ML20058D954
| ML20058D954 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 06/25/1982 |
| From: | Giesler C WISCONSIN PUBLIC SERVICE CORP. |
| To: | Hind J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20058D932 | List: |
| References | |
| CON-NRC-82-107 NUDOCS 8207270453 | |
| Download: ML20058D954 (25) | |
Text
ERC-82-107 WISCONSIN P U B LI C S ERVICE CORPORATIO N P.O. Box 1200, Green Bay, Wisconsin 54305 g g'A'"{.'3_S p
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June 25, 1982 Mr. J. A. Hind, Director Division of Emergency Preparedness and Operational Support Region Ill U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, IL 60137 Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunce Nuclear Power Plant SALP Report Comments
Reference:
Letter of June 10, 1982 from J. A. Hind (NRC) to E. R. Mathews (WPSC)
Thank you for the opportunity to meet with you and discuss the SALP report on June 17, 1982. As you know, we have endeavored to make the Kewaunee Nuclear Power Plant a safe, efficient plant. We believe we have achieved this, as indicated by our operating record and now your SALP report.
We appreciate your candid comments in respect to our operation and management of KNPP, and will continue to cooperate with you in the future.
In general, we have no comments on the report itself, with one minor exception:
On page 11, in the discussion regarding improvements made in our fire protection program, it is noted that in January of 1981 a Fire Protection Specialist was added to the plant staff.
While the staff position of Fire Protection Specialist was created in April, 1981, it was not filled until July, 1981. That individual subsequently resigned, and the position was filled again in Novembec, 1981. Additionally, the position of Fire Marshall was also established and filled in January of 1981.
Very truly yours, 0
C. W. Giesler Vice President - Nuclear Power js cc - Mr. Robert Nelson, US NRC 8207270453 820720 JUN 2 81982 PDR ADOCK 05000305 P
NRC-82-107 WISCONSIN PUBLIC SERVICE CORPORATION g
P.O. Box 1200, Green Bay, Wisconsin 54305 June 25, 1982 Mr. J. A. Hind, Director Division of Emergency Preparedness-and Operational Support Region III U. S. Nuclear Regulatory Commission 799 Roosevelt Road Glen Eliyn, IL 60137 Gentlemen:
Docket 50-305 Operating License DPR-43 Kewaunce Nuclear Power Plant SALP Report Comments
Reference:
Letter of June 10, 1982 from J. A. Hind (NRC) to E. R. Mathews (WPSC)
Thank you for the opportunity to meet with you and discuss the SALP report on June 17, 1982. As you know, we have endeavored to make the Kewaunee Nuclear Power Plant a safe, efficient plant. We believe we have achieved this, as indicated by our operating record and now your SALP report.
We appreciate your candid comments in respect to our operation and management of KNPP, and will continue to cooperate with you in the future.
1 In general, we have no comments on the report itself, with one minor exception:
On page 11, in the discussion regarding improvements made in our fire protection program, it is noted that in January of 1981 a Fire Protection Specialist was added to the plant staff.
While the staff position of Fire Protection Specialist was created in April, 1981, it was not filled until July, 1981. That individual subsequently resigned, and the position was filled again in November, 1981. Additionally, the position of Fire Marshall was also established and filled in January of 1981.
Very truly yours, ObS0u 1
C. W. Giesler Vice President - Nuclear Power js cc - Mr. Robert Nelson, US NRC JUN 2 B m2
I.
INTRODUCTION The NRC has established a program for the Systematic Assessment of Licensee Performance (SALP). The SALP is an integrated NRC Staff effort to collect available observations and data on a periodic basis and evaluate licensee performance based upon those observa-tions.
SALP is supplemental to normal regulatory processes used to insure compliance to the rules and regulations.
SALP is intended from a historical point to be sufficiently diagnostic to provide a rational basis: (1) for allocating future NRC regulatory resources, and (2) to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operation.
A NRC SALP Board, composed of managers and inspectors who are know-ledgeable of the licensee activities, met on June 3, 1982, to review the collection of performance observations and data to assess the licensee performance in selected functional areas.
This report is the SALP Board's assessment of the licensee safety performance at Wisconsin Public Service Corporation, Kewaunee Nuclear Power Plant for the seventeen month period from November 1, 1980, to March 31, 1982.
The results of the SALP Board assessments in the selected functional areas were presented to the licensee at a meeting held June 17, 1982.
1
II.
CRITERIA The licensee performance is assessed in selected functional areas depending whether the facility is in a construction, pre-operational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. Some functional areas may not be assessed because of little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observation.
