ML20155J614
| ML20155J614 | |
| Person / Time | |
|---|---|
| Site: | Duane Arnold  |
| Issue date: | 05/21/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20155J607 | List: |
| References | |
| 50-331-86-01, 50-331-86-1, NUDOCS 8605270123 | |
| Download: ML20155J614 (42) | |
See also: IR 05000331/1986001
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SALP 5
SALP BOARD REPORT )
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U. S. NUCLEAR REGULATORY COMMISSION
REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
50-331/86001
Inspection Report
Iowa Electric Light and Power
Name of Licensee
Duane Arnold Energy Center
Name of Facility
September 1, 1984 through February 28, 1986
Assessment Period
8605270123 860521
PDR ADOCK 05000331
0 PDR
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I. 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 to NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
A NRC SALP Board, composed of staff members listed below, met on April 18,
1986, to review the collection of performance observations and data to
assess the licensee's performance in eccordance 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.
SALp Board, for Duane Arnold Energy Center:
Name Title
J. A. Hind Director, Division of Radiological
Safety and Safeguards
C. J. Paperiello Director, Division of Reactor Safety
E. G. Greenman Deputy Director, Division of Reactor
Projects
D. R. Muller Project Director, NRR
W. G. Guldemond Chief, Reactor Projects Branch 2
L. R. Greger Chief, Facilities Radiation Protection
Section
M. Schumacher Chief, Radiological Effluents and
Chemistry Section
M. A. Ring Chief, Test Programs Section
D. C. Boyd Chief, Reactor Projects Section 2D
R. B. Landsman Project Manager, Reactor Projects
Section 20
M. Thadani Duane Arnold Project Manager, NRR
J. S. Wiebe Senior Resident Inspector
N. V. Gilles Resident Inspector
P. R. Rescheske Inspector
S. M. Hare Inspector
P. L. Eng Inspector
J. P. Patterson Inspector
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II. CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or
operating phase. Functional areas normally represent areas significant to
nuclear safety and the environment. Some functional areas may not be
assessed because cf little or no licensee activities, or lack of meaningful
observations. e pecial areas may 'be added to highlight sionificant
observations.
One or more of the 0 Mowing evaluation criteria were used to assess each
functional area.
1. Management inv'olvement 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 and Construction events (including response to, analyses
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 a,3propriate.
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 invo'lvement are aggressive and oriented toward nuclear safety;
licensee resources are ample and effectively used so that a high level of
performance with respect to operational safety and ccnstruction quality is '
being achieved.
Category 2: NRC attention should be maintained at normal levels. L.icensee r
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 and involvement is acceptable and considers nuclear
safety, but weaknes;es are evident; licensee resources' appear to be strained
or not effectively used so that minimally satisfactory performance with
respect to operational safety or construction quality is being achieved.
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III. SUMMARY OF RESULTS
Based on SALP 3, 4, and 5 ratings, the overall regulatory performance of the
Duane Arnold Energy Center has continued to improve. Improved performance '
in the areas of Emergency Preparedness and Security is noted during the
SALP 5 assessment period. The rating in the area of Surveillance and
Inservice Testing improved from a Category 3 to a Categcry 2 tnis period.
Actual improvement is marginal when one considers the weaknesses identified
in pump operability and control of instruments. Performance in the area of
Maintenance / Modifications is given a Category 2 rating this period. This
is an apparent decrease from the Category 1 rating given during the last
period. The apparent decrease is a result of more in depth inspection in
this area during the SALP period and is not considered an actual decrease
in performance.
April 1, 1983- September 1, 1984-
Functional Area August 31, 1984 February 28, 1986
A. Plant Operations 1 1
B. Radiological Controls 2 2
C. Maintenance / Modifications 1 2
D. Surveillance and
Inservice Testing 3 2
E. Fire Protection 1 1
F. Emergency Preparedness 2 1
G. Security 3 2
H. Outages 2
I. Quality Programs and
Administrative Controls
Affecting Quality 2
J. Licensing Activities 1 1
K. Training and Qualification-
Effectiveness *
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- f.ot Rated (new functional areas for SALP 5)
- Not Ratr: (no basis for evaluation)
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IV. PERFORMANCE ANALYSIS <
A. Plant Operations
1. Analysis-
Portions of nine routine inspections were performed by the
resident inspectors covering plant operations. The inspections
included observation's of control room operations, reviews of
logs, discussions with licensed,and unlicensed operators,
verification of operability of' emergency.:ystems, and reviews
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of reactor building and turbinetbuilding equipment status.
Three violations were identified as follows:
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a. Severity Level IV - Failure to have two Average Power
Range Monitor (APRM) downscale trip functions (331/85021).
b. Severity Level IV - Two examples of personnel errors
(331/85021).
(1) Failure to identify Inoperable High Pressure Coolant
Injection deluge system.
(2) Failure-to establish baseline Average Power Range
Monitor and Local Power Range Monitor neutron flux
noise levels.
c. Severity Level IV - Violation of secondary containment
integrity (331/84012).
The first'two violations resulted from personnel errors during
recovery from the 1985 refueling outage. Although these errors
were identified by the licensee, the violations were issued as a
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result of' reoccurrence of personnel errors. The licensee took
extensive corrective action to reduce the administrative work
load and distractions of the Snift Supervisor so that he was~ free
to supervise plant operations. The action included designating
. an off-duty Shift Supervisor to screen all personnel and paper-
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work going to .the control room to ensure that personnel had a
need to go to-the control room and that'all administrative
requirements were met prior to requesting Shift Supervisor's
The corrective action was very
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approval to commence work. -
successful and ro further personnel errors c:ccurred during the
recove ry.' In additiori, no significant personne1' errors occurred
in thid : area during the rest of the assessment period.
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The th,ird violation occurred prior to the assessment period but
wa.s not addressed in the last SALP report. The licensee's
corrective' action was prompt and effective. This instance is
< considered an isolated case and is not representative of licensee
, performance during this assessment period.
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The small number of violations is a result of an aggressive effort
by plant management to ensure operations are conducted only after
proper planning and establishment of priorities. This was evident
during the period by the prior planning of control rod sequence
changes, a power reduction to evaluate and repair a reactor feed
pump, and the removing from and placing in service of the
Condensate Demineralizer and Reactor Water Cleanup Demineralizers.
Corporate management is frequently involved in site activities
and visits the site regularly. During recovery from the 1985
refueling outage, several personnel errors prompted management
to take timely and effective action to correct the trend. Action
was effective as evidenced by the sudden reduction in errors.
Only two scrams from power occurred during this assessment period.
These scrams occurred in 1984 as a result of equipment problems.
In addition, the licensee's success in this area is demonstrated
by a plant record of 234 days of continuous operation during the
assessment period. The run was terminated by a scheduled outage
for technical specification required surveillance testing.
The licensee demonstrated a clear understanding of technical
issues. Conservatism is routinely exhibited during application
of technical specification requirements and in determining
operability of equipment as was evidenced by licensee response
to an inadvertent relief valve lift due to an apparent ground and
the licensee response to a design anomaly which would prevent
sequencing of loads onto the Emergency Diesel Generators during
certain conditions. In both cases, the affected equipment was
declared inoperable and the action statement entered until a
thorough review by operators, engineers, management, the
Operations Review Committee, and the Safety Review Committee
showed that action was taken to ensure proper operation of the
affected equipment.
The licensee is responsive to NRC initiatives and timely and
technically sound responses are given in almost all cases.
The operations area staffing is adequate and the positions are
identified with authorities and responsibilities well defined.
Overtime is controlled and not excessive.
Plant Management places importance on the professional conduct of
operating personnel. A dress code has been established and is
usually adhered to. Control Room atmosphere, although improving,
needs further work. At times the noise level becomes slightly
elevated. Although no effect on plant safety or operator
awareness has been noted, this detracts from the overall
professionalism of the Control Room.
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2. Conclusions
The licensee is rated Category 1 in this area which is the same
rating as the last assessment.
3. Board Recommendations
None.
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B. Radiological Controls
1. Analysis
Seven inspections were conducted during this assessment period by
region based inspectors. These inspections included operational
and outage radiation protection, plant chemistry / radiochemistry,
confirmatory measurements, environmental protection, effluent
releases, TMI action plan items, radiological waste management,
and transportation activities. The resident inspectors also
reviewed this area during routine inspections including frisking
techniques, anti-contamination clothing use, radiological barrier
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use, step-off pad use, and radiation surveys. Five violations
were identified as follows:
a. Severity Level IV - Failure to follow the proper procedure
for work it a locked high radiation work area, resulting
in unnecessary radiation exposure (331/85012).
b. Severity Level IV - Failure to adequately evaluate radiation
hazards associated with entering a locked high radiation
area (331/85012).
c. Severity Level V - Failure to identify the waste
classification for a drum of radioactive waste on the
shipping manifest (331/85005).
d. Severity Level V - Failure to follow release procedures when
releasing (to the river) circulating water system contents
which had been slightly contaminated with water from the
condenser hot well (331/85022).
e. Severity Level V - Failure to collect one of the wildlife
samples for the second half of 1983 and one for the first
half of 1984, and one of the triannual soil samples during
the growing season (May-September) in 1984 for the
radiological environmental monitoring program (REMP)
(331/85009).
