ML20151E836

SALP Rept 50-298/88-01 for 860801-880131

ML20151E836
Person / Time
Site:	Cooper
Issue date:	04/11/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20151E783	List: ML20151E779 ML20151E836
References
50-298-88-01, 50-298-88-1, NUDOCS 8804150399
Download: ML20151E836 (42)

See also: IR 05000298/1988001

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SALP BOARD REPORT

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U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

NRC Inspection Report 50-298/88-01

Nebraska Public Power District

Cooper Nuclear Station

August 1, 1986, through January 31, 1988

8804150399 86:0411

PDR

ADOCK 05000298

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I.

INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated Nuclear Regulatory Commission (NRC) staff effort to collect

available observations and data on a periodic basis and to evaluate

licensee performance based upon this information.

SALP is supplemental to

normal regulatory processes used to ensure compliance with NRC rules and

regulations,

SALP is intended to be sufficiently diagnostic to provide a

rational basis for allocating NRC resources and to provide meaningful

guidance to the licensee's management to promote quality and safety of

plant operation.

An NRC SALP Board, composed of the staff members listed below, met on

March 9, 1988, to review the collection of performance observations and

data, and to assess licensee performance in accordance with the guidance

in NRC Manual Chapter 0516, "Systematic Assessment of Licensee

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

provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety

performance at Cooper Nuclear Station for the period August 1, 1986,

through January 31, 1988.

SALP Board for Cooper Nuclear Station:

L. J. Callan, Director, Division of Reactor Projects, RIV

J. P. Jaudon, Deputy Director, Division of Reactor Safety, RIV

R. E. iall, Deputy Director, Division of Radiation Safety and Safeguards,

RIV

W. O. Long, Project Manager, NRR

E. J. Holler, Chief, Reactor Projects Section C, RIV

W. R. Bennett, Senior Resident Inspector, RIV

Other personnel who participated in all or part of the SALP Board were:

W. C. Seidle, Chief, Test Programs Section, RIV

W. L. Fisher, Chief, Nuclear Materials and Emergency Preparedness Branch,

RIV

D. R. Hunter, Chief, Technical Support Staff, RIV

L. A. Yandell, Chief, Radiological Protection and Safeguards Branch, RIV

B. Murray, Chief, Facilities Radiological Protection Section, RIV

R. J. Everett, Chief, Physical Security Section, RIV

E. A. Plettner, Resident Inspector, RIV

A. B. Earnest, Security Inspector, RIV

G. L. Madsen, Project Engineer, RIV

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II.

CRITERIA

Licensee performance was assessed in 11 selected functional areas.

Functional aress normally represent areas significant to nuclear safety

and the environment.

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One or more of the following evaluation criteria were used to assess each

functional area:

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A.

Management involvement and control in assuring quality

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B.

Approach to the resolution of technir.al issues from a safety

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standpoint

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C.

Responsiveness to NRC initiatives

D.

Enforcement history

E.

Operational events (including response to, analysis of, and correc-

tive 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

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nuclear safety; licensee resources are ample and effectively used so that

a high level of performance with respect to operational safety is being

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achieved.

Category 2:

NRC attention should be maintained at normal levels.

Licensee management attention 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

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operational safety is being achieved.

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Category 3:

Both NRC and licensee attention should be increased.

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Dcensee management attention or involvement is acceptabla and considers

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nuclear safety, but weaknesses are evident; licensee resources appear to

be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety is being achieved.

III. SUMMARY OF RESULTS

The SALP board concluded that overall site operations were well managed.

Plant operations, radiological controls, fire protection, and licensing

activities were significant strengths.

Individual performance continues

to be the major contributing factor to these strengths, overcoming

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programs that are generally weaker than the observed performance.

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Performance in radiological controls warranted moving the evaluation from

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Category 2 to Category 1; however, the board noted some matters regarding

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radiological control training which still need attention.

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Some improvement has been noted in programs, especially in the area of

procedure rewrite.

As noted in the previous SALP, the loss of a few key

individuals could still result in a significant reversal of performance.

Emergency preparedness training and security continue to need management

attention.

Notwithstanding_the continued need for management attention,

the board did note a positive upward trend in the security area.

Emergency preparedness training deficiencies, however, have the potential

for causing declining performance in the future.

Improvement in commun'ications between the general office and the site also

needs mamgement attention as does engineering backlog.

The board also

concluded, based principally on the Safety System Functional

Inspection (SSFI) findings, that control of modifications needed

improva.nent.

This reduced perfonnance in engineering technical support

for outages caused the outage area to be evaluated at Category 2.

The licensee's performance is summarized in the table below, along with

the performance categories from the previous SALP evaluation period.

Previous

Present

Performance Category

Performance Category

Functional

(2/1/85 to 7/31/86

(8/1/86 to 1/31/88)

A.

Plant Operations

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Radiolog: cal 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

2

2

G.

Security

3

3*

H.

Outages

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2

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Quality Programs and

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Administrative Controls

Affecting Quality

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Licensing Activities

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K.

Training and Qualification

2

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Effectiveness

• Positive trend noted by SALP Board

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Forty-six NRC inspections were conducted during this SALP evaluation

period, involving a total of 5928 direct inspection man-hours of which

1320 hours0.0153 days <br />0.367 hours <br />0.00218 weeks <br />5.0226e-4 months <br /> were attributed to the SSFI led by NRC Headquarters.

The

objective of the SSFI was to assess the operational readiness of selected

safety systems.

IV.

PERFORMANCE ANALYSIS

A.

Plant Operations

1.

Analysis

The assessment of this area consists chiefly of the activities

of the licensee's operational staff (e.g., licensed operators,

shift technical advisors, and auxiliary operators).

It is

intended to be limited to operating activities such as:

plant

startup, power operation, plant shutdown, and system lineups.

Thus, it includes activities such as reading and logging plant

conditions, responding to off-normal conditions, manipulating

the reactor and auxiliary controls, plant-wide housekeeping, and

control room professionalism.

This area has been inspected on a continuing basis by the NRC

resident inspectors and on several occasions by NRC regional

inspectors.

Specific areas inspected included operational

safety verifications, safety system walkdowns, followup on

significant events / problems, and review of licensee event

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reports (LERs).

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Management involvement in assuring quality was evident in this

functional area.

Five violations were identified in this

functional area.

Licensee management demonstrated a clear

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understanding of issues raised by the violations and corrective

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action was effective as indicated by lack of repetition.

The

minor violations identified were not repetitive and were not

indicative of a programmatic breakdown.

Several LERs were

issued by the licensee in this functional area.

The majority of

events and violations were attributable to inadequate procedures

and personnel error.

The licensee has instituted a procedure

rewrite program to improve the procedures and to provide mare

complete guidance to the operators.

This program has

contributed to the reduction in procedure related events at the

end of the evaluation period.

In addition, the licensee has

continued a program to label all plant equipment and has

continued the human factors upgrade of panels in the control

room.

Both programs i. ave aided the performance of plant

operators.

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Operational staffing positions and responsibilities are well

defined.

Staffing has remained relatively constant in this

period, and management is aggressively supporting continued

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license upgrades.

Experience levels continue to increase, and

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operational support has been improved with the assignment of

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senior reactor operators (SR0s) to the operations support group

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which provided senior operating personnel, other than those on

shift, for resolving operational problems.

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The conduct of operations was observed ~ to be well coordinated

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and efficient.

Professionalism was evident in the control room

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during this evaluation period.

Restriction lines were installed

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in the control room which improved operator access to control

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room panels during plant evolutions.

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Management has aggressively pursued plant cleanliness.

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wide housekeeping has been observed to be consistently good and

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improving.

While management involvement in this functional area was strong,

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three specific areas are deemed to require continued aggressive

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management oversight. These areas are:

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Continued emphasis to updato piping and instrument

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diagrams (P&lDs) and other operator aids to ensure their

adequacy for use in assisting operating personnel.

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Continued emphasis to ensure that operating experience is

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adequately reflected in the procedure rewrite program.

