ML18033B399
| ML18033B399 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/14/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B398 | List: |
| References | |
| 50-259-90-07, 50-259-90-7, 50-260-90-07, 50-260-90-7, 50-296-90-07, 50-296-90-7, NUDOCS 9006210558 | |
| Download: ML18033B399 (53) | |
See also: IR 05000259/1990007
Text
ENCLOSURE
INITIALSALP
REPORT
U. S.
NUCLEAR REGULATORY C001ISSION
OFFICE
OF NUCLEAR REACTOR REGULATION
SYSTEhNTIC ASSESSMENT
OF LICENSEE
PERFORhiANCE
INSPECTION
REPORT
NUMBER
50-259/50-260/50-296
90-07
YALLEY AUTHORITY
BROMNS
FERRY NUCLEAR PLANT
JANUARY 3,
1989 - l4ARCH 31,
1990
TABLE OF CONTENTS
Page
I.
INTRODUCTION .....................................................
1
II.
SUMMARY OF RESULTS ..............................................
2
I
. 'ITERIA .............".""""....".".""'".""....."... 3
III
'CR
IV.
PERFORMANCE ANALYSIS ................,...'.."...............
~....
4
A.
Shutdown Operations .......................
B.
Radiological Controls .....................
C.
Maintenance/Surveillance .........,........
D.
Emergency
Preparedness ....................
E
Security ...........,......................
f.
Engineering/Technical
Support .......;...,.
G.
Safety Assessment/guality
Verification ....
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9
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19
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21J
V.
SUPPORTING
DATA AHG SUMMARIES
~ -" ~ ~ . ~ ~.... ~ .. ~""~" ~ ~ ~ "~~....
31
A.
8.
-C.
D.
Licensee Activities .............;.........
Direct Inspection
and Review Activities ...
Enforcement Activity.......................
Review of Licensee
Event Reports ..........
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INTRODUCTION
The Systematic
Assessment
of Licensee
Performance
(SALP) program is
ar,
integrated
Nuclear
Regulatory
Commission
(NRC) staff effort to collect
available
observations
and
data
on
a periodic basis
and to evaluate
licensee
performance
on the basis of this information.
The program is
supplemental
to normal regulatory processes
used to ensure
compliance with
YRC rules
and regulations.
It is intended to be sufficiently diagnostic
to provide
a rational basis for allocation of NRC resources
and to provide
meaningful
feedback
to the
licensee's
management
regarding
the
NRC's
assessment
of their facility's performance
in each functional area.
, An
NRC
SALP Board,
composed of the staff members
listed below, met
on
May 15,
and
June
12,
1990,
to review the observations
and
data
on
perforttiance,
and
to assess
licensee
performance
in accordance
with the
guidance
in
NRC
Manual
Chapter
"Systematic
Assessment
of
Licenset:
Performance."
The
guidance
and
evaluation
criteria
are
suomarized
in Section III of this report.
The Board's
findings
and
recommendations
were
forwarded
to the Director, Division of Reactor
Projects III, IV,
V and
Special
Projects, Office of Nuclear
Reactor
Regulat)on
(NRR), for approval
and issuance.
This report is the
NRC's assessment
of the licensee's
safety
performance
at the Tennessee
Valley Authority's
(TVA) Browns Ferry facility for the
period
January
3,
1989
through
March 31, 1990.
The facility has
been
shutdown for
a
period of five years,
and
the
SALP process
has
been
suspended.
Because
the last full SALP would not be an accurate
basis
upon
which to
base
performance
trends,
the first six months of this period
were used
as the basis period.
The
SALP Board was
composed of:
B. D. Liaw, Deputy Director, Division of Reactor Inspection ard Safeguards
(SALP Board Chairman)
S.
C. Black, Deputy Director, Project Directorate I1-4, Division of Reactor
.Projects I/II, NRR
D. R. Carpenter,
NPC Site Manager,
TVA Projects,
Region II
D. M. Collins, Chief, Emergency
Preparedness
and Radiological Protection
Branch,
Region II
G. E. Gears',
Senior Project Manager,
License
Renewal Project Directorate,
G. T. Hubbard, Section Chief, Plant Systems
Branch, Division of System
Technology,
PE.
E. Merschoff, Acting Director, Division of Reactor Safety,
Region II
B. A. Milson, Chief, TVA Projects,
Region II
1
Attendees at SALP Board Meeting:
PR. H. Bernhard, Project Engineer,
TVAPD, NRR
8M. M. Branch, Senior Resident Inspector,
Matts Bar
8J. J. Blake, Chief, Materials Processes
Section
(MPS), Region II
~
II .
0
- D. M. Crutchfie'id, Director, Division of Reactor Projects - III,'V
and
V and Special Projects,
$ E. H. Girard, Reactor Inspector,
MPS, Region II
W. S. Little, Chief,
TVA Section
B, TVAPD,
O'.
R. Marston, Radiation Specialist,
Region II.
8E. J. McAlpine, Chief, Radiation Safety Projects,
Region II
8C. A. Patterson,
Restart Coordinator,
Browns Ferry,
TVAPD, Region II
PC.
D. Perny, Acting Chief, Security Section,
Region II
kR. C. Pierson, Assistant Director for Technical
Programs,
TVAPD, NRR
8W. H. Rankin, Chief; Emergency
Preparedness
Section,
Region II
fT. M. Ross, Project Manager,
TVAPD, NRR
8*T. S. Rotella, Reactor
Systems
Engineer,
TVAPD, NRR
W. E. Scott, Senior Operations
Engineer,
Performance
and guality
Evaluation Branch,
PR. B. Shortridge,
Radiation Specialist,
Region II
fE. 0. Testa,
Senior Radiation Specialist,
Region II
"* Not Present
May 15,
1990
- Attended via Telecon
May 15,
1990
PHot present
June 11, 1990
SUMMARY OF RESULTS
Cyc> 8 of the
Browns Ferry
SALP started
January 3,
1989
and
ended
March 31,
1990.
The period was divided into two parts for the purposes
of
this SALP:
a Base Period from January 3, 1989 until June 30, 1989,
arid an
Assessment
Period from July 1,
1989 through March 31,
1990.
Due to the
length of time the
SALP process
was
suspended
for Browns Ferry, this
divisicn allowed the facility to be rated against
a more recent perfor-
mance period.
The Base Period
was not rated.
The functional
area
of shutdown
operations
showed
improvement
over the
performance
in the
Base Period.
Unsatisfactory
performance
during opera-
tor requalification
exams early in the Assessment
Period
was corrected
by
increased
attention
tc
training.
Simulator
performance
during
inspections,
exercises,
and the requalificaticn
exams
given later in the
period
were satisfactory.
Weaknesses
were noted
in the
response
to
coni.rol
room
instrumentation
during
normal
shift
operations
and
compensatory fire protection measures.
Radiological
Controls
showed
strengths
in the training
program,
the
acquisition of
new
equipment,
and
the effectiveness
of programs for
conducting
day-to-day operations
at the plant.
Browns Ferry decided to
install
the
permanent
Post Accident
Sample
System
in advance of their
coamitment
dat<<.
Performance
measures
in this assessment
area
were
a
continuing strength.
Maintenance
performance
improvved during the Assessment
Period.
A Main-
tenance
Team Inspection
found the
program to be satisfactory,
and noted
many strengths.
During both periods,
modifications
was found tc be
an
0
e
area of weakness.
A lack of procedural
compliance
and poor work practices
were found,
and
problems
were noted in the area of surveillance activi-
ties.
An assessment. of the effectiveness
of the corrective actions taken
in response
to escalated
enforcement in this area
has not yet been
made.
Browns
Ferry's
performance
during
a full scale
emergency
exercise
demonstrated
strengths
in the
area
of Emergency
Preparedness.
continues to show improvements
in this area.
Major security upgrades
continue at the facility.
Long term compensatory
measures
remain
in place until upgrades
are
completed.
Problems
were
identified
in the
control
of Special
Nuclear Material
inventories.
Strengths
were
noted
in the
use of quality audits,
in the trending of
events
and their corrective action implementation,
and in the quality of
NRC submittals.
The quality of programs
in the Engineering
and Technical
Support areas
has
improved.
Inspections
found adequate
control of the engineering
process
ard gled enqineer ing reviews.
Timeliness of followup on identifiea issues
coula be improved.
The System Engineering
Program was
a strength.
- The Safety
Assessment
and guality Verification area
had
weaknesses
in
timeliness
and thoroughness
of submittals
and responses.
The quality of
the products
improved during the assessment
period.
Management's
use of
internal audits
and reviews for, feedback
on the quality of plant programs
is
a strength.
The
SALP Board Ratings in each functional area are:
Functional Area
Patino This Period
7 I 89.-.3 31/90
Shutdown Operations
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technica'l
Support
Safety Assessment/guality
Verification
III. CRITERIA
2
1
3, Improving
2, Improving
2
2
3, Improving
Licensee
performance
is assessed
in the functional
areas
shown
above.
Functional
areas
normally represent
areas
significant to nuclear safety
and the environment.
Special
areas
may be added to highlight significant
observations.
The evaluation crit~ria which were used,
as applicable,
to assess
each
functional
area
are described
in detail in
NRC Manual Chapter
This chapter
is in the Public
Document
Poom files.
Therefore,
these
criteria are
not repeated
here,
but will be presented
in detail at the
public meeting to be held with licensee
manage>rene
to discuss
the
results.
, However,
the
NRC is not limited to these criteria
and others
may
have
been
used,
where appropriate.
On the basis
of the
NRC assessment,
each functional
area
evaluated
is
rated according to three performance
categories.
