ML18101A457

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SALP Repts 50-272/93-99 & 50-311/93-99 for 930620-1105
ML18101A457
Person / Time
Site: Salem  
Issue date: 01/03/1995
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18101A456 List:
References
50-272-93-99, 50-311-93-99, NUDOCS 9501110145
Download: ML18101A457 (11)


See also: IR 05000272/1993099

Text

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)

SALEM UNITS 1 AND 2

REPORT NO. 50-272/93-99 l 50-311/93~99

I *

BACKGROUND

The SALP Board convened on December 1, 1994, to assess the nuclear safety

performance of the Salem Units 1 and 2 for the period June 20, 1993, to

November 5, 1994. The board was convened pursuant to U.S. Nuclear Regulatory

Commission (NRC) Management Directive (MD) 8.6, "Systematic Assessment of

Licensee Performance

(SALP)" (see NRC Administrative Letter 93-02).

Board

members were Richard W. Cooper, (Board Chairman), Director, Division of

Reactor Projects, NRC Region I (RI); James T. Wiggins, Director, Division of

Reactor Safety, NRC RI; Charles W. Hehl, Director, Division of Radiation

Safety and Safeguards, NRC RI; and John F. Stolz, Director, Project

Directorate I-2, NRC Office of Nuclear Reactor Regulation.

The board

developed this assessment for approval by the Region I Administrator.

The following performance category ratings and the assessment functional areas

are defined and described in NRC MD 8.6.

II.

PERFORMANCE ANALYSIS - OPERATIONS

The Operations functional area was rated category 2 in the last SALP period.

The licensee's performance was characterized by excellent operator response to

trips and other operational transients. Supervision and management oversight

of refueling and day-to-day operations was very good.

However, the operators'

attempt at several *startups of Unit 2 without sufficiently determining the

cause of repetitive rod control problems and effectively resolving the

problem, was identified as a significant management control and oversight

weakness.

Throughout the current SALP period, operators were often challenged by plant

trips and other operational transients. Operators exhibited generally good

command and control of the response to these events.

For example, on June 10,

1994, operators demonstrated appropriate command and control in response to an

automatic trip caused by failure of a main generator potential transformer.

Likewise, on August 30, 1994, Unit 2 operators responded well to a condenser

water box manway failure and reduced power to 75 percent.

However, during

the April 7, 1994, grass intrusion event, shift management personnel did not

remain free to survey and analyze all operating parameters and, for a short

period of time, lost control and perspective of the overall operations in the

midst of attempting to stabilize plant conditions.

Operations and plant management made operating decisions that generally led to

conservative operation of the plant. For example, in June 1994, plant staff

performed a methodical, controlled, safe startup of Unit 1 following the April

7, 1994 trip, after delaying startup in order to repair small leaks in the

reactor head vent valves and a pressurizer safety valve. Additionally,

9501110145 950103

PDR

ADOCK 05000272

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PDR

operators exhibited proficiency in making conservative, proper, and timely

emergency declarations for six actual events that necessitated consideration

of entering an emergency action level.

Notwithstanding the performance noted above, overall operations performance

during this assessment period was characterized by significant weaknesses in

several areas. Slow or inadequate resolution of equipment problems by other

plant departments caused operators to become accustomed to working around or

living with problems that created additional challenges to them in operating

the plant in normal and upset conditions. For example, the licensee provided

inadequate training, guidance, and procedures to the operators to cope with

plant transients resulting from grass intrusion events that had occurred

frequently at Salem.

Operator response to the April 7, 1994, grass intrusion

event was also complicated by a safety injection that was caused by a spurious

high steam flow signal of short duration that had been observed during three

previous reactor and turbine trips, but had never been fully investigated and

resolved.

In addition, during the transient, the atmospheric relief valve

control system exhibited a recurring problem in which it had to be shifted to

manual, then back to automatic after a short time delay to ensure proper

operation. Although this condition was known and existed for several years,

plant management accepted and accommodated the situation without any

resolution. Operators also did not aggressively pursue correction of

longstanding problems with the rod control system that caused numerous

occurrences of rods stepping into the core in half steps without appropriate

process demand signals.

Some events that occurred during this assessment period demonstrated a weak

questioning attitude by operators.

For example, in April 1994 with the plant

shut down, Unit 1 operators did not question a reading of 93% on the reactor

vessel water level indication system (RVLIS).

