IR 05000266/1987001
| ML20238C540 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 12/23/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20238C532 | List: |
| References | |
| 50-266-87-01, 50-266-87-1, 50-301-87-01, 50-301-87-1, NUDOCS 8712310071 | |
| Download: ML20238C540 (34) | |
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SALP 6 l u
SALP BOARD REPORT l
j U.S. NUCLEAR REGULATORY COMMISSION i
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REGION III
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE l
50-266/87001; 50-301/87001 Inspection Report No.
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. Wisconsin Electric' Power ;
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Name of Licensee Point Beach Units 1 and 2 Name of Facilit April 1, 1986 through September'30, 1987 l k
l Assessment Period l
I 8712310071 871223 '
gDR ADOCK 05000266 i 1 DCD
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s SUMMARY O F R E S U LTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 j i
I PERFORMANCE ANALYSIS............................................... 5 j Plant Operations.............................................. 5 l Radiological Controls......................................... 6 l Maintenance................................................... 8 u Survei11ance.................................................. 10 -l
! Fire Protection............................................... 11 Emergency Preparedness........................................ 12 Security....',................................................. 13 utages....................................................... 16 I, Quality Programs and Administrative Controls Affecting Quality........................................... 16 Training and Quali fication Ef festiveness. . . . . . . . . . . . . . . . . . . . . . 18 Licensing Activities.......................................... 20 SUPPORTING DATA AND SUMMARIES....................................... 23
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! Li ce ns ee Acti v i ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23
- Inspection Activities......................................... 24 Investigations and Allegations Review......................... 26' Escalated Enforcement Actions................................. 26 Licensee Conferences Held During Assessment Period............ 27 Confi rmatory Action Letters (CALs). . . . . . . . . . . . . . . . . . . . . . . . . . . . 27 Review of Licensee Event Reports and 10 CFR Part 21 Reports Submitted by the Licensee............ 28 Li cen s i ng Acti vi ti e s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29 -
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I. INTRODUCTION i
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The Systematic Assessment of Itr msee Performance (SALP) program is an integrated NRC staff effort o diect available observations and data on a periodic basis and to evi l ste licensee performance based upon this information. SALP is supplemet u to normal regulatory processes used to l ensure compliance to NRC rules o regulations.. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant construction and operatio l
An NRC SALP Board, composed of staff members listed below, met on 1 j
November 23, 1987, to review the collection of performance observations -
and data to assess the licensee performance in accordance with the "
guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor j This report is the SALP Board's assessment of the licensee's safety '
performance at the Point Beach Nuclear Power Plant for the period April 1, 1986 through September 30, 198 ,
SALP Board for Point Beach Nuclear Power Plant:
Name Title
- J. A. Hind SALP Board Chairman, Director, Division of Radiological Safety and Safeguards
- J. Chrissotimos Deputy Director, Division of Reactor Safety
- E. G. Greenman Deputy Director, Division of Reactor Projects
- W. G. Guldemond Chief, Reactor Projects. Branch 2
- R. L. Hague Senior Resident Inspector, Point Beach :
Nuclear Power Plant
- D. H. Wagner Licensing Project Manager, Point Beach .
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Nuclear Power Plant
- K. E. Perkins Director, Project Directorate III-3 R. W. DeFayette Chief, Reactor Projects, Section 2B W. L. Axelson Chief, Technical Support Staff J. W. McCormick-Barger Reactor Engineer, Technical Support Staff j R. L. Greger Chief, Facilities Radiation Protection Section R. C. Paul Specialist Inspector, Facilities Radiation Protection Section R. B. Holtzman Specialist Inspector, Radiological Effluents and Chemistry Section W. G. Snell Chief, Emergency Preparedness Section )
J. E. Foster Specialist Inspector, Emergency Preparedness Section J. R. Creed Chief, Safeguards Section B. S. Drouin Specialist Inspector, Safeguards Section J. Holmes Specialist Inspector, Fire Protection .
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T. Le Operation Engineer, NRR, Division of License Performance and Quality Evaluation
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b II. CRITERIA The licensee performance is assessed in selected functional areas depending on whether the facility is in a construction, preoperational or operating phase. Each functional area normally represents areas significant to nuclear safety and the environment, and are normal programmatic areas. 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 observation One or more of the following evaluation criteria were used in assessing each functional are . Management involvement in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Operational and Construction events (including response to, analysis of, and corrective actions for). Staffing (including management).
However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories. The definition of these performance categories is:
Category 1: Reduced NRC attention may be appropriat License 2 management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety and/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 so that satisfactory performance with respect to operational safety and/or construction quality is being achieve .
Category 3: Both NRC and licensee attention should be increase Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be strained or not effectively used, so that minimally satisfactory performance with respect to operational safety or construction is being achieve l
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Trend: The SALP Board may determine to include an assessment of the performance trend of a functional area. Normally, this performance trend is only used where both a definite trend of. performance is discernible to the Board and the Board believes that continuation of the trend may result in a change of performance leve The trend, if used, is defined as: Improving I Licensee performance was determined to be improving near the close of the assessment perio Declining Licensee performance was determined to be declining near the close i
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III. SUMMARY OF RESULTS
' Overall, the licensee's performance during this assessment period has been very good. Five functional areas maintained Category 1 ratings and ~one area (Fire Protection) improved from a Category 2 rating to a Category 1 ratin Three areas maintained a Category 2 rating. The only decline was inThis the area was of Plant Operations which declined from Category 1 to Category due in large part to weaknesses in procedures and their implementation that resulted in an increase in the number of violations (from one the last period to six this period), and an increase in reactor trip signals (from two the last period to eleven this period). Management involvement in plant activities was conservative, and responses to issues involving plant safety ,
was prompt and effective. One weak point was the slowness to address a
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long-standing NRC concern about the lack of routine procedures and the lack of specificity in non-routine procedures until events at the plant indicated a deficiency in this area. Once this became evident licensee management aggressively formulated a program to improve these procedure ". Rating Last Rating This Functional Area Period Period Plant Operations 1 2 Radiological Controls 2 1 1
' Maintenance 1 1 Surveillance 1 Fire Protection 2 Emergency Preparedness 1 1 Security 1 1 Outages Quality Programs and Administrative Controls 2 Affecting Quality 2 Training and Qualification 1 1 Effectiveness 2 Licensing Activities 2 i
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L IV. PERFORMANCE ANALYSIS
' Plant Operations i Analysis Evaluation of this functional area was based on the results of-routine inspections conducted by region and resident-based inspector Enforcement history in this area indicated a decline in performance. During this 18-month assessment period, one
Severity Level III, two Severity. Level IV, and three Severity Level V violations and one deviation were identified. A common element in the violations involved the licensee's procedures. One violation resulted from not having a procedure, one resulted from an inadequate procedure, three l resulted from failure to follow procedures, and the Severity Level III violation was a result of poor judgment on the part of seve'ral licensed personnel in the use of several different !
