IR 05000302/1987027

SALP Rept 50-302/87-27 for Apr 1986 - Aug 1987

ML20236W312
Person / Time
Site:	Crystal River
Issue date:	11/30/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20236W303	List: IR 05000302/1987027 ML20236W301
References
50-302-87-27, NUDOCS 8712070392
Download: ML20236W312 (42)

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UOV 3 0 1987 i

i ENCLOSURE SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION REGIO .

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-302/87-27 FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 APRIL 1, 1986 THROUGH AUGUST 31, 1987

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I INTRODUCTION l

The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a periodic basic and to evaluate licensee performance based upon this information. The SALP program is supplemental to normal regulatory processes used to determine compliance with NRC rules and regulation The SALP program is intended to be sufficiently diagnostic to prnvide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management to promote quality and safety construction and operatio An NRC SALP Board, composed of the staff members listed below, met on October 26, 1987, to review the collection of performance observations and data to assess licensee performance in accordance with the guidance in NRC Manual Chapter D516, " Systematic Assessment of Licensee Performance." A summary of the gu' dance and evaluation criteria is provided in Section II of this report. The SALP Board prepared this report and developed the ratings for review and approval by the Regional Administrato This report is tne NRC staff's assessment of the licensee's safety performance at Crystal River Unit 3 for the period of April 1, 1986, through August 31, 198 SALP Board for Crystal River Unit 3:

L. A. Reyes, (Chairman) Director, Division of Reactor Projects (DRP),RII C. A. Julian, Chief, Operations Branch, Division of Reactor Safety (DRS),RII J. P. Stohr, Director, Division of Radiation Safety and Safeguards (DRSS), RII D. M. Verre111, Chief, Reactor Projects Branch 1, DRP, RII H. N. Berkow. Director, Project Directorate 11-2, Division of Reactor Projects, NRR H. Silver, Project Manager, Project Directorate 11-2, NRR T. Stetka, Senior Resident Inspector, Crystal River, DRP, RII Attendees at SALP Board Meeting:

B. A. Wilson, Chief, Reactor Projects Section 1C (RPIC), DRP, RII H. O. Christensen, Project Engineer, RPIC, DRP, RII M. A. Scott, Project Engineer, RPIC, DRP, RII J. Tedrow, Resident Inspector, Crystal River, DRP, RII T. C. MacArthur, Radiation Specialist, Technical Support Staff (TDSS),

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J. Zeiler, Reactor Engir;eer, TSS, DRP, RII

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I CRITERIA l l .

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Licensee performance is assessed in selected functional areas depending on I whether the facility has been in the construction, preoperational, or operating phase during the SALP review period. Each functional area l- normally represents an area which is'significant to nuclear safety and the

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environment and which is a normal programmatic are Some functional areas may not be assessed because of little or no licensee activity or lack of meaningful NRC observations. Special areas may be added to ,

highlight significant observation {

One or more of the following evaluation criteria was used to assess each func'.ional area; however, the SALP Board is not limited to these criteria and cthers may have been used where appropriat Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint Responsiveness to NRC initiatives Enforcement history Operational and construction events (including response to, analysis of, and corrective actions for) Staffing (including management) Training and qualification effectiveness Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie The definitions of these 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 ampie and effectively used such that a high level of performance with respect to opera-tional safety or construction quality is being achieve Category 2: NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to operational safety or construction quality is being achieve Category 3: Boti' NRC and licensee attention should be increase Licensee managemer.t attention or involvement is acceptable and considers nuclear sefety, but weaknesses are evident; licensee resources appear to be strained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction quality is being achieved.

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The functional area beir.g evaluated may have some attributes that would place the evaluation in Category 1, and others that would place it in either Category 2 or The final rating for each functional area is a composite of the attributes tempered with the judgement of NRC management as to the significance of individual item The SALP report may also include an appraisal of the performance trend of a functional area. This performance trend will only be used when both a definite trend of performance within the evaluation period is discernable and the staff believes that continuation of the trend may result in a change of performance level. The trend, if used, is defined as:

Improving: Licensing performance was determined to be improving near the closa of the assessment perio Declining: Licensee performance was determined to be declining near the close of the assessment perio i l

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l III.. SUMMARY.OF RESULT Overall' Facility Evaluation The Crystal River facility was effectively managed and has achieved a satisfactory level of operational safety. . The licensee continued to exhibit a - strong maintenance program and has made significant

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improvements in: the radiological l controls, fire. protection, : quality i programs, security, and training areas. However, a general weakness encompassing all operational areas was noted with adherence to and adequacy of. plant procedures. The licensee's manag'ement of the inservice inspection and inservice testing programs also appeared.to

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be wea 'The weakness associated with personnel adherence to plant procedures was identified during the previous SALP assessment period. The li.censee has continued to implement' the programs previously established to correct this problem and has devoted considerably more resources to identify the root causes for this proble Plant management is stressing the importance' of procedure compliance with workers as a necessary part of getting the job done right and is continuing the policy of a high level management. review of recurrent instances of procedure noncomplianc During this assessment period approximately nine Licensee Even Reports (LERs) and over eleven violations were the result of inadequacies in plant procedures. To improve the. quality of plant procedures, the licensee has developed a single writer's guide which addresses the proper format and human factor consideration:s for the writing of plant procedure l The licensee has made significant efforts to maintain good plant housekeeping and cleanliness conditions throughout the plan A reduction in the size of contaminated areas has significantly improved plant access and has also resulted in improved cleanliness conditions. Personnel from outside agencies and the NRC have commented on the good general cleanliness of the plan ;

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There has been a significant effort by the licensee to improve the security are This effort has been evident by the increased

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security awareness by all site personnel, considerable expenditure of i l

money and resources to improve existing security systems, and the {

improvement of site security management through the reassignment of I some existing personnel and employment of new personnel. This effort appears to be providing acceptable results and a greatly improved security postur The licensee continues their efforts to smprove management controls over their contract personnel. These controls have improved over the onsite general contractor (FLOUR), however weaknesses still remain

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with the control over engineering contractors as evidenced by l problems in the ISI/IST programs. Attempts to str2ngthen this area by increasing the in-house engineering staff and toereby reducing the reliance on contract engineers is being actively pursued by the license B. The performance categories for the current and previous SALP period in each functional area are as follows:

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Functional Area March 31, 1986 August 31, 1987 Plant Operations 2 2 Radiological Controls 2 2 Maintenance 1 1 Surveillance 2 3 Fire Protection 2 1 Emergency Preparedness 2 2 (Improving)

Security and Safeguards 3 2 Outages 2 2 Quality Programs and Administrative Controls Affecting Quality 3 2 Licensing Activities 2 2 Training and Qualification Effectiveness 3 2 (Improving)

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IV. PERFORMANCE ANALYSIS Plant Operations Analysis During this SALP period, inspections of plant operations were performed by the resident and regional staff Major operational decisions were made at a management level that was adequate to assure appropriate supervisory involvemen Plant operations were generally conducted in a conservative manner to ensure plant safet There were indications of this conservative approach to operation when the decision was made to replace all four reactor coolant pump shafts even though only one shaft had broken and there was inconclusive evidence that the other shafts had cracks. Other occasions that demonstrated conservative operation involved the decision to rebuild and replace all four reactor coolant pump mechanical seal packages even though only one seal had failed and on another occasion the decision to shutdown the plant and replace a seal package when degradation was indicated even though the observed system leakage was well within licensed conditions. One instance of a non conservative operational decision was evident when it was decided to continue running a condensate pump after indications of potential pump failur Tne pump failed and resulted in additional pump damage and time to repair and could have resulted in a plant transien The plant staff appeared observant of Limiting Conditions for Operation (LCOs) and was generally conservative in its application of action statement requirement !

