attendance

could be waived;

significant redundancy

existed

among the several

annual

exams

given in the

same cycle;

and operators

were not provided with

27

feedback to their quiz grades

so they could take remedial

action

(learn the material).

Some of these

weaknesses

are reminiscent

of weaknesses

identified in 1985 and confirmed the necessity

of

the commitment to long-term actions.

In response

to the

NRC's

findings regarding the requalification program,

the licensee's

management

carried out appropriate

immediate corrective measures

and met with the

NRC staff to develop appropriate

long-term

actions.

Ouring this period,

replacement

exams

were administered to

26 license candidates:

22 of these

candidates

passed.

This

85 percent

pass rate is consistent with the previous

SALP

period and is about the industry norm.

2.

Conclusions

The licensee's

performance is rated Category

2 in this area.

The licensee's

performance

was rated Category

2 during the

previous

SALP period.

3.

Board Recommendations

Although performance is rated Category

2, the Board notes that

requalification training deficiencies

continued

from previous

SALP appraisals

and warrants

increased

management

attention.

ualit Activities and Administrative Controls Affectin

ualit

1.

~Anal sis

The licensee's

performance

in the functional

area of quality

programs

and administrative controls affecting quality was

evaluated

by assessing

two related but separate

areas.

The

first is the effectiveness

of the licensee's

independent

quality organizations.

This includes the quality assurance

organization

as well as other organizations that independently

review licensee activities to identify problems for corrective

actions.

The

second

area is the licensee's

management activities

aimed at achieving quality in overall plant operations.

As such,

strengths

and weaknesses

identified in other functional areas

were reviewed to determine if common attributes could be

identified.

In addition, licensee initiatives to maintain

or improve the overall quality of operations

were considered.

The licensee's

independent quality oversight organizations

were

evaluated

by considering

routine inspections

by the resident

inspectors,

three inspections

by regional

inspectors,

and the

results of a QVI team inspection.

The regional inspectors

focused

on follow up to previously identified matters

in the

area of modifications,

procurement

and maintenance.

28

With respect to the effectiveness

of the independent quality

oversight organizations,

enforcement history in this functional

area

showed

some

improvement,

but was not exceptional.

A total

of six violations (Three Severity Level IV, three Severity

Level

V) were identified during this appraisal,

compared to

eleven violations noted during the previous,

shorter period.

This performance

continued

an improving numerical trend in this

area.

On the other hand, three of the violations involved the

procurement

area; either aspects

of qualifying suppliers to the

licensee's

Qualified Suppliers List (QSL) or to maintenance

and

utilization of the

QSL.

Some of these violations contained

two

or three examples.

In addition,

one of the violations pointed

to

a weakness

in the certification process for lead auditors.

Management

was involved in decisions that affected quality.

As

a consequence

of this involvement, efforts were completed

which enabled

inspection closeout of about sixty previously

identified findings,

open or unresolved

items,

and

recommendations.

Improvement

was noted in the licensee's

resolution

and close out of backlogged

Condition Reports,

backlogged

Requests

for Change,

onsite review committee

workload,

and overall corrective action program administration

at the site.

While the closeout of these

items is considered

commendable,

the licensee's

proposed

actions to correct

problems in the area of procurement

program weaknesses

were

not responsive

to

NRC concerns,

despite

considerable

dialog

between

the utility and

NRC management.

Rather,

the licensee

was defensive

and argumentative

about thi s issue.

Failure of

licensee

management

to followup on problems

and take effective

corrective action

has contributed to previous

SALP Category

3

ratings in this functional area.

Although improvement

has

been

noted in several

areas,

management

involvement at the corporate

QA level

was not effective in improving performance

in the

procurement

area.

Conscious decisions

were

made at the corporate

level not to provide direct oversight of activities with potential

impact

on the quality of safety-related

components

and services.

Specifically, the crankshafts

of the diesel

engines

for the

emergency

generator

were reclassified

from safety related to

non"safety related in order to expedite

procurement of repair

services

from an approved supplier.

This was done instead of

completing

a formal technical

and engineering

evaluation to

establish

what in-process

controls by the vendor and additional

reviews

by qualified licensee

inspectors

may be needed at the

supplier's facility.

Subsequent

to this assessment

period, senior

NRC and licensee

management

have

met to discuss

adequate

corrective action,

especially in the area of procurement.

