ML20154E995

Final SALP Rept 50-482/88-14 for Mar 1987 - Mar 1988. Overall Performance Acceptable

ML20154E995
Person / Time
Site:	Wolf Creek
Issue date:	03/31/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20154E975	List: ML20154E972 ML20154E995 ML20154E997
References
50-482-88-14, NUDOCS 8809190212
Download: ML20154E995 (70)

See also: IR 05000482/1988014

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FINAL SALP REPORT

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U,$. NUCLEAR REGULATORY COMMISSION  ;

REGION !Y

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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NRC Inspection Report 50-482/88-14

Wolf Creek Nuclear Operating Corporation

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Wolf Creek Generating Station

March 1,1987, through March 31,1988

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8809190212 000912

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1. INTRODUCTION

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

integrated NRC staff effort to collect available observations and data on

a periodic basis and to evaluate licensee performance based upon this

information. SALP is supplemental to normal regulatory processes,used to

ensure compliance with NRC rules and regulatiens. SALP is intended to be

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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.

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

May 17, 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 summar

provided in Section !! ofy of thereport.

this guidance and evaluation criteria is

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l T'his report is the SALP Board's assessment of the licensee's safety

performance at Wolf Creek Generating Station for the period March 1, 1987,

through March 31, 1988.

SALP Board for Wolf Creek Generating Station:

L. J. Callan, Director, Division of Reactor Projects, Region IV (chairman)

J. L. Milhoan, Director, Division of Reactor Safety, Region IV

M. R. Knapp, Acting Director, Division of Reactor Safety and

Safeguards, Region IV

D. D. Chamberlain, Chief, Reactor Project Section A. Region IV

B. L. Bartlett, Senior Resident Reactor Inspector, WCGS, Region IV

P. W. O'Connor, Project Manager, Nuclear Reactor Regulation

The following personnel also participated in the SALp board meeting:

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J. M. Montgomery, Deputy Regional Administrator, Region IV

A. B. Beach, Deputy Director, Disision of Reactor Projects Region IV

J. P. Jaudon, Deputy Director, Division of Reactor Safety Region IV

R. E. Hall, Deputy Director, Division of Reactor Safety and Safeguards,

Region IV

J. B. Baird, Technical Assistant, Division of Reactor Projects, Region IV ,

C. A. Hackney, Emergency Preparedness Analyst, Region IV

J. L. Pellet, Chief, Operator Licensing Section i

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R. J. Everett, Chief. Emergency Preparedness and Safeguards Programs

Section, Region IV

R. E. Baer, Chief, Facilities Radiological Protection Section, Region IV

W. M. McNeill, Reactor Engineer, Materials and Quality Programs Section,

Region IV ,

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!!. CRITERIA

Licensee performance was assessed in 11 selected functional areas.

Functional areas normally represent areas significant to nuclear safety

and the environment. Some functional areas may not be assessed because of

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little or no licensee activities or lack of meaningful observations.

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Special areas may be added to highlight significant observations.

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

I functional area:

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1. Management involvement and control in assuring quality.

2. Approach to the resolution of technical issues from a safety

standpoint,

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Operational events (including response to, analysis of, and

corrective actions for).

6. 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 effectively used so that

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a high level of performance with respect to operational safety and

construction quality is being 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

operational safety and construction quality is being achieved.

Category 3. Both NRC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and considers

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

be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety and construction quality is

being achieved,

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!!I. SUMMARY OF RESULTS

The SALP Board review revealed areas of strength in fire protecti*on and

security with an increase in performance from the previous SALP period.

Performance in the areas of emergency preparedness and surveillance

remained consistent with the previous SALP period. All other areas

revealed a decline in performance or a declining trend from the previous

SALP period. The overall decrease in performance is due, in part, to the

failureoflicenseemanagementtomaintaineffectivecontrolofmajor

ottages.

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

the performance categories from the previous SALP evaluation period.

Previous Present

ory

Functional Performance Category) Performance

(02/1/86 to 02/28/87 Categ/88)

(03/1/87 to 03/31

A. Plant Operations 2 2

B. Radiological Control 2 2

C. Maintenance 1 2

D. Surveillance 2 2

E. Fire Protection 2 1

F. Emergency Preparedness 2 2

G. Security 2 1

H. Outages 2 3

!. Quality Programs and 2 3

Administrative Controls

Affecting Quality

J. Licensing Activities 1 2

K. Training and Qualification 1 2

Effectiveness

IV. PERFORMANCE ANALYS!$

A. Plant Operations

1. Analysis

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i The assessment of this area consists chiefly of the activities

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and nuclear station operators). It is intended to be limited to

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] operating activities such as: plant startup, power operation. L

plant shutdown, and system lineups. Thus, it includes f

I activities such as reading and logging plant conditions', .

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responding to off-normal conditions, manipulating the reactor

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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  !

4 impectors. Specific areas inspected included operational l

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se,ety verifications, safety system walkdowns, follow up on ,

significant events / problems, and review of licensee event  ;

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reports (LERs), t

i One violation was identified in this functional area and, while  !

! it indicated additional management controls were needed, i

i corrective action was promptly initiated by the licensee. Also, l

j one of the escalated enforcement violations listed in the outage  !

functional area included three examples of problems relating to  !

the operations functional area. Four LERs were issued by the

i licensee in this functional area. These four LERs had no major  ;

i effect on plint safety. One of the LERs concerned the one i

i violation that was identified in this area. The remaining three l

LERs were all perscnnel errors and were indicative of a failure  ;

) to pay attention to detail.  ;

l Corrective actions initiated by licensee management included

requiring the use of procedures in additional areas in  !

I operations. At the end of the SALP period the use of procedures

in operations was much improved. j

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! Operational events and NRC observations showed that operations  !

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interface with other departments is lacking. There has been an j

apparent failure of operations to make effective use of i

technical support groups. In some cases even when technical  ;

l support groups became aware of problems and provided input to i

) operations, the input was ignored or was lost. There are two ,

examples. The first was when operations was not responsive to i

Nuclear Safety Engineering's information and advice concerning  ;

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. the essential service water (ESW) pipe-wall thinning issue. As ,

a result, timely corrective action was needlessly delayed. The  ;

! second was when engineering provided disposition to repair a i

section of thinwall safety-related pipe and the disposition was l

l misplaced for approximately 3 months. j

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In general, operator performance, as observed by the NRC 1

i inspectors, has been good. Control room professionalise has l

1 been maintained and good operator morale exhibited. At times,

however, the operators failed to pay attention to detail. Two

examples of this are given below:

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• The first example occurred when vital batteries were

allowed to be depleted over a 30-hour time span wi,thout a

procedure being available to provide alternate AC power to -

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a the battery chargers, and without bus voltage being

observed carefully or without periodically observing ,

i current readings and comparing them to expected values. ,

j ' The second example was the uncontrolled use of operator

. aids, When ESF actuations occurred as a result of the  ;

' degraded batteries, the operators relied on the l

l uncontrolled aids in determining that certain manual  !

I isolation valves were shut. The valves were, in fact l

j open. Whenthevalveshadbeenopened,theuncontroIIed s

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aid had been forgotten. This resulted in the undesirable

placing of lake water in each of the steam generators.

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! The licensee continues to give strong management support to the  :

l college degree program for operations personnel. The number of i

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operators with engineering degrees or working toward degrees is  !

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l The number of operators with senior reactor operator licenses  !

i exceed the number of operators with reactor operator licenses by  !

1 more than 2 to 1. This allows the licensee mo'e versatility in  :

the use of the operators, while at the same time giving  !

operators additional training and mobility.

l In general, the licensee maintains a 6-shift rotation of their  !

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operating crews. This allows for a better utilization of the j

crews, less overtime, and increased training.

2. Conclusions j

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i The overall assessment of this area indicates that improvements

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need to be made. As stated in the previous SALP report,  !

licensee attention to detail in this area can be improved. The

, use of procedures in operations was noted to improve; however, ,

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this occurred only after the situation had been a110wed to '

I deteriorate to an unacceptable level,

l The examples of inattention to detail and the lack of effective

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operations interface with other departments reflects an

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ineffective management oversight in this functional area,

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! Staffing in this area is considered a strength, along with good

control room professionalism during power operations.

I The licen m is considered to be in Performance Category 2 in

i this area, with a declining trend.

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f 3. Board Recommendations '

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a. Recommended NRC Actions j

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The level of NRC inspection in this functional area should  !

be consistent with the basic inspection program, t

i Supplemental inspections should be performed to. focus on l

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! operations interface with other departments.

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J b. Recommended Licensee Actions

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i Licensee management should ensure that there is an adequate I

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and prompt QA, NSE, and engineering involvement in  !

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operational events and in the technical resolution to  !

safety issues. l

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B. Radioloalcal Controls }

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1. Analysis I

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The assessment of this functional area includes the following l

l areas of activity which are evaluated as separate subareas to  !

l arrive at a consensus rating for this functional area: l

(a) occupational radiation safety, which includes controls by [

J licensees and contractors for occupational radiation protection, f

j radioactive materials and contasination controls, radiological l

1 surveys and monitoring, and ALARA programs; (b) radioactive I

i waste management which includes processing and onsite storage l

ofgaseous, liquid,andsolidwaste;(c)radiologicaleffluent j

controls, which includes gaseous and liquid effluent controls

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and monitoring, offsite dose calculations and dose limits, i

j radiological environmental monitoring, and the results of the  !

NRC's confirmatory measurements program; (d) transportation of l

radioactive materials, which includes procurement and selection i

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of packages, preparation for shipment, selection and control of

i shippers, delivery to carriers, receipt / acceptance of shipments

by receiving facility, M riodic maintenance of pa

kagings and,  ;

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for shipment of spent fuel, point of origin of safeguards

I activitiest and (e) water chemistry controls, which includes

! primary and secondary systems affecting plant water chemistry,

I water chemistry control program and program implementation, j

i chemistry facilities, equipment and procedures, and chemical i

j analysis quality assurance.

Nine inspectiet.s were performed in the area of radiological

controls during the assessment period by Region-based radiation

specialist inspectors.

l There were five violations and one deviation identified in this

j functional area.

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a. Occupational Radiation Safety f

i The licensee's programs for occupational radiation  ;

. protection, radioactive material and contamination  :

i controls, radiological surveys and monitoring, and ALARA l

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programs were inspected four times during the assessment  !

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period. Two inspections were conducted during normal d ant l

operations, one inspection during a scheduled refueling  ;

outage, and one special inspection after the release e.f (

radioactive material to the local county landfill. t

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The licensee's exposure for 1986 was 142 person-rem r

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compared to the national PWR average of 3)2 person-rem.

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During 1987, the licensee's person-rem exposure was 124 _

compared to a national PWR of 376 person rem.

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The size of the radiation protection staff was dequate to l

! support olant operations. A low personnel turnon t rate t

I within the radiation protection group was experiened

i during the assessment period. The licensee's approach i

i concerning the resolution of technical issues indicated  ;

their understanding of issues was generally apparent.

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Acceptable resolutions were generally proposed in response  !

l to NRC initiatives. [

Those violations identified in the radiation protection f

program were an indication of a lack of management l

involvement in assuring quality and worker training. The [

two concerns noted during the previous assessment period  ;

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which included: (1) lack of steam generator mockup  ;

training and (2) lack of health physics supervisory i

personnel presence in the plant to oversee and evaluate i

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ongoing radiation protection activities, had not been fully [

) resolved. l

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The licensee had made changes in the position of radiation

protection manager, an individual with limited emperience [

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and not qualified in accordance with Regulatory Guide 1.8 l

1 was appointed to the position. The licensee recently [

contracted a qualified indiv8 dual to oversee and provide

direction to the radiation protection program, j

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b. Radioactive Waste Manage ent

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j The licensee's program involving processing and onsite  !

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storage of solid waste was inspected twice during the f

J assessment period. One violation was identified. The  !

] licensee released radioactive material as trash which was  !

l found thd recovered froa the local county sanitary t

i landfill. The licensee had reduced the volume of  !