Overall control of plant operations was satisfactory. Two reactor trips occurred during this assessment period, both of which were caused by equipment failur This number is a significant reduction in the total number of reactor trips which had occurred in the preceding evaluation period. Also, there were no trips for the first 16 of the 18 months in the SALP period. Although this evaluation period included two major plant outages, two successive continuous on line operating records were achieved. In March 1987, plant operators responded ;

effectively to prevent a reactor trip when an equipment problem )

associated with a test on the main feedwater system resulted in I

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a reduction in plant power generatio Also, in July 1987, operating personnel responded expeditiously during a reactor trip when the main turbine had to be manually tripped to prevent l an excessive plant cooldow I

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Operations staffing was adequat Due to an increase in licensed operator turnover from previous assessment periods, the licensee has had to increase the usage of overtime and has had to implement a five shift rotation schedule. The increased use of overtime has had a detrimental effect on operator morale, and in conjunction with the use of lesser experienced operators, could be contributing to the problem the licensee has had with operators adhering to plant procedure The licensee has recognized this factor and has begun an effort to provide enough operating personnel to form a six shift rotation schedule which is presently planned to be implemented during the first quarter of 198 Plant procedural inadequacies and failure of operators to implement procedures account for most of the violations listed below (violations a, b, d, e, f, g and two examples listed in the surveillance section). The licensee has been responsive to this problem and has implemented the following actions:

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Has established individual responsibility by department for the control of revisions and changes to procedures utilized by that department;

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Has increased the involvement of first line supervisors in the preplanning of work to ensure the worker has the necessary procedural guidance to accomplish the job correctly;

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Has solicited craft / operator recommendations for improving plant procedures;

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Has implemented a multi-discipline team to analyze the procedure adherence problem and recommend corrective action; and

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Has developed a single writer's guide which addresses the proper format and human factors considerations for writing plant procedures (except abnormal and emergency procedures).

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These procedural enhancement programs and initiatives apply to other affected functional areas as well, e.g., surveillance, maintenance, et The licensee has increased the operations engineering staff support and has dedicated these personnel to rewrite the i operating procedures and the emergency / abnormal procedure j Writer's guides associated with these procedures have been l l

rewritten with emphasis on human factor consideration !

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The licensee has implemented the use of shift administrative clerks to relieve the administrative burden placed on the nuclear shift supervisors. Relieving this burden should allow shift supervisors to increase their attention to matters related to safe operation of the plant and thereby enhance plant safet The conduct of shift turnover meetings continues to be a strong point in plant operation Representatives from other departments are present. during these meetings and this has a positive effect on overall plant control and coordination of plant activities. These meetings are held in the control room during which time access to this area is restricted. Control room operations continue to be conducted in an orderly and professional manne It should be noted that an Operational Safety Team Inspection (OSTI) was initiated at the end of this SALP perio The principal objectives of this inspection were operational safety performance, operations support, design, corrective actions, committee functioning, and management oversigh This inspection may deal with this and other attributes of the SALP report, but since its results will not be available until after the end of this period, it will not be discussed further in this report. As appropriate, the results will be covered in the next SALP perio Seven violations were identified, Severity Level IV violation for three examples of failure to implement procedures (Decay Heat Removal System valve ]q was found mispositioned, valve packing was adjusted without {

an approved work request and a snubber reservoir fluid I level was not refilled). The last example is an example of a surveillance violatio (86-20) Severity Level IV violation for failure to reduce the concentration of oxygen in the Waste Gas Decay Tank when hydrogen and oxygen concentration exceeded 4 percent. This violation was caused in part by an inadequate procedur (86-22) Severity Level IV violation for failure to take prompt corrective action to provide nitrogen equipment and nitrogen for the Waste Gas Decay Tan (86-22) Severity Level IV violation for an inadequate procedure in that containment isolation valves were improperly rest' red to service following maintenance. (86-27)

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9 Severity. Level IV violation for two examples of failure to .

implement procedures (no log entries were made when two independent emergency cooling subsystems were not available and no independent verification for valve positions after performing operability testing). (86-31) Severity Level IV violation for three examples of failure to maintain and adhere to procedures (a Decay Heat Removal System Valve was mispositioned, spent fuel bridge control console cabinet door was not locked and Emergency Plan Procedure was not updated). The second example is an example of an outage violation and the third example is a example of an emergency preparedness violatio (86-35) Severity Level IV violation for five examples of failure to implement-procedures (incorrect valve re toration positions on an equipment clearance, testing a main steam safety valve at improper steam system temperature, improperly-performing control rod exercising, improperly calculated heat balance power, and not identifying data outside of normal operating range). The second example is an example of a maintenance violation. (87-17, 87-19) Conclusion Category: ?

Trend: Recommendations The staff noted an improvement from the last SALP assessmen However, in order for the licensee to receive a higher category rating, it will be necessary to resolve adequacy and compliance problems associated with procedure B. Radiological Controls Analysis Caring the assessment period, occupational radiation dose control, radiological effluent release, and chemistry inspections were performed by the resident and regional inspection staff This included confirmatory measurements e using the Region II mobile laborator During the assessment period, the licensee's Supervisor of

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Chemistry / Radiation was appointed Acting Nuclear .

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Chemical / Radiation Superintendent and a new Radiation Protection Manager was assigned the responsibilities of the radiation protection program, i

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The licensee's health physics (HP), radwaste and chemistry staffing levels compared favorably with'other utilities having a facility of similar size. An adequate number of ANSI qualified licensee HP and Chemistry technicians'were available to support routine operation During outage operations, additional contract HP technicians were used to supplement the permanent plant HP staf Several improvements have been implemented by the licensee to strengthen the radiological controls area which was identified to be declining in performance during the previous SALP evaluation perio Significant management changes have been made to improve both internal and external communications within this organization and the supporting staff has been increased to oversee special projects, programs, and organizational goal These changes should help to improve the continuity and understanding of the licensee's various radiological control program A radiological safety incident reporting system has been established to identify noncompliance with the radiological control program. This reporting system is being extensively used by personnel and has identified many nonconformances. This system is also being utilized by NRC inspectors to identify problem areas. Although no formal tracking system has yet been established for the data acquired by this system, a computer software package is presently under development to trend this information. Development of this trending program would be beneficial in reducing the recurrence of events and improving personnel safet The licensee has been receptive to INP0 recommendations to improve performance in the radiological controls area. These recommendations include posting general radiation area survey maps on each floor of the RCA to identify contaminated areas and areas with significant radiation exposure levels. Also local i radiation postings include approximate dose rates expected in the immediate vicinity. In addition, copies of the :nost recent radiation and contamination survey maps have been attached to the job specific radiation work permits to increase the workers awareness to radiological condition One strength noted in the health physics, radwaste and chemistry programs was the stability of the technician staff. The low turnover rate has resulted in a more experienced group of individuals and has provided the time necessary to implement an ef fective and continuing training program for the technician However, the capability of the chemistry staff was weakened l

through transfer of the only academically trained chemist to the l OTSG Task Force and through transfer of a chief technician to the Training Departmen This left the Chemistry function

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11, without' the ' technical . base 'provided by an academically trained chemis To provide additional. supervisory coverage; a third laboratory supervisor had been added-to manage chemistry control on back shift During :the fifth fuel . cycle, the licensee continued .to experience difficulties with chemistry 'and oxygen control because of inleakage of air.and saline water into the secondary cooling system and because of transport of corrosion products to the once-through-steam generators (OTSG). Although the licensee had . attempted to eliminate blockege of tube-to-tube sheet-broached holes by a " slap-cleaning" procedure at the end of the fourth fuel cycle, the unit continued operations load-limited in'the'fifth fuel cycle because of.this problem. This cleaning procedure is scheduled to be repeated during the fifth refueling outage. These. actions are an indication of improved ' management-attention to the need for enhanced chemistry control The licensee was continuing to address the multiple problems 1 associated with the OTSG through the OTSG Task Force. .This Task Force was made.up of engineers from several disciplines and had been given lead responsibility for recommending means and priorities for achieving efficient operation of the OTSG Additional ~ restrictions have been placed on chemistry control by tne use of copper alloy tubes in the main condenser. 'The main condenser was also being degraded through galvanic and

. microbiological 1y-induced corrosion mechanisms. These problems, as yet, had not caused a plant shutdow The chemistry control implementing procedures were revised to include the technical guidelines developed by the Steam Generators Owner's Group (SG0G). However, the licensee had not provided a management level commitment or policy statement to the facility enclosing the SG0G guidelines as a priority for all facility organizations. Such a policy statement is recommended by the SGOG to establish as a company policy and priority the need for all components in the organization (not just the chemistry organization) to work to implement the SG0G criteri Improvements in the responsiveness to NRC initiatives and aggressiveness in addressing radiation control problems have been noted during this SALP perio For example, state-of-the-art whole body friskers (PCM-l's) and whole body y counters have been obtained for use at the facilit .

l The licensee's radiation work permit (RWP) and respiratory protection programs were found to be adequate. The licensee has upgraded their RWP program since the previous assessment period to provide for revising RWP's to address change of work conditions after a RWP had been issue __ _ - _ _ _ . _ _ _ _ _ _ .

