ML20150E462

Equipment Failure /:

Engineering

due to reactor

Design Problem

Support

vessel low

Reactor Feed Pump

level.

(RFP) A tripped

(LER 87-08)

due to a seal

failure while

operating with the

scoop tube

positioners

locked up.

06/10/87

Startup

2.

08/28/87

100%

Initially Unknown:

N/A

due to turbine

Troubleshooting ar.d

trip caused by

discussion with

generator field

vendor could not

ground fault,

determine cause.

(LER 87-12)

Following second

event on 9/7, the

phenomena discussed

below was determined

to be the cause. The

ground was present

only when the

generator was on-line.

08/31/87

Startup

3.

09/07/87

100%

Equipment Failure:

N/A

due to turbine

A deposition of

trip caused by

material on the

generator field

teflon insulation

ground fault,

tube of the exciter

(LER 87-12)

rectifier bank for

the turbine

generator resulted

in a ground fault.

09/11/87

Startup

1

,

.

10

UNPLANNED SHUTOOWNS, PLANT TRIPS AND FORCED OUTAGES

Power

Functional

No.

Date

Level

Description

Cause

Area

4.

09/24/87

100%

Equipment Failure /:

Engineering

due to reactor

_ Design Problem

Support

vessel low

Reactor Feed Pump

level.

(RFP) A tripped due

(LER 87-17)

to high vibration

while operating with

the scoop tube

positioners locked up.

09/25/87

Startup

5.

11/08/87

80%

Equipment Failure:

N/A

due to Average

High flux trip

Power Range

was initiated by

Monitor (APRM)

a sudden Reactor

.

High Flux Trip.

Water Recirculation

(LER 87-18)

System Pump speed

increase caused by

a random failure

in the pump speed

controller.

11/09/87

Startup

6.

12/09/87

100%

Reactor trip due Personnel Error:

Surveillance

to a reactor

While performing

vessel low

surveillance test

level signal.

I&C Technician

(LER 87-20)

trainee did not

fully close

reactor water

level inst:* ment

isolation valve,

resulting in a

false reactor water

Inw level transient.

12/10/87

Startup

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UNPLANNED SHUTDOWNS, PLANT TRIPS AND FORCED OUTAGES

Power

Functional

No.

Date

Level Description

Cause

Area

7.

01/23/88

0%

During a startup

Equipment Failure:

Engineering

from a scheduled

Installation

Support

maintenance outage deficiencies (within Construction

a leaking weld on

code requirements)

the Reactor Water

plus cyclic stresses

Cleanup System was were determined to

found requiring a

have caused a crack

plant shutdown to

in the weld.

repair.

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IV. PERFORHANCE ANALYSIS

A.

Operations (1001 hours0.0116 days 0.278 hours 0.00166 weeks 3.808805e-4 months , 31.8%)

1.

Analysis

During the previous assessment period, this functional area was rated as

Category 2, improving. A marked improvement was noted in the plant

operations with no significant personnel errors occurring during the period

and two reactor trips from power. Other improvements were made in the area

of control room professionalism and event critiques.

Poor performance on

past replacement operator licensing exams was attributed to poor screening.

In addition, weaknesses were noted in the administration of the

requalification program; however, this did not adversely affect plant

operations.

Plant operations have continued to be a strength.

The operations staff

continues to exhibit a safe and conservative approach to plant operations.

Management attention is highly evident and control room operators continue

to demonstrate professionalism and dedication in the conduct of their

duties.

These are evidenced by the absence of plant transients caused by

operations personnel and the conscientious approach taken during plant

startups and other evolutions.

During this assessment, improvements continue to be made in this functional

area.

Policies have been implemented to require formalized pre-shift

briefings. Organization and control of work activities continue to be

improved through better operation of the Work Control Center, which

includes a computerized tagging system.

Changes to the control room, based

on the Control Room Design Review, were implemented to improve the control

room from a human factors standpoint.

These changes included new label

plates for all equipment, which standardized the labeling and nomenclature;

improved mimicking and demarkation of systems; and new annunciator windows,

which incorporate standard nomenclature and format.

These changes have

standardized the control room and have given it a more professional

appearance. A commendable effort to reduce the number of continuously

lighted annunciators in the control room has resulted in having normally 3

or 4 continually lit (out of a total of 800) in the control room. These

initiatives are indicative of the licensee's management commitment to

improving plant operations.

None of the scrams which occurred during this period were caused by plant

operators.

It was determined that the operators' actions to attempt to

prevent scrams due to equipment malfunction were timely and correct.

'

Operators' actions during other operational events were also timely,

effective, and correct.

During the previous period, procedures and procedural adherence were noted

as being generally strong with minor exceptions that required plant

management attention. Although improvements have been - de, isolated cases

of inadequate procedures or lack of procedural compliar.e were noted.

Two

,

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13

examples involved a failure to follow procedures during radioactive liquid

f

discharge and an inadequate procedure resulting in a recirculation pump

trip during testing. Continued emphasis in this area is warranted by plant

,

management.

The operations departmont, is staffed to its full complement, with a six

shift rotation; there has been a low staff turnover rate.

The operations

staff works closely with other departments in recognizing, troubleshooting,

and correcting deficiencies. A strong interface between departments

>

provides for more efficient operations and good communications.

In

addition, operations personnel take active roles in the review of

modifications, implementation of inservice testing, and improvements in

training. Strong management involvement is evident throughout plant

operations. Mcnagers are involved in day-to-day operations, as well as

plant problems.

Examples of management irvolvement include the

identification of an unauthorized discharge during a log review and

on-shif t coverage during high activity periods, such as plant starbG

following maintecance outages.

During this appraisal period, LERs in general adequately described the

major aspects of each event, failures contributing to the event, and the

corrective actions to prevent recurrence.

The reports were thorough,

detailed, and easy to understand.

Sufficient details were givan to provide

a good understanding of the event,

i

The licensee's review and corrective actions related to operational events

were generally thorough and adequate to prevent recurrence.

In particular,

the licensee displayed aggressive and conservative actions to test safety

relief valves following notification of a concern at another boiling water

reactor. Detailed reviews and troubleshooting were conducted following an

unusual main generator ground fault problem which included an extensive

startup testing phase to assure the cause had been identified following a

second trip. Additionally, a detailed review was conducted following

identification of a reactor water cleanup system weld leak to determine

possible causes or other cracks.

However, isolated examples of insufficient review or corrective actions

were noted.

These involved the failure to fully determine the cause of a

main steam isolation valve closure which occurred while the plant was shut

down and ineffective corrective action to prevent a repeat of an emergency

diesel generator actuatien during tra.isfer of house loads.

During this assessment period, improvements continued in the t aining area.

A new training complex was nearly completed at the end of this assessnent

period. A rigorous program for simulator verification is in progress.

In

addition, the licenset is incorporating recent detailed control room design

review improvements, made to the main control room, into the simulator

.

during construction. The delivery of the simulator is scheduled for the

summer of 1988. An NRC requalification examination was administered to 10

operators to evaluate the requalification program based on previous

,

weaknesses.

Six out of seven Senior Reactor Operators and one out of three

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14

Reactor Operators passedLtheir respective requalification written

examinations. All six Senior Reactor Operators and two out of three

Reactor Operators passed their respective requalification operating

examinations. Based on the NRC criteria, the licensee requalification

program is' considered marginal, having six cut of ten operators pass all

portions of the examination.

No generic weaknesses were identified. The

licensee implemented corrective actions to address the specific

deficiencies identified during the examination.

The good.operatirig record

of the plant.is indicative of an effective requalification program.

One Fire Protection inspection was conducted during this SALP period. The

licensee's Fire Protection program, including administrative controls, fire

brigade organization, staff training, and surveillance and maintenance of

Fire Protection equipment were found satisfactory. Associated records were

well organized and were easily retrievable.

Licensee audits of the station

Fire Protection activities were conducted by trained and qualified

individuals.

Concerns identified in the aud'.s were properly dispositioned

in a timely manner.

Housekeeping and material condition, in general, was considered above

average.

Plant cleanliness was very good; however, equipment storage,

scaffolding control, and control of equipment deors and covers were noted

as needing improvement.

In summary, plant operations continue to be a strength. Operations

,

personnel are knowledgeable, dedicated, and highiy motivated toward safe

operations.

Licensee management promotes a safety conscious attitude and

accountability for performance.

They are committed to improving plant

performance as demonstrated by the importance placed in new training

ficilities and by improvements made to the ccntrol room.

2.

Conclusion

Rating:

1

3.

Board Recommendations

None

_.

_ _ _ .

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'B.

