IR 05000382/1987003

SALP Rept 50-382/87-03 for Jan 1986 - Jan 1987

ML20209H777
Person / Time
Site:	Waterford
Issue date:	04/30/1987
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20209H774	List: ML20209H770 ML20209H777
References
50-382-87-03, 50-382-87-3, NUDOCS 8705040120
Download: ML20209H777 (37)

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APPENDIX

>SALP BOARD REPORT:

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U.S. NUCLEAR REGULATORY COMMISSION I

REGION IV..

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SYSTEMATIC ASSESSMENT.OF LICENSEE-PERFORMANCE

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J 50-382/87-03 Y

Louisiana Power & Light Company

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- Wate'rford Steam Electric ' Station 1. . Unit 3

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-t January 1,1986, through January 31, 1987

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, INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) program is an integrated Nuclear Regulatory Commission (NRC) staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information. SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations. SALP is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote equality and safety of plant operatio An NRC'SALP Board, composed of the staff members listed below, met on March 27, 1987, to review the collection of performance observations and data, and to assess the licensee performance in accordance with the guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at Waterford 3 Steam Electric Station (W3 SES) for the period January 1,1986, through January 31, 198 SALP Board for W3 SES included:

E. H. Johnson, Director, Division of Reactor Safety and Projects, Region IV R. L. Bangart, Director, Division of Radiation Safety and Safeguards, Region IV G. W. Knighton, Director, PWR Project Directorate No. 7, Nuclear Reactor Regulation J. E. Gagliardo, Chief, Reactor Projects Branch, Region IV G. L. Constable,- Chief, Project Section C, Reactor. Projects Branch, Region IV J. H. Wilson, Project flanager, Nuclear Reactor Regulation J. G. Luehman, Senior Resident Inspector, W3 SES The following personnel also participated in the SALP. Board meeting:

W. C. Seidle, Chief, Technical Support Staff, Region IV J. P. Jaudon, Chief, Reactor Project Section A, Reactor Projects Branch, Region IV B. Murray, Chief, Facilities Radiological Protection Section, Radiological and Safeguards Programs Branch, Region IV R. E. Ireland, Chief, Engineering Section, Reactor Safety Branch, Region IV L. A. Yandell, Chief, Emergency Preparedness and Safeguards Programs Section, Radiological and Safeguards Programs Branch, Region IV R. P. Mullikin, Project Inspector, Region IV M. E. Skow, Project Inspector, Region IV T. R. Staker, Resident Inspector, W3 SES II. CRITERIA Licensee perfonnance was assessed in eleven selected functional area Each functional area normally represents areas significant to nuclear safety and the environment at operating plant ,

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-2-One or more of the following evaluation criteria were used to assess each functional area: 4

Management involvement and cont'rol in assuring quality.~ Approach to resolution of technic ~al issues from a safety. standpoin . Responsiveness to NRC initiative . Enforcement histor . Operational events (including response to, analysis of, and corrective actions for). Staffing (includingmanagement).

However, the SALP Board was not limited to these criteria and others may have been used where appropriat Based on the SALP Board Assessment, each functional area' evaluated is classified into one of three performance categories. The definitions of these performance categories are:

Category 1. Reduced NRC attention may be appropriate. Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety is being 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 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 is being achieve III. SUMMARY OF RESULTS Significant improvement was achieved in the area of Plant Operations, Surveillance, Fire Protection, Outages, Licensing Activities, and Training and Qualification Effectiveness. Improvement was also noted in the Maintenance functional area. Performance in the area of Security and Safeguards has

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-3-declined, in part, due to the failure of plant personnel outside the security organization to carry out their responsibilities to this progra The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation perio Previous Present Performance Performance Category Category (12/18/84 to (1/1/86 to Functional Area (12/31/85) (1/31/87) Plant Operations 3 2 Radiological Controls 2 2 Maintenance 3 2 Surveillance 2 1 Fire Protection 2 1 Emergency Preparedness 2 2 Security and Safeguards 1 2 Outages Not Assessed 1 Quality Programs and 2 2 Administrative Controls Affecting Quality Licensing Activities 2 1 Training and Qualification 2 1 Effectiveness The total NRC inspection effort during this SALP evaluation period consisted of 35 inspections, including ~ resident inspector inspections and emergency exercises, for a total of 4300 direct inspection hours. The plant availability factor was 72.8 ' percen IV. PERFORMANCE ANALYSIS Plant Operation Analysis This area has been inspected on a continuing basis by the NRC resident inspectors and on a periodic basis by region-based NRC

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-4-inspectors. Licensee management involvement in the area of plant operations was evident during this appraisal period. This involvement was, to a large extent, responsible for the substantial decrease in the number of both reactor trips and licensee event reports (LERs).

The licensee management established a group responsible for the review and reporting of potentially reportable events. This group, which is headed by a ~ senior reactor operator (SR0), has provided improved event analysis and higher quality LERs as evidenced by the LER analysis performed by the 11RC Office of Analysis and Evaluation of Operational Data (AE00). This analysis was provided to LP&L under a cover letter dated March 5, 198 There was a low turnover of personnel in the operations department during this appraisal perio The licensee instituted a college degree program for licensed operators which should, in part, encourage a continued low turnover. The increase in the number of available licensed operators has produced a number of benefits for the operations department. First, it has allowed the operations superintendent to allocate additional resources to ongoing projects such as upgrading of operating procedures and improving the labelling of plant equipment. Secondly, it has made possible the transfer of a number of very experienced licensed operators to the training departmen Upgrading of the control room and the control room panels progressed, as conditions permitted, throughout the appraisal period. The improvements made in the control room included panel relabeling, painting, recarpeting, and the addition of normal operating bands to many control room meters. Also, new distinctive clothing, desinned based on operator suggestions, was introduced for the on-watch licensed operator The licensee's program to reduce the number of illuminated annunciators during power operations made progress during the appraisal period; however, additional work remains to be don Efforts to reduce the overall number of temporary plant alterations have also had some success, but many remain in place with the majority awaiting completion of 'a particular plant modification. Substantial progress was made in improving the reliability of the engineered safety system features portion of the control room ventilation system by replacing the chlorine detection system. At the same time, however, during extended shutdowns the containment purge isolation system has exhibited operational problems. Spurious termination of containment purge has caused diversion of the reactor operator's attention from monitoring overall plant operations and caused high humidity in

