ML20198A700
| ML20198A700 | |
| Person / Time | |
|---|---|
| Site: | Hatch, 05000000 |
| Issue date: | 06/30/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20198A692 | List: |
| References | |
| 50-321-85-21, 50-366-85-21, NUDOCS 8511060138 | |
| Download: ML20198A700 (37) | |
See also: IR 05000321/1985021
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ENCLOSURE 1
SALP BOARD REPORT
U. S. NUCLEAR REGULATORY CCMMISSION
REGION II
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMEERS
50-321/85-21 AND 50-366/85-21
GEORGIA POWER COMPANY
EDWIN I HATCH UNITS 1 AND 2
NOVEMEER 1, 1983 THROUGH JUNE 30, 1955
hhj1060138051023
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ADOCM 050003 1
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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 informa-
tion.
SALP is supplemental to normal regulatory processes used to ensure
compliance with NRC rules and regulations.
SALP is intended to be suffi-
ciently diagnostic to provide a rational basis for allocating NRC resources
and to provide meaningful guidance to the licensee's management to promote
cuality and safety of plant construction and operation.
An NRC SALP Board, composed of the staf f members listed below, met on
September 17, 1985, to review the collection of performance observations and
data to assess the licensee performance in accordance with the guidance in
NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II of
this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Hatch for the period November 1,1983 through June 30, 1985.
SALP Board for Hatch:
R. D. Walker, Director, Division of Reactor Projects (DRP), Region II
(RII)(Chairman)
J. P. Stohr, Director, Division of Radiation Safety and Safeguards
(DRSS), RII
A. F. Gibson, Director, Division of Reactor Safety (DRS), RII
D. B. Vassallo, Chief, Operating Reactors Branch 2, Division of Licensing,
Office of Nuclear Reactor Regulation (NRR)
V. L. Brownlee, Chief, Projects Branch 2, DRP, RII
Attendees at SALP Board Meeting:
V. W. Panciera, Chief, Projects Section 28, DRP, RII
G. Rivenbark, Project Manager, Operating Reactors Branch 4, Division of
Licensing, NRR
- . Holmes-Ray. Senior Resicent Inspector, Hatch. DRP, RII
1. Nejfelt, Resicent Inspectcr, Haten DRP, RII
v. W. Branch, Acting Chief, Technical Support Staff (TSS), DRP, RII
T. S. MacArthur, Radiation Scecialist, TSS, DRP. RII
A. Belisle, Acting Chief, Quality Assurance Program Section, DRS, RII
. McGuire, Chief, Physical Security Section, DRSS, RII
W. E. Cline, Chief Emergency Preparedness Section DRSS, RII
J. Lenahan, Test Program Section, DRS, RII
P. Madden, Plant Systems Section, DRS, RII
K. P. Barr, Chief, Nuclear Material Safety and Safeguards Branch, DRSS, RII
S. D. Stadler, Opertions Program Section, DRS, RII
A. L. Cunningham, Emergency Preparedness Section, CRSS, RII
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P. G. Stoddart, Acting Chief, Independent Measurements and Environmental
Pretection Section, DRSS, RII
J. J. Blake, Chief, Materials and Processes Section, DRS, RII
B. T. Debs, Acting Chief, Operational Program Section DRS, RII
C. M. Hosey, Chief, Facilities Radiation Protection Section, DRSS, RII
II.
CRITERIA
Licensee performance is assessed in selected functional areas, depending
upon whether the facility is in a construction, preoperational, or operating
phase. Each functional area normally represents areas which are significant
to nuclear safety and the environment, and which are no-mal programmatic
areas. Some functional areas may not be assessed because of 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 in assess each
functional area.
A.
Management involvement and control in assuring quality
B.
Approach to resolution of technical issues from a safety standpoint
C.
Responsiveness to NRC initiatives
D.
Enforcement history
E.
Reporting and analysis of reportable events
F.
Staffing (including management)
G.
Training effectiveness and qualification
However, the SALP Board is not limited to these criteria and others may have
been used where appropriate.
Based upon the SALP Soard 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 involve ent are aggressive and orientec toward nuclear safety;
licensee rescu-ces are ample arc ef fectively usec so that a high level of
performarce with rescect to crerational safety c
const uction is being
achievec.
Category 2:
NRC attention should be maintained at normal level. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably effective
so that sa ti sf acto ry performance with respect to cperational safety or
construction 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 or construction is being achieved.
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The SALP Board has also categorized the performance trend over the course of
the SALP assessment period. The trend is meant to describe the general or
prevailing tendency (the performance gradient) during the SALP period. This
categorization is not a comparison between the current and previous SALP
rating; rather the categorization process involves a review of performance
during the current SALP period and categorization of the trend of
performance during that period only. The performance trencs are defined as
follows:
Imoroving:
Licensee performance has generally improved over the course of
the SALP assessment perioc.
Constant:
Licensee performance has remained essentially constant over the
course of the SALP assessment period.
Declining:
Licensee performance has generally declined over the course of
the SALP assessment period.
III. SUMMARY OF RESULTS
Overall Facility Evaluation
During this assessment period corporate and site management have continued
their strong commitment to the improvement of overall plant performance.
This has been evidenced by:
formation of a work control center; development
of a computerized commitment matrix; establishment of a steering and working
committee to review action taken on each scram; implementation of a
predictive maintenance program; use of the simulator to teach control room
disciplitte and plant operations; and the implementation of a system to
improve the scheduling of outage work.
There have been noticable improvements in the plant operations and quality
programs areas.
The surveillance area, fire protection, refueling / outages,
licensing activities, emergency preparedness, and security show acceptable
perfce ance, with the latter two areas showing a declining trend.
Strong
performance was cemonstrated in the area of radiological controls.
Areas
exhibitirg weaknesses include training are maintenance.
Weaknesses in
trainf rg were primary due to the unsatisfactcry licersed operator reaualifi-
catior crogram.
The maintenance area, wnica has sho.n an improving trend,
appears to be hincered by a large number of personnel and procedural errors.
Althou;n progress has been mace in the OrcDiem areas identified in the
previcus assessment period (adherence to procedure, personnel errors, and
identification and elimination of problem " root causes"), more attention to
detail would enhance the performance of all departments.
With the
facilities availaole and the programs in place at Hatch, improved plant
performance should be more evident. Continued management emphasis to ensure
improvement in the above mentioned problem areas is needed.
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Trend During
November 1, 1982 - November 1, 1983 - Latest SALP
Functional Area
October 31, 1983
June 30, 1985
Period
Plant Operations
3
2
Improving
Radiological Controls
2
1
Constant
Maintenance
3
3
Improving
Surveillance
2
2
No-e
Fire Protection
Not Rated
2
Nane
1
2
Ceclining
Security
1
2
Ceciining
Refueling / Outages
Not Rated
2
Nure
Training
Not Rated
3
Improving
Quality Programs and
3
2
Constant
Administrative Controls
Affecting Quality
Licensing Activities
2
2
Constant
IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
During this assessment period, routine and reactive irspections
were performed by resident and regional staffs.
Management involvement with plant operations continued at a high
level during this assessment period. Management review cf scram
causes prior to re-start improved as evidenced by the use of
formal critiques after each scram. These critiques were attended
by management and the course of action to determine the cause of
,
the trip must be reviewed and approved by management. The use of
critiques helped in determining the actual causes of plant trips
and proper corrective action prior to restart of the -eactor.
Personnel er cr ir the area of valve positioning cont'r;es to be a
problem, as it was curing tre previous SALP period.
~r ee viola-
,
tions for ir:r:rer valve alignment were citec during : 's assess-
ment period (viciations
f.,
g., and h.).
In the case c' sfolation
h. , dealing with atmospheric control system, valves c.
cf posi-
tion resulted in a reactor trip.
Responsiveness to Nuclear Regulatory Commission initiatives was
sound and tnorough. Management approach to safety con: erns was
good, with timely and prudent actions taken.
For example, on
February 3, 1984, while performing a Unit 2 torus inspection prior
to painting, the licensee discovered a through wall crack about
330 degrees around the circumference of the torus vent header.
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This crack was caused by cold nitrogen impingement curing the
inerting process (Violation a.),
When the cra:) was found in
Unit 2. Unit 1 was operating at rated conditions.
Management
ordered Unit 1 shut down for torus vent neader inspection even
though a differential pressure test showed no leakage and there-
fore, no significant cra:k. No cracking was fcund in Unit 1.
The
oriertation of the Unit I nitrogen inertin; line did not cause
nitregen impingement of the torus vent neader.
Therefore no
pipin; :nange was necessa y and the unit was returnec to power.
