ML20215E519
| ML20215E519 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 12/17/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20215E522 | List: |
| References | |
| 50-285-86-27, NUDOCS 8612220360 | |
| Download: ML20215E519 (45) | |
See also: IR 05000285/1986027
Text
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SALP BOARD REPORT
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U.S. NUCLEAR REGULATORY COMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
Inspection Report 50-285/86-27
Omaha Public Power District
Fort Calhoun Nuclear Station
March 1, 1985, through September 30, 1986
8612220360 861217
ADOCK 05000285
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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.
The SALP program is
supplemental to normal regulatory processes used to ensure compliance with
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 and safety of plant operation.
An .NRC SALP Board, composed of the staff members listed below, met on
November 13, 1986, to review the collection of performance observations
and data, and to assess licensee performance in accordance with the
guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee
Performance." A summary of the guidance and evaluation criteria is
provided in Section II of this report.
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This report is the SALP Board's assessment of the licensee s safeI,y
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performance at Fort Calhoun Nuclear Station for the period March 1, 1985,
through September 30, 1986.
SALP Board for Fort Calhoun Nuclear Station:
E. Johnson, Director, Division of Reactor Safety and Projects,
Region IV
J. Gagliardo, Chief, Reactor Projects Branch, Region IV
D. Hunter, Chief, Project Section B, Reactor Projects Branch,
Region IV
L. Yandell, Chief, Emergency Preparedness and Safeguards Program
Section, Region IV
P. Harrell, Senior Resident Inspector, Fort Calhoun Nuclear Station,
Region IV
A. Thadani, Director, PWR Project Directorate 8, Office of Nuclear
Reactor Regulation (NRR)
D. Sells, Project Manager, Fort Calhoun Nuclear Station, NRR
Other personnel who participated in all or part of the SALP Board were:
W. Seidle, Chief, Technical Support Staff, Region IV
M. Murphy, Project Inspector, Project Section B, Region IV
H. Chaney, Inspector, Facilities Radiological Protection Section,
Region IV
R. Baer, Inspector, Facilities Radiological Protection Section,
Region IV
N. Terc, Inspector, Emergency Preparedness Section, Region IV
A. Earnest, Inspector, Safeguards Section, Region IV
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II.
CRITERIA
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Licensee performance was assessed in 11 selected functional areas.
Functional areas normally represent areas significant to nuclear safety
and the environment.
Some functional areas may not be assessed because of
little or no licensee activities, or lack of meaningful. observations.
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Special areas may be added to highlight significant observations.
One er more of the following evaluation criteria were used to assess each
functional area.
A.
Management involvement in assuring quality
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B.
Approach to the resolution of technical issues from a safety
standpoint
C.
Responsiveness to NRC initiatives
D.
Enforce' ment history
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E.
Operational events (including response to, analysis of, and
corrective actions for)
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F.
Staffing (including management)
G.
Training and qualification effectiveness
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However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories. The definitions of
these performance categories are:
Category 1.
Reduced NRC attention may be appropriate.
Licensee
management attention and involvement are aggressive and oriented toward
nuclear safety; licensee resources are ample and effectively used so that
a high level of performance with respect to operational safety and
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construction quality is being achieved.
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Category 2.
NRC attention should be maintained at norcal levels.
Licensee management attention and involvement are evident and are
concerned with nuclear safety; licensee resources are adequate and are
reasonably effective so that satisfactory performance with respect to
operational safety and construction quality is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers
nuclear safety, but weaknesses are evident; licensee resources appear to
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be strained or not effectively used so that minimally satisfactory
performance with respect to operational safety and construction quality is
being achieved.
III. SUMARY OF RESULTS
The SALP Board review revealed licensee areas of significant strength with
high management invcivement in assuring quality and with a strong approach
to the resolution of technical issues from a safety standpoint.
However,
the SALP Board also noted that the licensee has failed to improve its
performance in the functional area of security and safeguards and showed a
declining trend in t.he functional areas of radiological controls and
outages.
Even though the functional area of training and qualification
effectiveness showed an improving trend there remain a number of
improvement initiatives to be completed and strong management attention
should continue in this area.
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The licensee's performance is summarized in'the table below, along with
the performance categories from the previous SALP assessment period...
Previous
Present
Performance Category-
Performance Category
Functional Area
(9/1/83 to 2/28/85)
(3/1/85 to 9/30/86)
A.
Plant Operations
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B.
Radiological Controls
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2
C.
Maintenance
1
1
D.
Surveillance
1
1
E.
Fire Protection
1
1
1
F.
2
2
G.
Security and Safeguards
3
3
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H.
Outages
1
2
I,
Quality Programs and
2
2
Administrative Controls
Affecting Quality
J.
Licensing Activities
1
1
K.
Training and Qualification
3
2
Effectiveness
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Fifty-two NRC inspections were conducted during this SALP assessment
period, involving 5828 direct inspection man-hours. NRC inspection
reports issued during this assessment period were:
285/85-02 through 285/85-04; 285/85-06; 285/85-08 through 235/85-29
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285/86-01 through 285/86-26
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IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
This area was inspected on a continuing basis by the NRC
resident inspector. The inspections included reviews and
observations to verify facility operations were performed in
accordance with regulations, Technical Specifications (TS), and
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procedures.
No violations or deviations were identified in this functional
area.
The three licensee event reports (LER) listed below were
attributed to activities in the functional area of Plant
Operations.
Initiation of the ventilation isolation actuation
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system (VIAS) due to operator error.
(LERs85-004 and
85-005)
Partial loss of onsite power during(a refueling outage due
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to an abnormal electrical lineup.
LER 85-011)
The licensee continued to maintain an experienced group of
licensed senior reactor operators (SR0) and reactor
operators (RO). The operator staff was stable during this
assessment period with a very small turnover rate of licensed
onshift operators.
Staffing was at a level that permitted the
licensee to maintain a six-shift rotation except during heavy
vacation schedules in the summer months. The licensee was in
the process of adding an additional six licenses to the operator
staff and upgrading five R0s to SR0s. The additional licenses
and upgrades were scheduled to be completed in the latter part
of 1987.
Nine plant management personnel held and maintained SRO
licenses. These personnel provided support and technical
expertise to the operations department. The licensed management
personnel included the plant manager, reactor engineer, training
supervisor and instructors, and operations supervisor and
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operations support personnel. During this assessment period,
one shift supervisor was reassigned to serve as an interface
between the maintenance and operations organizations, and an
additional SR0 was assigned to the operations support group.
In the latter part of this assessment period, all management
personnel, licensed and unlicensed, made frequent tours and
inspected the control room, equipment areas, and other operating
spaces. These tours resulted in improved conduct of operations
and increased management visibility.
The licensed operators exhibited a strong, and dedicated
comitment to procedural compliance and a good understanding of
the technical issues associated with plant operations.
These
strengths were observed by the NRC resident inspector and other
NRC inspectors during tours of the control room, during
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emergency and abhormal plant conditions, and during the annual
emergency preparedness exercise. Log keeping and other
documentation maintained by plant operators was performed in an
accurate and highly professional manner.
The NRC resident inspector and other NRC personnel noted that
operator morale declined over this assessment period. The
decline in morale was attributed to the inability of licensed
operators to pass NRC-administered examinations and the lack of
a career path advancement program for onshift licensed
operators.
The NRC resident inspector monitored activities of
onshift licensed operators and noted that the decline in
operator morale did not affect the safe operation of the plant.
During this assessment period, the plant experienced two reactor
trips. One trip occurred in July 1986 due to failure of an
instrument inverter and the other manually initiated trip in
August 1986 was due to overheating of an electrical generator
bus duct.
The last reactor trip prior to these two occurred in
July 1984. On July 31, 1986, the licensee received a letter
from H. R. Denton, Director of NRR, complimenting the licensee
on its low frequency of reactor trips and noting that the low
frequency is an important indication of safe and reliable plant
operation.
In January 1986 the licensee issued and implemented upgraded
emergency operating procedures (E0P), based on the Combustion
Engineering guidelines for emergency procedures.
These E0Ps
provided a symptom-based approach to plant emergencies.
In
conjunction with issuance of the E0Ps, the licensee issued
revised abnormal operating procedures (A0P) in January 1986. The
new A0Ps were issued as an upgrade to the previous emergency
procedures to complement the revised E0Ps.
During this assessment period, the emergency plan was
implemented on two occasions.
In September 1985 a Notice of
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Unusual Event-(N0VE) was declared due to a leaking chlorine
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bottle. The leak was quickly contained and the NOUE was
terminated.
In May 1986 another NOUE was declared due to
incorrect operation of a sampling valve by a chemistry
technician. The misoperation of the valve caused a release of
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radioactive gas to the auxiliary building (AB) and the gas was
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discharged to the atmosphere through the AB ventilation system.
