ML20209H777
| ML20209H777 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/30/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20209H774 | List: |
| References | |
| 50-382-87-03, 50-382-87-3, NUDOCS 8705040120 | |
| Download: ML20209H777 (37) | |
See also: IR 05000382/1987003
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APPENDIX
>SALP BOARD REPORT:
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION IV..
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SYSTEMATIC ASSESSMENT.OF LICENSEE-PERFORMANCE
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50-382/87-03
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Louisiana Power & Light Company
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- Wate'rford Steam Electric ' Station
Unit 3
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January 1,1986, through January 31, 1987
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8705040120 870430 ~
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ADOCK 05000382
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated Nuclear Regulatory Commission (NRC) staff effort to collect
available observations and data on a periodic basis and to evaluate
licensee performance based upon this information. SALP is supplemental to
normal regulatory processes used to ensure compliance to NRC rules and
regulations. SALP is intended to be sufficiently diagnostic to provide a
rational basis for allocating NRC resources and to provide meaningful
guidance to the licensee's management to promote equality and safety of
plant operation.
An NRC'SALP Board, composed of the staff members listed below, met on
March 27, 1987, to review the collection of performance observations 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 Waterford 3 Steam Electric Station (W3 SES) for the period
January 1,1986, through January 31, 1987.
SALP Board for W3 SES included:
E. H. Johnson, Director, Division of Reactor Safety and Projects, Region IV
R. L. Bangart, Director, Division of Radiation Safety and Safeguards,
Region IV
G. W. Knighton, Director, PWR Project Directorate No. 7, Nuclear Reactor
Regulation
J. E. Gagliardo, Chief, Reactor Projects Branch, Region IV
G. L. Constable,- Chief, Project Section C, Reactor. Projects Branch,
Region IV
J. H. Wilson, Project flanager, Nuclear Reactor Regulation
J. G. Luehman, Senior Resident Inspector, W3 SES
The following personnel also participated in the SALP. Board meeting:
W. C. Seidle, Chief, Technical Support Staff, Region IV
J. P. Jaudon, Chief, Reactor Project Section A, Reactor Projects
Branch, Region IV
B. Murray, Chief, Facilities Radiological Protection Section, Radiological
and Safeguards Programs Branch, Region IV
R. E. Ireland, Chief, Engineering Section, Reactor Safety Branch, Region IV
L. A. Yandell, Chief, Emergency Preparedness and Safeguards Programs Section,
Radiological and Safeguards Programs Branch, Region IV
R. P. Mullikin, Project Inspector, Region IV
M. E. Skow, Project Inspector, Region IV
T. R. Staker, Resident Inspector, W3 SES
II. CRITERIA
Licensee perfonnance was assessed in eleven selected functional areas.
Each functional area normally represents areas significant to nuclear
safety and the environment at operating plants.
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One or more of the following evaluation criteria were used to assess each
functional area:
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1.
Management involvement and cont'rol in assuring quality.~
2.
Approach to resolution of technic ~al issues from a safety. standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Operational events (including response to, analysis of, and
corrective actions for).
6.
Staffing (includingmanagement).
However, the SALP Board was not limited to these criteria and others may
have been used where appropriate.
Based on the SALP Board Assessment, each functional area' evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1.
Reduced NRC attention may be appropriate. Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety is being
achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
operational safety is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear'to
be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety is being achieved.
III. SUMMARY OF RESULTS
Significant improvement was achieved in the area of Plant Operations,
Surveillance, Fire Protection, Outages, Licensing Activities, and Training
and Qualification Effectiveness.
Improvement was also noted in the Maintenance
functional area.
Performance in the area of Security and Safeguards has
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declined, in part, due to the failure of plant personnel outside the
security organization to carry out their responsibilities to this program.
The licensee's performance is summarized in the table below, along with
the performance categories from the previous SALP evaluation period.
Previous
Present
Performance
Performance
Category
Category
(12/18/84 to
(1/1/86 to
Functional Area
(12/31/85)
(1/31/87)
A.
Plant Operations
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2
B.
Radiological Controls
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2
C.
Maintenance
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2
D.
Surveillance
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1
E.
Fire Protection
2
1
F.
2
2
G.
Security and Safeguards
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2
H.
Outages
Not Assessed
1
I.
Quality Programs and
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2
Administrative Controls
Affecting Quality
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Licensing Activities
2
1
K.
Training and Qualification
2
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Effectiveness
The total NRC inspection effort during this SALP evaluation period
consisted of 35 inspections, including ~ resident inspector inspections and
emergency exercises, for a total of 4300 direct inspection hours. The
plant availability factor was 72.8 ' percent.
IV.
PERFORMANCE ANALYSIS
A.
Plant Operation
1.
Analysis
This area has been inspected on a continuing basis by the NRC
resident inspectors and on a periodic basis by region-based NRC
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inspectors. Licensee management involvement in the area of
plant operations was evident during this appraisal period. This
involvement was, to a large extent, responsible for the
substantial decrease in the number of both reactor trips and
licensee event reports (LERs).
The licensee management established a group responsible for the
review and reporting of potentially reportable events. This
group, which is headed by a ~ senior reactor operator (SR0), has
provided improved event analysis and higher quality LERs as
evidenced by the LER analysis performed by the 11RC Office of
Analysis and Evaluation of Operational Data (AE00). This
analysis was provided to LP&L under a cover letter dated
March 5, 1987.
There was a low turnover of personnel in the operations department
during this appraisal period.
The licensee instituted a
college degree program for licensed operators which should, in
part, encourage a continued low turnover. The increase in the
number of available licensed operators has produced a number of
benefits for the operations department.
First, it has allowed
the operations superintendent to allocate additional resources
to ongoing projects such as upgrading of operating procedures
and improving the labelling of plant equipment. Secondly, it
has made possible the transfer of a number of very experienced
licensed operators to the training department.
Upgrading of the control room and the control room panels
progressed, as conditions permitted, throughout the appraisal
period. The improvements made in the control room included
panel relabeling, painting, recarpeting, and the addition of
normal operating bands to many control room meters. Also, new
distinctive clothing, desinned based on operator suggestions,
was introduced for the on-watch licensed operators.
The licensee's program to reduce the number of illuminated
annunciators during power operations made progress during the
appraisal period; however, additional work remains to be done.
Efforts to reduce the overall number of temporary plant
alterations have also had some success, but many remain in place
with the majority awaiting completion of 'a particular plant
modification. Substantial progress was made in improving the
reliability of the engineered safety system features portion of
the control room ventilation system by replacing the chlorine
detection system. At the same time, however, during extended
shutdowns the containment purge isolation system has exhibited
operational problems. Spurious termination of containment purge
has caused diversion of the reactor operator's attention from
monitoring overall plant operations and caused high humidity in
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the containment. This made for uncomfortable working conditions
as well as condensation on equipment.
The licensee's efforts to reduce the high concentrations of
short-lived, airborne radioactivity in the reactor auxiliary
building have been fairly successful but maintaining
consistently low levels will require a continuation of the joint
effort between plant operations and health physics personnel.
