ML20012E083
| ML20012E083 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 03/22/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20012E082 | List: |
| References | |
| 50-458-90-01, 50-458-90-1, NUDOCS 9003300049 | |
| Download: ML20012E083 (25) | |
See also: IR 05000458/1990001
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INITIAL SALP REPORT
U.S. NUCLEAR REGULATORY COMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-458/90-01
River Bend Station
October 1,1908, through December 31,-1989
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ADOCK 05000458
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I.
INTRODUCTION
The Systematic Assessment of Licensee Perfomance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee perfomance based upon this
infomation. The program is supplemental to normal regulatory processes
used to ensure compliance with NRC rules and regulations.
It is intended
to be sufficiently diagnostic to provide a rational basis for allocating
NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's perfomance
in each functional area.
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An NRC SALP Board, composed of the staff menbers listed below, met on
February 23, 1990, to review the observations and data on perfomance and
to assess licensee perfomance in accordance with NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance." The guidance and
evaluation criteria are summarized in Section III of this report. The
Board's findings and recommendations were fomarded to the NRC Regional
Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance
at River Bend Station for the period October 1,1988, through December 31,
1989.
The SALP Board for River hnd Station was composed of:
S. J. Collins, Director, Division of Reactor Projects Region IV
L. J. Callan, Director, Division of Reactor Safety, Region IV
L. A. Yandell, Deputy Director, Division of Reactor Safety and
Sefeguards, Region IV
G. M. Holahan, Acting Director Division of P.eactor
Projects-III/IV/V & Special Projects, Office of Huclear Rector
Regulation (NRR)
G. L. Constable. Chief, Reacter Prcject Section C. Region IV
V. A. Paulfon, Project Manager, Pro.iect Directorate IV
E. J. Ford, Senior W.si6ent Inspector
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The fc11owing personnel also participated in the SALP Board
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meeting:
D. Murray, Chief Facilities Radiation Protection Section Region IV
D. A. Powers Chief, Security and Emergency Preparedness Section
I. Barnes, Chief, Materials and Quality Programs Section
J. E. Gagliardo, Chief, Operational Programs Section, Region IV
P. C. Wagner, Reactor Inspector, Region IV
W. B. Jones Resident Inspector
R. V. Azua, Project Engineer
A. B. Earnest, Physical Security Specialist
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II. SlWARY OF RESULTS
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Overview
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Strong managenent support for excellence continued to be evident during
this SALP period. The licensee has exhibited strong perfonnance in the
areas of operations, radiological controls, and emergency planning. The
operations department in particular responded in an excellent manner to
plant upsets and demonstrated a conservative safety attitude routinely as
well as during several plant evolutions.
Improved performance in security
was noted reflecting your upgrade initiatives and the emergency
preparedness program continued to be strong and effective.
The SALP Board concluded that there were areas where weaknesses were
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evident. At times the root cause analysis of events was not thorough.
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Procedure implementation problems in the area of maintenance / surveillance
were not identified and resolved at an appropriate level within the
organization. Engineering was not consistently responsive to developing
issues. Operator training appears to be a strength; however, training in
other areas such as engineering is weak.
Licensee management continued to emphasize safe plant operations as
evident by extensive involvement with a range of safety issues and
self-assessment activities conducted during the SALP period. The
identification of issues by the quality organization was effective, but
weaknesses were evident in followup activities and managenent support for
resolution.
The licensee's perfonnance is sumnari ed in the table below, along with
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the performance categories from the previous SALP evaluation period.
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Previous
Present
Performance
Perforinance
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Category
Category
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Functional Area
(04/01/87 to 09/30/88)
g/01/86to12/31/89)
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1.
Plant Operations
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Radiological Controls
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3.
Maintenance / Surveillance
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1
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5.
Security
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2
6.
Engineering / Technical
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Support
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Safety Assessment /
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2
Quality Verification
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III. CRITERIA
Licensee perfomance was assessed in seven selected functional areas.
Functional areas normally represent areas significant to nuclear safety
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and the environment.
The following evaluation criteria were used, as applicable, to assess each
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functional area:
A.
Assurance of quality, including management involvenent and
control;
B.
Approach to the resolution of technical issues from a safety
standpoint;
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C.
Responsiveness to NRC initiatives;
D.
Enforcement history;
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E.
Operational events (including response to, analyses of,
reporting of, and corrective actions for);
F.
Staffing (includingmanagement);and
G.
Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have been
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used where appropriate.
On tt.e basis of the NRC assessment, each functionti area evaluated is
rated according to three periemance categcries. The definitions of these
performance categories am as follows:
Category 1 - Licensee management attention and involvement are readily
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Wi2fent end place emphasis on superior performar.ce of nuclear snfety or
safeguards activities, with the resulting performance shstarticity
exceeding regulatory requirements. Licensee resources are 6mple and
effectively used so that a high level of plant and personnel performance
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is being achieved. Redu.:ed NRC attention may be appropriate.
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Category 2 - Licensee management attention to and involvement in the
perfomance of nuclear safety or safeguards activities is 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.
Category 3 - Licensee management attention 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
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meet minimal regulatory requirements. Licensee resources appear to be
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strained or not effectively used.