procedure During the previous assessment period, one Severity Level IV violation was identifie Reactor trip signals were generated on eleven occasions during l{
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the assessment period. Six resulted in rod motion: four from 100% power and two during physics testing at 2% power or les The other five reactor trip signals occurred when the reactor trip breakers were already open during hot or. cold shutdown conditions. Two of the six trips involving rod motion were
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attributable to operations personnel. One safety. injection signal was also generated in conjunction with one of the above trips; however, no water was injected because primary pressure remained above safety injection pump discharge pressur During the previous assessment period, two reactor trips and one safety injection occurre Ten events requiring submittal of licensee-event reports (LERs)
were attributable to the plant operations area. Three of those were designated as personnel error: (1) two control rods out of alignment from bank demand position by more than 7.5 inches-in conjunction with reactor power being increased to above 75%
power, which is contrary to Technical Specifications; (2) reactor trip during beginning-of-life physics testing because of. low-low water level in the "A" steam generator; and (3) plant operation with main steam isolation valves inoperable. Events 1 and 2 were of minor safety significance, but event 3 was considered significant to safety and was cited as a Severity Level III violation. This is the same number of personnel error LERs assigned in the last assessment period, although all.three during the last period were of minor safety significanc _____ _
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As a result of the Severity Level III violation that occurred near the end of the period, the licensee has committed to increase management attention to procedural compliance, ~
procedural adequacy, and personnel attitude The licensee's approach to resolution of technical issues from a safety standpoint continues to be conservative. During this assessment period, the operations group was instrumental in'
implementing the computerized history and maintenance planning system (CHAMPS) and improved the accuracy and efficiency in evaluating ASME Section XI pump and valve test result Responsiveness to NRC initiatives continued to be evident throughout the assessment period. Most notable was during the enforcement conference held on September 23, 1987, at which the licensee presented an indepth summary of the events leading to, and the extensive proposed corrective actions to prevent recurrence of, the inoperable main steam isolation valve ~
Staffing in the operations area remains above the minimum required for a six shift rotation. This has allowed the Superintendent-0perations to utilize some valuable experienced personnel in needed support activities.
i Conclusion The licensee's performance is rated Category 2 in this functional area. The licensee was rated Category I during the previous assessment period. The decline in thein licensee's licensee performance rating, was largely due to weaknesses procedures and their implementation that resulted in an increase in and significance of violations in this functional are . Board Recommendations Non Radiological Controls i Analysis Evaluation of this functional area was based on the results of five routine inspections and one special inspection performed during this assessment period by region-based inspectors, and observations by the resident inspector Enforcement history in this area indicated a decline during this assessment period; five violations were identified (two violations collectively called a Severity Level III problem, two Severity Level IVs and one Severity Level V),
compared to two violations (Severity Levels IV and V)
identified during the previous period. The violations indicated weaknesses in licensee performance, and partial programmatic breakdown _ - - -
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. I Chemistry staffing is good; however, radiation protection staffing remains a licensee weakness but is improving. A 1 i
significant reduction of Radiation Control Operator (RCO) staff I turnover has resulted in increased staff stability and experience level. The RCO trainee staff has increased; however, several of these personnel are as yet unqualified and, 3
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consequently,.the licensee has been unable to cover all shif.ts with RCOs; the licensee expects to do so in 1988. The professional health physics (HP) staff has been augmented by the addition of a former corporate Health Physicist to the plant staff as the plant Superintendent-Health Physics. .This I
should provide more technical support and administrative direction to the overall HP program. The licensee has also j initiated a corporate review of the HP program to evaluate j
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staffing levels and remuneration structur :
I Licensee management was adequate in this functional are !
Because of several recent radiological incidents, corporate involvement in programs and incident investigations appears to have' increased. As a result of these investigations and NRC concerns, several long-standing fundamental weaknesses in
' the radiation protection program, including poor staff stability, staffing shortages, lack of professionally trained health physics management on site, lack of full-time health i physics coverage, and over-reliance on auxiliary operator l
radiation protection expertise have been recognized. In l
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response to these problems the licensee initiated corrective actions during this assessment period. The licensee's' actions appear to be addressing a long-standing NRC concern with the failure to establish an onsite radiation protection organiza-tion that is professionally staffed and has status equivalent to that of other onsite operating groups. Significant i improvements were also being made to primary and secondary water chemistry control program {
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Responsiveness to NRC initiatives was generally good. As noted
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above, actions have been initiated to resolve several_long- l standing NRC concerns regarding fundamental weaknesses in the
radiation protection program. On the other hand, quality assurance / quality control (QA/QC) weaknesses were evident'in
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commit to improvement The licensee's approach to resolving technical issues has !