When brought to their attention

by NRC, operators attributed the reading to a calibration problem instead of

an actual decrease in reactor vessel water inventory. Subsequently, the

condition was confirmed and eliminated by venting.

Earlier in the SALP

period, a cold leg accumulator's level was recorded in the control room logs

as being above the upper technical specification limit without a corresponding

technical specification entry. However, this deficiency was not identified by

either self checking or supervisory review, and, consequently, not corrected

in a timely manner.

Operability decisions made by the Operations staff were often weak due to a

poor understanding of the design basis of safety related equipment and

systems, as well as, a lack of clear guidance and training on Generic Letter 91-18.

The engineering organization was not consistently consulted on many of

these more difficult operability determinations.

For example, an initial

operability evaluation for 1PR25 (a check valve between the thermal relief

valves on the Safety Injection System and the Pressurizer Relief Tank) did not

involve any consultation with the engineering*organization and failed to

consider the design basis requirements of the valve. Other noteworthy

examples involving weak operability determinations include the degraded

performance of the IA emergency diesel generator, closure of the power

operated relief block valves, and safety injection relief valve leakage.

In

addition, there were several examples over the assessment period in which

operators took a non-conservative approach to entering and exiting Technical

Specification limiting conditions for operation (LCOs) for the same underlying

3

problem.

For example, in May 1994, during a Unit 1 startup, operators made

repeated entries into the Technical Specification (TS) LCO for the pressurizer

vent path in response to minor leakage through two head vent valves, but

inappropriately re-initialized the LCO entry each time. Operators also

entered and exited a containment isolation TS LCO for the service air system

twice in the same shift to perform maintenance that would have exceeded the

original LCO time period.

Operations also exhibited difficulty managing and controlling outage

activities. For example, operators created or contributed to a number of

tagging errors. These included an operator who removed tags from a bleed

steam coil drain tank pump, which allowed steam to escape through an unsecured

drain line, and an operator who erroneously opened a boundary valve that

allowed water to flow to a downstream valve that was undergoing a maintenance

activity. Subsequently, the licensee established corrective measures and

similar occurrences have not been observed. Also, during the refueling outage

in October 1993, with the spent fuel pools cross connected, operators did not

identify that a pre-existing high level condition in the Unit 2 spent fuel

pool masked further increases in pool level which, when such an increase

occurred, resulted in an overflow of the spent fuel pool water into the fuel

handling building ventilation exhaust ductwork.

Inspection activities late in the SALP period revealed that Quality Assurance

& Nuclear Safety Review organization's surveillance of Operations was not

performance-based and was ineffective in identifying significant previously

existing weaknesses in the Operations department.

The lack of self assessment

activities within the Operations organization, coupled with ineffective

independent oversight by the Quality Assurance and Nuclear Safety Review

organization, resulted in minimal feedback to the operators and their

management relative to the existence of significant performance problems in

Operations.

In summary, operators generally responded appropriately with good command and

control to the many plant trips and operational transients that occurred over

  • the SALP period. Likewise, they demonstrated good proficiency in making

emergency declarations for events for which such declarations should have been

considered. However, performance over the assessment period demonstrated

significant weaknesses in several areas. Operators did not practice ownership

of the plant and did not aggressively enlist other plant departments to

resolve longstanding equipment problems which frequently challenged them in

normal and upset plant conditions. A lack of an appropriate questioning

attitude by operators resulted in anomalous indications, or conditions being

unnoticed or not understood and not being acted upon.

A lack of guidance for

and training of operators on operability decisions resulted in some decisions

being nonconservative or having weak technical bases.

Examples of

nonconservative approaches to entering and exiting LCOs occurred over the

period.

Some difficulties were experienced managing and controlling outage

activities. Poor self assessment within the Operations department coupled

with ineffective independent assessment of Operations by the Quality Assurance

and Nuclear Safety Review organization contributed to the continuation of

performance problems throughout most of the period .

The Operations functional area is rated as Category 3.

4

III.

PERFORMANCE ANALYSIS - MAINTENANCE

In the previous assessment period, the maintenance and surveillance functional

area was rated Category 2.

Personnel errors had decreased, but still caused

three reactor trips and four engineered safety features actuations. Three

refueling outages were performed with strong planning and implementation.

Improvements were noted in the preventive maintenance program, procurement,

material control, and surveillance procedures quality through the procedures

upgrade program.

