ML20151B380
| ML20151B380 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 07/11/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20151B378 | List: |
| References | |
| 50-341-88-01, 50-341-88-1, NUDOCS 8807200347 | |
| Download: ML20151B380 (44) | |
See also: IR 05000341/1988001
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SALP.9-
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SALP BOARD REPORT.
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-341/88001
Inspection Report No.
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Detroit Edison Company
Name of Licensee
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Fermi 2
Name of Fa:ility
April 1, 1987 through March 31, 1988
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Assessment Period
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8807200347 880711
ADOCK 05000341
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TABLE OF CONTENTS
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I.
INTRODUCTION. . . . . . . .
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II. CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . .
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III. SUMMARY OF RESULTS. . . . . . . . . . . . . . . . . . . . . .
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IV.
PERFORKANCE ANALYSIS. . . . . . . . . . . . . . . . . . . . .
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A.
Plant Operations . . . . . . . . . . . . . . . . . . . .
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B.
Radiological Controls. . . . . . . . . . . . . . . ... .
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C.
Maintenance. . . . . . . . . . . . . . . . . . . . . . .
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D.
Surveillance . . . . . . . . . . . . . . . . . . . . . .
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E,
fire Protection.
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F.
Emergency Preparedness . . . . . . . . . . . . . . . . .
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G.
Security . .
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H.
Outages. . . . .
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1.
Quality Programs and Administrative
Controls Affecting Quality .
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J.
Licensing Activities
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K.
Training and Qualification Effectiveness . . . . . . . .
28
L.
Startup Testing
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H.
Engineerins/ Technical Support
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V.
SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . .
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A.
Licensee Activities. .
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B.
Inspection Activities. . . . . . . . . . . . . .
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C.
Investigation and Allegations Review.
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D.
Escalated Enforcement Actions. . . . . . . . . . . . . .
38
E.
Licensee Conferences Held During Assessment Period .
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F.
Confirmatory Action Letters . . . .. . .
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G.
Review of Licensee Event Raports,
and 10 CFR Part 21 Repor.s
Submitted by the Licensee. .
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H.
Licen si ng Acti vi ties . . . . . . . . . . . . . . . . . .
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INTRODUCTIDN
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data
on a periodic basis and to evaluate licensee performance based upon this
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information.
The SALP program is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations.
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SALP 1s intended to be sufficiently diagnostic to provide a rational
basis for allocating NRC resources and to provide meaningful guidance
to the licensee's management to promote quality and safety of plant
construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on
June 14, 1988, to review the collection of performance observations and
data to assess licensee performance in accordance with the guidance in
NRC Manual Chapter 0516, "Systematic Assestment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in
Section II of this report.
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This report is the SALP Board's assessment of the licensee's safety
performance at Fermi 2 for the period April 1, 1987 through March 31,
1988.
SALP Board for Fermi 2 Station SALP 9 assessment:
NAME
TITLE
C. E. Norelius'
SALP Board Chairman, Direccor, Division
of Radiation Sefety and Safeguards
H. J. Miller *
Director, Division of Reactor Safety
E. G. Greenman*
Director, Division of Reactor Projects'
D. R. Muller *
Directo', , Project Directorate III-1,
T.
P..
Quay *
Project Hanager, NRR
R. C. Knop *
Chief, Projects Branch 3
W. G. Rogers'
Senior Resident Inspector
M. J. Virgilio
Acting Deputy Director, DRP
J. J. Stefano
Project Manager, NRR
L. Kelly
Project Manager, NRR
P. R. Pelke
Project Inspector
B. S. Mallett
Chief, Nuclear Materials and Safeguards
Brance
M. P. Phillips
Chief, Operational Programs Section
G. C. Wright
Chief, Opc ations Branch
R. L. Hague
Acting Chief, Technical Support Staf f
M. Scht.nacher
Chief, haaiological Effluents and
Chemistry Section
L. R. Greger
Chief, Facilities Radiation Protection
Section
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NAME-
TITLE
R. A.-Paul
Inspector, Facilities Radiation
Protection Section
G. L. Pirtle
Physical Security Inspector
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W. Snell
Chief, Emergency Preparedness Section
J. E. Focter
Inspector, Emergency Preparedness
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Section
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H. A. Walker
Reactor Inspector, Maintenance and
Outages Section
S. A. Reynolds-
Reactor Inspector, Maintenance and
Outages Section
J.-M. Ulie
Reactor Inspector, Plant Systems
Section
A. Dunlop
Reactor Engineer, Technical Support
Staff
' Voting Members
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II.
CRITERIA
The licensee performance is assessed in selected functional areas,
depending on whether the facility is in a construction, preoperational,
or operating phase.
Each functional area represents an area significant
to nuclear safety and the environment and corresponds to a normal
programmatic area.
Some functional areas may not be assessed because
of little or no licensee activities or lack of meaningful observations
in that area.
Special areas may be added to highlight significant
observations.
The following evaluation criteria were used in assessing each functional
area:
A.
Management involvement in ensuring quality.
B.
Approach to resolution of technical issues from a safety star.ipoint.
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C.
Responsiveness to NRC initiatives.
D.
Enforcement history.
E.
Operational and construction events (including response to, analysis
of, and corrective actions for).
F.
Staffing (including management).
However, the SALP Board is not limited to these criteria, and others may
have been used where appropriate.
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 management
attention and involvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and ef fectively used so that a high level of
performance with respect to operational safety and/or construction quality -
is being achieved.
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Category 2:
NRC attention should be maintained at normal levels.
Licensee
management 4ttention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably
effective so that satisfactory performance, with respect to operational
safety and/or construction quality, is being achieved.
Category 3:
Both NRC and licensee attention should be incrr r ^d.
Licensee
management attention er involvement is acceptable and cons
irs nuclear
safety, but weaknesse, are evident; licensee resources apt...
to be
strained or not effectively used, so that minimally satisfactory
performance, with respect to operational safety or construction, is being
achieved.
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Trend: The SALP Board may choose to include an assessment of the
performance trend of a functional area.
Normally, this performance trend
is only used where both a definite trend of performance is discernible to
the Board and the Board believes that continuation of the trend may result
in a change of performance level.
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The trend, if used, is defined as:
A.
Improving
Licensee performance was determined to be improving near the close
of the assessment period.
B.
Declining
Licensee performance was determined to be declining near the close
of the assessment period.
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III. SUMMARY OF RESULTS
Rating Last
Rating This
Functional Area
Period (SALP 8)
Period (SALP 9)
A.
Plant Operations
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B.
Radiological Controis
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2
C.
Maintenance
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3
D.
Surveillance
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3
E.
F're Protection
NR
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F.
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G.
Security-
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H.
Outages
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I.
Quality Programs and
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3
Administrative Controls
Affecting Quality
J.
Licensing Activities
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2
K.
Training and Qualification
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2
Effectiveness
L.
Startup Testing
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M.
Engineering / Technical Support
NR
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NR = Not Rated
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
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Evaluation of this functional area was based on the resvits of
routine resident, region-based, NRC Restart Team, and Operational
Safety Team (OSTI) inspections.
Enforcement history consisted of nine violations. One Severity
Level III, four Severity Level IV and four Severity Level V
violations were associated with the operations area. A civil
penalty of $75,000 was issued for the Severity Level III
violation concerning a shift complement's inability to maintain
cognizance of plant parameters. This resulted in an unplanned
mode change.
The other violations were not as significant.
However, when viewed collectively they indicate a negative
trend showing a lack of attention to detail and poor
understanding of Technical Specification actions by operations
personnel. Almost all the violations were program implementa-
tion errors.
Most of the errors occurred during the performance
of Technical Specification mandated actions and activities
associated with valve lineups. The enforcement history
indicated a decrease in licensee performance from the previous
assessment period.
Four issues remained outstanding at the end of the assessment
period.
The first two issues are potential escalated
enforcement matters that involved a lack of organizational
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understanding of a Technical Specification support system, and
the adequacy of corrective actions associated with a previous
escalated enforcement violation.
The third issue arose late
in the assessment period and involves the scope of the valves
in the locked valve program. The final issue also occurred
late in the a ssessment period and involves instrument valve
lineup controls. The one outstanding issue from the previous
assessment period related to 50.59 was resolved by the issuance
of a notice of violation.
The reactor was critical for 4633.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the assessment
period and the scram frequency was 1.29 scrams per 1000 critical
hours.
This is an improvement from the previous assessment
period.
Notwithstanding, nine unplanned shutdowns occurred;
six of which were reactor scrams. The majority of these
shutdowns occurred during the first half of the assessment
period, resulting in sporadic plant operations. Most of the
shutdowns were caused by design and personnel errors, and half
of the scrams were caused by rorsonnel errors. Approximately 23%
of the total LERs for this assessment period were associated
with this ;unctional area, with the majority of these involving
personnel errors.
The frequency of events increased during
plant outages.
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Three central areas were identified in the previous assessment
period as needing additional management attention.
The areas
were placing' equipment in service or out of service, taking the
appropriate actions mandated by the license for given equipment
conditions, and understanding the necessary Technical Specifica-
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tion support systems. To varying extents, all three of these
weaknesses were manifested again during this assessment period.