I generally been technically sound and timely, as noted in y the following paragraphs. This has been evidenced by the l licensee's response to, investigation of, and assessment of !
radiological incidents concerning personal exposures to hot particles, internal contamination, and a radioactive sealed {
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The licensee has continued to maintain personnel doses at a relatively low level; such performance indicates good "as low as reasonably achievable" (ALARA) performance. Activity in gaseous effluents was less than 1% of applicable annual Radiological Environmental Technical Specification (RETS)
limits. Activity in liquid effluents continued to c'ecline; tritium sampled in subsoil drains and in processed waste has, stabilized. Elevated levels of both gross activity and dose-equivalent 1-131 concentrations in primary coolant were evident because of current fuel cladding failures; corrective actions have been initiated. Slightly radioactive sludge (3% solids) from the onsite sewage treatment facility was applied without NRC authorization to licensee-owned land, and resulted in a Severity Level V violation during this assessment period. Implementation of the Radiological Environmental Monitoring Program remained satisfactor A secondary water chemistry control program consistent with the Steam Generator Owners Guidelines has been established and the quality of plant water generally improved. Procedures were also being revised for controlling the chemistry of primary system water, and a new water make-up system is being built to provide high quality water during startups. New laboratory instrumentation has been installed to greatly increase the sensitivity for determining chloride, fluoride, and sulfate in reactor coolant and secondary system wate The radiological confirmatory measurements remained essentially unchanged during this assessment period. When one of two detec-tors tested accounted for four of the six disagreements observed in 41 comparisons, the licensee took prompt and appropriate corrective action. In nonradiological confirmatory measurements, the licensee performance was somewhat weak with ten disagreements in 29 comparisons, reflecting nossible weaknesses in the QA/QC progra ' Conclusion The licensee's performance is rated Category 2 in this functional area. The licensee was rated Category 2 during the previous assessment perio . Board Recommendations Non C. Maintenance
' Analysis Evaluation of this functional area was based on the results of routine inspections conducted by the resident inspectors and one region-based inspection conducted for the closecut cf NRC Bulletin 79-0 l
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Enforcement history in this area remains excellent; no violations were identified during this assessment period or during the previous assessment perio :
Two events attributed to activities in this area required the submittal of LERs. Neither of the events involved personnel error. This is an improvement over the previous assessmen period during which two personnel error LERs were assigned to the maintenance are It was evident that management was effectively controlling contractors; this was expressed as a concern in the last assessment period. No significant events involving contractors occurred during this assessment perio Significant achievements during the assessment period include:
modification of Unit I resistant temperature detector manifolds to remove problem valves which should significantly reduce exposures to plant personnel; replacement of instrument air compressors and system modification for improved capabilities and redundancy; development of a motor-operated valve thrust measure <nent system; replacement of condenser tubes and feedwater heater tubes to remove all copper bearing material from the feed system; and continued very low forced outage rates, 0.24% for Unit 1 and 1.92% for Unit i i
The maintenance group has continued to develop and improve procedures and preventive maintenance task sheets. A program !
to detect secondary-side pipe erosion was already in effect {
before the December 9, 1986, Surry event. After that event, j the program was expanded to include single phase flow sections l of the secondary plant. Management involvement in maintenance activities continues to be evidenced by work site tours by all l 1evels of maintenance supervisory personne l The Maintenance group response to NRC initiatives has been aggressive, as evidenced by its timely attention and resolution l
of potential problems outlined in information notices, bulletins and generic letters. Resolution of technical issues from a safety standpoint has been evidenced by the above mentioned programs and modifications which were implemented to improve both plant and personnel safety. Maintenance work requests and modification requests on safety-related systems are given top priority.
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Staffing remained very stable during the assessment perio One individual was lost due to retirement and four new individuals were added to the maintenance staff. The low turnover and high level of experience continues to be one of the strong points of this functional are . Conclusion The licensee's performance is rated Category 1 in this '
functional area. The licensee was rated Category 1 in this area during the previous assessment perio ,
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. Board Recommendations Non ;
D. Surveillance q
. Analysis Evaluation of this functional area was based on the results of routine inspections conducted by the resident inspectors, one special and two routine inspections of inservice inspection (ISI)
activities, and two containment integrated leak rate test (CILRT)
inspections by regional inspector Enforcement history remains good; one. Severity Level'IV '
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I violation was identified during this assessment period and l one Severity Level V violation was identified in the. previous assessment period. The violation cited during this period was .
against, activities the licensee conducted in 198 !
J Two LERs attributable to pernnnel error were reported during this period: (1) a technician tripped'an' incorrect breaker causing a reactor trip, and (2) an engineer incorrectly connected test leads causing 22 control rods to drop, followed by the insertion of a manual reactor trip. One LER attributable to personnel error was submitted during,the previous assessment period.
l Significant improvements in this area include: upgrading of I CILRT sensors, wiring, and data processing systems; procurement of an ultrasonic fuel assembly inspection system; utilization I of state-of-the-art robotics and detection techniques for the 10-year reactor vessel ISI examinations; replacement of several j
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power-range detectors; institution of biweekly instrument bus waveform plotting and analysis for early detection of inverter problems; installation of new neutron flux detectors to meet Appendix R and environmental qualification requirements; and l
I development of an expanded inspection program to detect secondary-side erosion. These improvements indicate management involvement and a commitment to using surveillance as a tool to help maintain the safe operation and high availability.of the unit Areas identified in the last assessment period to be considered for possible improvements in the technical program have been j addressed by the licensee and improvements have been made or are i being planned. The licensee also responded to NRC initiatives !
during the assessment period by meeting with NRR on three occasions to alleviate concerns or provide more details on j programs or modifications affecting' surveillance requiring NRC approval. All of the meetings were productive in. resolving the issues of discussion. The strong point of the surveillance program remains the quality of communication and cooperation between the groups performing surveillance and the control-
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room. Testing continues to be performed by well trained and knowledge 1ble individuals with no routine surveillance missed during the assessment perio ; Conclusion .
The licensee's performance is rated Category 1 in this functional area. The licensee was rated Category 1 during the previous assessment perio . Board Recommendations i
Non E. Fire protection Analysis Evaluation of this functional area was based on the results of routine. inspections conducted by the resident inspectors and one l special inspection performed by NRR, a region based inspector, l and consultants to determine the adequacy of the facility's post-fire, safe-shutdown methods and to review the licensee's routine fire protection program.
i Enforcement history in this functional area' remains excellent; no violations were identified in this assessment period and no violations were identified in the previous assessment perio There were also no LERs assigned to this area in either assessment period.