One or more of the following evaluation criteria were used to assess each functional area:
1.
Management involvement in assuring quality.
2.
Approach to resolution of technical issues from safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Reporting and analysis of reportable events.
6.
Staffing (including management).
7.
Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categories. The defini-tion of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not ef fectively used such that minimally satisfactory performance with respect to operational safety or construction is being achieved.
2
III.
SUMMARY
OF RESULTS Functional Area Assessment Category 1 Category 2 Category 3 1.
Plant Operations X
2.
Radiological Controls X
3.
Maintenance X
4.
Surveillance and Inservice Testing X
5.
Fire Protection and Housekeeping X
6.
7.
Security and Safeguards X
8.
Refueling X
9.
Licensing Activities X
10.
Environmental Controls X
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IV.
PERFORMANCE ANALYSES 1.
Plant Operations a.
Analysis Operations Operation of the Kewaunee Nuclear Power Plant (KNPP) has historically been very reliable. As of March 31, 1982, the plant had an availability factor of 83.4% with a unit capacity factor of 77.6%.
Also, since startup following the 1981 refueling outage, the unit has accumulated a continuous on line period of 306 days. This record was attained as a result of several contributing factors, mainly; experienced and dedicated personnel; effective management involvement, plant and corporate, in all aspects of operations; cffective formulation and imple-mentation of preventative and corrective actions; and low failure rates of equipment.
Portions of fifteen inspections were performed by the resident inspectors in this area covering direct observation of activities, review of logs and records, verification of selected equipment lineup and operability, and followup of significant operating events to verify that facility opera-tions were in conformance with the Technical Specifications and administrative procedures.
Six noncompliances were identified:
both trains of safety-related service water valves to the component cooling heat exchangers out of service -
Severity Level IV, B residual heat removal pump taken out of service j
without demonstrating operability of the redundant pump - Severity Level V, l
failure to follow procedures resulted in a release l
inside containment from the safety injection accumulator -
Severity Level V, failure to report unplanned release of radioactive gas - Severity Level V, l
failure to properly review a modification - Severity l
Level V, and 1
inadequate log keeping - Severity Level VI.
There were no apparent trends associated with the noncom-pliances. The licensee has demonstrated proper action to l
prevent recurrence.
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Four reportable events occurred, two of which were the subject of noncompliances shown above, that were the result of operating personnel errors during the seventeen month assessment period. This frequency is approximately average i
for Region III operating units. Corrective action appeared timely and adequate.
There were only three automatic reactor trips, all due to random equipment failure, and one manual trip, initiated because of an unusual noise emanating from a turbine shaft coupling. This scram frequency is quite low in comparison to industry experience and helped achieve an unscheduled off-line time for'the unit of less than 0.5% of plant j
availability.
The Performance Appraisal Section (PAS) performed an in-spection of management controls in support of nuclear safety on December 7-18, 1981. Their rating, while mentioning both strengths and weaknesses, was Category 1 overall for Plant Operations.
Training The Senior Resident Inspector (SRI) made one inspection in this area in response to a potential enforcement finding by the Performance Appraisal Section. The potential finding was related to possible false statements made in applications for renewal of operator licenses. The f,indings by the SRI indicated that false statements had not been made in the applications.
l The PAS inspection team rated both licensed and non-licensed training Category 3.
Observations made by the resident inspectors since the PAS Inspection indicate that the following improvements have been made or are in the process of being made to the training organization:
(a) authorization of nine new positions to the training
- staff, (b) development of administrative directives, programs, and training guides for various job classifications, (c) procurement of word processing equipment to aid in timely development and upgrading of training materials, (d) removal of collateral duties from the Supervisor of
- Training, l
(e) addition of facilities to schedule training on an l
annual basis, including a computer program using an i
installed computer terminal in the training facility, i
and 5
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(f) reorganization of the training record system to aid in proper training documentation.
In' summary it appears that corporate management has taken effective and vigorous actions to upgrade the training program since the PAS Inspection.
Administrative One item of noncompliance was noted in this area. Failure to maintain a current revision list for procedures - Severity Level VI.
Subsequent to the noncompliance, the licensee increased the clerical staff and procured word processing equipment to aid in maintaining updated procedures.
b.
Conclusion The licensee is rated Category 1 in this area primarily because of the excellent performance noted in the operations area which is attributable to aggressive and effective management, experienced and dedicated personnel, a low personnel turnover rate, and the effective maintenance of equipment operability. The particularly low reactor scram frequency during the period reflects a minimal challenge rate to plant safety systems and is an indication of superior per-formance. The number of noncompliances was more than normal for Category 1 performance, but they were not considered significant enough to override the positive attributes in assigning Category 1.
c.