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1 The licensee has exercised an aggressive contamination control i progra In January 1986 13,000 ft2 was considered contaminated, however, by January 1987, 8,500 ft2 out of a total area of ' 66,100 ft2 (excluding containment) was considered contaminated, which is 12.9?J of the radiation controlled area (RCA). The licensee had not set a goal for 1987 to further reduce the total contaminated area inside the RCA, other than to maintain the area which is now considered radiologically clea Housekeeping has been outstanding, with most areas very clean and orderly even late in outage During 1986, the licensee's cumulative exposure was 447 person-rem as measured by thermoluminescent dosimeters (TLDs),

which is comparable with the national average of 397 person-rem per unit observed at Pressurized Water Reactor (PWR) facilitie The licensee's original goal for 1986 was 50 person-re An additional 300 person-rem was added to the year's total to account for a reactor coolant pump repair outage. A subsequent dose estimate for a letemn cooler replacement was 60 person-rem. Welding difficulties were experienced for this job but the estimated exposure was not revised. This resulted in a total exposure of 447 person-rem for 1986, which was slightly higher than 410 perscn-rem, the estimated amoun Through August 31, 1987, the collective dose as measured by TLD's was 52 person-rem which is well within the 1987 goal of 350 person rem. The licensee has a refueling and maintenance outage scheduled for the fall of 1987, in which the remaining 298 person-rem for 1987, is projected to be expende The person rem goals for both 1986 and 1987, along with the ,

person-rem expended are indicative of management commitment to as low as reasonably achievable (ALARA).

During 1986, the licensee made 35 solid radioactive waste shipments totaling 12,864 ft3 and containing 1,347 curies of activity. This value compares favorably with a PWR average of 11,650 ft3 per reacto Through August 1987, the licensee had made 14 solid radioactive waste shipments totalling 6,244 ft3 and containing 201 curies of activit Liquid and gaseous radioactive effluents were within the Technical Specification limits and in compliance with 40 CFR 190 limits on radiation dose and radioactivity concentration in effluents. Fission and activation products in gaseous effluents for 1986 were higher than in 1985 but were less than the average comparable releases from PWR units in Region II (RII). Iodines and particulate in gaseous effluents were approximately the same in 1986 and 1985. Radioactivity in liquid effluents was approximately 40?4 lower in 1986 compared to 1985 and less than i the average of RII PWi;s for 1986. Tritium in liquid effluents l was essentially equal for 1985 and 198 There were no significant trends in the quantity of radioactivity in gaseous

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and liquid effluents discharged from the Crystal River plan Effluent summary data - for 1984, 1985 Land 1986 is contained in i Section V.K. of this report

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Radiation _ doses to maximally exposed offsite individuals from liquid and gaseous effluents , ford 1986 were 0.08 mrem (whole body) and 0.5 mrem'(organ). These doses were within Technical Specification limits-and below 40 CFR 190 limit .

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In the crea of transportation of radioactive material the licensee received two Severity Level IV violation These violations which included failure to follow Department of Transportation regulations' for surveying,. bracing- and documenting shipments of radioactive material were indicative of apparent programmatic weaknesses in the area of transportation of. radioactive materials. The licensee took prompt corrective-action in revising their procedures and providing appropriate instruction to responsible individual In the area of 'in-vivo (whole body) counting, the licensee

received a Severity Level IV violation. This violation involved failure to evaluate positive maximum permissible organ burdens (MP0B) values (greater than 1% MPOB), failure to assure that whole body position coordinates were properly entered into the required jobstream menu for each separate whole body analysis, failure to assure the thyroid detector was centered - on the thyroid of individuals being counted, and failure to perform

. routine background counts for the whole body counter to establish a baseline for the analyses. This violation with multiple examples is indicative of continued weaknesses in the area of whole body counting. During the previous assessment period the licensee received a violation for failure to have an adequate procedure for calibration of the whole body counte In addition to procuring two new whole body counters, the licensee has revised their procedure to address the problems they have experienced in the pas These actions should strengthen this aspect of the bioassay progra A licensee-identified event involved the uncontrolled release to

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the environment via the seawater discharge facility of approximately 20 ft3 of radwaste demineralized resi The loss resulted from a manufacturing defect in the installation of a resin-retaining screen on the outlet of the demineralized vessel. It could not be determined at what point in the 9 month operating cycle the loss of resin occurred; however, the nature of the defect was such that the loss probably occurred early in the cycle and therefore the cumulative radioactivity inventory on the resin was probably minimal . The licensee removed the l-

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demineralized unit from service, shipped it to the manufacturer for analysis and repair, and then reinstalled the repaired unit.

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The licensee's actions were considered to be responsive and timel Seven violations were identifie Severity Level IV violation for entry of personnel into a high radiation area without radiation monitoring devices (86-26) Severity Level IV violation for failure to perform an alpha contamination survey. (86-26) Severity Level IV violation for failure to adequately block and brace a radioactive materials shipmen (86-26) Severity Level IV violation for' failure to adhere to radiation protection posting requirements. (86-38) Severity Level IV violation for three examples of failure to comply with radioactive material shipment requirement (87-09)

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! Severity Level IV violation for inadequate re spi rato ry

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protection procedur (87-09) Severity Level IV violation for four examples of failure to perform an adequate whole body radiation surve (87-09)

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l Category: 2 1 Trend: Recommendations The staff noted an improvement in this area since the last SALP l assessmen The previous declining performance has been correcte C. Maintenance Analysis During this evaluation period, inspections were conducted by the resident and regional inspection staff In addition, an NRR inspection team conducted a maintenance 'si te survey of the licensee's maintenance progra The maintenance program continued to be strong. High management involvement in maintenance planning, practices, and goals were

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eviden Maintenance Department was restructured during this evaluauun period to combine this department with the Nuclear Outage and Modification Department. The Manager for Nuclear Operations Maintenance and Outages reports directly to the Director of Nuclear Plant Operation This management restructuring is discussed further in section III.H of this repor ,

The use of predictive maintenance analysis is a continuing strength of the licensee's program. This program utilizes oil and vibration analysis on mechanical equipment and infrared analysis on electrical equipment to predict degrading trends in equipment performance and thereby allow equipment to be repaired before failure occurs. This program has predicted the impending failure of a condensate pump and identified leaking oil coolers in the nuclear services closed cycle cooling pump The licensee has purchased a Motor Operated Valve Analysis and Testing System (MOVATS) to enhance testing for the operability and proper switch settings for motor operated valves and is training supervisors and electricians on the use of this equipment. Although this system was not fully implemented during this evaluation period, the resulting benefits of this program in regards to valve operability should be significan Overall control of maintenance activities was excellent. On one occasion in June 1987 prompt maintenance actions to close a stuck open pressurizer spray valve prevented a reactor tri However, two instances of inadequate control of maintenance activities were also observed. The first instance occurred in April 1986, when electricians inadvertently started the emergency diesel generator while performing a surveillance tes The second occurred in May 1987, when main feedwater pump pressure gauge instrument lines were vented with the main feedwater pump in automatic control. This action resulted in a plant feedwater transient and required prompt operator action to prevent a reactor tri First line supervisors and maintenance personnel generally indicated a high awareness for procedural adherence. However, during this assessment period, one violation listed below, one example listed in the operations section, and one example listed in the surveillance section identified a weakness in the area of procedure adherence and one violation listed below involved procedure adequacy. Tne licensee is continuing efforts to improve maintenance procedures and preventive maintenance (PM)

procedures. The adequacy of the PM procedures has been a weak area. When the licensee was made aware of this weakness, a program was developed to review and revise the PM program procedures. They have identified 55 PM procedures that will be reviewed and revised as necessary. Half of these procedures are