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solidified waste generated by use of a portable l

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demineralizer skid for liquids and processing spent resins

by dewatering methods. The licensee had identified key

positions and defined their responsibilities,

c. Radiolooical Effluent Con _tro_1_ and_Monitorina

This area includes gaseous and liquid effluent controls and

monitoring, offsite dose calculations and dose limits,

radiological environmental monitoring, radiochemistry ,

program, and radiochemistry confirmatory measurement

esults. Three inspections were conducted during the

assessment period, together they encompassed the complete

program area.

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The licensee has established a program concerning the

cor, trol 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 releases. A review of

gaseous and liquid releases indicates that offsite doses

were well below Technical Specification limits. Three

concerns were identified relating to: (1) liquid effluent

monitor setpoints, (2) condensate storage tank analyses,

and (3) radiation monitor calibration data.

The offsite radiological environmental tronitoring program

was inspected once during the assessment period. No

violations were identified. The adiological environmental

monitoring program is effectively managed from the

licensee's corporate office and implemented by station

personnel. The working relationship between the two groups

has been exc911ent.

The radiochemistry anri water chemistry program which

, included onsite confirmatory measurements with the NRC

Region IV sobile laboratory w4s inspected once during the

assessment period. No violaHons or deviations were

identified. The results of ;re confirmatory measurements

indicated 97 percent agreemtn',, a slightly higher value

from the previous assessment period.

d. Transportation of Radioactive Materials

This area was inspected twice during the assessment period

in conjunction with the solid radioactive waste management

program. Two violations were identified; one violation

involved the lack of proper storage and control of quality

assurance records of radioactive material shipments, and  ;

the second related to the lack of training provided to the

health physics supervisor radwaste. Corrective action

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taken by the licensee has generally been timely and *

effective in this area.

Transportation activities at the site usually involve the

support and guidance from the corporate offices. The

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licensee has established an adequate quality

control / quality assurance program for low-level. radioactive

material shipments. Transportation activity records are

complete.

e. Water Chemistry Controls

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

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evaluations. The results of the water chemistry

confirmatory measurements indicated 84 parcent agreement

between the licensee and the NRC's reference laboratory.

These results are considered within expected industry

performtnce levels. The inspection also identified four

concerns involving instrument calibration and the quality

control aspect of the water chemistry analysis program.

2. Conclusions

, The licensee's overall performance indicated a decrease in

effectiveness over the previous assessment period. Seven

violations and one deviation were identified during this

assessment period, as compared to no violations or deviations

being identified during the previous assessment period.

Inadequate management attention to NRC concerns is demonstrated

by the lack of resolution to the concerns noted during the

previous assessment period, which were: (1) lack of steam

generator mockup training and (2) lack of health physics

supervisory personnel presence in the plant to oversee and

evaluate ongoing radiation protection activities. Improvements

were noted regarding the implementation of the ALARA program.

The licensee's personnel radiation exposure history has been

better than (less than one half) the national everage for PWRs.

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No significant problems were identified in the functional areas

of transportation of radioactive material, and radiological

. effluent control and monitoring. The licensee's program for

these areas appeared adequate regarding management oversight,

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resolution of technical issues, training, procedures, and

J staffing.

The licensee is considered to be in Performance Category 2 in

this area. However, during the SALP period, performance was

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decreasing. Recent changes in management have not yet had time

to be effective. .

3. Board Recommendations

a. Recommended NRC Actions

The NRC inspection effort in this area should be consistent

with the basic inspection program with increased emphasis

on management involvement to assure quality.

b. Recommended Licensee Actions

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Hesith physics supervisory personnel should spend more time

in the radiologically controlled areas evaluating and

observing or. going radiation protection work activities to

ensure compliance with station procedures. Management

should take action to provide training to technicians to

enhance procedural compliance.

C. Maintenance

1. Analysis

The assessment of this area includes all licensee and contractor

activities associated with preventive or corrective maintenance

l of instrumentation and control equipment and mechanical and

electrical systems.

This area was inspected on a continuing basis by the NRC

resider +. inspectors and periodically by NRC regional inspectors.

There were two violations identified in this area. These

violations involved the failure of the licensee to request a

code exemption when required and three examples of a failure to

follow procedures. There were 11 LERs issued by the licensee in

this functional area. One LER was due to inadequate

post-maintenance testing on a containment isolation valve,

another LER was due to an accidental mispositioning of a breaker

switch.

The escalated enforcement action that was taken due to the

problems which occurred during the fall refueling lutage

revealed significant problems within the mainterar.e

organization. These problems consisted of workers failing to

follow procedures, inadequate procedures, inadequate control

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over special processes, and an overall breakdown of management

oversite of maintenance activities during the refueling outage.

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One of the major causes for the problems which occurred this

SALP period was workers failing to follow procedures.

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Three of the findings in the escalated enforcement package were

workers failing to follow procedures. These included ipsuance

of the wrong weld rod material, use of the wrong weld rod

material, and failure to check for an energized circuit. There

have been multiple occurrences of Wolf Creek event reports

written for failure to follow procedures. The failure to follow

procedures was pervasive at the Wolf Creek site. This could

only exist if it was allowed to sicwly build up over a period of

months or years. Licensee management was not effectiva in

correcting the problem.

During the last quarter of the SALP eriod, the maintenance

management organization underwent si nificant changes.

Maintenance was combined with facili ies and modifications to

form maintenance and modifications. This change combines all

maintenance activities under a single manager. The

superintendent of maintenance transferred to the outage planning

group and the manager of facilities modifications became the

manager of maintenance and modifications. In addition, some

lower level managers were transferred and some positions were

eliminated. These changes appear te have significantly

strengthened the maintenance area.

2. Conclusions

The NRC found evidence of upper management support for a strong

maintenance program. However, the implementation of this

program was not adequately carried out. Management oversight of

the day-to-day activities in the area of maintenance declined

significantly during the assessment period. Several examples of

the results of this decline were identified. Towards the end of

theSALPperiod,majormanagementchangeswereimplemented.

These changes appear to have significantly strengthened

management oversight of maintenance activities.

The licensee is considered to be in Performance Category 2 in

this functional area.

3. Board Recommendations

a. Recommended NRP Actions

The NRC inspeccion effort in this area should be consistent

with the basic inspection program. The resident inspectors

should increase their inspection activities in this area

b. Recommended Licensee Actions

The licensee should follow through and assess the

effectiveness of their corrective actions. The licensee

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should continue the increased emphasis on procedural

compliance.

D. Surveillance

1. Analysis

The assessment of this functional area includes all surveillance

testing and inservice inspections and testing activities.

Examples of activities included are: instrument calibrations,

equipment operability tests, special tests, inservice inspection

and performance tests of pumps and valves, and all otrer

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inservice inspection activities.

This functional area was inspected on a routine basis by the NRC

resident inspectors and periodically by NRC regional inspectors.

The enforcement history in this functional area identified two

violations during this assessment period. Also, several LERs

were issued by the licensee during this assessment period.

Personnel errors and inadequate procedures were the predominant

causes of the violations and reportable events during this

assessment period. This resulted in examples of missed

surveillances, late performance of surveillances, inadequate

post-test review, and undesirable engineered safety feature

actuations which are similiar to problems which occurred during

tM previous SALP period.

During the previous SALP per'od, the licensee was rated a SALP

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Category 2 in this functior.al area with a decreasing trend. ,

Although the enforcement and reporting history indi G te

improvement, as noted above, similar procedural and personnel

errors are being repea',ed during this SALP period. 1

2. Conclusions

The overall asse sment for this functional area indicates a

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program for scheduling and tracking of surveillance activities

that appears adequate. Procedures in some cases did not address

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all Technical Specification surveillance requirements

adequately. The repeat procedural and persornel errors indicate  ;

that additional management involvement is needed.

The licensee is considered to be in Performance Category 2 in l

this functional area. l

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3. Board Recommendations

a. Recommended NRC Action

The level of NRC inspection in this functional area should

be consistent with the basic inspection program.

b. Recommended Licensee Actions .

The licensee is encouraged to perform an indepth review of

the Technical Specification surveillance requirements and

ensure that the surveillance procedures address these

requirements. Also, additional management involvemen.'. with

surveillance activities is encouraged.

E. Fire Protection

1. Analysis

The assessment of this area includes routine housekeeping

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

activities. Thus, it includes the storage of combustible I

material; fire brigade staffing and training; fire suppression I

system maintenance and operation; and those fire protection '

features provided for structures, systems, and components

important to safe shutdown.

This area was inspected by a Region-based inspector and on a

continuing basis by the NRC resident inspectors. During this

assessment period the fire protection group went through some

organizational changes. One change was the transfer of the fire

protection training duties from the supervision of the fire

protection engineer to the training department. The other

change was the transfer of the fire protection group from the

plant support organization to the operations organization.

The following observations were made:

. The licensee has made significant improvement in the area l

of administrative controls for fire barrier penetrations

and openings. Especially significant has been the

reduction of missed fire watch patrols.

. Control of transient combustibles has been effective.

However, housekeeping could be improved in the area where

trash is being deposited in other than approved containers

(example: openings in tube steel).

. Fire brigade / watch training continued to be 9utstanding.

The transfer of the fire training group to the t : inh.:

department has shown no adverse effects.

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The licensee instituted a program to identify all fire barrier

penetration seals that were either never sealed or removed and

not resealed. This was an extensive program which the licensee t

aggressively pursued and completed.

2. Conclusions

The licensee has shown significant improvement in their fire

protection / prevention program. Management involvement, both in

the program as well as training, was evident. The mayor reason

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for the improvement in this area has been the continu ng

dedication and hard work of the well qualified fire protection

engineer and training instructor.

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The licensee is considered to be in Performance Category 1 in

t this area.

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3. Board Recommendations

a. Recommended NRC Actions

' The level of NRC inspection in this functional area should

be consistent with the minimum inspection program.

b. Recommended Licensee Actions

The licensee should assure that the recent organizational

changes that have the fire protection engineer reporting to

a different group and at a lower management level does not

result in a reduction of management support.

F. Emergency Preparedness

1. Analysis

The assessment of this area includes the licensee's preparation

for radiological emergencies and response to simulated

emergencies (exercises). Thus, it includes emergency plan and

implementing procedures; emergency facilities, equipment,

instrumentation, and supplies; organization and management

control; training; independent reviews / audits; and the

licensee's ability to implement the emergency plan.

During the assessment period, four emergency preparedness

inspections were conducted by Region-based and NRC contractor

insper. tors. One of these inspections was the observation and

evaluation of an annual emergency response exercise by a team of

NRC and contractor inspectors. During the exercise, four

deficiencies from a previous exercise were closed and one new

deficiency was identified. The deficiency identified during the

exercise involved incorrect classification of the emergency as

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15

an unusual event rather than an alert. The licensee's overall

performance during the exercise was evaluated as good. .The NRC

staff concluded that licen% = emergency response personnel

demonstrated their ability 'a protect the health and safety of

the public.

Three routine inspections resulted in identification of three

violations. One violation inicivcd failure to document required

communication tests of the emergency response facilities. The

other two violations, one of which was a repeat violation,

involved failure to determine availability of required emergency

preparedness personnel in the event of an accident. Training

was identified during the previous SALP period report as an area

. needing management attention. The licensee has developed lesson

plans, revised training requirements, and implemented a more

efficient record management system.

The 1987 SALP report stated, "However, several changes were made

to the onsite emergency planning administrator (EPA) position,

and the replacement EPAs have had little previous experience in

this area " Due to attrition, new inexperienced personnel have

been assigned the onsite emergency planning and preparedness

responsibilities. Discussions held with onsite management

l

revealed a difference of opinion as to what the functions of the

onsite emergency preparedness coordinator were and would be in

the future. The offsite emergency preparedness administrator is

located in Wichita, Kansas. The licensee has recently added

another level of supervision above the EPA, removing the EPA

further away from plant management. (This reorganization

presently is awaiting NRR approval.) The emergency preparedness

program appears to be in a transition phase with the shift in '

lead responsibility for emergency program to the corporate I

office. .