The licensee was responsive to these violations; corrective
actions were timely and appeared to be effective as recurrence
of the problems have not been evident. The violations appear to
be isolated incidents rather than indications of programmatic
weaknesses.
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Staffing in this functional area has generally improved. The
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staff appears to be experienced and competent. Efforts are
continuing to reduce reliance on contractor personnel. The
Dosimetry Coordinator, formerly a contractor position, was
filled internally during this assessment period. Additionally,
, the licensee has reduced the number of contract radiation
protection engineers and HP technicians during this assessment
period. Contractor heal ~th physics technicians are scheduled to
be replaced by licensee technicians as the licensee technicians
become shift qualified. A new position, Corporate Chemist, was
created and filled by the former Chemistry Coordinator. Several
additional staffing changes including the ALARA Coordinator,
Assistant Radwaste Coordinator, Acting Chemistry Coordinator,
and Assistant Chemistry Coordinator positions, were necessitated
by internal reassignments during this assessment period. These
positions were expeditiously filled with no observed lack of
continuity.
Management involvement in the functional area is evident. There
is consistent evidence that managers and supervisors are involved
in the day-to-day activities of the plant. The radiation protec-
tion group is represented at a weekly plant planning meeting,
where representatives from all plant areas discuss work scheduled
for the next week and the support required from other plant
groups. Representatives from health physics, dosimetry, deconta-
mination, radwaste, ALARA, and chemistry meet daily to discuss
problem areas, activities in progress, and activities scheduled.
These types of meetings are indicative of positive management
involvement in the coordination of plant activities.
Responsiveness to NRC initiatives has been adequate during this
assessment period. The licensee made significant progress in
reducing reliance on contractor personnel in both technical and
supervisory positions, was responsive to a gaseous effluent
monitor alarm setpoint problem, and resolved previous discrepan-
cies in the laboratory intercomparison analyses.
A conservative approach to resolution of radiological control
issues is routinely exhibited. Personnel radiation exposures
during 1984, a nonoutage year, were considerably lower than the
U.S. average for BWRs. Exposures for 1985, however, were
significantly elevated due to the licensee's ten year Inservice
Inspection (ISI) of the drywell and torus, the Induction Heating
Stress Improvement program (IHSI) in the drywell, and the recir-
culation piping weld overlay repair, in addition to the work
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normally performed during routine outages. The ISI/IHSI,
drywell, torus, and weld overlay doses contributed approximately
- 740 person-rem of the 1500 person-rem dose for 1985. The
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licensee's dose average over the last five years has been
approximately 800 person-rem. The U.S. average for BWRs over
this period was approximately 1000 person-rem. An Exposure Goals
Program was implemented during this assessment period as part of
a continuing effort to reduce radiation exposure to as low as
reasonably achievable (ALARA). This program sets annual exposure
goal limits by work groups and is intended to provide a method to
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measure cost-effective results in exposure reduction and ensure
supervisory awareness of personnel exposure. The licensee has
placed a considerable and continuing effort into reducing the
number of contaminated areas in the turbine building, reactor
building, and the radwaste building during this assessment
period.
The licensee continues their conservative policy of prohibiting
routine liquid radioactive releases. There were two liquid
releases during this assessment period: (1) a small planned
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release of about one liter of water occurred during condenser
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tube leak repair, and (2) a release of about a million gallons
of water occurred after the circulating water system inadver-
tently received about 8,000 gallons of slightly contaminated
water from the condenser hotwell during the refueling outage.
Concentrations of liquid as well as gaseous effluents have
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remained well below applicable release limits during this
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assessment period A minor problem with the procedure for
- calculating the alarm setpoint for normal range gaseous effluent
monitors was identified. In response, a timely change was made
to the procedure.
The volume of solid radioactive waste shipments, normally elevated
because of the restriction on liquid radioactive releases, was
further increased this assessment period by the extensive plant
cleanup program and efforts to ship as much radwaste as possible
prior to possible burial site restrictions after January 1,1986.
The licensee has implemented methods of reducing solid radwaste,
including compacting, hand sorting, and segregation. The
licensee appears to have adequately implemented the 10 CFR Part 61
and 10 CFR Part 20.311 requirements for radwaste classification
and form. Radwaste procedures were appropriately mcdified to
include these requirements and suitable correlation factors.
Licensee chemistry and radiochemistry programs were satisfactorily
implemented with no apparent problems in meeting regulatory
requirements. Laboratory equipment was of generally good quality
and adequate to perform required analyses. Quality controls were
in place for major analytical equipment with results indicating
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stable operation. Supervisory personnel were well acquainted with
the instruments and aware of operating problems and limitations.
Technicians observed were proficient and knowledgeable in the
analyses performed. The licensee has a generally satisfactory
program for testing technician competence using vendor supplied
blind samples and results have generally agreed with vendor
values. Two small problems noted in this program were the
generous ( 30%) deviations accepted by the licensee for metals
analyzed by atomic absorption spectroscopy and a systematic bias
(about 10%) in radioactive sample comparisons with the vendor.
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Laboratory space is quite crowded but the laboratory appeared to
be efficiently run. Climate control remained poor with unreliable
air conditioning, minimal air movement, and temperatures higher
-than optimal for analytical instruments and personnel. The
licensee is aware of the ventilation problems, having identified
them in a 1982 internal audit, but the design change package for
corrective action was given a low priority.
In confirmatory measurements the licensee achieved generally
satisfactory results, with 36 out of 39 comparisons in agreement
with the NRC. During the previous assessment period a continuing
problem was noted with Sr-89 and Sr-90 analyses comparison.
During this assessment period licensee performance improved in
this analysis.
Other than the failure to perform certain technical specification
required sampling and analyses (see violation above), implementa-
tion of REMP was generally satisfactory during this assessment
period. As a result of a licensee audit of the REMP, management
control over the program was improved to minimize errors and
omissions. The improvement included assigning specific responsi-
bility for the program and developing a method to keep management
informed of the program status.
2. Conclusions
The licensee is rated Category 2 in this crea. Licensee
performance was determined to be improving.
3. Board Recommendations
None.
C. Maintenance / Modifications
1. Analysis
Portions of nine routine inspections were perfonned by the
resident inspectors covering this area. In addition, one
inspection was performed by a resident inspector from another
plant and two regional based inspections were performed in this
area. The inspections included reviews of normal maintenance
and modification activities to ensure that approvals were
obtained prior to initiating work, activities were accomplished
using approved procedures, post maintenance testing was completed
prior to returning components or systems to service, and parts
and materials were properly certified. In addition, work planning
and scheduling was reviewed as well as the effectiveness of
administrative controls to ensure proper priority is assigned.
Five violations were identified as follows:
a. Severity Level V - Failure to follow Main Steam Line
Isolation Valve (MSIV) repair procedure (331/85010).
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b. Severity Level IV - Failure to perform post maintenance
testing on secondary containment interlocks -(331/85029).
c. Severity Level IV - Equipment drain sump pump timers
installed incorrectly (331/85029).
d. Severity Level IV - Inadequate engineering review of field
change request (331/85029).
e. Severity Level IV - Failure to conduct maintenance trending
(331/85032).
Item a. was a minor instance where the maintenance procedure
required certain data to be taken on Main Steam Line Isolation
Valve (MSIV) stems. This type of data was previously used to
evaluate MSIV performance improvement actions. In this instance,
the MSIV stems were being replaced with improved stems, and
therefore, the data was not taken. The licensee took action
to ensure that the workers are aware that procedures should be
changed in such cases.
Item b. was a result of not specifying a post maintenance test
after repairs to a secondary containment interlock. The
licensee has made major changes to the method used to specify
post maintenance testing.
Item c. was a result of a modification made in 1974 and is not
considered representative of present performance in this area.
Item d. was a result of a reviewing engineer's failure to recognize
the effect of changing the orientation of a flow detector. The
licensee changed the administrative requirements to ensure that
whenever possible the engineer that approves such changes is the
same engineer who initially approved the design.
Item e. was previously identified by the licensee and corrective
actions have been in progress since 1983 to complete a historic
computerized trending system.
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There were no major violations. There were several minor
violations which may indicate minor programmatic breakdown in
this area. The licensee has taken action to perform a major
revision to the administrative controls for maintenance
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activities which should correct this minor breakdown.
No significant events occurred relevant to this functional area.
Events are promptly reported, and in most cases completely
reported and analyzed. A large number of equipment failures
occurred which may be indicative of the adequacy of the corrective
and preventative maintenance program. Several reportable events
were the result of the High Pressure Coolant Injection or Reactor
Core Isolation Cooling systems being inoperable. Some of these,
however, were the result of the licensee intentionally removing
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the system from service for corrective maintenance in order to
improve the system's reliability. The licensee has also formed
a task force to review and recommend corrective action covering
these systems' reliability. The licensee has greatly reduced the
number of Reactor Water Cleanup Isolations which were caused by
false signals.