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More startup evolutions during simulator training.

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2.

Conclusions

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The overall assessment of this area indicated a strong and

continually improving operations program at Cooper Nuclear

Station. The licensee's approach to the resolution of technical

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issues from a safety standpoint' demonstrated a clear

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understanding of issues, routine conservatism, and technically

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sound and timely resolutions.

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The licensee is considered to be in Performance Category 1 in

this functional area.

3.

Board Recommendations

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a.

Recommended NRC Actions

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The NRC inspection effort in this functional area can be

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limited to the minimum program.

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b.

Recommended Licensee Actions

The licensee should maintain strong management attention in

this area to ensure a continued high level of performance.

Management involvement should continue in areas which

could aid the operator (e.g., update of P& ids, procedure

rewrite program, and simulator training for plant

startups).

B.

Radiological Controls

1.

Analysis

Eight inspections involving radiological controls were conducted

during the assessment period by region-based radiation

specialist inspectors.

These eight inspections covered the

following functional areas:

occupational radiation safety,

radioactive waste management, radiological effluent control and

monitoring, transportation of radioactive materials, and water

chemistry.

The radiological controls area was also inspected on

a continuing basis by the resident inspectors.

No violations or

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deviations were identified.

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a.

Occupational Radiation Safety

The licensee's program for occupational radiation

protection, radioactive materials and contamination

controls, radiological surveys and monitoring, and ALARA

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programs was inspected four times during the assessment

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period.

Three inspections were conducted during normal

plant operations and one inspection was perforned during a

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scheduled refueling outage.

The licensee's exposure for 1986 was 330 person-rem

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compared to the national BWR average of 693 person-rem.

During 1987, the licensee's person-rem exposure was

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98 conpared to a BWR national average of about

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300 person-rem.

Much of the licensee success in

maintaining low person-rem exposure is the result of:

(1) a good fuel maintenance program to control the release

of fission products. (2) the pipe preconditioning program

implemented during '.he 1985 recirculation pipe replacement

outage, and (3) maintaining an excellent reactor water

chemistry program.

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The radiation protection program has demonstrated the

licensee's aggressive management and leadership

capabilities.

The radiation protection department has

established a good working relationship with other plant

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departments; this helps to implement an effective radiation

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protection program.

Plant management has also provided

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strong support to the Radiation Protection Department.

Eleven new positions were approved and filled in the

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Radiation Protection Department during the assessment

period.

The licensee has purchased and installed several

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state-of-the-art instruments to improve radiological'

monitoring capabilities.

During the assessment period, the

licensee implemented a comprehensive ALARA program.

A

stable program was evident in that the personnel turnover

rate among the radiation protection-staff-was less than

10 percent during the assessment period.

The licensee'has demonstrated the ability to manage and to

implement an effective program for' routine', day-to-day

radiation protection activities.

However, the following

concerns were identified-and should be considered as

program improvement items:

(1) the protection staff does

not include an individual with a strong academic background

in health physics to_ provide technical support for the

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evaluation of complicated radiation protection issues,

(2) a formal training program cn plant systems had not been

implemented for radiation protection personnel, (3) an

organized training program had not been established for

radiation protection supervisors and professionals, (4) a

formal testing and evaluation program had not been

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established for prospective contractor radiation protection

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technicians, (5) a procedure that specifies the specific

training and experience requirements had not been issued

for backshift radiation protection technicians, and

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(6) quality assurance (QA) audits in the radiological area

have not included a team member with technical expertise in

the areas being reviewed.

b.

Radioactive Waste Management

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The licensee's program involving the processing and onsite

storage of gaseous, liquid, and solid radioactive waste was

inspected once during the assessment period.

No

significant problems were identified concerning radioactive

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waste activities.

A well defined training program had not

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been developed for operations personnel responsible for

operating the gaseous, liquid, and solid radwaste systems.

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c.

Radiological Effluent Control and Monitoring

This area includes gaseous and liquid effluent controls and

monitoring, offsite dose calculations and dose limits,

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radiological environmental monitoring, radiochemistry

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program, and radiochemistry confirmatory measurement

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results.

The activity in these program areas were

inspected once during the assessment period.

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The licensee has established a well defined program

concerning the control and release of gaseous and liquid

effluents.

Liquid and gaseous effluent release permit

. procedures have been developed to assure that planned

releases receive _ proper review and approval prior to

release.

A review of gaseous and liquid releases indicate

that offsite doses were well below Technical Specification

limits.

A review of the radiological environmental monitoring

program identified the following concerns:

(1)-the sample

and analysis data in the radiological environmental reports

were not presented in a format which made it readily

obvious that the licensee was in compliance with Technical

Specification requirements, (2) training and qualification

records for personnel responsible for collecting

environmental samples had not been completed, and (3) the

meteorological monitoring equipment and environmental

thermoluminescent dosimeter programs had not been included

in the licensee's QA audit program.

The inspection of the radiochemistry area included

confirmatory measurements with the Region IV mobile

laboratory.

The radiological confirmatory measurement

results indicated 100 percent agreement between the NRC and

the licensee,

d.

Transportation of Radioactive Materials

This area was inspected once during the assessment period.

No particular proble:rs were identified concerning

processing, packaging, storage, and shipment of radioactive

materials.

The licensee has established detailed

procedures and an adequate quality assurance / quality

control program for low-level radioactive waste and spent

fuel shipments,

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Water Chemistry Controls

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This area was inspected once during the assessment period.

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The inspection involved the initial use of prepared water

chemistry standards for confirmatory measurement

evaluations.

The results of the water chemistry

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confirmatory measurements indicated 85 percent agreement

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between the licensee and the NRC's reference laboratory.

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These results are considered within expected industry

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performance levels.

The inspection also identified several

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concerns involving calibration standards, quality control

charts, and instrument calibrations.

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2.

Conclusions

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The licensee's overall performance indicated significant

improvement over the previous assessment period.

No violaticnt

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or deviations were identified during this assessment, as

compared to seven violations identified during the previous

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assessment period.

Improvements were noted regarding the

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implementation of a comprehensive ALARA program, additional

positions in the radiation protection department, low person-rem

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exposures, and purchase of new state-of-the-art health physics

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instrumentation.

Comprehensive training and the evaluation of training

effectiveness programs had not been fully implemented in the

radiation protection, water chemistry and radiochemistry,

radiological environmental monitoring, and radwaste areas.

Audit teams have not always included a team member with

technical expertise in the areas being audited.

The radiation

protection staff does not include a member with a strong

background in technical health physics.

No problems were identified concerning management support for

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radiological control activities, responsiveness to NRC

initiatives, or staffing.

The licensee is considered to be in Performance Category 1 in

this area.

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3.

Board Recommendations

a.

Recommended NRC Actions

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The NRC inspection effort should be reduced.

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b.

Recommended Licensee Actions

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Licensee management action is needed to ensure proper

training programs are implemented in this area.

Consideration should be given to hiring an individual with

a strong academic background in technical health physics.

C.

Maintenance

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Analysis

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The assessment of this area includes all licensee and contractor

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activities associated with preventive or corrective maintenance

of instrumentation and control, mechanical, and electrical

systems.

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This area was inspected on a continuing basis by the NRC

resident inspectors and periodically by NRC regional inspectors.

Specific areas inspected included preventive and corrective

maintenance activities in the mechanical, electrical, and

instrument and control disciplines; minor plant modifications;

program plans and procedures; corrective action reporting; and

work item tracking.

There were four violations identified in

this functional area during this assessment period.

The

enforcement history in this functional area indicated that the

two major causes of violations were:

maintenance personnel not

following procedural requirements and requirements not being

identified in the maintenance procedures.

This was most evident

in the areas of prerequisites and precautions.

The violations

identified indicated minor programmatic inadequacies.

Several

LERs were issued by the licensee in this area.

The LERs

indicated the need to preplan corrective maintenance activities

and develop written courses of action as necessary to direct the

process.