2. Conclusions

The violations issued in shift staffing and augmentation

indicate that the personnel notification method and procedure

requires additional improvement. Management attention should be

devoted to meeting regulatory requirements and licensee

commitments.

Licensee management attention and involvement are evident; ,

licensee resources are adequate and reasonably effective so that i

I

satisfactory performance with respect to operational safety and

construction quality is being achieved.

4

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.

The inspection findings for this evaluation period indicate,

overall, that the licensee's einergency preparedness program is

adequate to protect the health and safety of the public.

The licensee is considered to be in Performance Category 2 in

this area.

3. Board Recommendations -

a. Recommended NRC Actions

NRC attention should be maintained at riormal levels.

Attention should be directed to licensee action taken

toward correcting the call-out drill response and shift

augmentation response times.

b. Recommended Licensee Actions

The level of management attention to the implementation of

the emergency preparedness program should be increased to

ensure proper response to NRC identified concerns relating

to call-out drill response and shift augmentation response

times. The licensee should expedite correction of the

call-out drill response and shif t augmentation concern.

Management should review the distribution of onsite and

offsite emergency program areas of authority and

responsibilities.

G. Security

1. Analysis

The category of security relates to all activities whose purpose

it is to ensure the protection of the plant. Specifically, it !

covers all aspects of the security program including ancillary

'

efforts such as fitness for duty and access authorization

programs. Examples are: the licensee's overall management

involvement in establishing protective policies; designing

physical security systems; submitting the security plan and ,

implementing associated procedures; selecting, training,

equipping, and supervising personnel maintaining the hardware

thatsupportstheprogram;andauditIngandmeasuringthe

performance of the security program.

This area was inspected on a continuing basis by the NRC

resident inspectors and on a periodic basis by the NRC

Region-based inspectors. Four inspections were conducted by

Region-based NRC physical security inspectors during the

assessment period. Four violations were identified, two by the )

licensee. 1

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htcre was evidence of prior planning and assignment of

p iorities. Policies and procedures are wil stated,

ap repriately disseminated, and understandable. Decisionmaking

was sually at a level that ensured adequate management review.

The , w corporate structure, which includes a repositioning of

'

the Qu lity Assurance Department, is committed to continuing an

,

indepen ent and effective oversight of security related matters.

Manageme t reviews of identif: 4d security matters were timely,

thorough, nd technically sound. The initial review of security

incidents s improved and further examination for generic ,

significance has been enhanced. Records were generally

complete, wel maintained, and available. Rarely were

procedures and olicies violated. However, some cases of

l personnel failu have occurred and these appear to be

j associated with mporary employee hiring practices. Corrective

action on licensee identified violations was generally

effective.

f

4 A clear understanding security issues was demonstrated and

subsequent decisions r ected reasonable and prudent judgement

on the part of man . These kinds of judgements were also

demonstrated in the - in' nd Human Relations Departments

-

where security's a y forts, such as fitness for duty,

continual observation o m e's behavior, and the access

authorization programs we . ed.

_ There has been a major organiz on 1 restructuring of the

-

QualityAssurance(QA)Depar n. e changes have been too

recent to evaluate their impa e heretofore strong

'

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security oversight.' effort. Th . e concern that these

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changes will not provide the le 1, audit expertise previously <

h

provided. A review of these cha nd the quality of the ,

audits performed will be necessar he future. <

The licensee has been usually respon .e o NRC initiatives, but ,

there continues to be two long standing r ulatory issues i

attributable to the licensee. These are co trol room access and

alarm assessment capability. Technically so nd and acceptable

resolutions were proposed initially in most c ses, but

timeliness of resolution for these outstanding issues is slow.  !

t

After considerable discussion, the licensee agr d that their

CCTV system had degraded and proposed proper cor ctive actions.

One major violation concerning security personnel a tentiveness

'

was directly attributable to a member of the securit {

organization. It was promptly and effectively correc d. A few

minor procedural mistakes by security personnel have o urred,

but were not repetitive. These mistakes appear to be in icative i

4

of a need to enhance the selection process for temporary l

l security personnel and to be persistent in programmatic

training.

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There was evidence of prior planning and assignment of

priorities. Policies and procedures are well stated,

appropriately disseminated, and understandable. Decisionmaking

was usually at a level that ensured adequate management

review. The new corporate structure, which includes a

repositioning of the Quality Assurance Department, is connitted

to continuing an independent and effective oversight of

security-related matters. Management reviews of identified

secu.*ity matters were timely, thorough, and technically sound.  ;

The initial review of security incidents has improved and i

further examination for generic significance has been

enhanced. Records were generally complete, well maintained,

and available. Rarely were procedures and policies violated.

However, some cases of personnel failure have occurred and

these appear to be associated with temporary employee hiring

practices. Corrective action on licensee identified violations

was generally effective.

A clear understanding of security issues was demonstrated and

subsequent decisions reflected reasonable and prudent judgement

on the part of management. These kinds of judgements were also

demonstrated in the Training and Human Relations Departments

where security's ancillary. efforts, such as fitness for duty,

continual observation of employee's behavior, and the access

authorization programs were managed.

There has been a major organizational restructuring of the

Quality Assurance (QA) Department. The changes have been too

recent to evaluate their impact on the heretofore strong

security oversight effort. There is some concern that these

changes will not provide the level of audit expertise

previously provided. A review of these changes and the quality

of the audits performed will be necessary in the future.

The licensee has been usually responsive to NRC initiatives,

but there continues to be two long-standing regulatory issues

i in need of resolution. These are control room access and alarm

assessment capability. Technically sound and acceptable

resolutions were proposed initially in most cases, but

timeliness of resolution for these outstanding issues is slow,

s After considerable discussion, the licensee agreed that their

CCTV system had degraded and proposed proper corrective actions.

One major violation concerning security personnel attentiveness

J was directly attributable to a member of the security

organization. It was promptly and effectively corrected. A

!

few minor procedural mistakes by security personnel have

occurred, but were not repetitive. These mistakes appear to be

indicative of a need to enhance the selection process for

) temporary security personnel and to be persistent in

} progranmcic training.

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Occasional computer outage related events, construction / outage

worker misunderstandings of security requirements, and*

maintenance related activities were attributable causes to

violations. These events were identified and reported in a

timely manner.

Security organization positions were clearly identified.

Authority and responsibility was clearly defined. This included

the relationship with the rest of the corporate organization. A

new squad manning structure has allowed for training and

practice in squad response tactics. Temporary contract

personnel, while not meeting anticipated standards, have been

utilized to staff appropriate watchperson billets. However, the

employment practices used for these temporary watchpersons,

combined with their lower experience levels and abbreviated

training, appear to have had some adverse impact on the security

operation. It did accomplish the overall goal of providing

relief for the more experienced officers and to make them

available for more critical tasks.

2. Conclusions

The licensee appears to have an ample number of supervisors,

fully qualified security officers, and support personnel

assigned to the security department to comply with the several

security plans. With the exception of a few minor procedural

errors, the security force had operated at a high level of

performance. The licensee manroement's attention and

involvement with nuclear securt y is evident. Licensee

resources were appropriate and effective so that there was very '

good performance with respect to site physical and personnel

security.

i

The licensee is considered to be in Performance Categorf 1 in

this area. i

i 3. Board Recommendations

I

'

a. Recommended NRC Actions

The NRC inspection level of the security program should be

consistent with the minimum inspection program, with some

exceptions. Exceptions where a more expanded inspection

effort is recommended include: licensee measures to

enhance and maintain physical security systems; methods for

i

selecting, training, equipping, posting and supervising

security personnel; and changes to the QA function where

audits are performed to measure the performance of the

i security program rid its ancillary efforts.

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b. Recommended Licensee Actions

.

The licensee should continue to probe the causative factors

of security events for broader implications and adjust

programs, training, disciplinary actions, maintenance, and

n ineering responses appropriately. The organizational

a ustments made in the QA area should be closely monitored

to nsure that the high quality of the security oversight

pro am continues.

H. Outage

1. Analysis

The assessment this area includes all licensee and contractor

activities associ ted with major outages. It includes

refueling, outage ment,majorplantmodifications, repairs

or restoration to m. components and all post-outage startup

testing of systems p r to return to service.

This area was inspecte n a continuing basis by the NRC

resident inspectors riodically by NRC regional

inspectors. In addit n, spection was performed by a

safety system outa if ion inspection (SSOMI) team. The

inspections included r el g activities, outage management,

-

planning and scheduling, ta majorcomponents/ systems

repairs and modifi, cation, up testing.

~ '

~

The licensee had two major o ring this SALP period.

There was a refueling outage c lasted approximately 101 days

and an outage to replace leaki r ctor vessel 0-rings which

lasted approximately 16 days. fU ing outage activities

included replacement of Raychem s '

s, replacement of eroded

essential service water pipe, annu , spection of the diesel

generators, removal of heaters from torque valve operators,

' umber one seal,

replacement of reactor coolant pump

replacement of the trip mechanism sha s the reactor trip

breakers, replacement of the tube bundle i thejacketwater

heat exchanger for diesel generator "A", re rk of Valcor valve

operators, cleaning of condenser tubes and in ections for thin

wall pipes. There were numerous significant o erational events

which were attributable to causes under the lic see's control

in this functional area.

There were four violations identified in this funct onal area.

Two of the violations involved escalated enforcement action and

a proposed imposition of Civil Penalty. There were t o LERs

issued by the licensee in this functional area. The t LERs

were on events that resulted in violations being issued.

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.

k

b. Recommended Licensee Actions

d

The licensae should continue to probe the causative i

factors of security events for broader implications and

adjust programs, training, disciplinary actions, ,

maintenance, and engineering responses appropriately. The L

< organizational adjustments made in the QA area should be _'

1 closely monitored to ensure that the high quality of the '

security oversight program continues, i

!

j H. Outage [

a 1. Analysis  !

4

The assessment of this area. includes all licensee and

f contractor activities associated with major outages. It i

includes refueling, outage ' management, major plant

'

,

!

modifications, repairs or restoration to major components, and

! all post-outage startup testing of systems prior to return to j

service.

'

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4 i.

J This area was inspected'on a continuing basis by the NRC

i

resident inspectors, and periodically by NRC regional

inspectors. In addition, an inspection was performed by a

safety system outage modification inspection (550HI) team. The

4 inspections included refueling activities, outage management,

planning and scheduling, staffing, major components / systems

repairs and modification, and startup testing. '

! The licensee had three major outages during this SALP period.

There was a refueling outage which lasted approximately  ;

j 101 days, an outage to replace leaking reactor vessel 0-rings l

) which lasted approximately 10 days, and a generator / exciter

outage which lasted 16 days. Refueling outage activities ,

j included replacement of Raychem splices, replacement of eroded

essential service water pipe, annual inspection of the diesel I

i generators, removal of heaters from Limitorque valve operators, l

l replacement of reactor coolant pump "B" number one seal,

j replacement of the trip mechanism shafts on the reactor trip j

i breakers, replacement of the tube bundle in the jacket water 4

j heat exchanger for diesel generator "A", rework of Valcor valve l

operators, cleaning of condenser tubes, and inspections for  !

] thin wall pipes. There were numerous significant operational i

events which were attributable to causes under the licensee's j

control in this functional area,

j i

j There were four violations identified in this functional area,

i Two of the violations involved escalated enforcement action and

i a proposed imposition of Civil Penalty. There were two LERs

4

issued by the licensee in this functional area. The two LERs

l

were on events that resulted in violations being issued. l

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The two violations that resulted in escalated enforcement

involved examples of procedural control weaknesses that the NRC ,

considered significant. These weaknesses indicate mantgement

failed to provide an appropriate level of .unagement oversight

of safety-related activities. This is evidenced by the examples

sited below as well as other areas in this report. Management

oversight of outage activities was less than adequate as pointed

',

out by the six examples of failure to follow proceduras and foi

examples of inadequate procedures listed in the escalated

enforcement package. The NRC staff was concerned with the

licensee's lack of indepth analysis of these events. The

licensee's ability to perform root cause analysis and implement

timely and appropriate correr'.ive actions was a noted weakness.

