ML20128B273

SALP Rept 50-213/85-99 for Sept 1983 - Feb 1985

ML20128B273
Person / Time
Site:	Haddam Neck, 05000000
Issue date:	04/23/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20128B265	List: B11411, Discusses SALP for Facilities.Input to SALP Evaluation Process & Followup to Previous SALP Rept Actions Encl IR 05000245/1985099 ML20128B261 ML20128B273
References
50-213-85-99, NUDOCS 8505240466
Download: ML20128B273 (46)

See also: IR 05000213/1985099

Text

n.

U.S. NUCLEAR REGULATORY COMMISSION

y REGION I

, SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

INSPECTION REPORT 50-213/85-99

CONNECTICUT YANKEE ATOMIC POWER COMPANY

HADDAM NECK PLANT

(582 MWe, WESTINGHOUSE DESIGN PRESSURIZED WATER REACTOR)

ASSESSMENT PERIOD: SEPTEMBER 1, 1983.- FEBRUARY 28, 1985

BOARD MEETING DATE: APRIL 23, 1985

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p TABLE OF CONTENTS

P_ age

.I. ' INTRODUCTION ......................................................... 1

A. Purpose and Overview ............................................ 1

- B. S A LP Bo a rd Memb e rs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

C. Background ...................................................... 1

II. -CRITERIA AND RATINGS ................................................. 3

I I I . SUMARY O F R ESU LTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 -

A. - Overal l Faci l i ty Eval uation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-

B. Training Evaluation ............................................. 4

C. Facility Performance ............................................ 6

IV. P E RFO RMANC E ' ANA LYS ES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

A. Plant Operations ................................................ 7

B. Radiological Controls ........................................... 11

C. Maintenance ..................................................... 14

D .- Surveillance .................................................... 16

E. Fire Protection / Housekeeping .....................................-19

F. Emergency Preparedness .......................................... 21'

G .- . Security and Safeguards ......................................... 23

H. Refueling and Outage Management ................................. 25

I. Design' Change Control / Quality Assurance ......................... 27

, J. Licensing Activities .............................................-30

V. SUPPORTING DATA AND SUMMARIES'........................................ 32

~ A. Investigations and Allegations Review ........................... 32-

B. - Escal ated Enforcement Acti ons ' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 32

C. ' Management Conferences .......................................... 32

D. Licensee Event Reports .......................................... 33

-TABLES

' TABLE 1 - INSPECTION HOURS SUMMARY =........................................ 35

TABLE 2 - VIOLATION SUMMARY ............................................... 36

" TABLE 3 - INSPECTION REPORT ACTIVITIES ....................................

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TABLE 4 - TABULAR LISTING OF LERS BY FUNCTIONAL AREA ...................... 41

TABLE 5 - LER SYNOPSIS .................................................... 42

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TABLE 6 - UNPLANNED AUTOMATIC SCRAMS AND FORCED OUTAGES ................... 44

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I. INTRODUCTION

A. Purpose and Overview-

The Systematic Assessment of Licensee Performance (SALP) is an integrated.

NRC-staff effort to collect information periodically and evaluate licen-

- see performance. SALP supplements the normal regulatory processes used

to ensure compliance with NRC regulations. .It is intended to be diag-

- nostic enough for rational allocation of NRC resources and to be mean-

ingful to licensee efforts to improve plant safety.

An NRC.SALP Board met on April 23,.1985 to assess licensee performance

in accordance with NRC Manual Chapter 0516, " Systematic Assessment of

Licensee Performance." A summary of the guidance and evaluation criteria

is provided in Section II of this report.

This report assesses performance at the Haddam Neck Plant during the 18-

month period from September 1, 1983 through February 28, 1985.

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.. B. SALP Board Members .

. R. W. Starostecki, Director,- Division of Reactor Projects (DRP), SALP

Board Chairman

- W.' F. Kane, Deputy Director, DRP-

T. T. Martin, Director,' Division'of Radiation Safety and Safeguards,

(DRSS)

L. H.-Bettenhausen, Chief,. Operations Branch, Division of Reactor Safety-

(DRS)

E. C. Wenzinger, Chief, Projects Branch 3,-DRP

E. C. McCabe, Chief, Reactor Projects Section 3B, DRP

P. D. Swetland, Senior Resident Inspector, Haddam Neck

T. P..Speis, Director, Division of Safety Technology, Office of Nuclear

Reactor Regulation (NRR)

F. M. Akstulewicz, Licensing' Project Manager, ORB 5, NRR

Other Attendees (Part-Time)

J. H. Joyner, Chief, Nuclear Materials Safety and Safeguards Branch, DRSS

J. R. White, Senior Radiation Specialist, DRSS

R. H. Smith, Emergency Preparedness Specialist, DRSS

M. A. Cioffi,. Radiation Specialist, DRSS

= C. Background

1. Licensee Activities

At the beginning of the assessment period, the facility had been

operating at or near full power since June 12, 1983. Full power

operation continued from September 1, 1983 until May 4, 1984, with

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the exception of power reductions for routine turbine valve testing,-

or equipment troubleshooting and repair. The plant operated in a

three-loop mode at 65% power for several hours on November'25, 1983

to facilitate repair of a-leaking steam generator level instrument

root stop valve.

On May 4,.1984, the facility began' a period of extended power coast-

down operation in excess of 70% power until August 1, 1984. The

plant was then shut down for refueling after completing over 417

consecutive days of safe power operation.

Refueling activities were to include the Core XIII fuel shuffle in-

cluding the addition of four zirconium clad-(vs. stainless steel

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, -clad) fuel elements to the core, an integrated containment leak rate

test, completion of several TMI Acticn Plan and Systematic Evaluation

Program modifications and significant secondary system overhaul,

upgrade and repair. During the outage, loss of all offsite AC power

events were experienced on August 1 and 24. On August-21, with the-

-refueling cavity filled in preparation for fuel shuffle' operations,

the refueling cavity seal failed, dumping about 200,000 gallons of

reactor grade water into the containment. No fuel handling opera-

tions'were in progress and the spent fuel pool remained isolated

from the refueling cavity. Consequently, no fuel was uncovered

during this incident. An expanded steam generator U-tube testing

program and the seal failure event recovery actions extended the

planned 46 day refueling outage to 105 days. .

Following the refueling outage, plant startup and power ascension

were conducted from November 9 - 19, 1984. Turbine generator voltage

regulator problems resulted in one-manual plant trip on November

-15, 1984. The plant again operated at or near full power from No-

vember 19, 1984, until the end of the assessment period with'the

exception of an automatic loss of flow trip which occurred on Novem-

ber 20, 1984. The trip occurred because a reactor operator inadver-

tently shut down the #3 reactor coolant pump. Power operation re-

sumed the same day.

2. Inspection Activities

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One NRC resident inspector was assigned to the site during the en- I

tire assessment period. The NRC inspection effort (both resident

and region-based) for the period totalled 2927 hours0.0339 days <br />0.813 hours <br />0.00484 weeks <br />0.00111 months <br />. This corres--

-ponds to 1951 inspection hours per year.

An NRC team inspection was conducted on October 24-28, 1983, to

follow-up on implementation of TMI Action Plan radiation monitoring

improvements. An NRC Emergency Preparedness Team observed the full-

scale emergency exercise on May 12, 1984. After the SALP period,

the annual emergency exercise on March 30, 1985 was observed. Tabu-

lations of inspection activities and findings are appended to this

report.

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II. CRITERIA ANO RATINGS

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_ Licensee performance is assessed in prescribed functional areas significant

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. _toinuclear safety and.the environment. Special areas may be added to high-

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light significant observations. .In'this SALP, the Quality' Assurance area was

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added_.to emphasize its importance. _ Design Change Control (DCC) was-high--

-lightedLin~the QA functional area because of significant DCC findings.

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'One or more of;the following criteria'were used to. assess.each area.

L JManagement involvement:and control in assuring quality.

2.- (Approach to resolu' t ion-of technical issues from a safety standpoint.

Responsiveness'to NRC initiatives.

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L4. Enforcement history.

5; Reporting-and analysis of reportable events.

-6. Staffirig (including management).

17.- Training effectiveness and qualification.

These criteria are not. limiting; others are used where appropriate.

Based upon:the'SALP Board assessment, each functional area is classified into

one of three performance categories. .These~are:

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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 so that a high level of

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-safetyjperformance is being. achieved.

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> Category 2. NRC attention should be maintained at normal 1evels. Licensee-

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. management attention and involvement are evident and are concerned with nuc-

Q ', 11 ear,s'afety; licensee resources are adequate and reasonably effective so that

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-satisfactory safety ' performance is being achieved.

M 7Ps . Category 3. _Both NRC and licensee attention should be increased. Licensee-

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. of the SALP: period to the overall performance for the entire SALP period.

That comparison was used to trend-licensee performance as " Improving," or

" Consistent" (essentially the same), or " Declining."

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(III.' Summary of Results'-

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g A.  : Overal'l' Facility Evaluation

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Priorzassessments.of; licensee performance have acknowledged a strong.

management commitment that was' effective in achieving high ratings in

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. most, if:not' all, functional areas. The licensee's performance this

period,. in .each functional . area . evaluated, continued to be acceptable.

In many; respects, the numerous high ratings reflect favorably on the

. performance of staff and supervisors working together. However, during

the assessment. period =several problems were identified. .When examined

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. individually,. remedial measures-were taken:to address each one. However,

the number of. problems and their. occurrence in various parts of the

organization leads the SALP Board to conclude'that these may be indica- t

tions of'a more serious situation.