Management involvement to assure quality was ineffectiva in the
first half of the assessment period. Numerous instances of
personnel circumventing procedures and operator proficiency
deficiencies occurred.
Equipment was not placed or properly
maintained in service as evidenced by damage to the south
reactor feedpump turbine, steam binding of a heater feedwater
pump, and the High Pressure Coolant Injection (HPCI) test
return valve not being deenergized in the closed position
during system restoration activities.
Finally, an unplanned
mode change occurred through operator inattention.
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Short range improvement was noted following management changes
at the beginning of the second half of the assessment period.
Personnel circumventing procedures was significantly reduced
end an overall improvement in attention to detail was noted
due to management involvement.
However, an improper valve
lineup resulted in a draindown via RHR to the torus.
No major
equipment failures occurred while placing equipment in service
or out of service.
Extended plant operation was achieved for
the first time and permission was granted to ascend to 100% power.
However, similar problems to those in the previous assessment .
period appeared late in this assessment period.
Personnel did
not take the required Technical Specification actions as
reflected by HPCI not being placed in service at the correct
time during a plant startup and core spray header differential
pressure not being verified at the proper time interval. A
Technical Specification support system, Non-interruptible
Control Air Division I, became inoperable and a mix of
inadequate training and procedures did not alert operators
that a limiting condition of operation (LCO) was in effect.
Subsequently, the LCO was not met.
Licensee reviews have indicated a need for improvement in
the area of shift log keeping.
Reports to the NRC via the
Emergency Notification System (ENS) telephone were generally
appropriate and timely.
Shif t turnovers were consistently
thorough except for short term reliefs which we-e significantly
upgraded after the unplanned mode change.
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Technical resolution of issues from a safety standpoint varied.
Management exhibited a strong understanding of the issues but
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their response to those issues was not always adequate.
Long
term actions to improve operating procedures, procedural
compliance, and provide better insight and understanding of
Technical Specifications were slow in development and implemen-
tation. No actions were taken to ensure a more complete mix of
procedures / training of plant operators in the area of support
systems.
In contrast, corrective actions to the mode change
incident appeared thorough and timely.
Late in the assessment
period, management initiatives resulted in more thorough
evaluations of personnel errors to determine cause and
corrective action.
One of the most significant technical issues that arose during
the assessment period concerned deficiencies in the Technical
Specifications.
Present actions to review and assure proper
content of the Technical Specifications appear to be receiving
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appropriate management attention.
However, a final conclusion
can not be drawn until the Technical Specification Improvement
Program is concluded.
On-shift operations staffing was adequate with the licensee
continuing to staff six full shifts. All key positions were
filled. However, there was an identified weakness in the
experience level of the operations personnel with respect
to commercial Boiling Water Reactor (BWR) experience. This
weakness was counterbalanced somewhat by more experienced BWR
individuals being brought into senior operational management
positions.
Control room decorum and professionalism was
evident.
Shift personnel understanding of their duties and
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responsibilities was not always evident.
This was recognized
as a deficiency and operational standards were developed to
provide the necessary direction.
The development of the
operational standards is considered to be a positive licensee
initiative.
Li:ensee responsiveness to NRC initiatives was generally
adequate.
A letter midway through the assessment period from
the regional administrator requested the development of a
program to conduct training evolutions at power levels less
than 50's due to the minimal licensee performance observed by
the Operational Safety Team Inspection (OSTI).
The licensee
initiated a program that exceeded the NRC request. The operator
evolution evaluation program was established and provided a
baseline on which to judge operator performance.
Licensee
management worked closely with all operating shifts to develop
support for this program and to critique overall performance
on selected plant evolutions.
The program has been in effect
since November and will continue until at least completion of
the startup test program. Also, the operations engineer duty
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station was changed to be closer to the control room. Actions
taken dealing with operator rounds sheets and emergency
operator response to a loss of feedwater were other examples
of appropriate, timely action.
2.
Conclusion
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The licensee's performance is rated Category 3 in this area.
The licensee was rated Category 3 in the previous assessment
period.
3.
Board Recommendations
The SALP Board notes that while licensee performance has
generally improved during the assessment period, it appears
to be somewhat cyclical as highlighted by the standby liquid
control event which occurred subsequent to the assessment
period.
This indicates a need for improved team work,
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attention to detail, and procedural adherence.
B.
Radiological Controls
1.
Analysis
Evaluation of this functional area was based on the results of
six routine inspections performed during this assessment period
by regional inspectors and routine observations by resident
inspectors.
Enforcement history in this area was good; one Severity Level V
violation was identified during this period. Enforcement
history in the previous assessment period was similar with two
Severity Level V violations identified.
One LER was reported
in this area regarding personnel errors and inadequate
procedures which resulted in excess sodium pentaborate
concentrations in the Standby Liquid Control storage tank.
Staffing levels wa:e ample and qui.lifications appeared adequate
to implement the operational radiation protection and chemistry
programs. Operating radiation protection experience levels.are
understandably 109 due to plant newness.
Observation of
chemistry and radiation protection technicians and professional
staff performance during inspections indicated satisf actory
performance.
The radiological engineering staff continued to
provide assistance to the radiological control staff in identifi-
cation and resolution of technical issues. Only minimal staff
turnover was experienced; however, staff experience was weakened
by the losses of the Radiation Protection Manager (RPM) and the
chemistry supervisor.
NRC review determined that the licensee's
proposed replacement for the RPM did not meet the required
experience qualifications; subsequently, another staff health
physicist was appointed who met the qualifications.
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Management attention towards ensuring quality in this area was
evident and generally good.
Indications of corporate and
station management support for the radiological control program
included provisions for ample staff additions (contractors)
during the first major maintenance outage, acquisition of
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improved contamination monitoring equipment, and continued
support for the plant decontamination and tygon tubing removal
program.
In-line instrumentation appeared to be adequate for
monitoring the essential chemistry parameters, and improvements
were being considered; the laboratory was equipped with
state-of-the-art instrumentation. The licensee expended great
effort to improve reactor coolant water quality, which had been
degraded by demineralizer resin ingress.
These efforts greatly
reduced out-of-specification (005) time for conductivity, and
kept the cumulative 005 well within the limits allowed by the
technical specifications. While the licensee had not committed
to the BWR Owners Group Guidelines, the water chemistry control
program appears to be generally consistent with the guidelines
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as evidenced by licensee actions to reduce reactor power when
high sulfate levels were present during the last part of the
assessment period.
Licensee responsiveness to NRC initiatives was good. The hot
machine shop and tool crib contamination controls were upgraded,
including facility modifications.
The licensee continued to
improve the decontamination control program, the incident
report system, and egress controls. The chemistry group's
QA/QC program for the control of analytical measurements
appears to be adeqijate and has progressed satisfactorily
since the last assessment period. This program includes
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control charts of instrument performance checks,
interlaboratory comparisons, and technician testing programs.
However, improvement is needed to reduce the high biases
observed in interlaboratory comparisons of sodium, low level
The licensee's approach to resolution of technical _ issues has
generally been sound and timely with appropriate consideration
of radiological safety. The licensee is implementing a prograr,
for "hot particle" training, ioentification, and control, and
has strengthened the surveiliance/ calibration program for
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effluent monitoring. ALARA program initiatives were evident
during the two outages during this period.
Personnel
contaminations and cumulative doses (person-rems) were very
low during the assessment period due to a combination of good
licensee performance and limited operating history.
Radiological ef fluents were also very low, reflective of the
limi+.ed plant operating history. One minor transportation
problem was identified.
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Radiological confirmatory measurements showed weaknesses, with
only 76 agreements in 104 comparisons. The discrepancies
occurred mainly in the backup detectors and appeared to be
related to improper calibration, software problems, and lack
of intercomparison of the various detectors in the licensee's
interlaboratory comparison program. The results of the
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nonradiological confirmatory measurements program were generally
good, with only two disagreements with the NRC values in 27
comparisons.
However, some of the results had significant-
biases, and the analyst had difficulties in obtaining reliable
boron values.
These appeared to be due to deficiencies in the
use of performance check control charts, which are still under
development.
2.
Conclusion
The licensee's performance is rated Catepry 2 in this area.
The licensee was rated Category 2 in the previous assessment
period.
3.
Board Recommendations
None.
C.
Maintenance
1.
Analysis
Evaluation of this functional area was based on routine
inspections conducted by resident inspectors and two
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inspections conducted by region-based inspectors. Areas
examined included corrective and preventive maintenance.
Enforcement history consisted of four violations and a deviation
from Updated Final Safety Analysis Report (UFSAR) commitments.
The violations were categorized as three Severity Level IV and
one Severity Level V, which is an increase in violations from the
previous assessment period.
Two violations were programmatic
in nature and had potential safety implications. These
violations reflected a lack of implementation of a preventive
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maintenance program and numerous e u,tples where personnel
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failed to follow procedures.
The other violations were
isolated personnel errors of minimal safety significance.
The
destation was also programmatic and further emphasized the lack
of implementation of preventive maintenance in the area of
electrical circuit breakers and protective relays. Corrective
actions were initiated; however, the effectiveness of all these
actions has not yet been assessed.