There has been increasing evidence of prior planning and
assignment of priorities. Corporate management is usually
involved and decision making is usually at a level that ensures
adequate review. As evidenced by spare parts problems with the
drywell Hydrogen-0xygen analyzers (caused unusual event and start
of required shutdown) and the Electric Fire Pump (caused pump to
twice exceed seven day out-of-service limit), increased
management attention appears to be warranted.
Technical issues are generally understood and conservatism is
generally exhibited. The licensee is responsive to NRC
initiatives with acceptable resolutions proposed initially in
most cases. This is evidenced by licensee response to problems
concerning control of maintenance activities, NRC concerns about
High Pressure Coolant Injection and Reactor Core Isolation
Cooling reliability, and trending of corrective maintenance.
During the special inspection of the licensee's reliability
program for HPCI and RCIC, it appeared that the licensee (1) was
not using trend information that was available in their deviation
report listings, (2) had excessively used cause codes " unknown"
and "other," (3) had a weak corrective maintenance policy
regarding root cause determinations, and (4) had an apparent
need for more QC or peer type inspections on maintenance work
involving technical specification required equipment.
In regards to these concerns, the licensee did provide generally
timely resolutions to quality related technical issues; however,
corrective action to preclude recurrence was weak. Corrective
action was usually taken but was not always effective at
correcting the root cause of the problems in the HPCI and RCIC
- systems as indicated by their occasional repetition. On some
occasions, proposed corrective action was delayed or found to be
not effective in producing the desired reliability improvement in
HPCI and RCIC. This observation was limited to the apparent
conditions and work related to HPCI and RCIC systems and may not
apply to other areas. The licensee has responded very well to
'hese areas of concern and have a reliability improvement program
A high percentage of Main Steam Isolation Valves (MSIVs) have
repeatedly failed local leak rate tests. The licensee has
replaced the stems and disks of these valves in an attempt to
improve their reliability. Although the MSIVs were leak tested
immediately following this replacement, they have not been tested
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after placing the plant in service following the 1985 refueling
outage. The next required test is during the 1987 refueling
outage and the NRC has requested the licensee to consider leak
testing at least one of these valves on a noncontrolling basis
during an outage prior to the 1987 refueling outage. During the
only outage since the replacement stems and disks were installed,
the licensee considered and rejected the testing of these valves.
The rejection was based on (1) the licensee's confidence that the
replacement stems and disks will increase valve reliability, and
(2) the leak testing could not be performed on a noncontrolling
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basis.
Key positions are filled on a priority basis with experienced
personnel. This is evic'enced by the prompt filling of the
Maintenance Engineering Supervisor position with a former
Operations Shift Supervisor (Senior Reactor Operator Licensee).
The Maintenance Superintendent is in Senior Reactor Operator
training, and the acting Maintenance Superintendent has taken
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an aggressive role in improving prior planning of maintenance
activities and overall maintenance performance. Permanent plant
staffing is marginally adequate. Maintenance has approximately
a three month backlog of work and high reliance is placed on
contractor help to keep the backlog manageable. The licensee
is reducing dependence on contractor help by hiring more
maintenance personnel.
Equipment problems were the cause of a high number of LERs which
could be reduced by improvement in preventive and corrective
maintenance practices; however, the long continuous run
(234 days) supports the conclusion that material conditions
are not significantly affecting plant operation. The licensee
has repeatedly demonstrated this commitment to maintaining the
plant by delaying recovery from outages until all necessary
maintenance is complete.
2. Conclusions
The licensee is rated Category 2 in this area, which is a change
from the last SALP rating. In hindsight, and after more indepth
inspection the Board concluded that the prior Cr.tegory 1 rating
may have been too high. However, improvement has been noted
during this period, especially in the area of prior planning.
3. Board Recommendations
None.
D. Surveillance and Inservice Testing
, 1. Analysis
During the assessment period, the resident inspectors routinely
inspected this area. These inspections included observations of
technical specification required surveillance testing to verify
adequate procedures were used, that instruments were calibrated,
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and that test results conformed with technical specification
and procedure requirements. In addition, several regional
inspections were conducted in this area. These inspections
included startup core performance, Containment Integrated Leak
Rate Tests, and inservice testing. Eight violations were
identified as follows:
a. Severity Level V - Maintenance and test equipment not
adequately controlled by surveillance procedures
(331/85001).
b. Severity Level V - Failure to document equipment use
history evaluation (331/85001).
c. Severity Level IV - Failure to perform as found
Containment Integrated Leak Rate Test (331/85017).
d. Severity Level IV - Failure to determine safety-related pump
operability via vibration measurements as delineated in the
ASME Code (331/85024).
e. Severity Level V - Failure to properly implement
surveillance procedures (331/85025).
f. Severity Level IV - Use of defective flow meter to obtain
surveillance data (331/85026).
g. Severity Level IV - Inadequate surveillance on drywell
equipment drain sump timers (331/85029).
h. Severity Level IV - Use of an unidentified instrument to
determine equipment operability (331/85026).
Items a., b., f., and h. are examples of insufficient control of
instruments used for equipment operability determinations. In
response to this issue, the licensee established a program to
identify inoperable or degraded instruments using tags and to
specify required instruments in appropriate procedures; however,
it is noted that communications among Operations, Plant
Performance and Instrument and Controls personnel must be
improved to assure use of proper instruments for surveillance
and inservice testing. The licensee is encouraged to pursue
this concern aggressively.
Item c. resulted from the licensee's failure to follow their
technical specifications in the area of Containment Testing,
specifically the requirement for an as found Type A test. While
the licensee has the largest allowable containment leakage in
Region III, they also have had consistent difficulty with
excessively leaking containment isolation valves, the primary
source of containment leakage. Any lack of containment integrity
due to excessively leaking isolation valves or personnel error
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may not have been realized because of their incorrect practice of
performing maintenance and repairing leaky containment isolation
valves prior to the performance of Type A tests. The licensee
is presently pursuing an exemption from these requirements that
will allow them to perform containment leak tests at the end
instead of the beginning of outages. The exemption will require
that they keep detailed records of containment leakage path
repairs to facilitate the calculation of an as found Type A
test result.
Item d. identifies the licensee's failure to determine
safety-related pump operability in accordance with the methods
delineated in the ASME Code for vibration monitoring. The
licensee subsequently verified the operability of all safety-
related pumps and has agreed to revise the appropriate procedures
to ensure future compliance with Code requirements; however, due
to past plant practices, valid vibration histories for six out of
18 safety-related pumps, including all the ECCS pumps, do not
exist.
Item e., as well as several open and unresolved items identified
in the areas of Integrated Leak Rate Testing, inservice testing
and portions of the startup test programs, are evidence of the
licensee's failure to follow procedures and properly record test
data. Inconsistencies regarding procedural requirements and
plant practices as well as the licensee's interpretation of the
term " operable" as it relates to inservice testing requirements
were also noted. Although inspections of the licensee's surveil-
lance programs were not conducted by Region based inspectors
during the last SALP period, the number and scope of the problems
identified indicate that identified deficiencies have existed for
an extended period of time.
Item g. is a result of a surveillance test not adequately testing
the technical specification required alarm function of the
drywell equipment drain sump timers. This resulted in this
alarm function being inoperable since a modification was made
to the timers in 1974. The licensee has initiated action to
review all surveillances to ensure adequate testing is performed.
There are multiple violations which do not indicate a major
programmatic weakness. Corrective actions are timely and in most
cases effective. However, in the case of Item d., the licensee's
actions were inadequate and resulted in Violation f.
ihere is evidence of prior planning and assignment of priorities;
however, as evidenced by two missed surveillances, additional
attention is warranted. Improvement has been noted as not as
many surveillances were missed in this assessment period compared
with last assessmen'. period. Decision making is usually at a
level that ensures adequate management review; however, inservice
testing problems sometimes do not receive timely management
i
15
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s
review and therefore, questionable equipment may not be declared
inoperable. Repeated difficulties resulting from test instrument
inadequacy have been noted. This problem has not caused any
technical specification action statements to be exceeded. The
licensee has taken action to correct this problem.
Attention to detail is sometimes lacking in record keeping,
procedure compliance, and testing techniques. This is evidenced
by violations for failure to follow procedures, and failure to
take proper vibration measurements. Corrective action is usually
taken but is not effective in all cases in correcting the root
cause as evidenced by occasional repetition of problems.
Understanding of issues is generally apparent, and conservatism
is generally exhibited. The licensee's surveillance program is
conservative with respect to technical specification requirements.
Conservatism is demonstrated by: (1) except for the physics area
several systems / instruments are surveilled at a frequency greater
than required by technical specifications; (2) all core cooling
pumps (RCIC, HPCI, RHR, Core Spray) and many valve monthly
surveillances also include the performance of the quarterly
surveillance requirements of the technical specifications; and
(3) the licensee routinely implements and enforces surveillance
requirements prior to the technical specification amendment
issuance which requires the surveillance. '
There were two reportable events related to this functional area
during SALP 5. One of. these was caused by personnel error (1.5's
of all LERs). The other event was caused by an inadequate
surveillance procedure. During SALP 4 there were five events
related to this functional area that were caused by personnel
error (7.4?; of all LERs). The above data indicates improvement
has been made in this area.