During the latter part of this assessment period, management improved its

safety focus in prioritizing and scheduling maintenance activities.

In the

plan-of-the-day meetings and other work planning meetings and activities

involving both operations and maintenance personnel, the emphasis was on

safety rather than production. Interdepartmental communication, especially

between maintenance and systems engineers, improved.

However, supervisors did

not always communicate effectively with workers while they were in the field

and during pre-job briefings, as evidenced by maintenance errors involving the

governor gear box oil change and turbine overspeed trip test device made

during preventive maintenance work on the Number 23 auxiliary feedwater (AFW)

pump.

Failure to use the vendor drawing during the pre-job briefing led to

subsequent errors where the mechanics mistakenly added gear box oil to the

turbine governor and disturbed the adjustment of the turbine overspeed trip

test device.

The AFW pump tripped twice during post-maintenance testing

before appropriate supervisory guidance was obtained for returning the pump to

service.

Salem had a high recurrent equipment failure rate indicating continuing

problems with corrective action effectiveness and inability to effectively

resolve longstanding equipment and system deficiencies.

For example,

inadequate root cause analysis and the need for training contributed to the

delay in correcting long-term deficiencies in the various radiation monitoring

systems; inadequate root cause analysis also contributed to repetitive

failures of the automatic control of the steam generator feedwater regulating

valves (BF19) over a two year period.

Supervisory control and management oversight were lacking for the numerous

groups and organizations that perform maintenance work on the site. For

example, a contractor employee conducted maintenance on a breaker for an

electro-hydraulic pump without the job supervisor ensuring that the equipment

first was tagged out. There were also several examples where contractors

performed outage maintenance items without detailed maintenance procedures.

Most recently, the licensee found that a contractor electrician cut into the

wrong 4160 VAC cable. A fatality was avoided only because the affected cable

was tagged out of service to support other unrelated work.

In the area of problem identification and resolution, the licensee has

implemented an effective way of tracking equipment problems using a process

called the equipment malfunction identification system (EMIS).

However, the

feedback process regarding problems that occur during maintenance activities

was not effectively implemented by field maintenance personnel. This

primarily delayed or prevented the timely correction of deficient procedures

5

and work packages.

Feedback did not always get into the planning system and

in some instances the initiator of the feedback form was not informed as to

the resolution of the problem.

Further, troubleshooting and implementation of

the root cause program was inconsistent, even though the licensee has

established a good root cause capability. For example, the licensee did a

good job of troubleshooting and determining the root cause of intermittent rod

stepping and oscillations on the AFW pump.

However, in addition to inadequate

root cause analysis and failure to resolve longstanding problems cited

earlier, the licensee performed inadequate troubleshooting and root cause

analysis on the four electro-hydraulic control power supply failures before

determining the fundamental root cause of the failures.

Finally, some of the

maintenance performance problems were related to conducting troubleshooting

without a procedure such as the example where the ability to capture as-found

defects was lost during removal of a failed emergency diesel generator

cylinder liner.

The material condition of the plant improved following the licensee's

establishment of the Salem Material Condition Revitalization Project.

However, there remains evidence of degraded conditions in the service water

intake structure and the Residual Heat Removal pump rooms.

Personnel errors, problems with procedural adherence, and excessive reliance

upon "skill of the craft" contributed to inconsistent implementation of the

maintenance program.

For example, there were a significant number of tagout

errors where maintenance was performed without appropriate tagging of

equipment to ensure that it was safe to work on, or improper removal of tags

that should have been maintained.

In addition to the examples cited earlier,

some of the other errors involved an electrician cutting into an energized 125

Volt DC distribution cable and an equipment operator removi~g tags and

subsequently opening vent and drain valves in an incorrect order allowing

steam to blow out drain fittings and a drain hose to whip about due to steam

pressure.

In general, surveillance testing activities were effective with respect to

meeting the surveillance program objectives.

The high risk surveillance

testing of the reactor trip breakers was performed well.

However, the

licensee failed to demonstrate the design basis capability of the emergency

diesel generators to start on a single air start system while performing

maintenance on the remaining air start system.

Also during this period, a

surveillance procedure deficiency resulted in the inadvertent discharge of a

safety injection accumulator into the reactor coolant system while at low

pressure.

Although the licensee completed a formal procedures upgrade program (PUP) in

1993, procedure adequacy continues to be a problem.