Tne use of the simulater produced an impre.ement in control room
discipline in that the shift sucervisor and the onshift cperaticns
supe visor received training that instilled the need for super-
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visier. of activities during abnormal events rather than involve-
ment in actual manipulation of the controls.
This improved
,
accuracy and timeliness of responses to su:n events.
The plant was clean and storage of material and equipment allowed
for access to plant areas necessary for maintenance.
Less
accessible areas (usually contaminated) tended not to be kept as
.
neat as areas easier to monitor. An effort, directed by manage-
nent, to reduce the number of areas which contain surface
centamination is (ngoing, this will result in more frequent
inspection of these areas. More plant walk-throughs by first line
and middle unagement have focused attention on plant house-
keep'.g.
It was noticed that many ladders were being left in the
piant ansecurec, not tiea of f, or in a "rc; ceing used" status.
Trese ladders wculd be::me missiles in a seismic event.
Ladder
ratss <ere installed tb:ughout the plant, the racks and ladoers
werc rumbered and instructions issued to prcperly store the
ladders or remove extra ladders from the reactor building af ter
use.
"c-t-f
room dereanor aas professional.
e wearing of unifer~s
,
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orteir ted tc the p*:'es sional appearante of tne control rec-
t
Tre
O' Cat) CDecators a 5] wear Darges whi:- display their assign-
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meet as reactor 00 erat 0<.
assistant react - trerator, etc. A: cess
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nei g ', : 0 , bet
- n cc:tston, somE ter:59:y t c a '. l c . - ;;;
rany :erscrnel into t e ::; orating area wai :bserved.
T9e ert a
cers:~el were often trainees, engineers :- cff duty operators.
n: . ac.ising raragere ; cf :nis cbsen st':n, a recu::1on c'
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persen el in tne cperating area of tne controi room occurrea.
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Du 'n; this assessment re-iod, cperator ;-ainirg was a problem
area and is ccvered in Sect on IV.J of this -ept-;.
The training
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prebi rs created a sta'fing challenge for tne licensee in that
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about half of the license holders were in training during the last
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half of the assessment period. The manager and superintendent of
coerations were often re sons acting in these pcsitions.
Despite
tnis lack of continuity in leadership, im:rovements in centrci
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Trend During
November 1. 1982 - November 1, 1983 - Latest SALP
Functional Area
October 31, 1983
June 30, 1985
Period
Plant Operations
3
2
Improving
Radiological Controls
'2
1
Constant
Maintenance
3
3
Improving
Surveillance
2
2
None
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Fire Protection
Not Rated
2
None
1
2
Declining
Security
1
2
Declining
Retueli.ng/ Outages
Not Rated
2
None
Training
Not Rated
3
Improving
Quality Programs and
3
2
Constant
Administrative Controls
Affecting Quality
Licensing Activities
2
2
Constant
IV.
PERFORMANCE ANALYSIS
A.
P7 ant Opere*icas
1.
Analysis
During this assessment period, routine and reactive inspections
were perfnrmed by resident and regional staf fs.
Management involvement with plant operations continued at a high
level during this assessnent period. Management review of scram
causes prior to re start improved as evidenced by the use of
formal criticues af ter each scram. These criticues were attended
by manage +ent and the course of action to determine the cause of
the trip rust be reviewed and app-oved by management. The use of
critiques helped in determining the actual causes of plant trips
and proper corrective action prior to restart of the reactor.
Personnelerrorin'theareaofvalvepositioningcontinuestogea
problem, as it was during the previous SALP period. Three viola-
tions for improper valve alignment were cited during this assess-
ment period (violations f. , g. , and h.).
In the case of violation
b., dealing with atmospheric control system, salves out of posi-
tion resulted in a reactor trip.
Responsiveness to Nuclear Regulatory Commi ssion initiatives was
sound and thorough.
Management approach to safety concerns was
good, with timely and prudcnt 1ctions taken.
For examele, on
February 3,1984, while performing a Unit 2 torus inspection prior
to painting, the licensee discovered a through wall : rack about
)
330 degrees around the circumference of the torus vent header.
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This crack was cat. sed by cold nitrogen impingement curing the
inerting process (Violation a.).
Knen the crack was found in
Unit 2. Unit I was coerating at rated conditions.
b'a n a gemen t
ordered Unit I snot down for torus vent neader inspection esen
though a dif ferertial pressu e test shewed no leakage and tre-e-
fore, no significant cract No cracking was found in Unit 1.
Tne
oriertaticn of the Unit I nitrogen inerting line did not cause
nitrogen i rp i n g e.,e n t of the terus vent header.
Tnerefore no
piping change was recessa y ard the unit was returnec to powe .
The use of the simulator prcduced an imorovement in control roc-
discipline in that the shift supervisor and the onshift epe atiers
superviso
receivec trainire that instilled the need for supe--
vision cf activities during abncrmal events rather than insclsc-
rent in actual manipulation of the controls.
This improved
,
accurac:, ano timeliress of responses to such events.
'
The plant was clean and storage of material and equipment allowed
for access to plant areas necessary for maintenance.
Less
accessible areas (usually centaminated) tended not to be kept as
i
neat as areas easier to monitor.
An ef fort, directed by manage-
ment, to reduce the num,rer of areas which contain surface
contaminaticn is cngoing, inis will result in more frequent
inspection cf these areas. Fore plant walk-throughs by first line
4
and micdle management have focused attention on plant house-
keeping.
It was noticed t at many ladders were being lef t in the
plant unsecured, not tied off, or in a "not Deing used" status.
Tnese ladcers would become rissiles in a seismic event.
Ladder
racks were installed throughc t the plant, the racks and ladders
were rumbered and instructicns issued to properly store the
ladders or remove extra lacders from the reactor building after
use.
Contro' room demeanor was p-ofessional.
The wearing cf unifer s
contributed to the crciess' oral aprearance of tne control roo ,
The on cuty operatcrs also wear bacges wnich display their assign-
ment as reactor operator, assistant reactor operator, etc. Access
centrol was gccc, bot upor. Occasion, some tendency to allow toc
many perscnnel into the ocerating area was observed.
Tne extra
personnel were often trainees, engineers or off duty operators.
Upc . acvising mara;ement c'
this obse vation, a reouction of
personnel in tne operating area of tne control room occurreo.
During this assessment pe-icd, operator training was a probler
'
area and is covered in Sect'en IV.J of this repcrt. The training
problems created a staf firg challenge for tne licensee in that
about half of the license holders were in trair.ing during the last
half of the assessment period. The manager and superintendent of
operations were of ten persors acting in these psitions.
Despite
this lack of continuity in leadership, improvements in centrol
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room discipline, event response and overall philosophy of opera-
tions were noted.
Setter use of procedures, better access
control, verification of parameters by use of redurdant instra-
ments, and shift supervisor's performance as a supervisor versus
operater during e, vents were examples of operations improvements.
Tne licensee's perfornance with recard to Licensee Event Reports
(LERs) was adeauate.
The licensee effectively used tne asailable
space in the abstract section of the LER anc t5e abstracts
correctly summarized the salient information of the text.
The
licensee correctly combined multiple events into a single LER in
accordance with the guidelines in NUREG-1022.
However, a numoer
of deficiencies in the LERs were also evicent.
A number of LERs
did not contain applicable cceponent failure inferr.ation in the
appropriate code area.
When failures were coded, some of the
subcoces were incorrect.
The licensee failed to include an
acequate assessment of the sa'ety consequences of the events in a
number of LERs and some of the reports failed to identify the root
cause of the event.
It r.ppeared that in certain instances the
root cause was not (;11y investigated.
Nine violations were identified:
Severity Level IV violation for
a.
admitting nitrogen to the
torus below specified temperature limits due to inadequate
procedures resulting in cracking the vent header.
b.
Severity Level IV violation for untimely (late) reporting of
engineered safety feature actuations,
Severity level IV violation for not
c.
performing drywell floor
drain leak rate calculation in a timely nanner resulting in a
delay in reccgnizing leakage in excess of technical specifi-
cation limits,
d.
Severity Level IV violation for operations with one automatic
depressurization valve inoperable and the
tior, of icw-low set
inadvertent actua-
.
s,a fe ty re li e f va l ve. logic with tne attendant lif ting of one
Severity Level IV violation for
e.
not
having
a procecure
established to impiement the minimum pressure / temperature
relationship for hydrostatic testing, non-nuclear heatup or
ccoldown and critical
Specifications.
operations as required by Technical
f.
Severity Level IV violation for personnel error resulting in
primary containment isolation valves being rendered inoper-
able due to tagging the wrong valves while hanging clearance
tags.
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r c Tt. distirline, event response and overall philosphy of ope-a-
tions we's noted.