-Specific problems include: a'n adverse trend in the incidence of personnel

and procedure-related errors, significant deficiencies in the program

.for.the=requalification training of licensed _ operators, deficiencies in

regard to event reporting and procedure reviews, repetitive and uncor-

Jrected minor violations in the radiological controls area, an event that

. involved a significant potential for personnel overexposure,-weaknesses

identified during the 1984 emergency exercisei substantive problems'in-

the control over design changes, and an increasing backlog of activities

in several areas including corrective action follow-up, maintenance, and

licensing.

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Although the licensee-has taken action to ameliorate or control.these

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problems, the examples indicate that there may be a-relaxation.or: letdown

in the aggressiveness toward self-appraisal and self-identification of

problems in the plant and.in-some of the corrective actions. Many of

the problems continue to be identified by NRC-inspectors. Notwithstand-

, ing, some areas continue to be . viewed as noteworthy, particularly the -

Security area. The improved performance in the March 30,-1985 emergency

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exercise demonstrated the ability of the organization to implement ef-

fective corrective measures. As such, it is clear that the licensee can

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be very effective.

.During this period, the plant achieved a record period of' continuous.

operation. Such an accomplishment reflects favorably on the staff re-

sponsible for operations, maintenance, and surveillance. However, based

on the nature of the varied problems addressed in this report, there

appears to be an adverse trend in the thoroughness and aggressiveness

of management toward support and oversight / audit activities. When prob-

lems are identified, the licensee can generally be relied upon to imple-

. ment effective remedial measures. However, identification of problems

by NRC inspectors 1(as'noted herein) rather than by established licensee

programs is disturbing. Unless vigorous management attention is provided

to bath offsite'and onsite activities, the corrective actions taken to

date may not be sufficient to prevent recurrence of similar problems.

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B. -Training Evaluation

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' Training activities were evaluated in three areas including general I

employee training (GET), technical / departmental training, and licensed

operator initial and requalification training.

The licensee has implemented a comprehensive GET. program. On an annual

basis, all employees receive training in security, radiation protection,

. quality' assurance, fire protection, cmergency preparedness, and general

. safety. Previcus concerns had been identified by NRC regarding-training  ;

attendance,; documentation, and measurement of-effectiveness. The licen-

see has taken. action to correct these deficiencies and the recently com-

pleted GET cycle was significantly improved in. attendance and documen-

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tation. There have been'some indications of subsequent performance ita-

. provement,' e.g.,7 decrease in_ fire barrier problems, but the overall ef-

fect of the program. improvements has not yet been shown.

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The licensee's technical training program for maintenance, instrument

and controls, health physics, chemistry and non-licensed operating per-

sonnel was historically a departmental responsibility. This training

was typically conducted on-the-job with a limited number of component / job

specific courses. This departmental training has generally been success-

~ful; however, certain-incidents such as main steam flow transmitter

m . . problems, an improper weld repair, and multiple fire barrier problems

indicated _ training weaknesses as a causal factor. During this period,

the~ licensee's training department has. expanded to includo.this area *

. within their overall program. Coordination with the. plant operating

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departments has-been maintained. The licensee is developing task-ori-

ented training requirements-for all technical disciplines and will im-

plement job-related initial and follow-on. training' programs in each of

these areas. While some improvements have been realized in this area,

technical training program goals have not yet been reached. It remains

to.be seen whether personnel performance is improved. .

. The training program for initial licensing of reactor operators has

. achieved excellent results in preparing operators for NRC examination. '

The operator requalification program, ksever, has been only marginally

,L successful. Based upon an audit by the NRC, several weaknesses were

identified and documented in correspondence to the licensee. Based on

,- these findings, major revisions to the requalification program and its

- . implementation have been initiated.

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C. Facility Performance

Category. Category Recent

. Functional Area ~ Last Period ~This Period Trend

.(9/1/82 - --(9/1/83 -

8/31/83) 2/28/85)

A. Plant Operations 1- 1 Consistent

B. Radiological. Controls 1 2 Consistent

C. Maintenance 1 -1 Consistent

D. Surveillance 2 2 Improving-

, E. Fire Protection / Housekeeping. No Basis * 2 Improving-

F. Emergency Preparedness- 1 2 Improving

. G. Security'& Safeguards 1 1 Improving

H. Refueling & Outage Management 1 1 Consistent

'I. Design Change Control / Quality #- 2. ~ Improving

Assurance

J. Licensing Activities 1 1 Consistent-

• Fire protection inspection was.not sufficient to support a conclusion.

1. Not'previously addressed as a separate area.

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>IV.1 PERFORMANCE ANALYSES (739 hrs., 25%)

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. ' A. Plant-Operations-(25%)

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- 1.-- ' Analysis-

' This functional area encompasses. operational activities, operator

training'and licensing,' committee activities, corrective actions

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and~ event reporting.~ The previous SALP rated licensee performance

as_ Category-1 in.this area. During this-SALP period,.there were

five NRC inspections by region-based inspectors._ Plant operatio'ns

were observed by'the resident _ inspector throughout the period.

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The plant operators continue to. distinguish themselves by' competent,

R conscientious performance of their day to day duties. The'NRC

7 , resident inspectorispecifically noted that operator professionalism

and. vigilance, control room demeanor, discipline, access control,

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and housekeepin'g were-strong assets to the plant operations area.

10perator response to operating events such as the refueling cavity

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seal. failure, loss of offsite power, and a loop isolation valve

packing leak _were uniformly _ prompt, effective:and professional.

The 417 consecutive days of plant operation at power are an'indi--

cation of the quality-and professionalism of these operators. In

regard to the initial qualification of licensed operators, the

operator training staff attained a high level-of performance.' 21

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of 22 reactor operator and senior reactor _ ope'rator candidates ex-

amined by NRC during this period-received licenses.

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NRC. review of the licensed operator requalification program, how-

ever,-concluded that significant'. weaknesses existed. In particular,

programmatic weaknesses were identified in the quality of the. annual

examination process and in overemphasis on'this. examination as the

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measure'of training effectiveness. Based on the performance of in-

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dividuals-examined by the NRC during NRC participation .in requali-

fication-training, the requalification program was identified.as

marginally acceptable. Inaccuracies.in plant training materials

were_also. identified. These problems were aggravated by.the licen-

see's initial reluctance to react to and take prompt corrective

action on these findings. By-the end of this assessment period,

however, senior licensee management had taken firm action with re-

gard to these findings and plans for a major revision of the re-

qualification program had been submitted to the NRC (later accepted).

The resident. inspector noted the licensee's effective daily-staff

meetings, prioritization, coordination and tracking of departmental-

responsibilities, and frequent site management tours of plant fa-

cilities. There is an adequately sized onsite engineering support

organization and the licensee has a strong and experienced corporate

staff from which to draw support. It was also noted that there was

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ta high level ^of corporate support to the Haddam Neck-Plant in'the

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risk assessment. ~ Senior management presence onsite has not.been

as. evident as at their Millstone site,.and NRC_ inspectors noted that-

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corporate' level _ engineering support such as technical evaluations

for steam' generator safety valve operability or equipment classifi-

cation 1(MEPL) determinations were not always. timely.

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'An adverse trend in licensee performance was identified involving

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individual procedural adequacy and compliance and the rising number  ;

of personnel.and_ procedure-related errors. It_was noted, for in- -

stance, that only three automatic plant. trips occurred during this

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SALP periodebut each.one was caused by personnel,and/or procedural

errors. A general weakness in quality and specificity in certain

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procedures fostered some. willingness on'the part of-plant personnel

to deviate from procedures. Personnel were prone to completing

activities without full documentation and without modifying pro-

cedure discrepancies involving improper or inadequate. directions.

Examples of this problem included safety injection check valve. leak

rate testing, core ~_ cooling / loss of AC testing, and locked valve

checklist procedures. The licensee.took_ strong corrective actions.

Those included-improved procedure review guidance coupled with

management. seminars with operating person.nel to stress _ strict pro-

cedural compliance and the methodology for procedure revision. A

recent lack of recurrence of this condition has been noted. None-

theless, ongoing licensee attention to this matter is needed, es-

pecially.during periodic (biennial) procedure reviews.

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The licensee encourages problem: identification from all staff-levels.

The Plant Information Reporting (PIR) system provides an excellent.

basis for problem identification, evaluation, reporting, management

notification and corrective action followup. Most PIRs are followed

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up by the assignment of a Controlled Routing.(CR) to track correc-

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tive action and all PIRs receive management and site review commit-

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tee reviews. These management control systems.have been' effective

in controlling the large volume of reactive activities generated

at the plant. -In recognizing the quality and thoroughness of.the

PIR/CR system, NRC!has also noted that the volume of actions has

become mildly burdensome to the plant staff. The number of PIRs

increased from 138 in 1983 to 230 in 1984. The number of CRs in-

creased from 1241 to.1692 in the same period. A small number of

PIRs such as those related to spent fuel pool ion exchanger resin

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-leaching, ventilation filter exhaustion, and a waste decay tank-leak

have not resulted in complete identification, documentation, or

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C correction of the root cause of the problem. Other and more signi-

ficantlinstances of ineffective problem closeout are discussed below

under event reporting. Incomplete problem closeout may result from

the large number of CRs awaiting action by plant personnel. The

backlog.of PIR/CR actions warrants management attention.

