ML20154S031
| ML20154S031 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 03/20/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20154S029 | List: |
| References | |
| 50-382-85-30, NUDOCS 8603310279 | |
| Download: ML20154S031 (39) | |
See also: IR 05000382/1985030
Text
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APPENDIX
.
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-382/85-30
Louisiana Power & Light Company
Waterford Steam Electric Station
Unit 3
December 18, 1984 - December 31, 1985
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8603310279 860320
PDR ADOCK 05000382
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated Nuclear Regulatory Commission (NRC) staff effort to collect
available observations and data on a periodic basis and to evaluate
, licensee performance based upon this information. SALP is supplemental to
normal regulatory processes used to ensure compliance to NRC rules and
'
! regulations. SALP is intended to be sufficiently diagnostic to provide a
i rational basis for allocating NRC resources and to provide meaningful
j guidance to the licensee's management to promote quality and safety of
- plant operation.
.
i An NRC SALP Board, composed of the staff members listed below, met on
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February 27, 1986, to review the collection of performance observations
and data, and to assess the licensee performance in accordance with the
! guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Waterford 3 Steam Electric Station (W3 SES) for the period
December 18, 1984, through December 31, 1985.
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E. H. Johnson, Director, Division of Reactor Safety and
j Projects, Region IV
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R. L. Bangart, Director, Division of Radiation Safety and
i Safeguards, Region IV
- D. M. Crutchfield, Assistant Director for Technology-PWR B, Nuclear
Reactor Regulation !
J. E. Gagliardo, Chief, Reactor Projects Branch, Region IV
i G. L. Constable, Chief, Project Section C, Reactor Project Branch,
- Region IV
J. H. Wilson, Project Manager, Nuclear Reactor Regulation
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J. G. Luehman, Senior Resident Inspector, W3 SES
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! II. CRITERIA
) Licensee performance was assessed in eleven selected functional areas.
-
Each functional area normally represents areas significant to nuclear
safety and the environment.
One or more of the following evaluation criteria were used to assess each
functional area.
1. Management involvement and control in assuring quality.
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2. Approach to resolution of technical issues from a safety standpoint
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- 3. Responsiveness to NRC initiatives
4. Enforcement history
5. Operational events (including response to, analysis of, and
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corrective actions for)
6. Staffing (including management)
However, the SALP Board is not limited to these criteria and others may
l have been used where appropriate.
Based upon the SALP Board Assessment, each functional area evaluated is
i classified into one of three performance categories. The definitions of
l these performance categories are:
Category 1. Reduced NRC attention may be appropriate. Licensee
! management attention and involvement are aggressive and oriented toward
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nuclear safety; licensee resources are ample and effectively used so that
,
- N Jh level of perfomance with respect to operational safety is being
- ach1eved.
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 is being achieved.
i Category 3. Both NRC and licensee attention should be increased.
- Licensee management attention or involvement is acceptable and considers
i nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety is being achieved.
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III. SUMMARY OF REFULTS
l Significant improvement has been achieved in the areas of
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Preoperational/Startup Testing, Security and Safeguards, and Surveillance.
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Performance has declined in the area of Quality Programs and j
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Administrative Controls Affecting Quality. Areas needing improvement i
include Plant Operations and Maintenance.
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The licensee's performance is summarized in the table below, along with
l the performance categories from the previous SALP evaluation period.
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Previous Present
Performance Performance
Category Category
(7/1/82 to (12/18/84 to
Functional Area 6/30/83) 12/31/85)
A. Preoperational/Startup 2 1
Testing
B. Plant Operations 2 3
C. Surveillance Not Assessed 2
D. Maintenance 3 3
E. Quality Programs and 1 2
Administrative Controls
Affecting Quality
F. Fire Protection Not Assessed 2
G. Radiological Controls 2
1. Radiation Protection 2
2. Radwaste Systems, Effluent 2
Releases, and Monitoring
3. Transportation 2
Activities
4. Confirmatory Measurements, 3 l
Chemistry / Radiochemistry
5. Environmental Surveillance 2
H. Emergency Preparedness 3 2
I. Training and Qualification 2 2
Effectiveness
J. Security and Safeguards 2 1
K. Licensing Activities 2 2
L. Outages Not Assessed Not Assessed l
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The total NRC inspection effort during this SALP evaluation period
consisted of 30 inspections, including resident inspector inspections and
emergency exercises, for a total of 4,065 direct inspection hours. The
plant availability factor from commercial operation on September 24, 1985,
through December 31, 1985, was 76.1.
IV. PERFORMANCE ANALYSIS
A. Preoperational/Startup Testing
1. Analysis
This area was inspected on a continuing basis by the NRC
resident inspectors during the performance of the initial
startup testing program. Routine inspections conducted by the
NRC resident inspectors during these tests included procedure
review, test witnessing, and test results evaluation. No
violations were identified in the functional area of startup
testing. No LERs associated with this area were submitted.
The NRC inspections conducted during the startup program
revealed management involvement and oversight was good,
resources were effectively utilized, and minimal retesting was
required. In general, the startup program can be characterized
as a smooth, well controlled evolution.
2. Conclusions
Licensee management demonstrated excellent prior planning and
effective control of startup testing. The licensee is
considered to be in Performance Category 1 in this functional
area.
3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection program in this functional area is
complete.
b. Recommended Licensee Actions
Licensee management is encouraged to apply the same
attention to detail during future facility operation
including post-outage testing.
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B. Plant Operations
1. Analysis
This area has been inspected on a continuing basis by the NRC
resident inspectors. One violation was identified involving
failure to follow the baron management system operating
procedures which resulted in the secondary side of the plant
becoming contaminated. (Severity IV, 85-16)
The 34 LERs associated with plant operations are listed below.
. Automatic actuations of the engineered safety features
portion of the control room ventilation system including
electrical spikes and spurious alarms. (84-01,85-02,
85-05,85-30,85-39,85-43,85-45,85-48)
. An inadvertent containment spray actuation occurred while
performing a matrix test on Channel D of the plant
protection system. (85-06)
. While in Mode 3 an inadvertent actuation of the reactor
protection system occurred due to noise in the Core
Protection Calculation Channels C and D. (85-07)
. The reactor tripped on high steam generator level once in
Mode 2 (4.5% reector power) and once in Mode 1 (15% reactor
power). In each case, steam generator levels were being
manually controlled. (85-08)
. The reactor tripped due to low water level in the steam
generator caused by loss of the Main Feedwater Pump B.
(85-13,85-14)
. The liquid effluent monitor was found inoperable due to a
valve misalignment. (85-15)
. The reactor tripped from 17% power following an inadvertent
closure of Nain Ste.am Isolation Valve 2. (85-17)
. A reactor coolant system unidentified leakage of 6.1
gallons per minute was calculated while at 65% power.
