ML20207M306
| ML20207M306 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/31/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20207M241 | List: |
| References | |
| 50-247-85-98, NUDOCS 8701130138 | |
| Download: ML20207M306 (60) | |
See also: IR 05000247/1985098
Text
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ENCLOSURE 2
SALP REPORT
U.S. NUCLEAR REGULATORY COMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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INSPECTION REPORT 50-247/85-98
CONSOLIDATED EDISON COMPANY, INC.
-INDIAN POINT STATION - UNIT 2
ASSESSMENT PERIOD: AUGUST 1, 1985 TO JULY 31, 1986
BOARD MEETING DATE: SEPTEMBER 23, 1986
8701130138 87010s 7
DR ADOCK 0500
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TABLE OF CONTENTS
Page
I. INTRODUCTION. . . . . . . . . . . . . . . . . . . . . . . . . 1
A. Purpose and Overview . . . . . . . . . . . . . . . . . . 1
B. SALP Board Members . . . . . . . . . . . . . . . . . . . 1
C. ' Background . . . . . . . . . . . . . . . . . . . . . . . 2
C.1 Licensee Activities. . . . . . . . . . . . . . . . 2
C.2 Inspection Activities. . . . . . . . . . . . . . . 2
II. CRITERIA. . . . . . . . . . . . . . . . . . . . . . . . . . . 4
, III. SUMMARY OF RESULTS. . . . . . . . . . . . . . . . . . . . . . 6
3.1 Overall Facility Evaluation. . . . . . . . . . . . . . . 6
3.2 Facility Performance . . . . . . . . . . . . . . . . . . 7
IV. FUNCTIONAL AREA ASSESSMENTS . . . . . . . . . . . . . . . . . 8
A. Plant Operations . . . . . . . . . . . . . . . . . . . . 8
8. Radiological Controls and Chemistry. . . . . . . . . . . 11
C. Maintenance. . . . . . . . . . . . . . . . . . . . . . . 15
D. Surveillance . . . . . . . . . . . . . . . . . . . . . . 18
E. Fire Protection. . . . . . . . . . . . . . . . . . . . . 20
F. Emergency Preparedness . . . . . . . . . . . . . . . . . 22
G. Security and Safeguards. . . . . . . . . . . . . . . . . 24
H. Outage Activities. . . . . . . . . . . . . . . . . . . . 27
I. Training and Qualification Effectiveness . . . . . . . . 30
J. Assurance of Quality . . . ............... 33
K. Licensing Activi ties . . . . . . . . . . . . . . . . . . 36
V. SUPPORTING DATA AND SUMMARIES . . . . . . . . . . . . . . . . 39
i A. Investigation and Allegation Review .......... 39
B. Escalated Enforcement Actions. . . . . . . . . . . . . . 39
C. Management Conferences . . . . . . . . . . . . . . . . . 39
D. Licensee Event Reports . . . . . . . . . ........ 39
, TABLES
Table 1 TABULAR LISTING OF LERs BY FUNCTIONAL AREA . . . . . . . 41
Table 2 INSPECTION HOURS SUMMARY . . . . . . . . . . . . . . . . 42
Table 3 ENFORCEMENT SUMMARY . . . . . . . . . . . . . . . . . . 43
Table 4 INSPECTION REPORT ACTIVITIES . . . . . . . . . . . . . . 46
Table 5 LISTING OF ALL AUTOMATIC TRIPS AND UNPLANNED SHUTOOWNS . . 49
Table 6 NRR SUPPORTING DATA AND SUMMARY . . . . . . . . . . . . . 52
FIGURES
Figure 1 ' NUMBER OF DAYS SHUT DOWN . . . . . . . . . . . . . . . . . 54
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I. INTRODUCTION
A. Purpose and Overview
The Systematic Assessment of Licensee Performance (SALP) is an inte-
grated NRC staff effort to collect the available observations and
data on a periodic basis and to evaluate licensee performance based
upon this information. The SALP program is supplemental to normal
regulatory processes used to ensure compliance to NRC rules and
regulations. The SALP program is intended to be sufficiently
diagnostic to provide a rational basis for allocating NRC resources
and to provide meaningful guidance to the licensee's' management to
promote quality ni safety of plant construction and operation.
An NRC SALP Board, composed of the staff members listed below, met on
September 23, 1986, to review the collection of performance observa-
tions and data and 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 the Indian Point Station, Unit 2 for the period
August 1, 1985 through July 31, 1986.
B. SALP Board Members
W. F. Kane, Director, Division of Reactor Projects (DRP)
W. V. Johnston, Deputy Director, Division of Reactor Safety
4 S. J. Collins, Deputy Director, Division of Reactor Projects
R. M. Gallo, Chief, Projects Branch No. 2, DRP
L. J. Norrholm, Chief, Reactor Projects Section 28, DRP
S. A. Varga, Director, PWR Project Directorate #3, NRR
J. D. Neighbors, Licensing Project Manager, NRR
L. W. Rossbach, Senior Resident Inspector, Indian Point 2
C. J. Cowgill, Acting Chief, Emergency Preparedness and
Radiological Protection Branch
Other NRC Attendees
M. M. Shanbaky, Chief, Facilities Radiation Protection Section
W. J. Lazarus, Chief, Emergency Preparedness Section
R. R. Keimig, Chief, Safeguards Section
G. C. Smith, Safeguards Specialist
D. P. LeQuia, Radiation Specialist
P. W. Kelley, Resident Inspector, Indian Point 2
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C. Background
1. Licensee Activities
e unit set several station performance records in 1985. These
in luded the highest capacity factor (88.8%) and most days of
con nuous operation (156). The unit shut down automatically on
Janua 13, 1986 when a main boiler feedwater pump tripped due to the
failure of a hose in its high pressure oil system. The unit remained
shut dow and began the cycle 7/8 refueling outage. The low pressure
turbine ro rs were replaced during the outage and tests of the main
electrical nerator revealed a number of shorts. The rotor was
pulled and ex nsive examination and repairs to the stator coils were
begun. Althoug the electrical generator remained out of service,
the refueling, r or replacement, and other scheduled maintenance
items were complet on schedule and the unit was brought critical
for zero power physi s testing on March 12. The unit was then shut
down while the electr al nerator repairs continued.
Plant heatup was begun on 3, however, reactor criticality was
delayed until May 25 due t everal component failures. The unit
reached 100% power on June 2
During this assessment period, nit tripped twelve times and had
two unplanned shutdowns, giving a t rate of 2.32 trips per 1000
hours critical. This is higher tha average trip rate of 1.04
for all Westinghouse units in 1985. rips and shutdowns are
described in Table 5 and are discusse ection IV.A.
The licensee made several organizational during this SALP
assessment period. The managers of Quality rance and Nuclear
Training, the Instrumentation and Control En , and the
Maintenance Engineer were newly assigned. The for Projects Manager
was given increased planning and materials contr 1 responsibilities
under the title of Planning and Projects Manager; nd, now reports to
the Nuclear Power Generation Manager. The position f Manager -
Fire, Safety and Security was created and filled. Th's position
provides for additional management oversight of the se rity program
and incorporates supervision of the security, safety, an fire pro-
tection programs under one administrator. The licensee a o created
a Records Management Center. On August 1, 1986, the licens began
the onsite consolidation of several engineering support group previ-
ously located at corporate headquarters. A new General Manage of
Technical Support began his duties on August I as part of this
consolidation.
2. Inspection Activities
Two NRC resident inspectors were assigned to the unit throughout
the entire assessment period,
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C. Background
1. Licensee Activities
The unit set several station performance records in 1985. These
included the highest capacity factor (88.8%) and most days of
continuous operation (156). The unit shut down automatically on
January 13, 1986 when a main boiler feedwater pump tripped due to the
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failure of a hose in its high pressure oil system. The unit remained
shut down and began the cycle 7/8 refueling outage. The low pressure
turbine rotors were replaced during the outage and tests of the main
electrical generator revealed a number of shorts. The rotor was
pulled and extensive examination and repairs to the stator coils were
begun. Although the electrical generator remained out of service,
the refueling, rotor replacement, and other scheduled maintenance
items were completed on schedule and the unit was brought critical
for zero power physics testing on March 12. The unit was then shut
down while the electrical generator repairs continued.
l Plant heatup was begun on May 3, however, reactor criticality was
l delayed until May 25 due to'several component failures. The unit
reached 100% power on June 20.
During this assessment period, the unit tripped twelve times,
I including one subcritical trip, and had two unplanned shutdowns,
giving a trip rate of 2.13 trips per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> critical. This is
higher than the average trip rate of 1.04 for all Westinghouse units
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in 1985. These trips and shutdowns are described in Table 5 and are
discussed in Section IV.A.
The licensee made several organizational changes during this SALP
assessment period. The managers of Quality Assurance and Nuclear
Training, the Instrumentation and Control Engineer, and the
Maintenance Engineer were newly assigned. The Major Projects Manager
was given increased planning and materials control responsibilities
under the title of Planning and Projects Manager; and, now reports to
the Nuclear Power Generation Manager. The position of Manager -
Fire, Safety and Security was created and filled. This position
- provides for additional management oversight of the security program
I
and incorporates supervision of the security, safety, and fire pro-
tection programs under one administrator. The licensee also created
a Records Management Center. On August 1, 1986, the licensee began
! the onsite consolidation of several engineering support groups previ-
ously located at corporate headquarters. A new General Manager of
Technical Support began his duties on August I as part of this
consolidation.
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2. Inspection Activities
Two NRC resident inspectors were assigned to the unit throughout
the entire assessment period.
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Special team inspections were conducted as follows:
- Appendix R Safe Shutdown, September 16-20, 1985
Environmental Qualification, May 12-16, 1986
- Health Physics Appraisal, June 16-20, 1986
Probabilistic Risk Assessment Based Inspection,
July 21-August 1, 1986
The scope of the probabilistic risk assessment team inspection
was formulated based on a review of the Indian Point
Probabilistic Safety Study and an NRC sponsored peer review by
Sandia Laboratory (NUREG/CR-2934). The risk significant
accident initiators, equipment failures, and operator errors
contained in the top twenty four dominant accident sequences
were studied. Major areas selected for review included recovery
actions from a loss of offsite power, as well as from a loss of
coolant accident. Assessments were made of the ability of the
operations staff to respond to events, of the reliability of
plant hardware, and of the effectiveness of management controls
in areas such as maintenance, testing, and quality assurance.
The overall results showed an experienced and knowledgeable
staff. A number of weaknesses in Emergency Operating Procedures
were identified, as discussed in Section IV.A. Several hardware
discrepancies relating to configuration management were identi-
fled, as discussed in Sections IV.A and C.
Inspection hours are summarized in Table 2 and total 4241 hours0.0491 days <br />1.178 hours <br />0.00701 weeks <br />0.00161 months <br />
for the assessment period. Table 3 lists specific enforcement
data. Inspection report activities are summarized in Table 4.
