ML20196C864
ML20196C864 | |
Person / Time | |
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Site: | Wolf Creek ![]() |
Issue date: | 06/23/1988 |
From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
To: | |
Shared Package | |
ML20196C787 | List: |
References | |
50-482-88-14, NUDOCS 8807010253 | |
Download: ML20196C864 (41) | |
See also: IR 05000482/1988014
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SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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SISTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
NRC Inspection Report 50-482/88-14
j Wolf Creek Nuclear Operating-Corporation
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l- Wolf' Creek Generating Station
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March 1, 1987, through March 31, 1988
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8807010253 880623
PDR ADOCK 050004G2
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I. INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on
a periodic basis and to evaluate licensee performance based upon this
information. SALP is supplemental to normal regulatory processes used to
ensure compliance with NRC rules and regulations. SALP is intended to be
sufficiently diagnostic to provide a rational basis for allocating NRC
resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant operation.
An NRC SALP Board, composed of the staff members listed below, met on
May 17, 1988, to review the collection of performance observations and
data, and to assess licensee performance in accordance with the guidance
in NRC Manual Chapter 0516, "Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Wolf Creek Generating Station for the period March 1, 1987,
through March 31, 1988.
SALP Board for Wolf Creek Generating Station:
L. J. Callan, Director, Division of Reactor Projects, Region IV (chairman)
J. L. Milhoan, Director, Division of Reactor Safety, Region IV
M. R. Knapp, Acting Director, Division of Reactor Safety and
Safeguards, Region IV
D. D. Chamberlain, Chief, Reactor Project Section A, Region IV
B. L. Bartlett, Senior Resident Reactor Inspector, WCGS, Region IV
P. W. O'Connor, Project Manager, Nuclear Reactor Regulation
The following personnel also participated in the SALP board meeting:
J. M. Montgomery, Deputy Regional Administrator, Region IV
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A. B. Beach, Deputy Director, Division of Reactor Projects, Region IV
J. P. Jaudon, Deputy Director, Division of Reactor Safety, Region IV
l R. E. Hall, Deputy Director, Division of Reactor Safety and Safeguards,
I Region IV
l J. B. Baird, Technical Assistant, Division of Reactor Projects, Region IV
C. A. Hackney, Emergency Preparedness Analyst, Region IV
J. L. Pellet, Chief, Operator Licensing Section
R. J. Everett, Chief, Emergency Preparedness and Safeguards Programs
Section, Region IV
R. E. Baer, Chief, Facilities Radiological Protection Section, Region IV
W. M. McNeill, Reactor Engineer, Materials and Quality Programs Section,
Region IV
II. CRITERIA
Licensee performance was assessed in 11 selected functional areas.
Functional areas normally represent areas significant to nuclear safety
and the environment. Some functional areas may not be assessed because of
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little or no licensee activities or lack of meaningful observations.
Special areas may be added to highlight significant observations.
One or more of the following evaluation criteria were used to assess each
functional area:
1. Management involvement and control in assuring quality.
2. Approach to the resolution of technical issues from a safety
standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Operational events (including response to, analysis of, and
corrective actions for).
6. Staffing (including management).
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1. Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety and
construction quality is being achieved.
Category 2. NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
operational safety and construction quality is being achieved.
Category 3. Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety and construction quality is
being achieved.
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III. SUMMARY OF RESULTS
The SALP Board review revealed areas of strength in fire protection and
security with an increase in performance from the previous SALP period.
Performance in the areas of emergency preparedness and surveillance
remained consistent with the previous SALP period. All other areas
revecled a decline in performance or a declining trend from the previous
SALP period. The overall decrease in performance is due, in part, to the
failure of licensee management to maintain effective control of major
outages.
The licensee's performance is summarized in the table below, along with
the performance categories from the previous SALP evaluation period.
Previous Present
Performance Category Performance Category
Functional (02/1/86 to 02/28/87) (03/1/87 to 03/31/88)
A. Plant Operations 2 2
B. Radiological Control 2 2
C. Maintenance 1 2
D. Surveillance 2 2
E. Fire Protection 2 1
F. Emergency Preparedness 2 2
G. Security 2 1
H. Outages 2 3
I. Quality Programs and 2 3
Administrative Controls
Affecting Quality
J. Licensing Activities 1 2
K. Training and Qualification 1 2
Effectiveness
IV. PERFORMANCE ANALYSIS
A. Plant Operations
1. Analysis
The assessment of this area consists chiefly of the activities
of the licensee's operational staff (e.g., licensed operators
and nuclear station operators). It is intended to be limited to
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operating activities such as: plant startup, power operation,
plant shutdown, and system lineups. Thus, it includes
activities such as reading and logging plant conditions,
responding to off-normal conditions, manipulating the reactor
and auxiliary controls, plant-wide housekeeping, and control
room professionalism.
This area has been inspected on a continuing basis by the NRC
resideist inspectors and on several occasions by NRC regional
inspectors. Specific areas inspected included operational
safety verifications, safety system walkdowns, follow up on
significant events / problems, and review of licensee event
reports (LERs).
One violation was identified in this functional area and, while
it indicated additional management controls were needed,
corrective action was promptly initiated by the licensee. Also,
one of the escalated enforcement violations listed in the outage
functional area included three examples of problems relating to
the operations functional area. Four LERs were issued by the
licensee in this functional area. These four LERs had no major
effect on plant safety. One of the LERs concerned the one
violation that was identified in this area. The remaining three
LERs were ali personnel errors and were indicative of a failure
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to pay attention to detail.
Corrective actions initiated by licensee management included
requiring the use of procedures in additional areas in
operations. At the end of the SALP period the use of procedures
in operations was much improved.
Operational events and NRC observations showed that operations
interface with other departments is lacking. There has been an
apparent failure of operations to make effective use of
technical support groups. In some cases even when technical
support groups became aware of problems and provided input to
operations, the input was ignored or was lost. There are two
examples. The first was when operations was not responsive to
Nuclear Safety Engineering's information and advice concerning
the essential service water (ESW) pipe-wall thinning issue. As
a result, timely corrective action was needlessly delayed. The
second was when engineering provided disposition to repair a
section of thinwall safety related pipe and the disposition was
misplaced for approximately 3 months.
In general, operator performance, as observed by the NRC
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inspectors, has been good. Control room professionalism has
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been maintained and good operator morale exhibited. At times,
however, the operators failed to pay attention to detail. Two
- examples of this are given below
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The first example occurred when vital batteries were
allowed to be depleted over a 30-hour time span without a
procedure being available to provide alternate AC power to
the battery chargers, and without bus voltage being
observed carefully or without periodically observing
current readings and comparing them to expected values.
The second example was the uncontrolled use of operator
aids. When ESF actuations occurred as a result of the
degraded batteries, the operators relied on the
uncontrolled aids in determining that certain manual
isolation valves were shut. The valves were, in fact,
cpen. When the valves had been opened, the uncontrolled
aid had been forgotten. This resulted in the undesirable
placing of lake water in each of the steam generators.
The licensee continues to give strong management support to the
college degree program for operations personnel. The number of
operators with engineering degrees or working toward degrees is
considered to be a plus.
The number of operators with senior reactor operator licenses
exceed the number of operators with reactor operator licenses by
more than 2 to 1. This allows the licensee more versatility in
the use of the operators, while at the same time giving
operators additional training and mobility.
In general, the licensee maintains a 6-shift rotation of their
operating crews. This allows for a better utilization of the
crews, less overtime, and increased training.