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technical issues appeared to be geod. For example, in the audit i review of the coordination (time-overcurrent) curves, the program was found to be comprehensive'and also satisfactorily documented. Other analyses such as the licensee's protection for common enclosures, associated circuit concerns, control of high/ low pressure interfaces, and the component cooling water !
pump area sprinkler system were satisfactory. The licensee I
provided the inspector with sound technical solutions. The licensee also demonstrated willingness and assertiveness to address NRC concern In the walkdown of control room inaccessibility procedure AOP-10A, the operator exhibited good familiarity with the procedure steps i
and equipment and responded well to unrehearsed postulated I occurrences submitted by the inspection team. In addition to a 4 l procedural review and walkdown, the team reviewed operator j l training at Point Beach with the licensee's training coordinato The lesson plans and training records were examined and found to be satisfactor .
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The licensee staff's responsiveness to NRC initiatives was generally very good. Considering the complexity of the generic concerns discussed during the special NRR/ Region team; inspection, the licensee's staff demonstrated excellent knowledge of the issues and presented sound engineering evaluations for resolutio Management involvement in this functional area continues to be evident. Housekeeping has continued to improve; most recently, an extensive painting effort was initiated in the auxiliary
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buildin The licensee maintains an aggressive attitude toward minimizing combustibles in all parts of the site. Significant work activities including grinding and welding were performed during this assessment period without incident. The fire brigade staffing remains at full complement with annual requalification conducted at Waukesha County Technical Institut . Conclusion l
The licensee's performance is rated Category 1 in this functional area. The licensee was rated Category.2 during the previous assessment period. Licensee performance improved as a result of increased management involvement, willingness and assertiveness to address NRC concerns, and excellent engineering evaluations of fire protection issue l Board Recommendations
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Evaluation of this functional area.was based on four inspections l conducted by region-based inspectors during this assessment l
period, including observation of the 1986 and 1987 annual I emergency preparedness exercise !
Enforcement history improved during this assessment period; no violations were identified. One Severity Level IV violation '
was identified during the previous assessment period. No significant concerns were identified during the routine inspection The 1986 and 1987 emergency exercises were considered challenging, ,
and each adequately exercised all aspects of the Emergency Pla l
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Several Exercise Weaknesses were identified during each exercise: five in the 1986 exercise, and three in the 1987 exercise. For example, the 1986 exercise resulted in the
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finding that the Operations Support Center lacked procedures, 1 and the 1987 exercise indicated that the Emergency Operations j s
Facility was understaffed, overburdening the Radeon/ Waste Manager and Assistant Radeon/ Waste Manager. None of the ]
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weaknesses were considered sufficiently significant to require a remedial exercise, but they indicated a need for more attention to overall' program detail in several area Management involvement in assuring quality'in this area has been good, as evidenced by corporate and plant management's participation in exit meetings following each inspection and as evaluators during exercises. Use of management personnel as exercise evaluators has provided insight into exercise problem The licensee has been responsive to identified NRC concerns ) '
by providing viable and thorough responses. When resolving
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weaknesses from a safety standpoint, the licensee demonstrated a good understanding of the issues involve Staffing of emergency response positions'has been generally, )
adequate, with the exception of understaffing in the Emergency l Operations Facility, identified during the 1987 exercis .l The authorities and responsibilities of emergency response personnel have been well identified. Knowledge and capability
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l to carry out emergency response' duties and responsibilities was demonstrated during the annual emergency preparedness exercises, as well as in walkthroughs during routine inspections. This indicated that the licensee's training program had adequately prepared personnel for their l
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assignment > Conclusion
Licensee performance is rated Category 2 in this area. The licensee was rated Category 2 in the previous assessment period. '( Board Recommendations Non G. Security Analysis Evaluation of this functional area was based on the results of three routine inspections and one special-security inspection-conducted by region-based physical security inspectors and on the observations of the resident inspectors as part of their routine inspection program. One additional special inspection was conducted at the beginning of the evaluation period (April'
1986) for a security event that occurred in March 1986. :The results of that inspection were included in the SALP 5 report and therefore will not be considered in this evaluatio l 13 ,
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A decline in the licensee's enforcement history was noted during this assessment period. One Severity Level III, one Severity Level IV, and one Severity Level V violations were 1 identified, compared with one Severity Level III and one ]
J Severity Level IV violations identified during the previous assessment period. The two more-significant violations l
involved the unauthorized accessing of a security door,'and the f ailure to report two similar events in January 1985. The 'i '
failure to report the two similar events resulted from an incorrect interpretation of " properly compensated" in the licensee's reporting procedure.i The procedure was revised in June 1986 and resulted in the t/mely reporting of the improperly accessed door event dJuly 1986).
The violations were promptly and thoroughly corrected. The violations identified had no direct safety significance, 3 although they did indicate that licensee management was 'j inattentive to detail at the beginning of the period. .This <
inattentiveness was noted as a declining trend in the last l assessment period. The licensee addressed all' aspects of the l
security program with the appropriate level of pttention for the remainder of the perio / ,
Management support in assuring qual ky w p exc'ellent after September 1986. Before that time, ma n glement was not as ,
attentive to the more routine aspectb of th+ security program,- l such as false-alarm rates, maintenance of proter.9 d area barriers, and effectiveness of the closed-circ W etelevision (CCTV) system. Managementrefocuseditsenergi@indimproved in the identified areas significantly over the enainde'r of the evaluation period. Quality in the security progEam was enhanced by the addition of state-of-the-art explosive detectors and by ;
other licensee initiatives such as new equipmenthraini,ng for
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the special reaction security team. During the entire period, management continued its support to'an excellent security ,
i training program and the stringent control of access involving vital atea personnel. In. addition, the licensee is.in the process of budgeting for a new security computer and further ~,
improvements to the alarm systms. Management support at both 1 i
corporate and site-level is a major factor'in the success of the security progra The licensee's approach to resolving technical . issues is goo The licensee's solution to improperly accessed security doors demonstrated a sound grasp of the underlying security issue The corrective action involvedpeytly developed training and procedures as well as a computRbrdware "fix." All solutions have been timely and comp'ehensiv' ,
The licensee's responsiveness to NRC initiatives was excellen The licensee effected the previously mentioned significant l l
improvements in the routine npe.sts; of the security program to
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address all inspector concerns.' The licensee is planning .