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During this period, there has been aLgeneral improvement in licensee-

1 implementation of NRC reporting requirements. This is' attributed

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to a better-understanding of and more conservative licensee-approach

, to the new NRC reporting' requirements which became effective in

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January 1984. .There has been, however, some inconsistency in the

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quality and content of Licensee Event Reports (LERs). .While the

'LERs reporting the reactor cavity' seal. failure and a potential per-

sonnel overexposure to radiation were particularly good, other LERs

' including the degradation of reactor protection system wiring, con-

tainment. isolation valve MS-TV-1212 failure, and a low temperature:

overpressure protection system fail.ure lacked specificity, contained

errors,:or failed to identify the root cause of failure. There

appears to_be'a gap in communication, in some cases, between the

-operating and maintenance personnel and the LER writer (s), such

that pertinent information is lost or not correctly translated into

the LER. Also, some LERs lack perspective on long term action to

. prevent: recurrence.' For instance, when procedural inadequacy

a factor in the cause of an event, evaluation of the_effectiveis.ness

of the plant procedure review process was not included in or initi-

ated by LERs (e.g. LERs 84-19,84-24,85-03).

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, Licensee committee a'ctivities were generally good;during this period.

' Specific failures related to design change package review were

identified and are'. discussed in~ Functional Area I of this report.

The Plant _ Operations Review Committee (PORC) has effectively managed

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the large volume of review requirements, however, there is a ten-

dency toward more cursory review when a large backlog has developed.

This was evidenced.by PORC failure to identify the ineffective or

incomplete closeout of certain PIRs and_LERs noted above. These

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examples were part of a large backlog of PORC review requirements

v which developed during the 1984 refueling outage. NRC inspector

observation of several PORC meetings resulted in the conclusion that

the detail of documentation in PORC meeting minutes does not reflect

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the level of deliberation of many PORC reviews or the answers to-

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many concerns raised by PORC members. The. Nuclear Review Board

(NRB) has'provided quality oversight-of plant activities, though

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NRB reviews have been somewhat limited by the content of packages.

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The NRC and the licensee have been concerned about-the lack of

definitive documentation of plant design and safety analysis bases.

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This situation makes it difficult to promptly evaluate the safety

significance of component / system failures and to make timely safety

, evaluations of plant changes and modifications. The licensee has

initiated significant compensatory programs including reanalysis

of the plant accident analyses, recovery / development of plant system

design basis documents, and performance of a full probabilistic

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risk assessment study for the Haddam Neck Plant. These programs

demonstrate a strong licensee commitment to the continued safety

and quality of plant operations.

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In summary, major licensee strengths in plant operations were evi-

dent during this period, especially in regard to operator and support-

staff response to actual events. There were no violations of NRC

requirements in this area. Initial operator qualification training

was excellent. There was notably good licensee response to self-

evident problems. Some less evident problems received very slow

response. Initial licensee response to operator requalification

program deficiencies did not meet NRC expectations, but the compre-

hensive nature of the recovery program and the final implementation

schedule were acceptable. Deficiencies were also noted in PORC

reviews,' event reporting,. corrective action followup, and procedure

review and adherence. These deficiencies indicate a need for more

vigorous and critical licensee self-appraisal.

Although a significant number of performance deficiencies were noted

in this area, the performance rating was ultimately controlled by

the substantive strengths identified. The results of corrective

-actions in this area have not yet had a chance to manifest.them-

selves, and a consistent recent performance trend is assigned.

2. Conclusion

Rating: Category 1 (This rating reflects primarily the favorable

emphasis on onsite operations activities. Most of the

concerns noted are assessed in other functional areas.)

Recent Trend: Consistent

3. Board Recommendations

Licensee:

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Improve the quality and aggressiveness of self-appraisal efforts.

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Continue emphasis on operator requalification.

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Continue initiatives to improve procedural review'and adherence.

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Assess the adequacy and timeliness of PIR/CR disposition.

NRC:

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Perform special evaluation of the effectiveness of requalifi-

cation program improvements.

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Perform a special inspection of facility procedure adequacy

and compliance.

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B. 1 Radiologic'al Controls (373 hrs., 13%)

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n 1. . Analysis

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The licensee's_overall performance in this area, relative to the

- previous ~ asses _sment period, is lower. In the last period, only

^ minor ~ problems were identified and_no programmatic' weaknesses were

, noted. In this period, more substantive problems were identified.

These1 indicate that a minor-programmatic breakdown has occurred. 1

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The licensee's radiation. protection program continues to be defined

. by generally: good policies and' procedures. Resident and specialist

inspector reviews generally indicated good performance in contamin-

i ation control',' radiological surveillance, personnel monitoring,

radiological _ waste management and effluent controls. ' Adequate staff-

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- was available_ to carry out the program and the personnel involved

were found to be qualified and capable of performing in their as-

signed areas of responsibility.

During the assessment period, a special post-implementation review

of the licensee's efforts involving the post-accident sampling and

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- monitoring requirements of_NUREG-0737 was performed. The review

identified several deficiencies including improper component in-

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, stallation that would have prevented sampling of the containment

atmosphere. (This matter is addressed in Functional. Area I under

design' change control.) Other deficiencies found in the PASS area

, included inadequate procedures for system operation and chemical-

analysis. In October 1984, the NRC found that containment integrity

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would be technically violated when-the containment air' sampling.

system was operated at power. .Such operation was prohibited'as an

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interim action. By the end of the.SALP period, the. licensee had

not amended the. Technical Specifications to allow surveillance and

testing ofathe containment-air sampling system. This indicates a

lack of timeliness and management support.

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While decision making is us'ually at a -level that ensures adequate

management review, an exception during this period resulted in an-

event having substantial potential to expose a worker in excess of

regulatory limits. In this instance, a technician, known by the

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licensee to be untrained, unqualified, and. inexperienced, was as-

signed by an upgraded senior. level technician to cover a steam

generator task involving high dose rates and significant radiologi-

. _ cal hazards. Supervisors were unaware of this action due to insuf-

F ficient oversight and communication. Subsequently, performance

errors by the unqualified technician resulted in a breakdown in the

established radiological controls and in an unplanned radiation

exposure to the worker. Because the event was isolated and not in

itself an' indicator of programmatic deficiency, enforcement action

was mitigated due to previous good performance. However, this event

4

does indicate that management was not sufficiently aggressive in

monitoring program compliance.

i

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Management ineffectiveness was also demonstrated in findings which

indicate that, while the licensee makes commendable efforts to

identify discrepant situations (i.e., non-adherence to procedures,

contamination events, and RWP problems), these efforts are generally

,

confined to. documenting the occurrences. Licensee followup actions

were limited to interdepartmental notification of these discrepant

conditions, without any effective control of, or feedback on,-cor-

rective actions to prevent recurrence. Interdepartmental authority

and responsibility for identifying and verifying corrective measures

were not effectively delineated. The licensee s identification of

multiple similar problems (many repetitive) is indicative of a minor

programmatic breakdown. However, effective corrective measures to

address these deficiencies were not applied. The licensee committed

to implement corrective action to address these deficiencies by

May 1, 1985.

During this period, several deficient conditions involving the im-

plementation of the QA program for radioactive material transport

packages and radioactive waste management were identified. The

licensee was not performing sufficient audits or effectively imple-

menting all necessary quality measures for these particular areas.

NRC inspection after the SALP period found that, while some QC pro-

gram improvements were implemented, a satisfactory level of QC in-

volvement had not been achieved. Other program elements associated

with these areas were found to be effective.ly implemented with a

well defined system of management control and oversight.

A stronger corporate commitment to ALARA is in the process of de-

velopment as evidenced by actions initiated by senior management.

These include new ALARA goals and performance objectives which have

-been made specific responsibilities of individual managers. A for-

malized ALARA job analysis and dose reduction program is currently

in place. This program, however, primarily functions as an exposure

estimating, tracking, and documentation system. Actual ALARA im-

plementation is a function of job supervisors, whose training in

this area has generally been weak. The licensee has initiated ac-

tion to improve this condition.

Overall, the licensee's performance during major projects involving

high levels of radioactivity demonstrated thorough planning and pre-

paration, good procedure development, and the establishment of ac-

ceptable radiological controls. This was evident for work associ-

ated with the 1984 outage including refueling tasks, reactor cool-

ant pump seal work, control rod drive shaft replacement, and cleanup

after the seal failure event. Adequate management review and over-

sight was evident as demonstrated by sufficient personnel awareness

of daily activities, and the effective use of planning meetings and

schedules to reduce personnel exposure.

_

_

v -- - -

13

A formal training program for the radiation protection staff con-

tinued to be implemented, and provided sufficient technical and

practical instructions to assure competence withinLthe organization.

One deviation was identified by NRC involving the documentation of

a formal radwaste handler requalification program. .The licensee

implemented an effective radiation worker training program to assure

that radiation workers are aware of radiological safety procedures

and are able'to implement them competently.

An effluent' control and radiochemistry review indicated that the

licensee was generally effective in implementing the program in

accordance with regulatory requirements.

Additionally, the licensee has successfully completed corrective

actions on several previously identified findings associated with

post accident sampling and monitoring, and has'successfully resolved

these open items in a timely manner.

2. Conclusion-

Rating: Category 2

Recent Trend: Consistent.

3. Board Recommendations

~

Licensee: Efforts should be made to strengthen management oversight

and interdepartmental communications. An effective system for

evaluating and correcting self-identified deficiencies should be

developed. The licensee should expedite efforts to seek a Technical

Specification Amendment for PASS containment isolation valves to

allow resumption of full system surveillance.

NRC: Consider a special team inspection midway through the next SALP

period to determine program status.

,

I

L

. --

,

>

14

. .

"C. -Mairitenance -(237 hrs. . 8%)

1. Analysis

The previous SALP found licensee performance in this area to be

Category 1. During this assessment period, routine inspections of

ongoing maintenance activities were conducted by the resident in-

spector.- One~ region-based inspection reviewed the licensee's per-

formance of post-maintenance testing.