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Management involvement and control in assuring quality in the
preventive maintenance area was lacking during the first part
of the assessment period. A preventive maintenance program
was established but there was insufficient management oversight
and direction in its implementation. inis resulted in a
significant percentage of preventive maintenance activities
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not being accomplished. Also a reactor shutdown was caused by
inadequate preventive maintenance scheduling for the reactor
recirculation M-G set brushes. Once identified as a problem
appropriate resources were applied resulting in considerable
improvement in this area by the end of the assessment period.
Management involvement in the corrective maintenance area was
mixed.
During the assessment period the material condition of
the facility improved primarily due to a maintenance outage
midway through the period which reduced the corrective
maintenance backlog from app-oximately 750 to 500. At the end
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of the assessment period, the licensee had a 6 to 7 week
backlog.
Nuisance annunciators continued to be reduced from
the previous assessment period.
However, one reactor scram was
caused by personnel not adbaring to procedures. Administrative
controls associated with lifted leads / jumpers were not always
adhered to.
There war little evidence of effective and efficient
pre planning of the Local Leak Rate Test (LLRT) outage from a
maintenance perspective.
For example, a number of electrical
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and mechanical maintenance procedures were poorly written and
often confused workers because of the numerous changes that
were required.
There was no evidence that the procedures were
validated prior to use. This contributed to the failure to
effectively accomplish maintenance activities.
No discernible
decrease in the number of lifted leads and jumpers was noted
during the assessment period.
This particular area was
identified in the previous assessment as needing additional
management attention. Although some improvement was noted in
the utilization of equipment history, management involvement
was lacking as evidenced by the lack of complete and accurate
equipment history information for deferrals of preventive
maintenance activities.
There was one major positive management decision during the
this time frame.
The work package closure process was changed
to mandate a maintenance staff and quality assurance review
prior to submittal to the shift supervisor.
This one action
has provided an incremental increase in assuring safety at
the facility. The backlog of work packages needing final
review after work completion, which had significantly increased
in size three fourths of the way through the assessment period,
should be virtually eliminated due to a change in the allocation
of resources for closing these packages.
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The licensee approach to resolution of technical issues in
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the area of preventive maintenance was weak. Technical
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justification for deferral or reschHuling of preventive
maintenance activities lacked thoroughness and depth, and
in some cases, was marginal if not unacceptable.
Effects
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on system operability, availability or reliability were
not evaluated by engineering; instead emphasis appeared to
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be on scheduling and availability of personnel.
The status and portrayal of backlogged preventive maintenance
activities was not clear and understandable making management
overview of preventive maintenance corrective actions
difficult.
Some improvement was noted in this area during the
end of tne assessment period; however, resolution of the
preventive maintenance issue is a continuing process, and
significant NRC management attention was required to affect
changes initially.
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Resolution of corrective maintenance issues was better. The
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licensee suspended all maintenance activities when an NRC
inspection identified that personnel were not following
procedures.
This stop work stayed in effect until all
personnel were briefed on the necessity to follow procedures.
Changes to the deficiency notice tag system were comprehensive
and positive. While the stop work order was commendable,
previous management involvement had not been effective in
instilling procedural adherence.
Responsiveness to NRC issues was considered ineffective during
the first part of the assessment period.
The preventive
maintenance issue was considered as an unresolved item
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during an inspection in 1985 but the same problems still existed
in mid-1987. At the end of the assessment period there was
considerable improvement in this area; however, in some cases,
action by the licensee was still slow.
For example, when
problems were noted in following maintenance procedures, work
was stopped and the problem addressed immediately; however,
response was slow to a question about possible overpressurization
of an emergency diesel engine water jacket.
All key positions were filled during the assessment period.
The one vacant position from the previous assessment period,
Instrumentation and Control (I&C) Supervisor, was filled three
fourths of the way through the assessment period.
2.
Conclusion
The licensee's performance was rated Category 3 with an improving
trend in this area.
The licensee was rated Category 2 in the
previous assessment period.
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3.
Board Recommendations,
The SALP Board notes that the Category 3 rating is not
reflective of a decline in performance from the previous
assessment period, but indicates that the increased NRC
inspection activity during this period identified significant
concerns which previously went undetected.
D.
Surveillance
1.
Analysis
Evaluation of this functional area was based on routine
inspections conducted by resident, NRC contract and
region-based inspectors and observations by the OSTI members.
Enforcement history consisted of eleven violations and a
portion of another violation. Only one of these violations
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was a Severity Level V and rest of the violations were Severity
Level IV.
Six of the violations reflected inadequate technical
procedure content of which three were programmatic in nature.
Two violations were programmatic deficiencies associated with
the control of surveillance activities. Three violations and
a portion of another were implementation breakdowns.
Five
violations were identified in the previous assessment period.
The previous assessment reflected the need for improvement
in management's involvement to assure quality. The same
occasional procedural quality inadequacies and proficiency
deficiencies were apparent in this assessment period.
Examples *
of inadequate procedure quality were improper Reactor Core
Isolation Cooling (RCIC) and HPCI logic circuitry overlap
testing, inaccurate sodium pentaborate concentration acceptance
testing criteria, improper switch verification for offsite
power sources, and incomplete testing of the remote shutdown
panel transfer logic.
Examples of proficiency deficiencies
were failure to perform shiftly instrument checks and failure
to document the periodic reactor coolant leakage.
Regarding the licensee's approach to resolution of technical,
issues, during the first part of the assessment period, the
licensee performed a line by line verification that each
Technical Specification surveillance requirement was
encompassed in a surveillance procedure, began rewriting all
the I&C surveillance procedures including the addition of loop
sketches, and revised the scheduling process for partially
completed surveillance procedures.
Retraining and consulting
was administered to reduce personnel errors.
All these actions were to address deficiencies from the
previous assessment period and were generally insufficient
to prevent reoccurrence. After completion of the Technical
14
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Specification line by line verification, similar deficiencies
in the surveillance program were identified reflecting
inadequate implementation of the Technical Specification
verification. The partial surveillance procedure scheduling
effort was not broad enough to prevent other scheduling errors.
Personnel errors did not appear to decrease even with the
-
corrective actions taken as reflected by the operational events
and the enforcement history.
Certain personnel errors had the
potential for safety significance involving ESF actuations and
reactor scrams.
Personnel errors often involved disregard of
procedural guidance, or occurred as a result of technicians
following deficient procedures.
The one positive area was
the I&C rewrite effort which appeared to be coordinated and
comprehensive.
Potential escalated enforcement was identified
regarding the inadequate corrective actions to the surveillance
problems.
In the second half of the assessment period the licensee
-
established the Technical Specification Improvement Program.
This program is comprehensive and adequate for the problems
identified in this area.
In conclusion, the licensee's
approach to resolution of technical issues was lacking in the
first part of the assessment period and showed improvement in
the second half with additional emphasis still needed on the
personnel error aspect.
The licensee was generally responsive to NRC initiatives with
the establishment of the Technical Specification Improvement
Program in response to the October 9, 1987, letter from the
regional administrator on numerous problems includino the
-
surveillance area. This program has all the necessary elements
to significantly upgrade the quality of this functional area.
Subsequent to the assessment period, the licensee enhanced the
program to include surveillances of essential support systems.
Completion of the Technical Specification verification and
the I&C procedure rewrite effort were not consistent with the
time frame committed to by the licensee. Additionally, the
schedular commitments made by the licensee regarding the
Technical Specification Improvement Program reflect
shortsightedness by licensee management and a lack of
understanding of the complexity and scope of tne effort.
This has necessitated a request by the licensee to extend
the completion date for the program by six months beyond
the originally scheduled completion date.
Staffing to support the surveillance effort was adequate
with no problems noted in the implementation of the in service
test pump and valve performance area which was a concern from
the last assessment period.
Previous assessment problems with
clearly defining duties and responsibilities appeared corrected
except in the scheduling and tracking areas which continued to
15
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exhibit occasional deficiencies.
Examples of this problem
were in improper test interval established for a Standby Gas
Treatment System fire protection test, an improper test
interval established for containment integrity valve position
verifications and not performing a Control Center HVAC chiller
-
pump performance test on schedule.
2.
Conclusion
The licensee's performance is rated Category 3 in this area.
The licensee was rated Category 3 in the previou' assessment
period.
3.
Board Recommendations
The SALP Board notes that senior licensee management involvement
is required to maintain adequate resources to keep the Technical
Specification Improvement Program on schedule.
.
E.
Fire protection
1.
Analysis
The licensee's performance in the functional area of fire
protection was evaluated based on the results of one fire
protection programmatic inspection (which included a review
of previous inspection findings, the fire protection
organization, administrative controls, fire protection system
inspection, maintenance and tes: programs, quality assurance,
technical specification review, deviation event report review,
and other fire protect'on requirements review) during this
assessment period.
Two violations regarding the fire protection area (one Severity
level IV and one Severity Level V) were identified during this
assessment period. One violation was for failure to conduct
quarterly firc
rigade classroom instruction meetings (the
licensee was conducting these meetings once every two
years).
The other violation was for f ailure to maintain
a critical diesel fire pump discnarge ,alve locked.
No
violations were identified in the prev 1cus assessment period.