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expected to be completed by the end of October 1987 and the rema.inder completed by March 1988. The progress to date has been effectiv This effort represents a good and timely response by the licensee to correct this weak area. To assist in the area of procedure adherence the licensee has instituted the use of training video When this training is fully implemented, videos of the performance of routine maintenance activities, proper health physics practices, and operation of the MOVATS system will be available for use to brief workers prior to job performanc The licensee holds various planning meetings at different departmental management levels to schedule and prepare for wor The licensee's daily planning meetings, which include representatives from all shops; security, operations, engineering, health physics, chemistry and other interested groups, is a strength to the maintenance progra Prework planning meetings or a safety meeting is held before each job is  ;

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started. After job cogletion, post-Job critiques are conducted to discuss problems encountered while performing the work and possible improvements which could be implemented to improve job performance. The operations planning department increases the effectiveness of the maintenance program by i

operations / maintenance interfac Work is . improving scheduled the in l conjunction with the performance of surveillance procedures to reduce the amount of time a component is out of servic In most areas the licensee's approach and resolution of technical issues continues to be sound. The licensee has formed task groups to develop programs for NRC and industry concerns regarding boron leakage caused corrosion on the reactor vessel and susceptible piping, and also the inspection of feedwater and related piping to determine wall thinning. These efforts have resulted in a preventive maintenance procedure for inspection of boron leakage caused corrosion which the licensee intends to implement this next refueling outage. The reliability centered maintenance program is still under development. This program utilizes machinery hi story data and the frequency at which components fail in an effort to anticipate future component failures. The licensee has 15 systems in this program and is presently improving the equipment data base to enhance computer l trending of equipment failure Another program under i development is the performance of preventive maintenance on the Integrated Control System (ICS). This program, when implemented, will include pre-operational and periodic checks of ICS components, response testing of ICS instrumentation, and calibration of the ICS control modules. When the licensee has fully implemented these programs, they should additionally I strengthen the overall maintenance program and enhance plant safet l

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Another strength of the maintenance program is the use of mockup

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facilities for workers to develop and practice good troubleshooting techniques before actually performing the wor This practice helps reduce equipment downtime during repairs, and also reduces a worker's stay time ' in radiation areas resulting in lower personnel exposur The licensee's maintenance department has been effective in increasing worker awareness of radiation protection requirements and reducing personnel exposure. The maintenance department has issued a radiological awareness policy specifying what actions-maintenance personnel and supervisors are to perform in preplanning and accomplishing radiological work. - The licensee  ;

1s also developing a training video on correct health physics practices which will be shown during preplanning meetings. The licensee's efforts have been effective in identifing and repairing radioactive gaseous and liquid leaks to reduce plant personnel exposure from these source The licensee's Station Self Assessment Program provides a mechanism for conducting scheduled tours of the plant by a team of management and craft personnel. Different areas of the plant have been assigned to separate teams for inspectio The objective is to assure that good maintenance and housekeeping conditions exist throughout the plant. The team findings are identified through work requests, prioritized and then repaire Although increasing the amount of work to be scheduled and accomplished, the benefits of this program are readily apparent in the better. maintenance service plant equipment receives and in the good general cleanliness and housekeeping conditions exhibited throughout the plan .

The licensee has implemented an INPO recommendation to provide Job Performance Manuals to workers. These manuals are designed to list all the skill, knowledge and experience requirements for i each craft position. The list includes a detailed itemization j of technical tasks, administrative functions, written ]

communication skills, and print reading skills required. The )

job requirements, as specified in the manuals, are matched to 4 the skill level of the craft personnel before assignments are made to a specific task. The primary objective of this practice is to avoid human error and minimize any maintenance rewor ,

Two violations were identifie j Severity Level IV violation for three examples of failure to implement procedures (Check valve cap studs were not lubricated, emergency feed pump testing was not stopped when high vibration levels were reached, and reactor building purge make-up fans were not shutdown when the l

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personnel and equipment hatches were open). The third example is an example of an outage violation. (86-12) Severity Level IV violation for an inadequate procedure used to verify proper nuclear instrumentation cable insulation resistance testin (86-14) Conclusion Category: 1 Trend: Recommendations Non D. Surveillance Analysis During this assessment period, inspections of surveillance activities were performed by the resident and regional inspection staf The licensee's surveillance testing and calibration control program was satisfactorily established and implemente The licensee however, exhibited problems associated with the scheduling of surveillance which resulted in violations for late performance of personnel air lock leak rate tests and not performing refueling interval surveil hnce tests at the required l frequency (violations c and d listed below). The licensee attributed the cause for these problems to an inadequate scheduling procedure which has subsequently been revise This action appears to have corrected the scheduling proble l Several violations listed below, (violations c, d, f, and k), {

and several Licensee Event Reports (LERs), identified surveillance procedures which were determined to be inadequate ])

in implementing requirements, or written poorly so es to impede I successful accomplishment of the procedure. It appears that I some of these procedure inadequacies are being caused by the l practice of having the engineering staff write and approve d surveillance procedures with little or no input from the field organizations. Lack of this input combined with the relative inexperience of the engineering staff aggravate this situatio I Several of these instances were identified by the licensee's j engineering staff which has devoted a considerable amount of j time and effort identifying and correcting these inadequacie l I

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These violations listed below, (violation a, e, and g), in conjunction with the example of surveillance procedure noncompliance in the operations section, relate to the lack of adherence to surveillance procedures. As stated previously, the procedure adherence problem'is present in all facets of facility operation, however, the lack of procedure adherence by a professional engineering staff has added considerably to the problems with the performance of surveillance. Some of these violations may have been avoided if an adequate post-test review by supervisory personnel was conducte The failure of supervisory personnel to conduct adequate post-test reviews is a weakness that has been repeatedly identified to facility management. The licensee has recently taken actions to improve these reviews but continued management cognizance in this area is neede A weakness associated with overall management of the licensee's inservice inspection and inservice testing programs was identified during this evaluation period. The licensee was cited for failure to properly implement the proposed inservice testing program (violation i listed below) and for failure to properly retain records associated with the inservice l inspections performed (violation listed in the quality controls section). Changes to the inservice inspection program were

,

found to be improperly reviewed and approved by plant personnel I (violation j listed below). These findings indicate that

! management support, involvement, and contractor control in these l' programs is lacking and increased management attention is warrante Eleven violations and one deviation were identifie Severity Level IV violation for failure to perform visual inspection of auxiliary building ventilation HEPA filters during surveillance testin (86-23) Severity Level IV violation for an inadequate procedure used to calculate the allowable shutdown margi (86-38) Severity Level IV violation for failure to meet I surveillance test interval time (86-38)

l Severity Level IV violation for failure to meet containment I leak rate testing requirements (86-38) Severity Level IV violation for three examples of failure l to implement procedures (release flow monitor was not l checked prior to initiating a Waste Gas Decay Tank release,

! no warning signs were posted on Containment Air Lock during performance testing and plant heatup calculations were l

l l

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performed incorrectly). The first example is an example of an operations violatio (87-01) Severity Level IV violation for failure to perform monthly channel checks on post accident monitoring instrumentatio (87-10) Severity Level IV violation for five examples of failure to follow procedures (Control Complex air compressor maintenance exceeded work instructions, an Emergency Diesel Generator (EDG) room fan control switch was in the incorrect position, sample line leak rate test was performed out of sequence, radiation monitoring instrumentation functional test was performed out of sequence, and reactor coolant system water inventory balance was performed incorrectly). The first example is an example of a maintenance violation. (87-12) Severity Level IV violation for failure to perform an operability check on 120 volt AC transforme (87-17)

i Severity Level IV violation for improper implementation of the inservice test progra (87-17) Severity Level IV violation for inadequate review of the inservice inspection progra (87-17) Severity Level IV violation for incorrect setting of the anticipatory reactor trip set point (87-19) Deviation for failure to revise clearance order forms for a surveillance procedur (86-23) Conclusion Category: 3 Trend: Recommendations The Board recognizes that the findings in this area indicate that mangement support, involvement, and engineering contractor control is lackin Increased managment attention is warranted to improve performance in this are Fire Protection l Analysis During this assessment period routine inspections were c,onducted by the regional and resident inspection staff to review the l

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11censee's implementation of the fire protection program and to j follow-up on previously identified fire protection and ;

safe- cutdown issues from an Appendix.R team inspection made in .