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the containment. This made for uncomfortable working conditions as well as condensation on equipmen The licensee's efforts to reduce the high concentrations of short-lived, airborne radioactivity in the reactor auxiliary building have been fairly successful but maintaining consistently low levels will require a continuation of the joint effort between plant operations and health physics personne Numerous-NRC inspections during the appraisal period have identified deficiencies in system valve lineup procedures, the referenced plant drawings, and the labelling of plant equipmen As discussed previously, the operations superintendent has assigned additional manpower to upgrading these areas, but these efforts have concentrated largely on the correction of previously identified discrepancies and not on the equally important correction of discrepancies noted as the system lineups are performe Based, in part, on observations made by the NRC resident inspectors, the licensee has recognized that the administrative burden on the shift technical advisors (STA) has at times diverted them from their prime responsibility of providing the shift supervisor with an independent engineering appraisal o operational situation Licensee management has taken a number of steps to refocus the STA's efforts to providing the needed technical reviews and recommendations. The steps taken included trying to reduce STA involvement in the plant temporary alteration request system and moving toward fully staffing all of the approved STA positions. Overall, the STAS were well integrated into the operating shift organization and continuing the practice of having STAS obtain senior reactor operator licenses should improve the operations departmen During the appraisal period, the licensee deviated from two commitments made to the NRC in the area of plant operation These deviations resulted, in part, from a lack of direct involvement of plant operations personnel in providing input to commitments made to the NR Furthermore, the lack of a central point, responsible for ensuring the accuracy of responses made to NRC Region IV and the NRC Office of Inspection and Enforcement, contributed to the deviations. Without such central coordination, there was apparently no assurance that all the necessary departments fully understood their commitments relative to the response The licensee has made a number of changes in hardware to reduce the number of reactor trips due to drcppcd ccr. trol element assemblies (CEA). Additionally, core protection calculator (CPC) software changes have been made to reduce the impact of a dropped CEA on plant operation .

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-6- Conclusions The NRC staff is encouraged by the large decrease in the number of reactor trips and licensee event reports that occurred during this appraisal period. The morale of the operations staff is considered very high, and the confidence of the staff continues to grow with operating experienc Operator distractions in the control room such as various illuminated annunciators, as well as the temporary alterations existing throughout the plant, are avoidable potential problem areas that operators must contend with on a daily basi The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the basic inspection program. Emphasis should focus on monitoring of licensee efforts to eliminating operator distractions such as spurious annunciators, inadvertent ventilation actuations, and existing temporary plant al teration Recommended Licensee Actions Continued efforts to clear. illuminated annunicators, remove temporary plant alterations, and eliminate spurious ventilation actuations should be given priorit Additionally, shift technical advisors should be removed from duties involving largely_ administrative functions so they can concentrate on the duties and responsibilities outlined in Technical Specifications. Licensee management should ensure preparation, tracking, and closure of regulatory compliance issues are pursued with the same systematic approach normally taken in the licensing are B. Radiological Controls Analysis Six inspections in the general functional area of radiological controls were performed by regional radiation specialist inspectors during the assessment period. The inspections included the following specific areas: occupational radiation safety, radioactive waste management, radiological effluent control and monitoring, transportation of radioactive materials, and water chemistry control *

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-7-a. Occupational Radiation Safety This area was inspected three times during the assessment period. These inspections included two inspections during routine operations and one refueling outage inspectio Management involvement was evident by the performance of comprehensive audits of radiation protection activitie The licensee's program is considered adequate in the areas of radiological training for the plant staff, stability of the health physics staff at the technician level, and the

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development of radiation protection procedures. The licensee demonstrated good planning and preparation for the 1986 refueling outage. The licensee's response to NRC initiatives is considered above averag Problems continue to exist concerning the release of airborne and liquid radioactive contaminates from valves and fittings in various plant systems. The licensee made some progress to repair leaky valves and fittings during the recent refueling outage. However, additional repair work is needed in order to reduce the amount of leakage that currently exists. This problem area was identified in the previous SALP repor The new Radiation Protection Manager (RPM) was hired during the assessment period. The new RPM has previous experience, with INP0, evaluating radiation protection programs at several utilitie A large turnover rate was experienced among the professional health physics technical staff. Almost a complete turnover occurred within the onsite and corporate staff during 1985-86. First-line, onsite supervisors are burdened with excessive administrative duties which prevent them from spending adequate time in the plant supervising radiation protection activitie Several problems were identified concerning the failure to follow Radiation Work

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Permit instructions and the proper control of contaminated workers leaving the site which reflects the need for more direct supervisory oversight of the radiation protection progra The person-rem exposure for 1986 was 270. This compares to an estimated national average for PWR reactors of 'about 270 person-re b. Radioactive Waste Management The licensee's program concerning the processing and onsite storage of gaseous liquid and solid radioactive waste was inspected once during the assessment perio . . . _ . . _ .

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-8-The licensee had not established a permanent low-level radioactive waste storage' facility. Low-level waste is currently stored in various temporary areas throughout the plant. A protected storage area had not been established for radioactive waste containers. Containers are presently stored outside and exposed to environmental condition c. Radiological Effluent Control and Monitoring The liquid and gaseous effluent control and monitoring program was inspected once during the assessment perio Effluent sampling and analyses activities were well defined in plant procedures to ensure compliance with the Radiological Effluent Technical Specifications. Gaseous and liquid release permit programs were established to ensure that planned releases receive the necessary review and approval prior to~ releas The radiochemistry / confirmatory measurements program was inspected once during the assessment period. The inspection included onsite confirmatory measurements with NRC Region IV mobile laboratory. The results of the confirmatory measurements values indicated 98 percent agreement between the NRC's and licensee's measurement This percent agreement is above an expected industry average of about 90 percen The radiochemistry / confirmatory measurements inspection also included a review of the post accident sampling system (PASS). Several major problems had been encountered while attempting to obtain liquid and containment air PASS samples. In order to correct these problems, extensive modifications to the PASS system were performed during the 1986 refueling outag The radiological environment monitoring program was inspected once during the assessment period. No problem areas were identified. The licensee has established a well documented program to ensure compliance with the offsite dose calculation manual and Technical Specification requi rements. All NRC identified matters have been resolve Transportation of Radioactive Materials-This area was not inspected during the assessment perio ~

, The previous inspection was performed in October 1985, and the next inspection is scheduled for March 198 m

