ML20196C864

SALP Rept 50-482/88-14 for 870301-880331

ML20196C864
Person / Time
Site:	Wolf Creek
Issue date:	06/23/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20196C787	List: ML20196C784 ML20196C864
References
50-482-88-14, NUDOCS 8807010253
Download: ML20196C864 (41)

See also: IR 05000482/1988014

Text

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SALP BOARD REPORT

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

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SISTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

NRC Inspection Report 50-482/88-14

j Wolf Creek Nuclear Operating-Corporation

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l- Wolf' Creek Generating Station

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March 1, 1987, through March 31, 1988

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PDR ADOCK 050004G2

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I. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) program is an

integrated NRC staff effort to collect available observations and data on

a periodic basis and to evaluate licensee performance based upon this

information. SALP is supplemental to normal regulatory processes used to

ensure compliance with 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 quality and safety of plant operation.

An NRC SALP Board, composed of the staff members listed below, met on

May 17, 1988, to review the collection of performance observations and

data, and to assess licensee performance in accordance with the guidance

in NRC Manual Chapter 0516, "Systematic Assessment of Licensee

Performance." A summary of the guidance and evaluation criteria is

provided in Section II of this report.

This report is the SALP Board's assessment of the licensee's safety

performance at Wolf Creek Generating Station for the period March 1, 1987,

through March 31, 1988.

SALP Board for Wolf Creek Generating Station:

L. J. Callan, Director, Division of Reactor Projects, Region IV (chairman)

J. L. Milhoan, Director, Division of Reactor Safety, Region IV

M. R. Knapp, Acting Director, Division of Reactor Safety and

Safeguards, Region IV

D. D. Chamberlain, Chief, Reactor Project Section A, Region IV

B. L. Bartlett, Senior Resident Reactor Inspector, WCGS, Region IV

P. W. O'Connor, Project Manager, Nuclear Reactor Regulation

The following personnel also participated in the SALP board meeting:

J. M. Montgomery, Deputy Regional Administrator, Region IV

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A. B. Beach, Deputy Director, Division of Reactor Projects, Region IV

J. P. Jaudon, Deputy Director, Division of Reactor Safety, Region IV

l R. E. Hall, Deputy Director, Division of Reactor Safety and Safeguards,

I Region IV

l J. B. Baird, Technical Assistant, Division of Reactor Projects, Region IV

C. A. Hackney, Emergency Preparedness Analyst, Region IV

J. L. Pellet, Chief, Operator Licensing Section

R. J. Everett, Chief, Emergency Preparedness and Safeguards Programs

Section, Region IV

R. E. Baer, Chief, Facilities Radiological Protection Section, Region IV

W. M. McNeill, Reactor Engineer, Materials and Quality Programs Section,

Region IV

II. CRITERIA

Licensee performance was assessed in 11 selected functional areas.

Functional areas normally represent areas significant to nuclear safety

and the environment. Some functional areas may not be assessed because of

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little or no licensee activities or lack of meaningful observations.

Special areas may be added to highlight significant observations.

One or more of the following evaluation criteria were used to assess each

functional area:

1. Management involvement and control in assuring quality.

2. Approach to the resolution of technical issues from a safety

standpoint.

3. Responsiveness to NRC initiatives.

4. Enforcement history.

5. Operational events (including response to, analysis of, and

corrective actions for).

6. Staffing (including management).

However, the SALP Board is not limited to these criteria and others may

have been used where appropriate.

Based upon the SALP Board assessment, each functional area evaluated is

classified into one of three performance categories. The definitions of

these performance categories are:

Category 1. Reduced NRC attention may be appropriate. Licensee

management attention and involvement are aggressive and oriented toward

nuclear safety; licensee resources are ample and effectively used so that

a high level of performance with respect to operational safety and

construction quality is being achieved.

Category 2. NRC attention should be maintained at normal levels.

Licensee management attention and involvement are evident and are

concerned with nuclear safety; licensee resources are adequate and are

reasonably effective so that satisfactory performance with respect to

operational safety and construction quality is being achieved.

Category 3. Both NRC and licensee attention should be increased.

Licensee management attention or involvement is acceptable and considers

nuclear safety, but weaknesses are evident; licensee resources appear to

be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety and construction quality is

being achieved.

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III. SUMMARY OF RESULTS

The SALP Board review revealed areas of strength in fire protection and

security with an increase in performance from the previous SALP period.

Performance in the areas of emergency preparedness and surveillance

remained consistent with the previous SALP period. All other areas

revecled a decline in performance or a declining trend from the previous

SALP period. The overall decrease in performance is due, in part, to the

failure of licensee management to maintain effective control of major

outages.

The licensee's performance is summarized in the table below, along with

the performance categories from the previous SALP evaluation period.