Ra'diolog'ical Control's and Chemistry (504 hours0.00583 days 0.14 hours 8.333333e-4 weeks 1.91772e-4 months ,'16.0%)

1.~

Anal sis

.Durin'itha' previous SALP assessment period,' the radiological controls area

g

, .

"

'was rated as Category 2.-

Weaknesses included delayed responses to NRC

findings 'and lack of management attention relative toJconforming to

radiation protection. pro.cedures.

'

During(thisassessmentperiod,onehealthphysicsappraisal'andthree

routine inspections were conducted.

Resident inspectors reviewed this area

t

on a' continuing basis.

Three' violations related to locked high radiation

area controls and audits.were cited.

In addition five violations related

~

to an extremity overexposure were cited.

Ra'diation Protection

Program weaknesses f aentified during the previous assessment period

continued to exist and impacted performance during the early part of this

assessment period.

The licensee's inadequate supervision of radiation

protection activities'during the.beginning of this assessment period may

have ontributt:d'to 'several instances of personnel failing to follow

-procedures, and the extremtty overexposure of-an empioyee. .This

overexposure occurred when a worker threw a piece of highly irradiated

material back into the spent fuel pool when it was inadvertently remond

during cutting of. instrument dry tubes.

Immediate program improvements

were noted in this' area after the overexposure incident.

-

Th'e' radiological protection program is staffed with qualified. personnel.

'

Previous problems associated with the lack of an health physics general

. supervisor were corrected near the beginning of thir assessment period by

-the appointment of.a well qualified and knowledgeable individual to this

position.

'

The -licensee has shown increased responsiveness to NRC concerns during this

. ass _essment period.

Programmatic and equipment weaknesses identified in NRC

inspection reports early in the assessment period were generally resolved

by the end of the~ assessment period.

A' notable exception _ continues to be

the radiological survey instrument controls and calibration facility.

Although the facility is adequate to support normal plant operation, it is

severely taxed during outage conditions.

During this assessment period the individual f;isking units located within

the radiation controlled area were removed from service due to concerns

~

expressed by NRC i.nspectors concerning high background count rates in the

frisker areas. These were replaced with seven IPM-7 complete personnel

, contamination monitoring systens installed at the access control points.

These monitors are state-of-the-art instruments arm should facilitate

detection of personnel contami.iation.

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radiological and environmental services personnel was found to'be very

-good. An initial . training program.has been established for all personnel

-

and a continuing training program has been established for. radiological and

Lenvironmental. technicians. ?These. training' programs'have received'INPO

.

. accredi tation'-duringithi s l period.

LThe ALARA' program is well_ organi.

with good management support and

represents a program. strength.

A_.AA reviews of planned work,. completed

work, and continuous _ exposure evaluation of work in progress are good.

,

Major projects that are in place or planned which will reduce. exposure

>

include. source term reduction through a complete primary system

.

, decontamination, installation of. removable. lagging, use of.high radiation

area video mapping, use of a drywell closed. circuit television system, and

use of_'~a tele-dose monitoring system.

During the course of two inspections

during this assessment period, the ALARA program was examined and found to

be of consistently good quality.

TheD11censee's ALARA person-rem exposure goal for the site was 950

person-rem for'1987,:a refueling year. Actual exposure accumulated was 940

person-rem which continues to be high. Although the ALARA section.was'able

to. plan and control many jobs well, inspectors observed instances of

non productive work involving the very large contracted work force.

For

example, approximately 25 personnel were. observed standing at the refuel

,

-guard ' rail in a 25 mr/hr area and watching the decontamination of the-

cavity.. Also', controls of work involving exposure were lax during the

refueling outage (i.e. contamination of personnel during cavity

decontamination, unmarked containers with radioactive material contributing

to personnel- unplanned exposure, and poor radiological controls of dry tube

cutting operation). .However, exposure goals for 1988 and beyond indicate a

<

much more aggressive' approach to ALARA. By 1990, the licensee's goal is

500 perso'n-rem for a three year average.

This is ambitious considering the

age and h.istory of the plant.

.The program for external and internal exposure control, after the

over-exposure incident, reflects an increased commitment to safety.

'

Following the over-exposure event, increased attention has been placed on

strict adherence to radiation work procedures and radiation work permits.

The respiratory protection program continues to be of high quality.

It is

apparent that the licensee has placed a high priority on this program as

evidenced by effective respirator selection, training, issue, use, and

-maintenance practices.

Licensee quality assurance audits of the radiation erotection program were

found to be technically sound and thorough.

The NRC identified one

deficiency regarding the lack of audits of the qualifications of radiation

protection supervisors below the level of the Radiological and

Environmental Services Superintendent, which was promptly corrected.

Audit

findings were resolved in a timely manner.

, . . _ . . .

,

.

_

_ _ _ _ - - . _ _ - _ - - - _ _

.

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17

..

Chemistry / Radiochemistry

An extensive plant chemistry upgrade program was noted during the

assessment period indicating a management commitment to improve performance

.in this area. Corporate involvement in, and support for, the program were

clearly evident. Technically sound and thorough approaches to improve

sampling and measurement capabilities, introduction of hydrogen water

chemistry and monitoring for control of intergranular stress corrosion

cracking demonstrated a clear understanding of the issues.

Chemistry

staffing at the facility was adequate, fully cognizant of their duties and

responsibilities, and knowledgeable of the licensee's sampling and analyses

procedures.

State-of-the-art analytical capabilit,es were provided.

Analytical capability intercomparisons showed the licensee's analyses to be

adequate with all results within agreement of NRC values.

Technicians

demonstrated both theoretical and practical knowledge of the operation of

the equipment while attempting to resolve disagreements with NRC

measurements. Adequate radiochemical capabilities were demonstrated by the

licensee during a measurements intercomparison with NRC-supplied

radioactivity standards.

Radioactive Waste Management

The licensee's radioactive waste management program was generally adequate.

The liquid and gaseous waste systems meet 10 CFR 50, Appendix I design

objectives but the ' censee takes a more conservative approach treating all

liquid waste before release and requiring the offgas treatment system to be

operational virtually at all times when the plant is operating.

The

licensee has adequate procedures for handling and discharging liquid and

gaseous effluents.

Procedures address, as appropriate, valve line-ups,

sampling and analys's, alarm and isolation setpoints and tracking of

releases to ensure compliance with technical specification limits. In

response to self-identified weaknesses, the licensee has initiated a

-program to improve the Offsite Dose Calculation Manual and related

,

procedures to better address the Radiological Effluent Technical

i

Specifications.

Summary

Several radiological program weaknesses noted early in this assessment

period may have contributed to an extremity overexposure of a worker.

However, significant program improvements in the areas of program oversight

and adherence to procedures were later achieved during this assessment

period.

Increased responsiveness to NRC concerns, a good radiation

protection training and qualification program, and further improvements in

the ALARA program were noted.

Supervisory staffing levels were appropriate

to ensure program oversight and effective implementation.

Subsequent to

the extremity overexposure incident, there exists an increased commitment

to safety and strict adherence to radiation work permits and procedures.

i

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18

Programs for the control o' plant chemistry and radioactive wastes are

effective and indicate' strong site and corporate management support for

these two programs,

2.

Conclusion

Rating:

2

3.

Board Recommendation

None

.

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C.

Maintenance (571 hours0.00661 days 0.159 hours 9.441138e-4 weeks 2.172655e-4 months , 18l2%)~

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1;

An'alysi s

-During'the. previous assessment period, the maintenance functionalLarea was

rated as Category 2.

Improvements were noted in this area withLthe absence

of personnel errors and proficiency in properly completing work. . Progress

.was generally good in implementing improvement: programs.

Procedural

compliance 'and root cause analysis were areas where attention.was :

. +

warranted.

~*

~

The area of outage management was combined with engineering support during

.the previous assessment period.

This area was rated as Category 2.with

improvements noted in the planning'and managing of two short outages (24

days total). During this assessment period, outage management and

maintenance are-addressed under one functional area.

During this period, three routine inspections were conducted covering

activities assor.iated with outage maintenance.

In addition,throughout the

assessment period, the resident inspector frequently reviewed' activities in

this area.

The licensee continued to make progress implementing the extensive'

improvement programs already begun. Although progress.is slow, the scope

and thoroughness of the programs and large volume of information needed

makes this a difficult task. The Master Equipment List (MEL) was completed

during this. period, and is the first key to the comprehensive preventive

maintenance program.

The licensee gathered all pertinent data

(manufacturer, drawings, nameplate) and assigned safety classification

(including basis) for 36,000 components. The next significant portion of

the program begun was the determination of preventive maintenance

requirements. As part.of this effort, the licensee began a program to'

'

validate all of the vendor-technical manuals.