The definitions of these
performance
categories
are
shown below:
Category 1.
Licensee
management
attention
and
involvement
are
readily evident and place emphasis
on superior performance of nuclear
safety
or
safeguards
activities, with the resulting
performance
substantially
exceeding
regulatory requirements.
Licensee
resources
are
ample
and effectively used
so that
a high level of plant
and
personnel
performance
is being achieved.
Reduced
NRC attention
may
be appropriate.
B.
Category 2.
Licensee
manaoement
attention to and involvement in the
performance of nuclear safety or safeguards
activities are good.
The
licensee
has attained
a level of performance
above that
needed
to
meet regulatory
requirements.
Licensee
resources
are
adequate
and
reasonably
allocated
so that
good plant and personnel
performance
is
being achieved.
NRC attention
may be maintained at normal levels.
C.
Category 3.
Licensee
management
aatention
to and involvement in the
performance
of nuclear
safety
or safeguards
activities
are
not
sufficient.
The licensee's
performance
does not significantly exceed
that
needed
to
meet
minimal regulatory
requirements.
Licensee
resources
appear
to
be
strained
cr not effectively used.
NRC
attention
should be increased
above normal levels.
The
SALP Board
may also include
an appraisal
of the performance
trend of a
functional
area.
This rating modifier will only be
used
when both
a
definite trend of performance
throughout the rating period is present,
and
4he Board believes that continuation of the trend
may result in the
change
of the performance level.
The trend modifier, if used, is defined as:
Irproving:
Licensee
performance
was
determined
to
be
improving
during the assessment
period.
Declining:
Licensee
performance
was
determined
to be declining
during
the
assessment
period
and
the
licensee
had
not taken
meaningful steps to address
this pattern.
IV.
PERFORMANCE
ANALYSIS
A.
Shutdown Operations
1.
Base Period Analysis:
This functional
area
addresses
the
control
and
performance
of
operations
activities related to units in an extended
outage,
and
0
fire protection.
The assessment
was based
on routine inspections,
a
special
reactive
core monitoring inspection,
and
an instrumentation
team inspection.
The
SALP period
began with Unit 2 fuel loading.
This was the first
major operations activity since
the 'unit was
shutdown in September
1984.
Significant weaknesses
were
noted
during the fuel loading
operatfor s with
10
CFR Part 50.59 reviews,
review and approval of
procedures,
and technical specifications
(TSs).
A special
reactive
inspection
was conducted to determine
the conditions that led to the
loading of
74 fuel
bundles
without adequate
indication of core
neutron flux levels.
The inspection
indicated that the licensee
accepted
without question
those
provisions
of TSs which did not
preclude
unmonitored
core
alterations.
Mhen
the
problem
was
initially identified,
the licensee's
assessment
and actions
were
nonconservative,
and incomplete.
Once the full significance of the
issues
of'nmonitored
core loading were acknowledged,
the corrective
actiors
taken
by the
1i.censee
were
conservative
and acceptable.
Corrective actions
included
a review of TSs and the
TS interpretation
documents'o
ensure
they were not in conflict with the plant design
basis.
kith the exception of fuel load, few'perational activities occurred.
The plant
was
shutdown,
with the operators
in
a monitoring
mode.
Operational activities that did occur were the placing of systems
in
- arid out of service to support
system modifications.
In'general,
control
room day-to-day operations
were satisfactory.
Ho
specific problems
were identified with the shift logs, night order
bcoks,
clearance
hold order books, configuration logs,
and Temporary
Alteration Change
Form
(TACF) files.
Proper control
room staffing
was maintained
and shift turnover meetings
were formally conducted.
Control
room drawings
were found to be clear
and legible, although
a
significant backlog of drawings requiring updating existed.
Several
events
occurred
which indicate irconsistencies
in Operations
response.
In one event, Operations
demonstrated
a lack of aggressive
response
to control
room indications of plant status.
An incident
occurred
on February
10,
1989 that resulted
in 200,000
gallons of
potentially contaminated
water being lost from a condensate
storage
tank.
Operators
failed to respond to a decrease
in the tank level
indication until the next shift.
V
Several
instances
occurred
where the compensatory
measures
taken for.
fire protection did not meet TS.
The corrective action taken
was to
train Fire Protection personnel
on the TS requirements,
but personnel
in the Shift Operations
Sup~rvisor
(SOS) position did not receive
this additional training.
In each
of these
events,
the
SOS
had
reviewed
and approved. the incorrect compensatory
measures.
This lack
of recognition of the SOS'ole
in these
events
was considered
a-
0
weakness
in root
cause
determination,
and
SOS
training
and
performance.
The licensee initiated
a
number of steps
to upgrade the control room
. and operator
work stations.
These included
an elevated
work station
for the Shift Operations
Supervisor,
quiet floor coverings,
labeling
of annunciators,
and improved operator aids.
In the
area
of fire protection,
an experienced
professional fire
brigade
was maintained on-site.
This exceeded
'NRC requirements
and
was
a strength of the fire protection program.
Operator training in
regard to the post-fire safe
shutdown instructions
was only fair.
Some operators
did not understand
the procedural
requirements.
TYA's
Fire
School
is
accredited
by
the
National
Fire
Protection
Association's
Professional
gualffications Board.
Two violations were identified in the base period;
Assessment
Period Analysis:
The
assessment
period analysis
was
based
on routine inspection,
operator
examinations,
and
a
special fire protection
inspection.
Operational
activities
consisted
of placing
systems
in and out of
service for Divisional Outages
(until the
core
was unloaded),
and
defueling the reactor;
During
the
weeks
of July 10-21,
1989,
the
NRC
conducted
requalification examinations for 24 operators
licensed to operate
the
Browns Ferry Nuclear Plant (BFNP).
Of the 12 reactor operators
(ROs)
and
12 senior
reactor
operators
(SROs) tested,
eight
and
seven
SRGs
passed
the examination for an overall
pass
rate of 63%.
In
accordance
with
the criteria
outlined
in
Section
of
Examiner
Standards,
the
NRC's
programmatic
evaluation
determined
the
BFN Requalification
Program
was unsatisfactory
.
Positive
management
attention
was
noted in solving training needs.
The active role
by management
in upgrading training provided
an
enhanced
program to support
safe plant operations.
The adequacy
of
these efforts
was
demonstrated
by the
100% pass
rate for all those
taking
the requalification
and initial examinations
the
weeks
of
January
22 and February 6, 1990.
Successful
usage
of the
emergency
operating
instructions
was
demonstrated
during
operator
examinations,
a
training
program
inspection,
and the annual
emergency
preparedness
exercise.
Control
of licensed
operator
status
was
found to
be
good
and
personnel
qualifications were reviewed at shift turnover.
The Unit 2 core
was defueled
during the
assessment
period.
This
operation
was performed in a methodical
and conservative
manner.
The
licensee
used
dunking
chambers
to monitor the
neutron
count rate
during defueling.
Only
one
minor problem occurred
resu1ting
in
slightly bending
the refueling
boom.
This occurred while moving the
empty boom back to the'vessel.
Management
immediately took action to
evaluate
and determine
the root cause,
and to take prompt corrective
action.
Overall the defueling
was well done.
Changes
were
made to strengthen
the Operations
organization.
An
Operations
t<anager
position over the Operations
Superintendent
was
created.
The Operations
Nanager
and three assistants
were hired to
bring in new management
perspectives.
These assistants
were assigned
to
upgrade
operator
training,
upgrade
procedures,
and
improve
nor -licensed
operator
performance.
To reduce
the administrative
burden
on the Shift Operations
Supervisor,
a Shift Support Supervisor
was created.
This
change
resulted
in increased
involvement of the
SOS
in operational activities.
Staffing could support operation of
one unit with a six crew rotation.
The ability of the
new operations
organization to function
as
a
team at an operating plant has not yet
been demonstrated.
The
Operations
organization
continues
to
have
problems
with
performing timely and
adequate
actions
in response
to control
room
alarms
associated
with off-normal conditions.
A second violation in
less
than
a year
associated
with loss of large quantities
of
potent>ally
contaminated
reactor
grade
water
occurred.
This
violation involved the overflow of water from the spent fuel storage
pool into the ventilation
system
and
onto
areas
of the reactor
building.
If the initial control
room alarm
had
been
adequately
. pursued
in accordance
with the Alarm Response
Procedure,
the event
would have been avoided.
An unplanned
engineered
safety feature
actuation
occurred
during
a
routine
power supply transfer
because
the operator
did not follow
procedures
to verify an alternate
power supply available prior to the
transfer.
A circuit breaker
was found out of position but this was
noi indicated
by the
configuration
control
records.
Previous
corrective actions for sim'ilar events
were ineffective.
The licensee's
program to provide incident investigations
when
an
error or plant event
occurs
has
been
strengthened.
These
reviews
included identification of the root cause
and corrective actions.
The investigation
reports
were self-critical with good corrective
actions.
The corrective actions
were found to be formally tracked
and
completed.
These rigorous self evaluations
and
good corrective
actions
are
a strength
of the
licensee
programs.
The licensee
initiated
a
scram reduction
program which included
a review of all
past
between
1978
and the
shutdowns
in 1985.
One
hundred
twenty-two scram reouction
recommendations
were made in the,.review.
Although plant
housekeeping
is generally
gocd,
housekeeping
and
identification of material deficiencies
in less frequently traveled
areas
of the plant
was poor.
Examples
which were corrected after.
being .identified by inspectors
were the Residual
Heat
Removal Service
.Water
(RHRSW) cable tray tunnel
and
Standby
Gas
Treatment
System
rooms.