Numerous-NRC inspections during the appraisal period have
identified deficiencies in system valve lineup procedures, the
referenced plant drawings, and the labelling of plant equipment.
As discussed previously, the operations superintendent has
assigned additional manpower to upgrading these areas, but these
efforts have concentrated largely on the correction of
previously identified discrepancies and not on the equally
important correction of discrepancies noted as the system
lineups are performed.
Based, in part, on observations made by the NRC resident
inspectors, the licensee has recognized that the administrative
burden on the shift technical advisors (STA) has at times
diverted them from their prime responsibility of providing the
shift supervisor with an independent engineering appraisal of.
operational situations.
Licensee management has taken a number
of steps to refocus the STA's efforts to providing the needed
technical reviews and recommendations. The steps taken included
trying to reduce STA involvement in the plant temporary
alteration request system and moving toward fully staffing all
of the approved STA positions. Overall, the STAS were well
integrated into the operating shift organization and continuing
the practice of having STAS obtain senior reactor operator
licenses should improve the operations department.
During the appraisal period, the licensee deviated from two
commitments made to the NRC in the area of plant operations.
These deviations resulted, in part, from a lack of direct
involvement of plant operations personnel in providing input to
commitments made to the NRC.
Furthermore, the lack of a
central point, responsible for ensuring the accuracy of
responses made to NRC Region IV and the NRC Office of Inspection
and Enforcement, contributed to the deviations. Without such
central coordination, there was apparently no assurance that all
the necessary departments fully understood their commitments
relative to the responses.
The licensee has made a number of changes in hardware to reduce
the number of reactor trips due to drcppcd ccr. trol element
assemblies (CEA). Additionally, core protection
calculator (CPC) software changes have been made to reduce the
impact of a dropped CEA on plant operations.
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2.
Conclusions
The NRC staff is encouraged by the large decrease in the number
of reactor trips and licensee event reports that occurred during
this appraisal period. The morale of the operations staff is
considered very high, and the confidence of the staff continues
to grow with operating experience.
Operator distractions in the control room such as various
illuminated annunciators, as well as the temporary alterations
existing throughout the plant, are avoidable potential problem
areas that operators must contend with on a daily basis.
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this area should be consistent
with the basic inspection program.
Emphasis should focus
on monitoring of licensee efforts to eliminating operator
distractions such as spurious annunciators, inadvertent
ventilation actuations, and existing temporary plant
al terations.
b.
Recommended Licensee Actions
Continued efforts to clear. illuminated annunicators, remove
temporary plant alterations, and eliminate spurious
ventilation actuations should be given priority.
Additionally, shift technical advisors should be removed
from duties involving largely_ administrative functions so
they can concentrate on the duties and responsibilities
outlined in Technical Specifications. Licensee management
should ensure preparation, tracking, and closure of
regulatory compliance issues are pursued with the same
systematic approach normally taken in the licensing area.
B.
Radiological Controls
1.
Analysis
Six inspections in the general functional area of radiological
controls were performed by regional radiation specialist
inspectors during the assessment period. The inspections
included the following specific areas: occupational radiation
safety, radioactive waste management, radiological effluent
control and monitoring, transportation of radioactive materials,
and water chemistry controls.
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a.
This area was inspected three times during the assessment
period. These inspections included two inspections during
routine operations and one refueling outage inspection.
Management involvement was evident by the performance of
comprehensive audits of radiation protection activities.
The licensee's program is considered adequate in the areas
of radiological training for the plant staff, stability of
the health physics staff at the technician level, and the
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development of radiation protection procedures. The
licensee demonstrated good planning and preparation for the
1986 refueling outage. The licensee's response to NRC
initiatives is considered above average.
Problems continue to exist concerning the release of
airborne and liquid radioactive contaminates from valves
and fittings in various plant systems. The licensee made
some progress to repair leaky valves and fittings during
the recent refueling outage. However, additional repair
work is needed in order to reduce the amount of leakage
that currently exists. This problem area was identified in
the previous SALP report.
The new Radiation Protection Manager (RPM) was hired during
the assessment period. The new RPM has previous
experience, with INP0, evaluating radiation protection
programs at several utilities.
A large turnover rate was experienced among the
professional health physics technical staff. Almost a
complete turnover occurred within the onsite and corporate
staff during 1985-86.
First-line, onsite supervisors are
burdened with excessive administrative duties which prevent
them from spending adequate time in the plant supervising
radiation protection activities.
Several problems were
identified concerning the failure to follow Radiation Work
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Permit instructions and the proper control of contaminated
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workers leaving the site which reflects the need for more
direct supervisory oversight of the radiation protection
program.
The person-rem exposure for 1986 was 270. This compares to
an estimated national average for PWR reactors of 'about
270 person-rem.
b.
Radioactive Waste Management
The licensee's program concerning the processing and onsite
storage of gaseous liquid and solid radioactive waste was
inspected once during the assessment period.
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The licensee had not established a permanent low-level
radioactive waste storage' facility. Low-level waste is
currently stored in various temporary areas throughout the
plant. A protected storage area had not been established
for radioactive waste containers.
Containers are presently
stored outside and exposed to environmental conditions.
c.
Radiological Effluent Control and Monitoring
The liquid and gaseous effluent control and monitoring
program was inspected once during the assessment period.
Effluent sampling and analyses activities were well defined
in plant procedures to ensure compliance with the
Radiological Effluent Technical Specifications. Gaseous
and liquid release permit programs were established to
ensure that planned releases receive the necessary review
and approval prior to~ release.
The radiochemistry / confirmatory measurements program was
inspected once during the assessment period. The
inspection included onsite confirmatory measurements with
NRC Region IV mobile laboratory. The results of the
confirmatory measurements values indicated 98 percent
agreement between the NRC's and licensee's measurements.
This percent agreement is above an expected industry
average of about 90 percent.
The radiochemistry / confirmatory measurements inspection
also included a review of the post accident sampling
system (PASS). Several major problems had been encountered
while attempting to obtain liquid and containment air PASS
samples.
In order to correct these problems, extensive
modifications to the PASS system were performed during the
1986 refueling outage.
The radiological environment monitoring program was
inspected once during the assessment period.
No problem
areas were identified. The licensee has established a well
documented program to ensure compliance with the offsite
dose calculation manual and Technical Specification
requi rements. All NRC identified matters have been
resolved.
d.
Transportation of Radioactive Materials-
This area was not inspected during the assessment period.
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The previous inspection was performed in October 1985, and
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the next inspection is scheduled for March 1987.
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Water Chemistry Controls
The primary and secondary systems affecting plant water
chemistry were inspected once. No problem areas were
identified.
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Conclusions
Leakage from liquid,and gaseous systems has resulted in
unnecessary personnel exposure and excessive contamination of
plant areas.
First-line health physics supervisors have not
spent adequate time in the plant overseeing ~ radiation protection
activities. The'large turnover rate among the professional
staff has reduced the- technical review of radiation protection
work.
No problems were identified in the areas of enforcement,
training, resolution of technical issues, or responsiveness to
NRC initiatives.
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should be
consistent with the basic inspection program. An
inspection of the new PASS should be conducted in early
1987.
b.
