ML20236C076
| ML20236C076 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 12/31/1988 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20236C043 | List: |
| References | |
| 50-341-89-01, 50-341-89-1, NUDOCS 8903210479 | |
| Download: ML20236C076 (35) | |
See also: IR 05000341/1989001
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SALP. BOARD REPORT
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U.S.' NUCLEAR REGULATORY COMMISSION
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REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
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50-341/89001
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Inspection Report No.
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Detroit Edison Company-
Name of Licensee
Fermi 2
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Name of Facility.
April 1, 1988, through December 31, 1988
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Assessment Period
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TABLE OF CONTENTS
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Page No.
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INTRODUCTION:
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II.' SUMMARY OF RESULTS,
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Overview
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Other Areas of Interest-
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MIII. CRITERIA.
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PERFORMANCE' ANALYSIS
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Plant Operations.
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Radiological: Controls
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. Maintenance ~
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Surveillance
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Emergency: Preparedness
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Security- .
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Engineering / Technical Support
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Safety Assessment / Quality Verification-
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Startup) Testing
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V.
SUPPORTING DATA AND SUMMARIES
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A.
Licensee Activities
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.B.
Inspection Activities .
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C.
. Escalated Enforcement Actions-
D.
Confirmatory Action Letters (CALs)
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E.
License Amendments Issued
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F.
Redew of Licensee Event Reports Submitted
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by the Licensee
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INTRODUCTION
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The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data
on a periodic basis and to evaluate licensee performance on the basis
of this information.
The program is supplemental to normal regulatory
processes used to ensure compliance with NRC rules and regulations.
is intended to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful feedback to the licensee's
management regarding the NRC's assessment of their facility's performance
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in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
February 15, 1989, to review the observations and data on performance, and
to assess licensee performance in accordance with the guidance in NRC
Manual Chapter 0516, " Systematic Assessment of Licensee Performance." The
guidance and evaluation criteria are summarized in Section III of this
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report. The Board's findings and recommendations were forwarded to the
NRC Regional Administrator for approval and issuance.
This report is the NRC's assessment of the licensee's safety performance
at Fermi 2 for the period April 1,1988, through December 31, 1988.
SALP Board for Fermi 2 was composed of:
Name
Title
A. B. Davis
Regional Administrator
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- E. G. Greenman
SALP Board Chairman, Director, Division of
Reactor Projects (DRP)
- T. R. Quay
Acting Director, Project Directorate III-1,
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Office of Nuclear Reactor Regulation (NRR)
- H.
J. Miller
Director, Division of Reactor Safety (DRS)
R. L. Spessard
Director, Division of Operational Assessment,
Office for Analysis and Evaluation of
Operational Data (AE00)
W. D. Shafer
Acting Deputy Director, DRS
- R. C. Knop
Chief, Reactor Projects Branch 3, DRP
- L. R. Greger
Chief, Reactor Programs, Division of
Radiation Safety and Safeguards (DRSS)
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R. W. Cooper
Chief, Reactor Projects Section 3B, DRP
M. P. Phillips
Chief, Operational Programs Section, DRS
M. C. Schumacher
Chief, Radiological Protection Section, DRSS
J. E. Foster
Emergency Preparedness, DRSS
- J. F. Stang
Project Manager, NRR
- W. G. Rogers
Fermi Senior Resident Inspector
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D. Funk ~
Security Specialist,,DRSS
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.A.- Dunlop
' Reactor Engineer,1DRP-
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P. R. Pelke'
Project 1 Inspector,JDRP
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E.:M.^McKenna
'SALP Coordinator, NRR:
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H. A.- Wal ker
Reactor' Inspector, DRS
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S. J. Collins
Deputy Director, DRP,LRegion I
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- J. House
Radiation Specialist,'DRSS-
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J. A. Gavula
Reactor Inspector, DRS-
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L.; Kelly
Project Manager, NRR
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- Denotes voting members.
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- Denotes voting: member except Radiological' Controls,' Emergency
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Preparedness, Security, and:Startup Testing areas
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- Denotes voting member of Radiological' Controls' Emergency Preparedness,
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and Security areas.
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II.
SUMMARY OF RESULTS'
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Overview
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Licensee performance improved in the areas of Plant Operations and
Surveillance from a Category 3 to a Category 2.
Category 3 performance
was evident in Maintenance and Engineering / Technical Support.
Safety
Assessment / Quality Verification, a new functional area, was rated
Category 2.
Repeat Category 1 ratings in Emergency Preparedness,
Security, and Startup Testing indicate a continued strong effort in
these functional areas.
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In the area of Plant Operations, enforcement history slightly improved
as the licensee completed the startup test program and began routine
operations. The frequency of events decreased and more effective
management involvement was evident at the end of the assessment
period.
Substantial progress has been made in the Surveillance
area, including an improved enforcement history and successful
implementation of the Technical Specification Improvement Program.
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Notwithstanding, the enforcement history for Engineering / Technical
Support and Maintenance was poor. Weak work interfaces and
communication problems contributed to fragmented engineering support
for the plant.
Many licensee actions have been initiated in the
Maintenance area and some improvement has been noted as a result.
High-level management attention is warranted in this area, in
particular, in the preparation for your first refueling outage and
in the implementation of the preventive maintenance enhancement
program.
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The licensee has continued to improve staffing as evidenced by
hiring experienced personnel for the key positions of Operations
Superintendent, Maintenance and Modification Superintendent, General
Director Nuclear Engineering, Technical Engineering Superintendent,
and Plant Systems Engineer.
The performance ratings during the previous assessment period and this
assessment period according to functional areas are given below:
Rating Last
Rating This
Functional Area
Period
Period
Trend
Plant Operations
3
2
Radiological Controls
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2
Maintenance
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3
Surveillance
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Security
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Engineering / Technical Support
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Safety Assessment / Quality
Verification
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Startup Testing
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Fire Protection
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Outages
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Quality Programs and
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Administrative Controls
Affecting Quality
Licensing Activities
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Training and Qualification
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Effectiveness
NR = Not Rated
- No longer SALP functional areas
B.
Other Areas of Interest
None.
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III. CRITERIA
Licensee performance is assessed in 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.
Special
areas may be added to highlight significant observations.
The following evaluation criteria were used to assess each functional
area:
1.
Assurance of quality, including management involvement and control;
2.
Approach to the resolution of technical issues from a safety
standpoint;
3.
Responsiveness to NRC initiatives;
4.
Enforcement history;
5.
Operational events (including response to, analyses of, reporting
of, and corrective actions for);
6.
Staffing (including management); and
7.
Effectiveness of training and qualification program.
However, the NRC is not limited to these criteria and others may have
been used where appropriate.
On the basis of the NRC assessment, each functional area evaluated is
rated according to three performance categories. The definitions of
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these performance categories are as follows:
Category 1:
Licensee management attention and involvement are readily
evident and place emphasis on superior performance of nuclear safety or
safeguards activities, with the resulting performance substantially
exceeding regulatory requirements.
Licensee resources are ample and
effectively used so that a high level of plant and personnel performance
is being achieved.
Reduced NRC attention may be appropriate.
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Category 2:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are good. The
licensee has attained a level of performance above that needed to meet
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regulatory requirements.
Licensee resources are adequate and reasonably
allocated so that good plant and personnel performance is being
achieved.
NRC attention may be maintained at normal levels.
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Category 3:
Licensee management attention to and involvement in the
performance of nuclear safety or safeguards activities are not
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sufficient.' The licensee's performanceLdoes not significantly exceed
that needed.to meet' minimal regulatory requirements.
Licensee resources-
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appear to be strained orinot effectively used.
