ML20065K837
| ML20065K837 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Salem |
| Issue date: | 08/31/1980 |
| From: | NRC |
| To: | |
| Shared Package | |
| ML082180535 | List:
|
| References | |
| FOIA-82-261 NUDOCS 8210080150 | |
| Download: ML20065K837 (8) | |
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SALEM 1 AND 2 Evaluation Period: 9/1/79-8/31/80 l
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General
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' 7; The licensee reorganized the corporate management structure to improve,
- 1 focus and strengthen management involvement in nuclear activities.
Line
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responsibilities for the licensee's nuclear and fossil facilities were
- .'9 separated and a separate General Manager was provided for each facility
- -2.N type. This separation allowed the General Manager-Nuclear Production to l
-7/.tH'i devote total attention to nuclear facility activities. The General
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Manager for Corporate Quality Assurance now reports directly to a Senior
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Vice President and the Station Quality Assurance staff reports to the g%
. Corporate Manager - QA Operations and Maintenance.
Realignment of the QA
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vf chain of command has increased the independence between station QA activities y,.lf and plant operations.
4 '3:
N -P The licensee revised the station Security Plan and took action to
- Q?[Q upgrade the quality of the guard force.
In addition the licensee took A t. f -
action to improve the timeliness and accuracy of reports to the NRC by z
[j; d appointing an individual to control and coordinate this activity.
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<4 II.
Specific u
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- Contention
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.f!M)l "The Salem facility displayed evidence.of weaknesses in four functional dias areas. These areas were plant operations, reporting, security and g9 safeguards, and management controls."
These contentions are addressed as follows:
Plant Operations (See Contention A)
Reporting (See Contention C)
Security and Safeguards (See Contention D)
Management Controls (See Contention E)
Contention A
" Weaknesses in plant operations were characterized by. instances of failure to operate in accordance with plant procedures and instances of violation of Technical Specification limitations."
1.
Basis During the evaluation period several non-IE Reports compliances were identified in this area, 50-272/79-28,
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principally as a result of failure to follow 80-05, 80-06, procedures.
Specific examples included:
80-12, 80-20 failure to follow procedures relative to valve position; simultaneous tagout of all
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emergency diesel. generator,s;, entry into 8210000150 B20712 4
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2 operational mode without complying with T.S. Limiting Conditions for Operation; failures to follow operating procedures (2 events);
q exceeding licensed power limits; and failure to follow procedures relative to logs and
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tagging. Inspection results and licensee LERS
.1 reported events indicate a lack of operator 79-71, 79-76, 3
attention to T.S. limits and procedural 80-19, 80-20,
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requirements.
80-43
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f1 2.
NRC Action f
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An IAL was issued on November 1,1979 after 11/1/79 NRC
'WQ.3 the inspector identified valve alignment Region I letter.
51,6 errors.
The IAL required independent verifica-(IAL 79-16)
Gp tion on all safety related systems prior to j$9[g achieving Hot Shutdown conditions; establi,shment of f
C.i positive means to ensure that all personnel
$N, with access to safety related equips.ent are
'W aware of requirements relative to valve status y.
.u and operations; and strengthened SIMi control of valve alignments.
&.OA M
p A notice of violatio'n was issued by IE HQ LER
@W?g;
%yg as a result of LER 79-71.that reported a case 79-71 y
"EDj where all diesel"generato'rs were put out 2/11/80 gg of service due to a tagging error.
NRC Letter IINE Increased inspection by the resident inspectors IAL 79-16 12 has identified one item of noncompliance' for 50-272/81-01 failure to recognize operation in a degraded 80-20, 80-23, mode.
The increased effort also has focused 80-32, the licensee's attention on this area.
IE Report Inspection results indicate that the degree 50-272/80-26 of attentiveness to operational situations and initiation of prompt corrective action ~
has demonstrably improved.
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3.
Licensee Corrective Action The Licensee has taken corrective action to Licensee letters address each specific item of noncompliance dated:
identified by the NRC.
Examples include:
1/22/80 establishing an independent verification 4/10/80 of valve lineups for systems covered by T.S.
3/6/80 (complete 1/1/80); reinstruction of personnel 7/2/80 in their responsibilities concerning valve 10/10/80 alignments; implementation of a computerized system to include operational mode changes,
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component status verification, and warning
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printouts for T.S. limits (in preoperational y.
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3 testing phase); counseling of individuals
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involved in personnel errors; allowing only shift supervisors (SRO) to authorize the
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placement or removal of tags; retraining of licensed and non-licensed personnel in tagging activities and responsibilities; and, M
establishment of a semi-ar.nual review of
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tagging procedures and effective tagouts.
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Contention B N.b.)
"There were reported cases where the licensee failed to complete required c.
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. surveillance tests."
(See contention A, above, and contention E, below) g 3
i 'c Contention C
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" Licensee reports were late, inaccurate, or incomplete on several occassions."