This report also discusses " Training and Qualification
Effectiveness" and " Assurance of Quality" as separate functional
areas. Although these topics, in themselves, are assessed in
the other functional areas through their use as criteria, the
two areas provide a synopsis. For example, quality assurance
effectiveness has been assessed on a day-to-day basis by
resident inspectors and as an integral aspect of specialist
inspections. Although quality work is the responsibility of
every employee, one of the management tools used to measure
Quality Assurance effectiveness is reliance on quality inspec-
tions and audits. Other major factors that influence quality,
such as involvement of first-line supervision, safety
committees, and worker attitudes, are discussed in each area.
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II. CRITERIA
Licensee performance is assesssed in selected functional areas. Each
functional area represents areas significant to nuclear safety and the
environment and are normal programmatic areas.
The following evaluation criteria were used to assess each functional
area:
1. Management involvement in assuring quality.
2. Approach to resolution of technical issues from a safety standpoint.
3. Responsiveness to NRC initiatives.
4. Enforcement history.
5. Reporting and analysis of reportable events.
6. Staffing (including management).
7. 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 Board assessment each functional area evaluated is
classified into one of three performance categories. The definitions of l
these performance categories are:
Category 1: Reduced NRC attention may be appropriate. Licensee manage-
ment attention and involvement are aggressive and oriented toward nuclear
safety; licensee resources are ample and effectively used such that a high
level of performance with respect to operational safety and construction -
quality is being achieved.
Category 2: NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are con-
cerned with nuclear safety; licensee resources are adequate and are rea-
sonably effective such that satisfactory performance with respect to
operational safety and construction quality is being achieved.
Category 3: Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear
strained or not effectively used such that minimally satisfactory
performance with respect to operational safety and construction quality is
being achieved.
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The SALP Board has also categorized the performance trend over the last
quarter of the SALP assessment period. The categorization describes the
general or prevailing tendency (the performance gradient) during the last
quarter (May - July 1986) of the SALP period. The performance trends are
defined as follows:
Improving: Licensee performance has generally improved during the last
calendar quarter of the current SALP assessment period.
, Consistent: Licensee performance has remained essentially constant
during the last calendar quarter of the current SALP
assessment period.
Declining: Licensee performance has generally declined over the last
calendar quarter of the current SALP assessment period.
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III. SUMMARY OF RESULTS
3.1 Overall Facility Evaluation
j The major site management changes made during the last assessment-
period have contributed to improved performance in several areas.
The leadership of the Vice President, Nuclear Power was instrumental
in bringing about these improvements and is continuing to have a
positive impact on overall performance.
Management effectiveness has improved as noted in the recent program
inspection for Appendix R and also, in the control of outage activi-
ties. Program changes in the Radiation Protection area have been
effectively implemented resulting in an improved program and SALP
rating. Based on inspections conducted during this assessment period,
the terms of the September 27, 1984 Order Modifying License were
determined to have been satisfactorily completed. Some recent
organizational changes have not been in effect for a sufficient time,
however, to adequately assess their impact, such as your recent
security initiatives.
Despite the overall improvements noted during this assessment period
two areas warrant specific attention. Our review notes that reactor
trips occurred at a rate higher than the industry average. Previous
efforts to reduce this rate have not been effective. We acknowledge
that a response team was recently initiated to provide a more in-
depth investigation of trips. Our analysis indicates to us a need
for additional operator training dedicated to normal evolutions.
Correspondingly, your actions should assure that the simulator
upgrade is properly and expeditiously completed, so that such training
will be available to provide a more accurate simulation of those
evolutions.
Secondly, the amount of maintenance remaining to be completed is of
concern to us. Your actions should consider the review of maintenance
staffing and prioritization including efforts to integrate probabilistic
risk assessment into the maintenance program to provide a work
prioritization system based on risk.
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3.2 ~ Facility Performance
Category Category Recent
Functional Area Last Period This Period Trend *
(August 1, 1984 to (August 1, 1985
July 31, 1985) to July 31,1986)
A. Plant Operations 2 2 Consistent
B. Radiological Controls 3 2 Consistent
and Chemistry
C. Maintenance 2 2 Consistent
D. Surveillance 1 1 Consistent
E. Fire Protection 2 1 Consistent
F. Emergency 1 2 Improving
Preparedness
G. Security and 1 2 Improving
Safeguards
H. Outage Activities 2 1
I. Training and Qualification Not Evaluated 2 Consistent
Effectiveness
J. Assurance of Quality Not Evaluated 2 Consistent
K. Licensing Activities 2 2 Improving
- Trend during the last quarter of the assessment period.
- No basis to determine a performance trend.
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IV. FUNCTIONAL AREA ASSESSMENTS
A. Plant Operations (23%, 981 Hours)
1. Analysis
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The previous SALP determined the operations area to be
Category 2. Nine trips occurred during the previous SALP period
and it was recommended that the licensee review the causes of
trips to reduce their frequency. It was also recommended that
the integration of the shift technical advisors (STAS) on shift
be evaluated and that the quality of written and verbal reports
be improved.
During this assessment period, the unit was critical for
approximately 5175 hours0.0599 days <br />1.438 hours <br />0.00856 weeks <br />0.00197 months <br /> (216 days) and had twelve trips. These
trips were distributed as follows: ten automatic trips while
critical, one manual trip while critical and one manual trip
while subcritical. Two other unplanned shutdowns also ocorred
during this assessment period.
Four trips can be attributed to operator errors, three by
licensed operators, one by a nonlicensed operator. The three
errors by licensed operators occurred during normal operations
and indicate a need for additional training time dedicated to
the conduct of evolutions such as power escalation and a need
for increased accuracy in the simulation of these evoldtions.
The error by the nonlicensed operator was due to failure to
follow procedures. Other instances of operators failing to
follow procedures have not been identified.
One trip occurred due to a drawing not being updated following
plant construction. The licensee's corrective actions in this
area are being followed by the inspectors.
In March 1986, at the end of the refueling outage, the licensee
initiated a trip response team whose goal is to reduce the
number of trips. The group investigates the event, determines
root causes, and recommends and tracks corrective actions. The
trip response team leader is also an active participant in the
Westinghouse owners group trip reduction and assessment program.
The effectiveness of this effort has not been assessed.
In October 1985 the licensee implemented symptom-oriented
Emergency Operating Procedures (EOPs). All licensed operators
received six weeks of training in their use prior to implementa-
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tion. Operators have been observed to use the E0Ps proficiently
during actual events. General simulator performance and exami-
nation results of SR0 classes in this assessment period and the
. previous assessment period were above average. Operators have
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accepted the E0Ps and appear to be well trained in their use.
All six SR0 candidates examined during this assessment period
received licenses.
E0Ps were not being evaluated and updated in a timely manner.
Apparently, due to a cumbersome change process in place for
E0Ps, changes were being accumulated for single revisions.
Also, the E0Ps were not being thoroughly reviewed as evidenced
by several procedure inadequacies identified by the PRA team
inspection.
The control room environment is a strength, consi- mtly neat
and orderly. Operators conduct themselves in a .ssional
manner. Shift turnovers are thorough and effect1ve.
Daily morning meetings chaired by the operations manager, are
used to coordinate each day's activities in the areas of
maintenance, surveillance, irad waste and modification
construction. In addition to a representative in each of these
areas, the meetings are attended by QA, health physics, and
security.
There are currently 43 licensed Senior Reactor Operators (SR0s)
and 14 licensed Reactor Operators (R0s). The shift staffing
consists of two SR0s and two R0s. One of the R0s is a roving RO
who can perform duties outside of the control room as long as he
is not more than ten minutes away. There are a total of six
shifts with the above manning. Starting at the end of the
refueling outage the licensee changed to twelve hour shifts.
The overtime usage is kept to a minimum and well within the
limits of NRC Generic Letter 82-12.
The licensee has evaluated how to provide better shift integra-
tion of STAS as recommended in the previous assessment. Assess-
ment of study findings and scheduled implementations are under
consideration.
The quality of the Station Nuclear Safety Committee (SNSC) and
the Nuclear Facilities Safety Committee (NFSC) reviews of events
and other items remains good. As discussed in Section 4.10, a
new SNSC Chairman was appointed effective August 1, 1986 as part
of a consolidation of Corporate office engineering personnel
with the onsite organizatio'n.
The licensee has been responsive to several NRC findings during
this assessment period, taking prompt corrective actions.
However, one area that has been a continuing problem since the
previous assessment period is in making prompt notifications by
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the Emergency Notification System. -Instances were identified in
which the required notifications were not made, were made late
or were incomplete. Required corrective actions are currently
being developed by the licensee in this area.
The four operations training programs (NPO, R0, SR0/SWS, STA)
were submitted to INPO on schedule during this SALP period.
Management attention to housekeeping has been evident by the
emphasis given to housekeeping at morning planning meetings and
by frequent plant tours by management. Despite management
attention, performance in this area has been inconsistent.
Control of contamination has improved, and as a result of a large
effort by the licensee, contaminated areas have been reduced by
50% since January 1985. The licensee continues to demonstrate a-
resolve to maintain a clean plant through programs to
decontaminate the Maintenance and Outage Building and utility
tunnel. Control of trash has generally been good, however,
various inspections have identified construction debris in the
pipe penetration area and containment building and trash in the
fuel storage building. Contrary to administrative control
measures, unsecured gas cylinders have been observed during NRC
inspections. Loose gas cylinders were also identified in a QA
surveillance report but no effective actions were taken to
resolve the finding.
In summary, plant operations are well managed. However, trips
are occurring at a rate higher than the industry average.
Emergency operating procedures were implemented well but need
to be thoroughly reviewed and updated in a timely manner.
2. Conclusion
Rating: Category 2
Trend: Consistent
3. Board Recommendations
Licensee: None
NRC: None
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B. Radiological Controls and Chemistry (21%, 903 Hours)
Analysis
On September 27, 1984, an Order Modifying License was issued due
programmatic deficiencies in the licensee's radiological
co trols program. During the previous SALP assessment period,
the icensee developed a completely revised radiation protection
prog m and trained personnel in the implementing procedures.
Full i lementation of the revised program occurred one month
prior to the end of the previous SALP assessment period. During
the curre SALP assessment period, the NRC conducted several
inspections to verify the licensee's program improvements and to
evaluate the ffectiveness of program implementation.
There were nine nspections and a Health Physics Appraisal by
radiation special f areas affecting radiological controls
during this period, sident inspectors also monitored radio-
logical controls rel activities.
Radiation Protection
The licensee has demonstra timely and thorough development of
program elements, including: fective communication cnd dis-
semination of radiological co information to the site
staff; establishment of coopera w rking relationships with ,
all plant groups; initiation of t ALARA incentives; and
development of concise health phys cs cedures. The licensee
has also demonstrated aggressive ac io d strong management
oversight in implementing the progra ements.
The licensee has a sufficient number of qualified and
trained individuals functioning at all le is within the
radiation protection organization. There re, however, some
changes within the organization during this sessment period.
Specifically, the Radiation Protection Oversig t Committee was
dissolved. This committee had been chartered t provide
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oversight of the Radiation Protection (RP) Progra following
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issuance of the Order Modifying License in 1984. e respon-
sibilities previously delegated to this committee ha been
reassigned to the Radiation Safety Committee, a subco ittee of
the Nuclear Facilities Safety Committee. In addition, e
position of Radiological Assessor, which had been vacant or
several months, was filled through the promotion of a plan
radiological engineer. This is a high visibility position, nd
a key link to help assure the continued quality of the RP
program.