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_ Water Chemistry Controls The primary and secondary systems affecting plant water chemistry were inspected once. No problem areas were identifie . Conclusions Leakage from liquid,and gaseous systems has resulted in unnecessary personnel exposure and excessive contamination of plant areas. First-line health physics supervisors have not spent adequate time in the plant overseeing ~ radiation protection activities. The'large turnover rate among the professional staff has reduced the- technical review of radiation protection wor No problems were identified in the areas of enforcement, training, resolution of technical issues, or responsiveness to NRC initiative The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The NRC inspection effort in this functional area should be consistent with the basic inspection program. An inspection of the new PASS should be conducted in early 198 Reconmended Licensee Actions Management attention is needed to: (1)ensureappropriate action is taken to reduce the radioactive leakage.from liquid and gaseous systems to an acceptable level, (2) ensure that first-line health physics supervisors spend adequate time in the plant overseeing radiation protection work activities, (3) ensure that stability is maintained-

~ with the health physics professional staff, and (4) evaluate the benefits of establishing a permanent low-level radioactive waste storage facilit C. Maintenance Analysis This functional area was periodically inspected by region-based NRC inspectors and on a continuing basis by the NRC resident inspectors. During this appraisal period, the region-based inspection efforts-included a maintenance program assessment ,

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-10-A number of major maintenance efforts were accomplished during the appraisal period. Many of these efforts, which included main turbine. inspection / maintenance, replacement of reactor coolant pump seals, and repairs of the . reactor coolant pump seal water heat exchangers, were accomplished during the refueling outag The licensee: continued efforts toward implementation of the maintenance segment of the station information management system (SIMS), a project that was begun late in the last appraisal period. In general, preventive maintenance initiatives such as SIMS and routine corrective maintenance have consistently been delayed in favor of priority corrective maintenanc Early in the appraisal period, the licensee continued to have problems with the measuring and test equipment (M&TE) progra The NRC resident inspectors identified a number of pieces of M&TE in use or available for use in the plant well past their calibration expiration dates. These problems were corrected near the end of the appraisal period through implementation of strict procedural controls and retraining of personne In general, routine corrective'and preventive maintenance was performed satisfactorily. Work observations indicated that maintenance personnel were well prepared and traine Maintenance activities did not directly contribute to any reactor trip It is not uncommon for emergent containment maintenance to be performed in areas where temperatures reach the 130-140 degrees Fahrenheit range. During the plant's refueling outage, the spurious terminations of containment purge, discussed in the Plant Operations section of this report, compounded existing temperature and humidity problem Events such as those described in LER 382/86-15 illustrate the role environmental factors can have both in operations and maintenance related activitie . Conclusions Improvement was noted in the licensee's maintenance progra Given the tempo of activity dictated by t.*o major outages, efforts in the area of corrective maintena.'ce were considered generally well coordinated and performed. However, a significant backlog of corrective maintenance items of a routine nature continued to exist. The existence of some of these outstanding items contributed to the large number of temporary plant modifications discussed in the Plant Operations section of this repor . .

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-11-Programmatic planned maintenance' initiatives such as SIMS have not been fully implemented due, in part, to the attention given outage activities. Licensee management has been very responsive to NRC inspection findings and concerns in this functional are Both, through telephone conversations and written correspondence, the licensee has attempted to close out many issues, some of which had been under review for long periods of tim The licensee is considered to be in Performance Category 2 in this functional are . - Board Recommendations Recommended NRC Actions The NRC inspection efforts in this functional area should be consistent with the basic inspection program. These efforts should, however, include followup of the licensee's efforts to implement preventive maintenance initiative Recommended Licensee Actions Licensee management should work toward reduction of the outstanding routine maintenance backlog and implementation of programs such as SIMS. Additionally, initiatives to improve the~ containment working environment should be considere D. Surveillance Analysis This functional urea was inspected on a continuing basis by the NRC resident inspectors and periodically by region-based NRC inspectors. Additionally, during the refueling outage, an inspection was performed using the facilities of'the NRC nondestructive examination mobile va The W3 SES surveillance program accomplished the required testing in a timely manner in accordance with required procedures. The activities performed by the licensee in the area of inservice inspection were well prioritized, well controlled, and executed using explicit procedures. Although timely completion of nonroutine surveillances continue to be a problem, the frequency of such problems has decline The Health Physics and Chemistry departments are responsible for a large number of the very frequently performed nonroutine surveillances which provide the most opportunities for missed surveillances. Licensee management has taken a number of

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positive-steps to minimize such problems including the installation of an automatic hydrogen / oxygen sampling system for various plant storage tanks. However, there are other problems such as the baron management / blowdown radiation monitors that need attention. .These monitors have' proven to be unreliable, i .and their frequent inoperability has required performance of j various nonroutine surveillances thereby setting up the possibility of missing a required sample or failing to verify a lineu '

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_ Conclusions

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Licensee management has taken positive actions to improve l performance in the. functional' area of surveillance, and these actions have helped reduce problems in the area. Problems with

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nonroutine surveillance exist but have declined in numbe The performance and tracking of surveillances has been good as has the licensee's evaluation and resolution of problems discovered during surveillance testin .The licensee is considered to be in Performance Category 1 in this functional are l

Board Recommendations i Recommended NRC Actions

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! The NRC should consider reduced inspection effort in this functional area; however, a review of the licensee's compliance with nonroutine surveillance requirements should still be accomplished, j Recommended Licensee Actions

! The licensee should continue to pursue procedural as well' ,

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surveillance problems. Evaluation ~of the long-term reliability of the boron management / blowdown' system radiation monitoring equipment, and the placement of the

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new hydrogen / oxygen analyzing system into routine

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operational service are two actions that will assist in this effor E. Fire Protection

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This functional area was inspected on a continuing basis by the NRC resident inspectors, and one-inspection of the fire

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-13-NRC inspector. These inspections verified that the licensee was maintaining a fire protection / prevention program that met the requirements of Branch Techntcal Position 9.5-1, the Plant Final Safety Analysis Report, the Plant Fire Hazards Analysis, and Technical Specification In general, housekeeping and cleanliness controls were adequate throughout the plant. Fire brigade training and fire detection / suppression surveillances were performed in accordance with TS (except as described in LER 382/86-27). During the refueling outage, the licensee installed the fire protection hardware required by license conditions and made the modifications resulting from the spurious signal analysi By the end of the appraisal period, the licensee was making a concerted effort to reduce the number of fire impairments existing throughout the plant and this, in turn, reduced the need for compensatory fire watche . Conclusions Licensee management demonstrated a definite commitment to having an effective fire protection / prevention program. However, for much of the appraisal period, the use of fire watches, in place of barriers / detection equipment, was very routine. As noted in the Quality Programs and Administrative Controls Affecting Quality area of this report, the licensee created a single fire protection / industrial safety group. Such a consolidated organization will provide quicker resolution to problems in the areas of fire protection / prevention by placing these areas and the functionally related area of safety under a single superviso The licensee is considered to be in Performance Category 1 in this functional are . Board Recommendations Recommended NRC Actions The NRC should consider a reduction of inspection effort in this functional are Recommended Licensee Actions Licensee management should continue to stress the reduction of the number of inoperable fire barriers and work toward the elimination of routine fire watches in areas containing safety-related equipmen _