-

During repair efforts on thin vall pipe due to erosion / corrosion

the licensee experienced some 'ifficulty. The licensee had on

site a contractor workforce knr..iledgeable and experienced in the

forming, fitting, rigging, and aligning uf heavy pipe. The

licensee decided to repair the thin wall pipe with their '

permanent maintenance workforce. The maintenance workforce was

not as experienced in this area as the contractor workforce.

1 This resulted in significant problems due to failure to follow

procedures, failure to follow work instructions, and failure to

, accomplish work activities by appropriately qualified personnel.

Maintenance management failed to realize the scope of work was

beyond their expertise.  !

!

The licensee was generally responsive to NRC concerns, however,

there was a lack of aggressive response to identified problens

prior to NRC involvement. The licensee's investigation of

outage related events indicated a less than aggressive approach

to the resolution of technical issues. The 0-ring outage, which

was the second major outage of the year, indicated that the

licensee failed to control the 0-ring cleanliness. The licensee

decided to restart the plant after the first outage with known

inner 0-ring leakage. ,

t

2. Conclusions c

. The licensee's ability to plan, manage, and maintain control over  ;

4

complex outage evolutions was inadequate and resulted in escalated  !

) enforcement action. The licensee apparently failed to believe in and

enforce strict procedural compliance. Aggressive management

4

involvement to address problems that occurred during the outage was ,

i

lacking, i

!

The licensee is considered to be in Performance Category 3 in this

I area.

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.

3. Board Recommendations

.

a. Recommended NRC Actions

Supplemental NRC inspections should be performed prior to

and during the next major outage.

b. Recommended Licensee Actions

The licensee should ensure that lessons learned from the

previous outages are identified and reviewed for program

improvements. The results of this review should be

incorporated into outage planning and control.

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 that confirm that the work was performed correctly.

The evaluation of the effectiveness of the quality assurance

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 evaluation of the ,

'

effectiveness and involvement of management in establishing and

assuring the effective implementation of the quality assurarce

program along with evaluation of 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.

In order to more clearly define the specific strengths and

weaknesses noted in this functional area, the analysis is

divided into three areas, as discussed below:

a. Engineering

,

'

'

This crea has been inspected on a routine basis by the NRC

J residerd inspecurs and by a SSOHI team inspection during

the assessseni, period.

'

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The staffing in the engineering urea is generally adequate

in terms of numbers, but it is weak in experience and

j training. Further, the weaknesses identified by the SSOMI

l

Inspection are indications that the communications between

the plant operating staff and the engineering organizations

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were poor. In one case, engineering made a change to the

cooling system for an electrical equipment room, @ich

required manual adjustment of a flow control valve to

adjust the temperature. Since the temperature in this room

was required to be maintained within a relatively narrow

range, a surveillance program to verify the temperature

should have been instituted but was not. As a consequence,

the qualified life or performance of the equipment may have

been affected.

In another instance, it appeared that the operating staff

failed to ask for engineering guidance when performing a

maintenance activity that resulted in a deep discharge of

the safety-related station batteries and disablement of the

vital AC buses at the same time. This in turn led to the

,

i

introduction of lake water into the secondary side of the

' steam generators.

The 550MI report includes a concern that appears to be

largely attributable to engineering since it involved a ,

failure to properly evaluate the effect of a temporary

modification. The modification involved application of a

l

clamp to keep a safety-related damper in the control room

emergency ventilation system open. Had actuation of the

'

damper been required, an operator would have had to remove

the clamp. The application of the clamp in such a manner

violated the intent of the Technical Specification for

system operability. There were also three LERs that were

at least in part attributable to engineering activities.

In each case, the LERs became necessary because there were

errors in design documents such as drawings,

specifications, and instrument set point data,

i b. Quality Assurance

This area has been inspected by both the NRC resident

inspectors and regional inspectors. In addition, the 550MI  ;

team inspected the areas of procurement, material storage,

and audit activities.

There were two violations in the areas of procurement and

of material receipt. Additionally, some of the problems in  ;

the management of the outage were related to QA. '

The licensee had received, accepted, and installed a

noncode part which formed a portion of the reactor coolant

system boundary. An audit after the plant restarted

disclosed this, and subsequent waiver to the code was

granted,

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The reactor vessel head 0-ring seals were not correctly

inspected prior to installation. Although this wa's not the

major contributor to the 0-ring leak, it showed a tendency '

for quality performance to be at pro forma level.

During the outage, there were problems with the weld

repairs to the essential service water systems. .These

problems included the issue of inappropriate welding

materials and welders making welds for which they were not

qualified. These problems were uncovered by quality

checks, but the investigation revealed that QA had missed

several opportunities to identify the problems earliec.

The licensee's vendor audit program did identify a problem

with the certification of fuses purchased from a supplier.

The licensee reported the facts to the NRC. Follow up

action by the NRC resulted in the issue of an Information

Notice.

The licensee had not conducted training in root cause

determination. Corrective actions tended to be focused on

specific events and did not often probe for the underlying

causes. For example, when a four-way valve on the MSIV

actuator failed, the original root cause determination was

not correct. The redesigned valve subsequently failed.

'

When incorrect fasteners were found in the charging pump

check valve, they were replaced. No determination was made

as to whether the problem was the fault of the fastener or '

the valve manufacturer.

c. Management and Administrative Controls

'

This area has been inspected on a routine basis by NRC

resident inspectors and regional inspectors.

During this SALP period, the licensee realized the ,

existence of problems with safety-related pipe wall  !

,

thinning. NRC had two basic concerns with this issue. The

first concern was that the short term operability

determination of the thin wall pipe was not technically J

sound in that it was made by plant management without input ,

from engineering. Management did not reassess system  !

'

operability even after engineering made the determination ,

that the pipe did not meet code requirements. Plant '

'

management comunications with engineering was not )

adequate. The second concern was with long term corrective i

actions. Plant management's narrow focus on the issue of l

short-term operability showed that their understanding of '

the issue was lacking. The question of generic application

'

of one thin wall pipe to other areas in the plant was not

addressed in a timely manner. It was not until these

!

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24

issues were raised by Nuclear Safety Engineering and the

Nuclear Safety Review Committee that appropriate corrective

tions were begun. The operational response to this

p blem was not timely and lacked thoroughness, The above

is ne example of a lack of management involvement in

ass ing quality. Other examples have been cited in other

SALP reas.  !

The enf rcement history in the area includes seven .

I violatio and no deviations. Four violations were related

to the ens ronmental qualification of equipment. Ten LERs  !

were issue by the licensee in this area. Eight of these '

LERs were re ated to control room ventilation isolation i

system (CRVIS actuations. Six of these were due to .

problems with e chlorine monitors. The licensee has made l

great strides i reducing the number of reportable events i

, due to CRVIS act  ; however, the reliability of the [

>

chlorine monitors still low. The improvement effort in ,

this area has be otracted. This has resulted in the  ;

! control room ope o longer trusting their chlorine l

! monitors.  !

r

2. Conclusions p

i

1

The assessment of this func n ea indicates that management l

j has not been effective in ti y lution of important issues.  ;

!

. Corporate management oversigh f t activities does not

always ensure adequate involve .t he quality and  ;

engineering or.gantiations in pla erations. When problems '

i .

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are identified by the quality and n neering organizations they

are not always acted upon in a tim anner, i

,

} The licensee is considered to be in Perf rmance Category 3 for

"

an overall rating of the SALP area of qua ity programs and l

administrative controls affecting quality.

.

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f

, 3. Board Recommendations j

!

L

i

a Recommended NRC Actions  ;

L

Supplemental inspection effort should be dev ed to this

area.  !

i b. Recommended Licensee Actions  !

Increased corporate management involvement in site l

activities is recommended. In particular, addition l

corporate management involvement is needed to ensure hat 1

1

proper engineering and QA involvement is maintained in all '

{ activities.

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,

'l

issues were raised by Nuclear Safety Engineering snd the

Nuclear Safety Review Committee that appropriate

corrective actions were begun. The operational response

to this problem was not timely and lacked thoroughness. l

The above is one example of a lack of management i

involvement in assuring quality. Other examples have been

cited in other SALP areas. 1

The enforcement history in the area includes seven .

violations and no deviations. Four violations were '

related to the environmental qualification of equipment. l

Thirteen LERs were issued by the licensee in this area. ,

, Eleven of these LERs were related to control room

ventilation isolation system (CRVIS) actuations. Nine of

,

these were due to problems with the chlorine monitors.

The licensee has made great strides in reducing the number

of reportable events due to CRVIS actuations; however, the

'

reliability of the chlorine monitors is still low. The

i

improvement effort in this area has been protracted. This '

has resulted in the control room operators no longer

l trusting their chlorine monitors.- ,

t

2. Conclusions

The assessment of this functional area indicates that

, management has not been effective in timely resolution of

important issues. Corporate management oversight of plant '

activities does not always ensure adequate involvement of the

quality and engineering organizations in plant operations.

When problems are identified by the quality and engineering

. organizations they are not always acted upon in a timely '

1 manner.

l

l'

The licensee is considered to be in Performance Category 3 for

an overall rating of the SALP area of quality programs and

administrative controls affecting quality.

,

3. Board Recomendations

a. Recomended NRC Actions

a

<

Supplemental inspection effort should be devoted to this

l area.

! b. Recomended Licensee Actions

1

a

Increased corporate management involvement in site I

4

activities is recomended. In particular, additional

corporate management involvement is needed to ensure that ,

I proper engineering and QA involvement is naintained in all l

l activities. I

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J. Licensing Activities . .

1. Analysis

During the present rating peri 6d, the 1(censee'5 Panagement

participated effectively in assuring the quality of submittals ,

forlicensingactionsandinresponsestoNRCstaffrequests.

The licensee s reviews were generally timely, thorough, and

technically sound. The licensee's participation was evident in

the ATWS Rule (10 CFR 50.62) submittal which demonstrated that .

'

l

the licensee appeared to adequately understand staff policies

! and be able to make decisions based on adequate management

l involvement. The licensee's submittal contained all of the

~

information that the staff requested for its review. An

appropriate level of management was present and significantly

involved at the review meeting held with the licensee, and the  ;

licensee's technical presentations were technically sound.

!

The licensee management was involved and responsive during the

staff's review of WCNOC's request to remove the fire protection  ;

program from the Technical Specifications. This licensing

-

action was the lead cause for generic technical specification

,

improvements and involved rapidly evolving staff requirements.

i

Because WCNOC involved its management in this review, they were

l

able to respond promptly to staff concerns to bring the review

'

to ccmpletion.

The WCNOC management has generally exhibited an adequate

understanding of the approach needed to resolve complex

technical issues involved in licensing activities. WCNOC's

June 16, 1987, submittal supporting analysis related to relaxed

i

outage time and increased surveillance intervals demonstrated a l

'

l clearunderstandingofthelicensingissuesinvolvedand

! followed the staff s guidance exactly as provided in the related

generic documentation.  ;

i

,

!

The quality

evaluation and levelsubmitted

summaries of detailpursuant

of the licensee's safety )(2)

to 10 CFR 50.59(b  !

I are not always adequate to permit the staff to conclude their

acceptability. In some cases these summaries only provide a ,

brief description of the change followed by a conclusive

statement that the change does not generate an unreviewed safety i

or environmental question; they do not provide a summary of the '

WCNOC safety evaluation that was prepared to support the change.

In review of WCNOC's submittal related to their inservice

testing program for pumps and valves, the staff met with the

,

licensee on September 8 and 9. During the meetings the licensee l

l agreed to revise their IST program in specific areas. However,

WCNOC did not make a number of revisions in their March 2, 1987,

Revision 6 resubmittal, as agreed to in the earlier meeting.

l

- . .__ _ _ - . . .