NRC attention should be increased above
nonnal levels.
IV. PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
The assessment of this area consisted chiefly of the control and
execution of activities directly related to operating the
plant, such as plant startup, power operation, plant shutdown,
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.and system lineups. Thus, it included activities such as
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monitoring and logging plant conditions, nonnal operations,
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response to transient and off-nonnal conditions, manipulating
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the mactor and auxiliary controls, plant-wide housekeeping,
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control room professionalism and interface with activities that
support operations.
This area was inspected by the resident inspectors and regional
inspectors. Specific areas inspected included operational
safety verifications, safety system walkdowns, followup on
significant events and problems and review of Licensee Event
Reports (LERs). During this assessment period, the licensee
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completed the second mfueling outage.
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The plant operating staff consists of 23 senior reactor
operators (SRO) and 15 reactor operators (RO).
Five crews are
presently used to operate the plant and a sixth crew is
scheduled to be activated in April 1990. Operations personnel
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have worked'significant evertime to support operational
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activities during outages and high vacation periods and to meet
training requirements such as fire brigade training. Previous
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efforts to inplement a sixth crew were planned; however,
attrition and support requirements for other activities did not
make this feasible.
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Most crews presently have an additional SR0 on shift above the
required shift compliment. This individual usually serves as
the plant operating foreman (P0F) who's duties are analogous to
those of the control operating foreman (C0F) except that the P0F
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is responsible for plant activities (instead of control room
activities). This allows the SR0 to gain additional experience
and to observe ongoing plant activities. Also, all crews have
at least one additional R0 on shift which helps each R0 to
remain familiar with plant equipment.
The inspectors noted on several occasions that operations
management and the plant manager were in the control room
observing normal shift activities and plant evolutions.
Plant
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management has also been observed on tours of the rest of the
plant. A code of conduct for reactor operators has been
docunented. Clerical support is provided for each shift which
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removed some the administrative burdens from the contml room
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operating staff.
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The licensee has been responsive to the arevious SALP period
reconnendations:
communications with otier departments,
attention to detail during snift tumovers and plant operations,
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configuration control, and procedural adequacy.
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Communications within the operations staff and with other groups
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1mproved considerably during this SALP period. Examples of this
included the chemistry department which was notified of plant
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transients that required sampling of the reactor coolant system.
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Health physics was also kept well infonned of plant transients
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because of the potential for changing radiological conditions.
The licensee established strict control over personnel access te
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the control room; this minimized disruptions of the operators.
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This was especially apparent during transient conditions.
During the refueling outage, congestion was limited in the
control room by setting up two work control areas away from the
main control area to process clearances and to authorize work
activities and testing. Reduced congestion in the main control
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room also resulted from the use of an extra C0F during the
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outage to process administrative items.
Licensee management has further reduced control room
distractions by originating energency preparedness drills and
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axercises from the plant specific simulator rather than using
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the actua' control room.
Two significant configuratian control measures added during this
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3 ALP period were the requireaients to document sLtety equipment
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status during shift turnovers and to verify proper control board
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lineup following manipulation of control switches. Control
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toord liraps were also conducted prior to entering hot shutdown
or startup from plant cold shutdown. During this SALP period,
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nu vahe lineup errors attributeble to oparations were noted.
The operator's attention to detail was apparent during several
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plant transients in which the operators responded in a
professional manner to maintain the reactor plant in a safe
configuration. This was demonstrated throug1 the proper use of
procedures and planning prior to assuming manual control of
systems. The operators responded quickly during several
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unexpected shutdown cooling system isolations to identify and
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correct the cause for the loss and reestablished shutdown
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cooling in a minimum of time. The operations staff also
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demonstrated the proper level of attention to detail necessary
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to safely and conservatively operate the plant. One such
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example occurred in May of 1989 when, prior to energizing a
large yard transformer, loads on the transfonner were minimized
and personnel in the affected switchgear room and in the vicinity
of the transfonner were moved to a safe distance. Upon
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energization, the transformer faulted and caught fire igniting a
nearby utility truck.
The precautions taken likely prevented
injury to personnel and minimized damage to equipment.
Although the licensee has demonstrated an increased awareness
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for attention to detail, continued emphasis in this area is
needed as evidenced by two incidents involving the improper
processing of clearances during this SALP period. One incident
was minor; the other was more serious and resulted in the
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unplanned loss of the Division I 125 Vdc bus.
During this SALP period, the facility had four automatic scrams.
Three scrams were attributable to equipment problems. The
fourth-scram was because of a generator load reject resulting
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from an off-site failure.
Finally, procedural adequacy and compliance improved
significantly during this SALP cycle. This is mostly the result
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of the procedures having been improved and implemented, however,
continued vigilance is needed to ensure that differing initial
plant conditions do not unexpectedly effect maintenance and
testing activities.
The licensees' limited efforts in the area of painting and
preservation have produced dramatic changes in those areas of
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the plant which have been completed. Overall plant housekeeping
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continues to be a strength.
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In sunmary, performance improvec: in this area. Operators
handled events well and improvements were made in areas
identified in the previous SALP as needing additional attention.
2.