2. Conclusions
The overall assessment of this area indicates that improvements
need to be made. As stated in the previous SALP report,
licensee attention to detail in this area can be improved. The
use of procedures in operations was noted to improve; however,
this occurred only after the situation had been allowed to
deteriorate to an unacceptable level.
The examples of inattention to detail and the lack of effective
operations interface with other departments reflects an
ineffective management oversight in this functional area.
Staffing in this area is considered a strength, along with good
control room professionalism during power operations.
The licensee is considered to be in Performance Category 2 in
this area, with a declining trend.
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3. Board Recommendations
a. Recommended NRC Actions
The level of NRC inspection in this functional area should
be consistent with the basic inspection program.
Supplemental inspections should be performed to focus on
operations interface with other departments,
b. Recommended Licensee Actions
Licensee management should ensure that there is an adequate
and prompt QA, NSE, and engineering involvement in
operational events and in the technical resolution to
safety issues.
B. Radiological Controls
1. Analysis
The assessment of this functional area includes the following
areas of activity which are evaluated as separate subareas to
arrive at a consensus rating for this functional area:
(a) occupational radiation safety, which includes controls by
licensees and contractors for occupational radiation protection,
radioactive materials and contamination controls, radiological
surveys and monitoring, and ALARA programs; (b) radioactive
waste management, which includes processing and onsite storage
of gaseous, liquid, and solid waste; (c) radiological effluent
controls, which includes gaseous and liquid effluent controls
and monitoring, offsite dose calculations and dose limits,
radiological environmental monitoring, and the results of the
NRC's confirmatory measurements program; (d) transportation of
radioactive materials, which includes procurement and selection
of packages, preparation for shipment, selection and control of
shippers, delivery to carriers, receipt / acceptance of shipments
by receiving facility, periodic maintenance of packagings and,
for shipment of spent fuel, point of origin of safeguards
activities; and (e) water chemistry controls, which includes
primary and secondary systems affecting plant water chemistry,
water chemistry control program and program implementation,
chemistry facilities, equipment and procedures, and chemical
analysis quality assurance.
Nine inspections were performed in the area of radiological
controls during the assessment period by Region-based radiation
specialist inspectors.
There were five violations and one deviation identified in this
functional area.
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a. Occupational Radiation Safety
The licensee's programs for occupational radiation
protection, radioactive material and contamination
controls, radiological surveys and monitoring, and ALARA
programs were inspected four times during the assessment
period. Two inspections were conducted during normal plant
operations, one inspection during a scheduled refueling
outage, and one special inspection after the release of
radioactive material to the local county landfill.
The licensee's exposure for 1986 was 142 person-rem
compared to the national PWR average of 392 person-rem.
During 1987, the licensee's person rem exposure was 124
compared to a national PWR of 376 person-rem.
The size of the radiation protection staff was adequate to
support plant operations. A low personnel turnover rate
within the radiation protection group was experienced
during the assessment period. The licensee's approach
concerning the resolution of technical issues indicated
their understanding of issues was generally apparent.
Acceptable resolutions were generally proposed in response
to NRC initiatives.
Those violations identified in the radiation protection
program were an indication of a lack of management
involvement in assuring quality and worker training. The
two concerns noted during the previous assessment period
which included: (1) lack of steam generator mockup
training and (2) lack of health physics supervisory
personnel presence in the plant to oversee and evaluate
ongoing radiation protection activities, had not been fully
resolved.
The licensee had made changes in the position of radiation
protection manager, an individual with limited experience
and not qualified in accordance with Regulatory Guide 1.8
was aupointed to the position. The licensee recently
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I contracted a qualified individual to oversee and provide
direction to the radiation protection program,
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b. Radioactive Waste Management
The licensee's program involving processing and onsite
storage of solid waste was inspected twice during the
assessment period. One violation was identified. The
l licensee released radioactive material as trash which was
found and recovered from the local county sanitary
landfill. The licensee had reduced the volume of
solidified waste generated by use of a portable
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demineralizer skid for liquids and processing spent resins
by dewatering methods. The licensee tyd identified key
positions and defined their- responsitiilities, f
c. Radiological Effluent Control and~ Monitoring t
This area includes gaseous and liquid effluent controls and
monitoring, offsite dose calculations and dtge limits,
radiological environmental monitoring, radiochemistry
program, and radiochemistry confirmatory.yeasurement
results. Threeinspectionswereconductedbyringthe
assessment period, together they encompassed the complete
program area.
lhe licensee has established a program concerning the
control and release of gaseous and liquid effluents.
Liquid and gaseous effluent release permit procedures have
been developed to assure that planud i* pleases receive
proper review and approval prior to releases. A review of
gaseous and liquid releases indicates that offsite doses
were well below Te:hnical Specification limits. Three
concerns were identified relating to: (1) liquid effluent
monitor setpoints, (2) condensate stora4e tank analyses,
and (3) radiation monitor calibration' data.
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The offsite radiological environmental ronitoring program
was inspected once during the ac40sment period. No
violations were identified. The radic,ogical environmental
monitoring program is effectively managed from the
licensee's corporate office and implemented by atation
personnel. The working relationship between the two groups -
has been excellent. ,
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The radiochemistry and water chemistry program 9iich
included onsite confirmatory measurements with the.NRC
Region IV mobile laboratory was inspected onct during tne
assessment period. No violations or deviations'were
identified. The results of the confirmatory mrasurements
indicated 97 percent agreement, a slightly higher value
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d. Transportation of Radioactive Materials
This area was inspected twice during the assessment period
in conjunction with the solid radioactive maste mar,agement
program. Two violations were identified;:d,e Wolation
involved the lack of proper storage and control of quality
assurance records of radioactive material shipments, and
the second related to the lack of training provided to the
health physics supervisor - radwaste. Corrective action
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takenbythelicer.cedhasgenerallybeentimelyand
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Transportation activities at the site usually involve the
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support.and guidance from the corporate offices. The
licensee has eh lblished an adequate quality
control / quality assurance; urogram for low-level radioactive
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material shipments. Transpor(ation activity records are
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This area was inspected once during the assessment period.
The inspection involved the initial use of prepared water i
chemistry standards for confirmatory measurement 1
evaluations.i T'1e results of the water chemistry
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s confiraatory measurements indicated 84 percent agreement \p
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Theserpitsareconsiferedwithinexpectedindustry
performape/ levels. The inspection also identified four
concerns involving inctrumtpt calibration and the quality
control aspect of the wated chrristry analysis program.
2. Conclusions
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The licensee's overall performance indicated a decrease in
effectiveness over the previous assessment period. Seven
violations and one deviation were identified during this t
assessment period, as compared to no violations or deviations
being identified during the previous assessment period. %
In' adequate management attention tq NRC concerns is demonstrated
' by the lack of resolution to the4 concerns noted during the
previous assessment period, which were: (1) f ack. of stea'm
generator mockup training and (2) lack of health /,;hysics . )/
supervisory personnel presence in the plant to oversee and
evaluate ongoing radiation protection activities. Improvements
were noted regarding the implementation of the ALARA program. .
The licensee's personnel radiation exposure history has been '
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better than ( Mss than one half) the national average for PW P.
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No significant problems were identified in the functional areas l
1 of trans;brtation of vadioactive material, and radiological l
effluentuontrol and monitoring. The licensee's program for i
,, 1 these areas appeded adequate regarding management oversight, s,l}
resolutioA,6ftechr{lty.1 issues, training, procedures,and ,, j
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The licenset is considere4 to be in Perforkahce Category 2 in
this area. 'dowwer, during the SALP period, performance was
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decreasing. ~Recent changes in management have not yet had ,t;ile
to be effective.