Management involvement in this functional area was evident by

aggressive identification, repair, and restoration of plant

equipment that required repair or routine preventive upkeep.

Maintenance personnel utilized appropriate plans and procedures

to correct known equipment deficiencies.

Quality checks and

postmaintenance testing were routinely performed prior to

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returning systems or components to an operable status.

Corrective actions including responses to NRC initiatives were

generally timely, comprehensive, and technically sound.

The two previous SALP reports identified weaknesses in the areas

of a training program for maintenance personnel, lack of

procedures for performing safety-related work activities and

equipment calibrations, procedure adherence, and control of

vendor documents and shop guides.

Improvements have ouurred

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during this assessment period in all the listed areas with the

exception of procedure adherence.

Requirements for previously

nonexistent procedures are being identified.

New pro:edures are

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being developed and approved for use in the performance of

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preventive and corrective maintenance activities.

During this

assessment period, the licensee developed and approved

procedures to address in detail postmaintenance testing

requirements.

The licensee has continued to categorize and

update safety-related equipment vendor manuals and applicable

procedures.

Completion has been delayed because of vendors' low

priority in producing the needed documents for the licensee.

Key positions in the maintenance area are identified and

responsibilities are defined.

Three new positions in

Maintenance Planning were created and filled during this period.

The staffing increase was needed to better control the backlog

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of Maintenance Work Request (HWR) items, which was previously

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identified as excessive.

2.

Conclusion

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Management involvement in the area of maintenance has continued

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to improve during the assessment period.

Majorimprovement

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projects are continuing in the areas of procedure development

and procedure updating.

Procedural adharence continues to be a

problem.

Formalized classroom training requirements were developed and

implemented in accordance with Institute of Nuclear Power

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Operations (INPO) accreditation standards for use during the

maintenance training scheduled for May 1988.

The number of

backlog RdRs has been decreasing in this assessment period.

The licensee is considered to be in Performance Categnry 2 in

this functional area.

3.

Board Recommendation

a.

Recommended NRC Actions

The NRC inspection effort in this functional area should be

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consistent with the routine inspection program with special

emphasis on the maintenance procedure development and

implementation effort,

b.

Recommended Licensee Action

Licensee management should continue a high level of

attention to this functional area to assure adequate

training of maintenance personnel and the completion of the

procedural development and rewrite project.

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D.

Surveillance

1.

Analysis

The assessment of this area includes all surveillance testing

activities as well as all inservice inspection and testing

activities.

Examples of activities included are:

instrument

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calibrations, equipment operability tes+.s, special tests,

inservice inspection and performance tests of pumps and valves,

and all other inservice inspection activities.

T51s area was inspected on a routine basis by the NRC resident

inspectors and periodically by NRC regional inspectors.

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The eaforcement history in this functional area identified three

violations during this assessment period; however, one violation

was for actions which occurred outside of the assessment period.

Several LERs were issued by the licensee in this area.

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Personnel errors were the predominant cause of the violations

and events in this assessment period, but inadequate procedures

were also an important contributor.

Managemont involvement in this functional area was evident.

Planning and scheduling were well coordinated, and all required

surveillances were performed on schedule.

However, this result

appeared to be because of efforts of personnel rather than

because of a well defined program.

The two previous SALP reports indicated unsatisfactory local

leak rate test results.

Excessive primary containment local

leakage was also discovered during this assessment period.

The

primary contributor to the leak rate in this reporting period

was due to the leakage of all feedwater check valves.

The

licensee appears to be making progress toward eliminating the

leakage problem; however, trending was not effectively utilized

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in predicting potential problem areas concerning the leak rate

test.

In addition, the SSFI identified that the trending

program for the service water inservice test data was

inadequate.

Instances were identified wherein service water

pumps were operating in the alert range without the increased

monitoring or corrective actions being accomplished as required.

2.

C_enclusions

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The overall assessment of this functional area indicates a

program for scheduling and tracking surveillance test

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requ;rements that works primarily because of the individuals

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responsible for implementing the program.

Records of

surveillances are generally complete and well maintained.

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Procedures and policies were adequately stated and were rarely

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violated.

Trending is not effectively used.

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The licensee is considered to be in Performance Category 2 in

this functional area.

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3.

Board Recommendations

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a.

Recommended NRC Actions

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The NRC inspection effort in this functional area should be

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consistent with the routine inspection program.

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b.

Recommended Licensee Actions

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The licensee is encouraged to improve the programmatic

aspects of surveillance scheduling and tracking whiie'

ensuring that the past strong performance is maintained.

Management involvement is encouraged to ensure that the

primary containment leak reduction program remains

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effective and that trending is effectively used to define

declining performance.

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Fire Protection

1.

Analysis

The assessment of this area includes routine housekeeping

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(combustibles, etc.) and fire protection / prevention program

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activities.

Thus, it includes the storage of combustible

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material, fire brigade staffing and training, fire suppression

system maintenance and operation, and those fire protection

features provided for structures, systems, and components

important to safe shutdown.

This area was inspected on a continuing basis by the NRC

resident inspectors and on two occasions by NRC regional

inspectors.

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No violations were identified in this functional area.

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were issued by the licensee in this functional area.

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Hanagement involvement in assuring quality was evident in this

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Policies were well stated and disseminated.

The procram

area.

forfirebrigadetraininganddrillswasfoundtobeeffective.r

Records were well maintained, complete, and available.

The

licensee commenced sending fire brigade members to the City'of

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Omaha fire fighting school during this assessment period,

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brigade equipment, including emergency breathing apparatus, was

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properly stored and maintained.

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The licensee completed the upgrading of fire protection systras

to meet Appendix R requirements during this assessment perioo.

Fire protection systems and equipment were functionally tested

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in accordance with applicable requirements.

Procedures and

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policies were strictly followed.

Staffing was adequate

throughout the assessment period.

Positions are identified, af.d

authorities and responsibilities are well defined.

A full tirw

fire chief was hired during this assessment period.

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Management has stressed the importance of reducing transient

combustittles in the plant, and the results have been excellent.

Housekeeping practices have continued to improve throughout the

assessment period.

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2.

Conclusions

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The overall assessment of this functional area shows a strong

fire protection program.

Management involvement in this

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functional area was evident by the excellent housekeeping

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prectices, cempletion of Appendix R requirements, and improved

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1rainingoffirebrigademembers.

,The licensee is considered to be in Performance Category 1 in

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,jthisfunctionalarea.

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>< Board Recommendations

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'Recommegitt_MEActions

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a (<TheNRCinspectioneffortinthisfunctional. area.canbe

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limited to the minimum program.

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b.

Recommended Licensee Action

The licensee should maintain strong canagement attention in

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this area to ensure continued good performance.

t

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F.

Emergency Preparedness

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i

1.

Analysis

~

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!

The assessment of this area' included the licensee's preparation

i

1

for radiological emergencies and response to simulated

!

,

emergencies (exercises).

Thus, it encompassed:

emergency plan

and implementing procedures; emergency facilities, equipment,

-

instrumentation, and supplies; organization and management

control; training; independent reviews / audit; and the licensee's

l

ability to implement the emergency plan,

j

During the assessment period, five emergency. preparedness

1

inspections were conducted by region-based NRC and contractor

,

i

inspectors. Two of these inspections were the observation and

j

evaluation of annual emergency response exercises by a team of

NRC and contractor inspectors.

During the first exercise, one

deficiency from a previous ex?rcise was closed and three new

,

deficiencies were identified.

During the following exercise,

two deficiencies from a previous exercise were clw ed and six

>

,

new deficiencies were identified.

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3

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{

Three inspections resulted in closure of seven open items, and

identification of four violations and one deviation from a

'

commitment, which is considered in this report under Section I,

"Quality Programs and Administrative Controls Affecting

'

Quality." Two of the four violations, one of which was a repeat

i

violation, ir,volved failure to perform required emergency

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15

'l

preparedness training.

Training weaknesses continued to be an

area deserving more licensee management attention.