Board Recommendations The Board recommends reduced inspection effort generally in this area.
Inspection of training, however, should not-be reduced until the effectiveness of improvements noted during the assessment period is verified.
2.
Radiological Controls a.
Analysis i
l Radiation Protection and Radwaste Management l
A Health Physics Appraisal (HPA) followup inspection and a
[
refueling radiation protection inspection were performed j
during the evaluation period by the region based inspectors.
The resident inspectors also inspected in this area. One l
Item of noncompliance for failure to post a high radiation l-area was found (Severity Level IV). The item was non-repetitive and did not indicate a programmatic weakness.
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A Performance Appraisal Section (PAS) inspection was con-ducted during the evaluation period. The PAS Inspection rated licensee management controls in this area as Category 2 and indicated that the licensee had effective personal exposure and radwaste controls but had weaknesses in formalization and audit of program activities.
During the SALP period, the licensee has improved their Health Physics Program, including:
creating a position for a university trained IIP; increasing the health physics technician staff; creating a radiation helper group; hiring a corporate health physicist; strengthening the health physics technician training program; developing procedures for the respiratory program; increasing the number of portable monitoring instruments; and improving facilities.
Licensee personal exposures were among the lowest in the nuclear power industry. Gaseous radioactive effluents and solid radwaste shipment volume during this SALP period were significantly below the average for PWRs.
Liquid radio-active effluents were slightly below the average for PWRs.
No problems were identified with radioactive material shipments.
The licensee's management involvement, resolution of technical issues, and personnel qualifications remained very good in this area during this SALP period. These program characteristics are credited with the licensee's good radioactive effluent and personal exposurn statistics.
b.
Conclusion The licensee is rated Category 1 in this area based on good enforcement history, low personal doses and radioactive effluents, and management's commitment to the Radiation Protection Program.
c.
Board Recommendations The Board notes that the licensee was rated above average in the previous SALP evaluation.
A reduced inspection program should be considered based on the licensen's performance in this area.
3.
Maintenance a.
Analysis Two inspections in this area were performed by region based inspectors. One resulted in finding one item of noncompliance (Severity Level V) with four examples of inadequate QA record keeping. Maintenance procedures contained insufficient detail to ensure material traceability or to document post maintenance 7
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4 testing, the evaluation of cause, or corrective actions. The licensee has proposed improvements which will be evaluated by inspection at a later date. The other inspection was a followup to a previous QA Inspection. Previous noncompliances were closed; one item remained open; no new noncompliances were identified.
4 A PAS Inspection during the assessment period rated main-tenance in Category 2 and indicated the licensee has an adequate maintenance program but with areas needing 3
improvement. As stated in the inspection report, there was a " lack of instructions for QC inspectors to document problems or deficiencies observed during inspections.
Other weaknesses existed in QC inspector qualification certification and the failure to effectively use machinery history information."
Portions of fifteen inspections by the resident inspectors were performed in this area including such activities as the observation of maintenance; compliance with procedures, industry codes, Plant Technical Specifications, etc. ; the use of qualified personnel; the use of properly certified parts and materials; adherence to radiological and fire protection controls; and other areas closely related to I
maintenance activities. No items of noncompliance were identified.
Strengths were noted by the inspectors in the high quality of workmanship and supervision in the performance of both corrective and preventative maintenance. This high quality l
is in spite of other shortcomings in the formality of docu-mentation, etc., and is a big factor on the plants high reliability and availability noted in IV.
1.,
Plant Operations, Analysis.
b.
Conclusion The licensee is rated Category 1 in this area as a result of the effectiveness of its mechanics and supervisors in performing high quality maintenance, which is required for the good operating experience and low scram frequency dis-cussed in Section IV., Item 1., and, because of the lack of significant plant problems identified as related to maintenance, the low number of noncompliances, and the positive attributes in the maintenance area identified in the refueling evaluation,Section IV., Item 8.
c.
Board Recommendations While assigning Category 1, the Board concurs with previous findings that the licensee needs to pursue improvements in the formalization and documentation of the maintenance l
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r program. The Board particularly recommends that they implement a failure trending system.for the early detection and correction of undesirable equipment failure patterns.
4.
Surveillance and Inservice Testing a.
Analysis A total of five inspections were conducted by region based inspectors in the surveillance area.
In the areas of core physics and reactor coolant system leakage determination, records were generally complete and available, activities were conducted in accordance with Technical Specifications and plant procedures.