Previous Present

Performance Category Performance Category

Functional (02/1/86 to 02/28/87) (03/1/87 to 03/31/88)

A. Plant Operations 2 2

B. Radiological Control 2 2

C. Maintenance 1 2

D. Surveillance 2 2

E. Fire Protection 2 1

F. Emergency Preparedness 2 2

G. Security 2 1

H. Outages 2 3

I. Quality Programs and 2 3

Administrative Controls

Affecting Quality

J. Licensing Activities 1 2

K. Training and Qualification 1 2

Effectiveness

IV. PERFORMANCE ANALYSIS

A. Plant Operations

1. Analysis

The assessment of this area consists chiefly of the activities

of the licensee's operational staff (e.g., licensed operators

and nuclear station operators). It is intended to be limited to

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operating activities such as: plant startup, power operation,

plant shutdown, and system lineups. Thus, it includes

activities such as reading and logging plant conditions,

responding to off-normal conditions, manipulating the reactor

and auxiliary controls, plant-wide housekeeping, and control

room professionalism.

This area has been inspected on a continuing basis by the NRC

resideist inspectors and on several occasions by NRC regional

inspectors. Specific areas inspected included operational

safety verifications, safety system walkdowns, follow up on

significant events / problems, and review of licensee event

reports (LERs).

One violation was identified in this functional area and, while

it indicated additional management controls were needed,

corrective action was promptly initiated by the licensee. Also,

one of the escalated enforcement violations listed in the outage

functional area included three examples of problems relating to

the operations functional area. Four LERs were issued by the

licensee in this functional area. These four LERs had no major

effect on plant safety. One of the LERs concerned the one

violation that was identified in this area. The remaining three

LERs were ali personnel errors and were indicative of a failure

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to pay attention to detail.

Corrective actions initiated by licensee management included

requiring the use of procedures in additional areas in

operations. At the end of the SALP period the use of procedures

in operations was much improved.

Operational events and NRC observations showed that operations

interface with other departments is lacking. There has been an

apparent failure of operations to make effective use of

technical support groups. In some cases even when technical

support groups became aware of problems and provided input to

operations, the input was ignored or was lost. There are two

examples. The first was when operations was not responsive to

Nuclear Safety Engineering's information and advice concerning

the essential service water (ESW) pipe-wall thinning issue. As

a result, timely corrective action was needlessly delayed. The

second was when engineering provided disposition to repair a

section of thinwall safety related pipe and the disposition was

misplaced for approximately 3 months.

In general, operator performance, as observed by the NRC

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inspectors, has been good. Control room professionalism has

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been maintained and good operator morale exhibited. At times,

however, the operators failed to pay attention to detail. Two

examples of this are given below

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The first example occurred when vital batteries were

allowed to be depleted over a 30-hour time span without a

procedure being available to provide alternate AC power to

the battery chargers, and without bus voltage being

observed carefully or without periodically observing

current readings and comparing them to expected values.

The second example was the uncontrolled use of operator

aids. When ESF actuations occurred as a result of the

degraded batteries, the operators relied on the

uncontrolled aids in determining that certain manual

isolation valves were shut. The valves were, in fact,

cpen. When the valves had been opened, the uncontrolled

aid had been forgotten. This resulted in the undesirable

placing of lake water in each of the steam generators.

The licensee continues to give strong management support to the

college degree program for operations personnel. The number of

operators with engineering degrees or working toward degrees is

considered to be a plus.

The number of operators with senior reactor operator licenses

exceed the number of operators with reactor operator licenses by

more than 2 to 1. This allows the licensee more versatility in

the use of the operators, while at the same time giving

operators additional training and mobility.

In general, the licensee maintains a 6-shift rotation of their

operating crews. This allows for a better utilization of the

crews, less overtime, and increased training.

2. Conclusions

The overall assessment of this area indicates that improvements

need to be made. As stated in the previous SALP report,

licensee attention to detail in this area can be improved. The

use of procedures in operations was noted to improve; however,

this occurred only after the situation had been allowed to

deteriorate to an unacceptable level.

The examples of inattention to detail and the lack of effective

operations interface with other departments reflects an

ineffective management oversight in this functional area.

Staffing in this area is considered a strength, along with good

control room professionalism during power operations.

The licensee is considered to be in Performance Category 2 in

this area, with a declining trend.

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3. Board Recommendations

a. Recommended NRC Actions

The level of NRC inspection in this functional area should

be consistent with the basic inspection program.

Supplemental inspections should be performed to focus on

operations interface with other departments,

b. Recommended Licensee Actions

Licensee management should ensure that there is an adequate

and prompt QA, NSE, and engineering involvement in

operational events and in the technical resolution to

safety issues.