Staffing is adequate; however, responsibility for ASME Code
compliance, including program implementation and decision making
regarding inservice testing matters, is delegated to a contractor-
employee. The licensee has recently hired an individual to
assume these duties, but increased management attention is
warranted to ensure improvement in this area while this employee
gains experience in this position.
2. Conclusions
The licensee is rated Category 2 in this area. While this is an
improvement from the Category 3 given in the last period, the
actual improvement is marginal when one considers the concerns
identified in pump operability and control of instruments.
3. Board Recommendations
None.
16
i
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.
E. Fire Protection
1. Analysis
During this assessment period, the resident inspectors performed
routine inspections in this area, including evaluation of
potential fire hazards, plant housekeeping and cleanliness, and
compliance with the plant fire protection plan. The inspections
showed that housekeeping and cleanliness is very good in readily
accessible areas of the plant, but improvement in equipment rooms
is desirable. One special inspection was conducted by Region III
personnel to assess the licensce's compliance with 10 CFR 50,
Appendix R, close out previously identified open items and verify
compliance with routine fire protection program requirements.
The inspection showed that implementation of the Appendix R
requirements was the best observed in Region III. One violation
in this area was identified:
Severity Level V - Failure to control aerosol cans of
flamable spray paint in reactor building (331/85003).
The violation occurred at the beginning of an extended refueling
outage. Extensive and effective corrective actions were taken
including administrative procedure changes and tours which
prevented additional problems during the outage with many
additional contractors onsite and extensive maintenance and
construction work in progress.
On two separate occasions the Electric Fire Pump was out of
service for greater than seven days. In both cases this resulted
from maintenance and spare parts problems. The licensee has
taken corrective action in this area and on another occasion
extensive effort was made to ensure the Diesel Fire Pump was
restored to service in the required seven days even though
extensive repair by a vendor was required.
Most of the responsibility for the fire protection program
implementation and Appendix R compliance was assigned to
contractor employees. Although management and station technical
staff were actively involved in the decision making process
regarding these matters, the licensee acknowledged the need for
greater involvement by members of their staffs and voluntarily
implemented positive corrective actions prior to the inspection
by Region III.
The licensee resolved technical issues with appropriate
justification and documentation and was enthusiastically
cooperative with regard to concerns raised by the NRC.
Response time was appropriate and communications were positive.
17
. .
.
Licensee personnel that were observed appeared to be
knowledgeable of their assigned responsibilities in most areas.
Some concerns were raised regarding training and experience of
some individuals and their overall qualifications to perform
assigned duties. The licensee acknowledged these concerns and
agreed to make additional efforts to provide required training
and experience for identified areas of weaknesses, thereby
developing a higher degree of in-house expertise in this area.
The level of staffing appeared to be adequate.
2. Conclusions
The licensee is rated Category 1 in this area. This is the
same rating as the last assessment.
3. Board Recommendations
None.
1. Analysis
Three inspections were conducted during the period to evaluate
the following aspects of the licensee's emergency preparedness
program: emergency detection and classification; protective
action decision making; notifications and communications;
implementation of changes to the emergency preparedness program;
shift staffing and augmentation; emergency preparedness training;
public information program; and independent audits of the
emergency preparedness program. One inspection involved the
observance of the annual exercise.
No_ violations were identified in the two routine inspections
conducted in January 1985 and January 1986.
Three weaknesses in the October 29, 1985, exercises were
identified as follows: (1) an unsatisfactory demonstration of
the Post Accident Sa.npling System (PASS) in both preparation
and timeliness; (2) one of the two offsite Radiological
Monitoring Teams (RMT) lost communications with the Emergency
Operations Facility (EOF) and the other RMT for approximately
one and a half hours; and (3) one of the two offsite RMTs failed
to follow the Emergency Plan Implementing Procedures (EPIPs) in
the collection, packaging and identification of soil, water, and
vegetation samples. The licensee's overall performance in the
October 1985 exercise was still rated above average. The
Control Room, the EOF, and the Emergency News Center performed
very well. The Technical Support Center (TSC) demonstrated an
above average performance with only minor problems. Subsequent
to this exercise an unannounced PASS drill demonstrating sample
acquisition and analysis was conducted successfully and
monitored by the Senior Resident Inspector. Therefore, the
response to this exercise weakness is considered satisfactory.
18
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.
In the previous SALP report, concern was raised by the NRC
regarding dose calculation and assessment capabilities. Licensee
performance in the October 1985 annual exercise and in " hands-on"
walkthroughs in the January 1986 inspection clearly indicated an
improvement and satisfactory competency in using the MIDAS
computer system for obtaining dose assessment values for
potential radiation release values based on in-plant radiation
levels. In addition, all licensee representatives observed by
NRC on both these inspections properly used a flow chart with
various plant conditions listed to " trigger" Protective Action
Recommendations (PARS) in conjunction with the dose assessment
values. The NRC's concern from the previous SALP period
regarding dose calculation and assessment capabilities for
potential release situations has been resolved by the licensee.
In June 1985, the licensee completed training, including simulator
training, for all Operations Shift Supervisors (OSSs) and other
key Control Room personnel, on the six new Symptomatic Emergency
Operating Procedures (EOPs). These Symptomatic E0Ps have been
revised to incorporate accident classification references to
assist the OSS as initial Emergency Coordinator to better
mitigate and classify accidents and cross-reference the E0Ps with
the EPIPs. These new E0Ps, integrated with the EPIPs, should be
helpful to OSS's from a cause and effect standpoint in
classifying an accident correctly and without undue delay.
The licensee has improved in their response to activations of
the Emergency Plan. A total of 20 emergency occurrences
(activations of the Emergency Plan) were evaluated by Region III
in two inspections during the SALP rating period. In each case
the appropriate EAL was chosen, and notifications were made to
State and local governmental agencies within the required time.
This improvement is partially due to a revised notification form
and also to continued training emphasis on emergency detection,
classification, and notification. Management has demonstrated
responsiveness to NRC emergency preparedness issues whether a
violation, major issue or minor issue is involved.
I The licensee has hired two staff assistants to assist the
Corporate Emergency Planner. One will be assigned to the plant
on a full time basis, while the other will be located at the
corporate office. A full time person at the site should improve
the interaction and cooperation for emergency preparedness from
the operating divisions and the health physics group.
Presently the licensee has been maintaining nine key staff
positions with 13 additional emergency support personnel
available for duty within 30 minutes. Shift augmentation was l
successfully demonstrated in the October 1985 exercise. The l
licensee improved its method to assure that individuals assigned
to Emergency Response Organization (ER0) positions were trained
annually.
19
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.
Lesson plans have been improved to include suggestions from
drill and exercise critiques. Two instructors are currently
assigned as full time EP instructors in the Training Center,
which was not the case earlier in the SALP period.
In summary, the licensee is continuing their effort to improve
the emergency preparedness program. Corporate and plant manage-
ment have demonstrated their involvement in this area and have
projected a positive attitude and response to our concerns.
Continued vigilance is needed in initiating action to correct and
improve the emergency plan implementing procedures. Also effort
should continue in improving the quality of the drills and the
annual exercise as a vital part of emergency preparedness
training.
2. Conclusions
The licensee is rated Category 1 in this area which is an
improvement over the previous SALP rating.
3. Board Recommendations
None.
G. Security
1. Analysis
Five security inspections were conducted by region based
physical security inspectors during the assessment period.
Three of these inspections were special and two were routine.
Additionally, the Resident Inspector routinely conducted
observations of security activities. Two violations were
identified relative to the security program as follows:
a. Severity Level IV - Some security officers had not
fulfilled training in some tasks required by the Training
and Qualification Plan. Additionally, supervisory
personnel failed to document the completion of training
for certain tasks (331/84015).
b. Licensee identified item - The licensee failed to conduct
maintenance in a timely manner (331/85031).
Allegations from a former licensee security guard were received
by Region III that dealt with security at the Duane Arnold
facility. The inspectors determined that the licensee took
adequate and immediate followup action after receiving the
information. Although the allegations could not be fully
substantiated, there was an apparent lack of communications,
and loss of some documents.
20
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.
With respect to the licensee identified item the following
actions were taken: (1) a security preventative maintenance
program was implemented; (2)-a security equipment hi: tory file
was established; and (3) corrective maintenance was conipleted
in a timely manner.
Information received from the monthly reports indicated that the
corrective maintenance turnaround has improved. The licensee
sent a security force representative to another facility to
gather additional information which may help them to further
improve their maintenance program. Additionally, the licensee
has two maintenance technicians dedicated to security
maintenance.
The corrective action for violations is timely and effective in
most cases.
'
One identified weakness pertained to onsite organizations'
participation-in security contingency drills. The licensee was
receptive to the NRC's recommendation for improvement in this
area.
Two weaknesses were identified with the licensee's security force
training program. One weakness pertained to the nonuniformity
in the training received by guards. The second weakness pertained
to the significant reduction in the number of licensee-conducted
security related drills.