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B. Radiological Controls and Chemistry (21%, 903 Hours)
1. Analysis
On September 27, 1984, an Order Modifying License was issued due
to programmatic deficiencies in the licensee's radiolcgical
controls program. During the previous SALP assessment period,
the licensee developed a completely revised radiation protection
program and trained personnel in the implementing procedures.
Full implementation of the revised program occurred one month
prior to the end of the previous SALP assessment period. During
the current SALP assessment period, the NRC conducted several
inspections to verify the licensee's program improvements and to
evaluate the effectiveness of program implementation.
There were nine inspections and a Health Physics Appraisal by
radiation specialists of areas affecting radiological controls
during this period. Resident inspectors also monitored radio-
logical controls related activities.
Radiation Protection
The Itcensee has demonstrated timely and thorough development of
program elements, including: effective communication and dis-
semination of radiological controls information to the site
staff; establishment of cooperative working relationships with
all plant groups; initiation of strong ALARA incentives; and
development of concise health physics procedures. The_ licensee
has also demonstrated aggressive action and strong management
oversight in implementing the program elements.
The licensee has a sufficient number of well qualified and
trained individuals functioning at all levels within the
radiation protection organization. There were, however, some
changes within the organization during this assessment period.
Specifically, the Radiation Protection Oversight Committee was
dissolved. This committee had been chartered to provide
oversight of the Radiation Protection (RP) Program following
issuance of the Order Modifying License in 1984. The respon-
sibilities previously delegated to this committee have been
reassigned to the Radiation Safety Committee, a subcommittee of
the Nuclear Facilities Safety Committee. In addition, the
position of Radiological Assessor was filled through the
promotion of a plant radiological engineer. This is a high
visibility position, and a key link to help assure the continued
quality of the RP program.
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An effective RP training program has been established for plant
Health Physics (HP) personnel. This program includes the use of
mock-ups as practical learning aids. In the area of contractor
HP technician training, apparent weaknesses were identified.
Specifically; formal lesson plans had not been established,
written performance tests were technically shallow, and
management oversight was not sufficient to assure that
contractor technician training was adequately prepared and
planned. Upon NRC identification of these weaknesses, licensee
management immediately committed to rectify them prior to
implementation of the contractor technician training program.
Subsequent re-inspection of this area verified that the licensee
had taken timely and effective action to correct program
weaknesses.
External radiation exposure controls were well established and
effective as evidenced by clear administrative and physical
controls of High Radiation Areas, Radiation Areas and Airborne
Areas. An effective Radiation Work Permit (RWP) system,
supported by adequate radiological assessments and measurements
is now in place. Improvements continued in the personnel
dosimetry program, with the purchase of a new TLD dosimetry
system and proposal for additional training of dosimetry
technicians and supervisory personnel. However, some weaknesses
in the implementation of the radiation protection program during
the outage were noted. Specifically, a high radiation area was
not posted or barricaded and several instances of failure to
follow RWP requirements occurred. The additional workload
associated with the outage appeared to stress the newly upgraded
program. The licensee is aware of this and it will be the
subject of further NRC reviews.
Internal radiation exposure controls were well established as
evidenced by: ongoing efforts to minimize contamination of
areas and components; adequate air sampling and evaluation of
airborne hazards; use of engineering controls; and use of
respiratory protection equipment. In addition, the licensee has
established an acceptable bioassay program. Minor program
weaknesses were noted which impact on program effectiveness: a
limited supply of high volume air samplers which reduced the
effectiveness of the licensee's ability to evaluate airborne
hazards; a poor maintenance program for self-contained-breath-
ing-apparatus; and poor whole body counting facilities. Whole
body counting facilities were not sufficiently environmentally
controlled to limit radio-signal interference with counting
equipment. In addition, high temperatures cause counting system
errors. A potential also exists for losing all whole body
counting capability during an emergency, since the same facili-
ties are used for worker decontamination. Once identified, the
licensee was responsive to these issues.
I
i
.
.. 13
Considerable improvement has occurred in the ALARA program due
to good management support and worker involvement. The program
is well staffed with qualified radiological engineers. ALARA
procedures and policies are well documented to implement the
prograrr , Significant exposure reductions were achieved in the
early stages of the improved program; however, the collective
exposure at Indian Point-2 remains higher than the average for
pressurized water reactors. Subsequent exposure reductions, as
the ALARA program matures, may require a substantial commitment
of resources to address the higher than normal source term at
the plant, and the less than optimum equipmerit shield design.
Licensee management was aware of this situation and is
considering alternate routes to reduce exposure.
The licensee's internal audits and assessments of the radio-
logical control program have substantially improved. However,
some weaknesses were identified in this area. Specifically,
. Radiological Occurrence Reports (ROR) were not actively used to
address deficiencies; no generic reviews of RORs were performed
to determine if any commonality existed in deficiencies; and the
independent radiological assessor did not have a system to track
his findings to resolution. The licensee corrected this situa-
tion by broadening the previously narrow scope of deficiencies
documented in RORs.
Transportation
The licensee is implementing an effective radioactive waste
transportation program. Licensee personnel at all levels in
radwaste transportation are very knowledgeable with regard to
their functions and responsibilities. On going training is
evident.
The licensee performed several QA Department audits of the
transportation program during the period. The audits were
performed in accordance with the requirements of 10 CFR 50,
Appendix B.
One concern was identified, in that the licensee did not ade-
quately communicate to the department responsible for implemen-
ting the radwaste program, that their responsibility includes
performing the quality control function associated with their
activities. This was corrected through comprehensive training
and procedures.
Effluent Control and Post-Accident Sampling
A review of the licensee's effluents program indicated it was
generally being effectively implemented; however, it was noted
that QA involvement was not evident in observing Technical
.-
, 14
Specification required surveillances on plant ventilation
systems.
A follow-up review of the licensee's Post-Accident Sampling
Systems indicated that the systems remain operative, well-
maintained, and that the licensee has adequately addressed
several of the concerns identified in-the previous inspection in
this area.
. Water Chemistry Controls
The licensee's nonradiological water chemistry program has been
upgraded with state of the art laboratory equipment and
procedures. They have initiated an effective QC program.
In summary, the licensee has made significant improvements in
the Radiation Protection Program since the Order Modifying
the License. A health physics appraisal team found all facets
of the program to be acceptable for routine and outage radio-
logical control activities. Management attention has been
appropriately focused toward continued improvements to the
program.
2. Conclusion
Rating: Category 2
Trend: Consistent
3. Board Recommendations
Licensee: None
NRC: Conduct a review of site radiochemistry program.
,
, - ~ - - . . ~ , . .- . . - . . . - , . - . , . , , . - , .,--.,.-~.,.----.,,----_n -n,-,n n,,,,.-,- - . , - - , , , . - . . - . _ . . . , - - , - , _ , - , .
.
. . 15
C. Maintenance (13%, 550 Hours)
1. Analysis
During the previous assessment period, the maintenance program was
recognized as strong with capable management and a large, experienced
staff. A large maintenance backlog had developed and was a concern.
Licensee management was taking steps to improve the physical
condition of the plant.
A total of four reactor trips were attributed to inadequate
maintenance during this assessment period. Two of these trips
occurred due to the loss of main boiler feed pumps and two occurred
due to capacitor failures. One of the feed pump trips occurred when
a high pressure oil hose failed. The hose failed one day before a
scheduled outage, during which it was to be replaced. The other feed
pump trip occurred due to the bearing oil trip setpoint screw being
turned after maintenance. This is one of several examples of
inadequate job site restoration which is discussed later in this
section. One trip occurred due to a capacitor failing in a reactor
coolant flow trip circuit. The capacitor failed before its
scheduled replacement. One trip occurred due to the failure of
'
the steam dump controller. A failed capacitor contributed to the
controller failure. As a result of this failure, the licensee
extended the capacitor replacement program to control circuits.
Several instances were rx:ed where maintenance work was considered
complete but the job site was not completely restored to its original
condition. One reactor trip resulted from not returning a boiler
feedwater pump trip setpoint to its correct position after mainte-
nance. Other instances of incomplete post-maintenance job site
restoration include: failure to replace a seismic restraint on a
reactor coolant pump; improperly reinstalling the reactor coolant
pump oil collection system; improperly reinstalling the recirculation
sump grating; and, cutting away portions of the service water pump
seismic restraints to simplify replacement of the pumps. Also,
tools, removed parts, trash, and leaked oil were observed to remain
at work sites after jobs were completed. Procedural inadequacies for
job site restoration and inadequate post-maintenance job site walk-
downs contributed to these events. Also, in the service water pump
seismic restraint event, the licensee identified that these
restraints were degraded but they were not repaired due to improper
prioritization of the work order. Upon identification of these
concerns, the licensee took prompt and effective corrective action.
However, proper completion of the job restoration phase of mainte-
nance requires increased management involvement.
4
i
1
--
- - , - , --ry. .- , - - . . _ . - - - - . .- ,,,_-_s
. . - . .
..
. 16
A large work order backlog continues to be of concern. The licensee
has taken measures to reduce this backlog. Additional maintenance
staff have periodically been assigned to the station from the Power
Generation Maintenance department and Electric Construction Bureau to
support the increased workload. The major projects manager was given
increased maintenance planning and materials control responsibilities
under the title of planning and projects manager. Senior plant
management actively assesses progress on a station goal to reduce
work order backlogs. The work order backlog, however, was about the
same at the end of this assessment period as it was at the beginning.
The backlog appears to be due in part to an increase in worker
awareness and responsibility for reporting equipment deficiencies.
Staffing level appears sufficient so that there is a decreasing trend
in the number of backlogged work orders although increased staff or ,
worker efficiency would further help to lower the backlog.
The licensee filled promptly and effectively the vacancy left by the
maintenance engineer who left the company at the end of the 1986
refueling outage. The current maintenance engineer was promoted to
the position from within the licensee's organization. The overall
personnel turnover rate is minimal at both the laborer level and
management level. The staffing level remains fairly constant
throughout, with the exception of outages when the licensee's offsite
maintenance personnel come to the site.
The licensee plans to use the probabilistic risk assessment to aid in
prioritizing work orders. Although this effort is not yet underway,
the licensee is planning to transfer the probabilistic risk
assessment staff to the site, where they will be available to support
4
this effort which should result in a reduction in risk from
inoperable equipment.
Due to difficulty in retrieving completed work packages, the licensee
4
'
is reducing the number of status changes the package goes through
during its life. The work packages will also be kept in one place
rather than distributing the packages to the various reviewing
organizations. The licensee's actions to resolve this problem appear
to be working.
,
,
Positive elements noted in the previous assessment period continue to
be exhibited. The maintenance staff is exper enced. Management in-
volvement in the maintenance program is evident and generally effec-
tive from preplanning to work completion, except as noted above.
Overall maintenance records and work packages are complete and accu-
rate. Maintenance procedures are, overall, adequate to perform work.