Perfomance Rating
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The licensee is considered to be in performance Category 1 in
this functional area.
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3.
Reconmendations
a.
NRC Actions
NRC inspection effort in this area should be consistent
with the Core Inspection Program.
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b.
Licensee Actions
The licensee should continue to stress reducing dependence
on~ operator overtime throughout the upcoming assessment
period.
B.
Radiological Controls
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Analysis
The assessment of this functional area consisted of the
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reviewed activities directly related to radiological controls,
radioactive waste management, radiological effluent control and
monitoring, water chemistry controls, and transportation of
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radioactive materials.
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The radiation protection program was inspected twice by
region-based radiation specialist inspectors in addition to the
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inspections perfomed by resident inspectors. Licensee
identified violations reported on December 4,1988, involved the
failure to maintain locked doors into very high radiation areas.
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The second, on September 28, 1989, involved a worker entering a
very high radiation area in order to exit a work area.
In
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response, the licensee's corrective actions were extensive and
appropriate.
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Staffing for the radiation protection department was maintained
at a level to support routine plant operations. Several new
positions have been establithed and filled at both the
supervisor and technician levels. Contractor personnel are used
to supplement the licensee's staff during major outages.
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Radiation protection department represer,tatives routinely attend
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plant status meetings and are kept informed of current and
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planned plant activities.
Good working relations exist between
the radiation protection department and other departments, such
as operations and maintenance. The area of communication has
improved considerably since the previous SALP period.
Personnel
turnover rate was less than that noted in the previous
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assessment.
Technicians involved with evaluating planned work and providing
job coverage were knowledgeable of proper radiation protection
practices and exhibited a professional attitude while performing
assigned work. Foremen and first line supervisors provide
continuous review of technician work activities and also make
frequent plant tours to inspect work in progress. The lack of
good field supervision and critiques for poor work practices was
identified as a problem during the early part of the assessment
period; the licensee made improvements in this area throughout
the remainder of this assessment period.
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Quality assessment involvement with radiation protection
activities was evident in the performance of audits designed to
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ensure compliance with approved plant procedures. Audit
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effectiveness could be improved by expanding the scope to
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include comments on the adequacy of existing procedures or
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observations on needed improvements.
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A well defined training program has been implemented for
department personnel at the technician level. Records are
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. maintained on each technician to ensure scheduled training is
ccepleted. A plant systems course is included as part of the
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technician training program. Radiation protection department
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technicians have a good general knowledge of plant systems and
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particularly of those systems that could involve radiological
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problem 3.
Supervisors and professionals attend periodic
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training, but an organized training program had not been
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established to ensure they maintain expertise in their assigned
areas.
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The ALARA program exhibited strengths that included the
implementation of an excellent program to handle day-to-day
noteworthy involved the inservice inspection (ISI)particularly
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operational ALARA activities. Two jobs that were
of reactor
pressure vessel nozzles, performed inside the biological shield,
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and the undemater repair of a damaged sparger.
For both jobs,
the licensee demonstrated several ingenious ALARA techniques to
keep exposures below established goals.
Radiation levels in the drywell, steam tunnel, and auxiliary
building are generally higher than those found at other boiling
water reactor (BWR) facilities apparently the result of Cobalt-60
in the reactor coolant system. One of the biggest sources of
Cobalt-60 appeared to be stellite entering the reactor coolant
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system as the result of maintenance and component wear. The
licensee plans to provide training for maintenance personnel
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concerning the prevention of the introduction of additional
stellite into the reactor coolant system. An angineering
evaluation of the issues it. elso planned.
About 530 person-rem were incurred in 1989, as compared to the
established goal of 325 person-rem. The radiation levels
encountered during Refueling Outage No. 2 were double those
found during Refueling Outage No.1; however, the licensee's
ALARA program has functioned in an excellent manner when dealing
with these existing radiation problems. The licensee has
demonstrated the ability to implement effective operations ALARA
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techniques, such as the installation of temporary shielding and
mock-up training. The licensee also formed a Radiation Source
Term Task Force to investigate this problem and the committee's
findings were scheduled to be issued in February 1990.
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The radioactive waste management program was inspected once
during the assessment period. An effective liquid and gaseous
release permit program had been established to ensure proper
analyses were performed and controls were in place prior to
allowing a release. No 10 CFR 50.59 changes have been made to
the waste processing systems since the previous assessment. All
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offsite doses resulting from radioactive effluent releases were
well within Technical Specification limits. The staffing level
was considered adequate to handle radwaste activities. A fomal
training and qualification program had been established for
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radwaste personnel. Management oversight was evident in the
fom of quality assurance audits, including an audit team member
with technical expertise in the radwaste area. However, the
quality assurance operations surveillance involvement with the
radwaste program area was not well defined. No surveillance
reports could be found that would indicate that radwaste
activities are included in their reviews.
The water chemistry program was inspected once during the
assessment period. Water chemistry confimatory measurement
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results perfonned during this assessment indicated the licensee's
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results are considered to be within accepted industry perfomance
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levels. The licensee maintains state-of-the-art instrumentation,
and procedures reflect current analytical techniques. The
licensee has shown good perfomance in chemistry, but there is
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concern that the current personnel turnover rate could cause a
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decline in this area. Management oversight was evident by the
performance of comprehensive audits training, and qualification
programs which were considered appropriate to support plant
operations.