Eetter use of procecures. tet .e r access
contrcl. serificatic'n of parartters by use rf recurcant instru-
cents, arc snift supervisor's performance as a supersisar versus
crerstre curing eserts were examples of opera 4 cts irprevements.
Tne litersee's perfer.mance with regard to Licensee Ever.t Repor.s.
(LERs) was a$eauate. The litersee effective') used the m ailable
space
'r
the abstract section of the LER a r.: the atstracts
corre:t') summari:+d the salient informatfor cf the text.
Tha
,'
licenses cc-rectly combined multiple events ir. : a single lER in
a:co ca :e witn tne guidelines in NUREG-lC22.
Hcweser. a r hrer
of deficien:ics ir the LERs were also evicent.
a number of LERs
did n:t ::ntain applicable cchponent failure i n fc rma ti on in the
appropriate coce ares.
When failures were ceded, some of the
succcces ae-e in:: te:tt
The licensee failec to inciuce an
acequate assessment of the iafety consequences cf the events in a
nu-ber of LERs and some ef.the reports failec to identify the root
cause cc ine event.
Il appeareo that in certain instances the
root cause was not fully investigated.
Nine vic'ations were identified:
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a.
Se.erity Level IV violation for admitti.g nitrogen to the
t:rus below specified temperature limits due to inadequate
prc:edures resulting ir-cracking the vert header.
b.
Seve-ity Level IV violation for untimely (late) reporting of
engineered safety feature actuations.
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c.
Se,erity Level IV violation for not performing drywell floor
,
craii leak rate calculation in a timely ranner resulting in a
ce' ) in re:rgrizing lcalage in excess c' technical spe:fft-
ca: cr, limits.
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5eserity Level IV violation for operations with one automatib
d.
decressurization valve inocerable and the inadvertent actua-~
t t :.r cf ica-iow set logi; with tne atterdant lifting of one
e.
Se.e-ity Level IV violation for
not
havieg
a procecure
establishea to impiement the minimym pre
- e/ temperature
relationship for hydrostatic testing, 'n:n-nuclear heatup or
cc;lcown and critical operaticns as re:uired by Technical
5; e t,i f i ca ti o n s ,
f.
Severity Level IV violation for personnel error resulting in
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prinary containment isolation valves being rendered inoper-
at'.e due tc tagging the wrong salves while hanging clearance
tags.
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Severity Level IV violation for improper diesel
generator
valve lineup.
h.
Severity Level IV violation for having primary containment
atmospheric control system valves out of position; resulting
in a reactor scram.
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Severity level V violation for failure to submit a licensee
event report within thirty (30) days.
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2.
Conclusion
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Rating: Category 2
Trend:
Improving
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Board Recommendations
The board acknowledges the licensee's management attention in
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improving this functional area from the previous SALP rating of
Category 3.
No decrease in licensee or NRC attention in this area
is recommended,
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B.
Radiological Controls
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I.
Analysis
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During the evaluation period, inspections were performed by the
resident and regional inspection staffs. This included confirma-
tory measurements using the Region II mobile laboratory.
The licensee's health physics staffing level was adequate and
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compared favorably to other utilities having a facility of similar
size.
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An adequate number of ANSI qualified licensee and contract
health physics technicians were available to support routine and
outage operations.
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As noted in the training section of this report, the licensee had
.
. an effe;tive general employee and specialized health physics and
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chemistry technician training program.
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Management support and involvement in matters related to radiation
}
protection was adequate. Health physics management was involved
sufficiently early in outage preparations to permit adequate
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planning. The manager of chemistry and health physics received
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the support of other plant managers in implementing the radiation
protection program.
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The performance of the health physics staff in support of routine
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plant operations was generally adequate. Health physics techni-
cians provided effective coverage of radiological work,
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Resolution of technical issues by the health physics staff was a
program strength.
During this evaluation period, the licensee disposed of 106,743
cubic feet of soli,d radioactive waste.
The national average
disposed of by a two Unit BWR site for 1983 was approximately
60,000 cubic feet. The volume increase over the previous evalua-
tion period was due in part to the licensee's continued effort to
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dispose of waste generated during the recirculation pipe replace-
ment outage.
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The licensee has implemented an effective program to reduce the
number of contaminated areas in the facility.
The number of
contaminated areas was reduced by approximately fifty percent.
Licensee management was adequately involved in radiological
controls and was generally responsive to NRC concerns.
The licensee's cumulative radiation exposure during 1984 was 2165
man-rem for both units; 900 man-rem of this total was attributed
to the recirculation pipe replacement outage.
This compared
favorably to exposures from other facilities of similar size and
operational activities. The average cumulative radiation exposure
for a BWR in the United States in 1984 was approximately 1000 man-
rem per unit.
The licensee's program to maintain radiation
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exposures as low as reasonably achievable was very effective in
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that significant plant maintenance was performed while the total
exposure for 1984 was approximately equal to the national average.
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The liquid and gaseous radioactive effluent' program was well
managed.
There were no unplanned or accidental releases during
the SALP period.
The radiological environmental monitoring program was well
managed. All required sampling and analysis schedules were met
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during this period.
The contractor laboratory quality control
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program met the general guidance in Regulatory Guide 4.15 and the
results of the En'i'onmental Protection Agency interlaboratory
vr
cross check program were acceptable. The environmental monitoring
program did not show any increase in radioactivity levels in the
-
environment.
The quality control program for environmental radiological
measurements met the general guidance of Dqu)atory Guide '4.15.
Licensee contractor results for gamma w urements of samples
split with the NRC~showed generally # t' F eement.
I
Radiological effluent sampling and mor%,ing (for liquid and.-
- gaseous effluents was generally acceptable.
Oiie violation was
identified in this area for inadequate calibration procedure for
radioactive -liquid ef fluent monitors.
It was noted that samples
of batch releases of liquid effluents were taken and analyzed for
,
!
!
-
.
.
_
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--
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, -
.
--.
. _ , , , , _
-
.
...
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-
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,
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I
radioactivity content prior to release of each batch; it was these
analyses which provided the principal control of liquid effluents,
with the effluent monitor acting to prevent inadvertent releases
of radioactive liquids that would exceed 10 CFR Part 20 limits.
,
,
With regard to the' chemistry area, the extensive down time
experienced during the last three years had been caused in part by
chemistry-related problems (e.g., cracks in Recirculating Water
lines, turbine blade degradation, and fuel rod degradation).
It
4
was evident that the licensee, at all levels of plant management,
was making extensive efforts to make the necessary repairs to the
recirculating water lines and to implement a continuing water
{
chemistry improvement program.
Positive results could be seen,
~
near the close of this assessment period, in the operation of the
major components of the plant where chemistry is controlled (e.g.,
reduction of the number of condenser tube leaks, greater effi-
ciency of the condensate cleanup system, and increased reliability
of the reactor water cleanup system). Similarly, the licensee had
upgraded its chemistry control program to be consistent with the
recommendations of the BWR owners group. The licensee had formed
a chemistry support group that focuses on numerous upgrading
efforts.
The chemistry staff had been increased to the extent
that contract technicians were no longer used.
A new plant
i
chemist haa been hired and state-of-the-art analytical chemistry
instrumentation had been acquired. The control of reactor coolant
chemistry was considered to be excellent near the close of this
assessment period.
The violations noted below 'were not indicative of significant '
'
programmatic deficiencies.
Three violations and one deviation were identified:
a.
Severity Level IV violation for inadequate calibration of
j
liquid effluen,t monitors.
!
.
.
b.
Severity Level IV violation for inadequate calibration of the
.
PCM-1 personnel contamination portal monitors,
i
-
-
.
c.
Severity Level V violation for failure to adhere to proce-
!
dures for routine sampling for unmonitored releases and
calibration of Geranium (Lithium) detectors.
-
d.
Deviation for inadequate calibration of two primary contain-
,
i
ment (drywell) high range radiation monitors on each decade
as recommended by NUREG 0737, item ~II.F.1, Attachment 3,
Table II.F.1-3.
F
4
,
.
-
-
.
-
-
_
_ _ _.
_ . _ . . _ .
._.
. _ _ . _ .
-
. _ . _ .
.
.
_
_
_
,
o
,
4
,
10'
4
l
2.
Conclusion
a
Rating:
Category 1
4
Trend:
Constant
4
,
i
i
3.
Board Recommendations
Performance in this area was evaluated as Category 2 during the
,
l
previous SALP assessment. Although the board noted the aggressive
effort in the water chemistry program, no decrease in licensee or
I
'
NRC attention is recommended.
2
C.
Maintenance
1.
Analysis
'
During this evaluation period, inspections were performed by the
3
resident and regional inspection staffs.
Due to a category 3 rating during the previous SALP period, the
licensee's overall maintenance program was undergoino revision
this assessment period. Procedures are being revised and upgraded
,
i
in content and format. An improved preventive maintenance program
was being developed and implemented.