Work steps are listed in order of performance and sign-off steps are
well defined. Work orders are tracked using the computerized power
plant maintenance information system (PPMIS). With PPMIS, all work
order status, priority and post-maintenance testing requirements are
assigned. The licensee is continuing the effort to increase the
, utilization of PPMIS capabilities for tracking purposes. QC hold
f
1
, , - - - - , . - , . . . , , . , - - - , - , . - . , . ----.--,-,,-.-n
.
-- - -n- - - - -- , , - ..,
.:
. 17
points were astablished in most work activities inspected. Quality
related maintenance records reviewed were complete. QC involvement
was appropriate for the work activities. QC performs random sur-
veillances of the job sites.
During this assessment period, the licensee developed training pro-
grams for Mechanical, Electrical and Instrumentation and Control
staff. The training is adequate for the staff to perform its routine
duties. No training-related problems were evidenced by the main-
tenance staff's performance. Self Evaluation Reports (SERs) for
these programs were submitted to INPO for accreditation.
In summary, the maintenance function is being performed satisfac-
torily by competent and skilled personnel. A considerable amount of
maintenance remains to be done. It is not known what system inter-
actions could result or what operator needs would go unmet in an
event due to the outstanding maintenance activities. The licensee's
efforts to integrate probabilistic risk assessment into the mainte-
nance program to reduce the risk from inoperable equipment is
therefore encouraged. Additional staffing and improved efficiency
would aid in working off the maintenance backlog. Increased atten-
tion to post-maintenance job site restoration is needed.
2. Conclusion
Rating: Category 2
Trend: Consistent
3. Board Recommendations
Licensee: Integrate the probabilistic risk assessment into the
maintenance program. Increase efforts to reduce maintenance
backlog, including review of staffing levels and work prioritization.
NRC: None
.
, 18
0. Surveillance (14%, 585 Hours)
1. Analysis
During the previous assessment period, this area was identified as a
strength, Category 1. During this assessment period, surveillance
activities were routinely observed by the resident inspectors.
Region-based inspectors also reviewed surveillance activities.
In general, the licensee's surveillance program is well defined uti-
lizing computerized schedules and technically adequate procedures.
Management conducts reviews of completed surveillances to ensure the
results are acceptable and meet Technical Specification reatirements,
records are complete, and the necessary follow-up is completed.
Surveillance procedures are well maintained and easily retrievable.
Technical Specification - limited conditions for operation entered
for testing purposes are tracked by Senior Reactor Operator and
Senior Watch Supervisor log books.
The licensee has' upgraded surveillance procedures during this assess-
ment period. Included in the upgrade were generic statement changes,
format changes, personnel notification changes, and procedure clari-
fications. The surveillance test writing staff consists of
knowledgeable people with a strong background in test writing. The
testing is performed by members of the operations, performance, and
I&C departments. The test documents and test document changes are
strictly controlled.
During the assessment period, there were three separate cases of
minor surveillance performance problems. One case was a late daily
heat balance check due to the operators being preoccupied with a
plant transient. The second case was an incomplete surveillance tect
due to the I&C technician omitting the source check of a radiation
monitor in the field. The third case was an incomplete surveillance
due to operations personnel omitting one control rod from the rod
exercise test because it had an inoperable position indicator. All
three of these cases were identified by the licensee while reviewing
completed test results and they were promptly reported and corrected.
Except for these three cases, the licensee completed surveillance
testing in a timely manner.
One subcritical reactor trip occurred due to a personnel error during
surveillance testing. While performing the reactor protection logic
functional test, a technician tripped reactor trip breaker A instead
of B as required by the test procedure. This is considered an iso-
lated instance.
The staffing of the Test and Performance department has remained
relatively constant throughout the assessment period. The department
writes the majority of the surveillance tests and post-maintenance
1
, , 19 l
l
l
i
i
tests. The tests are performed by members of the operations, I&C, 'l
and the Test and Performance department. Staffing is adequate to l
perform this function. Based on the performance of the Test and ;
Performance personnel, training appears adequate.
QA/QC personnel review a sample of completed tests. QA/QC also
performs certain hydrostatic test inspections in which certified
inspectors are required.
~
In summary, surveillance tests are well written and easy to follow.
Test data is in tabular form for ease of review. Reviews of
completed tests are effective in identifying problem areas. The
program is adequately staffed and effectively managed.
2. Conclusion
Rating: Category 1
Trend: Consistent
3. Board Recommendations
Licensee: None
NRC: None
_ _ _ _ _ _ _ . _ _ - _ _ _ - _ _ _ _ _ _ _ _
-
C-
, 21
Fire brigade drills were promptly responded to by the brigade. The
brigade leader gave clear instructions to the brigade and good com-
munications were maintained with the control room.
During this assessment period, the Itcensee assigned the additional
responsibilities of managing the security program to the person in
charge of the fire protection program. Although no degradation in
the management of the fire protection program has been observed, the
effects of this change will be evaluated during the next SALP period.
In summary, the implementation of Appendix R and the routine conduct
of the fire protection program show that the fire protection program
is well organized and effectively implemented.
2. Conclusion
Rating: Category 1
Trend: Consistent
3. Board Recommendations
Licensee: None
NRC: None
l
l
l
l
i
.
, 20
l
i
E. Fire Protection (6%, 234 Hours)
l
l 1. Analysis
! During the previous assessment period, satisfactory performance was
l evident in the fire protection program.
,
During this period, a team inspection was conducted of fire protect-
l ion and alternate safe shutdown modifications required by 10 CFR 50,
- Appendix R. The team included specialists in fire protection,
'
mechanical and electrical systems from NRR and Brookhaven National
Laboratory.
The inspection focused on the plant's safe shutdown capability. In
particular the team reviewed the plant's fire protection measures
.
which ensure that one train of equipment necessary to achieve and
!
maintain safe shutdown remains available in the event of a fire at
any location within the plant.
The review included an inspection of the fire barriers separating
redundant safe shutdown components and miscellaneous fire protection
systems. A review of the safe shutdown systems, safe shutdown
methodology and the emergency safe shutdown procedures was also
performed.
l The safe shutdown analysis performed by the licensee was comprehen-
sive. The established emergency procedures are clear and easily
! implemented, although a large number of operators is required
for this task. The licensee demonstrated that this crew is always
'
available and is well trained in these procedures.
The licensee's associated circuit analysis also adequately addressed
the regulatory concerns such as common bus, spurious signals, current
transformer secondaries and high-low pressure interfaces. All of the
above are indications of strong management involvement in fire
protection issues.
The licensee also routinely exhibits conservatism in areas of safety
significance and is innovative in the use of Unit 1 equipment, such
as the gas turbine, to provide backup power to the emergency diesels.
The fire protection program was also included in routine inspections
by the resident inspectors.
The fire protection program was found to be effectively implemented
i during this assessment period. Frequent plant tours are made by fire
l protection staff and supervision. Transient fire hazards are kept to
a minimum. Fire protection starf exhibited a good understanding and
l effective implementation of procedures for control of the removal and
reinstallation of fire barriers.
i
o
. 22
F. Emergency Preparedness (6%, 265 Hours)
1. nalysis
Du ng the previous assessment period, licensee performance in this
area as rated as Category 1, based on performance during the annual
exerc e, and management involvement in emergency preparedness as
evidenc by staffing levels, training, and responsiveness to identi-
fying an correcting program deficiencies.
During the c rrent assessment period, one full participation exercise
was observed, hanges to on and offsite emergency plans were re-
viewed, and NR staff attended meetings called by the Chairman of the
Regional Assista e Committee (for FEMA Region II) to resolve offsite
emergency planning issues.
During the full parti tion exercise conducted on June 4, 1986, the
licensee demonstrated ng emergency response capability. Per-
sonnel were well traine n alified in their emergency response
roles. In particular, em ency action levels were identified
promptly and the re-entry a covery planning was unusually thor-
ough ard complete. No signi nu deficiencies were identified re-
lating to onsite activities, ppmanceremainedatthepreviously
noted high levels. One onsite R at has remained unresolved,
is th2 question over whether the this EOF is adequate to
allow an effective onsite NRC prese ing an emergency. The
licensee contends that it is adequat )lan no changes. The
issue will be addressed during an upco i F appraisal.
Some significant deficiencies identified he offsite portion of
the exercise will necessitate a remedial e i e. A partial failure
of the Alert and Notification System (ANS) o red when fourteen
sirens failed to function due to "co-channel terference" which
occurred, blocking the activation signal. The terference occurred
because the frequency employed for siren activat n is also used by
the New York State Department of Transportation, R kland County
Highway Department and the Town of Clarkstown Highwa Department.
The licensee has taken administrative steps (broadcas ng a message
to clear the frequency prior to siren activation) to a id a repeti-
tion, and satisfactorily tested the system on June 28,1 6.
Although this action was the fastest way to correct the de'iciency,
more effective solutions are available, but would involve h dware
changes. Several offsite issues have persisted for a number f
years. Licensee participation with FEMA and the State and fou
Counties in resolving these issues could have been more aggressi ,
and has shown dramatic improvement recently (although outside the
assessment period).
e,
, 22A
F. Emergency Preparedness (6%, 265 llours)
1. Analysis
During the previous assessment period, licensee performance in this
area was rated as Category 1, based on performance during the annual
exercise, and management involvement in emergency preparedness as
evidenced by staffing levels, training, and responsiveness to identi-
fying and correcting program deficiencies.
During the current assessment period, one full participation exercise
was observed, changes to on and offsite emergency plans were re-
viewed, and NRC staff attended meetings called by the Chairman of the
Regional Assistance Committee (for FEMA Region II) to resolve offsite
emergency planning issues.
During the full participation exercise conducted on June 4, 1986, the
licensee demonstrated a strong emergency response capability. Per-
sonnel were well trained and qualified in their emergency response
roles. In particular, emergency action levels were identified
promptly and the re-entry and recovery planning was unusually thor-
ough and complete. No significant deficiencies were identified re-
lating to onsite activities. Performance remained at the previously
noted high levels. One onsite issue that has remained unresolved,
is the question over whether the size of this EOF is adequate to
allow an effective onsite NRC presence during an emergency. The
licensee contends that it is adequate, but is evaluating changes.
The issue will be addressed during an upcoming ERF appraisal.
Some significant deficiencies identified in the offsite portion of
the exercise will necessitate a remedial exercise. A partial failure
of -the Alert and Notification System (ANS) occurred when fourteen
sirens failed to function due to "co-channel interference" which
occurred, blocking the activation signal. The interference occurred
because the frequency employed for siren activation is also used by
the New York State Department of Transportation, Rockland County
Highway Department and the Town of Clarkstown Highway Department.
The licensee has taken administrative steps (broadcasting a message
to clear the frequency prior to siren activation) to avoid a repeti-
tion, and satisfactorily tested the system on June 28, 1986.
Although this action was the fastest way to correct the deficiency,
more effective solutions are available, but would involve hardware
changes. Several offsite issues have persisted for a number of
years. Licensee participation with FEMA and the State and four
Counties in resolving these issues could have been more aggressive,
and has shown dramatic improvement recently (although outside the
assessment period).
