ML20195F804
Text
. _ _ - - _ _ -
[^
UCLEAR REpVLATORY COMMISSION uc ma aiwsst tvue s23 0 s ~ ~e.
O(
^
F t : R - % _ s,T.,,
s.
l RESP NSE TO FREEDOM OF l'^^'
!N ""
1
- %v /
INFORMATION ACT (FOlA) REQUEST
JUN 151988 ee..-
e
- m. t me,. s~.
C%ep 76uuere EtOUEsita PART l.-RECORDS RELEASED OR NOT LOCATID (See checked bonest No agency records subect to the request have been located No add. tonal agency records subrect to the request have been located Agency records subect to the request t*at are centd.ed e Append a are abeady a.adable for pubhc inspecton and copymg m the NRC Pubhc Document Room.
1717 H Street N W. Wasbegton, DC gency records subect to the request tat are contifed m Append-a M D_
_ a e be.ng ~ase asadaoie for pubbe especton ar4 copymg m the NRC Pubhc Docueer t oom 1717 H Street. N W. WasNeg'on DC. m a folder under tF s FOI A numter a-d reauester name The nonpropretary vers on of the pcocsa st trat you ag'eed to accect in a te>ephcre con =e'saton u'% a me-ter of my sta*f s now becq made avadable for pubhc escecten u
and coymg at the NRC Put3.c Docu ment Room.1717 H Street, N W. Washmgton. DC. en a folde' under the FOI A numter and requestet name Enclosed is eformation on how you raay obta.n access to and tre charges for copymg records placed c the NRC Pubbe Document Room,1717 H Street N W.. Washmgtm. DC Agency records sub,ect to the request s's enclosed Any apohcable charge for copies o' the records powded and payment procedu es are noted m the commerts sectort r
Records subsect to the request be.e been referred to another Federat agencyhesi for revew and derect respor'se to you in ve* of NRC s response to thes request, no further acton es beeg taken on appeal W!ter dated PART 11 A-INFORM ATION WITHHELD FROM PUBLIC OISCLOSURE Certain eformaton m the recuested records es being Mthheid from pubhc disclosu e pursuant to the FOI A eseect ons descr4>ed e and for the reasons stated in Part H. sec-r teons 8. C. and D Any re6 eased port.ons of the documents for which only part of the re-ord is beeg etFbeid are beag made awadat4e for pt.bhc inspecten and copymg m the NRC Pubhc Document Room.1717 H Street. N W, Washmgton. DC. e a folder under tNs FOf A n mber and requester name u
h A
b A%
W L
Lai W tMMI U
(d M
&tLv; g )
nNLnto
' 'Tbb.AlMLW
)
u g
7 W%
AU iLY
/ GM' DD1WA 1Q M
si a
gw u,
I M
T Q JtwL xtiw n1 at f
f' l
y,/ 7/
/
I h k/
1 8806270149 080615 PDR FOIA BOLEYO7-830 PDR
!/
v /NAtumE. 0 stCica p./,e os o/s/,..A Ms aso atConos
/.
j 1
l
\\
NRC FORM 464.er 9N>
JUN 151988
\\h h
OATE FREEDOM OF INF09MATION ACT RESPONSE FOIA NUMBERISO PAfti 118-APTLICABLE FOIA EXEMPTIONS Records subject to the request that are described in the enclosed Appendices are being withheld in the r entuety or in part under FO' A Exemptions and for the reasons set forth below pursuant to 5 U.S C. 552(b) an#d 10kFf79 Stal of NRC Regulations.
- t. The uthheld information s propedy vassded pursuant to Esecutive Order 123'A IEXEMPTION 1)
- 2. The wthheid mformation relates so6edy to the eternal personned rules and procedures of NRC. IEXEMPTION 21 3 The wthheld mformaton is specificany esernpted from pubhc drsclosure by statute ed cated (EXEMPTION 31 Seeion 141145 of the Atomic Energy Act *Nch proNbits the disciosure of Restncted Data or Formerly Aestncted Data 142 U S C. 2161-2166)
Secten 147 of the Atomic Energy Act *Nch proNtuts the drsclosu e of Unclass fied Safeguards Irdormaton i42 U.S C 216h.
r
- 4. The ethheld information is a trade secret or comrretcial or firencial oformaton that is beir g ethheid for the reasonds) indicated 'E/EMPTION di The mformaton is corscored to be conf,dential buseess (propretaryl irdormaton.
The informaton e conscered to be propretary eformaton pursuant to 10 CFR 2.790tdH1)
The mformaton was submitted and recerved m conf 4ence from a foreign source pursuant to 10 CFR 2190(d:(2) 5 The wthheld eformaton consists of ete' agency or intraagency records that are not availab6e through d scovery durmg litig. ton. DecJosure of predecesonal informaton
, would tend to inhitst the open and frank enchange of ideas essental to the dehberatrve process. Where recofds are wthheld m thest eetirety, the facts are ineatncat9y eterevaned eth the predecisor al mformaton There also are no reasoest#v segregable f actual portsons because the reiease of the f acta *ou:d permit an indirect mouiry eto tne predecesonai process of the agency. (EXEMPTION 51 6 The mthbeid eformation e enervted from public desdosure because its disclosu e would result m a clearly unwarranted invason of personal pnwacy. (EXEMPTION 61 r
- 7. The ethheld information conosts of evestigatory records comoded for law enforcement pu poses and is being ethheld for the reascWsl edrcated (EJEMPTION h r
Desclosure wou6d interfere eth an enforcorrent proceeding because it could reveal the scope, detecton. and focus of enforcement e*rorts. aM thus could poss bry stio* them to take acton to sh*2d potentei *rongoc*ng or a volaton of NRC requirements from evest gators. IEXEMP5CN 7( AH Disclosi.re would constnute an un*srrented evneson of personal pnvecy (EXEMPTION hC))
The eformaton cons.sts of rsames of mdwidua4 arsi other information the disclosure of %'uch would reveal identites of conf 4ca's sources IEXEMPTIO^! hon PART ll C-DENYING OFFICIALS Pursuant to M CFR 9 9 and or 915 of the U S %ciear Regviatory Ccmmason regulatons, it has been oeterm.ned that the eformaton uthhead e exempt from production or osciosure.
and that ets producten or decnosure e contrary to ese pubhc interest. The persons respons6e for the denei are those offices identifed betoa as denyng officiais and the 0 rector.
orusion of Rules and Records. Offee of Admmetraton for any denials that may be appeaied to the Emacutive Director for Operatonsiroo.
OENYING OFFictAL j,
WL f0F,FIC E 4,
HECORDS DEN:ED APPELLATE OFFICIAL T\\Mm. 0.%
%We(w,(A'Wddh)
Q h ndi N NbM.. l@edv D x
SEcansav too i
s
' b. E F
.X i
Gut b o
% M D#*RM 4 G 3
g I
PART 11 D-APPEAL RIGHT5 The denial by each denying officialidentfed in Part ll.C may be appealed to the Appellate Offsial identified in that section. Any such appeal must be in writing and must be made within 30 days of receipt of this response. Appeals must be addressed as appropriate to the Executnre Director for Operations or to the Secretary of the Commission. U S. Nuclear Regulatory Commission, Washington, DC 20%5, and should clearly state on the envelope and in the letter that it rs an "Appeal from an initial FOIA Decrsson.
EC Foau asa (Part !!
U.S. NUCLEAR RCOULATORY COMMISSION m
FOlA RESPONSE CONTINUATION
Re: F01A-87-830 APPENDIX A RECORDS AVA!LABLE IN PDR Memo from Faulkenberry to Crews,)et al, submitting regional 1.
7/7/80 evaluation of facility. (7 pages POR f 8008250212 2.
7/16/80 Letter from Crews to Papay discussing 7/15/80 meeting with utility re results of NRC regional evaluation of licensee performance. (8 pages) PDR f 8008250205 3.
4/2/8 Ltr from Withers (PGE) to Engelken (RV) re: Trojan SALP Board Report. (3 pages) PDR f 8204230473 Ltr from Martin to McCarthy forwarding IE Mgt Meeting (2 4.
10/14/83 Reports 50-206/83-22, 50-36.'/83-36 and 50-362/83-34.
pages)PDRf 8310200220 5.
1/15/85 Memo from Dodds to Region V forwarding pages 27, 28, and 29 from SALP Report 50-344/84-5. (4 pages) PDR f 8501220254 6.
9/24/85 Memo from Kirsch to Crews, et al, advising that regional SALP Review Board Meeting scheduled on 11/6/85 at Region V will cover April 1984 - September 1985. (15 pages) PDR f i
8510020337 i
7.
10/8/85 Memo from Kirsch to Crews, et al, forwarding supporting preliminary data for SALF. (25 pages) PDR f 8510150388 8.
7/2/86 LtrfromMartinRegionVtoMazur(WPPSS)re: SALP.(2 pages) PDR f 8607180016 i
g o
Re: F01A-87-830 APPEN0!X B RELEASED RECORDS PALO VERDE 1.
4/22/86 Ltr from Van Brunt (ANPP) to Kirsch (RV) re: SALP 86-056-026 (8pages)
RA_NCHO SEC0 2.
2/11/83 Ltr from Maltimoe (SMUD) to Engelken (RV) re: SALP Board Report (4pages)
SAN ON0FRE 3.
10/28/87 Ltr from SCE to Martin re: SALP San Onofre (9pages) 4.
8/26/83 Ltr from Bishop (RV) to SCE (McCarthy) re: SALP (53 pages)
TROJAN 5.
2/11/86 Ltr from Martin (RV) to Withers (PGE) re: Enforcement Conference and Review of 1985 SALP Report (6 pages)
WNP-2 6.
8/22/80 Ltr from Engelken (RV) to Ferguson (WPPSS) re:
NRC Re Evaluation of Licensee Performance WNP-2 (14 pages) gional
\\
APPENDIX C F01A 87-830 Release DATE DESCRIPTION 1.
3/6/84 Memorandum, R. Cooley, RIV, to G. L. Plumlee, Ft. St. Vrain SRI, subject:
Fort St. Vrain SALP Input On Operator Licensing (1 page)
{
2.
1/18/85 Memorandum, R. A. Cooley to D. D. Chamberlain, River Bend SRI, subject: River Bend SALP Input On Operator Licensing (1 page) 3.
1/24/85 Memorandum, R. A. Cooley to J. Jaudon, RIV, subject: SALP Input For River Bend Station (1 page) 4.
2/28/85 Memorandum, R. Cooley to D. DuBois, Cooper Nuclear Station SRI. subject:
Cooper Nuclear Station SALP Input On Operator Licensing (1 page) 5.
3/18/85 Memorandum, R. Cooley to L. Yandell, Fort Calhoun SRI, subject:
Fort Calhoun Station SALP Input On Operator Licensing (1 page)
APPENDIX C FOIA 87-830 Pg 2 l
Release i
DATE DESCRIPTION I
6.
7/1/85 Memorandum, R. A. Cooley to C. Johnson, South Texas SRI, subject:
South Texas Project SALP Input On operator Licensing (1 page) l l
l 7.
7/2/85 Memorandum, R. Cooley to W. Johnson, Arkansas Suelear One SRI, subject: Arkansas Nuclear l
One SALP Input On Operator Licensing (1 page) l i
8.
1/10/86 Memorandum, R. Cooley to L. Constable Waterford 3, subject:
SALP Input For Waterford 3 Licensed Operater Trai-ing (1 page) 9.
2/13/86 Memorandum, R. Cooley to D. Hunnicutt, subject:
Wolf Creek SALP Input On Operator Licensing (1 page) 10.
7/8/86 Memorandus, R. A. Cooley to J. Jaudon, subject:
SALP Input For Cooper Nuclear Station (1 page)
[
11, 8/6/86 Memorandum, R. A. Cooley to J. P. Jaudon, subject:
l SALP Input For Cooper Nuclear Station (1 Page) l
APPENDIX C FOIA 87-830 Pg 3 i
Release DATE DESCRIPTION 12.
10/1/86 Memorandum, Ralph A. Cooley to Dorvin R. Hunter, subject:
Input To FCS SALP Training Section (1 page) 13.
1/22/87 Memorandum, R. Cooley to D. Hunter, subject:
ANO SALP Input On operator Licensing (1 page) attached Evaluation Report on ANO Unit 1 (1 page)
Evaluation Report on ANO Unit 2 (1 page) 4 14.
2/23/87 Memorandum, R. Cooley to L. Constable, subject:
Vaterford 3 SALP Input On Operator Licensing (1 page) t 15.
3/17/87 Memorandum, R. Cooley to D. Hunter, subject:
Volf Creek SALP Input On Operator Licensing (1 page) 16.
3/24/87 Phnorandus, R. A. Cooley to J. Jaudon, subject:
SALP Input For River Bend Station (1 page) 17, 6/3/87 Memorandum, R. Cooley to J. Jaudon, subject:
Ft. St. Vrain SALP Input For Operator Licensing (1 page) 18.
1/6/88 Memorandum, J. L. Pellet to G. L. Constable, subject: South Texas Project SALP Input On C$trator Licensing (2 pages)
Re: F01A-87-830 APPENDIX 0 1
EXEMPTION 5 DIABLO CANYON 1 & 2 1
l 1.
8/7/87 Memo from Mendonca, to etal, re: Forwarding of Inspection and LER Data for Diablo Canyon (12 pages)
- 2.
SALP-Evaluation flatrix for Operatina Phase Functional Areas. (5 pgt 3.
8/4/86 Memo from Kirsch to Crews, et al., re SALP for Diablo Canyon j
l (Period 8/1/85 through 7/31/86)
(13 oages).
4.
7/22/86 Memo from Kirsch to etal, re: SALP for Diablo Canyon (Period August 1, 1985 thru July 31,1986)
(16 pages)
PALO VERDE 1, 2 & 3, 5.
12/2/87 Memo from Kirsch, to etal, re: Transmittal of Draft SALP Report (44 pages)
RANCHO SECO 6*
11/21/86 Memo from Chaffee to Martin, re: Transmittal of Rancho Seco SALP Report and Recomendations Regarding NRC Actions (3 pages) 7.
8/7/86 Metro from Miller, to etal, re: SALP for Rancho Seco (period 6/1/8E through 6/30/86)
(67 pages) 8.
7/19/85 Memo t,om Kirsch, to etal, re: SALP for Rancho Seco (period 12/1/83 through 5/31/85)
(23pages) 9.
8/20/81 Memo from Young, to etal, re: Input data for SALP Review Board for Rancho Seco (ag pages) i 10-8/8/80 Memo from Regional Evaluation Review Board to Crews, re: Regional Evaluation of Rancho Seco - June 1979 through June 1980 (9pages)
- Denotes Denied in Entirety
-. ~
Re: F0lA-87-830 APPENDIX D F0IA 87-830 Ej.EMPT10N 5 Page 2 RANCHO SEC0 - continued 11.
10/23/80 Memo from Faulkenberry to etal, re: SALP Inspection & Reporting Requirements (3 pages)
SAN ONOFRE 1, 2 & 3 12.
3/26/86 Memo from Kirsch to etal, re: SALP for San Onofre Units 1, 2, & 3 (October 1,1984 thru 3/31/86)
(15 pages)
TROJAN 13.
12/30/87 Memo from Chan thru Knighton to Kirsch, re: NRR SALP input for Trojan and PGE for the report period from 11/1/86 thru 11/30/87 (11 pages) 14.
12/2/87 Memo from Kirsch to etal, re: SALP for Trojan (period 11/1/86 thru 11/30/87)
(41 pages) 15.
11/12/86 Memo from Kirsch to etal, re: SALP for Trojan (period 11/1/85 thru10/31/86)
(32 pages) 16.
10/24/85 Memo from Kirsch to etal, re: SALP for Trojan (period 11/1/84 thru10/31/85)
(26 pages) 17, 2/11/82 Memo from P. Johnson thru Zewtzig to etal, re: SALP - Trojan (43pages) 18.
9/16/81 Memo from Zewtzig to etal, re: SALP Board Review of Trojan (22pages) i l
u
Re: F01A-87-830 APPENDIX D FOIA 87-830 EXEMPTION 5 Page 3 TROJAN - continued
- 19 2/81 SALP Staff Sumary - Trojan - Regional Evaluation (9/79-8/80) (7 pages) 20.
9/25/80 Memo from Regional Performance Evaluation Board - Trojan to Crews re: Regional Evaluation of Trojan - Septemger 1979 through August 1980 (13 pages)
WNP-2 21.
7/31/87 Memo from Kirsch to Martin, re: Transmittal of WNP-2 SALP Report and rec:mmendations regarding NRC actions (2pages) 22.
7/1/87 Memo from Kirsch to etal, re: Transmittal of draft SALP report (44 pages) 23.
5/12/87 Memo from P. Johnson to etal, re: Forwarding of inspection and LER data for WNP-2 SALP (10 pages) 24 7/2/86 Memo from Kirsch to Martin re: Transmittal of WNP-2 SALP report and recommendations regarding NRC actions (31 pages) 25.
3/14/86 Memo from Kirsch to etal, re: Transmittal of draft SALP report
{45pages) 26.
Memo from Bradfute thru Bernero, Adensam to Lainas, re: NRR evaluation of Washington Public Power Supply System's Perfonnance - Draf t (14 pages) 27.
2/9/86 Memo from P. Johnson to etal, re: Forwarding of Inspection and LE data for WNP-2 SALP (10 pages) l 28' Memo from Chairman, Osignate WNP-2 SALP Board thru Kirsch to Mart Transmittal of WNP-2 report and recomendations regarding NRC re:
actions (2pages)
- Denotes Denied in Entirety l
Re: F0lA-87-830 APPENDIX E DOCUMENTS WITHHELO IN PART NOTE:
COVER PAGE5 RELEASED AND ENCLOSURES WITHHELO EXEMPTION 5 FOIA REQUIST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION Beaver Valley 1 1,
12/23/82 SALP Input (Physical Protection) for Assessment Period December 1, 1981 to November 30, 1982 (4 Pages) 2.
4/17/84 SALP Input (Physical Protection) for Assessment Period December 1,1982 to March 31,1984 (4 Pages) 3.
3/31/87 SALP Input (Physical Protection) for Assessment Period October 1, 1985 to March 15,1987 (9 Pages) 4.
3/26/87 Division of Reactor Safety (DRS) Salp Input for Assessment Period (October 1,1985 to March 15,1987 (10 Pages)
Beaver Valley 2 5.
4/7/86 SALP Input (Physical Protection) for Assessment Period April 1, 1985 to March 31, 1986 (4 Pages) 6.
3/10/87 SALP Input (Physical Protection) for Assessment Period
{
April 1,1986 to February 28,1987 (6 Pages) 7.
3/13/87 ORS SALP Input for Assessment Period April 1,1986 to March 31,1987 (10 Pages)
Calvert Cliffs 1&2 1
8.
11/10/83 SALP Input (Physical Protection) for Assessment Period October 1, 1982 to September 30,1983(5pages) 9.
4/25/86 SALP Input (Physical Protection) for Assessment Period 1
October 1, 1984 to April 30,1986 (5 Pages) l 10.
9/18/87 SALP Input (Physical Protection) for Assessment Period l
May 1, 1986 to August 31,1987 (6 Pages) s j
Pe: F0!A-87-830 2
APPENDIX E DOCUMENTS WITHHELD IN PART EXEMPTION-5 FOIA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION lla.
9/22/87 DRS SALP Input for Assessment Period May 1,1986 to August 31,1987 (3 Pages) lib.
10/2/87 ORS SALP Input for Assessment Period May 1,1986 to August 31, 1987 (6 Pages)
EtzPatrick 12.
04/2/82 SALP Input (Physical Protection) for Assessment Period 3/1/81 -
2/28/82 (5 Pages) 13.
1/31/83 SALP Input (Physical Protection) for Assessment Period 1/1/82 -
12/31/82 (5 Pages) 14.
6/25/84 SALP Input (Physical Protection) for Assessment Period 1/1/83 -
6/30/84 (4 Pages) 15.
12/26/85 SALP Input (Physical Protection) for Assessment Period 7/1/84 -
11/30/85 (5 Pages) 16.
12/5/85 SALP Input (Physical Protection) for Assessment Period 12/1/85 -
10/31/86 (6 Pages)
Ginna 17.
1/25/85 SALP Input (Physical Protection) for Assessment Period 7/1/83 -
12/31/84 (5 Pages) 18.
6/19/86 SALP Input (Physical Protection) for Assessment Period 1/1/85 -
5/31/86 (5 Pages) 19.
12/17/87 SALP Input (Physical Protection) for Assessment, Period 6/1/86 -
11/30/87 (6 Pages) 20.
12/17/87 SALP Input (Physical Protection) for Assessment Period 6/1/86 -
11/30/87 (Revised 1/12/88) (6 Pages) 21, 12/9/87 DRS SALP Input for Assessment period 6/6/86 - 11/30/87 (13 Pages) 22.
12/10/87 EP SALP Input for Assessment Period 6/1/86 - 11/30/87 (3 Pages)
Re: F0!A-87-830 3
APPENDIX E DOCUMENTS WITHHELD IN PART EXEMPTION 5 F0IA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION Haddam Neck 23.
3/20/85 SALP Input (Physical Protection) for Assessment Period 9/1/83 -
2/28/85 (6 Pages) 24.
3/14/86 SALP Input (Physical Protection) for Assessment Period 3/1/85 -
2/28/86 (5 Pages) 25, 4/10/87 SALP Input (Physical Protection) for Assessment Period 3/1/86 -
3/31/87 (7 Pages) 26.
3/19/87 DRS SALP Input for Assessment Period 3/1/86 - 3/31/87 (9 Pages) r Hope Creek 27.
12/5/86 SALP Input (Physical Protection) for Assessment Period November 1,1985 to November 30,1986 (6 pages) 28.
1/12/88 SALP Input (Physical Protection) for Assessment Period December 1,1986 to January 15, 1988 (Hope Creek) and October 1,1986 to December 31,1987 (Salem) (6 Pages) 29.
12/24/87 DRS SALP Input for Assessment Period December 1,1986 to January 15,1988 (5 Pages)
Indian Point 2 30.
8/23/85 SALP Input (Physical Protection) for Assessment Period August 1,1984 to July 31, 1985 (6 Pages) 31.
8/18/86 SALP Input (Physical Protection) for Assessment Period August 1,1985 to July 31,1986 (7 Pages) l 32.
12/10/87 SALP Input (Physical Protection) for Assessment Period August 1,1986 to November 30, 1987 (6 Pages)
P.e : F0!A-87-830 l
4 APPENDIX E DOCUMENTS WITHHELD IN PART EXEMPTION 5 l
FOIA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION 33.
12/1/87 DRS SALP Input for Assessment Period August 1,1986 to November 30,1987 (15 Pages) 34.
?/16/88 ORS SALP Input for Assessment Period August 1,1986 to February 7, 1987 (16 Pages)
Indian Point 3 i
35.
4/13/82 SALP Input (Physical Protection) for Assessment Period April 1, 1981 to March 31,1982 (5 Pages) i 36.
2/3/83 SALP Input (Physical Protection) for Assessment Period 1
January 1,1982 to December 31, 1982 (5 Pages) 37.
7/5/84 SALP Input (Physical Protection) for Assessment Period January 1,1983 to June 30, 1984 (5 Pages) 38.
12/18/85 SALP Input (Physical Protection) for Assessment Period July 1,1984 to November 30, 1985 (6 Pages)
Limerick 39.
12/9/83 SALP Input (Physical Protection) for Assessment Period December 1,1982 to November 30, 1983 (3 Pages) 40, 2/24/86 SALP Input (Physical Protection) for Assessment Period December 1,1984 to January 31, 1986 (9 Pages) l 41.
2/5/87 SALP Input (Physical Protection) for Assessment Period January 31, 1986 to January 31, 1987 (6 Pages)
Maine Yankee l
42, 11/20/85 sal.P Input (Physical Protection) for Assessment Period 7/1/84 -
10/31/85(6Pages) 43.