The other

two, both violations of 10 CFR Part 50.54, also suggested

inadequate management attention to emergency preparedness.

The

nine deficiencies identified during the 1986 and 1987 exercises

further reinforced the view that emergency preparedness had not

reached the desired level of proficiency.

Specifically, there

'

did not appear to be adequate management involvement in ensuring

such proficiency.

The 1986 SALP report stated, "During the assessment period the

licensee had made a positive corrective effort.

The licensee

initiated an upgrade to the emergency res onse training program;

however, the program did not materialize.p' During the current

SALP period, the licensee has worked to upgrade the emergency

preparedness training program.

For example, training records

are being computerized, lesson plans have been developed for

several functional emergency response areas, emergeray resporise

1

personnel have received training to become certified

instructors, and one emergency response instructor now has

previous emergency preparedness experience and training.

.

I

l

Following the 1987 Quality Assurance evaluation / audit, licensee

management was apprised of 21 emergency response team members

who had not received required annual emergency response

,

refresher training.

Seven months later an NRC inspector's

random review of 13 personnel training records determined that

9 of the 13 emergency response team members had not received

required annual emergency preparedness refresher training.

The

4

training program lacks depth in defining specific training

requirements for emergency response personnel and in ensuring

that those requirements have been met.

Another problem that suggests a need for greater management

attention is the offsite dose projection program.

The licensee

l

'

had not completed procurement of software required for the

offsite dose assessment capability.

An acceptable interim

capability exists, however, this item has been tracked since the

Emergency Preparedness Appraisal conducted in June 1981.

2.

Conclusions

The number of deficiencies observed during the exercises and

violations issued in training indicate that training methods and

procedures require additional improvement.

Special management

attention should be devoted to training pregram develepment,

implementation, and training record management to preclude a -

decline in future performance.

Management attention also should

be directed to timely correction of other problems, such as

management of the offsite dose assessment program.

/

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,

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-16-

,The ins'pection findings for this evaluation period indicate,

overall, that the licensee's emergency preparadness program is

adequate to: protect the health and safety of the public.

The licensee 's considered to be in Performance Category 2 in-

this area.

3.

Board Recommendation

a.

Recommended NRC Action

NRC inspection effort should remain at the present level.

Particular attention should be paid to training program

progress and to management involvement in expediting and

ensuring corrective action.

b.

Recommended Licensee Action

The level of managenient attention to the implementation of

the emergency preparedness program should be increased to

ensure timely response to NRC identified items.

The

1.icensee should complete and implement the emergency

preparedness training and retraining program as outlined by

training management.

The training program should include

training for both station and general office emergency

response team members.

G.

Security

1.

Analysis

The assessment of this area inc'itdes all activities whose -

purpose is to ensure the security of the plant.

Specifically,

it includes all aspects of the licensee's security program

(e.g., access control, security checks, safeguards).

This area

was inspected on a continuing basis by.the NRC resident

inspectors and periodically by NRC regional inspectors.

Five

inspections were conducted by NRC inspectors during the

assessment period.

Eleven violations were identified oy

regional and resident inspectors during the assessment period.

Three of the violations were repeatLviolations.

Two inadequate

access control - vital area violations, two compensatory

measures violations, and two access control - vehicle violations

were written during the SALP period.

One of the access

control - vehicle violations allowed live ammunition to be

brought onsite.

This resulted in an escalated enforcement

action.

One violation, concerning the failure to submit an NRC

required security plan change by the required date, indicated

that licensee management (particularly licensing) has instituted

a program that appeared to be so restrictive that CNS was late

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1

submitting the required change.

Three of the violations were

licensee-identified including the escalated enforce: tent

violation.

The licensee appears'to be resolving many of the previous SALP

-period noncompliance issues.

An effort is currently underway to

improve protected area' security systems._ Additionally,'CNS

security was. successful during contingency drills conducted

during the assessment period.

This is a reflection of improved

security management.

Management oversight also appears to have

resulted in improved security functions.

.

2.

Conclusions

.

Some problem areas identified during the previous SALP period

should be resolved by the ongoing security systems upgrade.

.

Increased support by plant management appears to-be having a

.

positive effect on the security organization.

However, the

security systems upgrade effort has been conducted slowly. LThe

licensee has been implementing the upgrade for a year and a

half, but not all equipment has been installed.

The numbers of

'

violations during the SALP period indicate that problem areas

are t till evident.

The repe=' violations indicate the need to

,

be more responsive to NRC '

.atives.

,t

The licensee is considered to be in Performance Category 3 but

with a positive upward trend in this functional area.

,

3.

Board Recommendations

a.

Recommended NRC Actions

The NRC regional-based inspection effort should be

continued on an increased basis in this functional area.

b.

Recommended Licensee Actions

The licensee should continue its current security systems

upgrade effort and place additional emphasis on those

problem areas identified in NRC reports during this SALP

period.

H.

Outage

,

1.

Analysis

,

The assessment of this area includes all licensee and contractor

activities associated with major outages.

It includes

refueling, outage management, major plant modifications, repairs

or restoration to major components and all postoutage startup

testing of systems prior'to-return to service.

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18

In order to more clearly define the specific strengths and

weaknesses noted in this functional area, the analysis is

divided into two areas, as discussed below:

1

a.

Outage Performance

This area was inspected on a continuing basis during the

outage by the NRC resident inspectors, and periodically.by

NRC regional inspectors. .The inspections included

j

refueling activities, outage management, planning and

<

scheduling, staffing, major components and systems repairs

and modification, and'preoperational startup testing.

There was one major outage during this assessment period

which began on October 6, 1986, and ended on January 3,

1987.

Management involvement in assuring quality was

evident throughout the outage.

There was consistent

evidence of. prior planning in that priorities were properly

assigned and policies were well stated and disseminated.

Outage activities included inspections of the main turbine

i

and generator, annual inspection of the diesel generators,

a

detailed control room design review, control room panel

modifications, 10 CFR Part 50, Appendix R alternate safe

1

shut down modifications, Regulatory Guide 1.97

l

instrumentation changes, primary containment purge valve

debris strainer installation, standby gas treatment . system

'

hanger recertification, control. room ventilation duct

I

changes, emergency diesel generator control power isolation

switch installation, equipment qualification upgrade, motor

control center structural supports modifications, residual

i

heat removal pumps wear ring upgrade,.and replacement of

the high pressure coolant injection system gland seal

exhaust condenser.

Few significant operational events

H

which were attributed to causes under the licensce's

control have occurred regarding-this. functional area.

l

Vacant key positions were filled on a priority basis.

A

dedicated full time Outage and Modification Manager was

appointed subsequent to the outage and should have an

impact on future outages.

b.

Engineering Technical Support for Outages

.

This area was inspected on a continuing basis by the NRC

resident inspectors and in depth by the SSFI team.

The

1

inspections included major components and system repairs

and modifications, preoperational startup testing, and the

design change program.

No violations or deviations were

identified in this area; however, the design and design

change program were a contributing factor in two violations

4

and five LERs during this assessment period.

These two

violations are identified in the functional area of quality

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'19

programs and administrative controls affecting quality.

In

addition,.the SSFI identified several potential design.

deficiencies which occurred outside this. assessment period.

There were two LERs in this functional area which indicated

a need to provide better' controls when-performing

postmodification testing.

Events were properly identified,

analysed, and promptly reported.

Implementation of.the: design change program was weak,.in

some instances, in that training and drawing modifications

were not identified-or' performed in a timely manner.

In

addition, the SSFI identified similar problems'.in updating

drawings, and had. concerns about the design change process

,

and procedures.

Onsite engineering staffing has increased

from 40 to 46 during this assessment period. The licensee

also transferred responsibility for all design changes to

the engineering staff in the general office <during the

assessment period.

Despite these changes, a large

engineering backlog still exists; this limits the

licensee's ability to respond in a timely manner to some

i

issues.

2.

Conclusions

,

The licensee has consistently displayed a strong management

commitment to a well organized and functional outage program.