NRC attention should be.
increased above normal levels.
The SALP. report may include an appraisal of the performance! trend in a.
functional: area for use as a predictive indicator -if .near-term ' performance
is of interest'.
Licensee performance during the last quarter of the
assessment period should be examined to determine whether a trend exists.
Normally, this performance trend should only be used if both a definite
trend ~is discernable and continuation of the trend may result in a change
in performance rating,
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The trend, if used, is defined as:
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Improving:
Licensee performance was determined to be improving near the
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close of the assessment period.
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Declining:
Licensee performance was determined to be declining near the
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close of the assessment period, and the licensee had not taken. meaningful
steps to' address this pattern.
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IV. PERFORMANCE ANALYSIS
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Plant Operations
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Analysis
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This functional area was evaluated on the basisLof six. routine
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and three special inspections conducted by~ regional and residen.t
' inspectors, as well as a diagnostic evaluation team (DET)' report.
prepared by the Office for Analysis and Evaluation'of Operational
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' Data (AE0D), and an' emergency operating procedure (E0P) team
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inspection conducted by NRR.
The enforcement history improved slightly from the previous-
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assessment period.
Six violations were issued during this
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assessment period and were categorized as one Severity Level III
violation, including an Order and $100,000 civil penalty, and
five Severity Level IV violations. Nine violations were issued
in the previous assessment period. Two of the violations,-
including the Severity Level III, occurred during the previous
assessment period.
The Severity Level III violation involved
a limiting condition for operation (LCO) that was not met.
Three of the four violations that occurred during this
assessment period were programmatic in nature and had some
safety significance.
These violations dealt with deficiencies
in the scope of valves in the locked valve program, weaknesses
in control room administrative controls, and lack of instructions
for placing instruments in the tripped condition.
The fourth
violation, the most safety significant in the operations area,
dealt with a failure to deenergize primary containment lighting
before starting up from a planned outage late in the assessment
period.
This was an administrative program breakdown due to
inadequate communications and inattention to detail. Corrective
actions for these four violations were appropriate and timely.
Moreover, the violations identified during this assessment
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period were much less safety significant than those identified
in the previous period.
The four outstanding issues from the previous assessment period
resulted in the issuance of violations.
No major issues were
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outstanding at the end of this assessment period.
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During this assessment period, the startup and test program was
completed and routine operation at 100% power commenced. The
reactor was critical for 4107 hours0.0475 days <br />1.141 hours <br />0.00679 weeks <br />0.00156 months <br /> of the assessment period,
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and the scram frequency per 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br /> critical decreased from
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1.29 to 0.97.
Seven unplanned shutdowns occurred, of these,
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four were unplanned scrams.
None were caused by operator error.
Also, none occurred in the last third of the assessment period.
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There were 29. licensee event reports (LERs) issued dut che
assessment period, of which 7 were attributed to activ.a es in
the operations area. The number of LERs attributed to personnel
error associated with the operations area significantly decreased
to three.
Nineteen engineered safety feature (ESF) actuations
occurred during the period which represents a decrease from 2,9
to 2.1 per month.
Staffing in the area of plant operations was good.
Six full
shift complements continued during the assessment period, and
all key positions were filled. Additionally, at the end of the
assessment period a new operations superintendent, who has
commercial experience with boiling water reactors (BWRs), was
hired.
Teamwork in performing control room activities was evident;
however, shift crews exhibited varying levels of expertise
identified during the assessment period. Additionally,
individual operators exhibited knowledge weaknesses of a random
nature. Operator qualification on systems within the drywell
did not require an understanding of major flowpath component
locations. Weaknesses in the operator training program appeared
to be a direct contributing factor in these areas.
On the positive side, the training department staff, in preparing
for the first NRC requalification examinations to be administered
in the fall 1989, took the initiative to give requalification
examinations to all licensed operators using the format of
NUREG-1021, " Operating Licensing Examiner Standards." Of the
one senior reactor operator (SRO) and eight reactor operator
(RO) replacement examinations administered by the NRC during the
assessment period, all candidates passed.
This was an improvement
from the 67% pass rate in the previous assessment period.
No
requalification examinations were conducted during the assessment
period.
However, operations training department staffing was strained to
properly provide both the normal training needs of the operations
department as well as supporting numerous special projects.
Development / implementation of new E0Ps, additional Technical
Specification (TS) training, and upgrade of course materials
were manpower-intensive areas and contributed to the excessive
workload.
Concerns with the training department included
ineffective utilization of the simulator to properly assess
differences in crew performance, especially during E0P
implementation.
Also, some lesson plans were superficial and
auditing of instructor performance was deficient.
Throughout the assessment period management kept aware of plant
status and operator performance through operator evolution
evaluations, daily status meetings in the control room area, and
general observation of control room activities.
On-shift
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personnel generally understood their duties and responsibilities.
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. Shift turnovers were consistently thorough.
Required. reports to
the'NRC via the emergency notification' system were made in a
timely manner. . Satisfactory logkeeping practices were generally
observed. All off-norma 1' events and equipment-failures were
properly handled in a controlled manner.' Reactivity manipulations
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were properly accomplished. The plant staff responded quickly
to all fire alarms with an appropriate complement of personnel.
Housekeeping was excellent. Control room decorum remained high;
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personnel conducted themselves in'a professional' manner and-
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projected a positive safety attitude. On-shift management
attention was strong in monitoring control room activities but
was' limited in observing and evaluating field activities.
Notwithstanding these accomplishments, management involvement to
assure quality _was occasionally ineffective during the first
half of _ the assessment period.
Control room administrative
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controls were weak and not properly implemented, as evidenced by
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the repeated. lack of use of the safety system status board. The
reactor was unexpectedly borated because of operator error and
inadequate maintenance scheduling.
Interdepartmental diagnostic
activities to determine the source of unidentified reactor
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coolant system leakage in July were poor.
The shift operating
advisor (SOA) never became integrated into-shift activities as
had originally been conceived and the program was terminated
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with NRC concurrence during the assessment period.
During the last half of the assessment period more effective
management involvement was evident. Administrative controls
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were adhered to, no equipment damage occurred through improper
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operator action, and numerous off-normal events and equipment
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failures continued to be handled in a controlled manner.
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Finally, new E0Ps were implemented, however, the procedures were
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in need of a general editing review, some calculations were
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difficul'. to perform and place keeping could be a problem due to
the lack. of flow charts.
Overall, the revised procedures
significantly improved the licensee's ability to
mitigate / terminate an emergency. Although the revised E0Ps
were a significant improvement affecting plant safety, observations
of several shift crews implementing the E0Ps on the simulator
indicated that additional training was warranted for the weaker
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shift crews.
E0P quality, legibility, and readability were very
good, and the licensee developed an excellent system to control
jumpers and safety system defeats associated with E0Ps.
In previous assessment periods, three central areas had been
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targeted as needing additional management attention.
These
areas were (1) placing equipment in and out of service,
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(2) taking the appropriate actions mandated by the license for
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given equipment conditions, and (3) understanding the necessary
TS support systems.
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In thef first area, significant improvement was noted. With the'
. exception of a boration of the reactor.early in- the assessment
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period, no equipment degradation / damage occurred when operators
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placedzequipment into or outiof service. With regard to the
second area, some improvement was noted.but continued emphasis
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is'needed. There were three instances of operators not taking -
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the appropriate actions mandated by the license for a given
equipment condition.
The root causes of these three. instances
were on-shift management inattention to detail, implementation
of a previous nonconservative operations management. interpretation.
of the containment lighting TS, and.a lack of operations
management guidance on tripping failed instruments.
In the
third area, minimal efforts have been expended.