(85-18)
. The reactor tripped from 25% power due to a malfunction in
the condensate polisher system. (85-20)
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- . The reactor tripped from 65% power due to low water levels
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in the steam generators. The reactor trip resulted when a
flow perturbation in the condensate system tripped the main
- feedwater pump on low suction pressure. (85-21) ,
t . The Emergency Diesel Generator B output breaker and both
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emergency feedwater pump motor breakers failed to close
during a surveillance test due to a problem with the
i breaker racking motor interlocks. (85-23)
. The reactor tripped from 91% power following the loss of
the main feedwater pump due to a fire. (85-27)
, . The reactor tripped at 2E-4 percent power due to the
control element assembly position deviation initiating a
large enough penalty factor to generate a DNBR and local
power density trip. (85-28)
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l . The reactor tripped from 15% power on'high steam generator
- level due to unisolating the main feedwater regulating
, valve in preparation for power ascension. (85-29)
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. The reactor tripped from 100% power on low water level in
the steam generator due to a loss of a main feedwater pump.
(85-31)
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. The reactor tripped from 58% power on high water levels in
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the steam generator due to a malfunction in the speed
4 controller for' the main feedwater pump. (85-33)
- . The reactor tripped from 90% power on low water level in
the steam generators due to a flow perturbation causing
! both main feedwater pumps to trip on low suction pressure.
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x, (85-34)
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( . The reactor tripped from 100% power when reactor coolant
- system pressure was out of the range allowed by the core
protection calculators due to an electrical fault in the
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digital electro-hydraulic control panel. (85-35)
l . Loss of 4.16 KV bus resulting in automatic start of EDG and
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reactor trip. (85-40)
. Reactor trip due to operator distraction. (85-42)
. Reactor trip due to over feeding steam generator. (85-44)
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! . Reactor trip as a result of deluge system actuation.
(85-47)
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. Reactor trip on inadvertent low DNBR. (85-51)
. Loss of offsite power due to lightning strike in Waterford
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switchyard. (85-54)
. Mode change with inoperable containment spray pump.
4 (85-55)
f . Reactor trip resulting from condenser level perturbation.
(85-56)
- Twelve of these events involved operator error.
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The operations department has experienced a significant loss of
licensed personnel during this appraisal period. Attrition due
to resigr.ations (9) and two transfers to another department
prevented the licensee from manning a full six shift rotation as
they did at the beginning of the appraisal period. The addition
i of nine licensed operators after the October 1985 examination
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has improved the situation somewhat and the operations
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department currently has 30 licensed operators. The licensee
has started an incentive program for the licensed operators in
which they would receive pay bonuses, and it is hoped this
j program will reduce the attrition rate.
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i Observations of operator conduct and perfonnance in the control
{ rooms and in the other areas of the plant have indicated that
! the operators perform their duties in a professional manner. No
! distractions such as extraneous reading materials or excessive
i noise have been observed in unaut':orized areas as required by
j licensee's procedures. NRC findings and LER reviews indicate
- that a contributing factor to some events has been a failure to
l follow procedures, especially for the secondary plant.
Licensee management involvement in reducing congestion and noise
in the control room is evident, yet the results of some efforts
have been mixed. The rear portion of the control room has been
j partitioned with glass. This allows the shift supervisor and
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other operations personnel to carry out required administrative
tasks and to interface with personnel from other departments
without interrupting the overall functioning of the control-
room. The areas around the control panels have been carpeted
and this substantially reduces ambient noise. The licensee has
chosen ball caps as a kind of distinctive clothing to identify
key shift personnel. This effort has not been entirely
successful as numerous reactor operators (R0s) and/or senior
reactor operators (SR0s) do not wear their caps. Even with the
partitioned area in back of the control room, the number of
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nonessential personnel allowed in the control board area varies.
by shift crew. ,
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The performance of licensed personnel during operational events,
I such as reactor trips, was very good. The reactor operators
carried out the required actions under the supervision of the
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control room supervisor, while the shift supervisor remained ,
i free to respond to other problems. Other personnel, including
plant management, remained clear of the area near control boards
until conditions were verified as being stable.
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The licensee has started a program of upgrading the W3 SES
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annunciator system to eliminate nuisance alarms and to have a
minimum of annunciators illuminated during power operation.
- Along with the required hardware modifications, this program
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needs to include the updating of the numerous incorrect
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dununciator response procedures that were identified by the NRC,
to assure that the operator has information to adequately
respond. The licensee has initiated a program which is heavily
- involved in overview of this effort as there are a substantial
i number of annunciators that need to be addressed.
I The large number of automatic actuations of the engineered
a safety system features portion of the control room ventilatier.
system, along with the numerous problems with both the control
,! rocm ventilation system chlorine and ammonia detoction systems
j too often diverted the reactor operator's attention away from
i monitoring overall plant operations. The underlying problems
associated with these events are, in some cases, design problems
to which quick solutions are unlikely. In the meantime, the
i licensee provided a spurious ventilation actuation diagnostic to
l the operators to assist them in dealing with any future
- problems. Because of the assorted problems, operation of the
i control room ventilation in the recirculation mode has become
- almost the normal practice.
f As discussed in the Radiological Controls section of this
j report, the plant has had a continuing problem of high
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concentrations of short lived airborne radioactivity in various-
! portions of the reactor auxiliary building (RAB). There has not
i been a coordinated effort, allotting sufficient time and
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manpower, between the operating staff and the radiological
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controls personnel to eliminate the causes. Some efforts have
been made in this area but other operational priorities have
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consistently been deemed more important; so the problem
continues to exist.
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The plant experienced 22 at-power reactor trips during 1985.
This number of trips is high; even for a newly licensed plant.
Many of the trips have occurred due to problems in the secondary
plant and the utilization of the Reactor Power Cutback System
(RPCS) should help reduce the number of future trips. Although
use of the RPCS should reduce the number of reactor trips due to
secondary side problems, it will not eliminate the causes of ,
those problems related to human error.
2. Conclusions
l The NRC staff views the licensed operators (on shift) as highly
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professional and dedicated to safe operation, lacking only in
long-term experience.
Lack of experienced operators due to the age of the plant and
the turnover of licensed operators were contributing factors to
the high number of reactor trips, as was the performance of the ,
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initial startup program. But, these factors do not explain all j
the problems. Otner factors, including lack of a plant specific i
simulator, the long term reliability of control element assembly l
(CEA) system, and the followup of operational events (discussed
in the Supporting Data and Summaries), need to be considered.
Though operator distractions (such as spurious ventilation
isolations and numerous illuminated annunciators) were being ,
addressed, progress was slow, forcing the operators to monitor ;
the plant under less than ideal conditions.
The frequency of reactor trips did not decrease appreciably as
i' the appraisal period progressed. In most cases, licensee
management took the necessary corrective actions to fix the
individual problems as they were identified, but an aggressive
overall trip reduction program was not evident. The licensee
- , has in place the organizations (Independent Safety Engineering
-and Operations Quality Assurance) to assist in such a program;
however, a lack of direct involvement of individuals with opera-
tions experience in the groups may limit their effectiveness.
The licensee is considered to be in Performance Category 3 in i
this functional area.
3. Board Recommendations
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a. Recommended NRC Actions
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. The NRC inspection effort in this functional area should
increase and should include increased emphasis in
, monitoring the licensce's actions to improve overall
i operations and reduce the frequency of reactor trips.
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- b. Recommended Licensee Actions
i An aggressive reactor trip' reduction program, including
i human factors evaluations and root causes determination,
i should be instituted to reduce the reactor trip frequency
1 toward the industry average. This program should include ~
j an in-depth review of the events by experienced operators
from outside the plant' operations department.