The licensee

has

engaged

the services of an independent

contractor to evaluate

the apparent

problem in the area of procurement.

Results of

that effort will be reviewed

and evaluated

during the

SALP 8

assessment

period.

29

The approach

used

by the licensee

to resolve technical

issues

from a safety standpoint

was generally conservative

and,technically

sound,

but there

were exceptions.

For example,

AEP corporate

QA management

decided to revert to procurement

methods

which the

NRC had previously determined to be weak.

In

addition, safety related

items and services

were re-classified

as non-safety related

(Commercial

Grade) to expedite

procurement.

This resulted

in the procurement of services

and parts,

including the crankshafts for the emergency diesel

engine,

with questionable

or indeterminate quality.

Two organizations

provide routine independent quality

oversight at the site level.

A new Safety

and Assessment

Department

(S&A) was created

on site during this

SALP period,

to consolidate

the Quality Control group,

the certified

nondestructive

examination

(NDE) technicians

and examiners,

the Fire Protection

Group

and Fire Protection Coordinator,

and

the Shift Technical Advisors (STAs).

The

S&A Department

does

independent

inspections

and survei llances,

administers

the

corrective action

and trending programs,

and performs support

studies of events

and various technical

issues.

The

second

organization is the site Quality Assurance

(QA) organization,

which implements the

10 CFR Part 50, Appendix

B auditing

requirements

and performs surveillance of other activities

at its own discretion.

The site

QA group is organizationally

independent

from plant and Nuclear Operations Division management.

The

S&A and site

QA organizations

were both effective,

conducting technically sound,

performance

oriented

verifications of the quality of activities at the working

level.

Both groups generally insisted

on

a broadly based,

effective corrective action for identified problems.

Of particular mention during this

SALP period was the

licensee's

decision to perform

a Safety

System

Functional

Inspection

(SSFI).

The Quality Assurance

corporate organization

sponsored this in-depth evaluation of the auxiliary feedwater

systems

at the

D.

C.

Cook plant.

Several

valuable observations

were

made

and

some subtle discrepancies

were identified.

This

type of challenging self-appraisal

is commendable.

Concerning the question of management activities aimed at

enhancing quality in overall plant operations,

a number of

attributes or activities

show involvement to ensure quality

and to resolve technical

issues

and

NRC concerns

from a safety

standpoint.

For example,

the licensee

maintains

strong

and

open communication

channels

from management

to staff and

back.

Responsibilities

are clearly assigned

among managers

for maintaining specified plant areas

and equipment in good

condition.

A broad-based,

visible corrective action program,

with built-in feedback,

which "grades"

problems

by significance,

analyzes for trends,

and requires participation

by senior-most

management,

is in daily use.

30

The licensee

has demonstrated

conservatism

in removing

a

unit from service

in order to resolve questions.

Substantial

material

resources

have

been provided to improve performance

capabilities (plant-specific simulator, auxiliary buildfng

upgrade);

to address

identified concerns

(request for change

backlog reduction,

warehouse

upgrade

and consolidation);

or

to improve material condition and/or appearance.

Ample staff

has

been provided in most functional areas.

The licensee

has

developed

and is implementing the innovative guality Maintenance

Team concept.

Thorough, detailed

LERs which provide

a good

understanding

of events,

root causes,

and corrective actions,

are typical.

There were also examples that indicate

some areas

need

continued or increased

management

attention.

For example,

changes

in base

documents

or commitments thereto (technical

specifications,

ASME Codes)

were not properly translated

into

working procedures

in several

cases.

Timeliness in upgrading

some weaker procedures

(annunciator

responses,

radiation

protection)

was poor.

The focus

on problem review for corrective

and preventive actions

was

sometimes

too narrow.

The licensee

relied,

on occasion,

on informal technical/engineering

input

or judgment to justify actions,

without always completing

a

previously documented

safety evaluation against all required

criteria.

Some contractors

performed important requirements

without strong-enough direct licensee

involvement and/or

supervision (radiation protection,

security) which caused

delayed or ineffective action

on performance

problems'dministration

of the gSL for safety related

procurement

was

associated

with several

violations, but comprehensive

corrective

actions

have not been

undertaken with a vigor appropriate

to

the degree of NRC concern in this area.

2.

Conclusions

The licensee's

performance is rated Category

2 in this area.