In 1984 and 1985, both the NRC and the licensee had identified
the need for a dedicated security training individual. The
licensee temporarily filled the position on January 6, 1986.
On March 12, 1986, the same individual accepted the official
position.
Although weaknesses had been identified with the training
program, it is a defined program and contributes to an adequate
understanding of work responsibilities. One unresolved item
was identified regarding the licensee's capability to maintain
the required minimum response force while in compensatory
measures. This issue has been forwarded to NRC Headquarters
for resolution.
The construction activities onsite have impacted on the security
program. The licensee has taken the additional steps necessary
to maintain an adequate level of plant security during this
phase.
There were no technical issues involving physical security from
a safety standpoint which required resolution during this
assessment period.
Events reported under 10 CFR 73.71 were properly analyzed and
reported in a timely manner.
21
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Positions within the security organizations are identified and
responsibilities are defined. There is good communication
between 'the security supervisor and the security force.
The records are generally complete, well-maintained and
available.
Good communications exist between site security, plant upper
management, and Region III.
Plant management's support for the security program has increased
and was made evident by the purchasing of new CCTV cameras; .
computer software modifications; handguns and walkthrough
explosive detectors.
In summary, the plant management's support for the program has
increased. This has been shown in the upgrading of some security
equipment and positive actions taken to improve the security
maintenance program.
2. Conclusions
The licensee is rated Category 2 in this area which is an
improvement from the previous SALP 3 rating achieved in the last
SALP assessment period. That rating was primarily based on the
enforcement history during the rating period which totaled two
Severity Level III violations and three Severity Level IV
violations. A positive trend has been identified during this
assessment period in that management support for security has
increased, and the licensee continues to increase its efforts in
upgrading security.
3. Board Recommendations
None.
H. Outages
1. Analysis
The resident inspectors performed routine inspections during
outages and four regional based inspections were performed
concerning outage related work. These inspections included
observation of maintenance activities including administrative
requirements, review of planning activities, refueling activities,
major plant modifications including the ARTS (Average Power
Range Monitor, Rod Block Monitor, and the associated Technical
Specification Improvements) Modification, weld overlays of
recirculation piping welds, and post outage testing. Five
violations were identified as follows:
a. Severity Level IV - Numerous examples of failure to have
or follow written procedures during the ARTS Modification
(331/85035).
s
22
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b. Severity Level V - Failure to maintain tool and material
logs during weld overlays (331/85011).
c. Severity Level IV - Failure to conduct Type B testing on
drywell penetration CV-4305 (331/85028).
d. Severity Level IV - Failure to control activities affecting
quality (removal of plug from CV-4305) (331/85028).
e. Severity Level IV - Failure to have an appropriate procedure
and failure to follow a hydrostatic test procedure valve
lineup for the Residual Heat Removal System (331/85028).
With respect to item a., the safety-related portion of the
modification (APRM's) constituted a very small portion of the
modification, and no problems were found in this area. The
main problems were identified in the Rod Block Monitor modifica-
tions which, while not safety-related, are considered important
to safety by virtue of minimizing conditions where plant safety
could be jeopardized. These problems were due to the following
weaknesses: (1) a high level of quality was not maintained
during the activities; (2) resolutions generally addressed
symptoms rather than root causes and a clear understanding of
significance and implications of technical issues was lacking;
(3) responses to inspector-identified concerns were generally
not timely or thorough, and frequently lacked technical depth;
and (4) the personnel responsible for or involved in the
modification activities frequently lacked the knowledge to
adequately respond to questions posed by the inspectors. It
should be noted that these observations are based on a narrow,
non safety-related area, and are not indicative of the entire
outage area.
Item b. appears to be an isolated case which was promptly
corrected by the licensee. Item c. resulted from not having
appropriate procedures for designation of post maintenance
testing. The licensee has extensively revised the administrative
requirements for designation of post maintenance testing to
ensure that knowledgeable individuals in the appropriate
departments specify appropriate post maintenance testing.
Items d. and e. resulted from inattention to detail by workers
and insufficient supervision to ensure attention to detail.
Contractors were primarily involved with this work. The licensee
is reducing dependence on contractors by increasing the number
of utility maintenance workers. Although contractors cannot
be completely eliminated from the workforce during outages,
additional utility maintenance workers will allow closer
supervision of the contractors. The licensee plans to utilize
more utility workers in the future, j
l
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No major violations were identified. Item d. did result in an
uncontrolled unauthorized breach of containment integrity;
however, the plant was not in a mode that required containment
integrity. Several examples of failure to follow procedures is
not indicative of a programmatic problem but is evidence of
inattention to detail and insufficient supervision. Corrective
action for the potential programmatic problem concerning post
maintenance testing was extensive and effective.
'
Increased evidence of prior planning and setting priorities has
been noted. The 1985 refueling outage was one of the best
planned outages in plant history. The outage included refueling,
10 year Inservice Inspection Activities, inspection and
refurbishing of several Control Rod Drive Mechanisms, rebuilding
of Main Steam Isolation Valves with new stems and disks, and
Induction Heating Stress Improvement of recirculation piping
welds. When cracks were identified in recirculation piping
welds, the additional work was integrated into the schedule. The
schedule was continually updated as work and concitions changed.
The effectiveness of the maintenance is evidenced by the long run
after the outage. The outage group was established prior to the
start of the SALP period, but during the SALP period has gained
new prominence as the authority concerning the outage schedule.
The outage group obtains input from the work group concerning
various activities and integrates them into the schedule. Since
the input comes from the work group, the work group is expected
to meet the schedule except for unforeseen circtmstances. As
work groups have gained experience in forecastir.g activity
resource requirements, the schedules have becoue better.
Refueling activities were conducted in an excellent manner. The
core was completely off loaded and reloaded without difficulty.
Communication between the control room and the refueling floor
was excellent. Continuous communications ensured that the
control room knew where each fuel bundle was at all times.
Decision making is generally at a level that ensures adequate
management review, and corporate management is frequently
involved in site activities. Management is kept informed of
maintenance status by a daily meeting at which all the new
maintenance requests are discussed and priorities evaluated.
Management is therefore able to obtain consistent information
and revise priorities as necessary. A weekly planning meeting
also provides a forum for discussion of complex activities
involving several departments to assign responsibilities and
track open items. This meeting also allows management to follow
priority maintenance. Corporate management is kept informed by
frequent plant visits and discussions with plant management.
l
24
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In some cases records are not complete and not well-maintained
as evidenced by problems noted with the ARTS modification
documentation and the unauthorized and undocumented removal of
a plug from containment isolation valve CV-4305. Minor procedure
violations occasionally occur but have not resulted in safety
significant events. Corrective action concerning programmatic
problems is prompt and effective, but minor procedure violations
continue.
The licensee generally demonstrates a clear understanding of
technical issues, and conservatism is normally exhibited. This
is demonstrated by the licensees approach to the recirculation
piping cracks and the problems associated with the CV-4305 valve
and penetration. The licensee is generally responsive to NRC
initiatives as evidenced by the extensive, prompt, and effective
corrective action taken to improve the Maintenance Action Request
(MAR) procedure.
Occasional events, attributable to causes under the licensee's
control, have occurred that are relevant to this functional area.
Examples of such events are: (1) A vent plug was removed and not
reinstalled in CV-4305: (2) Plugs were not reinstalled on Residual
Heat Removal relief valves following removal of gags after a
hydrostatic test; and (3) Failure to perform a Type B test on the
CV-4305 penetration. The first two events resulted in a failure
of a Type A Containment Integrated Leak Rate Test (CILRT). The
plugs were removed during the outage, and therefore, drywell
integrity was not required while the plugs were removed. A
Type B test was subsequently performed successfully on CV-4305
penetration, thereby showing that this item had no effect on
drywell integrity. As a result of these events, the licensee
has improved the maintenance procedures writer's guide to provide
guidance on procedure specificity and quality checks, has revised
tne hydrostatic test procedure, and has revised the MAR procedure
to provide more extensive review for designation of post
maintenance testing. The correttive action appears to be
extensive and appropriate.
Staffing is adequate with contractor support required during
outages and to support modification work. Key positions are
identified and responsibilities are defined. The licensee is
reviewing methods to minimize contractor dependency and to
integrate contractor and utility work force activities.
2. Conclusions
The licensee is rated Category 2 in this area. This is a new
area that was not included in the last SALP.
3. Board Recommendations
None.
25
. .
.
I. Quality Programs and Administrative Control Affecting Quality
1. Analysis
During the assessment period, the resident inspectors routinely
inspected this area, which included administrative controls for
maintenance and operations as well as deviation reports and
quality control department involvement in accordance with the
Quality Assurance Plan. In addition, this functional area was
examined as part of an inspection of QA programs in procurement,
offsite support staff, and receipt, storage and handling. Two
violations were identified as follows:
a. Severity Level V - Violation of secondary containment
integrity occurred as a result of inadequate post
maintenance testing of secondary containment door
interlocks (331/85029).
b. Severity Level V - Failure to identify a condition adverse
to quality (inadequate post maintenance testing)
(331/85029).