Licensee management must reverse the overall tre;;d related
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to staffing which should help reduce the number of
reportable events. Additionally, support of the completion
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of the program to upgrade the control room annunciator
system should continue. Licensee management should
initiate a preplanned program to eliminate the RAB airborne
radioactivity problem. Also, licensee management should
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use the formulation and review of the Technical
Specification (TS) for the broad range toxic gas detection
system required by License Condition 2.C.4 as an
{ opportunity to review the progress being made toward
j reliable monitoring systems associated with the control
room ventilation system.
j. C. Surveillance
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i 1. Analysis
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This area has been inspected by region-based NRC inspectors and
on a continuing basis by the NRC resident inspectors.
j Violations involving the failure to complete the data review on
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the emergency diesel generator surveillance test prior to
changing operational modes (Severity Level IV, 85-20) and
failure to comply with the requirements for ultimate heat sink
cooling tower level (Severity Level IV, 85-28)'were noted. .
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, Eight LERs involved activities in the functional area of
! surveillance.
i . A licensee review discovered that the surveillance used to
- prove the operability of the containment air lock had not
been performed within the~ required time frame specified in
j the TS. (85-09)
!
- . A licensee review found that W3 SES changed modes with an
- inoperable hydrogen analyzer and neglected to perform the
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appropriate surveillance on the excore nuclear
instrumentation. (85-10)
. Failure to sample the oxygen and hydrogen concentration in
the gas decay tank as required by TS. (85-11,85-19)
. Failure to do a proper data review of the emergency diesel
generator surveillance test prior to changing operational
modes. (85-25)
. Wet cooling tower basin level instrument discrepancy.
i (85-49)
. Inoperable radiation monitor without collecting and
analyzing required samples. (85-52)
. Core protection calculator surveellance deficiency due to
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inadequate procedure. (85-53)
The NRC inspectors' review of the W3 SES surveillance program
indicated that components and systems reviewed had been tested
in accordance with controlled procedures and that the testing
had been completed on schedule. During the early stages of
power ascension a weakness was identified in ability to keep the
status current for surveillances. The licensee took steps to
improve the communication between different disciplines and
revised procedures to help eliminate this problen.
! Additionally, the plant's computerized surveillarce tracking
i system was continuously refined to prcvide a more accurate
j status of pending surveillance requirements. ,
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l During the appraisal period the licensee's surveillance program
effectively controlled routine surveillance requirements. As J
evidenced by some of the LERs the control cf nonroutine
activities such as those surveillances required by TS action
requirements, was not as good.
,
2. Conclusion
1 Licensee management involvement in the functional area of
j surveillance has resulted in positive steps to overcome
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weaknesses identified in the early part of the assessment
period. Their approach to the resolution of technical issues
j has improved as reflected in the type and reduced number of
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operational events identified later in the appraisal period.
Problems with nonroutine activities continued to exist because,
in part, the method of tracking TS action requirements that the
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licensee used was not completely effective. The mere listing of
action statements on a turnover sheet does not alert the
operators to action statement entries that have multiple causes.
Also, the use of a listing of TS numbers does not provide the
operator with a reference for review of the action statment
requirements.
The licensee is considered to be in Performance Category 2 in
this area.
3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection effort in this area should be consistent
with the basic inspection program. Emphasis should focus .
on nonroutine surveillance activities such as those
required for mode changes.
b. Recommended Licensee Actions
Licensee management should continue improvements in this
area, especially in the area of communications between
different disciplines. The licensee should develop an
integrated and more descriptive action statement tracking
system. The combining of the equipment out of service log
and the tracking of action statements would make the task
of tracking TS related problems easier for the control room
operator.
D. Maintenance
1. . Analysis
This area was inspected by region-based NRC inspectors and on a
continuing basis by the NRC resident inspectors. Seven
violations described below were identified in this functional
area during the appraisal period.
. Failure to have procedures which assure proper
documentation for spare and replacement parts, assure that
design control reflects changes in spare and repair parts,
and assure that safety class spare parts are not 1
downgraded. (Severity Level IV, 84-42)
. Failure to have maintenance procedures for safety-related
equipment which reflect equipment manufacturer's
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recommended or suggested maintenance. (Severity Level IV, -
85-01)
. Failure to have procedures which verify supplier
documentation of changes to safety-related purchase orders,
require design change review for purchase order major
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exceptions affecting design specifications used to assure
the design bases upon which the plant was licensed, assure
the' review of spare and replacement material, parts and
components for design and quality changes, and implement
- maintenance of equipment qualification prior to fuel load
as comitted in Section A6 of Revision 2 (November 1982) of
LP&L's W3 SES n ponse to NUREG-0588. (Severity Level IV,
85-04)
. Failure to have procedures which provide adequate control
of classification of maintenance activities so that
i preventive maintenance tasks involving equipment
qualification are prcperly identified, controlled and
provide adequate instructions for 0-ring replacement and
lubrication or torquing af instrument covers to maintain
component qualifications. (Severity Level IV, 85-27)
. Failure to follow procedural requirements for replacement
and lubrication of instrument cover 0-rings per NI-3-323,
Revision 2 and for performing the required spare parts
equivalency evaluation request per UNT-8-042, Revision 1
and UNT-7-021, Revision 0 prior to using an 0-ring.
(Severity Level IV, 85-27)
. Failure to follow procedures UNT-5-002, FJi-6-003, and
OP-10-001 when perfonning work on Charging Pumps A and AB
under Condition Identification Work Authorizations (CIWAs)
022173 and 022169. (Severity Level V, 85-28)
. Failure to follow procedures relating to periodic
calibration of measuring)and
(Severity Level V, 85-33 test equipment (M&TE).
Six LERs listed below involved activities in the area of
maintenance as described below:
. Maintenance personnel, while troubleshooting a ground,
inadvertently shorted two leads together causing both the
operating Low Pressure Safety Injection Pump 8 and
Electrical Bus 3B-32 to trip. (85-03)
. An inadvertent reactor trip occurred while plant personnel
were installing heat shrink on the logarithmic power level
nuclear instrumentation. (85-04)
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. A turbine bypass valve. suddenly opened, swelling the steam .
generator water levels and causing a reactor trip. (85-22)
. A loss of offsite power occurred due to personnel errors
while troubleshooting the Main Generator Oil Circuit
Breaker B. (85-24) .
. An inadvertent actuation of the engineered safety features
portion of the control room ventilation system caused by
small holes / tears in the foil on the detectors for the
radiation monitors. (85-36)
. Reactor trip due to failure of feedwater control system
(FWCS) steara flow square root extractor. (85-41)
Several najor maintenance efforts were accor..,'lished during this
appraisal period. Maintenance activities were e complished
including replacement of the main generator rotor retaining
rings, replacement of a low pressure turbine rotor, replacement
of reactor coolant pump seals, chemical cleaning of ti.a main
electrical generator, and steam generator tube plugging. During
these outages the backlog of CIWAs was reduced substantially.
Extensive management involvement at the planning level enabled
these activities to be accomplished essentially on schedule.
This type of extensive planning is evident in the licensee's
contingency forced outage planning. Almost daily updates ensure
that in the event of a forced outage, each maintenance group
will have preplanned tasks to accomplish, thus reducing outage
time.