Examples this
period included personnel failing to understand flood mitigation
controls and 48/24-vdc batteries as they relate to TS equipment.
Technical resolution of issues in' the operations area was slow
early in the assessment period. Management was aware of control
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room administrative control weaknesses and the need- for an
instrument trip. procedure but had not aggressively pursued
resolution. Once NRC became involved, corrective actions were
timely and comprehensive as evidenced by the establishment
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of new control room administrative controls.
In the last part
of the assessment period, more timely resolution of technical
issues was evident.
Examples included corrective actions to a
containment lighting violation and corrective actions to a core
spray minimum flow valve lineup problem. Also, the licensee is
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aggressively pursuing flowcharting and rectifying other-EOP
weaknesses.
. Management was generally responsive to NRC initiatives during
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the assessment period, as discussed in the previous paragraph.
The NRC resident staff and the plant manager held weekly meetings.
Management response to inspector' concerns was, overall, adequate.
Concerns with control room lighting, process computer usage, and
system status awareness were well received and were resolved in
an expeditious manner.
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2.
Performance Rating
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The licensee's performance is rated Category 2 in this area.
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The licensee's performance was rated Category 3 in the previous
assessment period.
3.
Recommendations
None.
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B.
Radiolo'gical Controls
1.
Analysis
This functional area was evaluated on the basis of one routine
inspection performed by regional inspectors and on observations
by the resident inspectors and DET members.
The enforcement history was good with nozviolations issued
during the assessment period; one was issued during the
previous assessment period.
Staffing, training, and qualifications . remained good.
The experience level of the staff remains high and staff
turnover was low. Two radwaste supervisors who left the
company were replaced by qualified individuals from within the
health physics department and radiation protection manager (RPM)
responsibility was transferred to a qualified individual within
the department. Overall, technical qualifications of the staff
did not appear to be significantly diminished by these changes.
Management involvement in ensuring quality was generally good
as was shown by management support for imposition of strong
health physics controls during cleanup following two
significant contamination events involving liquid spills in
the reactor building. Additionally, the DET observed good
coordination between testing and health physics personnel
during pump surveillance testing.
The licensee was responsive to NRC observations regarding
the first event and weaknesses related to air sampling and
respirator use were not repeated during the second. The
licensee was also responsive to NRC concerns regarding
qualification in its appointment of a new RPM.
The licensee's resolution of technical issues was generally
satisfactory although weaknesses were observed related to the
handling of the first reactor building liquid spill and in the
failure to anticipate the effect of water level changes on
radiation level during maintenance on a sump drain.
The total worker dose for 1988 was about 100 person-rem
which is average for a BWR in early operation.
Personnel
contamination events averaged about three per week which is
normal. Airborne and liquid radioactive releases remained low.
One unplanned, but insignificant release occurred during the
first reactor building liquid spill. There were no
transportation incidents.
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'2.
Performance Rating'
The licensee's' performance is rated Category 2 in this area.
The licensee's performance was rated Category 2 in the previous
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assessment period.
3.
Recommendations
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None.
C.
Maintenance
1.
Analysis
This functional area was evaluated on the basis of six routine
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. resident inspections, five regional inspections, and observations
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by DET members. Activities examined included the corrective and
preventive maintenance programs, and implementation of those
programs.
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The enforcement history declined with four violations issued.
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during'the assessment period compared with four violations
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(three Severity Level IVs and one Severity Level V) and a -
deviation in the previous assessment period.
In this period,
three violations were categorized as Severity Level IV violations -
and the other, a Severity Level III violation with an associated *
$50,000 civil penalty. Two' examples of the Severity Level III
violation, the most safety significant maintenance findings of'
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the assessment period, dealt with inadequate motor-operated
valve (MOV) maintenance procedures and the lack of appropriate
qualification of contractor personnel performing M0V maintenance.
Corrective actions in these areas were prompt and adequate. Two
other examples of the Severity Level III violation are discussed
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in the Engineering / Technical Support and Safety Assessment /
Quality Verification sections.- All of the Severity Level IV
violations had potential safety implications.
Two of the-
violations occurred early in the assessment period.
The first
reflected implementation breakdowns in component return-to-
service verifications. The second reflected a-lack of control
in the 2 year maintenance instruction adequacy review program.
Corrective action for the two violations was prompt and comprehensive.
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The last violation occurred late in the assessment period and
reflected programmatic and implementation deficiencies. Three
examples were associated with this violation, with two examples
involving inadequate procedures and one involving a failure to
follow procedures.
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Three outages in excess of two weeks occurred during the assessment
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period, two of which were unplanned and were contributed to by-
inadequate maintenance activities.
Two of the four unplanned
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scrams at po' er during the' assessment period were caused by
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balance-of plant equipment. failures and six LERs were caused
exclusively by equipment f3: lures.
One scram occurred when the
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main steam bypass valves closed due to a: faulty relay, and the
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other occurred on.a'tbrbine trip due to high vibration. The
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other equipment failures included a failed relay causing the
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residual heat removal (RHR) shutdown cooling outboard i_solationL
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valve to close control center heating, ventilating, and air.
'
, ,
conditioning s'nifting to recirculation.due to a loss of control
. power, Group 2 control rods receiving a scram signal due to
4
contactor termination failure, and isolation of the reactor:
water cleanup (RWCU) . system due to relay ~ failure.
Management. involvement in assuring quality improved from the'.
- '
previous assessment' period. Management appeared to be actively
involved.in the planning and control of'both corrective and
<
preventive maintenance.
This resulted in considerable improvement
in implementing the defined preventive maintenance (PM) program.
1
'
Decision-making for deferral or reschedulirig of PM activities
now appears to have a technical basis for Priority '!A"
.
i
l
(safety-related and a' limited set of equipment termed important-
to-safety by the licensee) equipment.
There were no overdue
1
PriorityL"A" PMs at the end of the assessment period. The
i
corrective maintenance backlog continued to decrease from
.i
approximately 1000 to 750 items.
Improvements were noted in
!
outage management from.the local leak rate test (LLRT) outage at
the beginning of the assessment period to the MOV outage midway
through the assessment period as' reflected in the decrease of
unplanned ESF actuations during the latter outage.
However, even with this management involvement, parts-
[
availability and planning / scheduling were occasionally deficient.
'
The material condition of the plant did not appreciably improve.
1
Annunciator deficiencies.were reduced early in the assessment
period-but stabilized midway through the period at approximately .
30.
No discernible decrease in the number of lifted leads and-
jumpers occurred during the assessment period. This particular
area has been identified in the past two assessment periods as
needing managament attention.
The licensee's defined PM program
t
L
was not optimized. in achieving its overall function of a high
!
degree of availability and reliability for the safety systems.
I
3
On the average, one safety division was out of service for 12
l
hours each day for PM.
By management decision, PMs other than
l
Priority "A" required justification to perform and as a result
j
only a-small fraction (about 5*4) of Priority "B" PMs were
!
,
?
!
perfo6ted.
Poor maintenance of balance-of plant control room
instrumentation resulted in a decrease in the operators'. ability
'
to operate the plant. Tne equipment failure trend / analysis
efforts have not yet become an effective tool.
Finally, the
!
'
problems associated with inadequate maintenance procedures and
the failure to follow procedures greatly improved but problems
still remained as reflected in the enforcement history.
1
13
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The. licensee's approach to resolution of technical issues showed
1
considerable. improvement during this assessment period.
I
Corrective. actions to material availability issues have produced'
some improvements.
However, a key program.to identify obsolete
components / equipment for replacement has yet to be established.
,
Significant initiatives were undertaken-to improve maintenance
'
of MOVs. Technical justifications' for deferring or rescheduling
of PM activities for Priority "A" components appeared to'be.
