ML20198A700

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SALP Repts 50-321/85-21 & 50-366/85-21 for Nov 1983 - June 1985
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

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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

Emergency Preparedness

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

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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

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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

Emergency Preparedness

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

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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-

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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

safety relief valve.

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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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

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. 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

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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

~

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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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

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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

welds.

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

l

._

'

.

.

.

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.

Snubber

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

flange to shell weld.

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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.

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16*

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t

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

4

}

i

!

i

i

- -

- -

-

- - - - -

-

- -

'

,

,

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.

Emergency Preparedness

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.

,

,

'

. . _ . , - - - _ . . . . _ , _ . _ . , , _ . . . - . . . . . , . . - .. _ . _ _ , , , - - _ 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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.

,

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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

<

Generic Letter 83-36

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

Emergency Preparedness

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

- .

-

-