The radiochemistry program was inspected once during the
assessment period. The licensee continued to perform at an
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excellent level in the radiochemistry area. The licensee's
results indicated very good agreement for radiochemistry
confirmatory measurements perfomed during this assessment
period. These results reflect excellent radiochemistry quality
control and analytical procedures. The established staffing
level is considered adequate to handle this program area. A
formal training qualification program has been established.
The radiological environmental monitoring program wa . inspected
once during the assessment period. Minor problems were
identified concerning timely review of laboratory quality
control data and analytical results by appropriate supervision.
In addition, quality control charts for some instruments were
not maintained as recommended by program procedures. The
licensee demonstrated a good ability to measure radioactive
concentration in environmental samples; their confirmatory
measurements indicated 100 percent agreement with NRC and were
also in agreement with EPA Intercomparison Program results. The
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environmental sampling stations and meteorological
instrumentation were well maintained and operational. A well
equipped laboratory was maintained to provide the in-house
capability to analyze environmental samples. Environnental
reports were submitted on tine and contained the required
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infonnation.
Proper procedures have been established to address
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the collection, processing, and analyses of environmental
samples. The licensee's program was considered adequate in the
areas of staffing, training, and qualifications.
The radioactive material transportation program was inspected
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once during the assessment period. Violations were identified
during the last part of the previous SALP period but not
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dispositioned by NRC until this assessnent. The licensee
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performed a good root cause analysis regarding the
transportation problems. Shipping and packaging procedures have
been improved along with increased quality assurance oversight
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of transportation activities. No problems were identified in
the areas of staffing, training, and management involvement.
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In summary, the radiological control programs were effectively
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implemented and received strong management support at the River
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Bend Station. Although some problems were noted during this
assessnent period, improvements have been made in the
radiological controls area since the last assessment period.
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2.
Performance Rating
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The licensee is considered to be in Performance Category 1 in
this area.
3.
Reconnendations
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a.
NRC Actions
NRC inspection effort should be consistent with the
fundamental inspection program.
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Regionai initiative inspections should be performed in the
ALARA area.
b.
Licensee Actions
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Actions should be taken to evaluate Source Term Task Force
results and implement appropriate corrective actions.
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Maintenance / Surveillance
1.
Analysis
The assessment of this functional area included all activities
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associated with predictive, preventive, and corrective
maintenance; procurement, control, and storage of components,
including qualification controls; installation of plant
modifications; and maintenance of the plant physical condition.
It included conduct of.all surveillance, inservice inspection,
and testing activities.
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This area was inspected on a routine basis by the resident
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inspectors, periodically by regional inspectors, and by a
maintenance team inspection (MTI).
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There was strong evidence of management involvement in most
phases of the maintenance process, including prior planning with
the appropriate consideration for operational priorities in both
the maintenance and surveillance areas. Corporate policies were
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well defined, and clearly defined goals and objectives had been
established. The maintenance and support programs were
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generally strong. The plant manager took an active part in a
daily plan-of-the-day meeting held to discuss planned
maintenance and was actively involved in the decisionn.aking
process related to caintenance tetivities.
The last SALP report reccarcende.1 that licensee management ensure
that technically adequate proceduras are provided for each
maintanance and surveillance activity and that communicatiens
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among the disciplines be improved.
The licensee improved the technical adequacy of maintenance and,
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in particular, of surveillance procedures during the SALP
period. However, rumerous program implementation problems were
noted by the MTI. The problems included instances in which
craftsmen had not perfor:ned all of the steps required by a
maintenance procedure but had simply marked the steps "N/A"
(i.e., not applicable), multiple examples in which insufficient
instructions were provided in work plans, configuration controls
(tagging, lifted leads, etc.) that were poorly implemented,
craftsmen who had entered radiological controlled areas
improperly, instances where appropriate electrical safety was
not provided, and poor documentation of naintenance activities.
A loss of a freeze seal occurred because of an inadequate
procedure, and two loss of shutdown cooling events resulted from
inadequate procedure controls and an error in a reference
document.
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The maintenance team found that on many occasions the root cause
determination of safety system actuations had not been
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perform $d.
It was also evident that job specific planning was
weak because in many cases a job site evaluation had not been
perfonned. The maintenance planning guidelines were not
specific regarding the need for prework walkdowns and
postmaintenance reviews.
In the surveillance area, procedures
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were generally well written. One weakness was noted regarding
the tagging process for the containment' integrated leak rate
testing (CILRT) valve alignments in that the governing
procedures did not clearly require an independent verification.
However, no valves were found to be misaligned during the CILRT.
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The licensee's self-assessment process in the maintenance area
. was generally satisfactory.
Plant perfonnance data utilizing
the appropriate parameters were collected and tracked, but root
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cause and failure analyses were poor. The documentation systems
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(e.g., machinery history, equipment lists, NPRDS, and preventive
maintenance) that supported the licensee's self-assessment
efforts in this area were not fully developed.