. August 198 The . licensee has. issued revisions to procedures for the .,

'

administrative. control of fire hazards- within the plant, surveillance and maintenance of'the fire protection. systems and I equipment, and organization and training of the ' plant fire brigade. These procedures were reviewed .during the staf '

inspections and found to meet NRC requirements and guideline The staff's inspections also reviewed the licensee's implementation. of the fire prevention administrative control General housekeeping and; control of combustible and flammable materials in safety-related plant areas were found to . be satisfactor The fire protection extinguishing systems, fire detection systems and fire barrier assemblies protecting plant systems required for safe shutdown were found to be functiona In addition, the surveillance inspections, tests, and maintenance instructions for the plant fire protection systems

-

were found satisfactory and met the criteria of the plant !

technical specification The . licensee's fire brigade organization staffing and training was evaluated during the assessment period. The organization and staffing of the plant fire brigade meet NRC guidelines. The training and ' drills for the brigade members met the frequency specified by the procedures and NRC guidelines except, . late in the SALP period, it was identified that several members of the fire brigade had not completed all required quarterly-requalification training for the purpose of qualifying for on-shift fire brigade dut During this ascessment period, the inspection staff reviewed the annual fire prv._.ition/ protection QA fire protection audit These audits were conducted within the specified frequency and appeared to cover all of the essential elements of the fire protection progra The licensee had implemented corrective actions on the discrepancies identified by these audit As a result of the outstanding issues from the 1985 Appendix R inspection, the licensee implemented plant modifications which resolved the separation barrier concerns associated with redundant hot standby systems, inadequate fire hose stations, incomplete review of emergency lighting and communications for remote safe plant shutdown, and incomplete operator procedures and training for safe plant shutdown in the event of a fir These items have been completed and resolved during this assessment perio _

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The licensee's completion of their Appendix R modifications was timely and consistent with their schedular commitment The management involvement and control in assuring quality in the fire protection was adequate as evidenced by their successful completion of work required to close out open fire. protective issue Based on results of the followup inspections during this period, the licensee's present fire protection program has adequately addressed those Appendix R issues-identified from the 1 1985 Appendix R inspectio The fire protection staff positions are identified and authorities and responsibilities are clearly defined. Personnel l holding these positions are well qualified for their assigned dutie The' licensee has a limited staff supplemented by outside consultants and frequent overtime was required to i accomplish work activitie However, some improvement has been seen during the assessment period with the hiring of one technical staff member and the proposed establishment of an additional permanent positio One violation and one deviation was identified:

(a) Severity Level V violation for failure to implement a fire protection training procedure requirement for all fire brigade members to complete quarterly requalification training to maintain fire brigade assignment. (87-21)

(b) Deviation for failure to maintain a roving fire watch during safe shutdown system modifications. (86-12)

2. Conclusion:

Category 1 Trend:

3. Recommendations:

None

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!. . Emergency Preparedness i p Analysis l- During the assessment periodic inspections were performed by L resident and regional staf There was one inspection which addressed ' implementation of the Radiological Emergency Plan and s

. Procedures,land observation of two annual emergency preparedness l exercises. One Emergency' Plan revision was reviewe ')

L The annual emergency preparedness exercise disclosed that an l adequately staffed corporate emergency response organization routinely provided support.to the plant and that key positions in the corporate and plant emergency response organizations were filled. Corporate management was' directly involved in the 1986 and 1987. annual emergency preparedness exercises and respective critiques.

Observation and critique' of the exercises confirmed that, in general, the Emergency Plan could be effectively implemente The scenario for the 1987 exercise was challenging, and the licensee's actions demonstrated the capability to take actions to minimize public impact in the event of an . emergenc However, it was also observed that emergency training needed-improvement in several areas, in particular, medical emergency respons An exercise weakness identified during the 1986 exercise, disclosed that the medical emergency team demonstrated poor health physics practices and contamination control in preliminary treatment and management of injured personnel in preparation for transport of -same to an offsite medical

. facility. - Associated with this drill, security personnel also ,

demonstrated inadequate training in the required management of  !

response personnel within the emergency zone. A lack of adequate training of the medical emergency team was . also observed during the 1987 exercise. As a consequence, a remedial medical emergency drill, including the identified security weakness, was committed to by the license The licensee conducted this drill in an excellent manner and demonstrated that appropriate corrective action had been take Training inadequacies were also identified during the routine emergency preparedness inspection, resulting in two violations:

failure to provide periodic fire brigade training / retraining to a Senior Fire Protection Specialist and inadequate training of a communicator assigned by the Shift Supervisor to implement required notifications during an emergenc The licensee corrected these training problems by providing fire brigade and l communicator trainin The following essential elements for emergency response were

! found acceptable: emergency declaration; emergency

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classification; protective action decision making; dose projection and assessments; public information; coordination with offsite support agencies; and annual program audits. The licensee had demonstrated significant improvement in review and critiques of emergency drills and exercises, and implementing the required corrective action During the assessment period, the licensee made one change to the Emergency Plan. This change involved primarily title changes, sentence clarification, additions and/or deletions to various sections of the Emergency Plan. The changes resulted in a plan that continued to meet NRC criteri Two violations were identified; Severity Level IV violation for failure to conduct periodic retraining for the senior fire protection specialist as required by the emergency response pla (86-25) Severity Level IV violation for inadequate training of an individual to make emergency notification (86-25) Conclusion Category: 2 Trend: Improving Recommendations Non G. Security and Safeguards Analysis During the assessment period, inspections were performed by the Residert and Regional inspection staffs. Additionally, Regional and licensee managerrent met quarterly to discuss the implementation and progress of the licensee's planned improvements in the area of securit From the beginning to mid point of the assessment period the licensee continued to exhibit a failure to implement the security program as evidenced by six violations issued during this period most of which were caused by a lack of aggressive security management to identify and correct problems. One of the problems noted involved a lack of positive access control to a vital area when a guard posted at an open vital area door was found asleep. The investigation of this event led to the discovery of an additional violation in the area of access

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contro Originally the vital area door was meant to be used for a short period of tim However, the licensee had constructed a radwaste handling building and a laundry in the area, and the door was opened for routine use during normal duty hour Although the licensee had constructed a short wall around the area, positive access' controls were not in' place. As a result of this access control problem an Enforcement Conference was held and ultimately a civil penalty of $50,000 was issue The lack of management involvement was further displayed in some of the other violations of regulatory ' requirement The licensee had implemented a firearms program utilizing an unapproved method of scoring. A zone of the perimeter intrusion

- zone was not tested. during the required seven day test, which should have been noted -if management had reviewed the Closed Circuit ' Television (CCTV) testing. Additionally,. there was . an occasion when inadequate compensatory measures were implemente On a. positive note, the licensee has done some extensive work to upgrade major components of the security progra A new '

- protected area fence has been erected around most 'of the

protected area, exterior to the' existing fencing which has been redesignated as an. administrative fenc A new intrusion detection system has been installed between these fences as well as at the primary Access Portal and the system appears to be appropriately designed 'and installe The closed circuit

~ television system has been upgraded, i.e., replacing CCTVs as .l needed and installing new cables between the CCTVs and monitor i Also, new consoles and closed circuit television monitors were installed in the alarm station Recently the licensee's overall security program has shown an improving trend. Extensive efforts to improve the training and qualification of the guard force to perform routine security tasks is ongoing and the licensee is in the process of enhancing the guard force's tactical response capabilitie The annual audits of the security program are comprehensive, and provide a vehicle to identify problems, and provide corrective action guidance. There has also been a positive response to NRC findings and recommendation Corporate and site management support of the security program is exhibited by the planned security improvement program, which includes management changes, security hardware upgrades as previously discussed,. the establishment of senior corporate presence at the site to heighten the plant population awareness of security requirements, operations maintenance and security interface, and the implementation of a tracking / trending system to assist with the identification of security related problems. Additionally, j the licensee committed to greater emphasis on training, cuality l

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control, identification of the root cause of problems, as well j as a revision of the Physical Security Pla !