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.. j-14-F. Emergency Preparedness Analysis This area was inspected on a periodic basis by NRC region-based inspectors and contract personnel. During the assessment period, three emergency preparedness inspections were conducte Two violations and one deficiency were identifie The two violations identified during this assessment period were failure to follow document change procedure and failure to provide adequate training to emergency response personnel. The licensee took immediate corrective action in response to personnel making hand written procedure change The previous SALP assessment had identified that the licensee had reduced the retraining program. During this assessment period, it was determined that the licensee's training program still was weak. A sampling of operations personnel indicated some were unable to demonstrate adequate knowledge of the protective action decision-making procedures. Health physics technicians were unable to adequately demonstrate fundamental radiation protection techniques in determining habitability of emergency response facilities and performing offsite surveys to characterize a radioactive plume released in an accident. The licensee has not conducted a review of the training program to be assured that it is adequate for emergency response personne One deficiency identified during the emergency exercise concerned communications and the Emergency Operations Facility (E0F) organization. During the exercise, the licensee encountered problems in demonstrating comand and control of the Emergency Operations Facility (E0F). The command and control problem, in turn, precipitated onsite communication poblems with the E0F support groups. In response to the training violation, the licensee committed to training seminars for the health physics personnel and for other emergency response personnel on an as-needed basi The licensee conducted a joint emergency response exercise with

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this exercise indicated that there was reasonable assurance that the licensee could adequately protect the health and safety of i the public during an emergency. One unresolved item concerning i the size of the Technical Support Center (TSC) and the resulting

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overcrowded conditions in the TSC was identified. This item will be resolved during the NRC Emergency Response Facility Appraisa During this assessment period, the licensee improved the station emergency personnel callout system. The licensee had identified areas for improving the callout system during several unannounced

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-15-drills. The licensee has maintained sufficient depth in the emergency response organization. Additionally, the licensee exercised several different emergency response team The licensee entered this assessment period with approximately 40 deficiencies. Thirty-eight deficiencies were closed during the annual emergency preparedness exercis During this assessment period, the licensee improved the station emergency personnel callout system. The licensee had identified areas for improving the callout system during several unannounced drills. The licensee has maintained sufficient depth in the emergency response organization. During this assessment period, the licensee exercised several different emergency response team . Conclusions Training in emergency preparedness continues to be a weakness in the W3 SES program. This has reduced program effectiveness as evidenced during NRC walk-throughs and annual exercis The finding of the NRC inspections conducted during the evaluation period indicate that overall the licensee's emergency preparedness program is adequate to protect the public health and safet The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions i

The level of NRC inspection effort in this functional area !

should be consistent with the basic inspection progra Recommended Licensee Actions )

Upper level management's attention to the implementation of the emergency preparedness program should be increased to ensure proper response to NRC identified item The licensee management should evaluate the emergency preparedness initial training and retraining program as to training frequencies, scope, and depth for all emergency i response personne .

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-16-G. Security and Safeguards Analysis This area was inspected on a continuing basis by the NRC resident inspector and periodically by NRC region-based inspectors. Several violations that were identified resulted from activities performed by personnel other than the securit force, indicating the failure by management to make everyone onsite aware of their security responsibilities. The licensee has taken extensive corrective action to train everyone on the security requirements at W3 SES. It was noted that the number and severity of violations decreased during the latter part of this assessment period, indicating strong management support of the security progra Weaknesses were identified in the areas of physical barriers and the closed circuit television system. Several passive barriers have been corrected, and the closed circuit television is being evaluated for upgradin . Conclusions While there was an increase in the nuaSer of ser mity violations, most of' the violations were discovered as a result of the licensee's own initiative and an excellent record-keeping capability. The violations encountered during these inspections were promptly corrected. The licensee undertook and completed an extensive training and briefing program for all employees with access to the protected or vital areas. There was ample evidence of the effectiveness of the program during an early 1987 inspection which encountered no violations. The licensee continues to be very responsive to NRC concerns and initiative The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations I Recommended NRC Actions l

i The level of NRC inspection effort in this functional area )

should be consistent with the basic inspection progra !

! Recommended Licensee Actions The licensee should continue to enhance the security training of nonsecurity personnel in order to prevent recurrence of the physical barrier violation Additionally, licensee management should ensure the evaluation of the closed circuit television system is completed and appropriate modifications are mad .

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H. ~ 0utages

' Analysis-This functional area was inspected on a continuing basis by the j NRC resident inspectors during the mid-cycle outage of March 8 through March 30, 1986,~and the first plant refueling outage

- starting November 26, 1986, and continuing through the end of the SALP period. These inspections included verification that outage management, repairs and modifications to equipment, and-refueling activities were -performed in accordance with plant procedures, regulatory requirements, and Technical Specification .

l~ During both the mid-cycle and refueling outages, planning and scheduling 'of operations and maintenance activities were very

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good. The licensee's use of containment coordinators, as well as floor and assigned area radiation control technicians, resulted in effective control and coordination of all work performed in the containment during the refueling outage.

However, a violation (382/86-33) for failure to follow radiation j work permit requirements discussed the fact'that radiation technician control of work in progress was'not always performed l in strict conformance'with established procedures. This problem led the licensee to promptly pursue revision of established ,

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procedures and to retrain personne Prior to the refueling outage, a weakness in the organization and supervision during receipt of new fuel was identified. The

< weakness, in conjunction with poor layout of the fuel handling building, led to damage to a new fuel element which was discussedinviolation(382/86-29). At the beginning of the i fuel shuffle, a boraflex plate wa's'~1nadvertently pulled out of the spent fuel storage rack by the_ spent: fuel handling machine af ter it caught on the spent fuel : tool. The remainder of the fuel shuffle was revised.in order to accommodate the above

. . problem as well as the extensive search (in the core barrel and

lower structure' sections of'the reactor vessel) .for missing j steam generator tube plugs (LER 382/86-28). The revised

, evolutions were completed without inciden .