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additional improvements, such as backup intrusion detection systems for the vital and protected areas. These improvements which were based on the licemee's analysis of the security I program, represent significant enhancements to the system's overall effectivenes The licensee's program for reporting security events is exce'llen During this assessment period. .the licensee reported' ten security events,whichrepresentedasignificantincreaseoverthetwo'}
reports initiated in the previous period. The licensee revised ' z its reporting procedure in June 1986 and now employs a more J T
comervetive approach in the analysis of security events. Tht:.
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rehlted in a corresponding irecrease in reporting. Seven of the
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t rt reports dealt with computer failures directly or indirectl '
r 6 ted to lightning strikes. All reports were timely and dt: urate. Followup reports were comprehensive and technically ,
shJnd.' The licensee ensured that the NRC was well informed about q
security-related matter ,
Staffinh4 appropriate. The chain of command is well established j
and procedures for succession of command are well known. The licensee identified a need for a security training coordinato An individual hep bee.n appointed to coordinate the new security training requirements with the Fox Valley Technical College (FVTC) instructors. The new position has resulted in a security force training program that is more responsive to the licensee's .j security need The security force training program continues to be innovative, professionally administered, and technically competent. FVTC !
ensures that instructional material is timely and relevan l iThe licensee uses the NRC-approved weapons qualification and combat course; which conditions officer responses to attacks (it the site. Security force personnel are well motivated and technically competen j j Conclusion The licensee's performance is rated Category 1 in this are The licensee was rated Category 1 during the previous assessment "
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i Board Recommendations
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. Outaces i Analysis ;
Evaluation of this functional area was based on the results of routine inspections conducted by regional u d resident inspector Enforcement history in this area is good. No violations were {
identified during this assessment period. One Severity Level .
IV violation was identified in the last asseswent perio l t
i Tao !!r,it I and one Unit 2 refueling outages were conducted during this assessment period. Major accomplishments included: )
instil?ation cf nozzle d.tms in steam guertters; upflow {
modifications to reactor ber,sels to eliminate baffle jetting; l incorporation of ultrasonic fuel assembly ~ inspections; l
l rnodificatinn to the temponent coolir.g hut achanger, replacing the three original heat exchangers and adding a fourth; and modific) tion to the mo0.,ture preseparator, helping to minimize secc 'y-side erosion. Most of these major modifications were completed as 5cheduled. The first upflow modification was not completed on stbedule because Westinghouse experienced some tooling problem j Management contimws to be involved, and cognizant engineers monitor bcth contractor and in-house evolutions. Outage 1 l
activities continue to be controlled through the use of major item work list meetirigs, held three times a week, each generating a revised target completion date schedule. The inspectors routinely observed operational readiness testing i
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which is performed after maintenance and/or system outg e I This testing continues to be accomplished satisfactorily indicating that the systems were properly niaintained and ready to perform their safety functions. Well-trained individuals ,
performed refueling activities in a professional manne , Conclusio i The Itcensee's performance is rated Category 1 in this functior;al area. The licensee was rated Category 1 curing 1 the previous assess'nent perio . Scar _d __ Recommendations Non . Quaitty Programs and Administrative Controls Affd tinj Quality 1 AnalyQq The ' evaluation of this area addresses tw related but sentate functions. First, it assesses the licensie's management i
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activities aimed at achieving quality in overall pMnt'
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operations. This assessment in great measure is a reflection of the quality of. licensee activities'in individual functional areas addressed in other sections of this report. Secondly, this section assesses the licensee's internal, independent quality oversight . activities such as those performed by the quality control / quality assurance organization With respect to the evaluation of management's effectiveness in achieving high' quality in the overall operation of the facility, a wide range of subjective and objective performance measures and compliance history in all the functional areas was assessed. The evaluation revealed that over the last several. assessment periods, licensee management's approach to ,
'
this end has been conservative, methodical, and innovative, although not necessarily timely in all cases. -Traditionally, the licensee's management has responded promptly and effectively j '
to issues involving plant safety, while issues of perceived minor safety significance or of a policy nature receive less ^
attent, ion and resources. Specifically, although staffing an experience in the health physics area had been a long-standing NRC concern, progress to resolve this issue was slow until indepth analysis of events at the plant indicated that lack of .
experience may have been a root cause. This prompted an accelerated program.to rectify this long-standing concer Another concern expressed by the NRC over the past several assessment periods was the lack of routine procedures and the lack of specificity in.non-routine procedures. This concern received little licensee attention until events at the plant indicated ~a deficiency in this area, after which the licensee's management was aggressive in formulating a solutio The licensee's management has for many years been committed to maintaining a small, high quality staff. This commitment has required the prioritization of concerns with those of obvious safety significance receiving the majority of licensee's resources. As events disclose the significance of other issues, they immediately receive appropriate attentio With respect to evaluation of the licensee's internal and
' independent quality oversight activities, results of routine inspections by the resident inspectors and four inspections by regional inspectors were considere Enforcement history in this area has improved during.this assessment period; no violations were 'dentified. Two Severity Level IV violations were identified during the previous assessment period. No LERs were assigned to this. functional-area in either assessment perio During the early part of this assessment period, management genera'11y showed evidence of prior planning and assignment of
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priorities with defined procedures for controlling most .
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activities; however, control of receiving inspection procedure preparations was neglected. An unresolved item from a- 1983 inspection, related to this area, was not closed because the licensee had not established a target completion date and had not completed the work to satisfy the procurement program deficiency. This item was subsequently closed in March 1987)
In other areas of activity, there were' adequately stated and understood policies and procedures. Records were generally .I well maintained and availabl Site personnel sppeared to have a great deal of interest in and concern for the appropriate resolution of technical issues associated with QA program commitments and administrative !
controls. Most issues were resolved in a timely and thorough manner, except for the one issue related to procurement / receiving inspection (notedabove).