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Basis References
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Inspection by the resident inspectors identi-LERs Unit 1
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M problems co'ncerning timeliness, accuracy, and 80-04, 79-57,
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@xi" completeness of licensee event reports and li-80-41 censee action regarding IE Bulletins and re-LER's Unit 2
,f sponses to the NRC. Examples of incomplete or 79-25, 79-67
&dh inaccurate responses include: IE Bulletins 80-79-59 h
05, 80-20, 80-11, 80-15, Lessons Learned re-IE Reports 50-sponses relative to PORV limit switches and 272/80-13, 80-20 plant vent monitor.
80-21, 80-23 and 50-311/80-03 2.
NRC Action References The NRC has communicated its concerns regarding IE Report reporting to the licensee during routine 50-272/80-26 meetings between the NRC resident inspectors.
and 50-311/80-19 and the licensee and during the SALP management l
meeting on October 23, 1980. Timeliness and quality of licensee submittals was further discussed during meetings between the licensee and the resident inspectors and Region I management at various intervals.
The NRC l
continues to monitor licensee performance in this ares.,
3.
Licensee Corrective Action The licensee has taken action to improve perfor-mance in this area, including assigning responsi-(
bility for the coordination and control of re-porting activities to 'a single-indi'vidual onsite.
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Contention D "The Salem facility displayed evidence of weakness in... security and safeguards....There were problems in maintaining security controls between Unit 1, which was operating, and Unit 2,'which was still under construction and subject to different security requirements than an operating facility."
1.
Basis j
-s The NRC identified problems in the security
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area which resulted from inadequate control and construction of vital area barriers,
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failure to follow procedures and failure to T
provide adequate access control.
There were several events which occurred IE Report
'4 involving the control and construction of 50-272/79-26
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vital area barriers.
Examples include:
the NRC finding an interface door between Unit
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Nos. I and 2 not guarded and not barricaded,
.M5 allowing unimpeded access to at least three vital areas'in the Unit 1 Auxiliary Building
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(August 28,1979); a similiar event, occurring in September, 1979, involving another security
-#gj door in the interface wall between Unit Nos. 1 7.hy..M finding floor plates removed in the Unit 1 s
and 2; and, on September 30, 197C the.NRC
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Auxiliary Building (a vital area) which permitted unimpeded access to other vital areas.
As a result of a subsequent inspection on IE Reports July 1,4 thru 18, 1980 additional problems 50-272/80-17 involving the construction of vital area 50-311/80-13 barriers were identified.
An opening sized in excess of requirements was observed in the wall of the control room (a vital area) and an
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opening sized in excess of requirements was observed above the main door of the Auxiliary Building (a vital area).
In three physical security inspections, there IE Report were several events which involved failure to 50-272/79-26 follow the procedures implementing the physical security plan.
Examples include:
failure to adequately provide continuous visual surveillance to a vital area barrier during T.he period February 27, 1979 to August 26-27, 1979; and failure to isolate the
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individual responsible for the badge passout and last access dontrol; function in a bullet resistant structure.
5 During the security inspection conducted IE Report Janaury 21-25, 1980 NRC noted that the 50-272/80-02 HN licensee failed to assign watchmen ely to e,
watchmen duties; failed to forward appropriate changes to the Security Plan to NRC HQ for 3
approval; and failed to revalidate the need q,g for continued unescorted access to vital areas
~,. 9 every 31 days.
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In another instance, on July if,,1980 the IE Report licensee failed to maintain the isolation 50-272/80-17
~ b' tS zone free of materials or obstructions which 50-311/80-13 could provide cover and concealment.
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2.
NRC Action b,k.N
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Following the August 28, 1979 and September IE Report 30, 1979 events discussed in 1 above, the NRC 50-272/80-09
.f.,Q a;Nk conducted a significant licensee meeting on
...d February 26, 1980 regarding the limited j);
management controls of the security organization i'! g* el identified in a pending escalated enforcement
.d,g action.
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MMlM:( b"d Following the February 26, 1980 management IE Report meeting which covered other subjects as well 50-272/80-12 l j,4l as security, another managemenrmeeting was
' gi c f MM conducted on April 18, 1980 which dealt with D
the NRC intent to issue an Order to Modify the l
Facility Operating License.
On March 20, 1980, the NRC imposed a civil 3/20/80 penalty covering the events occurring between NRC Letter
, August 28 and September 30, 1979.
In addition, an Order to Modify the Facility Operating
,, M License was issued in conjunction with the civil penalty requiring the adoption and
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implementation of written security procedures l
requiring the continuous visual surveillance of the interface wall, review existing security l
procedures and controls, and the submission of special security procedures which would address problems identified in the civil penalty.
The NRC issued Notices of Violation addressing 3/20/80 NRC the other problems identified by security letter; inspections.
The NRC continues to monitor IE Report licensee corrective actions in the security 50-272/80-02 area.