During both~ the mid-cycle and refueling ' outages, problems With j coordination maintenance and testing.were observed on the

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individual component level. Certain pieces of equipment were taken out of service more than once in order to accomplish' ,

j assigned work. For instance, a piece of equipment would first

be taken out for preventive maintenance, then again for j i equipment qualification inspection, and finally for surveillance ;

i testin In many cases, all the work could have been

accomplished during a single period of inoperabilit In efforts to minimize nonproductive time during the beginning of unplanned / forced outages, the licensee has developed a i

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-18-detailed forced outage list that includes, not only the work to be accomplished, but other information such as who to contact to get the work started promptl . Conclusions Licensee management involvement was effective and aggressive in keeping informed, keeping control, and solving of problems as they developed during the outages. This involvement, along with good planning and scheduling, resulted in overall outage management that is considered above average for a licensee conducting an initial refueling outage. As noted, coordination of work activities between disciplines could have been better controlled on the individual component leve The licensee is considered to be in Performance Category 1 in this functional are . Board Recommendations Recommended NRC Actions Although a performance rating of one would suggest that reduced NRC inspection might be appropriate, the NRC inspection effort in this functional area should be consistent with the basic inspection program as major outages involve numerous, infrequently performed activitie Recommended Licensee Actions Licensee management should continue with aggressive involvement in outages. Some improvement could be made in scheduling of equipment testing / inspection so that multiple equipment outages could be avoide Progress of the revision of the radiation work permit procedures should be closely monitored so that the revised program is in place and functioning well before the next scheduled outag Quality Programs and Administrative Controls Affecting Quality

, Analysis Activities under this functional area were inspected by region-based NRC inspectors and by the NRC resident inspector During this appraisal period, the licensee's nuclear organization underwent a number of changes. First, a new senior vice president was appointed, and then a major reorganization was executed. As part of the reorganization, a vice president (site director) position was created. The guality control group was placed under the quality assurance (QA)

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-19-l manager, the Independent Safety' Evaluation Group (ISEG) was elevated in the-corporate structure, and a consolidated fire

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protection and safety group was establishe This functional area includes all verification and oversight activities which effect or ensure quality of plant activities, structures, systems, and components. The work of organizations such as the Plant Operations Review Committee (PORC), the Quality Assurance (QA) organization, the Safety Review Committee (SRC), and the ISEG form the basis for much of the l evaluation. Specific activities which were evaluated included procurement control, control of design changes, audits, inspections, records, and corrective action systems. One area needing improvement was noted in a number of NRC inspections. In certain plant procedures, informational cautions / notes were used

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as procedural' action steps. Considering procedures on a broader basis, it was noted in review of violations and LERs that in a number of functional areas two specific weaknesses existe First, LERs such as 382/86-15 and 382/86-24 demonstrated that the understanding of the basis / intended use of procedures was not always adequate on the part of the users. While an LER such as 382/87-03 or a violation such as the failure to follow procedures, described in NRC Inspection Report 50-382/86-02, i demonstrated individual failures to implement the established l procedure ,

Licensee management has effectively implemented a program to reduce the large backlog of outstanding station modifications, however, continuing effort in this area is needed as evidenced by the large number of temporary alterations still in place l dwaiting permanent changes. Further, NRC inspections indicated

'

that although procedures, specifications, and drawings were in place for station modification, the instructions in some modification packages were poorly stated, and retrieval of documents associated with a particular modification was sometimes a proble Problems with reliability of the plant monitoring computer that were evident during the last appraisal period have not been fully remedied. The licensee has gotten an approved change to

' the TS which reduces the operational impact of a core operating limit supervisory system (COLSS) failure, but this change has done nothing to' improve overall computer reliability. In addition to operating the COLSS, the plant computer supports a portion of the licensee's plant / environmental assessment capabilities, and regular losses of some or all of capabilities supported by the plant monitoring computer have resulte During this appraisal period, an inspection was performed to determine the status of the licensee's implementation of 10 CFR 50.49 requirements. It was determined that the licensee

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-20-has established an equipment qualification (EQ) program that meets the applicable regulatory requirements. Additionally, staffing and training in the EQ area were adequat Some specific problems were identified in the licensee's EQ program. These problems included: no records to demonstrate

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qualification for equipment subject to submergence under design basis accident conditions, improper temperature lag analysis, and inadequate schedules for replacement of components susceptible to aging effects at elevated service temperature Licensee management was very responsive in addressing these issues, and responses were both technically sound and thoroug . Conclusions Licensee management adequately implemented programs and controls

'

designed to ensure quality including the EQ program. The completion of a large number of station modifications during the first refueling outage will place extra demands on the licensee's system for modification closeout and drawing updat Even though the licensee has made some improvements, plant computer reliability continued to be a proble The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRC Actions The level of NRC inspection effort in this functional area i should be consistent with the basic inspection program with particular emphasis on the station modification program, Recommended Licensee Actions Licensee management needs to resolve the lingering problems associated with the plant computer system. Licensee management has taken steps to minimize the impact of plant computer outages but such outages continue to occu Additional reviews of plant procedures need to be done to eliminate the practice of using informational notes as procedural requirements. Followup of the concerns identified in the NRC EQ inspection should be monitored by licensee management to ensure continued compliance in this area. Careful monitoring of the station modification program also needs to be a priority so that progress made in reducing the number of outstanding station modifications in the review cycle continues even with the added volume of post refueling outage review l

. _ _ _ - - _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ - _ _ _

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-21-l J. Licensing Activities Analysis The licensing activities at W3 SES during the current SALP appraisal period have been characterized by a high level of dCtivity targeted toward preparation and conduct of the first reload, closure of license conditions imposed by the operating

,

license, completion of commitments made prior to licensing, and l

modifications to streamline and upgrade operations and increase plant reliabilit A total of 54 licensing actions were completed during the rating period, many of which were associated with the first reload. In addition to the 39 Technical Specification changes in support of the reload-analysis, the licensee closed out 4 multi-plant actions and carried out programs and commitments as required by 11 license condition During_ the assessment period, the licensee's management has demonstrated a high level of involvement and control in assuring qualit Prior planning and assignment of priorities were consistently evident. Regarding multi-plant actions, the licensee's management actively participated in efforts to work

closely with the NRC staff and there were no backlogs over which t

the licensee had control. With regard to plant-specific activities, the licensee has consistently demonstrated a high degree of planning and prioritization of actions to resolve plant-specific issues. TF.i; was especially evident during the staff review of Technical Specification amendment requests for Cycle 2 reload to increase the cycle length to 18 months and the implementation of actions to close out commitments and license conditions for the Broad Range Toxic Gas Detection System, axial l fuel growth, smoke detection in the control room, spurious l signal analysis modifications, neutron flux indication, and l

Increased enrichment evaluation of the spent fuel storage racks.