.-
,. 23
In addition, the licensee failed to make the one hour. notification
required by 10 CFR 50.72 (Loss of significant alert / notification
capability) due to a lack of licensee guidance in defining a
"significant" loss of capability to the operators. A Notice of
Violation was issued covering this and several reporting violations.
The licensee's onsite emergency response capabilities remain
excellent, however more direct involvement in resolving offsite
deficiencies would have resulted in more timely resolution of those
problems.
2. Conclusion
Rating: Category 2
Trend: Improving
3. Board Recommendations.
Licensee: None
NRC: None
o
, 24
G. Security and Safeguards (2%, 86 hours9.953704e-4 days <br />0.0239 hours <br />1.421958e-4 weeks <br />3.2723e-5 months <br />)
1. Analysis
The previous SALP rating was Category 1. Strengths were identified
as: some increase in management attention to the program; improve-
ments in the training program; and no violations. Weaknesses in-
cluded: maintenance and testing program; security training for
contractors; audits; and program management.
Two unannounced physical protection inspections were performed during
the assessment period by region-based inspectors. Routine resident
inspections continued throughout the assessment period.
In December 1985, at the licensee's initiative, members of the
licensee's new plant management team met with NRC Region I represen-
tatives to discuss weaknesses in the security program that they had
recognized and to describe the actions they had taken and planned to
take to correct them.
A routine, unannounced physical security inspection was conducted in
January 1986. During that inspection several examples of ineffective
access controls and vital area barriers were identified. Also during
that inspection, the licensee's resolution to several findings of the
Regulatory Effectiveness Review (RER) conducted in May 1985 were
reviewed and found to be ineffective. These findings indicate the
following program weaknesses: security was not properly integrated
with other plant groups; there was a lack of program management
direction and coordination; and there was a poor understanding of NRC
program objectives. Some of these program weaknesses were identified
by the licensee in the December 1985 meeting but the licensee's
corrective action plan had not yet taken effect.
As a result of the inspection an enforcement conference was held in
February 1986, at which time the licensee's senior management rep-
resentative outlined planned corrective actions to effect improve-
ments on an expedited basis. Significant among these was the
immediate assignment of an individual, on site, as program manager.
The absence of such an individual to provide oversight and direction
to the program had previously been brought to the licensee's
attention on several occasions by NRC. Also discussed were the
corrective actions that had already been initiated and commitments
for an even more comprehensive review of the program to identify
other potential problems.
A followup inspection in June identified that the licensee promptly
implemented actions to correct the specific violations identified in
the January inspection and those actions were effective. In
addition, several program improvements and enhancements had been
implemented and others had been initiated as a result of the
.
. 25
censee's comprehensive program review. Noteworthy among these was
a ongoing major revision to the security program plans to improve
the comprehensiveness and usability. The revisions are scheduled
for > bmission to the NRC by the end of 1986.
License management also instituted the following changes to improve
coordinat~on, communication and interface among the plant organiza-
tional uni : key security supervisors have been directed to attend
all signifi nt plant meetings and to conduct weekly security super-
visors' revie meetings, in an effort to improve both internal
security and i erdepartmental communications; the proprietary and
contractor secur ty management, supervision and records have been
consolidated in a entral, onsite location; and, more active involve-
ment of corporate s curity management in site activities was
initiated, and a wel u fled security specialist from the
corporate staff was a -
ed to conduct periodic announced and
unannounced audits of t curity program.
The licensee submitted a t al f 11 event reports, in accordance
with 10 CFR 73.71, that per d to the security program. Four of
the events were attributable he lack of a quality maintenance and
surveillance program for secur elated equipment. Three events
involved failure to follow proc one by a member of the se-
curity force and two by other pla kers. One event resulted
from a human error by a member of urity force. The remaining
events involved contractors who had at lied with the licensee's
personnel screening program requireme were identified by the
licensee's routine and aggnssive audit ram of this aspect of the
security program. The event reports gen contained sufficient
information to permit adequate NRC assess . In a few cases,
however, telephone contact with the license was necessary to de-
termine the root cause of the event. The qu ity of event reports
showed notable improvement toward the end of t is assessment period.
Compensatory actions implemented as a result of he events were found
to be prompt and appropriate in all cases. The censee's program
for identifying and reporting security events is c sidered adequate
but could be strengthened by providing better docum tation of the
analyses of the root causes of events, which could as ist the li-
censee in earlier identification of potential problem eas.
As a result of an NRC-identified weakness in the security 'orce
training and qualification (T&Q) program, and in an effort o enhance
the administration of training, the licensee initiated the velop-
ment of comprehensive lesson plans about mid-way during the a ess-
ment period. The effectiveness of this effort has not yet been
assessed by NRC. This effort, in conjunction with the major rev fon
to the physical security program plans previously addressed, repre
sent a substantial resource expenditure on the part of the licensee
and demonstrates a recent initiative by management to implement a
high quality program.
a
. 25 A
licensee's comprehensive program review. Noteworthy among these was
an ongoing major revision to the security program plans to improve
their comprehensiveness and usability. The revisions are scheduled
for submission to the NRC by the end of 1986.
Licensee management also instituted the following changes to improve
coordination, communication and interface among the plant organiza-
tional units: key security supervisors have been directed to attend
all significant plant meetings and to conduct weekly security super-
visors' review meetings, in an effort to improve both internal
security and interdepartmental communications; the proprietary and
contractor security management, supervision and records have been
consolidated in a central, onsite location; and, more active involve-
ment of corporate security management in site activities was initi-
ated, and since 1980, a well qualified security specialist from the
corporate staff has conducted periodic announced and unannounced
audits of the security program.
The licensee submitted a total of 11 event reports, in accordance
with 10 CFR 73.71, that pertained to the security program. Four of
the events were attributable to the lack of a quality maintenance and
surveillance program for security related equipment. Three events
involved failure to follow procedures, one by a member of the se-
curity force and two by other plant workers. One event resulted
from a human error by a member of the security force. The remaining
events involved contractors who had not complied with the licensee's
personnel screening program requirements and were identified by the
licensee's routine and aggressive audit program of this aspect of the
security program. The event reports generally contained sufficient
information to permit adequate NRC assessment. In a few cases,
however, telephone contact with the licensee was necessary to de-
termine the root cause of the event. The quality of event reports
showed notable improvement toward the end of this assessment period.
Compensatory actions implemented as a result of the events were found
to be prompt and appropriate in all cases. The licensee's program
for identifying and reporting security events is considered adequate
but could be strengthened by providing better documentation of the
analyses of the root causes of events, which could assist the li--
censee in earlier identification of potential problem areas.
As a result of an NRC-identified weakness in the security force
training and qualification (T&Q) program, and in an effort to enhance
the administration of training, the licensee initiated the develop-
ment of comprehensive lesson plans about mid-way during the assess-
ment period. The effectiveness of this effort has not yet been
assessed by NRC. This effort, in conjunction with the major revision
to the physical security program plans previously addressed, repre-
sent a substantial resource expenditure on the part of the licensee
and demonstrates a recent initiative by management to implement a
high quality program.
"
.
.. 26
,
During the assessment period, the licensee submitted one revision to
the security force training and qualifications (T&Q) plan. The
changes were responsive to NRC comments on a previous revision and
were found acceptable under 10 CFR 50.54(p). In an effort to improve
the quality of the security plan, licenste representatives, on their
, own initiative, visited the Region I office during this period to
discuss the major plan revision.
The licensee has provided all functions of the security program with
adequate staffing to meet program requirements. The assignment of a
program manager should' continue to strengthen the management of
resources and the effectiveness of the program.
In summary, the effectiveness of the security program, in general,
and the performance of the security force have improved during the
latter portion of this assessment period. The improvement is
attributed to implementation of the new commitments by licensee
management. However, the full effect of the implemented changes
cannot yet be completely assessed, and will be monitored during the
next SALP period.
i 2. Conclusion:
Rating: Category 2
Trend: Improving
, 3. Board Recommendations
j
Licensee: None
NRC: None
1
)
. . - _ _ , _
.,__.-__.-._7- _ _ - _ , _ - , _ , , , - , . . -
. . , . _ , . _ . _ , _ . _ , , . . _ , _ _ - _ . - , _ _ . - . . . . _ _
-
. , , - . _ - _ . _
.. __. __ _________ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _
,.
O
, 27
H. Outage Activities (15%, 637 Hours)
1. Analysis
During the previous assessment period, this area was evaluated as
Category 2 on the basis of observing the cycle 6/7 refueling outage
completion. Strengths included reorganization of the planning effort
and sound startup test procedures. Weaknesses included high man-rem
exposure and inaccurate drawings.
The unit was shut down from January 14 to March 12, 1986 for its sey-
enth refueling.
Several inspections were performed to examine the preparation for and
execution of the outage health physics program. The Environmental
Qualification program was reviewed by a team inspection and by the
resident inspectors. Startup physics testing, outage and modifica-
tion activities, and the licensee's response to Inspection and
Enforcement Bulletin 80-11 regarding masonry walls were also
inspected.
Major preplanned activities during the outage included refueling,
steam generator examination, replacement of the turbine generator low
pressure rotors, replacement of condenser tube inserts and installa-
tion of a new control system for the main boiler feed pumps. In ad-
dition, many smaller maintenance and modification activities were
completed. The refueling, steam generator examination and turbine
rotor replacement were performed by Westinghouse. Refueling activi-
ties were monitored by Westinghouse QC inspectors with licensee QC
inspectors overseeing the activities. Extensive preplanning and man-
agement oversight were provided by the licensee for these major
projects.
As discussed in the previous SALP, licensee management has aggres-
sively pursued improvements in outage management. A projects plan-
ning group was created and applied modern planning and scheduling
techniques to the outage. Outage coordinators were appointed for
major projects and work areas and provided effective oversight, coor-
dination, and feedback to upper management. The institution of the
project resource evaluation and management information system
(PREMIS) and improved maintenance management had positive effects on
communication, planning, and control of outage activities. The re-
suits of the extensive preplanning and strong, effective, day-to-day
management of outage activities was evident, enabling management to
focus their attention during the outage on major activities and
unanticipated problems.
During the previous assessment period, problems with radiological
controls during an outage led to an Order Modifying License. During
this assessment period, radiological controls were found to be
e-
, 28
significantly improved although some weaknesses were noted (see
Section IV.8).
During this outage, the licensee completed the installation of
several self-initiated modifications which were to improve plant
safety and performance. These included a new control system for the
Main Boiler Feedwater System, a new dryer system for the Instrument
Air System, and replacement of the cooling coils in two Containment
Fan Cooler Units. There are, however, examples of inadequate and
untimely resolutions to technical issues. In July 1984, Indian Point
Unit 3 tripped due to an electrical fault caused by salt spray from
the main condenser lifting jet exhaust. As a result, the lifting jet
exhaust was planned to be rerouted at Unit 2 but this modification
was not implemented before Unit 2 tripped on September 20, 1985 due
to a transformer short from salt buildup from the If fting jet
exhaust. Increased management attention is needed to improve the
timeliness of the resolution of technical issues.