The licensee's preventive and corrective maintenance programs con-

L

-

tinue to be a strong asset to overall facility performance, and con-

tributed significantly to the 417 days of continuous safe. operation.

-Management support of preventive maintenance (PM) is evident by the

wide scope of, and large effort devoted to, safety-related and non-

-"

safety related PM-activities. Management also reviews each compo- >

nent surveillance and operational failure to determine the cause

and revise the PM program, as necessary,.to prevent recurrence.

Extension of PM activities to~ equipment-in storage (spares) was

.

highlighted by the NRC in November 1984 as an area for improvement.

Licensee response to this item has not yet been inspected.

Corrective maintenance is conducted in a competent, professional

manner. * Repetitive repairs are rare. Maintenance instructions /.

procedures are normally appropriate to the difficulty of the job

land to the qualifications of the technicians. An exception occurred

m

when a weld repair to a high pressure l safety injection pump seal

line failed. The licensee concluded that the system had not.been

properly-drained prior to welding. Work instructions did not-detail

-the system draining. -In another instance, an improperly sized

gasket was installed in the low pressure safety injection system.

.

'Upon system-startup, the gasket failed and a portion of.the gasket.-

material was pumped into the reactor head area, resulting in a sig-

,

nificant effort to locate and retrieve the foreign material. These.

,

items were determined to be isolated and atypical.

• ~

In November 1983, the-licensee implemented a computerized mainten-

~

'

ance scheduling,-documentation and tracking system (PM S). While

the P M S program has been effective in tracking the large volume

of maintenance activities, the level of detail in the documentation

,

,

~o f work order instructions and close-out information could be im-

+

proved. :During this period, licensee and NRC followup of certain

,

- component failures such as condensate blowdown trip valve MS-TV-1212.

.was hampered because maintenance records did not_ detail the matter

well enough for the root cause and generic applicability to be

.

determined. NRC inspectors noted that licensee personnel unfamili-

!' arity with the new automated work order system detracted from their

confidence in~the system and recommended further training in this

'

.

,

area. Also, NRC noted that~the capability of the PMS system for

-

,

.

..

=- - - __-.

- . . . .

15

processing maintenance history and trending failure data had not

been realized. Although no evidence of repeated or generic failures

has been-identified, continued emphasis on improving the PMMS

capability is warranted.

The plant benefits from having strong instrumentation and. controls

(I&C), electrical, and mechanical maintenance staffs. There are

experienced. personnel in key roles, and the licensee has had a low

overall turnover rate despite the replacement of both the I&C ana

maintenance department supervisors. Improvements in the maintenance

technical training program scope and staff have also been imple-

mented during this period.

There is a modest backlog of plant maintenance work. The licensee

has effectively managed this situation through prioritization and

overtime. However, electrical maintenance has about one-fifth of

the department staff, about- one-third of the maintenance backlog,

and only one maintenance supervisor. Continued high activity in

this area emphasizes the need for. licensee management attention.

2. Conclusion

Rating: Category 1

Recent Trend: Consistent

3. Board Recommendations

Licensee: None

NRC: Maintain resident inspector coverage of this area, focusing

on technician knowledge and skill in maintenance activities.

't

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16 .

l

D. Surveillance (327 hrs., 11%)

.1. ' Analysis

The previous SALP rated this area as Category 2. During this

period, surveillance was reviewed by resident and region-based in-

spectors. NRC. inspections covered routine surveillance and cali-

bration activities, inservice inspection and testing (ISI/IST),

containment leak rate testing (CLRT), and startup physics testing.

The routine surveillance testing program was adequately implemented  !

in accordance with plant procedures. In general, the timeliness '

of management review of test results has improved since the previous

assessment. During this period, events relating to all four chan-

nels of main steam flow being inoperable, a startup rate trip due

to improper test equipment manipulation, and 2 out of 4 loss of flow

trip. channels being inoperable involved inadequate matching of the

level of control in surveillance procedures to the technicians'.

qualifications and understanding of those procedures. This high-

lights the need for better supervisory and management review of

surveillance to assure that procedures are' compatible with the

training and qualification of technicians. The lack of a master

-surveillance schedule was identified in 1982 by NRC inspectors.

It was reidentified by the NRC a year later. This condition con-

tributed to a violation for failure to perform fire damper inspec-

tions required by technical specifications. Although it took the

licensee over one year to establish a' complete and accurate master

surveillance schedule, no further inFtances of missed surveillances

have been identified. The licensee i.as implemented semi-annual

verifications of the master surveillance data base to insure that

the schedule remains current. The licensee also has initiated a

long term surveillance improvement program which includes procedural

and scheduling upgrades, surveillance compliance verification, and

failure reporting.

During this period, the licensee completed a major upgrade of the

instrumentation calibration program. Calibration of each installed

gauge is scheduled and tracked within the automated Planned Main-

tenance Management System. Test equipment calibration is controlled

by individual test procedures. One NRC identified violation for

inadequate gauge calibration resulted from omission of seven gauges

from the master calibration list. The licensee promptly ' corrected

this deficiency, and no further omissions have been' identified.

The ISI/IST program is adequately conducted by a qualified and

knowledgeable staff. Corporate and contractor support are readily

available. NRC inspectors did identify an inconsistency in the

reporting of several pump and valve deficiencies. These non-con-

formances were dispositioned under the Plant Information Reporting

(PIR) System rather than the Non-conformance Reporting (NCR) System.

_.

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i The licensee initiated efforts to clarify interfaces between PIR

and NCR reporting to insure effective management awareness ...d ds-

position'of deficiencies.  ;

For.contai.nment'_ leak rate testing, management involvement and con-

trol for assuring quality,' resolving technical issues, and respond-

-

ing to NRC initiatives were lacking. Problems: identified included:

. (1), inadequate margin in-the Type A test result to allow for "As

left" leakages for numerous penetrations isolated before the test; I

(2). insufficient test duration to allow the diurnal oscillations ,

to dampen; (3) attempted use of a selected " window" of test data '

instead of more accurate leak rate test data for the total test;_

- and (4). sensors not installed so as to mitigate the diurnal effect.

These were compounded by an initial lack of licensee responsiveness

to the inspector's findings and to an. ongoing lack of responsiveness

to previous issues raised by NRC in this area. There are seven (7)

~

,

open unresolved items which are over.eight years old. The licensee

-consistently stated that these-items have been under review as part

~ of their SEP response and the more recent-ISAP program. ~However,

- no-aggressive approach to resolution of these items has been taken.

The CLRT problems were resolved for the next operating cycle after

correction of the current CLRT data, development of an integrated

vs. local leak rate correlation, and licensee commitment to address

= the Lother' open items prior to the Type A test scheduled for the -

,

-

next refueling' outage.

-

<

NRC review of the Cycle 13 startup physics. test activiti_es found

improvement over previous startup physics tests, which had been

~

generally good. All physics tests had been performed satisfactorily

and all test data met acceptance criteria. Data sheets were pro-

'

perly_ signed and calculations were error free. This improvement

- can be attributed,-in part,.to an extensive effort by the reactor

engineering staff to rewrite,-update and clarify many of the proce-

dures and data sheets. In addition, the. licensee purchased new

videotape equipment which greatly improved the quality of the core

verification effort. Efforts to improve procedures and update

equipment were apparent in the quality of the startup test program.

The licensee has augmented chemistry department staffing to facili-

tate implementation of improved quality control measures in this

area. The present staffing levels were found to.be adequate for

conducting all required surveillance activities. However, the.

number of NRC and licensee identified problems and the extended-

intervals required to plan and implement effective corrective meas-

. ures'such as the master surveillance schedule and procedure upgrades,

'and to resolve the CLRT open items,_ indicate that additional licen-

see attention may-be appropriate in this area.

-

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-

18

-

-

The. licensee's efforts to_ upgrade surveillance procedures and in-- l

' prove the calibration, startup physics testing, and; inservice.in-

spection programs have. demonstrated the licensee's commitment to-

improvement.in'this area.

- 2. Conclusion

_ ,

Rating: Category 2 -

'Recent Trend: ' Improving

' 3. B'oard Recommendations

Licensee: Continue initiatives to upgrade surveillance procedures.

'

Improve management control overiitems like CLRT issues in order

to assure that resolution is not unduly. delayed.

,

NRC: Review Appendix J implementation prior to next CLRT.

_

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E. Fire Protectio'n/ Housekeeping (123 hrs., 4%)

1. Analysis'.

. . .

The previous .SALP.did not _ assign a. rating category to this area.due

to-insufficent inspection. During this SALP period, routine ob-

-servations were made by the resident inspector and one programmatic

inspection was conducted by a region-based inspector. The licensee

-is still-working'out the details of 10 CFR 50 Appendix R implemen-

tation, and no Appendix R inspection has been conducted yet.

The fire protection program is well defined and implemented by sta-

^

-tion procedures. Installed equipment is adequately maintained and-

tested with only minor exceptions. During this period, maintenance

of fire barrier integrity was a significant problem. The licensee

identified numerous instances (see LER chain in Section V.D_of this

SALP) where fire doors and penetration fire seals were compromised

-by plant or' contractor personnel. NRC inspectors also identified

two.related violations: one for. failure to inspect plant fire dam-

pers, and another~for failure.to seal a penetration fire barrier.

-The licensee implemented corrective action for each _ fire barrier

problem identified. However, weaknesses in general _ understanding

, of fire protection requirements and/or lack of respect for these

requirements resulted in numerous violations (mostly licensee iden-

~

tified) before the fire barrier integrity issue was brought under

' control.