A predictive maintenance
-
1
program was partially in place. A work planning group had been
formed and was functioning to improve job' planning and maintenance
i
~
work order (MWO) documentation and processing, and a computer
tracking system for MW0s had been implemented. -The maintenance
facilities were upgraded with the addition of skills training
,
!
laboratorie s.
Improvement was still necessary at the end of the
assessment period in adherence to procedures, proper assignment of
'
functional testing.following maintenance, proper identification of
" root causes", and quality control involvement.
Adherence to proce'dures remained weak during this assessment
period as indicated by the large number (10 of 15) of procedure
'
related violations.
The procedure adherence problems included:
- perforr.ance of work without proper documentation -(violation
a.,
1
f., and o.); not following procedures (violation c. , d. , e. , g. ,
j
and h.); and failure to provide a procedure when required (viola-
i
tion m.).
All of these violations .had as a root cause personnel
'i
error.
Ensuring that each person involved in the activities of
Plant Hatch feels responsible for doing the proper thing every
time, still remains a problem to be solved. Most violations would
.not have occurred had more attention to the details of the job
.
j
been applied.
.
^
'
V
i
4
&
'
. . . _ . , , _ . . . _ , , . _ . _ _
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11 '
Inadequate functional testing was evidenced by the return to
service of a residual heat removal system testable check valve
with the air lines reversed and the electrical leads arranged such
that the position indication showed open with the valve shut.
This event also indicates a lack of sufficient Quality Control /
Quality Assurance
'( QC/QA) .
Another example of inadequate
functional testing and inadequate QC/QA after maintenance was seen
when during the January 13, 1984 startup, it was found that one
automatic depressurization system valve had been returned to
service without being restored to an operable condition.
Reviews of MW0s revealed problems in identi fying " root causes"
Actions taken to correct deficiencies were usually limited to
those required to effect repairs and not to those required to
determine the root causes of the failures. An example of this was
when a recirculating system pump seal failed, the seal was
replaced, but not until another failure occurred was the cause of
the failure aggressively pursued.
Inadequate pump venting was
identified as the cause.
Involvement of the QC/QA organizations in maintenance activities,
was at times, inadequate as evidenced by inadequate inspections of
masonry wall modifications (violation k.) and improper QC of valve
assembly (violation m.).
In the area of electrical maintenance activities, NRC inspections
were conducted of the electrical QA program controlling the
activities of an outside contractor in conjunction with the
replacement of Unit 2 recirculation piping. A second inspection
examined conditions relating to an LER concerning unlanded /lif ted
electrical leads and cable separation in safety related panels.
In both inspections it was determined that the deficiencies had
been the result of the failure to follow procedures during modifi-
cation activities.
It was noted during both inspections that the
same deficiencies had been identified by the licensee and timely
and proper corrective actions taken. Onsite management had taken
a very active part 'in' the development of the corrective actions.
- During ,the evaluation period, inspections were also performed
relative to repair of intergranular stress corrosion cracking
(IGSCC) in the recirculation system, residual heat removal (RHR),
and reactor water cleanup system piping. All inspections were in
the areas of overlay welding (Unit 1) and pipe replacement
(Unit 2).
During the recirculation pipe replacement for Hatch 2,
key positions for the pipe replacement project were identified and
authorities and responsibilities were formally defined.
These
actions permitted the work to proceed in an ' efficient and
ef fective manner. The repair activities were reYiewed daily and
- -
- -
-
-
.
_
___
_ ._
.
_
.. .
.
<
.
'
s
<
12
management involvement was at a high level. The repair activities
I
were managed from the corporate level; therefore, corporate
management was heavily involved in site activities.
Engineering
analysis and reviews were timely, thorough and technically sound.
4
Records were generally complete, well maintained and available.
Understanding of technical
issues was apparent.
Resolution of
technical issues was timely and viable; sound, and thorough
j
approaches were used.
i
Fifteen violations were identified:
3
1
i
a.
Severity Level IV violation for performing work without
documented instructions, procedures or drawings appropriate
to the circumstances.
k
b.
Severity Level IV violation for failure to restore the plant
.,
1
service water system to original design requirements.
1
]
Severity Level IV violation for failure to follow procedure
c.
resulting in removal of snubbers from an operating residual
heat removal system.
i
-
d.
Severity Level IV violation for not properly implementing a
calibration procedure covering the low-low-set reactor
instrument functional test resulting in valves not being
properly aligned during system restoration.
,
i
e.
Severity Level IV violation with three . examples of not
l
properly implementirg procedures as evidenced by personnel
!
errors.
t
f.
Severity Level IV violation for failure to obtain a clearance
!
when required,
'
!,
resulting in a reactor. scram when a safety
i
parameter display system (SPDS) level transmitter was
]
improperly equalized.
,
i
Severity Leve~1 'IV violation for failure to follow procedure
g.
resulting in improper weld material being used.
h.
Severity Level IV violation for failure to follow procedures
,
!
resulting in -an inoperable automatic depressurization system
valve.
i
i
1.
Severity Level IV violation for improper incorporation of
l
cesign change request information resulting in an inadvertent
initiation of a safety relief valve.
,
i
l
j.
Severity Level IV violation for improper calibration of
4
i
precision measuring equipment.
- . _ .
-
_ _ _ _ . . _ . . _ . . . , . . _ . . _.-- _ ._._ _._ ___, _ ,._ _ , ~ ._ _ _ __
,
,
.
13 '
k.
Severity Level V violation for an inadequate inspection of
masonry wall modifications.
1.
Severity Level V violation for failure to provide a procedure
for calibration, of automatic welding equipment.
m.
Severity Level V violation for improper maintenance and
quality control practices while performing work on the high
pressure coolant injection system.
n.
Severity Level V violation for failure to provide correct
undercut acceptance criteria for American Welding Society
o.
Severity Level V violation for improper documentation of
expansion of maintenance work.
2.
Conclusion
Category:
Category 3
Trend:
Improving
3.
Board Recommendations
The board recognizes the licensee's effort in development of
additional programs to correct performance in this area. However,
an improvement over the previous SALP rating of Category 3 has not
yet occurred. The board recommends increased licensee management
attention in the area of procedure adherence, as well as
continuing with the increased inspection effort in order to
closely monitor the effectiveness of the licensee's program.
E
D.
Surveillance
1.
Analysis
During the assessment period, inspections were performed by
resident and regional staffs.
Inspection of activities related to post-refueling startup testing
and surveillances were conducted following the return to service
of equipment that was repaired or modified during the recircula-
ting pipe replacement outage.
The surveillance procedures
reviewed, those tests which were witnessed and the examination of
selected test results
indicated that the procedures were
technically adequate, properly followed and co'mpleted satis-
factorily.
V
l
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._
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.
.
.
14'
Licensee response to NRC initiatives was timely and there were few
long standing regulatory issues attributed to the licensee.
Viable, sound, and thorough responses were offered. For example,
when the application of the plus or minus 25% grace period, as
stated in Unit 1 Te,chnical Specifications (TSs), was found to be
misapplied the licensee reprogrammed the surveillance data base to
remove the minus 25%. The inspection in which the error was found
was conducted early in May 1985, and the data base changes were in
place by June 10, 1985.
The program for reviewing, testing, and controlling computer
software use in surveillance was inspected and it was found to be
a major strength in the surveillance effort at Plant Hatch. The
licensee had encountered some problems with this computer based
system.
Failure to maintain the data base current with TSs
resulted in a missed surveillance when the frequency of the
surveillance was changed by a TS amendment.
The change was
partially incorporated into the data base but not completely
(violation a.).
Inadequate or no procedures written resulted in
surveillances required by TSs not being properly documented
(violation c.
and e.).
The application of the grace period
allowed by TSs (unit 1) was found to be in error, which resulted
in the computer generated required dates for surveillance being
inaccurate (violation f.).
The performance errors, such as
improper performance of a surveillance procedure, are discussed in
the operations or maintenance sections of this report as appli-
cable.
This program remains a fine system; however, as seen by
the violations in this area, more attention to maintaining the
system is necessary. The licensee has in progress a major effort
to review all TS requirements, line by line, to ensure all
surveillance requirements are covered by procedure and then to
ensure the technical adequacy of each procedure.
The personnel
assigned _this task.are well qualified in that they are selected
from the most experienced senior reactor operators and shop
personnel.
,
Management was actively involved in assuring the quality of
snubber surveillance activities as evidenced by well defined
- p rocedure s',
adequate staffing -and adequate training.
surveillance records were found to be complete, well maintained,
legible and retrievable.
One problem was identified in that the
tables in procedures listing safety-related snubbers were not
current.