Management involvement in assuring quality in the decision
making process was adequate as demon,trated by the prompt
resolution of inspector concerns as discussed below.
The licensee's approach to the reso'ation of technical issues
from a safety standpoint was technt, ally sound and thorough.
For example, the licensee took the initiative in a timely
ma n.;c t to re-emrhasize to control room operators the
16
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requirement to follow the "Plant Fires" procedure for
immediately activating (assembling) the fire brigade following
receipt of an unplanned fire alarm.
The licensee's responses to NRC initiatives were generally
i
completed in a timely mannt* and an effort was made during
.
this assessment period to reso be outstanding fire protection
issues.
Two minor issue; from 1984 regarding the installation
of gauges in the Reactor Building and a revision to an
emergency lighting surveillance procedure were not completed
as scheduled; however, both were planned to be completed withiri
30 days following startup from the local leak rate testing outage.
The licensee has submitted two event reports regarding fire
protection program deficiencies.
Both cf these event reports
l
were promptly reported although minor information was lacking
l
for one of the reports which required a revision.
'
The licensee's f,re protection program is staffed with a
qualified fire protection engineer and a qualified fire
protection specialist whose responsibilities are well defined
l
and include the engineering aspects as well as the day-to-day
'
implementation of the fire protection program.
The licensee's fire brigsde training and effectivenest. were
l
evaluated during the programmatic review. As previously
I
mentioned, a violation an( both event reports related to fire
l
brigade training inadequacies. H) wever, an unannounced fire
drill was witnessed that demo'strated that adequate fire
brigada response, mannint. and donning of the proper fire
,
protective clothing (including breathing apparatus) was
performed in a timely mainer.
Fire detection and suppression equipment was generally well
maintained with hose stations properly staged, fire
extinguishers routinely inspected, fire detectors in service
and fire doors closed.
In the area of control of combustibles,
NRC plant tours and licensee inspection records reviewed during
the assessment period generally showed adherence by the licensee
to the fire protection administrative procedures.
However,
small amounts of combustibles were observed in the Reactor
Building during the plant shutdown due to ot) going painting
activities. These were properly controlled.
General housekeeping was above average with only extraneous
items such as tools or portable equipment, occasionally found
in the Reactor Building.
~
17
_ _ _ _ _ _ _ _ _ _ - _ _ - ____- ______
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2.
Conclusion
The licensee's performance is rated Category 2 in this area.
The licensee was not rated in the previous assessment period.
3.
Board Recommendations
_
None.
F.
Emeroency Preparedness
1.
Analysis
Evaluation of this functional area was based on two routine
inspections and one annual exercise inspection conducted by
regional-based inspectors during this assessment period.
No violations were identified during this or the previous
assessment period.
Four exercise weaknesses and six open
items were identified during the August 1987 annual exercise
inspection, indicating that exercise performance needed
improvement.
De weaknesses related to information flow to
the Technical Stpport Center, an unacceptable demonstration of
Assembly and Accountability, unapproved changes to the Post
Accident Sampling System procedure, and an unacceptable medical
drill.
A manageme1t meeting with licensee personnel was held
in November 1987, to discuss the corrective actions intended
for the exercise weaknesses and other actions for ovt - all
program improvement. A subsequent inspection confirmed that
aggressive correction actions were being taken regarding
identified weaknesses, and other program improvements were
actively being pursued.
Management involvement in assuring quality in this area was
good.
Some initial weaknesses were evident as indicated
by the four exercise weaknesses which were identified in the
annual exercise inspection, but corrective actions were
promptly initiated for problem areas, and subsequent program
enhancements were made.
Overall, the program continues to
improve.
In all cases, the licensee had been responsive to NRC initiatives
and concerns by providing viable, sound and thorough responses
in a timely manner.
The licensee's approach to resolution of
technical issues from a safety standpoint has remained cons.stently
good.
There were no long-standing regulatory issues attributable
to the licensee.
Staffing at the management level was unchanged.
In addition,
staff training and qualification effectiveness was good as
demonstrated by the lack of violations or significant
issues during the assessment period, and performance during
routine inspection walkthroughs.
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Subsequent to the assessment period, a successful emergency
exercise was held, demonstrating the effectiveness of
corrective actions made during the assessment period.
2.
Conclusion
The licensee's performance is rated Category 1 in this area.
The licensee was rated Category 1 in the previous assessment
period.
3.
Board Recommendations
None.
G.
Security
1.
Analysis
Evaluation of this functional area was based on the results of
five inspections (three onsite, two in-office) conducted by
region-based physical security inspectors and inspections
conducted by the resident inspectors to routinely observe
security activities. One onsite inspection was conducted to
support plant startup evaluation, and the other two onsite
inspections were routine in nature.
The in-of fice inspections
pertained to a review of the licensee's investigation of
allegations, and support to the Senior Resident Inspector on
a security issue.
Enforcement history has significantly improved during this
-
assessment period.
Three violations (two Severity Level IV
and one Severity Level V) were identified compared to eleven
violations curing the previous assessment period.
Although,
',
two of the violations were identified by the licensee and did
not represent a major safety concern, an Enforcement Conference
conducted on April 13, 1988, emphasized the need for increased
evaluation and oversight of the personnel access control program,
to correct programmatic weaknesses.
Staffing for the security section has also improved.
Permanent
assignments for the five department heads within the section
have been made and department responsibilities have been
clearly defined.
Key supervisory assignments for security
shift operations have also been made.
The primtry staff is
'
one of the largest in the region, and sustained improved staff
'
functions have been noted in reference to responsiveness to NRC
concerns, timely review and submittal of security plan changes,
<
and response to allegations.
The security training department
has also upgraded facilities during this assessment period.
Management involvement in assuring quality has improved during
this assessment period.
Self-audits by the security compliance
department have improved; root cause analysis is performed for
audit findings and security events; the Performance Indicator
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d
Program continues to be upgraded; and followup action on
inspection and audit findings is well documented.
Equipment
available to the security section is well maintained. Senior
plant management personnel take aggressive corrective actions
for personnel who cause security violations and exit meetings
are routinely attended by senior managers, up to the Group
-
Vice President level.
Senior managers are aware of significant
security issues and trends.
Technical issues are resolved in a timely and technically
correct manner.
Security plan submittals are detailed in
nature and complete.
Effective communication pertaining to
security issues exist between the licensee and NRC Region III
staff.
The security department is very responsive to NRC concerns.
Twelve of 13 inspection findings noted during the Regulatory
Effectiveness Review (RER) inspection, conducted in June 1987,
have been closed by the NRC, and licensee actions for the
remaining issue are adequate.
Some of the findings were
corrected during the RER inspection period.
Licensee
investigations pertaining to allegations have been thorough,
well documented, and timely.
Inspection concerns receive the
same leve' of management attention and action as violations.
Security ~.anagement is responsive to noted observations even
if they do not involve enforcement issues.
Procedural guidance for Security Event Reports (SERs) is detailed
and generally conforms to the guidance in the appropriate
regulatory cuide.
Thirteen SERs have been reported during this
assessment period, compared to nine in the previous assessment
period.
SER criteria changed in October 1987 and the licensee
has established a conservative approach to security event
reporting.
Eight of the thirteen SERs were caused by personnel
error, three were equipment-related, and the remaining two SERs
were beyond the licensee's control (bomb threat and contraband
found during vehicle search). The total
.7 umber of reported SERs
is not considered excessive. Two of the SERs resulted in
violations being cited.
Some security computer-related problems identified in inspection
reports still need to be fully resolved.
personnel security
screening and procedural deficiencies were noted during an
inspection conducted in March 1985 and require further action
action to resolve.
In summary, the improved trend in security performance can be
attributed to greater operational experience, an aggressive
self-audit program, effective root cause analysis for identified
problems, and a more stabilized management cadre within the
section.
20
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2.
Conclusion
The licensee's performance is rated Category 1 in this area.
The licensee was rated Category 2 in the previous assessment
period.
,
3.
Board Recommendations
None.
H.
Outaces
1.
Analysis
Evaluation of this functional area was based on routine
inspections conducted by resident inspectors. Areas examined
included steam line instrument tap repairs, Raychem heat
shrink inspections and repairs, block wall repairs, and
moisture separator reheater repairs.
Enforcement history in this area continued to represent
regulatory conformance.
No violations or deviations were
identified during this assessment period.
.
During the assessment period three outages in. excess of two
weeks occurred.
The first outage, early in the assessment
period, was to repair numerous steam line instrument taps that
were failing from vibration.
The second outage, midway through
the assessment period, was to improve overall material
condition of the plant.
However, problems were identified in a-
number of areas requiring modification / repair prior to plant
restart.
These areas included modification of the 72Cf swing
bus, examination and repair of heat shrink installations, repair
of emergency drain lines to the condenser, and installation of
additional bracing to select block walls.
The third outage,
in progress at the end of the assessment period, was to perform
local leak rate testing, eliminate backlogged preventative
maintenance activities, perform 18 month surveillances, and
complete select plant modifications.
Equipment damage was
identified af ter the shutdown involving major repair of the'
moisture separator reheater and a condensate pump.
No refueling
activities occurred during the assessment period.