Control room improvements
completed included extensive relabeling
and
work station upgrades
to enhance
control
room operations.
Relabeling
was especially
noteworthy.
The annunciator
windows are clear
and
easy to read.
New operator aids are in place.
Red and green colored
carpeting
has
been
placed
throughout the control
rooms to designate
restricted
access
areas.
During the assessment
period
a procedures
review and upgrade
program
was initiated to correct problems in operating
and abnormal operating
instructions.
A number of changes
were
made to clarify TS in
ar.
effort to avoid misinterpretation or liberal interpretation of TS.
A
violation was identified for not correctly updating controlled copies
of TS used
in plant operations.
Continuing
problems
were
noted with compensatory fire protection
measures.
A
TS violation was identified involving two fire door's
found open wiihout compensatory
measure's
being taken.
This item was
significant in that the two doors were on
a frequently traveled
path
to the
control
room
arid plant
personnel
did not question
this
conaition.
Another
TS violation occurred
when fire hose
stations
were
removed
from service
and
compensatory
fire hoses
were not
connected
as required.
In addition, the fire hose stations
in all
three reactor buildings
had
been
removed
from service,
placing the
plant outside of TS requirements.
Although procedures
were in place
that
established
a
system
to
control
compensatory
measures,
management
control
of the
system
was
ineffective.
Operations
personnel
were not knowledgeable
of the fire protection
compensatory
, measures
in place.
As
a result of these
events,
the responsibility
for fire protection
was integrated
into Operations
arid the on-duty
fire brigade
now reports directly to the SOS.
An inspection of the licensee's fire protectior program was performed
late .in the
assessment
period.
The inspection
did not note
any
weaknesses
in the areas
of fire protection control
and surveillance
procedures,
surveillance
inspection
and test results, fire brigade
tra'ining
and staffing, guality Assurance
(gA) audits, fire fighting
equipment,
arid fire, protection systems.
In addition, the performance
of the fire brigade
was
observed
during
an
unannounced drill ard
found to be acceptable.
Five violations were identified during the assessment
period.
Assessment
Period Performance
Rating.
Category:
2
Recommendations:
The
Board
recommends
that the
high level of management
attention
continue to,ensure
a safe
and essentially trouble free startup,
power
ascension
and operation of Unit 2.
A more aggressive
involvement and
sense
of ownership
by the operations staff could have prevented
some
of the problems in other areas
such
as post-maintenance/modification
'esting.
The effort to minimize personnel
error must continue to
receive increased
management
attention.
Radiological Controls
Base Period'Analysis
No inspections
were performed
fn the
base
period iri tie area of the
radiation
protection
program.
One
chemistry
and
radiological
effluent inspection
was conducted.
The
inspection
noted
an
aggressive
program
was
in place for
maintenance
of water quality.
An audit
had
been
conducted
in
effluert monitoring
by the
corporate
gA organization.
Plant
gA
conducted
quality surveillances
in the chemistry
and radiological
effluent areas.
Staffing was
51 persons of an allocation of 52.
New
equipment
had
been
installed
in
the
chemistry, laboratory
arid
additional
upgrades
were planned.
Mater chemistry
was maintained
under close control
and reviewed
by
management.
Administrative limits and action levels
were
changed
procedurally to bring the plant levels in line with the
new Electric
Power
Research
Institute
(EPRI) guidelines.
The Chemistry Notice
System
was
implemented to assure
an appropriate
level of management
would
be notified whenever
chemistry
samples
exhibited
deviant
trends,
equipment
was
out of service,
and
samples
indicated
unsatisfactory results.
I
During the
base
period,
plans
were to startup
the plant with an
Interim Post Accident Sample
System
(PASS) in=place.
There were no
violations or deviations in this area in the base period.
Assessment
Period Analysis
One
radiation
protection
inspection
was
performed
during
the
appraisal
period.
Key management
changes
were implemented
by the licensee during'his
assessment
period.
The health
physics
technical
supervisor
was
promoted
to Radiation
Protection
t':anager
when
the position
was
vacated.
The Radiation Protection
(RP)
group
was reorganized
into
four functionial groups with managers
over each
group.
The
RP group
0
10
had
been
downsized
from approximately
225 to 180 people.
During the
downsizing
and reorganization,
the level of RP program effectiveness
was
maintained.
All health
physics
(HP) contractor
support
was
terminated
early in the
assessment
period.
Improvements
in
program
support
were
evidenced
by the active
involvement of the
Senior Vice President
of Nuclear
Power.
Senior management's
direct
review and
comment
on key elements
of the
RP program have also
had
a
positive effect
on morale.
The solid
radwaste
group,
which
had
previously been
a part of Operations,
was
moved under the
RP group to
better
enhance
radiological controls.
Overall, radiation protection
management
consisted of a staff with strong technical
backgrounds
and
good power plant experience.
Collective annual site person-rem
was
1181 for 1987,
1155 for 1988,
and
656 for 1989, resulting in
a three year
average
of 997.
The
three year person-rem
average
was
good because
the licensee
was in
extended
outage with extensive modification throughout the assessment
period.
The reduction in collective dose
between
1988
and
1989 was
attributed to effective use of shielding
packages
and to the shift of
environmental qualification work from high cose
areas
in the plant to
lower dose
areas.,Through
the
end of March 1990, collective dose
was
216 p~rson-rem,
indicating
a downward trend.
Personnel
contamination
events
(PCEs), were
241 for 1987,
468 for
1988,
and
147 for 1989.
The large rise in 1988
was attributed to
contaminations
on
shoes
in the clean
areas
of the Radiation Control
Area (RCA).
The significant reduction of PCEs
nosed in 1989
was
a
result
of increased
mopping
of
RCA clean
areas,
placing solid
barriers
around
contaminated
areas,
and the overall reduction of
plant
contaminated
area.
Radiological
controls
utilized during
unexpected
events, for example spills of contaminated
liquids, were
effective in minimizing contaminated
area
and in maintaining the
low
level of PCEs.
Through March 1990 only 10
have
been reported,
indicating
a significant improvement and'ontinuing
downward trend.
Reductions
in contaminated
area
also
showed
an improving trend.
In
1988 approximately
12.2 percent
of the total
RCA (910,485 ft~) was
considered
contaminated.
In 1989 this was reduced to 10.5 percent
followed by a further reduction to 7.4 percent
in March of 1990.
Other licensee initiatives observed
during this appraisal
period were
as follows:
(1) the addition of
12
automated
personnel
friskers
located
throughout the
RCA for better personnel
contamination ident-
ification and control, (2) utilization of recirculation pipe, reactor
vessel
drain line,
and control rod drive seismic support
mockups for
job t,raining and dose reduction,
and (3) the addition of 3 As-Low-As-
Reasonably-Achievable
(ALARA) program engineers
ard the requiring of
an
ALARA review for jobs that
could result
in
a
one
person-rem
exposure.
Continuing training for
HP technicians
was increased
from 20 to 90
hours
annually.
Also,
a
new
5 part
course
was
added for general
0
0
11
employees
in ALARA awareness.
The last
segment of the course
was
a
practical
factors
demonstration
of the students'erformance
on
a
'functioning plant systems
mockup.
The mockup
was representative
of
in-plant valves, filters,
and
a demineralizer.
The licensee's
training
program 'was
considered
effective
fn preparing
licensee
personnel
for in-plant radiological operations.
Continued
management
support for the
chemistry
ard radiological
effluents
programs
was demonstrated
by adequate staff levels for the
chemistry
department
and
by the
upgrade
of laboratory,
count room,
and effluent monitoring equipment.
Support
was also demonstrated
by
the decision to install the
permanent
system prior to Unit 2
startup,
instead of the interim unit originally planned.
Liquid and gaseous
effluents
and corresponding
dcses
showed
a slight
decline
from previous, periods.
The
Radiological
Envfronmental
tlonito> fng Program
was
conducted
by an offsite agency
of TYA.
No
unusual results
were noted.
Annual Technical Specification audits
were conducted
by'
corporate
qroup.
More detailed surveillance audits were conducted
by an onsite
Ouality Surveillance
organization.
Audit findings appeared
to be
minor fn nature
and were corrected
fn a timely manner.
The licensee's
beta isotope
program was evaluated
through comparative
-analysfs
of
NRC provided
samples.
All analyses
were
fn- agreement
wfth
NRC r esults.
3.
No violations or deviations
were identified fn the Radiological
Controls area.
Assessment
Period Performance
Rating
Category:
1
C.
tiaintenance
ard Surveillance
Base Period Analysis:
The
conduct
of
plant
maintenance
and
the
installation
of
modifications
were
reviewed
on
a routine
basis
during the
base
period.
In additior, special
inspections
were conducted
fn the areas
of quality verification, desfgn control, arid Appendix R.
Inspection findings and reported
events
indicated
numerous
weaknesses
fn the
Browns
Ferry maintenance
program
and the installation of
modifications
during the
base
period.
The
weaknesses
included
problems
with fdentffjfng conditions
which adversely
affect the
plant,
work planning
and
scheduling,
material availability, work
impact
evaluations,
procedure
adequacy,
procedur al
adherence,
implementation
of work activities,
operability
requirements
for
12
,safety-related
equipment,
and preventive maintenance activities.
The
lack cf coordination
among responsible
groups
complicated
the work.
Licensee
corrective
actions
taken
during
the 'base
period
were
ineffective,
indicated
a
lack of
management
involvement
and
attention,
and reflected
a reactive approach to problem solving.
Problems
were identified in the
areas
of post-maintenance
and
post-modification testing
(PNT).