B. Radiological Controls

1. Analysis

The assessment of this functional area includes the following

areas of activity which are evaluated as separate subareas to

arrive at a consensus rating for this functional area:

(a) occupational radiation safety, which includes controls by

licensees and contractors for occupational radiation protection,

radioactive materials and contamination controls, radiological

surveys and monitoring, and ALARA programs; (b) radioactive

waste management, which includes processing and onsite storage

of gaseous, liquid, and solid waste; (c) radiological effluent

controls, which includes gaseous and liquid effluent controls

and monitoring, offsite dose calculations and dose limits,

radiological environmental monitoring, and the results of the

NRC's confirmatory measurements program; (d) transportation of

radioactive materials, which includes procurement and selection

of packages, preparation for shipment, selection and control of

shippers, delivery to carriers, receipt / acceptance of shipments

by receiving facility, periodic maintenance of packagings and,

for shipment of spent fuel, point of origin of safeguards

activities; and (e) water chemistry controls, which includes

primary and secondary systems affecting plant water chemistry,

water chemistry control program and program implementation,

chemistry facilities, equipment and procedures, and chemical

analysis quality assurance.

Nine inspections were performed in the area of radiological

controls during the assessment period by Region-based radiation

specialist inspectors.

There were five violations and one deviation identified in this

functional area.

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a. Occupational Radiation Safety

The licensee's programs for occupational radiation

protection, radioactive material and contamination

controls, radiological surveys and monitoring, and ALARA

programs were inspected four times during the assessment

period. Two inspections were conducted during normal plant

operations, one inspection during a scheduled refueling

outage, and one special inspection after the release of

radioactive material to the local county landfill.

The licensee's exposure for 1986 was 142 person-rem

compared to the national PWR average of 392 person-rem.

During 1987, the licensee's person rem exposure was 124

compared to a national PWR of 376 person-rem.

The size of the radiation protection staff was adequate to

support plant operations. A low personnel turnover rate

within the radiation protection group was experienced

during the assessment period. The licensee's approach

concerning the resolution of technical issues indicated

their understanding of issues was generally apparent.

Acceptable resolutions were generally proposed in response

to NRC initiatives.

Those violations identified in the radiation protection

program were an indication of a lack of management

involvement in assuring quality and worker training. The

two concerns noted during the previous assessment period

which included: (1) lack of steam generator mockup

training and (2) lack of health physics supervisory

personnel presence in the plant to oversee and evaluate

ongoing radiation protection activities, had not been fully

resolved.

The licensee had made changes in the position of radiation

protection manager, an individual with limited experience

and not qualified in accordance with Regulatory Guide 1.8

was aupointed to the position. The licensee recently

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I contracted a qualified individual to oversee and provide

direction to the radiation protection program,

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b. Radioactive Waste Management

The licensee's program involving processing and onsite

storage of solid waste was inspected twice during the

assessment period. One violation was identified. The

l licensee released radioactive material as trash which was

found and recovered from the local county sanitary

landfill. The licensee had reduced the volume of

solidified waste generated by use of a portable

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demineralizer skid for liquids and processing spent resins

by dewatering methods. The licensee tyd identified key

positions and defined their- responsitiilities, f

c. Radiological Effluent Control and~ Monitoring t

This area includes gaseous and liquid effluent controls and

monitoring, offsite dose calculations and dtge limits,

radiological environmental monitoring, radiochemistry

program, and radiochemistry confirmatory.yeasurement

results. Threeinspectionswereconductedbyringthe

assessment period, together they encompassed the complete

program area.

lhe licensee has established a program concerning the

control and release of gaseous and liquid effluents.

Liquid and gaseous effluent release permit procedures have

been developed to assure that planud i* pleases receive

proper review and approval prior to releases. A review of

gaseous and liquid releases indicates that offsite doses

were well below Te:hnical Specification limits. Three

concerns were identified relating to: (1) liquid effluent

monitor setpoints, (2) condensate stora4e tank analyses,

and (3) radiation monitor calibration' data.

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The offsite radiological environmental ronitoring program

was inspected once during the ac40sment period. No

violations were identified. The radic,ogical environmental

monitoring program is effectively managed from the

licensee's corporate office and implemented by atation

personnel. The working relationship between the two groups -

has been excellent. ,

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The radiochemistry and water chemistry program 9iich

included onsite confirmatory measurements with the.NRC

Region IV mobile laboratory was inspected onct during tne

assessment period. No violations or deviations'were

identified. The results of the confirmatory mrasurements

indicated 97 percent agreement, a slightly higher value

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d. Transportation of Radioactive Materials

This area was inspected twice during the assessment period

in conjunction with the solid radioactive maste mar,agement

program. Two violations were identified;:d,e Wolation

involved the lack of proper storage and control of quality

assurance records of radioactive material shipments, and

the second related to the lack of training provided to the

health physics supervisor - radwaste. Corrective action

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takenbythelicer.cedhasgenerallybeentimelyand

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Transportation activities at the site usually involve the

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support.and guidance from the corporate offices. The

licensee has eh lblished an adequate quality

control / quality assurance; urogram for low-level radioactive

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material shipments. Transpor(ation activity records are

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This area was inspected once during the assessment period.

The inspection involved the initial use of prepared water i

chemistry standards for confirmatory measurement 1

evaluations.i T'1e results of the water chemistry

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s confiraatory measurements indicated 84 percent agreement \p

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Theserpitsareconsiferedwithinexpectedindustry

performape/ levels. The inspection also identified four

concerns involving inctrumtpt calibration and the quality

control aspect of the wated chrristry analysis program.