Management involvement in assuring quality was generally
adequate.
All repair / modification activities were accomplished
satisfactorily.
Instructions for performing the modifications
were satisf actory for work performance. Documentation was
occasionally lacking.
Some modification work packages required
significant resources to assure the work was satisfactorily
accomplished after the equipment was in service. The 72CF
package was an example of this weakness.
Planning and
scheduling of testing was generally adequate as evidenced by
coordination for local leak rate tests.
In the last outage of
the assessment period, appropriate management planning was not
exhibited with regards to operating shif t work dynamics.
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Approach to resolution of technical issues from a safety
standpoint was evident.
Comprehensive actions were established
and implemented to resolve the Raychem splice, masonry block
wall, moisture separator reheater, and instrument tap problems.
Good corrective actions to work package documentation problems
_
were implemented with the establishment of quality "eviews
prior to submittal to the shift supervisor.
Eleven of the thirty five unplanned engineering safety features
(ESF) actuations occurred during outages.
Four of the ESF
actuations were personnel error related. This is an improvement
from the previous assessment period in terms of personnel
caused ESFs during outages. However, the licensee continues
to demonstrate a laxness in attention to detail that manifests
itself in an increase in events during plant outages. Continued
effort in this area is warranted.
2.
Conclusion
.
The licensee's performance is rated Category 2 in this area.
The licensee was-rated Category 2 in the previous assessment
period.
3.
Board Recommendations
None.
I,
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
,
The evaluation of this functional area addresses two related
but separate functions.
First, this assessment addresses the
licensee's internal independent oversight activities performed
by the quality control / quality assurance (0C/0A) organizations.
Secondly, this assessment addresses the effectiveness of
management's activities to achieve a high levei of performance
with respect to nuclear safety.
With respect to the evaluation of the licensee's internal and
independent quality oversight activities, results of routine
inspections conducted by resident, operational safety team
and region-based inspectors were considered. Areas examined
included quality verification methods, audit content,
documentation and frequency. Also cursory reviews of committee
activities and safety evaluations were performed by the
operational safety team.
Enforcement history consisted of one Severity level IV and one
Severity Level V violation.
Due to the inclusion of the new
Technical Support functional area a meaningful parallel between
the previous assessment period can not be drawn. The Severity
Level IV violation was for failure to verify compliance with
and determine the effectiveness of implementing the quality
22
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program, including failure to identify a significant condition
adverse to quality in an audited area. The Level V violation
included multiple examples of a failure to perform audits
within the periods specified by the Technical Specifications
and a procedural deficiency that allowed some of the noted
-
conditions to occur.
Corrective actions to all violations were
verified as acceptable.
One outstanding issue associated with
this area occurred late in the assessment period.
The matter
dealt with the onsite review committee approval of draf t
procedures. Due to this process, modifications were made to
some procedures changing their intent.
Regarding the licensee's internal and independent quality
oversight activities, management involvement and controls in
assuring quality appeared to be minimal during the first part of
the assessment period.
There was little evidence of management
reviews or efforts to ensure that audits were complete and
adequate, nor that noted problems were resolved in a timely
manner.
In some cases, audits appeared to be conducted merely
to fulfill audit requirements rather than to verify adequate
performance in functional areas.
In many cases, substantial
numbers of audit checklist items were not audited and no
evaluation was performed to determine the impact on the audited
area. With little or no justification, there were multiple
extensions granted to dates established for implementation of
corrective action.
Safety evaluations appeared weak and not
properly supportive of their conclusions.
During the second half of the assessment period, substantial
improvements were noted; for example, a new QA manager had been-
assigned and QA personnel were relocated inside the controlled
area, which provides improved access for verification of plant
activities. Management appeared to be concerned and actively
involved with the improvement of quality verification methods
and results.
Stricter controls were established on who could
review safety evaluations and additional training was given on
performing safety evaluations. One area where a weakness was
noted was QC inspectors.
The inspectors were not always aware
of procedural and acceptance criteria for maintenance activities
in progress; however, no problems were noted for inspection of
specific "hold" and "witness" points.
The approach to the resolution of technical issues was weak
during the first half of the assessment period. Audits were
concerned with compliance to procedures rather than with
technical aspects of the activities.
In several instances,
problems documented as observations, which required nt
corrective action, were actually valid audit findings.
23
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.
.
Considerable improvement was noted in this area during the
second half of the assessment period. However, in some cases,
conclusions were reached by the licensee in the evaluation of
audited conditions that did not appear to be substantiated by
the details included in the audit records. Methods of
_
preparing audit checklists had changed which appeared to make
the audits more performance-oriented. Additional management
reviews were evident, both before and after the audit.
Responsiveness to NRC initiatives was generally good.
Corrective actions to the problems in the audit area were
started imt.,ediately upon identification.
The proposed
resolutions were acceptable and accomplished in a timely
manner.
Staffing to perform required verification activities appeared
to be adequate.
Based upon a region-based inspection early in
,the assessment period there was a sufficient number of auditors
and certified lead auditors.
During an inspection late in the
assessment period, the licensee stated that 15 QC inspectors,
including some contract inspectors, were available to provide
QC coverage during the LLRT outage. This appeared to be
adequate based on a cursory review of the work to be performed.
With respect to the effectiveness of management's activities
to achieve a high level of performance, certain areas assessed
during this period, specifically emergency preparedners,
security and startup testing, the licensee achieved and
sustained a high level of performance with respect to nuclear
safety.
Management response was prompt and effective when
problems occurred or deficiencies were identified.
In certain other program areas such as plant operations,
maintenance, surveillance and engineering / technical support,
the licensee demonstrated minimally satisfactory performance
with respect to nuclear safety.
Management was ineffective in
its attempts to recognize and/or achieve sustained resolution
of deficiencies, many of which can be traced back through
several years of poor performance. At the onset of this
evaluation period, NRC and the licensee identified and
discussed weaknesses in each of these critical areas,
Operations and surveillance received a Category 3 rating
in SALP 8.
Maintenance and engineering / technical support
wet e the subject of NRC/ licensee management meetings following
inspections early in the assessment period, that identified
significant deficiencies.
From July 26, 1987 through August 7, 1987, NRC conducted a
special team inspection at Fermi, an Operational Safety Team
Inspection (OSTI).
The OSTI findings were discussed with the
licensee at the exit meeting. The team found no single root
cause.
Problems encompassed a broad range of activities
including operating practices, administrative controls,
24
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surveillances, training and the corrective action process.
In
general these findings supported previous assessments performed
by INPO, the Independent Overview Committee, NRC's restart team,
and the licensee.
A majority of these problems and deficiencies were evident
throughout the remainder of the assessment period.
Due to a
lack of attention to detail, personnel errors continued to
occur including the failure to comply with procedures.
Improvemente, in administrative controls, specifically the
Technical Specification Verification program and the I&C
procedure rewrite effort, suffered schedule slippages.
Deficiencies in the implementation of the surveillance program
continued throughout the assessment period. Design changes to
correct deficiencies that have caused repeated ESF actuations
during testing remain to be accomplished.
Closecut of LER
actions and assurance that actions taken in response to
Information Notices were not always perfo,med in a timely
.
manner. The deficiencies that resulted in the issuance of
$375,000 in civil penalties in July 1986 and a $100,000 civil
penalty in May 1987 were present throughout most of this
assessment period.
Early in the assessment period the licensee relied heavily on
improvement programs that were an outgrowth of lessons-learned
from events that occurred in 1985, at the time the full power
license was issued.
The Nuclear Operations Improvement Program,
Reactor Operations Improvement Prograv and Business Plans were
the licensee's road map to improved performanc.e.
However,
during this portion of the assessment period, while a general
improvement was noted, problems continued to occur intermittently
in areas specifically addressed by tnese programs which showed
demonstrated difficulty in achieving sustained improving
performance.
A number of changes occurred part way through the assessment
period that are beginning to have an everall positive impact
on performance.
Changes were made ir the plant manager, QA
manager and licensing supervisor positions to increase the
quality and experience leveis.
Additionally, the Vice
President of Engineering assumed an a:tive operational role,
and the I&C Supervisor position was filled.. Using new
techniques, the licensee performed m:re rigorous assessments
of events and identified problems to determine causes and
appropriate corrective actions.
The threshold to situations
requiring corrective action was lowe.ed and management
visibility of the probicm and corrective actions status has
been enhanced.
In addition, with regard to personnel performance
problems, accountability meetings anc disciplinary actions were
tools utilized to underscore management expectations.
In
parallel with these activities, in response to NRC initiatives,
25
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the licensee developed methods to better monitor performance of
operating crews, maintenance status, technical specification
improvement program progress and the status of implementation
of commitments to the NRC.
_
In summary, management has not been effective in its ability
to sustain improved performance above that considered minimally
acceptable to the NRC.
Extensive NRC oversight and involvement
was required to overcome licensee shortcomings and reactive
response to problems. Although less significant and frequent,
deficiencies were evident in personnel performance, administra-
tive controls and plant hardware at the end of the evaluation
period.
2.
Conclusion
The licensee's performance is rated Category 3 with an improving
trend in this area. The licensee was rated Category 2 in the
.
previous assessment period.
3.