Reconmended Licensee Actions
Management attention is needed to:
(1)ensureappropriate
action is taken to reduce the radioactive leakage.from
liquid and gaseous systems to an acceptable level,
(2) ensure that first-line health physics supervisors spend
adequate time in the plant overseeing radiation protection
work activities, (3) ensure that stability is maintained-
~ with the health physics professional staff, and
(4) evaluate the benefits of establishing a permanent
low-level radioactive waste storage facility.
C.
Maintenance
1.
Analysis
This functional area was periodically inspected by region-based
NRC inspectors and on a continuing basis by the NRC resident
inspectors. During this appraisal period, the region-based
inspection efforts-included a maintenance program assessment
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which was performed by NRC and contractor personnel.
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A number of major maintenance efforts were accomplished during
the appraisal period. Many of these efforts, which included
main turbine. inspection / maintenance, replacement of reactor
coolant pump seals, and repairs of the . reactor coolant pump seal
water heat exchangers, were accomplished during the refueling
outage.
The licensee: continued efforts toward implementation of the
maintenance segment of the station information management
system (SIMS), a project that was begun late in the last
appraisal period.
In general, preventive maintenance
initiatives such as SIMS and routine corrective maintenance have
consistently been delayed in favor of priority corrective
maintenance.
Early in the appraisal period, the licensee continued to have
problems with the measuring and test equipment (M&TE) program.
The NRC resident inspectors identified a number of pieces of
M&TE in use or available for use in the plant well past their
calibration expiration dates. These problems were corrected
near the end of the appraisal period through implementation of
strict procedural controls and retraining of personnel.
In
general, routine corrective'and preventive maintenance was
performed satisfactorily. Work observations indicated that
maintenance personnel were well prepared and trained.
Maintenance activities did not directly contribute to any
It is not uncommon for emergent containment maintenance to be
performed in areas where temperatures reach the 130-140 degrees
Fahrenheit range. During the plant's refueling outage, the
spurious terminations of containment purge, discussed in the
Plant Operations section of this report, compounded existing
temperature and humidity problems.
Events such as those
described in LER 382/86-15 illustrate the role environmental
factors can have both in operations and maintenance related
activities.
2.
Conclusions
Improvement was noted in the licensee's maintenance program.
Given the tempo of activity dictated by t.*o major outages,
efforts in the area of corrective maintena.'ce were considered
generally well coordinated and performed. However, a
significant backlog of corrective maintenance items of a routine
nature continued to exist.
The existence of some of these
outstanding items contributed to the large number of temporary
plant modifications discussed in the Plant Operations section of
this report.
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Programmatic planned maintenance' initiatives such as SIMS have
not been fully implemented due, in part, to the attention given
outage activities. Licensee management has been very responsive
to NRC inspection findings and concerns in this functional area.
Both, through telephone conversations and written correspondence,
the licensee has attempted to close out many issues, some of
which had been under review for long periods of time.
The licensee is considered to be in Performance Category 2 in
this functional area.
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Board Recommendations
a.
Recommended NRC Actions
The NRC inspection efforts in this functional area should
be consistent with the basic inspection program. These
efforts should, however, include followup of the licensee's
efforts to implement preventive maintenance initiatives.
b.
Recommended Licensee Actions
Licensee management should work toward reduction of the
outstanding routine maintenance backlog and implementation
of programs such as SIMS. Additionally, initiatives to
improve the~ containment working environment should be
considered.
D.
Surveillance
1.
Analysis
This functional urea was inspected on a continuing basis by the
NRC resident inspectors and periodically by region-based NRC
inspectors. Additionally, during the refueling outage, an
inspection was performed using the facilities of'the NRC
nondestructive examination mobile van.
The W3 SES surveillance program accomplished the required
testing in a timely manner in accordance with required
procedures. The activities performed by the licensee in the
area of inservice inspection were well prioritized, well
controlled, and executed using explicit procedures. Although
timely completion of nonroutine surveillances continue to be a
problem, the frequency of such problems has declined.
The Health Physics and Chemistry departments are responsible for
a large number of the very frequently performed nonroutine
surveillances which provide the most opportunities for missed
surveillances.
Licensee management has taken a number of
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positive-steps to minimize such problems including the
installation of an automatic hydrogen / oxygen sampling system for
various plant storage tanks.
However, there are other problems
such as the baron management / blowdown radiation monitors that
need attention. .These monitors have' proven to be unreliable,
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various nonroutine surveillances thereby setting up the
possibility of missing a required sample or failing to verify a
lineup.
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Conclusions
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Licensee management has taken positive actions to improve
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performance in the. functional' area of surveillance, and these
actions have helped reduce problems in the area. Problems with
nonroutine surveillance exist but have declined in number.
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The performance and tracking of surveillances has been good as
has the licensee's evaluation and resolution of problems
discovered during surveillance testing.
.The licensee is considered to be in Performance Category 1 in
this functional area.
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3.
Board Recommendations
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a.
Recommended NRC Actions
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The NRC should consider reduced inspection effort in this
functional area; however, a review of the licensee's
compliance with nonroutine surveillance requirements should
still be accomplished,
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b.
Recommended Licensee Actions
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The licensee should continue to pursue procedural as well'
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as equipment changes needed to eliminate nonroutine
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surveillance problems.
Evaluation ~of the long-term
reliability of the boron management / blowdown' system
radiation monitoring equipment, and the placement of the
new hydrogen / oxygen analyzing system into routine
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operational service are two actions that will assist in
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this effort.
E.
Fire Protection
1.
Analysis
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This functional area was inspected on a continuing basis by the
NRC resident inspectors, and one-inspection of the fire
protection / prevention program was performed by a region-based
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NRC inspector. These inspections verified that the licensee was
maintaining a fire protection / prevention program that met the
requirements of Branch Techntcal Position 9.5-1, the Plant Final
Safety Analysis Report, the Plant Fire Hazards Analysis, and
Technical Specifications.
In general, housekeeping and cleanliness controls were adequate
throughout the plant.
Fire brigade training and fire
detection / suppression surveillances were performed in accordance
with TS (except as described in LER 382/86-27). During the
refueling outage, the licensee installed the fire protection
hardware required by license conditions and made the
modifications resulting from the spurious signal analysis.
By the end of the appraisal period, the licensee was making a
concerted effort to reduce the number of fire impairments
existing throughout the plant and this, in turn, reduced the
need for compensatory fire watches.
2.
Conclusions
Licensee management demonstrated a definite commitment to having
an effective fire protection / prevention program. However, for
much of the appraisal period, the use of fire watches, in place
of barriers / detection equipment, was very routine. As noted in
the Quality Programs and Administrative Controls Affecting
Quality area of this report, the licensee created a single fire
protection / industrial safety group. Such a consolidated
organization will provide quicker resolution to problems in the
areas of fire protection / prevention by placing these areas and
the functionally related area of safety under a single
supervisor.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC should consider a reduction of inspection effort in
this functional area.
b.
Recommended Licensee Actions
Licensee management should continue to stress the reduction
of the number of inoperable fire barriers and work toward
the elimination of routine fire watches in areas containing
safety-related equipment.