Particular

management

attention

should

be given to area of

procurement,

specifically addressing

vendor qualification

and the procurement of parts

and services.

The licensee's

performance

was rated Category

2 in this functional area during

the previous

SALP period.

3.

Board Recommendations

None.

31

V.

SUPPORTING

DATA AND SUMMARIES

A.

Licensee Activities

1.

Unit

1

D.

C.

Cook, Unit

1 began this

SALP assessment

period in routine

power operation.

Peak

power level

was normally restricted to

90 percent of licensed

power throughout the assessment

period

in order to preserve

steam generator

tubes.

Unit 1's Cycle 9-10

refueling outage activities were completed during the middle

of the assessment

period,

and the unit ended the

SALP period

operating

again at nominal

90 percent

power levels.

Significant outages

or major events that occurred during the

assessment

period are

summarized

below:

Si nificant Outa es/Major

Events

a.

November 22-23,

1986 - Unit 1 was out of service following

a reactor trip caused

by drift of the turbine generator

thrust bearing wear detector circuit.

b.

April 8-21,

1987 - Unit

1 was shut

down because

of

increasing,

unidentified, primary coolant

system

leakage

of more than

one gallon per minute.

During the plant

cooldown,

the pressure/temperature

limits of technical

specifications

were violated.

After repairing leaks found

in both the primary and secondary

systems,

the unit was

returned to service.

C.

June

4,

1987 - Unit 1 tripped on steam generator

No.

12

high level because

of an operator error and controller

failure.

Some leaky valves were repaired

and the unit

was returned to service

June 5,

1987.

d.

June

27

October 4,

1987 - Unit 1 was shut

down for

its scheduled

refueling, maintenance,

and testing outage

(Cycle 9-10).

Activities included eddy-current testing of

steam generators;

refurbishment of reactor coolant

pump

seals;

NDE on various valves, fasteners,

flanges,

and

hangers;

steam generator

tube sheet

and annulus cleaning;

repair of train "A" emergency

core cooling system

(ECCS)

pump conduits;

and the reactor coolant

pumps

and Control

Rod Drive Mechanism

(CRDM) hatch covers.

32

e.

October

13-14,

1987

Unit

1 was out of service after

a reactor trip to repair the east

main feedwater

pump

lubricating oil pump,

whose failure had caused

the trip.

f.

January

13-14,

1988 - Unit

1 was out of service following

a reactor trip caused

by an operator error (attempting

to manipulate

the wrong reactor trip breaker for a test).

Unit

1 experienced

four reactor trips with the unit at greater

than or equal

to

15 percent

power;

two trip signals

occurred at

less

than

15 percent

power.

Two of the Unit

1 reactor trips

involved personnel/procedural

errors,

three were related to

mechanical/equipment

failures.

One resulted

from personnel

error combined with a mechanical

problem.

In addition,

one

engineered

safety features

actuation

(main

steam isolation valve

isolation signal) occurred, with the unit shut down, because

of

an equipment failure.

2.

Unit 2

D.

C.

Cook, Unit 2 was in routine power operation at

a nominal

80 percent

power limit (to preserve

steam generator

tubes)

during the

SALP assessment

period.

Several

power reductions

and two outages

were conducted to perform maintenance activities.

Significant outages

or major events that occurred during the

assessment

period are

summarized

below:

Si nificant Outa es/Major Events

b.

C.

March 3-April 21,

1987 - Unit 2 was shut

down for a

steam generator

maintenance

outage.

Activities included

100 percent eddy-current testing of all four steam

generators

and repairs to steam generator

leaks.

A total

of 110 tubes

were plugged.

June

1-3,

1987 - Unit 2 experienced

a brief outage after

a reactor trip that was caused

by low condenser

vacuum

resulting from leaking isolation valve.

July 14-23,

1987 - Unit 2 experienced

a reactor trip and

remained

shut

down to replace

a failed voltage regulator,

which caused

the event,

and to repair

some minor valve

leaks found during post trip containment inspections.

A second trip occurred during restart

on July 22 as

a

result of a feedwater controller failure.

33

d.

August 26-October

11,

1987 - Unit 2 was shut

down for

a

maintenance

outage which was precipitated

by discovery

of improperly installed bolts

on the reactor coolant

pump

(RCP) hatch covers.