2. Conclusions

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The licensee's overall performance indicated a decrease in

effectiveness over the previous assessment period. Seven

violations and one deviation were identified during this t

assessment period, as compared to no violations or deviations

being identified during the previous assessment period.  %

In' adequate management attention tq NRC concerns is demonstrated

' by the lack of resolution to the4 concerns noted during the

previous assessment period, which were: (1) f ack. of stea'm

generator mockup training and (2) lack of health /,;hysics . )/

supervisory personnel presence in the plant to oversee and

evaluate ongoing radiation protection activities. Improvements

were noted regarding the implementation of the ALARA program. .

The licensee's personnel radiation exposure history has been '

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better than ( Mss than one half) the national average for PW P.

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No significant problems were identified in the functional areas l

1 of trans;brtation of vadioactive material, and radiological l

effluentuontrol and monitoring. The licensee's program for i

,, 1 these areas appeded adequate regarding management oversight, s,l}

resolutioA,6ftechr{lty.1 issues, training, procedures,and ,, j

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The licenset is considere4 to be in Perforkahce Category 2 in

this area. 'dowwer, during the SALP period, performance was

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decreasing. ~Recent changes in management have not yet had ,t;ile

to be effective.

3. Board Recommendations  !

a. Recommended NRC't.ctions

The NRC inspedt.' ion effort in this area shculd be consistent

with the basic inspection prograr with increased emphasis

on management involvement to assure quality,

b. Recommended Licensee,_ Actions i

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Health physics stperviscry personnel should spend more time

in the radiological 1y controlled areas evaluating and

observing ongoirg re:diation protection w k activities to

ensure compliance with station procedures. Management

should take action to provide training to technicians to

enhance procedural compliance.

C. Maintenance

1. Analysis

TheassessmentofthisareaiM1udesalllicenseeandcontractor

activitics associated with preventive or corrective maintenance

of instrumentation and control equipment'and mechanical and

electrical systems.

This area was inspected on a continuing basis by the NRC

resident inspectors and periodically by NRC regional inspectors.

There were two violations identified in this area. These

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violations involved the failure of the licensee to request a

code ex.emption when required and three examples of a failure to (

follow precedures. There were 11 LERs issued by the licensee in

this functional area. One LER was due to inadequate

pct-maintenance / testing or, a containment isolation valve,

another LER was due to an accidental mispositioning of a breaker

switch.

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l The escalated enforcement action that was taken due to the

problems which occurred during the fall refueling outage

revealed significant problems within the mainterance

organization. These problems consisted of workers failing to

follow procedures, inadequate proceduras, inadequate control

over special processes, and an overs ' 5reakdown of management

oversite of maintenance activities dunng the eefueling outage.

l One of the major causes for the problems which occurred this

SALP period was workers failing to follow procedures.

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Three of the findings in the escalated enforcement package were

workers failing to follow procedures. These included issuance

a < i cf the wrong weld rod material, use of the wrong weld rod

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material, and failure to check for an energized circuit. There

-have been multiple occurrences of Wolf Creek event reports

written for failure to follow procedures. The failure to follow

procedures was pervasive at the Wolf Creek site. This could

only exist if it was allowed to slowly build up over a period of

months or years. Licensee management was not effective in

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correcting the problem.

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~/ During the last quarter of the SALP period, the maintenance

management organization underwent significant changes

Maintenance was combined with facilities and modificat. ions to

form maintenance and modifications. This change combines all

maintenance activities under a single manager. The

superintendent of maintenance transferred to the outage plannin0

group and the manager of facilities modifications became the

manager of maintenance and modifications. In addition, some

lower level h.anagers were transferred and some positions were

eliminated. These changes appear to have significantly

strengthened the maintenance area.

2. Conclusions

The NRC found evidence of upper management support for a strong

maintenance program. However, the implementation of this

program was not adequately carried out. Management oversight of

the day-to-day activities in the area of maintenance declined

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significantly during the assessment period. Several examples of

the results of this decline were identified. Towards the end of

theSALPperiod,majormanagementchangeswereimplemented.

These changes appear to have significantly strengtherad

- management oversight of maintenance activities.

The licensee is considered to be in Performance Category 2 in

this functional area.

3. Board Recommendations

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a. Recommended NRC Actions

l The NRC inspection effort in this area should be consistent

with the basic inspection program. The resident inspectors

should increase their inspection activities in this area.

b. Recommended Licensee Actions

l The licensee should follow through and assess the

l effectiveness of their corrective actions. The licensee

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should continue the increased emphasis on procedural

compliance.

D. Surveillance

1. Analysis

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The assessment of this functional area includes all surveillance

testing and inservice in;pections and testing activities.

. Examples of activities included are: instrument calibrations,

equipment operability tests, special tests, inservice inspection

and performance tests of pumps and valves, and all other

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inservice inspection activities.