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The licensee has well-stated and understandable policies disseminated throughout their Nuclear Operations organization through a system of Nuclear Operations Directives established dnd controlled through the office of the Senior Vice President-Nuclear. The licensee reorganized during the SALP evaluation period to redefine organizational reporting-i responsibilities which places decisionmaking consistently at a l level to ensure adequate, thorough, and technically sound management review. In general, the new organization places plant operations, design engineering and construction under a site director (the Vice President-Nuclear Operations), expands the role of training, consolidates similar functions, and places l increased emphasis ~on important functions, such as events

! analysis, trending, industrial safety, and fire protectio . .

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-22-The Senior Vice President - Nuclear maintains a site office for his frequent visits and is involved in site activities. The Vice President-Nuclear Operations, in his function as site director, maintains his office on site on a full-time basis and is involved on a day-to-day basis with plant and site activitie In order to enhance their involvement and increase their control of licensing activities, LP&L management has maintained an office in Bethesda. This licensing presence near NRC, which includes both technical and administrative liaison, has enabled LP&L management to be highly responsive to staff concerns and has expedited the resolution of licensing issue The licensee has demonstrated sound and thorough approaches with regard to almost all issues and has resolved the issues in a timely and responsible manner. Where additional information was needed by the staff to complete their reviews, the licensee demonstrated a responsive and aggressive role in reaching timely dnd thorough resolution, especially where there was a potential for safety significance. This immediate approach to resolution of the technical issues was particularly evident during the period from August 1986 through January 1987, when the safety analysis and 39 Technical Specification change requests were processed to support an 18-month Cycle 2. The continuation of a licensing presence in Bethesda has enabled LP&L to focus quickly and accurately on technical issues and to determine which resources need to be brought to bear to reach timely resolution based on sound communication There is, however, one area where LP&L could have been more responsive in following guidance provided by the staff. During review of the licensee's implementation of the SPDS, repeated discussions at meetings and during telecons have not been effective in directing LP&L's efforts to come up with a design that meets the intent of NUREG-0737, Supplement 1. In fairness to the licensee, it should be noted that many of the staff's criticisms of Safety Parameter Display System (SPDS) design have arisen because LP&L's design of the system preceded issuance of detailed guidance by the staf In view of the high level of responsiveness on a very large number of issues exhibited by LP&L during the rating period, failure to close out this single difficult issue is not judged to be a significant performance decremen The licensee has an apparently effective system for tracking and responding to NRC requests and, in nearly all cases, meets regulatory deadlines and commitments for timely resolution of issues. The licensee infrequently requires extensions to meet submittal dates, but is timely in alerting the staff in the rare instances when an extension is needed. Through meetings with the NRC staff, and through their Bethesda Licensing Office, the licensee has maintained an effective line of communication _ _ _

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-23-The licensee is always cooperative in meeting with the NRC staff whenever the circumstances warrant. The licensee has been responsive to first-of-kind programs, audits, and surveys. The Operational Licensing Group, located at the plant site, was instrumental in responding to NRC requests for plant performance and operating data by bridging communications with operations, engineering, and technical group Corrective action is effective, as indicated by a lack of repetition. The licensee has conducted licensing activities in such a manner as to allow adequate time for staff review and approval. No emergency Technical Specification changes were necessary during the rating period. The trip reduction program implemented by the licensee has been effective in reducing the number of reactor trips from 22 in the previous rating period to 7 this rating period. Plant modifications to increase reliability have been implemented and include: modifications to feedwater systems, rework of the turbine governors, replacement of CEDM cards and power supply, and an extensive valve replacement program to reduce RAB airborne activit . Conclusions Management involvement and control in licensing activities is effective in assuring quality. The licensee has consistently demonstrated a high degree of planning and prioritization of actions to resolve plant-specific issues, particularly during the recent first refueling outage. The licensee has well stated and understandable policies disseminated throughout its nuclear operations and has an effective system for tracking commitments and responding to NRC requests. The licensee's organization is configured such that reporting responsibilities consistently place decision making at a level to insure adequate, thorough and technically sound management review. The licensee has demonstrated sound and thorough approaches to almost all issues and has resolved the issues in a tiraely and responsible manne The licensee is considered to be in Performance Category 1 in this functional are . Board Recommendations Recommended NRC Actions NRC efforts should continue at the present level, or possibly be reduced in recognition of the completion of the first refueling outage. Continued emphasis should be given to assure that no declining performance trends develop in any of the licensee's program . - _

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-24- Recommended Licensee Actions The licensee should continue to maintain a high level of management involvement to assure continued improvement in this functional area. Continued emphasis should be placed to assure that supporting analyses continue to be thorough, complete, and accomplished in a timely manner. The licensee should focus on the expeditious resolution of the SPDS issues to achieve an acceptable design and operatio K. Training and Qualification Effectiveness Analysis The licensee has made substantial progress in certain aspects of the plant training programs. The skills training center was not only used for a broader scope of normal training activities, but it also provided the classrooms and equipment to perform much of the specialized training needed to support the refueling outag The plant licensed operator training program had an overall success rate of greater than 90 percent on three NRC administered examinations performed during the appraisal perio Finally, the licensee had all plant-training programs covered by i the Institute for Nuclear Power Operation (INP0) guidelines ready for accreditation by the December 1986 target dat An NRC inspection performed on selected aspects of the licensee's training programs did identify a-number of deficiencies in the area of training administration /

documentation; however, content and scope were adequate. The delivery of the plant specific simulator did not take place as scheduled, and the simulator was not on site at the end of the appraisal perio . Conclusions The licensed operator training program is functioning very well; however, ' administration / documentation of the 10 CFR Part 55 requalification program and other training programs could be improved. As evidenced by comments in )ther portions of this report, as well as in LERs and potentially reportable events (PRES), training for a number of unlicensed plant staff positions still needs strengthening. Though the licensee has

' devoted a large number of man-hours to the plant simulator project, problems with the project contractor have again delayed the delivery dat The licensee is considered to be in Performance Category 1 in this functional are .I

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-25- Board Recommendations Recommended NRC Actions The NRC should consider a reduction of inspection effort in this functional are Recommended Licensee Actions LP&L management attention should focus on delivery of the plant specific simulator to the site and all efforts necessary to make the unit fully operational. As discussed above, additional emphasis _should be placed on training of nonlicensed plant staff personnel. Finally, licensee management should direct the correction of the identified deficiencies in training program administration / documentation and ensure periodic reviews of these programs are performed to identify any future problems.

l V. Supporting Data and Sumaries Licensee Activities During this appraisal period, W3 SES was involved in two significant outages. The first outage to occur was a mid-cycle maintenance outage, and the second, which was reaching completion at the end of the appraisal period, was the plant's first refueling outag During the refueling outage, numerous modifications were made to meet !

license conditions. Additionally, during the outage, inspection of l the steam generator tubes was performed, plant snubbers were l inspected / tested, and extensive work was done on both the reactor coolant pumps and main steam isolation valve hydraulic system Inspection Activities Violations See Table I and II Major Inspections i Three major inspections were conducted during the assessment period. These were a maintenance program review (November 1986, 50-382/86-28), the independent verification inspections of plant modifications and inservice inspection using the NRC nondestructive examination mobile van (December 1986,50-382/86-31), and the equipment qualifications inspection (December 1986,50-382/86-32).