Outage activities included resolution

of the hatch bolting problems,

and maintenance

and

surveillance activities (100 percent eddy-current testing

and required plugging)

on the steam generator

tubes.

Unit 2 experienced

three reactor trips at greater

than or

equal to

15 percent

power;

two trip signals occurred at less

than

15 percent

power.

One of the Unit 2 reactor trips

involved personnel/procedural

errors,

three were related

to mechanical/equipment

failures.

One resulted

from the

combination of an equipment failure and

a personnel

error.

In addition,

one Unit 2 safety injection system (SIS) actuation

signal occurred, with the unit in mode 5, which was caused

by

an instrument technician error during maintenance.

B.

Ins ection Activities

This assessment

(covering the period October

1,

1986, through

February

29,

1988) considered

the results of 45 inspections.

The

associated

inspection reports

are listed in paragraph

B. 1. below.

Significant inspection activities are listed in paragraph

B.2 of

this section,

Special

Inspection

Summary.

1. ~t<<i

0

Facility Name:

D.

C.

Cook

Unit:

1

Docket No.: 50-315

Inspection

Report Nos.:

86013,

86035,

87001 through

87033 (excluding 87018,

not used)

and 88002 through 88007.

Facility Name:

D.

C.

Cook

Unit: 2

Docket No.: 50-316

Inspection

Report Nos.:

86013,

86035,

87001 through

87033 (excluding 87018,

not used)

and 88002 through 88008.

86038 through 86043,

020,

and

021 - which were

86038 through 86043,

020,

and

021 - which were

Table I

Number of Violations in Each Severit

Level

Functional

Areas

A. Plant Operations

B. Radiological Controls

C. Maintenance

D. Surveillance

E. Fire

Protection'.

Emergency

Preparedness

G. Security

H. Outages

I. Engineering/Technical

Support

J.

Licensing Activities

K. Training 4 Qualification

Effectiveness

I. Quality Prog

8 Admin.

Controls Affecting

Quali ty

UNIT 1

III IV

V

1]*

1

2

UNIT 2

III IV

V

COMMON

III IV

V

]*

3

2

2

TOTALS

UNIT 1

UNIT 2

COMMON TO BOTH

III IV

V

III IV

V

III IV

V

5

1"

1

13

4

"These violations were discussed

during SALP 6 and issued

dur ing

SALP 7.

S ecial Ins ection

Summar

i)

An emergency

prepar edness

inspection/exercise

was

conducted

during February 9-11,

1987 (Inspection

Report

Nos.

315/87006

and 316/87006).

ii)

A Quality Verification and Implementation

team inspection

was conducted

October 19-30,

1987 (Inspection

Report

Nos.

315/87026

and 316/87026).

35

C.

Investi ation and Alle ations

Review

Four allegations with concerns

associated

with the

D.

C.

Cook

Nuclear

Power Station were received in the Region III office during

this

SALP assessment

period.

Three of these allegations

as well as

seven

previous allegations

were closed during this

SALP period.

Two

allegations

remained

opened at the

end of this assessment

period.

D.

Escalated

Enforcement Actions

One Severity

Level III violation was issued during the assessment

period.

The associated

civil penalty, in the amount of $50,000,

was paid

on April 10,

1987.

On September

5,

1986,

the licensee

had

failed to perform the required action to initiate a reactor

shutdown

when both safety injection trains lacked

an operable

flow path

(Inspection

Report Nos.

315/860041;

316/86041

and 315/86042;

316/86042,

and Enforcement

Case

No. EA-87-013).

E.

Licensee

Conferences

Held Durin

Assessment

Period

1.

January

21,

1987,

Region III Office:

An enforcement

conference

was held with licensee

representatives

concerning

the operation

of Unit 2 when

one safety injection train

had

no flow path

and

the alternate train flow path

was restricted.

2.

February

5,

1987, Site:

A management

meeting

was held with

licensee

representatives

to discuss

the Systematic

Assessment

of Licensee

Performance

(SAI P 6).

3.

February

5,

1987, Site:

A management

meeting

was held with

licensee

representatives

to discuss

the licensee's

plans with

respect

to Unit 2 steam generator

leaks.

4.

April 27,

1987,

Region III Office:

An enforcement

conference

was held with licensee

representatives

to discuss

the apparent

technical specification violation regarding

a unit cooldown in

which Unit

1 was operated

outside the primary coolant

system

temperature/pressure

limitations on April 8, 1987.