The ventilation system was secured and the unplanned release
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terminated approximately two minutes after initiation due to
quick identification of the problem and subsequent initiation of
corrective actions by the plant operators. Operator actions
limited the level of the release at the offsite boundary. The
magnitude of the release was approximately three times the TS
limit at the site boundary for a duration of approximately
2 minutes. This release did not pose a threat to the health and
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safety of the public. After the AB was isolated and the release
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secured, the NOUE was terminated.
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The safety parameter display system (SPDS) was declared
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operational by the licensee during this assessment period.
Training was provided for plant operators on the use of the SPDS
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and observations by the NRC resident inspector indicated that
the operators used the SPDS effectively. A control room
modification was performed in order to locate an SPDS terminal
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near the plant control boards.
This nodification allowed the
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operators easy access to the terminal while performing
activities on the control boards.
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The licensee continued to implement changes to the control room
based on the results of'the detailed control room design review.
This' effort was ongoing and was not completed during this
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assessment period. The completion of the review was scheduled
for February 1987.
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A program for upgrading the annunciator system to eliminate
nuisance alarms continued throughout this assessment period.
Even though many nuisance alarms were eliminated, the
annunciator system Was still plagued by a number of alarms. The
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licensee continued to work at elimination of all nuisance
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alarms.
During tours of the facility made by the NRC Chairman, NRC
Regional Administrator, and other NRC Region IV personnel
subsequent to the review period, it was noted that plant-wide
housekeeping activities were adecuate.
However, it was also
noted that areas in the plant hac not received the level of
management attention to housekeeping that was considered
appropriate.
In these areas, dust, miscellaneous debris, and
cigarette butts had accumulated.
The need for additional
housekeeping attention in these areas was considered to be an
indication of the need for additional management attention in
maintaining the plant in a clean condition.
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During these tours, NRC personnel also noted that labeling of
valves and piping systems was inadequate.
The licensee used a
method of marking that included uncontrolled, handwritten
identification of system designations on pipes and walls with
felt-tip markers.
The licensee also used brass tags on valves
with the valve number designation only.
The tags did not
contain a description of the valve function.
The licensee
should consider upgrading the plant labeling program by removing
the miscellaneous felt-tip pen markings and initiating a
controlled system for marking piping systems.
In addition, the
Itcensee should consider the use of valve tags that provide a
description of the function, as well as the number of the valve.
2.
Conclusion
The overall performance level in this functional area was
excellent during this assessment period.
Plant management
involvement was effective as evidenced by no violations or
deviations being identified in this functional area and by an
excellent past operating history.
The licensee maintained a
well qualified and stable operations staff.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should
remain at the present reduced level,
b.
Recommended Licensee Actions
Licensee management should continue past efforts to ensure
that this functional area is maintained at the current high
level of performance.
Management should take actions to
complete the detailed control room design review and
implement the appropriate control room upgrades in a timely
manner, to eliminate all remaining nuisance alarms from the
control boards, and to upgrade the plant-wide housekeeping
and the plant labeling programs.
B.
Radiological Controls
1.
Analysis
Ten inspections in the functional area of Radiological Controls
were performed during this assessment period by NRC Region IV
personnel.
These inspections included the following areas:
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occupational radiation safety, radioactive waste management,
radiological effluent control and monitoring, transportation of
radioactive materials, and water chemistry controls.
The 13 violations listed below were identified in this
functional area.
No deviations were identified.
Failure to instruct workers prior to entering a restricted
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area.
(Severity Level V, 285/8502-01)
Failure to maintain occupational external radiation
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exposure histories, Form NRC-4.
285/8502-02)
Failure to maintain the data for current occupational
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external radiation exposures, Form NRC-5.
(Severity
Level V, 285/8502-03)
Failute to provide workers with exposure information in a
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termination report.
(Severity Level V, 285/8502-04)
Failure to follow procedures in posting a radiation area.
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(Severity Level IV, 285/8502-05)
Failure to identify a shipment as radioactive and failure
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to perform a transportation survey.
(Combined as one
Severity Level III, 285/8601-01)
Failure to provide workers with exposure information in a
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termination report.
(Severity Level IV, 285/8601-02)
Failure to cuntrol a very high radiation area.
(Severity
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Level III, 285/8601-03)
Failure to report Strontium 89 and 90 results.
(Severity
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Level IV, 285/8605-01)
Failure to review environmental monitoring procedures.
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(Severity Level IV, 285/8605-02)
Failure to follow procedures for retention of radiation
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monitor calibration records.
285/8608-01)
Failure to submit a special report on the inoperability of
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the postaccident sampling system (PASS).
(Severity
Level IV, 285/8608-02)
Failure to establish operating and calibration procedures
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for portable radiation monitors.
285/8608-03)
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The three LERs listed below were attributed to activities
associated with this functional area.
A chemistry technician caused the initiation of a VIAS
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while purging a line to take a reactor coolant sample.
(LER 85-001)
Containment purge initiated prior to complete purging of
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pressure in contairment caused a VIAS.
(LER 85-007)
Release of radioactive gas to the AB due to misoperation of
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a sampling valve by a chemistry technician.
(LER 86-003)
A detailed discussion of activities associated with this
functional area is provided below.
a.
This area was inspected four times during this assessment
period.
These inspections included three inspections
during routine plant operations and one refueling outage
inspection.
Eight violations related to radiation
protection activities were identified.
The numerous violations identified in the radiation
protection program was an indication of a lack of
management involvement in assuring quality, and worker
training.
Management / supervision had not performed routine
reviews of work activities at the job sites within the
radiation controlled area to ensure radiation protection
controls were properly implemented.
An aggressive,
comprehensive licensee audit / review program had not been
implemented regarding radiation protection activities.
Repeat violations were identified which indicated that the
root causes were not effectively eliminated. Weaknesses in
the radiation protection program were identified in that
radiation protection personnel were not familiar with basic
regulatory requirements and plant procedures.
The size of the radiation protection staff was adequate to
support plant operations.
A low personnel turnover rate
within the radiation protection group was experienced
during this assessment period.
The licensee's approach
concerning the resolution of technical issues indicated a
clear understanding of each issue and included a generally
sound and thorough solution.
The licensee continued to be below the national average
regarding personnel exposures.
The person-rem exposure for
1985 was 373 as compared with the PWR national average of
427.
In 1986 the licensee expended 73 person rem for the
period ending September 30, 1986.
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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 this assessment period.
No
violations or deviations were identified.
The Itcensee implemented a well defined program for the
processing of gaseous, liquid, and solid waste.
No
particular problems were identified in this area,
c.
Radiological Effluent Control and Monitoring
The plant liquid and gaseous effluent control program was
inspected twice during this assessment period.
Two
violations involving gaseous effluent monitoring
instrumentation were identified.
Effluent sampling and
analyses activities were well defined in plant procedures
to ensure compliance with the new Radiological Effluent
Technical Specifications that were implemented during this
assessment period.
Gaseous and liquid release permit
programs were established to ensure that planned releases
received the necessary review and approval prior to
release.
The offsite radiological environmental monitoring program
was inspected twice during this assessment period.
Two
minor violations were identified.
In general, the offsite
radiological environmental monitoring program was well
managed.
The radiochemistry program was inspected once which
included onsite confirmatory measurements with the NRC
Region IV mobile laboratory.
No violations or deviations
were identified.
The results of the confirmatory
measurements indicated that the licensee's percent
agreement was slightly below the value expected for an
operational radiochemistry program.
The PASS was inspected
in conjunction with the radiochemistry program.
One
observation was made which noted that the licensee had not
established a PASS operator requalification/ training
program nor documented chemistry technician performance
training on the PASS.
d.
Transportation of Radioactive Materials
This area was inspected once.
Two violations were
identified.
The two violations were the failure to survey
a radioactive contaminated main steam valve prior to
shipment to an offsite laboratory for repair, and the
failure to identify a radioactive shipment by labeling or
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marking.
These two violations were combined into one
Severity Level III violation.
As a result of the
transportation inspection findings and other related
radiation protection Severity Level III and IV violations,
an enforcement conference was held on April 11, 1986.
Weaknesses were noted concerning the maintenance of
training records and the scheduling of training activities
concerning personnel responsible for transportation
activities.
These weaknesses involved fragmented records
storage, with some of the training information being
maintained outside of the training department, and the lack
of an established schedule for required refresher training.
e.
Water Chemistry Controls
The primary and secondary systems affecting plant water
chemistry were inspected once.
No violations or deviations
were identified.
This inspection was limited in scope;
therefore, a more detailed inspection was planned for 1987.
2.
Conclusion
The following conclusions were made concerning the functional
area of Radiological Controls.
The licensee maintained a high
level of quality in the radiological environmental monitoring
and effluent release control programs.
The areas of
radiochemistry and radioactive waste management were deemed to
be satisfactory.
Several weaknesses were identified involving
management oversight, adequacy of records, conduct of the
radiation exposure control program involving high radiation
areas, and in the radiation protection and radioactive materials
transportation programs.
While management oversight of the various radiological control
program areas was evident by the performance of audits, a
programatic problem existed in that the audits were generally of
insufficient scope and detail to identify program weaknesses.