In the area of calibration and in-service inspection the program appeared to be adequately implemented. No items of noncompliance were identified.
Portions of fifteen inspections were conducted by the resident inspectors in this area covering direct observation of activi-ties, verification that testing was performed in accordance with adequate procedures, that test instrumentation was calibrated, that limiting conditions for operation were met, that removal and restoration of the affected components were accomplished, that test results conformed with Technical Specifications and procedure requirements and were reviewed by personnel other than the individual directing the test, and that any deficiencies identified during the testing were properly reviewed and resolved by appropriate management per-sonnel. One item of noncompliance was identified for failure to test the auxiliary feedwater pumps in the required time frame - Severity Level IV.
This noncompliance resulted from inadequate programmatic oversight and attention to detail. Management has subse-quently consolidated the responsibility for administration of testing per ASME Code Section XI, Pumps and Valves, to one individual. This action appears to have improved the viability of the testing program.
b.
Conclusion The licensee is rated Category 2 in this area. No significant strengths or wer.knesses were noted.
c.
Board Recommendations None.
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5.
Fire Protection and IIousekeeping a.
Analysis Fire Protection One inspection in October 1980 involving thirty-one inspector hours was performed by the regional inspection staff during this evaluation period. Seven potential noncompliances were identified during the inspection but, due to a subsequent temporary rule change, only one noncompliance was cited when the report was issued. The inspection findings are discussed below:
(1) The licensee violated the ignition source control procedure by not properly documenting fire watch requirements on the hot work permit - Severity Level V.
(2) The following violations of License Amendment No. 23 were observed during this inspection:
(Temporary rule 10 CFR 50.48 temporarily suspended the compliance dates associated with this license amendment which removed the regulatory basis for an item of noncompliance.)
(a) The licensee had not implemented the smoking controls required in the license.
(b) The licensee had not implemented the controls over combustible materials required in the license.
(c) The licensee was not conducting a fire brigade training program in accordance with license requirements.
(d) The licensee had not developed fire fighting strategies or preplans as required in the license.
(e) The licensee was not controlling the position of critical fire water system valves as specified in the license.
(f) The licensee was not training contractors in plant l
fire protection practices in accordance with the license.
The underlying cause for these findings was a lack of management attention to and control over the Fire Pro-tection Program.
Since the fire protection inspection in 1980, observations by the resident inspectors during their routine inspection activities indicated that substantial improvements had been 10
implemented and a more positive attitude by management was evident.
Some of the observed improvements are as follows:
Fire Protection Specialist was added to the plant staff with sole responsibility for implementation of the facility Fire Protection Program.
Previously, this responsibility had been a collateral duty of the Training Supervisor.
Administrative Control Directives which address plant fire protection organization, fire emergency response, combustible materials controls, control of ignition sources, and fire brigade / fire team training were upgraded.
Thirty additional MSA respirators and fifty additional MSA air tanks were purchased.
Fusible link automatic door closures were installed on approximately 14 doors.
Technical Support Procedures which addressed fire extinguisher and fire door inspection were developed.
A requirement was initiated that all maintenance work requests be reviewed by the Fire Marshall to identify potential fire protection problems.
Additional flammable materials storage cabinets were placed throughout the facility.
The fire retardant, wooden structure used as a tool crib in the auxiliary building was replaced with an all metal facility.
Procedural requirements were initiated to hydrostatically test all fire hoses at 250 psig which exceeds the Technical Specification requirement of 160 psig.
Housekeeping No housekeeping problems were noted by the resident inspec-tars during the assessment period. The PAS inspection team members noted in the " Executive Summary" of their inspection report that "The inspection team members were impressed with the cleanliness maintained at the Kewaunee Station.
It was obvious that management and staff took pride in the general appearance of the facility."
b.
Conclusion The licensee is rated Category 2 in this area based on improvements made by the licensee subsequent to the fire 11
protection inspection performed early in the assessment period.
c.
Board Recommendations The Board recommends that fire protection inspections continue as scheduled with particular emphasis during the next inspection on verifying the adequacy of improvements made to meet the plant fire protection requirements.
6.
Analysis Emergency Preparedness activities at the Kewaunee Nuclear Power Plant site were observed during the Emergency Prepared-ness Implementation Appraisal (EPIA), the followup inspection to this Appraisal, the licensee's emergency preparedness exercise, and in a special inspection of the early warning system.
Early in the SALP period, the NRC review of the licensee's emergency plan submitted in January 1981 showed several significant problems that;were discussed in a meeting on April 6, 1981, with the licensee.