The licensee has continued to improve conmunications between the
disciplines by providing a quarterly system outage schedule.
The draft of this schedule was presented to the different
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disciplines for conment. This ensured that all the disciplines
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were aware of upcoming system outages.
Management, however, had not provided sufficient oversight of
the maintenance process to assure that it was of fectively
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implemented at the craft level. This was especially true for the
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control of contract personnel.
Several events resulted during
the second refueling outage because of the inadequate control of
contract personnel. One event resulted in the partial loss of
offsite power.
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Personnel in the surveillence scheduling and testing area have
demonstrated a good understanding of technical issues. Although
improvement has been noted, continued management oversight is
needed to elimint.te missed or late surveillances.
In the maintenance area, the approach to the resolution of
technical issues was generally sound and thorough, but there
were a number of cases for which there appeared to be a lack of
depth or thoroughness. The weaknesses in performing critical
self-assessments in the maintenance area resulted in problems
not being identified until they became self-disclosing. The
number of ESF actuations attributed to human errors, a lack of
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procedure adherence, or procedural inadequacies has increased
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from 1988. The licensee's problems in this area were
exacerbated by the tendency to resolve problems at the job site
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rather than to forward them to management / engineering for a more
rigorous assessment of the problem. The maintenance inspection
team found many quality assurance findings reports (QAFRs) that
had been open for more than a year.
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The six violations identified in the maintenance area
collectively indicated a pattern of poor procedure adherence, a
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lack of attention to detail, and a failure to perfom appropriate
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prejob planning.
Staffing levels in the maintenance and
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surveillance areas appeared to be acceptable, although the
low staffing level in the mechanical maintenance area coupled
with the turnover rate resulted in a low experience level for
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this disci
The staffing level of the instrumentation and
controls (pline.IAC) planners presented a concern regarding the
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potential for significant becklog in maintenance planning. The
qualification levels of the maintenance staff were generally
good; however, several licensee systems engineers and planners
had received essentially no training in BWR systems.
Some
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knowledgeable contract system engineers were scheduled to be
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teminated in late 1990. The numerous errors in procedure
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adherence, attention to detail, and failure to rvview work
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activities did not appear to be a ruscit of a weakness in the
knowledge and skills of the maintenance staff and were more
likely a result of attitude or a lack of appreciation for
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management expectations in these areas.
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Review of the licensee's overtil 151 progrrm indicated that
management attention was evident in this area. This review.
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whicn incluhd both regional insp2ction and use of the NRC
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Mobile NDE Laboratcry, found the 151 program and t9plicchle NDE
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procedures to M satisfactorily implemented with a minor coner.rn
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poted in the area of cverview of ISI subcontactors.
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Inspection cf knevice testing (IST) activities has found the
overall IST program and irrplerentation to be in conforaance with
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ASME Section XI Code requirenents. One significant exception
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noted was the failure to establish a test program te assure that
two independent fuel buildirg ventilation charcoal filtration
subsystems and two independent main control room 61r handling
unit / filter train systems would perfom shtisfactorily in
service. As a result, the licensee failed to discover design
and installation flaws that would have prevented these
subsystems from operating as intended under certain design
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conditions.
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2.
Performance Rating
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The licensee is considered to be in Performance Category 2 in
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this functional area,
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3.
Reconenendations
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a.
NRC Actions
NRC inspection effort should be consistent with the
fundamental inspection program.
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Regional initiatives should be performed in this area to
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followup on weaknesses identified by the MTl and to review
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the licensee's corrective actions.
b.
Licensee Actions'
The licensee should assure that appropriate support and
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oversight of the activities in the maintenance and
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surveillance area is developed. Particular attention is
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required to address the root cause analysis process.
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D.
Drergency Preparedness
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1.
Analysis
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The assessment of this functional area included activities
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related to the establishment and implementation of the emergency
plan and implementing procedures, licensee performance during
exercise and actual events that test emergency plans, and
interactions with ensite and offsite emergency response
,
organizations during exercise and actual emnts.
During the atsassment period NRC kspectnrs and NRC contractor
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intpectors conducted two ow rgency preparedness inspections.
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One of these irwections consisted cf the cbservation and
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evaluction of the smal emergency resporst ewrcise. The.
licensee's performence during the March 1,1989, emergency
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en ecise was censidered to be adequate but below the performance
of the 1938 exercise due to a challenging and fast moving
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licensee developed scenarlo that greatly challenged the
licensee's performance. The licensee is to be consnended on the
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developnent of such a scenario. The major exercise weakness
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identified was the poor flow of infonnation between and within
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the control room and the technical support center. This
prevented an efficient coordination of response actions and
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interfered with command and control during the simulated
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emerge.1cy. Two other weaknesses identified during the exercise
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pertained to poor command and control exercised by the recovery
manager in the emergency operations f acility and failure to
follow a procedure that mandated a radiation protection
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technician to accompany an in-plant team. These weaknesses were
effectively corrected by the licensee during the course of the
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SALP period. The exercise weaknesses identified were not
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indicative of any progransnatic breakdown.
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The licensee's approach to resolution of exercise weaknesses
were technically sound and thorough and demonstrated a clear
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understanding and control of the issues.
