ML20138K243
| ML20138K243 | |
| Person / Time | |
|---|---|
| Site: | Beaver Valley |
| Issue date: | 12/12/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20138K230 | List: |
| References | |
| 50-334-85-99, NUDOCS 8512180327 | |
| Download: ML20138K243 (50) | |
See also: IR 05000334/1985099
Text
. . _ .
--
.
.
U. S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT 50-334/85-99
DUQUESNE LIGHT COMPANY
BEAVER VALLEY POWER STATION, UNIT 1
ASSESSMENT PERIOD:
APRIL 1, 1984 - SEPTEMBER 30, 1985
BOARD MEETING DATE:
NOVEMBER 12, 1985
l
l
G512180327 851212
'
ADOCK 05000334
,
G
l
-
- -
-
- - -
-
-
.
-
-
-
-
- -
- - -- ----
- ---- -
-
- -
--
.
.
TABLE OF CONTENTS
Pa[Le
I.
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . .
1
A.
Purpose and Overview
1
.................
B.
SALP Board Members
1
..................
C.
Background
2
......................
II.
CRITERIA
4
.
........................
III. SUMMARY OF RESULTS . . . . . . . . . . . . .
6
. .......
A.
Facility Performance
6
.................
B.
Overall Facility Evaluation .
6
.............
IV.
PERFORMANCE ANALYSIS
9
...................
A.
Plant Operations
9
...................
B.
Radiological Controls . . . . . . . . . . . . . . . . .
13
C.
Maintenance and Modifications . . . . . . . . . . . . .
17
D.
Surveillance
20
.....................
E.
Fire Protection and Housekeeping
23
...........
F.
25
................
G.
Security and Safeguards .
27
...............
H.
Refueling and Outage Management . .
29
..........
I.
Licensing Activities
32
.................
V.
SUPPORTING DATA AND SUMMARIES
34
...............
A.
Investigation and Allegation Review . . . . . . . . . .
34
B.
Escalated Enforcement Action
34
.............
C.
Management Conferences
34
................
D.
Licensee Event Reports
34
................
-TABLES
Table 1 Tabular Listing of LERs by Functional Area
T1-1
Table 2 LER Summary
T2-1
Table 3 Enforcement Summary
T3-1
Table 4 Enforcement Data
T4-1
Table 5 Inspection Hours Summary
T5-1
Table 6 Inspection Report Activities
T6-1
Table 7 Plant Shutdowns
T7-1
O-
.
I.
INTRODUCTION
A.
Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an inte-
grated NRC staff effort to collect the 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 with 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 management to promote quality and safety of plant
operation.
An NRC SALP Board, composed of the staff members listed below, met on
November 12, 1985 to review the collection of performance observa-
tions 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 cri-
teria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Beaver Valley Power Station, Unit 1 for the period
April 1, 1984 through September 30, 1985.
B.
SALP Board Members
Chairman:
R. W. Starostecki, Director, Division of Reactor Projects (DRP)
Members:
E. C. Wenzinger, Chief, Projects Branch 3, DRP
L. E. Tripp, Chief, Projects Section 3A, DRP
W. M. Troskoski, Senior Resident Inspector
J. P. Durr, Chief, Engineering Branch, Division of Reactor Safety
(DRS)
S. A. Varga, Division of Licensing, NRR
P. S. Tam, Project Manager, NRR
Observers
J. P. Stohr, Director, Division of Radiation Safety and Safeguards,
Region II
G. W. Meyer, Project Engineer, DRP
l
0:
..
2
C.
Background
1.
Licensee Activities
This assessment period began midway through the third fuel cy-
cle.
Prior to its completion, the reactor experienced two
trips, three manual shutdowns and five major power reductions.
The first trip occurred on May 24, 1984, due to a failed tran-
sistor in the time limitor module of the main generator's volt-
age regulator.
The unit was returned to service the next day.
The second trip occurred with the reactor at 94% power during
end of life coast down on October 11, 1984, and resulted in the
declaration of an unusual event due to a twenty minute loss of
one offsite power source.
4 KV buses IA and 1B were being used
as a temporary load source for Unit 2 transformer testing when a
protection relay malfunctioned.
The licensee decided to enter
the fourth refueling outage three days early.
The other manual
shutdowns and power reductions were mostly caused by component
problems on the secondary plant, such as condenser tube leaks,
main feed pump seal leaks and the heater drain tank level con-
trol system.
Major items covered during the 14 week refueling outage included
10 year ISI work, RCP flywheel and seal inspection and mainte-
nance, steam generator tube inspections, retubing of the main
condenser and first point feedwater heaters and refueling.
Ini-
tial heatup commenced on December 23, 1984, and the plant was
placed on line after core physics tests on January 4, 1985.
During the fourth cycle, two safety injections with. reactor trip
occurred.
The first event was due to a steam flow-feed flow
mismatch (in conjunction with a low SG level) on January 16,
1985.
This transient was initiated by a failure of the vital
bus breaker that powered all three SG level control circuits.
The second SI occurred on August 29, 1985.
A failed instrument
air header closed the MSIVs resulting in a main steam line
isolation low steam line pressure SI and reactor trip.
Throughout the fourth cycle, four other reactor trips occurred:
three at low power due to SG level control problems and one at
full power due to a spurious over temperature - delta tempera-
ture condition.
Additionally, the plant undertook an unsched-
uled two week outage starting April 26, 1985, to repair a
pressurizer manway cover leak.
The plant was also manually
shutdown four other times (included is one previously mentioned
low power trip that occurred during shutdown) for secondary com-
ponent problems, and experienced eight major power reductions.
The major contributors to this cyclic performance were a rash of
condenser tube leaks and secondary system pump problems, many of
which were not corrected on the first attempt.
.
.
3
2.
Inspection Activities
One NRC senior resident inspector was assigned.to Beaver Valley
Power Station, Unit 1 for the entire assessment period and a
second resident inspector was assigned until April 1985.
In
addition, a resident inspector was assigned to the station
beginning in September 1985. 'The total NRC inspection effort
for the period was 3387 hours0.0392 days <br />0.941 hours <br />0.0056 weeks <br />0.00129 months <br /> (resident and region-based) with a
distribution in the various functional areas shown on Table 5.
This represents 2258 hours0.0261 days <br />0.627 hours <br />0.00373 weeks <br />8.59169e-4 months <br /> on an annual basis.
NRC team inspections were conducted to evaluate the annual emer-
gency exercises conducted on June 27, 1984 and September 19,
1985.
Another team inspection of NUREG-0737, II.B.3, Post Acci-
dent Sampling System, was conducted during the week of September
10, 1984.
.
.
4
i
II.
CRITERIA
Licensee performance is assessed in selected functional areas, depending
on whether the facility is in a construction, preoperational or operating
!
phase.
Each functional area normally represents areas significant to nu-
clear safety and the environment, and are normal programmatic areas.
Spe-
cial areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
functional area.
1.
Management involvement and control in assuring quality
2.
Approach to resolution of technical issues from a safety standpoint
3.
Responsiveness to NRC initiatives
' 4.
Enforcement history
5.
Reporting and analysis of reportable events
6.
Staffing (including management)
7.
Training and qualification effectiveness
Based upon the.SALP Board assessment each functional area evaluated is
classified into one of three performance categories.
The definitions of
these performance categories are:
Category 1.
Reduced NRC attention may be appropriate.
Licensee manage-
ment . attention and involvement are aggressive and oriented toward nuclear
safety; licensee resources are ample and effectively used so that a high
level of performance with respect to operational safety is being achieved.
Category.2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are con-
cerned with nuclear safety; licensee resources are adequate and reasonably
effective so that satisfactory performance with respect to operational
safety is being achieved.
fCategory 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used so that minimally satisfactory perfor-
mance with respect to operational safety is being achieved.
'
.The SALP Board also assessed each functional area to compare the
licensee's performance during the last quarter of the assessment period to
that during the entire period in order to determine the recent' trend for
each functional area. The trend categories used by the SALP Board are as
follows:
L
,.
.
..
_
__
_ __
_ .
e
.
.
5
Improving:
Licensee performance has generally improved over the last
quarter of the current SALP assessment period.
Consistent: Licensee performance has remained essentially constant over
the last quarter of.the current SALP assessment period.
Declining:
Licensee performance has generally declined over the last
quarter of the current SALP assessment period.
4
=
4
4
f
,
w
- .
. .
- . +
,y,
-
7 :-
,
,
w
.
6
III. SUMMARY OF RESULTS
A.
Facility Performance
FUNCTIONAL AREA-
CATEGORY
CATEGORY
LAST
THIS
RECENT
PERIOD *
PERIOD **
TREND ***
1.
Plant Operations
2
2
Improving
2.