During the EPIA, the NRC identified thirty-one deficiencies transmitted as Appendix A to the EPIA report, eight deficiencies transmitted in an Immediate Action Letter (IAL) dated June 22, 1981, and one item of noncompliance. A followup inspection conducted October 14-16, 1981, showed that all Immediate Action Letter items had been satisfactorily completed. Acceptable progress had been made or completed on all issues. The licensee hired a contractor to help upgrade the level of emergency prepared-ness and appears to have been successful as demonstrated by the licensee's small scale exercise conducted on February 23, 1982. This exercise demonstrated significant improvements in the 1cvel of training and overall preparedness. The critique for this exercise resulted in only minor comments for improvement of the implementing procedures. The staff and management of Wisconsin Public Service Company has aggressively improved their emergency preparedness program since the EPIA and it appears that they have systematically resolved the deficiencies and have been responsive to NRC initiatives identified as a result of the EPIA.
Management staffing appears to be acceptable at the Kewaunee site with good support in emergency preparedness from the Corporate Offices. The licensee has committed to implement-ing NUREG-0654, Table B-1, Staffing, but at present does not meet the guidance. The licensee has demonstrated timely augmentation during offshift hours through a system using pagers.
Training effectiveness and qualification was an item addressed in the Immediate Action Letter resulting from the EPIA. The emergency preparedness inspection conducted to 12
followup on tue Immediate Action Letter licensee response and the inspection of the 1982 emergency preparedness exercise indicated that their tr'aining progress has been effective.
The inspection of the licensee's early warning system showed that it was installed and tested prior to February 1, 1982, as required. All deficiencies were corrected subsequent to the inspection.
b.
Conclusion The licensee is rated Category 2 in this area. The trend exhibited by the licensee with cooperativeness and performance indicates significant improvement in the program during the SALP period, c.
Board Recommendations None.
7.
Security and Safeguards a.
Analysis Three physical security inspections have been conducted by region based inspectors during the evaluation period. The resident inspectors made periodic tours of accessible pro-tected and vital areas. Four noncompliances were identified during this evaluation period. The noncompliances were:
(1) A Severity Level V violation for failure to search some packages entering the protected area.
(2) A Severity Level V violation for failure to properly display photo-identification badges within the protected area.
(3) A Severity Level IV violation for failure to establish contingency procedures and conduct associated training.
(4) A Severity Level V violation for failure to properly control a vital area portal.
The absence of implementing procedures four months after the Contingency Plan's approval by the NRC, and the apparent lack l
of enforcecent regarding the security badge requirement within the protected area were indicative of a-lack of management at-l tention in the security area. The licensee's corrective actions l
regarding the noncompliances were responsive. Followup inspections will be conducted to review these matters.
Site supervision of the security force is adequate for effective day-to-day security operations. Communications between site and corporate security appear to be effective.
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s The major Safeguards tasks facing the licensee are the full implementation of the Security Force and Qualification Plan, and the protection of Safeguards information in accordance with 10 CFR 73.21.
The licensee response to NRC identified noncompliances has been timely. The few longstanding issues (compensatory measures in the event of a computer failure, and security equipment) have been resolved during the evaluation period.
The initial training and qualification program contributed to an adequate understanding of work and adherence to procedures with a modest number of personnel errors. The licensee lacks a formal retraining program. The licensee has acknowledged this problem and has committed to the development of such a program.
b.
Conclusion The licensee is rated Category 2 in this area. The licensee's programs exhibited no significant strengths or weaknesses.
c.
Board Recommendatf or_s s_
NRC attention should be maintained at normal levels.
8.
Refueling a.
Analysis One refueling outage inspection was conducted by region based inspectors during the evaluation period. No items of noncompliance were identified.
However, the inspectors did have concerns with control of other unrelated work in progress near the open refueling pool with respect to loose parts accountability. The licensee satisfactorily addressed these concerns.
Fuel handling and other refueling related activities were found to be conducted in accordance with the Technical Specifications and the licensee's procedures.
Licensee management attention and involvement was acceptable and concerned with nuclear safety. Satisfactory performance was achieved with respect to operational safety.
I Observations by the resident inspectors during the refueling outage indicated effective and efficient performance in accomplishing maintenance and modification activities. The licensee utilizes a 35 foot logging board which is setup prior to the outage and indicates all scheduled activities.
The board is maintained current and all activities coordinated by the Maintenance Superintendent during the dayshifts and by an assistant on the backshift. Meetings are held twice daily by the Plant Manager with all key plant and contractor personnel to keep everyone cognizant of activities and to insure effective control of the outage.