Staffing and training needs were established commensurate with

the quantity and depth of activities that were planned.

The

licensee's Technical Support was not at the same standard as was

outage performance.

'

i

'

The licensee is considered to be in Performance Category 2 in

this functional area.

i

3.

Board Recommendations

a.

Recommenced NRC Actions

The NRC inspection effort in this functional area should be

i

consistent with the routine inspection program, except

,

increased attention should be directed toward design

control and change.

b.

Recommended Licensee Actions

Licensee management attention should be concentrated on

providing improved technical support and reduction of

'

engineering backlog.

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I.

Quality' Programs and Administrative-Controls Affecting Quality

1.

Analysis

The assessment of this area includes all management control,

verification and oversight activities which affect or assure

the quality of plant activities, structures, systems, and

components. This area may be viewed as a comprehensive

management system for controlling the quality of verification

activities which confirm that the work was performed correctly.

The evaluation'of the effectiveness of the QA system is based on

the results of management actions to ensure that necessary

people, procedures, facilities, and materials are provided and

used during the operation of the nuclear power plant.

Principal

emphasis is given to evaluating the effectiveness and

involvement of management in establishing and assuring the

effective implementation of the QA program along with evaluating

the history of licensee performance in the key areas of:

committee activities, design and procurement control, control of

design change processes, inspections, audits, corrective action

systems, and records.

This area was inspected on a continuing basis by the NRC

resident inspectors and, on several occasions, by regional

inspectors. Specific areas inspected included audit program,

audit implementation, procurement, Bulletin followup,

Information Notice followup, corrective action system, design

changes and modification, equipment qualification, and inservice

inspection.

In addition, a safety system functional

inspection (SSFI) was conducted by Region IV and headquarters

inspectors.

During this assessment period, five violations were identified

in this functional area.

Included was one violation fcr which

escalated enforcement action was taken. However, the Level III

violation was for actions which occurred outside of this

assessment period. One deviation regarding emergency

preparedness was identified. The licensee reported neveral LERs

>

attributable to this functional area during the assessment

period.

While management involvement in assuring quality was evident,

some problems with management involvement were identified as

root causes to events in this assessment period. Additional

contributing factors were design errors and the design change

process. Violations indicated minor programmatic inadequacies.

4

Corrective action was timely and effective in most cases.

Permanent plant staffing has increased from approximately 300 to

greater than 350 during this assessment period. Quality Assurance

staffing has increased from 9 to 12. Management is visible on

,

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21

site and corporate management is usually involved in site

activities. However, comunication problems continue to exist

between the r,ite and the General Office, which is located

approximately 160 miles from the site.

Although the QA staff is relatively small, it is aggressive and

effective in identifying quality problems. However, management

has'not always been supportive in ensuring that prompt

corrective action is taken when problems are idc.itified. The

size of the QA staff limits its. flexibility in responding to

site and industry problems.

The licensee has formalized its quality control program during

this assessment period. A dedicated quality control supervisor

is in place.

Formalized quality control training hac been

implemented and _is being conducted in preparation for the 1988

refueling outage. Additionally, the licensee has begun a

configuration management program.

2.

Conclusions

The overall assessment of this area indicates a QA program that

is growing and improving at Cooper Nuclear Station. Additional

management involvement is required to ensure that communications

problems are reduced and that QA findings are resolved in a

timely manner. Resolutions of technical issues are generally

conservative and timely. Management involvement is also

required to reduce engineering backlog and improve the design

control program.

The licensee is considered to be in Performance Category 2 in

this area.

3.

Board Recommendations

a.

Recommended NRC Actions

The NRC inspection effort should be consistent with the

routine inspection program with emphasis placed on the

design change program.

b.

Recommended Licensee Actions

The licensee should provide increased management oversight

to improve communications between onsite organizations and

general office.

The licensee should continue emphasis on

its configuration management program,

i

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J.

Licensing Activities

1.

Analysis

.This assessment represents the integrated inputs of the

Operating Reactor Project Manager (PM) and those technical

reviewers who expended significant amounts of effort on Cooper

Nuclear Station licensing actions during the. rating period.

The

reviewers included this information as part of each Safety

Evaluation transmitted to the Project Directorate.

The PM,

af ter reviewing the inputs of the technical reviewers, combined

this information with his own assessment of licensee performance

and, using appropriate weighting factors, arrived at.a composite

rating for the licensee's performance in the functional area of

Licensing Activities.

This rating also reflects the comments of

the NRR Senior Executive assigned to the SALP assessment.

A

written evaluation was then prepared by the PM and circulated to

NRR management for comments, which were incorporated in this

-assessment.

The basis for this assessmenti.1s the licensee's

performance in support of significant licensing actions that

were either completed or had a substantial level of activity

j

during the rating period.

These actions are identified in

J

Section V.G. of this report.

,

'

a.

Management Involvement and Control in Assuring Quality

During the rating period, licensee management increased its

level of involvement and attention to quality in issues of

,

major safety significance above the previous level which

was also rated Category 1.

In particular, increased

participation by senior management, was evident by

increased presence at meetings with the NRC.

Increased

participation by General Office (Columbus, NE) management

at on-site inspection exit meetings was also noted.

The

General Office is approximately 160 mi.les from the site.

Both locations lack convenient airline service, however the

licensee's use of private aircraft capable.of landing at a

small airfield near the facility enables General Office

personnel to visit the site frequently thereby facilitating

their overview of site activities and participation in

onsite meetings.

During the rating period licensee

management greatly increased its focus on security

concerns.

A program was initiated to develop a new

document which would consolidate the facility design base

.

documentation.

The licensee's success in implementing a fitness for duty

and drug testing program, in the face of an employee group

legal challenge is considered a noteworthy accomplishment

in this functional area.

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23

b.

Approach to Resolution of Technical Issues from a Safety

Standpoint

During the rating period several complex technical

situations arose which required expedited action on the

part of the licensee.

These were (1) reduction in main

steam bypass capacity because of a bypass valve hydraulic

control system problem, (2) failure of the position

indicator on a testable check valve, (3) discovery of

seismic qualification problems in certain piping systems,

and (4) discovery.ofidiesel generator cylinder head cracks.

The licensee's approach to resolution of these issues was

immediate and effective and demonstrated appropriate

priority of safety concerns.

During the rating period, a comprehensive Safety Systems

Functional Inspection (SSFI) was conducted by NRR with RIV

and contractor assistance.

A number of safety issues were

generated by this inspection.

The licensee's approach to

resolution of these issues demonstrated appropriate

attention to safety.

The licensee committed to conduct

considerable tests and analyses, and to implement major

programmatic improvements,

c.

Responsiveness to NRC Initiatives

During the rating period considerable progress was made on

several long-standing safety issues.

The containment vent

and purge issues are rapidly being resolved, and the issue

of combustible gas control is being resolved.

Greater

progress would have been made had it not been for the

effort spent in responding to SSFI findings.

However, the

,

major problems have been resolved and final resolution is

'

forthcoming.

As stated above, the licensee's initial

response to the SSFI issues is considered noteworthy.

The

'

administrative and the technical support the licensee

provided to the inspectors during the course of the

inspection was also noteworthy.

d.

Reporting and Analysis of Reportable Events

i

During the rating period, the licensee received a Notice of

Violation for failure to report a reportable event.

Also,

the licensee submitted an LER in which it reported a

considerable number of older ESF actuations which had

i

previously been considered not reportable.

Discussiens

between the Project Manager and plant staff indicate that

the licensee has considerable difficulty in determining

reportability.

The licensee initiated corrective action to

provide its personnel with special training in 10 CFR

.-

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24

Part 50.72 and 10 CFR Part 50.73.

(This training is being

conducted in the succeeding assessment period.)

In LER 87-023 the licensee submitted a voluntary item of

~

generic interest regarding a study of setpoint seasonal

drift in bourdon tube pressure switches.

The licensee's

voluntary efforts in presenting its findings to the

industry are commendable.