The violations resulted from the licensee's QA Program not
assuring proper quality for non safety-related equipment which
may affect the performance of safety-related equipment or
structures. In regards to Violation a., the maintenance error,
without adequate post maintenance testing, allowed a violation
of secondary containment. The condition adverse to quality was
not identified since the licensee's QA Program did not require
post maintenance testing for this equipment. The licensee
initiated broad corrective action by establishing a review
group to identify equipment in this category. The QA Program
is being changed to apply the appropriate quality controls. The
ARTS modification, discussed in Section H. (Outage), is also
indicative of an occasion where appropriate quality assurance
was not applied to a non safety-related system which affects
safety-related equipment.
Administrative control procedures which implement management
control, verification and oversight activities continue to be
improved. Administrative procedures which control maintenance
activities have been significantly improved while problems in the
areas of Surveillance and Inservice Testing. indicate that further
attention is necessary in these areas.
The Operations Committee and Safety Review Committee review of
plant activities is detailed and effective. Additional attention
is necessary to define and implement the training program referred
to by the Operations Committee charter. Control of the design
change process is generally good with major TMI modifications
26
. .
.
being implemented without problems; however, problems have been
identified with documentation and review of minor modifications.
The licensee has developed a minor modifications procedure to
improve control in this area. Corrective action systems are
excellent in identifying and documenting problems, but weaknesses
in determining root causes of problems have been noted.
Requirements for records are adequate; however, many examples
have been noted where insufficient attention to detail has
resulted in an incomplete or inaccurate records.
Decision making is usually at a level that ensures adequate
. management review and corporate management is usually involved
in site activities.
2. Conclusions
The licensee is rated Category 2 in this area.
3. Board Recommendations
None.
J. Licensing Activities
1. Analysis
a. Methodology
The basis for this appraisal was the licensee's performance
in support of significant licensing actions that were either
completed or had a substantial level of activity during the
current rating period. Some of these actions, consisting of
amendment requests, exemption requests, responses to generic
letters, and TMI items, are listed below as either multiplant
actions or plant specific actions.
(1) Multiplant Actions - included in this category were:
-Inspection of BWR Stainless Steel Piping (Complete)
-Environmental Qualification of Electrical Equipment
(Complete)
-Post Accident Sampling Modifications (Complete)
-Appendix I Technical Specification Implementation
Review (Complete)
-Detailed Control Room Design Review (Complete)
-Mark I Containment Long Term Program Implementation
(Complete)
-Masonry Wall Design
-Procedures Generation Package Review
-Salem ATWS Related items
-Technical Support Center-0737 Supplement 1
-Operations Support Center-0737 Suppiment 1
+
27
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.
-Emergency Operations Facility-0737 Supplement 1
-Hydrogen Recombiner Capability
-Safety Parameters Display System (Complete)
-Safety Concerns Associated with Pipe Breaks in the
(2) Plant Specific Actions - included in this category were:
-Update NDT Operating Limits (Complete)
-Thermal Hydraulic Stability and Single Loop Operation
(Complete)
-Reactor Power Uprate (Complete)
-Amendment to Security Plan (Complete)
-Lead Test Asserrbly Review (Complete)
-ARTS Improvement Modifications (Complete)
-Stainless Steel Piping Repair and Plant Restart
(Complete)
-Technical Specification Changes Related to NUREG-0737
Modifications
-ASME Code Relief Applications
-Extension of Alternate Safe Shutdwon Capability
Deadline
-Exemption from the requirements of 10 CFR 50.48
Appendix R,Section III J
b. Management Involvement and Control in Assuring Quality
During the present rating period, the licensee's management
demonstrated active participation in licensing activities
and kept abreast of all current and anticipated licensing
actions, making effective use of its plan for integrated
schedules of actions, and its licensing commitments tracking
system. Licensee management actively participated in an
effort to work closely with the NRC staff to establish
realistic and integrated schedules for all modifications of
the DAEC facility. In addition, the management's involvement
in licensing activities assured timely response to the
requirements of the Commission's rules related to Fire
Protection and Environmental Qualification of Electrical
Equipment. The implementation schedules for compliance with
the rules were fully met by the licensee. During its
refueling outage early in 1985, the licensee's management
took an aggressive part in assuring (1) thorough inspection
of the plants stainless steel piping, (2) completion of
repairs of all detected cracks in the stainless steel piping,
(3) completion of fire protection related modifications,
(4) completion of modifications related to environmental
qualification of electrical equipment, and (5) modification
related to TMI action items. All the modifications fully
met and some exceeded the Commission's requirements. An
example of exceeding the requirements was noted by the
Region III fire protection inspection team, which found
that the modifications of the plant and the procedures
exceeded the Commission's requirements, and the fire
28
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.
protection measures at the DAEC were the best of all the
plants seen by Region III inspection team. The licensee's
management consistently exercised good control over its
internal activities and its contractors to assure quality,
and maintained effective communication with the NRC staff.
The management's active participation was evident in its
firm involvement in the issues of significant potential
safety impacts. This was illustrated throughout this
rating period in the management's initiatives to seek
early staff guidance on the scope of the safety reviews ,
l required for future actions involving complex licensing )
'
issues.
c. Approach to Resolution of Technical Issues from a Safety
Standpoint
The licensee's management and its staff have demonstrated
sound technical understanding of issues involving licensing
actions. Its approach to resolution of technical issues
has demonstrated extensive technical expertise in all
technical areas involving licensing actions. The decisions
related to licensing issues have routinely exhibited l
conservatism in relation to significant safety matters as l
illustrated by the approach taken by the licensee to exceed '
the Commission's requirements related to rules for fire
protection and environmental qualification of electrical
equipment.
On occasions, when the licensee deviated from the staff
guidance, the licensee has consistently provided good
technical justification for such deviations. The Fire l
Protection Program and the program for Environmental
Qualification of equipment are good examples illustrating
the soundness of the technical justifications for deviations
from the guidance. When unusual events have occurred at the
Duane Arnold Energy Center, the licensee has invariably used
conservative approaches in dealing with the situations, and
performed in-depth analyses of safety issues raised by such
events. The licensee has consistently monitored itself to
assure that the safety systems function as designed and the
plant's technical specifications are well-maintained. An
example of a response to unusual events and self-monitoring
was the thoroughness with which the licensee identified and
dealt with the concerns raised by its own training staff
related to a potential problem of diesel generator load
sequencer bypass. As a result of the licensee's efforts
and communications to the staff, an information notice was
sent to other licensees for a potential diesel generator
sequencer problem. As stated above, the licensee made
frequent visits to NRC to discuss the forthcoming requests
for staff actions prior to formal submittals. This approach
has been consistently found to improve both the staff's and
licensee's efficiency in processing such actions.
29
_ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
, .
.
d. 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 as
illustrated by its responses to TMI action items, Appendix J
requirements and compliance with the rules related to Fire
Protection and Environmental Qualification of safety-related
electrical equipment. Perhaps the most significant
demonstration of the licensee's responsiveness to NRC
initiatives is its leadership of the industry in developing
and adopting an integrated schedule plan for all safety-
related modifications, and renewal of its license amendment
to continue to follow the integrated schedule plan. Since
establishing the integrated schedule plan over two and a
half years ago, the licensee has faithfully followed the
elements of the plan enhancing the ease with which it can
respond to NRC initiatives.
e. Enforcement History
This area is addressed in the other functional areas of
this report.
f. Reporting and Analyses of Reportable Events
The Duane Arnold Energy Center operated at power during the
first five months of the period and the last 7 1/3 months of
the period. The plant was in a scheduled refueling outage
during the 5 2/3 month period between February 3,1985 and
July 18, 1985. l
In the first five month operating phase, the unit operated I
with a reactor service factor * of 78% and reported 25
events ** to the NRC Operations Center per in CFR 50.72.
Three events involved reactor scrams, two of which involved
transients from operating power levels. The third occurred
inadvertently from less than 1% power while shutting down.
" Reactor Service Factor = (Hours of Critical Reactor
Operation /Possible Hours) x100%
- The number of events reported to the operations center
may not be the same as the number of License Event Reports
because of different reporting criteria and in some cases
an event initially reported to the operations center may
be reassessed as not reportable.
30
- -- _ _ - . _ . . - . - _ _
- - _ _ _ _ _ _ . - _ _ _ ,
. .
.
Twelve reported events involved inadvertent actuations of
Engineered Safety Features (ESF) equipment and are considered
to have low safety significance. Nine reported events
involved temporary inoperability of safety-related equipment
requiring entry into a Technical Specification Action
Statement. In all cases, the equipment was made operable
within time limits, and plant shutdown was not required.
Two events reported during this period were discussed at the
Operating Reactor Events Briefings. They were the' Auxiliary
Transformer Fire on November 4, 1984, and Failure of the
Start-up Transformer on November 22, 1984. Two events
, reported during the period involved fires onsite.
During the 5 2/3 month refueling outage, 23 events were
reported to the NRC Operations Center. Almost all of these
events involved inadvertent actuations of ESF equipment
during testing and maintenance operations. One event
reported during this period was discussed at the Operating
Reactor Events Briefings. This event involved Failure of
Leak Rate Tests on four of eight MSIVs on February 6,1985.