Several flRC inspections during this assessment period base
revealed inadequacies in procurement of spare parts,
implementation of applicable vendor technical information in
naintenance procedures, maintenance of environmentally qualified
safety-related equipment, control of measuring and test
equipment, and documentation of accomplished maintenance. As a
result of the violations discussed above, the licensee is
formulating a plan to address the possible generic weaknesses
identified in the maintenance program.
One licensee initiated comprehensive improvement project is the
establishment of the maintenance segment station information
management system (sills) toward the end of the assessment
period. This is a computer system with an equipment database
containing detailed information on each piece of plant
equipment. It is expected to enhance identification of quality
)
_ . _ _ - _ - _ _ - _ _ _ _
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requirements, naintenance history, CIWA tracking, and nuclear
plant reliability data system reporting.
2. Conclusion
Most of the weaknesses identified appear to be at the program
level as evidenced by inadequate procedures or procedures that
do not properly implement requirements. On the working level,
maintenance personnel generally do a good job on assigned tasks
with the procedural guidance provided. The licensee, at the end
of the appraisal period, appears to be implen,enting a
maintenance management system that should adequately address the
identified programmatic weaknesses.
The licensee is considered to be in Performance Category 3 in
this area.
3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection effort in this functional area should be
increased due to programmatic deficiencies and violations
identified during this assessment period,
b. Recommended Licensee Actions
The licensee should continue their increased management
attention to resolve the weaknesses identified in this
a rea. Those areas which should be of particular concern
are:
(1) Improving the interface with outside organizations to
ensure spare parts are properly procured, vendor
information is properly incorporated in procedures and
information from the architect engineer (AE) is used
when making changes to or replacing plant equipment.
(2) Upgrading the it&TE program to provide for timely
calibration of potentially radioactively contaminated
equipment.
(3) Ensuring effective programmatic guidance is in place
for maintenance of equipment environmental
qualification.
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E. Quality Programs and Administrative Controls Affecting Quality
1. Analysis
<
This functional area includes all verification and oversight
activities which affect or ensure the quality of plant
activities, structures, systems, and components. This area can
'
be viewed as the comprehensive management system for controlling
the quality of work performed and for controlling the quality of
verification activities that are intended to confirm that the
work was performed correctly. Appraisal in this area is based
on the results of management actions to ensure that the
necessary people, procedures, facilities, and materials are
provided and used during the operation of the plant. Emphasis
in the appraisal of this area is placed on the effectiveness and
involvement of nanagement establishing and ensuring the
implementation of the quality assurance (QA) program. Also
considered in this area is the licensee's performance in the
areas of connittee activities, design and procurement control,
control of design change processes, inspections, audits,
corrective action system, and records.
Activities under this functional area vere inspected by
region-based NRC inspectors and by the NRC resident inspectors.
Four violations were identified in this area during the
assessment period.
. Failure to have procedures to assure compliance with W3 SES
operations QA program. (Severity Level IV, 85-01)
Failure to have adequate documentation for EBASCO
'
.
safety-related ventilation heating system and replacement
parts used with charcoal filters. (Severity Level IV,
85-04)
. Failure to update procedures dealing with design changes.
(Severity Level IV, 85-16)
. Failure to conduct a proper 10 CFR 50.59 review dealing
with the control room heating and ventilating system.
(Severity Level IV, 85-20)
'
The two LERs listed below involved activities in this functional
area.
. One of the two banks of pressurizer heaters powered from
the IE bus was isolated due to a drawing discrepancy.
(85-16)
_ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ _ . _ _ __ __ __ _ ___. _ _ _ _ _ -
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. A reactor trip occurred at 6% power due to axial shape
index being out of range allowed by the core protection
calculator. The operating procedure did not include
adequate guidance for-calculating the axial shape index
below 6% reactor power. (85-32)
The NRC inspectors noted some changes in the area of QA. The QA
organization has undergone a reorganization.in which the QA
group was broken down into three sections which are listed
below.
. Vendor QA
,
. Operations QA
. System Development / Analysis QA
All of these sections report to the corporate QA manager. QA ,
audits were found to have been conducted in accordance with
approved checklists and were performed within the required-
intervals, with one exception, which is still under review
(Unresolved Item 8520-03). QA audits were well documented, and
the audit findings were addressed by the audited organization
and tracked by the QA group. QA auditor qualification records
were reviewed and found to meet applicable requirements.
Improvement programs were started in the area of quality control
(QC) which should increase the effectiveness of-QC activities.
The improveraents included:
. Increased staffing including QC engineers.
. Training of maintenance personnel to be qualifiec QC'
t
inspectors.
The hRC inspectors conducted a detailed inspection of'the
,
control of design changes and modifications. The inspectors
reviewed documents which outline the requirements and
'
responsibilities for the preparation, control, and review of
station modifications from request through implementation and
'
final closecut. Thestationmodificationpackage(SMP)is-the
vehicle by which design changes and modifications are made and
the use of the forms and documents that become a part of the SMP
provide the required control of design changes.
.
The inspection determined that there was a very large backlog of
SMPs in the work completion notice IWCN) and drawing update
stage. There were, in fact, only 1; SMPs completely closed out
and in project files with a!! da m mented updates done. There
. . _ . _ , _ _ , _ . . . _ _ _ _ . _ . . .. ._ __. _ _ _ .
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i were 125 awaiting drawing update and 206 SMPs completed but
1
awaiting some other form of review or document update. This
, backlog of SMPs causes some problems in the operational
documents such as the red line drawings, where in at least one
case, 5 SMPs were posted on the drawing as being completed but
i not marked on the drawing, as well as 3 additional SMPs marked l
up on the drawing. This represents a total of 8 SMPs affecting
i one drawing without any of them incorporated on the drawing.
i Reliability of the plant monitoring computer has been a constant
problem during the appraisal period. Frequent losses of the
core operating limit supervisory system (COLSS) due to computer
'
problems has caused numerous power reductions in order to comply
with TS action requirements. These power reductions, and the
,
subsequent power increases upon restoration of the COLSS, are
avoidable plant transients which require plant operator
, attention and generate unnecessary liquid waste. Near the end
'
of the rating period the licensee submitted a request for a
change to the TS that should minimize the operational impact of
i COLSS failures.
2. Conclusions
The licensee's performance in the area of QA and QC was
adequate. Specific improvement is needed in the area of design
change ccatrol. Also, management involvement is required to
assure evaluation and resolution of problems with the plant
computer system. An overall decrease in performance in this
functional area is possibly due to the QA reorganization. The
QA organization does not appear to be as actively and
aggressively involved in day-to-day operational activities as
i
has been previously observed.
.
l The licensee is considered to be~in Performance Category 2 in
- this area.
5 3. Board Recommendations
!
- a. Recommended NRC Actions
, The NRC inspection efforts in this functional area should
i be consistent with the basic inspection program, with
! increased attention to the evaluation of the effectiveness 4
of the QA program.
! b. Recommended I.icensee Actions
!
) The licensee management needs to work toward:
(1) A timely resolution of the NRC concerns regarding
i procurement control.
,
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(2) Involving the QA organization and other independent
organizational elements, such as the Independent
Safety Evaluation Group (ISEG), in problem areas.
Representative attendance at NRC exit interviews would
enhance their involvement.
(3) Devote the necessary resources to eliminate the SMP
backlog.