2/17/87 SALP Input (Physical Protection) for Assessment Period 11/1/85 -
1/31/87 (6 Pages)
I Re: FOIA-87-830 5
APPENDIX E DOCUMENTS WITHHELD IN PART EXEMPTION 5 FOIA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION Millstone 1&2 44, 9/20/82 SALP Input (Physical Protection) for Assessment Period September 1,1981 - August 31, 1982 (6 Pages) 45.
9/22/83 SALP Input (Physical Protection) for Assessment Period September 1,1982 to August 31, 1983 (5 Pages) 46.
3/21/85 SALP Input (Physical Protection) for Assessment Peried September 1,1983 to February 28, 1985 (7 Pages) 47.
6/16/86 SALP Input (Physical Protection) for Assessment Period March 1,1985 to May 31,1986 (6 Pages) 46.
1/20/88 SALP Input (Physical Protection) for Assessment Period June 1, 1986 to December 31,1987 (6 Pages) 49.
2/8/88 DRS SALP Input for Assessment Period June 1,1986 -
December 31,1987 (10 Pages)
Millstone 3 50.
9/19/85 SALP Input (Physical Protection) for Assessment Period September 1,1984 to August 31, 1985 (4 Pages) 51.
3/19/87 SALP input (Physical Protection) for Assessment Period September 1,1985 to February 22, 1987 (11 Pages) 52.
3/4/87 DRS SALP Input for Assessment Period September 1,1985 to Februant 28,1987 (9 Pages)
Nine Mile 1 53.
5/10/83 SALP Input (Physical Protection) for Assessment Period May 1,1982 to April 30, 1983 (4 Pages) 54.
5/31/84 SALP Input (Physical Protection) for Assessment Period May 1,1983 to April 20, 1984 (4 Pages) s
Re: FOIA-87-830 6
APPENDIX E DOCUMENTS WITHHELO IN PART EXEMPTION 5 F0IA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION 55.
6/19/85 SALP Input (Physical Protection) for Assessment Period May 1, 1984 to May 31, 1985 with draf t (13 Pages) 56.
Undated SALP Input (Physical Protection) for Assessment Period June 1,1986 to October 31, 1986 (6 Pages) 57.
2/26/88 SALP Input (Physical Protection) for Assessment Period October 31, 1986 to February 14, 1988 (5 Pages)
Nine Mile 2 58.
2/24/86 SALP Input (Physical Protection) for Assessment Period February 1,1985 to January 31, 1986 (5 Pages) 59.
2/25/87 SALP Input (Physical Protection) for Assessment Period February 1,1986 to January 31, 1987 (6 Pages)
Nine Mile Point 1&2 60.
2/25/88 DRS SALP Input for Assessment Period November 1,1986 to February 14,1988 (NM1) and January 31, 1987 to February 14, 1988 (NM2) (17 Pages) 61' 3/7/88 ORS SALP Input for Assessment Period November 1,1986 to February 29,1988 (NM1) and February 1,1987 to February 29, 1988 (NM2) (6 Pages)
Oyster Creek 62.
2/3/83 SALP Input (Physical Protection) for Assessment Period February 1,1982 to January 31, 1983 (4 Pages) 63.
6/4/84 SALP Input (Physical Protection) for Assessment Period February 1,1983 to April 30,1984 (S Pages) 64.
7/26/85 SALP Input (Physical Protection) for Assessment Period
(
May 5,1984 to June 30, 1985 (6 Pages) s
~
Re: F01A-87-830 i
7 APPENDIX E DOCUMENTS WITHHELD IN PART EXEMPTION 5 F0IA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION Syster Creek 65.
11/7/86 SALP Input (Physical Protection) for Assessment Period July 1, 1985 to October 15, 1986 (6 Pages) 66.
11/5/87 SALP Input (Physical Protection) for Assessment Period October 16, 1986 to September 30, 1937 (6 Pages) 67.
10/20/87 EP SALP Input for Assessment Period October 16, 1986 to October 1, 1987 (6 Pages)
Peach Bottom 68.
4/18/85 SALP Input (Physical Protection) for Assessment Period January 1, 1984 to March 31, 1985 (6 Pages) 69.
2/24/86 SALP Input (Physical Protection) for Assessment Period April 1, 1985 to January 31,1986 (5 Pages) 70.
2/17/87 SALP Input (Physical Protection) for Assessment Period January 31, 1986 to Januny 31, 1987 (6 Pages)
Pilgrim 71.
7/21/82 SALP Input (Physical Protection) for Assessment Period September 1,1981 to June 30, 1982 (4 Pages) 72.
7/29/83 SALP Input (Physical Protection) for Assessment Period July 1,1982 to June 30, 1983 (4 Pages) 73.
11/14/85 SALP Input (Physical Protection) for Assessment Period October 1, 1984 to October 31, 1985 (6 Pages) 74.
2/18/87 SALP Input (Physical Protection) for Assessment Period November 1, 1985 to January 31, 1987 (6 Pages)
I l
Re: FOIA-87-830=
8 APPENDIX E DOCUMENTS WITHHELO IN PART EXEMPTION 5 FOIA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION Salem 75.
9/21/84 SALP Input (Physical Protection) for Assessment Period October 1,1983 to August 31,1984 (4 Pages) 76.
10/30/85 SALP Input (Physical Protection) for Assessment Period September 1,1984 to September 30,1985 (7 Pages)
'/ 7.
10/23/86 SALP Input (Physical Protection) for Assessment Period October 1,1985 to September 30, 1986 (5 Pages) 78.
12/29/87 ORS SALP Input for Assessment Period October 16, 1986 to October 1,1987 (12 Pages)
Seabrook j
79.
8/25/87 SALP Input (Physical Protection) for Assessment Period j
April 1,1986 to July 31, 1987 (6 Pages)'
Shorehy j
80.
1/25/83 SALP Input (Physical Protection) for Assessment Period i
January 1,1982 to December 31, 1982 (4 Pages) l 81.
3/20/85 SALP Input (Physical Protection) for Assessment Period March 1,1984 to February 28,1985 (6 Pages) 82.
3/17/86 SALP Input (Physical Protection) for Assessment Period March 1,1985 to February 28,1986 (5 Pages) 83.
8/13/87 ORS SALP Input for Assessment Period March 1,1986 to July 31,1987 (10 Pages) k
Re: F0!R-87-830 9
APPENDIX E DOCUMENTS WITHHELD IN PART EXEMPTION 5 FOIA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION Susquehanna 84.
4/12/82 SALP Input (Physical Protection) for Assessment Period March 1,1981 to February 28, 1982 (4 Pages) 85, 2/15/83 SALP Input (Physical Protection) for Assessment Period February 1, 1982 to March 31, 1983 (4 Pages) 86.
5/30/85 SALP Input (Physical Protection) for Assessment Period February 1,1984 to April 30, 1985 (6 Pages) 87.
8/25/86 SALP Input (Physical Protection) for Assessment Period May 1,1985 to July 31, 1986 (6 Pages) 88.
2/12/88 SALP Input (Physical Protection) for Assessment Period August 1, 1986 to January 31, 1988 89.
2/29/88 DRS SALP Input for Assessment Period August 1,1986 to January 31,1988 (12 Pages)
TMI 1 90.
10/21/82 SALP Input (Physical Protection) for Assessment Period October 1,1981 to September 30, 1982 (4 Pages) 91.
11/4/83 SALP Input (Physical Protection) for Assessment Period October 1,1982 to September 30, 1983 (5 Pages) 92, 1/2/85 SALP Input (Physical Protection) for Assessment Period February 1,1984 to January 31,1985 (5 Pages) 93.
5/13/86 SALP Input (Phyrmi Protection) for Assessment Period September 16, ;W to April 30, 1986 (5 Pages) 94.
11/17/86 SALP Input (Pid:,: cal Protection) for Assessment Period 3
May 1, 1986 to October 31, 1986 (6 Pages)
l Re: F0!A-87-830 10 APPENDIX E DOCUMENTS WITHHELO IN PART EXEMPTION 5 FOIA REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT DESCRIPTION 95.
11/16/87 SALP Input (Physical Protection) for Assessment Period November 1,1986 to October 31,1987 (6 Pages) 96.
11/14/86 DRS SALP Input for Asressment Period May 1,1986 to October 31,1986 (5 Pages) 97.
12/7/87 SALP Input (Physical Protection) for Assessment Period November 1,1986 to October 31, 1987 (8 Pages) 98.
5/8/86 EP SALP Input for Assessment Period September 16, 1985'to April 30,1986 (8 Pages) 99.
11/3/86 EP SALP Input for Assessment Period April 1,1986 to September 30, 1986 (2 Pages) 100.
11/19/86 EP SALP Input for Assessment Period May 1,1986 to October 31, 1986 (5 Pages)
TMI 2 101.
10/21/82 SALP Input (Physical Protection) for Assessment Period October 1,1981 to September 30, 1982 (4 Pages) 102.
10/18/83 SALP Input (Physical Protection) for Assessment Period October 1, 1982 to September 30, 1983 (5 Pages)
Vermont Yankee 103.
5/18/83 SALP Input (Physical Protection) for Assessment Period May 1,1982 to April 30, 1983 (5 Pages) 104.
11/5/85 SALP Input (Physical Protection) for Assessment Period November 1,1984 to October 18, 1985 (7 Pages) i
Re: F0!A-87-830-11 l
APPEN0!X E DOCUMENTS WITHHELO IN PART' EXEMPTION 5.
FOIA' REQUEST NUMBER 87-830 DATE ORIGINATOR RECIPIENT-DESCRIPTION 105.
1/27/87 SALP Input (Physical Protection) for Assessment Period October 19, 1985 to December 31, 1986 (6 Pages)
Yankee 106.
5/6/83 SALP Input (Physical Protection) for Assessment Period May 1, 1982 to April 30, 1983 (4 Pages)-
107.
2/15/85 SALP Input (Physical Protection) for Assessment Period September 1,1983 to January 30,1985 (6 Pages).
108.
10/10/86 SALP Input (Physical Protection) for Assessment Period February 1,1985 to September 15, 1986 (6 Pages)
Re:-F01A-87-830 t
APPENDIX F DOCUMENTS WITHHELD IN THEIR ENTIRETY UNDER EXEMPTION 5 F0IA REQUEST NUMBER 87-830 DATE-ORIGINATOR RECIPIENT DESCRIPTION 1.
Undated SALP Input - Beaver Valley (2 Pages) 2.
3/12/87 0perator Licensing SALP Input - Beaver Valley 2 - Period April 1,1986 to February 29, 1987 (4 Pages) 3.
11/17/86 SALP Input - Fitzpatrick.(1 Page) 4.
Undated SALP Input - Haddam Neck (2 Pages) 5.
Undated SALP Input - Hope Creek / Salem (s
.ges) 6.
Undated SALP Input - Indian Point 2 (2 Pages) 7.
Undated SALP Input - Millstone 3 (3 Pages) 8.
Undated SALP Input - Oyster Creek (3 Pages) 9.
3/1/82 SALP Input - Oyster Creek (3 Pages) 10.
Undated Operator Licensing SALP Input - Seabrook (5 Pages) 11.
Undated Operator Licensing SALP Input - Seabrook (1 Page) 12.
Undated SALP Input - Shoreham (2 Pages) 13.
Undated SALP Input - Shoreham (5 Pages) 14.
Undated SALP Input - TMI (3 Pages) 15.
Undated SALP Input - TMI 1 (2 Pages) 16.
Undated SALP Input - TMI 1 (4 Pages) 17.
Undated SALP Review - TMI 1 (1 Page) 18.
Undated SALP Input - TMI 1 (5 Pages) 19.
Undated SALP Input - TMI 1 (2 Pages) 20.
Undated SALP Input - TMI 1 (NRC Appendix 0516) (21 Pages) s
^
l Re: F01A-87-830-2 APPENDIX F DOCUMENTS WITHHELO IN THEIR ENTIRETY UNDER EXEMPTION 5 FOIA REQUEST NUMBER-87-830 DATE ORIGIN /. TOR RECIPIENT DESCRIPTION 21.
5/5/86 N. Blumberg A. Blough Memo
Subject:
ORS Input Region I, NRC Region I, NRC for TMI Unit 1 SNP Post Restart Period (1/11/86 -
4/30/86) with attachment (5Pages) 22.
10/7/86 SALP Input - TMI 1 (1 Page)-
23.
11/6/87 Operator Licensing Input - TMI 1 - Period -November '1,1986 to October 31, 1987 (3 Pages) 24.
Undated SALP Input - Yankee-(2 Pages)
.g Appendix G F0IA 87-830 DEllIED lli EliTIRETY Date Description Exemption 1.
Various Dates SALP Functicnal Area Assessment and 5
Preliminary inspector Evaluation Fonn (327 pages) 2.
Undated Excerpts from draft SALP reports for 5
various sites a.
Monticello 86001 (3 pages) b.
Perry,86001 (3 pages) c.
Big Rock Point 87001 (2 pages)pages) d.
Callaway 87001 (4 e.
Davis-Besse 87001 (4 pages) f.
Kewaunee 87001 (4 pages) g.
Palisades 87001 (3 pa pages)ges) h.
Perry 87001 (3 1.
Point Beach 87001 (3 pages) j.
Quad Cities 87001 (4 pages) t
3
- PHOENIX ARI2oNA 450724034 bl*J J f -
I' April 22,1986 vc.0';'J h.:
ANPP-36349-EEVB/JYM/98.05 U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368
-Attention: Mr. D. F. Kirsch, Deputy Director, Division of Reactor Safety and Projects
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2 and 3 m
Docket Nos. STN 50-528 (License NPF-41)
STN 50-529 (License NPF-46)
STN 50-530 Systematic Assessment of Licensee Performance Report File: 86-056-026
References:
(A)
Letter from J. B. Martin, NRC, Region V, to E. E. Van Brunt, Jr.,
ANPP, dated December 19, 1985.
Subject:
Systematic < Assessment of Licensee Performance Report.
(B) Letter from D. F. Kirsch, NRC, Region V, to E. E. Van Brunt, Jr.,
ANPP, dated April 11, 1986.
Subject:
Systematic Assessment of Licensee Performance Report Numbers 50-528/85-36: 50-529/85-38:
50-530/85-28.
3
Dear Mr. Kirsch:
Attached is a copy of the ANPP response to the Systematic Assessment of Licensee Performance Report (SALP) provided in Reference (A). The two editorial errors iden-tified in Reference (B) were noted in the attached response.
Very truly yours, l
-yw.-
f-
. E. Van Brunt, Jr.
(tr Executive Vice President Project Director Attachment cc:-
A. C. Gehr (all w/a) l R. P. Zimmerman G. W. Knighton J. B. Martin t
$ -I y %,
Msmo
i W-
..l
.\\
7 Arizona Nuclear Power Project P.o. box 52034 e PHOENIX, ARIZONA 45072 2034
. g--.
a February 21, 1986-ANPP-35270-EEVB/WFQ/98.05 Mr. John B. Martin,' Regional Administrator Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596-5368 Attention:
J. B. Martin Regional Administrator l-.-
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Units 1, 2, and 3 Docket Nos. STN 50-528 (License NPF-41)
STN 50-529 (License NPF-46)
STN 50-530 Systematic Assessment of Licensee' Performance Report File: 86-056-026
Reference:
Letter from J. B. Martin, NRC Region V, to E. E. Van Brunt, Jr., ANPP, dated December 19, 1985.
Subject:
Systematic Assessment of Licensee Performance Report
Dear Mr. Martin:
Il We have reviewed the Systematic Assessment We were pleased to see thatPalo Verde Units 1, 2, and 3 which was trans this report, the referenced letter.
ties for the eighteen month period April 1,1984 - September 30which evaluat our overall performance to be 1985, found inaccuracy found during our review. satisfactory. The attachment lists an area of
'Ihis report is very important to the Palo Verde Project and, as such, it has been given considerable attention by our senior and functional management personnel. Senior management has met with the functional managers and h directed that actions responding to the recommendations and concerns of the be taken. These actions involve development, report tracking and implementation of appropriate actions to enhance ANPP programs. In many cases actions were recognized by management and were taken prior to issuance of the report, a example: A revised development and approval process, (LERs) program were developed in October 1985. As a resu eport ness of LER's are improving, also the deficiencies in sub-contractor work, quality and timely-most of which resulted from work performed prior to this SALP evaluation, resultdd in additional monitoring and improved work quality.
Throu;n our resultant actions to the constuctive comments contained in report, we intend to achieve continued management involvement.
,., f. c ~) o ! u n, ) M k.
- 1 j ig A,
L' ff
/-
[9 y'.
3 Mr. John B. Martin 5'ystemat'ic' Ai'ses'shnt' BTliciinsee' Pe'r55r=an~ce' Report - ^
ANPP-35270 Page 2.
~
~
.,c a
k'e a' ppreciate the significance of this report and believe we-can.make even futher
~i=provements in the future.
L-Very truly yours.
g
(. q LC.
R.C.l.
O LLC. p E. E. Van Brunt, Jr.
Exeqvtive Vice President Pro'ect Director-j EEVB/'nTQ/rv Attachment cc:
A.'C. Gehr R. P. Zimmerman G. W. Knighton i
s il e
ll
.I 4
/
+
g
^ %, '
..e e
.o Attachpent..
w.......
,,,, s.. c a....:
i Page 3, Su==ary Results Table, Item 18, 'reoperational Tescing
- i.
}
~
lists a SALP rating of."2" and trend as "not apparent";
i-Lsuv uhereas
^~~ ~~-
Page 28. Perfor=ance Analyses. Item 18, l.
states a SALP rating of "1" and a trend as "improved".
m 9
e G
l 1
l 1
l ll
'e 9
W s-_-__---__._-_---___
aq. enc.:_ ; % )
- ,,.. g,,,g\\
(U R{ @ '
" $6-M/- Mg, 86 APR 16 A10 38
/
UNITED STATES E
$S DOC CENIEiNUCLEAR REGULATORY COMMi$iSl0N
~j e
(%,' A[,(6 4
e REGION V
~
1450 MARIA LANE. SUITE 21e ResponJible Aotion 3Y WALNUT CREEK, CALIFORNIA S4596 g
April 11, 1986
'(tato) l Y/& kt>
Docket Nos. 50-528, 50-529 and 50-530 Arizona Nuclear Power Project 30'l'* * ] Info s.,....
Co==ent Post Office' Box 52034 Phoenix, Arizona 85072-2034
]pollow
] Process Attention: Mr. E. E. Van Brunt, Jr., Executive Vice President Gentle =en:
~
Subject:
Syste=atic Assess =ent of Licensee Performance Raport Nu=bers 50-528/85-36, 50-529/85-38 and 50-350/*J-28 The SALP Board report was sent to you on Dece=ber 19, 1985. No reply to the SALP report or =eeting was requested; however, you were invited to discuss any questions concerning the report.
To date, we have not yet received any written co==ents fro: you.
We identified two editorial errors in the S' ALP Board report after it was issued and they are corrected by the attached errata sheet.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this 1.tter and the SALP Report will be placed in the NRC's Public Docu=ent Roo=, as will any co=nents you =ay wish to sub=it to NRC regarding the content of the SALP Report.
1 No reply to this letter is required; however, should you have any questions concerning the SALP report, we would be pleased to discuss the= with you.
Sincerely l
D. F. Kirsch Director Division of Reactor Safety and Projects
Enclosure:
Errata sheet w/ original and corrected pages cc w/ enclosure:
J. Bynu=, ANPP T. D. Shriver, ANPP W. E. Ide, ANPP C. N. Russo, ANPP Ms. Jill Horrison, PVIF Lynne Barnabei (CAP)
(
Duke Railsback, Arf:ena Corp. Co==1ssion
(
Arthur C. Gehr, Esq., Snell & Wi1=er J. C. Partlow, IE H. L. Tho=pson, NRR E. Licitra, NP2 J. M. Taylor. IE e
--/
j,~
e e
e 4
- Errata Sheet-
...c SALP Board Report No. 50-528/85-36, 50-529/85-38 and 50-530/85-28 P$rtIII
..SL*W.ARY OF RESULTS Tunctional Area 18. Preoperational Testing Page 3
~
Now Reads:
Last SALP This SALP Functional Areas Period Racing
-Period Rating Trend *
- 18. Preoperational Testing 3
2 Not Apparent" Should Read:
Last SALP This SALP Functional treas Period Rating Period Rating Trend
- 18. Preoperatior.t1 Testing 3
1 Improved" l
I Basis:
I I
i This is an editorial error in the summary table. The evaluation detail in pages 27 and 28 show Category 1 rating and steadily improved performance during the assess =ent period.
Therefore, the summary table is revised to j
reflect the evaluation detail.
1
~
G(ics079/ bj,".
4 L
III.
SUMMARY
OF RESULTS
~
c.
Overall, the SALP Board found the licensee's perfomance to be accep.
.s and directed toward safe facility operation.
table The-Board identified trength or improvements in the areas of operator's response to unusual pkntconditions,fireprotectionsystems,andpreoperationaltesting.
However, perfor=ance should be improved in the areas of surveillance,-
s emergency _ preparHness, security, and subcontractor quality assurance, l
due't observed weaknesses or a declining trend.
Functionabeas Period Ratina
.-s---
Period Rating Trend
- 1.
Plant Op'eptions 2
2 Improved 2.
Radiologii:51 Controls 2
2 3.
Maintenance 2
Not Apparent 2
Ieproved i
4.
Surveillance.,
None
. -- 2 Not Apparent 5.
Fire Protectibn None 1
Not Apparent 6.
E=ergency Prepa @ ess 1
2 Declined **
7.
Security y
2 2
.Ieproved 8.
Refueling None 1
None g
9.
QualityProgramanQ None 2***
Ad=inistration Cont,yols Not Apparent
- 10. Licensing Activities
- 2 2
Not Apparent
- 11. Training
%g2 None 2
._ _12.
Contain=ent Safety-Not Apparent 2
Related Structures.
N Not Appdrent Piping SystemsandMajorSteelSupports%e 13.
and Supports 2i 2
14.
Safety-Related M
Not Apparent I
Co=ponents 2
2
- 15. Auxiliary Systems 2
Not Apparent 2
- 16. Electrical Equip:ent N
Not Apparent i
and Cables 2
i 2
17.
Instru=entation 1
Not Apparent i
1 18.
Preoperational Testing 3
Not Apparent 2
Not Apparent
- 19. Startup Testing 3
2
\\
Not Apparent The trend indicates the SALP Board's perception of the trend of the licensee's performance durine the current assessment period.
necessarily a ec=parison of perfomance during the current period with It is not the previous period. For example, perfor=ance in thL fire protection area was considered to be improving, even though perfor=ance in this functional area was not assessed during the previous SALP period.
While an overall decline between rating periods was observed icprovement a
in perfor=ance was' noted toward the end of this appraisal
, an period.
(
with significant deficiencies.This area was considered by the Board to )
l i
ORICI"AL PACE i
i
{
s i
~
l A
l
+
6 III. SLM'.ARY OF RESULTS Overall, the SALP Board found the licensee's perfor=ance to be acceptable and directed toward safe facility operation. The Board identified a
strength or i=provecents in the areas of operator's response to unusual plant conditions, fire protection systems, and preoperational testing.
However, perforcance should, be improy.ed in, the, ar,eas of surveillance, emergency preparedness, security, and subcontractor quality assurance,-
due to observed weaknesses or a declining trend, i
Last SALP This SALP Functional Areas Period Ratine Period Rating Trend
- 1.
Plant Ope-acions 2
2 I= proved I
2.
Radiological Controls 2
2 Not Apparent 3.
Maintenance 2
2 Improved 4.
Su rveillance None
,,,2 Not Apparent
.S.
Fire Protection None 1
Not Apparent 6.
E=ergency Preparedness 1
2 Declined **
7.
Security 2
2 Improved 8.
Refueling None None 9.
Quality Program and None 2***
Not Apparent l
Ad=inistration Controls 10.
Licensing Activities 2
2 Not Apparent 11.
Training None 2
Not Apparent 12.