3. Board Recommendations !
a. Recommended NRC't.ctions
The NRC inspedt.' ion effort in this area shculd be consistent
with the basic inspection prograr with increased emphasis
on management involvement to assure quality,
b. Recommended Licensee,_ Actions i
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Health physics stperviscry personnel should spend more time
in the radiological 1y controlled areas evaluating and
observing ongoirg re:diation protection w k activities to
ensure compliance with station procedures. Management
should take action to provide training to technicians to
enhance procedural compliance.
C. Maintenance
1. Analysis
TheassessmentofthisareaiM1udesalllicenseeandcontractor
activitics associated with preventive or corrective maintenance
of instrumentation and control equipment'and mechanical and
electrical systems.
This area was inspected on a continuing basis by the NRC
resident inspectors and periodically by NRC regional inspectors.
There were two violations identified in this area. These
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violations involved the failure of the licensee to request a
code ex.emption when required and three examples of a failure to (
follow precedures. There were 11 LERs issued by the licensee in
this functional area. One LER was due to inadequate
pct-maintenance / testing or, a containment isolation valve,
another LER was due to an accidental mispositioning of a breaker
switch.
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l The escalated enforcement action that was taken due to the
problems which occurred during the fall refueling outage
revealed significant problems within the mainterance
organization. These problems consisted of workers failing to
follow procedures, inadequate proceduras, inadequate control
over special processes, and an overs ' 5reakdown of management
oversite of maintenance activities dunng the eefueling outage.
l One of the major causes for the problems which occurred this
SALP period was workers failing to follow procedures.
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Three of the findings in the escalated enforcement package were
workers failing to follow procedures. These included issuance
a < i cf the wrong weld rod material, use of the wrong weld rod
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material, and failure to check for an energized circuit. There
-have been multiple occurrences of Wolf Creek event reports
written for failure to follow procedures. The failure to follow
procedures was pervasive at the Wolf Creek site. This could
only exist if it was allowed to slowly build up over a period of
months or years. Licensee management was not effective in
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correcting the problem.
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~/ During the last quarter of the SALP period, the maintenance
management organization underwent significant changes
Maintenance was combined with facilities and modificat. ions to
form maintenance and modifications. This change combines all
maintenance activities under a single manager. The
superintendent of maintenance transferred to the outage plannin0
group and the manager of facilities modifications became the
manager of maintenance and modifications. In addition, some
lower level h.anagers were transferred and some positions were
eliminated. These changes appear to have significantly
strengthened the maintenance area.
2. Conclusions
The NRC found evidence of upper management support for a strong
maintenance program. However, the implementation of this
program was not adequately carried out. Management oversight of
the day-to-day activities in the area of maintenance declined
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significantly during the assessment period. Several examples of
the results of this decline were identified. Towards the end of
theSALPperiod,majormanagementchangeswereimplemented.
These changes appear to have significantly strengtherad
- - management oversight of maintenance activities.
The licensee is considered to be in Performance Category 2 in
this functional area.
3. Board Recommendations
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a. Recommended NRC Actions
l The NRC inspection effort in this area should be consistent
with the basic inspection program. The resident inspectors
should increase their inspection activities in this area.
b. Recommended Licensee Actions
l The licensee should follow through and assess the
l effectiveness of their corrective actions. The licensee
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should continue the increased emphasis on procedural
compliance.
D. Surveillance
1. Analysis
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The assessment of this functional area includes all surveillance
testing and inservice in;pections and testing activities.
. Examples of activities included are: instrument calibrations,
equipment operability tests, special tests, inservice inspection
and performance tests of pumps and valves, and all other
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inservice inspection activities.
This functional area was inspected on a routine basis by the NRC
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resident inspectors and periodically by NRC regional inspectors,
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The enforcement history in this functional area identified two
violations during this assessment period. Also, several LERs
were issued by the licensee during this assessment period.
Personnel errors and inadequate procedures were the predominant
causes of the violations and reportable events during this
assessment period. This resulted in examples of missed
surveillances, late performance of surveillances, inadequate
post-test review, and undesirable engineered safety feature
actuations which are similiar to problems which occurred during
the previous SALP period.
During the previous SALP period, the licensee was rated a SALP
Category 2 in this functional area with a decreasing trend.
Although the enforcement and reporting history indicate
improvement, as noted above, similar procedural and personnel
errors are being repeated during this SALP period.
2. Conclusions
The overall assessment for this functional area indicates a
program for scheduling and tracking of surveillance activiG es
that appears adequate. Procedures in some cases did not address
all Technical Specification surveillance requirements
adequately. The repeat procedural and personnel errors indicate
that additional management involvement is needei
The licensee is considered to be in Performance Category 2 in
this functional area.
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3. Board Recommendations
a. Recommended NRC Actions
The level of NRC inspection in this functional area should
be consistent with the basic inspection program,
b. Recommended Licensee Actions
The licensee is encouraged to perform an indepth review of
the Technical Specification surveillance requirements and
ensure that the surveillance procedures address these
requirements. Also, additional management involvement with
surveillance activities is encouraged.
E. Fire Protection
1. Analysis
The assessment of this area includes routine housekeeping
(combustibles, etc.) and fire protection / prevention program
activities. Thus, it includes the storage of combustible
material; fire brigade staffing and training; fire suppression
system maintenance and operation; and those fire protection
features provided for structures, systems, and components
important to safe shutdown.
This area was inspected by a Region-based inspector and on a
continuing basis by the NRC resident inspectors. During this
assessment period the fire protection group went through some
organizational changes. One change was the transfer of the fire
protection training duties from the supervision of the fire
protection engineer to the trainir.g department. The other
change was the transfer of the fire protection group from the
plant support organization to the operations organization.
The following observations were made:
. The licensee has made significant improvement in the area
of administrative controls for fire barrier penetrations
and openings. Especially significant has been the
reduction of missed fire watch patrols.
. Control of transient combustibles has been effective.
However, housekeeping could be improved in the area where
trash is being deposited in other than approved containers
(example: openings in tube steel).
. Fire brigade / watch training continued to be outstanding.
The transfer of the fire training group to the training
department has shown no adverse effects.
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The licensee instituted a program to identify all fire barrier
penetration seals that were either never sealed or removed and
not resealed. This was an extensive program which the licensee
aggressively pursued and completed.
2. Conclusions
The licensee has shown significant improvement in their fire
protection / prevention program. Management involvement, both in
the program as well as training, was evident. The major reason
for the improvement in this area has been the continuing
dedication and hard work of the well qualified fire protection
engineer and training instructor.
The licensee is considered to be in Performance Category 1 in
this area.
3. Board Recommendations
a. Recommended NRC Actions
The level of NRC inspection in this functional area should
be consistent with the minimum inspection program,
b. Recommended Licensee Actions
The licensee should assure that the recent organizational
changes that have the fire protection engineer reporting to
a different group and at a lower management level does not
result in a reduction of management support.
1. Analysis
The assessment of this area inciudes the licensee's preparation
for radiological emergencies and response to simulated
emergencies (exercises). Thus, it includes emergency plan and
implementing procedures; emergency facilities, equipment,
instrumentation, and supplies; organization and management
control; training; independent reviews / audits; and the
licensee's ability to implement the emergency plan.
During the assessment period, four emergency preparedness
inspections were conducted by Region-based and NRC contractor
inspectors. One of these inspections was the observation and
evaluation of an annual emergency response exercise by a team of
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NRC and contracter inspectort. During the exercise, four
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deficiency was identified. The deficiency identified during the
exercise involved incorrect classification of the emergency as
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an unusual event rather than an alert. The licensee's overall
performance during the exercise was evaluated as good. The NRC
staff concluded that licensee emergency response personnel
demonstrated their ability to protect the health and safety of
the public.