For example, an excellent

troubleshooting procedure was developed and implemented in the controls area,

but a similar procedure in the mechanical maintenance area was not

implemented.

There were recurring maintenance problems that needed specific

procedure changes which were being delayed because of an excessive procedure

change backlog.

In several instances, there was a planning failure to

specify appropriate post-maintenance testing requirements in work order

l

6

packages. This was attributed to the inadequacy of the controlling procedures

for the planning process and training of planners in post-maintenance testing

requirements.

The Salem in-service testing program was adequate. The use of spectrum

analysis for vibration and high quality procedures were noteworthy.

However,

several shortcomings were identified in program oversight by station

management.

Many program weaknesses were identified by comprehensive and

self-critical audits, but were not acted upon.

The programs for in-service

inspection, erosion/corrosion and steam generator leakage monitoring were

adequately implemented.

In summary, performance weaknesses were evident in maintenance programs and

activities, such as procedural adherence and adequacy, the feedback process,

specification of post-maintenance testing. requirements, and control of work

activities by numerous onsite groups.

Management has improved its safety

focus in prioritizing and scheduling maintenance activities. However,

management oversight of corrective action program activities has been weak as

evidenced by the high recurrent equipment failure rates.

Inconsistencies in

troubleshooting activities and root cause analysis contributed to the delay in

correcting recurring problems. Material condition of the plant continues to

improve, but there remain several areas that need improvement.

Although the

in-service testing program was adequate, management did not effectively

resolve self assessment findings.

Programs for in-service inspection,

erosion/corrosion and steam generator leakage monitoring were adequately

implemented.

The Maintenance functional area is rated Category 3.

IV.

PERFORMANCE ANALYSIS - ENGINEERING

In the last SALP, engineering was rated Category 2.

Engineering provided good

support for refueling and maintenance outages and strong performance was noted

in addressing day-to-day activities. The training programs for engineering

personnel were excellent. Weaknesses were noted in handling of engineering-

related nonconformances, in the erosion/corrosion program implementation and

in fire protection programs. Also, while the root cause training program was

found to be strong, the threshold for initiating root cause analyses was not

clear or consistent.

During this period, the quality of engineering activities was inconsistent and

varied significantly from activity to activity. Quality depended on the issue

involved and the perceived importance of that issue by engineering and plant

management and staff. Management expectations for engineering performance

were clearly articulated but were implemented inconsistently throughout the

organization.

Communication and coordination among the Engineering and Plant Betterment

(E&PB) organization, the Technical Department of the plant staff and the

balance of the plant staff were not always effective. While there was good

communication and coordination of highly-visible problems, day-to-day

7

interactions were ineffective in resolving some repetitive equipment problems

that continued to challenge the operation of the facility. While close

interactions occurred between the Maintenance organization and Technical

Department system engineers, the engineering expertise of the E&PB

organization was not always effectively engaged.

Engineering did not always

proactively seek out and correct system and component deficiencies before they

led to increasingly challenging plant events.

Further, E&PB did not

effectively involve itself in support of plant operations as demonstrated by

the fact that, while backlogs of its activities were well controlled, its work

priorities were not well-integrated with those of the operating organization.

For example, the "Engineering Critical Issues List" did not match the plant's

critical issues list and was not prioritized by safety significance. Further,

even subsequent to the April 7 grass intrusion event, none of the items that

were being tracked as operator work-arounds by the Operations organization

were included on the engineering list. Notwithstanding, significant positive

engineering leadership and good quality engineering work were demonstrated in

the recovery from the rod control systems problems, in the main steam line

flow monitoring modifications, and in the commitment of resources toward the

switchyard betterment and radiation monitoring system upgrade programs.

Design engineering procedures were comprehensive and their quality was good.

Work instructions associated with modification installation were generally

good.

Temporary modification activities were well controlled, with installed

temporary modifications tracked and periodically assessed by the system

engineer.

The quality of technical support provided to the Operations and Maintenance

organizations was mixed.

Engineering support was good in a number of

instances, such as those associated with indications of condensate pump

pedestal damage, with the identification of thermal fatigue cracks in Unit 1

steam generator feedwater nozzles, and with a leaking flange joint associated

with the #22 reactor coolant pump.

Further, the engineering evaluation of

emergency diesel generator cylinder liner cracks was comprehensive and of high

quality.