This effort is designed to

ensure that the licensee's technical manuals are up to date with the

~

- vendor's latest revision and any other information, plus gather information

i

concerning recommended maintenance. spare parts, and drawings.

In 1983 (Generic Letter 83-28), the NRC requested that all licensee's

upgrade or confirm their MEL and validate their vendor supplied

information, including the appropriate technical manuals.

The NYPA efforts

described above, although slow and indicative of limited resources, are

responsive to these issues.

The licensee is committed to completing the

update of vendor manuals by December 1988.

During this period, maintenance personnel continued to exhibit a good

safety perspective concerning the potential impact of their activities on

plant operation. This is evidenced by the absence o' plant transients or

equipment failures attributed to personnel error during maintenance.

Maintenance personnel generally exhibit pride and professionalism in the

l

conduct of their activities. Management involvement in and control of the

.

quality. of maintenance was evident by adequate planning and prioritization

.

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of maintenance activitiesLincluding ample QA/QC coverage for these

activities. .'Individua_l-responsibilities and authorities are well~ defined.

for control'of Jaaintenance' activities. . Maintenance. staffing is. adequate

'

to perform _the existing work load, with a very low turnover rate. :During-

the 1987 refueling o_utage, three maintenance supervisors, thirty-four craft

/pers'onnel, and' containment integrated. leak rate testing consultants were

,

added to support the maintenance activities'.

Generally, maintenance personnel conduct work: activities in a quality

manner, as noted during replacement of an emergency diesel generator

turbocharger,' calibration-of instrumentation, and during the generator

ground l troubleshooting. .However, several examples of. poor workmanship or

practices.were'noted.- These involved inadequate troubleshooting.which-

failed to recognize a low. control oil pressure and corrective maintenance

which damaged ~a valve operating cylinder of a High Pressure Coolant

' Injection system,. insufficient testing of_ reactor :ooca switch in all modes,

failure to tighten fasteners for a Limitorque valve operator switch-

component,:and continuing' maintenance problems for reactor feed pumps.

Although these are considered isolated occurrences, they indicate'a need

for more effective supervision. -In addition, although the licensee's

program implementation for control of measuring and test equipment is

generally, satisfactory, three instances of not recording test instrument

usage were-found. Although some improvement in procedural adherence was

observed,'centinued emphasis should be placed in this area.

Two examples

of_ inattention to procedures were noted during Standby Liquid Control pump

'

maintehance involving system tagout recommendations and inattention to the

' expiration date.of the procedure.

During this pericd, a refueling outage of 105 days and a planned outage for

plant maintenance of 14 days were conducted. This was the first refueling

outage under the recently established Planning and Contract Services

Department and Work Control Center.

Improvements were evident in the

_ planning, -scheduling, and control of activities under these newly-

-established programs. Work progressed smoothly and problems were

effectively communicated and resolved.

The_ licensee took prompt corrective

action following an overexposure incident on the refuel floor, and

conducted extensive analysis and review of a missing Control Rod Blade

-roller guide ball, and the failure of bolts in the High Pressure Coolant

Injection Turbine.

During the 1987 refueling outage, it was observed that the licensee made a

-concerted effort to produce quality welds by training welders in the use of

the automatic welding equipment.

However, review of other welding

activities indicated poor judgment or lack of technical support for not

properly evaluating the adequacy of the welding requirements involving

dissimilar metal joints.

This is indicative of a need for more supervisory

oversight in this area.

I-

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21

Improvements continue to be made in training of personnel.

Benefits from

implementation of'the four year apprentice training program are, in

general, evident in the conduct of work activities.

The licensee

effectively utilizes mock-ups of equipment in training personnel.

INP0

accreditation was received in December 1987 for the maintenance training

program. Management's commitment to improvements in performance is-

evidenced by the emphasis placed in the training of personnel.

In summary, the maintenance program is adequately staffed with well-trained

and experienced personnel.

Slow, steady progress is being made on a very

comprehensive maintenance program, although continued emphasis is required

to ensure timely completion. Management attention should be focused on

improving supervisory oversight to ensure proper workmanship and procedural

compliance.

2.

Conclusion

Rating:

2

3.

Board Recommendations

Licensee: Expedite upgrading the preventive maintenance program

including validation of vendor nanuals.

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22

D.

Surveillance (406 hours0.0047 days 0.113 hours 6.712963e-4 weeks 1.54483e-4 months , 12.9%)

1.

Analysis

During the previous assessment period, this functional area was rated as

Category 2.

A strength noted was the lack of personnel errors during

testing.

Improvements were noted in the procedures which fall under the

inservice testing (IST) program, including providing for a thorough review

of data by the operator and the addition of the acceptable values. However

review of data by plant performance personnel was, at times, excessively

slow.

Increased management attention was warranted in the area of program

administration, as evidenced by three missed surveillance tests.

During the current assessment period, inspections were conducted in the

areas of containment local leak rate testing (LLRT), containment integrated

leak rate testing (CILRT), and inservice testing of pumps and valves. The

resident inspectors reviewed routine surveillance activities regularly.

The licensee surveillance program is, in general, technically adequate and

sufficiently controlled. Each department is responsible for scheduling,

tracking, and performing their own surveillance testing. Approximately

5000 surveillance tests were completed during this assessment period.

The

scheduling and tracking of surveillance tests utilizes computerized

systems.

Procedures generally are clearly written and sufficiently

detailed for effective implementation.

One reactor scram and three Engineered Safety Feature (ESF) actuations

occurred while conducting surveillance testing during this assessment

period.

The cause of the scram was mainly due to personnel error in that

an instrument isolation valve was not tightly shut.

Following shutting of

the valve by the technician trainee, a very small amount of valve movement

(approximately 1/16th of a turn) was found by a supervisor, during initial

l

review of the scram. During followup investigation of the trip, this

occurrence was verified.

Contributing to this event is the fact that these

valves are original plant equipment and require a slightly larger amount of

torque to fully close, due to years of operation.

Two of the three ESF

actuations were reactor core isolation cooling system isolations; both

involved personnel error.

The third ESF actuation involved a core spray

system and emergency diesel generator start during integrated leak rate

testing; this occurred due to a procedural inadequacy involving lifted

leads.

In addition, isolated cases were identified, by the NRC, where

surveillance test procedures were in error or confusing. These were

promptly corrected by the licensee.

In general, operators and technicians

readily identify and correct surveillance test inadequacies during

l

performance of testing activities.

I

Training of Instrument and Control (I&C) Technicians, who are involved in a

large portion of the surveillance testing, is considered to be a strength

as indicated by the small number of plant transients or equipment failures

l

caused by surveillance testing.

Improvements were made in this area

!

throughout the assessment period.

Implementation of the four year

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' apprentice,' training program has' improved the' technicians overall

pe rformance .' Except asinoted above, the I&C department on-the-job training

for'te_chnicians involved in surveillance' testing assures personnel are

adequately. trained prior to becoming responsible for. conducting testing,

Plant management';s'. increased attention'and emphasis on training indicate a

,

commitment-to improved! performance.

>

During the previous assessment period, three surveillance tests were missed

.or late; two of which~were missed due to surveillance test scheduling

~

. inadequacies.

Following these missed surveillances,'the licensee took

prompt action to. strengthen their administrative controls through increased

audits and improved tracking programs.

In this period, two Technical

<

.

Specification surveillance test requirements were identified by the

licensee as being missed.

These surveillance test problems were of little

or no safety significance.

One involved the failure to calculate d ywell

leak rate during one four-hour period. This' occurred while the plant was.

..

shut down preparing for.a reactor startup.and instrumentation was operating

12 '

.to detect'any abnormal leak rate.

The second missed surveillance test was

a TS required. test of the standby gas treatment system during secondary

leak rate te'sts-(normally once per cycle). This requirement had been

overlooked and had never been scheduled at the plant because these tests

have also been performed on a six month interval as required. Although

'

these two examples of missed surveillance tests occurred,.overall

improvement in' the scheduling and tracking of required surveillance tests

was noted.

Administrative controls for LLRT were good. Positive aspects of this

control included individual acceptance criteria for valves, good record

keeping of LLRT results, and a good tracking system for valve maintenance.

Management involvoment and control of LLRT activities, and response to NRC

concerns and initiatives were satisfactory, which was reflected through the

licensee's effective performance.of the control rod drive removal hatch

seal test and LLRT.

However, it was observed that, although the QA

personnel had conducted LLRT'surveillances,-no evaluation of the LLRT

program was performed.