Three routine inspections resulted in identification of three
violations. One violation involved failure to document required
communication tests of the emergency response facilities. The
other two violations, one of which was a repeat violation,
involved tailure to determine availability of required emergency
preparedness personnel in the event of an accident. Training
was identified during the previous SALP period report as an area
needing management attention. The licensee has developed lesson
plans, revised training requirements, and implemented a more
efficient record management system.
The 1987 SALP report stated, "However, several changes were made
to the onsite emergency planning administrator (EPA) position,
and the replacement EPAs have had little previous experience in
this area." Due to attrition, new inexperienced personnel have
been assigned the onsite emergency planning and preparedness
responsibilities. Discussions held with onsite management
revealed a difference of opinion as to what the functions of the
onsite emergency preparedness coordinator were and would be in
the future. The offsite emergency preparedness administrator is
located in Wichita, Kansas. The licensee ha; recently added
another level of supervision above the EPA, removing the EPA
further away from plant management. (This reorganization
presently is awaiting NRR approval.) The emergency preparedness
program appears to be in a trantition phase with the shift in
lead responsibility for emergencf program to the corporate
office.
2. Conclusions
The violations issued in shift staffing and augmentation
indicate that the personnel notification method and procedure
requires additional improvement. Hansgement attention should be
devoted tu meeting regulatory requirements and licensee
commitments.
Licensee management attention and involvement are evident;
licensee resources are adequate and reasonably effective so that
,
satisfactory performance with respect to operational safety and
l construction quality is being achieved.
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- _ _ _
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16
The inspection findings for this evaluation period indicate,
overall, that the licensee's emergency preparedness program is
adequate to protect the health and safety of the public.
The licensee is considered to be in Performance Category 2 in
this area.
3. Board Recommendations
a. Recommended NRC Actions
NRC attention should be maintained at normal levels.
Attention should be directed to licensee action taken
toward correcting the call-out drill response and shift
augmentation response times.
b. Recommended Licensee Actions
The level of management attention to the implementation of
the emergency preparedness program should be increased to
ensure proper response to NRC identified concerns relating
to call-out drill response and shift augmentation response
times. The licensee should expedite correction of the
call-out drill response and shift augmentation concern.
Management should review the distribution of onsite and
offsite emergency program areas of a thority and
responsibilities.
G. Security
1. Analysis
The category of security relates to all activities whose purpose
it is to ensure the protection of the plant. Specifically, it
covers all aspects of the security program including ancillary
efforts such as fitness for duty and access authorintion
programs. Examples are: the licensee's overall management
involvement ir, e-tablishing protective policies; designing
physical security systems; submitting the security plan and
implementing associated procedures; selecting, training,
equipping, and supervising personnel; maintaining the hardware '
that suppcrts the program; and auditing and measuring the
performance of the security program.
This area was inspected on a continuing basis by the NRC
resident inspectors and on a periodic basis by the NRC
Region-based inspectors. Four inspections were conducted by
Region-based NRC physical security inspectors during the
assessment period. Four violations were identified, two by the
licensee,
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17
There was evidence of prior planning and assignment of
priorities. _ Policies and procedures are well stated,
appropriately disseminated, and understandable. Decisionmaking
was usually at a level that ensured adequate management review.
The.new corporate structure, which includes a repositioning of
the Quality Assurance Department, is committed to continuing an
independent and effective oversight of security-related matters.
Management reviews of identified security ratters were timely,
thorough, and technically sound. The init.a1 review of security
incidents has improved and further examination for generic
significance has been enhanced. Records were generally
completo, well maintained, and available. Rarely were
procedures and policies violated. However, ;ome cases of
personnel failure have occurred and these appear to be
associated with temporary employee hiring practices. Corrective
action on licensee identified violations was generally
effective.
A clear understanding of security issues was demonstrated and
subsequent decisions reflected reasonable and prudent judgement
on the part of management. These kinds of judgements were also
demonstrated in the Training and Human Relations Departments
where security's ancillary efforts, such as fitness for duty,
continual observation of employee's behavior, and the access
authorization programs were managed.
There has been a major organizational restructuring of the
Quality Assurance (QA) Department. The chanaes have been too
recent to evaluate their impact on the herett fore strong
security oversight effort. There is some concern that these
changes will not provide the level of audit expertise previously
provided. A review of these changes and the quality of the
audits performed will be necessary in the future.
The licensee has been usually responsive to NRC initiatives, but
there continues to be two long standing regulatory issues
attributable to the licensee. These are control room access and
alarm assessment capability. Technically sound and acceptable
resolutions were proposed initially in most cases, but
timeliness of resolution for these outstanding issues is slow.
After considerable discussion, the licensee agreed that their
CCTV system had degraded and proposed proper corrective actions.
One major violation concerning security personnel attentiveness
was directly attributable to a member of the security
, organization. It was promptly and effectively corrected. A few
l
minor procedural mistakes by security personnel have occurred,
'
but were not repetitive. These mistakes appear to be indicative
of a need to enhance the selection process for temporary
l
security personnel and to be persistent in programmatic
'
training.
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18
Occasional computer outage related events, construction / outage
worker misunderstandings of security requirements, and
maintenance related activities were attributable causes to
violations. These events were identified and reported in a
timely manner.
Security organization positions were clearly identified.
Authority and responsibility was clearly defined. This included
the relationship with the rest of the corporate organization.- A
new squad manning structure has allowed for training and
practice in squad response tactics. Temporary contract
personnel, while not meeting anticipated standards, have been
utilized to staff appropriate watchperson billets. However, the
employment practices used for these temporary watchpersons,
combined with their lower experience levels and abbreviated
training, appear to have had some adverse impact on the security
operation. It did accomplish the overall goal of providing
relief for the more experienced offi ers and to make them
available for more critical tasks.
2. Conclusions
The licensee appears to have an ample number of supervisors,
fully qualified security officers, and support personnel
assigned to the security department to comply with the several
security plans. With the exception of a few minor procedural
errors, the security force had operated at a high level of
performance. The 'icensee management's attention and
involvement with nuclear security is evident. Licensee
resources were appropriate and effective so that there was very
good performance with respect to site physical and personnel
security.
The licensee is considered to be -:, Performance Category 1 in
this area.
3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection level of the security program should be
consistent with the minimum inspection program, with some
exceptions. Exceptions where a more expanded inspection
effort is recommended include: licensee measures to
enhance and maintain physical security systems; methods for
selecting, training, equipping, posting and supervising
security personnel; and changes to the QA function where
audits are performed to measure the performance of the
security program and its ancillary efforts.
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19
b. Recommended Licensee Actions
The licensee should continue to probe the causative factors
of security events for broader implications and adjust
programs, training, disciplinary actions, maintenance, and
engineering responses appropriately. The organizational
adjustments made in the QA area should be closely monitored
to ensure that the high quality of the security oversight
program continues.
H. Outage
1. Analysis
The assessment of this area includes all licensee and contractor
activitiesassociatedwithmajoroutages. It includes
refueling, outage management, major plant modifications, repairs
or restoration to major components and all post-outage startJp
testing of systems prior to return to service.
This area was inspected on a continuing basis by the NRC
resident insp:ctors, and periodically by NRC regional
inspectors. In addition, an inspection was performed by a
safety system outage modification inspection (SCOMI) team. The
inspections included refueling activities, outo s management,
planningandscheduling, staffing,majorcomp.mnts/ systems
repairs and modification, and startup testing.
The licensee had two major outages during this SALP period.