However, several instances were noted where engineering support in

response to equipment problems was poor.

Examples included the ineffective

response to control air compressor problems and the lack of a timely and

effective review of the main steam line pressure pulse phenomenon prior to the

April 7, 1994 event.

In a number of programmatic areas, performance was good.

The motor-operated

valve testing program was found to be progressing well toward its planned

completion date. The erosion/corrosion program improvements achieved at the

end of the last SALP period were maintained in effect. The steam generator

inspection program was well controlled and implemented.

Engineering support

to maintenance troubleshooting activities was, in general, good.

The

Environmental Qualifications Master List was appropriately maintained.

In

addition, the engineering assurance program was revised and improved during

this period.

Configuration baseline documents were found to be of good

quality, but a licensee self-assessment noted opportunities to improve their

use.

In the procurement area, commercial grade dedication packages were

complete and the warehouse storage areas were well maintained; however the

material issuance process failed to prevent issuance of the incorrect

8

materials to support a modification of Unit 2 power-operated relief valves and

to support emergency diesel generator fuel injector stud changeouts. Also,

notwithstanding the problems identified in the licensee's reaction to the

April 7, 1994, event, the licensee performed an excellent and comprehensive

investigation and implemented a monitoring program for grass intrusion into

the circulating water/service water intake structures.

Problems with root cause analyses continued from the last SALP period and

contributed to weaknesses in resolution of long-standing problems.

In several

instances, such as in response to indications of ground-water leakage near

auxiliary feedwater system piping penetrations, to indications of operation at

greater than 100% power, and to repeated steam generator feedwater pump

control oil power unit problems, root cause analyses performed by the plant

maintenance and technical organizations tended to focus narrowly on the

symptoms of equipment problems at hand.

In reaction to NRC interest or as a

result of an event, senior licensee management focused on specific issues and

commissioned more in-depth root cause activities, such as Significant Event

Review Teams. The outcomes of these focused efforts were markedly better than

those done routinely by the line organizations, indicating the licensee had

the capability to perform these assessments and suggesting that the

performance problem continued to be associated with the threshold established

for initiating root cause evaluations.

Engineering personnel, particularly reactor engineering personnel, were found

to be very knowledgeable of their discipline, however system engineers were

not trained in current NRC operability guidance despite the fact that they are

routinely engaged in operability assessments.

Personnel performance was

generally good, however two noteworthy contractor control problems were noted

associated with the auxiliary feedwater system controller and the primary

water oxygen reduction modifications where the contractors engaged in

installation activities failed to follow established station work process

control procedures.

In summary,

Engineering performance was inconsistent, with substantial

variation in quality.

The quality of the discipline design work was good,

with significant engineering management focus shown in several modification

activities. However, engineering work priorities did not always reflect plant

needs.

In several significant programmatic areas in which the Engineering

organization had an important role, performance was, on balance very good.

Significant problems, nonetheless were noted associated with root cause

assessments and with equipment problem resolution.

The fact that there

existed engineering capability, that when focused by station management and

brought to bear on important issues, demonstrated the ability to achieve very

good performance, suggested that a significant aspect of the problem was

associated with the effective engagement of available engineering expertise in

activities important to safe plant operations, such as in root cause

assessment and equipment problem resolution.

The Engineering functional area is rated as Category 2 .

9

V.

PERFORMANCE ANALYSIS - PLANT SUPPORT

This functional area is new; representing a significant change from the

previous SALPs.

The plant support functional area covers all activities

related to plant support functions, including radiological controls, emergency

preparedness, security, chemistry, fire protection, and housekeeping controls.

In the previous SALP the radiological controls, emergency preparedness and

security functional areas were all rated as Category 1; however a declining

trend was assigned to the emergency preparedness area. Performance

observations in the radiation protection area included: strong management

involvement, as shown by excellent as-low-as-reasonably-achievable {ALARA)

oversight; effective supervision of on-going work; and challenging

occupational exposure goals.

The licensee demonstrated continued strong

performance in activities involving radioactive waste handling and

transportation, and contamination control. The chemistry, effluent and

environmental monitoring programs remained highly effective. Performance in

the emergency preparedness area was excellent with a high quality drill and

exercise program, and extensive management involvement. Although the

emergency plan was effectively implemented for four events requiring

declarations of Unusual Events, weaknesses were identified in classifying and

reporting the December 1992 loss of control room annunciator event at Salem 2.