I t

Noteworthy was the licensee's liaison with its local law enforcement response agencies as evidenced by a well coordinated I and extensive contingency drill at the site which involved the ;

exercising of various departments in harmony with the plant's security and operations organization Late in the SALP period the licensee committed to reorganizing the security management structure, creating four positions to allow for a more effective supervision and control of the program. A new Site Nuclear Security Manager was hired in August of this yea The licensee is also rewriting its Security Pla Six violations we e identified during this evaluation period: Severity Level III violation with a $50,000 civil penalty i for:

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Failure to provide positive access control to a vital are (87-02)  ?

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Sleeping guard (87-02) Severity Level IV violation for inadequate scoring during firearms testin (86-19) Severity Level IV violation for failure to operationally i test zone of perimeter alarm syste (86-32) 3 Severity Level IV violation for failure to submit plan change. (87-02) Severity Level IV violation for failure to escort visito (87-14) Severity Level V violation for an inadequate compensatory measur (86-32)

2. Conclusion Category: 2 Trend: Recommendation l' The staff notes an improvement in this area since the last SALP assessmen Although several weaknesses, persisted at the l

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1 beginning of the SALP period, significant improvement was noted ;

during the latter part of the period. Management involvement in this area should continu H. Outages Analysis During this evaluation period, inspections of outage management and major plant modifications were performed by the resident and regional inspection staff At the beginning of this assessment period the plant was in an outage to replace th? rotating assemblies on all four reactor coolant pumps and remained in the outage until June 198 Another major, but unplanned outage was commenced in November 1986 and was completed in December 1986 when both makeup and purification letdown coolers had to be replaced due to leakag i

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Overall control and planning for major outages is a strength in this area, as is the continued use of outage planning meeting These meetings are held twice daily to schedule activities and resolve conflicts that arise during the outag The Nuclear Outage and Modification Department was restructured j to combine this department with the Maintenance Department. The '

Manager for Nuclear Operations Maintenance and Outages reports directly to the Director of Nuclear Plant Operation Consolidation of modification activities with maintenance activities under one manager should strengthen the licensee's ,

programs and provide consistency in the performance of these !

'

activities. As part of this consolidation effort, the licensee is converting the modification procedures into maintenanc ,

procedures which will then receive the additional reviews and !

controls which the maintenance procedures receive. The licensee will have this conversion completed before the next refueling outage begin ;

The overall control and planning of outages of short duration continues to also be a decided strength. Even for outages of short duration, the work is properly planned in regards to scope, repair parts and work procedure In an effort to reduce the number of noncompliance resulting from personnel not adhering to plant procedures, the licensee's general contractor (FLUOR) has implemented training on the ;

modification procedures to familiarize the workers with i procedural requirement The contractor is also trending i instances of procedure noncompliance to determine the effect of j this trainin Although a significant reduction in these instances is indicated in the outage area, the licensee's ,

efforts to achieve total compliance should continu j i

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To prepare for the upcoming refueling outage scheduled to begin l in September 1987, the licensee is conducting train ng of 4

" stepped up" supervisors. These supervisors are full time licensee employees who are temporarily upgraded to supervisory positions to oversee contractor activitie This training is intended to emphasize the importance of procedure adherence and to familiarize the new supervisors with the requirements of infrequently used procedure Documentation to verify hydrostatic pressure boundaries did not appear to be adequate for certain piping systems. This finding was considered as an other example to a violation issued for this activity by the resident inspectors as described in the surveillance section of this repor Piping systems, supports and safety-related components were routinely inspecte This work effort included review of seismic analysis for as-built safety-related piping systems (Inspection and Enforcement Bulletin, IEB79-14); safety related pipe supports, base plate designs using concrete expansion anchor bolts (IEB79-02); installation of replacement letdown cooler _

The violations (a, b, c, and d) discussed below pertain to procedure adherence and adequac The licensee's action associated with this problem is discussed in the plant operations section of this repor ..

Within these areas it was determined that the subject activities were adequately planned and performed in a safe and controlled t manne Documentation was concise and well maintainea. Qual %y h ntrol involvement in these areas was considered adequat )

Four violations and two deviations were identifie )

e

' Severity Level IV violation for failure to have rpent fuel

'

'

pool missile shields properly installe (86-23) - .

\ Severity Level IV violation for failure to have an adeqiate [ ,

installation and test procedure for the containment hydrogen monitoring syste (86-23)

'I Severity Level IV violation for failure te adhere to procedures when performing a phy si cal alteration to the ,

emergency diesel generato (86-23)

'

) Severity Level IV violation for two examples of failure to conduct adequate evaluations ( a, ground on reactor protection system hot leg temperature channel and failure

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to test a temporary modification to hot leg temperature channel). (86-39) Deviation from the FSAR for the removal of a spent fuel cooling water radiation monitor. (86-39)

f .. Deviation from a violation response for failure to retest the containment hydrogen monitoring system during the next available outage. (87-01) ' Conclusion Category: 2 l

Trend: Recommendation Non Quality Programs and Administrative Controls Affecting Quality ! Analysis l During this assessment period inspections were performed by the J resident and regional inspection staff.

'?

For the purposes of this assessment, this area is defined as the q ability of the licensee to identify and correct their own problems. It encompasses all plant activities, all plant

' personnel, as well as those corporate functions and personnel

'; that provide services to the plan The plant and corporate

'

, Quality Assurance (QA) staff have responsibility for verifying

> -

quplity. The rating in this area specifically denotes results for various grouge in achieving quality as well as the QA staff M verifying that yjalit .

y ;

QA effectiveness inspections were conducted of licensee trending r indicators as the basis for a broad based assessment across 9 '

- various" performance areas. The premise of the QA program is to ensure safe and reliable plant operation and the ultimate effectiveness of the licensecT QA program can be measured by

'c examining various operational trer. ding indicator The inspection included reviewing licensee corrective actions developed to address the indicated problem area !

y/ During this assessment period there were two inspections in the area of Quality Assurance Effec:1veness. The first assessment l / fn:1uded a detailed 'eeview of two operational issues. The l ",I review concluded that in general, the Licensee's Quality 7 '

, Assurance program is fectional and the general attitude towards yi

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Quality Assurance is based on sound principles. The second

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{ review covered Operations and Maintenance, Design Control, Licensing and Commitments, and The Quality Assurance Departmen # 4-~'

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TSe overall conclusion was the licensee performance in the area lj of Quality Assurance was adequate. Weaknesses were balanced l N, . with ' strengths, though the _ trend was towards an overall j i '% .

improvment in performance. This perceived trend is reflected !

Y/ in the' trending indicator data and appears to be the result of )

jo aincreased management attention in areas of less than adequate -

,

perh;rmanc '

k l , A review was performed in the area .of QA/QC controls of I L ,

i protective coating The review of procedures, calibration

'? /

controls, audits and records indicated that these aspects of the f' coating program meet the intent of Regulatory Guide 1.54 and ANSI 101.4

[' s- The licensee has instituted several improvements to strengthen

' N this area since the previous SALP evaluation perio The k

'

licensee .has redefined specific responsibilities for quality i program commitments to delete any potential ambiguities which l

'

may have previously existe The licensee has completely revised the method used to perform quality program audits from a purely functional area based audit to one which is based on the performance of. ' the organization. This method of auditing

'

inspects a scecifit organization in all functional areas for which that organization is involve This program, which is

'

similar in technique to the inspections performed by the NRC, has been in place since January, 1987. Additional improvements

/ have been made in the' types of audits which are being performed by the license Four types of audits are presently being performed: organizational performance based audits; safety system functional audits; modification audits; and special activity (such as refueling) audits. The intent of this new approach to.the. audit process in conjunction with the use of an audit te a;n , is to identify any programmatic or significant findings wh'c'n' remained undetected in the pas To clarffy and simplify the many methods of reporting i nonconformances .which are Adentified in the quality program

'

organization, tJe1 licensee has combined approximately half of l these repory ng' ' system This streamlining of the nonconfermancq reporting systems should enhance trending of these items and help eliminate potential confusion between the

" different types of systems.

l

l/ Two of the violations listed below, (violations c and f),

l involved a failure to report certain events. The licensee has a

! very low threshold for making reports and has a good deportability recor Therefore, these violations are considered to be isolated events.