This functional area was inspected on a routine basis by the NRC

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resident inspectors and periodically by NRC regional inspectors,

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The enforcement history in this functional area identified two

violations during this assessment period. Also, several LERs

were issued by the licensee during this assessment period.

Personnel errors and inadequate procedures were the predominant

causes of the violations and reportable events during this

assessment period. This resulted in examples of missed

surveillances, late performance of surveillances, inadequate

post-test review, and undesirable engineered safety feature

actuations which are similiar to problems which occurred during

the previous SALP period.

During the previous SALP period, the licensee was rated a SALP

Category 2 in this functional area with a decreasing trend.

Although the enforcement and reporting history indicate

improvement, as noted above, similar procedural and personnel

errors are being repeated during this SALP period.

2. Conclusions

The overall assessment for this functional area indicates a

program for scheduling and tracking of surveillance activiG es

that appears adequate. Procedures in some cases did not address

all Technical Specification surveillance requirements

adequately. The repeat procedural and personnel errors indicate

that additional management involvement is needei

The licensee is considered to be in Performance Category 2 in

this functional area.

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3. Board Recommendations

a. Recommended NRC Actions

The level of NRC inspection in this functional area should

be consistent with the basic inspection program,

b. Recommended Licensee Actions

The licensee is encouraged to perform an indepth review of

the Technical Specification surveillance requirements and

ensure that the surveillance procedures address these

requirements. Also, additional management involvement with

surveillance activities is encouraged.

E. Fire Protection

1. Analysis

The assessment of this area includes routine housekeeping

(combustibles, etc.) and fire protection / prevention program

activities. Thus, it includes the storage of combustible

material; fire brigade staffing and training; fire suppression

system maintenance and operation; and those fire protection

features provided for structures, systems, and components

important to safe shutdown.

This area was inspected by a Region-based inspector and on a

continuing basis by the NRC resident inspectors. During this

assessment period the fire protection group went through some

organizational changes. One change was the transfer of the fire

protection training duties from the supervision of the fire

protection engineer to the trainir.g department. The other

change was the transfer of the fire protection group from the

plant support organization to the operations organization.

The following observations were made:

. The licensee has made significant improvement in the area

of administrative controls for fire barrier penetrations

and openings. Especially significant has been the

reduction of missed fire watch patrols.

. Control of transient combustibles has been effective.

However, housekeeping could be improved in the area where

trash is being deposited in other than approved containers

(example: openings in tube steel).

. Fire brigade / watch training continued to be outstanding.

The transfer of the fire training group to the training

department has shown no adverse effects.

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The licensee instituted a program to identify all fire barrier

penetration seals that were either never sealed or removed and

not resealed. This was an extensive program which the licensee

aggressively pursued and completed.

2. Conclusions

The licensee has shown significant improvement in their fire

protection / prevention program. Management involvement, both in

the program as well as training, was evident. The major reason

for the improvement in this area has been the continuing

dedication and hard work of the well qualified fire protection

engineer and training instructor.

The licensee is considered to be in Performance Category 1 in

this area.

3. Board Recommendations

a. Recommended NRC Actions

The level of NRC inspection in this functional area should

be consistent with the minimum inspection program,

b. Recommended Licensee Actions

The licensee should assure that the recent organizational

changes that have the fire protection engineer reporting to

a different group and at a lower management level does not

result in a reduction of management support.

F. Emergency Preparedness

1. Analysis

The assessment of this area inciudes the licensee's preparation

for radiological emergencies and response to simulated

emergencies (exercises). Thus, it includes emergency plan and

implementing procedures; emergency facilities, equipment,

instrumentation, and supplies; organization and management

control; training; independent reviews / audits; and the

licensee's ability to implement the emergency plan.

During the assessment period, four emergency preparedness

inspections were conducted by Region-based and NRC contractor

inspectors. One of these inspections was the observation and

evaluation of an annual emergency response exercise by a team of

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NRC and contracter inspectort. During the exercise, four

l deficiencies from a previous exercise were closed and one new

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deficiency was identified. The deficiency identified during the

exercise involved incorrect classification of the emergency as

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an unusual event rather than an alert. The licensee's overall

performance during the exercise was evaluated as good. The NRC

staff concluded that licensee emergency response personnel

demonstrated their ability to protect the health and safety of

the public.

Three routine inspections resulted in identification of three

violations. One violation involved failure to document required

communication tests of the emergency response facilities. The

other two violations, one of which was a repeat violation,

involved tailure to determine availability of required emergency

preparedness personnel in the event of an accident. Training

was identified during the previous SALP period report as an area

needing management attention. The licensee has developed lesson

plans, revised training requirements, and implemented a more

efficient record management system.

The 1987 SALP report stated, "However, several changes were made

to the onsite emergency planning administrator (EPA) position,

and the replacement EPAs have had little previous experience in

this area." Due to attrition, new inexperienced personnel have

been assigned the onsite emergency planning and preparedness

responsibilities. Discussions held with onsite management

revealed a difference of opinion as to what the functions of the

onsite emergency preparedness coordinator were and would be in

the future. The offsite emergency preparedness administrator is

located in Wichita, Kansas. The licensee ha; recently added

another level of supervision above the EPA, removing the EPA

further away from plant management. (This reorganization

presently is awaiting NRR approval.) The emergency preparedness

program appears to be in a trantition phase with the shift in

lead responsibility for emergencf program to the corporate

office.