The licensee recognized the concern and instituted

an LLRT effectiveness audit.

In the area of CILRT, the licensee's technical staff demonstrated good

knowledge and competency in CILRT methodology and test performance.

The

licensee hired a CILRT consultant who collected test data, analyzed the

test results and provided technical assistance.

The progress of CILRT

preparation and execution were discussed daily by the licensee management

and technical staff.

However, administrative control of the test and its

related activities appeared weak in some areas. The test director did not

have complete control over test preparation or containment access prior to

the test.

The operations and I&C departments worked independently of the

test director and he was not apprised of the status of such preparations as

CILRT sensor installation and operability, and valve lineup.

In one

instance, the I&C department accessed the containment to check a dewcell

and upon exiting could not secure the equalization valves properly.

This

led to large leakage during pressurization.

This lack of adainistrative

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control was'alsoLevident'in another instance during the. initial containment-

' pressurization for the test'when incorrect leadswere lifted which actuated'

c

emergency diesel generators land the core spray system.-

.

7

1

During the previous period,.the review of. data by"plant? performance

personnel following. the t'est was,' at times, excessively slow.

Administrative controls have adequately addressed this concern, however,

continued' ineffective control and: implementation _.of the.IST program

indicate poor' management oversight of the program.

Lack of proper

~

allocation ofiresources,-including _ staffing, and' lack of attention to

details and review of.the test activities.were' identified.

Test

documentation and corrective action were also inadequate. . Two specific

concerns were' identified:'(1) failure to follow IST procedures,-and (2)

failure to verify and document -the acceptability of. the new High Pressure

Coolant' Injection pump reference data, per ASME Section XI.

These

..

instances-indicated inconsistency in data recording and general program

implementation,'which were attributable to the lack of formal-methodology

to generate and retain test data, and inattention to details by the

-cognizant-test reviewer. -Many of the IST-program implementation related

changesLwere made on-the-spot without appropriate safety committee review

and attention to details. This contributed to lack of reference to

differential pressure -in the test program, -lack of incorporation of ' Alert-

-and Required Action values in the test reports, and existence of various

transposition errors in the; test reports, including stroke times, valve

designation, and white-out of test data. These deficiencies indicate a

lack of management attention to the IST program.

In summary, the licensee continues to implement an adequate surveillance

^

program. Although improvements have been made in some areas, weaknesses

continue in program administration.

These are noted by inadequate staffing

in.the IST program area and deficiencies in the management involvement and

' administrative control of the IST and CILRT programs.

Personnel are well

qualified :and conscientious;-however, continued emphasis needs to be placed-

in. procedural control and adherence.

2.

Conclusion

Rating:

2

3.

Board Recommendation

Licensee:

Review IST program and evaluate reasons for continued

ineffectiveness in program administrations.

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45

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Engineering and Technical Support (323 hours0.00374 days 0.0897 hours 5.340608e-4 weeks 1.229015e-4 months , 10.3%)

'

'1.

Analysis

t

This area was notfevaluated as a. separate functional area in the previous

v

-assessment,'but was discussed under the functional area-of Outage.

.

Management and Engineering ~Suppor.t.. In the. previous period, this area was

..

rated-as_a~ Category 2.

Although the engineering support group generally

. performed well in. assuring technical. adequacy of modifications,. several

'

.

inadequacies noted-required-the need-for increased management attention.

DuringLthis assessment period, this functional-area addresses the adequacy

of' technical and engineering support for all plant activities, including

design of plant modifications and engineering support for operations,

outages, maintenance, and surveillance.

The angineering; support evaluation for this period is based on four

o -

inspections which covered the licensee's Equipment Qualification (EQ)

-

progra..i. implementation, evaluation of the pipe supports per NRC Bulletin 79-14, plant de' sign changes and modification activities, and drawing

control activities. .In addition, the resident inspector reviewed this area-

throughout the assessment period.

,

The plant technical services department is responsible for reviewing and

designing modifications,; resolving plant engineering problems,

administering the-EQ program, and supplying engineering support as needed.

The major modifications installed in the plant for most of this period were

originated and controlled from the utility's corporate office in White

Plains, New York. .In addition, an Operations and Maintenance Support group

located in the corporate office assists in providing engineering support to

the fa ility.

During this assessment period, the performance in this area was

inconsistent.

The-technical services department continues to be staffed

with dedicated, knowledgeable, and industrious personnel. This department

is actively involved in significant improvement programs, wSich include the

(Master Equipment List, procurement programs, motor operated valve

performance enhancement, and development and implementation of new design

change control program procedures from a corporate level.

The engineering

support organization demonstrates the ability to adequately control major

modifications, complete minor plant modifications, and provide support on

.an as-needed basis.

Examples of timely and effective completion of

modifications include: installation of the new plant computer system and

piping removal and replacement.

In addition, numerous modifications in the

radioactive waste systems and main control room (recorders and

. instrumentation) were effectively implemented.

In support of plant

problems, noteworthy performance was demonstrated in review of operation

with 3 of 4 steam. lines, analysis of a reactor water cleanup system cracked

weld, and follow up and analysis of plant trips and transients.

45?

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'However, ins'tances:where the licensee's: design and engineering were not

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, properly reviewed a'nd-coordinated and. analyses which lacked depth or proper-

u

documentation were'also noted- , Numerous deficiencies were noted in the

.

g

modification-to. upgrade the automatic.depressurization. system pneumati.c

'

supply, tExamples where the flicensee's ' analysis or documentatjon lacked -

,

Jdetails' included determining' effects on the residual heat removal system

2

>

components.due to missing check valve internals, documenting the test

'

,

pressure of a hydrostatic test of the core . spray. system, and analysis of

p

.

m

pitting:on the. core spray system-piping.

-In addition, some 'l'ong-standing engineering problems have been slow to be

4

resolved.' In.particular, a problem with the recirculation pump speed ~

control circuit contributed to 2 scrams during this period.

This problem

has. existed since 1979; several fixes were attempted since that time,

_

howeser, they had been unsuccessful.

In September, 1986, an engineering

. review, which made.use of'information from other sites, identified a

'3 ,.

modification to correct-the problem. This modification was in2talled in

January-1988 and has corrected the speed control problem.

In Jan'uary'1988,.a, licensee reorganization took place to strengthen the

engineering organization.

Portions of the previous Engineering and Design

group were placed under the nuclear generation department.

This change was

made so-that all activities, including engineering, will fall under the

cognizance'of one-department and are intended to improve communications,

management,- and control of the activities at the_ nuclear facilities.

In

,

addition, a new field engineering group was added at_ the FitzPatrick site

'

which reports to the corporate office.

Their role is to assist in the

- engineering of major plant modificat' ions which originate from the corporate

' office. . This group is staffed with 4 engineers, who previously worked for

the plant's. technical services department and 4' contractor engineers; it

provides the interface'and work area for engineers from the corporate

office during their site visits.

Their main function is to review and

assist in major modifications and provide an interface with the plant,

assuring the modifications accurately reflect the as-built plant and input

any operating experience.

This group!s efforts has allowed the technical

services engineers to focus their efforts in supporting minor modifications

and day-to-day support of plant activities.

.The EQ inspection identified a lack of active site management involvement

to address and resolve EQ issues.

In addition, limited staffing and

expertise were available to properly review, evaluate and comply with the

EQ requirements in a timely fashion. The technical service department,

.which has the responsibility for the EQ program, astigned three

individuals, including the department supervisor, to establish and

implement the EQ program and maintain station equipment qualification

within the guidelines of 10 CFR 50.49.

Several concerns were identified.

The licensee could not establish qualification of several EQ related

.

components prior to the November 30, 1985 deadline, and did not provide an

caerability statement (justification for continued operation).

The

licensee relied heavily on consultants to respond to the NRC concerns; EQ

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27

,

n.

-

files;chnsisted.~of the consultant's review of specific EQ components.

This

_

-resulted inJa lack of self-sufficiency'and an~ inability to resolve the

plant-specific EQ concerns on their own.

'

E

'

In the area of drawing control, improvements have been noted in reducing

.the backlog .of drawings, awaiting update,to final as-built conditions.

However,. examples of drawings not y'et updated where the modifications had

'been completed over.two years ago still exist. Additionally,, minor

discrepancies-are continuing to be identified in the. control of drawings.

'

.Although. improvements have been made and discrepancies found are-of minor

significance, continued attentionLis warranted in-the control of drawings.

In. summary, station engineering support has been adequate.

Deficiencies

have been noted in the quality of modification packages; however, the

e

corporate management has takaa measures to improve:the communication and

control of engineering fro.i the' corporate level .