(4) Bring in the necessary resources from LP&L and Middle
South Utilities to help resolve the plant computer
problems.
F. Fire Protection
1. Analysis
This area was inspected on a continuing basis by the NRC
resident inspectors. One violation involving the removal of a
fire door from service was noted. (Severity Level IV, 85-16)
The eight Licensee Event Reports (LERs) listed below involved
activities in the functional area of fire protection.
. Fire doors were not verified operable. (84-02)
. Continuous fire watch with backup fire suppression
equipment was not established within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. (85-01)
. A fire zone did not have a fire detector capable of
automatically activating. (85-12)
. Fire barriers were found to be degraded. (85-26,85-37)
. did not cover several of the conduit support
Fire wrap (85-38)
points.
. Fire watch tours were not properly performed. (85-46)
l
. Deficient fire watch tours. (85-50) ;
1
The licensee has responded to the NRC violation and concerns and
the related LERs by implementation of an improved fire
protection program. Responsibility for performance of fire
watch tours was reassigned to the security department. This was
accompanied by changes in personnel, supervision, '
administration, and training practices. The security computer l
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is now routinely used to audit performance of fire watch tours.
Plant operations personnel have also received additional
training in their fire protection responsibilities, particularly
in the area of performing compensatory actions when fire
barriers, detection or suppression systems are degraded.
The licensee reinspected fire seals related to TS 4.7.11.lc in
response to a number of identified deficiencies. The licensee
is to analyze data from this inspection to determine the root
cause of the deficiencies and establish whatever programs are
necessary to ensure fire barriers are maintained functional.
In general, plant cleanliness is good with materials and
equipment properly stored; however, cleanliness in less
frequently accessed areas is not maintained as high as in the
plant in general.
2. Conclusions
The licensee has improved the level of technical competence in
the area of fire prevention / protection. Management interest and
involvement have been demonstrated in the responsiveness to
identified technical problems by revamping the fire watch
program and demonstrating increased emphasis on staffing and
training.
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Board Recommendations
a. Recommended NRC Actions
The level of fiRC inspection in this functional area should
be consistent with the basic inspection program.
b. Recommended Licensee Actions .
Licensee managemer.t should be directed toward:
(1) Installation of the fire protection equipment required
by license conditions.
(2) Resolution of fire barrier problems including
implementation of a program to maintain fire barriers
. functional.
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G. Radiological Controls
1. Analysis
Ten inspections concerning radiological controls were conducted
during the assessment period by region-based radiation
specialist inspectors. These inspections involved the following
areas: occupational radiation safety; radioactive waste
management and radiological effluent control and monitoring;
water chemistry controls; and transportation of radioactive
materials. Three violations and one deviation were identified:
. Failure to provide proper storage of radioactive material
shipping containers. (Severity Level IV, 85-26)
. Failure to provide training for solid radwaste operators.
(Severity Level IV, 85-26)
. Failure to establish sampling procedures for waste gas
cecay tanks. (Severity Level V, 85-17)
. Failure to store low-level radioactive waste in designated
areas. (Deviation 85-26)
a. Occupational Radiation Safety
This area was inspected three times during the assessment
period. No violations or deviations were identified.
The release of airborne and liquid contaminates from valves
and fittings in various plant systems has resulted in
excessive contamination of personnel and plant areas.
Licensee management has not demonstrated an aggressive
attitude for implementing a maintenance program to correct
the root cause of these contamination problems. In
addition, the licensee's As Low As Reasonably Achievable
(ALARA) program has been ineffective regarding its ability
to bring about the necessary corrective actions to correct
the contamination problems. The licensee's approach to
handling these contamination problems has been the use of
additional health physics personnel for increased radiation
protection coverage instead of taking proper action to
repair the leaking valves and fittings.
The radiation protection organization has performed in an
acceptable manner considering the contamination problems
they must contend with. The licensee maintained an
adequate radiation protection program to support plant
_ _ _ ~
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operations. This was accomplished by the use of overtime
and supplementing the permanent plant staff with about
20 contractor health physics. technicians. The personnel
turnover rate at the technician level has been low.
The licensee has implemented a radiological training
program for general employee training, radiation worker
training, and training for radiation protection staff. The
radiation protection staff includes the necessary
qualifications and levels of experience.
Management oversight is evident by the support the
corporate radiation protection group provides to the onsite
organization. Management oversight also involved QA audits
and program reviews by the corporate office.
b. Wa Chemistry Controls
This area was inspected three times during the assessment
period. Twc of the inspections included onsite
radiochemistry confirmatory measurements of actual gas and
liquid with the Region IV mobile laboratory. One violation
involving the lack of proper sampling procedures for the
wdste gas decay tanks was identified.
The first confirmatory measurement inspection results only
indicated 76% agreement with the NRC. A followup
inspection was performed and results for this inspection
indicated greater than 95% agreement. An effective program
for these kinds of measurements should have comparative
agreement greater than 90%.
lio problems were identified concerning management
oversight, resolution of technical issues, and
responsiveness to NRC initiatives. The
chemistry / radiochemistry staff consists of well qualified
and experienced personnel. The staff has experienced a low
turnover rate. A comprehensive training program has been
implemented. All identified NRC concerns in this area have
been resolved. Management oversight was apparent by the
performance of QA audits and program reviews by the
corporate office,
c. Radioactive Waste Management and Radiological Effluent
Control and Monitoring
The area of radioactive waste management and radiological
effluent control and monitoring was inspected-twice during
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the assessment period. No violations or deviations were
identified.
The licensee has established a dedicated radwaste
organization. Staffing for this area has been stable with a
low turnover rate. Management oversight was evident by the
performance of QA audits and program reviews. Responses to
audit findings have been completed in a timely manner. The
licensee's responsiveness to NRC initiatives has been
generally acceptable. A liquid release permit program has
been implemented to assure that planned releases receive
the necessary review and approval prior to release. No
problems were identified in the areas of effluent releases,
effluent monitoring, effluent monitoring instrumentation,
air cleaning systems, or reactor coolant water chemistry.
The training and qualification programs for Nuclear
Auxiliary Operator responsible for radwaste operation has
indicated some weaknesses. These weaknesses were apparent
by the numerous operator errors associated with the
operation of the various radwaste systems.
The radiological environmental monitoring program was
inspected once during the assessment period. No violations
or deviations were identified. The licensee has
implemented a well managed, comprehensive program. The
program is considered adequate in the areas of management
-
oversight, staffing, training and qualifications,
resolution of technical issues, responsiveness to NRC
concerns, reports, control of contractor activities, and QA
audits. All previous NRC identified concerns for this area
have been resolved.
d. Transportation of Radioactive Materials
This area was inspected once during the assessment period.
Two violations and one deviation were identified. These
three enforcement items were minor concerns and not an
indication of an inadequate transportation / solid radwaste
program.
This program area is well managed and staffed with
qualified personnel. Personnel turnover has been low for
this area. Management oversight was evident by the
performance of QA audits and program reviews. The
licer.see's responsiveness to NRC initiatives and resolution
of technical issues has been adequate.
,
.
-24-
2. Conclusions
Although within regulatory limits, excessive personnel and plant
area contamination exists. Management has not established the
necessary priority concerning these chronic contamination
problems to assure corrective action is implemented in a timely
manner. The ALARA program has also exhibited weaknesses in that
contamination problems that exist in the plant are contrary to
good ALARA practices.