The fire. brigade training program was well. defined. There were

adequate numbers of qualified operations and support personnel.

Although quarterly fire brigade training sessions were given, each

brigade member was not_ required to attend each session as specified

in 10 CFR 50 Appendix R. This was identified during an NRC inspec-

tion early in the SALP period. The. licensee took corrective action

such'that, by the end of the period,~ sufficient quarterly training-

-

sessions were held and each fire ~ brigade' member was required to

attend at least one session per quarter. That or equivalent train-

ing has been implemented for each-fire brigade member.

~

A member of the plant engineering staff is designated as the site

'

fire protection coordinator. He performs onsite fire protection

reviews and interfaces with corporate fire protection staff members.

During this period the licensee completed a comprehensive review-

of the implementation'of Appendix R requirements. This study in-

cluded plant, corporate and consultant personnel and is indicative

of management support to improvement in the fire protection program.

Implementation of a corrective action program for those discrepan-

cies identified is ongoing.

-

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- . . . . . .-

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20

-

,

'

LThelicenseeconsistentlymaintains:impressivelyhighplanthouse-

, keeping conditions._ Visiting NRC personnel are almost-always im -

pressed by the high standards maintained in this area. Although

exceptions-to the high housekeeping standard _have been found.(e.g.,

the. Terry Turbine Room), such exceptions have required only cosmetic

. attention to meet the overall high standard. -There:has'been no-

. problem with graffiti ~onsite. 'These conditions are the result of

overt management policy emanating from, and designed to further,

employee pride in the workplace. A written station policy.deline-

ates respons 4flities_for maintenance of plant housekeeping. 'Fre-

quent supervisor presence in the workplace and regular tours by

plant management staff serve to reinforce this policy. . Adequate

plant services staff and support are allocated to housekeeping.

As a result of the licensee's concerted effort, personnel instinc--

tively maintain the _high cleanliness standard. Disciplinary meas-

-ures are not-required to maintain these. conditions.

~

The overall performance ~ rating in this area would be higher if.it

1were not for the multiple problems with fire barriers. As noted

in.the preceding, this problem now' appears to be under control.

b 2. ' Conclusion

Rating: Category 2

Recent Trend: : Improving

3. Board Recommendations

Licensee:

Maintain attention to fire barriers.

~

--

,

--

Discuss with NRC the status of findings and corrective actions-

related to the Appendix R implementation program.

NRC: None.

s

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_ . . _ _ . . _ .

21

F. Emergency Preparedness (338 hrs., 12%)

1. Analysis

The previous SALP evaluation rated licensee performance in this area

to be Category 1. During this assessment period, three inspections

of emergency preparedness activities were conducted by NRC regional

I

inspectors. One inspection evaluated licensee performance during

the annual full-scale emergency exercise conducted on May 12, 1984.

Also, after the SALP period, the March 30, 1985 annual emergency

exercise was observed. This exercise was included in this analysis

insofar as it reflected on the performance trend.

NRC inspections resulted in one violation for failure to provide

required training to six personnel assigned emergency response

duties. Additionally, six concerns related to the licensee's dose

assessment program were identified. The licensee was responsive

to these problems and has proposed or completed corrective actions

in each area.

NRC observation of the annual emergency exercise on May 12, 1984

identified three significant deficiencies.

--

The information flow from the Control Room / Technical Support

Center (CR/TSC) regarding plant parameter data and plant in-

formation was not timely and in some cases not clear.

--

According to the Emergency Action Levels, a General Emergency

classification should have been declared at 8:45 a.m., based

on a simulated loss-of-coolant accident and a simulated loss

of the emergency core cooling system. This classification was

delayed until approximately 10:00 a.m.

--

During the exercise, the TSC did not demonstrate the technical

functions typically provided by a TSC. These functions include

technical evaluations of plant conditions and development /or-

ganization of accident response and emergency repair activities.

In particular, the TSC staffing including the number of re-

sponders, their experience, and timeliness of reporting did

not support the performance of the required technical support

responsibilities.

j A management meeting was held June 1, 1984, at which the licensee

I proposed satisfactory corrective actions to address these problems.

These actions were incorporated into NRC Region I Confirmatory Ac-

tion Letter 84-10. During plant events on July 5 and August 21,

1984, involving a reactor coolant loop stop valve leak and the re-

fueling cavity seal failure, respectively, the licensee assembled

a highly effective event support organization in the TSC. This

group consisted of management and supervisory personnel. Although

the emergency organization was not implemented during these events,

. .-

-.

,

'

22

NRC noted a potential conflict in function and work space between

this group (which forms naturally during any event response) and

the licensee's. formal TSC responders (which should serve the same

. functions). To. address this, the licensee added several supervisory

personnel to the emergency call-up list. These personnel will sup-

port or relieve, as appropriate,_the normal emergency support on-

call personnel. After the SALP period, improved TSC performance

was noted during the annual emergency drill.

The licensee has been responsive to NRC initiatives and acceptable

responses were generally proposed. A long standing open issue re-

garding the location of the TSC was resolved during this SALP period.

The licensee responded to NRC questions on this topic in a timely-

fashion. The result was licensee justification and accomplishment

of relocation of the TSC from near the control room to the E0F.

The licensee's onsite emergency preparedness staff consists of one

-

full time coordinator. In addition, ample corporate and contractor

personnel are available as required to support emergency preparedness

- activities.

2. Cc,iciusion

Rating: Category 2

Recent Trend: Improving

3. Board Recommendations

.

Licensee: Continue efforts to improve the coordination of emergency-

- response activities.

NRC: None.

I

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2 -

G. . Security and Safeguards (156 hrs., 5%) -

-

- 1. Analysis

The previous SALP found performance in this area.to be Category 1.

g During this assessment period, three routine physical protection-

n " inspections were performed by region-based inspectors. Routine

. resident inspection continued throughout the SALP period. -

Management interest.in and attention to the physical protection

. -program is evident and has resulted in no violations of NRC require -

ments during two consecutive assessment periods. Both site and cor-

g porate. security. management representatives are currently upgrading

their audit programs, utilizing-NRC inspection procedures for the

~

~

physical protection. program. This includes the incorporation of . -

E -

the generic features of these-inspection procedures into a formal

corporate audit plan and a site self-assessment program. The two

programs are conducted independently.under the Corporate System

Security Director and the Site Security Supervisor,'respectively.

,

The site-self-assessment program will be . accomplished primarily.by

ti

site security shift supervisors and is intended to keep them current

.

t'

with the detailed functional requirements of the security program ,

and to prov.ide a means for making improvements to the program.

. Evaluations and recommendations are encouraged from all personnel.

.

, s Renovation and refurbishing of the security building and general

"

upgrading of supervisor's offices.and the access control area was

.-in progress during the SALP period. The-purpose of this project

was to improve-the working environment for guards and provide pri-

'

vacy for discussions between supervisors and_ subordinates. The

firearms range facility has also been' improved over the past few

years.- These initiatives by plant management demonstrate their <

commitment:to an effective security program. *

~

The licensee reported a total o'f seven Security Event Reports during

this period. .Four events involved computer system difficulties

.

L causing some degree. of. system loss. ~~ The ~others: involved a flooding

! incident which degraded security hardware, a peaceful demonstration,-.

and a threat received by telephone.' Appropriate compensatory meas---

ures for each event were implemented in a timely manner and in ac- '

L cordance with NRC requirements. Computer-related events were ana-

' lyzed for cause, repairs were promptly effected, and-down time was

minimal. The event reports were well prepared and informative, re-

,

.

F flecting the quality of supervision and attention to detail.

L , In 1984, the licensee. accomplished an innovative solution to a

. problem affecting the set up of one alarm zone. Vibrations from

e nearby equipments and river water exposure had caused an unaccept-

t able frequency of spurious alarms in this zone. Compensatory meas-

p ures were implemented and a series of controlled experiments were

l:,

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24

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initiated to resolve the system problem. The. solution involved the

-

. funding of maintenance, instrumentation and calibration outside.

contract = assistance,. and interim compensatory actions, and reflects

>

.the highLimportance the licensee'placed on. maintaining a quality

.

tprogram.

.

Staffing of the licensee's' security organization was consistent with

'the administrative, logistical and operational support needs of the

i- security program. Human resources were: allocated efficiently and

= were found to-be professionally competent. Facilities equipment ,

and systems were effectively maintained. 'This degree of management

attention:further demonstrates the licensee's commitment to a qual-

A

ity program.

'

zThe . licensee' has expanded the security training program, particu-

larly in-the area of contingency response actions. Various drill

scenarios have been developed and'are constantly updated in response

.to current-events. Licensee supervisors are required to confirm

-the capabilities of the security force.by conducting random and im--

'

- promptu'drillsfon a frequent basis._ This.is done to. reinforce for-

. mal and on-the-job training and to enable supervisors to determine

the. performance of the force under stress conditions. There has

also been significant improvement-in rapport with~other plant func-

'

"

tions as a: direct. result of their participation in such drills.

Records indicated that the licensee had conducted 56 security drills

'

during CY 1984._'The training records were well organized and were-

accessible. The licensee continues to provide funding for career;

i

development opportunities for security personnel in an effort to'

provide depth in personnel qualification and to stimulate morale.

-

2. Conclusion

Rating: Category 1 -

TRecent' Trend: Improving

,

3. Board' Recommendations

, Licensee: None-

_ NRC: Reduced region-based inspection priority for routine inspection

' effort.

.