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F.
1.
Analysis
This area was inspected on a periodic basis by NRC region-based
inspectors and contract personnel. During the assessment
period, three emergency preparedness inspections were conducted.
Two violations and one deficiency were identified.
The two violations identified during this assessment period were
failure to follow document change procedure and failure to
provide adequate training to emergency response personnel. The
licensee took immediate corrective action in response to
personnel making hand written procedure changes.
The previous SALP assessment had identified that the licensee
had reduced the retraining program. During this assessment
period, it was determined that the licensee's training program
still was weak. A sampling of operations personnel indicated
some were unable to demonstrate adequate knowledge of the
protective action decision-making procedures. Health physics
technicians were unable to adequately demonstrate fundamental
radiation protection techniques in determining habitability of
emergency response facilities and performing offsite surveys to
characterize a radioactive plume released in an accident. The
licensee has not conducted a review of the training program to
be assured that it is adequate for emergency response personnel.
One deficiency identified during the emergency exercise
concerned communications and the Emergency Operations
Facility (E0F) organization.
During the exercise, the licensee
encountered problems in demonstrating comand and control of the
Emergency Operations Facility (E0F). The command and control
problem, in turn, precipitated onsite communication poblems with
the E0F support groups.
In response to the training violation,
the licensee committed to training seminars for the health
physics personnel and for other emergency response personnel on
an as-needed basis.
The licensee conducted a joint emergency response exercise with
the NRC, state, and local parish participation. The results of
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this exercise indicated that there was reasonable assurance that
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the licensee could adequately protect the health and safety of
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the public during an emergency. One unresolved item concerning
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the size of the Technical Support Center (TSC) and the resulting
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overcrowded conditions in the TSC was identified. This item
will be resolved during the NRC Emergency Response Facility
Appraisal.
During this assessment period, the licensee improved the station
emergency personnel callout system. The licensee had identified
areas for improving the callout system during several unannounced
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drills. The licensee has maintained sufficient depth in the
emergency response organization. Additionally, the licensee
exercised several different emergency response teams.
The licensee entered this assessment period with approximately
40 deficiencies. Thirty-eight deficiencies were closed during
the annual emergency preparedness exercise.
During this assessment period, the licensee improved the station
emergency personnel callout system. The licensee had
identified areas for improving the callout system during
several unannounced drills. The licensee has maintained
sufficient depth in the emergency response organization. During
this assessment period, the licensee exercised several different
emergency response teams.
2.
Conclusions
Training in emergency preparedness continues to be a weakness in
the W3 SES program. This has reduced program effectiveness
as evidenced during NRC walk-throughs and annual exercise.
The finding of the NRC inspections conducted during the
evaluation period indicate that overall the licensee's emergency
preparedness program is adequate to protect the public health
and safety.
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
i
The level of NRC inspection effort in this functional area
should be consistent with the basic inspection program.
b.
Recommended Licensee Actions
)
Upper level management's attention to the implementation of
the emergency preparedness program should be increased to
ensure proper response to NRC identified items.
The
licensee management should evaluate the emergency
preparedness initial training and retraining program as to
i
training frequencies, scope, and depth for all emergency
response personnel.
.
_
_
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-16-
G.
Security and Safeguards
1.
Analysis
This area was inspected on a continuing basis by the NRC
resident inspector and periodically by NRC region-based
inspectors. Several violations that were identified resulted
from activities performed by personnel other than the security.
force, indicating the failure by management to make everyone
onsite aware of their security responsibilities. The licensee
has taken extensive corrective action to train everyone on the
security requirements at W3 SES.
It was noted that the
number and severity of violations decreased during the latter
part of this assessment period, indicating strong management
support of the security program.
Weaknesses were identified in the areas of physical barriers and
the closed circuit television system. Several passive barriers
have been corrected, and the closed circuit television is being
evaluated for upgrading.
2.
Conclusions
While there was an increase in the nuaSer of ser mity violations,
most of' the violations were discovered as a result of the
licensee's own initiative and an excellent record-keeping
capability. The violations encountered during these inspections
were promptly corrected. The licensee undertook and completed
an extensive training and briefing program for all employees
with access to the protected or vital areas. There was ample
evidence of the effectiveness of the program during an early
1987 inspection which encountered no violations.
The licensee
continues to be very responsive to NRC concerns and initiatives.
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
I
a.
Recommended NRC Actions
i
The level of NRC inspection effort in this functional area
should be consistent with the basic inspection program.
b.
Recommended Licensee Actions
The licensee should continue to enhance the security
training of nonsecurity personnel in order to prevent
recurrence of the physical barrier violations.
Additionally, licensee management should ensure the
evaluation of the closed circuit television system is
completed and appropriate modifications are made.
.
4
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i
,
H.
~ 0utages
' 1.
Analysis
-This functional area was inspected on a continuing basis by the
j
NRC resident inspectors during the mid-cycle outage of March 8
through March 30, 1986,~and the first plant refueling outage
starting November 26, 1986, and continuing through the end of
-
the SALP period. These inspections included verification that
outage management, repairs and modifications to equipment, and-
refueling activities were -performed in accordance with plant
procedures, regulatory requirements, and Technical
Specifications.
.
l~
During both the mid-cycle and refueling outages, planning and
~
scheduling 'of operations and maintenance activities were very
good. The licensee's use of containment coordinators, as well
as floor and assigned area radiation control technicians,
resulted in effective control and coordination of all work
performed in the containment during the refueling outage.
However, a violation (382/86-33) for failure to follow radiation
j
work permit requirements discussed the fact'that radiation
technician control of work in progress was'not always performed
l
in strict conformance'with established procedures. This problem
led the licensee to promptly pursue revision of established
procedures and to retrain personnel.
,
'
Prior to the refueling outage, a weakness in the organization
and supervision during receipt of new fuel was identified. The
weakness, in conjunction with poor layout of the fuel handling
<
building, led to damage to a new fuel element which was
discussedinviolation(382/86-29). At the beginning of the
i
fuel shuffle, a boraflex plate wa's'~1nadvertently pulled out of
the spent fuel storage rack by the_ spent: fuel handling machine
af ter it caught on the spent fuel : tool. The remainder of the
fuel shuffle was revised.in order to accommodate the above
. problem as well as the extensive search (in the core barrel and
.
lower structure' sections of'the reactor vessel) .for missing
j
steam generator tube plugs (LER 382/86-28). The revised
evolutions were completed without incident.
,
.
During both~ the mid-cycle and refueling ' outages, problems With
j
coordination maintenance and testing.were observed on the
individual component level. Certain pieces of equipment were
'
taken out of service more than once in order to accomplish'
,
j
assigned work.
For instance, a piece of equipment would first
be taken out for preventive maintenance, then again for
j
i
equipment qualification inspection, and finally for surveillance
i
testing.
In many cases, all the work could have been
accomplished during a single period of inoperability.
In efforts to minimize nonproductive time during the beginning
of unplanned / forced outages, the licensee has developed a
i
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.
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-18-
detailed forced outage list that includes, not only the work to
be accomplished, but other information such as who to contact to
get the work started promptly.