'
adequate.. . The licensee is'beginning to address the safety
system availability problem by having a contractor review the
'
PM program. .The total maintenance procedure rewrite effort
completed.at the end of the assessment period should help
address maintenance procedure ~ deficiencies.
The licensee's responsiveness to NRC initiatives appeared to be
acceptable although it was sometimes slow and was limited to
-safety-related areas.
For example, many actions had been taken
in the PM area.that resulted in what now appears to be an
adequate PM program definition.
Satisfactory definition of the
PM program required action in three assessment periods and
implementation was limited to areas that were safety-related
or important-to-safety as defined by the licensee.
Although the
responsiveness to NRC initiatives was acceptable, the licensee
should have identified and corrected some of the issues without
l
NRC involvement,
f
During the assessment period, a positive initiative was the
. hiring of a maintenance superintendent who has commercial-BWR
experience and an additional individual in the administration
of the PM program. Material control responsibilities were
realigned by consolidating material engineering, procurement,
and the warehouses under one manager. The craft complement
'
generally appeared adequate.
However, the maintenance staff
appeared strained as a result of the limited technical staff
capability and the procedure rewrite effort. Actions were'in
progress to address this situation by the end of the assessment
period. With the new hires and the procedure rewrite effort
recently completed, a final assessment of the resulting
improvements in this area can not yet be made.
Personnel were adequately trained with a notably strong
instrument and control (I&C) program. The exception to this
condition was in the area of root-cause/ failure analysis where
training was minimal.
Personnel were qualified for their jobs
except for some contractor craft personnel utilized in the LLRT
outage early in the assessment period.
2.
Performance Rating
The licensee's performance is rated Category 3 in this area.
!
The licensee's performance was rated Category 3 in the previous
assessment period.
j
14
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3.
Recommendations
l
'
The board notes that a Region III Maintenance Team Inspection
will be conducted in the next assessment period.
Licensee
management attention is required to ensure adequate implementation
of improvements in the maintenance area including the PM
enhancement program, jumpers and lifted leads, parts availability,
i
planning / scheduling and plant material condition.
D.
Surveillance
1.
Analysis
This functional area was evaluated on the basis of nine routine
l
and special inspections conducted'by resident and regional
inspectors and observations by DET members. Areas reviewed
included nonradiological chemistry controls, surveillance
activities implemented by maintenance and operations personnel,
the inservice test (IST) program., and to a lesser extent, the
Performance Evaluation Program.
The enforcement history consisted of eight violations with only
N
three of these violations occurring during the assessment
period.
This compares with eleven violations and a portion of
another in the previous assessment period. All eight were
categorized as Severity Level IV violations.
Two of the three
violations that occurred during the assessment period were
implementation breakdowns by operations shift personnel and had
safety implications; of these, one occurred early and the other
occurred late in the assessment period.
The third violation
'
that occurred during this assessment period reflected a lack of
control of instrumentation specification sheets and had potential
safety implications.
Interim corrective actions were initiated
for the specification deficiencies with final resolution not to
i
be accomplished until the end of the next assessment period. As
f
such, the effectiveness of these actions has not been completely
evaluated.
Management's involvement to assure quality significantly improved
and was generally evident in the IST program and in the
i
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surveillance program required by TS. Administrative controls
'
!
were well-established with only minor deficiencies noted.
Scheduling of surveillance was comprehensive and rarely used
'
the allowed grace period.
Surveillance procedure content, an
area stated as needing improvement in the previous assessment,
improved as a result of rewriting the surveillance procedures,
developing a surveillance procedure writing guide to assist in
procedure preparation, and reviewing TS to ensure each
i
surveillance requirement was adequately tested and scheduled.
l
The new surveillance calibration procedures included a separate
l
" Functional Test and Return to Normal" section that will ensure
a functional test is performed following each calibration.
The
logic functional testing methodology was also greatly improved.
15
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The prev'ious assessment reflected a need to reduce' occasional
l
. proficiency deficiencies when performing the established
l
surveillance program.
To improve in..that. area, the licenseo
l
designed test boxes to simulate the trip logic test conditions.
]
This methodology decreased the number of jumper / lifted leads by
approximately.90%.
Subsequently, the number of unplanned ESF-
,
actuations caused by I&C surveillance efforts-decreased to one
!
in the last half.of the assessment period.. However, overall
q
proficiency deficiencies persisted throughout the assessment
"
period as' evidenced by the issuance of nine personnel'
erior-related LERs associated with this functional area.
!
This represented more than 50% of the total personnel' error.
'
].
"
related LERs.
Management involvement in assuring quality with respect to
nonradiological chemistry controls was good; the licensee has
formally committed to the Owners Group guidelines. 0verall
water quality improved and now generally meets the Owners Group
. guidelines.
Considerable progress was made in the implementation-
,
of the quality assurance / quality control'(QA/QC)' program in the
l
laboratory.
Licensee performance in the nonradiological split
1
sample confirmatory measures with the Brookhaven National
i
Laboratories was' good, with five of six samples-in agreement.
However, some problems persisted with the boron assay process
and sampling techniques utilized by the licensee.
The licensee
1
was actively pursuing this area at the end-of the assessment
i
period.
The same good level of management involvement was not apparent
in the post-maintenance testing and Performance Evaluation
i
Program.
The Performance Evaluation program is a testing,
j
trending, and analysis program for equipment whose failure
j
could reduce plant availability.
The poor valve testing on the
!
reactor core isolation cooling system and alternate. rod insertion
!
check valves reflected this situation.
Furthermore, the licensee-
appeared to have an inadequate mechanism.to systematically .
i
identify Updated Final Safety Analysis Report (UFSAR) commitments
,
that warranted periodic' testing or to ensure the timely development
'
and implementation of such testing. Also,.the licensee had no
program to document and trend check valve failures or to test
relief valves that were not included in tne ASME Code Section XI
!
IST program.
_
The licensee continued to exhibit an appropriate approach to'
j
resolution of technical issues identified in the last half of
the previous assessment period. The Technical Specification
Improvement Program continued to identify procedural and TS
weaknesses. Testing was expeditiously accomplished and TS
actions were complied with when circuits or functions were
.{
discovered not to have been appropriately tested.
Corrections
to the TS were prioritized and are being submitted in a timely
fashion for resolution.
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Surveillance'and nonradiological controls staffing was generally
adequate; key positions were identified and filled. This was
accomplished even though there were some changes of key personnel
in the chemistry department and the surveillance program was
transferred to the operations group.
Strained resources were
noted in two areas associated with surveillance scheduling /
,
tracking and IST results review.
The strained resources in the
!
IST results area were a contributing factor in the licensee's
failure to identify the need to place a high pressure coolant
injection valve on an accelerated testing schedule. All
personnel appeared appropriately trained and qualified.
2.
Performance Rating
!
The licensee's performance is rated Category 2 in this area.
The licensee's performance was rated Category 3 in the previous
assessment period.
1
3.
_ Recommendations
The board recommends that the licensee continue management
attention in the resolution of the items identified by the
Technical Specification Improvement Program and in the
implementation of the Performance Evaluation Program.
E.
1.
Analysis
This functional area was evaluated on the basis of one routine
inspection and one annual exercise inspection conducted by
!
regional inspectors during this assessment period.
!
No violations were identified during this or-the previous
assessment period.
No exercise weaknesses or open items were
identified during the June 1988 annual exercise inspection,
and open items from the previous exercise were closed,
indicating that exercise performance had innproved substantially.
The December 1988 routine inspection indicated that the
emergency preparedness program continued to be well-defined and
well-in alemented, with continual minor program enhancements,
both shcrt-term and long-term.