The licensee's LERs are comprehensive and well

documented.

e.

Staffing

The rating period was one of intensive licensing activity.

The intense workload was due to the effects of responding

to the SSFI.

This resulted in rescheduling of other lower

priority licensing activities.

However, the licensee

performed exceptionally well under the unusual

circumstances.

The licensing organization is well

qualified and adequately staffed to handle normal

workloads.

During periods of increased unplanned licensing

activity, lower priority work slips.- A highly experienced,

senior licensing engineer has been relocated from the

General Office to the site.

This action-should help

expedite resolution of licensing issues.

2.

Conclusion

The licensee's-performance.in the area of licensing activities

during the rating period had been above average.

Only one

notable circumstance arose during the period which could be

criticized.

In December 1987, the licensee applied for an

expedited Technical Specifications (TS) amendment to revise

certain surveillance intervals from 6 to 18 months.

The

surveillance test for'which relief was requested is a secondary

containment isolation logic functional test.

Cooper's TS

require the test at 6 month intervals whereas standard practice,

per Standard TS, is at 18-month intervals during refueling

outages.

The application explained that the licenses was

concerned about the likelihood of a scram during the test,.

because of a loss of cooling air to.the Recirculation Pump MG

sets.

The application stated that the test had only once before

been performed (in 1979) while at power and that "unplanned

shutdowns" have historically provided the necessary

opportunities to conduct the test.

It is the opinion of the

staff that the licensee should have anticipated the need for an

amendment in time to permit routine amendment processing.

The

emergency amendment would not have been issued had not the

licensee otherwise had an excellent performance record in the

,

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25

licensing area.

The licensee has agreed to perform a review of

its TS to identify any other similar potential situations.

An overall performance rating of Category 1 has been assigned

for the functional area of Licensing Activities.

3.

Board Recommendations

a.

Recommanded NRC Actions

The staff should visit the licensee's General Office more

frequently for increased communications and familiarization

with the licensee's offsite QA, engineering and committee

activities.

b.

Recommended Licensee Actions

The licensee should accelerate its efforts in documentation

of design bases.

TS should be reviewed for consistency

with current practice and upgraded to reduce the likelihood

of need for emergency amendments and interpretations.

K.

Training and Qualification Effectiveness

1.

Analysis

This functional area includes all activities relating to the

effectiveness of the training, retraining, and qualifications

program conducted by the licensee's staff and contractors for

the 10 categories of facility training.

These categories are

non-licensed operators, control room operators, senior control

room operators / shift supervisors, shift technical advisors,

instrument and control technicians, electrical maintenance

personnel, mechanical maintenance personnel, radiological

protection technicians, chemistry technicians, and onsite

technical staff and managers.

This area was inspected on a continuing basis by the NRC

resident inspectors and once by NRC regional inspectors.

The

inspections included plans and procedures, licensed operator

training, operator requalification training, and training of

non-licensed personnel including shift technical advisors,

contracted personnel, administrative, maintenance, engineering,

site and corporate personnel.

No violations or LERs were

identificd in this functional area.

However inadequate training

and training records could occasionally be traced as a root

cause for problems identified in other SALP areas during this

assessment period.

Several potential violations in the area of

training were noted during training inspections.

However, in

accordance with the Commission Policy statement on Training and

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26

Qualification of Nuclear Power Plant Personnel (50 FR 11147

dated March 30,1987), these potential violations were not cited

but were documented as unresolved items.

During this assessment period, the licensee has continued to

expend considerable effort to upgrade its training and

qualification effectiveness.

Improvements included the

completion of the new training facility. The contract for the

purchase of a plant specific simulator was completed and the

simulator is scheduled to be installed in 1991. The licensee

received final accreditation by the INPO for the nonlicensed -

operator, control room operator, and senior control room

operator training programs during this assessment period. The

licensee is scheduled for final accreditation by INP0'in the

other seven areas of training in May 1988.

Implementation of

many of these programs is still forthcoming.

Inadequate

training was identified as a contributing cause of both major

and minor events that occurred during the last SALP rating

period and continued to be a problem in this assessment period.

Operator licensing examinations were administered in February

and September 1987.

Seven SR0 upgrade examinations were

administered during this assessment period with all seven

candidates being issued SR0 licenses.

Five Reactor

Operator (RO) candidates were examined during this assessment

period with all five candidates being issued R0 licenses.

The

high pass rates in SR0 and R0 candidate performances can be

attributed to the training and qualification program for

licensed operators.

The NRC did not perform a requalification

program evaluation during this assessment period.

Key positions in training are identified and responsibilities

are defined. The licensee filled all key positions in its

training department organization during this assessment period.

In addition contract personnel in operator licensing training

were replaced with experienced SR0's from onshift operations

personnel.

2.

Conclusions

The licensee has a well defined and implemented licensed

operator training program. The licensee has many training

programs which require implementation after INP0 accreditation.

Several key positions in the training organization were filled.

Weaknesses in this area were identified in the two previous SALP

reports.

Progrannatic deficiencies in training and training

records continues to be a problem.

The licensee has expended

considerable effort to prepare for INP0 accreditation but with

long delays.

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27

The licensee is considered to be in Performance Category 2 in

this functional area.

3.

Board Recommendations

a.

Recommended NRC' Actions

The NRC inspection effort in this functional area should be

consistent with the routine program.

Particular emphasis

should be placed on training program development and

,

implementation.

b.

Recommended Licensee Action

Management attention should continue in the area of-

training program development and implementation for

nonlicensed site and' corporate personnel.. Management-

attention should remain. strong to ensure timely:

installation and readiness of the plant specific simulator.

V.

Supporting Data and Summaries

A.

Licensee Activities

There was one major outage during this assessment period.

The outage

began on October 6, 1986, and ended on-January 3, 1987.

Outage

activities included inspection of the main turbine and generator,

annual inspection of the diesel generators, detailed control room

design review, control room panel modifications, 10 CFR Part 50,

Append;x R alternate safe shutdown modifications, Regulatory

Guide 1.97 instrumentation changes, primary containment purge valve

'

debris strainers installation, standby gas treatment system hanger

recertification, control room ventilation duct changes, emergency

diesel generator control power isolation switch installation,

equipment qualification upgrade, motor control center structural

supports modifications, residual heat removal pumps wear r'ig

upgrade, and replacement of the high pressure coolant inje tion

'

system gland seal exhaust condenser.

B.

Inspection Activities

NRC inspection activity during the this SALP evaluation period

)

included 46 NRC inspections performed with 5928 direct inspection

hours expended.

These inspections included a first round team

inspection of environmental qualification of electrical equipment and

a safety system functional inspection (SSFI) by Region IV and

'

headquarters inspectors.

Table 1 provides a tabulation of NRC enforcement activities for each

functional area evaluated.

Table 2 provides a listing of inspection

findings in each SALP category.

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28

C.

Investigations and Allegations Review

No major investigation activities were conducted during this

assessment period.

D.

Escalated Enforcement Actions

1.

Civil Penalties

A Notice of Violation and Proposed Imposition of Civil Penalty

was issued on March 16, 1988 for a violation which occurred

during this assessment period.

A $25,000 civil penalty was

proposed for a Severity Level III violation regarding the

inadequate search of a contractor vehicle that entered the

protected area with undetected ammunition in the vehicle.

2.

Enforcement Orders

An Order Imposing Civil Monetary Penalty was issued October 10,

1986.

The Order regarded security violations which occurred in

the previous rating period.

E.

Management Meetims Held During Assessment Period

1.

Conferences

An enforcement conference was held at the Region IV office

during on January 28, 1988 to discuss apparent violations

i

regarding security matters and the design review of a plant

change.

2.

Confirmation of Action Letters

Noa

F.

Review of Licensee Event Reports and 10 CFR Part 21 Reports

Submitted by the Licensee

1.