2.
Conclusions
Licensee management involvement was effective and aggressive in
keeping informed, keeping control, and solving of problems as
they developed during the outages. This involvement, along with
good planning and scheduling, resulted in overall outage
management that is considered above average for a licensee
conducting an initial refueling outage. As noted, coordination
of work activities between disciplines could have been better
controlled on the individual component level.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
Although a performance rating of one would suggest that
reduced NRC inspection might be appropriate, the NRC
inspection effort in this functional area should be
consistent with the basic inspection program as major
outages involve numerous, infrequently performed
activities.
b.
Recommended Licensee Actions
Licensee management should continue with aggressive
involvement in outages. Some improvement could be made in
scheduling of equipment testing / inspection so that multiple
equipment outages could be avoided.
Progress of the
revision of the radiation work permit procedures should be
closely monitored so that the revised program is in place
and functioning well before the next scheduled outage.
I.
Quality Programs and Administrative Controls Affecting Quality
,
1.
Analysis
Activities under this functional area were inspected by
region-based NRC inspectors and by the NRC resident inspectors.
During this appraisal period, the licensee's nuclear
organization underwent a number of changes.
First, a new senior
vice president was appointed, and then a major reorganization
was executed. As part of the reorganization, a vice
president (site director) position was created. The guality
control group was placed under the quality assurance (QA)
,
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l
manager, the Independent Safety' Evaluation Group (ISEG) was
'
elevated in the-corporate structure, and a consolidated fire
protection and safety group was established.
4
This functional area includes all verification and oversight
activities which effect or ensure quality of plant activities,
structures, systems, and components. The work of organizations
such as the Plant Operations Review Committee (PORC), the
Quality Assurance (QA) organization, the Safety Review
Committee (SRC), and the ISEG form the basis for much of the
l
evaluation. Specific activities which were evaluated included
procurement control, control of design changes, audits, inspections,
records, and corrective action systems. One area needing
improvement was noted in a number of NRC inspections.
In
'
certain plant procedures, informational cautions / notes were used
as procedural' action steps.
Considering procedures on a broader
basis, it was noted in review of violations and LERs that in a
number of functional areas two specific weaknesses existed.
First, LERs such as 382/86-15 and 382/86-24 demonstrated that
the understanding of the basis / intended use of procedures was
not always adequate on the part of the users. While an LER such
as 382/87-03 or a violation such as the failure to follow
procedures, described in NRC Inspection Report 50-382/86-02,
i
demonstrated individual failures to implement the established
l
procedures.
,
Licensee management has effectively implemented a program to
reduce the large backlog of outstanding station modifications,
however, continuing effort in this area is needed as evidenced
by the large number of temporary alterations still in place
l
dwaiting permanent changes.
Further, NRC inspections indicated
'
that although procedures, specifications, and drawings were in
place for station modification, the instructions in some
modification packages were poorly stated, and retrieval of
documents associated with a particular modification was
sometimes a problem.
Problems with reliability of the plant monitoring computer that
were evident during the last appraisal period have not been
fully remedied. The licensee has gotten an approved change to
l
the TS which reduces the operational impact of a core operating
limit supervisory system (COLSS) failure, but this change has
'
done nothing to' improve overall computer reliability.
In
addition to operating the COLSS, the plant computer supports a
portion of the licensee's plant / environmental assessment
capabilities, and regular losses of some or all of capabilities
supported by the plant monitoring computer have resulted.
During this appraisal period, an inspection was performed to
determine the status of the licensee's implementation of
10 CFR 50.49 requirements.
It was determined that the licensee
.
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-20-
has established an equipment qualification (EQ) program that
meets the applicable regulatory requirements. Additionally,
staffing and training in the EQ area were adequate.
Some specific problems were identified in the licensee's EQ
program. These problems included: no records to demonstrate
qualification for equipment subject to submergence under design
'
basis accident conditions, improper temperature lag analysis,
and inadequate schedules for replacement of components
susceptible to aging effects at elevated service temperatures.
Licensee management was very responsive in addressing these
issues, and responses were both technically sound and thorough.
2.
Conclusions
Licensee management adequately implemented programs and controls
designed to ensure quality including the EQ program.
The
'
completion of a large number of station modifications during the
first refueling outage will place extra demands on the
licensee's system for modification closeout and drawing update.
Even though the licensee has made some improvements, plant
computer reliability continued to be a problem.
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The level of NRC inspection effort in this functional area
i
should be consistent with the basic inspection program with
particular emphasis on the station modification program,
b.
Recommended Licensee Actions
Licensee management needs to resolve the lingering problems
associated with the plant computer system. Licensee
management has taken steps to minimize the impact of plant
computer outages but such outages continue to occur.
Additional reviews of plant procedures need to be done to
eliminate the practice of using informational notes as
procedural requirements.
Followup of the concerns
identified in the NRC EQ inspection should be monitored by
licensee management to ensure continued compliance in this
area. Careful monitoring of the station modification
program also needs to be a priority so that progress made
in reducing the number of outstanding station modifications
in the review cycle continues even with the added volume of
post refueling outage reviews.
.
- -
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l
J.
Licensing Activities
1.
Analysis
The licensing activities at W3 SES during the current SALP
appraisal period have been characterized by a high level of
dCtivity targeted toward preparation and conduct of the first
reload, closure of license conditions imposed by the operating
license, completion of commitments made prior to licensing, and
,
l
modifications to streamline and upgrade operations and increase
plant reliability.
A total of 54 licensing actions were completed during the rating
period, many of which were associated with the first reload.
In
addition to the 39 Technical Specification changes in support of
the reload-analysis, the licensee closed out 4 multi-plant
actions and carried out programs and commitments as required by
11 license conditions.
During_ the assessment period, the licensee's management has
demonstrated a high level of involvement and control in assuring
quality.
Prior planning and assignment of priorities were
consistently evident.
Regarding multi-plant actions, the
licensee's management actively participated in efforts to work
closely with the NRC staff and there were no backlogs over which
the licensee had control. With regard to plant-specific
t
activities, the licensee has consistently demonstrated a high
degree of planning and prioritization of actions to resolve
plant-specific issues. TF.i; was especially evident during the
staff review of Technical Specification amendment requests for
Cycle 2 reload to increase the cycle length to 18 months and the
implementation of actions to close out commitments and license
conditions for the Broad Range Toxic Gas Detection System, axial
l
fuel growth, smoke detection in the control room, spurious
l
signal analysis modifications, neutron flux indication, and
Increased enrichment evaluation of the spent fuel storage racks.
l
l
The licensee has well-stated and understandable policies
'
disseminated throughout their Nuclear Operations organization
through a system of Nuclear Operations Directives established
dnd controlled through the office of the Senior Vice
President-Nuclear. The licensee reorganized during the SALP
evaluation period to redefine organizational reporting-
responsibilities which places decisionmaking consistently at a
i
l
level to ensure adequate, thorough, and technically sound
management review.
In general, the new organization places
plant operations, design engineering and construction under a
site director (the Vice President-Nuclear Operations), expands
the role of training, consolidates similar functions, and places
l
increased emphasis ~on important functions, such as events
!
analysis, trending, industrial safety, and fire protection.