In the past 71/3 months, the plant has operated relatively
trouble-free with a reactor service factor of 100's.
Accordingly, there have been no reports of reactor scrams.
Twenty events have been reported to the NRC Operations
Center during this period. Seventeen of these events
involved temporary inoperability of safety-related equipment
requiring entry into Technical Specification Action
Statements. In all cases, the equipment was made operable
within time limits and plant shutdown was not required.
Three events involved inadvertent actuation of ESF
equipment and were considered to be of low safety
significance. One event reported during the period was
discussed at the Onerating Reactor Events Briefings. This
event involved discovery of a Des'.gn Deficiency with the
Emergency Diesel Generator (EDG) Load Sequencer.
Licensee events at the Ouane Arnold Energy Center appear to
have been reported promptly, accurately, and conservatively
in the case of entry into Technical Specification Action
Statements, Performance during the past seven months has
been very good with a frequency of event reports of less
than three per month and no reactor scrams.
g. Staffing
The licensee maintains a large licensing staff. The
licensing staff is rotated through tours of duty at the
plant to gain first hand experience of plant operations.
The licensee's management key staff are identified with well
defined authority and responsibility. The plant shift staff
exceeds the Commission's requirements by having extra
operators on shift during refueling in addition to those
specified in the Commission's rule.
31
. .
'
.
h. Training and Qualification Effectiveness -
There is no basis for evaluating this attribute during the
reporting period.
i. Housekeeping
The DAEC site and the facility continues to be maintained
at a high level of cleanliness. The plant is maintained
with clear markings, well organized storage of supplies,
and color coded signs which constantly caution workers
about safety significance of various areas of the facility.
The workers have been observed to behave in a disciplined
manner in conformance with goed housekeeping practice. The
- plant engineering and operating staff have been found to
conduct themselves in a highly professional manner, and no
adverse behavior of plant operators and other personnel was
observed during this reporting period.
2. Conclusion
An overall performance rating of Category I has been assigned
in the licensing area.
Not withstanding, we plan to give no less attention by NRC to the
DAEC licensing submittals. We further believe that no less
management effort on the part of the licensee should be exerted
in licensing activities.
3. Board Recommendations
None.
K. Training and Qual _ification _ Ef fectiveness
1. Analysis
Resident and regional inspectors have evaluated training and
qualification effectiveness during inspection of specific program
areas. No violations were identified in this area.
During inspection of operations activities; non-licensed
operators, control room operators, senior control room operators
(shift supervisors), and shift technical advisors were generally
knowledgeable and effective in carrying out their duties.
Examples of cases where knowledge and training appeared to be
deficient were: (1) Failure to have the required number of APRM
32
_ _ _ _ _ _
_- _ _ _ _ _ _ _ _ , _ _ . _ _ _ _ . _ _ _ _ . . . _ _ _ .
_.___ __ _.. -_ _
. .
'
-
. .
downscale trip functions;.and (2) Failure to obtain baseline APRM
and LPRM flux levels. These examples appeared to be isolated
cases and not programmatic., ,During the assessment period, ,
examinations were administered to 12 senior reactor operat'or and
five reactor operator applicants. The overall pass rate for
these candidates was 70%. This passing rate is lower than'the
national average. During the last. assessment period, the pass
rate was above the, national average. With the small number 'of
examinations, the significance of the pass rate cannot be
determined. The operating history during the assessment period
does not reflect any adverse effect.
During inspection of maintenance and outage activities,
instrument and control technicians, electrical maintenance
personnel, and mechanical maintenance pe'r'sonsfl wer'e generally
knowledgeable of their responsibilities. On several occasions
contractor personnel demonstrated inddequate' knowledge of the
importance of equipment and administrative controls. Examples of
-lack of contractor knowlddge discussed in'other sections of this
report were: (1) Unauthorized removal of a plug from drywell
isolation value CV-4305; and (2) Improper, implementation of the
return to normal valve lineup fe'. lowing residual Heat Removal
hydrostatic test. The problem with_ contractor knowledge may be
indicative of a programmatic pcobicm since contractor personnel
do not usually receive the plant oxperience or the plant specific
training that is normally given to' utility personnel.
'
During inspection of the radiological chemistry areas, regional
inspectors evaluated trsining and qQalification effectiveness.
Licensee training and qualification programs generally improved
during this assessment period. A step training program for new
HP technicians wai implemented. The training program consists of.
practical and academic tasks and represents the licensee's plan
for HP technician staffing for future needs. Despite some early
schedule slippage, the licensee plant to have their training
program INPO accredited by September 1986. Chemical Technician '
training is also being improved by implementa, tion of an eight- -
step program designed to be completed over a'four-year period.
The program, under the direction of the licensee's' Joint
Apprenticeship Training Committee, leads to a journeyman status
and appears quite adequate. Four of,the eight chemistry
technicians completed the program by'the summer of 1985.
Development of the program is directed toward eventual INP0
accreditation. Currently, training and qualification effective- ~
ness are characterized by an adequate understanding of work and
adequate adherence to procedures. '
.
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. .
.
During routine inspections, the knowledge of the technical staff
and managers appeared adequate. The licensee sends as many of
the technical staff to Senior Reactor Operator training as
possible. This takes knowledgeable individuals away from the
organization for long periods of time, but in the long run this
practice will improve performance overall. The licensee also
places design engineers in the quality assurance organization
for periods of time. This reinforces the importance of quality
assurance within the design engineering organization and will
lead to an overall improvement in this area. The Maintenance
Engineering Supervisor was a Senior Reactor Operator and the
Maintenance Superintendent is presently in Senior Reactor
Operator training. This further demonstrates the licensees
commitment to training.
The licensee is making good progress towards INPO accreditation
of training programs. Accreditation of the Shift Technical
Advisor, Senior Reactor Operator, Reactor Operator, Second
Assistant Nuclear Station Operating Engineer, and Nuclear Station
Auxiliaries Engineer training programs are expected in the near
future (May 1986) and the remaining training programs are expected
to be accredited by September 1986.
2. Conclusions
The licensee is rated Category 2 in this functional area.
3. Board Recommendations
None.
34
. .
.
V. SUPPORTING DATA AND SUMMARIES
A. Licensee Activities
The unit engaged in routine power operation throughout most of
SALP 5. A major schedu ed outage for plant refueling, modification,
maintenance, induction heating stress improvement treatment, and weld
overlays of recirculation piping began on February 3, 1985 and was
completed on July 18, 1985. After this outage the plant operated
for 234 consecutive days.
The remaining outages throughout the neriod are summarized below:
September 29 - October 25, 1984 Routine Maintenance
November 4 - November 11, 1984 Auxiliary Transformer
Failure
November 23 - November 26, 1984 Fire Suppression Deluge
System Tripped Startup
'
Transformer
The plant scrammed nine times (seven occurred while shutdown). In
1984, two at power scrams were caused by a short circuit in the
auxiliary transformer and a spurious fire protection deluge system
activation on the startup transformer. Six of the remaining scrams
were caused by spurious signals on the LPRM, IRM, or APRM channels.
One scram was caused by a failure to bypass the high Scram Discharge
Volume Level signal while resetting the RPS logic after another scram.
B. Inspection Activities
A special team inspection was conducted by Region III on November 24,
1984 to assess the licensee's actions in regard to the auxiliary
transformer failure. The inspectors found the licensee's staff to
function effectively in dealing with this emergency.
Additionally, a special in depth assessment of engineering,
maintenance, and surveillance testing activites associated with the
High Pressure Coolant Injection and the Reactor Core Isolation Cooling
systems was performed. The inspectors identified some concerns in
this area and the licensee initiated a reliability improvement program
'for these two systems.
Violation data for the Duane Arnold Energy Center is presented in
Table 1, which includes Inspection Reports No. 84012 through 86005.
35
. .
.
TABLE 1
ENFORCEMENT ACTIVITY
FUNCTIONAL NO. OF VIOLATIONS IN EACH SEVERITY LEVEL
AREA V IV III II I
A. Plant Operations 3
B. Radiological Controls 3 2
C. Maintenance / Modifications 1 4
D. Surveillance and
Inservice Testing 3 5
E. Fire Protection 1
G. Security 1
H. Outages 1 4
I. Quality Programs and
Administrative Controls
Affecting Quality 2
J. Licensing Activities
K. Training and Qualification
Effectiveness
TOTALS 11 19 0 0 0
C .~ Investigations and Allegations Review
1. A worker alleged that work hours were reduced as a result of
workers questioning why the chemical decontamination of the
recirculation system piping was cancelled. The chemical
decontamination was sc.heduled to reduce radiation levels to
workers. Inspection showed that the reduction in work hours
appeared to be unrelated to the concerns raised about the
decontamination cancellation. The inspection also showed that
the decontamination was cancelled as a result of possible
pitting and sensitization of piping. No violations were
identified.
2. A private citizen alleged certain individuals had never been
qualified as welders, but had " bought" their union cards.
Licensee records did not show that these individuals had ever
been to DAEC. No violations were identified.