Numerous operational
related
events
occurred
due to
PNT deficiencies,
some of these
included engineered
safety features
(ESF) actuations,
TS violations',
and inoperable
and
damaged
equipment.
Oeficiencies
in the
PNT program were attributed
to
a lack of planning, failure to follow instructions
by maintenance
arid modifications
personnel,
and
confusing
and
inadequate
PHT
instructions. 'everal
instances
of improper
cable
terminations
occurred
during the period.
These
improper electrical
connections
were indicative of
a
weakness
in electrical. maintenance
performed
during plant mooiiications.
Proper
PNT would have identified the
improper connections.
Hanagement
was ineffective in identifying the
cause of the events
and preventing
subsequent
similar occurrences;
Licensee
investigations'or
maintenance
and modification related
events
were ri utinely superficial
and were routinely completed after
the
component
or
system
was -returned
to service.
Programmatic
conitrols for dispositioning
PHT deficiencies
dsd not require either
root cause
analysis
os
management
involvement tu resolve
possible
-safety significant issues.
S
TVA conducted
a
maintenance
self-assessr.;ent
in
Viay 1989,
which
concluded that program implementation
problems existed,
A weakness
was
noted in the control of backlogged
maintenance
requests;
There
was
a backlog of approximately
7500 maintenance
requests
of which
4500
items were startup
items.
A backlog of approximately
860 late
p~ eventive maintenance
(PH) requests
existed.
The overall
PH program
was determined to be weak.
The licensee
made
numerous
changes
in the conduct of. maintenance
and
the maintenance
organizaticn during the base period.
The Maintenance
Superintendent
was
replaced
twice
and
Maintenance
Managers
were
reassfgned
to different
areas
of responsibility.
To
complete
maintenance
and modifications in an organized
manner,
the licensee
divided the plant
systems
>nto three divisions to be worked in
divisional
outages.
Each
division
included
associated
instrumentation,
electrical
and mechanical
equipment.
The licensee
conducted
two routine
outage
meetings
daily coinciding with shift.
changes.
The first line supervisors
from the various plant groups
met
to
discuss
the
real-time
progress
of ongoing activities,
schedules
for planned activities,
and overall
schedules
for the
divisional
outages.
These
discussions
provided
a
forum for
interaction
between
the
different
groups
and
enhanced
the
prioritization and
coordination
of work activities
by the various
groups'
13
The .licensee
experienced
numerous
delays
in the
completion
of
scheduled
milestones
during
most
of the
period.
After the
maintenance
changes,
the maintenance
department
exceeded
MR work off
rates
and
by the
end of the period decreased
the overall backlog.
The installation of modifications
remained well behind
schedule
and
with lower than
expected
productivity rates
throughout
the
base
period.
The licensee
encountered
numerous
problems with the procurement
of
materials
and
components for maintenance
and modifications.
These
problems
contributed to the failure to meet schedules
and were the
result of inadequate
assessments
of wor k requirements,
poor planning,
and untimely requests for materials
and components.
The licensee
experienced
several liquid spills during the performance
of maintenance
activities.
These
were attributed
to inadequate
scoping of work and inadequate
equipment clearances.
A
number
of
CAgRs
were, written
on the
lack of 'timeliness
in
conducting
Measurement
and Test
Equipment
(MATE) out-of-tolerance
investigations.
These
CAgRs were to determine if previous
use of
out-of-tolerance
MSTE
was
acceptable
and
evaluate
the potential
impact upon op~rability cf systems
or equipment.
Investigations
were
routinely performed
beyond the TVA's required time period.
The lack
of licensee
management
action
on these
CA(Rs indicated
an inadequate
- sensitivity to potential plant safety problems.
The area
of TS surveillance testing
was reviewed- and observed
on
a
routine
basis
during the
base
period.
In addition,
a
special
inspection
was
conducted
on instrument
adequacy
in January - March,
1989,
which included
reviews of surveillance
testing
in progress.
The findings included
numerous
examples
of inadequate
Surveillance
Instructions (SIs)
and calibration procedures,
failure to follow SIs,
failure to perform SIs within the
TS required frequency,
and failure
to perform SIs
implemented
as
TS compensatory
measures.
Management
failure to resolve
SI problems,
and failure to utilize the procedure
change
process
when procedure
deficiencies
were identified were also
problems.
NRC inspectors
identified that the
licensee failed to
implement fully a
commitment in the Nuclear Performance
Plan
(NPP),
Volume 3,
to review
and
upgrade
SIs.
Insufficient management
attention
had
been directed
toward full implementation of the
cooziitments with regard
to the
SI upgrade
program
and toward the
adeouacy of the review, walkdown, validation and verification of SIs.
This was evidenced
by the numerous deficiencies identified during
NRC
inspections
in the base period.
The
licensee
implemented
significant actions
to address
the
Sl
problerrs
and provided
more detailed
procedures
for SI verification
and validation.
These
actions,
as
evidenced
by the continuing
events,
did not result. in
a decrease
in the SI deficiencies
by the
end of the base period.
0
St
14
Seven violations
and
one deviation
were identified during. the base
period.
Assessment
Period Analysis
The
conduct of plant maintenance
was
reviewed
on
a routine basis
during the, assessment
period.
In addition,
a Naintenance
Team
Inspection
(NTI) was
conducted
fn Oecevber
1989,
through
January
1990.
The HTI findings indicated that both the maintenance
program
and its
implementation
were satisfactory.
The satisfactory rating indicated
adequate
development
and implementation
of the important elements
of
a maintenance
program, with the areas
of weakness
being approximately
offset by strengths
iti other areas.
This was
a qualified rating,
as
Browns Ferry
has not operated
in over five years
and the capability
of maintenarice
to support
plant operation
could not
be directly
assessed.
Because
of the nuoh~r of key areas
not assessed
the NTI
recommended
a
followup maintenance
inspection
after restart
of
Unst 2.
The
new
maintenance
management
personnel
appeared
to work well
together
ard
address
prob1ems
fn a timely manner.
Nanagement
was
very receptive to
NRC findings and focused
increased
attentior. to the
work off rates
and proper
performance
of maintenance.
Hanagement
emphasized
compliance
with procedures
arid completion of assigned
work.
The
m .intenance
organization
made significant progress
in
reducing
the
number of open
Haintenance
Requests
(HR)
and
CAgRs
during
the
assessment
period.
The
decrease
in emergent
work
occurring
on
a aay-to-day basis,
the increased
management
attention
to improving work off rates,
and the
increased
emphasis
placed
on
eliminating late preventive
It'.aintenance
items all contributed to the
. reduction.
A number of management initiatives were
implemented tu increase
the
quality of maintenance.
These
included participation
in Owner's
Groups,
and the
use of performance
indicators
and trending in the
maintenance
process.
Engineering
support for maintenance
was strong
as evidenced
by the
technical
support that
management
provided for maintenance
through
System
Engineering.
The System
Engineering
Program
was noted
as
a
significant strength
during the NTI.
The
NRC staff observed
that
systems
engineers
were fully involved in decisions
associated
with
maintenance,
modification, ard design of their designated
systems.
The maintenance
backlog
appeared
to be excessive.
Ouring the HTI,
there
were
2300
open
NRs
on Unit 2,
and
a total of 4500 open
HRs on
all three units.
The
cause
of the large
number of open
NRs
was
attributed to inadequate
coordination of the work control process,
0
outlays
caused
by
the unavailability of
spare
parts,
drawing
discrepancies,
and plant modifications which had not been
completed.
The
maintenance
facilities
were
rated
as
more
than
adequate.
Maintenance
shops
were well organized
and contained
good equipment.
The control of issuance
of calibrated
tools
was
good.
The
N&TE
controls for .-calibrated
tools
were
very
accurate
and
the
lab
facilities for tool calibration were found to be good.
Inspection
findings
and
events
reports
indicated
that
problems
occurred early in the assessment
period which were the result of poor
work practices,
inattention to detail during the performance of work,
and failure to follow procedures.
Increased
management
attention
was
given to these
problems
and corrective
actions
were
implemented,
including personnel
disciplinary actions,
and increased
attention to
maintenance
by the general
foremen.
Many of the maintenance
problems
were
resolved
as
evidenced
by the
lack of reported
events
aria
work-related violations throughout
the
remainder of the
assessment-
period.
Maintenance
personne1
errors
decreased
sigrificantly from
the base period
and the early part of the assessment
period.
The
MTI identified that the maintenance
data
base
had insufficient
trending capability aria limited equipment operating history.
The NTI
noted unattended,
partly disassembled
.equipment
which
had not been
tagged
to identify in-process
work.
Tagging
practices
weri:
identified as
a weakness'during
the NTI.
Staffirg levels in the maintenance
organization
were above average at
the time of the inspection,
but were
reduceo after the NTI.
The
effect of the reduced staffing has not been
assessed.
A weakness
was
identified with the communication
between
upper management
and lower
levels of maintenance
management
and craft personnel
in that the
existing
communication
did not appear
to be effective in improving
the conduct of maintenance.
There also
appeared
to be
inadequate
coordination of maintenance
work between
the individual maintenance
craft
groups,
and
other
organizations
such
as
Operations,
Modifications, and Planning
and Scheduling.
The guality Control (gC)
.
staff
was satisfactorily organized,
staffed,
and trained to support
the plant's maintenance activities.
The maintenance
training program
was found to be generally strong.
The
licensee
has
implemented
a
good
technical
training
and
qualification program for craft personnel.
Training is provided
on a
rotating shift basis
and
most of the craft personnel
had
completed
upgraded training.