From the site engineering

group,-performance has been inconsistent; this appears to be due to heavy,

workload of on-site. engineers. . Efforts 1should be continued to improve the

. effectiveness of1the engineering support organization.

-

2.

. Conclusion

Rating:

2

3.

Board-Recommandations

Licensee: Eval 6 ate the adequacy and use of site staff in the

engineering support arsa to ensure a high level of

performance.

no

NRC:

Perform followup inspection of EQ-program open issues

including the licensee oversight of the program.

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Security ' and ~ Safeguards' (126 hours0.00146 days 0.035 hours 2.083333e-4 weeks 4.7943e-5 months , 4.0%)'

_

1.

Analysis-

c

During the, previous'SALP, the licensee's performance in this area was

' Category l'. . That rating was influenced by the licensee's responsiveness'to

NRC concerns,. initiatives to review the effectiveness-of the program,

1

?

acquisitions;of' state-of-the-art systems and equipment, and' continued

support for the program'from corporate and site management.-

c

During this assessment period, two routine. unannounced physical security

'in.pections were condu'cted.

Routine inspections by-the resident inspector

continued throughout the. period.

One violation was identified during the

period.

Corporate security. management continued to be actively involved in all site

security program-matters, including visits to the site by the corporate

staff.to provide assistance, program appraisals and direct support in the

budgeting and planning processes affecting program modifications, upgrades

- and program plan' changes.

Security management personnel are also actively

involved-in the Region I Nuclear Security Association and other industry

groups engaged in nuclear plant. security matters. This demonstrates

program support from upper level management.

- As in past SALP periods,'the licensee continues to utilize a self-appraisal

program which is independent of NRC's required annual security program

review. This licensee initiative. allows management to identify potential

problems early and take action to prevent their occurrence.

This program,

combined.with the licensee's annual program review, is a contributing

factor in the success of the program and reflects management's commitment

to a .high quality and effective program. ' The annual review of the security

program, performed by the licensee's quality assurance group, was made more

comprehensive in scope and depth than previous reviews at the licensee's

initiative; it placed more emphasis on the detailed requirements of the NRC

approved Security, Contingency, and Training and Qualifications Plans.

Corrective actions on deficiencies identified during the annual reviews

were prompt and effective with adequate follow-up to ensure their proper

,

implementation.

There were no security events that required reporting under 10 CFR 73.71

.during the assessment period. Review of the licensee's event reporting

procedures found them consistent with the NRC'; revised regulation (10 CFR

- 73.71) and implemented by personnel knowledgeable of the reporting

requirements.

As during the previous SALP periods, management and training of the

proprietary security force continued to be effective, as evidenced by a low

personnel error rate, low turnover rate, high morale and a professional

- attitude toward job performance by members of the security force.

Staffing

of the security management organization and the security force is adequate

as indicated by the limited use of overtime.

The security force training

.-

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a'nd requalification program is well developed.and effectively administered.

'

This is apparent from the excellent jobLknowledge' demonstrated by members!

..

of,the security: force during interviews:by NRC personnel.

In addition to

20

theiinitial and requalification training, a self-appraisal prog' ram measures

,the retention and ~ proficiency. of individuals with regards to generaliand;

,

46

specific:securi+vLprogram requirements between-qualification periods.

,

'

I

lThe licens~ee also conducted numerous' Safeguards Contingency-PlanLdrills

,

during. this~ assessment. period to exercise members of the security force in

emergency' procedures, however there was very little_ indication of

participation from.the operations organization'. :When'this was brought to

the. licensee's attention, plans were promptly made' to' conduct joint-drills -

'

for' contingency events.

During the period when a vital area door was found in an unlocked condition

by the NRC, immediate. compensatory measures were taken and the corrective-

' actions.were' prompt and extensive.

Even though, in the case cited, the

-

dete: tion aid was still operable,-the1 licensee took the initiative to

,

change'all'vitalEarea door locks to a type that will prevent recurrence of-

F

.the problem. - This is' further evidence of the licensee's desire to

11mplement and maintain an effective high quality security program.

,

There were four revisions to the licensee's security. program plans

submitted ~toLthe NRC under 10 CFR 50.54(p) during this assessment period.

The' plan changes were clear'and concise, with detailed ' explanations of the

< .

-reasons.for change._ This is indicative of knowledgeable' personnel and

adequate management oversight of submittals~to the NRC.

,

'In. summary,'the . licensee continues to manage and implement a security

program that is effective and goes_beyond regulatory requirements and

.

^

-

security plan commitments. Licensee initiatives, responsiveness to NRC

concerns, and support for the program were readily apparent during the

' assessment period and combined to provide evidence of a high quality

program.

'2.-Conclusion:

Rating:

1

3. Board Recommendation:

o

None

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Emergency Preparedness (212 hours0.00245 days 0.0589 hours 3.505291e-4 weeks 8.0666e-5 months , 6.8%)-

1.D Analysis

E

~

'

Ouring the previous assessment period, the' licensee was rated Category 1 in

this area,; based on information. gathered during observation of a partial

' parti.cipation exercise,. review of the. Emergency Preparedness (EP) training

program, and support of off-site emergency activities.

During this assessment period, the e were two unannounced, routine, safety

inspections and observations of the annual _ exercise. 'Ouring the.

. inspections,-it was noted that Emergency Response Facilities (ERFs) were

.

adequately maintained and Emergency Preparedness procedures, equipment,

.

f~

training and training records were current. About 85% of the 550 full

'

~

time, on site NYPA-personnel are qualified for one or more of the emergency

' response organization' positions.

Three or four full activation drills.are

conducted annually in addition to a number of partial activation drills.

During requalification' training, licensed operators are given eight

a

_ classroom hours of EP instruction, plus another eight hours on simulator.

The effectiven'ess of this training was demonstrated by the results of

twalk-throughs with licensed, senior < operators qualified as Emergency

Of rectors (ED). These' operators were well trained and capable of

'

' discharging ED responsibilities correctly.

-

Communications and computer systems were functional. The Safety Parameter

Display Systems (SPOS) was installed and used during the last exercise. A

-

/

new, dedicated Emergency Operations Facility (E0F) was' built, having an

a ea of about 2500 square feet, and is located beyond the ten mile

Emergency Planning Zone (EPZ).

NRC review of the findings of independent reviews / audits required by 10 CFR 50;54(t) disclosed that EP. personnel gave the auditors their exercise

observation ' assignments 'and tracked their findings, which is contrary to

.the requirement for independence of the auditor. Additionally, the

auditors reviewed off-site interfaces for adequacy but failed to notify the

County of results until this was called to their attention by the NRC.

~

'

During this assessment period, the' licensee reduced staffing support in the

EP area by one technical position. The site emergency planning coordinator

is supported by one professional and one administrative assistant. This

reduction'has the potential to negatively impact performance and

coordination in this area.

Observations of an unannounced, off-rormal hours, ful', participation,

-

exercise indicated that, although the licensee could implement the

emergency plan and implementing procedures adequately, performance was not

as strong as in previous exercises.

Observations indicated protective

action recommendations (PARS) were sometimes in error, or reviewed after

transmittal to the State and County.

This is attributed to a lack of

leadership within the Health Physics group at the Emergency Operations

! 5

.

31

Facility (E0F). Otherwise, there was good command and control as well as

communication within and among Emergency Response Facilities (ERFs).

ERF

activation was timely.

Emergency worker doses were well controlled.

In summary, while the licensee maintains commitments to Emergency

Preparedness resulting in an adequate program, weaknesses identified above

indicate a reduction in management attention to this area.

2.

Conclusion

Rating: 1

Trend:

Declining

3.

Board Recommendations:

Licensee: Improve administration of protective action recommendations

including dose assessment.

-__

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32

'

H".'

LICENSING

,

1.

Analysis'

In the previous SALP assessment, a Category 2 rating with a declining trend

~

,

-

swas given to;this functional area.

Communications and spirit of

~

cooperation with the NRC were noted.as the principal-areas where licensee

'

improvement was needed.

1

'

During the current assessment' period, a more active participation on the

part of corporate. management has been evident in the area of licensing.

Management has been cognizant of_the status and priorities of current.and

anticipated licensing actions, both licensee-initiated.and NRC-initiated,

'

and utilizes an expanded, automated commitment tracking system to assist in

their' oversight. JAdditionally, there has been increased communication

during this-period between the licensee and NRC at the corporate

Vice-President level concerning licensing activities.