Management oversight was evident for the various program areas
by the performance of QA audits and program reviews. A low
personnel turnover rate was noted in each area.
The licensee is considered to be in Performance Category 2 in
this area.
3. Board Recommendaticns
, a. Recommended NRC Actions
The NRC inspection effort in this area should be
consistent with the routine program,
b. Recommended Licensee Actions
Managen,ent attention is needed in order to correct the
numerous gaseous and liquid leaks that have resulted in
excessive contamination of workers and plant areas. The
training and qualification program for radwaste operators
should be improved for tne purpose of reducing the number
of operator. errors associated with operating the various
radwaste systems.
1. Analysis
During the assessment period, four emergency preparedness
inspections were conducted. One violation was identified;
failure to perform adequate training (Severity Level IV, 85-23).
The first inspection conducted on March 11, 1985, involved
inspecting the newly constructed emergency operations facility
and the relocation of the emergency equipment and comunications
to the new facility.
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The second was a routine emergency preparedness inspection
during the period of May 6-10, 1985. The three major areas
inspected were program review, changes to the Emergency Plan,
and knowledge and performance of duties. It was determined
.
'
during a review of the licensee's action item list that some
!
open items had not been corrected within one year.
i Additionally, there were operations personnel that had teen
- identified as weak in emergency detection and classification.
l Due to responsibilities associated with start up,-emergency
j preparedness walk-throughs for the operators were deferred to
- the August 1985 inspection.
During the third inspection, conducted August 5-9, 1985, -
operator walk-throughs were conducted in conjunction with
reviewing LP&L corrective actions on previously identified open
items. It was determined that three of five crews did not
i
utilize protective respons'e areas when formulating protective
action recommendations. Two of five crews were unable to make
correct protective action recommendations for the conditions of
a general emergency without a radiological release occurring.
These findings resulted in a Notice of Violation being issued
for inadequate emergency response personnel training.
The final inspection during this assessment period was conducted
.I September 16-20, 1985. The licensee conducted a joint emergency
'
response exercise with the NRC, state, and both parishes
participating. The results of this inspection indicated that
there was reasonable assurance that LP&L could adequately
protect the health and safety of the public during an emergency.
Five deficiencies were identified for LP&L action. Two of the
deficient areas were previously pointed out to LP&L management
following the operations walk-throughs as areas of concern. The
deficiencies involved not notifying the NRC of the declaration
of an-emergency and updating information to the state. The
three remaining deficiencies involved management restrictions on
information to the NRC, duties of the emergency director, and
inadequate space for the NRC site team personnel in the technical l
support center command center. l
The licensee has reduced the requirenents for personnel
retraining to approximately one-half-those in place'for initial
training. Staffing appears adequate to man positions established
,
by the emergency response plan.
2. Conclusions
It appears that some essential po-tions of training were reduced
or deleted by the retraining progiam that was established. This
,
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- reduced program resulted in areas of ineffective response .y
.
licensee emergency response personnel during operations
'
walk-throughs and the annual exercise. Licensee management's
response to NRC concerns did not appear to be timely and ;
effective.
i
' LP&L entered this assessment period with no significant
f deficiencies and a minimal number of open items. The findings
!
of the NRC inspections conducted during the evaluation period
! indicate that, overall, the licensee's emergency preparedness
1
program is adequate to protect the health and safety of the
i public. ;
l The licensee is considered to be in performance category 2 in
this area.
lt
3. Board Recommendations
a. Recommended NRC Actions
The level of NRC inspection in this functional area should
continue at the same level.
. b. Recommended Licensee Actions
!
l The level of management attention to the implementation of
the emergency preparedness program should be increased to
ensure proper response to NRC-identified items. Emphasis
should be given to addressing the NRC Notice of Violation -
and deficiencies. The licensee should evaluate the
,
emergency preparedness retraining program as to scope and
- depth.
,
.
4 .
Training and Qualification Effectiveness.
~ ~
?
I. l
l
l
, 1. Analysis i
e a
<
An inspection of training was perforved to ascertain that the
~
licensee is accomplishing maintenance training and establishing
a program of licensed and nonlicensed training to meet Institute
i for Nuclear Power Operation (INP0) guidelines.by December 1986.
- Selected licensee potentially reportable event reports (PRES)
were reviewed to determine if events vere'apparently caused by,
or. negatively influenced by, maintenarice training. No problems
attributable oto training were identified.
'
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l
1 Two LERs were causally related to technical support personnel
training:
- . Missed sample on gas decay tank. (85-19) l
. Failure to take gas decay tank samples. (85-11)
Ten LERs were causally related to operator training:
'
! . . Mode change was made with inoperable containment spray
<
pump. (85-55)
- . Radiation monitor was made inoperable for trouble shooting
i
and required sampling was not performed. (85-52)
. Reactor trip caused by operator entering incorrect ,
addressable constant to control element assembly calculator-
,
(CEAC). (85-51)
. Reactor trip due to over feeding the steam generators.
(85-44) ,
. Reactor trip caused by out-of-range axial shape index
(ASI). (85-32)
! -
i . Reactor trip caused by CEA position deviation. (85-28)
J
Failure to correctly " rack in" 4160 v breakers. (85-23)
f .
I . Reactor trip initiated by opening suction isolation valve
on out-of-service condensate pump. (85-14)
. Reactor trip from high steam generator water level.
(85-08)
. Containment spray actuation caused by failure to reset
initiation relays. (85-06)
On October 16, 1985, the NRC administered the only set of '
operator (R0 and SRO) licensing examinations during this
appraisal period. Of the 22 candidates taking the. examination,
9 passed. All failures were on the written examinations. The
success rate attained on this examination was iow compared to
the last examination administered at W3 SES in which 16 of 17
candidates passed.
Since the last appraisal period the plant training department
has moved into a new training facility. This facility has space
a'llotted for the plant-specific simulator that is presently
>
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.
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under construction. Additionally, licensee management has
dpproved a plan to remodel one of the present site buildings to
house the maintenance training laboratories. and general employee
training.
2. Conclusion
Overall performance in training has been satisfactory.
Management involvement is apparent as evidenced by the expanded
facilities, plans for a plant-specific simulator, and plans to
remodel one of the present site buildings to house maintenance
training laboratories and general employee training. Staffing
of the training department appears to adequately support stated
goals. Analysis of the LERs and the high failure rate on the
October 16, 1985, R0/SRO examination indicate that the training
conducted is not always effective. However, most of the
candidates who failed the examination exhibited a weakness in
only one area.
The licensee is considered to be in Performance Category 2 in
Training and Qualification Effectiveness.
3. Board Recommendations
a. Recommended NRC Actions
<
The NRC should continue to monitor licensee progress
towards INP0 accreditation. Inspections in the training
area should continue at the basic level.
b. Recommended Licensee Actions
The licensee should closely monitor his program to assess
completion of all actions necessary to obtain INP0
dCCreditation by December 1986.
Furthermore, the licensee should evaluate PRES, LERs,
CIWAs, quality notices, and other problem identification
documents to measure and increase training effectiveness.
Continued LP&L management attention needs to be directed
toward timely completion of the plant ;;-c.ific simulator.