.- . ,

.

I

.

, ,

26

.

The failure to follow up on the agreed upon technical rasolution !

delayed the completion of the licensing action on the itservice l

testing program. l

The licensee had been generally responsive to NRC initiative -

during this rating period, with few longstanaing regulatory '

issues being attributable to the licensee. . l

<

On occasion, the licensee's response had not been adequate to

permit the staff to resolve the technical issue without the need

for additional interaction with the licensee. The staff's [

>

review of WCNOC's submittal related to the main steam line break :

j outside of containment issue required multiple requests for

additional information, and the licensee's responses to these

requests were not expeditious.

P

j The licensee reported 53 nonsecurity events to the NRC

1 operations center pursuant to 10 CFR 50.72. These events were

j almost always reported in a timely manner.

I

The licensee also submitted 49 nonsecurity Licensee Event ,

. Reports (LERs) during the reporting period, ihe LERs were well  !

'

written and almost always timely.

I

'

There have been 8 LERs during this reporting period that have '

been caused by malfunctions or spurious actuations of the  ;

chlorine monitors. These LERs follow up on 18 previous LERs

that have occurred since Wolf Creek was initially licensed.

This continuing series of LERs is indicative of a failure to

!j identify the root cause of these failures and an ineffectual

corrective action program for the chlorine monitor problems.

1 The plant has experienced seven unplanned scrams during this '

rating period. All of the scrams occurred during Cycle 2 which

ended in September 1987. There were three Safety System l

Actuations, no Sign'ficant Events and five Safety System  ;

I

Failures during this rating period, i

2. Conclusion

l

..

The licensee continues to maintain a competent, knowledgeable l

j licensing staff; however during this rating period there were '

'

i occasionalinstancesofIackoftimelyresponsetostaff  ;

requests and a decline in content of summaries of safety -

1 evaluations submitted by the licensee in response to l

{ 10 CFR 50.59. The licensee is considered to be in Performance i

Category 2 in this area.  ;

i

l

l

i l

t

i -

i

,

- - _- . -- -

9

. .

27

i

'

Board Recommendation

a. Recommended NRC Actions

hone l

.

b. Recommended Licensee Actions  !

e licensee should improve the quality of the safety l

e luation summaries submitted pursuant to 10 CFR 50.59 and

'

r

i sho ld improve the content of licensing submittals to  :

prec ude the need for staff requests for additional

infor tion that could have been foreseen by the licensee. ,

,

,

K. Training and Qual ication Effectiveness  :

1. Analysis

i

i

The assessment of s functional area includes all activities

f relating to the eff tiveness of the training / retraining and

-

qualifications progr ucted by the licensee's staff. This  ;

I area was inspectede ontinuing basis by the resident ,

,

inspectors. This a 150 the subject of an inspection  ;

-

which was performed i appraisal period to look into the  ;

, training of both the e d and nonlicensed staff. During the ,

4

appraisal period, lice ing nations were administered by

, the NRC to seven (7) rea r ator (RO) candidates and to

j seven (7) senior reactor candidates. Five (5) of the

.

!

) RO candidates ,and fix (6) candidates passed the

,.

-

examinations and were subseg n.t issued licenses. The  !

! licensee currently has 36 ind is who hold an SR0 license  !

j

and 15 individuals who have an cense. During the l

l

administration of the above exam ons, the examiners found i

i that the trainees had been adequa 1 informed of the I

significant events that had occurred d ing the week of

j October 18, 1987. The trainees had als been schooled on the

lessons learned from these events.

l

l The inspections in the operator requalifica on training area l

-

indicate that the management oversight in thi area h&s not been

sufficiently thorough. This is evidenced by: '

)

'

j The section of the procedure (ADM 06-224) o licensed

j operator requalification training which relax d a

, requirement of 10 CFR 55 without Commission ap oval.

l *

4

An operator who had failed the annual requalific ion  !'

examination and was therefore required to enter in o an

} accelerated requalification program was allowed to ntinue

,

to stand watch and perform watch standing duties pri to

{ his completion of the accelerated training.

!

l l

1

. .

27

3. Board Reconnendation

a. Recomended NRC Actions

None

b. Reconinended Licensee Actions

The licensee should improve the quality of the safety

evaluation sunnaries submitted pursuant to 10 CFR 50.59

and should improve the content of licensing submittals to

preclude the need for staff requests for additional

information that could have been foreseen by the licensee.

K. Training and Qualification Effectiveness

1. Analysis

~

The assessment of this functional area includes all activities

relating to the effectiveness of the training / retraining and

qualifications program conducted by the licensee's staff. This

area was inspected on a continuing basis by the resident

inspectors. This area was also the subject of an inspection

which was performed during the appraisal period to look into

the training of both the licensed and nonlicensed staff.

During the appraisal period, licensing examinations were

administered by the NRC to six (6) reactor operator (RO)

candidates and to seven (7) senior reactor operator

candidates. Four(4)oftheR0candidatesandseven(7)ofthe

SRO candidates passed the examinations and were subsequently

issued licent 1. The licensee currently has 34 individuals who

hold an SRO cense and 17 individuals who have an R0 license.

During the aaministration of the above examinations, the

examiners found that the trainees had been adequately informed

of the significant events that had occurred during the week of

October 18, 1987. The trainees had also baen schooled on the

lessons learned from these events.

The inspections in the operator requalification training area

indicate that the management oversight in this area has not

been sufficiently thorough. This is evidenced by:

• The section of the procedure (ADM 06-224) on licensed

operator requalification training which relaxed a

requirement of 10 CFR 55 without Coninission approval.

An operator who had failed the annual requalification

examination and was therefore required to enter into an

accelerated requalification program was allowed to

continue to stend watch and perform watchstanding duties

prior to his completion of the accelerated training.

. .

. .

28

The required reactivity manipulations had not been

completed in the 1985-1986 requalification cycle for at

least six licensed individuals. The correction of this

i problem had not been formally addressed, but an informal

effort by the simulator instructors is to track the ,

performance of the manipulations by each licensed  ;

individual.

4

'

During 1986, at least nine licensed individuals had failed

, to review all of the errergency and off-normal procedures as

a required by the requalification program. The licensee ,

revised the appropriate procedure to specify the off-normal

and emergency procedures to be reviewed. The procedures

i

-

requested after the revision were also incomplete and the

procedure had to be further revised at the prompting of the i

NRC inspector.

The licensee had not provided procedures for implementing

the 10 CFR 55 rule change issued by the NRC on May 27,

1987.

j The above examples are indicators that the training department

i

'

arrangement had not provided the attention to detail necessary

to assure adequate oversight of this area.

There has also been evidence of inattention to detail on the

part of the training staff. Examples of this are:

minor uncorrected errors in the lesson plans that were

reviewed;

' *

failure to have lectures scheduled for 10 CFR Parts 2, 21,

50, and 55 in the operator requalification program;

a

failure to revise a procedure tc reflect a new requirement I

,

instituted by a rule change; and ,

-

• '

4

failure to delete a procedure requirement which was dropped

i by a rule change.

No deficiencies were identified in the area of training of the i

j nonlicensed staff. The procedures and policies in this area  ;

were adequately stated and understood. Training records in this

area were generally complete and well maintained. ,

I t

l 2. Conclusions

l

The initial training of licensed operators and the training of I

the nonlicensed staff is effectively controlled and the 1

licensee's performance in licensing examinations has been good. l

The area of requalification training for licensed operators has

,  :

i

!

'

\

. '

.

_

i . .

29

.

suffered from an apparent lack of management oversight and

inattention to detail on the part of the training staff, The

licensee is considered to be in Perforniance Category 2 in this

area.

l 3. Board Recommendations

-

! a. Recommended NRC Actions

The NRC inspection effort in this area should continue at

the level prescribed by the basic inspection program,

b. Recommended Licensee Action

The licensee should further emphasize the need for

oversight of operator requalification training and the need

for the training staff to be more attentive to details in

the performance of their activities. Licensee management

should continue their oversight and support of the training

of the nonlicensed staff.

,

V. Supporting Data and Summaries

A. Licensee Activitiej

Major Outages

l

. The unit was shut down on April 19, 1987. The cause was an

'

inadvertent trip due to control rod logic card failures. The

l outage duration was 13.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

. The unit was shut down on April 23, 1987. The cause was an

I inadvertent trip due to control rod logic card failures. The

outage duration was 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />.

. The unit was shut down on May 28, 1987. The cause was an

inadvertent trip due to a loss of power to the main turbine l

electro-hydraulic controi system. The outage duration was

22.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

. The unit was shut down on June 29, 1987. The cause was an

inadvertent trip due to a loss of a main feedwater pump. The  ;

outage duration was 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />. l

. The unit was shut down from July 20, 1987, to July 26, 1987. '

The cause was an inadvertent trip due to a loss of a main

feedwater pump. The outage was extended to repair a containment I

cooling fan. The outage duration was 129.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

.I i

l 1

. _ -. _. .

.

. .

I

30 l

1

The unit was shut down on September 10, 1987. The cause was an :

inadvertent trip due to a failure of a main transmission line, j

The outage duration was 33.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

. e unit was shut down on September 27, 1987. The cause was an !

ii dvertent trip due to a mispositioned rod control switch. The  ;

lic see decided to remain down and enter refueling o.utage II i

i earl The outage duration due to the inadvertent trip was  !

> 93.5 h urs. The refueling outage duration was 2,418.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />, j

'

i

. The unit s shut down on January 21, 1988. The cause was a  ;

j. manual shu own to replace failed reactor vessel 0-rings. The  !

t outage durat on was 379.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. During startup following this  !

4 -

outage, two t bine trips without reactor trips occurred. The i

duration of eac of se two outages was 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. l

t

Inspection Activities

) B.

NRC inspection activity his SALP evaluation period included l

] 49 inspections performe i 31 direct inspection aanhours

expended. These inspe s ed team inspections of the

,

equipment qualification p ra d a SSONI. This inspection effort I

i represents an approximate 5 r increase over the previous SALP i

j period. l

J

l

Table 1 provides a tabulation of RC, nforcement activity for each i

'

-

functional area evaluated. Table pt vides a listing of inspection

i findings in each P LP category.

'

~

InvestigationsandAllebationsReview

'

-

C.

) There was one investigative activity conducte during this assessment

period. The results have not been formally iss d yet.

!

.

'

!

D. Escalated Enforcement Actions

j 1. Civil Penalties  !

1 l

1 A Notice of Violation and Proposed Imposition of Ci il Penalty '

i was issued on March 17, 1988. A $100,000 civil pena ty was

.

proposed for two Severity III violations involving a failure to t

i follow procedure and a failure to have appropriate proc ures.  !

2. Enforcement Orders

i '

'

None

I

!

I

i

1

4

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

.-

.

L

, .

,

30

i

'

. The unit was shut down on September 10, 1987. The cause was an

inadvertent trip due to a failure of a main transmission line. ,

. The outage duration was 33.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

. The unit was shut down on September 27, 1987. The cause was an  ;

inadvertent trip due to a mispositioned rod control switch. l

3

The licensee decided to remain down and enter refueling I

outage II early. The outage duration due to the inadvertent

j trip was 93.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The refueling outage duration was

, 2,418.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ,

L  ;

-

. The unit was shut down on January 21, 1988. The cause was a -

. manual shutdown to replace failed reactor vessel 0-rings.

l During startup following this outage, generator / exciter

'

problems were experienced and two turbine trips without reactor

i trips occurred.

.