Additionally, problems with formulation of event classification and protective

action recommendations during exercises were identified. The licensee

maintained a very effective security program, with good management support,

high quality maintenance support, excellent rapport with other plant groups,

and effective audit and self-assessment programs.

Although rated in

conjunction with the Operations Area during the last SALP, the fire protection

program exhibited some programmatic and personnel performance problems.

During the current SALP period, the licensee's radiation protection program

performance continued to be a significant strength. Effective external and

internal exposure control programs continued to be implemented.

Effective

application of engineering controls to control contamination resulted in

commendably low air activity levels, resulting in low internal exposures.

Continued effective ALARA program implementation was evidenced by dose

reductions achieved through extensive application of temporary shielding

during both unit outages, good radiation safety work coverage and pre-job

briefings, and appropriate work area postings.

The licensee effectively

implemented the revised 10 CFR Part 20 by integration of the new requirements

in applicable radiation protection procedures and in timely training of the

work force.

High quality training for radiation protection technicians and

staff was evident. A very effective radioactive material and contamination

control program was implemented.

Radiological housekeeping was generally very

good.

Audits and surveillances of the radiation protection area were

performance-based, performed by appropriately qualified individuals, and were

effective in identifying performance problems.

Corrective actions taken in

response to identified problems were effective. The radioactive waste

handling, processing, packaging, storage, and transportation programs

continued to be very good.

The licensee completed construction of a state-of-

j

10

the-art radwaste storage facility. Radwaste generation reduction efforts were

very effective as evidenced by the continuing downward trend in radwaste

produced.

Performance in the radiological environmental monitoring and effluent control

programs continued to be strong. Effective programs for measuring

radioactivity in process and effluent samples were implemented as well as an

effective program for the radiation environmental monitoring. Quality

assurance audits were thorough and of good t.echn i ca 1 qua l i ty. Responses to

audit findings were timely and identified appropriate corrective actions.

Excellent emergency preparedness (EP) program performance was noted during

drills and exercises. However, the licensee's initial notification to the NRC

of an Unusual Event involving the April 7, 1994, Salem Unit 1 trip was poor

relative to communication of the complications that were known to, and

experienced by, the operators during the transient.

An exercise strength was

highlighted regarding Emergency Response Manager command and control.

Effective management support was evidenced by active involvement of upper

level management in the emergency response organization (ERO) qualification

and drills, and rapid replacement of ERO members following recent employee

layoffs. Several improvements were implemented during the period, including

development of a radiologically-based protective action recommendation flow

chart and improved containment boundary emergency action levels, which

enhanced response capability. The emergency response facilities were well

equipped and generally well maintained, however, problems were identified

regarding periodic efficiency tests on the high efficiency particulate filters

associated with the Emergency Operations Facility and radiation monitors for

the Technical Support Center heating and ventilation system being out of

service for 18 months.

The licensee continued to implement a very effective security program.

Management attention and involvement generally continued at a high level.

Support of security equipment by the maintenance staff was effective in

minimizing the need for compensatory measures.

However, some assessment aids

had deteriorated to a point that even aggressive maintenance was not entirely

effective in maintaining this equipment.

The licensee continued to implement

a good performance-oriented training and qualification program.

However,

personnel performance issues raised questions regarding complacency of

security force members and supervisor oversight of routine security program

implementation.

The licensee initiated actions to address problems in this

area.

The fire protection and prevention program was effectively implemented.

Corrective actions put in place to address equipment and personnel performance

problems highlighted in the previous SALP were effective. There was good

fire-fighting equipment maintenance and surveillance. Responses to emergent

equipment conditions were appropriate. Combustibles and ignition sources were

well controlled.

Performance during drills demonstrated the licensee's

readiness and fire fighting capabilities. Audits were detailed and of

appropriate depth.

11

In summary, the plant support functions contributed effectively to safe plant

performance.

Performance in the radiation protection area continued to be a

significant licensee strength. Well trained technicians and staff coupled

with effective management resulted in aggressive ALARA program implementation

with significant dose savings realized.

Excellent performance in the

radiological environmental monitoring and effluent control programs was again

noted. There was continued good performance in the emergency preparedness

area. Security program performance continued to be a strength.

Fire

protection program implementation was substantially improved.

The Plant Support functional area is rated as Category 1 .