Licensee Event Reports (LERs)

J

Ine NRC resident inspectors and project inspector reviewed:LERs

submitted by the licensee throughout the assessment period and

noted corrective actions. A SALP review panel was convened in

the Region IV office on February 4, 1988, to review inspection

findings and LERs for proximate causes and trends. The review

panel inputs were factored into the analysis of the SALP areas.

2.

Part 21 Reports

There were no 10 CFR Part 21 reports submitted by the licensee

during thic SALP assessment period.

l

.

.

.

.

29

i

G.

Licensing Activities

1.

NRR/ Licensing Meetings (Names Refer to NRR Participants)

November 28, 1986, meeting in Arlington, TX, regarding

miscellaneous security amendments.

Meeting summary dated

April 4,1987 (W. Long)

January 20, 1987, meeting in Bethesda with selected utilities on

combustible gas control in Mark I containments (J. Zwolinski,

J. Donohue, J. Kudrick).

Meeting summary dated March 19, 1987

April 30, 1987, meeting in Bethesda with licensee and licensee's

contractor to discuss security plan changes.

Meeting summary

dated June 4,1987 (R. Dube, B. Manili, W. Long)

May 12-13, 1987, SSFI entrance meeting at General Office

(W. Long, J. Dyer, SSFI Team)

May 22, 1987, meeting at Arlington, TX, regarding security

system upgrade modifications (W. Long) meeting summary dated

June 11, 1987

.

'

June 30, 1987, meeting in Arlington, TX, regarding findings of

SSFI (W. Long)

November 13, 1987, meeting in Arlington, TX, regarding security

system upgrade (W. Long)

2.

Commission Meetings

None

3.

NRC Site Visits (Names Refer to NRR Participants)

September 8-9, routine site visit and management meeting

(W. Long)

November 5-7, 1986, EQ audit / inspection (W. Long, inspection

'

team)

November 4, 1986, site visit and management by L. Zech,

R. Martin, D. Humenansky

December 16-17, 1986, routine site visit and management

(W. Long)

January 7-9, 1987, routine site visit and management meeting

(W. Long)

~.. ..

.

. . .

.

-

- .

-

-

. .

-

.

.

.

,

-.

30

March 11-13, 1987, Regulatory Effectiveness Review (W. Long,

l

D. Orrick, D. Pickett,_R. Dube)

May 18-19, 1987, site visit ano utility management meeting with-

F. Bernthal (see W. Long meeting summary dated June 1, 1987)

June 18-19,~1987, routine site visit and' utility management

meeting (W. Long)

)

July 16-17, 1987, routine site visit and utility management =

naetir.g (W. Long)

August 31 through September 1, 1987, routine ~ site visit and

utility management meeting (W. Long)

September 28-29, 1987, meeting to discuss containment vent and

purge and combustible gas control issues (W. Long, J. Kudrick)

October 6-8, 1987, annual emergency exercise (W. Long)

l

November 17-19, 1987, to observe control room and shift

activities and attend SORC meeting (W. Long, R. Wright)

December 1-2, 1987, site visit and utility management meeting

(D. Crutchfield, W. Long, R. Dudley) Meeting surmaary dated

December 11, 1987

i

4.

Schedular Exemptions Granted

Schedular exemption for relief from property insurance

,

requirements of 10 CFR Part 50.54(w)(1) dated December 2, 1987.

l

5.

Relief Granted

Implementation schedule for ATWS modifications.

Staff letter

dated September 10, 1986.

Extension to GL 87-02 requirement to provide a schedule for

verification of equipment seismic adequacy.

Letter from Long to

Trevors dated May 5,.1987.

Relief from commitment to replace mechanical water level

i

transmitters with analog trip units.

Letter from Long to

i

Trevors dated August 28,'1987

6.

Exemptions Granted

See 4 above

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7.

Emergency Actions Granted

Amendment 114 extending surveillance interval for testing of

secondary containment isolation logic from 6 months to

18 months.

8.

License Amendments Issued

Amendment 101, Technical Specification (TS) changes relating to

administrative control of procedures.

Amendment 102, TS changes relating to Standby Gas Treatment Sys

.

and Control Room Vent. System, sample line isolation setpoint,

and refueling interlocks

,

Amendment 103, TS changes related to removal of reactor vessel

head spray piping and associated conte.inment isolation valves

-

Amendment 104, TS changes to battery surveillance requirements

Amendment 105, TS changes relating to access control of high

radiation areas

Amendment 106, TS changes relating to the Cycle 11 reload

analysis

Amendment 107, TS changes defining the normal position of

certain containment isolation valves

Amendment 108, TS changes relating to scram and rod block

instrumentation

Amendment 109, TS changes relating to reactor water chemistry

Amendment 110, TS changes relating to testing of primary

containment airlock doors

Amendment 111, License modification relating to Physical

Security Plan

Amendment 112, TS changes reflecting modifications to prim 6ry

containment monitoring instruments

Amendment 113, TS changes related to fuel storage facilities

Amendment 114, Emergency authorization (see above)

-

- -

-

.

.

'

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32

9.

Orders Issued

Order Imposing Civil Monetary Penalty based on security

violations dated October 10, 1986.

(Applies to violations of

the previous rating period.)

10.

NRR/ Licensee Management Conferences

See 1 and 3 above

i

)

.

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S

Table 1

Enforcement. Activity.

FUNCTIONAL AREAS

NUMBER OF VIOLATIONS IN EACH LEVEL

DEFICIENCIES / DEVIATIONS

V

IV

III

A.

Plant Operations

5

B.

Radiological Controls

C.

Maintenance

1

3

0.

Surveillance

3

'

E.

Fire Protection

F.

Emergency Preparedness

9/0

4

G.

Security

10

1

H.

Outages

I.

Quality Programs and

Administrative Controls

Affecting Quality

0/1

4

1

J.

Licensing Activities

K.

Training and Qualification

Effectiveness

Total

9/1

1

29

2

i

.

'

,

o

.. .

,

TABLE 2

ENFORCEMENT ACTIVITY

TABULATION OF VIOLATIONS, DEVIATIONS, AND EMERGENCY PREPAREDNESS DEFICIENCIES

BY

PERFORMANCE CATEGORY

_

A.

Plant Operations

Violations

Failure to follow procedure concerning High Pressure Coolant

Injection system valve positioning (Severity Level IV, 8626-02)

l

l

Inadequate review of surveillance test results (Severity Level IV,

(8626-03)

j

Failure to have adequate refueling procedure (Severity Level IV,

8627-02)

Service water valve out of position (Severity Level IV, 8728-01)

Failure to maintain secondary containment (Severity Level IV,

8728-02)

Deviations

None

B.

Radiological Controls

Violations

None

Deviations

None

C.

Maintenance

Violation

Inadequate cleanliness controls (Severity Level IV, 8627-05)

Failure to provide adequate controls (Severity Level IV, 8627-06)

Failure to have maintenance procedure (Severity Level IV, 8627-07)

Failure to perform required NDT examinations (Severity Level V,

8720-03)

Deviations

None

,

'

.. .

,

-2-

D.

Surveillance

Violations

Failure to quantify leakage per Appendix J (Severity Leval IV,

8630-01)

Failure to document procedure review (Severity Level IV, 8636-02)

Missing data in calibration records (Severity Level IV, 8706-04)

Deviations

None

E.

Fire Protection

Violations

None

Deviations

None

F.

Emergency Preparedness

Violations

Failure to perform training (Severity Level IV, 8702-01)

Failure to notify NRC of plan change (Severity Level IV, 8702-02)

Failure to perform training (Severity Level IV, 8802-01)

Failure to make available 50.54(t) evaluations to states (Severity

Level IV, 8802-02)

Deviations

None

Deficiencies

Dose assessment error (8625-01)

Inadequate staffing at general office emergency center (8625-02)

No recovery plan procedures issued (8625-03)

Delayed notifications (8725-01)

Deficient information flow (8725-02)

Deficient performance of shift supervisor (8725-03)

Inadequate emergency action level (8625-04)

_

_

'

-

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-3-

Deficiencies in technical support center (8625-05)

Inadequate medical team performance (8625-06)

G.