A lack of effective primary containment closeout was observed during
several inspections. Problems, including missing seismic supports
and poor housekeeping, that should have been identified by the
licensee prior to closecut have already been described in Sections
IV. A. and IV. C. of this report.
The Cycle 8 startup physics tests were performed in accordance with
approved test procedures by highly qualified personnel. The Reactor
Engineering staff is small, but highly qualified with reactor engi-
neering activities always performed in a highly professional manner
and well documented. The licensee's performance of startup physics
testing during the approach to criticality and subsequent zero power
physics tests and power ascension tests was deliberate and carefully
controlled. At each power level, all test results were analyzed and
thoroughly understood prior to raising power to the next level.
QA/QC involvement in startup physics testing was consistently visi-
ble. During the startup period, a QA auditor was present to witness
zero power physics testing and, at the conclusion of the testing, a
thorough and comprehensive audit was performed by the same QA audi-
tor. These examples are indicative of the involvement of management
in assuring quality programs are adequately performed.
'
Inspections were conducted of the licensee's Environmental Qualifi-
cation (EQ) program. Some problems were identified with activities
relating to the assurance of quality of the EQ program and these are
described in Section IV. J. Overall staffing was adequate to
properly administer the program.
Licensee response to the major inspection issue (potentially unquali-
fled Lewis Cable) was prompt and effective. The response included an
evaluation of potential failure modes, a temporary operating in-
struction, a justification for continued operations, the replacement
. _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _
. 29
of Lewis cable in the Hydrogen Recombiner thermocouple circuit prior
to startup from the refueling outage, and performance of testing
on the removed cable.
Management responsible for EQ maintained a file of related NRC
initiatives including records of licensee actions and final resolu-
tions. Licensee response to the most recent NRC initiatives relating
to issues of particular concern, such as the limitorque wiring def t-
ciencies identified in Information Notice 86-03, were prompt and gen-
erally thorough. The field execution of some of these corrective
actions was inadequate in some cases such as poorly sealed conduit
and unqualified splices. The licensee identified several deficien-
cies in the implementation of the EQ program including unqualified
terminal blocks. Corrective actions were prompt and effective
and included extensive direct involvement by top management in
investigating the root cause of the deficiencies.
Licensee responsiveness to NRC initiatives was also evidenced by Con
Edison's response to IE Bulletin 80-11. The response was adequate,
in that appropriate action was taken in a timely manner to assure
that those masonry walls in close proximity to or attached to
safety-related piping or equipment were independently identified and
evaluated for modification.
The licensee's initiatives to establish a program to repair cracked
mortar joints and evaluate the cause, adequacy of repair, and need
for a surveillance program is another example of the licensee's re-
sponsiveness to NRC concerns.
In summary, improvements in outage management were evident and
resulted in effective outage control. Startup testing continues to
be performed well. The licensee's implementation of Environmental
Qualification requirements and response to masonry wall issues were
effective.
2. Conclusion
Rating: Category 1
Trend: No basis for trend assessment
3. Board Recommendations
Licensee: Assess effectiveness of prioritization of proposed design
changes and modifications.
NRC: None
- - . _.
, 30
I. Training and Qualification Effectiveness (N/A)
1. Analysis
During this assessment period, training and qualification effective-
ness is being considered as a separate functional area for the first
time. Training and qualification effectiveness continues to be an
evaluation criterion for each functional area.
The various aspects of this functional area have been considered and
discussed as an integral part of other functional areas and the re-
spective inspection hours have been included in each one. Conse-
quently, this discussion is a synopsis of the assessments related to
training conducted in other areas. Training effectiveness has been
measured primarily by the observed performance of licensee personnel
and, to a lesser degree, as a review of program adequacy. The dis-
cussion below addresses thrce principal areas: licensed operator
training, nonitcensed staff training, and status of INPO training
accreditation.
During the assessment period, inspections routinely reviewed training
effectivenss. A programmatic nonlicensed training inspection was
conducted and radiological training effectiveness was examined during
the health physics appraisal. The plant radiological training
program was found to be effective; however, NRC identified
weaknesses in contractor HP technician training for which the
licensee took appropriate action. Non-licensed technician training
has resulted in some improvements, especially in the identification
of equipment deficiencies; in the conduct of surveillance
activities; and in the effective response by the fire brigade.
The performance of nonlicensed staff, indicates that the training and
qualification program contributes to an adequate understanding of
their work and adherence to procedures. The one instance of per-
sonnel error related to surveillance activities which resulted in a
reactor trip is considered an isolated case.
The licensee is proceeding on schedule with INP0 accreditation of
training programs. To effectively manage the activities for seeking
fu': INP0 accreditation the licensee has newly established and
staffed the position of Project Manager - INP0 Accreditation. All
Operations Training programs have been evaluated by INP0. All other
training programs have been submitted for INPO evaluation except for
the Management and Technical Staff program which was submitted
September 1, 1986. The licensee training staff has been increased to
develop and teach these new programs.
.E
, 31
In addition, the licensee has remodeled the simulator building to
provide a training library, four classrooms and additional offices.
An upgrade of the licensee's non-licensed training center has been
budgeted.
Training in the use of Emergency Operating Procedures (E0Ps) appears
to be effective as evidenced by their use following unit trips. The
licensee provided six weeks of classroom and simulator training on
E0Ps before they were implemented. Operators have accepted the.EOPs
and have performed well while using them in licensing exams.
Two areas in which training effectiveness appears weak are in
security and operations. The NRC identified a weakness in the
security force training and qualification program. The
effectiveness of the licensee's improvements has not yet been
determined. In addition, some enhancements are not yet in effect
due to an outstanding plan revision.
Several inadequacies exist in the plant simulator which is considered
marginally acceptable for examinations. In the past, the licensee
has not been aggressive in updating the simulator. -Although, the
licensee recently decided to upgrade the simulator, management
attention is warranted to assure that the upgrade is properly and
expeditiously completed or the upgrades may take several years to
complete.
Operator licensing candidates have been well prepared as evidenced
by all six license candidates passing their_ exams and being issued
licenses. However, three plant trips occurred which may be attri-
buted to licensed operator training. Two trips occurred when gen-
erator load was increased too quickly resulting in a high level Steam
Generator trip. One trip occurred on plant startup when the operator
failed to block the low setpoint high flux trip signal quickly
enough. These events occurred during normal evolutions. Insufft-
cient training dedicated to normal evolutions and inaccurate simula-
tion of these evolutions may have contributed to these events.
In summary, shortcomings exist in the plant simulator. E0P training
was effective and operator training in general is a strength although
isolated examples of ineffective operator action were identified.
The INPO accreditation program is on schedule. Non-licensed training
is adequate.
2. Conclusion
Rating: Category 2
Trend: Consistent
, 32
3. Board Recommendatior.s
Licensee: None
NRC: None
.
. 33
J. Assurance of Quality (N/A)
1. Analysis
Management involvement and control in assuring quality continues to
be.an evaluation criterion for each functional area. During this
assessment period, assurance of quality is being considered as a sep-
arate functional area. The various aspects of the programs to assure
quality have been considered and discussed as an integral part of
each functional area and the respective inspection hours are included
in each one. Consequently, this discussion is a synopsis of the
assessments relating to assurance of the quality of work conducted in
all areas.
The enhancement of design change / modification procedures to step-by-
step detailed instructions; a " traveler" type work control method;
and the allocation of human resources for effective work planning
indicates an increased involvement by senior management in assuring
efficient plant operations and better control over the work process.
The day-to-day involvement of QA and QC in the overview of ongoing
activities has been expanded and is under improved administrative
control. Completed work packages demonstrated that the QA and QC
functions were being properly implemented. For example the
licensee's QA/QC during masonry wall repairs in response to IE
Bulletin 80-11 was thorough. Hold points were established for review
and verification of work by Con Edison's Site Power Generating QA
engineers and for witnessing and verification of specific tests by
QC. The overall acceptability of the wall modification work was au-
dited by Con Edison's corporate quality assurance and reliability
organization. This involvement is not as evident in the areas of
operations and surveillance activities.
Assurance of quality is achieved by the craft worker's supervisors
through the supervisor periodically checking the work site and
verifying worker compliance with the procedure. The supervisors, QA,
and QC also review completed work packages for procedure compliance.
If, in the opinion of QA or the maintenance department, an indepen-
dent inspection is required to satisfy requirements, QC will perform
the independent inspection and these inspections are documented in
the work procedure. This approach appears to be effective.
Surveillance test procedure results are reviewed by the operations
department for acceptability requirements and then finally reviewed
by the test engineering department. The test procedures themselves
are reviewed by the test engineering department and the Station
Nuclear Safety Committee (SNSC) for safety considerations, ease of
^~
..
m
, 34
performance, and meeting Technical Specification requirements. The
performance of tests is monitored as necessary by the test engineers
to verify compliance with the written test procedures. -
QA is responsible for the proper performance of material receipt
inspection. Written instructions are used by receipt inspectors to
check the materials for damage, conformity to procurement documents
and the level of quality of the vendor's material prior to the
inspector accepting the material.
The licensee has revised and updated QA and corporate engineering
procedures to include Environmental Qualification (EQ) program
implementation. However, only one QA audit of the EQ program was
conducted.
The QC outage surveillance program, which has provisions to increase
surveillance frequencies in areas of high unsatisfactory performance
and to decrease surveillance frequencies for areas with acceptable
performance, was effectively implemented during this appraisal
period. The NRC found during a review of this program that the
licensee effectively prioritized their work load so that areas (or
work items) demonstrating poor performance, received a greater amount
of surveillance.
There was no apparent QC involvement in initial field work done to
implement the EQ program except for modifications involving the
replacement of non-EQ equipment. Deficiencies in the application of
sealants were identified by NRC EQ inspections and resulted in a large
effort to reinspect and reapply seals. Also in the QC area, weak-
nesses in performing close out inspections of the Containment Building
and other areas after outages were apparent. One additional concern
was identified due to inadequately establishing and executing the QC
program for radwaste. The licensee's corrective actions were res-
ponsive to this concern.
'
The quality of the SNSC review of events, procedures and other items
continues to be good although in one instance, the plant trip on
June 9, the committee did not identify a root cause for the trip and
focused their review almost exclusively on a safety injection actu-
ation which followed the trip. On August 1, 1986, the SNSC chairman
and General Manager of Technical Support transferred within the
company. The SNSC chairman had a major impact on improv Ng the
quality of the SNSC reviews. The Nuclear Engineering group at cor-
porate headquarters has now been consolidated at the site with the
Technical Support Department as of August 1. The Chief, Nuclear
Engineering, is now General Manager of Technical Support and the new
SNSC chairman.
. . -- -
.
.
. 35
The Nuclear Facilities Safety Committee (NFSC) reviews of licensee
activities have been thorough. NFSC discussions of operational
events and equipment failures have focused on evaluating their safety
significance, root causes, and corrective actions. The use of
sub-committees contributed to the thoroughness of these evaluations.
In summary, the attention of management appears to be focused on
quality. Quality programs are generally effective although their
involvement in operations and surveillance is not as evident as in
other areas.