The approach used to resolve a snubber design deficiency, the indications identified during the nondestructive examinations on the balance-of plant piping, and the repairs and/or modifications performed on all deficient installations to bring them up to NRC Bulletin 79-02 requirements were conservatively conceived and technically sound. Recent changes to the 50.59 procedure, event reporting guidelines, and the licensee's self-initiate safety system functional inspection (SSFI) are also evidence of this conservative approac The licensee responded in a timely manner to NRC initiative Resolutions and actions taken on most of the previous inspection findings were generally acceptable. The licensee responded aggressively to the information notice that was issued to alert licensees to a potentially generic problem involving feedwater pipe thinnin . Conclusion The licensee's performance is rated Category'2 in this functional area. The licensee was rated Category 2 during the previous assessment perio . Board Recommendations Non Training and Qualification Effectiveness , Analysis Evaluation of this functional area was based on the results of licensed operator replacement examinations, a pilot ;
program observation of a utility-administered requalification i
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examination, and a region-based inspection that focused on the- )
effectiveness of the licensee's training and qualifications progra ;
Enforcement history in this area indicated conformance with applicable regulatory requirements. No violations or deviations were identified during this assessment perio ,
Management involvement in ensuring quality in this functional o area was very geod. During the assessment period, NRC-examinations were administered to five reactor operator ]
candidates and one senior reactor operator candidate; all
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candidates passed. This pass rate was identical to that found during the previous SALP period. The examiners identified some weaknesses in the area of rod control radiation limits, and
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theory; and strengths were found in the use of procedures in the examination process and-in knowledge of plant areas outside the control room. On the basis of observation of the. utility '
administered requalification examination, which all seven candidates passed, the requalification program was found to be effective. This was based on the content of the examination questions and the close agreement between facility and NRC grading of the examination From a safety point of view, the. licensee's approach to resolving technical issues has also been very good. The training program utilized a "needs" analysis system.to ensure that lessons learned from events occurring-at Point Beach and other plants throughout the industry were factored into the continuing and initial training programs. On the basis of.the results of the needs analysis, lesson plans were developed for inclusion into the specific training provided to each disciplin As a result, personnel were found to be very knowledgeable about their duties, and an analysis of operational events did not indicate inadequate training as a contributing caus Training and qualification of inspection personnel improved during this assessment period and all personnel performing activities affecting quality were completely trained in a four-month period. .The program was well defined and was
' implemented in an effective manner. Offsite support staf were qualified in accordance with commitments and requirement The licensee-had received Institute of Nuclear Power Operations (INPO) accreditation for the following five areas: Senior Reactor Operator, Reactor Operator, Shift Technical Advisor, non-licensed Operator, and Radiological Protection Technicia The. remaining five programs were evaluated by an INP0 site team ;
during July 1987, and final accreditation is expecte )
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. Conclusion The. licensee is rated Category 1 in this functional are The licensee was rated Category 1 in this area during the last assessment perio . Board Recommendations ,
Non Licensing Activities Analysis The basis for this assessment was the licensee's performance.in support of licensing actions (amendment requests, responses to generic letters, and other actions) which have been. reviewed-and evaluated by the staff during the rating period. These actions have resulted in 18 license amendments,1a relief-request, an exemption to 10 CFR Part 50, Appendix R, and other licensing. action During this rating period, the licensee's management appeared to be actively involved in licensing activities and appeared to remain abreast of current and. anticipated. licensing action Management involvement in licensing actions-has resulted in timely responses to staff initiatives requiring responses by specified dates. These submittals,.such as responses to generic letters and responses to staff' questions regarding generic issues, are of good quality and sufficiently complet Although the majority of applications for specific actions (TS amendments, plant-specific licensee issues) are of good quality.-
are submitted in a timely fashion, and do not require significant rework to address staff requirements, a number of notable exceptions exis For example, late in this assessment period the licensee sought NRR approval for the land-spread disposal of slightly radioactive sludge. Although the licensee considered this a high priority-
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issue, the staff was required to' issue'an extensive request for additional information to the licensee in order to continue the review. The licensee's original application was incomplete,.
despite the staff _'s referring the licensee to another utility's similar request for land-spread disposal. of radioactive sludge as an example of a complete applicatio Additionally, in a. letter dated September 10,-1987, the licensee sought NRC authorization for replacing a number of snubbers with 3 energy absorbers during the Unit 2 outage, commencing October 2, j 1987. The licensee should have had full knowledge of the lead time NRC .eeded for this type ofureview because earlier, the-staff performed a lengthy review authorizing'use of: energy.,
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absorbers at Point Beac At that time, the staff stressed that the review was not only plant specific, but also component specific because it relied on non-linear analysis as technical
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justificatio Although most of the licensee's submittals to the NRC are j complete and timely, the licensee and its management should exert more effort to ensure that all licensing action applications are complete and timel The technical content of license action applications and responses to requests for additional information are generally ,
quite good. However, as noted above, some incomplete actions have been submitted. In most cases, the NRC requests additional information because material submitted is incomplete rather than because of the quality of the technical content provide I The analysis for "no significant hazards" considerations is ~
somewhat " threadbare" and relies, in some cases, too heavily on similar applications made at other plant j
' l During this rating period, a number of telephone conferences and i
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meetings have taken place between the licensee and NRC staf The licensee has ensured that the appropriate corporate / station !
personnel were available to discuss-the issues. For example, !
l during the Unit I refueling outage in the spring of 1987, in response to a UT (Ultrasonic Test) indication of a problem in the reactor pressure vessel, on a day's notice, the licensee flew to NRC-Bethesda to meet on Saturday with the staff, in anticipation of restart the next day. The licensee brought along sufficient personnel to ensure that the issue would be adequately addresse The LERs submitted during the rating period were of good qualit Overall quality of the LERs has increased since the last SAL Improvement was noted in the safety assessment section of the i LERs. A particular strength of the LERs is that the licensee !