Radiological Controls
1
2
Consistent
3.
Maintenance and
Modifications
1
1
Consistent
4.
Surveillance
2
2
Improving
5.
Fire Protection and
Housekeeping
2
1
Consistent
6.
1
1
Consistent
7.
Security & Safeguards
1
1
Consistent
8.
-Refueling and Outage
Management
2
3
Not applicable
9.
Licensing Activities
1
1
Consistent
- December 1, 1982 to March 31, 1984 (16 months)
.
- April 1, 1984 to September 30, 1985 (18 months)
- Trend during the last quarter of the current assessment period
B.
Overall Facility Evaluation
Licensee performance remained generally consistent throughout this assess-
ment period as compared to the improved overall performance noted in each
of the last two SALP assessments, though operations did slip during the
fourth refueling outage and startup. One reason is the impact of the Unit
2 project on the licensee's personnel resources.
Prior to the fourth re-
fueling outage, the Nuclear Group Vice President and General Manager had-
sole responsibility for Unit 1.
Located on site, their presence and in-
volvement in the day-to-day aspects of plant operations made the
licensee's unique matrix structured organization work, and was considered
a strength. This has been subsequently diluted by a reorganization that
has focused the Vice President's attention toward the completion of BV-2,
leaving the day-to-day operations delegated to one of the General Managers.
This is significant because many of the various groups with responsibil-
ities for Unit I do not report to the plant manager in that his responsi-
bilities are very narrow and are limited to only operations, maintenance
and testing.
1
L.
o
.
7
To support the startup and test activities, some of the most experienced
people were reassigned to Unit 2.
Other drains on Unit 1 resources have
been the extensive cross-training required of operators, and especially
senior staff members, and the impact of insuring that a large number of
newly licensed operators have the requisite hot plant experience for fu-
ture Unit 2 licensing.
This has interrupted the continuity of plant oper-
ations by rotating licensd personnel out of the control room as their
plant-specific experience and knowledge level is just developing.
Posi-
tive aspects of the reorganization include the number of licensed person-
nel that have been assigned to various support groups, including I&C,
-
Procedures, and Planning and Scheduling.
This adds depth to the plant's
organization.
The most significant problem encountered was a breakdown in the management
control systems at the end of the fourth refueling outage.
This Severity
Level III problem was attributed to a lack of a clearly defined policy for
recovering from a major work outage in a disciplined and well controlled
manner.
The licensee has been responsive in addressing the root cause.
Another problem area that has become apparent during the last cycle is
secondary side equipment problems.
About three quarters of the major pow-
er reductions are due to these failures, caused in part by the lack of an
effective preventive maintenance program.
The licensee has recently begun
redirecting efforts towards the balance of the plant.
The licensee lacks an internal management driven self evaluation program
to identify potential problem areas and promote better performance.
In-
stead, there are reactive responses for those problems that either mani-
fest themselves in significant plant events, or are identified by NRC
inspections.
Areas such as shift turnover practives, surveillance test
scheduling, equipment configuration control and control room congestion
are examples where actions were taken only after program deficiencies al-
lowed a problem to occur.
More initiative is needed for continued inter-
nal identification of weak areas or programs that are no longer meeting
plant needs.
It should be noted that good performance has continued in many areas such
as fire protection, security, licensing and emergency planning. When the
licensee undertakes a task, it is usually approached from the philosophy
of how to best accomplish it for their particular set of circumstances
rather than meeting some minimum requirement.
From a regulatory point of
view, they have continued to be responsive to safety issues.
Training
The licensee maintains a good commitment toward training as exemplified by
the addition of a plant specific simulator and the establishment of an
unlicensed training program for mechanics and technicians. The simulator
resulted in better prepared condidates for NRC operator license examina-
tions as noted by their increased familiarity with the control boards.
The unlicensed training program consisting of classroom instruction and
L
..
.
8
on-the-job training is strong in the areas of fire protection, emergency
preparedness and instrumentation systems for I&C technicians.
It is sat-
isfactory for mechanics, auxiliary operators and radiation technicians,
though on-the-job training is not as well defined as in the above areas.
Quality Assurance
The Operations Quality Assurance Program appears to be undergoing some
fundamental changes.
Previously, it had been used mostly as an audit
group to verify a particular area complied with existing regulations
through document reviews and personnel interviews.
The QA role has re-
cently been modified to include surveillance activities and special re-
views of target areas as requested by management.
Other upgrades include
providing reactor operator training for some auditors and transferring a
licensed individual (SRO) to the surveillance group.
QA identification of
real problems is a positive trend.
L
.
.
.
9
IV, PERFORMANCE ANALYSIS
A.
Plant Operations (947 hours0.011 days <br />0.263 hours <br />0.00157 weeks <br />3.603335e-4 months <br />, 28%)
1.
Analysis
The previous assessment discussed several system configuration
control problems that occurred during the third refueling out-
age. These problems occurred because shift turnover procedures
were poorly implemented, 18-month surveillance tests contained
inadequate system restoration instructions that relied heavily
on operator's judgement, and the conduct of operations from the
control room was not well supervised during the outage and sub-
sequent plant startup when a large number of newly licensed op-
erators had just recently been put on shift. A Severity Level
III Violation was issued without civil penalty. The overall
conduct of operations during non-outage conditions was consid-
ered satisfactory.
During the current assessment period, the licensee's performance
has been cyclical:
ranging from very good prior to the fourth
refueling outage, to poor during the outage and startup phases
and returning to a more satisfactory level during Cycle 5.
Fur-
ther assessment of the refueling outage management control prob-
lems can be found in section H.
One reason for the vacillation in plant performance has been the
impact of the Unit 2 project on the operations staff. The
control room staff has undergone almost two complete turnovers
within the past three years; much of this turnover was to support
Unit 2.
For example, three experienced shift supervisors were
reassigned to Unit 2 startup. Another twelve licensed individuals
from the shift compliment were involved in extensive cross-
training on Unit 2.
Although there were approximately seventy-
six licensed operators in the Nuclear Group, many lack experience
as licensed operators and several of the other experienced
operators are assigned to duties and groups other than opera-
tions.
Since there are only twenty licensed operators on the
five operating shifts at any one time for the shift compliment,
it has resulted in significant rotations in the operating shifts
to insure that a large number of newly licensed operators have
the requisite hot plant experience for future Unit 2 licensing.
These rotations have resulted in a control room staff that
generally has a limited plant-specific experience of one to two
years. Consequently, the operators lack historic perspective
and the level of confidence was not as high as previously
achieved.
e
.
.
10
Though the operators are well drilled on the simulator, this has
not been an adequate substitute for hands on experience as
exmplified by the low power steam generator level trips that oc-
curred during the fifth cycle. Previous procedures adequately
minimized the problem based in part on the operations shift
functioning as a cohesive unit.
Interruption of the cohesive-
ness and a reduction in the experience level has required devel-
opment of more detailed guidance.
This can best be seen by
considering one of the root causes of the last two level III
violations that occurred during the third and fourth refueling
outages. Although the first violation was prior to this assess-
ment period, operator experience was a contributing factor. The
RHR system was rendered inoperable when both component cooling
water trains were tested and not returned to normal alignment
because the test procedure left the need for system restoration
to the inexperienced operators' judgment.
Two river water pumps
.on one train were left in the pull-to-lock position due to new
operators not understanding their responsibilites and authori-
ties when performing equipment align.nents. Shift turnovers
failed to identify both problems.
Operator experience continued
to contribute to operational problems experienced during this
assessment.
In addition to the plant trips caused by failures
.to maintain steam generator level, the fourth refueling outage
problems relating to an excessive baron dilution incident and a
unrelated loss of containment integrity (discussed in section H)
again involved the experience levels of operators and first line
supervisors.
Thus, while experience levels for the operating
shifts has been adequate, it was not as high as noted in previous
assessment periods. This factor plus the plant's operating
history (No. of trips and forced power reductions / shutdowns) are
the major considerations leading to the continuing Category 2
rating.
Control of plant equipment during plant operation is good.
Equipment clearance points and system alignments receive a de-
tailed review by licensed personnel prior to the start of main-
tenance. At the conclusion, system restoration and
post-maintenance test requirements are also determined by the
control room staff.
Procedures for identifying the status of
equipment through tagging and the use;of marked control room
prints and status boards were well implemented and effective.
Similar strong controls were exercised over surveillance and
modification testing. All surveillance tests required the shift
supervisor's permission prior to performance to assure that ini-
tial conditions were met and that it did not adversely affect
other ongoing plant activities. These methods have proved to be
adequate during routine operation, when minimal equipment is
out-of-service and the plant is in normal system alignment.
.
.
.