The majority of the craft had more than ten years
of work experience;
The
NTI noted,
however,
that electrical
maintenance
personnel
required to perform SIs
had not received training in SI performance,
Instrumentation
and
Controls
( ISC) maintenance
perso>nel
received
0
0
16
little or no refresher training,
and that few onsfte
mockups for 15G
training existed.
The
implementation of modifications
was
reviewed
by the resfdert
inspection
staff
on
a
routine
basis,
by
inspections
on
the
installation of modificatiors related to Inspection
and Enforcement
Bulletins
(IEB) 79-02
and 79-14,
and
by
a Safety
System gualfty
Evaluation
(SSQE)
team inspectiorI.
. Inspection
findfngs
and
operational
events
indicated
that
the
licensee's
performance
in modifications
was
poor near the end of the
assessment
period.
Violatfons were
issued for several
examples of
the'ailure to follow the procedures
and devfatfori from the drawings
during pipe support
and other hardware installations.
The violations
were attributed to inattention to detail,'oor work practices,
and
the failure of personnel
to follow instructions.
The
SS(E
identiffed
cases
of failure to follow the
General
Construction
Specifications,
drawings
and
instructions
fn
the
installation of modifications.
Browns Ferry identified cases
of work
performed
not ir, accordance
with procedures
and of violating
gC
holdpoints
in
two
non-cited
violations.
These
are
further
indications of poor work practices.
The licensee
has consistently failed to meet scheduled
milestones for
- the
completion
of. modifications.
Vodfffcatfons work rates
in the
plant increased
by the
end of the assessment
period due to increased
management
attention
and to review of work in the field.
The area of TS surveillance testing
was reviewed
and observea
through
inspections
ard during
a special
inspection
conducted
fn September
through
October
1989.
Inspection
findings
and
reported
events
sndicated
problems. with inadequate
test procedures,
failure to meet
surveillance
test
intervals,
failure to
implement
and
mafntafn
compensatory
measures
required
by TS,
and the failure to follow
procedures.
The problems also included lack of communication
between
operations,
surveillance,
maintenance,
and engineering
staffs.
In
addition,
the violations identified were similar to violations that
occurred
over the past
two years.
The deficiencies
indicated that
sufficient management
attention
was lacking and dfd not correct the
identified problems or adequately
implement the improved surveillance
test
program that has
been
developed
since
1986.
Escalated
enforcement
action
was
taken
fn this area.
A severity
level III violation was
issued for a programmatic
breakdown of the
surveillance
testing program.'he
escalated
enforcement
included
violations occurring in August and September
1989, which were similar
to violations issued
fn the two prior years.
Since
the. enforcement
conference
was
held
on
the
escalated
enforcement
action,
licensee
management
has
taken
steps
to improve
17
3.
personnel
accountability
arid adherence
te the surveillance
testing
program
requirements.
This
increased
managem'ant
attention
and
enhanced
personnel
performance
have resulted
in the absence
of new
events.
The
removal of fuel from the
core in January
1990,
the
subsequent
relaxation of TS requirements,
and the less restrictive
TS
amenidments
issued
for
secondary
containment
ard
the
Standby
Gas
Treatment
System,
have
reduced
the plant activity fn this area to a
minimum.
Because
of these
factors,
an
adequate
analysis
of the
improvement of the surveillance
program could not be made at the end
of the assessment
period.
Seven violations
were
issued
in the maintenance/surveillance
area
during the assessment
period.
Assessment
Period Performance
Rating:
Category:
3
Trend:
Improving
Recomendatiuns:
D.
The
Board
recommends
continued
management
attention
in the
area of
surveillance testing, to assure
that the corrective actions
taken
as
a
result
of the
escalated
enforcement
action
are
effective.
Implementation
of modifications is
a
weakness
in this functional
area,
and
emphasis
on
problem resolution
fn this
area
should
continue.
The
maintenance
area
generally
showed
significant
improvement but management
attention
should continue particularly in
those
areas
not assessed
by the
NRC Maintenance
Team Inispection.
Emergency
Preparedness
Base Period Analysis
This functional area
includes evaluation of activities related to the
implementation
of the
Emergency
Plan'and
procedures;
support
and
training of onsite
and offsite emergency
response
organizations,
and
licensee
performance
during
emergency
exercises
arid actual
events.
Performance
is also evaluated
in the areas
of event notifications,
recovery actions, protective actions,
and interactions
between
onsste
and offsite
emergency
response
organizations
during exercise
and
actual events.
During the base period one routine inspection
and one
remedial exercise evaluation were performed.
The
licensee's
emergency
preparedness
(EP)
program
continued
to
improve during the
base
period despite
the loss of two engineering
aiae positions
on the
EP staff.
The licensee's
Prompt Notification
System
was
enhanced
by the addition of 45 sirens to provide fixed-
coverage
in the 5-to-10
>pile radius
formerly covered
via
mobile-siren routes.
18
, The
emergency
preparedness
program received
management
support to
upgrade
the basic
emergency
elements
needed
to identify promptly,
correctly classify,
adequately
staff,
and to
implement
the
key
elements
of the Radiological
Emergency
Plan
(REP)
and respective
procedures
in response
to emergency
events.
The corporate
EP staff
has continued to show strong support
by providing necessary
resources
in the areas
of scenario
development for exercises
and revisions to
the Emergency
Plan and Implementing Procedures.
'mergency
response facilities,
equipment
and supplies
were properly
maintained
and
the training of emergency
response
personnel
was
effective.
However,
the
large
number of make-up
sessions
for
emergency
response
training
had the potential of reducing
EP staff
time available for undertaking
program initiatives.
Two
and
Emergency
Plan
Implementing
Procedures
(EPIPs)
changes
were approved
by licensee
management
and transmitted to the
NRC in a
timely
manner.
The
1 icen see '
yearly
internal
audit
was
comprehensive
ard included
an evaluation of the offsite interfaces.
There were five emergency
declarations
during the base period, all of
which were Notification of Unusual
Events.
Four of the five were
weather
related
(tornado
warning).
The other
involved loss of
qualified offsite
power.
All were
determined
to
be correctly
classified in a timely manner with appropriate offsite notifications
completed.
The l,icensee's
performance
during
a remedial exercise,
conducted
on
Hay 31,
1989,
was considered fully successful
and demonstrated
that
the licensee
could effec4ively implement the Raaiological
Emergency
Plan
and
procedures.
In general,
the
licensee
demonstrated
the
ability to identify off-normal conditions,
classify
events
in the
appropriate
emergency
category,
notify
appropriate
offsite
authorities,
ard
make appropriate
protective action recommendations.
The scenario
development
team did not have
a clear understanding
of
the Site
Area
Emergency
Action Level event
used
in the exercise;
'however,
the Site
Emergency
Director,
based
on his
judgement,
overcame
the
scenario difficulty and
made
a correct
and
prompt
classification.
The exercise
critique was effective
and detailed.
There were no exercise
weaknesses
identified.
2.
Assessment
Period Analysis
No inspections
were
conducted
in this area
during the
assessment
period.
However",
a full-scale exercise
was observed.
The licensee's
performance
during the exercise,
conducted
on November I and 2, 1989,
was
considered fully successful
and
demonstrated
that the licensee
coula effectively
implement
the
Emergency
Plan
and
implemer ting
procedures.
The exercise
included'n evaluation of the licensee's
ability to perform
assessments
cf plant status
and radiological
hazarCs,
and
make proper notifications to offsite authorities.
The
Emergency
Response
Facilities
were staffed in
a timely manner
and
were
adequate
to support
the response.
No equipment
or facility
related deficiencies
were found.
The
NRC participated
in the exercise,
including
a
Headquarters
Executive
Team,
and the Region II Base
and Site Teams.
The licensee
provided
support to the State for the ingestion
exposure
pathway
portion of the exercise
on the second
day.
The scenario
was adequate
to exercise fully the licensee
organization
as" well as the State,
Local, and the
NRC organizations.
Site accountability
was timely and
classification
and
notifications
were
prompt'nd
well within
,acceptable
time limit criteria.
The .critique reflected
an in-depth
analysis
of exercise
observations
and
management
commitments to,
improve the program.
TVA's response
to Bulletin 79-18, Audibility Problems
Encountered
on
Evacuation of Personnel
From High - Noise Areas,
has not been
com-
pleted,
but is still scheduled
for completion during the Unit 2
cycle
6 outage.
Overall,
during
the
assessment
period,
the
licensee
demonstrated
improvement in the capability to implement the
REP during simulated
and actual events.
No violations were reported
in the assessment
period.
S.
Assessment
Period Performance
Rating
Category:
2
Trend:
Improving
Security
Base Period Analysis
This functional area
addresses
the licensee's
program for controlling
personnel
access
to the safety related vital equipment.
During the
base
period there were
two inspections
of the licensee's
safeguards
program.
The licensee
continued to make
improvements
in the operation of its
alarms stations
and its training of the security officers.
Progress
was noted in completing the Unit 2 start-up
items.
This is largely
attributable
to
aggressive
and
knowledgeable
'site
security
management.
Package
search
capability at the
warehouse
improved
during this p~riod because
of the enhancement
of the N-ray equipment
and better trained operators.
There were five examples of failure to control safeguards
information
in a licensee identified viclation and
one instance cf the licensee
0
20
exceeding
the
one hour notification requirement
by three
hours for a
non-cited violation.
2.
Assessment
Period Analysis
There
were
two Security
inspections
and
one Material Control
and
Accountability inspection during the assessment
period.
Two severity
level
IV violations were identified for failure to control safeguards
information and failure to control protected
area
access.