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Violations a and b involved the failure to properly implement the licensee's corrective action programs. Violation a was caused by a failure to adhere to a facility procedure and is indicative of the procedure adherence problems reflected throughout this report. Since these violations were issued, the licensee has made progress in improving their corrective action programs. With the exception of the procedure adherence issue, these violations do not reflect a programmatic problem with the corrective action system The following are some observed strengths in management controls affecting quality:

Management involvement in maintaining good general cleanliness of plant as evidenced in reduction in size of contaminated area Management attention to maintenance planning as evidenced by utilization of mock-ups to minimize personnel exposure and equipment down tim Control and planning of outages as evider:ced by performance during two major and several shorter duration outages within the SALP perio Experienced level of Health Physics, Radwaste, and Chemistry personnel is high due to low turnover and continued trainin The following are observed weaknesses in management controls affecting quality:

Adequacy of and adherence to procedures, especially in operations area, as evidenced by the number of LERs and violations attributed to these f actor Management controls of engineering contractors as evidenced by problems in the licensee ISI/IST program Surveillance program post-test review as evidenced by surveillance deficiencies due to inadequate supervi sory revie Six violations and one deviation were identified, Severity Level IV violation for failure to write a corrective action assignment on a motor operated valve I deficienc (86-14) Severity Level IV violation for inadequate corrective action on identified problems with the 230 KV switchyar (86-38)

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32 Severity Level IV violation for failure to issue an LER on unverifiable containment. leak rat (86-38) Severity Level IV violation for failure to retain inservice inspection test record (87-17) Severity Level V violation for use of a housekeeping change to revise procedures. (86-12) Severity Level V violation for a failure to make a 10 CFR 50.73 report on a design erro (86 12) Deviation for failure to submit a FSAR update on the normal operation of cooling water systems for the makeup pump (87-19) Conclusion Category: 2 Trend: Recommendation Non J. Licensing Activities Analysis During this period, the licensee has taken significant actions to improve the extent and consistency of management involvement and contro The Nuclear Vice President, despite other increased activities discussed elsewhere, appears more involved in site and licensing activities than previously. Site support management and the Manager of Licensing are either based at the site or et least spending considerably more time at the plan FPC and its senior nuclear management personnel are deeply involved in the B&W Owners Group (BWOG), the Safety and Performance Improvement Program (SPIP), and the Technical Specification Improvement Program (TSIP). Specific programs which will define and clarify the plant design basis and improve configuration control have been initiated and are underwa Results in licensing actions related to this attribute have, in general, been goo Some major issues clearly indicate a high level of management involvement (e.g., Reactor Coolant Pump (RCP) shaft crack and General Design Criteria (GDC)-4 exemption). Other matters, such as the failure of the licensee to address in a timely manner its control room habitability i commitment; to recognize the Units 1/2 sulfur dioxide (50 ) 2 )

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threat; and to submit timely surveillance extension requests for i the internals vent valves and High Pressure Injection (HPI) and l Low Pressure Injection (LPI) pumps and valves, indicate that continued management involvement would be appropriat Of issues completed or worked on heavily during this SALP period, the large majority demonstrated an adequate to good understanding of the issues involvec and resolution of those issues which is sound, timely, and conservative. Among the few exceptions was the failure to consider initially several technical issues involved in extending the operating license to 40 years. The licensee has submitted an Emergency Feedwater (EFW) reliability study. Although our review of this study is still incomplete, it appears that at least one important unreliability estimate is unrealistically lo '

In general, the licensee continues to make significant efforts to resolve issues which may arise during our review. Requests - - ,

for assistance in such matters as implementation status occasioned a timely and helpful response, although the licensee declined to provide requested meteorological data to assist in reviewing data evaluation capabilities at nuclear plant The response to our EFW reliability review effort was forthcoming and cooperative, although some requested information was not provided promptl With few exceptions, issues identified to the licensee, as illustrated in the discussion above, resulted in timely and adequate response to resolve the matters in questio The licensee continues to report and analyze operational events in a timely and adequate manne The Nuclear Regulatory Commission's (NRC) Office for Analysis and Evaluation of Operational Data (AE00) has recently completed an assessment of FPCs Licensee Event Reports (LERs) for this SALP period. The overall quality scores of the LERs are above the industry average, i.e., scores of 8.9 and 9.0 compared to the industry average score at the time of each evaluation of 7.7 and 8.6, respectivel The quality of text discussions of personnel error, safety consequences, and corrective actions has improved but were partially offset by declines in the quality of discussions of root cause, mode, mechanism, and effect and operator actions. The score for the requirement to adequately identidy failed components discussed in the text improved from the previous evaluation, but it is still considered to be deficient and should receive additional attentio The licensee has acknowledged deficiencies in previous post-trip evaluations and has indicated that more thorough analyses will be periormed on such matters with Plant Review Committee review prior to restar .

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The creation of the position of Director, Nuclear Site Support, at the plant, which reports to the Vice-President, Nuclear, resulted in four of the six positions reporting to that individual now being located at the sit Staffing appears adequate to meet the licensing demands, although the licensee continues to rely heavily on its architect / engineer and other contractors for much analysis and other engineering work. In the case of the analysis being performed by an outside contractor as part of the review of LER 87-007, the analysis has been delayed by 3 months from the original scheduled dat As evidenced by the knowledgeability of FPC's licensing staff in day-to-day interactions with the NRR staff in licensing activities, the effectiveness of training and qualification of FPC personnel in this area appears to be adequat . Conclusion Category: 2 Trend:

Recommendation Non K. Training and Qualification Effectiveness Analysi s During the evaluation period, close out inspections, in the area of training, were performed by the regional staf These inspectons encompassed a review of previous open items as well I

, as corrective actions implemented as a result of previous violation )

l During the assessment period, the licensee has made significant i improvement in the area of training through procedure upgrades, increased management attention and tighter administrative controls. Where the licensee has been previously cited for a i reduction in scope of the licensed operator requalification j training program, a revised and approved program has beer, l l reestablished. Additionally, administrative controls have been I l set in place to ensure a reduction in scope will not occur again without prior approva Overall, the licensee has made significant improvements in all facets of trainin This is evidenced by factors such as enhanced requirements for Nuclear Operator Instructor qualifications and implementation of the Nuclear Operations Training Information System (NOTIS), which provides a mechanism l

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through which training commitments, both, program wide and individual requirements, can be tracke Additional improvements include administrative- controls over the preparation and grading of licensed operator and requalification examinations and establishing a hard copy working file to ensure that . training department records are effectively managed and

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maintaine The licensee's health physics, radwaste and chemistry technician and general employee radiation protection training programs were found to be adequat The technician training program was accredited by the Institute-for Nuclear, Power Operations (INP0);

however, the licensee received this accreditation after the SALP perio Programmatically the licensee has made a strong move towards increasing the credibility of their training progra Subsequent to the SALP period all remaining training programs have received INPO accreditatio In May of 1987, *1icensed operator requalification examinations were administered at the facilit The exams were completed under the NRC's pilot requalification program whereby .the facility prepares the exam and subsequently grades it in conjunction with the NR Of the ten individuals that participated (four R0 and six SR0 candidates) all six SR0 exams were passed, three R0 exams were passed and one RO failure was recorded. In the case 'of the oral exams (four R0s and four SR0s) all eight individuals passed. Based on these results the requalification program was judged to be satisfactor During the evaluation period, 13 replacement operator examinations and I requalification retake examination were administered at the facility ~ in addition to the May 1987 examination The breakdown and results of those exams are noted below:

I reactor operator retake - 1 pass 4 senior reactor operator upgrades - 4 pass i 7 reactor operator - 6 pass, I fail 1 senior reactor operator retake - 1 pass 1 senior reactor operator requalification retake - 1 pass The success rate of the requalification program (90%) and j replacement examinations (92.3%) reflect the licensee's trend ]

toward improving the quality of training at the facilit During the assessment period a review of the management training ,

program was conducte It was determined that there exists an adequate program for management training. The program is directed by the Corporate management Development Plan and is designed to develop the skills necessary for individuals to fulfill the responsibilities of management position . _ . _ _ _ _ _ _ ___ -__ _ _ _