Overall, the program is mature,
continues to improve, and now is being finely tuned.
Management involvement in assuring quality in this area was good.
Corrective actions were promptly initiated for problem areas,
,
and subsequent program enhancements were made.
)
i
In all cases, the licensee has been responsive to NRC
1
initiatives and concerns by providing viable, sound, and
j
thorough responses in a timely manner. As an example, the
1
1
17
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C
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licensee" volunteered.to be one of the first plants to-install
,
_
the Emergency Response Data System (ERDS).
The licensee's-
1
s
approach to resolution of technical issues from a safety
,
standpoint has also remained' consistently good,'and identified
j
. emergency response problems, such'as those: resulting from the
4
May' 1987 exercise have been aggressively resolved.- Inspection
j
.c
results indicate.that.the licensee's emergency. facilities are
I
"
-well designed and maintained. Minor' facility-related:
.
deficiencies,.such as those in the Operations Support Center,
are being resolved by the licensee. There were no long-standing
. regulatory issues attributable to the licensee.
The. acting' supervisor for the Radiological Emergency, Response
Program (RERP) was selected for the position of supervisor,
RERP, and the position now reports directly to the Vice
.i
.Presiden.t, Nuclear Engineering and Services.
Full-time
,
staffing of the RERP was increased by one person.
{
RERP training and~ qualification effectiveness was good, as
!
,
demonstrated by the lack of violations during the assessment
. period,. individual performance during the 1988 exercise,'and
!
routine . inspection walkthroughs with licensee personnel.
l
t
2.
Performance Rating
a
The licensee's performance is rated Category 1 in-this area.
The : licensee's performance was rated Category 1 in the previous
assessment period.
l
3.
Recommendations
1
None.
-
F.
Security
.
}
1.
Analysis
l
This functional area was evaluated on the basis of one inspection
L
conducted by regional physical security inspectors and routine
I
observations by the resident inspectors to evaluate security
activities.
(
The enforcement history has continued to improve.
One Severity
l
Level V violation was identified compared with three violations
during the previous assessment period. An aggressive licensee
program of self-assessment by the security compliance section,
and a high level of knowledge of program requirements by
supervisors contributed to the improvement.
The security-related reportable events trend has also improved.
Cnly 3 such events were reported during this assessment period
compared with 13 reportable events during the previous period.
18
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.
The three reportable events were non security personnel errors.
-
A conservative reporting threshold has continued during this
assessment period.
Responsiveness to NRC concerns continued to be a major strength
of the security program.
Enforcement issues, licensing matters,
and inspection findings are addressed in a timely manner and
resolved in a technically competent fashion. The licensee's
response to the miscellaneous amendments and search requirements
revision to 10 CFR 73.55 and the recordkeeping requirements of
10 CFR 73.70 was well stated and showed a clear understanding of
the requirements and evidence of prior planning. Adequate
staffing and a high level of technical competence contributed to
this program strength.
Communications with NRC Region III have
been frequent and effective, and the security director has
developed a keen awareness of issues of regulatory interest.
Managers and supervisors are responsive to inspectors' observations
and perspectives and address them in a thorough and positive
manner.
Staffing for the security section continued to be ample.
Department heads continued their stabilized performance and
have attained a high level of specialized expertise through
controlled and monitored rotation of selected department heads.
Strong supervision is provided for day-to-day security operations.
Procedural guidance is detailed, and is revised and modified in
a timely manner.
The security force training and qualification program continues to
be effective. The overall excellent performance of the uniformed
security force attests to the program's benefits.
Security
officers were thoroughly knowledgeable of procedural requirements
and confident of their capabilities.
Management involvement in this area continued to be good.
The annual QA audit was very extensive and broad in scope.
The security compliance section resource allocation demonstrated
a continued commitment to strong and aggressive self-inspection.
Senior managers, up to the vice president level, continued to
attend exit meetings and were aware of significant security
issues.
The security director's delegation of responsibility
and authority has enabled him to concentrate on overall program
needs and direction, rather than on narrow details of specialized
functions. A strong commitment to root-cause analysis and
'
monitoring of performance trends has also contributed to the
i
assurance of quality.
Security computer-related problems and personnel security
screening and procedural deficiencies noted in the previous
assessment period have been aggressively addressed.
Recent
hardware and software modifications have been completed for
the computer system. Completion dates for personnel screening
concerns identified through self-inspection have been
l
19
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implemented. Management oversight for these two areas is still
l
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"
warranted to assure that corrective actions address and resolve
i
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l
root causes and that adverse trends have been reversed.
2.
Performance Rating
The licensee's performance is rated Category 1 in this area.
The . icensee's performance was rated Category 1 in the
!
previous assessment period.
3.
Recommendations
None.
G.
Engineering / Technical Support
1.
Analysis
!
l
This functional area was evaluated on the basis of three
!
routine inspections by regional inspectors, several inspections
by the resident inspectors, a regional team inspection of
engineering activities, observation of DET members, an NRR
!
inspection of material control, an NRR E0P team inspection, NRR
.
interactions with the licensee, and NRR review of licensee
i
submittals.
j
The enforcement history during this assessment period continued
to be poor, consisting of one Severity Level III violation, an
4
I
example from the Severity Level III violation listed in the
Maintenance section, five Severity Level IV violations, and two
l
Severity Level V violations. This compares with one Severity
i
Level III violation, six Severity' Level IV violations, and three
i
Severity Level V violations during the previous assessment period.
!
The Severity Level III' violation with associated civil penalty of
2
$75,000 dealt with the primary containment monitoring piping
l
configuration not being in conformance with General Design
i
Criterion 56,.which was an outstanding issue at the end of the
previous assessment period.
Two other violations, a Severity
Level IV and a Severity Level V, occurred outside the assessment
period. The example from the Maintenance section Severity
j
Level III violation dealt with the programmatic breakdown in the
j
MOV torque switch program. Of the rumaining five violations,
j
three were associated with breakdowns in the material control
l
and review process; one dealt with the lack of vendor manual
control, and the final violation dealt with deficiencies
in maintaining drawings to the as-built condition of the
facility. Corrective actions implemented as a result of
)
previous violations appeared to be effective in general and
were performed in a timely manner.
]
Of the 29 LERs issued during the assessment period, 3 involved
)
ineffective design control.
Of the 19 unplanned ESF actuations, 3
j
were caused by ineffective design control. This is a significant
]
i
20
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i
6
K
. r
.
.
' reduction-of.'LERs and ESF'actuations caused by' design. control
1
deficiencies in-that 14 LERs and 12 ESFs were attributed to
f
-
this area in the previous assessment period.
[y
Management involvement-to ensure quality in this' area was mixed.
Weak work interfaces and communications problems contributed to
fragmented.and overlapping engineering support'for.the plant.
Although there was-significant improvement-in the interactions
i
between nuclear engineering and other plant organizations,
l
additional improvement was needed. One example where continued-
improvement was necessary was the raising'of the stroke time for
an emergency essential cooling water valve from 50 to 66 seconds
.by the inservice inspection group without consulting nuclear
,
~1
engineering.
The performance requirements specified by the
design calculations required a valve stroke time of 50 seconds.
.j
Another example was in the lack of control of torque switch
settings. This reflected a breakdown in the design process and
a-breakdown in the interface between the engineering and the
maintenance organizations.
Previous problems associated with
the valve operators should have served as an indicator that-
greater management involvement was appropriate.
In the material review area, management was not always. effective.
Previous material engineering policies as implemented by memoranda
were vaguely worded and. frequently misunderstood. As a result,
the engineering evaluations for commercial grade procurement
j
were frequently inadequate and the evaluations were not
i
appropriately maintained as QA records, although. post-installation.
i
evaluations determined that the material was acceptable.