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• Investigations and Allegations Review One major investigation was completed during this assessment period. This related to possible misrepresented facts in October 1984 concerning managers (November 1986,50-382/86-30). Three allegations were reviewed and closed (January and February 1986, 50-382/86-02 and 50-382/86-05). Escalated Enforcement Actions Civil Penalties During the a Actions (EA)ppraisal period, were issued two Escalated involving Enforcement W3 SES. Ona of these EAs did not impose a civil penalty. On April 16, 1986, EA 86-50 involving the inoperability of a containment spray pump was issued. The licensee responded to EA 86-50 and the proposed civil penalty of $50,000 in a letter dated May 16, 1986. The letter imposing the civil penalty was subsequently issued on August 27, 198 . Enforcement Orders Non Licensee Conferences Held During Appraisal Period A management meeting was held on January 8,1986, to discuss facility and programs status and planning. An enforcement conference was held on March 5, 1986, to discuss apparent violations concerning a mode change and various security issues. A management meeting was held April 1, 1986, to discuss SALP Report 50-382/85-30. A management meeting was held on September 19, 1986, to discuss general plant

status. An enforcement conference was held November 18, 1986, to discuss security matters relating to access contro Confirmation of Action Letters Non Review of Licensee Event Reports and 10 CFR Part 21 Reports Submitted by the Licensee Licensee Event Reports (LERs)

During this assessment period, a review was conducted for LERs submitted during the period January 1,1986, through January 31, 1987. This review included LERs 382/86-01 through 382/87-0 The technical content of LERs was greatly improved during this assessment period. Table III contains a tabulation of LERs by performance categor P

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An additional evaluation of the content and quality of a representative sample of the LERs submitted between January 1, 1986, and January 1,1987, was performed by the NRC Office of Analysis and Evaluation of Operational Data (AE00). This -

analysis was provided to LP&L under a cover letter dated ,

March 5, 1987. This, the second evaluation of the licensee '

using AE0D's methodology, resulted in an overall score of r out of a possible 10 points which was a large improvement over a previous average score of 7.3. The current industry average is , >

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One weakness involving the requirements to uniquely identify failed components was identified. Two strong points involved

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i the discussions concerning safety assessments and the failure mode mechanism /effect of failed component . Part 21 Reports None, ,

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H. Licensing Activities [l NRR/ Licensee Meetings 2/18-19/86 Meeting to discuss basemat confirmatory analyses / ,

3/26/86 Meeting to discuss results of basemat /

confirmatory analyses

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5/13/86 SPDS Design Review ~

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5/13/86 Reload Scoping Meeting 5/14/86 Basemat 6/3/86 Scheduling and Resource Management for Reload .

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8/28/86 Review of updated basemat crack mapping effort NRR Site Visits 4/1/86 SALP Management Meeting - ,

7/31/86 Inspection of previously unmapped basemat cracks 10/15/86 EP Exercise 1/14-15/87 Project Director Site Visit Commission Briefings None

. Scheduler Extensions Granted None l

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- Reliefs Granted EDG inspection per manufacturer's recommendations delayed until first (vicerefueling)and 18 months scheduled at 24-month intervals thereafter 1J Exemptions Granted Appendix J exemption for postponement of LLRT until first refueling outage g License Amendments Issued

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) Emergency Technical Specifications Issued

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None

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' Orders Issued

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< None 1 NRR/ Licensee Management Conferences 2/21/86 Additional basemat confirmatory analyses refinements 3/27/86 Basemat confirmatory analyses

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, 7/2/86 Basemat surveillance program and crack

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mapping / reload

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Analyses and supporting Technical Specification changes 9/9/86 Reload - related submittals and analyses

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10/21/86 Discussion of licensee's recent reorganization

, and reload - related activities

' 12/9/86 Discussion of refueling outage progress-to-date and schedule for startup testing and return to power

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TABLE I ENFORCEMENT ACTIVITY

• No. of Violations in Each Severity Level

Functional Area III IV V Deviation

. A. Plant Operations 1 2 -

B. Radiological Controls - - - -

C. Maintenance -

3 - -

D. Surveillance -

1 - -

E. Fire Protections -

1 - -

F. Emergency Preparedness -

1 1 -

G. Security and Safeguards 1 12 1 -

H. Outages -

2 - -

i I, Quality Programs and -

6 1 -

Administrative Controls Affecting Quality J. Licensing Activities - - - -

,

K. Training and Qualification - - - -

Effectiveness

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TABLE II ENFORCEMENT ACTIVITY TABULATION OF VIOLATIONS AND DEVIATIONS BY PERFORitANCE CATEGORY A. Plant Operations Violations

. Failure to meet the limiting condit'an for operation for a containment spray pum (Severity Level III, 50-382/86-02)

. Failure to use an adequate RWP and failure to use an approved procedur (Severity Level IV, 50-382/86-02)

. Failure to meet 10 CFR Part 50.72 and 50.73 reporting requirement (Severity Level IV, 50-382/86-15)

Deviations

. Failure to fully implenent the actions specified in response to IE Bulletin 86-01. (50-382/86-13)

. Failure to update an operating procedure within the time period specified in LER-382/86-15. (50-382/86-33)

B. Radiological Controls Violations None Deviations None C. Maintenance Violations i

, Failure to properly document essential chiller retes (Severity Level IV, 50-382/86-02)

. Failure to recall pastdue measuring and test equipmen (Severity Level IV, 50-382/86-15)

. Failure to properly control temporary removal and replacement of current limiting fuse (Severity Level IV, 50-382/86-28)

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-2-Deviations None D. Surveillance Violations

. on fire protection valves as re Failure by to perform Technical valve lineup (Severity Level IV, 50-382/86-29) quired Specifications.