Licensee engineers were aware of this problem and were
in the process of updating the procedures during the inspection.
This problem was caused by plant modifications being implemented
-under_ design change requests which had not been closed out.
The NRC evaluated the licensee's program for inssrvice testing of
pumps and valves in addition to inspecting the 1 ~ ensee's imple-
menta tion' prograr... The licensee was very responsive to resolving
problems identified during inspections.
f
o
.
15*
Overall, the surveillance program is a viable one, and with the
completion of corrective actions necessary to ensure the accuracy
of the data base, the types of errors seen during this SALP period
should be minimized.
Violations, as note'd below, were not repetitive and were not
indicative of a programmatic breakdown.
Corrective action
appeared to be timely and effective for the violations identified.
Six violations were identified:
a.
Severity Level IV violation for improper maintenance of
surveillance frequency resulting in missed surveillance.
b.
Severity Level
IV violation for not having established
written procedures covering surveillance requirements on
safety-related systems (three examples).
c.
Severity Level IV violation for failure to properly implement
the battery pilot cell surveillance procedure.
d.
Severity Level V violation for having a test procedure for
molded case circuit breakers not in accordance with TSs.
e.
Severity Level V violation for failure to show the extent and
location of the area inspected in the ultrasonic inspection
records for the " Fall 1982" inspection of the reactor vessel
f.
Severity Level V violation for allowing a surveillance test
schedule to be established which permitted test performances
to exceed the 25% extension of time interval allowed by
Unit 1 TSs.
.
2.
Conclusion
Category: 2
Trend:. None
3.
Board Recommendations
Performance in this area was evaluated as Category 2 during the
previous SALP assessment.
No decrease in licensee or NRC atten-
tion in this area is recommended.
.
- -.
-
_ -
-
.-
. _ -
-
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.
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E.
Fire Protection
i
j
1.
Analysis
,
)
During this assessment period inspections were performed by the
j
regional and resident inspection staffs.
An inspection of the
l
site fire protection / prevention program and permanent plant fire
l
protection features was conducted by the Regional Based Staff.
The NRC reviewed a sample of the licensee's fire protection
Technical Specification surveillance procedures, evaluated the
l
fire brigade training program and assessed the readiness of
various permanent plant fire protection features.
.
The fire protection surveillance procedures which were reviewed,
,
identified the necessary inspections and test instructions
i
required to meet NRC fire protection guidelines and the surveil-
}
lance requirements of the plant's Technical Specifications.
t
The licensee's fire protection staff appeared to be thoroughly
familiar with the technical requirements of the NRC's fire
,
protection guidelines with regard to fire brigade training and
l
organization.
This was exhibited by the comprehensive fire
brigade ' training program which the licensee's fire protection
j
staff had developed and implemented.
j
In addition, the permanent plant fire protection features were
4
found fully operational and appeared to be properly maintained
,
except for the degraded conditions associated with the Nelson
l
Frame type fire barrier penetration seals located in the cable
j
spreading / reactor building wall and the underground fire water
i-
distribution system.
However,
the licensee
initiated the
j
necessary corrective actions to restore the Nelson Frame fire
barrier penetation. seals and the underground fire water distribu-
i
tion system to their full functional condition.
The events
associated. with the Nelson Frame fire barrier penetration seals
,
and the underground' fire water di.stribution system were promptly
!
and completely reported.
i
- In general, management involvement and control of the normal
routine ~ fire protection program was adequate and problem areas
were generally resolved in a timely manner.
One violation was identified:
'
4
4
Severity Level V violation for failure to follow inspection
instructions required by fire protection surveillance proce-
dures.
~
,
I
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}
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i
i
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- -
-
- - - - -
-
- -
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,
,
1
17
2.
Conclusion
Category.
2
Trend:
Nene
,
3.
Board Recommendations
Performance in this area was not rated during the previous SALP
assessment. No decrease in licensee or NRC attention in this area
is recommended.
F.
1.
Analysis
During the assessment period, inspections were performed by
regional and resident inspection staffs. These included observa-
tion of a small-scale exercise and two routine inspections.
Two
revisions to the licensee's emergency plan were reviewed.
A routine inspection disclosed that operations supervisors were
able to promptly detect and classify emergencies, but they were
unable to determine appropriate protective action recommendations
in a timely manner.
The inspection showed that the operations
supervisors had to refer to several precedures in
attempting to
make recommendations and were unfamiliar with the applicable
principal
procedure.
Based on this finding, the licensee
committed to a prompt retraining of operations supervisors in this
area. The ability to make prompt protective action recommenda-
tions was subsequently demonstrated during a small scale exercise
and in walk-throughs.
'
Otter than training
in protective action
recomendations,
pe scarel assigaed te the emergency orga * cations appea ed to be
acequateiy trained' in requirec areas of emergency response.
Trainino records of crerations sucervisors documented that
training was concuctec consi stent witn tr,e emergency plans and
- procedges.
Irdivicuals were cognicant cf their responsibilities
and authorities, and demonstrated understanding of their assigned
emergency resorase c; ties and furcticas. These assigned emergency
response functions during the exercise performed their duties
adequately.
It was noted that the trocedure for making protective action
recommendations was not consistent with federal guidance in that
it did not include a protective action recommendation immediately
following declaration of a general emergency, And it did not
conform tc federal guidance for protective action recommendations
for certain core melt sequences
The licensee revised the
procedure to conform to feceral guidance and retrained staff on
tne precedure.
-
- -
-
-
.
. -
-
-
-
-
.
--
-
-.
_-
.-
- -
- .-
-
-
,
,
.
18*
1
.
1
The licensee's program for shift staffing and augmentation
j
considered road distances and conditions in assuring that onsite
!
staff could be augmented promptly in the event of an emergency.
This program for augmentation was adequate to assure sufficient
.
,
staffing in an eme,rgency.
The corporate emergency planning
!
,
organization provided support to the plant.
Contractor support
was of ten used for emergency preparedness training and exercise
'
!
development. . An individual onsite was assigned the duties of an
emergency preparedness coordinator.
i
j
The licensee's notification procedures and communications systems
were adequate and equipment was adequately tested, although the
,
licensee did encounter difficulty in retrieving some records of
,
I
communications checks.
During the exercise, communications to
j
local offsite agencies and within and between the licensee's
emergency facilities were adequate, although the Operations
+
Superintendent was personally involved .in such notifications
i
.,
during the exercise rather than delegating this function to the
i
control room conmunicator. Had this delegation been made, the
l
Operations Superintendent could have better overseen resolution of
'
plant problems simulated for the exercise.
The licensee's post
accident instrumentation was adequate to support the needs of
projected emergencies. Staff demonstrated the ability to use this
j
emergency instrumentation during the exercise.
!
l
Although there were some minor inconsistencies in the scenario,
j
the snall scale exercise demonstrated that the plan and required
!
procedures could be effectively implemented by the licensee's
l
staff.
During the exercise, several areas for improvement were
!
j
noted by the NRC and the licensee.
I
!
Corporate and plant management appeared to be committed to
maintenance of an . effective emergency response plan and was
directly involved in the exercise and critiques. The licensee had
been responsive to most NRC initiatives on emergency preparedness
l
issues.
One except' ion to this was lack of timely response to an
- l
IE Notice issued in ~1983 concerning protective action decision-
{
making during emergencies.
This matter was discussed with
- license,e representatives following issuance of the notice;
j
however, the licensee failed to incorporate the notice information
i
in emergency plan implementing procedures.
The failure to be
responsive to this issue contributed significantly to the
j
violations specified below.
!
i
The . violations identified are not indicative of a programmatic
breakdown.
4
i
d.
,
,
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. . _ . , - - - _ . . . . _ , _ . _ . , , _ . . . - . . . . . , . . - .. _ . _ _ , , , - - _ m
_. , - ... ,, _ -,..,, _ .,_. - ,.. _ . , - _ _
-
1
.
.
.
,
19'
Two violations were identified:
a.
Severity Level IV violation for failure to maintain a
training program sufficient to assure licensee employee's
ability to make protective action recommendations.
b.
Severity Level IV violation for failure to develop a range of
protective actions consistent with federal guidance.
2.
Conclusion
Category:
2
Trend:
Declining
3.
Board Comment
An inspection conducted shortly after the assessment period
substantiated a decreasing trend in the quality of licensee
performance in emergency preparedness.
In addition, the most
recent exercise, conducted August 6-9, 1985, also shortly after
the appraisal period, showed a decrease in the quality of
performance.
Although the Board found the licensee's performance
to be a Category 2, the decline in quality of the program warrants
management's attention to preclude further degradation in imple-
mentation of the emergency preparedness program.
No decrease in
NRC attention to this area is recommended.
G.
Security
1.