Inadequate
physical
inventories
in 1987
and
1988 resulted in the identification
of 26 discrepancies
in 1989 involving nuclear material
control
and
accountability
which were not detected
in the earlier inventories.
One severity
level
IV violation
and
a civil penalty for repeat
violations were issued for failure to perform adequate
inventories.
The licensee
continued
tc experience
problems, with its safeguards
information program.
However, extensive
corrective actions
appeared
to be effective towards the end of the
SALP rating period.
Norale of
-the security officers was also
noted to be improving.
Inspectors
noted
the, quality assurance
audits
by three
auditing groups
were
thorough,
complete,
and effective.
The licensee
trended
and assured
that effective corrective
measures
were taken in response
to Safe-
guards
Events.
At the
Corporate
level the
licensee
continued to
experience
change
of key personnel.
.Responses
to Generic Letters
(GL)
have
been
thorough
and reflect" technical
ana
procedural
forethought.
Staffing was adequate
and procedures
have improved.
Physical Security,
Contingency,
Security Training,
and gualification
Plan revisions
were well coordinated, within and
by the licensee's
security organization prior to submittal to the
HRC.
Plan submittals
were clearly written and required little or no additional discussion
with the licensee.
Support of the site security program is still evidenced
by the strong
fiscal
commitments to upgrading
or replacing out-dated
equipment
and
hardware.
Physical
barriers
inside
the control
room
have
been
completed,
relocation
of part of the protected
area
perimeter is
finished,
and detection
and
assessment
capabilities
are
improved.
Interim upgrade
items
have
been
completed;
however,
slippage
of
scheduled
completion dates
has occurred
and resulted in the continued
use of long term compensatory
measures.
The licensee
plans
a major
security system
upgrade to be implemented in 1992.
Progress
was
made
toward this implementation durirg this assessment
period.
The
new
system would reduce the number of compensatory
posts
now in effect.
There were three violations reported in the assessment
period.
Assessment
Period Performance
Rating
Category:
2
21
Recorder dati ons
The Board
recommends
special
attention be'laced
on maintenance
of
the existing
equipment until the major security
system
upgrade,
scheduled for 1992, is fully implemented.
Engineering
and Technical Support
Base Period Analysis
The Engineering/Technical
Support
functional
area
addresses
the
adequacy
of the technical
and
engine~ring
support for all plant
activities.
It includes
licensee activities associated
with design
baseline.
evaluation
ard resultant
modifications,
engineering
and
technical
support
provided for the restart effort and to support
operations,
maintenance,
surveillance,
tr aining,
procurement,
and
configuration
management.
The
bases
for this assessment
were the
licensee's
technical
submittals,
and inspections
conducted
in this
area
including Seismic,
Appendix
R, Bulletin Closeout,
and
the
Monthly Resident
Reports.
Early
in the
base
period,
the
licensee's
engineering/technical
support staff continued to struggle with the
scope of work required
to resolve
the
many technical
and design 'issues
identified in Browns
Ferry's
Nuclear
Performance
Plan.
In addition,
the support staff
continued
to be
hampered
by its inabil'ity to assist effectively in
the
completion
of the
large
backlog
of modifications
already
identified.
The
combination
of the
large
BFNP
work backlog,
ineffective TVA engineering
and aodification efforts,
and unrealistic
dates
contributed significantly to the
problems
TVA had in
reaching the timely resolution of significant restart
issues.
Unable
to correct its ineffective engineering/modification
structure
and the
attendart
constra>nts;
TYA often relied
on
pursuing
additional
analytical
methods
to further limit major restart mr,difications and
used
a pre-restart/post-restart
approach
to defer the correction of
noted deficiencies..
For example,
during the base period,
TVA had
made little progress
in
correcting past deficiencies that had been identified with piping and
supports at
BFNP.
In addition,
TVA has
shown an inability to adhere
to design criteria, past
commitments, or, incorporate the results
from
other independent
review efforts in the civil engineering discipline.
t'.anagement
.involvement
and
control
were
lacking in the
areas
of
nzsonry walls in that information on certain modifications of several
walls was not accurate.
The
NRC identified errors in the nuclear
steam
supply system
(NSSS)
seismic calculation of the reactor
pressure
vessel
during the
base
period.
The analytical
model
was found to have
assumed
that the
control rod drive
(CRD) housings
were seismically-restrained
when, in
fact,
no seismic
restraints
were installed
at
the
Browns Ferry
0,
22
2 ~
facility.'his resulted
in
a violation issued during the assessment
period.
During
the
base
per iod,
the
licensee
reorganized
the
onsite
engineering
and modification groups.
The new organization resulted
in
improving
the
site's
focus
on
accountability,
and
the
responsiveness
and
effectiveness
of
these
groups.
The
new
organization
put the engineering
and modification groups
under
one
site administrative
and functional authority who reports directly to
the Site Director.
As
a result,
Design
Nuclear Engineering
(DNE)
management
oversight
and involvement
was evident during the morning
turnover
and
outage
planning
meetings.
The reorganization
also
resulted in the iritiation of a duty DNE manager for weekend
and back
shift engineering
support for Operations,
and provided for direct
management
involvement'n
the
organization
'and
allocation
of
resources for the Restart
Test Program.
The base
period ended with the new organizational
structure
beginning
to establish
control
and accountability within the engineering
and
modifications
groups.
This
was
clearly
demonstrated
by site
management
placing
a temporary
hold on all engineering
work because
ot unsatisfactory
engineering quality.
measures
were developed
and
implemented to improve the quality and timeliness of engineering
work
packages.
- During the base
period,
no routine training inspections
or operator
licensing
examirations
were
conducted.
No
requalification
examinations
were administered,
however,
BFNP was in the final stages
of preparation for a requalification
exam to be conducted
during the
assessment
period.
The
NRC spent the week of June 26,
1989 reviewing
the 'xamination
material
for
inclusion
in
the
upcoming
requalification
exams.
Several
weaknesses
were identified
ard
comunicated to the
BFNP training staff.
Four violations and
one deviation were issued.
Assessment
Period Analysis
In the
assessment
period,
TVA senior
management
increased
their
involvement and control.
With the reorganization of the engineering
and modifications
group,
stea'dy
improvements
were
noted
in TVA's
disposition of the many restart technical
issues.
Management
involvement
and control were evident in the Seismic Class
I small
bore piping program.
A specific instance
was management's
effect on the size of the rigorous analysis
sample for the small bore
piping
program.
had
originally
committed
to
analyze
approximately
ten percent of the program scope.
However, additional
piping .within the
program
scope
was identified during implementation
of the Design Baseline
and Verification Program.-
This resulted
in
the analysis
sample
being
less
than
ten
percent.
Although it
23
involved
a
considerable
investment
in resources,
TVA agreed
to
increase
the sample size to meet the original ten percent
commitment.
Some
instances
in which management
control
was
less
than
adequate
included lack of timely followup on identified items in the areas of
emergency lighting, proper tagging of valves,
safe
shutdown lists and
instructions,
and component lists.
Increased
TVA management
attentior
has started
to affect issues
of
timeliness
and quality of the
products
from the
DNE groups.
In
addition,
TVA management
initiated the development of specific tools
to track the progress of these
groups in producing quality and timely
products.
This is
a major strength
shown during this period.
The approaches
taken
by the engineering staff to resolve technical
issues
from
a
safety
standpoint
showed
considerable
improvement
during
the
assessment
period.
TYA's resolutions
of the t~chnical
issues
associated
with Appendix R, post-fire
safe
shutdown,
cable
irstallation
practices,
Regulatory
Guide 1.97
( in
terms
of
alternative
instrumentation),
the
TS
submittals
for continuous
neutron
monst~ring
during refueling,
and
provisions
for
thermal
hydraulic stability were all clear
and complete.
Inspections
performed
of the engineering
effort to resolve
the
electrical
issues
at
Browns
Ferry founa
adequate
control of the
engineering
process
and
good
engineering
reviews of the
issues.
-Problems
were found, but with the large
amount of work examined,
the
problems did not represent
a significant percent of the output.
During the assessment
period,
the ongoing
BFNP Seismic Design
Program
implementation
was found to be satisfactory.
The licensee's
response
to the
CRD housing violation was to install seismic restraints
on the
Unit 2
housings.
The modification
was
accomplished
in
a
comprehensive,
well
planned
manner.
Further,
the
licensee
constructed
a
new full-scale model of the
CRD housings
and restraints
in order to rehearse
physical installation of the modification to
minimize radiation exposure
and time during actual installation.
The
installation
of
housing
seismic
restraints
is
a positive
indication of the licensee's
commitment to enhance
the safety of the
plant.
A detailed
review by an inspection
team of the
BFN Core Spray System
indicated that there appeared-to
be adequate
program implementation
fn the following areas to support Unit 2 startup:
Design Baseline
and
Verification Program,
TVA As-Constructed
Malkdowns, Drawing Control
Program,
ASllE Code Section XI, Restart
Test
Program (Prestartup),
Design
Changes,
Instrument
Line
Slope,
Melding,
g-List
Implementation,
ard Contractor
Recommendations.
The Calculations
and
Ycdification Controls
areas
were identified as requiring additional
TVA attention
and
NRC followup.
The staff evaluation
indicates
significant improvement in TVA's resolution of technica'1
issues
when
compared to the base period.
24
The
reported
events
pertaining
to Engineering/Technical
Support
involved seismic criteria, single failure issues
and
unplanned
actuations.
The
events
were traceable
to the nine circuit
protectors
installed in each unit.
The licensee's
engineering
and
technical
support
personnel
are
pursuing.
a
hardware fix for this
problem in a deliberate,
controlled,
and professional
manner.