It was noted that some licensee personnel did not have a good
understanding of regulatory requirements and plant procedures
which is an indication of an ineffective training program.
The licensee's performance was considered adequate in the areas
of resolution of technical issues, reporting operational events,
and staffing.
The licensee's performance was judged to be less
than satisfactory in the area of responsiveness to NRC
initiatives in that responses were often viable, but lacking in
thoroughness or depth.
The licensee is considered to bo in Performance Category 2 with
an overall declining trend in this functional area.
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3.
Board Reconuendations
a.
Recommended f4RC Actions
Inspection effort should be maintained at the normal level
with decreased emphasis in the areas of radiological
environmental monitoring, radiochemistry, effluent control
and monitoring, and radioactive waste management.
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Inspection effort in the areas of occupational radiation
safety, transportation, and water chemistry controls should
be increased,
b.
Recommended Licensee Actions
Management / supervision should spend more time visiting job
sites to ensure radiation controls are properly
implemented. The audit / review program should be expanded
to improve the self-identification of program weaknesses.
The effectiveness of training should be reviewed to ensure
personnel have a good understanding of regulatory
requirements and plant procedures.
C.
Maintenance
1.
Analysis
This area was inspected on a continuing basis by the flRC
resident inspector. These inspections included verification
that maintenance activities were performed in accordance with
procedures, regulatory requirements, and TS.
This area was also
inspected during a special inspection conducted by an NRC
inspection team in the area of equipment environmental
qualification (EEQ).
Two violations and two deviations were identified in this
functional area during this assessment period.
Maintenance was not performed on the component cooling
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water pumps to maintain the EEQ status of the pumps.
(Severity Level IV, 285/8509-01)
Failure to meet a comitment related to cleanliness of
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fluid systems.
(Deviation, 285/8527-01)
Failure to meet a connitment related to storage of critical
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quality equipment (CQE))in temporary storage areas.
(Deviation, 285/8527-02
Failure to store boric acid in a CQE storage area to
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prevent damage or deterioration.
285/8621-01)
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No LERs were identified in this functional area.
The licensee maintained a very stable and well qualified
maintenance work force with little turnover during this
assessment period.
The licensee added three new instrumentation
and control (I&C) technicians and five new maintenance engineers
to the maintenance staff during this SALP period.
These
additions provided additional technical support for the
maintenance group and additional I&C technicians for an
increased work load in site security systems maintenance and
calibrations.
The maintenance group maintained plant equipment in good working
order.
For this reason, the licensee did not experience any
forced plant shutdowns due to maintenance problems.
During this SALP period, the licensee implemented an automated
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tracking system for maintenance orders (MO).
This system,
CHAMPS, was also used to track and generate preventive
maintenance (PM) items to ensure PM activities were performed
when due to minimize delinquent PMs.
The CHAMPS tracking system
was initiated just prior to the refueling outage in 1985-1986
and tracked each M0 and PM to verify proper and timely
completion.
A special inspection was performed by an NRC inspedion team in
the area of EEQ.
The team noted a maintenance-related problem
in the area of performing maintenance on electrical motors.
The
licensee completed corrective actions for the identified
deficient area.
In the area of EEQ, the licensee also took
corrective actions related to the checking and repair of all
Limitorque motor-operated valves.
The corrective actions
included checking and replacement, as necessary, of the internal
wiring in the Limitorque valves based on problems identified by
the NRC in IE Information Notice 86-03.
This effort was
completed during the 1985-1986 refueling outage.
The licensee's backlog of maintenance activities for all crafts
remained approximately constant during this assessment period.
The level of backlog was approximately 250 man-hours of work on
safety-related systems in each of the areas of electrical, I&C,
and mechanical maintenance.
To ensure that maintenance efforts were directed toward
equipment and components requiring the most immediate attention,
a daily meeting was held between the maintenance and operations
groups.
In this meeting, operations personnel established their
priorities for which maintenance activities should be completed
first.
8ased on the input, the maintenance group established
its daily work schedule.
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The licensee experienced problems controlling the temporary
storage of CQE material during this assessment period.
During
followup on a violation (285/8501-01) identified during the
previous SALP period, the NRC resident inspector noted that the
licensee had not taken the appropriate corrective actions as was
stated in the licensee's response to the violation.
Appropriately, a deviation was issued. At a later time, it was
noted that the boric acid used for control of primary plant
reactivity was not properly stored to prevent damage or
deterioration.
The licensee took actions to correct these
problems.
To correct the problems of having to store CQE
materials in the plant in temporary storage areas, the licensee
proposed and secured funds to relocate the warehouse.
The
warehouse is currently located outside the plant protected area.
The relocation of the warehouse will allow access to materials
from within the protected area and eliminate the need to store
material inside the plant.
The proposed schedule for completion
of the warehouse relocation was 1988.
2.
Conclusion
The licensee had shown increased management attention in the
functional area of Maintenance as indicated by consistent
evidence of prior planning and assignment of priorities.
Additional licensee management attention is needed to reduce the
backlog of maintenance items and to establish and implement an
effective program for storage of CQE material in the plant.
Licensee management attention was evident in that no
maintenance-forced outages occurred during this assessment
period.
The licensee maintained plant equipment in good working
order through an effectively administered PH program.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should
remain at the present reduced level,
b.
Recommended Licensee Actions
Licensee management should continue an active involvement
in this functional area to ensure that the present
performance level is maintained.
Management should
continue to reduce the quantity of the maintenance order
backlog.
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D.
Surveillance
1.
Analysis
This area was inspected on a continuing basis by the NRC
resident inspector and by NRC Region IV inspectors.
The
inspections included verificatlun that tests were completed in a
timely manner using an approved testing procedure, tests were
conducted in accordance with TS requirements, and test results
were reviewed to verify equipment and/or component operability.
The violation listed below was identified in this functional
area.
No deviations were identified.
Failure to implement a surveillance required by the TS,
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(Severity Level IV, 285/8515-03)
One LER was identified in this functional area.
Containment pressure instrument surveillance test was not
.
completed within the required frequency.
(LER 86-002)
'
,
The licensee maintained an effectively managed surveillance test
program. A monthly surveillance testing schedule was published
that included the test due date and responsible performing
organization to ensure the appropriate individuals were notified
of testing res nsibilities.
The master surveillance schedule
was updated, as appropriate, whenever TS amendments were issued.
The NRC resident inspector verified during numerous observations
of survelliance test activities that the testing was prcperly
completed, the latest revision of the testing procedura was
used, and the test was reviewed for compliance with established
acceptance criteria.
The NRC resident inspector observed that
the individuals performing the tests were well acquainted with
the testing requirements and performed the tests in a highly
,
l
professional manner.
The primary basis for the high level of
I
performance was the licensee's stable work force and experience
of the personnel performing the tests.
Surveillance test
results were reviewed at the completion of the test to verify
the acceptance criteria were met.
If the results indicated that
l
the test was unsatisfactory, the equipment and/or component was
repaired and a retest performed in a timely manner.
Although the licensee experienced one identified problem in
l
implementing TS-required surveillances and one in performing
!
surveillances within the required frequency, these problems
appeared to be isolated cases.
Typically, the licensee
l
performed approximately 2500 TS surveillances each year in a
i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ ________
o
.
17
timely manner.
The licensee maintained a program to ensure that
surveillance activities required by new TS amendments were
!
incorporated into the surveillance program.
2.
Conclusion
The licensee maintained an effectively managed surveillance test
program.
In this functional area, the responsiveness to NRC
issues was timely and technically sound.
Major violations were
rare and were not indicative of a programatic breakdown.
Personnel performing surveillance activities were well trained
and qualified.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should
remain at a reduced level,
b.
Recommended Licensee Actions
Licensee management should continue to exercise strong
management controls over the surveillance test program to
ensure that the current high level of performance is
maintained.
E.
Fire Protection
1.
Analysis
This area was inspected by NP,C Region IV inspectors and on a
continuing basis by the NRC resident inspector.
The inspections
were performed to verify the licensee maintained a fire
protection / prevention program in accordance with Branch
Technical Position 9.5-1, commitments to Appendix R to 10 CFR Part 50, and the licensev's fire hazards analssis; housekeeping
and cleanliness control were adequate; and fire brigade training
was perforned in accordance with the TS.
Two violations and no deviations were Identified in this
functional area.
Failure to perform hourly fire watch patrols of degraded
.
(Severity Level IV, 285/8603-02)
.
-
-
--
-
-
-
-
-
-
.
e
18
Failure to submit a report, as required by the TS, for a
.
fire barrier that was degraded longer than 30 days.
(Severity Level V, 285/8621-02)
The LER listed below involved activities in the functional area
of Fire Protection.
A continuous firewatch was not posted during halon system
.
inoperability.
(LER 85-012)
During this assessment period, the NRC completed the review and
processing of the licensee's exemption requests under Appendix R
to 10 CFR Part 50 and issued the final fire protection Safety
Evaluation Report.