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J. Security and Safeguards
1. Analysis
The physical security staff performed four inspections during
this assessment period. No violations or deviations were
identified. The security program made a smooth transition into
the operating license phase because of the prior experience
gained through early implementaticn of the security program.
Two of these four inspections focused on following up on
allegations. The security officers were well prepared and
guided through training and supervision. The program is well
supported by management and the access control and intrusion
detection equipment is maintained effectively under a
surveillance and preventive maintenance program. Corrective
maintenance is prompt.
There is effective communication between the site security
management and the regionally based NRC inspectors.
2. Conclusion
The licensee's security program has recently evolved from the
startup phase to commercial operations. The extensive
preparation during the pre-startup phases is reflected in their
current effective security operations. Licensee corporate and
site management attention and involvement are strong and
responsive to NRC initiatives.
The licensu is considered to be in performance category 1 in
this area.
3. Board Recommendations
a. Recommended NRC Actions
The level of NRC inspection effort in this functional area
should be maintained at the normal level as prescribed in
the security and safeguards operational procedures during
the first year of commercial operation.
b. Recommended Licensee Actions
Care must be taken to ensure that the quality of the
selection and training techniques for the replacement of
security personnel continues at the high-level employed to
begin the program. '
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K. Licensing Activities
1. Analysis
The f4RC Office of fluclear Reactor Regulation has performed an
dssessment of licensee performance in the functional area of
Licensing Activities. Refer to Attachment 1 for details of this
assessment.
2. Conclusions
As discussed in Attachment 1, the licensee is considered to be
in Performance Category 2 in this functional area.
3. Board Reconmendations
a. Recommended NRC Actions
The hRC should continue timely processing of licensing
actions.
b. Recomended Licensee Actions
Licensee management should continue to be highly involved
in licensing activities. They should concentrate on those
items suggested for improvement in Attachment 1.
L. Outages
Two outages occurred within the context of the startup program and
initial operations. Specific inspections to assess outage
performance were not performed. Therefore, the licensee was not
assigned a performance category in this functional area.
V. SUPPORTIfiG DATA AND SUMMARIES
A. Major Site Activities
W3 SES began the appraisal period having just received a low power
(5%) license. Initial criticality was achieved on March 4,1985,
with the issuance of the full power license occurring March 16, 1985.
The plant entered commercial operstion September 24, 1985. Other
significant events of the appraisal period included:
1. An extended outage to repair the nain generator.
2. The Middle South Utilities capacity run.
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3. Outage to replace reactor coulant pump seals and a reactor
coolant system (RCS) resistance temperature detector (RTD).
B. Enforcement Actions
On May 24, 1985, the NRC issued Enforcement Package EA 85-10, which
contained a Notice of Violation and Proposed Imposition of Civil
Penalties in the amount of one hundred thirty thousand dollars. The
violations, which related to deficiencies in construction activities
identified by the NRC W3 SES Task Force, occurred prior to this SALP
period. The licensee responded on July 19, 1985, and this response
was being evaluated by the NRC at the end of this SALP period. Refer
to Table 1 for a cross reference of violations and deviations by
functional area for the current SALP period.
C. Licensee Conferences Held During Appraisal Period
A number of W3 SES status meetings were held between LP&L and NRC
management at the request of the licensee during this SALP period.
They involved a mutual exchange of regulatory and operating
information. None of these meetings dealt with regulatory
performance or enforcement.
D. Review of Licensee Event Reports (LERs)
Individual LERs were reviewed by the NRC and a discussion of their
relationship to performance is covered under the appropriate
functional areas. It should be noted that a single LER can relate to
i
performance in more than one functional area. The following
discussion is a summary of the licensee's overall effectiveness in
generating LERs which adequately identify the problems involved and
provide appropriate corrective action. To assist the licensee in
correcting any identified deficiencies, a detailed analysis
supporting this discussion is being forwarded under a separate cover
letter.
f An evaluation of the content and quality of a representative sample
of the LERs submitted by W3 SES during December 18, 1984, to December
31, 1985, SALP period was performed using a refinement of the basic
methodology presented in NUREG/CR-4178, "An Evaluation of Selected
l
Licensee Event Reports Prepared Pursuant to 10 CFR 50.73 (Draft)."
1 The results of this evaluation indicate that W3 SES has an overall
l
average LER score of 7.3 of a possible 10 points, thus ranking it
23rd out of 35 units that have been evaluated to date using this
methodology.
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. The principal weakness identified involves the root cause discussions
in the report. Deficiencies in the discussions' involving root cause
,' determination, especially for those events involving personnel error,
i
prompts concern that the corrective actions implemented as a result
of the investigation into cause may not adequately address the root
- cause. Further, the licensee's LER outline does not include a
i section specifically devoted to cause. Such a section is needed as
it would prompt better root cause discussions.
i;
E. Investigations and Allegation: Review
) The NRC received and reviewed five new allegations during 1985. None
j of the allegations identified substantive safety issues.
!
! During this evaluation period, numerous previously identified
technical allegations were closed based on the earlier findings of
the NRC W3 SES task force. These allegations were identified and
resolved prior to the beginning of this evaluation period.
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TABLE 1
ENFORCEMENT ACTIVITY
- No. of Violations in Each
Severity Level
Functional Area V IV OEVIATION
_
Plant Operations 1
Radiological Controls 1 2 1
Maintenance 2 5
Surveillance 2
Fire Protection 1
Security
Preoperational/Startup Testing
Quality Programs and Administrative Controls 4
Affecting Quality
Licensing Activities
Training and Qualification Effectiveness
TOTAL 3 16 1
- No violations 1.ere identified in Severity Levels I, II, or III.
.* #.
_ __. __ _ __
,
4
, Attachment 1
- N UNITED STATES
y') /j NUCLEAR REGULATORY COMMISSION
' ~
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7. ' cE REGloN IV
k, q 611 RYAN PLAZA DRIVE, SUITE 1000
ARLINGTON, TEXAS 76011
,, ,
Enclosure
FACILITY: Waterford Steam Electric Station, Unit 3
,
LICENSEE: Louisiana Power and Light Company
EVALUATION PERIOD: December 13, 1984 to December 31, 1985
!
PROJECT MANAGER: James H. Wilson
I. Introduction
i
This report contains NRR's input to the SALP review for the Waterford Steam
Electric Station, Unit 3. The assessment of the licensee's performance was
'
conducted according to NRR Office Letter No. 44, NRR Inputs to SALP Process,
! dated January 3,1984. This Office Letter incorporates NRC Manual Chapter 0516, Systematic Assessment of License Performance.
II. Sumary
3 NRC Manual Chapter 0516 specifies that each functional area evaluated will be
] assigned a performance category (Category 1, 2 or 3) based on a composite of
a number of attributes. The performance of the Louisiana Power & Light company
,
in the functional area of Licensing Activities is rated Category 2.
III. Criteria
The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of
License Performance.
IV. Methodology
.
This evaluation represents the integrated inputs of the Project Manager (PM)
and those technical reviewers who expended significant amounts of effort on
'
Waterford Steam Electric Station, Unit 3 licensing actions during the current
,
rating period. Using the guidelines of NRC Manual Chapter 0516, the PM and
!
each reviewer applied specific evaluation criteria to the relevant licensee
performance attributes, as delineated in Chapter 0516, and assigned an overall
rating Category (1, 2 or 3) to each attribute. The reviewers included this
information as part of the safety evaluation for each review. The PM, after
reviewing the inputs of the technical reviewers, combined this information
with his own assessment of licensee management and technical performance and,
arrived at a composite rating for the licensee. A written evaluation was
.