identifies similar events that may have been reported in previous LER However, a number of LERs lacked certain information considered necessary to complete a root-cause discussion. For example, stating that a specific component failed and was replaced is not adequate to satisfy the requirements concerning cause and corrective actions. The reason for component failure must be stated, thereby allowing assessment of the causal relationship and determination of generic implication Those comments are similar to those which have been made on previous Point Beach SALPs. We notice that there is variety in the quality of the licensing actions submitted for NRC revie Although we believe the licensee is capable of excellent work in all licensing actions, the licensee is not consistently !
performing at this leve _ _ -
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2. Conclusion The licensee is rated Category 2 in this functional are The licensee was rated Category 2 during the previous assessment perio . Board Recommendations l
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i V. SUPPORTING DATA AND SUMMARIES Licensee Activities . Unit 1 Point Beach Unit 1 began this assessment in preparation for refueling outage No. 13 scheduled to begin on April 11, 198 One other refueling outage occurred between April 4 and June 7, 1987. During the remaining months of the SALP assessment period, Unit I engaged in routine full power operation for extended periods of time. Unit 1 experienced three engineered safety feature (ESF) actuations, four reactor scrams (two at > 15%
power, two at < 15% power (one with no rod movement). The average plant availability during the assessment. period was approximately 82%. Significant outages / major events occurring during the assessment period are summarized below:
Significant Outages / Major Events Ap'ril 11 - May 18, 1986, Unit 1 was shut down to perform annual refueling and maintenance outage No. 13. Major activities included replacing the condenser tubes and feedwater heaters, performing EQ pressurizer safety valve position indication tests, and installation of a new compute July 12-13, 1986, Unit I was shut down to investigate the cause of abnormal noise noted in the Unit 1A moisture separator reheater. The moisture separator reheater and the baffle plate welds were repaire November 17-18, 1986, Unit I tripped from 100% power and remained down so an instrument bus could be repaire April 4 - June 7, 1987, Unit I was shut down to perform annual refueling and maintenance outage No. 14. Major activities included containment integrated leak rate tests, reactor vessel internal modifications, and a ten year ISI of the Unit I reactor vesse July 18,1987, Unit I was shut down for a short maintenance outage to repair a steam leak on a root valve for the-lower level tap of the steam generator level instrumentatio . Unit 2 During this assessment period, Point Beach Unit 2 engaged in routine full power operation for extended periods of time until it began routine refueling and maintenance outage No. 12, on September 27, 1987. Unit 2 experienced three (ESF) actuations, and seven reactor scrams (two at > 15% power, five at < 15%
power,(fourwithnorodmovement}. The average plant
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availability during the assessment period was approximately 87%.
Significant outages / major events that occurred during the
assessment period are summarized below:
Significant Outages / Major Events I July 3-4,1986, Unit 2 was shut down to repair one of t.he
"A" loop reactor coolant flow transmitters, l September 27 - November 14, 1986, Unit 2 was shut down to l j perform refueling and maintenance outage No. 12. Major activities included flow work to the core barrel, integrated i leak rate testing, steam generator nozzle dam installation,
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and steam generator eddy current testin March 7-8,1987, Unit 2 was shut down to perform scheduled maintenance on the "A" moisture separator reheater, and to .l repair the "A" and "B" main feed regulating valve .j i May 14-17, 1987, Unit 2 was shut down for secondary ;
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chemical cleanup necessitated by the unacceptably high !
amount of sodium introduced to the secondary system resulting from the failures in the blowdown evaporator reboile l August 16-18, 1987, Unit 2 was shut down to repair and test a transformer after it was struck by lightnin Inspection Activities
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There were 38 inspection reports issued covering this assessment period, April 1, 1986 through September 30, 198 ! Major or significant inspection activities are listed in Paragraph 2 of this section, "Special Inspection Summary." Inspection Data
'j Facility Name: Point Beach Unit: 1 Docket No: 50-266 Inspection Report Nos: 86001, 86005 through 86021, and 87002 through 8701 l Facility Name: Point Beach Unit: 2 Docket No: 50-301 Inspection Report Nos: 86001', 86005 through 86021, and 87002 through 8701 ;
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Table 1
Number of Violations in Each Severity Level UNIT 1 UNI COMMON TO {
BOTH '
{
i Functional Areas III IV V III IV V III IV V DEV 13 j Plant Operations 1 1 1
_' Radiological Controls 1 2 -I Maintenance l Surveillance 1 l Fire Protection I Emergency Preparedness l Security 2* 2* 1 Outages Quality Programs, and Administrative Controls Affecting Quality Training & Qualification Effectiveness Licensing Activities
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TOTALS 2 1 3 5 5 1 l
l *0ne Severity Level III and.one Severity Level IV violations in the security area were identified during this assessment period but discussed in the SALP 5 report.
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. Special Inspection Summary September 8-11, 1986, emergency preparedness exercise:was conducted (266/86018, 301/86017).
September 14-17, 1987, emergency preparedness exercise was conducted (266/87018; 301/87018).