The licensee completed all commitments for
modifications made to satisfy the requirements of Appendix R.
Other significant items initiated by the licensee during this
assessment period are listed below.
-
Requested and received an inspection of all fire doors by
.
Underwriters Laboratory.
As a result of this inspection,
the licensee identified a number of fire doors to be
repaired or replaced.
Installation of new fire doors was
in process at the end of the assessment period.
Selected plant personnel were trained and certified to
.
install and/or inspect the most common types of fire
barrier penetration seals.
Fire barrier records were revised to make them more usable.
.
New fire barrier labels were being installed.
.
A revised fire hazards / transient loading study was
.
initiated.
The licensee issued five special reports on the inoperability of
fire barriers as required by the TS during this assessment
period.
In each reported case, the licensee issued an MO for
repair of the barrier and established a roving or continuous
fire watch, as appropriate.
The licensee took appropriate
corrective actions to ensure the degraded barrier was repaired
as soon as possible.
The 11consee maintained the plant in en adequately clean
condition, with only a few exceptions.
On four occasions, the
NRC resident inspector noted areas where significant amounts of
miscellaneous material had accumulated and the licensee had to
provide addition 6l housekeeping attention.
In each case, the
licensee provided immediate attention to the areas to eliminate
the identified discrepancies.
In no case identified by the NRC
_ - _ _ _ - _ _ _ _ _ _ _ _ _ _
O
3
t
19
inspector, did the housekeeping discrepancies cause the fire
loading for the affected areas to exceed the fire loading stated
in the fire hazards analysis.
During this assessment period, reviews were performed by NRC
inspectors to verify that fire brigade training was performed in
accordance with the TS. The results of these reviews indicated
that the licensee implemented an effective fire brigade training
program and that the individuals participating in the program
were well trained and qualified.
2.
Conclusion
The licensee continued to show significant progress in the
development of an effective fire protection / prevention program.
Licensee management involvement in this functional area was
evident by the progress made in the program.
'
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should be
reduced.
b.
Recommended Licensee Actions
Lic. ensue management should continue to implement the
program improvement initiatives by completion of the
activities presently underway.
F.
Emerooney Preparedness
1.
Analysis
This area was inspected on a periodic basis by NRC Region IV
inspectors, the NRC resident inspector, and contract personnel.
Three violations and one deviation were identified in the
functional area of Emergency Preparedness.
Three operating shifts were unable to demonstrate the
.
ability to perform 15-minute notifications to state and
local authorities.
(Severity Level IV, 285/8519-01)
.
. _
.
-
l
.
,-
'
'
20
Failure to provide adequate emergency response training to
.
health physics technicians, shift technical advisors, and
reactor operators, and failure to provide adequate training
tests.
(Severity Level IV, 285/8519-02)
Inadequate review of the emergency preparedness program.
.
(Severity Level IV, 285/8519-03)
Failure to meet a commitment to perform training of
.
emergency personnel within 1 year.
(Deviation,
285/8519-04)
No LERs were identified in this functional area,
r
During this assessment period, an emergency response
facilities (ERF) appraisal and four emergent.y preparedness
inspections were conducted.
Two of the inspections consisted of
exercise observations and evaluations, and the other two were
,
routine unannounced inspections.
The results of these inspections indicated that the licensee
demonstrated weaknesses in the areas of training; internal audit
,
program; and procedures related to notifications, protective
action recommendations, security during emergencies, and dose
projections.
Repeat deficiencies were identified during observation of the
,
annual emergency exercise drills.
The deficiencies were
prompting and coaching of the drill players by individuals
running the delli and excessive delay in making notifications to
'
local and state authorities.
These deficiencies are discussed
in NRC Inspection Reports 50-0d5/85-16 and 50-285/86-19.
Additional deficiencies identified during the second exercise
performed during this SALP period indicated that more definitive
corrective actions were needed and that, although the exercise
demonstrated a satisfactory state of emergency response
readiness, improvement was needed in some areas.
,
.
i
The violations and deviation identified during inspections
{
i
indicated a minor programatic breakdown in these areas.
1
However, the licensee's replies and responses to NRC-identified
.
I
problems showed a proper understanding of the issues; viable.
'
generally sound, and thorough approaches and timely responses
i
and resolution of issues.
For example, the NRC inspectors
!
verified that adequate corrective actions were taken in response
'
l
to the violations identified during this assessment period.
l
Sixteen deficiencies were identified during this assessment
i
period aside from the deficiencies identified during the ERF
!
Inspection.
The NRC inspectors closed nine of ten deficiencies
.
l
identified during the first emergency exercise inspection.
l
1
i
i
!
!
t
. _ _ _ _ _ _ _ _ _ _ _ _ _ - .
O
8
21
During this assessment period, a special team inspection was
performed to verify that the licensee had properly constructed,
located, and equipped the ERF as required by NUREG-0737,
Supplement 1.
The results of the inspection noted no violations
or deviations; however, fourteen deficiencies were identified.
The 14 deficiencies identified during the ERF appraisal
pertained to the methods and models used for performing dose
assessment; to the availability of radiation instruments, pocket
dosimeters, and meteorological data; and to the procedures used
for protective action recommendation decisionmaking.
The
details of the deficiencies are provided in NRC Inspection
Report 50-285/86-20.
On May 1, 1986, the licensee declared a NOUE due to release of
radioactive gas to the A8 which was subsequently released to the
environment.
See the functional area of Plant Operations for a
discussion of this event.
The licensee implemented the
emergency plan as required by regulations.
The actions taken by
the licensee for this event included staffing of the technical
support center (TSC).
The NRC resident inspector was present at
the plant and observed the actions taken by the licensee.
Licensee personnel demonstrated the ability to implement the
requirements of the emergency plan during an actual event.
2.
Conclusion
The licensee established adequate emergency response
capabilities and responded well to violations and other
deficiencies identified during NRC inspections.
The results of
the licensee's participation in annual emergency exercises
demonstrated a satisfactory state of emergency response
readiness.
No violations or deviations were identified during
the ERF appraisal and a relatively small number of deficiencies.
However, repeat findings and new exercise deficiencies indicated
the need for additional management attention in this area.
The licensee is considered to be in Performance Category 2 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
lhe NRC Inspection effort in this functional area should
s
remain at the present level,
b.
Recommended Licenson Actions
The licrnsee should address the weaknesses in the emergency
preparedness training program and correct the deficiencies
-
.
,
22
identified in the last exercise and the ERF appraisal.
The
licensee should establish a program to determine the root
cause of identified problems to ensure the problems are
corrected and not found to be repeat problems in subsequent
inspections.
G.
Security and Safeguards
1.
Analysis
This area was inspected on a continuing basis by the NRC
resident inspector and periodically by NRC Region IV inspectors.
The inspections were performed to verify the licensee was
maintaining a security and safeguards program as required by the
licensee's security program and 10 CFR Part 73.
The 16 violations listed below were identified in the functional
area of Security tend Safeguards.
No deviations were identified.
Unqualified security personnel were performing security
.
duties.
(Severity Level IV, 285/8508-01)
Failure to follow a search procedure at an access control
.
point.
(Severity Level V, 285/8520-01)
Failure to display security badges while in the protected
.
area.
(Severity Level V, 285/8527-03)
Locks, keys, and combinations were not properly controlled.
.
(Severity Level IV, 285/8528-01)
Detection aids for the protected area were found to be
.
inadequate.
(Severity Level IV, 285/8604-01)
Assessment aids were inadequate.
.
285/8604-02)
Control of locks and keys was inadequate.
(Severity
.
Level IV, 285/8604-03)
A vital area barrier was found to be inadequate.
(Severity
.
Level IV, 285/8607-01)
Inadequate control of a protected area barrier.
(Severity
.
Level IV, 285/8610-01)
Inadequate security force response capability.
(Severity
.
Level IV, 285/8615-03)
Individual guard suitability records were unauthenticated.
.
(Severity Level IV, 285/8615-01)
.
-
-
-
-
- -
-
-
-
-
-
. _ _
-
.
.
23
Failure to conduct behavioral observations.
(Severity
.
Level IV, 285/8615-02)
Inadequate access control for a vital area barrier.
.
(Severity Level to be determined, 285/8617-01)
Inadequate control of safeguards information.
(Severity
.
Level IV, 285/8623-01)
Not identifying a diagram as safeguards information.
.
(SeveriLy Level IV, 285/8623-02)
Inattentive compensatory watchperson.
.
285/8626-01)
No LERs were identified in this functional area.
Eight inspections were conducted by NRC Region IV physical
security inspectors during this assessment period.
Additionally, physical security violations were identified in
four separate reports issued by the NRC resident inspector.
During this assessment period, the licensee failed to take
appropriate corrective action as evidenced by recurring
violations in three different areas. The areas affected
included two violations in control of locks and keys; three
violations for failure to properly control vital and protected
area barriers; and three violations related to the performance,
training, and quantity of security personnel.
