ML20138B701
| ML20138B701 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 03/19/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20138B687 | List: |
| References | |
| 50-305-86-01, 50-305-86-1, NUDOCS 8603250135 | |
| Download: ML20138B701 (35) | |
See also: IR 05000305/1986001
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SALP 5
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SALP BOARD REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
REGION III- .
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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50-305/86001 i' ~ .-
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Inspection Report No.
Wisconsin Public Service Corporation
Name of Licensee -
Kewaunee Nuclear _' Power Plant -
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Name of Facility '
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( July 1, 1984 - December ~31, 1985
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Assessment Period -
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to proi.:ote quality and safety of plant construction and operation.
A NRC SALP Board, composed of staff members listed below, met on
February 14, 1986, to review the collection of performance observations
and data to assess the licensee performance in accordance with the
guidance in 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 is the SALP Board's assessment of the licensee's safety
performance at the Kewaunee Nuclear Power Plant for the period July 1,
1984, through December 31, 1985.
SALP Board for Kewaunee Nuclear Power Plant:
NAME TITLE
J. A. Hind Director, Division of Reactor Safety and Safeguards
(DRSS)
C. J. Paperillo Director, Division of Reactor Safety (DRS)
G. E. Lear Project Director, Project Directorate No. 1, PWR A
L. A. Reyes Chief, Operations Branch (DRS) '
E. G. Greenman Deputy Director, Division of Reactor Projects (DRP)
M. B. Fairtile Project Manager, Kewaunee, NRR
L. R. Greger Chief, Facilities Radiation Protection Section (DRSS) I
M. P. Phillips Chief, Emergency Preparedness Section (DRSS) l
M. Schumacher Chief, Radiological Effluents & Chemistry Section
(DRSS)
R. L. Nelson Senior Resident Inspector, Kewaunee
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II. bRITERIA
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The licensee performance is assessed in selected functional areas depending
whether the facility is in a construction, pre-operational or operating
s phase. Ea.ch functional area normally represents areas significant to
nuclear safety and the environment, and are normal programmatic areas.
' ' ' Some functional areas may not be assessed because of little or no licensee
3 activ.ities or lack of meaningful observations. Special areas may be added
j to highlight significant observations. A
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One!or nore of the following evaluation criteria were used to assess each
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functional area.
A. Management involvement in assuring quality.
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B. Approach to resolution of technical issues from a safety standpoint.
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C.
ResponsivnessyoNRCinitiatives.
D. Enforcement history.
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E. Reporting and analysis of reportable events.
I F. Staffing (including management).
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G. Training effectiveness and qualification.
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
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Based upon the SALP Board assessment each functional area evaluated is
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classified into one of three performance categories. The definition of
these performance categories is:
Category 1: Reduced NRC ' attention may be appropriate. . Licensee management
attention and involv.ement are aggressive and oriented toward nuclear
safety; licensee rsources are ample and' effectively used so that a high
level of'oerformance with respect to operational safety or construction is
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being achieved.
Category 2: NRC attention should be maintained at normal. levels. Licensee
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management attention ~and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably
effective such that satisfactory performance with respect to operational
safety or construction is being achieved.
Category 3: 89th NRC and licensee at;tention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear
safety, but weakaesses are evident; licensee resources appear to be
strained or not effectively used so that minimally satisfactory performance
with respect to operationdl' safety or construction is being achieved.
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! Trend: The SALP board has categorized the performance trend in each
, functional area rated over the course of the SALP assessment period.
The categorization describes the general or prevailing tendency (the
i~ performance gradient) during the SALP period. The performance trends
are defined as follows:
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Improved: Licensee performance has generally improved over the
course of the SALP assessment period.
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j Same: Licensee performance has remained essentially
constant over the course of the SALP assessment
period.
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j Declined: Licensee performance has generally declined over
the course of the SALP assessment period.
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III. SUNRY OF RESULTS
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Rating Last Rating This
Functional Area Period Period Trend
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A. Plant Operations 1 1 Same
B. Radiological Controls 1 1 Same
C. Maintenance 1 1 Same
D. Surveillance 1 2 Improved
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E. Fire Protection 1 1 Same
F. Emergency Preparedness 2 1 Improved
G. Security 2 2 Improved
H. Refueling 1 1 Same
I. Quality Programs and
Administrative Controls Not Rated 2 Same
J. Licensing Activities 2 1 Same
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IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
Evaluation of this functional area is based on the results of
routine inspections conducted by the resident inspector. The
inspections included direct observation of activities, review
of logs and records, verification of selected equipment lineup
and operability, followup of significant operating events, and
verification that facility operations were in conformance with
the Technical Specifications, administrative procedures, and
commitments. One violation was identified as follows:
Severity Level IV: Failure to properly perform the surveillance
procedure for testing of the Nuclear Flux Source Range High Flux
Trip bistables. (Inspection Report No. 50-305/85016(DRP))
The violation occurred when the plant was returned to power
without properly performing the surveillance procedure. Failure
to perform the trip test and not remaining in hot shutdown was
a violation of a limiting condition for operation. The
Operator-Trainee mistakenly used the value for High Flux at
Shutdown as the High Flux trip setpoint. This violation was
of minor safety significance, and appears to be an isolated
occurrence.
Eight reactor trips occurred during this assessment period.
Three of the trips occurred at hot shutdown conditions, and one
trip occurred while the plant was at approximately 5% power and
in the process of being taken off-line. In addition, three
automatic and one manual trip occurred while at greater than j
70% power level. The four trips at greater than 70% power
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level resulted from component failures; namely, momentary loss I
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of instrument bus voltage caused by a loose connection; rupture !
of a two inch steam. vent line (the plant was manually tripped l
to facilitate isolation and repair); failure of a main feedwater
regulating valve; and failure of a constant voltage transformer {
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feeding an instrument bus. Two of the trips at hot shutdown and
the one trip at approximately 5% power were caused by personnel
error, the remaining trip at hot shutdown occurred during rod
drop tests while calibrating a nuclear power intermediate range
instrument. The post-trip investigation revealed that the
installed picoameter used for calibration of the intermediate
range instrument were at different ground potentials. The three
trips attributed to personnel error were caused by: prematurely
securing the main feedwater pump while the demand was greater
than that available from the auxiliary feedwater system; allowing
a steam generator water level to reach the low level setpoint
with an actuated steam flow /feedwater flow signal; and failure to
block the Source Range High Flux trip during plant startup.
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During this assessment period there were seven Licensee Event
Reports (LER) involving operator error, four involved licensed
operators and three involved non-licensed operators. The four
LERs involving licensed operators were associated with the
violation and reactor trips previously noted above. The three
LERs involving non-licensed operators resulted in: (1) the
refueling water storage tank being approximately 1.5% below the
Technical Specification (TS) limit for a period of approximately
six hours due to a valving misalignment, the misalignment was
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identified by an auxiliary operator while performing his routine
tours; (2) both fire pumps being inoperable for approximately two
minutes while performing a fire pump test, the event resulted
from performing the procedural steps out of sequence. The
control room operators were alerted to the condition by an alarm
and immediately initiated corrective actions; and (3) the
actuation of the auxiliary building special ventilation on high
temperature which occurred when an overpressure protection
rupture disk on the boric acid evaporator was ruptured, the
overpressure was caused by improper isolation of the steam
supply to the evaporator.
Individually, these events were of minor safety significance,
however, collectively these events indicate the need for improved
attention to detail by both licensed and non-licensed operators.