I

l B. Inspection Activities

e

j NRC inspection activity during this SALP evaluation period included

49 inspections perforned with 6031 direct inspection manhours

expended. These inspections included team inspections of the

j equipment qualification program and a SSOMI. This inspection effort

. represer.ts an approximate 50 percent increaso over the previous SALP

period.

l

'

Table 1 provides a tabulation of NRC enforcement activity for each

functional area evaluated. Table 2 provides a listing of inspection ,

j findings in each SALP category.  ;

,

! C. Investigations and Allegations Review ,

i

j There was one investigative activity conducted during this

assessrmnt period. The results have not been formally issued yet. t

1

0. Escalated Enforcement Actions

1. Civil Penalties

l l

l A Notice of Violation and Proposed Imposition of Civil Penalty l

j was issued on March 17, 1988. A $100,000 civil penalty was i

proposed for two Severity III violations involving a failure to

i

follow procedure and a failure to have appropriate procedures. [

] i

j 2. Enforcement Orders

i

3

j None j

1

)

.

1  !

4  !

i l

!

'

-

.. .

'

. .

'

. .

31

E. Manaaecent Conferences Held During Assessment Period

.

1. Conf.rences

i

'

A management meeting was held on October 21 1987, to discuss

theeventswhichoccurredduringtherefuelIngoutage. An  :

enforcement conference was held on January 11, 1988, to discuss

violations which had occurred during the refueling outage,

i 2. Confirmation of Action Letters

Nont

i., Review of Licensee Event Reports and 10 CFR Part 21 Reports

Submitted By the Licensee

]

I

1. Licensee Event Reports

i

'

The SALP Board reviewed the LERs for the periori March 1,1987,

through March 31, 1988. This review included the LERs listed by

.i SALP category in Table 3.

2. Part 21 Reports

[

There were no 10 CFR Part 21 reports submitted by the licansee j

during this SALP assessment period.  ;

l

.

4 I

j  !

!

i

'

4

i

i  !

}

. .

I

f

i

,

i

'

i

j

.

!

'

!

l'  !

. .

Table 1

Enforcament Activity

FUNCTIONAL AREAS NUMBER OF VIOLAT.10NS

IN E>'.CH LEVEL

\ DEFICIENCIES / DEVIATIONS V IV III

A. Plant Operations 1

B. Ra ological Controls 0/1 1 4

C. Mainte ce 2

D. Surveillanc 2

E. Fire Protection 1

F. Emergency Preparedne 1/0 2 1

G. Security - 4

'

H. Outages 1 1 2

I. Quality Programt and

Administrative

h, g 1 9

'

Controls Affecting

Quality

J. L-icensing Activities

'

K, Training and -

'." 2

-

Qualification

Effectiveness

Total 1/1 7 25 2

i

l

4

i

l

l

. .

l

Table I

Enforcement Activity-

l

FUNCTIONAL AREAS NUMBER OF VIOLATIONS

'

IN EACH LEVEL

l

l DEFICIENCIES / DEVIATIONS V IV III

1

1

'

A. Plant Operations 1

B. Radiological Controis 0/1 1 4

i

C. Maintenance 2

D. Surveillance 2 '

E. Fire Protection 1

F. Emergency Preparedness 1/0 2 1

G. Security 4

t

H. Outages 1 1 2

I, Quality Programs and 1 7

Administrative

Controls Affecting

Quality

J. Licensing Activities

1

K. Training and Qualification 2

Effectiveness  :

,

TOTAL 1/1 7 23 2

l

l

1

c

. .

'

. .

Table 2

ENFORCEMENT ACTIVITY

= i

TABULATION OF VIOLATIONS, DEVIATIONS, AND

EMERGENCY PREPAREDNESS DEFICIENIES t

PERFORMAN CATEGORY

'

A. Plant Operations

Violations

. Failure to enter Technical Specification 3.0.3 when both trains

of CRVIS were inoperable. (Severity Level IV, 8720-01) ,

.

Deviations

>

. None

B. Ra.hological Controls

Violations f

!

. Failure to properly control, store and protect quality records.  ;

(Severity Level V, 8708-01) l

. Radiation Protection Manager not fully qualified. (Severity

Level IV, 6712-01)

. Failure to properly evaluate radiologichl surveys of two  !

contaminated persons. (Severity Level IV, 8728-01) {

. Unauthorized disposal of contaminated material.- (Severity l

Level IV, 8736-01)  ;

. Failure to lock high radiation door. (Severity level IV, f

8809-01)

Deviations

. Repeated failure to implement a continuous airborne monitoring

program. (8712-02)

C. Maintenance

Violations

, Failure to comply with TS 4.0.5 by not obtaining a relief request

from NRC, (Severity Level IV, 8715-01)

. Three examples of failure to follow procedure. (Severity

Level IV, 8807-38)

. -- - . . . -_ - _ __ - -_ -. . - -._ .

,

-

. .  !

-

. -

l

2

f

-

i

a  !

Deviations j

!

.

j None

.

f

I  ;

i D. Surveillance t

,

.

,

Violations

i . Failure to demonstrate automatic isolation of the containment

i purge pathway. (Severity Level IV, 8715-02)

i

. Failure to alternate starting locations for the motor driven fire [

pump. (Severity Level IV, 8722-01)  ;

i

Deviations l

l None

.

(

! t Fire Protsetion

l Violations  !

.  ;

) . Fire door inoperable by being blocked open. (Severity Level IV, l

j 8706-01)  ;

l i

, . ,

4  :

j Deviations  !

!

. None l

i

l F. Emergency Preparedness  ;

! >

l Violations l

i ,

'

l . Failure to document a communication test. (Severity Level V,

l 8714-01)

.

l . During an unannounced call-out drill, the communicators could not

j be reached. (Severity Level IV, 8714-02)  !

t i

i

. Repeat violation of a failure to meet call-out time limits. l

i (Severity Level V, 8812-01)

1

l Deviations -

i {

j . None

[

I

!

i

I -

I

.

I

- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ __-_____--__________

_ _ _ _ _ _ _ _ _ _ __

. ..

-

. .

3

.

Deficiencies

. During an emergency plan exercise, an incorrect classification

was made. (8721-01)

G. Security

Violations *

. Failure to follow compensatory procedures. (Severity Level IV,

8716-01)

. Inadequate compensatory measures. (Severity Level IV, 8723-01)

.' Failure to maintain assessment aids. (Severity Level IV,

8734-01)

. Failure to maintain control of security badge. (Severity

Level IV, 8805-01) ,

Deviations  ;

i

. None

l

H. Outages

Violations

. Six examples of failure to follow procedures. (Severity

Level III, 8731-A)

. Four examples of failure to have appropriate procedures.

(Severity Level III, 8731-B)

. Two examples of inadequate procedures. (Severity Level IV,

8806-01)

{

. Failure to make inservice test log entri'ss. (Severity Level V,

8811-02)

Deviations

. None

I. Quality Programs

Violations

. Failure to have qualified electrical splices. (Severity

Level IV, 8724-01)

_

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

.

j i .

4

l

i t

,

a

I Connection boxes mounted below post-accident containment water .

l level. (Severity Level IV, 8724-02) .

l

. pace heaters operating in motor operated valves. (Severity f

vel-IV,8724-03)  !

.

a

1 . Use f unqualified terminal blocks. (Severity Level IV, 8724-04) l

l }

.

Failur to evaluate temporary modification. (Severity Level V, j

8801-01  :

,

!i . Inadequate cceptance criteria for reactor vessel 0 rings.  :

1 (Severity Le el IV, 8804-01)  ;

,

i

. .

Purchase order alle to specify code requirements. (Severity  ;

4

Level IV, 8815-0  ;

i

f

. . Purchase request di document Spec levels. (Severity i

Level IV,8815-02)  !

!

t l

Unqualified code a t. (Severity Level IV, 8815-03)  ;

l .

{ Deviations f

j i

q

, None j

.

.

4

l J. Licensing Activities .

I

!

'

. .

Violations .

-

-

l

,

l

. None  ;

'

i

Deviations  ;

- i

. None j

j K. Training and Qualification Effectiveness

! Violations

j

. Failure to provide health physics retraining. (ieve ty Level V, ,

B

8717-01) l

Failuit tt, maintain health physics training records. (Se erity

l .

Level V, 9717-02)

4

I l

Deviations I

l

. None j

l

'

i

!

!

l I

!

'

I

!  !

. .

4

. Connection boxes mounted below postaccident containtnent water

level. (Severity Level IV, 8724-02)

. Space heaters operating in motor operated valves. (Saverity

Level IV, 8724-03)

! . Use of unqualified terminal blocks. (Severity Level V, 8801-01) i

- Failure to evaluate temporary modification. (Severity Level V.

8801-01)

,

. Inadequate acceptance criteria for reactor vestel 0-rings.

3

Severity Level IV, 8804-01) ,

. Failure of procurement program with three examples. (Severity

Level IV, 8815-01)

I Deviations

4 . None

. J. Licensing Activities

, Violations

. Noiie

I

i Deviations

. None

. 1

I K. Training an'. Qualification Effectiveness

Violattens

~

l

. Fai' e to provide health physics retraining. (Severity l

Level V, 8717-01)

!

. Failure to maintain health physics training records. (Severity !

,

Level V, 8717-02)  !

Deviations l

. None

1

.

_ _ _ _ _ _ _ _ _ _ -_ .___ ___ - - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _

. *<

-

. .

,

Table 3

OPERATIONAL EVENTS

TABULATION OF LICEN5EE EVENT REPORTS

=

PERFORMAN CATEGORY

A. Plant Operations

. Error while placing block switch in ' permit' results in aux,

feedwater actuation. (87-018) .

. Failure to communicate allowed an open door creating a pressure

boundary breach. (87-034)

. Errors result in loss of power to control rod moveable gripper

coils which causes a reactor trip. (87-041)

. Error leads to Hi-Hi 5/G 1evel resulting in feed isolation

signal. (87-042)

B. Radiological Controls

.

Inadvertent

without release of secondary)

prior sampling. (87-036 liquid waste monitor tank

. Inadequate control results in loss of licensed material.

(87-056)

C. Maintenance

. Logic cabinet cards overheated causing reactor trip. (87-017)

. Containment purge isolation due to signal spike on radiation

monitor. (87-019)

. Reactor trip caused by loss of power to main turbine

electro-hydraulic control system. (87-022) l

!

. Reactor trip resulting from personnel error in not correctly ,

tightening instrument sensing lines. (87-027) l

!

. Potential transformer failure causes partial loss of offsite ,

power and reactor trip. (87-030)

. Inoperable containment isolation valve due to incomplete

retesting following maintenance. (87-033)

. High Voltage transmission line failure causes generator

trip / reactor trip. (87-037)

. Accidental mispositioning of breaker switch causes inoperability

of one power operated relief valve. (87-039)

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. Omission of snubber from inspection procedure. (87-044)  ;

.

. Inadequate hydrostatic pressure tests due to procedural

inadequacy. (87-045) j

. Containment purge isolation caused by moisture induced corrosion i

of an electrical connector. (87-054) ,

'

D. Surveillance

. TS violation caused by missed surveillance procedure. (87-014)  !

. Shaft seal on containment air lock failed during testing causing ,

, total leakage above allowable. (87-023) l

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Containment purge isolation due to personnel error during

'

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I radiation monitor testing. (87-025)

>

. Late performance of spent fuel building vent tritium analysis.  !

(87-026) j

. Inoperable Class 1E batteries dLe to inadequate post-test review C

of surveillance test. (87-028)  !

I

. Required testing deleted from sureeillance procedures. (87-029)

. Failure to properly verify operability of fire pumps due to

procedural inadequacy. (87-038)  ;

,

. Nonconservative error in containment purge radiation monitoring I

setpoint. (87-040)  !

!

. Surveillance of power range low setpoint & P 8, P-9, and P-10 l

interlocks not performed properly. (87-043) {

. Containment isolation valve failed during testing causing total

path leakage to be above allowable. (87-050) g

i

. Procedural deficiency causes two feedwater isolations & an an aux  !

feed actuation. (87-051) {

t

. Procedural inadequacy resulting in TS violation. (87-060) l

E. Fire Protection f

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. Four fire dampers not actuated due to drawing error. (87 013) ,

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Failure to maintain fire watch as required by TS. (87-016)

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. Hourly fire watch performed late due to personnel I

error / individual overlooked one impairment. (87-021) j

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-_ _ . .-

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Spent fuel pool heat exchanger room doors not 3-hour fire rg,ted.