There was a refueling outage which lasted approximately 101 days
and an outage to replace leaking reactor vessel 0-rings which
lasted approximately 16 days. Refueling outage activities
included replacement of Raychem splices, replacement of eroded
essential service water pipe, annual inspection of the diesel
generators, removai of heaters from Limitorque valve operators,
replacement of reactor coolant pump "B" number one seal,
replacement of the trip mechanism shafts on the reactor trip
breakers, replacement of the tube bundle in the jacket water
heat exchanger for diesel generator "A", rework of Valcor valve
operators, cleaning of condenser tubes and inspections for thin
wall pipes. There were numerous significant operational events
which were attributable to causes under the licensee's control
in this functional area.
There were four violations identified in this functional area.
Two of the violations involv.d escalated enforcement action and
a proposed imposition of Civil Penalty. There were two LERs
issued by the licensee in this functional area. The two LERs
were on events that resulted in violations being issued.
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20
The two violations that resulted in escalated enforcement
involved examples of procedural control weaknesses that the NRC
considered significant. These weaknesses indicate management
failed to provide an appropriate level of management oversight
of safety-related activities. This is evidenced by the examples
sited below as well as other areas in this report. Management
oversight of outage activities was less than adequate as pointed
out by the six examples of failure to follow procedures and four
examples of inadequate procedures listed in the escalated
enforcement package. The NRC staff was concerned with the
licensee's lack of indepth analysis of these events. The
licensee's ability to perform root cause analysis and implement
timely and appropriate corrective actions was a noted weakness.
During repair efforts on thin wall pipe due to erosion / corrosion
the licensee experienced some difficulty. The licensee had on
site a contractor workforce knowledgeable and experienced in the
forming, fitting, rigging, and aligning of heavy pipe. The
licensee decided to repair the thin wall pipe with their
permanent maintenance workforce. The maintenance workforce was
not as experienced in this area as the contractor workforce.
This resulted in significant problems due to failure to follow
procedures, failu.*e to follow work instructions, and failure to
accomplish work activities by appropriately qualified personnel.
Maintenance management failed to realize the scope of work was
beyond their expertise.
The licensee was generally responsive to NRC concerns, however,
there was a lack of aggressive response to identified problems
prior to NRC involvement. The licensee's investigation of
outage related events indicated a less than aggressive approach
to the resolution of technical issues. The 0-ring outage, which
was the second najor outage of the year, indicated that the
licensee failed to control the 0-ring cleanli ess. The licensee
decided to restart the plant after the first outage with known
inner 0-ring leakage.
2. Conclusions
The licensee's ability to plan, manage, and maintain control over
complex outage evolutions was inadequate and resulted in escalated
enforcement action. The licensee apparently failed to beli 2 in and
enforce strict procedural compliance. Aggressive management
involvement to address problems that occurred during the outage was
lacking.
The licensee is considered to be in Performance Category 3 in this
area.
_j
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21
3. Board Recommendations
a. Recommended NRC Actions
_
. Supplemental NRC inspections should be performed prior to
and during the next major outage.
b. Recommended Licensee Actions
The licensee should ensure that lessons learned from the
previous outages are identified and reviewed for program
improvements. The results of this review should be
incorporated into outage planning and control.
I. Quality Programs and Administrative Controls Affecting Quality
1. Analysis
The assessment of this area includes all management control,
verification and oversight activities which affect or assure the
quality of plant activities, structures, systems, and
components. This area may be viewed as a comprehensive
management system for controlling the quality of verification
activities that confirm that the work was performed correctly.
The evaluation of the effectiveness of the quality assurance
system is based on the results of management actions to ensure
that necessary people, procedures, facilities, and materials are
provided and used during the operation of the nuclear power
plant. Principal emphasis is given to evaluation of the
, effectiveness and involvement of management in establishing and
assuring the effective implementation of the quality assurance
prograa along with evaluation of the history of licensee
performance in the key areas of: committee activities, design
and procurement control, control of design change processes,
inspections, audits, corrective action systems, and records.
In order to more clearly define the specific strengths and
weaknesses noted in this functional area, the analysis is
divided into three areas, as discussed below:
f
a. Engineering
l
,
! This area has been inspected on a routine basis by the NRC
l resident inspectors and by a SSOMI team inspection during
( the assessment period.
I
The staffing in the engineering area is generally adequate
in terms of numbers, but it is weak in experience and
training. Further, the weaknesses identified by the 550MI
inspection are indications that the communications between
the plant operating staff and the engineering organizations
l
. .
22
were poor. In one case, engineering made a change to the
cooling system for an electrical equipment room,.which
required manual adjustment of a flow control valve to
adjust the temperature. Since the temperature in this room
was required to be maintained within a relatively narrow
range, a surveillance program to ve-ify the temperature
should have been instituted but was not. As a consequence,
the qualified life or performance of the equipment may have
been affected.
In another instance, it appeared that the operating staff
failed to ask for engineering guidance when performing a
maintenance activity that resulted in a deep discharge of
the safety-related station batteries and disablement of the
vital AC buses at the same time. This in turn led to the
introduction of lake water into the secondary side of the
The S50MI report includes a concern that appears to be
largely attributable to engineering since it involved a
failure to properly evaluate the effect of a temporary
modification. The modification involved application of a
clamp to keep a safety-related damper in the control room
emergency ventilation system open. Had actuation of the
damper been required, an operator would have had to remove
the clamp. The application of the clamp in such a manner
violated the intent of the Technical Specification for
system operability. There were also three LERs that were
at least in part attributable to engineering activities.
In each case, the LERs became necessary because there were
errors in design documents such as drawings,
specifications, and instrument set point data.
b. Quality Assurance
This area has been inspected by both the NRC resident
inspectors and regional inspectors. In addition, the SSOMI
team inspected the areas of procurement, material storage,
and audit activities.
There were two violations in the areas of procurement and
of material receipt. Additionally, some of the problems in
the management of the outage were related to QA.
The licensee had received, accepted, and installed a
noncode part which formed a portion of the reactor coolant
system boundary. An audit after the plant restarted
disclosed this, and subsequent waiver to the code was
granted.
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23
,
The reactor vessel head 0-rin'g seals were not correctly
inspected prior to installation. Although this was not the
major contributor to the 0 ring leak, it showed a tendency
for quality performance to be at pro forma level.
During the outage, there were problems with the weld
repairs to the essential service water systems. The'e
problems included the issue of inappropriate welding
materials and welders making welds for which they were not
qualified. These problems were uncovered by quality
checks, but the investigation revealed that QA had missed
several opportunities to identify the problems earlier.
The licensee's vendor audit program did identify a problem
with the certification of fuses purchased from a supplier.
lhe licensee reported the facts to the NRC. Follow up
action by the NRC resulted in the issue of an Information
Notice.
The licensee had not conducted training in root cause
determination. Corrective actions tended to be focused on
specific events and did not often probe for the underlying
causes. For example, when a four-way valve on the MSIV
actuator failed, the original root cause deter.nination was
not correct. The redesigned valve subsequently failed.
When incorrect fasteners were found in the charging pump
check valve, they were replaced. No determination was made
as to whether the problem was the fault of the fastener or
the valve manufacturer.
c. Management and Administrative Controls
This area has been inspected on a routine basis by NRC
resident inspectors and regional inspectors.