Board Recommendations
The SALP Board recognizes a positive improving trend in
performance due in part to the new management team's efforts
and the acquisition of new management talent in key areas.
J.
Licensing Activities
1.
Analysis
Evaluation of this functional area was based on the licensee's'
performance in support of licensing actions. The items
evaluated were 10 Technical Specifications changes, two relief
requests, one exemption request and followup activities
associated with a Detailed Control Room Design Review / Safety
Parameter Display System (DCRDR/SPDS) audit from the last
,
'
assessment period.
The project managers and applicable NRR
technical reviewers performed the evaluation.
One Severity Level V violation was identified for failure to
l
submit a Technical Specification change request to reflect
l
changes in offsite and unit organizations.
No violations
!
were identified in the previous assessment period.
f
The licensee management's role in assuring quality in licensing
related activities continued to improve during the period.
Licensee submittal quality during the initial portion of the
period was less than desired until the hiring of a new licensing
supervisor.
This supervisor worked closely with NRR to promote
a better working relationship and improvements continued.
Recent submittals have been generally clear and of higher
quality.
Licensee submittals however, have generally been
26
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untimely, resulting in the need for the staff to expedite
several reviews. This is due in part to some lack of planning
by the licensee as well as some problems identified during
operation.
However, toward the end of the period, the licensee
has demonstrated a willingness to meet with NRR on short notice
to better coordinate the scheduling of licensing activities.
Many of the licensing activities during this period have been
related to startup issues and the Technical Specification
improvement program.
Because of this program, the volume
of Technical Specification change requests during this
period has been unusually high and is expected to remain high
until the end of the program which is scheduled for completion
in December 1988.
Management appears to be taking a more direct role in licensing
activities; however, there is still a need for improvement in
the planning and timeliness of licensing submittals.
,
The licensee's approach to resolution of technical issues has
shown some improvement in that the licensee has usually
demonstrated an understanding of the technical issues involved
in licensing activities and proposed acceptable resolutions.
During the period, significant progress was made on the DCRDR
and SPDS and the licensee's submittals on these subjects tre
currently under staff review.
The quality of licensee submittals has also improved during the
period as has the licensee's approach toward resolution of
technical issues. The licensee is demonstrating far greater ,
interest in resolving technical issues and has taken the initiative
in contacting NRC.
Licensee submittal quality can still be
improved.
The licensee's responsiveness to NRC initiatives improved
during the period.
In response to concerns identified by the
NRC, the licensee made submittals to correct deficiencies in the
SPDS and DCRDR that were identified during an audit at the very
end of the previous period.
Licensee efforts during this
period have these issues on the path tc,<ard resolution. During
the latter portion of the period, the licensee has responded
promptly and accurately to information requested by the staff.
The licensee has provided appropriate members of their
organization at meetings with the staff.
In addition, the
licensee has hired a new plant manager and licensing supervisor.
The licensing supervisor has extensive background and
experience in licensing. These individuals have improved the
licensee's performance in licensing activities. The licensing
staff is located in the Nuclear Operations Center (NOC). The
NOC is located on the Fermi-2 site a nd consequently, the
proximity of the licensing staff to the plant appears to be
a significant advantage.
27
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2.
Conclusions
'
The licensee's performance is rated Category 2 in this
area. The licensee was rated Category 2 during the previous
assessment period.
~
3.
Board Recommendations
None.
K.
Training and Qualification Effectiveness
1.
Analysis
Evaluation of this functional area was based on the results of
licensed operator examinations administered to six candidatos,
one special inspection to evaluate the adequacy of the
impleaientation of the licensed operator requalification program,
and observations by resident, Operational Safety Teans and
region-based inspectors while inspecting other functional areas.
Three apparent violations were identified during the assessment
period associated with the operator requalification program.
The severity level of these violations was under consideration
at the end of the assessment period. The licensee took
comprehensive corrective actions addressing each of the
potential violations.
Further, the licensee presented their
corrective actions and implementation schedule to the NRC in a
meeting held on June 9,1987.
NRC review determined that the
corrective actions were adequate; however, followup inspection
in the area was not conducted in that the violations have not
yet been issued and as such, a formal response from the
licensee has not been required. A violation related to
training is discussed in the Fire Protection functional area.
No violations were identified in the previous assessment period.
As discussed in the previous assessment period an inadequate level
of management attention to the operator requalification training-
aspect of this functional area was evident. Management
involvement in this area was subsequently increased and tighter
administrative controls were established.
The inadequacies in the operator requalification program
resulted in the issuance of a Confirmatory Action Letter (CAL).
The CAL required the licensee to perform a number of analyses
and reviews and submit the results to the NRC. By May 15,
1987, all the required information had been received. Based
on NRC acceptance of the licensee's response and actions taken,
the NRC resumed processing of license renewal applications
which had been held in abeyance pending completion of the CAL
items.
28
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.
Also, management efforts were focused on improving operator
instructor skills during the assessment period.
Personnel
exchanges ber. ween the operations department and the training
organization helped to increase the credibility and awareness
of the training organization. As evidenced by some of the
,
operator responses to plant cond'tions, additional refinements
in the site simulator were necessary. These changes were
accomplished. These actions are viewed as positive.
Stronger feedback mechanisms were established from management
to the shifts regarding their performance.
Efforts to assure
consistent performance from the operating shifts were not
totally successful.
Training initiatives to correct original
weaknesses in understanding the Technical Specifications were
slow in developing.
Operator licensing examinations were administered in December
1987.
Four of the six candidates passed their examination.
The sample size was too small to draw any meaningful
quantitative conclusion.
However, the success rate of the
operator licensing program showed no improvement.
The training and qualification effectiveness of other
organizations appeared adequate in most areas such as security,
radiation / chemistry, and emergency planning.
Mechanical
and electrical engineering personnel were trained to the
appropriate level of expertise with the exception of how to
provide proper justification for preventive maintenance
deferrals.
Key personnel received environmental qualification
([Q) training with the only exception being maintenance personnel.
The maintenance individuals responsible for EQ activities were
not formally trained regarding specific EQ requirements. Also
in the maintenance area, based on several procedural violations,
training of first line supervisors and craft personnel needed
improvement in the areas of quality consciousness and awareness
of administrative controls that affect safety and quality.
Training and qualification of auditors and lead auditors
appeared to be adequate.
INPO completed accreditation of all
the training programs in May, 1987.
2.
Conclusions
The licensee's performance is rated Category 2 in this area.
The licensee was rated Category 3 during the pre'ious
assessment period.
3.
Board Recommendations
None.
29
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L.
Startup Testing
1.
Analysis
Evaluation of this functional area was based on routine
inspections of Test Condition 3 and 5 test results conducted by
region-based inspectors and resident inspector observations of
Test Condition 3 and 5 testing.
Enforcement history in this area continued to indicate
regulatory conformance.
No violations or deviations were
identified during this assessment period.
Management involvement to assure quality in this functional
continued to be apparent. Testing evolutions were properly
controlled and scheduled to minimize impact on normal plant
activities.
Proper planning was always evident with extra
preparation taken on the more difficult and complex evolutions.
Reflective of this was the execution of HPCI testing at lower
than normal power levels without causing major operational
transients. A specific shift team was assigned to complete
shutdown from outside the control room testing.
This dedicated
shift team received additional training and familiarization
prior to test performance and is considered to be a positive
licensee initiative.
Proper procedural adherence was always
noted and good documentation of test deficiencies was always
performed.
As a result of these actions a significant design
deficiency in the HPCI system and degraded equipment
performance in the feedwater control system were identified.
The licensee's approach to resolution of technical issues
was appropriate as evidenced by reperformance of the major
HPCI startup tests following major modifications to that
system.
No reportable events were attributed to startup
testing personnel errors.
There were few NRC initiatives in
this functional area.
In those few instances management was
responsive and appropriately addressed the cencerns.
Staffing was adequate.
Personnel were experienced and
knowledgeable.
Authorities and responsibilities were well
defined even during the transition period when the Startup
Manager changed half way through the assessment period.
2.
Conclusion
The licensee's performance is rated Category 1 in this area.
The licensee was rated Category 1 in the previous assessment
period.
30
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1
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.
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3.
Board Recommendations
None.
M.
Engineering / Technical Suorort
.
1.
Analysis
This is a new functional area and consequently was not rated in
the previous assessment period.
Evaluation of this functional
area was based on the results of several inspections performed
by region based inspectors, resident inspectors, and one
Operational Safety Team inspectiv... Areas examined included
equipment environmental qualification, licensee actions in
response to certain NRC documents (IEB 85-03, Generic Letter 84-11, Unresolved Safety Issue A-7), licensee activities
with regard to selected mechanical, electrical and structural
deficiencies and enginaaring support to the maintenance / operations
.
departments.
Enforcement history during the assessment period was poor and
consisted of ten violations. One Severity Level III, six
Severity Level IV, and three Severity Level V, were identified
during the assessment period. The Severity Level III violation
highlighted inappropriate engineering decisions during final
construction / initial licensing.
These decisions resulted in
the Low Pressure Coolant Injection (LPCI) loop select bus being
vulnerable to a single failure.
The violation incurred a
civil penalty of $25,000.