2. Conclusions

The violations issued in shift staffing and augmentation

indicate that the personnel notification method and procedure

requires additional improvement. Hansgement attention should be

devoted tu meeting regulatory requirements and licensee

commitments.

Licensee management attention and involvement are evident;

licensee resources are adequate and reasonably effective so that

,

satisfactory performance with respect to operational safety and

l construction quality is being achieved.

l

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.-. -_ _- -

- _ _ _

. .

16

The inspection findings for this evaluation period indicate,

overall, that the licensee's emergency preparedness program is

adequate to protect the health and safety of the public.

The licensee is considered to be in Performance Category 2 in

this area.

3. Board Recommendations

a. Recommended NRC Actions

NRC attention should be maintained at normal levels.

Attention should be directed to licensee action taken

toward correcting the call-out drill response and shift

augmentation response times.

b. Recommended Licensee Actions

The level of management attention to the implementation of

the emergency preparedness program should be increased to

ensure proper response to NRC identified concerns relating

to call-out drill response and shift augmentation response

times. The licensee should expedite correction of the

call-out drill response and shift augmentation concern.

Management should review the distribution of onsite and

offsite emergency program areas of a thority and

responsibilities.

G. Security

1. Analysis

The category of security relates to all activities whose purpose

it is to ensure the protection of the plant. Specifically, it

covers all aspects of the security program including ancillary

efforts such as fitness for duty and access authorintion

programs. Examples are: the licensee's overall management

involvement ir, e-tablishing protective policies; designing

physical security systems; submitting the security plan and

implementing associated procedures; selecting, training,

equipping, and supervising personnel; maintaining the hardware '

that suppcrts the program; and auditing and measuring the

performance of the security program.

This area was inspected on a continuing basis by the NRC

resident inspectors and on a periodic basis by the NRC

Region-based inspectors. Four inspections were conducted by

Region-based NRC physical security inspectors during the

assessment period. Four violations were identified, two by the

licensee,

f

. _ _ _ ,__ -

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

, ,

17

There was evidence of prior planning and assignment of

priorities. _ Policies and procedures are well stated,

appropriately disseminated, and understandable. Decisionmaking

was usually at a level that ensured adequate management review.

The.new corporate structure, which includes a repositioning of

the Quality Assurance Department, is committed to continuing an

independent and effective oversight of security-related matters.

Management reviews of identified security ratters were timely,

thorough, and technically sound. The init.a1 review of security

incidents has improved and further examination for generic

significance has been enhanced. Records were generally

completo, well maintained, and available. Rarely were

procedures and policies violated. However, ;ome cases of

personnel failure have occurred and these appear to be

associated with temporary employee hiring practices. Corrective

action on licensee identified violations was generally

effective.

A clear understanding of security issues was demonstrated and

subsequent decisions reflected reasonable and prudent judgement

on the part of management. These kinds of judgements were also

demonstrated in the Training and Human Relations Departments

where security's ancillary efforts, such as fitness for duty,

continual observation of employee's behavior, and the access

authorization programs were managed.

There has been a major organizational restructuring of the

Quality Assurance (QA) Department. The chanaes have been too

recent to evaluate their impact on the herett fore strong

security oversight effort. There is some concern that these

changes will not provide the level of audit expertise previously

provided. A review of these changes and the quality of the

audits performed will be necessary in the future.

The licensee has been usually responsive to NRC initiatives, but

there continues to be two long standing regulatory issues

attributable to the licensee. These are control room access and

alarm assessment capability. Technically sound and acceptable

resolutions were proposed initially in most cases, but

timeliness of resolution for these outstanding issues is slow.

After considerable discussion, the licensee agreed that their

CCTV system had degraded and proposed proper corrective actions.

One major violation concerning security personnel attentiveness

was directly attributable to a member of the security

, organization. It was promptly and effectively corrected. A few

l

minor procedural mistakes by security personnel have occurred,

'

but were not repetitive. These mistakes appear to be indicative

of a need to enhance the selection process for temporary

l

security personnel and to be persistent in programmatic

'

training.

l

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_ _ _ _ _

+ .

18

Occasional computer outage related events, construction / outage

worker misunderstandings of security requirements, and

maintenance related activities were attributable causes to

violations. These events were identified and reported in a

timely manner.

Security organization positions were clearly identified.

Authority and responsibility was clearly defined. This included

the relationship with the rest of the corporate organization.- A

new squad manning structure has allowed for training and

practice in squad response tactics. Temporary contract

personnel, while not meeting anticipated standards, have been

utilized to staff appropriate watchperson billets. However, the

employment practices used for these temporary watchpersons,

combined with their lower experience levels and abbreviated

training, appear to have had some adverse impact on the security

operation. It did accomplish the overall goal of providing

relief for the more experienced offi ers and to make them

available for more critical tasks.