> (87-031)

.

Failure to fully understand the requirements causes TS violation

l

for hourly rather than continuous fire watches. (87 057)

! . Wired glass insert discovered in fire door causes loss of 3-hour

fire rating. (87-059

F. Emergency Preparedness

. None

G. Security

j

j .

Unauthorized vital area entry. (87-046)

i . Vital door unsecured. (87-047)

j . Security officer inattentive to duty. (87-055)

H. Outages

j

. Improper maintenance causes fatality. (87-048)

l . Low battery bus voltage. (87-049)

I, Quality Programs and Administrative Controls Affecting Quality

I

i . CRVIS caused by chlorine monitor spike. (87-012)

l

CRVIS caused by paper tape bunching up on chlorine monitor,

l .

j (87-015)

l . CRVIS caused by paper tape breaking on chlorine monitor.

(87-020)

)

.

. FA-CRVIS caused by loss of power to chlorine monitor because of

faulty sample pump. (87-024)

J

) . CRVIS caused by paper tape breaking on chlorine monitor.

4 (87-032)

1

j .

CRVIS - two events caused by malfunctions of the chlorine

!, monitors. (87-035)

I .

Instrument termination splices installed which fail to meet

environmental qualification requirements. (87-052)

l

CRVIS caused by paper tape bunching up on chlorine monitor.

)j

.

.

(87-053)

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)

_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ __________ _________ __- _ ___ ______________ _ _ . . ______________ - __ __________________ _

.

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4

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.

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,' . TS Violation, due to error in design document. (87-058)

. Radiation monitor spike causes fuel building ventilation

isolation. (88-001)

. Probable transient in power supply for radiation monitor causes

containment purge isolation. (88-002) i

. CRVIS from chloriria monitor spike. (88-003)

. CRVIS from chlorine monitor spike. (88-005)

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SALP MEETING SUMMARY

Date: July 20, 1988

Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)

Facility: Wolf Creek Generating Station (WCGS)

License: NPF-42

Docket: 50-482

"

SUBJECT: SALP MEETING AT WCGS

On July 20, 1988, the Regional Administrator, NRC Region IV, members of the

Region IV staff, and NRR representatives met with representatives in an open

meeting at WCGS to discuss the SALP Board Report covering the period March 1,

1987, through March 31, 1988. The NRC material presented at the meeting and a

list of attendees are attached. The meeting was held at the request of NRC

Region IV.

,

! After opening remarks by the Regional Administrator, the Director, Division of

Reactor projects, presented each of the functional areas evaluated in the SALP

Board Report using Attachment 1 as an outline. The WCNOC Senior Vice

President and other licensee representatives discussed planned actions to

improve performance and/or respond to NRC recommendations in each of the SALP  ;

categories. [

,

Attachments: (

, 1. NRC Material Presented at Meeting

2. Attendance List .

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INTRODUCTION

ROBERT D. MARTIN, EGIONAL

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ADMINISTRATOR NRC EGION IV

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SALP PESENTATION J0E CALLAN, DIECTOR, DIVISION OF

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EACTOR PROJECTS, NRC EGION IV  !

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i WOLF CEEK NUCLEAR OERATING LICENSEE MANAGEENT AND STAFF l,

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CORKRATION ESKitSE AND l

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COtENTS  !

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1 CLOSING PEXARKS ROBERT D. MARTIN  !

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j LNilED STATES NUCLEAR EGULATORY C0ft!SS10fi l

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i SYSTRATIC ASSES 9ENT OF LICENSEE PERF0WANCE l

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WDLF CREEK NUCLEAR OPERATING CORPORA 110N l

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WOLF CEEK GEERATING STATION

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j MARCH 1, 1987 - MARCH 31, 1988

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W)LF CEEK GEERAT!?$ STATION

JULY 20, 1988

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SALP PROGRAM OPJECTI\ES

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IMPROVE LICENSEE PERFORMANCE

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PROVIDE A PASIS FOR ALLOCATION OF

NRC ESOURCES

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IMPROVE NRC EGULATORY PROC.W1

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i ERFORMANT ANALYSIS AREAS FOR WOLF CRFFK EERATING STATION

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A. PLANTOERATIONS l

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l C. MAINTENANCE  !

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i D. SURWILLANCE  !

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I E. FIRE PROTECTION  !

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F. EERGENCY PREPAREDESS

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G. SECURITY l

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I H. OUTAGES  !

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i 1. QUALITY PROGRAMS AND  ;

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ADMINISTRATl W CONTROLS  !

AFFECTING QUALITY

j J. LICENSINGACTIVITIES  !

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K. TRAINING AND OUALIFICATION

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FUNCTIONAL AEA KRF0mANCE CATEGORY

CATEGORY 1

EDUCED NRC ATTENTION PAY E APPROPRIATE, LICENSEE

MANACDENT ATTENTION AND INVOL\9ENT AE AGGRESSIVE AND

,

ORIENTED TOWARD NUCLEAR SAETY: LIENSEE ESOURCES AE #ftE

AND EFFECTlWLY USED S0 THAT A HIGH LEWL OF ERFOR%NE

WITH ESECT TO OPERATIONAL SAFETY IS EING ACHIEVED.

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} CATEGORY 2 [

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NRC ATTENTION SHOULD E MAINTAIED AT NORMAL LEWLS,

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AND AE CONCERNED WITH NUCLEAR SAFETY, LICENEE ESCORCES

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) AE AECUATE AND AE EASONABLY EFFECTlW SO THAT l

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j SATISFACTORY ERF0W#CE WITH ESECT TO OERATIONAL SAFETY l

l IS EING ACHIEED, [

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CATEGORY 3 l

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BOTH NRC AND LICENSEE ATTENTION SHOULD E INCEASED. LIENSEE  !

MANAGDENT ATTENTION OR ltWOLWeiT IS ACCEPTABLE AND CONSIDERS

NUCLEAR SAFETY, BUT EAKESSES AE EVIDENT: LICENSEE ES00RES

.

APEAR TO E STRAltED OR NOT EFFECTlWLY USED S0 THAT MINIMALLY

SATISFACTORY ERF0WAE WITH ESPECT TO OERATIONAL SAFETY IS [

EING ACHIEWD.  !

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EVALllt. TION CRITERIA l

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1. MANAGEENT INVOL\ DENT AND CONTROL IN ASSURING QUALITY

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l 2. APPROACH TO ESOLUTION OF TECHNICAL ISSLES Ff01 A SAFETY j

l STANDPOINT  !

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3. ESPONSl\0ESS TO NRC INITI ATlWS

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i '4 . ENFORCDENT HISTORY

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5. OPERATIONAL EWNTS (INCLUDING ESPONSE T0, ANALYSIS OF,  ;

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j AND CORECTlW ACTIONS FOR) f

I 6. STAFFING (INCLUDING f%%GEENT) l

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.SIBENES  !

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FIE PROTECTION AND SECLRITY AE STRONG AEAS j

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(EE OF PROCEDURES IN OPERAi!0NS WAS MIH IPPROVED TOWARD TE

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END OF ERIOD

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ERSONEL RADIATION EXPOSURE HISTORY HAS BEEN ETTER

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THAN TE NATIONAL AVERAGE FOR FHRs (LESS THAN 50% OF AWRAE)

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PAJOR MANAGEENT CHANGES MADE IN TE MAINTENANCE AEA APPEAR  :

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TO E POSITlW ,

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EAKESSES i

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ACTUAL OERALL DECLIE OR DECLINING TEND IN TE

ERF0 WANCE FOR T E FOLLOWING FUNCTIONAL AREAS:  !

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PLANTOKRATIONS I

RADIOLOGICALCONTROLS

PAINTENANCE  ;

Ll&NSING ACTIVITIES

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TRAINING AND QUALIFICATION EFFECTlW. NESS l

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MIN! PALLY SATISFACTORY ERF0WANCE IN TE i

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AREAS OF QUAllTY F90 GRAMS AND OUTA T S l

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LACK OF EFFECTlW C00 ERAT 10N AND COORDINATION j

ETEEN TE PLANT OPERATIONS STAFF AND TE l

vARiOUS TtcaCAt sum cR0ueS  !

TRA!NING IN ROOT CAUSE DETEmlNATIONS

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PLANT OKRATIONS

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CATEGORY 2

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TERE IS CONTINtED STRONG MANAGDENT SUPPORT FOR

!

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TE COLLEGE DEGEE PROGRAM FOR OPERATIONS PERSONNEL  !

,

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l USE OF PROCEDUES IN OEPATIONS WAS MUCH IEROWD I

TOWARD TK END OF TE SALP KRIOD l

i

j OKRATIONS INTERFACE WITH OTER DEPARTENTS IS A l

1 TOTED EAKtESS  !

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AT TIES, OKRATORS Fall TO PAY ATTENTION TO DETAIL  !

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REC 0tENDFD LIEfM A{llg l

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! LICENSEE MANACBENT SHOULD ENSURE THAT TEE IS AN

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.' ADEQUATE AND PROPT 00AllTY ASSURANCE, NUCLEAR SAFETY i

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, ENGlEERING, AND ENGlEERING INVOLWENT IN OPERATIONAL  !

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BENTS AND IN DE ECmlCAL WET!0N TO SAFETY ISSLES,  ;

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RADIOLOGICAL CONTROLS

CATEGORY 2

,

TE LICEfEE'S KRSON'EL RADIATION EXPOSUE HISTORY HAS BEEN BETTER

!

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(LESS THAN OE-RALF) THAN TK NATIONAL AW. RAGE FOR FVRS

i OERALL KRFORMANCE INDICATED A DECEASE IN EFFECTIESS OWR TE  ;

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4

PEVIOUS ASSES 9ENT KR100

f

i  !

f INADEQUATE F#iAGEENT ATTENTION TO NRC CONCERNS IS DOONSTRATED BY (

TE LACK OF ESOLUTION TO TE CONCERNS NOTED DURING TE PEVIOUS  !

)! -

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ASSES 9fNT KRIOD: l

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LACK OF STE#4 EfERATOR MDCX UP TRAINING

f

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LACK OF EALTH PHYSICS SUKRVISORY KRS0ffEL PESENCE IN  !

! wm

!

EC0tENnFT) LIERTF ACTION .

i

EALTH FWSICS SLFERVISORY KRS0ffEL SHOULD SEND M)E TIE IN TE

RAD 10 LOGICALLY CONTROLLED AEAS EVALUATING #0 OBSERVING ONGOING  !

i

RADIATION PROTECTION WORK ACTIVITIES TO ENSUE C&PLIANCE WITH

]

j STATION PFOCEDUES,

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l PANAGEENT SHOULD TAKE ACTION TO PROVIDE TRAINING TO TEONICIANS TO

)

,

ENHANCE PROCEDURAL C&PLIME.

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PAINTENANCE l

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GE@RY 2

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TOWARD TE END OF TE SALP KRIOD, PAJOR MANAGDENT CHANGES HAVE EEN l

} IWLEEfffED, AND APEAR TO HAW SIGNIFICANTLY STENGTEED TE  !

PAINTENM AREA

1  :

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3 FANACHENT HAS SHOWN STRONG SUPPORT FOR TE PAINTENANCE PROGRM, BUT  !

' '

IWLEE? RATION OF THIS PROGRAM WAS NOT ALWAYS ADEQUATELY CARRIED OUT

\ 1

L

i ESCALATED ENFORCEENT ACTION REWALED SIGNIFICANT PROBLEMS WITHIN TK

-

PAINTENANCEORGANIZATION, INCLUDING: l

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WOFERS FAILING TO FOLLOW PROCEDUES

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INAKCUATE PROCEDUES  !