1
Appropriate controls were not established over the-spare parts
!
reference program. A number of management actions were taken to
,
improve the spare parts reference system and material ~ suitability
j
reviews.
Subsequent reviews of installed equipment indicated
that the equipment was adequate for'its intended service.
1
On the positive side, licensee management increased its
j
involvement in the planning and prioritizing of activities
l
during this. period.
Management was required to address many
of the issues that surfaced as a result of material control
allegations.
Increased management involvement resulted in
changing Fey management positions and establishing the Nuclear
Materials Management Division in an effort to improve overall
effectiveness. The modification work prioritization system was
viewed as a strength and is expected to help improve
communication between the plant staff and nuclear engineering.
Although the structure and responsibilities of the various
engineering organizations still needed to be refined, management
appeared to be conscientiously addressing weaknesses in this
area.
In most cases, analyses appeared to be appropriately
j
performed, and recent corrective action programs showed an
j
improvement in the extent of actions taken,
j
21
)
_ _ . _ _ _ _
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- . - - - - - -
A
-_
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e
.
4
.j
The' licensee's approach to resolution of technical issues from
-
3
-a safety standpoint was mixed. Approaches were often viable,
' l
f
but sometimes lacked thoroughness and. depth. ' Engineering groups
were often slow to' resolve plant deficiencies, and occasionally
,
provided inadequate resolutions. A modification to remove the
delay volume in the RWCU subsequently resulted in conditions
that produced two water hammer events.
The E0Ps implemented .
I'
'
during the assessment period did not have comprehensive provisions
.
!
a
for containment venting, the use'of tygon tubing'to vent the
1
potentially hot and high pressure fluid for the control rod
l
' drives did not have a feasibility evaluation, and E0P entry
)
conditions deviated from those specified by the Owners Group
j
guidelines without being evaluated for acceptability. Generally,
,
there was appropriate engineering and technical support for
generating the new E0Ps as. evidenced by the quality of the
setpoint/ boundary calculations for performing certain E0P
l
A number of ESF actuations could have been prevented
{
actions.
/
had engineering provided operations personnel with a clearer
!
'
understanding of modular power unit electrical circuit failure
!
modes .that had been identified as 'a weakness in previous assessment
periods, so that this information could be. factored into appropriate
operating procedures.
Generally, when given an adequate amount of time to thoroughly-
examine various deficiencies, engineering personnel did an
j
acceptable job at root-cause analyses and establishing
appropriate corrective actions.
However, many areas involving
engineering support could be greatly improved.
Examples include
j
the engineering group's failure to control MOV torque and limit
!
switch settings even though the problems were known to exist for
l
a number of years, taking an excessive amount of time to resolve
i
and close out deficiencies, not performing adequate reviews concerning
whether modifications should be implemented, and not adequately
!
addressing whether the. design function of safety-related or
balance-of plant check valves was being met,
i
i
On th'e positive side, for the modifications, design changes, and
deviation event reports (DERs) reviewed by the NRC engineering
i
inspection team, there was a clear technical understanding of
.
'
the issues involved.
In almost every case, adequate conservatism
were utilized in the technical evaluations and the methodologies
were technically sound and thorough.
Recent modifications to
the facility adequately considered the overall effects on the
original design basis.
The licensee's responsiveness to NRC initiatives was mixed.
There were'still numerous examples where deviations existed when
comparing the as-built condition of the plant with design
documents or various data bases used by the licensee to keep
,
track of design-related information.
This indicated that
i
problems with configuration control that NRC identified at the
i
time of licensing were not completely resolved. The licensee's
)
1
22
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1
- DER system was comprehensive and included many of the examples
'
of. inadequate configuration control that awaited resolution.
With respect to the M0V torque switch control issue, prompt and.
extensive corrective action was effected once the generic
implications of the issue were identified.
Responses were
,
viable, generally ' sound, and thorough, Continuous changes. .
j
.within the engineering organization have caused some uncertainties.
,
relative to the authority and responsibility of some key positions.
A number of supervisory positions were held by ." acting" personnel
pending. final selection.
The new director of nuclear engineering,.
supervisor for plant systems. engineering,'and superintendent of
.
technical engineering have BWR operations experience. .For the
-1
most part, the changes appear to improve the organization, but a
final assessment of the new organization's effectiveness can not
yet be made. Technical expertise within.the staff appeared .to
be good for most areas and the. nuclear engineering staff appeared
well qualified technically; however, positions and responsibilities
,
had not been clearly defined or properly utilized as indicated
!
by excessive backlogs of unevaluated material, overtime requirements,
i
and shelf-life program implementation problems.
Systems engineers
.;
were overcommitted and sometimes designed temporary modifications
'
that should have been designed by nuclear engineering. Management
,
was in the process of more than doubling the size of the systems
l
engineering staff to address these concerns. Use of outside
i
consuhants appeared to be at an appropriate level, although the
exact role of outside consultants versus the nuclear engineering
i
staff in design modification work had not been resolved.
Technical expertise was available within the licensee's staff to
provide adequate technical oversight whenever outside consultants-
were used. Currently, outside consultants performed the majority
of engineering design modification work.
The staff had a
positive attitude about improving plant performance.
2.
Performance Rating
j
The licensee's performance is rated Category 3 in this area.
The licensee's performance was rated Category 3 in the
previous assessment period.
3.
Recommendations
,
Strong licensee management attention needs to continue in this
area in order to improve several aspects of Engineering / Technical
Support including the effectiveness of the new engineering
organization, interface between engineering and plant organizations,
material reviews and thoroughness and depth of technical reviews.
H.
Safety Assessment / Quality Verification
1.
Analysis
This functional area was evaluated on the basis of routine
resident inspections, two regional inspections, and
23
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._
l
.
.
observations of DET members. Activities examined included
"
QA audit functions, conduct of the onsite and offsite review
committees, conduct of the independent safety engineering group,
NRC issuance reviews, licensee safety evaluations, and the
licensee's internal corrective action system.
In addition, NRC
staff reviews of license amendment requests were considered.
The enforcement history consisted of one Severity Level V, one
Severity Level IV, and an example of the Maintenance section
Severity Level III violation.
The Severity Level III violation
example dealt with inadequate corrective action for MOV deficiencies.
Corrective actions in this area have not been totally evaluated
as of the end of the assessment period.
violation dealt with deficiencies in implementing the independent
safety engineering group (ISEG) function and had limited safety
significance. The Severity Level V violation dealt with onsite
review committee deficiencies and was of minimal safety significance.
Corrective action to these last two violations was prompt and
adequate.
Since this is a new functional area, no enforcement
history is available for comparison.
Management involvement in assuring quality continued to be
evident in the licensee's independent quality oversight activities
(Nuclear Safety Review Group (NSRG), Onsite Safety Review
Organization (OSRO), QA audits, ISEG).
Quality assurance audits
were effectively used to identify weaknesses in the organization.
Audit findings were resolved in a more timely manner during
the assessment period, even though some findings were slow
in resolution. The offsite review committee was viewed as a
strength because of its aggressiveness and increased involvement
in the quality and results of the audit process.
Both the
onsite and offsite review committees generally reviewed the
appropriate subjects and material ascribed to that committee
function.
The committees met significantly more often than
required and normally had an appropriate quorum.
However, there
was an occasional use of independent member reviews rather than
a committee meeting review for some matters. This process was
terminated part way through the assessment period. The ISEG is
a positive program, however, it was not utilized as effectively
as it could have been in reducing personnel errors and reviewing
operating experience. This was because significant ISEG resources
were being applied to previously identified weaknesses in the
safety evaluation process. An Institute of Nuclear Power
Operations (INPO) Maintenance Assistance Review Team was utilized
during the period and the licensee frequently uses INP0 in other
areas.