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y H .' = Refueling and-Outage Management.(215' hrs., 7%)

w

. 1.- ' Analysis-

Previous licensee' performance in.this functional area has-been o

Category 1. A 15-week refueling outage (August 1 - November 14,

~1984) was conducted during this SALP period. ThreelNRC inspections"

-were conducted by region-based inspectors during the refueling out-

-

Lage and the resident inspector r'evie'wed licensee preparation for

refueling and refueling activities.' Areas reviewed included outage

_

^

~

coordination, new fuel receipti refueling operations, inservice <in--

4

spection, radiological controls, and a refueling cavity seal failure.

m The planning a'nd coordination of _ outage activities continued to be

-

a. noteworthy strength in the licensee s management control' system.

Computer-tracked planning and aggressive supervisory control of.

plant activities enable the licensee to maintain accurate critical

path monitoring and coordihation of contracted work activities to

maximize outage efficiency. .The licensee also maintains round-the-

clock management-level supervision and coordination.

'

.During this. refueling outage, there were two events which challenged

the licensee's ability to deal with unexpected conditions: requiring

significant expenditure and coordination of licensee assets. The

first event o'ccurred when'the redesigned refueling cavity seal

-failed because of inadequate design. -About- 200,000 gallons of con-

taminated reactor grade water drained to the containment floor,- .

causing significant problems with contamination cleanup and wetted-

equipment. The second event involved the identification of 58 de-

.fective U-tubes during steam generator (SG) eddy current testing

of SG-2 and SG-3. As a result, a.majo'r. expansion of the SG eddy -

current inspection program was-required. All U-tubes in each-SG

were inspected and the defective tubes were plugged. The licensee '

satisfactorily: incorporated the seal failure recovery actions and

the augmented SG inspection program into the outage schedule using ,

a conservative approach to these two events. The outage was ex-

'

-tended from 46 to 105 days because of the seal failure and SG work.

-

'

-Maintenance and surveillance activities performed during the re-

L'

fueling outage were properly conducted as described in previous

sections of this assessment. ~ Adequate staffing levels were main-

, tained through contracted health physics, quality control-and in-

. termediate maintenance personnel. ,

.a

2. Conclusion

U Rating: . Category 1

~

-

Recent Trend: Consistent

.

t.

'l

1

. . - _ :. _..a,a-.-..~,__.._...-_n._ . . . . . , _ , _ _ , _ . - - , , _ - . . _ , . . . , , , . _ _ , - _ _

-

__

26

.

'.

,.

-

3 .' Board Recommendations

-

. i

Licensee: None.

NRC: None.

<

,l

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9

l ,

,,

f

h.

I' ',

-

f. .

.

i-

27

x

I. ' Design Change' Control / Quality Assurance (310 hrs., 11%)

1. - Analysis-

Design Change Control (DCC) and-Quality Assurance (QA) are addressed

as a separate-functional area to highlight significant strengths-

and weaknesses. Four NRC inspections were conducted by region-based

inspectors-during this SALP period. DCC/QA activities were observed

by the resident inspector throughout the period.

The licensee has a strong commitment to high quality. QA philosophy

emanates from senior level management and emphasizes proper perfor-

. mance the first time (proper planning and implementation) and that-

- QA is everyone's job. The QA organization is not looked upon as

the central control for quality, line management is. Understanding

of this commitment to quality is evident at all levels of the or-

ganization. Notwithstanding, instances of poor performance and

non-aggressive management followup of these instances may contribute

to a weakening of the quality / safety' ethic at the working levels

of the organization. For example, several concrete imbedment an-

chors for seismic supports in the diesel generator rooms did not

have sufficient thread engagement.- Despite specific installation

procedure acceptance criteria, quality control-(QC) signed off on

the incorrect installation.

.

Engineering and construction personnel

approved the installation because, in their judgement, the thread

engagement discrepancy was not significant. Upon NRC identification,

the discrepant anchors were formally dispositioned to "use as is"

and QC inspectors were cautioned to be more careful. The licensee

did not take action on the construction and engineering personnel

willingness to deviate from the installation procedure in this case.

However, as a result of other procedural compliance problems, the

licensee has taken action to strengthen the correct usage of proce-

dures by all plant personnel. Also, licensee QC identified that

the reactor cavity inflatable seals had been modified (by pressing

L pins through the solid rubber section of the seal) without an ap-

proved procedure, material certification for the pins, or quality

Nonconformance reports were written on these

control

deficientinsp@ection.

p .:tices and were subsequently dispositioned to "use as

is" based on post-maintenance inspection and verification of mate-

rial certification documents. In discussions with the licensee,

NRC found that this modification had been initiated on a " risk"

basis in order to expedite its implementation pending satisfactory

, resolution of quality requirements at a later time. The licensee

considered that management knowledge of the necessity to resolve

all outstanding quality issues prior to refilling the refueling

cavity provided adequate assurance of the fulfillment of quality

requirements. However, the licensee bypassed the normal procedures

used to expedite and control time-sensitive maintenance and limit

after-the-fact determination of quality. No strong licer.see effort

to prevent recurrence was observed.

.

-

- ,-e-- ,=-+-e-.

y -

,

_

q

1

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4

~

,

28

'

-The~ QA: audit program is well defined and implemented. The scope,'

<

,: .- , planning, scheduling and execution of-plant audits is thorough and

receives appropriate management review. Audit findings are accurate

?and_ valid and plant corrective action is generally effective and

' timely. In one cas~e, an NRC inspector noted that his concern over

ineffective disposition of. inservice testing non conformances had.

not been resolved by corrective action.for a similar finding in a

. plant audit dated July.6,.'1984. Plant'Information Reports identi-

fying inservice-testing program nonconformances did not provide the

controls for effective disposition required by the:nonconformance

reporting system. -Further licensee action was necessary to resolve

'

-this issue. _One~ violation was cited for not auditing all corrective

~ action, programs. Although difficulty was experienced in resolving

which systems fall into the category of corrective action programs,;

once'the safety concern was understood, senior licensee management

provided prompt support to resolve this issue. The licensee has

also implemented a. computer-based trending program which moni_ tors

,

quality-related inputs (NCRs, audit findings, NRC findings,Letc.)

.throughoutLthe utility organization. This program is in its initial

implementation, but has the potential to be an effective tool for:.

long term monitoring of quality-related activities.

While the QA audit program successfully reviews the correct imple--

mentation of safety-related activities from a documentation review--

L ' standpoint, QA/QC surveillance _of ongoing' activities has been less

. effective. Specifically, observation of ongoing activities, tech-

_

nical review of observed procedures, and QA/QC involvement in evo-

J lutions such as plant startup testing and radioactive waste trans-

' -

.portation have been weak. The licensee. recognized this problem and

'

'has-made:an effort, especially during outages, to' observe more on-

.-going-activities.~ There was adequate QA/QC coverage of the con-

-

.tainment leak rate test in August 1984. Plant personnel have indi-

cated, however,.that QA/QC staffing limitations prevent further ex-

'

pansion of this effort. NRC inspection in April 1985 (after the

SALP. period) indicated that radwaste QA/QC continued to be a weak-

~

<

ness, in that QA coverage was an after-the-fact instead of an in-

J

,

'

- process review. Licensee management attention to improving the QA

surveillance effort'is indicated.

^

Several component / design failures, including the post accident con-

tainment" air sample valve, the conteinment high range radiation

, monitors and the reactor refueling cavity pneumatic seal revealed

~

significant weaknesses in the -licensee's DCC program. These in-

- cluded the level of detail / justification documented in design pack-

ages, inadequate construction details, inadequate pre-operational

testing, and inadequate review by management review bodies. NRC

. inspection identified five violations in these areas. Three of

these resulted in' escalated enforcement actions. The licensee re-

sponded to each identified problem. A task group headed by senior

management was formed to evaluate and revise the DCC program to re-

f

_

-_ . .-

%

'N'.

. 5

i

-

29-

l

l

'

4

- fquire-more' detail, documentation, and control of future design!.

'

-changes. However,-the licensee focused ~ corrective actions on new

changes and conducted only limited reviews of previously completed

design change packages. 1After.several. problems were identified in

separate areas.of different changes, NRC prescribed, in an Order:

-

on the license, comprehensive corrective action including an inde-

pendent review of old-design changes. By the end of the assessment ,

period, the. licensee had implemented a comprehensive revision to-

the DCC program procedures and conducted specific training in these

, procedures with all.affected personnel. The ordered independent

review-is underway.

'One further problem identified during the period involved an inac- ,

curate list of quality-related systems and components-(MEPL). The

licensee had recognized this problem and had.a. low priority project

ongoing to correct it. . In. general, the licensee had compensated

.for this condition by' conservative interpretation of system QA

boundaries. ~However, one violation was identified where a component

was maintained without quality control because of incorrect'QA

classification. As a result, the MEPL update project was given

t higher priority, and satisfactory. interim actions have been imple-

mented to' insure. correct classification of quality-related compo~-

nents.

2. Conclusion

Rating: Category 2-

Recent-Trend: 2 Improving

~ 3. Board Recommendations

' Licensee: Continue implementation'of DCC/QA program improvements

and review the effectiveness of the QA/QC surveillance effort.

-NRC: Perform a programmatic review of licensee quality assurance

activities focusing on design change control and QA/QC surveillance.

-

9

.

N

k'-

,, -. . . - - - . _ ~ , _ . . , . _ . _ _ _ . _ __ _ _ - _ . _ _ . - _ . _ --_-_- _.

-

,

'

,

w

, - e

30 1

~

.

, .. .

. ?J.- Licensing-Activities i

o .

-

-l. Analysis

~

<

The basis of this,. appraisal was the. licensee's performance,in:sup--

- port offlicensing actions that were either completed or active dur-

"

.ing the current rating period. 'These consisted of amendment-re-~.

quests, exemption requests, responses-to. generic letters,;TMI' items, .