In each case the licensee's corrective actions were timely and
appropriate.
The overall performance of the Operations Group has continued
to be very good. The continuing excellent performance of the
Kewaunee Nuclear Power Plant (KNPP), as evidenced by the
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approximately 99.5% unit availability for scheduled operations
during this eighteen-month assessment period can be attributed,
in part, to the conduct of plant operations by very good,
professional on-shift operating personnel. The general
improvements noted during the previous SALP period in independent
verification; operational control of systems and components,
that is, use of out-of-service stickers and informational type
, tagging; and professionalism in which control room activities
are conducted have been maintained during this assessment period.
- The NR'
- issued Inspection and Enforcement Circular No. 81-02
, and Inspection and Enforcement Information Notice No. 85-53,
regarding the performance of NRC licensed personnel while on
duty. The circular and notice provided guidance on conditions
, and practices which the NRC believes to be necessary for safe
reactor operations. The licensee's policy for conduct of
operating shift activities is in accordance with the NRC i
guidance. The policy has been established through the use of 1
Administrative Control Directives, Operations Group Orders, and I
direct communications between plant management and on-shift I
personnel. The resident inspector's observation of shift
activities has indicated that those activities were conducted
in accordance with the established policy.
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Operation of the KNPP has historically been very reliable. As
of December 31, 1985, the plant had an availability factor of
83.6% with a unit capacity factor of 79.5%, this is a 0.7% and
0.6% improvement, respectively, over the values at the end of
the previous SALP period. This operating record was attained
as a result of several contributing factors; namely, experienced
and dedicated personnel; involved plant and corporate management;
effective formulation and implementation of preventative and-
corrective programs; and low failure rates of equipment.
During this assessment period NRC examinations were administered
to eight applicants for senior reactor operator licenses. Also,
during this period WPSC requalification examinations were
administered to 11 reactor operators and 19 senior reactor
operators. All candidates for the NRC senior reactor operator
license passed the examination. This passing rate is
significantly above the national passing rate. Of the 30
licensed operators who were administered the requalification
examinations, one reactor operator failed the examination.
Following remedial training, the individual satisfactorily passed
a re-examination. Based on the 100% passing rate for the NRC
examinations and 97% passing rate for the licensee's
, examinations, the training program for licensed operators is
considered satisfactory.
In 1983, Wisconsin Public Service Corporation (WPSC) began work
with the University of Maryland-University College to define a
curriculum which would significantly upgrade the knowledge level
of nuclear power plant personnel in the areas of Nuclear Science /
Engineering, Reactor Operations and Diagnostics, Thermodynamics
and the supporting scientific disciplines. This curriculum began
at the nuclear plant site in July,1984. This training is
accomplished by' computer aided instruction, conventional
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classroom presentations and tutored self-study modules with
l examinations. Since its inception, approximately fifty personnel
have enrolled in the program, the completion of which yields a
bachelor of science degree in Nuclear Science with a minor in
Technology Management. Other activities underway in support
of the degree program include the utilization of teaching
laboratories at the University of Wisconsin-Green Bay, assignment
of WPSC Nuclear Training staff as course mentors / tutors, and the
evaluation of onsite, WPSC taught courseware by the American
Council on Education for academic credit recommendations. The
overall program demonstrates WPSC's commitment to further the
education of personnel responsible for the operation of the
Kewaunee Nuclear Power Plant.
2. Conclusion
The licensee continues to be rated Category 1 in this area. No
discernible trend was identified.
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3. Board Recommendations
None.
B. Radiological Controls
1. Analysis
Evaluation of this functional area is based on four inspections
by Region III specialists and on routine assessments by the
resident inspector during implementation of the resident
inspection program. These inspections covered radiation
protection, radwaste management, disposal of low-level
radioactive waste, TMI Action Plan Items, environmental
protection, chemistry and radiochemistry, and confirmatory
measurements. Two violations were identified as follows:
a. Severity Level IV: Failure to complete Form NRC-4
before exceeding 1.25 rems quarterly whole body exposure
of a worker. (Inspection Report No. 50-305/85003)
b. Severity Level V: Failure to follow procedures requiring
a whole body count for an individual with facial
contamination. (Inspection Report No. 50-305/85003)
These violations are not repetitive and are not indicative of
programmatic or managerial breakdowns in radiological controls.
The circumstances surrounding these violations were thoroughly
investigated by station and corporate representatives and
corrective actions were promptly taken.
Strong management support for the radiation protection and the
chemistry programs remains a high licensee priority and strength;
corporate involvement with site activities continuas at a high
level. Evidence of prior management planning that emphasizes
the ALARA concept was noted, particularly for outage activities.
Audits are timely and thorough, with good licensee responsiveness
to findings. Corrective action systems promptly and consistently
address reportable and nonreportable concerns. Quality control
within the licensee's chemistry and radiochemistry program has
improved since the last rating period, attributable in part, to
enhanced supervision of the program. The program is currently
receiving satisfactory management attention and review. Quality
control, although implemented well, was controlled by draft
procedures. On December 30, 1985, eight procedures addressing
quality control within this area had been reviewed and approved
for implementation.
Licensee staffing remains very stable and is ample to meet i
programmatic needs. Promotions and transfcr:: within the I
department account for most personnel 1resses. Staff
qualifications exceed industry norms. High staff experience
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levels and the practice of maintaining separate radiation
protection and chemistry staff specialties have had a positive
impact on program implementation. Limited reliance on contracted
health physics technicians continued throughout this assessment
period; contractor support is used primarily during outages.
The licensee appears to do a good job of screening contractor
technicians. A high rate of contractor returnees was observed,
this practice promotes familiarity with plant operations. During
this assessment period there were two LERs involving personnel
error in this functional area. One LER pertained to violation
"a" (noted above); the second LER was for failure to maintain
appropriate cccess controls over a high radiation area
(1000mr/hr).
The licensee has a formal training program for radiation
protectit.n technicians, chemistry technicians, contract
techniciaqs, plant workers, and visitors. Currently the
entire radiation protection staff is involved in a well
defined three year radiation protection training program
provided by the training department; INP0 accreditation review
is anticipated in late 1986. A plant system overview training
course was provided for radiation protection technicians during
this assessment period in response to previous NRC concerns.
Approximately 80% of the health physics technicians have
completed the course. Chemistry technicians attend an ongoing
retraining program for eight hours every other week on selected
topics, including systems and their relation to the chemistry
program. These courses appear to have a positive contribution
to technician performance and increasing awareness of
radiological hazards.
The licensee's response to NRC initiatives has been adequate
during this assessment period as evidenced by several
implemented ALARA measures applied to radwaste operations where
personal exposure levels were greatest, the willingness to add
elements to the QC program to tighten control of analytical
measurements, and initiation of the reactor system review course
for radiation protection staff. Corrective actions taken in
response to violations identified in the previous SALP period
were prompt and effective.
Resolution of technical issues has generally been thorough,
exemplified by closure of several NUREG-0737 items. Radiological
effluents remain well below Technical Specifications and
10 CFR 20 limits. One minor unplanned gaseous release was
reported; the release, from the reactor coolant pump, was
similar to a 1984 release. Solid radwaste requirements of
waste classification, form, inspection / review of shipments,
manifest preparation, and shipment tracking found in 10 CFR 61
and 10 CFR 20.311 have been satisfied for all radwaste shipments
made since the new regulations went into effect. No problems l
were noted with the transportation program. l
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A design change was completed during early 1985 to allow
shipment of dewatered resins using 170 cu.ft. high integrity
containers (HIC) in place of the previous practice of cement
solidification in 55 gallon drums. This change should reduce-
the radwaste volume of spent resins by a factor of 3 to 4, and
decrease the dose to the radwaste operators by eliminating the
need to handle the individual 55 gallon drums, and to maintain
the cement solidification equipment.