3. While the unit has shutdown, an employee alleged that the
southeast corner room was flooded with three to four inches of
water and referred to the incident as an operations department
" screw-up." Inspection substantiated that the flooding had
occurred and further established that the cause was procedural
inadequacy and poor communications which led to personnel errors
in the system iineup. The licensee addressed this incident along
with several other personnel errors and initiated corrective
actions to prevent occurrence. No violations were identified.
36
. .
.
4. An anonymous allegation stated that the auxiliary transformer
had a history of problems and management had a " cavalier" attitude
towards the problems and made no attempt to investigate or
correct them. Inspection showed that the allegations were not
substantiated. No violations were identified.
5. A security guard alleged 12 security and one radiation protection
problems. Inspection showed the ellegation to be unsubstantiated.
The individual also filed a complaint of discriminatory employ-
ment practices with the Department of Labor. The complaint was
determined unproved. No violations were identified.
6. A contractor employee alleged harassment and employment
discrimination and identified four specific " defects."
Inspection showed the allegation concerning the four " defects"
to be unsubstantiated. Concerning harassment and employment
discrimination, the employee was informed how to file the
complaint with the Department of Labor. The complaint was
never filed. No violations were identified.
D. Escalated Enforcement Actions
There were no escalated enforcement actions during the assessment
period.
E. Licensee Conferences Held During Appraisal Period
1. November 27, 1984 (Glen Ellyn, Illinois)
Meeting to review Systematic Assessment of Licensee Performance
(SALP 4).
2. October 16, 1985 (Glen Ellyn, Illinois)
Meeting requested by the licensee to address concerns expressed
in recent NRC inspection reports.
F. Confirmation of Action Letters (CALs)
There were no CALs issued during this SALP assessment.
G. Review of Licensee Event Reports, Construction Deficiency Reports,
and 10 CFR 21 Reports Submitted by the Licensee
1. Licensee Event Reports (LERs)
LERs issued during the 18 month SALP 5 period are presented
balow:
37
_
r-
, .
.
_LERs No.
84-31 through 84-45
85-01 through 85-47
86-01 through 86-04
Proximate Cause Code * Number During SALP 5
Personnel Error (A) 1 (9)
Design Deficiency (B) 11 (13)
External Cause (C) 1 (1)
Defective Procedure (D) 4 (8)
Management / Quality Assurance
Deficiency (E) 5 (5)
Others (X) 24 (30)
No Cause Code Marked"* 20 ( 0)
Total 66 (66)
- Proximate cause is the cause assigned by the licensee according
to NUREG-1022, " Licensee Event Report System."
- NUREG-1022 only requires a cause code for component failures.
The numbers in parenthesis are the LERs in each category when all
the LER's are assigned cause codes.
In the SALP 4 period, the licensee issued 67 LERs in 17 months
for an issue rate of 3.94 per month. In the SALP 5 period the
licensee issued 66 LERs in 18 months for an issue rate of
3.67 per month. For most of the SALP 5 period, the technical
specifications prohibited any loss of secondary containment
thus requiring an LER to be issued regardless of the duration
of the loss. In January 1986, the NRC approved a revision to
the technical specifications to make them consistent with most
other technical specifications, and allow loss of secondary
containment for short periods of time without violation of
technical specifications. An LER, therefore, is no longer
-required if secondary containment is restored within the required
time period. If the LER's which would not be issued under the
revised technical specifications were deleted, the SALP 4 period
would have included 65 LER's for an issue rate of 3.82 per month,
and the SALP 5 period would have included 56 LER's for an issue
rate of 3.1 per month. The reduction in overall LERs and the
reduction in personnel errors is indicative of an improving
trend.
The office for Analysis and Evaluation of Operational Data (AE0D)
reviewed the LERs for this period and concluded that, in general
the LERs are of above average quality based on the requirements
contained in 10 CFR 50.73; however, they identified some minor
deficiencies. A copy of the AEOD report has been provided to the
licensee so that the specific deficiencies noted can be corrected
in future reports.
38
<
, . - .
. .
.
2. Construction Deficiency Reports
No construction deficiency reports were submitted during the
assessment period.
3. 10 CFR 21 Reports
No 10 CFR 21 reports were submitted during the assessment period.
H. Licensing Activities
1. NRR/ Site Visits / Meetings
a. Site Visits
March 20, 1985 - Detailed Control Room Design Review
(DCRDR) In Progress Audit
September 17, 1985 - Visual Inspection of the Impact of
Cooling Tower Drift on Vegetation
January 28, 1986 - Site Visit and Progress Meeting
i
b. Meetings
October 30, 1984 - SALP Board Meeting at Region III
November 27, 1984 - SALP Meeting with the Licensee at
-Region III
January 24, 1985 - Technical Specification Change Request
January 30, 1985 - Technical Specification Change Request
February 22, 1985 - TMI Modifications Related Technical
Specification Changes
March 7, 1985 - Technical Specification Changes for Lead
Test Assemblies (LTA's), Power Uprate, ARTS, and Reload
April 12, 1985 - DCRDR Program Change
April 22, 1985 - Stainless Steel Piping Inspection Results
June 14, 1985 - Emergency Technical Specification Change
Request
July 30, 1985 - Technical Specification Change Errors and
Actions to Prevent Them
October 3, 1985 - Meeting on Pipe Cracks and Technical
Specification Improvements
39
___ _ _ _ _ _ . _ _ __. __ _ _ _ -. _. - .
_ . _
. .
..
,
October 31, 1985 - Hydrogen Recombiner Capability
November 18, 1985 - Appendix I and Hydrogen Control
2. Commission Briefings
None.
3. Schedular Extension Granted
May 30, 1985 - extension of Alternate Shutdown Capability
requirements of 10 CFR 50, Appendix R to March 1987
4. Relief Granted
June 10, 1985 - Relief granted from ASME Coda Section XI
requirements related to torus-drywell vacuum breaker leakage
testing
5. Exemption Granted
July 1,1985 - Exemption from the requirements of 10 CFR 50.48
and 10 CFR 50 Appendix R Section III J
6. License Amendments
Amendment No. 107, dated September 4, 1984, incorporated the
containment high range monitor technical specifications.
Amendment No. 108, dated October 29, 1984, revised the technical
specifications to permit reduction in RHR service water flowrate
requirement.
Amendment No. 109, dated January 14, 1985, incorporated the
Radiological Effluent Technical Specifications (RETS).
Amendment No.110, dated February 1,1985, incorporated technical
specifications for Automatic Depressurization System (ADS) valve
automatic actuation.
Amendment No. 111, dated February 5, 1985 revised the setpoint
for turbine trip and low power load rejection reactor scrams.
Amendment No.112, dated February 26, 1985, revised the Security
Plan, and the guard training and qualifications.
Amendment No. 113, dated March 12, 1985, revised snubber testing
requirements.
Amendment No. 114, dated March 14, 1985, incorporated
administrative changes.
Amendment No. 115, dated March 27, 1985, incorporated technical
specification changes to permit uprating of the reactor rated
power.
40
, . __ _ _ _ _ _ _ __
._
.- . _ . .
. .
.
Amendment No. 116, dated April 11, 1985, incorporated changes to
permit storage of new and spent fuel Lead Test Assemblies in the
fuel pool.
Amendment No. 117, dated April 17, 1985, incorporated changes to
permit Cycle 8 reload.
Amendment No. 118, dated April 18, 1985, incorporated changes to
permit loading of the Lead Test assemblies in the core.
Amendment No. 119, dated May 28, 1985, incorporated changes to
assure thermal hydraulic stability and permit single loop
operation.
Amendment No. 120, dated May 28, 1985 incorporated extended load
limit line, and APRM and RBM technical specification improvements.
Amendment No. 121, dated May 28, 1985, revised the NDT operating
limits.
Amendment No. 122, dated May 28, 1985, incorporated changes to
conform to 10 CFR 50 Appendix J Type C testing.
Amendment No. 124, dated June 20, 1985, revised the effective
date'of Amendment No. 121.
Amendment No. 125, dated July 9, 1985, extended the effective
date of the license condition for integrated schedule.
Amendment No. 126, dated October 10, 1985, incorporated the
operator overtime restriction.
Amendment No. 127, dated December 5, 1985, incorporated
additional leak testing requirements for ADS accumulator check
,
valves.
Amendment No. 128, dated January 4, 1986, incorporated
corrections to RETS.
Amendment No.129, dated January 9,1986, incorporated an action
statement for maintaining pump discharge line filled.
Amendment No. 130, dated February 18, 1986, deleted the
terrestrial monitoring requirement and Appendix B to the
Technical Specifications.
7. Emergency / Exigent Technical Specification Changes
Emergency Amendment No. 124, dated June 20, 1985, revised the
effective date of Amendment No. 121 to permit testing against
pervious NDT operating limits.
8. Orders Issued
None
,
41
- - - -. . _ - _ . - - . _ _ _ - _,, -
. .
.
9. NRR/ License Management Conferences
None
10. Issues Pending
(a) Hydrogen recombiner capability.
(b) Appendix R exemptions.
(c) ATWS rule.
(d) Technical Specification changes for TMI Item III.D.3.4.
42