Three of the violations reflected inadequate technical decisions
by engineering personnel during the assessment period that
affected equipment / structures performance capability. Three of
the violations reflected a failure to correctly translate the
design basis into drawings, one of which was safety signifi: ant
and resulted in modifications to some of the masonry block
walls.
One violation dealt with a breakdown in the spare parts
dedication process, and another involved failure of engineering
personnel to properly classify a minor electrical modifications.
The last violation dealt with isolated environmental qualification
documentation deficiencies and was of minimal safety significance.
Another issue similar to the LpCI swing bus and of the same
timeframe remained outstanding at the end of the assessment
period. This issue dealt with the containment isolation
,
portion of the primary containment monitoring piping
configuration net being in conformance with Ger.aral Design
Criteria 56.
The matter is under consideration for escalated
enforcement.
31
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Manag nent involvement in assuring quality by addressing
identi'ied engineering problems was mixed.
Proper involvement
was i.oted in resolving main steam line instrument tap failures,
vibration testing, resolving swing bus electrical circuit
deficiencies, and resolution to moisture separator reheater
damage.
Management involvement was lacking in issues dealing
_
with the Jamesbury butterfly valves, MSIV spring failures, use
of Furmanite, analysis of masonry block walls and concrete
expansion anchors, and engineering support provided to the
Maintenance Department.
It appears that several of the
problems encountered by the Maintenance Depar. ment could have
been prevented by accurate and effective support from the
Engineering Department.
Though some initiatives were made to
increase engineering presence in the freility, this was not the
norm.
The engineering effort applied to the issue of flow induced
vibration cracks of instrument lines on the main steam system
.
significantly improved the piping configuration with respect to
fatigue design.
This effort demonstrated excellent management
involvement and attention. Similarly, during startup vibration
testing, the er.gineering records were found to be generally
complete, well maintained, and available.
In contrast, the engineering effort with respect to analysis of
black walls and concrete expansion anchors resultec in three
violations with multiple examples.
Engineering records were in
some cases not complete and contained numerous errors. With
respect to the Jamesbury butterfly valves, repeated valve
failures occurred due to common causes because the design
weakness of the materials used was not well evaluated after the'
first failure.
In addition, gradual degradation in the valve's
performance was allowed to continue until valve failure without
taking any corrective action. With respect to the failure of
several MSIV springs, corrective action was taken, but was not
effective because the lessons learned on one component were
not extrapolated to similar components.
For example, the
licensee's investigation of the broken MSIV springs was limited
to inner springs until a broken outer spring was found.
The heat
treatment, which was eventually established as the cause of,the
problem, was performed for both sets of springs and for the
"proposed" replacement springs by the same vendor at about the
same time.
Site engineering had concluded that based on spring
compression tests of 105% the r placement springs could be used
despite corporate engineering'., analysis that a 105%
compression test was unacceptable.
The site had failed to
assume embrittled material when the fracture analysis was
conducted, even though testing had identified that the material
32
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was embNttled.
These inconsistencies in the quality of
engineering ~ performance appear to be function of the individual
assigned a specific tast rather than engineering discipline or
level of management review.
An NRR audit conducted at the end of the previous period
~
(March 1987) on the Detailed Control Room Design Review (DCRDR)
and the Safety Parameter 91 splay System (SPDS) identified
significant deficiencies Un management ovessight.
In particular,
one of the findings with respect to the DCRDR was that there
was an apparent lack of licensee mr.nagement support to perform
a meaningful and effective DCRDR. Meetings on these two items
were held during the current period in August and November
1987. As a result of these meetings, the licensee submitted
an updated summary DCRDR report and SpDS report.
This is
further evidence that the licensee's management is demonstrating
greater involvement. With respect to the DCRDR/SPDS and MSIV
spring issues, significant NRC management involvement was
,
required to achieve appropriate resolution.
The OSTI identified that overall technical support to operations
appeared to be weak.
Actions on operational improvement
documents were slow as evidenced in the establishment of
ambient room temperature criteria and electrical load lists.
Operations administrative support appeared strained.
Some
improvements were noted in the last part of the period as
evidenced by modifications to the emergency equipment cooling
water system in an effort to reduce unplanned ESF actuations.
However, this type of performance needed to be exhibited on a
broader, more consistent basis.
The licensee's approach to resolution to technical issues from
a safety standpoint was mixed.
In the area of environmental
qualification, the licensee demonstrated viable and generally
sound approaches in resolving techni;al issues.
In several
other cases, such as validation of feedwater suction piping
pressure qualification, replacement of unqualified check valve
soft seats and HPCI overpressurization, resolution of
engineering issues was generally sound, conservative, and
thorough.
- owever, poor resolution of technical issues from a safety
standpoint was identified in a number of areas:
the lack of
a program to address testing or long-term operability of MOVs
identified in Bulletin 85-03, the lack of depth and timely
correction of multiple failures of the Jamesbury butterfly.
valves, and MSIV spring failures.
In addition, the Engineering
Department in a number of instances did not provide effective
support of the preventive maintenance (PM) program. The most
significant case was the justification to defer or reschedule
137 PM activities on Class IE circuit breakers.
The engineering
justification lacked thoroughness, depth, technical completeness,
33
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and accuracy; and failed to evaluate the effects on system
operability, availability, or reliability.
Scheduling and
availability of personnel were the predominant reasons listed
for deferrals of PM items.
The licensee indicated that steps
would be taken to re-evaluate the justification to ensure
_
operability and reliability of the breakers; however, the
deferral of PMs without adequate justification appeared to be
a pervasive and chronic problem.
Responsiveness to NRC initiatives was mixed. Generally the
licensee provided sound, timely, acceptable responses.
The
licensee's analysis and documentation to support proposed
resolution to EQ issues was adequate.
In response to the NRC
identified deficiencies relative to the ECCS motor adapters
and termination box mountings, the licensee performed a
comprehensive review and identified additional deficiencies.
All deficiencies had been scheduled to be corrected in a timely
manner and the program has prevented further deficiencies in
,
this area.
Response to Bulletin 85-03, on the other hand, was poor in
that requirements of the bulletin were not implemented by the
requested completion date.
Similarly, initial responses to
two of tha violations were inadequate in that they failed to
adequately eddress the concerns identified by the original
violations. Acceptable responses were subsequently received
after the NRC provided a written description of how the original
responses were inadequate.
A number of operational events assoc 4 ted with this functional
area occurred during the assessment period.
Twelve of thirty-
five unplanned ESFs were due to either design or design control
deficiencies.
Approximately 25% of the LERs were due to the
Three of the nine unplanned reactor protection
same ceuse.
system actuations were the result of design / design control
p rot,l ems . A number of these events were due to original design
deficiencies.
Staffing was adequate.
Key positions were identified and
responsibilities were well-defined.
EQ personnel were
knowledgeable of technical and regulatory requirements. Only
one key position, Te:hnical Engineer, was not permanent 1'
filled.
2.
Conclusion
The 1 censee's per.s wance is rated Category 3 in this area.
This area was not rated in the previous assessment period.
34
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3.
Board Recommendations
-
The SALP Board notes that licensee ranagement attention is
required to further integrate the engineering function into
the support of plant operations, to provide consistency in
the resolution of technical issues within engineering, and to
~
encourage engineering to become more proactive in anticipating
plant problems.
.
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as
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V.
SUPPORTING DATA AND SUMMARIES
-
A.
Licensee Activities
During the SALP 9 assessment period, the licensee continued to
implement the startup testing program.
Significant outages and
~
major events which occurred during the period are summarized below:
1.
On April 11, 1987, the plant was shut down to re, air several
steam leaks.
2.
On May 13, 1987, the plant scrammed due to failure of the south
reactor feed pump.
3.
On May 21, 1987, the plant was shut down to repair a valve
packing which had been leaking in the reactor water cleanup
system.
4.
On June 25, 1987, the plant was manua'lly scrammed because of
excessive arcing from the "B" recirculation M-G set due to
excessive wear of the generator brushes.
5.
On June 26, 1987, an unplanned mode change occurred.
6.
On July 31, 1987, the reactor scrammed while shutting down to
repair feedwater check valve leakage. The plant entered an
extensive maintenance outage until October 10, 1987.
7.
On December 5, 1987, the plant was authorized to operate up to
75 percent power.
8.
On January 15, 1988, the plant was authorized to exceed 75
percent power, the final NRC restart effort holdpoint.
9.
On February 27, 1988, the olant entered a planned local leak
rate testing outage following a shutdown when all four diesel
generators were declared inoperable.
Fermi 2 experienced 35 ESF actuations, and 9 reactor scrams.
B.
Inspectisn Activities
Forty-six inspection reports were issued during April 1, 1987
through March 31, 1988, however, four of these inspection reports
(87006, 87008, 87012, and 87013) were addressed in the previous
SALP 8 report.
Forty-eight inspection reports are discussed in
this SALP report and are listed below, some of which have not yet
been issued to the licensee.
Significant inspection activities are
listed in Paragraph 2 (Special Inspection Summary) of this section.
36
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1.
Inspection Data
Facility Name: Fermi
Unit: 2
Docket No. 50-341
_
Inspection Reports Nos. 87000, 87001, 87007,
87014 through 87016, 87018 through 87050, 88002
through 88007, and 88009 through 88011.