The licensee
has
implemented
programs to address
-concerns identified
with design criteria,
thermal
stresses
and as-built details
of
piping/pipe supports,
and to address
concerns
identified with TVA's
past
implementation of
NRC Bulletins 79-02 (Pipe Support
Base Plate
Designs
Using Concrete
Expansion
Anchor Bolts)
and
79-14
(Seismic
Analyses for As-Built Safety-Related
Piping Systems).
These
programs
involved reinspection
and re-evaluation
of all piping systems
and
implementation of required restart modifications.
An inspection
was
performed
to verify that the pipe support
design modifications
had
been
completed
iri accordance
with design
documents.
The procedures
and
pipe
support
calculations
were
determined
to
be acceptable.
However,
a violation was identified for failure to follow procedures
in the construction
of. pipe
supports
arid in the guality Control
inspection of the completed supports.
The Maintenance
Team Inspection
noted the System Engineering
Program
as
a strength
in the Technical Staff.
.
The number of drawing deviations
increased
from 1500 during the base
p~riod to over
2000 during the
assessment
period.
Inconsistencies
existed
between
procedural
time limits for revision/correction
of
primary drawings significant to plant operational
safety.
Previous
corrective
action
was insufficient.
Using
updated
drawings with.
large
numbers of deviations is cumbersome
and increases
the potential
for errors.
During
the latter part of this
assessment
period,
Region II
ir.spectors
conducted
an, inspection
of the licensee's
control
room
operator
aria licensed
operator requalification accredited
trairiing
programs.
Improvements
in the area reflected
increased
management
attention.
The results of the inspection indicated that the program
appeared
to be adequate
to support safe plant operation,
however, the
simulator
had
numerous fidelity problems.
The licensee
proposes
to
correct
these
problems with the simulator upgrade
program scheduled
to
be
completed
by
December
1991.
The
Emergency
Operating
Instructions
(EOIs) were evaluated
as not being user friendly, but
are
adequate
for Unit 2 restart.
The upgrade to Revision
4 of the
'wner's guidelines will be performed after start-up of Unit 2.
Two violations
and three non-cited violations were identified during
the assessment
period.
Performance
Rating:
Category:
2
25
G.
Safety Assessment
and gualfty Verification
Base Period Analysis
During the base
period there
were frequent
changes
fn both sfte ana
corporate
management.
This contributed to programatfc instability
during the
base
period
and resulted
in minimal completion of work
activities
and the failure to meet scheduled
milestones.
During the
earlier
part of the
base
period,
corporate
management
was
riot
effectively involved fn site actfvities.
However, there
was
a steady
increase
in corporate
management
participation
and effectiveness
toward the
end of the
base
period.
The licensee
also performed
a
corporate audit on operatiorial readiness
during the base period.
A reorganization of the Plant Reporting Section which was responsible
for review,
investigation,
and reporting plant events,
occurred
during the
base
period.
NRC concerns
about failures to report
and
inadequate
root
cause
analysis
associated
with plant events
were
addressed
by TVA management.
Root cause
determination training was
provided to members of the management
and technical
organiizatfons
and
corrective
actions
and
Licensee
Event
Report
(LER) quality
was
improved.
While the licensee's
reportabflity threshold
and root
cause
determinations
improved
throughout
the
base
period,
the
licensee
on occasfoni
took the
approach
of fully analyzing
an event
prior to submitting
a
LER, resultfrig'n late submittals.
This
~
occurred
even with indication of
a problem existing when the event
was discovered.
Two examples of failure to submit
a
LER within 30
says
of the
discovery
of the
event
per
10
CFR Part 50.73
were
identified during the base
period.
An additional
example of failure
to
make
a four hour report
fn accordance
with
10
CFR Part
50.72
involved
an
unianalyzed
condition
dealing
wfth non-seismically
qualified clay pipe.
Significant
TVA and
NRC staff resources
were
concentrated
on the
resolution of technical
issues
during the
base
period, especially
concerning
Seismic
and Electrical Design
issues.
Licensee positions
ard submfttals
on these
issues
were often not timely, not sound,
ana
.
not well thcught out.
In the Seismic Design area,
many meetings
had
to
be
held
to
resolve
long-standing
issues
involving design
acceptance
criteria for restart.
There
were
instances
during the
base
period
when
the
licensee
provided
data
(e.g.,
electrical
separatiori)
that
had not receivea
adequate
I'evfew, resultfng fn the
need for further licensee
re-evaluation.
In the licensee's
response
to
NRC Position
on
Intergranular
Stress
Corrosion
Crackfng in
BNR Austenftfc Stainless
Steel
Piping,
the
licensee
had failed to include approximately
5GO welds in the three
units requiring examinatfcn
under the
GL 88-Cl fntergrar.ular stress
corrvsfon cracking program.
26
During the
base
period the
licensee
was constantly
in
a reactive
problem solving mode.
TVA made little progress
in correcting design
deficiencies
in the plant during the
base
period.
TVA identified
many of these
design deficiencies
as early as 1984.
In addition,
continued to change
many of its technical
positions during the base
period.
Thus, resolution of significant technical
issues
was often
protracted.
Even in those technical
areas
where the corporate staff had developed
considerable
experience
at Sequoyah,
a pro-active approach
to similar
Browns
Ferry
problems
was
not evident,
Corporate's
role often
appeared
to result
in less
conservative
positions.
The position
taken
on ampacity
was divergent
from the
one approved for Sequoyah
without a clear rationale.
During the base period,
the staff's review of the
TS change
requests
showed
an unclear
trend of the licensee's
technical
and licensing
capabilities.
Variability in the quality of
TS submittals
was
observed.
With
a
change
in Site Licensing
management,
there
was
a
discernible
improvement in the quality of submittals during the latter
portion of this base period.
The
NRC staff
conducted
an
inspection
in the
area
of quality
verification.
This
inspection
was'performed
to
assess
the
effectiveress
of the
licensee's
organization
for achieving
and
self-verifyino quality
in their functions.
Although
several
weaknesses
were
identified
during this
inspection,
the final
assessment
cannot'e
made until completion of the planned guality
Assurance
Programmatic
Team Inspection to be conducted
in the future.
The licensee's
10
CFR Part 50.59 program was reviewed during
a Design
Change
Program Inspection,
and in most
cases
found to comply with
minimum regulatory requirements,
however significant weaknesses
were
.
identified.
In addition,
two special
reactive
inspections
were
conducted
duritig the
base
period
to
determine
the
conditions
associated
with separate
problems
involving
inadequate
10
CFR
Part 50.59
reviews.
The results of the inspections
are
discussed
below.
The first inspection
dealt with the initiation of Unit
2
core
reloading without adequate
monitoring of the core neutron flux.
The
second
inspection
dealt with the failure by
TVA to identify and
correct
a condition where three
separate
EECW discharge
flow paths
associated
with safety
related
components
were
not seismically
qualified
due
to
the
presence
of vitrified clay piping.
The
condition did net
meet the
design
requirements
of the
Final Safety Analysis Report, Section 10.10.2,
and
had existed since
original plant construction.
The condition went undetected
by the
licensee
in spite of numerous
opportunities
to discover it.
When
finally identified by contractor
personnel
working for
- the licensee
engineering
organization, it took 23 days for the information to be
0
27
reported to licensee
operations
personnel.
This delay resulted
in the
s fte proceeding
with Unit 2 core reload
unaware that
a 1 1 Emergency
Core
Cooling
Systems.
required
by Technical
Specifications
were
potentially inoperable.
This problem also raised
the concern that
the
licensee'may
not
have effectively
implemented
commitments
in
response
to
NRC Order
EA 85-49.
Mhen the problem was identified to
plant operations,
their response
was conservative,
complete,
and
'adequate.
In addition,
corporate
management
conducted
a thorough
review of the event which led to an aggressive
correction plan.
Three violations were identified during the base period.
2.
Assessment
Period Analysis:
t
Safety
assessment
and quality verification activities were. monitored
by Resident
Inspector activities,
team inspections
and through review
of technical submittals
made during the period.
The most significant improvement in this functional area
has
been in
the
implementation
of the
licensee's
corrective action
programs.
'This
was evident
by the progrweatic
upgrades
in the handling of
identified safety significant issues,
improvements
in the tracking
and assurance
of timeliness of addressing
identified problems,
and
an
increased
level of attention
by management
in the review of Condition
Adverse to guality (CA/) documents.
The latter is accomplished
by daily
- Management
Review Coomittee
meetings
to discuss
the disposition of
all
CA( reports.
These
meetings
include the Site Director, Plant
Manager,
Site
gA Yanager,
and Site Engineering
Manager.
Additional
improvements
were
notea
in better comunications
between
managers,
supervisors,
and
the staff, ard
increased
attention
by senior
, management
toward improvement of the CA( programs.
Management
feedback
was also obtained
through the semi-arnual
audits
of the Correction of Deficiencies
Program.
The remaining
concern in
this
area
is the large
number of items that must
be escalated
to
managemert prior to corrective action being taken.
During the December
1989 through
February
1990 time period,
the
HRC
conducted
an in-depth
team inspection of the
BFHP Maintenance
Program
and its
implementation.
The inspection
included
reviews of the
licensee's
auality assurance
program.
The quality, control, storage,
and
retrievability of
records
for mater ials,
equipment,
and
construction
was satisfactory.
management
demonstrated
a continuing
interest in work planning
and the orderly control, of records.
Generally, the work done
by TVA on licensing issues
showed
evidence
of prior planning
by management.
TN established
target
dates for
submittals
and generally
met those
dates.