Containment Safety-2 2
Not Apparent Related Structures, and Major Steel Supports 13.
Piping Systems and Supports 2
2 14 Safety-Related Not Apparent Co:ponents 2
2 Not Apparent i
- 15. Auxiliary Systtes 2
2 Not Apparent 16.
Electrical 2 quip ent and Cables 2
2 17.
Instru=entation 1
1 Not Apparent Not Apparent 18.
Preoperational Testing 3
1 Improved 19.
Startup Testing 3
2 Not Apparent The trend indicates the SALP Board's perception of the trend of the licensee's performance during the current assess =ent period.
It is not necessarily a comparison of perfor=ance during the current period with the previous period.
For exa:ple, performance in the fire protection area was considered to be i= proving, even though performance in this functional area was not assessed during the previous SALP period.
While an overall decline between rating periods was observed, an icprove=ent in perfor=ance was noted toward the end of this appraisal period.
This area was considered by the Board to be a marginal Category 2 rating with significant deficier.cies.
\\-
CORRECTED PAGE
.)
_ _ _ _ _ _ - _ - - - - ~ - - - - - - - - - - ~
(
i 4
( e suuo -
SACRAMENTO wuNICIPAL UituTY otsTRICT O 001 s street Boa 1s830. sxtarrenta 6)rtrng 95413, 016) 4s2 3211
- v February 11, 1983 R H ENGELKEN REGIONAL ADMINISTRATOR U S NUCLEAR REGULATORY COMMISSION REGION V 1450 MARIA LANE, SUITE 210 WALNUT CREEK CA 94596
REFERENCE:
SALP BOARD REPORT The District has reviewed the refer 9nced report and wishes to address the SALP Board conclusions, lf Plant Operations k
The District has adopted the policy of writing Licensee Event Reports (LERs) whenever an event might treet the requirement of Regulatory Guide 1.16. To call attention to the number of LERs is counter productive.
The District is in concurrence with Region V that the Quality Assurance Depart-ment has improved its perfortunce; management involvement in corrective actions is one evidence of the new program. The District does not agree that the perfoimance assessment should be Category 2.
Radiological Controls The District has no corxnent.
Maintenance The District agrees that the repair of the high pressure inject'3n (HPI) nozzles and thermal sleeves was expediciously and satisfactorily accomplished.
The District is not in agreement that the design and installation of the auxiliary feedwater header was solely a maintenance function. This repair demonstrates the ability of the District to marshall its forces to accomplish cajor plant modifications in a judicious and timely manner.
The modifications incluJed proper planning, testing, and reporting requirements besides normal naintenaate activities and reflects the strength of this organization.
The District feels that the maintenance activity should be rated Category 1.
.. v a,
? -2L
-.............._..-..-._.u---
r R H Eng71 ken February 11, 1983 not irrodiately agree with the NRC staff on either the existence of a safety issue of their recomended solution, we are non-responsive.
The tower crane problem identified in both of these items is a good example.
The tower crane operation was no threat to any Class ! equipment during the early phases of the project and could have been resolved by administra-tive controls during its entire operating period. Although we still consider our proposed solutions completely adequate, we spent an extra $100,000 designing and installing guy lines and anchors to satisfy the NRC ttaff, plus avoid major claims by the construction contractor.
Relative to our responsiveness to NUREG's bulletins, etc., the NRC frequently issues these documents with unrealistic schedules.
In some instances, the document will provide us 30 days or some other short period of time to submit our schedule. Many of these tasks require a detailed design before an accurate schedule can be developed.
In these instances, our schedule submittal will either be submitted late or it will be very praliminary and subject to slippages.
The District wants to emphasize to the SA1.P Evaluation Comit tee that the NRC should consider design evaluation times when they issue their require-(
ments.
C, Responsiveness The District takes exception to scoring this attribute a Category 3.
Most schedule changes result because of design difficulty, vendor slippages, and construction impacts. This is especially true when information from the NRC is needed to finalize design requirements.
D.
Reportable Events, The District has no coment.
E.
Staffing The District has no comment.
F.
Tra ining The District wishes to emphasize the excellent records of people ttking reactor operator (RO) and senior reactor operator (SRO) tests.
Conclusion The District feels this area should be assessed Category 1.
Plant Hodifications The District concurs that limiting contractors to firms that have prior nuclear related experience would be advantageous.
This is not in agreement with the
-r.
-~-'8--
- " ' " ~
1 R H Cngelken Februa ry 11, 1983 right of all oo.'ified bidders to perfom work for the District. While we were not sat'sfied with the initial perfomance of some of our contractors, none of the noncompliances that occurred during this 15 month period were of a severe nature and our corrective action was insnediate and effective. While we will continue to strive for improvement, we believe our program was good, particularly in view of the magnitude of work in progress. We believe that our performance in this area was significantly better than the Category 3 rating given.
j The District does not object to greater inspection emphasis placed by the NRC for the 1983 modifications. The major TMI modifications are scheduled for an outage during the early part of 1983 and will result in greatly increased personnel and different contract organizations working at Rancho Secn.
It should be noted that with more activity we would expect more deviations to occur.
The NRC assessment should not be solely on the number of violations detected, but on how the District perfoms in comparison to organizations with similar programs.
District Sunnary to SALP Report The District finds the remaining sections of the SALP Report teneficial in evalua-ting the NRC's participation at Rancho Seco.
We are not in agreement with the sunstion of the total hours spent by inspectors at Rancho Seco. Our analysis credits the NRC with a larger consignment of inspector hours than is credited in thL report.
The District acknowledges that the summary of results stating the ten functional areas listing two Category 1, seven Category 2 and one Category 3 leaves oppor-
.inity for improvement.
Though the District does not agree with some of the as.*ssment, it is the District's policy to strive for improvement in all areas affesting the Rancho Seco Unit.
fL. ' AaL,t j
dohn J. Ks t *.imoe General K3ni ger I
l l
\\
-A
y *fj Southem Califomia Edison Company P. O. S O X 8 0 0 2244 WALNUT GROvt AVENUC ROSCM CAD CALirORNIA 98770 vic e t ocn October 28, 1987 sie aos aos I
U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region V 1450 Maria Lane, Suite 210 Halnut Creek, California 94596-5368 Attention: Mr. J. B. Martin, Regional Administrator
Dear Sir:
Subject:
Systematic Assessment of Licensee Performance (SALP)
San Onofre Nuclear Generating Station, Units 1, 2, and 3
References:
A) letter, J. B. Martin (NRC) to D. J. Fogarty (SCE), same subject, dated August 7, 1986 B) Letter, M.
0.. Medford (SCE) to NRC (Document Control Desk), Docket Nos. 50-206, 50-361, 50-362, dated October 16, 1987 By copy of Reference A, the results of the previous SALP period were forwarded to the Southern California Edison Company (SCE).
Now that the most recent SALP period has been concluded, SCE has reflected on its performance during this latter period to gauge the effectiveness of efforts to achieve excellence in facility operation and safety.
He have noted improved performance in a number of areas, especially plant operations and maintenance.
As our operating staff gains experience, we have had a corresponding positive increase in those parameters that are indicative of unit capacity.
At the same time, we have noted a reduction in the number of plant trips and other occurrences which require Nuclear Regulatory Commission notification. Maintenance activities are being completed in a more V
6 fy-g c
~
r ENCLOSURE 1 SALP Performance Summary I.
Plant Operations l
The NRC SALP Board recommended in Reference A that SCE correct weaknesses in operator attentiveness and use of procedures.
As evidenced by the significant reduction in NRC reportable occurrences during the just-completed SALP period, SCE's efforts to achieve improved operator performance have had a great measure of success. Additionally, no citations attributable to ou'r operations staff were received in this period.
Improvement on the part of SCE's plant operators was also reflected in notable increases in unit capacity factors, a decrease in unplanned safety system actuations, and a decrease in unplanned automatic reactor trips.
These trends should continue as a result of ongoing SCE efforts, maturity of the plant operating staff, and the overall improvement of support furnished by other site organizations.
The correction of deficiencies in housekeeping and material plant condition was recommended by the Board.
Largely as a result of extensive resources being applied to these areas early in the SALP period, plant appearance and material condition are greatly improved.
i The Board also advised that telephonic communications between the control room and the NRC be improved.
SCE has initiated training improvements, as well as implemented a procedure revision, to facilitate formal, telephonic communications.
II.
Radiological Controls The Board suggested that SCE continue its support of the radiation protection program and continue to reduce liquid radioactive waste releases.
The program to reduce the level of radioactive materials contained in liquid effluents, as discussed in the last SALP report, was highly successful and has been continued.
The amount of radioactive material released in liquid effluents was reduced in the present SALP period by over ninety percent from that released in the previous SALP period.
Similarly, efforts to produce smaller amounts of compacted solid radioactive waste resulted in a decrease of well l
over 40 percent.
Overall personnel radiation exposure has been in a steep decline over the past two SALP periods.
i The continued reduction in personnel l
radiation exposure has been a long-term management goal for SCE.
During the past SALP period, personnel exposure (as measured by person-REH) declined by over 60 percent.
The program to deal with "hot particles" represents SCE's greatest ongoing challenge.
Although SCE has implemented a wide range of corrective actions involving administrative, technical, and personnel measures, the extent of the problem and the scope of measures necessary to deal with it were not fully appreciated at the outset.
SCE remains sensitive to the continuing potential for worker exposure from these particles and the need to constantly seek methods to improve radiation control processes.
SCE's performance in the area 4G e4 4
9
3-IV.
Surveillance Emphasis on continued IST program improvements was requested by the Board.
During this SALP period, SCE has focused considerable attention on the application of computer technology to the scheduling, tracking, and trending of IST program data.
Seat leakage test requirements have been added to a number of valves in the Unit 1 main and auxiliary feedwater systems in the aftermath of the water hammer event.
In addition to a major effort currently in. progress to revise and enhance IST procedures, the IST program has been closely scrutinized by SCE's quality assurance organization, which included performing two audits and 12 field surveillances during the SALP period.
The Board suggested that SCE should provide more attention to surveillances performed by groups other than operations, and to communications and procedure compliance by all surveillance personnel.
SCE's continuing attention to these areas is evidenced by the reduction of over 50 percent in missed surveillances (as reported to the NRC in licensee event reports) and in surveillance-related deficiencies noted by NRC inspectors that resulted in citations.
Formal communications and procedure compliance have been emphasized in training programs conducted by and for operations and maintenance personnel.
V.
Fire Protection The Board advised SCE to continue to devote management resources to this area, especially employee training and the proper implementation of fire protection programs that are properly intJgrated with all aspects of plant operations.
SCE has upgraded several key components of fire protection training including that portion presented to all new employees. Additionally, a new skills oriented class was initiated.for electricians, mechanics, velders, and machinists to qualify them as fire watches.
Improved performance in tne area of fire protection is particularly evident by the 90% decrease in the number of technical specification fire doors reported blocked open, and the 50%
decrease in the number of technical specification compensatory fire watch hours required for the last SALP period.
This latter statistic indicates a significant increase in fire protection equipment operability.
VI.
Emergency Preparedness The Energency Preparedness Bulletin Program (EPBP) was developed in response to the Board recommendation to ke activities on emergency response.ep workers informed of the impact of plant As a result of implementing the EPBP has improved the awareness of working level personnel to all emergency, SCE preparedness programs.
In addition, the establishment of an electronic mail network has assisted in providing another mechanism for the timely notification of the site population of any changes in emergency response.
A major revision to the SONGS Emergency Plan was completed in May of 1987 which shifted the emergency coordinator function to the Emergency Operations Facility, when activated, in order to provide for improved continuity of protective action recommendations and interface with offsite jurisdictions.
SCE's interaction with the offsite jurisdictions through the i
s e
S-VII.
Security and Safeguards The Board recommended that SCE continue its efforts to identify, evaluate and report security events and apply lasting corrective measures.
As a result of its continuing program of internal audits and self assessment, SCE's site security organization has reduced the number of security event reports to the NRC by almost one-half.
In addition, SCE did not receive any citations for -
events that occurred during the recently completed SALP period.
VIII. Outages The Board requesteJ SCE to continte the current emphasis on careful outage planning and to seek to minimize the overlap of unit outages. SCE has given careful attention to outage planning techniques during the most recent SALP period. As a result, refueling outage durations for Units 2 and 3 were decreased over the past two SALP periods.
In addition, SCE is completing about one-fourth more maintenance orders during the most recent refueling outages when compared to those outages conducted during the SALP period October 1984 through May 1986.
SCE's ability to complete refueling outages more quickly, and the continuing use of its five year outage schedule permits early identification of potential overlap conditions.
Plans are already in place to address a potential overlap between Units 1 and 3 refuelings in 1988.
SCE has established additional supervisorial positions effective during all outages to provide more observation of key activities and to enhance compliance.
SCE management concern for efficient outages has been further f(f demonstrated by executing refueling evolutions with SCE personnel rather than by contract personnel as was done previously.
IX. Quality Programs and Administrative Controls The Board asked SCE to evaluate the execution of its quality assurance program to ensure that it was being done in a rigorous manner.
SCE's Quality Assurance (QA) organization has instituted a number of program enhancements i
and has conscientiously pursued program implementation overall. As an example, since June of 1986, QA has conducted two audits and 12 field surveillances of the IST program.
Results from these audits were used to ennance the IST program.
Before the end of 1987, two additional audits and ten field surveillances will be conducted on the IST program.
More effective means of ensuring quality have been implemented, and as a result, physical (i.e., wrong part, damaged part, etc.) rejection rates at receipt inspection now account for less than one percent of received items, while rejections for paper discrepancies have been cut approximately in half.
A performance improvement program to facilitate focusing QA resources on incipient problem areas before they become significant enough to affect overall performance has been implemented.
Quality goals have been established for those processes work-sampled by QA (e.g., maintenance orders, procurement documents, and design changes), and quality trends are analyzed jointly by QA and line management teams to establish areas to be targeted for improvement.
Increased 0A attention is also being directed toward root cause assessments and corrective action follow-through.
(x 4
4 e
EliCLOSURE 2 A012 s
50123 October 16, 1987 NRC 1
U. 5. Nuclear Regulatory Commission Attention:
Document Control Oesk l
Washington, D.C.
20555 Gentlemen:
1
Subject:
Docket Nos. 50-206, 50-361 and 50-362 San Onofre Nuclear Generating Station Units 1, 2 and 3 Since the start of the San Onof re project, Southern Califorreia Edison Company (SCE) has actively pursued methods to increase plant safety, availability and operability.
Consistent with past SCE practice, the purpose of this letter is to inform the NRC of some plant modifications and activities that have been implemented at San Onofre that improve the overall plant performance and enhance regulatory compliance.
SCE formed the liquid Effluent Activity Reduction (LEAR) task force in January 1986 in an ef fort to reduce the amount of liquid effluent (in terms of activity released) discharged from all three units.
The task force was comprised of representatives from a number of disciplines including y((
operations, maintenance, technical, and chemistry.
Examples of improvements
(
include the implementation of site-wide chemical control and training programs, the installation of baffles in radwaste sumps, the addition of polyelectrolytes to improve resin beds, and the use of a strong base / strong acid resin bed.
As a result of these efforts, the activity released in 1986 was a factor of thirteen less than that released in 1985 (1.46 curies versus 19.0 curies).
In addition to reducing liquid radioactive effluents, SCE has achieved substantial reductions in the amount of solid radioactive waste produced at San Onofre.
The most effective method to reduce solid radwaste is at the source (don't produce the waste in the first piace). At San Onofre, heavy use of rewashable items, use of plastic berms to limit the size of contaminated areas, an aggressive area decontamination program to eliminate areas that provide the opportunity to produce radwaste, and restricting the use of wood in contaminated areas (because it is so difficult to decontaminate) have been responsible for reducing solid radwaste by 7500 cubic feet per year.
Since 1983, SCE has produced less solid radwaste than th>
industry average and has surpassed INP0's goal in 1986.
e
Document Control Oesk October 16, 1987 I
In othes-ef forts at San Onofre Units 2 and 3. SCE, with cooperation from the NRC, was able to replace the spray additive (NaOH) tank used in the containment spray system with trisodium phosphate (TSP) baskets located in the containment emergency sumo.
(The purpose of either the NaOH or TSP is to control containment sump pH level to increase the iodine removal of the spray and the iodine retention in the sumo, respectively).
The change is beneficial in that it allows the spray additive tank and associated systems (pumps, lines, sensors, etc.) to be removed from the plant thereby reducing surveillances and required preventive maintenance.
Additionally, this change replaces an active system with a passive system, minimizing the risk of system failure.
In other Units 2 and 3 improvements, SCE was able to reduce critical path outage time.
Previously, RCS water level was required to remain high during
{
refueling activities to prevent vortexing in the shutdown cooling system l
(SOCS) suction (This prevented the RCS from being lowered to mid-loop).
By j
reducing the Technical Specification required SOCS flow rate during refueling, the RCS water level can be lowered to mid-loop during refueling (without SOCS i
vortexing) thereby allowing steam generator nozzle dam removal and reactor coolant pump (RCP) seal placement concurrently.
Critical path outage time saved by NRC approval of this change is approximately five days for each refueling outage.
l SCE's Nuclear Safety Group has been successful in reducing the Units 2 and 3 core-melt frequency due to a loss of offsite power (LOOP) by 30L A
g PRA based study identified a procedure change that would more effectively cope with a station blackout (LOOP with concurrent failure of both emergency diesel I
generators at one unit).
By revising the procedure by which the Units 2 and 3 diesel generators are manually cross-connected, the probability of completing l
this task prior to core damage has been increased.
SCE has participated in the development of sensitive personnel monitoring equipment identified as 'PBM-200 monitors."
These monitors utilize sensitive, large area, gas flow proportional counters to examine personnel for contamination.
The P8M-200s are extremely sensitive and because of the large detector area, are more effective in detecting high-energy beta particles, such as irradiated fuel particles, than hand frisking methods.
Eleven P8M-2005 are currently in daily use at the plant in addition to the existing Geiger-Muller hand friskers.
One of the eleven P8M-200s has been located outside the protected area so that any concerned site employee can perform a personal radiation survey, even if they do not have protected area access.
During a recent IMPO plant and corporate evaluation, several SCE
' good practices * (unique and successful solutions to generic industry operating concerns) were identified by INPO.
In this evaluation, INPO was pleased by tne positive attitude of San Onofre employees, the teamwork that was displayed, the rapid and effective comunications, our aggressive pursuit k-
l Occument Control Oesk
-5 October 16, 1987 Of the $mprovements cited above, SCE considers the Trip Reduction
\\
Task force to be the most significant.
Thus, I would like to take this opportunity to invite NRC Project Management to San Onofre to review the TRTF program.
If you have any questions, please do not hesitate to call.
Very truly yours, N[N M. O. Medford Manager of Nuclear Engineering and Licensing BRD/CEW:8482T Enclosures J. O. Bradfute, NRR Project Manager, San Onofre Unit 1 cc:
H. Rood, NRR Senior Project Manager, San Onofre Units 2 and 3 J. 8. Martin, Regional Administrator, NRC Region V
- f. R. Huey, NRC Senior Resident inspector, San Onofre Units 1, 2 and 3 m
1
Enclosure TRIP QEDUCTION TASX FORCE EFFORTS I
)
l Established Precrans I
All relevant past trips for Units 1, 2 and 3 have been carefully reviewed and i
the critical components (components which are single failure prone and abased on the inform failure can result in a trip), have been identified.
obtained, 31 programs were initiated with initial completion (except for licensing actions) planned by June 30, 1987.
Most of these programs are grouped into the following five categories:
Detect incipient failures in the critical components before they can 1) cause a trip.
Improve preventive maintenaace practice on a few critical components 2) such that they are not likely to cause a trip.
Imorove the design of those critical components which are single 3) failure prone.
l Reduce the frequency of at-power surveillance activities.
4)
Imorove personnel awareness of critical components through better 5) k labeling, more obvious caution signs, and more detailed caution statements in Maintenance and Operating procedures.
Cemeleted Actions l
The following work was completed in January 1987:
Required reading for ILC and Test Technicians on wire alteration 1) control (i.e., any electrical wire alteration during maintenance must be returned to its original condition).
Cleaning up Unit 3 turbine unitized actuators and establishment of 2) performance monitoring programs for the actuators to detect incipient problems such that the problems can be fixed at power without risking a trip.
f Signs designed and fabricated that caution the I&C and electrical l
3) test technicians of critical equipment.
The following work was completed in February 1987:
A single-failure analysis on the Feedwater System has been completed 1) to identify all critical subcomponents whose failure could cause a These critical subcomponents will receive more attention unit trip.
so that their good operating condition can be continuously
(
maintained.
s
==
W
ene advanced anti-rotation washer (called lock-disk) has been shop tested for its functionality.
Test results show that with this type of washer, it takes twice the original torque to unscrew a bolt as compared to 75% of the original torque for a commonly used washer.
It will be used, whenever possible and appropriate, on all the critical, vibrating components.
(5) An advanced thermal image system has been purchased for Use in determining the incipient failures in PPS and other critical electronic components.
The following work was completed in May, June and July 1987:
(1) The operation and maintenance procedures related to critical components of Unit 2 and 3 have been enhanced.
Appropriate caution statements have been added, and all critical steps in the procedures have been modified to require double verification.
l (2)
The operator run sheets have been enhanced for the critical components of Units 2 and 3.
These run sheets now include items to look for symptoms of incipient failures.
(3)
A tracking system has been established for TRTF action items that have resulted from the evaluation of near plant trips by the TRTF task force.
This tracking system will ensure that hil TRTF action items are completed as scheduled.
(4)
All the secondary side critical instruments for all three Units (such as low pressure (LP) turbine exhaust hood temperature measurement) are now included in the preventative maintenance (PM) program.
They are scheduled to be calibrated or checked during every refueling outage.
(5)
Shift Superintendent accelerated maintenance (SSAM) process has been improved.
The SSAM process allows the Shift Superintendent to bypass the normal maintenance order (HO) process and direct the performance of immediate maintenanca when needed to prevent an eminent plant trip.
The activities performed under the SSAM process l
on critical components are now required to be tailboarded by Shift l
Superintendent and pre-planned.
Status Overview Since initiation of the task force, the list of programmatic action items has grown to 61.
Approximately 75 percent of these items have been completed.
)
i 5;D:8482F
~
9
f l
h s', o r. y'
- *./
Mouq'e p
g
\\
UNITED S1 ATES
\\
' 'k NUCLEAR REGULATORY COMMISSION
8 5.,
{
.j KEGION V
,g
,4 1450 MARIA L ANE.SulTE 210 s
6 q....
,e WALNUT CRE EK. CALIFORNI A 94596 AUG 261983 Docket Ncs.
50-2 50-361 50-362 4
Southern California Edison Company P. O. Box 800 2244 Walnut Grove Avenue Rosemead, Celifornia 91770 Attention:
C. B. McCarthy, Vice President Advanced Engineering Gentlemen:
Subject:
System tic Assessment of Licensee Performance (SALP) k The NRC Region V SALP Review Board met on July 15, 1983, and evaluated the performance of the licensed activities, at the San Onofre Nuclear Generating Station Units 1, 2 and 3, during the period of July 1, 1983'through May 30, 1983. The report of our assessment is enclosed.
We will meet with you on September 7, 1983, to discuss our assessment and any comments you may have regarding our report.
Please inform us in writing within twenty days from the date of this meeting, of any ecmments you may have regarding the SALP report and any actions you deem necessary in the above identified functional areas.
9/.O$I_lSDi'M~
/
v.
ne
.' tY t
= _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _
C"0.'?
{,
' {
e Southern California Edison Company 2-e
.Following our meeting and receipt of your response, the enclosed report, your response, and a summary of our findings and planned actions will In: placed in the NRC Public Document Room.
Your cooperation is appreciated.
Sincerely, o"
T. W. Bishop, Director Division of Resident, Reactor Pro'jects and Engineering Programs
Enclosure:
As stated cc w/ enclosure:
H. B. Ray, Station Manager Mr. R.
. DeYoung, Director, IE j ;
bec: RSB/ Document Control Desk (RIDS).