5.

July 24,

1987,

Region III Office:

A management

meeting

was held

with licensee

representatives

to discuss

the results of NRC's

administration of operator requalification examinations

and the

licensee

evaluations.

6.

September

17,

1987, Site:

A management

meeting

was held

with licensee

representatives

to discuss

and gain further

understanding

of potential

problems in the areas

of quality

control inspections

and procurement of products/services.

7.

September

30,

1987, Site:

A management

meeting

was held with

licensee

representatives

to discuss

equipment

hatch cover

bolting deficiencies

in Unit 2, the results of the analysis

for the as-found condition,

and proposed corrective actions.

36

8.

October 23,

1987,

Region III Office:

A management

meeting

was

held with licensee

representatives

to discuss

the

steam generator

replacement

program in Unit 2.

9.

December

10,

1987,

Region III Office:

A management

meeting

was held with licensee

representatives

to discuss

NRC concerns

regarding

the radiation protection

program.

F.

Confirmator

Action Letters

CALs

One

CAL .and its amendment

were issued during this assessment

period

(CAL-RIII-87-012, July 15,

1987 and CAL-RIII-87-012A, September

4,

1987).

These

documents

addressed

the failure rate

on operator

requalification examinations

administered

during the weeks of June

22,

1987 and August 3,

1987.

G.

A Review of 10 CFR Part 21

Re orts

and Licensee

Event

Re orts Submitted

b

the Licensee

1.

10 CFR Part 21

Re orts

One Part

21 report

was issued

by the licensee

concerning

Brown-Boveri Electric Co. dry type tranformers, with terminal

corrosion

caused

by acid residue left on the leads

by the

manufacturing

process.

Corrective actions were reviewed

and

the item closed in

NRC Inspection

Report

Nos.

315/88003(DRS)

and 316/88004(DRS).

2.

Licensee

Event

Re orts

LERs

D.

C.

Cook, Unit

1

Docket No.: 50-315

LER Nos.:

85072,

86021 through 86024,

87001 through 87022,

and

88001.

Twenty-eight

LERs were issued during this assessment

period for

Unit 1.

LERs listed by basic

cause

are

shown below:

BASIC CAUSES

Unit

1

SALP 7

Personnel

Errors

Procedure

Inadequacies

Equipment/Component

Design Discrepancies

Other

37.5X

17.95

26.8X

14.3%

3.

6'00.OX

(10.5)*

( 5 0)

(

7 5)A'

4.0)

1.0

28.0)

  • One event caused

by both personnel

error and component

failure

37

D.

C.

Cook, Unit 2

Docket No.: 50-316

LER Nos.:

86026 through 86031,

87001 through 87015,

and 88001.

Twenty-two LERs were issued during this assessment

period for

Unit 2.

LERs listed by basic

cause

are

shown below:

"BASIC CAUSES

Personnel

Errors

Procedure

Inadequacies

Equipment/Component

Design Discrepancies

Other

Unit 2

SALP 7

56.8% (12.5)"

9.1% ( 2.0)

2S.'O%%d ( S.'S)

00.0% ( 0.0)

~2.%

2.2

100% (22.0)

"One event caused

by both personnel

error

and equipment failure

Collectively, Unit

1 and Unit 2 issued

50

LERs during this

SALP

period.

The following table

shows

a comparison of LERs for

the

SALP 6 and

SALP 7 periods:

BASIC CAUSES

Per sonnel

Error s

Procedure

Inadequacies

Equipment/Component

Design Discrepancies

Other

SALP 6

30.1% (28)

31.1% (29)

23.7% (22)

10 '% (10)

~4. 3%

4

100% (93)

SALP 7

46.O% (23)

14.0% ( 7)

26.0% (13)

B.o%%d ( 4)

~6.N

3

100.0% (50)

Frequency of Issuance:

7.8 LERs/mo.

2 '

LERs/mo.

NOTE:

The above information was derived from review of LERs

performed

by

NRC staff and

may or may not completely coincide with

the unit cause

assignments

which the licensee

would make using

a

proximate

cause

per event,

and they may or may not coincide with the

multi-cause

assignments

discussed

in Section

IV of this

SALP report.

H.