Analysis
During the assessme,nt period, inspections were performed by the
resident and regional inspection staffs.
There was evidence 'of prior planning by site personnel which
usually included corporate level management.
Solutions to most
technical safeguard problems were generally sound and timely,
. indicatjng an understanding of the issues.
However, resolutions
were not implemented promptly in some cases as evidenced by the
repeated violations in the area of access controls.
Two security events were reported to the NRC during the assessment
period which resulted in escalated enforcement actions.
Both
events reflected deficiencies in the area of access controls to
the facility.
The first event, which resulted in a Severity
Level III Violation, concerned an employee gaining' access into the
protected area, and subsequently into a vital area without a
security badge.
The second event concerned an inadequate search
i
(
___
_ _ _ _ _ _ _ . - _ _ _ _ - _ - - - _ _ - -
.
,
,
20
which resulted in the undetected introduction of a small hand
weapon into the protected area.
This event was evidence of a
continued weakness in the area of access control and resulted in
the imposition of a civil penalty.
Had the licensee devoted
sufficient attention to this area, the second violation may have
been prevented.
In response to NRC concerns regarding the events, the licensee
provided corrective actions to each violation and initiated a
program to evaluate and improve the effectiveness of the access
control system which included conducting periccic crills to test
the effectiveness of access controls features.
In addition, the
licensee purchased and installed additional equipment for use in
processing personnel and equipment into the protection area.
However, the access control facility is small and becomes very
congested during peak traffic periods.
Installation of the
additional equipment further limits available space for processing
personnel into the protected area.
The limited space within the
access portal is a detriment to positive access control during
high traffic periods.
The security organization was adequately staffed and equipped, and
during the latter part of the assessment period, additional
security ranagement positions were authorized and filled.
There
was evidence that this action enhanced the ef fectiveness of the
security force operations.
Further, a change in the security
force work schedule to 12-hour duty tours, which provided longer
rest periods between duty tours, appeared to have a positive
effect on the morale and performance of station security
personnel.
Three violations were identified:
a.
Seve-ity Level III violation for allowing an employee to
inrcperly gain access into the protected area and a vital
area.
b.
Sever'ty Level III violation for allowir; the introduction of
an crauthorized weapon into the protectec area,
c.
Seve-ity Level IV violation for inadequate testing of intru-
sion alarm systems.
2.
Conclusion
Category:
2
Trend:
Declining
_
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. .-
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.
,
t
21
3.
Board Recommendations
Performance in this area was e valuated as Category 1 during the
previous SALP assessment.
Additional management attention is
needed to ensure positive access controls are implemented to
i
correct the significant decrease in performance in this specific
aspect of security.
H.
Refueling /Catages
1.
Analysis
During the assessment period Units 1 and 2 under went refueling
outages. Both the regional based and resident inspectors observed
refueling operations.
Management commitment to system oriented planning and scheduling
resulted in improved outages.
This commitment was seen in the
establishment of a work control group to provide for more
accurate, timely, and complete control of maintenance work order
processing from initiation to clearance. Management emphasized
the need for better work definition and scheduling and required
more stringent adherence to schedules. The results of this effort
could be seen in the last Unit 2 outage which was scheduled for 54
days and was completed in 45 days.
Corporate and plant management involvement during the recircula-
.
tion piping outage was noted by their attendance at the daily
planning meeting conducted on site.
On October 6,1984, a fuel bundle was dropped about 12 feet into
'
its storage position in the spent fuel pool due to inadvertent
operation of the grapple release switch.
This maloperation was
possible because the safety ccver was missing. No adverse radio-
logical results were observed.
The bundle was not reloaded into
the core.
Tha safety cover over the switch was instelled.
During the Unit 2 refueling, the new fuel was loaded into the fuel
pool such that the locations expected were pair reversed in actual
lccation. This reversal errcr was discovered by the licensee when
an assembly being loaced into the core was not the expected serial
number. A complete core verification found one assembly (new) nut
in the expected position. A nuclear physics problem did not exist
since all new fuel assemblies were of equal enrichment.
The
licensee's program for core verification discovered this error and
the documentation for the assembly location was revised to reflect
the actual loading.
'
-.
. - -
-
.-
. .
. - -
-
. _ .
_. -
-
-
1
.
,
-
22
During the Unit 1 fuel inspection, following the end-of-cycle
seven core, the licensee determined that a fuel rod was bowed to
the extent that it contacted an adjacent fuel rod. An engineering
review had determined that there was no significant safety hazard
associated with this occurrence.
The licensee's approach to the
resolution of this technical issue was satisfactory.
A defined training program was implemented for a large portion of
the refueling crew.
Initial preparations and conditions were
satisfied prior to refueling in accordance with licensee and NRC
requirements. Controls were in place to assure that all foreign
material had been removed by thorough wiping with clean lint-free
cloths.
No violations or deviations were identified.
2.
Conclusion
Category:
2
Trend:
Ncne
3.
Board Recommendations
Performance in this area was not rated during the previous SALP
assessment.
The board considers the two problems noted during
fuel handling as not being indicative of a strong refueling
program. However, the board does note that the licensee exhibited
,
agressive effort in the area of refueling outage control .
No
decrease in licensee or NRC attention is re:o- ended.
4
J.
Training
1.
Analysis
During the assesscent period,
- pections were performed by the
regional 5"d resident inspection staffs.
!
In Septe :er 1954 nine reactor operators reqsalification examina-
tions were administered with seven operators (7E'.) passing and
fourteen senior reactor operator requalification examinations were
administe ed with five senior operators (36'.) passing.
These
examinatiens resulted in the unsatisfactory rating for the
requalification program and subsequent imolenentation of the
accelerated requalification
training
program.
Two
special
i
inspections were conducted to review the implementation and
ascertain the adequacy of this accelerated requalification
training program.
The first inspection was conducted in December
1984.
Both classroom and simulator training were observed;
operators, instructors, and management personnel were interviewed;
and the revised training materials, including lesson guides,
-.
--
-_
-
.
- - - - _ - . .
.-
--
. . . -
'
.
.
.
23
procedures, and examinations were reviewed.
Training program
improvements were made in response to findings during this
inspection.
In February 1985, the second inspection was con-
ducted. Again, classroom and simulator training was observed and
interviews were conducted.
This inspection also included an
in-depth records review. Three violations were identified and are
noted at the end of the section.
This training program was
,
'
completed after the SALP evaluation period on July 15, 1985.
Based upon the NRC determination that the Hatch requalification
program was unsatisf actory, Georgia Power will submit for NRC
approval, the requalification program which will be initiated
after completion of the accelerated requalification program.
Approval of this program is expected by early November 1985.
,
In March 1985, selected licensed operators who had completed the
licensee's accelerated training program were administered NRC
i
!
requalification examinations.
Five licensed reactor operator
examinations were administered with five operators (100*;) passing
and seven senior reactor operator examinations were administered
with four senior operators (57';) passing.
Additional requalifi-
cation examinations were administered by the' NRC in July 1985.
Three licensed reactor operator examinations were administered
with two operators (67';) pass'ng and eight senior reactor operator
examinations were administered with six ( 86*;) passing.
The
effectiveness of the new accelerated training program was
reassessed upon completion of this further testing.
This assess-
ment determined that the corrective actions by the licensee were
adequate and the knowledge and performance of licensed operators
were substantially improved by the accelerated requalification
training.
Results of cperator licensing replacement examinations admin-
,
istered by the NRC during this period were as follows:
ten
'
reactor operator replacement examinations were administered with
i
eight candidates (80'.) pass'ng; fourteen senior operator replace-
'
ment examinations were ac- histered with twelve candidates (86',)
passing.
These results a e slightly above industry averages for
replacement examinations.
With respect to maintenan:e training, the licensee's instructional
aids and laboratory facilities for training in the areas of
electrical, mechanical and :&C maintenance were considered to bc
exemplary, with extensive f acilities provided for pump and valve
maintenance training.
Ne fermali:ed on-the-job training program
had been implemented for maintenance personnel.
This should be
resolved upon development of a performance-based training
methodology which meets INPO accreditation standards.
l
. -
-
-
-
-
- -
'
.
.
.
24
At the close of the assessment period, the licensee did not have a
formal training program developed for support engineers; however,
initial development was underway. Some support engineers attended
the maintenance plant systems course on a limited basis, but the
level of instruction was only commensurate to that needed by a
mechanic or technician.
The licensee's general employee training was considered to be
effective. The facility guard qualification and training plan was
implemented on a continuing basis at all levels of the security
organizations.
Specialized training for health physics and
chemistry technicians was in place.
The fire brigade training
program was comprehensive and well managed.
!
Emergency Preparedness training had not provided the Operations
Supervisors with the skills to make timely and accurate protective
l
action recommendations. This was determined by routine inspec-
tion.