Distributed by RV:
JBM State of California Resident Inspector Project Inspector 1
/' f'
/
RV f k
D.Kir(sch:dh T. Bishop 8/,P5/83 8/
/83 ou T
,y-
,n.
y
..m~..
o
(-
(
~
U. S. NUCLEAR REGULATORY COMMISSION REGION V e
SYSTDIATIC ASSESSMENT OF T.ICENSEE PERFORMANCE FOR i
SAN ONOFRE NUCLEAR GENERATING STATION JULY 15, 1983 W'Se
4 i
{
{'
TABLE OF CONTENTS I([
Page I.
Introduction
.1 II.
Summary of Results 4
III. Criteria 5
IV.
Performance Analysis 5:
Operations e'
O.1. Plant Operations 5.
0.2 Radiological Controls l11 0.3 Maintenance 12 0.4 Surveillance 15 0.5 Fire Protection 18 0.6 Emergency Preparedness 20 0.7 Security and Safeguards 21-0.8 Fuel Loading _
22 0.9 Licensing Activities 22
/
Construction 28 V.
Tables Table 1 - Inspection Summary, Units 1, 2, 3 30 Table 2 - Nature and Number of Violations, Units 1, 2, 3 31 Table 3 - Items of Noncompli,nce, Unit 1 32 Table 4 - Items of Noncompliance, Unit 2 33 Table 5 - Items of Noncompliance, Unit 3 37 VI.
Supporting Data and Summaries 1.
Licensee Event Reports Analysis 38 2.
Investigation Activities 41 3.
AEOD Evaluation of LERs 43 a
- a I.
Introduction a.
Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect available observations on a periodic basis'and-evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and licensee performance.
The period of this assessment was July 1, 1982 through May 30, 1983.
Evaluation criteria used during.this assessment are discussed in Section III. Each criterion was applied using the "Attributes for Assessment of Licensee Performance" contained in NRCcManual Chapter
~
0516.
b.
SALP Attendees SALP Board Meeting: July 15, 1983, Region V Office Board Members:
T. W. Bishop, Chief, Reactor Projects Branch' No. 2 (Board-Chairman)
D. F. Kirsch, Chief, Reactor Projects Section No. 3 J. L. Crews, Technical Assistant to Regional Administra tor
- R. Pate, Senior Resident Inspector, SONGS 3 K. Scown, Project Inspector, SONGS 1 J. Eckhardt, Project Inspector, SONGS 2 and 3 J. Stewart, Resident Inspector, SONGS 2 and 3 A. D'Angelo, Resident Inspector, SONGS 1 G. Hernandez, Project Inspector (Construction)
G. Yuhas, Senior Radiation Specialist R. Fish, Senior Emergency Preparedness Analyst G. Knighton, NRR, Chief Licensing Branch 3 W. Paulson, NRR, Project Manager, SONGS 1 D. Schaefer, Physical Security Inspector.
O. Shackleton, Chief Investigator, OI
- Did not attend board meeting, however, submitted significant written assessment to board, c.
Background
(1) Previous Systematic Assessment of Licensee Performance The previous San Onofre Nuclear Generating Station SALP' covered the period July.1, 1981 through June 30, 1982. 'the meeting with licensee management was held on November 3, 1982.
Changes in the licensee's program as a result of the previous SALP are addressed in the detailed discussions of appropriate functional areas.
a
+?1-ee----
f-9 "r-
e<'
2
(,
(
'(2) Licensee Activities Unit I has remained shutdown during this assessment period to accomplish sei.=mic upgrading and TMI action items. Unit 2 has achieved initial criticality and completed a significant portion of the power ascension testing during_the period.' Unit 3, which received a low power license November 15,.1982, has completed construction and pre-core load preoperational testing, performed initial fuel loading, and performed a portion of startup testing during the period, m
(a) Unit 1 At the beginning of'the assessment period,:thd reactor remained shutdown for an outage which commenced February 28, 1982, and which the licensee indicated would last through November, 1982.
This extended outage was to accomplish seismic upgrading and TMI action items.
In hovember, 1982, however, considerable outage work t eraained. At this time.the licensee sharply reduced the construction force from about 1100 to 100 workers. This reduction drastically reduced the construction activity at the facility. The licensee indicated that only that i
construction work which was known to be requi>2d, by the NRC, to be completed prior to restart of the unit would be continued.
Also,~ discussions with the NRC were held to determine what other work might be required to be completed. At the end of the assessment period, these discussions were still in progress.
The licensee has indicated their intention to seek approval of an integrated long term outage plan which would distribute anticipated modifications over the next several fuel cycles. Meanwhile, pending development and approval of this plan, the licensee intends to stop further-construction activity cs of August, 1983.
(b) Unit 2 Licensee performance in the area of Unit 2 operations was considered unsatisfactory during a portion of the 1
assessment period.
This resulted in an enforcement conference and civil penalty being imposed.
The licensee has taken aggressive corrective actions to improve performance.
These corrective actions are still in progress, and it appearslas if the licensee's performance 1
is improving.
the beginning of the assessment period the facility wac At well into the preoperational test program.
The low power and power ascension testing programs have been completed on the following schedule:
Initial Criticality July 26, 1982 l
r 3
(
{-
Low Power Physics Testing.
August 1982 20% power Oct. 27 - Nov. 12, 1983 50% power Nov. 16, 1982 - May 14, 1983 80% power May 28 - June 5, 1983 100% power June 15 - Schedule under review.
The licensee has experienced delays in the t esting program due to the following:
Failure of reactor coolant pump seals in December.
1982 and June 1983 i
Turbine condenser leakage in January 1983 'and February 1983 Malfunction of the turbine control valves in January and February 1983 Turbine bypass valves and steam line failure in February 1983 Reactor trip breaker failures in March and April 1983 g
\\
Inoperability of the past accident sampling system -
March through-April 1983 The licensee has completed all of the TMI modifications.
required for full power operation.
(c) Unit 3 The construction of the plant is essentially complete'with only a few construction restraints remaining for low. power testing (5% power).
The licensee has completed the j
pre-core load preoperational test program. -The low power license was issued November 15, 1982.
Fuel loading was completed November 21, 1982. The schedule ~for initial l
criticality is under review.
The licensee has experienced delays in the startup testing program due to the following:
Reactor trip breaker failures Extended outage for replacement of control element drive motcr (CEDM) coil stacks on all 91 control rods.
Modifications in main steam bypass piping.
Design change to turbine control valves.
l, 4
Modification of turbine condenser hotwell to prevent and better identify' saltwater leaks.
In addition, the licensee has. intentionally slowed the progress of startup testing on Unit 3 to preclude the simultaneous peak testing activities on both unit:;. 'This was a major positive step which resulted, in part, from a.
recent enforcement action (March 1983) which resulted from the licensee's difficulty in handling simultaneous peak testing activity on both units. The self imposed slowdown appears to have,resulted in an overall improvement in the
~
licensee's performance.
(3)
Inspection Activities The total number of inspection hours applied to San Onofre were-6170 with 1341 hours0.0155 days <br />0.373 hours <br />0.00222 weeks <br />5.102505e-4 months <br /> applied to Unit 1, 2604 hours0.0301 days <br />0.723 hours <br />0.00431 weeks <br />9.90822e-4 months <br /> applied to Unit 2, and 2225 hours0.0258 days <br />0.618 hours <br />0.00368 weeks <br />8.466125e-4 months <br /> applied to Unit 3.
Distribution of inrpection hours is shown in Table 1.
Tabulation of functional. area inspection activity and enforcement actions are contained in Table 2.
Tables 3, 4, and 5 provide descriptive amplification of enforcement actions for 4
Units 1, 2, and 3, respectively.
During the current assessment period an enforcement conference was held and a civil penalty was imposed on Unit 2 by the NRC.
II.
Summary of Results:
The summary of results for each operations and construction functional area are provided in tabular form below.
The Category 1, 2 or 3 ratings l
are explained in Section III of this report.
r Performance Analysis Summary l
Unit Unit Unit Operations 1
2 3
Overall 0.1 Plant Operations 1
3 2
3 0.2 Radiological Controls 2
3 2
3 l
0.3 Maintenance 1
2 2
2 0.4 Surveillance 2
'2 1
2 0.5 Fire Protection 1
2 2
2 0.6 Emergency Preparedness 1
1 1
1 0.7 Security and Safeguards 2
2 2
2 0.8 Fuel Loading NA
- - NA 1
1 0.9 Licensing Activities 2
2 2
2 Construction C.1 Construction 1
1 1
1
,-,--,,-4
,r
0 0
^
(
{
c U. S. hTCLEAR REGULATORY C0rf!ISSION PIGION V e
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORr! NICE FOR i
SAN ONOFRE hTCLEAR GENERATING STATION JULY 15, 1983 W $e
. e t, * ',.
/
(.
\\
TABLEOhCONTENTS r.,
' (L, Page I.
Introduction 1
II. Summary of Results s
4 III. Criteria 5
IV.
Performance Analysis 5
Operations i
s s'
O.1. Plant Operations 5
0.2 Radiological Controls 11 0.3 Maintenance 12 0.4 Sdrveillance 15 0.5 Fire Protection 18 0.6 Emergency Preparedness s
20 0.7 Security and Safeguards 21 0.8 Fuel Loading 22 0.9 Licensing Activities 22 l
Construction 28 V.
Tables Table 1 - Inspection Summary, Units 1, 2, 3-30 Table 2 - Nature and Number of Violations, Units 1, 2, 3 31 Table 3 - Items of Noncompliance, Unit 1 32 Table 4 - Items of Noncompliance, Unit 2 33 Table 5 - Items of Noncompliance, Unit 3 37 VI.
Supporting Data and Summaries 1.
Licensee Event Reports Analysis 38 2.
Investigation Activities 41 3.
AEOD Evaluation of LERs 43 I
s O
4 q
4 4 g
(
(
I.
Introduction a.
Purpose and Overview The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort to collect available observations on a periodic basis and evaluate licensee performance based on those observations with the objectives of improving the NRC Regulatory Program and licensee performance.
The period of this assecsment was July 1, 1982 through May 30, 1983.
Evaluation criteria used during this assessment are discussed in Section III. Each criterion was applied using the "Attributes for Assessment of Licensee Performance" contained in NRC Manua'l Chapter 0516.
b.
SALP Attendees SALP Board Meeting: July 15, 1983, Region V Office Board Members:
T. W. Bishop, Chief, Reactor Projects Branch' No. 2 (Board Chairman)
D. F. Kirsch, Chief, Reactor Projects Section i
No. 3 J. L. Crews, Technical Assistant to Regional Adminirtrator
- R. Pate, Senior Resident Inspector, SONGS 3 K. Scown, Project Inspector, SONGS 1 J. Eckhardt, Project Inspector, SONGS 2 and 3 J. Stewart, Resident Inspector, SONGS 2 and 3 A. D'Angelo, Resident Inspector, SONGS 1 G. Hernandez, Project Inspector (Construction)
G. Yuhas, Senior Radiation Specialist R. Fish, Senior Emergency Preparedness Analyst G. Knighton, NRR, Chief Licensing Branch 3 W. Paulson, NRR, Project Manager, SONGS 1 D. Schaefer, Physical Security Inspector
- 0. Shackleton, Chief Investigator, OI
- Did not attend board meeting, however, submitted significant written assessment to board.
c.
Background
l (1)
Previous Systematic Assessment of Licensee Performance The previous San Onofre Nuclear Generating Station SALP covered the period July 1, 1981 through June 30, 1982.
The meeting with licensee management was held on November 8, 1982.
Changes in the licensee's program as a result of the previous SALP ate l
addressed in the detailed discussions of appropriate functional areas.
t 2
{
1 (2)
Licensee Activities Unit I has-remained shutdown during this assessment period to accomplish seismic upgrading and TMI action items.
Unit 2 has achieved initial criticality and completed a significant portion of the power ascension testing during the period.' Unit 3, which received a low power license November 15, 1982, has completed construction and pre-core load preoperational testing, performed initial fuel loading, and performed a portion of startup testing during the period.
(a) Unit 1 At the beginning of~ the assessment period, thd reactor remained shutdown for an outage which commenced February 28, 1982, and which the licensee indicated would last through November, 1982. This extended outage was to accomplish seismic upgrading and TMI action items.
In November, 1982, however, considerable. outage work remained. At this time the licensee sharply reduced the construction force from about 1100 to 100 workers. This reduction drastically reduced the construction activity at the facility. The licensee indicated that only that i
construction work which was known to be required, by the NRC, to be completed prior to restart.of the unit would be continued.
Also,~ discussions with the NRC were held to determine what other work might be required to be completed. At the end of the assessment period, these discussions were still in progress. The licensee has indicated their intention to seek approvalgof an-integrated long term outage plan which would distribute anticipated modifications over the next several fuel cycles.
Meanwhile, pending development.and approval of this plan, the licensee intends to stop further construction activity as of August, 1983.
(b) Unit 2 Licensee performance in the area of Unit 2 operations was considered unsatisfactory during a portion of the assessment period.
This resulted in an enforcement conference and civil penalty being imposed. The licensee has taken aggressive corrective actions to improve performance.
These corrective actions are still in progress, and it appears as if the licensee's performance is improving.
At the beginning of the assessment period the facility was well into the preoperational test program._ The low power and power ascension testing programs have been completed on the following schedule:
Initial Criticality July 26, 1982
= -
~
y
3
(,
(-
Low Power Physics Testing August 1982 20% power
.Oct. 27 - Nov. 12, 1983 50% power Nov. 16, 1982.- May 14, 1983 80% power May 28 - June 5, 1983 100% power June 15 - Schedule under review The licensee has experienced delays in the testing prcgram due to the following:
Failure of reactor coolant pump seals in December 1982 and June 1983 c
Turbine condenser leakage in January 1983'and February 1983 Malfuaction of the turbine control valves-in January and February 1983 Turbine bypass valves and steam line failure in February 1983 Reactor trip breaker failures in March and April 1983 Inoperability of the post accident sampling system -
March through-April 1983 The licensee has completed all of the TMI modifications required for full power operation.
(c) Unit 3 The construction of the plant is essentially complete with only a few construction restraints remaining'for low power testing (5% power).
The licensee has~ completed the.
pre-core load preoperational test program.
The low power license was. issued November 15, 1982.
Fuel loading was completed November 21, 1982.
The schedule'for initial.
criticality is under. review.
The licensee has experienced delays in'th'e startup testing program due to the following:
Reactor trip breaker failures Extended outage for replacement of control element-drive motor (CEDM) coil stacks on all 91 control I
rods.
Modifications in main steam bypass piping.
Design change to turbine control valves.
. ~.
4 Modification of turbine condenser hotwell to prevent and better identify' saltwater leaks.
In addition, the licensee has-intentionally slowed the progress of startup testing on. Unit 3 to preclude the simultaneous peak testing activities on both units. 'This was a major positive step which.resulted, in part, from a recent enforcement action (March 1983) which resulted from the licensee's difficulty in handling simultaneous peak testing activity on both units. The self-imposed slowdown' appears to have resulted in an overall improvement.in-the licensee's performance.
(3)
Inspection Activities The total number of inspection hours applied to San Onofre were 6170 with 1341 hours0.0155 days <br />0.373 hours <br />0.00222 weeks <br />5.102505e-4 months <br /> applied to Unit 1, 2604 hours0.0301 days <br />0.723 hours <br />0.00431 weeks <br />9.90822e-4 months <br /> applied to Unit 2, and 2225 hours0.0258 days <br />0.618 hours <br />0.00368 weeks <br />8.466125e-4 months <br /> applied.to Unit 3.
Distribution of inspection hours is shown in Table 1.
Tabulation of functional area inspection activity and enforcement actions are contained in Table 2.
Tables 3, 4, and 5 provide descriptive amplification of enforcement actions for
/
Units 1, 2, and 3,-respectively.
During the current assessment period an enforcement conference was held and a civil penalty was imposed on Unit 2 by the NRC.
II.
Summa ry o f Re sul t s :
The summary of results for each operations and construction functional area are provided in tabular form below. The Category 1, 2 or 3 ratings-are explained in Section III of this report.
Performance Analysis Summary Unit Unit Unit Operations 1
2 3
Overall 0.1 Plant Operations 1
3 2
3 0.2 Radiological Controls 2
3 2
3 0.3 Maintenance 1
2 2
2 0.4 Surveillance 2
2 1
2 0.5 Fire Protection 1
2 2
2 0.6 Emergency Preparedaess 1
1 1
1 0.7 Security and Safeguards 2
2 2
2 0.8 Fuel Loading NA
- - NA 1
1 j
0.9 Licensing Activities 2
2 2
2 i
Construction C.1 Construction 1
1 1
1
\\
l 4
I
...-. -a.-
T; 5-1
(
(
III. Criteria i
The following evaluation criteria were applied to each functional area:
1.
Management involvement in assuring quality.
2.
Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement h' story.
5.
Reporting and analysis of reportable events.
6.
Staffing (including manageme t).
7.
Training effectiveness and qualification.
To provide consistent evaluation of licensee performance, the characteristics applicable to Category 1, 2, and 3 performance'were applied as defined in NRC Manual Chapter 0516, Part II and Table 1.
The NRC Manual Chapter definitions of the categories include the following:
Category 1: Licensee management attention and involvement are aggres.sive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety or construction is being achieved.
f Category 2:
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and ara reasonably effective such that satisfactory performance with respect to operational safety or construction is being achieved.
Category 3:
Both Licensee managemen,NRC and licensee attention should be increased.
t attention or. involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appeared strained or not ef fectively used such that minimally satisfactory performance with respect to operational safety and construction is being achieved.
IV.
Performance Analysis - July 1, 1982 - May 30, 1983 0.
Operations 0.1 Plant Operations Unit 1 Considering the fact that the plant has been in Mode 5 during the entire evaluation period, the licensee demonstrated more than adequate safety performance in this area.
Weaknesses identified during the previous SALP cycle have markedly improved. For example, only one violation (Level V) was identified and the. number of Licensc* Event Reports-attributable to errors or linked to previous events declined from six to three.
Plant staffing quantity and quality were more than adequate (including full time equipment
(
control, training, and procedures groups).
Training was effective (15 of 17 candidates for operating licenses passed their exams on
~.
6
(
(
4 the first attempt).
Problems noted in.the. training of craftsmen and technicians in the previous assessment appear to have been resolved.
The licensee's resolution of technical issues in the operations area indicated a better understanding of safety considerations.
In addition, inproved procedural compliance and formality, in the control room, by operators has been observed.
Conclusion Category 1 Board Recommendation None Unit 2 During this period the licensee continued to progress through the startup test program. This ' program was interrupted on numerous-occasions due to equipment problems and NRC concerns (e.g. Scram Breakers). A large number of equipment problems occurred due, in part, to Unit 2 being the lead Combustion Engineering plant for its size.
Also, Unit 2 has a larger array of systems than older plants and much more detailed technical specifications. These factors.have resulted in a large number of-Unit 2 Licensee Event Reports (112) during this period.
During this evaluation period twelve Regional inspections (193 inspection hours) and continuous Resident Inspection (726 inspection hours) were performed on Unit 2.
This inspection activity identified th'e following weak areas:
Operator Control of Plant Systems Operators failure to lineup the auxiliary feedwater system properly which eventually resulted in damage to this system (Level IV violation, Inspection Report 82-25).
i i
Operator failure to recognize in a timely fashiori the loss of the majority of the Containment' Pressure Control System and take proper action to shutdown the plant (Level III violation, Inspection Report 83-06)
Seventeen LER's addressing operator failures to meet Limiting Conditions for Operation (L.C.O. 's) due to operator errors.
Control of Temporary Modifications i
Operations staff / Station Engineering failure to communicate.
operability considerations associated with temporary }lPSI pump i
suction piping which was not seismically designed.
This resulted in the operations staff erroneously declaring this system operational.
Two violations resulted; failure to perform an adequate 10 CFR 50.59 review and failure to follow s m
y
(
(
temporary modification procedure.
(Level IV violation, l(.
Inspection ~ Report 83-06).
Valve Lineup Controls Operator failure to perform an independ.?nt wrification of the alignment of eqrtipment returned to service -(Lc. vel IV violation, Inspection Report 83-06).
Failure to provide correct valve lineup proudures for safety related systems.(e.g. auxiliary feedwater and fire protection)
(Level IV violation, Inspection Report 83-15).
Failure to follow valve lineup procedure for safety related.
component cooling water system (Level IV violation, Inspection Report 83-15).
Failure to maintain sufficient records to furnish evidence of activities affecting quality (Level V vi31ation, Inspection Report 83-15).
Six LER's showed examples where L.C.Os were violated.
Safety related equipment was made inoperable, due to valve lineup f
errors.
Reporting Administrative Controls for Reportable Items Failure to report an unusual event in a timely fashion as required (Level IV violation, Inspection Report 82-41).
Failure 'to report the failure of certain reactor trip breakers to function (Level IV violation, Inspection Report 83-13).
Failure to report PASS system inoperability (Level III violation, Inspection Report 83-06).
Operator Overtime Administrative Controls-Two violations were issued during this period identifying the licensee's failure to properly control operator overtime.
(Level V violation, Inspection Report 82-30 and Level IV violation, Inspection Report 82-39).
In addition, during the end of the previous SALP period the licensee had a Level IV violation in this area.
Housekeeping i
Two violations resulting fro [n failure to maintain adequate housekeeping (Level IV violation, Inspection Report 82-22 and Level IV violation, Inspection. Report 83-02).
Temporary Procedure Change Controls -
j N.
l l
6 8
(
(
One violation resulting from licensee's failure to have proper j
management approval of one procedure change-(Level V violation,
.('.
Inspection Report 83-06).
Previous to this violation'the licensee's Quality Assurance Organization,had identified' weaknesses in this area, which the licensee.was' correcting.
Corrective Action Response Program-The licensee has had difficulty responding in a timely fashidn -
to the.large number of CAR's generateds during this period.
Safety Related System Reliability During this period 69 LER's have been generated. showing failures of Safety Related Systems due to the following_ causes:
28 Design Error 2 Manufacturing Error 3 Installation Error 10 Defective Procedure-26 Component Failure The underlying causes for the above weak areas appear to be the following:
High pace of activity Large, relatively new, unseasoned organization Unclear definitions of responsibility and authority Weak inter-organizational communications Failure to follow procedure Inadequate procedures-Some knowledge level deficiencies in Tech-nical Specification requirements Failure to effect adequate _and permanent corrective action The above troublesome performance in the operations area (excluding valve lineup citations) was brought into focus during a major Enforcement. Conference held in March 1983. At this point-the NRC was concerned about what appeared to be recent deterioration in the -
licensee's performance so that in addition to the Enforcement-Conference, the Director of the Office.of Inspection and Enforcement, Richard C. DeYoung and the Region V Regional Administrator, Robert Engelken, held a management conference with the Chairman of the Board, William R. Gould, and his Executive Vice President, David J. Fogerty of Southern California Edison.
The two meetings were used by the hPC to emphasize concerns regarding the high pace of activity resulting from' Unit 3 startup being so close behind Unit 2, the need for significant involvement of the highest levels of SCE management, the apparent recent degradation in f
licensee performance, the appearance of lack of candor in SCE
(
communications with NRC and the appearance that schedule has, at b
{'
9
(
(
times, come close to reaching the same priority as safety.
The
((#~
licensee has responded to these; concerns by instituting many changes.
In particular,:a s'ignificant increase in high level k
management attention has been evident since the Enforcement Conference, Unit 3 startup activities were curtailed for the. rest of this period, and the licensee made.significant efforts to emphasize to all levels that safety is.the number one priority in all. cases.
In addition, improvement in all other areas.of concern have been
~
noted.