Total personal exposures remain very low, (160 person-rem) for
1985 and a five year average of 140 person-rem. These exposures
which are well below the average for U.S. pressurized water
- reactors (about 550 person-rems), are indicative of continued
excellent exposure controls. Contamination controls also are
among the best in the industry.
The licensee continues to perform well in confirmatory
measurements having achieved five agreements in five
comparisons. These further substantiate good quality control.
The Radiological Environmental Monitoring Program has been
satisfactorily implemented. Activity measured compared
favorably with measurements made by the State of Wisconsin.
2. Conclusion
The licensee is rated Category 1 in this area, as they were
during the last assessment period. This rating is based on
the overall high quality of the licensee's radiological control
program, including very low personnel exposures, extremely good
contamination controls, strong management involvement and staff
qualifications, and good confirmatory measurements and radioactive
waste management performance.
3. Board Recommendation
None.
C. Maintenance
1. Analysis
Evaluation of this area is based on routine inspections by the
resident, three inspections by Region III specialists, and the
findings of a maintenance survey conducted by NRR's Division of
Human Factors Safety. Areas examined during the inspections
and survey included: calibration; preventative, general, and
corrective maintenance; control of measuring and test equipment;
procedures; organization and administration; and facilities and
equipment. One violation was identified as follows:
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Severity Level IV: An unplanned release of waste gas.
(50-305/85001(DRP))
During the 1985 refueling outage, maintenance personnel dropped
a reactor coolant pump (RCP) shaft; that is, disconnected the
pump shaft from the drive motor shaft, not realizing that the
dropped shaft would open sealing surfaces and provide a path
4 for waste cover gas to vent into the containment. This anomaly
was identified and corrected by the auxiliary operator. To
prevent recurrence an annual refueling activity has been
designated for dropping the RCP shafts, which will refer to a
maintenance procedure that requires the isolation and tagging
of the gas supply.
During this assessment period there were three LERs involving
personnel error. These reports described the circumstances
which resulted in: (1) actuation of one train of the Auxiliary
Building Special Ventilation System. The actuation occurred
when an Instrument and Control Technician unplugged the control
and power cable from a radiation instrument drawer. The cable
removal generated a false high radiation signal which started
the ventilation system; (2) the actuation of safeguards
ventilation which occurred while performing an Instrument and
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Control Procedure. When a lead was lifted, per the procedure,
the result should only have been a control room alarm.
Investigation revealed that miswiring of a replacement relay
had resulted in the logic for starting of the ventilation being
1/2 instead of 2/3; (3) the inadvertent initiation of a safety
injection signal. During the 1985 refueling outage an
Instrument and Control Technician calibrated one channel of
pressurizer pressure while another channel had its bistables
tripped. The plant equipment lineup at shutdown prevented any
injection to the reactor coolant system.
All of the events were of minor safety significance and were
isolated occurrences.
i Four reactor trips occurred which were attributable to equipment
faults. The cause of trips were: (1) loss of instrument bus
voltage resulting from a loose connection on an inverter
circuit breaker, (2) failure of bolts attaching the actuator to
a main feedwater regulating valve causing a loss of feedwater
to a steam generator, (3) failure of a constant voltage
transformer causing a loss of voltage to the level controls for
a steam generator, and (4) a manual trip to isolate and repair
a ruptured two-inch steam line. Corrective actions to prevent
recurrence of the type faults associated with trips (1), (2),
and (4) appear to be timely and adequate. The fault resulting
in trip (3) appears to be a non predictive type occurrence and
no further action is planned.
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The licensee's preventative maintenance program shows consistent
evidence of prior planning and assignment of priorities; it is
well-defined, controlled, and has explicit procedures for
control of preventative maintenance activities which is evidenced
by the plant's high availability factor and small corrective
maintenance backlog. Records of maintenance activities are
well maintained and readily available. The success of their
maintenance program has been recognized by other utilities and
organizations. During this assessment period the plant was
visited by three utilities for the express purpose of reviewing
and observing maintenance activities.
The success of the program can be attributed, in part, to:
(1) an experienced work force. The everall plant staff turnover
rate is less than 2 percent per year and a significant percentage
of the supervisors and craftsman have been at the plant since
initial plant startup, (2) positive worker attitude and pride in
workmanship, (3) an extensive preventative maintenance program.
There are approximately 350 preventative maintenance procedures
and approximately 50 percent of craftsmen's time is spent on
preventative maintenance, and (4) extensive informal communica-
tions. The relatively small staff size and the absence of
! significant jurisdictional boundaries promote excellent
communications: craft-to-craft, foreman-to-foreman; and
supervisor-to-supervisor.
2. Conclusion
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The licensee continues to be rated Category 1 in this area.
No discernible trend was noted.
3. Board Recommendations
None.
D. Surveillance
1. Analysis
Evaluation of this functional area is based on routine
assessments by the resident inspector during implementation
of the resident inspection program, one special inspection by
the resident inspector, and four inspections by Region III
specialists. Five violations were identified as follows:
a. Severity Level IV: Failure to determine an as-found
containment integrated leakage rate. (Inspection Report
- No. 50-305/84019(DRS))
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b. Severity Level V: Failure to request relief from certain
ASME Section XI Code requirements prior to implementing
testing that was at variance with the code (3 examples).
(Inspection Report No. 50-305/84021(DRS))
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c. Severity Level V: Failure to require the use of calibrated
tachometers or stopwatches in certain surveillance
procedures. (Inspection Report No. 50-305/84021(DRS))
d. Severity Level III: Disabling of the automatic feature for
shifting the suction supply for the safety injection pumps
from the boric acid storage tank to the refueling water
storage tank (Inspection Report No. 50-305/84023(DRP)).
e. Severity Level IV: Failure to have adequate procedures for
shift turnover and testing of boric acid tank level (BAST)
instruments (Inspection Report No. 50-305/84023(DRP)).
Region III specialist inspection of the April 1984, Containment
Integrated Leak Rate Test (CILRT) resulted in Violation a. In
addition to the violation, this inspection identified
discrepancies in the technical content of the CILRT procedure
which could yield non-conservative results; however, confirmatory
calculations performed by the NRC demonstrated that the Kewaunee
containment leakage was well within prescribed limits. While the
licensee was responsive to the issues identified during this
inspection, the violation and procedural discrepancies were
indicative of a weakness in their understanding of certain
aspects of 10 CFR 50 Appendix J.
An in-depth inspection of inservice testing of pumps and valves
by Region III specialists results in Violations b. and c.
Violation b. invrived in large measure minor interpretation
errors of code requirements. Violation c. involved a failure
to apply a portion of 10 CFR 50, Appendix B, requirements to
inservice testing. It was found that the licensee had fully
implemented its pump and valve inservice testing program.
Testing was generally well defined with appropriate evaluations
of collected data being performed by the licensee's staff. The
inspectors noted that the licensee has implemented an aggressive
preventive maintenance program that complements and supports the
inservice testing program.