2. Conclusions

The licensee appears to have an ample number of supervisors,

fully qualified security officers, and support personnel

assigned to the security department to comply with the several

security plans. With the exception of a few minor procedural

errors, the security force had operated at a high level of

performance. The 'icensee management's attention and

involvement with nuclear security is evident. Licensee

resources were appropriate and effective so that there was very

good performance with respect to site physical and personnel

security.

The licensee is considered to be -:, Performance Category 1 in

this area.

3. Board Recommendations

a. Recommended NRC Actions

The NRC inspection level of the security program should be

consistent with the minimum inspection program, with some

exceptions. Exceptions where a more expanded inspection

effort is recommended include: licensee measures to

enhance and maintain physical security systems; methods for

selecting, training, equipping, posting and supervising

security personnel; and changes to the QA function where

audits are performed to measure the performance of the

security program and its ancillary efforts.

l

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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _

. .

19

b. Recommended Licensee Actions

The licensee should continue to probe the causative factors

of security events for broader implications and adjust

programs, training, disciplinary actions, maintenance, and

engineering responses appropriately. The organizational

adjustments made in the QA area should be closely monitored

to ensure that the high quality of the security oversight

program continues.

H. Outage

1. Analysis

The assessment of this area includes all licensee and contractor

activitiesassociatedwithmajoroutages. It includes

refueling, outage management, major plant modifications, repairs

or restoration to major components and all post-outage startJp

testing of systems prior to return to service.

This area was inspected on a continuing basis by the NRC

resident insp:ctors, and periodically by NRC regional

inspectors. In addition, an inspection was performed by a

safety system outage modification inspection (SCOMI) team. The

inspections included refueling activities, outo s management,

planningandscheduling, staffing,majorcomp.mnts/ systems

repairs and modification, and startup testing.

The licensee had two major outages during this SALP period.

There was a refueling outage which lasted approximately 101 days

and an outage to replace leaking reactor vessel 0-rings which

lasted approximately 16 days. Refueling outage activities

included replacement of Raychem splices, replacement of eroded

essential service water pipe, annual inspection of the diesel

generators, removai of heaters from Limitorque valve operators,

replacement of reactor coolant pump "B" number one seal,

replacement of the trip mechanism shafts on the reactor trip

breakers, replacement of the tube bundle in the jacket water

heat exchanger for diesel generator "A", rework of Valcor valve

operators, cleaning of condenser tubes and inspections for thin

wall pipes. There were numerous significant operational events

which were attributable to causes under the licensee's control

in this functional area.

There were four violations identified in this functional area.

Two of the violations involv.d escalated enforcement action and

a proposed imposition of Civil Penalty. There were two LERs

issued by the licensee in this functional area. The two LERs

were on events that resulted in violations being issued.

l

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- - _ _ _ _ _ _ _ .

_.

. .

20

The two violations that resulted in escalated enforcement

involved examples of procedural control weaknesses that the NRC

considered significant. These weaknesses indicate management

failed to provide an appropriate level of management oversight

of safety-related activities. This is evidenced by the examples

sited below as well as other areas in this report. Management

oversight of outage activities was less than adequate as pointed

out by the six examples of failure to follow procedures and four

examples of inadequate procedures listed in the escalated

enforcement package. The NRC staff was concerned with the

licensee's lack of indepth analysis of these events. The

licensee's ability to perform root cause analysis and implement

timely and appropriate corrective actions was a noted weakness.

During repair efforts on thin wall pipe due to erosion / corrosion

the licensee experienced some difficulty. The licensee had on

site a contractor workforce knowledgeable and experienced in the

forming, fitting, rigging, and aligning of heavy pipe. The

licensee decided to repair the thin wall pipe with their

permanent maintenance workforce. The maintenance workforce was

not as experienced in this area as the contractor workforce.

This resulted in significant problems due to failure to follow

procedures, failu.*e to follow work instructions, and failure to

accomplish work activities by appropriately qualified personnel.

Maintenance management failed to realize the scope of work was

beyond their expertise.

The licensee was generally responsive to NRC concerns, however,

there was a lack of aggressive response to identified problems

prior to NRC involvement. The licensee's investigation of

outage related events indicated a less than aggressive approach

to the resolution of technical issues. The 0-ring outage, which

was the second najor outage of the year, indicated that the

licensee failed to control the 0-ring cleanli ess. The licensee

decided to restart the plant after the first outage with known

inner 0-ring leakage.

2. Conclusions

The licensee's ability to plan, manage, and maintain control over

complex outage evolutions was inadequate and resulted in escalated

enforcement action. The licensee apparently failed to beli 2 in and

enforce strict procedural compliance. Aggressive management

involvement to address problems that occurred during the outage was

lacking.

The licensee is considered to be in Performance Category 3 in this

area.

_j

. .