Overall, the licensee's management and _ organizations haye responded in a very positive manner to the concerns precipitating the Enforcement Conference, however, performance improvements have only occurred during the last part of this evaluation periods In summary, since the Enforcement Conference Southern California Edison has made significant effort to correct-deficiencies by:
increasing management involvement in assuring quality; improving the response to NRC initiatives; increasing efforts to augment _and increase staffing levels; initiating management changes; and initiating efforts to assure that the operations and other organizational staffs are more fully cognizant of their responsibilities and interfaces.
b Conclusion f
Category 3 Board Recommendation Since the licensee has shown significant improvements stemming from the March 7, 1983 Enforcement Conference, continued emphasis by.
licensee management is recommended.
Unit 3 During this period, five Regional Inspections (consisting of 17 inspection hours) and continuous routine resident inspection (consisting of 744 inspection hours) were used to evaluate this functional area. Three items of noncompliance were identified in this area:
(Note:
All three citations are applicable to both Units 2 and 3).
a)
(Inspection Report 83-15, level IV) Failure to provide correct l
valve lineup procedures for safety related systems (e.g.
{
auxiliary feedwater, fire protection).
)
b)
(Inspection Report 83-15, Level IV) Failure to comply with
)
safety related component cooling water system valve lineup procedure.
c)
(Inspection Report 83-15, level V) Failure to maintain l
sufficient records to furnish evidence of activities affecting
-(
quality.
's.
l
a-10
(
(
The. licensee appears to be taking satisfactory corrective actions'in l('~
response to these problems.
Twenty-two LERs were submitted in this area, eleven Unit 3 LERs and
' eleven Unit 2 LERs dealing with common. systems. The causes for these LERs are as follows:
Personnel error - 8 Design error - 4 Manufacturing error - 1 Inadequate procedure - 2 Component failure - 7 A low power operating license was issued for Unit 3 on November 15, 1982. Thus, for the first five months of this period the licensee's plant operations were not being evaluated for compliance to an operating license since preoperational testing was in progress.
It was evident during this preoperational testing period that many of the lessons learned on Unit 2 had resulted in a more polished Unit 3 preoperational test program.
With the issuance of the Unit 3 Operating License, it was anticipated that this trend would continue, which, in fact, it did, to a large extent.
The three citations in this area are Unit 2/3 citations which is not inconsistent with the fact that Unit 3 has.been able to capitalize on Unit 2 lessons learned. However, LER analysis indicates several operator errors due to carelessness on the part of the operators, indicating that the operators may not be as attentive as necessary.
A factor that contributed to the lower production rate of Unit 3 LER's, as compared to Unit 2 (112), is that Unit 3 was put into an extended three month delay to reduce the activity level station-wide.
This achieved the desired effect and helped reduce the number of Unit 3 LER's.
Overall, the Unit 3 performance was much improved over Unit 2 for the following reasons:
lower activity level-good use of lessons learned from Unit 2 more seasoned and well run operations organization resulting from corrective actions completed in response to problems identified on Unit 2.
Conclusion Category 2 Board Recommendation None p, fy e
T'N 2#
11 0.2 Radiological Controls
?~,
k Units 1, 2, and 3 The area "radiological controls" includes:
radiation protection, radioactive waste management, effluent monitoring and control,-
shipment of radioactive material, radiological environmental monitoring, and post-accident sampling programs.
Cycle 2 SALP inspection findings detailed major programmatic deficiencies in the radiation protection area.
Cycle'3.SALP described improvements'in radiation protection but presented weaknesses in the effluent monitoring and control program.
During this cycle, six separate inspections, involving 544 hours0.0063 days <br />0.151 hours <br />8.994709e-4 weeks <br />2.06992e-4 months <br />' of direct inspection effort were performed.
These inspections reviewed all areas except shipment of radioactive materials.
As a result of this effort; two severity level three violations (post-accident sampling program); four level four violations (informing workers, radiation surveys, calibration of effluent monitors, bypassing of effluent monitors); and three level.five violations (labeling of containe.rs, posting of notices to workers, failure to submit special report) were identified. An Enforcement Conference was held on March 7, 1983 and a Civil Penalty was paid by the licensee'on May 2, 1983.
While the items of noncompliance are individually important they are so closely related so ar to conclude that a serious breakdown of not the licensee's "radiological control" responsibility has occurred.
j There are, for example, several areas where continued improvements in the radiation protection and environmental monitoring programs have been observed. These include:
stabilization-of site radiation protection staff, creation and staf fing of a corporate radiation protection function, implementation of formalized ALARA and radwaste reduction programs, implementation of the SONGS HEALTH PHYSICS IRFORFiATION NOTICE system, improved radiation protection training for technicians and professionals, improved radiological and environmental monitoring programs, and incident free shipment'of~
radioactive materials during the past year.
One area which continues to demand additional licensee and NRC resources is the effluent monitoring system, including those necessary to monitor post-accident conditions. 'During this evaluation period, although considerable resources were expended, the licensee failed to fully meet their commitments in this area.
For example, in response to the inspection findings and Enforcement Confer *nce held during Cycle 3 the licensee committed to take several actions to improve Unit l's Operational Radiation Monitoring System. A December 1982 inspection at Unit 1 (Inspection Report No.
50-206/82-36) found the licensee had failed to iriplement several of their commitments.
The post-accident sampling capability (NUREG-0737 Item II.B.3 and II.F.1) has been a highly visible problem area for the licensee during thee last year. The licensee failed to assure the required capabilities were in place for Unit 2 by their commitment date.
Inspection Report No. 50-361/83-08 details the
{
failure to meet the commitment and presents information to indicate r
s
-.-,r-n
.r-r r
yw.,., -v..,.
9
(-
t' 12 that licensee management was aware of the problems and failed to inform NRC. A subsequent inspection in March, 1983 (Inspection Report No. 50-361/83-14) identified additional noncompliance in the effluent monitoring and control program at Unit.2.
The licensee's written response to these findings has been adequate and performance is apparently improving, as noted from review of their May 18, 1983' letter.
It is expected that implementation of these commitments will further improve performance during the next evaluation period.
The licensee has been responsive to NRC identified findings.
Inspections have found the licensee to be^less responsive,to internally identified problems.
In two cases, failure to respond to Quality Assurance findings resulted in noncompliance, (10 CFR 19.'11, Unit 2 License Condition 2G).
In another case, (Inspection Report 50-361/83-14) if meaningful action been taken in response to Startup Problem Report No. 3606 two items of noncompliance might have been prevented.
Conclusion Although the licensee has performed' well in the areas of radiation protection, radiological environmental monitoring and shipment of radioactive materials, the inspection findings in effluent monitoring and post-accident ~ sampling degrade the overall performance classification of "Radiological Controls" to Category 3.
Board Recommendation The licensee should be encouraged to continue the good direction radiation protection and environmental monitoring programs have taken in the last year. They should be directed to maintain a high level of management support to correct deficiencies'in effluent monitoring and to be more sensitive to internally identified findings.
0.3 Maintenance Unit 1 The licensee's performance in this area improved markedly, No violations (down from one Level IV in the previous period) and only one Licensee Event Report, due to a personnel error (down from ten i
in the previous period), were recorded.
Training of working level personnel in the documentation of work performed was effective.
Use j
of procedures and work orders by personnel was much improved.
k'o r k packages for the performance of ull maintenance activities generally appeared to be complete. Also, accuracy and detail of the procedures and work orders which are to be used by the worker (NRC Inspection Report No. 83-13) appeared adequate.
Staffing in the maintenance group was adequate to complete high-priority work,'but a
(
considerable backlog of routine minor deficiencies appears to have accumulated.
In addition, the EFCOMATIC containment isolation I
l i
1
- - - - - - - - - - - - - - - ' - - - - - - - - - - - - - - - - - - ~ - - '
~ ~ ~ ~ ~ ~
..\\-
13
(
(
valves-and the saltwater pump discharge valves continue to be occasionally unreliable (NRC Inspection' Report No. 83-07) indicating that improvements may be in order to satisfactorily resolve technical issues from a. safety standpoint.
Although general area housekeeping has been good, the large amount of construction, activity in the first half of the period has degraded the.
housekeeping level in the less accessible areas. Management direction and attention to the improvement of maintenance performance was evident, particularly among managers and supervisors assigned solely to Unit 1.
Conclusion Category 1 e
Board Recommendation None Unit :
During the current assessment period, six region based inspections and routine inspection by the resident inspectors identified three violations.
The inspection effort-in the' maintenance area consisted of 277 hours0.00321 days <br />0.0769 hours <br />4.580026e-4 weeks <br />1.053985e-4 months <br /> by resident inspectors and 92 hours0.00106 days <br />0.0256 hours <br />1.521164e-4 weeks <br />3.5006e-5 months <br /> by region based inspectors for a total of 369 hours0.00427 days <br />0.103 hours <br />6.10119e-4 weeks <br />1.404045e-4 months <br />. The licensee's station maintenance organization has expanded during this. assessment period and maintenance responsibilities have been gradually turned ~over to the station staff.
The maintenance staffs are currently organized into the following three groups:
Station Maintenance, Startup Maintenance, and Instrumentation and Control.
The maintenance organizations presently utilize a large contractor work force.
The rapid expansion of the Station Maintenance staff and the transition of responsibilities during this assessment period are contributing factors to the following program weaknesses.
Inadequate documentation of maintenance work.
Incomplete factoring of operating experience into preventive maintenance frequencies.
Lack of strict procedural compliance by contractor personnel.
1 Progress has been noted in two areas, identified as weak areas during the previous assessment period, however, both still require additional improvement:
Failure to assure that vendor information is appropriately coordinated, controlled and evaluated for incorporation into Technical Manuals and/or procedures.
The Reactor Trip Breaker Failures were partly caused by the failure to include vendor recommended maintenance intervals and acceptance criteria in the maintenance program (item of noncompliance).
\\s_
- ~
14 I~
Failure to. establish an adequate post maintenance retest program.
t Twelve Licensee Event Reports were'due to problems with valve limit switches and valve position indicators, which have root causes relating to installation errors and inadequate maintenance. -Due to-the large number of valve operator problems which have occurred._the licensee initiated a limitorque valve operator task force to eliminate valve failures due to maintenance errors.
Improvements in this ar :a are currently in progress.
Conclusion Category 2 Board Recommendation None Unit 3 During this period three regional inspections (consisting of 30 inspector hours) and continuous routine resident inspection (consisting of 121 inspector hours) were used to evaluate the
'i maintenance area.
No items of noncompliance were identified.
Ten LERs were submitted, nine Unit 3 LERs and one Unit 2 LER on-a common system. The causes of the LERs are as follows:
Pcesonnel error - 5 Design error - 1 Defective procedure - 3 Component failure - 1 The maintenance program on Unit 3 is the same organization as on Unit 2.
Thus the weaknesses discussed in the Unit 2 maintenance area functional analysis also apply to Unit 3.
The areas where some i
i weaknesses were found are as follows:
Control of vendoo activities Incorporation of vendor and NRC supplied information and other documentation into maintenance procedures.
Program for preventive maintenance frequency reevaluation based on operating and machinery history.
i Machinery history retrieval process.
Documentation of completed maintenance activities.
I
\\s_
Retest program for maintenance activities.
4'
. 3,,
-i
{pr.
In addition to the above. program weaknesses, the licensee's.
maintenance organization is very complex due to.a limited number:of
(;,
licensee station maintenance personnel. This condition requires'the' extensive use of startup and Bechtel personnel for a large y
percentage of all maintenance activities.
v A review of the LER's in this area indicates severalipersonnel errors associated with maintenance activities which resulted in, inoperable equipment, and also. identifies instances of-inadequate '
procedures. Reactor trip breaker maintenance procedure deficiencies highlight a most notable example.
This-instance resulted in a several week outage affecting both Units 2 and 3 and' subsequently aided in identifying many other weaknesses identified above.
The maintenance program at Unit 3, as well as Units 1 and 2, has continued to improve. Although many improvements are currently ongoing, si'gnificant improvements have already.been made. However, these improvements were not timely enough or complete enough to prevent the reactor trip breaker problem.
Conclusion Category 2
'l Board Recommendation
(-.
None 0.4 Surveillance 4
Unit 1 The licensee demonstrated satisfactory safety performance in this area. The deficiencies noted in management control of the surveillance program late in the previous assessment period (Inspection Report No. 82-20) were addressed by the licensee in a comprehensive program of corrective action during~this period' 'This program, indicating increased management involvement'in assuring quality, included a review to identify other surveillances missed, revision and replacement of administrative procedures to more closely track and control Technical Specification surveillance-4 requirementa, and a special audit of the corrective' action taken.
Three additional instances of missed surseillances resulted from the review of the surveillance history by the licensee (LER 82-20).
~
j The licensee's program of corrective action, in response to NRC initiatives, appears to have been effective in rectifying the weak areas in the surveillance program.
Conclusion l
Category 2 I
x i
,, _,.. _ - ~ -
}
16
{-
Board Recommendation lr- '
None i
A, s
Unit 2 During this period seven regional inspections (consisting of 79 inspection hours) and 17 resident inspections-(consisting of 473 inspection hours) were expended to evaluate surveillance.
Three items of noncompliance were identified:
a)
(Inspection Report 82-38, Level V) Failure to perform quarterly surveillance on safety related batteries.
d b)
(Inspection Report 83-06, Level IV) Failure to perform a 10'CER 50.59 review associated with a temporary test loop used to verify ISI test results on HPSI pump flows.
c)
(Inspection Report 83-06, Level IV) Failure to control a temporary modification used to perform ISI testing of HPSI. pump flow in accordance with licensee procedures.
The licensee appears to be taking satisfactory corrective actions in i
response to these problems.
Fifty-six Licensee Event Rep' orts were submitted by the licensee in this area. Of these 56 LERs, approximately 37 represent equipment deficiencies identified by these programs, while approximately 15 represent problems due to faulty procedures or operator errors.
The licensee surveillance program was aggressively pursued.
However, several personnel errors did result in occasional missed surveillances. Also, several procedural errors were identified which caused system inoperability.
The licensee surveillance program and startup test program were successful in identifying inoperable systems.
The major enforcement actions in this area were centered around two events.
Failure to properly perform battery surveillance which appeared to be caused by a faulty procedure.
Inadequate control of a run of temporary piping which was being installed to measure HPSI pump flow rates. This temporary piping was being installed to resolve licensee identified inadequacies in the normal inservice testing flow measuring instrumentation.
The two citations in this area pointed out a failure in the licensee's program to control this type of work.
Inadequate information transfer between the several i
organizations involved in this particular activity and incomplete procedures were the major contributors.
1 Another area of concern was the adequacy of startup testing
{
/
associated with changes to the control room emergency air cleanup
(,
system (CREACUS).
In this case, the licensee displayed resistance
17
{'
to NRC initiatives urging that they perform a final full test of the control room pressurization system after fan replacement.
The licensee's position was that engineering calculations were adequate to show the new larger fans would ensure adequate'd/p across the control room pressure boundry.
This position was proven in error when subsequent testing, at NRC insistance, failed to' meet the' acceptance criteria.
A similar type of occurrence, associated with an interlock to prevent two HPSI pumps from starting on one diesel, had the same root cause of licensee reluctance to1 perform a full operability test. The licensee has subsequently improved in the area of resolution of technical issues from a safety standpoint.
Conclusion Category 2 Board Recommendation None Unit 3 During this period five regional inspections (consisting of 119 inspection hours) and continuous routine resident inspections
.i (consisting of 249 inspection hours) were used to evaluate surveillance and preoperational testing.
No items of noncompliance were identified.
i Twenty-one Licensee Event Reports (LER's) were submitted in this area during this period. Thirteen were Unit 3 LERs and eight were i
Unit 2 LERs on common systems.
The causes of these LERs are as follows.
l Personnel error - 5 Design error - 3 Defective procedure - 2 Component failure - 9 Other - 2 The licensee's surveillance, startup testing, and inservice I
inspection programs have been successful during this period in identifying inoperable systems.
Twelve problems resulting in LERs were identified by the surveillance program. Many of the failures were due to equipment failure or design errors.. However, a few were also due to personnel error in valve lineups. Also, one surveillance item was missed during this period and identified by the licensee.
Overall, the licensee's program in this area has been successful.
Conclusion Category 1 I(
i l
w
18
{-
Board Recommendation C,
None 0.5 Fire Protection Unit 1 The licensee demonstrated satisfactory safety performance.in this The large number and variety of_ construction projects in this area.
period required the licensee to periodically disable portions of the fire detector and suppression systems and to substitute compensatory protection measures, such as fire watches and temporary fire. hoses.
In some instances, for example, two Level IV violations'in Inspection Report No. 82-32, the licensee made errors in the administration and maintenance of these compensatory measures and exhibited weaknesses in personnel training.
The routine resident inspection of the fire protection system indicates that these errors have been corrected. Fire watch personnel appear alert, effectively trained, and responsible. A full time fire brigade of professional fire fighters has been on duty at the station since March,1982.
The licensee's reporting of fire protection system discrepancies appears accurate.
Conclusion Category 1 Board Recommendation None Unit 2 During this period three regional inspections (consisting of 75 inspector hours) and continuous routine resident inspections (consisting of 41 inspection hours) were expended to evaluate fire protection. Two items of noncompliance were identified:
a)
(Inspection, Report 83-15.. Level.IV) Failure to provide electrical supervision of certain fire protection v'lves as a
required by the Fire Hazards Analysis, b)
(Inspection Report 83-19, Level IV) Failure to provide adequate emergency lighting to plant safe shutdown areas in accordance with license requirements.
No LER's were identified in this area.
i Overall the licensee appears to have an aggressive fire protection program, although some weak areas have been noted. The major j
problem appears to be the licensee's failure to aggressively verify implementation of the details of all requirements contained in the 7g Fire Hazards Analysis, which is required to be implemented.
The l
I
.i
19
(
(
Fire Hazards Analysis is a.three inch book and contains numerous detailed requirements. The licensee has initiated an ongoing program to identify and verify all requirements in this area.
Another area of concern stems from the large number of inoperable fire barriers and occasionally inoperable fire protection systems.
This situation necessitated a large backup fire barrier patrol' organization to meet technical specification requirements and there have been occasional lapses in.the completeness of this coverage.
The numerous out-of-commission fire barriers is the result of extensive modification work throughout the plant.
Two citations were given in this area which were associated with failure to provide the required fire protection and emergency equipment (e.g. electrical supervision of valves and emergency lighting). -These are, in part, a result of the problem, identified-above, concerning the licensee's incomplete review and verification of proper implementation of the extensive array of license requirements in this area. Management has increased their involvement in assuring quality, improved reporting and analysis of reportable events, and taken a more aggressive approach to the resolution of technical issues from a safety standpoint.
Conclusion Category 2 Board Recommendation None Unit 3 During this period two regional inspections (consisting of 49 inspection hours) and continuous routine resident inspections were used to evaluate fire protection. No items of noncompliance were identified.
Ten LER's were submitted with the following causes:
Personnel error - 3 i
Installation error - 1 Inadequate procedure - 1 Other - 5 Overall, the fire protection program on Unit 3 has been acceptable.
Some personnel errors have resulted in inoperable equipment.
- Also, the licensee has experienced a recurring problem of spurious actuation of portions the system, resulting in wetting down of equipment.
The licensee, early in this period, had problems with transfer of alarm status information from the fire protection computer to the operators. This was due to the modeling of information transfer which removed previous alcrm conditions from k'
visual display upon receipt of a new alarm.
The licensee has provided a backup system by supplying a full time fire protection s_.
i
20
-k' '
person to monitor all alarms and another to respond'and assist in diagnosis. This system appears to'be effettive.
The licensee also has a large number of. breached fire barriers due to the large number of design changes on Unit 3.
Again, this necessitates a compensatory Fire watch staff.
Another area of weakness, which has been discussed in the Unit 2 Fire Protection Functional Area Analysis, is the need to verify compliance with all requirements in the Fire Hazards Analysis. This is an ongoing process and the effectiveness will be evaluated'during the next assessment period.
Overall the licensee's performance in this area is adegoa'te.
Conclusion Category 2 Boa'rd Reconnendation None 0.6 Emergency Preparedness Units 1, 2, and 3 The inspection effort during the period of this assessment consisted of a special inspection and observation of a full-scale exercise of the site-widg emergency plan.
The inspection confirmed that the licensee had satisfied the license conditions pertaining.to emergency preparedness.
Problems identified during the initial installation and operation of the health physics computer system appear to have been addressed in a timely mannet Obcervation of the full-scale exercise, preparation meetings and critiques of the exercise, the sum of which involves most aspects of the program, showed that emergency preparedness had been maintained on a level similar to the findings of the previous assessment period.
Upper level management, which was involved in the-full-scale exercise, appeats to have continued their interest and participation in assuring a more than acceptable state of emergency preparedness.
The home office and site personnel devoted to the emergency preparedness program constitutes an above average level of resources for this program.
Conclusion Category 1 Boa rd Recommendation None I
y y,.,,,
21 p.
c 0.7 Safeguards and Security A'
During the previous SALP evaluation period SONGS Unit-1 was assessed a Category 3 and Unit 2 was assessed a Category 2.
As a result, Unit I received a 200% increase in inspection effort.in the Safeguards and Security area.
Through this increased inspection effort it was determined that Unit 1 has sufficiently improved their overall performance to warrant an overall assessment of Category 2.
Unit 1 During this evaluation period Unit I was the subject of 303 man hours of inspection. No violations were identified.
The licensee continues to use a security alarm annunciator (computer) 'for vital.
area access which periodically fails. The licensee has properly compensated for each of the failures and has reported the incidents, as required, to the NRC Regional Office.
The licensee is using security personnel to control access through high traffic vital area doors ~to reduce dependence and activity on the system.
Specifications for a new alarm annunciation system have been prepared, however the licensee has delayed the purchase of'the new system pending the publication of the proposed access authorizati9n rule, 10 CFR 73.56.
Unit 2 During this evaluation per[od, Unit 2 was the subject of 188 man hours of inspection.
Six Level IV' violations ~were assigned primarily in the area of personnel access control requirements for entrance into,the protected area. These licensee failures occurred between September and November 1982 and were generally caused by ineffective management supervision.
During that period of time the licensee was reorganizing their security management structure in addition to coping with the requirement of implementing the new security program at Unit 3.
Since that period of time, continued inspe :tions of the eecurity program have not identified safety i
problems with the adequacy of management supervsion, nor identified continued security systems problems in the area of searching and access control.
15it 3 During this evaluation period, Unit 3 was the subject of 391 hours0.00453 days <br />0.109 hours <br />6.464947e-4 weeks <br />1.487755e-4 months <br /> of pre-operational inspection effort and 70 hours8.101852e-4 days <br />0.0194 hours <br />1.157407e-4 weeks <br />2.6635e-5 months <br /> of routine inspection effort. No violations were identified.
Although no violations were identified at this unit, it shares secarity systems and personnel with Unit 2.
The Unit 2 performance in this area has resulted in six Level IV violations being assigned primarily in the area of personnel access control.
Conclusion The current licensee's management organization is adequate to manage (s
the station's total security program.
No identified problems exist l
1 J
22 p
g.
with security personnel or hardware.
The licensee's overall performance in this area is. rated Category'2.
Board Recommendation None 0.8 Initial Fuel Loading Unit 3 During this period two resident inspections-(consisting of 45 inspection hours) were used to evaluate activities involving initial fuel load. -No items of noncompliance were identified.
One Licensee Event Report (LER) was submitted in this area.
During initial fuel loading the containment equipment hatch was not fully sealed. Four bolts holding the hatch. closed were not tight.
With the exception of the containment equipment hatch door not being fully sealed, this activity went very smootaly with no other major
- problems, o
Conclusion Category 1 Board Recommendation None 0.9 Licensing Activities Unit 1 The licensee's performance evaluation is based on a consideration of seven evaluation criteria given in the NRC Hanual Chapter.
For most of the licensing issues considered in this evaluation, only four of the evaluation criteria were of significance. Therefore, the composite rating.is based on the following evaluation criteria:
Management involvement Approach to resolution of technical issues Responsiveness to NRC initiatives Training i
With the exception of Enforcement History, for which there was no basis within NRR for evaluation,.the remaining evaluation ' criteria of l
i Reportable events Staffing
(
\\,,
were judged to apply only to a few licensing activities.