The resident inspector performed a special inspection concerning
the circumstances surrounding the licensee's discovery on
December 18, 1984, that the automatic transfer feature provided
to ensure adequate suction head for the safety injection pumps
during accident conditions, had been disabled. This inspection
identified Violations d. and e. Violation d. involved the
failure to correctly reposition a selector switch at the
conclusion of a surveillance test, which resulted in an
inoperable automatic interlock in the safety injection pump
system. Although civil penalties may be imposed for Severity
Level III violations, a civil penalty was not proposed in this
case. The NRC decision not to propose a civil penalty was
reached following a review of the licensee's immediate and
proposed long-term corrective actions, and prior good performance
in the area of operations and surveillance. The immediate
corrective actions involved placing the selector switch in the
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correct position, investigating the cause of the switch
misalignment, discussing the problem with plant department heads
the following day, reviewing the problem with plant maintenance
personnel, and having the Operations Superintendent speak with
all the operating crews concerning the event. The long-term
corrective actions involved a revision to the surveillance
procedure involved, a review and evaluation of the safety
injection system hardware, planned modification of the control
room safety injection status panel, and a review of all plant
surveillance procedures. Violation e. resulted from the use of
two inadequate procedures. The shift turnover procedure did not
specify an unambiguous indication to be used by determining which
boric acid storage tank was properly aligned for the safety
injection pump suction. Secondly, tre tank level test procedure
did not include specific steps which would ensure that the BAST
selector switch was at all times positioned to the BAST
physically aligned for safety injection pump suction. In
addition, procedural steps requiring operator action did not
require the operator to initial the step, thereby attesting that
the action had been completed.
The licensee's corrective actions in response to the violations
were timely and adequate.
Extensive corrective actions were implemented to prevent
recurrence of this type of violation. In addition to
correcting the inadequacies of the above procedures, the licensee
established a committee of 10 individuals to perform a review of
all, approximately 280, plant ~ Surveillance Procedures (SP). The
committee consisted of four Senior Reactor Operators (SRO), a
former SR0 with an engineering degree, and five Shift Technical
Advisors (STA) with degrees in various engineering fields. The
process of reviewing all SPs began with the assignment of an SP
to someone independent of the group responsible for performance
of the procedure. The initial reviewer performed a review which
included ensuring that the procedure addressed compliance with
plant technical specifications during test performance, that
adequate provisions for independent verification of safety-
related manipulations are included, and ensuring provisions for
operator sign-offs if operator manipulation of equipment are
required. The second review was performed by a reviewer with
an SRO license. Both reviews were documented and all
recommendations passed on to the review coordinator. The
review coordinator then ensured that all reviews and recommenda-
tions were consistent. Finally, the recommendations were
forwarded to the appropriate plant group supervisor for
resolution. Any conflicts between the reviewer's recommendations
and the appropriate plant group supervisor's implementation was
resolved by the Plant Operations Review Committee. In all, at
least four individuals were involved in the review process for
each SP. The resident inspector's review of procedures, with
15
l
'
_ _
-
.
r
revisions resulting from the licensee's review process,
- indicates a major improvement in the requirements for
independent verification, clarification of prerequisites,
the requirements for sign-off of procedural steps, the
- identification of applicable TS, and the use of clearly
'
defined acceptance criteria.
i
An inspection of the licerisee's program for reactor coolant
system (RC3) leak rate testing was performed by a Region III
specialist. While no violations were identified, it was
determined that the constant used in the manual calculations of
RCS leakage to account for changes in volume control tank level
- changes was in error. The computer-based calculation method
was found acceptable.
i
!
'
An inspection of the licensee's implementation of the inservice
inspection program for piping systems was performed by a
Region III specialist. The inspection included a review of
l the ISI program and procedures, equipment certification and
calibration, personnel qualifications, and selected records
of nondestructive examination performed during the February to
April 1985, refueling outage. Also, eddy current examinations
<
of selected steam generator tubes and the ultrasonic examination
of a reactor vessel weld were observed during this outage. For
i
the areas examined the inspector determined that the management
control systems were effective in that activities had received
j prior planning and priorities had been assigned. Activities ,
.
were controlled through the use of well stated and defined
procedures. Records were found to be generally complete, well
'
maintained, and available. The records also indicate that
i equipment and material certifications were current and complete
) and that the personnel performing nondestructive examinations
were trained and certified. Observations indicate that personnel
j have an adequate understanding of work practices and that
l procedures were adhered to. No violation or deviations were
identified.
'
An inspection, limited in scope, was performed by a Region III
specialist to review activities associated with reactor core
- physics. The areas of core power distribution limits, target
j axial flux difference, isothermal temperature coefficient,
'
control rod worth, and core thermal power was examined during -
the inspection. No violations were identified. Management
involvement in assuring quality, resolution of technical issues,
responsiveness to NRC' initiatives, analysis of reportable events,
and training effectiveness were all judged to be adequate based
on limited observation. Staffing in the area of core physics
- was comparable to that of much larger utilities,
t
i
16
__ - _ - _ _ - _ _ _ _ - _ _ _ - - _ - _ - _ - _ _ - - _ _ _ _ _ _ _ _ _ - _ _ _ - - _ _ - _ _ _ - _ - _ _ _ _ _ _ _ _ - _ _ _ - - _ _ _ _ _ - _ - _ - - _ _ _ _ - _ -
-
.
Three events attributed to activities in this area required the
submittal of Licensee Event Reports (LER):
1. LER 84021 Mispositioned BAST Selector Switch
2. LER 85001 Inadvertent Actuation of Containment Spray
3. LER 85012 Inadvertent Reactor Trip During Calibration of
Intermediate Range Nuclear Instrumentations
Item 1. is discussed under Violations d. and e. of this section.
Item 2. was caused by crosstalk between bistables in duplex
bistable units while performing a surveillance test of the
Engineered Safeguards Logic. During the 1986 refueling outage,
varistors will be placed in parallel with the bistable ~ outputs
to prevent recurrence. Item 3. was caused by using an installed
picoameter which was at a different ground potential than the
nuclear instrumentation. The portable picoameter normally used
for this calibration was not available. This was an isolated
occurrence and no further action is required. Based on the
inspections performed in the areas of inservice testing of pumps
and valves; inservice inspection of nuclear plant components;
containment integrated leak rate testing; and reactor coolant
leak rate testing, it is concluded that the licensee has
conscientiously pursued a surveillance testing program to
demonstrate the operability of systems and components important
to safety. This prg ram is enhanced by the implementation of
an aggressive preventative maintenance program. A weakness
identified during these inspections was technical errors in
testing procedures. In no case did these errors contribute to
identified safety concerns; however, they do indicate that more
attention to detail is warranted.
2. Conclusions
The licensee is rated Category 2 for this assessment period.
The licensee was rated Category 1 in the past SALP period. The
decreased rat bg is based on the number and severity level of
the identified violations. The extensive effort and improvements 1
demonstrated by the licensee in correcting the causes of the
identified violations is recngnized by the NRC. The licensee's
decision to extend his efforts beyond that necessary for
attaining compliance has resulted in an overall significant
improvement to surveillance procedures and demonstrates an
aggressive and responsive attitude towards nuclear safety by
management. An improving trend of performance in this area has
been noted by the NRC.
3. Board Recommendations
None.
i
17
. .- . ._ __ ___ _- - _
.
E. Fire Protection and Housekeeping
1. Analysis
Evaluation of this functional area is based on routine
assessments by the resident inspector during implementation
of the resident inspection program and one inspection by a
> Region III specialist. Two violations were identified as
follows:
4
a. Severity Level IV: Failure to perform technical
specification required visual fire damper inspection.