11
Licensee responsiveness to NRC concerns has been directed toward
identifying the root cause(s) and implementing technically sound
solutions to correct the problem and not just meet minimum NRC
requirements.
For example, the shift turnover procedures are
now unusually thorough and strong and have prevented a repeti-
tion of problems identified in the last SALP.
Station adminis-
trative controls are being reviewed and restructured to get away
from the band-aid approach they have assumed after ten years of
modification and revision. The problem identification correc-
tive action systems have been recently improved to also require
incident reports for off-normal events of a lower threshold on
the secondary side to improve overall station operability.
Routine plant activities are well coordinated through plan of
the day meetings and daily work schedules developed by Planning
and Scheduling. The licensee also tracks work items for un-
scheduled shutdowns by this method.
The control room environment is business like during normal
plant operations.
Noise levels and distractions are generally
kept to a minimum through enforcement of station policies.
Dur-
ing outages, congestion has been a recurring problem because all
equipment clearance work and permission for maintenance and
testing activities must be obtained through the shift operations
staff.
At shift change, there has routinely been in excess of
30 people present.
The licensee has taken steps to limit the
number of people, but their effectiveness has yet to be demon-
strated during a major outage.
Operator licensing exams were conducted by NRC in October 1984,
February 1985 and April 1985. During the first two exams, weak-
nesses were noted with many of the candidates in areas such as
the following:
locating and operating control room pump and
value controls and knowledge of P& ids, Technical Specifications,
facility procedures and transient analysis.
These were attrib-
uted to lack of emphasis on on-the-job training and inabilities
of the training program to adequately prepare candidates. Only
about two thirds of these candidates were licensed.
In the
April 1985 exams, the plant specific simulator was operational
and used. A significant improvement was noted in the candi-
'date's knowledge level; all eleven candidates were licensed.
This marked improvement is attributed to the incorporation of
the simulator in the licensee's training program.
The operations staff is well trained. The value of the new
plant specific simulator has been demonstrated several times
during recent plant transients, as the operators response ob-
served by the inspector was professional and well drilled.
L
.
12
.
i
/
A detailed evaluation of LER quality using a sample of 13 LERs
issued during the assessment period was made by AE00 using a
refinement of the basic methodology ~ presented in NUREG/CR-4178.
In general, they found the LERs to be of acceptable quality
based on the requirements contained in 10 CFR 50.73. When com-
pared to the evaluations performed to date using this methodol-
ogy for fourteen other units, Beaver Valley LERs are slightly.
above average in quality.
The only apparent LER trend attribut-
able to operations has been the lov power steam generator level
trips.
The cause is due to a combination of secondary control
system anomalies, operator inexperience and procedural Suideline
inadequacies.
Recent changes in those guidelines are expected
to limit this problem in the future. Of the approximately 7
reactor trips and 20 major power reductions, only 2 of them were
due to operator error (see section H for discussions of outage
problems).
Enforcement history involving plant operations has been good
with only two Severity Level IV violations issued prior to the
last refueling outage.
(The Severity Level III violation with a
civil penalty occurred during recovery from the last major refu-
eling outage and is more appropriately considered in the refuel-
ing functional area, Section H.)
As discussed in the previous assessment, the Offsite Review Com-
mittee continues to perform very strongly in fulfilling their
function.
Also, the Onsite Safety Committee composed of more
junior members of the plant staff, continues to adequately per-
form their function.
In summary, the licensee's performance slipped during the last
major refueling outage at a time when resources were being redi-
.rected toward Unit 2.
As the new operators and line supervision
gained experience, performance has improved. The staff is well
trained, minimum overtime.is used, procedures are improving and.
the administrative system is being revamped.
Performance was
satisfactory and improved as the new operations organization
matured.
2.
Conclusion
Rating:
Category 2
Trend:
Improving
3.
Board Recommendation:
Licensee:
Develop an integrated transistion program for phasing in Unit 2 oper-
ations with minimal impact on Unit 1.
1
L
U
'
.
.
.
13
B.
Radiological Controls (749 hours0.00867 days <br />0.208 hours <br />0.00124 weeks <br />2.849945e-4 months <br />, 22%)
1.
Analysis
The Category I rating in this area in the last assessment was
based on strong performance in the radiological controls and
protection areas.
The effective implementation of existing pro-
grams resulted in good control of personnel exposures.
Total
plant man-rem exposure was below the industry norm for PWRs.
No
unplanned environmental releases occurred, and total planned
releases were well below allowable limits. Additionally,
radwaste shipments were routinely conducted without incident.
No major program weaknesses were apparent.
This assessment is based upon eight inspections by region-based
radiation specialists and routine resident inspector observation
of ongoing plant activities.
Program areas reviewed included
In-Plant Radiation Protection, Radioactive Waste Management and
Transportation, and Effluent Control and Monitoring.
Three mi-
nor violations were issued.
During this assessment period, the licensee continued to effec-
tivelv control the conduct of plant activities to ensure that
the total dose to individuals did not exceed the standards of
radiation protection contained in 10 CFR 20.
Total plant mem/
rem exposure increased to levels comparable to other PWRs.
Ex-
cellent controls were excrcised over those radiation areas with
historically high dose rates such as solid waste, incore instru-
mentation room and containment entries under vacuum at power.
Implementation of the radiation work permit requirements during
-both outages and operations was good.
Plant postings and locked
barrier controls over conta:ainated and potentially high
radiation areas exhibited a conservative approach.
Policies are clearly stated and well organized.
Operating pro-
cedures are extensive aad detailed, often accompanied by illus-
trations.
There is a well controlled system to revise the
procedures and policies.
Responsiveness to NRC findings and
initiatives has been timely, technically sound and thorough,
although final resolution is sometimes delayed.
Based on a recent reorganization, four departments have been
formed, with directors reporting to the radiation protection
manager, who in turn reports to a general manager. This con-
tinues to have the radcon management chain outside the direct
control of the plant manager, and necessitates improved coordina-
tion with other departments at the general manager level.
Fur-
thermore, there appears to be uncertainty as to the functions
and responsibilities of some groups during the transition.
A
general lack of management aggressiveness also contributed to
L
- - . .
- .=
.
.
_ - -
- _ _ _ ~ - _
_
-
. .
.-
-
. .
14
a slow response to the resolution of technical issues and slow
implementation of certain programs.
Several items not significant in themselves when taken as a whole,
indicate an underlying problem.
The licensee failed to establish
i
a QA program to audit transportation activities and also failed to
provide QC overchecks of radwaste shipments.
The formal ALARA
program was originally scheduled to be implemented in April 1984,
but was postponed until January 1985 after an October 1984 NRC
inspection determined that personnel were not aware that the ad-
ministrative procedures were issued several. months earlier and
had not taken action to implement them. The licensee was among
the last in Region I to implement a thorough and comprehensive
respiratory protection program in the spring of 1985.
The whole
body counter used to evaluate possible uptakes on site is capable
of detecting only gross levels of cobalt, cesium and iodine.
Also,
a study of skin dose from beta radiation in noble gas atmospheres
was estimated to take one year of study when widely available
literature already provides several methods to calculate these
exposures.
Problems such as the above result in a program which,
although adequate to protect in plant workers and the public, does
not exhibit the initiatives or higher performance levels that are
achievable as demonstrated by other licensees. .Although such
symptoms may be random problems, the SALP Board views these as
indicative of weaknesses resulting from the fragmented organiza-
tional structure that has not had sufficient management attention
during the transition.
Other minor problems involving technical issues were apparent.
Effluent radiation monitor discriminator settings were not prop-
erly set.
Sample cartridges for iodine were assumed to be face
loaded, but actual NRC measurement indicated homogeneous distri-
bution.
The station did not verify the response of effluent
monitors to low energy radiation, as recommended by the vendor.
A plateau check to ensure proper operation of the monitors was
not conducted.
There is a program to split samples as a quality
control check of the laboratory analytical procedures, but the
data was not analyzed in a manner currently accepted as good
industry practice.
These are indicative of the lack of effec-
tive critical reviews and/or an in-house program to periodically
review the radiation safety programs to self-identify weaknesses
and upgrade programs.
The classroom training programs were found to be strong and effec-
tive.
Sufficient resources have been dedicated, with extensive
training provided for the TLD and respiratory protection programs.
The on-the-job training program does not appear to be as strong.
Technicians perform various assignments on a rotating basis, with
minimal oversight and control by the foremen.
This system seems
to preclude the efficient development of job proficiency.
Notwith-
standing, turnover rates are low and contractors are minimized.
.
L_ =
.
.
.
15
The recordkeeping system is mostly manual and judged to be cum-
bersome in the areas of personnel exposure records, routine
radiation surveys, instrumentation calibration and maintenance
and technician retraining.
Several minor problems were identi-
fied which appeared to be exacerbated by not having a record
system that lends itself to easy upkeep.