~
23
(
("-
- The evaluation was based on our evaluatio'n of.the following:
licensing activities:
3
. Responses to NUREG-0737 items Overpressure mitigation Radiological Effluent Technical' Specifications and Offsite Dose Calculational Manual Pressurized thermal shock Steam generator inspection t
Systematic evaluation program - seismic evaluation I
Systematic evaluation program (SEP) all other, topics.
Operator licensing-Appendix R i
o Management Involvement in Assuring Quality i
t The.overall rating for this evaluation criterion is Category 2.
- The performance. rating for individual licensing actions falls i
into Category.1 or 2, with the-majority being Category 2.
i There is evidence of planning and. assignment of priorities.and i
decision making seems to be.at a level that ensu':es management L
review. Areas where it was judged that man =cetant involvement was particularly evident were fire protec', ion - Appen.iix R, overpressure mitigation, and steam generator inspection report.
l 1
Approach to Resolution of Technical Issues From a Safety l
Standpoint i
The overall rating for this evaluation' criterion is Category 2.
1
~
The perf,ormance rating for individual licensing actions falls into Category 1 or 2, with the majority being Category 2.
The licensee's masonry wall test program (part-of the SEP seismic reevaluation) is a viable approach to demonstrating the i
conservatics of analytic methodology. SCE has prasented generally sound and thorough approaches in resolving technical issues.
i Responsivensss to NRC Initiatives The overall rating for this evaluation criterion is Category 2.
' Performance ratings for the individual licensing actions varied from Category 2 to Category 3 with the majority of ratings-i being Category 2.
The licensee was judged to have provided generally timely responses in most cases.
On the other hand, the final submittal of the Radiological Effluent Technical Specifications, the SEP topic assessment on pipe break inside containment, and NUREG-0737 technical specifications and schedules for e.astgency response capability have all been significantly delayed.
Enforcement History
(
There is no important basis for an NTR evaluation of this criterion.
i N-.
9 I
.,..,.m r-.
.r---
., - ~. - -
24-
{'
Reportable Events.
There was no basis for'NRR evaluation of this criterion for the s
licensing actions considered.
Staffing Only one topic was evaluated with regard to-staffing..This o evaluation (Category 2 rating? was judged to be too limited a,ne sample to provide an overall rating.
Training A Category I rating was assigned to this criterion / 'This evaluation. criterion was evaluated based on the results of the operator licensing examinations and an audit of the operator training for pressurized thermal shock. Two examinations of operator candidates were completed during the assessment period.
The first set of exams was given in September 1982.
The result of this exam was that 4 of 5 SR0s and 6 of 6 Ros passed for a passing rate of 8^%=and 100%, respectively. The second set of exams was'given in' January 1983. Four of five Ros passed the exam; in addition one SRO and one RO passed i
their oral retake. The combined passing rate for the second set was about 86%.
Based on these passing rates it was judged that the training provided by the licensee for these candidates was appropriately defined and implemented.
Conclusion Based on the evaluation of the above seven criteria with regard to Southern California Edison's performance in the functional area -
Licensing Activities - for San Onofre Unit No.
1, an overall performance rating of Category 2 is determined.
Board Recommendations None i
Units 2 and 3 l
l The licensee's performance evaluation is based on consideration of seven attributes given in the NRC Manual Chapter. For most of the licensing actions considered in this evaluation, only three or four of the attributes were of significance.
Therefore, the composite j
rating is heavtly based on the following attributes.
Management invo lvemen t- ---
Approach to resolution of technical issues Responsiveness The remaining attributes of (L
a v
-e.-
,.,_,,,..,..-m-%,
,___~..-v
,..,._m
.I
.c e
_ Enforcement history Reportable events Staffing
~
Training were judged to apply to only a few licensing activitit..
i i
The conclusions reached are' based on our evaluation of the following licensing activities:
Startup Test Program i
Natural Circulation Testing Post Accident Sampling System-Control Room Pressurization e
Instrumentation and Control Turbine Overspaed Protection AFW System Core Protection Calculator t
Reactor Trip Breakers i
Technical Specifications
-i Management involvement in Assuring Quality
+
l Overall rating for this attribute is. Category 2.
There is
{
I evidence that plannin; and assignment.of priorities and decision making seems to be at a level that ensures management j
i review. Typical areas where management involvement was' evident l
are the startup test program and instrumentation and control systems. Management involvement was excellent in the reactor 5
trip bre,aker effort but was below average in the-areas of
{
turbine overspeed protection, core protection e.alculator, and technical specifications.
A discussion of these areas is given below:
f Turbine Overspeed Protection System f
a.
During the staff review of a licensee request for a I
temporary waiver of technical specifications with regard to low pressure turbine valve testing, the staff asked I
i' specific questions about any prior history of high or low pressure turbine valve malfunctions. The licenree's licensing personnel indicated there was none, and the l
staff granted the temporary waiver on the basis' that no significant safety concern was involved.
Subsequently, it was determined that there was indeed a history of high pressure valve malfuncticas which, if they reoccurred, ccuid have created a safety concern.
There is aothiog to indicate, and the staff does not believe, that the licensee deliberately supplied erroneous l
r.f o rma t io n.
Hraever,. it appears that the licensee's system of record keeping, and the communication between plant operating and licensing personnel should be improved.
w.
i i
4 9
26
(
b.
Core Protection Calculator
(.
While preparing for a staff audit during startup testing in December 1982, licensee personnel discovered a non-conservative error in the values of the power multiplier addressable ;onsultants used to define instrument uncertainties.
The correct value was transmitted to the licensee from CE by a letter dated August 20, 1981.
The letter was said to be lost and the modification was not implemented.
The licensee and NSSS. supplier committed to review.their software change procedures and their QA program.and to report on actions to prevent a repeat of
- this type of error.
We hase, as yet, received no report of corrective actions from the licensee.
- e c.
Technical Specifications Experience suggests that the licensee management does not usually anticipate technical specification problems in advance of needed dates.
This frequently requires. changes to be processed on an urgent or emergency basis.
Approach to Resoluticn of Technical Issues from a Safety 4
Standpoint The overall rating for this attribute is category 2.
The only
(
area needing improvement is Technical Specifications in which the staff concluded that the licensee has frequently N-demonstrated a lack of understanding for technical s, cific,ation issues as evidenced by several phone calls requesting technical specification informatica and by an application to suspend Technical Specification 3.0.4 until the beginning of commercial operation.
The licensee had previous y been advised that such a request would be unacceptable.
1 Responsiver.ess The overall rating for this attribute is category 2, with several areas rating category 1.
The only area rated as category 3 is Technical Specifications, based on the staff observation t'aat the licensee frequently does not anticipate technical specification problems in advance of needed revision dates.
Enforcement History In this attribute.
there were two category 1s, two category 2s and one category 3.
Half of the licensing, areas were judged to be N/A. The category 3 area was the post accident sampling system, in which a civil penalty was imposed for not making'the system operable by January 1, 1983, as required by the operating license.
(
e e
--y.ww,-,.
-1,w.---,,
yr.,-,,
y
-.<e.
,,p.p-,-w_,-
.,w-mm-
.e,
.-t e.
p,,+-
-e.
2T
(
if Reportable Events The overall rating for this category is 2.
Most licensing areas were N/A. The trip breaker area was rated category 3 because of a lack of reporting of trip breaker surveillance failures that occurred in July 1982.
Staffing Three licensing areas were evaluated for this attribute; the rest were N/A. Comments about staffing are as follows:
Post Accident Sampling System a.
This area was judged category 3 because' trained people are not available to operate.the system at all times.
n Furthermore, there is doubt that appropriately trained people will be so available in the near future.
s b.
Technical Specifications This area was rated category 3.
Staffing appears to be weak as indicated by failure to submit change requests on a timely basis. This failure may be the result of insufficient staf fing and/or organizational inadequacies.
Training This area was given two category 2 ratings and two category 3 ratings., Most areas were N/A.
Comments in the category 3 areas are as follows:
Post Accident Sampling - same comment as above under a.
Staffing b.
Technical Specifi:stions - licensee staff does not appear to have a thorough knowledge of the technical specifications and the bases for them.
Conclusion Based on the evaluation of seven attributes of the licensee's performance for a number of significant activities in the functional area of licensing, an overall performance rating of category 2 is 1
determined.
Management attention is needed in the area of Technical Specifications, as this area was rated category 3 in all attributes evaluated.
In addition, we r.ote that several attributes in this area were given a category 3 rating in last year's SALP evaluation.
Board Recommendation None
<L
.2g t
C.
Construction-C.
Unit 1 C.1 Facility Modifications The inspectors examined the overall programmatic aspects of the construction effort including the organizations, personnel, and procedures involved in the Unit 1~ seismic. upgrading.
Concern's identified by the NRC inspectors were quickly. addressed and resolved by the licensee.
A total.of 55 inspection hours were utilized in this functional ~ area and no items of noncompliance or deviations were identified during the assessment. period.
4 C.2 Piping Systems and Supports A total.of 63-inspection hours were utiliued in this functional 1
s Twenty-four of these hours were related to an KRC area.
reactive effort to invest 1 gate allegations at Unit I concerning welding deficiencies and the proper implementation of welding codes and standards. The remainder of the inspection effort related to the verification of licensee action on previously identified inspector concerns. No items of noncompliance or deviations were identified during the-assessment period.
NRC concerns were quickly addressed and resolved by the licensee.
Unit 2 One hundred and nine inspection hours were utilized to inspect allegations e,oncerning deficiencies and the proper implementation of welding codes and standards. No items of noncompliance were identified.
Unit 3 Four construction inspections were performed during the SALP reporting period.
In the performance of these inspections, 258 1
inspection hours were utilized.
The four functional areas examined during this period are detailed below:
i i
C.1 Piping Systems and Supports A total of 171 inspection hours were utilized in this functional area, with no items of noncompliance being identified.
All safety related piping activities and pipe supports examined were found to meet the applicable requirements.
One hundred and nine of these hours were related to an NRC reactive effort to investigate allegations at Un4.t 3 concerning welding deficiencies and the proper implementation of welding codes and standards.
(
L
20
(
(-
C.2 Electrical Power Supply and Distribution A total of 36 inspection hours were utilized in this functional No items of noncompliance were identified.
area.
C3 50.55(e) Items and Bulletins A total of 43 inspection hours were utilized in this functional Licensee responses to bulletins, 50.55(e) items, items area.
of noncompliance and other inspector findings were found to be timely and satisfactory.
No items of noncompliance were identified during this assessment period. The licensee's approach to resolution of technical issues from a safety standpoint was acceptable.
e C.4 Design A total of eight hours were utilized in this functional area.
No items of noncompliance or deviations were identified.
Conclusion Category 1 Board Recommendation None i
i
[
_ _ ~ - -. -. ~ _. ~.
b 30 Tab M pection Summary - Units 1, 2 and 3 UNIT I Unit 2-Unit. 3 No. of No. of No. of Inspection Activities Inspections flanhours Inspections flanhours Inspections Pfanhours a.
Regional Inspection 1.
Routine Operations Inspection 5
173 13 322 12 405 2.
Reactive Operations Inspection 0
0 2
154 1
62 3.
Routine Construction Inspe icn 3
94 0
0 3
149 O
4 Reactive Construction Inspection 1
24 1
109 1
109 i
b.
Resident Inspection (t!ostly Operations)
I1 495 20 1440 21 923 c.
Ilealth Physics l.
Routine Inspection 3
210 5
171 2
86 2.
0 0
0 0
0 j
3 IIcalth Physics Appraisal 0
0
- 0 0
0 0
t d.
Environmental i
- l; 1.
Routine 1
12
." 1 10 1
10
'd 2.
LER Follow-up 0
0 0
0 0
0 i l Security and Safeguards
.e.
a 1.
Routine 5
313 4
188 4
461 4
2.
Reactive 0
0 2
70 0
0 f.
Routine 1
20 1
20 1
20' j
2.
Reactive 0
0 0
0 0
0 4
j 3.
Emergency Preparedness Appraisal 0
0 0
0.
O' 0
4 l
g.
Ttti Action Items 0
0
-2 120 0'
O j
,O
.,O
[
31 Tab NATURE AND nut!BER OF VIOI.ATIONS - Units 1, 2 and 3 l-UNIT I UNIT 2 UNIT 3
)
FUNCTIONAL INSP.
VIOI.ATIONS INSP.
VIOI.ATIONS INSP.
VIO!ATION l
AREA flANilRS V IV Ill 11 I
flANilRS V IV 111 If I flANilRS V-IV III II i
1.
Plant Op_erations 299 2
919 3
9 1
761
~ 1 1
l 2.
Radiological Controls a.
Radiation Protection 87 1
67 1
2 22 2
is. Radioactive Waste O
2 l
tlanagement 77 64 1
37-c.
Transportation 0
0 0
d.
Effluent Control l
and tionitoring 46 1
40 1
1 27 1
3.
fla in tenance 150 3'69 2
151 t
4.
Surveillance - Includes i
Inservice and
~
Preoperational Testing 150 592 1
2 368 I
5.
Fire Protection 66 2
1 116
- 2 75 1
6.
Emergency Preparedness 20 20 20 t
i 7.
Security and Safeguards 313 188
-6 461 D-8.
Refueling - includes Initial Fuel I,oading 0
0 45' i
9.
Quality Assurance -
3 Program and Implementation 15 0
0
- 10. 'I?!I Action Items (PASS) 0 120 2
0
- 11. Construction 118 109 258 s-D = Deviation
~~
1 g
f 32 TABLE 3 ITEMS OF NONCOMPLIANCE UNIT 1 NRC. INSPECTION SEVERITY PESCRIPTION REPORT NO.
LEVEL 82-21 IV Fire-protection procedures and license.
condition 3.H not properly. implemented -
combustible material stored in safety..
related areas, emergency lighting not being-
. serviced properly.
82-23 V
No approved procedure for reactor coolant
~
sampling method used in cold shutdown.
82-26 V
Nuclea r Audit Review. Committee omitted the.
review of some design changes.
82-32 V
Open flame work' performed without fire ~.
watch required by procedure..
82-32 V
Continuous fire watch required by technical specification, in lieu of fire-protection system,'was.not on duty.
82-33 V
Failure to post notices, 10 CFR 19.11(b).
(Breakdown in management controls).
82-36 IV Failure to calibrate effluent monitors as
~
required 'by Technical Specification 4.6.E.
. l l
/(
a s.
m
,'4
'33 TABLE 4 ITEMS OF NONCOMPLIANCE ^ '
UNIT 2 NRC INSPECTION SEVERITY DESCRIPTION REPORT NO.
LEVEL 82-22 IV Failure to maintain adequate housekeeping (failure of management to establish and implement adequate housekeeping program).
82-25 IV Operator failure to follow procedure which subsequently resulted in-damage to-the auxiliary feedwater system 2" er'oss connect piping during' followup testing. (repeat 82-15) 82-29 IV Failure to report major loss of security effectiveness as required by 10 CFR 73.7:(c).
82-29 IV Failure to provide positive access control at a vital area portal, 82-30 V
Failure to implement operator overtime requirements (managemeet failure to effect adequate corrective actt'n - see 82-15 Level IV).
82-33
.V Failure to post notices, 10 CFR 19.11(b).
(Breakdown in management controls).
82-35 IV Investigative screening of employees for unescorted access accomplished after employee had received access.
82-37 IV Failure to search all personnel prior to protected area access.
82-37 IV Failure to' search personnel in conformance with approved security plan.
82-37 IV Failure to provide positive access control at a vital area portal, i
4 82-38 y
Failure to perform quarterly surveillance I
on safety related batteries as required by technical specifications (management failure to provide adequate procedure).
82-39 IV Failure to implement operator overtime requirements-repeat, see 82-30, above.
(management failure to take adequate 4
L corr-etive action) aos
34
{~
82-41 IV Failure to report'an unusual event within one hour as required by 10 CFR 50.72 (management error).
82-43 V
Failure to properly label a container of radioactive material as required by 10 CFR 20.203f (Technician error).
83-02 IV-Failure to maintain adequate housekeeping-repeat, see 82-22 Level IV (Management failure to provide adequate authority and training) 83-04 V
Failure to report -results of len'd use census (Failure of first line supervision).
83-06 III Failure to commence. plant shutdown within one hour as required upon the loss of an effective containment overpressure protective system while at 50% power (management / operator. error).
83-06 IV Failure to perferm a 50.59 review i
associated with a. test loop in the suction of safety related high pressure safety injection pumps (management failure to provide adequate procedure).
83-06 IV Failure to control a temporary modification consisting of 20 feet of temporary piping in suction to safety related HPSI pump in accordance with j
procedures (repeat 82-12 previous SALP)
(management failure '.o provide adequate procedure).
83-06 IV Failure to perform independent verification of the alignment of equipment returned to service (management / operator error).
83-06 IV Failure to perform prompt corrective action in the case of a defective interlock for safety related HPSI pumps (management failure to provide adequate guidance).
83-06 V
Failure to approve a temporary change to a procedure in 14 days (personnel error).
L l
i i
\\ %
i
I,.
35
{
~
83-08 III Failure to comply with Post Accident Sampling System / Program _- License Condition 2.C.19.1 (Lack of management control).
83-08 III Failure to report PASS program.not implemented, License Condition 2.G.
(management error).
83-13 IV Failure to report the occurrence of reactior trip breaker failure to trip properly on undervoltage trip actuation (management failure to provide adequate controls).
83-13 IV Failure to include vendor recordendation in the preventive maintenance program _for the reactor trip breakers (management failure
'to provide adequate program).
83-14 IV Liquid effluent monitor bypassed, T.S.
3.3.3.8.
(Breakdown in management controls).
83-14 IV Failure to perform radiation survey, 10 g
CFR 20.201.
(Multiple personnel errors).
83-14 IV Failure to inform workers, 10 CFR 19.12.
(Personnel error).
83-15 item (1)
IV Failure to provide correct valve lineup
(
procedures for safety related systems (e.g.
auxiliary feedwater, fire protection)
(management failure to provide adequate procedures).
83-15.i em (2)
IV Failure to comply with~ safety related t
component cooling water system valve lineup procedure (management failure to provide adequate review).
83-15 IV Failure to provide electrical supervision of certain fire protection valves as i
required by fire hazards analysis j
(management failure to provide adequate commitment verification).
)
t 83-15 V
Failure to maintain sufficient records to furnish evidence of activities affecting quality (operator error / management inattentiveness).
a s_
s.
36 83-19 IV Failure to provide adequate emergency
('.
as required by license conditions lignting to plant' safe shutdown plant areas (management failure to provide adequate condition verification).
4 e
e em 4
g..
37 e'
(
TABLE 5
(
ITEMS OF 5JNCOMPLIANCE
\\
UNIT 3 NRC INSPECTION SEVERITY DESCRIPTION REPORT NO.
LEVEL 82-22 Deviation Failure to implement procedure changes in nuclear material control and accounting procedures previously committed to a NRC inspector (Failure of management followup system).
83-14 IV Liquid effluent monitor bypassed, T.S.
3.3.3.8.
(Breakdown in management controls).
83-14 IV Failure to perform a radiation survey, 10 CFR 20.201.
(Multiple personnel errors).
83-14 IV Failure to inform workers, 10 CFR 19.12.
(Personnel errors).
83-15 IV See Unit 2 noncompliance listing inspection report S3-15 item (1).
83-15 IV See Unit 2 noncompliance listing inspection report 83-15 item (2).
83-15
'V See Unit 2 noncompliance listing inspection report 83-15.
(
s,s
~J
s...
38
~
SUPPORTING DATA AND' SUMMARIES 1.
Licensee Event Reports Analysis Tabular Listing Type of Events:
Unit 2 Unit 3 Common
- Total A.
Personnel Error 40 19 (5) 59 B.
Design / Man./Const./ Install.
67 8
(4) 75 C.
External Cause 0
1 0'
1 D.
Defective' Procedure 27 5
(6) 32 E.
Component Failure 65 11
- (6).
76 F.
Other 4
5 0_
9 Total 203 49 (21) 252
- Unit ? LERs that apply to Unit 3.
Licensee Event Reports Reviewed:
Unit 2:
LERs 82-27 through 82-176 and 83-01 through 83-58 e
Unit 3:
LERs 82-01 through 82-11 and 83-01 through 83-38 i
r' Causal Analysis (Unit 2)*
l
\\s Sixteen sets of common mode events were identified:
LERs 82-52, 8'2-54, S2-55, 82-56, 82-58, 82-63, 82-70, 82-77,82-134, a.82-140, and 83-023 identified events in which surveillance testing i
found safety related instrument setpoints out of specification due to setpoint drift (LERs 82-52, 82-54, 82-55, 82-58, and 83-23 involved instrument drif t of the toxic gas isolation system ammonia analyzer channel B).
i b.
LERs 83-15 and 83-46 involved failure of the reactor control operator to maintain Tc above the technical specification limit of d
544*F.
LERs82-145 and 83-156 involved fcilure of the reactor control c.
operator to perform the reactor coolant system water inventory within the time interval required by the technical specifications, 7
j 1
d.
LERs82-153, 82-154,82-162 and 82-169 involved failure of the low pressure turbine stop valves to close fully due to galling between the disc stub and casing bore, caused by lack of adequate design clearances, LERs 82-84, 82-85, 82-86, 82-88, 82-91, 82-92,82-128, 82-139, and e.
3 83-148 involved the slipping and dropping of Control Element Assemblies (CEA) caused by the slow operation of the CEA grippers, i
z
~ ~.
39.
{
f.'
LERs'82-168 and 82-171 involved events in which the reactor was tripped on:a high LPD/ low DN3R signal. due to reed switch failures in-the Control Element Assembly Calculator System.
g.
LERs 82-46,82-122, 83-33, and 83-48 identified events in which both trains "A" and "B" of the butane / propane monitors of'the toxic' gas isolation system were inoperable due to low hydrogen gas supply
- pressure, h.
LERs82-175, 82-176, 83-19 and 83-25 identified events in which the Reactor Trip Breakers (RTB) undervoltage trip relay failed to' trip the RTB due.to inadequate lubrication and an excessive maintenance s
j interval.
7 i.
LERs 82-27 and 82-32 identified events in the auxiliary feedwater piping in which unstable reverse flow through kerotest. valves caused vibration, resulting in fatigue failure of the veld between a vent valve and the piping, producing an-unisolatable one-inch diameter leakage path on pump P_-141.
j.
LERs 82-28, 82-29, 82-30, 82-42,'82-47, 82-66, 82-67,82-146, 82-149 describe events in which an auxiliary feedwater system train was' made inoperable due to valve failures associated with the r
maintenance of the valve operator (1) actuators, (2) limit switches, and (3) position indicators.
k.
LERs 82-69, 82-94,82-103, 82-126,82-133, 83-04, 83-07, 83-22, 83-38 describe events in which valve limit switch failures on valve operators caused containment _ isolation valves and'other valves in engineered safety feature systems to be inoperable ("j" above identifies similar problems with valve operator limit switches).
^
1.
LERs 82-59 and 82-60 involved the faulty flow control switch for the train "B" Control Room Emergency Air Cleanup System's (CREACUS) emergency water chiller.
LERs 82-40 and 82-65 involved inoperability.of the CPIACUS due to a m.
compressor faulty high temperature bearing alarm module, LERs 82-99, 83-24 and 83-42 involved inoperability of the CREACUS n.
~
due.to inadequate valve and electrical lineup checklists, which I
would render CREACUS inoperable.
4 LERs 83-20, 83-27, and 83-32 involved inoperability of the CREACUS o.
due to the inoperability of door C3-67 between the Control Room and the Cable Risers Gallery Room.
t 1
LERs 82-44/L, 82-49/L, 82-50/L, 82-51/L, 82-53/L, 82-57/L, 82-68/L, p.
j 82-71/L, 82-74/L, 82-79/L, 82-82/L, 82-83/L, 82-89/L, 82-95/L, 3
1 82-97/L, 82-102/L, 82-104/L, 82-106/L,'82-107/P, 82-108/L, 82-109/L, 82-110/L, 82-111/L, 82-112/L, 82-116/L, 82-117/L, 82-119/P, 82-121/P, 82-123/P, 82-124/L, 82-129/L, 82-130/L, 82-141/P, 4
i,
(
82-147/P, 82-161/P, 83-01/P, 83-02/P, and 83-16/P involved the
}
inoperability of the Condensate Storage Tanks T-120 and T-121 due to s
d i
-,c_
m.