During this SALP period, the licensee realized the
existence of problems with safety-related pipe wall
thinning. NRC had two basic concerns with this issue. The
first concern was that the short term operability
determination of the thin wall pipe was not technically
sound in that it was made by plant management without input
from engineering. Management did not reassess system
operability even after engineering made the determination
that the pipe did not meet code requirements. Plant
management communications with engineering was not
adequate. The second concern was with long term corrective
actions. Plant management's narrow focus on the issue of
short-term operability showed that their understanding of
the issue was lacking. The question of generic application
of one thin wall pipe to other areas in the plant was not
addressed in a timely manner. It was not until these
i
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. -_ ____ _- _.
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24
issues were raised by Nuclear Safety Engineering and the
Nuclear Safety Review Committee that appropriate corrective
actions were begun. The operational response to this
problem was not timely and lacked thoroughness. The above
is one example of a lack of management involvement in
assuring quality. Other examples have been cited in other
SALP areas.
The enforcement history in the area includes seven
violations and no deviations. Four violations were related
to the environmental qualification of equipment. Ten LERs
were issued by the licensee in this area. Eight of these
LERs were related to control room ventilation isolation
system (CRVIS) actuations. Six of these were due to
problems with the chlorine monitors. The licensee has made
great strides in reducing the number of reportable events
due to CRVIS actuations; however, the reliability of the
chlorine monitors is still low. The improvement effort in
this area has been protracted. This has resulted in the
control room operators no longer trusting their chlorine
monitors.
2. Conclusions
The assessment of this functional area indicates that management
has not been effective in timely resolution of important issues.
Corporate management oversight of plant activities does not
always ensure adequate involvement of the quality and
engineering organizations in plant operations. When problems
are identified by the quality and engineering organizations they
are not always acted upon in a timely manner.
The licensee is considered to be in Performance Category 3 for
an overall rating of the SALP area of quality programs and
administrative controls affecting quality.
3. Board Recommendations
a. Recommended NRC Actions
Supplemental inspection effort should be devoted to this
area.
b. Recommended Licensee Actions
Increased corporate management involvement in site
activities is recommended. In particular, additional
corporate management involvement is needed to ensure that
proper engineering and QA involvement is maintained in all
activities.
. o
25
J. Licensing Activities
1. Analysis
During-the pre:,ent rating period, the licensee's management
participated effectively in assuring the quality of submittals
forlicensingactionsandinresponsestoNRCstaffrequests.
The licensee s reviews were generally timely, thorough, and
technically sound. The licensee's participation was evident in
the ATWS Rule (10 CFR 50.62) submittal which demonstrated that
the licensee appeared to adequately understand staff policies
and be able to make decisions based on adequate management
involvement. The licensee's submittal contained all of the
information that the staff requested for its review. An
appropriate level of management was present and significantly
involved at the review meeting held with the licensee, and the
licensee's technical presentations were technically sound.
The licensee management was involved and responsive during the
staff's review of WCNOC's request to remove the fire protection
program from the Technical Specifications. This licensing
action was the lead cause for generic technical specification
improvements and involved rapidly evolving staff requirements.
Because WCN0C involved its management in this review, they were
able to respond promptly to staff concerns to bring the review
to completion.
,
The WCNOC management has generally exhibited an adequate
understanding of the approach needed to resolve complex
technical issues involved in licensing activities. WCNOC's
June 16, 1987, submittal supporting analysis related to relaxed
outage time and increased surveillance intervals demonstrated a
clearunderstandingofthelicensingissuesinvolvedand
followed the staff s guidance exactly as provided in the related
generic documentation.
The quality and level of detail of the licensee's safety
evaluation summaries submitted pursuant to 10 CFR 50.59(b)(2)
are not always adequate to permit the staff to conclude their
acceptability. In some cases these summaries only provide a
brief description of the change followed by a conclusive
statement that the change does not generate an unreviewed safety
or environmental question; they dn not provide a summary of the
WCNOC safety evaluation that was prepared to support the change.
In review of WCN0C's submittal related to their inservice
testing program for pumps and valves, the staff met with the
licensee on September 8 and 9. During the meetings the licensee
agreed to revise their IST program in specific areas. However,
WCNOC did not make a number of revisions in their March 2, 1987,
Revision 6 resubmittal, as agreed to in the earlier meeting.
. _ _ _ _ _ _ _ _
. . . .
26
The failure to follow up on the agreed upon technical resolution
delayed the completion of the licensing action on the inservice
testing program.
The licensee had been generally responsive to NRC initiative
during this rating period, with few longstanding regulatory
issues being attributable to_the licensee.
On occasion, the licensee's response had not been adequate to
permit the staff to resolve the technical issue without the need
for additional interaction with the licensee. The staff's
review of WCN0C's submittal related to the main steam line break
outside of containment issue required multiple requests for
additional information, and the licensee's responses to these
requests were not expeditious.
.
The licensee reported 53 nonsecurity events to the NRC
!
operations center pursuant to 10 CFR 50.72. These events were
almost always reported in a timely manner.
The licensee also submitted 49 nonsecurity Licensee Event
Reports (LERs) during the reporting period. The LERs were well
written and almost always timely.
There have been 8 LERs during this reporting period that have
been caused by malfunctions or spurious actuations of the
chlorine monitors. These LERs follow up on 18 previous LERs
that have occurred since Wolf Creek was initially licensed.
This continuing series of LERs is indicative of a failure to
identify the root cause of these failures and an ineffectual
corrective action program for the chlorine monitor problems.
The plant has experienced seven unplanned scrams during this
rating period. All of the scrams occurred during Cycle 2 which
ended in September 1987. There were three Safety System
Actuations, no Significant Events and five Safety System
Failures during this rating period.
2. Conclusion
The licensee continues to maintain a competent, knowledgeable
'
licensing staff; however, during this rating period there were
occasional instances of lack of timely response to staff
requests and a decline in content of summaries of safety
evaluations submitted by the licensee in response to
10 CFR 50.59. The licensee is considered to be in Performance
Category 2 in this area.
_______.
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27
3. Board Recommendation
a. Recommended NRC Actions
None
b. Recommended Licensee Actions
The licensee should improve the quality of the safety
evaluation summaries submitted pursuant to 10 CFR 50.59 and
should improve the content of licensing submittals to
preclude the need for staff requests for additional-
information that could have been foreseen by the licensee.
K. Training and Qualification Effectiveness
1. Analysis
The assessment of this functional area includes all activities
relating to the effectiveness of tne training / retraining and
qualifications program conducted by the licensee's staff. This
area was inspected on a continuing basis by the resident
inspectors. This area was also the subject of an inspection
which was performed during the appraisal period to look into the
training of both the licensed and nonlicensed staff. During the
appraisal period, licensing examinations were administered by
the NRC to seven (7) reactor operator (RO) candidates and to
seven (7) senior reactor operator candidates. Five (5) of the
R0 candidates and six (6) of the SR0 candidates passed the
examinations and were subsequently issued licenses. The
licensee currently has 36 individuals who hold an SR0 license
and 15 individuals who have an R0 license. During the
administration of the above examinations, the examiners found
that the trainees had been adequately informed of the
significant events that had occurred during the week of
October 18, 1987. The trainees had also been schooled on the
lessons learned from these events.
The inspections in the operator requalification training area
indicate that the management oversight in this area has not been
sufficiently thorough. This is evidenced by:
The section of the procedure (ADM 06-224) on licensed
operator requalification training which relaxed a
requirement of 10 CFR 55 without Commission approval.
.
An operator who had failed the annual requalification
'
examination and was therefore reouired to enter into an
l accelerated requalification program was allowed to continue
j to stand watch and perform watch standing duties prior to
his completion of the accelerated training.
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The required reactivity manipulations had not been
completed in the 1985-1986 requalification cycle for at
least six licensed individuals. The correction of this
problem had not been formally addressed, but an informal
effort by the simulator instructors is to track the
performance of the manipulations by each licensed
individual.