Security

Violations

Inadequate physical barrier to vital area (Severity Level IV,

8629-01)

Failure to report security degradation (Severity Level IV, 8629-02)

Inadequate compensatory measures (Severity Level IV, 8629-03)

Keys in unattended vehicles it, protected area (Severity Level IV,

8629-04)

Inadequate access control - tailgating (Severity Level IV, 8701-01)

j

Inadequate security organization screening (Severity Level IV,

8701-02)

Inadequate compensatory measures procedure (Severity Level IV,

'

8701-03)

Failure to file security plan changes (Severity Level IV, 8708-01)

Inadequate access control - issued wrong badge (Severity Level IV,

8727-01)

Lock and key control (Severity Level IV, 8727-02)

Shotgun shells in protected area - inadequate search (Severity

Level III, 8732-01)

Deviations

None

H.

Outages

Violations

None

Deviations

None

_ _ _ _ _ _ _ _

_

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,

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,

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I.

Quality Programs

Violations

Failure to have latest revision to a refueling procedura (Severity

Level IV, 8C36-03)

Failure to provide adequate procedures following a design change

(Severity Level IV, 8703-01)

Failure to follow SRAB procedure (Severity Level IV, 8712-02)

Failure to make required 50.73 report (Severity Level IV, 8718-01)

Inadequate 50.59 review (Severity Level III, 8731-01)

Deviations

Failure to test mobile sirens (8802-03)

J.

Licensing Activities

Violations

o

None

Deviations

o

None

K.

Training and Qualification Effectiveness

Violations

o

None

Deviations

o

Hone

1

._ _

_ _ _ _ .

.

_

.

._

_

__

_

.

..

'

,

• , . . .

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TABLE'3

OPERATIONAL EVENTS

TABULATION OF LICENSEE EVENT REPORTS

BY

PERFORMANCE CATEGORY

'

- A.

Plant Operations

- Failure to Monitor Reactor Water Conductivity (86-018)

'

Reactor Water Cleanup (RWCU) Group III Isolation (86-019)

i

Group Isolations and Reactor Protective. System (RPS) Trip During

"

Reactor Shutdown.(86-022)

RWCU Group III Isolation (86-024)

Reactor Scram During Startup (87-002)

)

Low Reactor Vessel Water Level Scram & Group Isolation (87-006)

Unanticipated Reactor Scram and Group Isolations Due to Low Reactor

j

Vessel Water Level Caused by Inadvertent Manual Trip of the Operating

Reactor Feedwater Pump (87-009)

Unplanned Group I Isolation and Reactor Scram While Shut Down Due to

Overtravel of the Reactor Mode Switch When Operated (87-015)

Unplanned Diesel Generator Actuation While Verifying Electrical

Schematic Drawings (88-001).

B.

Radiological Controls

None

C.

Maintenance

Reactor Scram During HFA Relay Replacement (86-016)

Closure of High Pressure Coolant Injection (HPCI) Steam Supply Valve-

.

(86-017)

,

4

]

Inadvertent Auto-Start of Diesel Generator No. 2 (86-025)

Inadvertent Bumping of Relay Causes Auto-Start of Emergency Diesel

'

Generator (86-030)

,

Unplanned Actuation of Group II and VI Containment Isolation

Circuitry as a Result of'Short Circuit During Design Change

Modification Activities (86-031)

,

'

Unplanned Challenge to the RWCU System Due to Personnel Error While

Troubleshooting (86-035)

3

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D.

Surveillance

Inadvertent Isolation of RWCU (86-Ow )

Main Steam Safety Relief Valve Setpoint Drift and Stuck Pilot Valve

Inoperability Discovered During Scheduled Valve Testing and

Refurbishment (86-032)

Residual Heat Removal and Core Spra)

,,ap Motor Deficiencies Believed

to be Caused by High Cycle Fatigue Loading which were Discovered

During Inspection (86-033 and Supplement 1)

Primary Containment Leakage During Local Leak Rate Testing (87-004)

Unplanned Actuation of Group VI Isolation Due to Personnel Error

While Calibrating Area Radiation Monitors (87-008)

,

Unplanned Actuation of the RPS and Containment Isolation Valve

?

Groups II, III, and VI Initiated During and Subsequent to Turbine

Valve Testing Due to Operator Error (87-011)

Unplanned Actuation of Group I Isolation Valves During Surveillance

Testing Due to Operator Error (87-012)

Initiation of Plant Shutdown Due to Malfunctioning Pressure

Suppression Chamber Reactor Building Vacuum Breaker Valves (87-01',,

Unplanned Closure of RWCU System Isolation Valve Due O Personnel

Error During Surveillance Testing (87-022)

Setpoint Drift of Barksdale Bourdon Tube Pressure Switches, Model 82T

(87-?3)

Failure of HPCI Turbine Overspeed Trip Mechanism to Automatically

Reset During Surveillance Testing Due to Binding of the Tappet

Assembly (87-24)

E.

Fire Protect 1o_n

None

F.

Emergency Protection

None

G.

Security

<

Improper Personnel Access (87-501)

Improper Vehicle Search (87-502)

_ _ _ - _ _ _

'9

.

_ - _ . _ . . _ _ _

. .. .

.

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.

H.

Outages

Reactor Coolant System In-Service Leak Test ~ Causes-Reactor Scram

(87-001)

'

Reactor Scram & Group Isolations Due to Troubleshooting (87-003).

I.

Quality Programs and Administrative Controls Affecting Quality

loss of Emergency Transformer Supply (86-021)

Apparent Unnecessary Operation of an Auto-Start On Both Diesel

Generators (86-023)

Emergency Diesel Generator cylinder Head Cracking (86-026)

Safety Related Instrument Rack Seismic Deficiencies (86-027)

Standby Gas Treatment System Seismic Design Deficiencies (86-028)

Storage of Fuel in the Spent Fuel Storage Pool with U-235 Loading in

Excess of Technical Specification Limits due to Pellet Design Changes

-

and Manufacturer Variances (86-034)

.

Reactor Scram Due to Main Steamline Isolation Valve Closure During

Containment Inerting (87-005)

.

Deficiency in a Design Engineering Effort Performed in Response to a

TMI-2 Lessons Learned NRC Concern (87-025)

,

'

J.

Licensing Activities

'

None

K.

Training and Qualification Effectiveness

,

4

None

l

L.

Not Applicable

t

Loss of Emergency Transformer Supply Due to Lightning (86-015)

Loss of Emergency Transformer Supply Due to Lightning (86-020)

'

Loss of Emergency Transformer Supply Causing Emergency Diesel

'

Generator Auto-Start (86-029)

'

Isolation of RWCU System Due to High Flow When Restoring System to

Operation (87-007)

,

1

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Automatic Starting of Diesel Generators Upon Loss-of the Emergengy;. ( ,v'

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Transformer. Supply Due to Inclement Weather (87-010)

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Unplanned Actuation of> Diesel Generator #2 Due to Loss of-V'citage on

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i

4160V IG Sus During Transfer of Power from:its Startup to Normal

a

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'

Unplanned Reactor Shutdown as.a Result of High Reactor Water

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Conductivity Due to Condenser Tube Leakage (87-014)

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Unplanned Automatic Startup of Both Diesel Generators Due to a

'

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Suspected Lightning-Strike on the Offsite 69KV Emergency Power Supply.

Transmission System (87-016)

f

Unplanned Automatic Startup of.Both Diesel Generators Due tola

4

Lightning Strike on the Offsite 69KV Emergency Power Supply

Transmission System (87-017)

'

Unplanned Automatic Startup of Both Diesel Generators Due to a

Lightning Strike on the Offsite 69KV Emergency Power Supply A

Transmission System (87-018)

. , ,

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Apparent Noncompliance with Surveillance Testing Frequency

Requirements (87-020)

,, . e

Unplanned Automatic Start Actuations of Both Diesel Generators

(87-021)

Withdrawal of 1-hour Security Report (87-503)-

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