A violation was issued
for a recurring problem of late termination exposure reports to
workers.
About 20% of the radiation survey records for one
month were incomplete or unavailable.
Survey maps were also
unavailable for some plant areas.
Confusion results from the
use of multiple forms to track instrument calibration dates,
which resulted in some meters being calibrated annually while
the procedures required semi-annual calibration.
This general
area, through acceptable, is another example where areas for
improvement could have been readily identified by greater self
evaluation and initiative.
In the area of radioactive waste management and transportation,
the licensee's performance has generally been good.
No problems
were identified with the packages spot checked at the burial
sites, indicating that controls were apparently accomplishing
the intent of the regulations.
Although there were no particu-
lar technical problems noted, there was a failure to properly
include QA/QC overview of these activities as indicated above.
Effluent control and monitoring are good.
There has been a com-
mendable effort to properly maintain the offsite environmental
monitoring stations.
Additional wind speed and direction indi-
cators were installed in the meteorological tower, though not
required by technical specification.
The instrumentation is.
frequently calibrated.
There is evidence of good planning and
control over the routine air cleaning system tests.
Likewise,
the audit system ensures compliance with the technical specifi-
cation limiting conditions for operations in the environmental
area. Minor problems were identified in the area of records.
The " official" file of procedures in the chemistry office con-
tained expired and unsigned procedures.
One semi-annaul
effluents report failed to estimate the dose to the public,
while another omitted the strontium analysis.
Also, the
licensee found that for the 10 year period of 1976 to 1985, the
calculation of tritium releases was low by a factor of 1000.
More review or management oversight of records and routine re-
ports is needed.
In summary, the licensee's performance is good, and has' achieved
the goal of limiting the dose to individuals and releases to the
environment.
Many of the support programs achieve a level of per-
formance that is acceptable, but not at the previously observed
higher levels observed in earlier assessments.
Minor problems
continue to be identified by the NRC and not by the licensee, a good
i
- ~ .
.
.-
16
self-evaluation program is lacking.
The organization has been
somewhat fragmented during the reorganization transition. Man-
agement attention is required to assure that communication among
the various groups is effective such that follow-up on problems
occurs in a more timely manner.
2.
Conclusion
Rating:
Category 2
Trend:
Consistent
3.
Board Recommendation
Licensee:
Take initiatives to restore program to previously observed high-
er performance level by evaluation and implementation of poten-
tial improvements as identified through such self evaluation
efforts.
L
_.
-- -
-
.
.
17
C.
Maintenance and Modification (486 hours0.00563 days <br />0.135 hours <br />8.035714e-4 weeks <br />1.84923e-4 months <br />, 14%)
1.
Analysis
During the last assessment period, no major programmatic weak-
nesses attributable to the conduct of maintenance were identi-
fled.
The strong performance was attributable to a combination
of a good procedure system, adequately trained maintenance per-
sonnel, and strong management action in assuring the development
and dissemination of plant policies.
The licensee has continued their strong level of performance for
maintenance and modification of safety-related components at
Beaver Valley. Only 2 trips have been partly attributable to
instrument and control technician error during the last 18
months.
LER casual analysis establishes no trend applicable to
maintenance personnel, procedures or the general program. This
can be attributed to the system specific training for all I&C
technicians; mechanic adherence to well-written surveillance
procedures that incorporate specific initial conditions, accep-
tance criteria, and double verification of critical steps; and
the station policy on personnel accountability.
One weakness evident during this assessment period has been the
large number of secondary side component problems.
Of the 15
reactor shutdowns, 8.can be attributed to component problems on
the secondary side.
Additionally, there were 13 major power
reductions; three problems each resulted in two power reductions
to rework the same basic problem such as a feed pump seal re-
pair.
A second concern is the length of time certain backup
safety related components have been out of service for mainte-
nance and modification work.
In particular, the C charging pump
(6 months), the A river water pump (10 weeks), and various back-
up component cooling water pumps and heat exchangers (several
months each) have been out of service for an excessive amount of
time due to a combination of vendor support problems, procure-
ment and other delays caused by construction and engineering.
When a safety related component impacts a technical specifica-
tion action statement, licensee action has usually been swift,
well thought out and correctly performed.
However, when an item
is less pressing in terms of technical specification operability
requirements and portions of the work have to be done off site,
it tends to remain incomplete for an inordinately long period of
time as noted above.
These problems have been mostly related to
the mechanical components and not instrumentation or electrical
equipment.
Plant support from the Nuclear Engineering and Construction Unit
(NECU) has improved over this assessment period.
Previous con-
,
'
cerns with the timely resolution of problems and the prioritiza-
tion of engineering memoranda for resolution of the most
l
[
.
.
18
impo'rtant safety problems in a timely manner have received in-
creased management attention.
The total lag time in responding
to plant problems has been slowly improving during this assess-
ment period.
In the area of a non-licensed training program, the licensee has
revised and reestablished a training manual based on the concept
of " Systematic Approach <to Training".
The instructors are
knowledgeable and qualified, and coverage of topics is adequate.
The improvement in the quality of instruction and its effec-
tiveness was achieved mainly through permanent staffing of three
maintenance instructors.
The management is currently seeking an
INP0 accreditation for their non-licensed training program.
,
I
Plant safety-related modification activities nre well con-
trolled.
Review of those activities related to the 125V DC bat-
4
tery replacement and the NUREG-0737 required safety parameter
display system by regional specialists indicated that such work
i
complied with the engineering requirements of the technical
.
i
specifications, applicable Reg. Guides and industry standards.
Resident inspector review of other ongoing modification activi-
ties throughout'the assessment period confirmed that quality
control inspectors were actively involved in the day to day work
performance, and that appropriate equipment clearances and con-
ficuration controls were implemented.
'
j
. Quality Control activities have been very good for all mainte-
'
nance and modification work. The program is structured such
that all maintenance work requests, corrective maintenance pro-
cedures, and preventive maintenance procedures are initially
forwarded to QC for assignment of any desired hold points.
i
Safety significant nonconformance reports are dispositioned in a
,
timely manner.
One potential concern identified in an earlier
assessment was that there were two basic QC programs, one con-
4
4
ducted by Operations QC for all Unit 1 maintenance and a second
conducted by vendor supplied QC for modification work.
Noncon-
j
forming items identified by the vendor's group were not always
'
administrative 1y closed out in a timely manner because the con-
tractor could not get NECU to take the necessary action.
The
licensee has been responsive in making the necessary program
changes to assure that all nonconforming items are now tracked
,
and closed out in a timely manner.
,
The procurement program and the administrative controls for re-
ceipt, storage and handling are generally satisfactory. The
4
Master Equipment List is maintained up to date and used exten-
]
sively.
NECU effectively evaluates and insures that EQ require-
ments are included in procurement of safety-related items.
-
audits of these areas are adequate, and identified deficiencies
are properly dispositioned.
Requirements have been established
to specify special tests, instructions, other technical
.
t
.
19
J.
i
l
requirements, documentation, preventive maintenance, shelf-life
program, and storage and handling.
However, these requirements
were not always effectively implemented in the field.
Problems
found include the maintenance of inadequate qualification status
for spare instruments and inadequate implementation of the pre-
ventive maintenance and shelf-life programs for spare parts.
Another area needing increased attention is the zero reorder
level of certain critical parts (especially electrical).
Also,
there have been several instances in the past where non-critical
maintenance was delayed due to a lack of such parts.
Further
licensee attention to this area is appropriate.
Vendor assistance and support to the station has sometimes been
poor.
For example, the charging pump work has been protracted
due to vendor errors in supplying correct parts. The same prob-
lems occurred earlier with the river water pump.
This indicates
that station staff needs better corporate support.
In summary, safety related maintenance activities by the Mainte-
nance Group continues to be performed well.
The I&C and Elec-
l
trical Groups have performed particularly well.
The Mechanical
'
Group has experienced problems, particularly on the secondary
side and with respect to modification work of standby safety
components that need vendor or engineering support. Additional
attention could be provided by the licensee to better direct
efforts when equipment problems require coordination between
,
'
multiple plant groups.
2.
Conclusion
Rating:
Category 1
Trend:
Consistent
3.
Board Recommendation
Licensee:
Consider evaluation of secondary system mechanical problems
impact upon reactor protection system through unnecessary
challenges.
,
k
_ . _ .
._.
_
_.
- . - - - - - . - . -
-
-
,
.
.
20
D.
Surveillance (404 hours0.00468 days <br />0.112 hours <br />6.679894e-4 weeks <br />1.53722e-4 months <br />, 12%)
1.