Yet there
were several
instances,
most notably the evaluation of offsite hazardous
materials
and
an
amendment
request
on Standby
Gas Treatment
System operability
requirements
that were either delayed or not timely.
0
28
Ouring the
assessment
period,
TVA submfttals
generally
improved.
TVA's approach
to many technical
issues
exhibited
conservatism
and
were
generally
thorough
and
sound.
This
was especially
true
concerning
Fire
Protection,
the
Mafntenance
Program,
and
t~iicrobiologfcally Induced Corrosion
Program.
The staff noted fn an
October
1989 site visit that
TVA lacked aggressiveness
fn addressirg
the staff's
comments
on
BFN Emergency
Operating
Procedures
detailed
fn Inspect.fon
Report
88-200.
Inconsistencies
fn the quality and
in-depth
analyses
of TVA's submittals
were
evident
during
the
assessment
period;
however,
a definite trend toward
improvement in
quality and timeliness
was noted.
TVA exhibited strong
management
attention in identifying weaknesses
curing the
assessment
period.
Reliance
on the
gA Team inspection,
the Operational
Readiness
Pevfew
Team,
and the Nuclear Experience
Review Group providea continuing evidence
of TVA management
concern
for the status
of the restart effort.
The System Plant Acceptance
Evaluation
(SPAE)
process
was
implemented
to review the
system
documentation
to ensure
completion of the work scope prior to return
to service.
Still, this auait-type
feedback
only confirmed TVA's
problems with the successful
implementation of many of the corrective
action programs.
In those
cases
where
TVA management
implemented
continuous
feedback,
progress
was
being
made
toward
developing
consistent
quality
- engineering
work.
For
example,
the licensee's
measurement
of the
number of Field Change
Notices requfred for each
Engineering
Change
Notice appeared
to provide
a direct measurement
of the progress
being
made
toward providing quality engineering
work to the field.
Audits
corducted in the security, chemistry,
and radiological controls areas
by the
licensee
continued
to provide
feedback
to
management
on
achieved quality of the programs.
A broad spectra
of safety
issues
were identified by TVA employees
in
the
Employee
Concern
Task
Group
(ECTG)
program that reflected
a
previous
.lack of management
involvam~nt with quzlfty.
The
NRC
staff's
review of the
Browns Ferry -ECTG investigations,
correctfve
actions,
and
planned
programmatic
improver~nts
resu1ted
fn the
conclusion that the evaluations
were adequate
ard well documented.
Routine
NRC inspectiors
found that the safety analyses
of TACFs were
of good quality,
LERs were
adequately
closed,
and
10
CFR Part
21
reviews were well. done.
Conservatism
fn the licensee's
technical
approach
to problems
was
generally exhibited
and decision
making
was usually
on
a level that
ensured
adequate
management
review.
Yet
technical
reviews
occasiorally
lacked details
and
adequate
technical
bases.
Several
examples
were identified of the failure to take
prompt effective
action to correct identified deficiencies
related to problems with
engineering
calculations
and
welding
record
retrfevablity.
0
29
Additionally, the
licensee
failed to identify many
hardware defi-
ciencies during
a walkdown on the Core Spray System performed shortly
before
the scheduled
NRC vertical slice inspection.
The licensee's
presentations
during
meetings
continued
to
show
improvements
suggesting
better
communication
among licensee organizations.
During the
assessment
period, the licensee'generally
responded
well
to
NRC initiatives.
Host noteworthy
was the licensee's
revised
commitment to expedite
the necessary
modification work to complete
the
remaining
issues.
The licensee
also
committed to
install
hardened
wetwell vents
on Unit 2
before the requested
completion date.
A followup inspection
performed
on
GL 88-01 issues
found Browns Ferry
responsive
to correcting
the deficiencies
identified in the
base
perioo.
The corrective actions
were determined to be thorough.
However,
there
have
been
some
instances
where
TVA has
not
been
responsive
in
a timely manner.
The schedule for correction of the
instrument
sense line was delayed at least twice ano correction for a
long
krown
design
deficiency
in
the
control
room
emergency
ventilation
system still is not complete.
TVA's recent
Operational
Readiness
Review indicated that the
BFNP response
to
NRC
Potential
Safety-Related
Pump Loss,
may reflect
a lack of technical
and critical review.
The site licensing organization
improved the timeliness
of TVA's
responses
to the
NRC; however,
weaknesses still exist in both the
timeliness
arid quality of Notice of Violation responses.
A number of
the
licensee's
written responses
received
during the 'assessment
period were not timely and frequent extensions
were requested
to the
time requirements
of 10
CFR Part 2.201.
One deviation
was issued for
the failure to submit
a special
report in accordanice
wiKh a prior
commitment to the
NRC.
The staffing of the site licensing organization generally
supported
improvements in the timeliness of responses
to the
NRC, even with the
apparent
downsizing of the staff.
But continuing
changes
in line
personnel
in site licensing resulted in some problems with delivering
consistent,
high-quality submittals to the
NRC.
Consultants
have
been effectively used
by the licensing staff to support
the
heavy
work loaa supportirg restart.
There is
a defined
program of training established
at the site.
management,
provided identification of emerging training 'needs
and the
formulation of records.
Training was maintained
as
a high priority
relative to work scheduling.
The training 'facilities, curriculum,
and
instructors
appeared
to reflect
quality
and
indicated
responsiveness
to industry initiatives ard guid~lina.s.
30
-Procedural
compliance
continued tc be
a problem and was
a result of
fnacequate
training and line'organfzatfcral
interfaces.
There still
are quality problems with some
procedures.
A staff review of the
Browns Ferry
Emergency
Operating
Instructions
indicated
a
need to
revise the
EOI Writer's Guide to reflect the specific
human factors
concerns
pointed
out previously
in Inspection
Report 88-200.
In
addition,
TVA's
Phase
II Operational
Readiness
Review
Report
(triarch 9, 1990)
indicated similar deficiencies
fn
a wfde variety of
procedures
and associated writer's guides.
Three
violations
and
two deviations
were identified during
the
assessm~et
period:
3.
Performance
Rating:
Category:
3
Trend:
Improving
31
SUPPORTING
DATA AND SUMMARIES
Licensee Activities
The start of the
base
perivd corresponded
to the
commencement
of fuel
loading.
This occurred
at 9:50 a.m.
(CST)
on January
3, 1989.
The core
reload
was
complete at 11:Ol a.m., on January
30,
1989.
The reload
was
delayed while in progress
by refueling bridge
and
source
range
neutron
monitoring problems.
Maintenance
and mod'ificatic n work continued after reload.
Work was
performed with the
major plant
equipment
divided into
one of three
divisions
to minimize
Technical .Specifications
impact
on
the
work
schedule.
New
emerging
work items
made
the existing
schedule
impractical if
divisional outages
were to continue.
TYA decided to offload the core to
expedite
work completion,
to
complete
a
Special
Nuclear
Materials
inventory,
and to resolve
some Environmental gualifications issues.
The
Unit
2 core offload began
at 2:00
a.m.
on January
6,
1990,
and
was
complete
at 4:33 p.m.
on January
23, l990.
The offload enabled
Browns
Ferry, with Tech
Spec relief, to begin working in
a Bulk Work fashion,
with minimal restrictions
caused
by equipment restrictions.
All-three units at
Browns Ferry are offloaded.
Unit 2 is currently
scheduled for critically in September
1990.
Direct Inspection
and Review Activities
In adaition to the routine
inspections
performed at the
Browns Ferry
facility by the
NRC staff,
a
number of special
team inspections
were
conoucted.
These
were conducted
in fire protection, quality verification,
design
control,
Appendix
R, maintenance,.
and
seismic.
The inspection
results
are discussed
in the applicable functional area.
Review activities were all associated
with licensing activities based,
in
part,
upon licensing actions successfully
completed during this appraisal
period.
These
activities
included
the following:
one waiver of
compliance
issued,
three requests
for relief granted,
one exemption,
one
emergency
or exioent
license
amendment
issued,
two Hulti-Plant Action
items resolved,
and eleven significant plant specific issues
resolved.
To
support licensing activities, meetings
were also held with TYA to address
licensing
and other technical
issues.
32
C.
Enforcement Activity
FUNCTIONAL
AREA
3 ut own
pera
sons
Radiological Controls
Maintenance/Surveillanc~
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/guality
Verification
TFQ
4
1
5
1
3
2
1
2
2
1
2
SEVERITY LEVEL
BASE PERIOD
ASSESSMENT
PERIOD
Dev.
V
IV
III .
Dev.
V
IV III
~
~
~
0
33
D.-
Review of Licensee
Event Reports
(LERs)
During the
SALP period
71
LERs .were analyzed,
35 of which were in the
assessment
period.
Most
LERs were well written and issued in a timely
manner.
The distribution of these
events
by cause
as determined
by the
NRC was as follows:
Ease Period
Cause
Personnel
Error
Design, Manufacturing, Construction/Installation
External
Causes
Defective Procedure
t:,anagement/guality
Assurance Deficiency
Other
% + W W&&&W W W&W W W &W&W&&& A&W WA&WW&W W W WWW W W WWW 0
Total
Unit
1
2
3
4
9
2
6
3
1
1
3
1
2
4
A&W&&WW&&W&WWW&WW&W
14
19
3
- Assessment
Period
Cause
WW
W&&&WW && W&&&WAW&&&&&W&&&
Personnel
Error
Design, hhnufacturing, Construction/Installation
External
Causes
Defective Procedure
Management/guality
Assurance
Deficiency
Other
W&%&WW&&&W
~
Total
Unit
1
2
3
3
5
2
5
1
1
5
1
4
6
2
18
12
5
0