C. Investigation and Allegations Review During this assessment period, the region received two allegations relating to the Point Beach Nuclear Power Station; these allegations were closed during the assessment perio D. Escalated Enforcement Actions A physical security inspection of licensee activities was conducted during April 1986. During that time, enforcement actions were considered for the degradation of a vital area barrier which could have allowed unauthorized and undetected ,
access into the vital area. After this potential Severity i Level III violation was reviewed, the staff decided not to issue a violation because (a) the licensee had identified the problem itself and (b) the licensee had a record of good performance in the security area [SALP 5, Category 1 Rating (Ref: Inspection Report Nos. 266/86005;301/86005)]. However, after a special physical security inspection of licensee activities during July 18 through August 17, 1986, similar violations involving the degradation of vital area barriers were again id(ntified. These actions resulted in the issuance of an Order Imposing Civil Penalties for a Severity Level III Violation in the amount of $50,000 (Ref: Inspection Report Nos. 266/86012, 301/86011 and Enforcement Action Case No.86-148). An escalated enforcement case involving open main steam 1 901ation valves (MSIVs) and related inoperable channels was investigated during the assessment period. The causes that led to this Severity Level III violation were external and personnel errors (i.e , lightning struck a transformer and personnel failed to properly clear red tags and to follow red J tag procedures, adding to the incident). An enforcement board i met on September 3, 1987, to discuss this matter and an l enforcement conference was held with the licensee on September 23, i 1987. This event resulted in the issuance of an Order Imposing {
Civil Penalties in the amount of $25,000 (Reference: Inspection i Report No. 301/87016 and Enforcement Action Case No.87-182). l An escalated enforcement case relating to health physics concerns (i.e., the lack of awareness of radiological hazards, and the failure to adequately instruct employees in the processes and procedures of handling radioactive materials) resulted in two
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violations that collectively.have been evaluated as a Severity Level III violation. The Severity Level III violation was issued l to the licensee, but no civil penalty was imposed. This case J
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is considered resolved and no further action is necessary at this time (Ref: Inspection Report Nos. 266/87011, 301/87010, 266/87014, 301/87013 and Enforcement Action Case No.87-095),
i Licensee Conferences Held During Assessment Period I April 15, 1986, Regional Offices: Enforcement conference with '
licensee representatives to discuss vital area barrier l
weaknesse . April 24, 1986, Point Beach: Routine tour and management meeting with licensee representatives to discuss plant operation . July 1,1986, Point Beach: Meeting with licensee to present the SALP 5 report for the period October 1, 1984 through March 31, 198 . July 18',1986, Regional Offices: Enforcement conference with licensee representatives to discuss violations involving vital areas access control barrier . September 17, 1986, Regional Offices: . Enforcement conference with licensee representatives to discuss a special inspection that was conducted to review circumstances of intake of radioactive material by a worker on July 19, 1986.
, July 18, 1987, Regional Offices: Enforcement conference with licensee representatives.to discuss two events: one concerned skin exposure received by contractor technicians to radioactive l
(hot) particles, and one concerned extremity dose received by
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a company technician trainee while handling radioactive sources Inspection Reports No. 266/87011,'No. 301/87010).
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(Reference: . September 10, 1987, Regional Offices: Management meeting with licensee representatives to discuss the licensee's plans to conduct a safety system function inspection (SSFI) of the l
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electrical system . September 23, 1987, Regional Offices: Enforcement conference- J with licensee representatives to discuss potential violation in which control power to the MSIVs was tagged ope Confirmatory Action Letters (CALs) .
No Confirmatory Action Letters were issued for Point Beach Nuclear' 1 Power Station during this assessment perio J
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Review of Licensee Event Reports and 10 CFR part 21 Reports Submitted ! l by the Licensee
- Licensee Event Reports (LERs)
Point Beach Unit 1 j Docket No. 50-266 -
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LER Nos. 86002 through 86006, and 87001 through 87004 Nine LERs were issued during this assessment period: two LERs resulted from personnel errors, one LER resulted from procedure !
l inadequacies, three LERs resulted from component / equipment failures, two LERs related to design problems, and one LER fell l
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into another category (i.e., external causes, anknown human, l
undefined, or other).
1 I Point Beach Unit 2 Docket No. 50-301 LER Nos. 86001 through 86008 and 87001 through 8700 '
Eleven'LERs were issued during this assessment peried: three LERs resulted from personnel errors, two LERs resulted from component / equipment failures, two LERs related to design ,
problems, and four LERs fell into other categories (i.e.,
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external causes, unknown human, undefined, or other).
During SALP 5, 20 LERs were identified over a 16-month assessment l l
period for an average of 1.3 per month compared to an average of .1 LERs per month during this assessment period. The percentage l of LERs that were caused by personnel error remained the sam NOTE: The LER information in this section was derived from review of LERs performed by NRC staff and may not coincide-with the unit cause assignments that the licensee would mak . 10 CFR Part 21 Reports Ii Point Beach responded to a potential Part 21 report submitted by The Westinghouse regarding the component cooling water system.
l, licensee informed NRC that it had performed stress analysis, and NRR accepted the licensee's results. This item is close ,
, Analysis and Evaluation of Operational Data ( AEOD)
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The results of the Office of Analysis and Evaluation of Operational Data (AEOD) assessment of a selected group of LERs for Point Beach, Units 1 and 2 indicated an improvement in quality, and an increase '
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in the overall points scored. Although the site showed signs of
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improvement, the discussions relating to the.cause of events remained unchanged from AE0D's previous evaluation and may warrant attentio (
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However, because the quality of text and abstract discussions have improved, AEOD gave Point Beach an overall average score ; of 8,7 points out of a possible 10 point I H. Licensing Activities NRR/ Licensee Meetings October 23. 1986 - Energy Absorbers March 3, 1987 - Inservice Testir.g Program May 30, 1987 - RPV Indications ; Commission Meetings Non . Schedular ' Exceptions' Granted l f
None.*
. Relief Granted May 7, 1987 - ASME Section XI relief request regarding the shell-to-shell tubesheet and nozzle-to-shell welds in the - '
non-regenerative heat exchanger . Exemptions Granted December 31, 1986 - Exemption to Appendix R of 10 CFR 50, Section III.G for various plant location i License Amendments Issued '
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June 17, 1986 - Reactor Trip Breaker Surveillanc June 25, 1986 - Component Cooling Water System (Amendments 101 and 104).
June 27, 1986 - Iodine Spiking ( Amendments 102 and 105).
July 3,1986 - Reactor Coolant. Pumps (Amendments 103 and 106).
August 27, 1986 - Containment Integrated Leak Rate Testing (Amendments 104 and 107).
February 2, 1987 - Component Cooling Water System ,
i (Amendments 105 and 108). l l
March 3, 1987 - Valve Surveillance Requirements (Amendments 106 and 109).
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.c March 17, 7.987 - Operating. License Extension (Amendments 107 and 110).
May 27, 1987 - Leaking Fuel Rod (Amendments 108 and lil).
7.. Emergency Technical Specification Changei
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Non . Orders Issued Non . NRR/ Licensee Management Conferences Non '. q i
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