Analysis
During the last assessment period, problems identified in the
surveillance area included scheduling of non-routine tests need-
ed to meet off-normal requirements (i.e. , special refueling mode
tests, increased frequency ASME Section XI tests of pumps and
valves, etc.) and management oversight and control of the
Inservice Inspection (ISI) and Inservice Testing (IST) programs.
Previous problems encountered in scheduling surveillance tests
of a non-routine frequency have not recurred during this assess-
ment period indicating that corrective actions were adequate.
The lack of a single document that identified and cross refer-
enced all required tests to the specific plant procedures was
corrected by the development of a matrix.
During this assess-
ment period, the development of this matrix has contributed in
the continued identification of other problems (6 LER items)
that had existed but gone undetected.
Examples include surveil-
lance tests that were incomplete because not all components were
tested (such as the containment vacuum breaker and manual trans-
fer switch of safety injection to recirculation mode), inade-
quate testing of station batteries, failure to meet ASME IST
requirements for the component cooling water pump due to an in-
adequate surveillance method, the failure to schedule the PORV
isolation valve limit switch calibrations after procedure re-
writing, discrepancies in reactor trip response time testing due
to a tracking deficiency for a logic train tested on a
non-staggered basis, and the failure to log various surveillance
requirements that are specific to Mode 4.
Most of these defi-
ciencies had existed for some time and were identified as a re-
sult of the matrix.
The use of this matrix is expected to pre-
clude the introduction of new deficiencies as the technical
specificatians are amended.
Inspections confirmed that the BV-1 Inservice Inspection - Non-
destructive Examination Program is sound.
Procedures reviewed
met the technical requirements of ASME B&PV Code Section XI -
1974 and other regulatory guidelines. Testing methodology ob-
served in the field was correct, personnel were well qualified
and data was properly recorded and reviewed.
Performance in
this area has been enhanced by acquiring the services of a qual-
(fied contractor specializing in this area.
Inspections at the end of the last SALP period and early in this
one determined that licensee control of the contractor involved
in the snubber surveillance and hangers / supports ISI program was
not as effective as control of the NDE contractor.
Problems
found included inadequate data collection methodology for ASME
Class 1 and 2 hangers and supports, and no review of that data
L
_ _ .
.
..
'
21
for acceptability.
After identification of the general ISI pro-
gram deficiencies, the licensee was responsive in developing an
extensive plan of action, due to be completed by October 15,
1985.
The effectiveness is yet to be reviewed.
Three Level IV Violations associated with surveillance and
inservice testing were cited during this period.
Included were:
(1) the failure to test station batteries to system design re-
quirements, (2) deficient surveillance logs for boric acid in-
ventory calculation, and (3) valve leak testing not to ASME
'
Section XI requirements.
All of these problems existed because
of test procedure deficiencies' existing since initial plant
startup indicating previous inadequate procedure development and
review (s).
Because of the completion of the surveillance proce-
dure matrix and Unit 1/ Unit 2 Technical Specification cross re-
view, additional procedural deficiencies of this nature are
thought to be unlikely.
The surveillance program has been effective in identifying com-
ponent problems.
The licensee takes prompt corrective action to
address the root cause of those problems.
For example, when a
480V chemical addition pump failed to start from the control
room on its first attempt, investigation revealed that one of
.
three phases in the breaker was not making proper contact. The
licensee changed their administrative control procedures to re-
quire that whenever a safety related component is racked off of
its electrical bus, the component be bumped prior to declaring
,
it operable when racked back on.
1
Other program problems have been or are in the process of being
corrected.
Some 18 month surveillance tests were found to ref-
erence other approved routine tests that have conflicting ini-
tial conditions.
During the last refueling outage, several
operations surveillance tests (OST) were run over extended peri-
ods of time by multiple shifts of operators without reverifying
initial conditions.
The licensee is in the process of upgrading
their administrative controls of these OSTs to the same
programmatic level already achieved by other station groups
1,
(Plant Performance and Testing, I&C, Maintenance).
In summary, the overall surveillance program, administrative
controls, and test procedures are considered good.
Licensee
responsiveness to NUREG-0737 item I.C.6 for operational verifi-
cation has been well implemented throughout the various plant
.
procedure groups.
The last area still requiring increased man-
agement attention is control over the contractor groups conduct-
ing Inservice Inspection and Testing Programs.
During the
latter half of this assessment, the licensee's performance has
been excellent.
Continued performance at this level should re-
sult in a Category 1 rating next assessment period.
.
. - - - - . - -
- .
-
.
..
,
.
l
22
2.
Conclusion
Rating: . Category 2
Trend:
Improving
3.
Board Recommendation:
NRC:
At least two months before start of next refueling outage,
schedule meeting with licensee to discuss ISI program and plans.
E
,
.
.
23
E.
Fire Protection and Housekeeping (134 hours0.00155 days <br />0.0372 hours <br />2.215608e-4 weeks <br />5.0987e-5 months <br />, 4%)
i
1.
Analysis
During the last assessment period, no significant new problems
were identified in this area; licensee corrective actions initi-
ated to address weaknesses noted in late 1982 were either com-
plete, or scheduled to be completed shortly after the end of
that assessment.
This assessment is based on one region-based inspection of the
licensee's Fire Protection / Prevention Program, including program
administration and controls; hardware maintenance, inspections
and tests; staffing, training and drills; and QA audits plus
routine resident inspection of plant conditions.
The licensee has completely implemented all of the corrective
actions that were underway during the previous SALP.
This has
resulted in an excellent Fire Protection / Prevention Program that
is in compliance with the plant Fire Hazard Analysis, FSAR and
Technical Specifications.
The fire protection group (including
shift support personnel) is well staffed with qualified and
trained personnel whose responsibilities and duties are clearly
defined and understood.
The licensee has instituted controls to
review and approve fire protection related construction, modifi-
cation and maintenance activities affecting safe plant opera-
tion.
Special authorization is required prior to welding,
cutting and grinding.
The use of combustible or hazardous mate-
rials are safeguarded in all areas.
Sufficient resources are employed for fire brigade training.
Included are initial training, monthly drills for each shift and
semi-annual drills that include hands on practice.
Management
has established requirements for announced and unannounced fire
drills.
Especially noteworthy is the coordination between the
plant and local fire departments that is demonstrated through
annual on-site exercises.
The condition of the fire protection water system and associated
equipment and accessories including fire hydrants and contents
of hose houses, fire detection and alarm system, fire barriers
and penetration seals, fire doors, and portable fire extinguish-
ers indicate that the management involvement and control in as-
suring plant fire protection and loss prevention are good.
Licensee actions taken when technical specification required
fire systems and equipment problems are,found demonstrate that
the' plant's approach to resolving fire protection related safety
issues is also good.
On the whole, housekeeping is properly maintained.
Licensee
performance did slip during the fourth refueling outage due to
L_
._
.
.
24
the large amount of work activity.
Recovery of general house-
keeping conditions was slow and sporadic because the plant
lacked a programmatic approach consistently applied through rou-
tine plant tours by senior management.
Also, licensee manage-
ment did not hold craft and maintenance personnel accountable
for the as-left condition of their job site. More emphasis has
recently been placed in this area.
In summary, the BV-1 fire prevention program has been effective
in minimizing fire hazards and maintaining a high state of read-
iness to handle such challenges through a well trained and
equipped staff.
2.
Conclusion
Rating:
Category 1
Trend:
Consistent
3.
Board Recommendation:
None
_
-.
. _ . . . - - -
- ..
.-- .
-
.-. -
.
.
25
F.
Emergency Preparedness (388 hours0.00449 days <br />0.108 hours <br />6.415344e-4 weeks <br />1.47634e-4 months <br />, 11%)
1.
Analysis
The previous assessment identified no programmatic weaknesses or
significant individual problems.
During this assessment period, there were no violations or re-
portable events related to the licensee's state of emergency
preparedness.
This assessment is primarily based upon NRC team
inspections of the emergency exercises conducted on June 27,
1984, and September 19, 1985, including NRC particiaption in the
latter exercise, and routine observations by the resident
inspectors.
The licensee's commitment of adequate resources to the emergency
preparedness program in the areas of staffing, training, manage-
ment, facilities and equipment has provided a superior level of
performance.
Based on the two emergency exercises, it is appar-
ent that management emergency response personnel possess the
necessary skills and temperament to cope with emergency condi-
tions.
During both exercises, the licensee successfully demon-
strated the use of their newly constructed, dedicated Emergency
Response Facility which contains the Emergency Operations Facil-
ity, the Technical Support Center and associated support
services.
The depth of the licensee's commitment to meeting the intent of
the emergency preparedness requirements was evident in the num-
ber of small scale exercises held throughout the year, the
amount of cross-training that results in their ability to assign
any one of a number of qualified people to each emergency staff
position, and the extensive coordination with local community
and government organizations.