In December 1986,_

-

the licensee completely revised its procedure concerning the preparation,

review, and control of submittals to the NRC. As a result, the licensing

< '

staff has _been given increased authority to assign . work to other

organizations and to better control its adequacy and timeliness. Also,

under a.recent management reorganization, the engineering and design

function ~ for FitzPatrick has been assigned to the Nuclear Generation

Department. As a result, resolution of problems occurring between the

1

s

licensing. staff and the engineering / design staff, which previously needed

to be handled interdepartmentally, is now simplified,

t

In the previous SALP evaluation, it was _ noted that corporate and station

.

. management had not directed sufficient attention toward correcting e'rrors

and upgrading some confusing sections of Technical Specifications (TS).

During.the current SALP period, no significant progress has been made in

this area. - Although a large number of TS errors were identified by the

licensee early in the rating period, an amendment request to eliminate

these errors has_not yet been submitted. A majority of the errors are

typographical in nature; however, there are several cases where TS' are

ambiguous, inconsistent, or have wording which does not clearly reflect

'their intent. Though none of the identified problems, per se, represents a

-

-direct or immediate_ safety concern, this situation may complicate the

day-to-day implementation of the TS by operating personnel.

During this

~

assessment period, examples of inadequate TS concerning minimum Emergency

-Core and Containment Cooling System availability while shut down,

conflicting TS in the case of spiral offload, and inattention to TS

,

surveillance requirements involving standby gas treatment system were also

'

' identified.

In addition, several longstanding inadequacies including the

TS table concerning containment isolation valves and containment integrated

leak rate test acceptance criteria continue to go uncorrected.

Although in the final few months of this rating period, the level of

activity devoted to rectifying this situation has increased, these problems

demonstrate a lack of sensitivity to the accuracy and clarity of TS from a

licensing standpoint.

However, the plant operating staff has been

attentive in implementing TS requirements.

,

.:.:, ,

-

, .-.

. - - , -

. . . . - - . .

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

.

33

A second area where additional management attention is needed is in

assuring consistency in the technical quality of licensing submittals

Evaluation of the licensee's approach to the resolution of the technical

issues, as related to licensing _ activities, is based on an assessment cf

the technical quality of various licensing documents submitted, as well as

on the licensee's priorities for scheduling these submittals.

During the

current rating period, variability in the technical quality.of licensing

submittals has been evident.

For the most part, the licensee has presented

clear and substantive descriptions and evaluations of the relevant issues,

thus minimizing the need for requests for additional information and

resubmittals.

Examples of high quality submittals include the reload TS

amendment request and the Intergranular Granular Stress Corrosion Cracking

(IGSCC) evaluations submitted in support of the 1987 refueling outage.

In certain instances, however, the licensee has not provided adequate

technical justification to suoport its position.

System / component

reliability data, based on pl&nt operating history, which would have

clarified the licensee's arguments, were not utilized.

Examples are the TS

regarding operability of the control room emergency filtration system, and

the responses concerning the recirculation pump trip aspect of the

anticipated transient without scram (ATWS) rule.

Additionally, there were

several cases where weak justification was provided far the licensee's no

significant hazards determinations. An example of this is the analysis

submitted as part of the amendment request regarding license conditions for

handling nuclear material. With respect to setting priorities for

resolving safety-significant issues, the licensee's performance has been

satisfactory overall .

Notwithstanding the need for increased attention to TS improvement and

assuring the technical quality of submittals, licensee management has

exhibited a greater involvement in managing and directing licensing

activities during this rating period than in the past.

In the past three SALP evaluations, it was noted that improved performance

was sought concerning the licensee's responsiveness to NRC initiatives.

During the current rating period, the licensing staff has exhibited notable

improvement in its cooperation with the NRC. As a result, there have been

fewer impediments to conducting day-to-day business.

The licensee has

shown a greater willingness to provide schedules for licensing submittals,

has kept the staff better informed on the progress of various activities,

and has responded to requests for information in a more timely manner.

1

Additionally, submittals required to support refueling outages or other

major activities have, in general, been timely and have been discussed with

the NRC in advance.

There have been isolated cases, however, where

submittals were significantly delayed.

A case in point is the additional

information required to support an amendment request regarding containment

purge / vent valves.

Staffing levels for the licensing group are adequate and have remained

,

l

constant (at nine persons) from the beginning of the rating period until

L

l

.

_

..

.

.. - - - - - - -

s

.

"

34

January 1988, when one engineering position became vacant following a

reorganization. The licensee plans to fill this position in the near

future.

Presently, the entire licensing staff is situated at headquarters.

Ccmmunications between the licensing staff and the plant appear strong,

with frequent project meetings held on site and a morning conference call

held daily.

During this rating period, adequate resources have been allocated to

training of the licer. sing group.

In addition to annual requalification

training, ALARA training, computer software training, and training in

writing and communications, certain members of the licensing staff received

more specialized technical training. This included a 3-day Probabilistic

Risk Assessment course, a one-week simulator course, and EQ training.

In

addition, during the last refueling outage, two licensing engineers were

sent to the site for a two-month period to assist in refueling operations.

In summary, during this rating period, licensee management has demonstrated

a more active involvement in-licensing activities and generally.

satisfactory performance in resolving technical issues.

In addition, the

licensing group is adequately staf fed and trained and has exhibited an

improved attitude of cooperation with the NRC. Additional management

attention, however, should be directed toward TS improvement and assuring

consistent hlgh quality submittals.

2.

Conclusion

Rating: 2

Trend:

Improving

3.

Board Recommendations

None

!

I

_ _ - _ _ _ _ _ _

-

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4

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..

35

.

'

.I h

Assurance of Quality

~ 1) Analysis

hssurance of Quality is a summary assessment of management oversight and

effectiveness in_ implementation of the-quality-assurance program and

administrative controls affecting quality. This functional. area Lis not an

assessment:of the quality assuranr- M artment alone, but is an overall

evaluation of the_ licensee's_ initiatives, programs, and policies which

'

~ ffect or assure quality.

It also~ assesses the attitude and performance of

a

plant staff personnel.

'

This functional area was rated as Category 2, improving, during the.

previous assessment period.

Strengths noted were the active role of the

Quality Assurance Department in assuring quality at the facility and the

aggressive attitude _ displayed by plant management in improving the quality

at the_' facility. ' Weaknesses noted were the slowness in implementing

- "

programs and corrective actions, and lapses in the requalification training

program, root.cause~ analysis, and procedural adherence.

,-

Various aspects of this area were routinely reviewed as part of the NRC

routira inspections.

In addition, an NRC team inspection assessed the

effecti.veness of the licensee's quality verification activities.

The

licensee has maintained a high emphasis on quality throughout all levels.of

J

~~

the organization.

This is exemplified by the plant management's continuing

efforts to improve communications throughout the site organization.

Efforts. include: meetings with all station personnel- to discuss plant and

industry problems and promote a_quali.ty conscious attitude; training

sessions for all station-personnel which have improved overall radiological

practices; implementing an employee feedback program; and conducting

routine meetings between supervisors and department staff. Although

additional attention needs to be focused in some areas (as noted in the

s

particular- furctional areas) and isolated problems occur, an excellent

worker attitude and approach to performance of duties is evident by the

lack of personnel errors.

Corporate and plant management continue to strive for excellence and foster

improvement in performance throughout the organization.

For example, more

n equent and better quality critiques of events are being performed with

more worker involvement in the critique. Approximately 30 individual plant

goals have been set with these goals extending over a 3 year period to

track long term improvement.

Individual tasks have been developed to help

achieve these goals. Many of these goals are tracked on a monthly basis

with some posted for all personnel to review.

The above actions are aimed

at making long lasting improvements through increasing the awareness and

pride of ownership through each individual.

Management has also demonstrated their commitment towards plant improvement

in other areas.

The completion of a new training complex, including plant

specific simulator, installation of a new plant computer, reduction of the

number of lit control room annunciators, implementation of Hydrogen Water

.

4

.

a

'

36

Chemistry program, significant efforts to detect and mitigate IGSCC,

equipment upgrade for local leak rate improvements, motor operated valve

performance enhancement programs, improvement in the procurement area, and

planned construction of a new warehouse and maintenance facilities are

examples of this commitment.

Reorganization of the corporate engineering

staff is indicative of management's active role in identifying and taking

action to correct weaknesses.

Progress, .although slow, has been noted on some of the licensee's long term

improvement programs.

In particular, the Master Equipment List has been

completed and training conducted on use of the computerized system, and the

vendor manual validation program has begun. Although these are

longstanding concerns, the licensee is following an extensive and detailed

planned maintenance program approach.

This approach includes developing

detailed procedures for establishing component classification, closely

monitoring of the vendor to assure the desired product is achieved, and

conducting extensive material history reviews and equipment reliability

studies to formulate a preventive maintenance schedules.