These violations
of a repetitive nature was an indication of licensee
management's failure to determine the root cause of identified
problems and take appropriate corrective actions, and the
failure to apply generic corrective actions for eclat,d areas
when a problem was identifled in a specific area.
An enforcement conference was held in Region IV on August 22,
1986, to discuss identified problems related to the failure to
maintain a vital area barrier.
This violation is currently
under review by NRC Headquarters for potential escalated
enforcement.
The enforcement conference was followed by a
management meeting between the licensee and NRC Region IV
security management and inspection personnel to discuss
recurring problems in the area of security.
During this SALP period, the licensee established and staffed
new positions within the security organization.
The licensee
placed nuclear watch officers (unarmed security personnel) on
each shift to supplement the existing security force.
The watch
officers performed compensatory measures and various security
duties.
In addition, the security force was increased to eight
e
.
24
guards per shift.
These actions were taken to ensure sufficient
manpower was available to meet requirements stated in the
licensee's security plan.
The licensee made a personnel change in the security
organization during this SALP period.
The change replaced the
previous management-level individual with an individual with
little previous background and experience in the area of
security.
The licensee has taken action to increase management
positions on each security shift by creating a new position of
security shift supervisor. The positions were in the process of
being filled at the end of the assessment period.
The licensee commenced expansion of the security ouilding during
this assessment period.
The security building expansion will
allow the licensee to control the entrance and exit of personnel
to and from the protecteu area at different control points. The
expansion is currently scheduled to be completed in early 1987.
The licensee also proposed to upgrade the security computer
system.
The upgrade should be completed in 1988.
In May 1986 a Regulatory Effectiveness Review (RER) was
performed by NRC Headquarters, Region IV, and U.S. Army Special
Forces personnel.
The RER was performed to review the impact of
security on safe plant operations and to evaluate the overall
effectiveness of the security program to protect against the
design basis threat for theft and radiological sabotage as
defined in 10 CFR Part 73.
The results of the RER found similar
probleas as had been found by the NRC Region IV inspectors
during this SALP period.
The results of the RER were issued in
a special report dated November 4, 1986.
2.
Conclusion
Licensee management demonstrated a lack of dedication to
establishing and maintaining a security program that is only
minimally acceptable.
Fxpertise and staffing did not appear to
be adequate at the security management level, but the licensee
initiated action to correct this problem.
The licensee was slow
in correcting basic security component deficiencies and tended
to rely on long-term compensatory measures.
At the end of this
assessment period, the licensee developed plans for correcting
some of the long-term deficiencies, but actual hardware changes
were not implemented.
The licensee is considered to be in Performance Category 3 in
this functional area.
.
.
25
.
3.
Board Reconmendations
a.
Recommended NRC Actions
The NRC inspection effort in this functional area should be
increased due to weak management controls and the large
number of violations identified during this assessment
l
period.
The NRC inspection effort should focus on
management effectiveness in resolving problems identified
in weak areas.
b.
Recommended Licensee Actions
The licensee should take aggressive action to increase
management attention to resolve the weaknesses identified
in this functional area. These actions should include
obtaining personnel with a strong security background to
assist in resolving the problems that continue to plague
the licensee's security and safeguards program, resolution
of identified problems and implementation of appropriate
corrective actions to ensure problems do not recur, and
initiation of a program to establish a sound management
approach for upgrading the program.
H.
Outages
1.
Analysis
This functional area was inspected on a continuing basis by the
NRC resident inspector during the period of the Cycle 10
refueling outage from September 28, 1985 through January 9,
1986.
A special inspection was performed by the Safety Systems
Outage Modification Inspection (SSOMI) team of activities
related to this functional area.
The SS0MI team consisted of
members from NRC Headquarters, Region IV, and consultants.
The
inspections included verification that refueling activities,
outage taanagement, repairs and modifications to equipment, and
precperational startup testing were performed in accordance with
the TS, regulatory requirements, and procedures.
No violations, deviations, or LERs were identified during this
assessment period for this functional area.
For the first time, in-house personnel provided supervision and
coordination of Cycle 10 refueling activities.
The supervision
and coordination included refueling of the reactor, modification
work, and preoperational testing.
To provide additional
management involvement with future naintenance and refueling
outages, the licensee established a new position of
L
.
- .
m
.
- --
.
-
m
. . .
. -
_ _ _ _ _ , _ _ - _ _
_.
_ ..
'
, ; "-
.
,
i-
2G
L
Supervisor-Outage Projects. The group headed by this new
manager will provide planning and scheduling of refueling
activities.
Movement of the fuel was completed without incident. The'NRC
resident inspector observed fuel handling activities on numerous
occasions.
Refueling activities were performed in accordance
with TS requirements. The personnel performing fuel movement
activities were well trained and qualified.
The SSOMI team inspection noted significant problems associated
with the installation and testing of modifications installed
during the Cycle 10 outage.
Problems were noted in the areas of
control of special processes, not following testing and
installation instructions, and not providing required
independent inspections by the quality control (QC)
organization. The details of the identified problem areas are
provided in NRC Inspection Report 50-285/85-29.
The NRC is
currently reviewing the results of the inspection and will be
making a determination of the expected enforcement actions. For
this reason, the violations were not listed in this functional
area.
2..
Conclusion
Licensee management demonstrated effective control of the outage
activities associated with the movement and handling of fuel-
during transport to and from the reactor vessel. The licensee
demonstrated significant weaknesses in the area of installation
and testing of plant modifications during the outage. The
weaknesses identified by the SS0MI team were attributed to
taking corrective action that was not effective in correcting the
root cause of identified problems, failing to fully understand
the technical issues and apparent programmatic breakdowns.
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
remain at a reduced level for activities associated with
fuel handling and movement. The inspection effort for
installation of modifications should remain at the normal
level. The NRC should perform a detailed followup of
licensee actions taken in response to the items identified
by the SS0MI team.
.
..
27
b.
Recommended Licensee Actions
Licensee management should continue.to exercise the same
level of management control as has been apparent in the
past for the movement of fuel. Management attention and
control should be increased in the significant weak areas
identified by the SSOMI team to ensure activities in these
'
areas are performed in accordance with requirements.
I.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
This functional area was inspected on a continuing basis by the
NRC resident inspector and by NRC Region IV inspectors.
This
area was also inspected by a special team inspection performed
in the area of EEQ. A special inspection was also performed of
activities related to this functional area by the SSOMI team.
Inspections performed in this functional area included review of
the administration of quality assurance (QA) and QC activities,
operations QA program, QC program, safety review committees
(onsite and offsite), document control, records, procedures, IE
Bulletin followup, and procurement controls.
The 13 violations and one deviation identified in this
functional area are listed below.
Records for piping thermal stress analysis were not
.
retrievable.
(Severity Level IV, 285/8503-02)
Failure to request exemption for inservice inspection
.
requirements for recirculation piping.
285/8503-04)
Accuracies for PASS monitoring transmitters had not been
.
established.
(Severity Level IV, 285/8509-02)
Containment electrical penetration assemblies instal:ed in
.
the plant were not properly qualified for EEQ applic5tions.
,
(Severity Level III, 285/8509-03)
'
Terminal blocks installed in the plant were not properly
i
.
qualified to EEQ applications.
285/8509-04)
Electrical cable installed in the plant was not properly
l
.
'
qualified for EEQ applications.
285/8509-05)
Failure to maintain completed surveillance tests in the
.
files.
(Severity Level V, 285/8511-01)
{'
- .
28
Failure to establish document control procedures. (Severity
.
Level IV, 285/8515-01)
Failure to meet licensing requirements related to storage
.
of uranium hexafluoride (UF6) cylinders.
(Severity
Level IV, 285/8515-02)
Failure to follow a procedure related to inspection of UF6
.
cylinders.
(Severity Level IV, 285/8602-07)
Modification to a safety-related system was performed
.
without the use of an approved procedure.
(Severity
Level IV, 285/8603-01)
Failure to maintain installation of cable trays and cable
.
tray covers in accordance with design documentation.
(Severity Level IV, 285/8614-01)
Failure to establish measures to prevent acceptance of
.
electrical cable without a material test report.
(Severity
Level V, 285/8616-01)
Failure to meet a commitment related to parameters
.
monitored by the SPDS. (Deviation, 285/8618-01)
The LER listed below was identified for this functional area.
A nonsingle-failure proof circuit was identified during a
.
refueling shutdown.
(85-009)
A special inspection in the area of EEQ was performed by an NRC
inspection team that included personnel from NRC Headquarters
and Region IV.
The team noted problems affecting the
qualification of various plant components due to inadequate or
missing documentation.
A Severity Level III violation was
identified during the inspection for the failure to properly
qualify the Conax penetrations installed in the plant.
The
inspection team noted that the licensee had implemented an EEQ
program at an unusually early date and that the program was well
developed.
Two' followup inspections were performed by Region IV
and one by the NRC resident inspector.
The results indicated
that the licensee had corrected the documentation deficiencies.
i
A special inspection by the SSOMI team was also performed
related to activities within this functional area.
This team
inspection noted areas of weakness associated with design
configuration control.