(Inspection Report No. 50-305/84015(DRS))
b. Severity Level V: Failure to adequately identify a
deficient fire damper such that effective compensatory
measures could be implemented. (Inspection Report
No. 50-305/84015(DRS))
Violation a. resulted from a misinterpretation on the part
of the licensee over whether the fire dampers were active or
passive components of fire barriers. The licensee inspected
the subject dampers during the 1985 refueling outage, and the
dampers will continue to be inspected at the same interval as
required for fire barriers. Violation b. resulted when the
licensee failed to take timely action to either correct an
identified discrepancy for a particular fire damper or ensure
that personnel responsible for compensatory actions were aware
of the discrepancy. The damper was in a defined fire area which
had an established fire watch prior to, during, and following
the identification and correction of the discrepancy. The
j licensee corrected the disciepancy within approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
In addition to tm violations referenced above, a number of other
minor discrepancies were noted during the Region III specialist
inspection including an improperly connected fire hose in one
fire equipment house, minor surveillance and operating procedure
i discrepancies, and inconsistencies in the credit taken for fire
brigade training. These items are also viewed as isolated events.
The licensee's corrective actions were timely and adequate.
In general, the inspection concluded that the licensee is
effectively implementing their approved fire protection program
with adequate numbers of trained and qualified personnel as
evidenced by a favorable enforcement history and few reportable
, events. The licensee was very responsive to NRC questions and
initiatives and provided technically sound bases for positions
'
taken. As a result of the violations / discrepancies identified,
the licensee was requested to ensure that the responsibilities
assigned to the Plant Fire Marshal were not becoming excessive
to the point where a deterioration in performance might be
anticipated. ,.
> 18
_. .
-
.
With respect to implementation of 10 CFR 50, Appendix R
requirements, the licensee's technical exemption request
concerning cable combustibility is under review by NRR. It is
significant to note that this was the only exemption from the
technical requirements of Appendix R. An existing schedular
exemption requires the licensee to complete all modifications
prior to startup from the 1987 refueling outage.
Housekeeping continues to result in a high degree of cleanliness
in all areas. To further enhance the degree of cleanliness, the
licensee has sealed and painted the turbine hall lower level
floor. The continuing effort to maintain and improve the plant
appearance is reflective of the plant staff's pride in their
plant. The clean, well-ordered, appearance of the plant,
simulator, and training facilities has been noted by a visiting
NRC Commissioner, NRC headquarters and regional personnel. In
addition, two Region III Senior Resident Inspectors visited the
plant for the express purpose to observe a plant which is
considered to have an excellent state of housekeeping.
2. Conclusion
The licensee continues to be rated Category 1 in this area.
3. Board Recommendations
None.
- F. Emerger.cy Preparedness
1. Analysis
Five inspections were conducted during the assessment period
to evaluate the licensee's performance with regard to emergency
preparedness. These included observation of two annual emergency
preparedness exercises, a special inspection of the licensee's
'
emergency response facilities, and two annual routine inspections i
of the following aspects of the emergency preparedness program:
emergency detection and classification, protective action
decisionmaking, notifications and communications, changes to the
emergency preparedness program, shift staffing and augmentation,
dose calculation and assessment, training and licensee audits.
i Two violations were identified.
a. Severity Level IV - Failure to conduct monthly
d
communication checks during June 1984 as required.
(Inspection Report No. 50-305/84007)
19
_ _ - - _ _ _- -
. . _ . . __ _ - _. . . -.
- - . . _ - _
l
-
.
- b. Severity Level IV - Failure to evaluate and document
the adequacy of interfaces with the State and local
governments during the annual audit as required.
(Inspection Report No. 50-305/85009)
The above violations were the result of oversights on the part
of the licensee, and were not indicative of any major
programmatic problems or breakdowns. In each case the licensee
took prompt and adequate corrective actions to address NRC
concerns and avoid recurrence.
Management involvement and control in assuring quality in the
emergency preparedness program has been demonstrated through
decisionmaking that has consistently been at a level that
ensures adequate management review. Corporate management is
frequently involved in site activities and records are
'
generally complete, well maintained and available. The
- licensee has provided timely and sound resolutions to NRC
concerns in almost all cases. This was evidenced by the
reduction of open items requiring resolution (from 29 at the
beginning of the SALP period to 5).
The licensee demonstrated a high level of proficiency in both
- of the emergency preparedness exercises. Emergency response
i organization positions were identified, authorities and
i responsibilities defined, and personnel were capable of
implementing their assigned functions. Staffing to implement
day-to-day emergency response duties is well defined and
adequate. Past NRC concerns over training have been eliminated.
The training program is well defined and implemented with
dedicated resources, including a simulator which was used during
both of the exercises to enhance realism.
2. Conclusion
I The licensee is rated Category 1 in this area due to their
4
responsiveness to NRC concerns and the demonstrated proficiency
in their annual exercises. The licensee received a rating of
Category 2 in the last SALP period. The licensee's performance
during the assessment period has improved,
i 3. Board Recommendations
None.
G. Security
1. Analysis
Three routine safeguards inspections were completed by regional
based inspectors during the assessment period. In addition,
the resident inspector routinely conducted observations of
security activities. Two violations were identified as follows:
}
20
.
a. Severity Level V: Background screening was not adequately
completed for some unescorted personnel. (Inspection
Report No. 50-305/85004(SS))
b. Severity Level IV: Some alarm station barriers did not
offer the required penetration resistance. (Inspection
Report No. 50-305/85018(SS))
In addition to the above violations, two findings were identified
that could have resulted in degradation of certain specific areas
of the security program. These findings, which were identified
as items of concern, dealt with compensatory measures for
intrusion alarms and the personnel control program for vital area
access. Subsequent reviews during this assessment period
verified that the licensee has implemented action which should
answer our concerns. Although there was one less violation than
the previous assessment period, this did not represent a
significant trend.
4
The licensee's approach to taking corrective action to NRC
identified violations or self identified items were timely and
generally effective. However, on three occasions management
lacked thoroughness when reviewing self identified problems,
although corrective action was taken, the action was not
comprehensive. For example, this lack of comprehensive action
became evident when the licensee experienced similar failures
4
in their access control program. The licensee recognized the
potential significance of each individual event but did not
implement comprehensive and thorough action to correct the
problem until after the fourth event. This weakness in
evaluation and review is not a significant programmatic
deficiency but is indicative of the need for some fundamental
improvements. Management should more closely monitor identified '"
deficiencies in order to better evaluate the effectiveness of
both short-term and long-term action. Actions should be i
comprehensive and results-oriented. l
l
Site security management, has a good working knowledge of the
security plan. A periodic review of program fundamentals on an
individual or collective basis might provide an additional more
effective method of assisting managers in better assessing
problems and their corrective actions. Implementation of the
program is adequate. Corporate management exhibits adequate but
not aggressive oversight in site security activities. Corporate
involvement is limited to administrating security plan changes
and reviewing site responses to NRC inspection reports.
Licensee security management and the independent audit /
surveillance program are generally effective in identifying and
correcting specific security plan deficiencies. However, the
licensee does not take the same aggressive action to consider i
or review improvements to the security plan, which are not
regulatory requirements. For example, during the assessment
21
i
.
period, ten open items / observations (security program
improvements) were identified by the inspectors. The findings
dealt with the following areas: testing and maintenance; access
control; physical barriers; assessment aids; lighting and alarm
stations. Licensee action for most of the findings was to
evaluate and consider action. In most cases, the suggested
improvements were not implemented. The review of these
identified areas should receive the same close monitoring
recommended for the matters described earlier which were
identified by the licensee. Licensee management should analyze
system / program improvements equally, whether or not they are
, compliance issues.