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The licensee appeared to be responsive to NRC initiatives, specifically in the ' area of training. This is demonstrated b the fact that the licensee has on order a plant specific simulato One violation was identifie Severity Level IV violation for failure to implement training requirement when operators received an unsatisfactory simulator performance rating. (86-21) Conclusion Category: 2 Trend: Improving Recommendations The staff noted significant improvement in the area of licensed operator training as evidenced by the high pass rate on NRC administered examinations. Continued attention to other areas of training is warrante V. SUPPORTING DATA AND SUMMARIES Licensee Activities At the beginning of the assessment period, the unit was in a maintenance outage for the replacement of reactor coolant pump shafts. The unit returned to commercial operations on June 20, 198 On November 11, 1986, the unit was taken off the line to replace a defective control rod drive stator and remained in an outage until December 24, 1986 to complete replacements of both letdown cooler The unit was again removed from service on January 2, 1987 to perform maintenance on the reactor coolant pump shaf t seals. The unit was returned to power operation on January 23, 1987. On August 1, 1987, the unit was shutdown to repair a defective control rod drive stato Power operation was resumed on August 7. On August 21, 1987, the unit entered another maintenance outage to replace a reactor coolant pump seal and remained shutdown through the end of the SALP evaluation period. Other outages included those discussed under Item V.J.-Reactor Trip Inspection Activities The routine inspection program was performed during this period, with special inspections conducted to augment the program as follows: June 23-27, 1986, in the areas of licensed operator replacement training, requalification training, general employee training and management training.

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37 August 19-25, 1986, to investigate the loss of ion exchange resin.

, September 24-26, 1986, to review the progress of security equipment upgrade efforts.

! November 17-21 and December 1-5, 1986, in the areas of licensee action on previous enforcement matters, quality assurance effectiveness, and licensee action on previously identified inspection finding . March 2-6, 1987, involved plant water chemistry and protection of the primary and secondary coolant system from corrosio . August 24 to September 4, 1987, in the areas of operational assessmen C. Investigations No major investigative activities occurred during this SALP perio D. Escalated Enforcement Actions Civil Penalties A Notice of Violation (Severity Level II, Supplement I) and Proposed Imposition of Civil Penalty (EA 86-37) for $80,000 was issued October 23, 1986, for numerous examples of failure to properly implement Operator Training Program This violation, although issued during the current SALP period, was addressed in the previous SALP analysi A Notice of Violation (Severity Level III, Supplement III)

and Proposed Impostion of Civil Penalty (EA 86-22) for

$100,000 was issued April 16, 1986, for physical security issues. FPC partially denied the violation and requested reduction of the Civil Penalty on May 30, 1986. An Order Imposir; a Civil Penalty for 550,000 was issued August 26, 198 nis violation, although issued during the current SALP period, was addressed in the previous SALP analysis, A Notice of Violation (Severity Level III, Supplement III)

and Proposed Imposition of Civil Penalty (EA 87-47) for

$50,000 was issued April 22, 1987, for access control ans sleeping guard issue . Orders An order imposing a civil monetary penalty was issued on August 26, 1986, as discussed in paragraph D.1.b. abov _ _ _ _ _ - _ _

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E. Licensing Conferences Held During Appraisal Perio June 3, 1986. Management meeting to discuss proposed changes to

' the Crystal River physical security pla . June 30, 1986, Senior Management meeting to discuss secerity issue . July 9, 1986, Management meeting to discuss SALP board assessmen . July 9, 1986, Enforcement Conference to discuss management involvement in health physics issues, out-of-specification waste gas decay tank corrective actions and operator training deficiencie . September 10, 1986, Management meeting to discuss Crystal River quarterly SALP followu . October 23, 1986, Technical meeting to discuss security plan conten . December 1,1986, Management meeting to discuss Crystal River quarterly SALP followu . February 25, 1987, Management meeting to discuss the licensee's quarterly SALP follow-up and an Enforcement Conference on security issue . May 20, 1987, Management meeting to discuss training, quality assurance and security issue F. Confirmation of Action Letters Non G. Review of Licensee Event Reports and 10 CFR 21 Reports Submitted by the Licensee During the evaluation period, 30 LERs were evaluated by the NRC staff to determine event caus The distribution of these events was as follows:

Cause NUMBER Component Failure 8 Design 2 Personnel:

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Operating Activity 3

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Maintenance Activity 2

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Test / Calibration 8

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Other 4 Other Activity 3 TOTAL 30 H. Licensing Activities NRR/ Licensee Meetings Dates RCP shaft cracks April 24, 1986 Control room. habitability June 9, 1987 Management meeting with Director, NRR July 21, 1987 EFW reliability July 30, 1987 NRR Site Visits Plant / licensing status review May 28-29, 1986 Maintenance survey November 3-7, 1986 Plant status, quarterly meeting February 5-6, 1987 EFW reliability review March 31-April 2, 1987 Quarterly meeting May 20-21, 1987 Operational safety team inspection August 24-Sept. 4, 1987 Commission Briefings None Schedular Extensions Granted ATWS implementation September 22, 1986 Reliefs Granted ISI relief (requests 220 & 230) May 27, 1987 Pump and valve IST May 29, 1987 Pump IST surveillance May 29, 1987 Exemptions Granted GDC-4 May 23, 1986 License Amendments Issued Delete snubber list May 1, 1986 Delete LER administrative requirements July 17, 1986 Admin. control of containment isolation September 16, 1986 ,

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valves Reactor trip breaker shunt trip October 3, 1986 i Fuel pool enrichment October 14, 1986 Extend surveillance in Mode 6 November 7, 1986

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Containment isolation valve LLRT January 7,1987 H.P. trip and ART Janua ry 21, 1987 EDG Cold Fast Starts February 25, 1987 OL extension March 31, 1987 EDG test April 7, 1987 PASS TS May 13, 1987 ESF corrections May 28, 1987 Enforcement Activity FUNCTIONAL NO. OF DEVIATIONS AND VIOLATIONS IN EACH AREA SEVERITY LEVEL D V IV III II I Plant Operations 7 Radiological Controls 7 Maintenance 2 Surveillance 1 11 Fire Protection 1 1 Emergency Preparedness 2 Security 1 4 1 q

~ Refueling / Outages 2 4

Training 1 Quality Programs and Administrative Controls Affecting Quality 1 2 4 TOTAL 5 4 42 1 Reactor Trips and Manual Shutdowns Two unplanned reactor trips and four manual shutdowns occurred during this evaluation period. The unplanned trips and shutdowns are listed belo . November 12, 1986, the unit was shutdown to replace a control rod drive stator and perform additional preventive maintenance j activitie j i

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' January 2, 1987, the unit was shutdown from 38 percent power due to repairs on the 1A reactor coolant pump (RCP) shaft sea Performed maintenance on the remaining three RCP seals while the plant was off-lin . July '2,1987, the reactor tripped from approximately 88 percent power due to failure of the inverter power supply to the ' A'

vital bus while the 'B' Control Rod Drive Mechanism circuit breaker was ope . July 10, 1987, the reactor tripped from approximately 64 percent power due to a failed reactor coolant pump power monitor rela . August 1,1987, the unit was shutdown due to a dropped control rod, that was caused by a failed stato . August 22, 1987, the unit was shutdown from 64 percent power to repair a reactor coolant pump sea K. Effluent Summary for Crystal River Nuclear Station 1984 1985 1986 Gaseous Effluents Fission and Activation Gases 1.96E+3 1.96E+3 2.76E+3 (1.06E+4) (9.37E+3) (8.04E+3)

Iodine and Particulate 2.08E-4 8.46E-4 1.01E-3 (9.56E-2) (9.62E-2) (4.60E-2)

Liquid Effluents Fission and Activation Products 2.32E-1 1.51E+0 8.20E-1 d

(3.27E+0) (2.59E+0) (2.11E+0)

Tritium 4.02E+2 1.75E+2 1.73E+2 (7.23E+2) (7.35E+1) (7.42E+2)

Values in parentheses are Region II averages for PWR Values are exprested in curies Dose Maximum Whole Body Dose Offsite NA* 0.115 0.0816 Maximum organ Dose Offsite NA 1.85 0.495 Values are expressed in mrem

• Not Available

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