The specific areas included problems in
issuance of inadequate installation and testing procedures and
drawings, modification of the facility without performance of a
documented safety evaluation, lack of control for design inputs,
inadequate or inappropriate design analyses, inadequate
o
-
29
procurement documentation, and an inadequate corrective action
program.
The details of these problems are provided in NRC
Inspection Reports 50-285/85-22 and 50-285/85-29.
The NRC is
currently reviewing the results 'of the S50MI for potential
enforcement actions.
For this reason, the severity Itvel for
any potential violations has not been determined; therefore, the
violations have not been listed in this functional area.
During previous SALP reports, the area of records retention and
retrieval was identified as an area of concern to the NRC.
The
licensee experienced problems with records during this
assessment period.
The problem areas included failure to
maintain completed surveillance tests in the files, failure to
retrieve records for piping thermal stress analysis, and failure
to maintain an adequate licensed-operator and health physics
training records program.
The licensee continued to work on
resolving a problem noted in the last SALP report regarding the
filing and retrievability of construction records.
During this assessment period, the licensee experienced
difficulty in meeting commitments made to the NRC.
This was
evidenced by the issuance of deviations in the functional areas
of Maintenance, Radiological Controls, Emergency Preparedness,
and this functional area.
Deviations were identified due to the
licensee's failure to meet commitments made in response to
notices of violation or in response to implementation of
regulatory requirements.
Deviations were also identified from
the licensee's failure to submit reports required by the TS.
The deviations resulted from the licensee's failure to take
actions or to implement the actions within the required time
frame as specified in the response.
The licensee had not yet
established a formal commitment tracking system to ensure that
commitments were met. The licensee was in the process of
establishing a program for commitment tracking which should be
in place in the near future.
Region IV personnel reviewed the licensee's submittal that
described the QA program in effect in 1985.
The review
concluded that the QA program continued to satisfy the
requirements of Appendix B to 10 CFR Part 50.
The licensee increased the staff size during this assessment
period. The staff was increased from 256 to approximately 320
personnel in the Nuclear Production Division.
The licensee
proposed to increase the staffing level at the plant and in the
engineering offices above the current level to resolve the SSOMI
team identified weaknesses, resolve security problems, and
l
provide additional support in training.
!
'
To provide a more timely response to NRC items of concern and
other issues, the licensee established and staffed a new onsite
!
!
l
L
.
.
.
30
position just prior to the end of this assessment period.
The-
position is an onsite licensing engineer whose primary function
is to interface with NRC inspectors and to provide timely
resolutions of any identified concerns or issues.
The licensee established a program to increase management
involvement in plant activities. This program required that
plant management participate in routine activities performed in
the plant on approximately a weekly basis.
Each week the
management group visited a different area of plant activity and
participated in performance of the activity.
The program was
intended to increase plant management's awareness of problems
arising in daily activities.
During this SALP period, reviews were performed to verify that
the onsite Plant Review Committee (PRC) and the offsite Safety
i
Audit and Review Committee (SARC) performed their activities in
accordance with the TS and licensee requirements. The results
of the inspections indicated that the PRC and SARC are
adequately performing their required activities.
The SARC
performed audits during the assessment period that included more
individuals on the audit team with a technical background in the
area being audited.
Inspections were also performed in the areas related to
activities performed by the QA and QC groups.
These inspections
were performed by NRC Region IV inspectors and on a periodic
basis by the NRC resident inspector.
The results of the
inspections indicated that the licensee was maintaining an
adequate QA and QC staff with the appropriate qualifications.
The licensee has proposed increases in both the QA and QC
staffs.
The QA department has increased the usage of technical
specialists for the performance of audits in the areas of
security, chemistry, EEQ, inservice inspection, and the
radiological effluent program.
2.
Conclusion
The licensee demonstrated implementation of acceptable QA and QA
programs during this assessment period.
The licensee has shown
difficulties in meeting commitments made to the NRC due to a
commitment tracking system not being established.
The licensee continued to exhibit difficulties in the area of
records storage and retrievability.
This has been identified in
past SALP reports and the' licensee has expended resources in
this area; however, the establishment of an appropriately
functioning records system has not been completed.
The licensee has not been timely in resolving or addressing
concerns or issues identified by NRC inspectors.
The problems
%
, ~ .
-
-
, - - - -
. - -
.
.
.e
31
identified by the SSOMI team indicated a need for increased
management attention in the area of design configuration
control.
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
remain at ncrmal levels.
b.
Recommended Licensee Actions
Licensee management should increase efforts to resolve the
problems identified in SALP reports regarding a record
retention and retrieval system.
Licensee management
involvement in the area of commitment tracking should be
increased to provide a tracking system that will ensure the
commitments made are completed accurately and in a timely
manner.
Licensee management should take action to ensure
that more timely response to concerns or issues identified
by the NRC is provided. Additional licensee management
'
attention should be provided in the area of design
configuration control.
J.
Licensing Activities
1.
Analysis
This functional area was monitored on a continuing basis by the
NRR Project Manager during this SALP period.
Licensing
activities included technical reviews associated with
amendments, extensions, exemptions, orders, and miscellaneous
reviews related to plant operations.
A listing of the licensing
activities completed during this assessment period is provided
in Section V.H.
,
i
The licensee continued to show good management overview in the
functional area of Licensing Activities.
The licensee
consistently balanced the desire to maintain or improve plant
productivity with the need to protect the health and safety of
the public.
The majority of the licensing actions completed
-
during this SALP period were resolved by the licensing group.
I
This was accomplished by closely coordinating the technical
efforts of the licensee's staff, consultants, contractors, and
suppliers.
In instance's where matters were referred to upper
management, the individuals involved proved to be well informed
and helpful in resolving questions.
Upper management was
f..
32
!
actively involved in resolving problems and was well informed of
conditions that needed their attention.
Upper management was
also involved in maintaining and improving the quality of work
done at the facility by actively participating in the
development of quality improvement programs that included the
initiation of planning to develop an integrated living schedule.
During this assessment period, errors were found in the codes
used in the core physics analysis.
Licensee management took
aggressive action to ensure an early and satisf actory resolution
of this issue.
Licensee management continued to pursue a
program that was aimed at improving and increasing the technical
capability of the staff, including the approval to purchase and
install a site-specific simulator and initiating a construction
program to improve the security and staff facilities at the
plant.
During this assessment period, a SSOMI team inspection
was conducted.
Licensee management was active in addressing the
issues raised by this inspe. tion.
As indicated above, the licensee continued to maintain a
significant technical capability in engineering and scientific
disciplines necessary to resolve items of concern to the NRC and
the licensee.
During this assessment period, the licensee
expanded the staff at the facility as well as the support staff
located at the main office in Omaha.
Further staff expansion
was planned in the future.
In addition, the licensee continued
to utilize the services of Combustion Engineering and other
nuclear support groups to assist in the resolution of technical
problems or to develop improvements that enhanced the operation
t
and safety of the facility.
The licensee was completing the
review of analytical models to be submitted to the NRC for
approval for use in the 1987 refueling outage at the end of this
assessment period.
The licensee's extensive and improving technical capability was
reflected in the submittals made in support of or in response to
I
i
licensee- or NRC-initiated actions. With few exceptions, the
l
technical content of these submittals was complete and thorough.
l
t
Where additional information was needed, it was of a clarifying
!
nature for the most part and in many cases handled by a phone
call with a followup letter to confirm the verbal conversations.
Few licensee responses to NRC requests for additional
information required subsequent questions.
The licensee applied probabilistic risk assessment techniques in
the analysis of the auxiliary feedwater (AFW) system.
The
analyses were used to support the continued operation of the two
i
AFW pump system at the plant.
Although this issue has not been
I
completely resolved, the results of the analyses performed by
the licensee were presented to the staff in November 1985 and
provided the bases for continued use of the existing system.
I
,
, . .
e
I
33
The licensee responded promptly to NRC staff initiatives.
During this assessment period, the licensee worked with the NRC
in resolving multiplant and TMI action items.
In each case, the
licensee carefully evaluated the action in question and provided
meaningful input to the NRC staff.
Particularly noteworthy is
the support provided by the licensee to the control room
habitability study performed by the NRC. The licensee also
provided the necessary support to bring TMI action items related
to the ERF and the SPOS to a point where final NRC closeout can
be expected in the next assessment period. Where differences
occurred, the. licensee negotiated changes to ensure that the
results adequately reflected safety considerations and
incorporated the staff's positions and licensee's desires.
This
c: curred in the development of the TS changes made to
incorporate the requirements of 10 CFR Part 50.72 and 50.73 and
provided the bases for the resolution of the TS changes that
will incorporate the inadequate core cooling instrumentation
system.
Staffing improvements were made by increasing the number of
qualified personnel and the realignment of responsibilities to
better utilize the individuals that support plant operations.
For example, additional operators were added to the staff during
this assessment period to ease staffing problems that occurred
due to intensified training requirements.
2.