Eight security-related events were reported under the provisions
of 10 CFR 73.71(c) during the assessment period. Each event was
reported, as required, in a timely manner and compensatory
measures at the time of the events appeared to be adequate.
Evaluation verified that four events involved security equipment
failure and the remaining events were errors in the access
program. Seven of the eight events happened in the first half
of the assessment period. This may be representative of an
,
improving trend if it continues. Licensee reporting, logging
'
and corrective action appeared to be generally effective.
The supervision and training of the contract security force is
satisfactory. Procedural guidance for the security force has
sufficient detail and the security force has adequately
implemented the security program described in the licensee's
commitment. The Training and Qualification Program, although
not extensive, is considered to be acceptable and is being
adequately implemented to meet program commitments. Security
personnel staffing levels appear to be adequate. The security
equipment utilized by the licensee is adequate to meet security
plan commitments. Inspection findings during this assessment
period verified that the licensee has updated some security-
related equipment and more updating of equipment is planned
within the next several years. Licensee progress in this area
appears to be adequate.
Inspection results during this assessment period showed that
licensee resources dedicated to the security program are
adequate and reasonably effective so that the security program
and plan are being satisfactorily implemented.
In summary, the licensee's performance during this period has !
'
been adequate overall. The progress towards replacing licensee
identified marginally effective equipment is positive. Coupled
with a broader more thorough view and analysis of performance
by the licensee's management should result in a more efficient
and effective program.
l
22
1
_ __ . _
.
2. Conclusion l
The licensee is rated a Category 2 in this area. Licensee
performance has improved over the course of the assessment
4
period due to the improvements in equipment and adequate
continued program implementation.
4
3. Board Recommendations
None.
H. Refueling Activities ,
'
1. Analysis
Evaluation of this functional area is based on the results of
inspections conducted by the resident inspector. The inspection
j activities included: observation of fuel movements; verification
that surveillance for refueling activities had been performed;
~
,
that refueling containment integrity requirements were met; and
l observation of outage controls and activities. No violations or
j deviations were identified.
The inspector observed that core reload activities were performed
i by an experienced contractor under the direct supervision of
j licensee personnel. The licensee established cleanliness,
communication, and material accountability controls to support
,
core alternations which were conducted in a safe and expeditious
manner. It was noted that detailed refueling procedures were
strictly adhered to unless a deviation was necessary. Then, any
deviation was properly considered and well documented.
- During the outages the inspector noted extensive involvement of
corporate office personnel in plant activities. This involvement,
particularly in the area of modifications and design changes, is
4 a significant factor in the continuing well controlled and
productive outages.
2. Conclusion
- The licensee continues to be rated Category 1 in this area.
3. Board Recommendations
None.
I, Quality Programs and Administrative Controls
1. Analysis
Quality Assurance (QA) programs and leneral administrative
controls were routinely assessed during the period by the
resident inspector. One special inspection by the resident
'
23
-
_ __ -_- _______
- - .. - . _
-
.
, inspector, one special inspection by Region specialists, and
_
three routine inspections by Region III specialists were i
conducted during this assessment period. Two violations were
identified as follows:
I s. Severity Level V: Failure to respond in writing to audit
report findings within 30 days. (Inspection Report
No. 50-305/84020(DRS))
b. Severity Level IV: 10 CFR 50.72 Violation, failure to
notify the NRC Operations Center via the Emergency
Notification System, within four hours, of a plant
condition as stated in 10 CFR 50.72 (2) (iii) (D).
(Inspection Report No. 50-305/84023(DRP))
i
- The licensee's corrective actions in response to Violation a.
were reviewed during a subsequent inspection and found to be
adequate. In response to Violation b., the licensee's
.
Technical Support Staff prepared a presentation highlighting
j the reportability requirements and emphasizing conservatism in
<
reporting requirements. This presentation was provided to each
Shift Technical Advisor and individuals with an active Senior
Reactor Operator license on the Kewaunee Nuclear Power Plant.
Some weaknesses were identified in the area of the design
change request program. Specifically, the program lacked
essential administrative elements to ensure that procedure
revisions, drawing changes, and operator training were '
recomplished at the appropriate time. Additionally, elements '
for adequate design verification and design package content
also needed evaluation by the licensee. With the exception of
,
design verification, the licensee has completed the corrective
actions with regard to these issues. In general, the licensee
~
reviews in the quality programs area were timely and thorough.
,
Records were generally complete, well-maintained, and available.
! Procedures are adequate and adhered to. Decisions are usually
made at a level that ensures adequate management review. A
strength noted by the inspectors was that detailed installation
4 and test procedures were prepared, given proper review, and used
.
during design changes.
The results of the inspection of training for non-licensed
employees indicated that the licensee is providing and
1
developing training courses in the areas of auxiliary operators,
maintenance, instrument and control, health physics, chemistry
engineering, shift technical advisor, and supervision. The
licensee has greatly increased his training effort in these
areas during the past three years. l
l
During this assessment period there were three LERs involving )
personnel error. Those LERs described the circumstances which
resulted in: (1) a tube in the 1A steam generator requiring
.
plugging was found plugged in the hot leg only. An adjacent i
l l
24
,
'
.
tube, not requiring plugging, was found plugged in the cold leg
only; (2) the fire hose inspection required by the Technical
Specifications being performed beyond the plant required
18-month time interval. The surveillance was completed seven
days late; and (3) the target band determination required by
plant Technical Specifications was performed outside of the
required time interval of each effective full power month.
The surveillance was completed 4 1/2 days late.
No adverse effects resulted from the events. Review of the
licensee's actions to prevent recurrence were found to be
timely and appropriate.
Review of plant incident reports indicate that appropriate
investigation, review, and corrective actions were performed,
and proper NRC notifications were made.
During this assessment period the duties of: Manager-Nuclear
Power; Plant Manager-Kewaunee Nuclear Power Plant; Plant
'
Operations Superintendent; Plant Technical and Services
Superintendent; Nuclear Licensing and Systems Superintendent;
and Plant Maintenance-Assistant Superintendent were performed,
in the most part, by personnel not having those responsibilities
during the previous SALP period. The transition of responsibili-
ties was accomplished in an orderly, professional manner. The
continuing excellent performance of the plant during this
transition of responsibilities can, in part, be attributed to
the professional long term, in-depth planning by the upper
levels of management in making their personnel selections.
Upon being notified on December 10, 1985, by the resident
inspector that the Commonwealth Edison Company had filed a
4
10 CFR 21 Report identifying non qualified internal wiring
in Limitorque valve actuators used at the Zion Nuclear Plant,
Wisconsin Public Service Corporation immediately initiated an
investigation into the matter. The investigation revealed
that, contrary to their belief, the internal wiring used in
the plant's actuators could not be directly linked to the
Limitorque test results. At the request of the licensee, a
meeting was held with NRC Region III management on December 20,
1985 to present the results of the investigation, and the
contents of their 10 CFR 21 report. The report described the
background; evaluation of affected components; field inspection
findings and engineering evaluation of those findings; schedule
for upgrading of actuator internal wiring; and an evaluation of
qualification of Limitorque actuator PVC control wiring.
A special safety inspection of the circumstances which resulted
'
in the above licensee finding was conducted by Region III
specialists. No violations or deviations were identified;
however, some unresolved and open items require further
evaluation by the NRC.
25
.