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The emergency preparedness inspection of the operational status
identified no concerns or violations. The licensee provided'a
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newly revised set of energency action levels (EALs) in the new
revision of their emergency plan. Furthermore, the licensee has
undertaken an extensive initiative to further improve their
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emergency plan by a comprehensive review of EALs against the
guidelines of the NUMARC/NESP and NUREG-0654, Appendix 1.
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Three new staff positions were added to the emergency response
organization in order to improve the quality of their emergency
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response readiness and to prevent the recurrence of the
infomational flow weaknesses identified de; ring the March 1989
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exercise,
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A tvview of the independent audit program conducted by the
quality assurance departnent revealed that the scope and depth
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of the audit during this SALP period was enhanced by the use of
additional emergency preparedness expertise outside of the
licensee's organization. Comprehensive training interviews with
five emergency response teams showed that the overall
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perfomance of key emergency responders is the result of a
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strong corsnitnent to quality emergency training.
Managernent control and coraorate support of the emer5ency'
organization was er.cellent, and dec141onmaking was consistently
made at a level that ensured adequate maaageenent review. The
snell number of adverse !nspection findings and resonnsive
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corrective measures implenented show an effective approach to
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resolving programmatic weaknesses.
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The weaknesses at the beginning of the period were effectively
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addressed, and the licensee maintained a strong pr> gram to
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protect the health and safety of the public.
2.
Performance Pating
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Recorrrrendations
a.
NRC Actions
NRC inspection effort should be consistent with the core
inspection program.
b.
Licensee Actions
Maintain present level of management attention to
implementation of the emergency preparedness program.
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E.
Security
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1.
Analysis
This functional area includes all activities that ensure the
security of the plant, including all aspects of access control,
security background checks, safeguards information protection,
and fitness-for-duty activities and controls.
This functional area was routinely inspected by the resident
inspectors and on six occasions by region-based inspectors.
As 6 iesult of a management initiative in response to the
previous SALP, the licensee directed the development of a
security program improvenent plan. A plan was developed based
on GSU Audit 89-02-1-SECY dated March 2, 1989. The NRC staff
reviewed the plan during meetings with the licensee and during
onsite inspections.
Violations were noted that involve inadequate detection aids,
compensatory measures, and assessment aids that were identified
'
by the NRC staff.
In addition, the licensee reported violations
involving) inattentive or sleeping security officers (repeatand a failure by
violation
the security access control requirements. These violations do
not appear to have a common root cause and are not indicative of
a programmatic breakdown; however, increased oversight by
first-level security supervisors appears warranted.
The licensee completed upgrades of the perimeter detection and
assessnent aids systems during this assessnent period. Both
systems were greatly improved due to these upgrades; however,
some weaknesses were identified by the NRC late in the
assessrmnt period and the licensee has initiated corrective
actions.
During the assessment period, several personnel changes
occurred, including the security manager and his imnediate
supervisor. The size of the uniformed guard force remains
adequate. Shift supervision has not provided sufficient
oversight to ensure that some identified problems are quickly
corrected. The training program has improved since a new
training supervisor was hired, but more time is needed before
significant improvements in the performance of the uniforned
guard force is observed.
Licensee management has demonstrated support for the security
organization and has conunitted the necessary resources for
f acilities, equipnent, and staff. However, because of the
effort and time involved with responding to management
initiatives, the security manager is limited in his ability to
spend tine seeking, identifying, and correcting problem areas in
the program.
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_ The licensee's quality assurance program oversight of the
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' physical security proram is well organized and active. Three
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audits were conducted during the assessment period that
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identified numerous problems. The audits included experienced
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auditors and outside independent security expertise. The
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licensee has also generated a comprehensive list of improvement
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items related to the security program, and these items are being
tracked by the licensing and. quality assurance departments.
.The licensee has made progress in improving the security
program; however, additional efforts are warranted in order to
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enable the security staff to self-identify and correct problems.
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2.
Performance Rating
The-licensee is considered to be in Perfonnance Category 2 in
this functional area.
3.
Recommendations
E
a.
NRC Actions
A management meeting should be held with the licensee to
review the progress of implementation of the licensee's
security program improvement plan. NRC inspection effort
should be consistent with the fundamental inspection
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program. Regional initiative-inspections should be
conducted in the areas of records and reports, testing and
maintenance, compensatory measures, protected area physical
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barriers, assessment aids, protected area detection aids,
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and training.
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b.
Licensee Actions
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Licensee management should continue to provide strong
support to the security program. Mancgement should seek
ways to enable the physical security' program to gain the
initiative and become more proactive.
F.
Engineeejng and Technical Support
1.
Analysis
The purpose of this functional area is to address the adequacy
of technical and engineering support for all plant activities.
The assessment of this area included all licensee activities
associated with the design of plant modifications, engineering
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and technical support for operations, training, procurement of
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safety-related and commercial grade items, and vendor interface
activities.
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This functional area was inspected on an ongoing basis by the
resident inspectors and periodically by region-based inspectors.
In addition, a Vendor Inspection Branch team inspection was
performed.
The engineering and technical staff has. improved in-the area of
operational support.