- -
-
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-22-
The Senior Vice President - Nuclear maintains a site office for
his frequent visits and is involved in site activities. The
Vice President-Nuclear Operations, in his function as site
director, maintains his office on site on a full-time basis
and is involved on a day-to-day basis with plant and site
activities.
In order to enhance their involvement and increase
their control of licensing activities, LP&L management has
maintained an office in Bethesda. This licensing presence near
NRC, which includes both technical and administrative liaison,
has enabled LP&L management to be highly responsive to staff
concerns and has expedited the resolution of licensing issues.
The licensee has demonstrated sound and thorough approaches with
regard to almost all issues and has resolved the issues in a
timely and responsible manner. Where additional information was
needed by the staff to complete their reviews, the licensee
demonstrated a responsive and aggressive role in reaching timely
dnd thorough resolution, especially where there was a potential
for safety significance. This immediate approach to resolution
of the technical issues was particularly evident during the
period from August 1986 through January 1987, when the safety
analysis and 39 Technical Specification change requests were
processed to support an 18-month Cycle 2.
The continuation of a
licensing presence in Bethesda has enabled LP&L to focus quickly
and accurately on technical issues and to determine which
resources need to be brought to bear to reach timely resolution
based on sound communications.
There is, however, one area where LP&L could have been more
responsive in following guidance provided by the staff. During
review of the licensee's implementation of the SPDS, repeated
discussions at meetings and during telecons have not been
effective in directing LP&L's efforts to come up with a design
that meets the intent of NUREG-0737, Supplement 1.
In fairness
to the licensee, it should be noted that many of the staff's
criticisms of Safety Parameter Display System (SPDS) design have
arisen because LP&L's design of the system preceded issuance of
detailed guidance by the staff.
In view of the high level of
responsiveness on a very large number of issues exhibited by
LP&L during the rating period, failure to close out this single
difficult issue is not judged to be a significant performance
decrement.
The licensee has an apparently effective system for tracking and
responding to NRC requests and, in nearly all cases, meets
regulatory deadlines and commitments for timely resolution of
issues. The licensee infrequently requires extensions to meet
submittal dates, but is timely in alerting the staff in the rare
instances when an extension is needed. Through meetings with
the NRC staff, and through their Bethesda Licensing Office, the
licensee has maintained an effective line of communications.
_ _ _
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The licensee is always cooperative in meeting with the NRC staff
whenever the circumstances warrant. The licensee has been
responsive to first-of-kind programs, audits, and surveys. The
Operational Licensing Group, located at the plant site, was
instrumental in responding to NRC requests for plant performance
and operating data by bridging communications with operations,
engineering, and technical groups.
Corrective action is effective, as indicated by a lack of
repetition. The licensee has conducted licensing activities in
such a manner as to allow adequate time for staff review and
approval. No emergency Technical Specification changes were
necessary during the rating period. The trip reduction program
implemented by the licensee has been effective in reducing the
number of reactor trips from 22 in the previous rating period to
7 this rating period. Plant modifications to increase
reliability have been implemented and include:
modifications to
feedwater systems, rework of the turbine governors, replacement
of CEDM cards and power supply, and an extensive valve
replacement program to reduce RAB airborne activity.
2.
Conclusions
Management involvement and control in licensing activities is
effective in assuring quality. The licensee has consistently
demonstrated a high degree of planning and prioritization of
actions to resolve plant-specific issues, particularly during
the recent first refueling outage. The licensee has well stated
and understandable policies disseminated throughout its nuclear
operations and has an effective system for tracking commitments
and responding to NRC requests. The licensee's organization is
configured such that reporting responsibilities consistently
place decision making at a level to insure adequate, thorough
and technically sound management review. The licensee has
demonstrated sound and thorough approaches to almost all issues
and has resolved the issues in a tiraely and responsible manner.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
NRC efforts should continue at the present level, or
possibly be reduced in recognition of the completion of the
first refueling outage.
Continued emphasis should be given
to assure that no declining performance trends develop in
any of the licensee's programs.
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b.
Recommended Licensee Actions
The licensee should continue to maintain a high level of
management involvement to assure continued improvement in
this functional area. Continued emphasis should be placed
to assure that supporting analyses continue to be thorough,
complete, and accomplished in a timely manner. The
licensee should focus on the expeditious resolution of the
SPDS issues to achieve an acceptable design and operation.
K.
Training and Qualification Effectiveness
1.
Analysis
The licensee has made substantial progress in certain aspects of
the plant training programs. The skills training center was not
only used for a broader scope of normal training activities, but
it also provided the classrooms and equipment to perform much of
the specialized training needed to support the refueling outage.
The plant licensed operator training program had an overall
success rate of greater than 90 percent on three NRC
administered examinations performed during the appraisal period.
Finally, the licensee had all plant-training programs covered by
the Institute for Nuclear Power Operation (INP0) guidelines
i
ready for accreditation by the December 1986 target date.
An NRC inspection performed on selected aspects of the
licensee's training programs did identify a-number of
deficiencies in the area of training administration /
documentation; however, content and scope were adequate. The
delivery of the plant specific simulator did not take place as
scheduled, and the simulator was not on site at the end of the
appraisal period.
2.
Conclusions
The licensed operator training program is functioning very well;
however, ' administration / documentation of the 10 CFR Part 55
requalification program and other training programs could be
improved. As evidenced by comments in )ther portions of this
report, as well as in LERs and potentially reportable
events (PRES), training for a number of unlicensed plant staff
positions still needs strengthening. Though the licensee has
' devoted a large number of man-hours to the plant simulator
project, problems with the project contractor have again delayed
the delivery date.
The licensee is considered to be in Performance Category 1 in
this functional area.
.I
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3.
Board Recommendations
a.
Recommended NRC Actions
The NRC should consider a reduction of inspection effort in
this functional area.
b.
Recommended Licensee Actions
LP&L management attention should focus on delivery of the
plant specific simulator to the site and all efforts
necessary to make the unit fully operational. As discussed
above, additional emphasis _should be placed on training of
nonlicensed plant staff personnel.
Finally, licensee
management should direct the correction of the identified
deficiencies in training program administration / documentation
and ensure periodic reviews of these programs are performed
to identify any future problems.
l
V.
Supporting Data and Sumaries
A.
Licensee Activities
During this appraisal period, W3 SES was involved in two significant
outages. The first outage to occur was a mid-cycle maintenance
outage, and the second, which was reaching completion at the end of
the appraisal period, was the plant's first refueling outage.
During the refueling outage, numerous modifications were made to meet
!
license conditions. Additionally, during the outage, inspection of
l
the steam generator tubes was performed, plant snubbers were
l
inspected / tested, and extensive work was done on both the reactor
coolant pumps and main steam isolation valve hydraulic systems.
B.
Inspection Activities
1.
Violations
See Table I and II
2.
Major Inspections
i
Three major inspections were conducted during the assessment
period. These were a maintenance program review (November 1986,
50-382/86-28), the independent verification inspections of plant
modifications and inservice inspection using the NRC nondestructive
examination mobile van (December 1986,50-382/86-31), and the
equipment qualifications inspection (December 1986,50-382/86-32).