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The resident inspectors also observed the refueling activities
'during the outage which were performed by an experienced con-tractor under the direct supervision of licensee personnel.
The inspectors noted that detailed written procedures were strictly adhered to unless a deviation was necessary. Then, any deviation was properly considered and well documented.
Maintenance and operational checkout of the refueling equip-ment was completed prior to use and the refueling contractor per.sonnel were closely supervised by the licensee. No fuel handling incidents occurred during the outage and the entire process from plant cooldown to restart was well controlled and efficiently handled.
b.
Conclusion The licensee is rated Category 1 in this area.
c.
Board Recommendations None.
9.
Licensing Activities a.
Analysis The licensee's performance evaluation is based on a con-sideration of seven attributes, as discussed below, in relation to the following licensing activities:
Responses to NUREG-0737 items Appendix R activities Core reload and fuel performance Degraded grid voltage Auxiliary feedwater system evaluations Administrative controls Environmental Technical Specification changes Power distribution Heavy loads Rod misalignment (1) Management Involvement and Control in Assuring Quality The supervisor of Nuclear Systems at Kewaunee is also the supervisor of Nuclear Licensing so that authorative, capable and direct responses on all licensing issues are obtained.
(2) Approach to Resolution of Technical Issues from a Safety Standpoint There is a clear understanding of the technical and legal issues involved. Conservatism is generally exhibited in 15
design and installation. During consideration of operation, there is an acceptable position of meeting only the minimum requirements.
(3) Responsiveness to NRC Initiatives An Enforcement Conference was held on April 23, 1981, to discuss the licensee's inadequate response to a September 19, 1980, Generic Order requiring a complete response to IE Bulletin No.79-01B on the environmental qualification of safety-related equipment. A Severity Level IV noncompliance was cited as a result of the meeting. Corrective action has since been noted and the licensee's responses are now timely and complete.
Technically sound responses are provided based primarily on the licensing bases for the plant and additional re-quirements from NRC. The licensee will not, in general, submit to proscriptive requirements when they perceive that alternate resolutions are more resource effective, indicating a sense of responsibility on their part.
(4) Staffing (Including Management)
The corporation has moved rapidly to appoint key people in recognition of earlier situations in which deficiencies were revealed. Additional supporting staff are also evident the current status is very good.
Responsibilities are well defined as evidenced from interface meetings on a variety of disparate subjects.
(5) Training and Qualification Effectiveness The substantive effectiveness of the training require-ments of the NUREG-0737 items is apparent in all licensing contact activities. The current status is very good.
i b.
Conclusion l
The licensee is rated Category 2 in this area based on I
generally very good performance with some areas noted as adequate or needing improvement during the assessment period.
c.
Board Recommendations The continuation of improvements in this area should result in a Category 1 performance evaluation during the next assessment period.
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b 10.
Environmental Controls a.
Analysis Three inspections were performed during this appraisal period (50-305/81-04; 50-305/81-26; and 50-305/82-08).
In the Confirmatory Measurements Program, the licensee achieved fourteen agreements or possible agreements out of seventeen comparisons during the March 1981, inspection.
In the three disagreements, the licensee overestimated the activity on a Region III supplied National Bureau of Standards (SBS) trace-able spiked filter. Following the inspection, the licensee recalibrated their analyzer system for the air particulate filter geometry and submitted new values for the spiked filter. The new values were in agreement with the NRC values except at the Y-88 energy of 1836 kev. The licensee's efficiency at that energy had been obtained by extrapolation from points at lower energies using a number of discrete energy point sources. The error at 1836 kev was ascribed to uncertainties in the extrapolation. As an interim measure, the licensee agreed to use an efficiency based on the Region III NBS traceable spike until he obtained a new extended geometry source and recalibrated his system for air particulates. This was accomplished before the March 1982, inspection.
In the March 1982, sample split, the licensee had improved his performance by obtaining thirteen agreements or possible agreements out of fourteen comparisons. The one disagreement involved overquantification of I-131 on a charcos1 adsorber.
The licensee has had an ongoing problem in underquantifying Cs-137 at 662 kev in liquid samples in the presence of Ag-110m at 657 kev. The peak fitting routine associated with his l
current analyzer system apparently fails to accurately resolve the composite peak. The licensee is planning to purchase a new analyzer with more sophisticated peak fitting capability by the fall of 1982.