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Licensee Corrective Action To resolve the events involving vital area 4/14/80 boundary control that occurred between August Licensee Ltr.
28, 1979 and September 30, 1979 and for which a civil penalty and an Order to Modify the Facility Operating License were subsequently issued.
The licensee discentinued using the interface between Unit Nos. I and 2 as vital a,
area barriers; brought vital area key control under the exclusive domain of the security organization; and expanded the protected area barrier to encompass all of the buildings in Units 1 and 2 within the confines of a
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single barrier.
The redefinition of the 1
protected area obviated the need for additional i
patrolling er controlling of access inside the Auxiliary Building of each facility.
In i
addition, the licensee significantly increased Security Force compensation (increased pay and allowances) to increase the caliber of I
individuals hired and to demand a higher level of performance.
g.A D9 In regards to corrective action relative to 4/10/80 the use of watchmen, the licensee changed Licensee Ltr.
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the Security Plan allowing more flexibility in the use of watchmen.
In the instance of I'
failure to forward a request for security plan l
changes to NRC HQ within 2 months, the licensee wrote a procedure to guide his managers on t-how to make authorized changes to the plan.
The revalidation of unescorted access to vital i.
l areas-was included in a security procedure to insure the procedure would be accomplished every l.
31 days on all vital areas.
To resolve the item of noncompliance relative 9/15/80 to obstructions in the isolation zone, a Licensee Ltr.
memorandum was sent to all division heads i
to re-emphaszie the requirement to maintain isolation zones free of obstructions.
Contention E "The Salem facility displayed evidence of weakness in the area of management controls."
1.
. Basis References I
The licensee has displayed difficulty in ef-LERs 80-19, 80-21 fectively implementlng an ade4ua'te. system of
~ 80-27, 80-28, L
7 management controls. Examples are: missed 80-42 surveillance testing; degradation of physical security (see Contention D ); failure to pro-IE Reports perly apply station tagging rules; and, fail-50-272/79-26, ure of operators to comply with station proce-80-17, 80-13, dures (see Contention "A").
79-32, 80-20, 79-28, 80-05, 80-06, 80-12, 80-20 2.
NRC Actions References The NRC issued Notices of Violation addressing IE Reports eich specific finding discussed above. Parti-50-272/80-26 I
cular emphasis was placed on management con-50-311/80-19 trol weaknesses by the NRC during the manage-ment meeting in whicn the SALP results were discussed with the licensee. The NRC continues to closely monitor the licensee's performance in this area.
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3.
Licensee Corrective Actions References l
l is The licensee has committed to take actions to licensee letters sad;a correct the specific items identified above.
of:
l In addition, the licensee has taken steps to 9/15/80 improve management involvement with plant 10/6/80 activities.
Responsibility for the licensee's 8/15/80 nuclear facilities now resides under the 7/2/80 General Manager-Nuclear Protection. Responsi-4/10/80 l
bility for the fossil fuel facilities now re-l sides under a separate General Manager. Further, 1/6/81 the licensee reorganized the Quality Assurance NRC Letter (TS organization, enhancing the independence be-Amendment #31) tween QA activities and plant operations. At the licensee's request a management meeting was held on December 10, 1980 at NRC Region I to 12/23/80 discuss the proposed reorganization.
NRC Letter Contention F "Although the station staff demonstrated an ability to identify problems and propose solutions, there were instances where corporate management did not provide a timely response.."
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1.
Basis References Routine NRC inspections during the assessment IE Reports period identified items of noncompliance indi-50-272/79-28, cative of the problem discussed above, partic-79-33, 80-04, ularly involving design changes and modifications.
80-19 and 50-311/
Examples include: failure to develop master 80-01, and 80-14 equipment lists and a method to provide to the plant, timely "as built" information; failure to provide the required information in a design change / modification package; failure to protect and maintain design records; and, failure to l
review Engineering Department procedures.
t An additional item of noncompliance related to IE Reports the failure of the Training Department to 50-272/80-15 trath licensed operators in facility design and changes in a timely fashion. This failure 50-311/80-10 resulted from the inability of the Training Department to obtain design change information from the corporate office.
2.
NRC Action
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i Enforcement action was taken for each specific NRC letters of:
item of noncompliance' identified. The NRC 1/2/80 (C
continues to monitor licensee performsnce.
3/7/80 i
5/6/80 l
7/29/80 9/29/80 3.
Licensee Corrective Actions Corrective action was implemented by the Licensee letters licensee to address each item of noncom-of:
pliance identified. Additionally, the 1/22/80 licensee took steps to. improve corporate 4/7/80 and site management involvement in and 6/3/80 responsiveness to plant activities by 8/19/80 implementing a reorganization of cor-10/17/80 porate and site management. This re-12/23/80 organization is further discussed in NRC letter; 1/6/81 Contention E.
NRC letter (TS Amend-ment #31) l
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