SEP topics, and other' actions. _

,

At the start of the'SALP-rating period,-there were 68' active licen-

.

- sing issues. During the 18 month period, 22 issues-were1 completed-

and 29 new issues were~added. Thus, at the completion of the iating"

'

period, 75 active issues remain. The licensee's. staffing is:ade6

quate with only occasional-difficulties with backlog. Two vacaNies;

have recently been filled in the licensing organization and improvedi

. performance in this area is expected. The. licensee and NRC are

meeting. regularly' to coordinate efforts'to reduce the backlog of ,

-licensing actions. 'The licensee has built up their technical staff

s- - and' management such that most. safety. issues can be resolved without

outside assistance.

-

-

Licensing activity'during this SALP period has been at a high. level;

In. addition to the routine actions and completion of a number of:

~ SEPLi_tems,1 major activities-have-included ~a fuel reload, approval

of exemptions from 10 CFR 50 Appendix R, and an incident involving ~

the failure'of the reactor cavity: seal.used during refueling.' These.

activities showed the involvement of licensee management in prior - -;

planning of activities and in'exerci_ sing explicit' control of.the

licensing activities. .The staff'was pleased with the outstanding . .

commitment to safety demonstrated by corporate management after the

reactor cavity seal failure. It was obvious that management played'

_

a significant role in responding to the event.

In the resolution of technica1' issues, the license'e has exhibited

~

- an understanding of the issues and a conservative. approach has'been

- routinely employed. For example, the information submitted in con-

junction with the resolution'of' fire protection issues disp)ayed'

clear understanding of staff concerns with the level of fire-pro-

tection at Haddam Neck. 'The licensee's commitments'and the justi-

fication provided in support of the fire protection program and

,

alternate safe shutdown exemption request-were based on sound fire

protection engineering principles. The licensee's performance for

other individual licensing actions was similarly competent and-

generally timely. However,.the licensee's submittals for the de- ,

>

graded grid voltage issue were characterized as not so timely or

complete.

In conclusion, management attention and involvement with matters

of nuclear safety are consistently evident. The licensee's resources

are adequate and the staff is'well trained, providing a satisfactory

, ~

+ ar.-wx.--case ew--,e,- m --e-- ,-e,r-et.asr.+ e--r e r ste t m w v * '--=-- 1 v = a-

e-- ---'---w-------:reePve-re-ty-

, . - .

,

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31

.

-performance 'with respect to-operational safety. .The-licensee's -

~

1 responses were; generally timely'and the' proposed resolutions to

, , g:4 pp clicensing.. issues'are usually. technically sound.and thorough.

.

c , .

A 4~~;2;' 'C6nclusion.

. > _ ' .,

, y

- - -  ? Rating: - Category l'

'

- - .? -

1Recent Trend: Consistent

'

.' 3.-~~ Board Recommendations

Licensee:' As indicated in Sections B and D, the licensee should ag-

<:- gressively pursue licensing resolution in the areas of 10 CFR 50

-Appendix J compliance and operation of the post-accident sample

system at power.

-

NRC: None.

.

\ ~

t

9

i-

32

V. SUPPORTING DATA AND SUMARIES

A. Investigations and Allegations Review

There were.no investigative activities during this SALP period.

B. Escalated Enforcement Actions

1. Civil Penalties

-A civil penalty of $80,000 was assessed on December 13, 1984, for

violations of design control and committee review requirements re-

lated to the August 21, 1984 refueling cavity seal failure.

2. Orders

.A confirmatory order was issued June 13, 1984, on commitments for

emergency response capability.

An order modifying the license, issued on December 13, 1984, related

to the August 21, 1984 refueling cavity seal failure. .The order

required independent review of the design change program and cor-

rective actions for identified deficiencies.

3. Confirmatory Action Letters

A confirmatory action letter was issued on June 5, 1984 regarding

corrective actions for significant deficiencies identified by the

NRC during review of the annual emergency exercise on May 12, 1984.

C. Management Conferences Held During the Assessment Period

1. On November 14, 1983, an enforcement conference was held at the NRC

Region I office to discuss the post accident sample system discre-

pancies found during NRC inspection 50-213/83-25.

2. On November 29, 1983, a SALP management meeting was held at the

corporate office in Berlin, Connecticut to discuss the SALP report

for the period September 1, 1982 - August 31, 1983.

3. On June 1, 1984, a management meeting was held at the corporate of-

fice in Berlin, Connecticut to discuss significant deficiencies re-

lated to the May 12, 1984 annual emergency exercise and documented

in NRC Inspection Report 50-213/84-10.

4. On October 1, 1984, an enforcement conference was held at NRC Region

I to discuss design control deficiencies related to the August 21,

1984, refueling cavity seal failure. These deficiencies were docu-

mented in NRC Inspection Report 50-213/84-23.

!

... - - _

. _

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~ 33 ' ^

'

-

-

,.

u 5) 10n . December 6,1984, an e~nforcerant conference was held at NRC Re-

- gion I to discuss a potential radiation over-exposure event which

, was documented in-NRC Inspection Report ~ 50-213/84-24.

'

, -

6 '. . On December 17, 1984, a managementimeeting was-held at the Millstone

- site in Waterford, Connecticut to discuss; licensed' operator requali '

O _ fication program deficiencies documentedlin NRC Inspection Report

- 50-213/84-31.

'

'D. Licensee Event Reports- _

, ,

,

< Tabular' Listing

- <

,

l Type'of' Events:

,

A.; ' Personnel Error ~.......................................... 13-

18. D'esign/Manf./Constr./ Install .............................. 5

C.- External?Cause ............................................. O

D. . De fective P rocedure . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-

E. . Component Failure'........................................ 11

X. Other .................................................... 10

Total 42'

Licensee Event Reports Reviewed

"

,

. Report Nos. 83-15'through 85-02.

y

Causal Analysis.(Rev'iew Period. January 1, 1982 - February 28,1985);

-Five sets of common mode events were identified:

'a. LERs 84-01, 84-03, 84-06, 84-08 and 84-18 reported fire door' prob-

- lems ' caused by inadequate personnel understanding and respect for

-installed fire barriers.

b. LERs 84-04-and 84-22 reported inoperable penetration fire seals

-

caused by~ maintenance / construction personnel failing to-follow plant

procedurts.

c. LERs-83-04 and 84-12 reported failures of the containment penetra-

tion local leak rate tests. Two check valves (CC-CV-721 and 885)

were.particular contributors to the failure of both these succes-

sive refueling interval tests.

.

.s

_

.

34-

- d. LERs 84-16 and_85-01 reported failures of automatic containment

isolation valve MS-TV-1212 to trip properly.

e. ~LERs 84-09, 84-21 and 84-25 reported plant trips caused by personnel

error and inadequate procedures. -These were the only unplanned

trips during the assessment period.

Thirty eight percent of the~LERs submitted during this assessment period

involve personnel or procedural errors ~ as causal factors. This high

percentage-of personnel and management'related errors, when compared to.

5 and 17 percent' reported in the previous two SALP evaluations, was noted

as an. adverse trend.

t

9

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35'

.

4

STABLE'1

INSPECTION HOURS SUMMARY (9/1/83 - 2/28/85)

HADDAM NECK PLANT'

,

HOURS  % OF TIME

' 7-A. s Pl ant; 0perati ons . . . . . . . . . . . . . . . . . . . . . . . . . . . . ' 739 25

_

.B.t Radiological Controls ...................... 373 13-

1C.= . Mai$tenance ................................ 237 8

D.. Surveillanc'e ................................ 327 11

'

E. Fire Protection / Housekeeping ............... 123 4

F.  ; Emergency. Preparedness ...................... 338 12

1G. SecurityLand Safeguards .................... 156 5

'H. Rifueling & Outage ManagementJ...............'215 7

JI. Design 1 Change Control / Quality Assurance 1..... 310 11-

J. Licensing Activities ........................-109*-

.

_J[

Total 2927 100

,

-*0perating Reactors Licensing Activities performed by Region I personnel. NRR

. personnel time'is not included. ,

-Note: . Allocations of Inspection Hours vs. Functional Areas are approximations

-based on inspection report data.

.

_,- ._ _ . _ . . . _ _ _ _ . - - , _ . , _ _ .- _ - . . - . _ . . . . _ - . . . . _ . - - _ _ _ _ . _ _ _ - - . _ -

__

.

. , --

36

TABLE 2-

VIOLATION-SUMARY (9/1/83 - 2/28/85)

'HADDAM NECK NUCLEAR POWER PLANT

-I. Number and Severity Level of Violations and Deviations

Severity Level'

Severity Level ~I 0

Severity Level.II 1

Severity Level III 2

Severity Level IV 7

Severity Level V 4

<

Deviations 1

TOTAL 15

II. Violations and Deviations vs. Functional Area

. Severity Levels

FUNCTIONAL AREAS . I II III IV V DEV

A. P.lant Operations

B. Radiological Controls 1 2 1 -1

C. Maintenance

D. Surveillance 1

.E. . Fire Protection'& Housekeeping 2

F. Emergency Preparedness 1

G. Security Safeguards

H. Refueling & Outage Management-

I. Design. Change Control / Quality Assurance 1 1 2 2

J. Licensing Activities

Subtotals 0 1 2 7 4 1

Total -------15--------

D

y

n -

.

37

, _  !

.III. Summary

.