Conclusion
The licensee's activities in this functional area were conducted
by a well staffed and well trained group resulting in an overall
efficient operation.
Management overview was evident in that
the licensing effort, for the most part, was well integrated
into other plant and licensing activities as reflected in a
uniform approach.
Upper management became involved in licensing
actions, when necessary, to assist in resolving potential
deadlocks.
The licensee should be commended for the diligent
way in which licensing actions were resolved and the willingness
to compromise to achieve agreement with NRC staff positions.
The licensee is considered to be in Performance Category 1 in
this functional area.
3.
Board Recommendations
a.
Recommended NRC Actions
Continue the close monitoring of licensee activities in
this functional area and provide the NRC guidance required
to assist the licensee in the resolution of licensing
issues.
m
.
.
34
b.
Recommended Licensee Actions
Continue to improve the quality and size of the staff and
continue to exercise the same level of management attention
that has been apparent in the past.
K.
Training and Qualification Effectiveness
1.
Analysis
This functional area was inspected by Region IV personnel and on
a periodic basis by the NRC resident inspector.
Inspections
included review of nonlicensed training and licensed-operator
training. The review of licensed-operator training was
performed to verify that the licensee implemented the
requirements stated in Appendix A to 10 CFR Part 55 and the
licensee's NRC-approved training program.
No violations, deviations, or LERs were identified in this
functional area.
An inspection was performed in the area of nonlicensed training.
The inspection included reviews in the areas of general employee
training; chemistry and radiation protection training; and
training provided for maintenance, QC, test engineering, and
shift technical advisor personnel. The results of this
inspection indicated that these programs were being implemented
effectively and in accordance with commitments made to the NRC.
During this assessment period, examinations were administered by
the NRC as tabulated below.
Initial Examinations
.
SR0 Candidates
R0 Candidates
Total
Pass Fail
Total
Pass Fail
June 18, 1985
2
2
0
4
4
0
November 12, 1985
1
1
0
0
0
0
Upgrade Examinations
.
SR0 Candidates
Total
Pass Fail
November 12, 1985
3
1
2
____-_____
_ _ _ _
.
.
35
.
Requalification Examinations
.
SR0 Candidates
R0 Candidates
t
Total
Pass Fail
Total
Pass Fail
November 12, 1985
5
0
5
3
2
1
March 18, 1986
5
4
1
2
1
1
Based on the failure rate of the examinations given on
November 12, 1985, a' management meeting was held in
December 1985 to discuss the status of the licensee's
licensed-operator requalification program.
Based on the
management meeting, the licensee committed to institute changes
- to the program.
The licensed personnel that failed the examination were removed
from licensed duties and placed in accelerated requalification
training. At the end of the requalification training, the
personnel were reexamined on March 18, 1986.
Based on the results of the performance by licensed operators on
examinations, the licensed cperator training program was rated
by the NRC as unsatisfactory for fiscal year 1986. The program
will be further evaluated during the week of November 17, 1986.
-
An inspection was performed in the area of licensed-operator
training in August 1986 to evaluate the program status and the
licensee's progress in making improvements in the
requalification program. During this inspection, four
unresolved items were identified that constituted potential
violations. Problems were noted in the areas of review of
emergency procedures, completion of manipulations on plant
controls, lecture attendance, and maintenance of training
records.
The inspection results also indicated that the licensee had
provided accelerated requalification training to the individuals
that failed to pass the NRC-administered examination given on
November 12, 1985. However, the NRC inspectors noted that the
licensee had not completed the actions committed to during the
management meeting in December 1985. The implementation was in
progress but the schedule indicated that corrective actions
would not be completed until the middle part of 1987.
The licensee proposed and secured funds to construct a new
,
training facility with a site-specific simulatcr. The training
l
facility,was scheduled to be completed in 1989 and the simulator
i
to be completed in 1990. During a visit to the plant on
November 5,1986, the NRC Chairman noted that licensee
__
-
_ _ _ _ _ _ _ _ _ _ - _ _ _ _ - _
_ _ _ _ _ _ _ _ _ _ _ _ _
. _ _ _ .
- _ _
-
. __
__
_.
. - - _ _ _ _ _ _
-
9
I
36
h
management should consider taking actions to construct the
training facility and simulator sooner than the currently
proposed schedule.
The licensee began work on obtaining accreditation for training
programs from the Institute of Nuclear Plant Operations (INP0).
The INP0 accreditation was expected to be received by the end of
1986.
'
Just prior to the end of this assessment period, an
organizational change was made within the training organization.
The Supervisor-Station Training was assigned to report to the
Manager-Administrative Services, a corporate-level position.
Prior to this change, the supervisor reported to the plant
manager.
The size of the training staff maintained by the licensee was
small. However, the number of operators at the facility is
small and it appeared that the size of the training staff was
sufficient to meet the facility's training demands.
During this assessment period, the licensee initiated or
completed activities to improve performance in this functional
'
area. A discussion of these activities is provided below.
Developed performance-based training materials.
.
Implementation of the new materials was scheduled to be
completed in the near future.
Expanded the examination question bank to include
.
performance-based questions.
Developed a training program master plan (TPMP) to replace
.
the training manual.
The TPMP will provide more
comprehensive and easier to interpret training
requirements. The TPMP was scheduled for implementation in
1987.
Established a QC personnel training program with the
.
Southeast Commumity College.
This program provided
continued refresher training for QC personnel.
2.
Conclusion
The licensee maintained an effective program in the area of
nonlicensed training. Weaknesses were identified in the area of
licensed-operator training.
The licensee took actions to
improve performance in this functional area.
.
.
37
The effectiveness of the licensee's training programs appeared
to be, in part, due to the low personnel turnover rate.
The
licensee has not demonstrated that the training programs would
be adequate in the event the turnover rate increased.
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
maintained at the normal level with emphasis placed on
licensed operator training.
b.
Recommended Licensee Actions
Licensee manigement should continue implementaton of the
actions initiated during this assessment period to improve
the licensed and nonlicensed training programs.
Licensee
management attention to resolve the weaknesses identified
in the licensed-operator training program should be
increased.
V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
1.
Major Outages
The license + shut down the plant on September 28, 1985, for the
Cycle 10 re!aeling outage at the Fort Calhoun Nuclear Station.
Major activ w..:s accomplished during the refueling outage
included eddy current testing of both steam generators, plegging
of steart. generator tubes, installation of seismic supports for
masonry walls, replacement of HFA relays, replacement of
instrument invarters, and replacement of containment penetration
assemblies.
Tne reactor was taken critical on January 9,1986,
to end the refueling outage.
2.
Power Limitations
Power was limited during this assessment period during various
plant startups for steam generator chemistry considerations.
When the plant was started up, hold points for power level were
observed to allos steam generator chemistry to be adjusted
within specific guidelines.
After the chemistry was within the
guidelines, power escalation was continued.
o
.
38
3.
License Amendments
Amendment 86
April 3, 1985
Incorporate Requirements
of Appendix I
Amendment 87
April 29, 1985
Toxic Gas Monitoring
Amendment 88
May 9, 1985
Bypassing / Tripping
Amendment 89
May 24, 1985
Postaccident Sampling
Amendment 90
August 19, 1985
Testing Frequency for
AFW Pumps
Amendment 91
August 22, 1985
Surveillance Requirements
Amendment 92
November 29, 1985
Cycle 10 Power Operation
Amendment 93
December 6, 1985
Administrative Changes
Amendment 94
January 10, 1986
Capsule Removal Schedule
Amendment 95
February 3, 1986
Leakrate Testing
Surveillance
Amendment 96
April 24, 1986
Updated Snubber Tables
Amendment 97
June 3, 1986
Recirculation Heat
Removal
Amendment 98
July 1, 1986
Fire Suppression
Equipment
Amendment 99
August 13, 1986
50.73 Requirements
Amendment 100 September 8, 1986
Heatup and Cooldown
Curves
4.
Significant Modifications
Modifications completed during this assessment period included
installation of seismic supports for masonry walls, installation
of a fire support system in the AFW pump area, replacement of
instrument inverters and transformers, and installation of
delta T power process loops.
.
.
p.
39
B.
Inspection Activities
1.
Violations
See Table 1 for a tabulation of the identified violations and
deviations in each functional area for this assessment period.
2.
Major Inspections
Special inspections were' performed in various areas of licensee
activities.
The listing below provides details of the
inspections.
An EEQ special inspection was performed by NRC Headquarters
.
and Region IV personnel in April and May 1985 to verify
licensee compliance with 10 CFR Part 50.49.
The details of
the inspection are provided in NRC Inspection
Report 50-285/85-09.
A special inspection in the area of outage modification
.
activities was performed in September, October, November,
and December 1985 by the S50MI team.
The SSOMI team
consisted of members from NRC Headquarters, Region IV, and
consultants. This inspection was performed as part of a
trial NRC program being implemented to examine the adequacy
of licensee management and control of modifications
performed during major plant outages.
The details of the
inspection results are provided in NRC Inspection
Reports 50-285/85-22 and 50-285/85-29.