Finally, the licensee has embraced the safety system
functional inspection as a program of worth and plans to inspect
the low pressure coolant injection system during the next
assessment period.
24
-.
_-
.
.
i
?
Management involvement, though evident, was not as effective in
-
managing the internal corrective action system. The licensee
has established a low threshold for identification of problems
for the internal DER corrective action system, which routinely
identified conditions adverse to quality.
It is in the
resolution of those identified concerns that weaknesses were
noted.
Slow resolution was exemplified by numerous MOV
deficiency DERs being written prior to the two failures of the
l
reactor recirculation discharge valve in August and a second
reactor building contamination event occurring before adequate
'
interim corrective action was implemented under this system;
,
'
The DER system had a limited trend capability that may have
contributed to not targeting the MOV deficiencies earlier.
4
Improvements were made to the safety evaluation process.
However, there are some outstanding issues at the end of the
assessment period that may warrant additional initiatives in
this area.
These deal with the inadequacy of preliminary
safety evaluations that resulted in the licensee not performing
safety evaluations for modifications when such evaluations were
appropriate and not evaluating temporary modifications properly.
Responsiveness to NRC initiatives was generally adequate.
Actions pursuant to generic letters, Three Mile Island (TMI)
items, and bulletins reviewed during the assessment period were
implemented with minimal problems noted.
Prompt preventive
actions were taken to ensure that power oscillations that
occurred at other BWRs would not occur at Fermi. Additional
licensee initiatives were brought forth late in the assessment
period to improve the operator evaluation program for the present
operating crew maturity level.
However, the licensee was slow
in implementing corrective actions associated with information
notices as exemplified by the extensive time in the establishment
of corrective actions associated with reactor protection relay
'j
failures. The anticipated transient without scram (ATWS)
mitigation system currently at the facility for alternate rod
insertion was not well-designed because it lacked sufficient
j
diversity from the existing reactor trip system, was incapable
<
of manual actuation, and did not include a bypass for maintenance.
Finally, actions established and implemented under three
confirmatory action letters were adequate.
The licensee continued to increase the nuclear power plant
commercial experience at the senior and middle management
levels.
Staffing generally appeared adequate for performing
internal and independent quality reviews except for ISEG where
the minimum required complement was not always maintained. One
key weakness was noted in the training of personnel with regard
to root-cause analyses.
On a broader scope, though slow in
development, leadership training and technical training programs
were' embarked upon late in the assessment period.
25
__
,
-
.
u
...
a
,
[t .
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-..
,
,-
.0verall management generally provided viable resolution to
j
'-
,
obstacles detracting.from quality. -The licensee expended-
a
considerable resources in. completing the. rewrite / upgrade of site
procedures on schedule, an area of weakness-from initial.
.
lice; sing.
The TS Improvement Program' was completed'on schedule
with numerous deficiencies rectified.' Procedural errors
decreased as a result of-these programs. A combination of
senior vice president video tapes on procedural compliance',
managerial daily verbal reinforcements, use of the Human
Performance Evaluation System,- accountability ~ meetings, and a-
a
1
maturing of-line organizations have. contributed to the reduction
of safety significant personnel errors during the assessment
period.
Though slow in coming, performance improvements have
been observed.
Notwithstanding'these accomplishments, all facets of the Fermi'
organization have not yet stabilized because of management /
organizational changes, poorly defined engineering. support-
functions, and lack'of an integrated, effective planning and
scheduling process, particularly relative to the effect that
this has had on the unavailability of safety systems.
-2.
Performance Rating
1
f
The licensee's performance is rated Category 2 in this area.
Because this is a new functional area, it was not rated in
the' previous assessment period.
3.
Recommendations
None.
I.
Startup Testing
.1.
Analysis
!'l
This functional area was evaluated on the basis of observations
l
by resident and regional inspectors of Test Conditions 4 and 6
l
testing.
,
The enforcement history in this area continued to indicate
regulatory conformance.
No violations or deviations vere
1
identified during this or the previous assessment period.
Management involvement to assure quality in this functional
'
area continued to be apparent.
Testing activities were properly
controlled and scheduled to minimize impact on normal plant
activities.
Proper planning was always evident and extra
preparation taken on the more difficult and complex evolutions.
Reflective of this was the superior execution of the
i
recirculation pump trips, reactor feedwater pump trip, main
!
steam isolation valve (MSIV) closure test, and shutdown from
!
l
26
_ _ _ _ _ - _ _ _
-
.
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-outside the control-room test.- Dedicated shift personnel'.were
'
assigned to these tests and additional' simulator training-was
provided.
Excellent pretest briefing <, were' conducted with all
i
'
3
applicable parties attending.
Proper adherence to procedures
was noted and test results were 'well-documented.
1
There'were few NRC initiatives in this' functional area.
I
In those- few instances, management was responsive and
f
appropriately addressed the concerns.
~
Staffing was adequate.
Personnel were experienced and
knowledgeable. Authorities and' responsibilities were
.well-defined between' operations and startup personnel.
a
2.
Performance Ratinq
!
The licensee's performance' is= rated Category 111n this' area.
!
The licensee's performance was rated Category 1 in the previous
assessment' period.
j
!
3.
Recommendations
!
'
i
None.
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_ _ _ _ _ _ _ _ _ _ _ . _ . _ . _ _ . . . _ _ _
-
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)
V.
SUPPORTING DATA'AND SUMMARIES
A.
. Licensee Activities
Fermi 2 began the assessment period by continuing a scheduled LLRT
outage.
The plant operated at routine power levels up to 100%, and
throughout the assessment period several power reductions / reactor
l
outages occurred.for maintenance, repairs, and surveillance activities.
Toward the end of the assessment period, the licensee completed its
startup testing program including the fast closure of the MSIVs,
shutdown from outside the control room, and the warranty run.
The
1
plant ended this period operating at routine power levels.
i
Fermi 2 experienced 19 ESF actuations, and 6 reactor scrams. Two
scrams occurred when. operating above 15% power, two at below 15%
L
power, and two with no rod motion.
Two scrams were the result of
personnel / procedure errors, three were the result of equipment
failures, and one was caused by interruption of offsite power.
Significant outages and events that occurred during the assessment
period are summarized below.
l
1
Significant Outages and Events
[
1.
During April 1 through May 5, 1988, the plant remained shutdown
to complete its scheduled (10 weeks) LLRT outage that began
February 27, 1988.
!
2.
On July 23, 1988, the plant was shutdown in accordance with
TS because of an increase in unidentified drywell leakage.
Leaking valves in the drywell were repaired
3.
During August 20-23, 1988, the plant was shutdown when a
recirculation pump discharge valve failed to close.
!
4.
During August 29 through October 5, 1988, the plant was
shutdown following a repeat event when a recirculation
pump discharge valve failed to close.
5.
On November 1, 1988, the plant was shutdown for six days
following completion of the startup tests involving MSIV
full closure and shutdown from outside the control room.
6.
Startup testing was completed on November 18, 1988.
B.
Inspection Activities
Twenty-five inspection reports are discussed in this SALP report
(April 1, 1988, through December 31,1988) and are listed in
Paragraph 1 of this section, Inspection Data.
Table 1 lists the
violations per functional area and severity levels.
Significant
inspection activities are listed in Paragraph 2 of this section,
Special Inspection Summary.
l
28
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_
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3
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-1.
Inspection Data-
.