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l If&DE00 ATE C0hTROL OWR SECIAL PROCESSES j

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j CfdRALL BEAKDOWN OF PANAGEENT OWRSIGHT OF MAINTENANCE

I

ACTIVITIES DURING TE FALL EFLEllNG OUTAGE

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EC0tEhTFD LIERW ACTION

i I

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j TK LIENSEE SHOULD FOLLOW THROUGH AND ASSESS TE EFFECTlWESS OF (

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TEIR CORECTIVd ACTICtG. AND CONTlhE TE INCEASED EMEASIS ON

I

!

PFOCEDURALCOPPLIANCE.

! i

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_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - __- _ _-___________ ___

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SURVEILLANT l

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j ADE00 ATE PROGRNi EXISTS FOR SCEDULING At0 TRACKit4G OF SURWILLMEE

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! ACTIVITIES  !

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ENFORCDENT AND EPORTING HISTORY INDICATE ITRO\9ENT OVER TE  !

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i PEVIOUS ASSES 9ENT ERIOD, RTT ERAT PROCEDURAL AND ERSONNEL j

ERRORS INDICATE THAT ADDITIONAL PANAGDENT INVOLN9ENT IS EEIED  !

) I

PROCEDURES IN SCPE CASES DID NOT ADDESS ALL TECHNICAL SKCIFICATION j

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SURVE!LLANCE EQUIRDENTS l

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l ECCitENrrn LIENTF ACTIONS ,

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TE LIENTE IS ENC 00RAED TO KRFORM INDEPTH EVIEW OF TE TECmlCAL

, SKCIFICATION SURNEILLANE EQUIRDENTS MD ENSUE THAT TE  :

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SUR\EILLA'CE PROEDURES ADDESS TESE EQUIEENTS, j

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ADDITIONAL PAVEENT lit.0LMENT WITH SURWILLANCE ACTIVITIES IS

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EN000 RAGED,

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, FIFE PROTECTI@ ,

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J CATEGORY 1  ;

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SIGNIFICANT IPPROMENT IN TE FIE PROTECTION, PEWNTION PROGRAM

i HAS BEEN ACCGftlSKD i

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] FIE BRIGADE / WATCH TRAINING IS OUTSTANDING

I .

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l CONTROL OF TRANSIENT CCNBUSTIELES HAS BEEN EFie .E '

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l TEE HAS BEEN A SIGNIFICA?U PEDUCTION IN TE NtNEER OF MISSED FIE !

'

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j WATCES

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! EQMENDED LICENSEE ACTIONS  !

I

I  ;

TE LIENSEE SHXJLD ASSURE THAT TE EENT ORGANIZATIONAL 0%NGES

I

THAT HAW TE FIE PROTECTION EN31EER EPORTING TO A DIFFEENT

i .

! GROUP AND AT A L0ER LEWL DOES NOT ESttT IN A REDUCTION OF

J .

i MAVGEENT SUPPORT.  !

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EMERGENCY PREPAPEDNESS

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fATEGORY2

! TE ANNUAL EERGENCY ESPONSE EXERCISE WAS VIEWED BY TE EVALVATICH

TEAM AS GOOD

PERSONNEL NOTIFICATION ETHOD AND PROCEDURE REQUIES ADDITIONAL

IEROVEENT FOR CALL-0UT AND SHIFT AlRENTATION RESPONSE TlWS

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EC0 WENDED LICENSEE ACTION

TE LEVEL OF MANAGEENT ATTENTION TO TE IELEENTATION OF TE

^

l EERGENCY PREPAREDNESS PROGRAM SHOULD BE INCREASED TO ENSURE PROPER

l ESPONSE TO NRC IDENTIFIED CONCERNS ELATING TO CALL-0UT DRILL

RESPONSE AND SHIFT AUGENTATION ESPONSE TIE.

TE LICENSEE SHOULD EXEDITE CORRECTION OF TE CALL-0UT DRILL

'

RESPONSE AND SHIFT AUGENTATION CONCERN,

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MANAGEENT SHOULD REVIEW TE DISTRIBUTION OF ONSITE AND OFFSITE

EERGENCY PROGRAM AEAS OF AUTHORITY AND ESPONSIBILITIES,

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SECURIT(

CATEGORY 1

.

FOLICIES AND PROCEDURES ARE WELL STATED, APPROPRIATELY DISSEMINATED

AND UNDERSTANDABLE

A NEW SOUAD MANNING STRUCTURE HAS ALL0kED FOR TRAINING AND PRACTICE

IN SOUAD RESPONSE TACTICS

MINOR PROCEDURAL MISTAKES INDICATE A NEED TO ENHANCE TE SELECTION

PROCESS FOR TEFPORARY SECURITY PERSONNEL AND TO E 5RSISTENT IN

PROGPMATIC TRAINING

REC 0 WENDED LICENSEE ACTION

M LICENSEE SHOULD CONTINUE TO PROE TE CAUSATIVE FACTORS OF

SECURITY EVENTS FOR BROADER IMPLICATIONS AND ADJUST PROGRAMS,

TRAINING, DISCIPLINARY ACTIONS, MAINTENANCE, AND ENGINEERING

RESPONSES APPROPRIATELY,

TE ORGANIZATIONAL ADJUSTENTS MADE IN TE 0A AREA SHOULD E CLOSELY

MONITORED TO ENSURE THAT THE HIGH QUAllTY OF TE SECURIT( OVERS!Giff

PROGRAM CONTINUES,

,.,

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.

DUTAGES

CATEGORY 3

SIGNIFICANT WEAMESSES WERE IDENTIFIED IN TE LICENSEE'S ABILITY TO

PLAN, MANAGE, AND MAINTAIN CONTROL OVER COMPLEX OUTAGE' EVOLUTIONS

AND ESULTED IN ESCALAiED ENFORCEENT

TE LICENSEE'S INWSTIGATION OF OUTAE-RELATED EVENTS INDICATED A

LESS THAN AGGESSIVE APPROACH TO TE ESOLUTION OF TECHNICAL ISSUES

WEAKNESSES WEE IDENTIFIED IN PROCEDURAL COMPLIANCE

.

RECCitENDED LICENSEE ACTION

TE LICENSEE SHOULD ENSURE THAT LESSONS LEARNED FROM TE PEVIOUS

OUTAGES AE IDENTIFIED AND REVIEWED FOR PROGRAM IMPROV9ENTS TE

ESULTS OF THIS REVIEW SHOULD E INCORPORATED INTO OUTAGE PLANNING

AND CONTROL.

. .' * ."

.

QUALITY PROGRAPS AND A mlNIS"RATIVE CONTROLS

AFFECTING G_AL TY

CATEGORY 3

FANAGEENT HAS NOT BEEN EFFECTIVE IN CONSISTENTLY ENSURING TIELY

RESOLUTION OF IDENTIFIED SAFETY PROBLEMS

TE STAFFING IN TE ENGINEERING AREA IS GENERALLY ADEQUATE, BUT THERE

AE WEAK? ESSES IN EXERIENCE AND TRAINING

TE LICENSEE'S ABILITY TO ERFORM ROOT CAUSE ANALYSIS AND IMPLEENT

,

TIE LY AND APPROPRIATE CORRECTIVE ACTIONS WAS A NOTED WEAKNESS

CORPORATE FANAGEENT OVERSIGHT OF PLANT ACTIVITIES DOES NOT ALWAYS

ENSURE ADEQUATE INVOLVEEtU OF TE QUALITY AND ENGINEERING

ORGANIZATIONS IN PLANT OERATIONS

REC 0ftENDED LICENSEE ACTION

INCREASED CORPORATE MANAGEENT INWLVEENT IN SITE ACTIVITIES IS

'

RECCttENDED,

,

ADDITIONAL CORPORATE MANAGEENT INVOLVEENT IS NEEDED TO ENSURE THAT

i

PROKR ENGINEERING AND QUALITY ASSURANCE INWLVEENT IS MAINTAIED IN

ALL ACTIVITIES.

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LICENSING ACTIVITIES

CATEGORY 2

THE LICENSEE'S EVIEWS WERE GEERALLY TIELY, THOROUGH, AND

TECHNICALLY SOUND

,

TE QUALITY AND LEWL OF DETAll 0F TE LICENSEE'S SAFETY EVALUATION

'

SlfEARIES SUMITTED PURSUANT TO 10 CFR 50,59(B)(2) ARE NOT ALWAYS

FULLY ADE00 ATE TO PERMIT TE STAFF TO CONCLUDE TEIR ACCEPTABILITY

l

OCCASIONALLY, TE LICENSEE'S RESPONSES HAVE NOT BEEN ADEQUATE TO

ERMIT TE STAFF TO RESOLVE TECHNICAL ISSUES WITH0lfT TE NEED FOR

ADDITIONAL INTERACTION WITH TE LICENSEE

REC 0 WENDED LICENSEE ACTION

TE LICENSEE SHOULD IMPROVE TE QUALITY OF TE SAFETY EVALVATION

SlfEARIES SUBMITTED PURSUANT TO 10 CFR 50.59,

'

!

TE LICENSEE SHOULD IMPROVE TE CONTENT OF LICENSING SUBMITTALS TO

PRECLUDE TE NEED FOR STAFF REQUESTS FOR ADDITIONAL INF0fEATION THAT

4

COULD HAVE BEEN FORESEEN BY TE LICENSEE,

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TRAINING AND QUALIFICATION EFFECTIVENESS

CATEGORYJ

TE INITIAL TRAINING OF LICENSED OERATORS AND TE TRAINING 0F TE

NONLICENSED STAFF IS EFFECTIVELY CONTROLLED AND TE LICENSEE'S

PERFORMANCE IN LICENSING EXAMINATIONS HAS EEN GOOD

TRAINING RECORDS WERE GEERALLY COMPLETE AND WELL MAINTAINED

TE AREA 0F EQUALIFICATION TRAINING FOR LICENSED OPERATORS HAS

SUFFERED FROM AN APPARENT LACK 0F PANAGE E NT OVERSIGHT AND

INATTENTION TO DETAIL ON TE PART OF TE TRAINING STAFF

REC 0ftENDED LICENSEE ACTION

I

TE LICENSEE SHOULD FURTER EMPHASIZE TE NEED FOR OVERSIGHT OF

OPERATOR EQUALIFICATION TRAINING AND TE NEED FOR TE TRAINING STAFF

TO E MORE ATTENTIVE TO DETAILS IN TE RF0WANCE OF TEIR ACTIVITIES,

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ATTACHMENT 2

ATTENDEES

,

,

Name Affiliation

.

t

'

R. Martin NRC - RIV ~

'

L. Callan NRC - RIV t

J. Milhoan- NRC - RIV

D. Chamberlain .NRC - RIV

v. Calvo NRC - NRR i

'

P. O'Connor NRC - NRR

B. Bartlett NRC - RIV l

M. Skow NRC - RIV

'

G. Boyer WCN00

F. Rhodes WCNOC i

B. Withers WCNOC  !

J. Bailey WCNOC  !

i W. Wood . WCf'0C

J. Houghton WCNOC

'

B. Hagan WCNOC

'

B. McKinney :WCNOC

H. Chernoff WCNOC- l

C. Parry WCNOC

l 0. Maynard WCNOC

a T. Morrill WCNOC

1

^

K. Moles WCN00

R. Holloway WCNOC l

C. Estes WCNOC

T. Deddens, Jr. WCNOC

>

R. Hackman WCNOC

D. Fehr WCNOC

4 A. Freitag WCNOC

P. Potter WCNOC

i C. Sprout WCNOC

<

G. Rathbun WCNOC .

4

M. Grimsley WCNOC l

R. Smith

'

WCNOC

J. Pippin WCNOC  :

J. Johnson WCNOC  !

i

M. Williams WCNOC

1 H. Dyer Dan Glickman's Office

,

M. Johnson KG&E i

J. Kramer KCPL  !

1

i B. Gashom KEPCO

'

T. Ryan KEPC0 i

J. Hays Wichita Eagle Beacon l

l S. Kempin Kansas City Star I

i S. Swartz Topeka Capitol - Journal  !

l P. Wenske Kansas City Times I

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4

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