-Inspection; : Inspection. Severity Functional

' Report No. -Date -Level Area Violation

-

183-22 9/26-30/83- IV 'E- Failure to perform Tech Spec

surveillance-

L83-24- 10/3-7/83 V- I- Inadequate audit of Plant In-

formation Report system

' 83-25'- 10/24-28/83 III I Post-accident sample system

inoperable-

83-26: ~11/14-18/8'3 V B Failure to follow a transuranic

~ analysis procedure-

83-28) 12/5-8/83 IV. F -Failure to provide-required

training

84-03' 2/1-3/30/84 'V D Failure to control gauge

calibration

-.84-11- 6/26-29/84 IV~ B Failure to follow receipt,in-

spection procedures-

'

'IV B Failure to conduct a quality

control program

DEV B Rad Waste handler requalification

program not properly implemented

84-14' 8/29-10/31/84 IV E Failure to seal a fire penetra-

tion barrier

, V I Inadequate field change review

procedures

.- 84-22 ; 8/25-28/84 IV I Design basis for Emergency Diesel

Generatorss not correctly trans-

lated into procedures

<

84-23- 8/21-9/4/84 II* I Failure of safety committees to

identify an unreviewed safety

question

II* I Inadequate design of the refuel-

[- ing cavity seal

l

p

[

r

• 0ne-aggregate Severity Level II violation was assigned for these two violations.

kO .

.,_. -

38

Inspection- Inspection Severity Functional

. Report No. Date Level Area Violation .

84-24 10/22-23/84 III** B -Inadequate health physics tech-

nician qualifications

III** B Failure to provide training in

-

radiation protection procedures

III** B Failure to provide positive con-

trol over high radiation area

work.

84-26 11/13-16/84 IV I Failure to maintain quality con-

trol of a safety-related com-

ponent.

85-03 2/12-15/85 *** D Inoperable Reactor Protective

System (RPS) loss of flow

channels

• • • ' D Inadequate RPS surveillance

procedure

• • 0ne aggregate Severity Level III violation was assigned for.these three

violations.

• • • Enforcement action not yet issued

..

- - . .

__ .-. . _ - .. .~. ..

.

A L

P

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39

-TABLE ~3

.

-INSPECTION. REPORT' ACTIVITIES (9/1/83 ^2/18/85)

.

HADDAM NECK NUCLEAR POWER PLANT

'

Inspection -Inspection- Areas _

Report No. Hours- Inspected

=

.

83-20~ 54 - Routine resident

83-21-- 71 Routine' resident

[ 83-22 48 Fire Protection-

83-23. -42 Radiological Controls

'

-83-24: 24 Quality Assurance

.

83-25 ' :144 TMI Action Plan Implementation

83-26 64. Radiological Controls

.83-27 78 Routine resident-

L 83-28~. 60 Emergency Preparedness'

84-01 29 Security and Safeguards-

~

84-02 96 Routine resident

84-03- 167 Routine resident 1

-84-04 .28 Non-radiological Chemistry Program

84-05 102 Followup on It Bulletins

84-06 50 Emergency Preparedness

- 84-07. - 135 Routine resident

, -

84-08 22 Design Change Control

84-09- 70 Quality Assurance / Training

84-10 228 Emergency Preparedness

'84-11- 37. Radwaste Transportation

84-12 86 Routine resident

vs -

<

~ '

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40 '

, -

,

'L.,

'

.

,

Inspection. Inspection ~ Areas

Report-No. Hours ~ Inspected

,84-132 29 Containment Leak Rate Testing

.-84-14= 352- Routine resident

84-15 (cancelled)

84-16~ 24 ' Radiological-Controls

_

84-17 20 Operator Licensing Examinations

'

84-18" 24 Loss of AC Event

'84-19  ; 64 Degraded Grid Voltage

84-20- .45 ' Security & Safeguards

i84-21 56 Inservice Inspection Program

.

,84-22 78 Loss of Offsite Power

.84-23; 63 Cavity Seal' Failure

'84-24' 32 Review of Exposure Event-

84-25 '21 Containment Integrated Leak Rate Test

84-26 106 . Followup on NRC Generic Letter 83-28

'84-27_(cancelled).

84-28 101 Routine resident

84-29; 32 Security and Safeguards

84-30 24 Radiological Controls

84-31: 28 -Requalification Training

-84-32~ 60 Routine resident

85-017 100 Routine resident

85-02 30 startup Testing

85-03 9 Inoperable Loss Of Flow Trip

_

, . _ _ _ - _ - _ _ _ _ , .

4

Ei

g 41 -

,

,-%

'

(

'

H. TABLE'4

. TABULAR LISTING OF LERs BY FUNCTIONAL' AREA

-

"

HADDAM NECK PLANT

'

' AREAL NUMBER /CAUSE CODE l TOTAL:

'

,-

A. Plant,0perations- 1/A,' 2/B, 1/D, S/E, 2/X' =11

-

B.. Radiological Controls'- 1/A 'l

i . C. 2 Maintenance. 2/A, 1/D -3-

'

10. . Surveillance -3/A, 6/E, 5/X 14

E. Fire Protection / Housekeeping 6/A, 1/B, 1/D, 1/X 9'

F. -Emergency Preparedness ' NONE.

G. Security and Safeguards NONE

~

H. ' Refueling and 0utage Management 1/B 1

I. Design Change Control / Quality 1/B 1-

1 Assurance

-J. -Licensing Activities '2/X. 2

TOTAL ~ 42

'

Cause Codes

'

. A'- Personnel Error.

B - Design, Manufacturing, Construction, or Installation Error

'

C - External Cause

.D'- Defective Procedures

E - Component Failure

X - Other

L

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l.

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L

L

.

!

- -. . .L . ,-, - - . . , . - . - . . . . - . . - . . - . . . . . - - . - . _ . - . _ _ . . , _ _ _ , . . - . . . _ . . . . - . .

O g, -

,

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'

-TABLE-5

LER SYNOPSIS'(9/1/83 --2/28/85)

-HADDAM NECK NUCLEAR POWER PLANT

LER No; Type. Summary Description

[ .

83-15-3L: .30 day  : Pressurizer level instrument failure

-83-16-3Li '30 day Failed charging pump bearing thermocouple

- ;83-17-1P  : Prompt. Post accident sample system inoperable-

,83-18-3L 30 day  ; Charging' pump out'of service due to seal leakage

_

+ !83-19-3L? 30 day Low pressure safety injection pump start timer. slow

83-20-3L' 30 day Loss of containment control air

-Loss of containment control air

~

83-21-3L 30 day.

~

83j22-3L- 30 day- Failed volume control tank outlet valve control circuit

>

'83-23-3L 30 day ~ Diesel generator 2B assumed load greater than the governor--

setting

'

83-24-3L - 30 day -Inadequate: service water to the Containment Air Recircu-

lation (CAR) fans:

83-25-3L. 30 day Failure of the control rod motion slave cycler

84-001-00 .30 day. -Fire doors inoperable

~ 84-002-00 -30 day Screenwell fire detection system inoperable

84-003-00 -30 day Inoperable fire door

84-004-00 30 day Inoperable fire barrier

84-005-00- 30 day Potential non-conservative 3-loop operating condition

'

'84-006-00

.

30. day. Inoperable fire door

84-007-00 30 day Degraded. cable penetration fire barriers

'

-84-008-00 30 day Inoperable fire door

.84-009-00 30 day Total loss of offsite power / reactor trip

n. -

,

.

,

-

-

a

1. . ,

'l

l

,

43

'

L '

,

'. LERL No. Tyge Summary' Description

-84-010-00- !30 day ~ . Reactor. coolant system overpressure protection system

zinoperable~

84-011-00; 30 day. Containment integrat'ed leak rate test: failure

84-012-00.

~

30; day Containment local. leak rate test failure

-84-013-00 30 day Reactor, cavity' seal. failure

.84-014-00 30 day Loss of offsite power;-diesel generator failed to pick'up

load'

. 184-015-00- 30 day- -Steam generator tube degradation-

-84-016-00 130 day Slow containment isolation valve-

84-017-00 -30 day -Degraded reactor protection system wiring

84-018-00 30 day- Inoperable fire door

84-019-00 :30 day Containment isolation valves improperly opened

84-020-00 30 day . Potential ~ personnel overexposure during maintenance

ts

?84-021-00 30 day Spurious ~high startup rate trip during physics testing-

84-022-00 -30 day . Inoperable fire barrier penetration seal

-84-023-00 30 day Failures of Westinghouse circuit breaker relays

84-024-00 30 day False steam flow indication-in reactor protection' system

~

84-025-00 -30 day- Reactor trip due to inadvertent trip of Reactor Coolant

Pump #3

84-026-00 30 day Manual reactor trip due to voltage regulator malfunction

84-027-00 30 day Reactor protection system overpower setpoint drift

.

84-028-00 30 day Out of specification main steam safety valve settings

84-029-00 30 day -Spurious load runback due to nuclear instrument setpoint

drift

85-001-00 30 day- Containment isolation valve failed to open (MS-TV-1212)

.85-002-00 30 day Reduced Containment Air Recirculation fan flow

,

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~ TABLE 6

UNPLANNED NUTOMATIC SCRAMS'

- Date. - Power Level Cause

- 8/1/84- ^0% Loss of offsite AC power during plant shutdown due

to. operator / procedure error.

.  : 11/3/84 0% -High startup rate trip due to technician error.

11/20/84 100%- Loss of flow-due to inadvertent shutdown of number

.three reactor coolant pump.

~

FORCED OUTAGES / POWER REDUCTIONS

Date- ~ Power' Level Cause

- 3/13/84 - 100% to 5%

.

Suspected control rod malfunction.

11/09/84- 25% to 0% Main turbine generator problems.

11/15/84 25% to 0% Manual trip due to main generator voltage regulator-

-cycling.

.

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