The violations and
associated severity levels from these two reports will be
issued in the near future.
In April and May 1986 an RER was performed by personnel
.
from NRC Headquarters, Region IV, and members of the U.S.
Army Special Forces.
The RER was performed to review the
impact of security on safe plant operations and to evaluate
the overall effectiveness of the security program to
protect against the design basis threat for theft and
radiological sabotage as defined in 10 CFR Part 73. The
results of the RER were issued in a special report dated
November 4, 1986.
A special inspection was performed in July 1986 by NRC
.
Region IV personnel and contractors.
The inspection was
performed to verify the adequacy of the licensee's ERF as
required by NUREG-0737, Supplement 1.
The details of this
inspection are provided in NRC Inspection
Report 50-285/86-20.
i
.
.
40
i
C.
Investigations and Allegations Review
During this assessment period, an allegation was made by a licensee
employee that licensee management had failed to take remedial action
in response to incidents of fighting, sleeping on the job, harassment
of personnel, and intimidation of fellow employees that occurred
during the period 1979 through 1984.
The NRC reviewed the allegation
and determined that the incidents described by the licensee employee
were not a safety concern and that the incidents did not affect the
health and safety of the public.
No investigations were completed during this SALP period.
D.
Escalated Enforcement Actions
Three notices of violation with proposed imposition of civil
penalties were issued to the licensee during this assessment period.
A discussion of each is provided below.
A Severity Level III violation without a proposed civil penalty
.
was issued in NRC Inspection Report 50-285/85-09. The violation
was issued as a result of the licensee's failure to properly.
qualify Conax electrical penetration assemblies in accordance
with the equipment qualification rule stated in 10 CFR Part 50.49(k).
A civil penalty was not proposed for this
violation as the violation was identified prior to the
November 30, 1985, deadline for environmental qualification of
electrical equipment, and an extension for this item could have
been granted by the NRC.
In NRC Inspection Report 50-285/86-01, two Severity Level III
.
violations were issued without a proposed civil penalty.
The
violations included the failure to identify a main steam valve
as radioactive and to perform radiological surveys prior to
shipping the valve offsite, and the failure to control a very
Due to the licensee's demonstrated past
good performance in the functional area of Radiological
Controls, a civil penalty was not proposed for these two
violations.
E.
Licensee Conferences Held During This Assessment Period
The following conferences were held between the licensee and the NRC
during this assessment period.
A management meeting was held on December 12 and 13, 1985, to
.
discuss the NRC concerns related to the qualification of
NRC-licensed operators.
In an examination given on November 12,
1985, six of eight operators failed to pass the NRC examination.
This high failure rate and the proposed requalification of the
six individuals were the bases for the management meeting.
l'
. - .
41
A management meeting was held December 13, 1985, at the
.
Region IV office to discuss concerns related to the EEQ
inspection.
The bases for the meeting were the results noted
during performance of an NRC inspection in the area of EEQ as
detailed in NRC Inspection Report 50-285/85-09.
An enforcement conference was held on April 11, 1986, to discuss
.
concerns related to health physics activities.
The bases for
the conference were the findings stated in NRC Inspection
Report 50-285/86-01. The NRC noted in the report that the
licensee failed to perform a radiological survey on a
contaminated valve prior to shipment to an offsite calibration
facility and failed to properly control a very high radiation
area.
On July 10, 1986, an enforcement conference was held to discuss
.
the findings of a special inspection performed by the S50MI
team.
The results of the team inspection are detailed in NRC
Inspection Reports 50-285/85-22 and 50-285/85-29.
The NRC is
currently reviewing the results of the team inspections for
potential enforcement actions.
The results of this review will
be issued in the near future.
An enforcement conference was held on August 22, 1986, in the
.
Region IV office to discuss the licensee's failure to adequately
maintain a vital area barrier.
The details of this violation
are provided in NRC Inspection Report 50-285/86-17.
F.
Confirmatory Action Letters
During this assessment period, one confirmatory action letter (CAL)
was issued by the NRC.
This letter, dated December 20, 1985, related
to confirmation of commitments made by the licensee in a management
meeting held in Region IV on December 13, 1985.
The CAL discussed
actions planned to be taken by the licensee as a result of an NRC
followup inspection in the area of EEQ.
G.
Review of Licensee Event Reports and 10 CFR Part 21 Reports Submitted
by the Licensee
1.
Licensee Event Reports
There were 16 LERs issued during this assessment period
including LERs85-001 through 85-012 and 86-001 through 86-004.
Trends were noted in the following areas.
.
The licensee reported seven instances of inadvertent
.
initiation of the VIAS due to various reasons (e.g.
equipment problems, personnel error, and plant systems
leakage).
The VIAS initiations occurred up to the latter
part of 1985.
Since that time, the licensee has not
_ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ .
. _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.:* a
42
experienced an actuation due to licensee management
involvement in preventing an inadvertent operation of the
system.
The LERs listed below were issued by the licensee during this
assessment period.
The SALP Board reviewed these LERs and
determined that the root cause did not warrant placement within
a specific functional area.
Automatic reactor trip caused by failure of an instrument
.
inverter.
(LER 86-001)
Manual reactor trip due to overheating of a bus duct on the
.
station electrical generator.
(LER 86-004)
Initiation of a VIAS caused by leaking radioactive
.
effluents from a piping system.
(LER 85-002)
Initiation of a VIAS due to torn filter paper in a
.
'
radiation monitor.
(LER 85-008)
Main steam safety valves failed to lift within setpoint
.
values during surveillance testing.
(LER 85-006)
A lockout relay failed to properly function during
.
surveillance testing.
(LER 85-010)
The NRC's Office of the Analysis and Evaluation of Operational
Data performed an evaluation of the content and quality of a
representative sample of LERs submitted by the licensee.
The
results of the evaluation were provided to the licensee under a
separate cover letter.
2.
10 CFR Part 21 Reports
In a letter dated March 17, 1986, the licensee issued a 10 CFR Part 21 report to the NRC regarding failure of Valcor valves.
The report stated that the valve disc guide assembly springs had
failed causing the valve to be inoperable.
The spring failure
was attributed to hydrogen embrittlement.
The licensee replaced
the springs in the valves with the same spring material and
tested the valves for satisfactory operation.
The licensee
intends to replace the springs during the 1987 refueling outage
with a material not susceptible to hydrogen embrittlement.
.~~a
43
H.
Licensing Activities
1.
Licensing Activities Completed
Issue
Completion Date
Special steam generator tube
March 8, 1985
inspection
Reevaluation of the AFW Technical
April 24, 1985
Specifications
Emergency core cooliag system error
June 13, 1985
and core height
Reactor vessel-to-nozzle welds
June 19, 1985
Control of heavy loads, Phase II
June 28, 1985
Loss-of-coolant accident analysis
July 1, 1985
Compliance with 10 CFR Part 50.46
July 1, 1985
Core reload methodology changes for
August 26, 1985
Cycle 10
Alternate shutdown capability, upper
November 4, 1985
electrical penetration room
Steam generator tube integrity
December 11, 1985
December 27, 1935
Validation of mini-CECOR/ BASS system
March 10, 1985
Inservice inspection relief for
June 24, 1986
recirculation piping
Clarification of fire protection
July 1, 1986
modifications
Generic Letter (GL) 83-28, Salem
July 3, 1986
anticipated transient without
GL 83-28, Salem ATWS, Item 4.5.1
July 10, 1986
2.
Extensions, Exemptions, and Orders
EEQ deadline additional extension
March 29, 1985
i
.
- a
f
44
Appendix R to 10 CFR Part 50, fire
July 3, 1985
protection
' Modification of Commission Order, dated
January 9,'1986
February 22, 1984
Appendix J to 10 CFR Part 50,
January 10, 1986
containment leakage
3.
Meetings
Reliability of the AFW system
November 8, 1985
. se o
TABLE 1
ENFORCEMENT ACTIVITY
FUNCTIONAL AREAS
NUMBER OF VIOLATIONS IN EACH LEVEL
I
II
III
IV
V
OEVIATIONS
A.
Plant Operations
0
0
0
0
0
0
B.
Radiological Controls
0
0
2
6
5
o
C.
Maintenance
0
0
0
2
0
2
D.
Surveillance
0
0
0
1
0
0
E.
Fire Protection
0
0
0
1
1
0
F.
0
0
0
3
0
1
G.
Security and Safeguards *
0
0
0
13
2
0
H.
Outages **
0
0
0
0
0
0
I.
Quality Programs and
0
0
1
S
3
1
Administrative Controls
Affecting Quality **
J.
Licensing Activities
0
0
0
0
0
0
K.
Training and Qualification
0
0
0
0
0
0
Effectiveness
TOTAL
0
0
3
35
11
4
- One additional violation was identified in this functional area but the
severity level of the violation has not been determined.
- Additional violations were identified in this functional area based on the
results of the SS0MI team inspection.
The number and severity level of the
violations have not been determined.
This determination will be made in the
near future.