Training records of these personnel showed that all
!
f amiliarization training had been conducted.
Personnel assigned
to the emergency organizations were cognizant of the'r responsi-
bilities and authorities, and understood their assigned duties and
functions.
Several findings regarding emergency preparedness
training inadequacies resulted in two violations which are
described in Section IV.F of this report.
Three violations were identified:
a.
Severity Level IV violation for failure to implement the
recuirements of NUREG-0737 in that maintenance personnel did
not receive operating experience feedback and the current
plant manager did not receive training in the mitigation of
core damage,
b.
Severity Level IV violation for submitting two applications
for senior operator licenses which contained inaccurate
information.
c.
Seve-ity Level V violation for failure tc have a procedure
fcr the control or retention of training records.
2.
Conclusion
Category:
3
Trend:
Improving
-
- -
-
-
i
.
.
.
25*
3.
Board Recommendations
The board notes that the unsatisfactory licensed operator
requalification program dominated the rating in this area.
Aggressive licensee effort to correct this deficiency was verified
by intensive inspection and reexamination efforts. No additional
increase in licensee or NRC attention is recommended.
K.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
During the assessment period inspections were performed by the
resident and regional inspection staffs.
These inspections
involved reviews of: OA program; design changes and modifica-
tions; procurement, receiving, and stcrage; audits; surveillance
testing and calibration control; measuring and test equipment
program; EWR recirculation piping replacement; verification of
as-builts for BWR recirculation piping modification; licensee
action on previous enforcement matters; and licensee action on
previously identified inspection findings.
Inspections in the area of design control and modifications
indicated that certain design change requests were not being
closed out properly or in a timely manner.
Violation b.
was
issued because a design change request was closed without all
necessary actions being completed.
A considerable backlog of
completed design changes were awaiting close out.
This problem
was also identified during the previous SALP period.
In some
cases, the actual plant modification had been completed for up to
two years and occasionally longer without completion of final
close-out.
Final close-outs included reautred document review,
field walkdowns, cgmpletion of as-built drawings, and updating
affected procedures.
There were a number of maintenance related violations which
indicated a lack of suf ficient QC/QA.
As discussed in Section
IV.C:
violation a. dealt with inadequate functional testing as
evidenced by the return to service of a residual heat removal
system testable check valve with the air lines reversed and the
electrical leads arranged such that the position indication showed
open with the valve shut; violation
h.
was an example of
inadequate functional
testing and inadequate
QC/QA
after
maintenance when during the January 13, 1984 startup, it was found
that one automatic depressurization system valve had been returned
'
to service without being restored to an operable condition;
violation m. was another example where work was being performed
without adequate documents; and violation k. highlights a failure
of a QC inspector to note a discrepancy in a masonary wall weld
connection. While these violations were the result of errors by
maintenance personnel, they indicate a lack of QA overview of
maintenance activities.
.-
_ __
'
l
.
.
.
26 *
i
Inspection in the area of audits indicated an acceptable program
with strong management involvement to ensure resolution of audit
findings.
Audits appeared adequate and corrective action for
,
audit findings were generally well handled.
Violaticn a.
below
I
was issued for failure to issue audits within required time
frames.
This does nbt appear to be a programmatic problem.
The measuring and test eauipment program was programatically
adequate and properly implemented except for two examples:
,
violation j of Section IV.C and violation f of Section IV.O.
The
latter violation involved failure to provide adequate controlling
procedures for activities performed in the maintenance shop
calibration facility.
The programs for procurement, receiving, and storage of equipment
and verification of as-builts relating to recirculation piping
replacement was adequately implemented.
Overall management
control of this activity was commendable.
Audits performed by the licensee of the radiological control
program were of sufficient scope and depth to identify problems
and adverse trends. Appropriate corrective actions were taken and
documented.
Two violations were identified:
a.
Severity Level Ik violation for failure to issue audits
within time f rame required by Technical Specifications.
b.
Severity Level V violation for failure to fully implement the
controlling procedure for plant modifications.
2.
Conclusion
,
!
Category:
2
Trend:
Constant
l
3. . Board Recommendation
Performance in this area was evaluated as Category 3 during the
previous SALP assessment.
Although the rating increased, addi-
!
tional licensee management attention needs to be focused in the
area of timely close out review of design change implementation.
I
,
l
1
i
. . _
_
- - - -
_
_ _ . -
- _
_ - - . - ,
.-- , _,.--.._ ___,
- . , _ .
. _ , _ . .
.
.
.
27
L.
Licensing Activities
1.
Analysis
In general, the licensee's management participated in licensing
activities in a manner appropriate for the significance of the
issue.
There had been streng management involvement concerning
licensing activities pertaining to Unit 2 pipe replacement, vent
header crack resolution and TS amendments for Analog Transmitter
and Trip System ( ATTS) and Average Power Range Monitor / Rod Block
Monitor ( APRM/RBM) modifications.
However, there were a number of submittals requesting emergency,
expedited review of a requested license amendment or involving
untimely requests for schedular relief from commitments to
implement requirements.
Many of these submittals provided
insufficient or inadequate information, necessitating additional
submittals in order for the staff to evaluate the requests. These
submittals included overcurrent protection TSs for containment
penetration conductors and containment isolation valve actuation
setpoints; and schedular extension reques'.s for implementation of
Appendix R,
equipment qualification and post-accident sampling
capability requirements.
Based on consideration of these
submittals, it appears that there had been inadequate planning and
management involvement in the submittals a..d related issues. Tnis
area had been a problem in the past and performance had declined
during this review period. The N4C believes that plant management
had not assured the adequacy of the emergency submittals and that
corporate management had not assured the timeliness and adequacy
of requests for schedular extensions.
The licensee's approach to issues had been generally technically
sound and thorough. While resolutions were sometimes untimely,
conservatism was exhibite
when a potential for safety signifi-
cance existed. While the licensee's approach to most issues was
adequate, there were scre issues (e.g. , post-accident sampling,
Appendix I of 10 CFR Part 53, anc A?Rv! REM TSs) which showed gecd
technical approacn anc resolutiors.
The licensee had impreved the significant ha:ards consideration
determinations that were submitted with each TS change request.
These were generally acceptable for use in preparing the Fedaral
Register pre-notices.
The licensee had generally responded to NRC requests, includirg
generic letters and plant specific requests, in a timely and
technically adequate manner.
A few submittals were good with
respect to timeliness and adequacy. These included requests for
ATTS and ARPM/ REM TSs and the Unit 2 Pipe replacement and torus
vent header crack activities. however, a number of requests for
schedular extensions were not, as discussed above, timely or
.
.
.
28 *
adequately supported the request.
Overcurrent protection for
containment penetration conductors was required on an energency
basis even though a similar request for changes to the TSs had
been processed months before.
This indicated a lack of respon-
siveness to NRC comments about the adequacy of the remainder of
the TSs at the time'of the review of the earlier request for a
similar TS change.
2.
Conclusion
Category:
2
Trend:
Constant
3.
Board Recommendations
Performance in this area was evaluated as Category 2 during the
previous SALP assessment.
The board recommends that additional
licensee management attention be directed to the technical quality
of license amendment submittals.
No additional NRC attention is
recommended.
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
During this assessment period major licensee activities included normal
power operations, refueling of both units, and extensive modifications
and repairs as follows:
Unit 1
Main Turbine (Low Pressure) Repair Af ter Blade Damage
From a Water Slug
Partial Installation of Analog Transmitter Trip System (ATTS)
Installation of the Safety Parameter Display System (SPDS),
Recirculation Pipe Overley Welds
Forced Outage to Replace "B" Recirculation Pump Seals
Forced Outpge to Replace "A" Recirculation Pump Seals and
Repack Valves Inside the Drywell
Unit 2
Piping Replacement (Recirculation and Residual Heat Removal
Systems)
Main Turning Gear Replacement
ATTS Installation
SPDS Installation
s
-- - --
_- .
. - . - _ -
. . - - . _
-_
-
-. _
v
,
,
.
29
Two notices of unusual event classifications were made during this
assessment period:
l
1.
On October 6,1984, a fuel bundle was dropped about twelve feet
'
into its storage position in the spent fuel pool due to inadver-
tent operation of the grapple release switch.
2.
On May 15, 1985, water from the control room ventilation filter
deluge system flowed threagh the ductwork (due to clogged drains)
onto the Unit 1 ATTS canels causing one safety relief valve to
open and stay open.
Scosequently, the reactor was manually
scrarmed.
!
l
B.
Inspection Activities
t
The routine inspection progra
was performed during this period. The
routine inspection program was enhanced by additional routine inspec-
tions during the recirculatior piping replacement in Unit 2 and the
weld overlay work in Unit 1.