- - . _. _ ~ ___ _ ., - _ . _ ,
_
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then prepared by the PM and circulated to NRR management for comments, which
were incorporated in the final draft.
The basis for this appraisal was the licensee's performance in support of
licensing actions that were either completed or had a significant level of
activity during the current rating period. These actions consisted of requests
for license amendments, exemption requests, responses to generic correspondence
and requests for information, TMI items, and other licensing actions. The
elements considered in the basis for this appraisal are as follows:
Steam Generator Limitations
Inservice Inspection Program
CECOR Methodology
Fire Protection
Masonry Walls
Remote Shutdown Capability
Containment Coatings
for Changes to the Technical Specifications)
Review of Basemat Confirmatory Analyses
Final Closure of 23 Issues of 6/13/84 Eisenhut letter to
LP&L (Task Force)
Overall Licensing Activities (including Requests
V. Assessment of Performance Attributes
l The licensee's performance evaluation is based on consideration of the seven
attributes specified in NRC Manual Chapter 0516. These are:
-
Management Involvement and Control in Assuring Quality
-
Approach to Resolution of Technical Issues from Safety
Standpoint
-
Responsiveness to NRC Initiatives
-
Staffing
-
Training Effectiveness and Qualification
-
Enforcement
-
Reportable Events
A. Management Involvement and Control in Assuring Quality
,
The management team which was assembled to assure timely construction project l
completion and to support the operating phase has demonstrated active partici- '
pation in licensing activities and kept abreast of all current and anticipated
licensing actions. In order to enhance their involvement and increase their
control of licensing activities, LP&L has maintained an office in Bethesda.
This licensing presence near NRC, which included both technical and ~
administrative liasion, enabled LP&L management to be highly responsive to
staff suggestions and comments and expedited the resolution of licensing issues.
Through these actions, LP&L's management has demonstrated a willingness to
work closely with the NRC staff to establish realistic schedules for
completion of licensing activities. In addition, the management's involvement
i
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in licensing activities assured timely response and closure of issues. The
licensee's management consistently exercised good control over its internal
activities and its contractors, and maintained effective comunications with
the NRC staff.
On the basis of the above observations, a rating of 1 is assigned to this
attribute.
B. Approach to Resolution of Technical Issues from a Safety Standpoint
The licensee's management and staff have demonstrated adequate technical
understanding of issues involving licensing actions. Its approach to
resolution of technical issues has demonstrated technical expertise in all
licensing actions. The establishment of a licensing presence in Bethesda has
enabled LP&L to focus quickly and accurately on technical issues and to
determine which resources needed to be brought to bear to reach timely
resolution based on sound communications. The decisions related to licensing
issues have been thoughtful and routinely exhibit conservatism in relation to
significant safety matters. The licensee has provided adequate technical
justification for most licensing actions.
The licensee has made frequent visits to NRC to discuss proposed responses
to staff requests prior to making fomal submittals. This practice, coupled
with a local office to serve as a technical and administrative liaison between
the staff and the licensee, has been found to be beneficial to both the
staff's and the licensee's efficiency in processing licensing actions. i
Based on the above discussion, the rating of a strong 2 is assigned to this
category.
C. Responsiveness to NRC Initiatives
The licensee has been consistently responsive to NRC initiatives. During
the rating period, it has made every effort to meet or exceed the established
commitments and schedules for licensing activities, particularly those
associated with full-power licensing.
One area where LP&L could be more responsive is in providing the NRC staff with
information concerning licensee events. Waterford 3 had well over 50 reportable
events during the rating period. Many of these events, where the staff perceived
a possible safety problem, were of great interest to the staff, yet because ,
'
10 CFR 50.73 allows 30 days in which to file a written report, often
information about these events was available only after a several-day lag
following the staff's request for information. While the staff does not expect
to have analyses and written reports available immediately following an event,
the staff feels a need for accurate information about those events in which it
has significant safety interest. We would encourage LP&L to provide for better
communication between their plant staff and the LP&L licensing group to enable
the NRC to quickly and accurately follow future events.
Based on the above considerations, a rating of 2 is assigned to this attribute.
N
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D. Enforcement History
During the rating period, LP&L was assessed a proposed civil penalty of
$130,000 as a result of weaknesses in LP&L's construction QA program during
the multi-year construction phase of the Waterford 3 facility. The NRC
staff's review, inspection and evaluation of the issues involved has been
extensively documented. Although the violations did not appear to lead to an
end-product of unacceptable quality, the civil penalty was assessed to
emphasize the weaknesses in the construction quality assurance program and to
assure that these weaknesses did not carry over to the operational QA program.
LP&L's corrective actions during the rating period demonstrated a good under-
standing of the technical issues involved, were responsive to the technical
staff initiatives and were aggressively followed by utility management to
ensure timely completion.
Based on the above the considerations, a rating of a strong 2 is assigned to
this attribute.
E. Reporcable Events
During the evaluation period, the licensee had more than 50 events reportable
under 10 CFR 50.73. Many of these events were due to equipment problems that
arose during the conduct of the startup test program. Where the occurrence
of several related events indicated a trend, LP&L agressively pursued
necessary corrective actions to avoid a recurrence. Although the required
reports were filed within the specified time, some appeared to lack the depth
needed to closely examine the root cause. Also, as described in Section C
above, information concerning these events was often unavailable to the staff
in the time frame needed to support NRC follow up activities. It is hoped
that development of better communication between plant staff and LP&L
licensing will enhance the licensee's responsiveness in the future.
Based on the above considerations, a rating of 2 is assigned to this attribute.
F. Staffing
During the first part of the rating period, the licensee had licensed operators
in excess of those required for six operatiag shifts. Towards the middle of
the rating period, after full power licensing and after achieving 100%,
several licensed operators had resigned for various reasons. LP&L still
maintained adequate operating staff to support five shifts, including SR0s
with hot operations experience to serve as advisors. Furthermore, the licensee
has maintained a licensing and technical staff to evaluate events and design
changes, support license amcodment requests and assist in responding to NRC
needs and requests.
Based on the above consideration, a rating of 1 is assigned to this attribute. l
l
G. Training Effectiveness and Qualification
The licensee's responses to staff requests for additional information and !
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previously identified open items regarding. plant; personnel training programs
demonstrates a clear understanding of the issues. Resolution of these concerns
has been timely. LP&L has exceeded Commission criteria and requirements in
two key areas concerning training. . The licensee elected to have shift advisors
train and obtain SR0 licenses and has committed to installing a plant-specific
simulator to assist in operator training and requalification (this simulator is
currently scheduled to become operational in the 4th Qtr of 1986. The
licencee's training and requalification program has sufficient enrollment and i
appears capable of providing qualified, well-trained operators in excess of
LP&L's needs for the foreseeable future.
On the basis of the above considerations, an rating of 1.is assigned for this
attribute. ,
,
VI. Conclusion
A complete performance rating of a strong 2 has been assigned by the NRR SALP
evaluation effort for the current rating period.
.
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