The licensee has improved his chemistry and radiochemistry program of analytical measurements by instituting a training program for all laboratory technicians; by introducing new standard sources for calibration of counting equipment; and by planning to upgrade his analytical capability by purchasing a new gamma spectroscopy system.
In the area of the radiological environmental monitoring program, performed under contract by Hazleton Environmental Sciences Corporation, the licensee has upgraded his air monitoring program during 1982 by purchasing all new air samplers. The inspector's review of records showed all samples were accounted for and appropriate analyses conducted. Results showed three incidences of elevated l
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tritium levels in water samples collected at the discharge and one area, Two Creeks Park, midway between Kewaunee and Point Beach Plants. Concentrations were 1% or less of regulatory requirements for unrestricted areas. Trace amounts of Co-58, Co-60, and Cs-137 were also found in sediment and aquatic biological sampics. These results are typical for a facility of this type.
The licensee's contractor performs a good QA program.
Corrective actions on open items found from the licensee's internal audit on the REMP and also the licensee's chemistry program were timely, b.
Conclusion The licensee is rated Category 2 in this area.
c.
Board Recommendations Normal inspection activity should be continued.
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V.
SUPPORTING DATA AND SUMMARIES A.
Noncompliance Data Facility Name: Kewaunee Nuclear Power Plant Docket No. 50-305 Inspection Reports:
No. 80-24 through 80-25*
No. 80-27 through 80-30 No. 81-01 through 81-27 No. 82-01 through 82-08 Noncompliances Severity Levels Functional Area Assessment I
II III IV V VI 1.
Plant Operations 1
4 2
2.
Radiological Controls 1
3.
Maintenance 1
4.
Surveillance and Inservice Testing 1
5.
Fire Protection and Housekeeping 1
6.
7.
Security and Safeguards 1
3 8.
Refueling 9.
Licensing Activities 1
- 10. Environmental Controls TOTALS 5
10 2
- Inspection Report No. 80-26 was covered in SALP 1.
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B.
Licensee Report Data LER Reports - Kewaunee Assessment Periods 1 and 2*
(17 Months)
Proximate Cause**
11/01/79 - 10/31/80 11/01/80 - 03/31/82 Personnel Error 6 (0.5)***
12 (0.7)***
Design, Manufacturing 3 (0.3) 3 (0.2) and Construction /
Installation External Cause 1 (0.1) 0 Defective Procedure 0
2 (0.1)
Component Failure 16 (1.3) 21 (1.2)
Other 10 (0.8) 14 (0.8)
TOTALS 36 (3.0) 52 (3.1)
- The LER numbers for Period 2 include 80-36 and 80-39 through 82-06.
- Proximate cause is the cause assigned by the licensee according to NUREG-0161, " Instructions for Preparation of Data Entry Sheets for Licensee Event Report (LER) File."
- Numbers in parentheses are number of events per month.
Summary LER Evaluation Comparing SALP 1 (12 months) with SALP 2 (17 months) indicates there was essentially no change in the rate of occurrences. The major contributor to the increase of personnel errors were five errors by the chemistry group. While the errors were of minor significance, observations by the resident inspectors indicated an apparent need for improved management controls in this area.
The three events concerning overload tripping of the boric acid pumps indicates inadequate followup on determining the cause of l
the initial event. Licensee corrective actions showed insufficient f
heat tracing and insulation to have been the root cause. This was l
not recognized until after repeated failures.
As a result of repeated failures of the shield building ventila-tion system a design change request was initiated. The inspector noted that it had been assigned a relatively low priority, and expressed his concern to the licensee.
In response to the concern, the licensee has assigned a more appropriate priority to the design change request.
l l
Part 21 Report l
On November 20, 1980, the licensee submitted a Part 21 Report relative to installed bullet resistant fire doors. The licensee i
j requested documentation from the door manufacturer that the doors i
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had satisfactorily passed fire testing, which had been approved by l
a nationally recognized laboratory. To date, the manufacturer has not supplied the requested data. The licensee did initiate and
}
is continuing compensatory measures for degraded fire protection as required by their Technical Specifications.
C.
Licensee Activities 4
During the appraisal period, KNPP was on-line a total of 476 days out of a scheduled 483 days, included mostly in this period was a J
j continuous on-line run of 306 days. Of special note is that since commercial operation (June 16, 1974) the KNPP has not experienced any detectable reactor coolant to steam generator leakage.
Four trips occurred during the evaluation period, all trips were precipitated by equipment failure / malfunction. No safety limits were exceeded and all safety related equipment operated as required.
During the appraisal period, the licensee completed the Cycle VI-VII refueling outage.