2. Conclusion
The licensee is rated Category 2 in this area. This area was
not rated in SALP IV.
3. Board Recommendations
None.
J. Licensing Activities
1. Analysis
The basis for this appraisal was the licensee's performance in
support of licensing actions that were either completed or had
a significant level of activity during the rating period.
There were a total of 56 active actions at the beginning of the
rating period. Twelve actions were added for a total of 68
actions by the end of the rating period. Forty-eight of those
68 actions were closed during the rating period. These actions
and a partial list of completions consisting of amendment
requests, exemption requests, responses to generic letters, TMI
items, and licensee initiated actions are:
32 Multi-Plant Actions (20 completed). Some of the completed
actions in this category are:
Masonry Wall Design (IE Bulletin 80-11; MPA-859)
Equipment Qualification of Safety Related Electrical
Equipment (MPA-860)
Safeguards Regulatory Effectiveness Review
Control of Heavy Loads-Phases II (MPA C-15)
Appendix I (MPA A-02)
Many Salem ATWS Items
Definition of Operable (MPA 0-17)
Reactor Vessel Overpressure Protection (MPA B-04)
4
23 Plant-Specific Actions (21 completed). Some of the
completed actions in this category are:
- Control Room Filters
Administrative Changes with Staff Reorganization
Appendix J Related Changes
- Deletion of Autoclosure Feature
- Increased Peaking Factor and Higher Burn-up Fuel
13 TMI (NUREG-0737) Actions (7 completed). Some of the
completed actions in this category are:
NUREG-0737 Technical Specifications (GL 82-16)(MPA B-72)
- Detailed Control Room Design Review Program Plan
26
_ _ _ _
.
- Completed Review of Emergency Response Facilities
- Small Break LOCA Analysis Item II.K.3.30
- Post-Accident Sampling System Item II.B.3
During the present rating period, the licensee's management
demonstrated active participation in licensing activities and
kept abreast of current and anticipated licensing actions. The
licensee's management actively participated with the Project
Manager to reduce the backlog of licensing actions with NRR.
The 48 actions completed attest to the licensee's management
involvement and represent 70 percent of the total number of
licensing actions in force during the period. The licensee's
'
management maintained effective communication with the staff.
The licensee has met schedules or informed the Project Manager
at an early date of schedular problems.
The interaction of the licensee, including visits and
i management discussions / meetings, with the NRC staff, have
resulted in a clear understanding of safety issues. Sound
technical approaches are taken by the licensee's technical
staff toward their resolution. Conservatism is being exhibited
in relation to significant safety issues on a routine basis.
Thoroughness in the approach to the technical issues has been
demonstrated by the number and complexity of the licensing
actions completed during this period.
Consistently sound technical justification is provided by
the licensee for deviations from staff guidance. The good
communications between the licensee and NRC staff have been
beneficial to both in the processing of licensing actions and
minimizing the need for additional information.
Some notable areas of sound approaches were the Inservice
Inspection Program - 2nd 10 year interval, implementation of
Appendix I and reactor vessel overpressure protection. The
NRC technical reviewers were able to complete their safety
evaluations on the basis of the original submittals with no
more than telephone questions. In the case of the Appendix I
review, the reviewers stated it was the best submittal in this
area received by NRC and the technical specifications were
approved without a single change in the licensee's submittal.
The licensee's findings of no significant hazards were thorough,
although some minor changes were discussed with the licensee.
The licensee has been responsive to NRC initiatives. In one
instance, however, regarding the Radioactive Effluent Technical
Specifications (RETS), the licensee was among the last plants
to implement the RETS due to late submittal; however, it was a
high quality submittal.
27
-- _ - .
-
.
NRR personnel had an opportunity to participate in an
Enforcement Conference with Region III and the licensee
- regarding a personnel error in a boric acid tank mispositioned
switch setting. All NRC personnel at the conference were
impressed with the licensee's responsiveness, high quality
input to the conference and candor in the discussions.
1 The licensee has a licensing staff which appears to be
sufficient to provide adequate and timely responses. The staff
is knowledgeable about the issues discussed. The licensing
personnel are rotated in the plant for Shift Technical Advisor
duty and other special plant assignments.
Tha licensing staff all have engineering or physics degrees and
are provided extensive training as Shift Technical Advisors.
,
,
2. Conclusion
The licensee is rated Category 1 in this area. This is an
improvement from the Category 2 rating during the last SALP.
3. Board Recommendations
None.
.
!
l
2
2
,
l 28
- . _ _ . ..
'
. .
4
'
V. SUPPORTING DATA AND SUMARIES
A. Licensee Activities
'
1. On July 3, 19'4,
8 the unit tripped on a steam flow /feedwater _
flow mismatch coincident with low steam generator water level
signal actuation, caused by an instrument bus inverter failure.
The unit was off-line for approximately eight hours'. -
1
l 2. On February 8, 1985, the unit was shutdown for the Cycle X-XI
i refueling outage.
!
3. On April 11, 1985, the unit was placed back on-line. Activities
- during the outage included: retubing of main condenser;
t installation of additional space cooling capabilities for
safety-related area; 100 percent eddy current testing of steam
'
generator tubes; installation of a nitrogen backup suphly and
overpressure protection for the refueling cavity seal ring;
completed the first ten year inservice inspection program; and
10 CFR, Appendix "R" modifications. ,
4. On August 8, 1985, the unit was manually tripped to facilitate
isolation and repair of a ruptured two-inch steam line, The
- unit was off-line approximately 15 hours1.736111e-4 days <br />0.00417 hours <br />2.480159e-5 weeks <br />5.7075e-6 months <br />. ,
5. On November 13, 1985, the unit tripped on a steam flow /feedwater
- flow mismatch coincident with low steam generator water level
l signal actuation, caused by failure of a feedwated regulating
! valve. The unit was off-line for approximately 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />.
6. On December 12, 1985, the unit tripped on steam flow /feedwater
'
flow mismatch coincident with low steam generator water level
signal actuation, caused by the failure of a constant voltage
transformer which fed an instrument bus. The unit was off-line
approximately nine hours.
>
7. Improvements made to ftcilities and plant systems during this
,
assessment period included: completion of a 67,000 square foot
i
warehouse and office building; er.largement of the health physics
4 office and construction of new locker room facilities;
!- modification of the radioactive waste systern to allow use of high
'
integrity containers foi *hipment of waste resins; installation
i of rupture disks on the piping downstroas of the pressurint
safety valves; upgrading nf emergencyslighting for the access
route from the control room to the dedicated shutdown panel;
upgrading of the installed fire protection system'; and upgrading
of the plant perimeter detection system.
B. Inspection Activities ,
'
l .
1. One special safety inspection was conducted during'the period
of December 19, 1984 through January 15, 1985 by the resident
f
.;
I
_ - _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ - _ - - - - _ _ _ _ - _ - _ _ _ _ _ - _ _ _ - - -__ _ _ _ - _ _ _ _ _ . . . _ _
-
.
,
inspector. The inspection was conducted to determine the
circumstances which resulted in the inoperability of the
automatic feature for switching the safety injection pump
suction supply from the boric acid storage tank to the
refueling water storage tank.
2. As part of the U.S. Nuclear Regulatory Commission's (NRC)
Maintenance and Surveillance Program's Survey and Evaluation of
Maintenance Effectiveness Project, a site survey was conducted
at the Kewaunee Nuclear Power Plant. The purpose of the visit
was to collect descriptive data about Kewaunee's maintenance
and surveillance program, and to evaluate the effectiveness of
a data gathering protocol in collecting that descr.iptive data.