NRR ACTIVITIES

NRR/LICENSEE MEETINGS

Appendix

R Safe

Shutdown,

Bethesda,

MD

Steam Generator

Repair,

Bethesda,

MD

Steam Generator

Tube Leakage,

Bethesda,

MD

NRC -

SQUG Meeting,

Bethesda,

MD

Control

Room Ventilation, Bethesda,

MD

DATE

October

1986

December

12,

1986

March 6,

1987

June

29,

1987

July 24,

1987

38

Individual Plant Evaluation

SIMS Issues,

AEPSC Offices,

Columbus,

Ohio

Modification to Crane Girder,

AEPSC

Offices,

Columbus,

Ohio

Diesel Generator

Fuel Oil Surveillance

Requirements,

Bethesda,

MD

2.

NRR/LICENSEE/REGION MEETINGS

Re-qualification

Exams

Proposed

Procedure

Changes

3.

NRR SITE VISITS/MEETINGS

Technical Specification

Upgrade

Program

Technical Specification

Improvements

Short-and-Intermediate-Term

Goals

Reactor Coolant

Pump Hatches

New Project

Manager Orientation

Meeting,

AEPSC Office, Columbus,

Ohio

Site Visit

4.

COMMISSION MEETINGS

None

5.

COMMISSIONERS SITE VISITS

None

6.

NRR EVENT BRIEFING

None

7.

ACRS MEETINGS

None

8.

EXTENSION GRANTED

None

July 31,

1987

August 21,

1987

October 20,

1987

November

16,

1987

September

9,

1987

November 19,

1987

November 31,

1986

March 23,

1987

July 17,

1987

September

30,

1987

February

10,

1988

February ll, 1988

39

9.

RELIEFS

GRANTED

Inservice Testing

RHR Valves

Inservice Testing

RHR Valves

10.

EXEMPTION GRANTED

December-19,

1986

December ll, 1987

None

11.

LICENSE AMENDMENTS ISSUED

Amendment 99/86,

Reactor Trip System

Instrumentation

Amendment 100/ -, Surveillance

Extension

Amendment

101/87,

Footnote

Change

on

Crane Travel

Amendment 102/88, Deletion of Maximum

Fuel

Rod Weight

Amendment

103/89,

Crevice Flushing of

Steam Generator

Amendment - /90, Allow One-time

Substitution of Row 8 For

Row 9

Ice Basket Weights

Amendment

104/91, Editorial Changes

to

Snubber

Requirements

Amendment 105/ -, Limit Hourly

Verification of quadrant

Power Tilt

Ratio to the First Twelve Hours

Amendment

106/92,

Add Reactor

Vessel

Instrumentation

System

and Core Exit

Thermocouples

to the Post Accident

Monitoring Instrumentation

Amendment

107/ -, Surveillance

Extension

for Cycle

9

Amendment 108/ -, Surveillance

Extension

for Ice Condenser

Amendment

109/ -, Burnup Extension for

Cycle

9 Core

Amendment 110/93, Allow Ice Condenser

Lower Inlet Door Surveillance

to be

Done in Modes

3 and

4

Amendment ill/94, Revise

Boron

Concentration for Refueling in the

RWST

and Accumulators,

Increase

Water Volumes

in the

RWST, Increase

the

RWST Temperature

and

Change Moderator Temperature

Coefficient

Amendment 112/95,

Add Requirements

for

Containment

Sump Level Instrumentation

December

10,

1986

December

20,

1987

February

28,

1987

March 27,

1987

April 1,

1987

April 3,

1987

April 7,

1987

April 7,

1987

Apl il 10,

1987

April 17, l987

May 8,

1987

May 19,

1987

May 29,

1987

Qune

10,

1987

December

10,

1987

40

December

17,

1987

December

18,

1987

Amendment 113/96,

Delete

Footnote which

Required that Main Hoist of Crane

be

De-energized

Whenever the

Load is Moved

over the Pool

Amendment -/97, Surveillance

Extensions

Amendment

114/98,

License

Changes - Name

Changes

from Indiana

and Michigan Power Co.

to Indiana Michigan Power Co.,

January

13,

1988

Amendment -/99, Surveillance

Extensions

February

29,

1987

12.

EMERGENCY TECHNICAL SPECIFICATION ISSUED

Allows one-time substitution of

row 8 for

9 ice basket weights

Surveillance

Exten s i on s

13.

ORDERS

ISSUED

None

April 3,

198?

February

29,

1988