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Deviations None E. Fire Protection Violations

. Failure to p operly control flammable liquid (Severity Level IV, 50-362/86-16 Deviations None F. Emergency Preparedness Violations

. Failure to provide adequate emergency response trainin (Severity Level IV, 50-382/86-04)

. Failure to follow procedures for updating document (Severity Level V, 50-382/86-27)

Deviations None G. Security l Violations

. Failure to demonstrate positive access control personne (Severity Level IV, 50-382/86-01)

. Failure to maintain positive access control through posting of a security office (Severity Level IV, 50-382/86-01)

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. Failure to change locks, keys, and/or. combinations as required.-

(Severity Level IV, 50-382/86-01)

. Failure to properly control access control-packages. - (Severity

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Level IV, 50-382/86-01)

.

. Failure to properly res (Severity Level IV, 50-382/86-01) pond to a vital area alarm.

. Failure to positively control all points of personnel access into a

vital area. (Severity Level IV, 50-382/86-01)

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. Failure to positively control allipoints of personnel access into a vital- area ~. (Severity Level IV, 50-382/86-01)

. Failure to conduct an adequate audit ~of'ths security progra (Severity Level'IV, 50-382/86-10) . .

. . Failure to provide positive access control to' vital area (Severity Level III, 50-382/86-14 and 50-382/86-23)

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. Failure to report a major loss of physical security effectivenes (Severity Level IV, 50-382/86-14)

. Failure to record tests as require (Severity Level V, 50-382/86-14)

f

. Failure to follow procedures detailing duties and responsibilities of security personnel. (Severity Level IV, 50-382/86-16)

. Failure to perform surveillance of the se'curity diesel generator at ,

the requested interval. (Severity Level IV, 50-382/86-26)  !

i j . Failure to follow procedures for escorting of visitor (Severity Level IV, 50-382/86-29) i

~

Deviations-None- Outages f

Violations

. Failure to follow new fuel receipt procedure (Severity Level IV, 50-382/86-29)

1 . Failure to follow radiation work permit procedure (Severity Level IV, 50-382/86-33)

.

, . . - - . , , - . - , , . . - . > , , - , ,,N',,.. r ,.w- , ,

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-4-Deviations None I. Quality Programs and Administrative Controls Affecting Quality Violations

. Failure to take prompt co.Tective actio (Severity Level IV, 50-382/86-13)

. Failure to update drawings following a station modificatio (Severity Level IV, 50-382/86-13)

. Failure to adequately inspect installation of safety-related components. (Severity Level IV, 50-382/86-16)

. Failure to follow procedures for station modification installatio (Severity Level IV, 50-382/86-31)

. Failure to control the use of nonconforming component (Severity Level IV, 50-382/86-31)

. Failure to follow procedures for evaluation of supplier (Severity Level IV, 50-382/87-01)

. Failure to specify plant management succession as required by Techaical Specifications. (Severity Level V, 50-382/87-01)

Deviations None J. Licensing Activities Violations None Deviations .

None K. Training and Qualifications Effectiveness Violations None Deviations None

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TABLE III TABULATION OF LICENSEE EVENT REPORTS BY PERFORMANCE CATEGORY A. Plant Operations Thirteen LERs involved activities in the ' functional area of plant operation . Reactor trip on dropped control element assembl (382/86-01)

. Reactor trip due to dropped control element assembly Number 88 and failure of blowdown valves to close. (382/86-02)

. Reed switch failure results in reactor trip on low departure from nucleate boiling rati (382/86-09)

. Simultaneously using two methods of draining reactor coolant system results in lost of rhutdown coolin (382/86-15)

. Insufficient procedural cequirements resulted in the boron concentration for the safety injection tanks to fall below the Technical Specification limi (382/86-16)

. Reactor trip due to a. turbine trip caused by Hi-Hi level in moisture separator reheater shell Drain Tank-2A. (382/86-19)

. Automatic actuations of engineered safety features portion of the ,

control room ventilation system including electrical spikes, spurious alarms, and equipment failures. (382/86-03,382/86-20,382/86-22, and 382/86-29)

. Reactor trip due to dropped control element assembl (382/86-23)

. Inadvertent discharge of boric acid condensate tank due to procedure noncomplianc (382/86-24) i

. Reactor trip during startup due to prolonged low power operatio (382/86-25)

B. Radiological Controls l l

One LER involved activities in the functional area of radiological l control i

. Technician wore contaminated clothing offsit (382/87-03)

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-2-I Maintenance-

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Three LERs involved activities in the functional area of maintenanc . Personnel error resulted in improper ~ tag-out causing the , low pressure safety injection pump being inoperable due to the discharge valve being closed. (382/86-04)

. Improper connection of contro1' element assembly cable resulted in reactor tri (382/86-13)

"

. Inadvertently opening of safety injection tank isolation valves due to inadequate work instructions. (382/86-14)

. Inadvertent fuel handling ventilation system actuation due to personnel error. (382/86-26)

. Containment isolation valve inoperable due to improper reassembl (382/87-01)

,

. Small size snubber test failures due to improper installation.

l (382/87-02) Surveillance Five LERs involved activities in the functional area of surveillanc . Surveillance procedure resulted in suspect hot leg temperature monitoring operability. (382/86-05)

,

. Mode change without performing surveillance on the boric acid makeup tank. (382/86-06)'

. Operator error during surveillance testing resulted in inadvertent activation of emergency feedwater syste (382/86-08)

. Improper filing of. scheduling card results in failure to perform

, required secondary activity sampl (382/86-10)

. Failure to sample the proper gas decay tank. -(382/86-17)

. Fire protection valve lineup not checked due:to inadequate procedur (382/86-27) Fire Protection

Five LERs involved activities in the functional area of Fire Protection-

. Missed fire watch tou (382/86-07)

. Missing internal penetration fire seals. ;(382/86-11)

. . Deficient fire door surveillanc (382/86-12)

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. Fire watch tour not performe (382/86-21)

. Fire barrier requirement not me (382/87-04)

F. Emergency Preparedness No LERs were issued in this functional are G. Security and Safeguards No LERs were issued in this functional are H. 0: stages No LERs were issued in this functional are Quality Programs and Administrative Controls Affecting Quality The two LERs listed below involved activities in this functional are . Hydrogen recombiner panel not securely mounted due to missing structural weld. (382/86-18)

. Loose steam generator tube plugs due to inadequate installatio (382/86-28)

J. Licensing Activities No LERs were issued in this functional are K. Training and Qualifications Effectiveness No LERs were issued in this functional area.