The site survey was conducted the week of July 22, 1985, with a
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team of three NRC and three Pacific Northwest Laboratory (PNL)
,
staff.
3. Commissioner L. W. Zech visited the plant and was given a plant
tour on May 7, 1985.
4. One special safety inspection was conducted during the period
of December 16-20, 1985 by Region III specialists. The
inspection was conducted to determine the circumstances which
resulted in the licensee submitting a 10 CFR, Part 21, report
regarding the environmental qualifications of Limitorque valve
actuators used in the plant.
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INSPECTION ACTIVITY AND ENFORCEMENT
KEWAtlNEE NDCLEAR POWER PLANT, DOCKET NO. 50-305
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I'nspection Reports: No'. S4007 through 84012
No. 84014 through 84023
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No. 85001 through 85006
No. 85008 through 85019
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FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA I II III IV V DEV. l
Plant Operations s
1
Radiological Controls 1 1
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Maintenance 11
Surveillance 1 2 2
Fire Protection 1 1
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Security 1 1
Refueling -
Quality Programs and
Administrative Controls 1 1
Licensing Activities
Totals 0 0 1 10 6 0
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C. Investigations and Allegations Review
None were conducted.
D. Escalated Enforcement Actions
1. Civil Penalties
As a result of findings, detailed in Inspection Report
No. 305/84023, a notice of violation classified at Severity
Level III was issued. Although civil penalties are considered
for Severity Level III violations, a civil penalty was not
proposed in this case. This conclusion was reached when
consideration was given to the licensee's immediate and long
term corrective actions, and prior good performance in the
areas of operation and surveillance.
2. Orders
No orders were issued during this assessment period.
E. Management Conferences Held During Appraisal Period
1. On September 18, 1984, a management meeting was held at the
Kewaunee Nuclear Power Plant to present the licensee with the
findings of the SALP IV report.
2. On January 7,1985, an Enforcement Conference was held in the
NRC Region III office regarding the failure to meet a technical
specification for post accident operability of the safety
injection system.
3. On January 7,1985, a management meeting was held, at the
licensee's request, to discuss the regulatory basis for
four potential violations identified in Inspection Report
No. 305/84015. Following the review of information presented
by the licensee at the meeting and in their written response,
the NRC withdrew two of the notices of violation.
4. On December 20, 1985, a management meeting was held, at the
licensee's request, to discuss their findings which resulted
in a submittal of a 10 CFR, Part 21 Report, regarding the
environmental qualifications of Limitorque valve operator
internal wiring.
F. Review of Licensee Event Report and 10 CFR 21 Reports
1. Licensee Event Reports (LERs)
On August 29, 1983, the NRC published an amendment clarifying
its regulations regarding Licensee Event Reports required by
10 CFR 50.73. Details of the new reporting system were published
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as NUREG-1022 " Licensee Event Report System". The effective
date of the amendment was January 1,1984. The amended
regulation deleted reporting requirements for several types
of licensee events which had been found, through experience,
to be of little value to the Commission.
In addition, the new rule incorporated changes in the proximate
cause codes and definitions of the proximate causes. Therefore,
a comparison of the number and proximate cause codes of LERs
submitted during this assessment period with the submittals
during previous periods would not provide meaningful comparative
information. The SALP board did review all LERs submitted during
this assessment period, and from this review determined which
events resulted from personnel error. Those LERs are discussed
in the appropriate functional area analysis section of this
report.
a. The LERs for this evaluation period includa 84-13 through
84-21 and 85-01 through 85-23.
PROXIMATE CAUSE* SALP V
Personnel Error 3 (0.17)**
Design, Manufacturing,
Construction / Installation 0
External 0
Defective Procedure 0
Management / Quality
Assurance Deficiency 2 (0.11)
Other 11 (0.61)
Non-Coded 16 (0.89)
TOTAL 32 (1.78)
- Proximate Cause is the cause assigned by the licensee in
accordance with NUREG-1022, " Licensee Event Report System".
- Numbers in parenthesis are the average number of events per
month.
b. Evaluation
Review of the LERs indicated that the information given
generally provided a clear and adequate description of each
event; the entries reviewed were correct and the codes
agreed with the information in the narrative. The licensee
submitted voluntarily a report (LER 85-04) that was not
required by the reporting requirements of 10 CFR 50.73. The
report was provided because the event may be of generic
interest and exemplified a positive attitude of exceeding
the minimum reporting requirements. NUREG-1022,
Supplement 2, " Licensee Event Report System", published by
the Office for Analysis and Evaluation of Operational Data
in September, 1985, describes an evaluation of an
industry-wide sample of LERs that was conducted to
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determine whether or not those LERs were prepared in
accordance with the requirements set forth in 10 CFR 50.73.
Kewaunee's LER No. 84-03/01 " Rod Cluster Control Assembly
Cladding Wear" was selected as an example of a well
written LER.
An evaluation of the content and quality of a representative
sample of LERs submitted during this assessment period was
performed by the NRC Office for Analysis and Evaluation of
Operational Data. The results of this evaluation indicate
that Kewaunee has an average LER score 7.6 of a possible 10
points, thus ranking it 13th out of the 35 units evaluated.
The principal weakness identified involves the personnel
error and safety consequence discussion.
The SALP Board's review determined that of the 32 LERs
submitted, 15 were a result of personnel error.
2. 10 CFR 21 Reports
The licensee submitted a report on December 20, 1985, which
indicated that the electrical qualification of Limitorque
valve actuators used at the Kewaunee plant were not completely
supported by the test reports referenced by Limitorque. The
item of concern is the internal wiring of the limit switch
compartment. Included in the report were the results of an
engineering study performed to identify those components
affected, their type, location, qualification requirements, and
a evaluation of their function. The study which concluded that
the affected components would perform as required is being
- reviewed by NRR.
1 G. Licensing Actions
1. NRR/ Licensee Meetings
Fire Protection 08/15/84
Upper Plenum Injection-Evaluation Model 03/06/85 :
Inservice Test Program 03/12 & 03/13/85
Steam Generator Tube Sleeving 09/10/85
Upper Plenum Injection-Program Plan 10/16/85
2. NRR Site Visits / Meetings ,
SALP 4 Plant Meeting 09/17 - 09/19/84
Integrated Scheduling Meeting 07/31/85 i
Plant / Resident 08/01/85 l
- Maintenance & Surveillance Task Force
! Exit Interview 08/02/85
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3. Commission Briefings
None .
4. Schedular Extensions Granted
Detailed Control Room Design Review Summary
Report 02/19/85
Reliefs Granted 1.97 Report 02/19/85
5. Reliefs Granted
ISI Hydrotest Relief 01/22/85
6. Exemptions Granted
None
7. License Amendments Issued
Amendment Title Date
55 ISI Program 07/03/84
56 Containment Fan Coils 11/14/84-
57 List of Snubbers Deleted 12/26/84
58 Reporting Requirements 01/04/85
59 NUREG-0737 Tech. Specs. 01/09/85
60 Administrative Changes 01/22/85
61 Main Steam Valve Testing 04/04/85
62 Peaking Factors 06/20/85
63 Definition of Operable 07/08/85
64 Radiological Effluent T.S. 07/29/85
65 Administrative Controls 08/05/85
66 Airlock Surveillance 10/15/85
8. Emergency Technical Specification Issued
None
9. Orders Issued
None
10. NRR/ Licensee Management Conferences
Division of Licensing, Division Director
Briefing 02/04/85
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