Some of the more significant plant initiated modifications included:
A new low pressure turbine rotor was installed in LP-2 cylinder location to allow for refurbishment of the orginal LP-2 rotor.
Control circuitry for the safeguards diesel generator start system was modified to provide for more comprehensive testing and increased reliability. The modification was completed on the 1A diesel and will be completed on 1B during the 1982 refueling.
i Refrigerant type air dryers were installed in the safeguards diesel starting air system.
Safeguards power was supplied to all Gaitronics telephones.
There is an ongoing program to upgrade the boric acio heat tracing circuits Throughout the appraisal period the license'e pursued IE Bulletin work, fire protection modifications, and TM1 Action Items completion.
D.
Inspection Activities During the evaluation period, the resident inspectors performed 15 routine safety inspections and one special inspection.
Region based l
inspections performed 23 inspections in specialized areas.
l These inspections consisted of a selective examination of procedures and records, and observations and personnel inter-views in the areas of safety systems operability, routine plant operations, surveillance testing, maintenance, refueling 21 l
e activities, plant modifications, licensee actions concerning identified problems, licensee response to NRC requests and directives, off-normal operating conditions, health physics, emergency planning, quality assurance, radioactive material j
packaging and transport, and security and safeguards. The resident inspectors performed the primary inspection effort in all of these areas except health physics, emergency planning, quality assurance, and security and safeguards.
Inspection in these areas was primarily performed by the regional inspection specialists with support from the resident inspectors.
The above inspection effort involved approximately 4700 inspector-t hours. A total of 17 items of noncompliance were identified.
In addition to the above, two major " team" inspections were accomplished:
Performance Appraisal Section (PAS) - 522 inspector-hours; and Emergency Preparedness - 567 inspector-hours.
The Emergency Preparedness inspection findings are discussed in Section IV, Item 6.
A summary account of the PAS Inspection is below.
(Note that performance categories given by the PAS are defined exactly as those for the SALP performance categories in Section II of this report.)
Excerpt from the 12/81-1/82 PAS Inspection Report, Appendix A, Executive Summary:
"A team of six Inspection Specialists from the Performance Appraisal Section conducted an announced inspection at the Kewaunee Plant and the Wisconsin Public Service Corporation corporate office during December 7-18, 1981, and January 5-8, 1982. The management controls in nine areas were evaluated, and each area was classified into one of three performance categories: Category 1, Category 2, or Category 3.
Of i
the nine areas evaluated, the management controls for the area of Plant Operations were classified as Category 1, four areas were classified as Category 2, and four areas were classified as Category 3.
The inspection team members were impressed with the cleanliness maintained at the Kewaunce Station.
It was obvious that manage-1 ment and staff took pride in the general appearance of the facility. The Kewaunee staff appeared to be well qualified with l
a very low turnover rate.
Staff members interfaced with each l
other and were highly motivated.
One significant weakness identified in the management controls that was evident, to some extent, in all areas evaluated was the lack of written procedures describing the performance of staff activities and responsibilities. For the most part, the performance of the activities was not questioned, only the informality."
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The Category 3 items in the PAS Inspection were Quality Assurance Audits, Corrective Action Systems, Licensed Training, and Non-Licensed Training. The key to any perceived differences between ratings by the SALP Board and the PAS Inspection Team is in the approach of the two different groups. PAS emphasizes management controls and formal programs while SALP looks at actual perform-ance.
(The emphasis by the PAS is indicated by the last sentence on the above quote from the PAS Report.) These differences do not minimize findings by the PAS but, rather, emphasize strengths in the experience and capability of the Kewaunee staff in actual performance of their duties.
E.
Investigations and Allegations Review 1An investigation was conducted into a possible material false statement regarding completion of fire prevention measures.
An apparent incorrect statement was identified as being made because of misunderstandings by the licensee personnel in communicating with the NRC. No materially false statement was.
Identified.
F.
Escalated Enforcement Actions An Immediate Action Letter was issued on June 22, 1981, to correct deficiencies identified during the Emergency Preparedness appraisal.
This is also discussed in Section IV, Item 6, Emargency Preparedness.
G.
Management Conferences During the evaluation period, one Enforcement Conference was held which resulted from the licensee's inadequate response to IE Bulletin No.79-01B.
This meeting, documented in IE Inspection Report No. 50-305/81-07, was conducted on April 23, 1981. One item of noncompliance resulted from this meeting, failure to provide complete information - Severity Level IV.
This is also discussed in Section IV., Item 9.,
Licensing Activities.
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