During 1986, at least nine licensed individuals had failed
to review all of the emergency and off-normal procedures as
required by the requalification program. The licensee
revised the appropriate procedure to specify the aff-normal
and emergency procedures to be reviewed. The procedures
requested after the revision were also incomplete and the
procedure had to be further revised at the prompting of the
NRC inspector,
The licensee had not provided procedures for irplementing
the 10 CFR 55 rule change issued by the NRC on May 27,
1987.
The above examples are indicators that the training department
arrangement had not provided the attention tc detail necessary '
to assure adequate oversight of this area.
There has also teen evidence of inattention to detail on the
part of the training staff. Examples of this are:
minor uncorrected errors in the lesson plans that were
reviewed;
failure to have lectures scheduled for 10 CFR Parts 2, 21,
50, and 55 in the operator requalification program;
failure to revise a procedure to reflect a new requirement
instituted by a rule change; and
failure to delete a procedure requirement which was dropped
by a ruie change.
No deficiencies were identified in the area of training of the
nonlicensed staff. The procedures and policies in this area
were adequately stated and understood. Training records in this
area were generally complete and well maintained.
2. Conclusions
,
The initial training of licensed operators and the training of
! the nonlicensed staff is effectively controlled and the
licensee's performance in licensing examinations has been good.
The area of requalification training for licensed operators has
l
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29
suffered from an apparent lack of management oversight and
. inattention te detail on the part of the training staff. The
licensee is considered to be in Performance Category 2 in. this
area.
3. Board Recommendations
a. Recommended NRC Actions
The NRC inspection effort in this area should continue at
the level prescribed by the basic inspection program.
b. Recommended Licensee Action
The licensee should further emphasize the need for
oversight of operator requalification training and the need
for the training staff to be more attentive to details in
the performance of their activities. Licensee management
should continue their oversight and support of the training
of the nonlicensed staff.
V. Supporting Data and Summaries
A. Licensee Activities
Major Outages
. The unit was shut down on April 19, 1987. The cause was an
inadvertent trip due to control rod logic card f:ilures. The
outage duration was 13.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,
. The unit was shut down on April 23, 1987. The cause was an
inadvertent trip due to control rod logic card failures. The
outage duration was 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />.
. The unit was shut down on May 28, 1987. The cause was an
inadvertent trip due to a loss of power to the main turbine
electro-hydraulic control system. The outage duration was
22.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
. The unit was shut down on June 29, 1987. The cause was an
inadvertent trip due to a loss of a main feedwater pump. The
outage duration was 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />.
. The unit was shut down from July 20, 1987, to July 26, 1987.
The cause was an inadvertent trip due to a loss of a main
feedwater pump. The outage was extended to repair a containment
cooling fan. The outage duration was 129.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.
, --_ ___ _
. .
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30
. The unit was shut down on September 10, 1987. The cause was an
inadvertent trip due to a failure of a main transmission line. ;
The outage duration was 33.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />. ;
. The unit was shut down on September 27, 1987. The cause was an
inadvertent trip due to a mispositioned rod control switch. The
licensee decided to remain down and enter refueling outage II *
early. The outage duration due to the inadvertent trip was j
93.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The refueling outage duration was 2,418.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.
. The unit was shut down on January 21, 1988. The cause was a
manual shutdown to replace failed reactor vessel 0-rings. The
outage duration was 379.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. During startup following this
outage, two turbine trips without reactor trips occurred. The
duration of each of these two outages was 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.
B. Inspection Activities
NRC inspection activity during this SALP evaluation period included .
49 inspections performed with 6031 direct inspection manhours
expended. These inspections included team inspections of the
equipment qualification program and a SSOMI. This inspection effort
represents an approximate 50 percent increase over the previous SALP
period.
Table 1 provides a tabulation of NRC enforcement activity for each i
functional area evaluated. Table 2 provides a listing of inspection
findings in each SALP category.
C. Investigations and Allegations Review
There was one investigative activity conducted during this assessment
period. The results have not been formally issued yet.
D. Escalated Enforcement Actions
1. Civil Penalties
A Notice of Violation and Proposed Imposition of Civil Penalty
was issued on March 17, 1988. A $100,000 civil penalty was
proposed for two Severity III violations involving a failure to
follow procedure and a failure to have appropriate procedures.
2. Enforcement Orders
None
_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ ._ ___ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _
_
s- l4
-
31
E. Management Conferences Held During Assessment Period
1. Conferences
A management meeting was held on October-21, 1987, to discuss
the events which occurred during the refueling outage. An
enforcement conference was held on January 11, 1988, to discuss
violation which had occurred during the refueling outage.
2. Confirmation of Action Letters
None
- F. Review of Licensee Event Reports and 10 CFR Part 21 Reports
Submitted By the Licensee
1. Licensee Event Reports
The SALP Board reviewed the LERs for the period March 1, 1987,
through March 31, 1988. This review included the LERs listed by
SALP category in Table 3.
2. Part 21 Reports
There were no 10 CFR Part 21 reports submitted by the licensee
during this SALP assessment period.
,
4
4
!
l
L
. .
Table 1
Enforcement Activity
FUNCTIONAL AREAS NUMBER OF VIOLATIONS
IN EACH LEVEL
DEFICIENCIES / DEVIATIONS V IV III
A. Plant Operations 1
B. Radiological Controls 0/1 1 4
C. Maintenance 2
D. Surveillance 2
E. Fire Protection 1
F. Emerger.cy Preparedness 1/0 2 1
G. Security 4
H. Outages 1 1 2
1. Quality Programs and 1 9
Administrative
Controls Affecting
Quality
J. Licensing Activities
K. Training and 2
Qualification
Effectiveness
Total 1/1 7 25 2
._________ _-_ _ _
_
, ,
Table 2
ENFORCEMENT ACTIVITY-
TABULATION OF VIOLATIONS, DEVIATIONS, AND-
EMERGENCY PREPAREDNESS DEFICIENIES
PERFORMAN CATEGORY
A. Plant Operations
Violations
. Failure to enter Technical Specification 3.0.3 when both trains
of CRVIS were inoperable. (Severity Level IV, 87?0-01)
Deviations
. None
B. Radiological Controls -
Violations
. Failure to properly control, store and protect quality records.
(Severity Level V, 8708-01)
. -Radiation Protection Manager not fully qualified. (Severity
level IV, 8712-01)
. Failure to properly evaluate radiological surveys of two
,
contaminated persons. (Severity Level IV, 8728-01)
. Unauthorized disposal of contaminated material. (Severity
Level IV, 8736-01)
. Failure to lor;k high radiation door. (Severity Level IV,
8809-01)
Deviations
. Repeated failure to implement a continuous airborne monitoring
program. (8712-02)
C. Maintenance
Violations
! . Failure to comply with TS 4.0.5 by not obtaining a relief request
from NRC. (Severity Level IV, 8715-01)
. Three examples of failure to follow procedure. (Severity
Level IV, 8807-38)
_ _ - _____________ _ _
--
. . .
2
Deviations
. None
D. Surveillance
Violations
. Failure to demonstrate automatic isolation of the containment
purge pathway. (Severity Level IV, 8715-02)
. Failure to alternate starting locations for the motor driven fire
pump. (Severity Level IV, 8722-01)
Deviations
. None
E. Fire Protection
Violations
. Fire door inoperable by being blocked open. (Severity Level IV,
8706-01)
.
Deviations
. None
Violations
'
. Failure to document a communication test. (Severity Level V,
8714-01)
l . During an unannounced call-out drill, the communicators could not
l- be reached. (Severity Level IV, 8714-02)
. Repeat violation of a failure to meet call-out time limits.