This management philosophy was
also evident in the other emergency service areas of fire pro-
tection and security.
,
The licensee's serious approach to the drills resulted in well
thought-out and developed scenarios.
A plant specific simulator
was used to walk down details of the drill and obtain realistic
operating data.
Prior to the exercise conducted on September
19, 1985, the licensee's Director of Emergency Planning and two
staff members conducted a well organized training and orienta-
tion session at Region I regarding the licensee's emergency fa-
cilities and program including the emergency programs of the
three states in their Emergency Planning Zone.
The purpose was
to provide the NRC Region I Emergency Response Organization with
detailed information to enhance their participation with the
licensee and states during the exercise.
_-
- . .
..
.
26
The Federal Emergency Management Agency (FEMA) selected the
licensee as the utility representative to participate in the
Relocation Tabletop Exercise to be conducted during December
1985.
The licensee has shown good support of this effort by
preparing a scenario for the exercise and involving FEMA and
other Federal Agencies in exercise planning.
2.
Conclusion
'
Rating:
Category 1
!
Trend:
Consistent
3.
Board Recommendations:
None
-
4
.
4
,-.
.
27
G.
Security and Safeguards (161 hours0.00186 days <br />0.0447 hours <br />2.662037e-4 weeks <br />6.12605e-5 months <br />, 5%)
1.
Analysis
During the previous assessment period, no programmatic weakness-
es or significant individual problems were identified in this
-area.
Two routine unannounced physical security inspections were con-
ducted during this assessment period by a' region-based inspector
and routine inspections-were conducted by resident inspector.
During'this SALP period, the licensee submitted five security
event reports.
Four of the events concerned personnel access
control. Two of these events involved issuing an employee the
incorrect access badge.
The third event concerned an employee
<
being admitted access ~to the plant without_ displaying his badge
'
or-having it in his possession.
The fourth event may have also
involved access to the plant without a badge.
Although the en-
ployees admitted to the protected area (PA) were authorized ac-
cess, the events could be indicative of the beginnings of a less
than fully attentive attitude on the part of the security force.
No major or programmatic problems were-identified, but the
licensee _should intensify his oversight of the security contrac-
tor to ensure that a decline in security program effectiveness
is not occurring.
Licensee management was involved in the program as evidenced by -
.the foresight used in planning for the inclusion of Beaver Val-
ley Unit 2.
Those plans include a hardened, seismic environmen-
tally controlled' Security Building in which an upgraded
secondary alarm station will be located.
Two Modcomp Classic II
- 75/A r.omputers have been procured and are already on site.
These will vastly improve the security data processing capabili-
ty by providing two fully independent computers, s.:ither of which
will be capable of processing the combined Unit 1 and Unit 2
security system computer traffic after the current Unit 1 system
is modified to be compatible with the new computers.
Overall, the training program appears to be good as evidenced by
the low number of reportable events and violations during the
period and the performance of the personnel during contingency
and emergency drills observed by NRC inspectors.
Morale is high
and personnel exhibit a very professional demeanor.
Additional-
ly, turnover is minimal.
The scope of the annual corporate security audit was comprehen-
sive and included all aspects of the security program. The team
was comprised of well qualified individuals, one from corporate
security and two from the quality assurance departments.
No
deficiencies were noted; however, two observations were made to
"
- .- ,
.
..
.
.
28
improve the program and to prevent deficiencies from occurring.
Appropriate actions were promptly undertaken by the licensee to
improve those potential problem areas.
i
The licensee's management and contractor supervisory organiza-
'tions remained essentially unchanged from that discussed in the
previous SALP report.
With the exception of those potential
weaknesses previously discussed, those organizations appear to-
have remained effective in implementing the program.
2.
Conclusion
Rating:
Category 1
Trend:
Consistent
3.
Board Recommendations:
None
i
.
.
29
H.
Refueling and Outage Management (118 hours0.00137 days <br />0.0328 hours <br />1.951058e-4 weeks <br />4.4899e-5 months <br />, 3%)
1.
Analysis
The previous assessment identified no major programmatic prob-
lems in the refueling and modification area.
The Severity Level
III problem for the RHR system alignment and river water system
alignment was considered to be an operations related problem
caused in part by inadequate surveillance procedures and shift
turnover procedures.
Outage management was not considered a
contributing factor.
Licensee actions to correct this problem
were strong and unusually thorough.
During recovery from the fourth refueling outage during this
assessment period, major problems occurred which included a bo-
ron dilution past the desired end point due to a grcss operator
miscalculation, the unnecessary challenge of the main steam
safety valves during initial plant heatup and the failure to
establish containment integrity prior to plant heatup.
Although
-these problems were operational in nature, they are attributed
to inadequate management control of restoration and outage re-
covery activities preceding startup and are thus included in
this functional area.
During the refueling outage recovery and plant restart phase,
the normally effective management controls exercised during
plant operations broke down as the licensee attempted to place
the plant back on line to meet a scheduled deadline. Items that
were considered to have a contributed to this problem included
control room congestion, the lack of supervisory attention to
major plant evolutions, and a cumbersome startup procedure
methodology.
The licensee was responsive in addressing weaknesses in this
area.
Formal configuration controls were strengthened as stated
in the licensee's response to the civil penalty.
In addition to
those actions to which DLC formally committed, the Operations
Department has embarked on an overall improvement program for
the administrative controls. Though these corrective actions
appear effective as evidenced during the two week maintenance
and repair outage of April 1985, overall effectiveness cannot be
demonstrated or evaluated pending performance during recovery
from a major outage.
The bulk of the 14 week outage, other than the restart phase,
was well controlled.
Previous problems such as loss of RHR pump
suction were successfully avoided by performing such evolutions
in a deliberate and preplanned manner.
Actual refueling maneu-
vers were generally well controlled with two minor exceptions
due to poor communication techniques.
. - - -
-
-
- - - . _ .
-.
.
..
.
.
30
j
l
Satisfactory control was exercised over the startup physics
testing following the fourth refueling.
The cycle's reload
safety evaluation, which indicated that no unreviewed safety
concerns were involved, received appropriate review and approval
by the plant safety committee.
The refueling was conducted in
accordance with an approved procedure that provided for QC hold
points and confirmation of the core "as-loaded" conditions. The
test program compared the as-measured data to predicted values.
Specific tests observed were properly conducted and results met
specified acceptance criteria.
The previous assessment discussed several industrial safety
problems that occurred inside containment .
Though these exact
problems were not repeated, there was one near fatality and an-
other significant near miss due to falls inside containment.
Since startup, the licensee has placed increased emphasis on
personnel safety due to an overall increase in injuries,
In-
creased licensee attention in this area during the next outage
is still warranted.
,
The licensee's ability to manage unscheduled outages has been
good.
The two week outage in May 1985, to repair a steam leak
on the pressurizer manway cover went well with no major prob-
lems.
Items on the unscheduled shutdown list were also worked
during this time.
Recovery from this outage was done in a pur-
posely deliberate manner to avoid all previous problems.
This
demonstrates that the licensee does not intend for the previous
outage recovery problems to reoccur.
Recovery from other reac-
tor trips and plant shutdowns since the fourth refueling outage
have likewise been well controlled and deliberate.
In summary, licensee control over work during unscheduled shut-
downs remains good.
The Planning and Scheduling Group provides
good coordination of the outage plans as approved by the Plant
Manager.
Maintenance activities are well controlled and the
plant is restarted in a deliberate and disciplined manner.
The
major contributor to the rating in this functional area was the
inadequate management control of restoration and outage recovery
activities following the last refueling outage; the licensee has
since developed additional controls for such activities.
If the
licensee continues to maintain this philosophy and adheres to~those
changes implemented in their response to the civil penalty, no
further problem should occur during recovery from the next major
outage.
2.
Conclusion
Rating:
Category 3
Trend:
Not applicable; no major outages during last quarter.
-
.. .
.
.
__ _ -
_ _ _ -
.
. _ _ - _ -
-
-
.. - .
.
.
31
.
3.
Board Recommendation:,
'
Licensee:
Finalize tightened administrative controls for outage recovery
before start of next refueling outage.
NRC:
Also discuss licensee plans for outage recovery in same manage-
ment meeting as discussed in Section D.
Augmented inspection
coverage during outage recovery.
J
4
1
J
J
~.
-
-
.
. _ _ .
. . _ _ -
_ . _ , , . , _
_
.
. . . - . . . . .
-
. . -
- - .
. . - - _ _ _ .
_ _ - -
.
-
_ _ _ _ _ __
__
- E
-.
32
_
I.
Licensina
1.
Analysis
The last three SALPs noted that the licensee had continued to
demonstrate a high level of performance in this. functional area.