Facility Name:
Fermi 2-
i
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Docket No:
50-341'
!
l
-Inspection' Report Nos:
88008, 88012 through 88021, 88023-
'
through.88032, and 88034 through
~
l;
88037.
Table I
'-
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l
Number of Violations in'Each Severity Level
,
Functional Areas
III
IV
V-
1
,
A.
Plant Operations
1
5
-
j
B.
Radiological Controls
'
-
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-
-
'
C.
Mainteriance
1
3
-
!
8*
D.
Surveillance
-
-
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E.
-
-
-
1
i
F.
Security
-
-
1
G.
Engineering / Technical
1**
6
1
Support
1
1
'
H.
Safety Assessment /
-
. Quality Verification
I.
Startup' Testing
l
-
-
-
l
TOTALS
III
IV
V
3
23
3
J
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Three'of these violations were discussed during SALP 9, but were issued
E
'in SALP 10.
They are included in the totals of'this SALP.
[
This violation was discussed during SALP 9, but was issued in SALP 10.
It is included in the totals for this SALP.
,
2.
Special Inspection Summary
a.
During March 8 through September 20, 1988, a special
NRR inspection was conducted regarding the
licensee's actions in response to material control
allegations that were reported during January and
February of 1988 (Inspection Report No. 341/88008).
l
b.
During May 17-20, 1988, the annual emergency preparedness
I
exercise was conducted (Inspection Report No. 341/88016).
)
i
c.
During January 17 through April 28, 1988, a special
-inspection was conducted on the circumstances surrounding
the failure of the noninterruptible control air compressor
on January 14, 1988 (Inspection Report No. 341/88014).
29
_ - _ _ _ _ -
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d.
During May 16 through June 10, 1988, a special inspection
was conducted on MSIV open/close manual relay logic and
,
surveillance program review (Inspection Report
.
No. 341/88018).
j
e.
During August 4-5,'1988, a=special inspection was-
_
y
-
conducted in response to an August 2, 1988 event in which
24 control rods inadvertently received a full scram signal
while the reactor was in cold shutdown (Inspection Report
f
No._341/88023).
!
f.
During August 22 - September 16, 1988, AE0D conducted a
Diagnostic Evaluation.
g.
During September 6 through October.6, 1988, a special
j
inspection was conducted in response to the' events
-J
-relating to the failure.of the recirculation pump
"B"
discharge valve to close on August 20 and 28, 1988
(Inspection Report No. 341/88025, CAL-88-024).
8
h.
During October 17 through November 4, 1988, a special
i
inspection was conducted-to assess the effectiveness
j
and technical capability of the onsite engineering
!
organization (Inspection Report No. 341/88027).
!-
1.
During July 5-14, 1988, NRR conducted an E0P inspection
(Inspection Report No. 341/88200).
i
i
C.
Escala'ted Enforcement Actions
i
!
1
1.
_An Order Imposing Civil Penalty in the amount of $175,000 was
issued to the licensee on December 28, 1988.
This action was
based on two Severity Level III violations. Both issues were
discussed during SALP 9.
The first issue related to'the discovery
I
that the licensee's containment isolation provisions for the
j
!
primary containment radiation monitoring system were not in
compliance with the requirements of 10 CFR 50, Appendix A,
4
The second issue related_to the
licensee's operation of the noninterruptible air system in a
degraded mode which resulted in the violation of two TSs
j
(Inspection Report Nos. 341/87048 and 341/88014, Enforcement
Notice Nos. 88-52 and 88-52A, Enforcement Action No.88-104.
2.
A Notice of Violation and Proposed Imposition of Civil Penalty
in the amount of $50,000 was issued to the licensee on
1
January 6,1989. This action was based on a Severity Level III
violation regarding the failure of recirculation pump "B"
discharge valve to close on August 20 and 28, 1988 (Inspection
Report No. 341/88025 and Enforcement Action No.88-281).
9
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30
- _ _ - . _
- _ _ _ _ _
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D.
Confirmatory Action Letters (CAls)
!
m
.
.
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1.
On April:19, 1988, CAL-RIII-88-009 was' issued to the licensee-
'
p!-
regarding the deadheading of the RHR. pump, damage to the moisture'
i
separator reheaters, and operational problems related to human
l
i
performance.
-
,
2.
On July 15,-'1988,. CAL-RIII-88-020 was issued-to the' licensee
,
regarding the breaking of a compression fitting on an. instrument
l
line in the RWCV system on July 13, 1988. The, event led.to a
loss:of several hundred. gallons of reactor. water into the
.
'
reactor building and was a repetition of a similar event in the
same line on May 28, 1988.
3.
On August 30,.1988, CAL-RIII-38-024 was issued to the-licensee.
to confirm the licensee's corrective actions-regarding the.
!
repeat failure of the "B" reacter recirculation loop discharge
'
valve to close~when signaled from the control room.
E.-
Licensee Amendments Issued
' i
Amendments No.
Description
Date
i
18
A one-time TS extension
April 15, 1988
of the surveillance interval'
%
for the Type C LLRTs of three
RHR shutdown cooling isolation
j
valves.
19
Revised a TS table to delete
June'3, 1988
the daily channel check
requirements for the average
power range monitor flow
biased neutron flux-high
!
scram functional unit.
20
Changed TS drywell air
June 23, 1988
.
temperature limit from
'l
135 F to 145'F.
'
21
Deleted the non regenerative
August 5, 1988
i
heat exchanger outlet
!
temperature-high signal from
!
the TS listing of RWCV system
isolation signals.
'
22
Updated TS circuit breaker
July 27,1988
.
table.
)
,
f
31
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_ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __
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223,
Revised TS to correct an-
July 28, 1988.
errorzin Table 2.2.7.12-1.
24"
. Revised TS to change the
' July 28, 1988.
,
. action and table notations
l:
for the gaseous'and liquid'
"
effluent monitoring'
'-
instrumentation.
25
Revised _TS with respect to-
August 3,:1988
a-footnote in Table 1.2.
26
' Revised the Operating ~ .,
August.5, 1988
License to require, compliance-
,
'
with the amended Physical
Security. Plan.
27.
Revised.TS with respect
August 5, 1988'
to the containment high
radiation monitors.
28
Revised TS with respect
August 19, 1988
to the standby gas treatment
. system monitors and the.
containment range monitor,
,
,
29
Revised TS to clarify
December 15, 1988
LC0 for the 480-v MCC
72CF swing bus.
F .-
Review of Licensee Events Reports Reports Submitted by the Licensee
1;
Licensee ' Event Reports (LER's)
Twenty-nine LER's were iss'ued during this as'sessment period.
Table f. 'shows cause code comparationes of. SALP 9 versus =SALP.10
LERs.
LER Nos: 88009 through 88037
J
1
.
32
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_ . _ _ _ _ . ._.. _ _ _
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Table:2
, ~
,
'(12-M0)
(9-M0).
>
No'. (Percent)
No. (Percent)
.CAUSE AREAS-
SALP 9
SALP 10'
Personnel Errors
16 (28.1%)
14 ' ( 48.~ 3%) .
+
Design. Problems.
14 (24'.5%).
1 (.3.5%)
D
External Causes-
.
' 16 (28.1%)
3 (10.3%) ,
0('O.0%)
1-(,3.5%)-
l'
Procedure Inadequacies'
h
1 Component / Equipment
6 (10.5%)
10 (34'.6%)
i'
Other/ Unknown
5 ( 8.8%)
0 ( 0.0%)-
TOTAL'
57-
29-
- '
s
FREQUENCY (LERs/MO)
4.8
3.2
. NOTE: The above information was derived from review-ofc.LERs-
performed _by NRC staff-and may.~not completely coincide
.with the site's cause assignments.
1
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33
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