Field and design engineer personnel have
become morn involved in the day-to-day resolutions of
operational events and problems. Good engineering support- had-
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been provided to the ALARA program.
Examples of good
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engineering. support include:
sponsoring the development of a
new rwactor water clean up (RWCU): pump seal (the present seals
have a chronic leakage problem); development of a vendor
approved feedwater nozzle " wet" welding procedure; and use of
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probabilistic risk assessment (PRA) studies to prioritize'
testing and work on various valves during outages. Engineering
also-provided PRA' data for managements' consideration of a
course of action following the loss of a preferred transformer.
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Two areas of declining performance were noted during this SALP
period involving procedural adherence and timely assessment of a
significant safety concern. The first area concerns work
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conducted outside the scope of the modifications request
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program. The second area concerned the lack of timely resolution
of instrument air system deficiencies.
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An inspection of engineering and technical support was conducted
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during this SALP period. This inspection concentrated on the
adequacy of the design engineering involved in correcting
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facility problenis and in implementing new requirements or
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improvements. The inspectors concluded that, although the
engineering program documentation had weaknesses, the existing
engineering implementation was acceptable,
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The inspectors' review of the engineering effort in response to
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the main steam isolation valve (MSIV) failures, caused by
sticking of solenoid operated valves, found the engineering
evaluations to be sound and well documented.
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An inspection of plant modifications was conducted during this
SALP period, which also identified problems with the
completeness of modification packages. The results of the
Vendor Inspection Branch team inspection indicatad a substandard
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program in the area of procurement and dedicatio; of commercial
grade items. This resulted in the utilization of numerous
components in safety-related applications for which quality and
qualification had not been determined.
Operator licensing training appears to be excellent based on the
success of-17 candidates who passed all portions of their NRC
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exams. The training of personnel in the surveillance and
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startup testing areas was adequate. Personnel in this area were
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fonnally certified to perform their assigned tasks.
Two inspections were performed during this SALP period which
addressed nonlicensed staff training._- These inspections
identified that existing procedural requirements for training of
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nonlicensed staff were not being fully implemented. While it is
recognized that initiatives are in progress to enhance the
._A
training program, additional management attention appears
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warranted with respect to establishment of specific interim.
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training requirements and administrative controls to assure
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implementation,
Training in the maintenance area appeared to be adequate, but
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the many performance errors in the maintenance area raise
questions regarding the effectiveness of the training in this
area.
It would appear that some of the procedure adherence and
attention-to-detail problems could have been prevented by a
stronger training ' effort which stresses the use/ adherence to
procedure.
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The training of the system engineers and maintena.. .e planners
was marginal and had contributed to a number of the errors
resulting from maintenance activities. There is no form <
training program for design engineers.
2.-
Perfonnance Rating
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Reconnendations
a.
NRC Actions
NRC inspection effort should be consistent with the
fundamental inspection program.
Regional initiative
inspections should include a team inspection to evaluate
more fully the engineering capabilities, including the
training and qualification of engineers.
b.
Licensee Actions
The licensee should evaluate the need for program
improvements, procedural guidance, and additional training
to ensure that designs and modifications are acceptable and
adequately documented.
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G.
Safety Assessment /0uality verification
1.
Analysis
The assessment of this functional area included all licensee
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review activities associated with the implementation of licensee
policies; licensee activities related to amendment, exemption,
and relief requests; and response to generic letters, bulletins,
and information notices. The assessment of this functional- area
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also included licensee activities related to resolution of
safety issues, 10 CFR 50.59 reviews, 10 CFR Part 21 assessments,
safety committee and self-assessment activities,' analyses of
industry's operational- experience, root cause analyses of plant
events, use of feedback from plant quality assurance / quality-
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control (QA/QC) reviews, and participation in self-improvement
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programs. The assessment included the effectiveness of the
licensee's quality verification function in identifying and
correcting substandard or anomalous performance, in identifying
precursors of potential problems, and in monitoring the overall
perfonnance of the plant.
This functional area was assessed on a continuing basis
throughout the SALP period by the resident inspectors and
regional-based inspectors.
The licensee's management continued to emphasize safe plant
operations. This was evident through the extensive management
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involvement with a range of safety issues during the SALP
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period.- During the second refueling outage, plant management
utilized a self-initiated probabilistic risk assessment in
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deciding not to restart the plant until a preferred station
transformer had been replaced, resulting in an additional 18-day
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forced outage. The study had concluded that there was a
decrease in overall plant capability to deal with a postulated
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LOCA. The preferred station transformer was not required .to be
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operable by the River Bend Station Technical Specifications. A
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second example involved the licensee's management decision to
delay a reactor startup to perform a 100 percent reverification
of safety-related valve position following the identification
,
that a valve was out of position on a control rod drive
4
hydraulic control unit.
During the assessment period, the licensee QA organization
- sponsored an internal safety system functional
inspection (SSFI). The SSFI was conducted on the instrument air
system (IAS) to determine if the system was installed, modified,
tested, operated, managed, and maintained in accordance with its
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original design basis. This inspection resulted in the
identification and subsequent resolution of several IAS safety
issues. The selection of the IAS as the subject of the SSFI
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demonstrated the licensee's desire to perform a meaningful
inspection because of;the problems that have been identified
with the IAS industry wide.