The licensee is

expending a large amount of effort to ensure the job is done right the

first time to assure a quality product with long term benefits.

Management involvement has also been demonstrated by increasing the effort

to get supervisors into the plant, providing oversight by assigning

management coverage of outage activities and plant startups, and

implementing lessons learned, throughout the organization, from an

overexposure incident.

The Plant Operations Review Committee (PORC) continues to take an active

role in reviewing plant events and safety evaluations.

Noteworthy

performance was identified during review of the personnel overexposure,

generator field ground problems, and the reactor water cleanup system

cracked weld.

Safety evaluations for plant modifications were found to

adequately address the basis for determining whether an unreviewed safety

question existed.

However, two examples were noted where a formal safety

evaluation was not written for changes made to the facility.

In these

examples the PORC had considered the safety impact of the changes made.

The site quality assurance (QA) organization has continued to play an

active role in assuring quality at the plant.

The QA department has

established open lines of communications with plant management and all

levels of the plant staff and interacts daily with these individuals.

During regional based inspections, management support to assure quality in

the area of inspection and examination was found to be satisfactory.

This

was evidenced by the addition of contracted QC personnel who more than

tripled the site QC staffs.

In addition to the regular QC inspection, the

licensee has introduced another level of OC overview, monitoring of

safety-related activities.

The QC overview was further enhanced by an

on going update of the QA audit program. A liberal use of technical

specialists is a noteworthy feature of this audit program.

l

-.

-

J ;

3

7;

a

37

j

t,

O

The licens'ee's warehouse controls and conditions are satisfactory.

The'

l

enveloping of other than. large items in a porous transparent wrap is an

example 1of the licensee's action to improve quality of' storage.

~

,_

'

Concurrently,.the procurement-has also improved as evidenced by'

strengthened. controls.

The requirements, as established in.the source

documents such as FSAR, the plant Technical Specifications, and industry

standards, are~. incorporated-in the procurement document.

-In the, area;of LLRT-and CILRT, QA/QC interfaces have been good. .A

Q

-provided extensive coverage of the test program, including preparation,

. initiation and. performance of the tests. The test personnel and QA

individuals were knowledgeable of test methodology and demonstrated

conscientious, efforts _to complete the test professionally. The QA

department communicated effectively with the cognizant test groups to

resolve QA findings, including general procedural compliance and tagging of

, the containment isolation vains.

The above are f riicative of an improvement in the licensee's QA/QC

interfaces in th areas'of audits, inspection, and testing.

.0verall, the' site.and co porate management is doing an effective job of

identifying and correc'.ing problems and programmatic weaknesses as

,

t

described above. As discussed in each of the appropriate functional areas,

attention is' warranted in improving performance.in the review of and

corrective actions for events, improvements of Technical Specifications,

and: surveillance program administration. _In t ;dition, efforts should

4

.

continue to be placed in resolving long stanu ng problems'and concerns,

such as NRC open -items, and the implementation of minor plant

modifications.

A professional' and conscienticus attitude is displayed by all members of

the plant staff.

Free and open communications are encouraged with outside

organizations, including the NRC.

The licensee takes a very self-critical

and conservative approach towards their activities and performance.

This

,

was demonstrated by testing of Safety Relief Valves, on their own

initiative, following problems identified at another facility and the

E.

prompt and extensive corrective actions following the overexposure

incident.

In stmmary, there exists a sensitivity to Assurance of Quality throughout

management and plant staff personnel of the FitzPatrick facility.

The

management has demonstrated a conservative approach to operation and

instituted numerous improvement programs.

Continued attention is warranted

in the areas of engineering support and Technical Specifications.

.-

..

.-

'.

.

38

2.

Conclusion

Rating: 2

Trend: l Improving

3.

Board Recommendations

None

,

.

c

.

,

.

'

39

V.

SU? PORTING DATA AND SUMMARIES

A. Investigations and Allegations Summary

During this assessment period, a total of three allegations were received

and reviewed by tha NRC. One was directed towards the Department of Labor

and unsubstantiated. Of the remaining two, one was unsubstantiated and the

other partially substantiated.

B.

Escalated Enforcement Actions

An Enforcement Conference was held on March 25, 1987, to discuss numerous

violations identified from the event on February 13, 1987, leading to the

occupational extremity radiation exposure of a co-tract worker in excess of

NRC quarterly limits. A Notice of Violation was issued on March 11, 1987,

detailing five instances of violations, citing an aggregate Severity Level

III and cumulative $75,000 civil penalty.

C.

Management Conferences

The management meeting for the previous SALP period was held on April 15,

1987, in the NRC Region I Office, King of Prussia, PA.

On January 29, 1988, a meeting was held at the NRC Region I Office, King of

Prussia, PA, at the licensee's request to discuss plant performance and

programs, future plans, and a recent reorganization of the corporate

engineering department.

..

.

-.

'

40

TABLE 1

INSPECTION HOURS SUMMARY

AREA-

HOURS

% OF TIME

Operations

1001

31.8%

Radcon/ Chemistry _

504

16.0%

Maintenance /0utages

571

18.2%

Surveillance

406

12.9%

Engineering

323

10.3%

Sec/ Safeguards

126

4.0%

Emergency Preparedness

212

6.8%

Licensing

Assurance of Quality

---

__

TOTALS:

3143

100%

Hours expended in the area of assurance of quality are included in

other functional areas, therefore, no direct inspection hours are

given for these areas. Operator licensing activities are not included

with direct inspection effort statistics.

Hours expended in facility licensing activities are net included in

direct inspection effort statistics.

,-

-

,

..

.g

-

~

41

TABJ.E 2

ENFORCEMENT SUMMARY

A. Violations Versus Functional Area By Severity Level

Functional

No. of Violations in Each Severity Level

Area

LI*

V

IV

III

II

I

Total

Plant Operations

1

2

3

Radiological Controls

2

1**

3

Maintenance and Outages

1

Surveillance

2

1

4

Emergency Preparedness

0

Security and Safeguards

1

Assurance of Quality

3

Licensing

0

Engineering and

1

3

4

Technical Support

TOTALS

3

r

10

1

0

19

LI - Licensee Identified Violations (10 CFR 2, Appendix C)

- 5 violations in aggregate were considered to be a severity level

III violation.

'

.

42

TABLE 3

LICENSEE EVENT REPORTS

Cause Determined by SALP Board

An assessment bas been conducted to determine the root cause of each evene from

the perspective of the NRC.

The causes fell into the following categories and

sub-categories.

Personnel Errors (PE)

1.

Lack of Knowledge (LK) - the individual was not properly trained or

provided with' instructions from supervision.

2.

Inattention to Detail (IC) - the individual failed to pay proper

attention to a task and was careless.

3.

Poor Judgement (PJ) - the individual failed to make the correct

assessment with the proper amount of training and attention to fac'.s.

Equipment Malfunction / Failure (EM/F)

1.

Random (R) - isolated component problem not of generic concern.

2.

Design Deficiency (DD)

poor design was the cause cf the

malfur.ction/ failure.

3.

Construction Deficiency (CD) - improper installation during

construction / modification caused or could have causec the malfunctirn

failure.

4.

Maintenance Deficiency (MD) - improper preventive or corrective

maintenance.

Procedural Error (PROE)

The procedure failed to provide adequate instruction, was coorly worded or

was not properly reviewed for use.

Ineffective Corrective Action (ICA)

Action was not taken by management or the action taken on a previously

identified item was not timely or did not correct the roct cause ard

allowed this occurrence.

__.

_

____ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _

.

.

..

' ' '

43

'

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

,

Cau:es As Determined By The Licensee

The licensee i's required to include cause codes in the reports.

These codes are

only required when equipment malfunction or failure is determined to be the

cause of the occurrence. -The following codes are used:

A - Personnel Error

8 - Design, Manufacturing, Construction or Installation

C - External Cause

0 - Defective Procedures

E - Component Failure

X - Other

.,

p.

- - -

__

,-

.

..-

...

.e

$

'

44

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

Summary of Cause Determined by SALP Board by Functional Areas

CAUSE

OPS

RAD

MAINT

SURV

ENG/TS

SEC

QA

TOTAL

P E/'_K

1

PE/ID

1

5

7

PE/PJ

0

EM/F/R

2

3

5

EM/F/DD

1

2

3

.EM/F/CD

1

EM/F/MD

4

PROE

2

1

4

ICA

1

2

3

TOTAL

4

1

10

7

4

2

28

Summary of Cause of Equipment Malfunctions / Failure Determined by. Licensee

Area

A

B

C

D

E

X

TOTAL

Assurance of Quality

1

Surveillance

1

Maintenance

2

1

5

8

Operations

2

TOTALS

1

2

0

1

0

8

12

. - _ _ _ _ _ _ _ -

.,

.