.
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-26-
C.
Investigations and Allegations Review
1.
One major investigation was completed during this assessment
period. This related to possible misrepresented facts in
October 1984 concerning managers (November 1986,50-382/86-30).
2.
Three allegations were reviewed and closed (January and
February 1986, 50-382/86-02 and 50-382/86-05).
D.
Escalated Enforcement Actions
1.
Civil Penalties
Actions (EA)ppraisal period, two Escalated Enforcement
During the a
were issued involving W3 SES. Ona of these EAs did
not impose a civil penalty. On April 16, 1986, EA 86-50
involving the inoperability of a containment spray pump was
issued. The licensee responded to EA 86-50 and the proposed
civil penalty of $50,000 in a letter dated May 16, 1986. The
letter imposing the civil penalty was subsequently issued on
August 27, 1986.
2.
Enforcement Orders
None.
E.
Licensee Conferences Held During Appraisal Period
A management meeting was held on January 8,1986, to discuss facility
and programs status and planning. An enforcement conference was held
on March 5, 1986, to discuss apparent violations concerning a mode
change and various security issues. A management meeting was held
April 1, 1986, to discuss SALP Report 50-382/85-30. A management
meeting was held on September 19, 1986, to discuss general plant
status. An enforcement conference was held November 18, 1986, to
discuss security matters relating to access control.
F.
Confirmation of Action Letters
None.
G.
Review of Licensee Event Reports and 10 CFR Part 21 Reports
Submitted by the Licensee
1.
Licensee Event Reports (LERs)
During this assessment period, a review was conducted for LERs
submitted during the period January 1,1986, through January 31,
1987. This review included LERs 382/86-01 through 382/87-04.
The technical content of LERs was greatly improved during this
assessment period. Table III contains a tabulation of LERs by
performance category.
.
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-27-
4
An additional evaluation of the content and quality of a
representative sample of the LERs submitted between January 1,
1986, and January 1,1987, was performed by the NRC Office of
Analysis and Evaluation of Operational Data (AE00). This
-
analysis was provided to LP&L under a cover letter dated
,
March 5, 1987. This, the second evaluation of the licensee
'
using AE0D's methodology, resulted in an overall score of 8.8
r
out of a possible 10 points which was a large improvement over a
previous average score of 7.3.
The current industry average is
,
8.2.
>
.
One weakness involving the requirements to uniquely identify
failed components was identified. Two strong points involved
i
the discussions concerning safety assessments and the failure
mode mechanism /effect of failed components.
'
2.
Part 21 Reports
None,
,
,
H.
Licensing Activities
[l
1.
NRR/ Licensee Meetings
2/18-19/86
Meeting to discuss basemat confirmatory analyses
/
,
3/26/86
Meeting to discuss results of basemat
/
'
confirmatory analyses
5/13/86
SPDS Design Review
~
~
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5/13/86
Reload Scoping Meeting
5/14/86
Basemat
6/3/86
Scheduling and Resource Management for Reload
.
,'
4
8/28/86
Review of updated basemat crack mapping effort
2.
NRR Site Visits
4/1/86
SALP Management Meeting
-
,
7/31/86
Inspection of previously unmapped basemat cracks
10/15/86
EP Exercise
1/14-15/87
Project Director Site Visit
3.
Commission Briefings
None
.
4.
Scheduler Extensions Granted
None
~
4
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,
.
5.
Reliefs Granted
-
EDG inspection per manufacturer's recommendations delayed until
first refueling)and scheduled at 24-month intervals thereafter
(vice 18 months
1J
6.
Exemptions Granted
Appendix J exemption for postponement of LLRT until first
refueling outage
g
7.
License Amendments Issued
^
11
o
.,i
)
8.
Emergency Technical Specifications Issued
,
None
9.
Orders Issued
'
,
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,
<
None
10.
NRR/ Licensee Management Conferences
2/21/86
Additional basemat confirmatory analyses
refinements
3/27/86
Basemat confirmatory analyses
'
7/2/86
Basemat surveillance program and crack
,
mapping / reload
<
,
.
Analyses and supporting Technical Specification
changes
9/9/86
Reload - related submittals and analyses
10/21/86
Discussion of licensee's recent reorganization
'
and reload - related activities
,
' 12/9/86
Discussion of refueling outage progress-to-date
and schedule for startup testing and return
to power
~
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1
4
5
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TABLE I
ENFORCEMENT ACTIVITY
- No. of Violations in Each
Severity Level
4
Functional Area
III
IV
V
Deviation
A.
Plant Operations
1
2
2
-
.
B.
Radiological Controls
-
-
-
-
C.
Maintenance
-
3
-
-
D.
Surveillance
1
-
-
-
E.
Fire Protections
-
1
-
-
F.
-
1
1
-
G.
Security and Safeguards
1
12
1
-
H.
Outages
-
2
-
-
i
I,
Quality Programs and
6
1
-
-
Administrative Controls
Affecting Quality
J.
Licensing Activities
-
-
-
-
,
K.
Training and Qualification
-
-
-
-
Effectiveness
.
J
_
_
-
-
-
_
_
.
.
TABLE II
ENFORCEMENT ACTIVITY
TABULATION OF VIOLATIONS AND DEVIATIONS
BY
PERFORitANCE CATEGORY
A.
Plant Operations
Violations
Failure to meet the limiting condit'an for operation for a
.
containment spray pump.
(Severity Level III, 50-382/86-02)
Failure to use an adequate RWP and failure to use an approved
.
procedure.
(Severity Level IV, 50-382/86-02)
Failure to meet 10 CFR Part 50.72 and 50.73 reporting requirements.
.
(Severity Level IV, 50-382/86-15)
Deviations
Failure to fully implenent the actions specified in response to IE
.
(50-382/86-13)
Failure to update an operating procedure within the time period
.
specified in LER-382/86-15.
(50-382/86-33)
B.
Radiological Controls
Violations
None
Deviations
None
C.
Maintenance
Violations
Failure to properly document essential chiller retest.
(Severity
,
Level IV, 50-382/86-02)
Failure to recall pastdue measuring and test equipment.
(Severity
.
Level IV, 50-382/86-15)
Failure to properly control temporary removal and replacement of
.
current limiting fuses.
(Severity Level IV, 50-382/86-28)
1
_
,
-
_ - - _ _ _ _ _ _ _ _ _ _ _
.
.
.
-2-
Deviations
None
D.
Surveillance
Violations
Failure to perform valve lineup (Severity Level IV, 50-382/86-29) quired
on fire protection valves as re
.
by Technical Specifications.
Deviations
-
None
E.
Fire Protection
Violations
Failure to p operly control flammable liquids.
.
50-362/86-16
Deviations
None
F.
Violations
Failure to provide adequate emergency response training.
(Severity
.
Level IV, 50-382/86-04)
Failure to follow procedures for updating documents.
(Severity
.
Level V, 50-382/86-27)
Deviations
None
G.
Security
Violations
Failure to demonstrate positive access control personnel.