-.__-L,__-c_
,-3r -
r
_l
' ','L.1 40
-{,
- {
A failure to' maintain the tank level above the required technicali specification limit.
All events are' causally linked unless noted by "P", which are.
personnel error.
Causal Analysis (Unit 3)
Three sets of common mode events were identified:
~
LERs 83-30,~83-32, S3-33, and 83-35 identified events in which fire a.
protdction spray systems were spuriously. activated, leaving the-actuation fire detector inoperable until it was reset.
b.
LERs 83-04 and 83-11 involved-the inoperability of Loop 1 hot leg temperature indication of the Essential Plant Monitoring Systen..
The -failure to properly repair the improper cable 1 termination, following the initial identification of the inoperable indicator, was a causative factor in the occurrence of the second event.-
LERs 83-01 and 83-06 involved inoperability of Emergency Chiller c.
E-335, associated with Control Room Emergency Air Cleanup System Train "B", due to a failed Resistanca Temperature Detector (RTD) in the motor winding high temperature ti.t circuit.
f 3
f f
N f
~
i 2
4 4
f
'l
}
k p
I
)
- s _
s i
I r
4
l i,,,
..c
[
'g UNITED STATES s
y NUCLEAR REGULATORY COMMISSION
.j REGION V l
g, WALNUT CRE E K, CALIFORNIA 94596
,4 1450 MARIA LANE SUITE 210 Docket No. 50-344 f {@ 11]986 Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Attention:
Mr. Bart D. Withers Vice President Nuclear
. Gentlemen:
Subject:
Enforcement Conference and Review of 1985 Systematic Assessment of Licensee Performance (SALP) Report This refers to the enforcement conference and the meeting to review the 1985 SALP for the Trojan Nuclear Plant held with Mr. W. J. Lindblad and members of your staff at your offices in Portland, Oregon on January 22, 1986.
Subjects discussed.during the meeting are described in the enclosed inspection report provided for your information.
Overall, your performance of licensed activities showed improvement over the previous SALP period. However, as discussed at our meeting, the SALP Board j(
identified problem areas in need of management attention. While it appears that the changes you have set in motion are promising, the next year is a k
very critical period to ensure the succets of these changes. Therefore, it is important that continued management attention be given to assure that emphasis is maintained on these programs. We encourage you to continue to look for opportunities for improvement.
No response to this letter is required.
If you have any questions concerning this report, please feel free to contact this office, i
In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosures will be placed in the NAC Public Document Room.
Your continued cooperation is appreciated.
Sine ly,
$h $$
John P. Martin Regional Administrator
Enclosure:
NRV RV Meeting Report No. 50-344/86-004 cc w/ enclosure:
W. S. Orser PGE J.W. Durham, Esq., PgE W. Dixon, DOE
/
~
en
.o f
U. S. NUCLEAR REGULATORY COMMISSION
, REGION V Report No. 50-344/86-04 Docket No. 50-344 License No. NPF-1 Licensee: Portland General Electric Company 121 S. W. Salmon Street Portland, Oregon 97204 Facility Name: Trojin Nuclear Plant Inspection at: Portland General Electric Company Headquarters, Portland, Oregon d
4 Report Prepared By:
ay/
teh,
Date Signed D. B. Per a, R ctor Incractor Approved By:
[
[
R. T. Dodds, Chief Dat( Signed Reactor Projects Section 1
(
Meeting Summary:
lk Meeting on January 22, 1986 (Meeting Report No. 50-344/86-04)
Scope: Enforcement Conference and special management meeting to discuss the violations identified in inspection report no. 50-344/85-33 and to discuss the results of the NRC assessment of the licensee's performance from November 1, 1984 through October 31, 1985, as part of the NRC's Systema *.ie Assessment of Licensee Performance (SALP) program. Specific areas addressed included:
Plant Operations, Quality Assurance, Maintenance, Surveillance, Engineering and Construction, Licensing Activities and Training.
Results:
A summary of the NRC licensee perfomance assessment was presented and two violations of NRC requirements were discussed.
L
?
~-
?Y
( j,-., p
['
e""Y scw
1 DETAILS 1.
Meeting Attendees a.
Principal Licensee Attendees W. J. Lindblad, President B. D. Withers, Vice President Nuclear W. S. Orser, Trojan Plant General Manager C. 2. Yundt, General Manager, Technical Functions A. Olmstead, Quality Assurance Manager R. L. Steele, Manager, Nuclear Plant Engineering G. A. Zimmerman, Manager, Nuclear Regulation Branch R. P. Schmitt, Manager, Trojan Operations and Maintenance D. R. Keuter, Manager, Technical Services J. W. Lentsch, Manager, Nuclear Safety and Regulation S. E. Hoag, Manager, Trojan Programs C. Brown, Manager, Quality Assurance Operations Branch M. C. Street, General Manager, Security D. W. Swan, Supervisor, Maintenance b.
NRC Attendees J. B. Martin, Regional Administrator A. Johnson, Enforcement Officer A. E. Chaffee, Chief, Reactor Projects Branch R. T. Dodds, Chief, Reactor Projects Sectica 1 S. A. Varga, Project Director, PAD #3, NRR K. E. Johnston, Project Manager, NRR S. A. Richards, Senior Resident Inspector D. B. Pereira, Project Inspector G. Kellund, Resident Inspector c.
Oregon Department of Energy M. W. Alsworth, Manager, Reactor Safety 2.
Results of SALP The NRC SALP Board conclusions and recommendations were discussed.
The licensee representatives discussed their perception of the SALP report and described actions planned to address specific items in the report.
The discussion centered around the licensee's ability to utilize available resources to critically assess events and deficiencies in the operation of their facility and then to followup their assessment with thorough corrective action.
.e following functional areas of identified concerns were discussed:
a.
Quality Assurance / Quality Control
1)
A positive trend is contributed by the new Quality Assurance (QA) manager, and QA's increased involvement in review of_ plant operational problems.
2)
Two disappointing examples were identified during the recent regional team inspection, namely (1) the implementation of quality control activities st Trojan during maintenance activities were essentially non-existent and (2) weaknesses also exist in the administrative control of temporary modific'ations.
3)
Efforts to increase the effectiveness of the QA organization should be continued as a high priority item.
The licensee's QA manager responded that implementation of quality control activities during maintenance are being increased and QA effectiveness is regarded as a high management priority item.
b.
Training 1)
A concern was expressed that the training staff was small and there being no simulator for the operators to train on.
Management was encouraged to maintain an increased support of the retraining and replacement training program.
2)
A positive contribution was the above average passing rate based on Region V data for reactor operators and senior reactor operators written exams.
3)
Six shift operation enabled the licensee to institute an expanded training program for the reactor and senior reactor operators.
4)
The licensed and non-licensed operator programs were accredited by INPO in December, 1985.
The licensee's time frame for INPO accreditation for shift technical advisor programs and for the maintenance and technician programs is December, 1986.
c.
Maintenance 1)
The lack of formal Quality Control involvement in maintenance activities was discussed as discovered during the recent team inspection.
2)
A positive improvement was noted in the updating of vendor manuals and drawings.
The licensee committed that safety-related vendor drawings would be updated by the end of 1986 and the vendor manuals by July, 1987. As indicated above, there has been a substantial increase in Quality Control involvement for maintenance activities.
This will be addressed in the licensee's response to the two violations described 3
N,_
during the enforcement conference.
3 4
d.
Surveillance 1)
Inservice testing (IST) and Inservice Inspection (ISI) programs indicated weaknesses in both areas.
Management involvement was encouraged in the administration of both the IST and ISI programs.
2)
The SALP Board noted that, while there were no plant trips directly related to errors made during the performance of surveillance, three of the four safety injections could be attributed to surveillance activities.
The licensee committed to review the scheduling and conducting of surveillance activities in reducing challenges to safety systems.
e.
Operations 1)
The Board recognizes that significant actions have been implemented in this area to improve performance. The "Ready for Startup" program was implemented and appeared to provide added assurance that plant recovery from refueling outages did proceed in a controlled, formal manner.
2)
The need for independent verification of safety-related systems following maintenance and surveillance activities was discussed. The licensee was encouraged to consider the adequacy of their program.
3)
The Board indicated that eight of the cumulative total of fif teen plant safety injections have occurred during the past 24 months.
The licensee committed to reviewing their independent verification program of safety-related systems.
f.
Engineering and Construction 1)
The Board reviewed the concern with the reliability of the auxiliary feedwater (AFW) system.
Bechtel had been tasked with evaluating the AFW system and making recommendations for improvement.
2)
The licensee should strive to encourage the successful implementation of the systems engineer program.
The Bechtel evaluation of the AFV system has been completed and the licensee will be implementing appropriate recommendations in accordance with the schedule as stated in the correspondence to the NRC dated November 25, 1985.
The licensee's systems engineer program would continue to be implemented and strong technical reviews would be reinforced with all nuclear division departments-,
i m
4 a
1 i
f!
g.
Licensing Activities 1)
The Board recommended that all licensing submittals have an L
adequate level of management involvement and control in assuring quality.
It was considered in some cases that the licensee would take issue without adequate analysis.or little l
thought put into the analysis.
It was recommended that the licensee telephone prior to submittal of licensing submittals for a clarification on any issue or aspect of the submittal.
2)
It was felt that the licensee had good plant housekeeping practices and had satisfactory behavior of personnel in the control room.
3)
It wa's recommended that the licensee place additional emphasis on the quality of the "significant hazards consideration" discussion in licensee change applications.
The licensee agreed to evaluate the content of future submittals for completeness and accuracy.
3.
Enforcement Conference k
A copy of inspection report no. 50-344/85-33 was sent to the licensee on Janua ry 17, 1986.
The report identified two violations of regulatory requirements involving the lack of certain quality control inspections and failure to install safety related components in accordance with approved drawings. The licensee indicated that the report had been t
received and acknowledged the facts and circumstances that allegedly constituted the violations 'of the described regulatory requirements.
The licensee representatives described recent reorganizational changes, and other corrective actions initiated to ensure compliance with the cited regulatory tequirements.
Mr. Martin indicted that the licensee's comments would be considered during h*RC's determination of enforcement action to be taken with regard to the violatious, y
l 4
I i
p L
id ;&. AA
[,mg W@
V4 8 h.,,, g o
UNITED STATES
~ - - -
~
NUCLEAR REGULATORY COMMISSION
-[-
f 1990 N. CALIFORNIA BOULEVARD c
REGION'V "o
g * %.',/
SulTE 202, WALNUT CREE K PLAZ A lk WALNUT CREEK CALIFORNIA 94596 AUG?
' 1" '
Oceket tio. 50-397 Uashinoton Public Power Supoly System P. O. Box 963 Ri;;hland, '.lashington 99352 Attention: Mr. R. L. Ferguson Managing Director Gentlemen :
Subject:
ilRC Regional Evaluation of Licensee Performance Washington iluclear Project No. 2 This refers to the meeting held at the NRC Region V Office in Walnut Creek, California on August 12, 1980, between Hr. R. H. Engelken and members of the Region V staff with fir. R. L. Ferguson and other Wshington Public Power Supply System senior mnagement personnel.
The purpose of this meeting was to discuss the results of NRC's regional evaluation of licensee performance regarding
[.
activities authorized by liRC Construction Permit fic. CPPR-93. A sumary report
(
of the reeting and supporting data are enclosed.
Items discussed curing the meeting included a summary of the findings and evaluation of the i;RC regional review board regarding compliance with NRC requirements at the Washington fluclear Project No. 2 during the period April 1979 through Acril 1980, specific areas of concarn and ratters requiring corrective actions by UPPSS and a sumary of the findings and evaluation of an investigation into the activities of your 215 contractor (W3G). The areas of concern and required corrective actions are delineated in the NRC Office of Inspection and Enforcement Director's letter to you of June 17. 1980.
In accordance with Section 2.790 of the HRC's "Rules of Practice", Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the Nuclear Regulatory Ccmmission's Dc:un nt Room.
L.
b g' g w w.
D' 4
~
AUG 2 21980 Mr. R. t.. Ferguson
- P.
l((-
Should you have any questicns concerning the encloseo na. ion and supportino data, we will be glad to discuss them with you.
~
Sincerely, n/G T L A L.
R. 'H. Engelken Director
Enclosure:
IE Inspection Report ?!o. 50-397/80-11 cc w/ enclosures:
Senator T. Bottiger, Washington State Senate Senator S. Gould, Washington State Senate f!. D. Lewis, EFSEC, Washington State cc w/o enclosures:
D. L. Renberger, WPPSS F. D. McElwee, WPPSS W. C. Bibb, WPPSS M. E. Witherspoon, WPPSS W
W er 4-en e e e 6
,e--
.w e
---n-e-,
a p
...~..-.,n.-
. ~
U. S. IlVCLEAR REGULATORY C0KilSSION 0FFICE OF INSPECTION AND ENFORCE!!EllT k
REGION V Report No. 50-397/80-11 Docket No. 50-397 License No. CPPR 03 Licensee: Washington Public Power Supply System P. O. Box 958 Richland, Washington 99352 Facility Name. Washington iluclear Project Unit 2 (WNP-2)
Meeting at: NRC Region V, San Francisco Meeting conducted: August 12, 1980 Report Sy,:
T/4/[8C
- p.,. 3. Toth3 Resioent Inspector Wi4P-2 Date Signeo
'I E
t'[W[R' Acproved By:
P R. n. dngelken, Director Date Signed Su. ary:
T Ma.lacerent 'feeting Auaust 12, 1930 (Recort No. 50-397/80-11)
This was a special corporate management meeting -to present to R. L. Ferguson, newly appointed fianaging Director of the Supply System effective August 1,1980, the results of flRC Region V evaluation of licensee performance for the period of Acril 1979 through July 1980.
This review enecmpassed data presented in a similar meeting of f4ay 20,1980 and included review of subsequent inspection and investigation findings.
Specific areas of NRC concern wrre discussed, as well as planned flRC actions regarding WPPSS restart of work which had been subject of flRC immediate action letters.
1 l
1 "l*
f
( h ovvi I d fl.
- --, 1
~
~
)
DETAILS
(
l.
Meetina Attendees Washinoton Public Power Sucolv System R. L. Ferguson, Managing Director D. L. Renberger, Assistant Director, Technology
- F. D. McElwee, Assistant Director, Projects M. N. Hultaren, Manager of Projects W. C. Bibb, Project Manager
'lNP-2 M. E. Witherspoon, Division Manager, Quality Assurance Nuclear Reculatory Cormission - Reaion V R. H. Encelken, Director G. S. Scencer, Chief, Reactor Construction & Engineering Succort Branch -
R. C. Haynes. Chief, Reactor Projects Section Construction R. T. Dodds, Chief, Engineering Support Section, Construction J. L. Crews, Chief, Reactor Operations Branch D. M. Sternberg, Chief, Reactor Projects Section 1, Operations A. D. Toth, Resident Reactor Inspector, WNP-2 T. W. Sishoo, Resident Reactor Inspector, WNP-3/5 J. H. Hanchett, Public Affairs Washinaton State Senate Senator T. Sottiger, Chairman, Senate Energy and Utilities Committee Senator S. Gould, Ranking Republican, Senate Energy and Utilities Committee C. Eschels, Senior Research Analyst, Senate Energy and Utilities Committee Eneray Facility Site Evaluation Council F. Hahn, Chairman, Monitoring Comnittee G. Hansen, Staff Engineer Bonneville Power Administration J. R. Lewis, Project Engineer - UNP-2 2.
NRC cosition Statement The 'iRC Regional Director described the Inspection and Enforcement mission and the potential impact on the issuance of a WNP-2 operating licensee.
He noted that over the past two years NRC has repeatedly expressed concerns
._g 7
7 9
s
- - - +---
a g
lc lF, s
over the ineffectiveness in the imolementation of the WPPSS quality assurance progran and in.aequate control of contractor activities. He stated that the ilover.ber 21,1979 'IRC Stop Work letter and the June 17, 1980 Notice of Violation, Civil Penalty, and 10 CFR 50.54(f) letters set forth the
!!RC cosition on these-matters and _the required corrective actions.
The Director emchasized the need _for strono management attention by WPPSS to these problems.
3.
General Areas of NRC Concern The following items were identified as specific and general problem areas which appear to eaist for the WNP-2 project:
a)
Contractors with significant quality deficiencies had been allowed to cerform quality class 1 eark, b)
Excessive time requireu to correct identified defiEiencies, c)
Large inspection backlogs for completed work.
d)
Poor site records control.
e)
!!uititude of site contractors having inde er %nt quality assurance programs,
f)
Assignment of quality assurance staff with lead responsibility for contractor work compliance.
9)
Overly complex and e /er-committed procedural requirements.
h)
Inadequate indoctrination of personnel.
1)
Inadequate pre-planning and preparation.
j)
Inadequate feedback of pr@lems to first-line personnel.
4 Enforcement History The r qion V staff discussed the enforcement history and apparent trends e
for '.::lP-2.
Inspection finding versus manhour statistics indicated that it has recently taken 10ss effort for NRC inspectors to identify problem areas on this project as compared to other projects in Region V.
(See Attachments 1 and 2). A review 4 NRC inspection findings show uncorrected or receat items and cases where procedures which were to control work were not in place prior to start of the work.
(See Attachment 3).
A review of events associated with the sacrificial shield wall and pipe-whio restraint problems since 1975 show that several opportunities were
/
presented wherein WPPSS could have identified and corrected the significant
(-
quality assurance program deficiencies which were recently founo +o exist.
(See Attachment 4).
1
+
~..
1 A
5.
Recent Investication/Insoection Results in early 1980, a Washington State Senate Investigating Committee interviewed various MlP-2 project personnel regarding project cost matters.
Various statements obtained aopeared to relate to construction cuality matters,
and these were verbally conveyed to NRC headouarters personnel. No written allecations were submitted by WNP-2 nrsonnel in this regard.. The NRC considered first 38. then an additional 7 itens as areas of concern.
A Region " inspector investigator-supervisor team then spent 780 man-hours on-site, and in the vicinity of the site, conducting further interviews and insoecting hardware and records.
The~NRC Director of the.0ffice of Insoector and Auditor attended interviews on several days to assess the potential' for any criminal activity.
The period of interest for the investigatien into work / records was 1978 to present, relating to on-site mechanical contractor activities.
A total of 12 apoarent items of noncomoliance, 7 unresolved items and 21 o by the investigation team (pen items requiring.follevue action were identified
- eeattachment). The results of the investigation reinforced the earlier conclusions described in the' NRC June 17, 1980 10 CFR 50.54(f) letter, regaroing need for management action.
6.
Work Restart Proaram The Region V staff discussed the events and requirements for restart of site construction activities, the need for adequate procedures, preparation cf personnel, and completion of other prerequisites was noted. Relative to NRC inposed constraints, the.following actions are anticipated:
1)
Region V November 21, 1979 Irnediate Action Letter regarding sacrificial shield wall: HPPSS plans to submit data to i;RR to supplement the WPPSS/NRC August 6,1980 meeting presentation.
Following the NRR review, Region V will issue a letter acknowledging the satisfactory comoletion of this condition (i.e. comprehensive corrective action plan) stipulated in the IAL.
2)
NRC July 13, 1980 letter regarding contract #215:. The NPC. Senior Resident Inspector at WNP-2 will examine the results of the WPPSS re-evaluation of detailed work methods and associated corrective action clans for cor. tract #215.
Following this review, Region V uill issue a letter lifting the work restart constraint.
3)
MRC June 17, 1980 letter regarding 10 CFR 50.54(f):
The NRC resident insoector and Regional Office based inspectors will routSely review the implenentation of the commitments described in the abuve letter.
The results of these reviews will be documelited in monthly inspection reports.
The resident inspector at WNP-1/4 was transferred to the WHP-2 sDecifically to provide close followup of these activities.~
The inspector is not, however, part of the WPPSS review / approval chain.
--m
l 4
F' ~
(
Uith regard to.WPPSS plans submitted _ in response to' the flRC letter,
.the HRC steff cautioned that the described reviews be moreLthan' cater reviews, and include meaningful hardware :inscections.
7.
Conclusion The NRC Regional Director expressed the view that WPPSS can recover from the orablems discussed at the meeting, although close manaaement attention will be recuired.- The VDPSS Managing Director noted that he will be personally involved in this matter and will keep -he Region V office informed.
He indicated that WPPSS will particularly_re-evaluate how WPPSS does business with its cc7 tractors.
l
-. ~
ATTACll>fCNT 1 d
ifP-2 BFORCEENT HISTORY DESIG.'l, PROCUREf1EtlT, & C0flSTRUCTI0tl 60-2500-c0-
-100 ITEMS OF fl0:lCOMPLI AtlCE
't
/
2000,-90 I
I I
i
~80 w 40-w l
5
/'.
'1 t
's REATSESSMENT
/
i I
1500
'70 i
sy teSS
/
I s
h/ <
l c
8 j'
i B
b 30 -
/
' 60 CC::STRUCTION W
PROGRESS
/
8 L
d
/
H W
I U
~
g w
,1 E 1000 -50 g
/
IflSPECTION M
/
/
HOURS d
,0-
/
-40 e c.
i l
E'
/
/
/
500.
30 j
/
/
/
10 -
/
20
/
/
/
\\
',/
0 ~-10 e
ItSPECTION MANHRS PER i;O!!CCMPLIAt;CE IIR 11 0 ftR IIR IfR 0
/
E 9fE " E E
E
,0
' 71
'72
'73
'74
'75
'76
'77
'78
'79
'80
'81
'82 YEAR 1
e
-M
1 ATTACHMENT 2 tIRC RV ENFORCEMEtlT ACTIVITY r.
i(
DESIGN, PROCUREMENT, & CONSTRUCTION (AVG. OF 18 MOS. PRECEDING 7/80) 150 -
5
~s E
s 100-5 5
M E5 5
c.
E E
E 50-0 l
U
-l 2
~,
0-PROJECT A PROJECT B WNP 1/4 WNP 3/5 WNP 2
ATTACIDS.NT 3 0
4 WilP-2 ErlFORCEMEilT HISTORY ITE'1 TYPE
- DESCRIPTION REPEAT 1
1 Failure to maintain cleanliness JCI X
2 I
Failure to monitor weld preheat 3
D Failure to maintain inspection status a
D Failure to properly code electrical cables 5
I Failure to properly install battery racks 6
0 Failure to properly identify circuit breakers 7
I Failure to cualify PWHT procedure 8
I Failure to provide procedure for PWHT 9
D Failure to naintain records of PWHT 10 I
c'ailure to PWHT per ASME Code 11 I
Failure to maintain system cleanliness X
F/L 12 I
Failure to maintain systen cleanliness X
JCI 13 I
Failure to provide class I-E equipment for RPS I4 Failure to properly weld SSW 15 I
Failure to maintain system cleanliness X
F/L & JCI 16 I
Failure to provide SSW UT procedure 17 I
Failure to provide PWR UT procedure 18 I
Failure to provide SSU Heat straightening procedure 19 I
Failure to provide PWR heat straightening procedure
(
20 I
Failure to provice SSW weld sequence procedure
ATTACHMENT 3 / Continued)
WNP-2 Enforcement History )
ITEM TYPE
- DESCRIPTION REPEAT 21 I
Insufficient SSW records identification of Inspection personnel 22 I
Insufficient SSW records inconsistent in formation 23 I
Insufficient PWR records - identification of inspection personnel 24 I
Insufficient PWR records - inconsistent it0C reports 25 I
Insufficient PWR records - incorrect inspection identification 26 I
Insufficient PWR records - incorrect insoection identification 27 I
Failure to qualify PWR inspection personnel 28 I
Failure to qualify SSW inspection personnel 29 1
Failure to control weld-filler material 30 1
Failure to repair per AWS 31 I
Failure to properly UT PWRs 32 I
Failure to properly inspect pipe supports X
33 D
Failure to document weld inspection
- V = VIOLATIC1 I = INFRACT'ON D = CEFICIE:;CY
' s -.