Special inspections were conducted to
t
augment the routine inspection programs as follows:
1
November 14-18, 1983, in the areas of NUREG-0737 items, recircula-
'
i
tion piping replacement, project-health ohysics preparations, and
j
licensee preparation for 10 CFR 61 (Licensing Requirements for
]
Land Disposal of Radioactive Waste) compliance;
!
February 4-7, 1984, in tre areas of torus vent header cracking,
'
feed ater line ultrascric indication, and recirculation piping
replacement;
i
,
March 7-9,
1984
in the areas of exposure control and records,
'
!
radiological controls fer Unit 2 outage and radiation worker
j
training;
,
i
l
June 11-15, 1984, in the areas of a worker's concerns with regard
i
to Newport News Industries (NN1) recirculation pipe replacecant
j
project work of Hatch L*'t 2;
i
August 14-17, 1994, in t s areas of licensee event reports, cesign
'
change request modificat'Ons, and independent inspection ef forts;
November 13-16, 1984, cc cerning licensee's response to generic
,
letter 83-28, required a:tions based on generic implications of
the Salem Anticipated Tratsient Without Scram (ATW5) events.
1
!
i
i
f
. . _ .
_ , _ _ . .
._ . . . _ _ _ _ _ , _ _ - , _ _ .
. . _ . _
_ , . _ - - . . _ _ _ _ _ . _ , . _
_,,__-, ,_.__,_-__.. _ __ _ . _ __ _ _
_ .
_
m.
.
_ _ _ . __
_ . _ __
.
.
_
. . - -
.
.
..
i
i
)
30*
1
,
!
'
December 17-18, 1984, to review the implementation and ascertain
,
the adequacy of the accelerated operator requalification training
i
program being conducted in response to NRC Examinations given in
September 1984.
t
February 5-7,
1955, * in the areas of the accelerated operator
,
~
requalification program review and plant training program review;
February 11-13, 1985, the NRC Inspection and Enforcement vendor
,)
program branch conducted a special inspection to determine the
effectiveness of the information exchange between the diesel
'
generator manufacturer (Colt-Fairbanks Morse Engine Division) and
.
'
the plant staff.
'
l
C.
Licensing Activities
The performance assessment was based on NRC evaluation of the
licensee's performance in support of licensing actions involving a
-
,
significant level of activity during the current ratirg period
These
actions consisted of amendment requests, responses to generic letters,
'
requests for schedular extensions, and submittals related to multi-
plant and N'JREG-0737 items. Actions that invo'ved a significant level
of activity during the current rating per'od are listed below.
.
l
11 multi plant actions of which 4 were completed:
1
<
Appendix I TSs
Survey of Mechanical Snubbers
Inservice Testing
j
NUREG-0737 TSs
,
7 NUREG-0737 actions completed:
1
!
Safety Parameter Display System (1.0.2)
'
'
Post A:cident Sampling (II.B.3)
42 plant-specific actions of which 31 were completed
I
~
ATTS TSs
APRM/RBM TSs
Unit 2 Pipe Replacement Plan - Recirculation System
Pipe In*pection Program - 1984 Refueling
Overcurrent Protection TSs - Containment Penetration Conductors
Containment Isolation Valve Actuation Setpoint TSs
Reload 4 TSs
-
Unit 2 Vent Header Crack Activities
Appendix R Implementation Schedule Extensions
4
Equipment Qualification Implementation Schedule Extensions
'
4
Post Accident Sampling (II.B.3) Implementation Schedule Extension
Operation Restriction - ELLA Region TS
,
i
i
1
__ . _ _ _ ___..-.-_ _ ,____ _
_
, . . _ , - , _
_ . _ _ . . ,
__,___.______..___m_
- - _ _ . , _ - . ~ , . . - ~ - , _ . . _ . _ _ . . .
- -
-. . . _
.--
- _ - - - - . _ - -.
--
. . _ .
-
-
._
.
l
t
1
,o
,
,
l
.
,
31
.
I
i
D.
Investigation and Allegation Review
,
There were no significant irvestigations or allegation activities
j
during the assessment period.
'
E.
Escalated Enforcement Actions
.
1.
Civil Penalties
.
A Severity Level III viciation for failure to provide security
access control.
While inis involved escalated enforcement
,
actions, no civil penalty was proposed.
A Severity Level III for introduction of fire arms into a
protected area was issued with a civil penalty of 560,0']O.
.
.
t
i
!
2.
Orders
,
t
.
No orders relating to e.fe-cement matters were issued.
!
F.
Management Conferences Held During the Assessment Period
'
An enforcement conference was meld on November 2, 1983, to discuss the
reactor shutdown conducted frc- the rod scram test panel nn July 19,
?
i
1933.
l
A management meeting was hele on December 9,
1983, to discuss the
1
proposed organi:ational cha ;es within Georgia Power Company for
nuclear operations and const s: tion activities.
!
l
<
t
A management meeting was hele on January 11, 1984, to discuss the
significant failure rates cr reactor operator and instructor certifi-
,
!
cation examinations adm.inistered at Plant Hatch.
!
A management reeting was hel: Or March 22, 1984, to discuss the Unit 2
.
j
feedaater nozzle crack and tre corrective action necessary for future
unit operation.
>
'
An enforcement conferer.ce was teld on April 16, 1984, to discuss an
event ralative to access corte:1s which occurred on April 4, 1954
1
i
,
l
A manaw. cent meeting was helc cr. April 24, 1984, to discuss the indica-
'
tion found in feedwater noz::e and the future corrective action.
>
j
A management meeting was heic on May 21, 1984, to discuss the plann'd
l
modification to the rod bloce. rcnitoring system at the Hatch facility.
i
A nanagement meeting was hele on May 31, 1984,. to discuss the Unit 1
high pressure coolant injectice system at the Hatch facility.
4
4
I
_
l
,, '
.
.
s
32
A management meeting was held on October 23, 1984, to discuss the
licensed operator qualifications and training at the Hatch facility.
A management meeting was held on November 9, 1984, to discuss the
results of the recirculation pipe inspection conducted during the
Hatch 1 outage.
A.1 enforcement conference was held on January 11, 1985, to discuss
sequence of events dealing with the failure to comply with Technical
Specifications pertaining to reactor coolant system leakage.
A management meeting was held on April 23, 1935, to discuss matters of
mutual interest with respect to Section 8 of the administered requali-
fication examination.
A management meeting was held on May 24, 1985, to discuss the
requalification examination conducted at Plant Hatch during the week of
March 11, 1985.
G.
Confirmation of Action Letters
Two confirmation of action letters dated October 16, 1984, and
November 9,
1985 - Prohibiting licensed operators who failed NRC
i
requalification examinations from performing licensed duties until
satisfactorily completing an accelerated requalification program and
passing an NRC approved examination.
Confirmation of action
letter dated March 15,
1985 - Required
personnel who were eligible to perform licensed duties to satis-
factorily complete an accelerated requalification program.
H.
Review of Licensee Event Reports and 10 CFR 21 Reports Submitted by the
Licensee
.
During the assessment period, there were 72 LERs reported for Unit I
and 83 LERs reported for' Unit 2.
The distribution of these events by
cause, as determined by the NRC staff, was as follows:
.
Cause
Unit 1
Unit 2
Component Failure
15
29
Design
9
8
Construction, Fabrication
or Installation
4
4
Personnel:
Operating Activity
1
7
-
Maintenance Activity
7
7
-
'
Te-t/ Calibration Activity
9
-
'12
Other
3
1
-
Out of Calibration
12
8
Other
12
7
TOTAL
72
83
.
. -
.
-
-
-
-
-
-
-
. - -
- .- _ _ _ -
. _ . _ _ _ - ._,
_.
=.
-
_
t
,o
'
o
D3
,
I
l
It was noted that 29*, of the LERs were submitted because of component
'
'
failure, 14% for test / calibration problems, 9*, due to maintenance, and
13*, for "Other" which included storm damage and miscellaneous causes.
4
'
It is further noted that 13*. of the LERs were caused by some form of
'
identifiable personnel, error.
!
1.
Inspection Activity and Enforcement
!
,
1
Functional
No. of Deviations and Violations
Area
in Each Severity Level
,
1
l!
III
IV
V
D
~
i
Plant Operations
8
1
Radiological Controls
2
1
1
Maintenance
10
5
Surveillance
3
3
Fire Protection
,
1
2
Security
2
1
Refueling
Training
2
1
Quality Programs and
Administrative Controls
!
Affecting Quality
1
1
.
Licensing Activities
i
d
YOTAL
~~2
29
13
1
.
a
.
&
4
.
1
0
J
-
4
,
i
!,
9
4
- .
-
-