(Severity Level V, 8812-01)
Deviations
. None
. _ - _ _ _ _ _ - _ _ _ _ - _ _ _ - . _ _ _ _ _ _
.. ,-
3
Deficiencies
. During an emergency plan exercise, an incorrect classification
was made. (8721-01)
G. .Segurity
Violations
. Failure to follow compensatory procedures. (Severity Level IV,
8716-01)
. Inadequate compensatory measures. (Severity Level IV, 8723-01)
. Failure to maintain assessment aids. (Severity Level IV,
8734-01)
. Failure to maintain control of security badge. (Severity
Level IV, 8805-01)
Deviations
. None
H. Outages
Violations
. Six examples of failure to follow procedures. (Severity
Level III, 8731-A)
If
. Four examples of failure to have appropriate procedures.
(Severity Level III, 8731-B)
. Two examples of inadequate procedures. (Severity Level IV,
8806-01)
. Failure to make inservice test log entries. (Severity Level V,
l
,
8811-02)
Deviations
. None
I. Quality Programs,
Violations
. Failure to have qualified electrical splices. (Severity
Level IV, 8724-01)
. _ _ _ _ _ _ .
.- u-
4
I
.
- Connection boxes mounted below post-accident containme d water
level. (Severity Level IV, 8724-02) i
(
. Space heaters operating in motor operated valves. (Severity.
Level IV, 8724-03) i
. Use of unqualified terminal blocks. (Severity Level IV, 8724-04) !
,
. Failure to evaluate temporary modification. -(Severity Level V,
8801-01)
. Inadequate acceptance criteria for reactor vessel 0-rings.
(Severity Level IV, 8804-01)
i
. Purchase order failed to specify code requirements. (Severity
Level IV, 8815-01)
'
. Purchase request did not document Spec levels. (Severity x
Level IV,8815-02) .
. Unqualified code boundary part. (Severity Level IV, 8815-03) (,
Deviations
.- None
is:
J. Licensing Activities
Violations
. None
Deviations
. None
K. Training and Qualification Effectiveness
Violatior l
. Failure to provide health physics retraining. (Severity Level V,
8717-01)
. Failure to maintain health physics training records. (Severity
Level V, 8717-02)
Deviations
L
, None
"
.
\
4
$
_ .-- __. _ _ _ . _ -- -.
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,
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'
' Table 3 '
'
-OPERATIONAL EVENTS
j pBULATIOROFLICENSEEEVENTREPORTS L)t
a qv
.
4 .,
PERFORMANCI CATEGORY
g.
A. Plant' Operations
3
L \d T
, ' Error while placing bis k switch in ' permit' results in aux.
.feedwater actuation. (87-013) ,
,
Failuretocommunicateallepedanopendoorcreatingapressure
boundarybreac( (31-034)
! . . ' Errors result in loss of< power to control rod moveable gripper
4 coils which causes a rea; tor trip. (87-041)
{'
'
. Error leads to Hi-Hi S/G level resulting in feed isolation ,
signal. (87-042) ,
!
B. Radiological Controls
. Inadvertert release of secondary liquid waste mbaitor tank
without pribe sampling. (87-036)
. Inadequate control results in loss of licensed naterial.
(87-056)' ,
. C. Maintenance
- . Logic cabinet cards overheated causing reactor trip. (87-017) J
. Containment purge isolation due to , signal spike on radia't'.'on
monitor. (87-019) ,
. Reactor trip caused by loss of power to main turbine '
<
electro-hydraulic control system. (87-022) !
. Reactor trip resulting from personnel error ftr not correctly
tightening instrument sensing lines. (87-027)
p \
. Potential transformer failure causes partial loss of offsite '
power and reactor trip. (87-030)
. Inoperable containment isolation valvh aue to incomp14.e
retestir.g following maintenance. (87-033) x ,
. High Voltage: transmission line failure causes generator
- trip /reactur '(. rip. (87-037)
,
. Accidental mispositioning of breaker switch causes inoperability '
,
of one power operated relief valve. (87-039)
l \
e ,
s +,
,I
.s
-
,
l
- - -. _ , _ _ _
,_ 'I
-/
'
-
.
/
.!
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.; I
. Omission of snubber from inspection procedure. (87-044)
. Inadequate hydrostatic pressure tests due to procedural
inadequacy. (87-045)
. Containment purge-isolation caused by moisture induced cc,rrosion
of an electrical connector. (87-054)
D. Surveillance
. TS violation caused by missed surveillance procedure. (87-014)
. Shaft seal on contd ament air lock failed during testing causing
total leakage above allowable. (87-023)
. Cor.tainment purge isolation due to personnel error during
radiatian monitor testing. (87-025)
Late performance of spent fuel building vent tritium analysis.
(87-026)
. Inoperable Class 1E batteries due to inadequate post-test review
of surveillance test. (87-028)
. Required testing deleted from surveillance procedures. (87-029)
. Failure to properly verify operability of fire pumps due to
procedural inadequac. '(87-038)
. Noncoaservative error in containment purge radiation monitoring
setpoint. (87-040)
. Surveillance ' power range low setpoint & P-8, P-9, and P-10
interlocks noi.' performed properly. (87-043)
. Containment isohtion valve failed during testing causing total
path leakage to be above allowable. (87-050)
. Procedural deficiency causes two feedwater isolations & an an eux
j feed actuation. (87-051)
. Procedural inadequacy resulting in TS violation. (87-060)
E. Fire Protection
l- . Four fire dampers not actuated ;ue to drawing error. (87-013)
. Failure to maintuin fire wutch as required by TS. (87-016)
l
. Hourly fire watch performed late due to personnel
error / individual overlookcd one impairment. (87-021)
l .
l
t
... . - - - - -
____ . _ _ _ - _ _ __ . _ _ _ _ _ - - _ _ - .
o. <.w
3
. Spent fuel pool heat exchanger room doors not 3-hour fire rated.
(87-031)
. Failure to fully' understand the requirements causes TS violation
for hourly _rather than continuous fire watches. (87-057)
. Wired glass insert discovered in fire door causes loss of 3-hour
fire rating. (87-059
. None
G. Security
. Unauthorized vital area entry. (87-046)
. Vital door unsecured. (87-047)
. Security officer inattentive to duty. (87-055)
H. . Outages
. Improper maintenance causes fatality. (87-048)
. Low battery bus voltage. (87-049)
I, Quality Programs and Administrative Controls Affecting Quality
. CRVIS caused by chlorine monitor spike. (87-012)
. CRVIS caused by paper tape bunching up on chlorina monitor.
(87-015)
. CRVIS caused by paper tape breaking on chlorine monitor.
(87-020)
. 'FA-CRVIS caused by loss of power to chlorine monitor because of
faulty sample pump. (87-024)
,
'
. CRVIS caused by paper tape breaking on chlorine monitor.
(87-032)
,.
L . CRVIS - two events caused by malfunctions of the chlorine
L
monitors. (87-035)
!
l . I strument termination splices installed which fail to meet
-
L v vironmental.qualificction requirements. (87-052)
. CRVIS caused by paper tape bunching up on chlorine monitor.
(87-053)
- ~ , . _ .-- _ _ _ _
.
, . -
4
. TS Violation, due to error in design document. (87-058)
. Radiation monitor spike causes fuel building ventilation
isolation. (88-001)
. Probable transient in power supply for radiation monitor causes
containment purge isolation. (88-002)
. CRVIS from chlorine monitor spike. (88-003)
. CRVIS from chlorine monitor spike. (88-005)
,