. Based on their performance in support of licensing actions that
were either completed or had a significant level of activity
during the current period, that assessment remains valid.
During the present rating period the licensee's management dem-
onstrated active participation in licensing activities and kept
abreast of current and anticipated licensing actions.
The man-
agement's involvement in licensing activities generally assured
a timely response to requirements of the Commission.
Involve-
ment was evident in the use of a system in which all open ac-
tions were scheduled and tracked.
Management generally
exercised good control over its internal activities and its con-
tractors and maintained effective communication with the NRC
staff. The licensee has invariably met schedules or' informed
NRC at an early date of schedular problems. There has been no
need for emergency or expedited issuance of amendments; this is
indicative of good planning and management of licensing
activities.
The interaction of the licensee with the NRC staff has' resulted
in clear understanding of safety issues.
Responses were usually
on time. .For those that may be late, the licensee invariably
provided advance notice to the project manager.
Sound technical
approaches are taken toward their resolution.
Conservatism was
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.
The licensee has been
aggressive in pursuing closeout of open licensing issues.
Licensee personnel were in constant open dialog with the NRC
Project Manager; verbal commitments were always adhered to and
followed up in writing.
Consistently sound technical justification were provided 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 ad-
ditional information.
There were no longstanding regulatory
issues attributable to the licensee.
In summary, the licensing organization was staffed by qualified
technical personnel who adequately understood the regulatory
requirements and technical issues.
This organization was well
managed, resulting in adequate and timely responses to safety
issues,
k
.
.
33
2.
Conclusion
Rating:
Category 1
Trend:
Consistent
3.
Board Recommendation:
None
-
,
L __
.
.
34
V.
Supporting Data and Summaries
A.
Investigations and Allegations Review
Four allegations were received during the 18 month assessment period.
A special inspection of electrical QC in response to one allegation
and routine resident followup of two other allegations failed to sub-
stantiate them.
The fourth allegation involved radcon and industrial safety practices
during containment closeout after the refueling outage. The resident
inspector inspected and documented findings in report 334/84-33.
The
first part of the allegation concerning RWP violations had been pre-
viously identified and corrected by the licensee.
The second part of
the allegation pertaining to maintenance of personnel access pathways
in containment remains open and will be monitored during the next
outage.
No investigations were conducted.
B.
Escalated Enforcement Actions
A Severity Level III Violation and $50,000 Civil Penalty was issued
'
on March 19, 1985, due to management control problems related to
startup activities following refueling outages.
These problems re-
sulted in the failure to establish containment integrity prior to
plant heatup, an unnecessary challenge of a main steam safety valve
and a gross miscalculation of dilution of boron and lack of proper
confirmation during dilution.
The civil penalty was not contested.
C.
Management Conferences
Date
Subject
6/12/84
Management Meeting at site to discuss
SALP for 12/1/82-3/31/84 assessment
period.
2/13/85
Enforcement Conference concerning the
proposed Civil Penalty.
.- _.
-
_. . - .
.
.
- ..
- ...
- -
.
..
35
D.
Licensee Event Reports (LERs)
Tabular Listing
Type of Events:
A.
Personnel Error . . . . . . . . . . . . . . . .
5
...
B.
Design / Man./Construc./ Install . . . . . . . . . . . .
3
C.
External Cause
...................
O
D.
Defective Procedures. . . . . . . . . . . . . . . . .
8
E.
Component Failure . . . . . . . . . . . . . . . . .
11
X.
Other .
.......................
6
Total
33
Licensee Events Reports Reviewed:
Report Nos.84-003 through 85-016
Causal Analysis
Two distinct trends were identified:
1.
84-05, 84-06, 84-09, 84-13, 85-05,-85-09 and 85-12 involved sur-
veillance program deficiencies.
Five of the items were due to
failure of procedures and tests to incorporate TS surveillance
requirements and the other two items were scheduling errors.
Most were identified by licensee reviews.
2.
85-06, 85-10 and 85-13 involved reactor trips due to steam
generator level control problems since startup from the fourth
refueling outage.
This relatively recent development can be
attributed to a combination of secondary equipment problems,
experience level of newly licensed operators and procedure
inadequacies.
'e- -
- -.
.- -
1
i
l
.
,
,
TABLE 1
LISTING OF LERS BY FUNCTIONAL AREA
BEAVER VALLEY POWER STATION UNIT 1
AREA
NUMBER /CAUSE CODE
TOTAL
A
B
C
D
E
X
Plant Operations
1
2
7
1
11
Radiological Controls
0
Maintenance
1
1
Surveillance / Inservice
< -
Testing
2
3
5
4
5
19
'
Fire Protection /
Housekeeping
1
1
0
Security and Safeguards
0
-
Refueling /0utage
Management
1
1
Licensing
0
'
TOTAL
33
Cause Codes:
.
A
Personnel Error
B
Design, Manufacturing, Construction or Installation Error
C
External Cause
D
Defective Procedures
- E
Component Failure
X
Other
F
v.---
-
---w_ _ _ , - , . , _ , , - ,,
-7,...
,,,,~,--,-y
, _
, , , - .
m-y-
.,-,-~.-,,-v
- , , - - -
. - - , _
..e, , - - + - - - - , - -
4-.
,
.
.
TABLE 2
LER SUMMARY (4/1/84 - 9/31/85)
BEAVER VALLEY UNIT 1
LER Number
Summary Description
84-003
Reactor trip on source range high flux during manual
reactor shutdown.84-004
Reactor trip due to generator / turbine trip.84-005
containment vacuum breaker and
manual transfer of safety injection to recirculation
mode.84-006
Inadequate surveillance testing - station batteries.84-007
Failure of containment recirculation cooling coils
chilled water system outlet isolation valve.84-008
Inadvertent reactor trip at 0 power due to failure to
follow surveillance procedure.84-009
Missed operations surveillance test required by
technical specification (containment fire detectors).84-010
Inoperable hydrogen recombiner.84-011
Main steam safety valve lift settings outside
allowable limits.84-012
Unit I reactor trip due to Unit 2 breaker trip.84-013
Failure to meet ASME Section XI IST Requirements.84-014
Inoperable hydraulic snubber.84-015
"A" steam generator tube plugging.-84-016
Seismic monitor inoperable more than 30 days.84-017
Reactor trip from 0 power due to low level amplifier
installation.84-018
Pressure high level reactor trip setpoint greater than
Tech. Spec. limit.84-019
Pressurizer code safety valve lift setting greater than
Tech. Spec. limit.
L
.
.
'T2-2
LER Number
Summary Description
85-001
Startup prior to establishing containment integrity.85-002
Reactor coolant system leakage.85-003
Inadvertent reactor trip and safety injection.85-004
Auxiliary Feedwater pump spurious auto-start.85-005
Failure to perform PORV isolation valve limit
switch calibration.85-006
Turbine trip / reactor trip due to low SG level.85-007
Inoperable hydraulic snubbers.85-008
Automatic actuation of reactor protection system
while shutdown.85-009
Discrepancies in reactor trip response time testing.-85-010
Reactor trip due to low-low steam generator level.85-011
Inoperable chemical addition pump.85-012
Surveillance Program Deficiency.85-013
Reactor trip on low-low steam generator levels
during power ascension.85-014
Inability of diesel generator to assume full load.85-015
Safety injection / reactor trip due to loss of
station instrument air pressure.85-016
Reactor trip due to vital bus electrical spike.
-
,
.-
,
TABLE 3
' ENFORCEMENT SUMMARY (4/1/84 - 9/30/85)
BEAVER VALLEY POWER STATION UNIT 1
.A.
Number and Severity Level of Violations
0
Severity Level'II
O
1
12
1
Deviations
0
Total
14
B.
Violation vs. Functional Area
Functional Area
Severity Levels
I
II
III IV
V
Dev
Plant Operations. . . . . . . . . . . . . . . . .
2
Radiological Controls . . . . . . . . . . . . . .
2
1
Maintenance . . . . . . . .
....
Surveillance / Inservice Testing. . . . . . . . . .
3
Fire Protection / Housekeeping
1
. .........
Emergency Preparedness. . . . . .
.
Security and Safeguards . . . . . . . . .
4
....
Outage Management / Refueling . .......
1
Licensing . . . . . . . . . . . . . . . . . . . . . . . . . . .
Totals
1
12
1
0
.
.
TABLE 4
ENFORCEMENT DATA
BEAVER VALLEY POWER STATION UNIT 1
Inspection
Inspection
Severity Functional
Report No.
Date
Level
Area
' Violation
84-15
6/2-7/6/84
IV
Plant
Failure to follow
Operations
equipment clearance
procedures.
,
IV
Surveillance
Station batter its
not tested to
system design
requirements.
84-25
11/2-12/9/84
IV
Security
Protected area access
procedures not
followed.