Table I
Number of Violations in Each Severity level
Functional Areas
I
II
III
IV
V
A.
Plant Operations
1
4
4
B.
Radiological Controls
1
C.
Maintenance
3
1
'
D.
Surveillance
10
1
E.
Fire Protection
1
1
F.
G.
Security
2
1
H.
Outages
I.
Quality Programs
1
1
and Administrative
Controls Affecting
Quality
J.
Licensing Activities
1
K.
Training & Qualification
Effectiveness
L.
Startup Testing
'
M.
Engineering / Technical
1
6
3
Support
TOTALS
I
II
III
IV
V
2
27
14
2.
Special Inspection Summary
a.
During July 1-10, 1987, a special inspection was conducted
as a result of the unplanned mode change incident of
June 26, 1987 (Inspection Report No. 341/87027).
b.
During July 13-30, 1987, members of Region III's Quality
Assurance Program Section, and NRR conducted an inspection
of the licensee's QA program, this included a followup on
corrective actions taken in response to the NRR maintenance
survey.
37
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.
.
c.
During July 27-August 7,1987, an Operational Safety Team
.
Inspection was conducted which focus <d on the effectiveness
of management oversight of plant operational performance.
This was part of RIII's overall regulatory assessment to
determine the licensee's readiness to operate at power
levels greater than 50'4 (Inspection Report No. 341/870030).
_
d.
During August 27-20, 1987, the annual emergency preparedness
exercise was conducted (Inspection Report No. 341/87029).
C.
Investigation and Allegations Review
'
Sixteen allegations relating to Fermi 2 were received in Region III
during this assessment period.
Ten allegations were closed during
the assessment period.
Overall, seventeen allegations remained
open at the conclusion of the assessment period.
D.
Escalated Enforcement Actions
1.
A severity level III violation and proposed imposition of civil
penalty in the amount of 575,000 was issued to the licensee on
September 24, 1987. This action was based on the June 26, 1987,
Technical Specification violation, involving the uncontrolled
hea+.-up of the reactor which resulted in a change from Mode 4
te 'dode 3.
The escalated and mitigation factors in the
Enforcement Policy were consider and the civil penalty was
increased by 100'4 because of the licensee's past poor
performance in this area.
However, unusually prompt and
extensive corrective actions by the licensee, including
disciplinary actions of the individual (s) involved warranted a
50 percent reduction in the civil penalty (Enforcement Case
-
No. EA-87-133, Enforcement Notice No. EN-87-081, Preliminary
Information No. PN-III-87-091, Inspection Report No. 341/87027).
2.
A severity level III violation and proposed imposition of civil
penalty in the amount of $25,000 was issued on February 11,
1987.
This action was based on a design error discovered on
September 8,1987, in the circuitry of the swing electrical
bus, which would have resulted in the loss of both divisions
of low pressure coolant injection, during an accident condition.
The civil penalty was mitigated by 50 percent because of the
licensee's prompt and extensive corrective action (Enforcement
Case No. EA-87-232, Enforcement Notice No. EN-88-011,
Inspection Report No. 341/87049).
E.
Licensee Conferences Held During Assessmer.t period
1.
On May 11, 1987, a management meeting was conducted at the
site with RIII management, NRR, and licensee representatives
to discuss the status of the maintenance program including
preventative maintenance, staffing, material control,
training and planned corrective actions in response to the
NRR Maintenance Survey.
38
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2.
On June 4,1987, a management meeting was conducted at
Region III with licensee representatives to discuss actions
being taken by the licensee to ensure that all activities
required by the operator licensing requalification program are
implemented and to resolve the processing of pending reactor
operator renewal applications.
.
3.
On July 7, 1987, a management meeting was conducted at
Region III with licensee representatives to discuss the
licensee's investigation and corrective actions associated
with the unplanned mode change on June 26, 1987.
4.
On July 31, 1987, an Enforcement Conference was conducted in
the Region III office with licensee representatives to discuss
the inspection findings concerning the June 26, 1987, incident
in which an unplanned mode change occurred.
5.
On August 7, 1987, a management exit meeting was conducted at
the site with ifcensee representatives, at which time the NRC
Operational Safety Team Inspection (OSTI) findings were presented
to the licensee.
6.
On August 24, 1987, a management meeting was conducted at Monroe
County Community College to discuss SALP 8, the status of
ongoing licensee programt, addressing issues discussed in the
December 1985,10 CFR 50.54(f) letter, the Reactor Operations
Improvement Plan, and the Nuclear Operations Imr-ovement Plan.
7.
On October 5,1987, a management meeting was conducted at the
site to review outstanding issues which must be resolved prior
to exceeding 50'. power.
~
8.
On October 29, 1987, a management meeting was conducted at
Region III to discuss Fermi 2 plant status and plans.
9.
On November 2,1987, a management meeting was conducted at
Region III to discuss the Control Room Evolution Evaluation
Program.
10.
On November 16, 1987, a management meeting was conducted at
Region III to discuss corrective actions taken as a result of
deficiencies identified during the emergency preparedness
annual exercise.
11.
On November 18, 1987, a management meeting was conducted at
Region III to review the results of the Control Room Evolution
Evaluation Program.
12.
On December 22, 1987, an Enforcement Conference was held at
Region III to discuss the violation of 10 CFR 50.59 on two
separate occasions.
39
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13. On February 1,1988, a monthly meeting to discuss plant ' status,
schedules, improvement programs, and NRC commitments was held
at the site,
,
14.
On March 29. 1988, a monthly meeting to discuss plant status,
schedules., improvement programs, and NRC commitments was held
.
at Ren'.sn III.
15.
On April 13, 1988, an Enforcement Conference was conducted to
discuss access control programmatic weaknesses and a violation
pertaining to use of force by a security officer.
F.
Confirmatory Action Letters
1.
On April 3,1987, a Confirmatory Action Letter (CAL-RIII-87-003)
was issued to the licensee addressing corrective actions to be
taken regarding licensed operator requalification training
deficiencies.
G.
Review of Licensee Events Reports and 10 CFR Part 21 Reports
Submitted by the Licensee
1.
Licensee Event Reports (LER's)
Fermi 2
Docket No.: 50-341
LER Nos.: 87007, 87009, 87010 through 87056, and
88001 through 88008.
Fifty-seven LER's were issued during this assessment period.
-
A table of cause code comparisons it shown below:
(12 mo)
(12 mo)
CAUSE AREAS
SALP 8
SALP 9
Personnel Errors
40.7% (22) 28.1% (16)
Design Problems
12.9% ( 7) 24.5% (14)
Ft.ternal Causes
0% ( 0)
0% ( 0)
Procedure Inadecuacies
22.2% (12) 28.1% (16)
Component / Equipment
9.2t ( 5)
10.5% ( 6)
Other
9.2% ( 5)
3.5% ( 2)
Unknown
5.8% ( 3)
5.3% ( 3)
TOTALS
1004 (54)
1004 (57)
. REQUENCY (LERs/M3)
4.5
4.8
"
NOTE:
The above information was derived from review of LER's
performed by NRC Staff and may not completely coincide
with the licensee's cause assignments.
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p
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2.
10 CFR Part 21 Reports
a.
A Part 21 was reported by the licensee on June 30, 1987,
regarding premature failures of hydrogen and oxygen
sensors manufactured by Exosensor, Inc.
The sensors are
.
used in the post accident h/drogen/ oxygen analyzers.
b.
On December 3, 1987, the licensee notified the NRC of a
potential 10 CFR 21 regarding unqualified Kalrez soft
seats used in feedwater check valves supplied by Atwood
and Morrill.
H.
Licensing Activities
1.
NRR/ Licensee Meetings
August 1987
SPDS and DCRDR
Oetober 30, 1987
Compensatory measures in
support of GDC-56 exemption
request.
November 17, 1987
Progress on SPDS
February 17, 1988
To discuss interpretations
of certain Technical
Specifications.
2.
Commission Meetings - None
3.
Schedular Extensions Granted - None
-
4.
Reliefs Granted
September 28, 1987
Inservice Testing
October 6, 1987
ASME Code,Section XI
5.
Exemptions Granted
November 13, 1988
Exemption to GDC-56 for
Radiation Monitor
6.
Orders Issued - Not.<
7.
Emergency Technical Specifications '.ssued
October 9, 1987
TS table changes for leakage
testing
January 6,1988
Setpoints for reactor coolant
system interface
i
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O
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8.
License Amendments Issued
=
Amendment No.
Description
Date
8
Editorial correction to
July 17,1987
T.S.
-
9
APRM setpoint action
July 21,1987
statement and control
rod block information
20
Leakage test requirements
October 9, 1987
for containment isolation
valves
11
Administrative controls
October 22, 1987
12
December Ic, 1987
lube oil surveillance
program
13
Battery surveillance
January 11, 1988
requirements
14
Reactor coolant leakage
Janua ry 12, 1988
15
LPCI cross-tie valve
March 14, 1988
16
March 21, 1988
isolation valves
17
Addition of isolation
March 29, 1988
valves for the primary
containment radiation
monitor
42