T i ' ' E!;T,
C Wil? 2 SACRIFICIAL SHIELD WALL / PIPE WHIP RESTRAlflT CHR0Il0 LOGY 4
1075 CC:! TRACTOR GIVEil APPROVAL TO START FABRICATI0tt 0F SHIELD WALL 7/75
- RC INSPECTION OF SH!".D WALL SITE ERECTION ACTIVITIES NONCOMPLIANCE-LACK 0F QUALITY PROCEDURES 7/76 STOP WORK ISSUED, SITE ACTIVITIES AUDITED BY CONTRACTOR / BURNS & R0E 8/76 CONTRACTORS SHOP ACTIVITIES AUDITED BY BURtS & ROE /WPPSS 6/73 CONTRACTOR CERTIFIES SACRIFICIAL SHIELD WALL COMPLETE 10/78 v01CS DETECTED IN SHIELD WALL BY 215 CONTRACTOR 11/78 215 CCNTRACTOR IDENTIFIES tlUMEROUS DEFECTS, ASKS WPPSS TO
- E-E','ALUATE THE SHIELD WALL 2/79
': PSS NOTIFIES NRC 0F MAJOR WELD DEFECTS FOU:1D IN BRACKETS F?SRICATED BY THE SHIELD WALL CONTRACTOR 3/79 BURNS & ROE ESTABLISHES PLAN TO ASSESS SHIELD WALL ADEQUACY 6/79
': C RECEIVES ALLEGATIONS REGARDING SHIELD WALL AND REPAIRS,
":: ECTCRS IDENTIFY GAP BETWEEN RINGS, QUESTION RECORDS
/
^
.. P SS CC'MITMENT TO NRC TO REVIEW ALL SHIELD WALL QUALITY RECORDS 7/'7 215 CCNTRACTOR INITIATES QUALITY REVIEW OF SHIELD WALL CONTRACTOR i
UPPSS REPORTS TO NRC THAT SHIELD WALL IS NOT PROPERLY WELDFS TOGETHER 10/79
':RC F.EVIEW O' BURNS & ROE EVALUATION ACTIVITY REVEAL.S fHE EVALUATION IS BASED ON INCOMPLETE DATA (TYPICAL VS ACTUAL DEFECTS)
UPPSS NOTIFIES NRC OF RECORDS IRREGULARITIES IN PIPE WHIP RESTRAINT DECT.D PACKAGES (SAME CONTRACTOR AS SHIELD WALL)
- RC ISSUES IMMEDIATE ACTION LETTERS, WORK STOP ON SACRIFICIAL
- iilELD WALL AND PIPE WHIP RESTRAINTS 1
NRC INVESTIGATION OF SHIELD WALL / PIPE WHIP RESTRAINT CONTRACTOR'S 2/EI) ' GPSAM AtlD RECORDS, 18 ITEMS OF NONCOMPLIANCE h 6
.o WitP-2 REPORT il0. 50-397/80-08 110tlCOMPLIAtiCE/Vi1 RESOLVED /0PEll ITEMS LIST TRACK fl0.
PARAGRAPH ITEM 01 3.a Infraction - Organizational freedom of QA/QC.
02 3.b(1)
Deficiency - Survey document of vendor not maintained 03 3.c Unresolved - Acceptance criteria for receiving inspection-of hangers 04 3.d Open
- Licensee to examine program for documenting i inspection findings 05 3.e 0 pen
- llork continued on a support FDR-385 after issuance.of a f1CR 06 3.g Unresolved - Welds being cut out rather than repaired to preclude 8/R review 07 a.b Deficiency - failure to document inspection findings relative to incorrect amperage settings for MT probes 08 4.c(1)
Open
- WP-57 does not address the removal of temporary weld attachments 09 4.c(1)
Infraction - Failure to maintain records for temporary weld attachments 10 4.c(4)
Open
- Form NF-286 contains note that temporary welding records willinot necessarily fora, a part of permanent documentation 11 5.a(1)(a)
Infraction - Piping support clearances in excess ~of requirements.
12 5.2(2)
Open
- Inspectors to be instructed to request engineers review of fillet welds on, curviture of pipe' 13 5.b Open
- Licensee to consider reportability of welding problems related to Pybus steel 14 5.c Unresolved - Control and documentation of arc strikes on structural. steel 15 5.d Open.
- Licensee to consider generic problem related to lack'of penetration in pipe from Associated Pipe 16 5.e Infraction - Failure to' use filler metal specified in procedure 17 3.5(1)(b)
Unresolved - Dispositioning of questionable filler metal and corrective ac tion 18 3.d(1)(b)
Open
- Disposition of pipe in quaranteen, heat numbers til2476 and fl12477 19 5.e Open
- Inconsisten'cy in purging procedure for socket welds 20 5.f Open
- Question of reportability of problems related to the anchoring of support base plates 21 6.a & b Open
- Handling of pipe. minimum wall thickness problems J
Nbncompliance/ nresolved/0 pen Items List (
TRACK 11 0.
PARAGRAPH ITEli 22 6.b(3)
. Deficiency - Incorrect acceptance standards used to evaluate results of LP examinations 23 7.a Open
- WBG QAP-7 does not require o'ner approval w
of contractor procedures and revisions 24 7.b(6)
Open
- Establishment of controls to coordinate hanger material identification 25 7.c Open
- Control of certain heats of pipe.in-quarantine as identified in surveillance report No. H-246 26 7.c Open
- Heat number is missing from pipe' spool RHR-2018-1 27 79 Open
- Pipe'with an apparent legitimate heat number has been installed, but has the word "scrap" painted on it 28 7.h Unresolved - Difference between stores requisition records and laydown inventory records 29 8.a, b & c Infraction - Calculations were not provided to. support'
. deletion or redesign of support welds 30 8.a Open
- Page 1 of Engineering Quality Audit is missing from documentation package for support RCC 31 8.b Open
- Inspection / control of oversized support steel fillet welds 32 9.a Ocen
- Followup on cleanliness of pipe being installed 33 9.b Open
- Review of system flashing procedures during preoperational inspections since.
flushing not planned prior to hydrostatic tests 34 10.c Unresolved - Calibration'of torque wrenches and for tightening of Velan valves in pump house (flCR -5163 )
35 10 9 Unresolved - Question relative to the"satisfactory removal of.a ladder that had been tack welded inside MS-528-7.10 pipe-spool 36 ll.a & 11.k(b).
Deficiency - Failure to provide a procedure and/or checklist for document review of work packages 37 ll.a Deficiency - Failure of QA Manager to review records of rework.that was performed subsequent to the document package acceptance review 38 ll.a Infraction - Failure to perform weld. inspection as required by procedure 39 ll.a, h & k(6)
Open
- General review of licensee's action to assure final document reviews are properly accomplishei, including commitment to the ilRC on document review 40 7.a Infraction - Failure to comply with procedure revision requirements
g.~
r,
[p stano UNITED STATES
! h.( (',i NUCLEAR REGULATORY COMMISSION
- ' ~
- c-\\ " /
- l REGION V 0,
f 1450 MARIA LANE, Sulf E 210 WALNUT CREEK, CALIFORNI A 94596 JUL 191985 MEMORANDUM FOR:
J. Crews, RV A. Chaffee, RV L. Miller, RV C. Myers, RV J. Eckhardt, RV G. Perez, RV R. Scarano, RV G. Lainas, AD/0R, NRR
'S. Miner, Project Manager, NRR L. Norderhaeg, RV M. Cillis, RV R. Fish, RV P. Qualls, RV FRCM:
D. Kirsch, Acting Director Division of Reactor Safety and Projects, RV
SUBJECT:
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
FOR RANCHO SECO (Period December 1, 1983 through May 31,1985)
I(k
References:
(1) NRC Manual Chapter 0516 (2) Proposed changes to the SALP process, J. M. Taylor Memorandue dated June 27, 1985 (3) Region V Instruction 0701 (4) SALP Board Schedule, J. D. Martin Memorandum dated July 18, 1985 Pursuant to references (1), (2), (3) and (4) above, the regional SALP Reviev Board meeting for Rancho Seco is scheduled to convene at the Region V Walnut l
Creek office on August 7, 1985, at 8:30 a.m.
The board members vill consist of the above addressees and myself who will serve as chairperson.
This assessment will cover the 18 month period from December 1, 1983, through May 31, 1985.
Since this period ends during completion of a refueling outage, the evaluation period vill be updated to include recent events through July, 1985.
Members of the Rancho Seco SALF "card are herewith provided a review guidance package to be used in preparing c.
"ormance analyses of the various functional areas. This package consists of the following: Information ln this rec 0rd was In 3CColdance witefreegamog;97 Description of functional areas (Attachment 1)
Act, exemptions Evaluation criteria (Attachment 2) pg, g
g Attributes for the evaluation criteria (Attachment 3T ' -
(
Performance categories (Attachment 4)
SALP evaluation matrix (Attachment 5)
Sample SALP functional area performance analysis (Attachment 6)
Supporting Data and Summaries (Attachment 7) 7
)
c f~
Hemo on SALP 50-312 2
(s.
The following is the anticipated outline of the Rancho Seco SALP report, along with the individuals assigned lead responsibility for preparing input for each section.
I Introduction Myers II Criteria Myers III Su==ary of Results Myers IV Performance Analysis 1.
Plant Operations Eckhardt 2.
Radiological Controls Cillis 3.
Maintenance Eckhardt 4
Surveillance Eckhardt 5.
Fire Protection Qualls 6.
Emergency Preparedness Fish 7.
Security and Safeguards Norderhaug 8.
Refueling Eckhardt 9.
Quality Programs and Administrative Controls Affecting Safety Eckhardt 10.
Licensing Activities Miner 11.
Engineering & Construction Crews /Echkardt 12.
Training Eckha rd t V
Supporting Data and Sunsaries Myers s%,
(Including tables)
Each person assigned lead responsibility for a functional area shall prepare a performance analysis and submit it to C. J. Myers by C.O.B. July 26, 1985.
Each performance analysis shall be prepared as follows:
1.
Assess the licensee's performance in the functional area based upon inspections performed, available data and observations of the licensee's performance during the SALP period. Obtain inputs from others who had inspection responsibilities in the functional area.
In assessing the licensee's performance, use the guidance in i through 4.
2.
Prepare a performance analysis for the functional area following the format of Attachment 6.
If possible, discuss the trend of the licensee's performance since the previous SALP period.
The analysis should reference pertinent data, enforcement items or events, uhen appropriate. but ohould be principally a quantitative ana ysis of the licensee's. performance in the area (depending upon the level of activity, approximately one to one and one-half page t
in longth when single space typed).
3.
Include reco=mendations for licensee actions related to the functional area.
4 Provide a copy of the SALP cvaluation matrix (Attachment 5),
assigning a performance category for cach evaluation criterion.
s
^
l f~
2 j
Memo on SALP 50 312
'3 Q
s By copy of this memorandum, the Director, Office of Investigations, San Francisco Field Office, is requested to provide a summary of major investigative activities and results involving Rancho Seco by July 26, 1985.
In addition, by copy of this memorandum, the of fices of NMSS and A'20D are requested to provide performance analyses by July 26, 1985 (or updated earlier submittals to address the extended SALP period).
D. F. Kir ch S ALP Board Chairman Acting Director, Division of Reactor Safety and Projects
Enclosures:
As Stated cc:
J. Davis, NMSS R-. Seyfrit, AE0D
- 0. Shackleton, 01/SFF0 J. Carter, NRR lgr F. k'enslavski, EV k
l I
i e
,,..,7
--n--.
e n-
\\M V
L&?V VkCA.L d ?SA y
o UNITED STATES y,
,"v. c )
NUCLEAR REGULATORY COMMISSION C
REGION V g
[
% ' v [/
14 50 M A R I A L A N E. SUIT E 210 n AtsuT cRE E k. C ALIFORNI A 94596
~
JUL 0 21986 MDiORANDL'M FOR :
J. B. Martin, Regional Administrator FROM:
D. F. Kirsch, Chairman, WP-2 SALP BOARD
SUBJECT:
TRANSMITTAL OF WNP-2 SALP REPORT AND RECOMMENDATIONS REGARDING NRC ACTIONS 4,.,. 6.. >.. a k;[.Y;..
.y. p r; t
'.f - :
- f.0 y.f..:.:.:: n :'~_';.:'.f.:.) -. ;...
v. ;.! :..
a.
....,..., :;Q, Uz. { 's.
.... ps a...
-q:s.:..y!,f'OIb!:.
c.
hh,,
Y.$
- kk'. :
Uk I
'5:.
.$.?,,..0, ~ Y.' : :. N.' T- : '-
'Y D;,: h $.;$gt h..,--N $ d..it3 d N.. M.... T. h(. D:.:.,
73$h..?}M-u~
h...
s.? g.,..Yk 'k.h. O h ' nyW n!les?1 $' Nh.q.;.c..c.
a s.n. d Y,h; +:*:?:'::s. -
s; -
1h a
. y.
p.
.~...:.
bi h*
I 'Y.?.;0.],Y:Y ': ? l ki
u'.(. +.s(S.r..<; :1 cas m.
sQ:c?q.W.h. g,Q.y..@ll ] { f.Q.k n. h;/ i; ; ~~(i:!%' '.W~:%.. ;;: U.'
'...,... e -
4
,&.s;.m:;u., y;. )h x,. ; e '.,s
/
- -[t.'J.-
p
~.
i 'i.),I /. ffj: ilh.,
..n
...Y#
N
. ? C',,j%l.
.,e. ? #f: wl,f ;.'.
- i'.-M u.h A. M.. %y..
.s
...4'[?:
' [J'.4*.3. '-)
f /:,
- . w.:. ;,,.,V:~ a.?; b :b.:L.' : ::, u,.3).*j'MR. : N.w:l?;
f,'
v 2
s.
k
,. w.
- ..>.... n.x.
,. s ;.. v.:
. a,f$.. :'.' [
'. 9 h+.,y..
o bh-7.h.- :
.h
[ w v.c. n,.$
k
.4Y~
f.
E.
'h
.n m,h.5 5!- h!h u,..
n.
v ~.~
- h
- hI
, 5. -
. A f;y.f... M3% 7 L;! 8,.
- r..s...m.d.
.c.m
?
l- *;
,. thw.
w$ '..
..w.xw w : x,..a.. w > n:.
n ww M..;... c......, J,w{9 1%,$c:w[MMkg%p.w:
- .a
,e
.m c
jf.
f.
fi//
NQ t[:j[
jy/i['
fMWWWM5W N k k k k h N $ b@ h h s &
hkhfhhhk 4
1 g
', &&,;g p.:74.gqq.e'n w h f
I E
.c
_s 7a:nG,:c3.,..~ g
. )k
-:t. e u ~ v O
n g
fp.
~~
~~-
f~
~
.o L.
h
.A JUL 021986 l
.2-
'k I.,!.'
% ' h. ' l1 R l.,4 f.
- '.r
$W fs:. y.f..h.l d. :,W.l'$
Ip E.'
f...
V r.Y,W:A...aW $9N. %.'y
$ k. R /
M W j. W ? $ y.i. @D :
%. W h.:.
-lq ',;.. Q ya 9 4 n. %
,y n
.. ~:
i. '
a ~'Qf. '
- y'f *. j/ *-p..[. - -',
.,./,,,..,, -.-
p",-*
/.,
's,_. l
- ' 'l.,
' j
,~ 9.
- V
.'y r.
['.
?,
N
'? }, *
.. w @l },
y, c
.[,f
. l
.v.s.,
- 4: '.:
.,t,
,,n
.c.GW v..
j. +,.
=t%
. 2l:f.t.' '.'. '; '.. - :: "
. c.'- -
- *l s
4....,.
W' *& 3 4!A,.... :'.- ; %..
> :~..T: %,L d.\\
., ~.' + g; U
,,...e.... :
-. - Q,y.
. f..;
0-
.. alb
.g*
.r.,'.
+
'{
+1 3.*
.. s n f.
^ wr.-.g,. *., -
-4
- (
s
.e,.
fy-a
!. l.
,. "<j e z. (*,[
-. e. ~. ;f..
.s.:. g.,
or
. _ '. b.,
,.*:~.1--
7Vq
..m
- i. _:
.. : ~.. ;
. -. ' *..~.'..' ' [ -
., ;; y, l L...
,j!g}f:_Zi : -
4.,, p
>..:' ;~. :. n,. \\... *:
's T.-
.;.. l, ':3.,e d $e.\\ %q..;.., ' L
..)..:-.,,u '.;
..w
. h,c
-:- -.. ~,.
e - ' :.1.
4..
.... ~
y
. B..
b- - '.. :
g ; 7;p f,g.g. *f ' -., 1... " f.; ' ?..
,.,l; j $.j...
,, :.T. 7. ;. :
. :. - ?
.- 9
...,,y p., 3.;,
.p.qf,...:+- '; '.,
_'t
't.,., -
L -
9,,'..
.g
., ) z '..
k.-,
4...
- - y :.-
0 DM,$_ GN ;' F l,. l '.L:.:. *G,
- 2. l d' '. l.." l: ' ?l O " '.Q,' ',Ll:. V t%l.'.
'Y.; C e.,Y.!l. V. N:L
- t v%c
- 3;+.n.:t. g /; %x 4 g G.;.;;wl..%, ;hr +.*.5;
- i q.?.,;.. y:j@
t f': &*
R
,.;f. 2..,.
W.
j t.
y>
.. M.,
b 4' C :.:
1,M'4. )!,.:. U:n;.s:' ; %.:r' T *:
- !, f f ';.v,.
h
- L:; i F., W Q.W;w :.
G:. A. D l h
,.',N' h
a 3: :.:;4.s
?.,:.t f, h. q %.
S. w s...
.... :..~
2 gli, :u:Wik ll: '.A.hx, ~?.%
& kl0.V.(u@,.)1 ~$n.s.w..
%m m.J~ : -
.k 1
WSMD.%,,.e.f.;. 44;km 8..:.
- p
- ;r.:: 9:
g
...p.
4
.t
- a
$.,,'le f,?$ l
.h N
'A W
f' 3'...yh.
.a 3.:y.,)> ;; y fg'y;y.,;-)% 4'.. c r f.
%.3.y&
',.f.
g
. v. s e
.v.
e
.: u. m.
4,:
1 z n w.'.;;@
A y ;p.4.;;.g p.'.
- 7.., ):
Q.gg' ' y, y,;^9.. p.g c,rit@t4'.-;g t 1g f..g f
-(
c;..
.p.,
. ;.; - -. s 3... -
g,pp 3,.
g;..
'y ;:
g:4 -:y;..,y.' y,;v.-.
. y.,.
s g.p* u.
.. ~. 9~
- ..
- Y -,e
.. ' j >;:.4. 5.,.
z.r.;< g...'gppj%.-} %.r,l'.; }Q'._.:
e
,*. 39 5 %,,.,
Q',
~
'h'
- .l
' ',:.'l
~. :-.
.. '. _ _. ; )..,,f,}-ly.:,
,,,e.s.c,:..y,. q. :.'..,'. f;...]< -
y'
.. f..:
s_
- ,- r n
- . y p.
- .,,k e.,..
.. g(4 m+.. r.. :., s..,..v,+
,e
.+Q*..
n..
,.._.s.
~
. ~,.
-y.)}-..',9 a -
4,lJ.p. ;.
.{.;,u +..,. ' p.,.'..
4',-'
.....g : g -- #..
.v.....
1.Q. _...
1 W : :. *Q,hi.%,. 7. 4...
. ~lj. -
4<
.s
<y k
- '..,g :. ~. 4..,.,N
- n.
,! *? ' !;?,.i e
I'. :
L
~\\
.f,.'l
!. '.. ;e M.., J,f:,., ;y;..i %...
1 l.
'}Q...,,.y*
~, SW... 4..
- . y, :;;.
G! N,^,^{.[. * ?f g 9 ( y ','I % ; y.fl %,2? p 2.',[:2.f*1. b '
.y ; @ -f
<.. Q.1. i:. :
... r'! :.*
a : 3.'
.. ' y,. Y. y : :
.-q
,..t fe -q, E J
G h:.. :.'
5
M$N.I.h n.bQ%9)McN; h.?
- W
- ,f :*?.SM h.t. I;U.{.C.l[( d. E h $ $
T$
b
,. E? $ %. 'i ?. N.,':Q
' k 5 5:
'.h.
s s
..f'.... -: 's -* ::. +
. o
.G'.'.'.; L '. : '.,.. f ps._.'
,r
- f" 1. g.. ". f. L[- ?A, f.1.
f s
.n
- -;:. i-
- L-
- ..,.s
.,- -.s
,r e
A*,.h. :s '.e 4..F ' ' t. p *..; *.: :.? C' t.
r n. n. % W,:a ::.'. t.
,m.....',s -\\ 'A "....... -
^.. '... lj.
a.,.u!
,' R V n ' a.p..
'.,.. z.;',+
l[f _ p. yl,:
_ s L.o, -,. i. :. v ; m....,... L:,.. -:..' p., s4 q.,F y. y
. - 6:
.y.
p*
.9
+. ": p jQ,.;:'. [
.;..';f VQ$j:y,;.m,y;&.k _Gy%}.f:. (.::; ? ~,;.y,). ? L -
(;.;R 4.. f
- [. _,j
.. f. y.....a u. ; 7
- 7:... : :.%.; p.' ay ::3; m:.,..s
- ub;.y- % ;. '. :
, a.
- pn. v. :,> n...
m.
-?
. p n-3 i..;,...h.I.
i.,.. i.- e.., u.. ; 1.. c e
. u,-
w.,.: 9 ' '..,;. '. l % ]-
QfM,1
- p. m, s.g.Q,4 %,s'l.',.l - L :, R..',< ':.b ;;', * ; ?. G...
,y,.f<.: ?. p p :.; n. f. ylq Q.
- V.
j y u.,p..:+:n..,y@.w...._..
.n
- y. g.;;.a e y a.sd
- n
- .. n.::;.,: 5 :s :. v.r, x. :. ;:s::.
+
% R{y ';a.. 3 q _,m-;., w.
r.y.
Od.DNiUNhN/k.;s:q..
s n
.. a.T. a.
cp k iN.N,:< W.,4 &e., h:N k h.c$ h.E u f.W) %
w M
%dk(gym,nt hkM 9.U.
&:~hdDiM.
':.hI
- k. W. %n lM.Ag' y *:I?&. t Q.$
- Q.~ ls%.Mm -.i,
- 1. o b
7 Af. W.
g'.m.u T'k'j A.-p
.s 4-cW
>=1 J p-c.a c,. n&.. ag. 3
..&$ l4Sg 'y
- c i
4 r,8.Y Y:{ g-
&s t?/ - y ',i[;
Ah,.ghc.% g?
7: -M
<w y
f I
- $lM:yy ].g
.y.L $Ey R
- ch.
j]y2:,$&):J/pK.p%;G':'!l%[pge@4.h.L
, $ gy 3.:
g4 s' g.a. v ay pqg
- l '
y h*f.5 kWh., vem'I ':$'
2 ns m.. n +
y.N$aw~kh,ffff,.m$Y'Y.gh
~ $ m ;. h,hih{
c
\\
.ppys r.
..t p
g.
e h
m
.e.-
JUL 021986 l~'
,y- ~
\\~.~
D. F. Kirsch, Director Division of Reactor Saf ety and Projects Chairman, WNP-2 SALP Board cc w/o enclosure:
WNP-2 SALP Board Members R. Scarano J. Montgomery F. Wenslavski B. Faulkenberry D Pereira f
vRegion V SALP File
.w,y,y,,--
,y-wiw-e,--w,---e
-v--
- -*T NPV"-"***
~
-- - - - - -