2. Conclusion
Rating: Category 2
Trend: Consistent
3. Board Recommendations
Licensee: None
NRC: None
O
, 36
K. Licensing Activities (NA)
1. Analysis
During the SALP evaluation period, the licensee has shown good man-
agement overview in the area of licensing activities. This was evi-
dent through the timely submittal and subsequent approval of several
license amendments aimed at improving the cycle 7/8 refueling outage
which occurred during the rating period. The licensee's management
demonstrated active participation in licensing activities and kept
abreast of current and anticipated licensing actions. All open li-
censing actions are scheduled and tracked through use of the
licensee's Regulatory Action Tracking System. During the rating pe-
riod, a system for identifying both licensee and NRC priority items
was initiated.
The licensee's submittals are most often timely. However, in many
instances, additional information or revisions are necessary before
review can be completed. This occurs most often in the area of
plant-specific licensing actions. The licensee's treatment of the no
significant hazards standards of 10 CFR 50.92 has shown some im-
provement, however, further improvement in this area is needed. The
licensee tends to provide too little detail in most discussions.
There were several instances during the period when submittals were
made following their scheduled submittal date. These submittals
were, in all instances, required because of NRC requests for infor-
mation. In most instances, the original schedules were set by
the licensee after receipt of the information request, and, in most
cases, the licensee informed the staff that the submittals would be
late. The schedular delays are usually limited to one or two weeks
and seem to be more a management problem that a responsiveness
problem. The fact that schedule dates were not arbitrarily imposed
by the staff, but instead agreed upon or set by the licensee, and
that the licensee appears to be more responsive to those items for
which it has placed a high priority rather than those for which the
NRC had indicated a high priority demonstrates need for more
management attention to ensure prompt resolution of safety issues. A
- new policy has been initiated whereby both the licensee and the NRC
will agree on prioritization of certain licensing actions. This
should belp alleviate some of the past problems in this area.
The licensee maintains a significant technical capability in almost
all engineering and scientific disciplines necessary to resolve items
of concern to the NRC and the licensee. In addition, the licensee
utilizes the services of other nuclear support groups to assist in
the resolution of technical problems or to utilize new and proven
techniques that will enhance the operation and safety of the Plant.
,
I
l
- - , _ . - - - _ _ - -
C
, 37
The licensee's extensive and improving technical capability is re-
flected in the submittals made in support of, or in response to,
licensee or NRC initiated actions. Although, as discussed above, the
licensee is not always forthcoming with all of the information neces-
sary to complete a review without requests for additional informa-
tion, few licensee responses to NRC requests for additional
information require subsequent questions.
It should be noted that during the assessment period the licensee was
requested to provide a detailed submittal concerning the alternate
shutdown capability of Indian Point 2 in the remote chance of loss of
certain capabilities due to high winds at the site. The information
was requested with a fairly short turnaround time. The licensee
provided a timely and thorough submittal.
The licensee's licensing activities are conducted by a well staffed
and well trained group resulting in an overall efficient operation.
Management overview is evident in that the licensing group is well
integrated into other plant activities and licensing activities re-
flect a uniform approach. Upper management becomes involved in 11-
censing actions when necessary to assist in resolving potential
deadlocks.
The licensing group has exhibited a high degree of cooperation with
the NRC staff. The good communication between the licensing group
and the NRC has been !.aneficial to both in the processing of licens-
ing actions. Areas of expertise are well defined within the group.
In addition the group does an excellent job of coordinating the ef-
fort when input is required from the different groups within Consoli-
dated Edison. However, the group could be more effective if
management would emphasize to all Consolidated Edison supporting
organizations the need for meeting ccmmitted licensing schedules for
responding to the NRC. The licensing group holds informal training
sessions on topics of current and future interest. The group also
participates in corporate-wide training programs and participates in
industry-wide training programs provided by various organizations.
In summary, the licensee's greatest strengths appear to be in its
extensive technical capability that is reflected in its submittals
and discussions with the NRC, and, in the continued upgrading of the
experience, capability and effectiveness of the licensing group and
the supporting administrative and technical personnel required to
operate a good facility. More detail in submittals would require
fewer iterations during the review process, and, closer attention to
submittal schedules would avoid short term schedular slippages.
., . - _ - - . - - -
C
', 38
2. Conclusion:
Rating: Category 2
Trend: Improving
3. Board Recommendations
Licensee: None
NRC: None
.
. 39
V. SUPPORTING DATA AND SUMMARIES
A. Investigation and Allegation Review
No investigations were conducted during the assessment period.
Four allegations were received during the assessment period:
improper ALARA performance;
individual disciplined for refusing to work in the containment
building;
security guards discouraged from talking with NRC inspectors;
radioactive spill released to river, inadequate radiation pro-
tection for workers during spill cleanup.
All four allegations were inspected and closed out with no violations
identified.
B. Escalated Enforcement Actions
No civil penalties, or confirmatory action letters were issued. No
orders were issued for enforcement action. One enforcement confer-
ence was held on February 13, 1986 for security violations.
C. Management Conferences
October 25, 1985: SALP management meeting;
December 17, 1985: 1986 refueling outage preparations and
plans, review of maintenance related LERs for the previous SALP
period, and analysis and corrective actions for reactor trips.
D. Licensee Event Reports (LERs)
1. Causal Analysis
Thirty-five LERs, numbered 85-07 thru 86-24, were reviewed for
this assessment period. These LERs are characterized in Table 1
by cause for each functional area. The following causally-
linked event sets were identified:
LER No. Cause
85-10 These events are reactor trips due to personnel
85-12 error.
85-14
85-16
85-24
86-08 These events are instances of instrument setpoint
86-09 drift.
86-11
86-22
'
..
. 40
2. AE0D Review
The Office for Analysis and Evaluation of Operational Data
(AE00) assessed a third of the LERs submitted during the
assessment period using a refinement of the basic methodology
presented in a report entitled "An Evaluation of Selected
Licensee Event Reports Prepared Pursuant to 10 CFR 50.73
(DRAFT)," NUREG/CR-4178, March 1985. The results of this eval-
uation were forwarded to the licensee on October 3,1986, _ and
indicate that Indian Point 2 LER's are above average.
The principal weaknesses identified in the LERs, in terms of
safety significance, involve the requirement to provide identi-
fication of failed components. The failure to adequately iden-
tify the manufacturer and model number of the components that
fail prompts concern that others in the industry won't have im-
mediate access to information involving possible generic
problems.
Strong points for the Indian Point 2 LERs cre the c'i3cussions of
the mode, mechanism, and effect of failed components, and the
discussion of personnel errors.
..
-. 41
,
TABLE 1
TABULAR LISTING OF LERs BY FUNCTIONAL AREA
INDIAN POINT STATION - UNIT 2
Area Number /Cause Code Total
A B C D E X
A. Plant Operations 7 1 8
B. Radiological Controls 0
and Chemistry
__ C. Maintenance 2 1 3
D. Surveillance 2 2
E. Fire Protection 0
G. Security and Safeguards 0
H. Outage Activities 0
1. Training and Qualification 0
Effectiveness
, J. Assurance of Quality 1 1
K. Licensing Activities 0
L. Other 2 1 1 15 2 21
TOTALS 11 3 1 3 15 2 35
Cause Codes:
A - Personnel Error
B - Design, Manufacturing, Construction, or
Installation Error
C - External Cause
D - Defective Procedure
E - Component Failure
X - Other
.
w y_ -- _ --_ p ---__#_ -
,,
-. 42
TABLE 2
INSPECTION HOURS SUMMARY (8/1/85 - 7/31/86)
INDIAN POINT STATION - UNIT 2
Area Hours % of Time-
A. Plant Operations ........................... 981 23
B. Radiological Control s and Chemi stry. . . . . . . . . 903 21
C. Maintenance ................................ 550 13
D. Surveillance ............................... 585 14
E. Fire Protection............................. 234 6
F. Emergency Preparedness ..................... 265 6
G. Security and Safeguards .................... 86 2
H. Outage Activities .......................... 637 15
I. Training and Qualification Effectiveness ** . N/A --
J. Assurance of Quality ** ..................... N/A --
K. Licensing Activities * ...................... N/A ---
TOTAL' 4241 100%'
- Hours expended are not included with direct inspection effort statistics.
- Hours expended in training and assurance of quality are included in other
functional areas. <
.
l
i
,
mr +=w-
. . . - .
, _
_
-
.
, 43
TABLE 3
ENFORCEMENT SUMMARY (8/1/85 - 7/31/86)*
,
INDIAN POINT STATION - UNIT 2
Severity Levels
AREA I II III IV V TOTALS
A. Plant Operations 1 3 4
B. Radiological Controls and Chemistry 2 2
C. Maintenance 2 2
D. Surveillance 0
E. Fire Protection 1 'l
G. Security and Safeguards 1 1 2
H. Outage Activities 0
i
I. Training and Qualification
Effectiveness 0
'
.
J. Assurance of Quality 1 1
K. . Licensing Activities 0
.
TOTAL 0 0 1 7 4 12
- Does not' include Inspection Report 86-11
1
4
i
,.
.,n- .-n , .. ,. , _ n - -- - , , . , . , - . -
- ;7 _
.. 44
TABLE 3 (CONT'D)
Inspection Severity Functional
Report /Date Level Area Violation
86-01 IV Quality Inadequately established
1/6-10/86 Assurance and executed QC program
to assure compliance with
10 CFR 61.55 and 10 CFR
61.56.
86-02 III Security & Three instances of
1/13-17/86 Safeguards failure to control
access to vital areas.
V
"
Failure to perform an
adequate search of
contractor's vehicle
entering protected area.
86-08 IV Radiological Failure to post high
2/24/86 Controls radiation boundaries.
IV "
Failure to follow
-procedures for use of
protective clothing,
posting contaminated
areas, and writing
event reports.
86-10 V Operations / Failure to submit Annual
4/1-30/86 Radiological Radiation Exposure
Controls Report on time, failure
to make telephone
notification.
86-15 IV Maintenance / Unit brought out of cold
6/10-7/7/86 Outage shutdown with seismic
restraint disconnected.
86-19 IV Operations Failure to properly
7/2-8/1/86 establish and maintain
Emergency Operating
Procedures and Abnormal
Operating Procedures.
-
,
. ,
, 45
TABLE 3 (CON'T'D)
Inspection Severity Functional
Report /Date Level Area Violation
86-19 IV Maintenance / Recirculation sump
7/2-8/1/86 Outage grating not properly
reinstalled.
IV Housekeeping Failure to follow house-
keeping procedures.
86-23- V Operations Failure to notify the
7/8-31/86 NRC in accordance with
10 CFR 50.72 on three
separate occasions.
"
V Failure to perform
required operability
. checks on a Control Rod
Drive and Plant Vent
Noble Gas Activity
Monitor.
'I
-w--- e , - -- -rr- ,,-w ,-n,n-_-,m,- ---,-ve.-we---,,mer=-ww--- - - - --m--,, - -, - -w
. 46
TABLE 4
INSPECTION REPORT ACTIVITIES (S/1/85 - 7/31/86)
INDIAN POINT STATION - UNIT 2
Report / Dates Inspector Hours Areas Inspected
85-21 Resident 51 Routine, daily inspections
8/1-31/85 and unscheduled backshift
inspections.