' .s

's'

TABLE 3 (Cont'd)

.

LICENSEE EVENT REPORTS

LER Number /

Cause Cetermined

Functional

Cause Code *

Event Date

Description

SALP Board

Area

86-19 **

11/12/86

Automatic

PE/ID - Technician

Surveillance

Actuation of

failed to check test

an Engineered equipment readiness

Safety

before commencement

Feature

of activities.

(Reactor

Core

Isolation

Cooling

Isolation).

86-20

12/21/86

TS Violation:

PE/ID - Radwaste

Operations

Unauthorized

operator did not

release of

ensure discharge

radioactive

permit requirements

liquid,

were met prior to

commencing

'

discharge.

86-21

12/23/86

High Pressure EF/DD - Battery

Engineering

Coolant

Motor Control

Support

Injection

Center was not

System

water tight

allowing intrusion

due to water

of water,

intrusion

into Battery

Motor Control

Center.

87-01

01/18/87

Excessive

EF/MD - Cause of

Maintenance

X

leakage of

failures was

Primary

attributed to wear,

Containment

licensee is

1 solation

developing program

Valves during to review failures

LLRT.

and maintenance

histories of the

failed components

to develop preventive

maintenance

recommendations.

,

-

--

-

'

,

j

..

.

.a

46

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

LER Number /

Cause Determined

Functional

Cause Code *

Event Date

Description

SALP Board

Area

87-02

02/13/87

TS Violation:

PE/ID - Deficiencies

Rad. Control

Extremity

included inadequate

overexposure,

radiological surveys,

training, poor

pre-job planning

failure to follow

procedure.

87-03

02/19/87

High Pressure EF/MD - Failure

Maintenance

B

Coolant

mechanism of the

Injection

bolts caused by

Turbine

high bolt hardness

throttle

and contributed by

valve bolts

pitting due to use

broken,

of copper antiseizure

compound.

87-04

02/04/87

Three of six

EM/0D - No apparent

Maintenance

X

Main Stem

reason for setpoint

Safety Relief drift other than

Valves

sticking of one of

setpoints

the pilot valve disc,

found out of

tolerance.

87-05

04/01/87

Main Steam

EM/MD - Stem packing

Maintenance

X

Line

leakage from main

Isolation.

steam differential

pressure isolation

valves allowed

instrument

depress _rization

creating a simulated

high steam flow

resulting in PCIS

actuation.

.- .

c.-

.'

.

,

' i '.

t

47

TABLE 3(Cont'd)

LICENSEE EVENT REPORTS

LER Number /-

Cause Determined

Functional

Cause Code *

Event Date

Description

SALP Board

Area

87-06

04/07/87

Core Spray

PROE - Procedure did

Surveillance

and Emergency not give adequate

Diesel

instructions to

Generator

ensure proper

Automatic

electrical leads

Actuation due were lifted.

to procedure

deficiency.

87-07

04/09/87

Reactor

EM/CD - During

Assurance of

A

Vessel Head

construction

Quality

vent piping

supports were not

inoperability installed as

due to

required by plant

missing pipe

drawings.

supports.

87-08

06/10/87

Low reactor

ICA - Reactor Scram

Engineering

vessel water

caused by operating

Support

level scram

with scoop tube

due to

positioners locked

Reactor Feed

up, losing the

Pump Trip,

ability to receive

while

an auto recirculation

operating

system runback on a

with scoop

loss of feed pump,

tube

positioners

locked up.

87-09

06/11/87

Emergency

EM/DD - During

Engineering

Diesel

transfer of loads

Support

Generator

voltage drop

start due to

sufficient to

temporary

activate

degraded

protective system

voltage

before operator

!

cot.di tion

action could correct

during bus

voltage.

transfer.

!

.o

.-

?4

C'

' '

48

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

LER Numbur/

Cause Determircd

Functional

Cause Code *

Event Date

Description

SALP Board

Area

87-10

07/23/87

High Pressure EF/R - Auxiliary

Maintenance

B

Coolant

oil pump bearing

Injection

failed resulting

in lower discharge

due to

pressure. Cause of

Auxiliary

failure was not

Oil Pump

determined.

low pressure.

87-11

07/28/87

Fire Barrier

PROE - Previous

Assurance

Electrical

procedures for

of

Penetration

inspection of fire

Quality

Seals not

barriers failed to

installed.

contain

unscheduled

penetrations.

87-12

08/28/87

Reactor Trips EF/R - Teflon

Maintenance

09/07/87

due to Main

insulation tubes had

Turbine trip

a cupric oxide layer

caused by

buildup which under

generator

certain electrica'

field ground.

conditions becomes

fully conductive.

87-13

09/05/87

Reactor Core

EF/R - The trip

Operations

X

Isolation

unit and transmitter

Cooling

were replaced.

Vendor

System

analysis could not

Isolations

determine a cause

due to

of the spurious trips.

spurious

Analog

Transmitter

Trip Unit

trip.

87-14

09/12/87

Emergency

ICA - Corrective

Operations

Diesel

actions taken to

Generator

prevent recurrence

start due to

of this event were

temporary

inadequate (see

degraded

LER 87-09).

voltage during

bus transfer.

. _ -

i

.-

,

c o

49

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

LER Number /'

Cause Determined

Functional

Cause Code *

Event Date

Description

SALP Board

Area

87-15

09/16/87

High Pressure EM/MD - Malfunctional Maintenance

X

Coolant

because of foreign

Injection

material deposits

on internal float

due to

mechanism,

unstable

suppression

chamber level

switch.

87-16

09/16/87

High Steam

PE/ID - Operator

Surveillance

flow

failed to follow

Isolation

prescribed sequence

of Reactor

of surveillance

Co ,*e

test procedure.

Isolation

Cooling

System due

to operator

error.

87-17

09/24/87

Reactor low

ICA - Reactor scram

Engineering

level scram

caused by operating

Support

following

with scoop tube

feed pump

positioners locked

trip on

up, losing the

high

ability to receive

vibration,

an auto recirculation

system runback on loss

of feedpump.

1

l

"

l

,

&=

'

50

i

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

LER Number /

Cause Determined

Functional

Cause Code *

Event Date

Description

SALP Board

Area

87-18

11/8/87

High Flux

EF/R - Recirculation

Operations

X

Reactor Trip

System Speed Controller

due to

malfunctioned;

reactor water suspected cause was an

recirculation age effect, controller

system pump

was replaced with a

sudden speed

spare unit.

increase.

87-19

12/7/87

TS Violation:

PE/IO - Responsible

Maintenance

Failure to

supervision did not

perform

ensure that the

Standby Gas

specified

Treatment

surveillance test

Surveillance

was performed as

Test as

required.

87-20

12/9/87

Reactor Trip

PE/LK - Technician

Surveillance

X

from low

failed to fully

water level

close an isolation

actuation

valve prior to

caused by

valving in test

personnel

equipment.

error

during

surveillance

test.

87-21

12/13/87

Reactor Water PROE - Bolt

Maintenance

Cleanup

torquing

Isolation

procedure

on High

was inadequate,

temperature

causing improper

due to

flange makeup,

inadequate

resulting in a

procedure,

steam leak which

resulted in system

isolation on high

room temperature.

a

-

e

51

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS

LER Number /

Cause Determined

Functional

Cause Code *

Event Date

Description

SALP Board

Area

87-22

12/20/87

TS Violation:

PE/ID - Operators

Surveillance

Failure to

failed to perform

perform

surveillance test

drywell

at required

leakage rate

frequency.

surveillance

at required

frecuency.

88-01

03/10/88

High Pressure PROE - Maintenance

Maintenance

D

Coolant

precedure did not

Injection

include evaluation

System

of relubrication of

of the valve stem

due to motor

and stem nut during

operated

maintenance causing

valve failure motor operated valve

as a result

failure due to

procedure

excessive current.

deficiency.

88-02

03/10/88

Reactor Core

PE/ID - I&C

Surveillance

Isolation

technician petforming

Cooling

the assigned task did

Automatic

not follow the

Isolation

prescribed procedure;

during

there was no copy of

Surveillance

the procedure

Testing as a

utilized, which led

result of

to the wrong trip

personnel not unit placed in test.

following

procedures.

I

,

_

_ _ _ _ _ _ ,

t

%

3,

52

TABLE 3 (Cont'd)

LICENSEE EVENT REPORTS