The licensee's QA engineers have identified several issues which
demonstrated substandard performance or were the precursors to
significant problems. Although QA management was informed of
each of the issues, their subsequent _ response did not always
reflect the independence and objectivity required to implement
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an effective QA program. The following two examples illustrate
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QA management's inadequate response to safety issues. During
the second refueling outage, several- clearance program-
violations were identified. These violations were aggressively
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pursued by the QA engineers, however the same aggressive pursuit
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was not demonstrated by QA management. Adequate corrective
actions to prevent: recurrence were not required by the QA-
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organization until after significant NRC staff involvement. The
second example involved QA management allowing modifications to
proceed on the control building instrument air system despite
the activity being in direct violation of the governing
procedure.
The licensee's QC efforts in the maintenance area were generally
acceptable. The QA audit and surveillance functions, however,
shou'id have identified many of the problems found by the
maintenance inspection team. A proactive QA effort should have
noted the declining trend in ESF actuations caused by
performance errors and urged a more thorough review and root
cause determination of the errors identified in this area. QA
also failed to take 'a more proactive aporoach to assuring that
QAFRs were closed in a timely manner.- The number of QAFRs that
were open for more than a-year indicates that QA management's
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attention was not adequately focused on the resolution of the
issues identified by the QAFRs.
The Vendor Inspection Branch team inspection identified that the
licensee had failed to perform timely evaluations of NRC
InformationNotices(ins). The Nuclear Licensing status showed
approximately 77 ins (for the 1984 to 1989 time frame) to be
outstanding / overdue, based upon no reply or closecut having been
received from the engineering group that was assigned the
responsibility for the evaluation.
The licensee's corrective action program, which was evaluated as
an excellent system in the last SALP cycle, was found generally
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-to be effectively implemented.
It was noted, however, that
evaluations of condition reports and certain quality audit
finding reports were not in-depth with respect to root cause.
Inspection of licensee self assessment activities identified
examples where facility changes had not received required
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. reviews by both the Nuclear Review Board and the Facility Review
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Committee. Activities of'the Facility Review Committee were
better documented than those of the Nuclear Review Board.
The Independent Safety Engineering Group was found to be an
organizational strength, with its activities covering a broad
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spectrum and its . reports generally being of high. quality.
2.
Performance Rating
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The licensee is considered to be in~ Performance Category 2 in this
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area,
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3.
Recomendations
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a.
NRC Actions
NRC inspection effort should be consistent with the fundamental
inspection program.
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Regional initiative inspections should be conducted in the areas
of quality assurance program implementation and self-assessment
capability,
b.
Licensee Actions
The licensee should evaluate the QA program to ensure it is
. performance based.
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
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1.
Major Outages
The second refueling outage was conducted from March 15, through
June 8, 1989. Activities performed included refueling, 18-month
surveillance-testing, containment integrated-leak rate testing,
and service water system inspection and repair.
The licensee entered into a forced outage on June 8, 1989, to
complete repairs on a preferred station transformer. This
outage was completed on June 23, 1989, when the licensee
synchronized- the main generator to the grid,
2.
License Amendments
During this assessment period, there were 11 operating license
amendments issued. Some of the more significant license
anendments were:
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= Revised Technical Specification to allow single
recirculation loop operation. - Amendment 31
DeletedLicenseCondition2.c.(4),' Attachment 2.ItemI
requirement to install an additional brace on the control
rod hydraulic units as used in the qualification testing. -
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Amendment 34
-Deferred the implementation of neutron flux monitoring
system modifications. - Amendment 39
3.
Significant Modifications
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Installed a system for monitoring reactor vessel level
using a- feedwater control system level transmitter.
Modifie( the spent fuel cooling system backwash tank design
to prevent contamination of the fuel building ventilations-
ductwork.
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Installed a 3/4-inch bottom pipe drain from the residual
heat removal' suppression pool ~ suction isolation valve.
Modified four fuel building ventilation dampers to' fail
open on loss of instrument air.-
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Provided keylock switches and indicating lights for
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emergency operating procedure performance.
Installed backup air bottles for the safety-related
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instrument air accumulators in the control and auxiliary
buildings.
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B.
Direct Inspection and Review Activities
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NRC inspection activity during this SALP cycle included 44
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inspections performed with approximately 4767 direct inspection hours
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expended.
'C.
Enforcement Activity
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The SALP Board reviewed the enforcement history for the period
October 1,1988, through December 31, 1989, tabulated in the enclosed
table. No civil penalties or orders were issued.
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TABLE
ENFORCEMENT ACTIVITY
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NO. OF VIOLATIONS
FUNCTIONAL
IN SEVERITY LEVEL
AREA ~
Weaknesses DEV
V
IV
III
II
A.
Plant Operations
2
9
B.
Radiological Controls
2
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C.
Maintenance / Surveillance
9
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D.
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E.
Security
7
F.
Engineering / Technical Support
2
G.
Safety Assessment /
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Quality Verification
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TOTAL
1
23
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' No civil penalty
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