85-22 Specialist 108 Special, announced safety
9/17-20/85 inspection of masonry wall
design (Bulletin 80-11).
85-23 Resident 131 Routine, daily inspections
9/1-30/85 and unscheduled backshift
inspections.
85-24 Specialist 201 Routine, announced safety
9/16-20/85 inspection of 10 CFR 50,
Appendix R.
85-25 Resident 208 Routine, daily inspections
10/1-31/85 and unscheduled backshift
inspections.
85-26 Resident 120 Routine, daily inspections
11/1-30/85 and unscheduled backshift
inspections.
85-27 Specialist 65 Special, unannounced
11/12-15/85 dosimetry inspection.
85-28 Specialist Licensed operator exams.
12/10-13/85
85-29 Specialist 41 Routine, unannounced
12/2-6/85 inspection of design changes /
modifications and QA program.
85-30 Resident 217 Routine, daily inspections
12/1/85-1/15/86 and unscheduled backshift
inspections.
85-31 Specialist 46 Special inspection of
12/16-18/85 licensee's implementation of
radiological controls
improvement program.
a
. 47
TABLE 4 (CONT'D)
Report / Dates Inspector Hours Areas Inspected
86-01 Specialist 37 Routine, unannounced
1/6-10/86 inspection of transportation
activities.
86-02 Specialist 43 Routine unannounced
1/13-17/86 safeguards inspection.
86-03 Cancelled
86-04 Specialist 141 Routine, unannounced
1/21-24/86 inspection of radiation
protection program.
86-05 Resident 230 Routine, daily inspections
1/16-3/3/86 and unscheduled backshift
inspections.
86-06 Specialist 132 Special, unannounced
2/10-14/86 inspection of maintenance,
modifications, and outage
controls.
86-07 Specialist 30 Routine, announced inspection
2/10-13/86 of the nonradiological
chemistry program.
86-08 Specialist 128 Special, unannounced
2/24-28/86 inspection of radiological
controls program.
86-09 Resident 184 Routine, daily inspections
3/4-31/86 and unscheduled backshift
inspections.
86-10 Resident 148 Routine, daily inspections
4/1-30/86 unscheduled backshift
inspections.
86-11 Specialist 142 Special, announced inspection
5/12-16/86 of environmental qualification.
86-12 Resident 280 Routine, daily inspections
5/1-6/9/86 and unscheduled backshift
inspections.
-, 48
.
'
TABLE 4 (CONT'D)
Report / Dates Inspector Hours Areas Inspected
86-13 Specialist 242 Routine, announced emergency
6/2-5/86 preparedness inspection and
observation of emergency
exercise.
86-14- Specialist 50 Routine, un&nnounced
6/2-6/86 inspection of non-licensed
staff training.
86-15 Resident 145 Routine, daily inspections
6/10-7/7/86 and unscheduled backshift
inspections.
86-16 Specialist 25 Routine, unannounced
6/2-5/86 safeguards inspection.
86-17 Specialist 241 Special, announced health
6/16-20/86 physics appraisal.
86-18 Specialist 42 Special, unannounced
6/16-20/86 inspection of sewage
contamination.
.
86-19 Specialist 586 Special, announced
7/21-8/1/86 probabilistic risk
assessment based inspection.
86-20 Specialist 40 Special, announced inspection
7/10-17/86 of post-accident sampling
and monitoring.
86-21 Specialist 30 Routine, unannounced radio-
7/15-18/86 active effluents inspection.
86-22 Specialist 35 Routine, unannounced
7/14-18/86 inspection of startup
physics program.
86-23 Resident 122 Routine, daily inspections
7/8- /86 and unscheduled backshift
inspections.
4241 hours0.0491 days <br />1.178 hours <br />0.00701 weeks <br />0.00161 months <br />
i
a
, 49
TABLE 5
LISTING OF ALL AUTOMATIC TRIPS AND UNPLANNED SHUTDDWNS
INDIAN POINT STATION - UNIT 2
Power
No. Date Level Description Cause (Note 1)
1 9/20/85 95% Reactor trip on turbine Modification
generator trip. Turbine control. Untimely
generator tripped due to correction of
short on #21 main trans- design error.
former. Brackish water
drifting from lifting jet
exhaust caused short.
(LER 85-09)
9/23/85 Startup
2 9/23/85 12% Reactor trip on turbine trip. Personnel error -
Turbine tripped on high steam operations. Oper-
generator level . Steam gener- ator failed to an-
ator swell while picking up ticipato swell.
load after bus synchronization Simulator modeling
caused high level. (LER 35-10) and training con-
tributed to high
rate of load
pick-up.
9/24/85 Startup
3 9/27/85 77% Tech. Spec. required shutdown Natural event.
due to hurricane Gloria.
9/27/85 Startup
4 9/28/85 25% Reactor tripped on power range Personnel error -
high flux-low level trip signal. operations. Oper-
The high flux level occurred ator failed to
during power ascent. (LER 85-12) block trip signal
as required by
procedure due to
high rate of load
pickup.
9/28/85 Startup
Note 1 - Determined by SALP Board, may not agree with LER Analysis
a:
50
TABLE 5-(CONT'D)
Power
No. Date Level Description Cause (Note 1)
5 10/24/85 13% Reactor trip on turbine. trip. Personnel error -
Turbine tripped on high steam operations. Oper-
generator level. Steam gener- ator failed to an-
ator swell while picking up ticipate swell.
load after bus synchronization Simulator modeling
caused high level. (LER 85-14) and training con-
tributed to high
rate of load
pick-up.
10/24/85 Startup
6 12/12/85 100% Reactor tripped on loss of flow Equipment failure
signals from coolant loop #21. maintenance.
The loss of flow signal was due A failed capacitor
to a bistable tripping in one caused a bistable
channel and a separate flow to trip.
channel being previously placed
in the tripped position due to
a faulty flow transmitter.
(LER 85-16) -
12/13/85 Startup
7 12/31/85 100% Reactor tripped on low pressur- Equipment failure -
izer pressure when a pressurizer under review
spray valve failed open. (LER A spray valve
85-17) pneumatic operator
malfunctioned.
1/1/86 Startup
8 1/13/86 94% Reactor tripped on low low Equipment failure -
steam generator level. The maintenance.
low level resulted from low High pressure oil
feedwater flow due to a trip hose failed in
of #21 Main Boiler Feed Pump MBFP controls.
(MBFP). (LER 86-01)
3/12/86 Startup (Reactor critical -
zero power).
9 5/23/86 SD Subcritical trip of shutdown Personnel error -
banks when reactor trip breaker. Surveillance. Tech-
was inadvertently opened during nician tripped the
a test. (LER 86-16) wrong breaker.
5/25/86 Startup
e.
.o. 51
TABLE 5 (CONT'0)
.
10 5/28/86 30% Reactor tripped on Safety Equipment failure -
Injection: high steam flow / low maintenance Faulty
Tavg signal. The high steam steam dump control-
flow was caused by the steam ler.
dumps opening. (LER 86-17)
5/30/86 Startup
11 5/31/86 0% Unplanned shutdown due to short Personnel error -
in exciter. maintenance. Error
in re-assembly by
contractor.
6/7/86 Startup
12 6/9/86 56% Manual reactor trip due to Equipment control -
loss of MBFP. MBFP #21 operations and
tripped while starting MBFP maintenance. High
- 22. (LER86-19) bearing oil trip
setpoint; open oil
bypass valve.
6/11/86 Startup
13 6/25/86 43% Reactor trip on turbine trip. Personnel error -
The turbine tripped due to design control.
actuation of the independent Drawing was not
electrical overspeed protection updated following
system while a technician'was plant construction.
replacing relays in that system.
(LER 86-21)
6/26/86 Startup
14 7/18/86 100% Reactor tripped when control rod Personnel error -
motor generator set was tripped operations. Oper-
while starting second motor ator failed to
generator set. (LER 86-24) properly synchro-
nize motor
generators.
7/20/86 Startup
_
y y , , n--+ w w -- , -g - y m+- y -r~ -
r
.. 52
TABLE 6
NRR SUPPORTING DATA AND SUMMARY
INDIAN POINT STATION - UNIT 2
1. NRR/ Licensee Meetings
Fuel Removal Time Constraints T.S. Application 7/9/85
IST 11/13-14/85
DCRDR 12/4/85
Organization 7/25/86
12. NRR Site Visits / Meetings
Fire Protection Audit 9/16-20/85
PM/ Resident 11/18-21/85
Refueling Activities 12/17/85
EQ Audits 5/15-16/86
3. Commission Meetings
None
4. Schedular Extension Granted
None
5. Reliefs Granted
ASME Section XI Relief 3/17/86
6. Exemptions Granted
Appendix R 11/13/85
7. License Amendments Issued
Amendment Numbers Title Date
97 Limiting Overtime, Audit Frequency 9/30/85
For EP Program and Safeguards Contingency
Plan, Quality Assurance Record Retention
Requirements
98 Fuel Removal Time Constraints 9/30/85
i
4
1
-~ - - -.,---,--,-------.--..,,--e + - + - - - - - - , . . . - - -
--w c -,n - ,-- -
g
?
'e 53
TABLE 6 (CONT'D)
Amendment
Numbers Title Date
99 Surveillance Interval Limit Extension 9/30/85
100 Initial Reactor Core Design 10/17/85
101 Decay Heat Removal, Number of Operating 10/23/85
Reactor Coolant Pumps, Over Pressure.
Protection
102 Generic Letter 83-36, 83-37 Tech. Specs. 11/13/85
103 Temporary Closure Plate 11/13/85
104 BIT Removal 12/05/85
105 Boric Acid Addition Capabilities 12/05/85
106 Organizational Changes 12/31/85
107 Anticipatory Reactor Trip on Turbine 1/13/86
Trip
108 CTMT Cooling, Iodine Removal, CTMT 1/27/86
Isolation
109 Total Nuclear Peaking Factor Limits 1/29/86
110 Part Power Multiplier 3/31/86
111 Increased Enrichment 4/21/86
112 Hydraulic Snubbers 5/19/86
113 Code Safety Valves 6/11/86
114 RV and SV Failures and Challenges, 7/22/86
Monthly Operating Report
8. Emergency Technical Specifications Isseed:
Amendment Numbers Title Date
113 Code Safety Valves 6/11/85
9. Orders Issued
Revision of Supplement 1 to NUREG-0737 6/19/86
--
4
e
54
FIGURE 1 .
'
l
NUM8ER OF DAYS SHUT DOWN
INDIAN POINT STATION UNIJ 2
'
August, 85 No Days Shut down
September, 85 15 Days Shut down
October, 85 7 3 Days Shut down
November, 85 No Days Shut down
December, 85 ] 1 Day Shut down
January, 86 19 Days Shut downl Seventh Refueling Outage
February, 86' 28 Days Shut down 1
March, 86 31 Days Shut cown i
April, 86 30 Days shut down i
May, 86 27 Days Shut down 1
June, 86 1 10 Days Shut down
July, 86 ] 2 Days Shut down
. - - . - - -
. - - - ________