84-27
11/13-16/84
IV
Security
Vital area key control.
IV
Security
Excess vegetation
within PA isolation
zone.
84-31
12/17-21/84
IV
Transportation QC program for 10 CFR 61.55 and 61.56.
IV
Transportation QA program for
transport packages.
84-33
12/10/84-
V
Radiological
Termination exposure
1/7/85
Controls
report not issued.
IV
Operations
Equipment control
procedures not
implemented.
85-02
1/8-2/19/85
IV
Surveillalce
Surveillance logs
deficient for BA
inventory.
IV
Surveillance
Valve leak testing
not to ASME
requirements.
.
--
,--
. .
e
T4-2
Inspection
Inspection
Severity Functional
Report No.
Date
Level
Area
Violation
85-03
1/8-15/85
III
Outage
Containment integrity
Management /
not established prior
Refueling
to plant heatup.
85-11
3/21-4/5/85
IV
Fire
Vent duct fire rating
Protection
deficient.
85-18
7/27-8/31/85
IV
Security
Wrong security badge
issued.
1
I
r
er
---v.-
.--.p-n
.-
-- - -- - - +
, , - - -
-,e
,
a-,
-
,-n
~n-
- ~<
--,rw
, --
-y
w
a
O
TABLE 5
INSPECTION HOURS SUMMARY (4/1/84 - 9/30/85)
BEAVER VALLEY POWER STATION UNIT 1
HOURS
% OF TIME
Plant Operations. . .
. . . . . .
947
28
..
Radiological Controls . . . . . . . .
749
22
Maintenance . . . . .
. . . . . . .
486
14
.
Surveillance / Inservice Testing . . .
404
12
Fire Protection / Housekeeping . . . .
134
4
Emergency Preparedness. . . . . . . .
388
11
Security and Safeguards . . . . . . .
161
5
. Outage Management / Refueling . . . . .
118
3
Licensing .
-*
-*
. . . . . . ........
TOTAL
3387
100%
- Hours expended in facility license activities not included with
direct inspection effort statistics.
L
,
.
o
TABLE 6
INSPECTION REPORT ACTIVITIES
BEAVER VALLEY POWER STATION UNIT 1
REPORT NO. AND
INSPECTION DATES
INSPECTOR
AREA INSPECTED
84-09
4/1-5/4/84
Resident
Routine
84-10
4/10-13/84
Specialist
Radiological Controls
84-11
4/30-5/4/84
Specialist
Security
84-12
5/5-6/1/84
Resident
Routine
84-13
84-14
5/29-6/1/84
Specialist
Snubber Surveillance and
ISI Program
84-15
6/2-7/6/84
Resident
Routine
84-16
6/25-28/84
Specialist (Team)
84-17
7/9-13/84
Specialist
Radiological Controls
84-18
7/7-8/13/84
Resident
Routine
84-19
7/23-27/84
Specialist
Rad Waste Program
84-20
8/14-9/24/84
Resident
Routine
84-21
9/10-14/84
Specialist (Team)
84-22
9/25-11/1/84
Resident
Routine
---
-
-
-
.
.
6
O
T6-2
REPORT NO. AND
INSPECTION DATES
INSPECTOR
AREAS INSPECTED
84-23
10/9-12/84
Specialist
Instrumentation /
Modification
84-24
10/1-5/84
Specialist
Radiological Controls /
QC Measurements
84-25
11/2-12/9/84
Resident
Routine
84-26
10/29-11/2/84
Specialist
84-27
11/13-16/84
Specialist
Security
84-28
12/3-6/84
Specialist
Procurement / Receipt.
Storage and Handling
84-29
Cancelled
84-30
12/11-21/84
Specialist
Electrical, QC,
Allegation Followup
84-31
12/17-21/84
Specialist
Transportation
84-32
10/15-19/84
Specialist
Operator Licensing Exams
84-33
12/10/84-1/7/85
Resident
Routine
85-01
1/7-11/85
Specialist
Startup Physics Testing
85-02
1/8-2/19/85
Resident
Routine
85-03
1/8-15/85
Resident
Special - Operations
85-04
2/26-28/85
Specialist
Operator Licensing Exams
J
L-
- _ .
- . - - . -. -.
.
-- _.
-.
- - . - .
-o
r
e-
,
L-
T6-3
'
l
I
h
REPORT NO. AND
INSPECTION DATES
INSPECTOR
AREAS INSPECTED
r
l
85-05
2/19-21/85
Specialist
Fire Protection
l-
85-06
Resident
Routine
2/20-3/20/85'
85-07
Specialist
Nonrad. Chemistry
4/2-4/85
85-08
Cancelled
'
85-09
'
3/25-27/85
Specialist
Non-licensed Training
85-10-
4/30-5/3/85
Specialist
Operator Licensing Exams
85-11
3/21-4/5/85
Resident
Routine
85-12
4/6-5/13/85
Resident
Routine
85-13
5/13-17/85
Specialist
Environmental
85-14
5/13-17/85
Specialist
Surveillance, Calibration
IST of Pumps and Valves
>
85-15
5/20-24/85
Speciai st
Radiological Programs
i
85-16
<
5/14-6/17/85
Resident
Routine
85-17
6/18-7/26/85
Resident
Routine
85-18
7/27-8/31/85
Resident
Routine
85-19
9/18-20/85
Specialist (Team)
EPP Exercise
85-20-
-9/1-30/85
Resident
Routine
. . -
- -
-
- -
-
-
- - -
-
- -
-
-
- -
- - -
-
. . ..
_ _ _ _ . _ - . _ _ _ . _ _ _ _ _ .
_ _ . _ _ _ . . _ . . _ _ _ _ .
. _ - -
_m__ _ _ _ _ _ _ _ _ _ _ . .
_ _
o
.
,
,
,
i'
!y
T6-4
'
,
,
b
REPORT NO. AND
INSPECTION DATES
INSPECTOR
AREAS INSPECTED
l
- -
85-21
9/23-27/85
pecialist
Radiological Controls
~
S
!
1-
p
'
I
s'
k
i
t
!
.i
~
'
,
r
i
'
4
4
.
I
T
4
t
1
4
I
i
<
- 4'
,
,I
3
.,
i
4
&
.:
4
'1
4
+ .i.---
-
.
.
.
.
. .
.
.
. .
o-
.
o
-
TABLE 7
,
.
.
PLANT SHUTDOWNS
-
Date
Description
Cause
5/24/84
Reactor trip due to main
Generator voltage regulator
generator trip.
control system component
failure.
(Random component
failure)
6/8-11/84
Manual shutdown
Main feedwater pump seal
leak.
(Maintenance instal-
<
lation deficiency)
7/5-8/84
Manual shucaown due to
Containment recirc. cooling
high containment
isolation valve failed
temperature.
closed.
(Random component
failure)
10/11/84
Reactor trip due to RCP
IB 4KV Bus lost due to relay
bus undervoltage.
failure during special line
up to test Unit 2 transformer.
(Testing error)
10/13/84
Plant placed in cold shutdown
to start Fourth Refueling
Outage.
1/16-17/85
Safety injection - reactor
Vital bus 3 breaker failed,
- trip due to steam flow -
causing FW control system
i
feed flow mismatch in
to open all main feed reg
coincidence with low SG
valves.
(Possible I&C Tech
level.
error)
1/24/85
Manual shutdown due to
Packing follower on isolation
loss of RCP-1A seal water.
valve failed.
(Random com-
ponent failure)
2/20-21/85
Manual shutdown due to high
Main condenser tube leaks.
secondary system conductivity.(Design)
2/21/85
Reactor trip due to turbine
Main feedwater system control
trip.
failure. (Component failure
and poor operator response)
3/1-4/85
Reactor placed in Mode 2
Condenser tube leaks.
(Design)
due to secondary conductivity.
.
,
- -
.
.._
_ . ~
_
9
+
T7-2
Date
Description
Cause
4/26-5/6/85
Manual shutdown due to high
Leak from pressurizer manway
RCS leak rate.
cover gasket.
(Component
failure and possible installa-
tion error)
5/6/85
Reactor trip due
Feedwater control problems
to low-low steam generator
(Operator error)
level.
7/6-8/85
Steam dump valve
due to low-low steam
malfunction during manual
generator level.
shut down for condenser
tube leaks.
(Component
failure
poor operator
response)
8/29-9/3/85
Safety injection - reactor
Instrument air header joint
trip due to low steam line
failure allowed air-to-open
pressure.
MSIVs to close.
(Design
problem - random failure)
9/16/85
Reactortrkpduetoover-
Short on vital bus II while
temperature - delta
surveillance testing a
temperature.
second loop.
(Modification
installation error)
.
m
m
-
.
.
.