(Severity
.
Level IV, 50-382/86-01)
Failure to maintain positive access control through posting of a
.
security officer.
(Severity Level IV, 50-382/86-01)
.
._
. ~ ~
._
. _ . .
_
..
.
.
__ ._
.
.
.
1
-3-
Failure to change locks, keys, and/or. combinations as required.-
.
(Severity Level IV, 50-382/86-01)
Failure to properly control access control-packages. - (Severity
.
Level IV, 50-382/86-01)
-
.
(Severity
50-382/86-01) pond to a vital area alarm.
Failure to properly res
.
Level IV,
Failure to positively control all points of personnel access into a
.
vital area.
(Severity Level IV, 50-382/86-01)
Failure to positively control allipoints of personnel access into a
'
.
vital- area ~.
(Severity Level IV, 50-382/86-01)
Failure to conduct an adequate audit ~of'ths security program.
.
(Severity Level'IV, 50-382/86-10) .
.
Failure to provide positive access control to' vital areas.
(Severity
.
.
Level III, 50-382/86-14 and 50-382/86-23)
!
Failure to report a major loss of physical security effectiveness.
.
(Severity Level IV, 50-382/86-14)
Failure to record tests as required.
(Severity Level V, 50-382/86-14)
.
f
Failure to follow procedures detailing duties and responsibilities of
.
security personnel.
(Severity Level IV, 50-382/86-16)
Failure to perform surveillance of the se'curity diesel generator at
.
,
the requested interval.
(Severity Level IV, 50-382/86-26)
!
i
j
Failure to follow procedures for escorting of visitors.
(Severity
.
Level IV, 50-382/86-29)
i
~
Deviations-
None-
H.
Outages
f
Violations
Failure to follow new fuel receipt procedures.
.
50-382/86-29)
Failure to follow radiation work permit procedures.
(Severity
1
.
Level IV, 50-382/86-33)
.
, . . - - .
,
, - . - ,
,
. . - . >
, , - ,
,,N',,..
r
,.w-
,
,
.
.
4
-4-
Deviations
None
I.
Quality Programs and Administrative Controls Affecting Quality
Violations
Failure to take prompt co.Tective action.
(Severity Level IV, 50-382/86-13)
.
Failure to update drawings following a station modification.
.
(Severity Level IV, 50-382/86-13)
Failure to adequately inspect installation of safety-related
.
components.
(Severity Level IV, 50-382/86-16)
Failure to follow procedures for station modification installation.
.
(Severity Level IV, 50-382/86-31)
Failure to control the use of nonconforming components.
(Severity
.
Level IV, 50-382/86-31)
Failure to follow procedures for evaluation of suppliers.
(Severity
.
Level IV, 50-382/87-01)
Failure to specify plant management succession as required by
.
Techaical Specifications.
(Severity Level V, 50-382/87-01)
Deviations
None
J.
Licensing Activities
Violations
None
Deviations
.
None
K.
Training and Qualifications Effectiveness
Violations
None
Deviations
None
__
_
_ _ _ _ _ _ _ _ _
_ - _ _ _ _ _ _
.
.
.
TABLE III
TABULATION OF LICENSEE EVENT REPORTS
BY
PERFORMANCE CATEGORY
A.
Plant Operations
Thirteen LERs involved activities in the ' functional area of plant
operations.
Reactor trip on dropped control element assembly.
(382/86-01)
.
Reactor trip due to dropped control element assembly Number
.
88 and failure of blowdown valves to close.
(382/86-02)
Reed switch failure results in reactor trip on low departure from
.
nucleate boiling ratio.
(382/86-09)
Simultaneously using two methods of draining reactor coolant system
.
results in lost of rhutdown cooling.
(382/86-15)
Insufficient procedural cequirements resulted in the boron concentration
.
for the safety injection tanks to fall below the Technical Specification
limit.
(382/86-16)
Reactor trip due to a. turbine trip caused by Hi-Hi level in moisture
.
separator reheater shell Drain Tank-2A.
(382/86-19)
Automatic actuations of engineered safety features portion of the
,
.
control room ventilation system including electrical spikes, spurious
alarms, and equipment failures.
(382/86-03,382/86-20,382/86-22,
and 382/86-29)
Reactor trip due to dropped control element assembly.
(382/86-23)
.
Inadvertent discharge of boric acid condensate tank due to procedure
.
noncompliance.
(382/86-24)
i
Reactor trip during startup due to prolonged low power operation.
.
(382/86-25)
B.
Radiological Controls
One LER involved activities in the functional area of radiological
controls.
Technician wore contaminated clothing offsite.
(382/87-03)
.
i
,
.
.
-
_
--
.
.
.
--
.
.
.
.
-2-
.
I
C.
Maintenance-
-
Three LERs involved activities in the functional area of maintenance.
Personnel error resulted in improper ~ tag-out causing the , low pressure
.
safety injection pump being inoperable due to the discharge valve
being closed.
(382/86-04)
Improper connection of contro1' element assembly cable resulted in
.
(382/86-13)
"
Inadvertently opening of safety injection tank isolation valves due
.
to inadequate work instructions.
(382/86-14)
Inadvertent fuel handling ventilation system actuation due to personnel
.
error.
(382/86-26)
Containment isolation valve inoperable due to improper reassembly.
.
(382/87-01)
Small size snubber test failures due to improper installation.
.
,
l
(382/87-02)
D.
Surveillance
Five LERs involved activities in the functional area of surveillance.
Surveillance procedure resulted in suspect hot leg temperature
.
monitoring operability.
(382/86-05)
,
Mode change without performing surveillance on the boric acid makeup
.
tank.
(382/86-06)'
Operator error during surveillance testing resulted in inadvertent
.
activation of emergency feedwater system.
(382/86-08)
Improper filing of. scheduling card results in failure to perform
.
required secondary activity sample.
(382/86-10)
,
Failure to sample the proper gas decay tank. -(382/86-17)
.
Fire protection valve lineup not checked due:to inadequate procedure.
.
(382/86-27)
E.
Fire Protection
4
Five LERs involved activities in the functional area of Fire Protection-
Missed fire watch tour.
(382/86-07)
.
Missing internal penetration fire seals. ;(382/86-11)
.
Deficient fire door surveillance.
(382/86-12)
.
.
i
..
- - - . -
, - . - ,
-.
.y---
,
,,, ,
,,
,
-,
-
, - -
.
t
.
-3-
Fire watch tour not performed.
(382/86-21)
.
Fire barrier requirement not met.
(382/87-04)
.
F.
No LERs were issued in this functional area.
G.
Security and Safeguards
No LERs were issued in this functional area.
H.
0: stages
No LERs were issued in this functional area.
I.
Quality Programs and Administrative Controls Affecting Quality
The two LERs listed below involved activities in this functional area.
Hydrogen recombiner panel not securely mounted due to missing
.
structural weld.
(382/86-18)
Loose steam generator tube plugs due to inadequate installation.
.
(382/86-28)
J.
Licensing Activities
No LERs were issued in this functional area.
K.
Training and Qualifications Effectiveness
No LERs were issued in this functional area.