21

3. Board Recommendations

a. Recommended NRC Actions

_

. Supplemental NRC inspections should be performed prior to

and during the next major outage.

b. Recommended Licensee Actions

The licensee should ensure that lessons learned from the

previous outages are identified and reviewed for program

improvements. The results of this review should be

incorporated into outage planning and control.

I. Quality Programs and Administrative Controls Affecting Quality

1. Analysis

The assessment of this area includes all management control,

verification and oversight activities which affect or assure the

quality of plant activities, structures, systems, and

components. This area may be viewed as a comprehensive

management system for controlling the quality of verification

activities that confirm that the work was performed correctly.

The evaluation of the effectiveness of the quality assurance

system is based on the results of management actions to ensure

that necessary people, procedures, facilities, and materials are

provided and used during the operation of the nuclear power

plant. Principal emphasis is given to evaluation of the

, effectiveness and involvement of management in establishing and

assuring the effective implementation of the quality assurance

prograa along with evaluation of the history of licensee

performance in the key areas of: committee activities, design

and procurement control, control of design change processes,

inspections, audits, corrective action systems, and records.

In order to more clearly define the specific strengths and

weaknesses noted in this functional area, the analysis is

divided into three areas, as discussed below:

f

a. Engineering

l

,

! This area has been inspected on a routine basis by the NRC

l resident inspectors and by a SSOMI team inspection during

( the assessment period.

I

The staffing in the engineering area is generally adequate

in terms of numbers, but it is weak in experience and

training. Further, the weaknesses identified by the 550MI

inspection are indications that the communications between

the plant operating staff and the engineering organizations

l

. .

22

were poor. In one case, engineering made a change to the

cooling system for an electrical equipment room,.which

required manual adjustment of a flow control valve to

adjust the temperature. Since the temperature in this room

was required to be maintained within a relatively narrow

range, a surveillance program to ve-ify the temperature

should have been instituted but was not. As a consequence,

the qualified life or performance of the equipment may have

been affected.

In another instance, it appeared that the operating staff

failed to ask for engineering guidance when performing a

maintenance activity that resulted in a deep discharge of

the safety-related station batteries and disablement of the

vital AC buses at the same time. This in turn led to the

introduction of lake water into the secondary side of the

steam generators.

The S50MI report includes a concern that appears to be

largely attributable to engineering since it involved a

failure to properly evaluate the effect of a temporary

modification. The modification involved application of a

clamp to keep a safety-related damper in the control room

emergency ventilation system open. Had actuation of the

damper been required, an operator would have had to remove

the clamp. The application of the clamp in such a manner

violated the intent of the Technical Specification for

system operability. There were also three LERs that were

at least in part attributable to engineering activities.

In each case, the LERs became necessary because there were

errors in design documents such as drawings,

specifications, and instrument set point data.

b. Quality Assurance

This area has been inspected by both the NRC resident

inspectors and regional inspectors. In addition, the SSOMI

team inspected the areas of procurement, material storage,

and audit activities.

There were two violations in the areas of procurement and

of material receipt. Additionally, some of the problems in

the management of the outage were related to QA.

The licensee had received, accepted, and installed a

noncode part which formed a portion of the reactor coolant

system boundary. An audit after the plant restarted

disclosed this, and subsequent waiver to the code was

granted.

l

_

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. .

23

,

The reactor vessel head 0-rin'g seals were not correctly

inspected prior to installation. Although this was not the

major contributor to the 0 ring leak, it showed a tendency

for quality performance to be at pro forma level.

During the outage, there were problems with the weld

repairs to the essential service water systems. The'e

problems included the issue of inappropriate welding

materials and welders making welds for which they were not

qualified. These problems were uncovered by quality

checks, but the investigation revealed that QA had missed

several opportunities to identify the problems earlier.

The licensee's vendor audit program did identify a problem

with the certification of fuses purchased from a supplier.

lhe licensee reported the facts to the NRC. Follow up

action by the NRC resulted in the issue of an Information

Notice.

The licensee had not conducted training in root cause

determination. Corrective actions tended to be focused on

specific events and did not often probe for the underlying

causes. For example, when a four-way valve on the MSIV

actuator failed, the original root cause deter.nination was

not correct. The redesigned valve subsequently failed.

When incorrect fasteners were found in the charging pump

check valve, they were replaced. No determination was made

as to whether the problem was the fault of the fastener or

the valve manufacturer.

c. Management and Administrative Controls

This area has been inspected on a routine basis by NRC

resident inspectors and regional inspectors.

During this SALP period, the licensee realized the

existence of problems with safety-related pipe wall

thinning. NRC had two basic concerns with this issue. The

first concern was that the short term operability

determination of the thin wall pipe was not technically

sound in that it was made by plant management without input

from engineering. Management did not reassess system

operability even after engineering made the determination

that the pipe did not meet code requirements. Plant

management communications with engineering was not

adequate. The second concern was with long term corrective

actions. Plant management's narrow focus on the issue of

short-term operability showed that their understanding of

the issue was lacking. The question of generic application

of one thin wall pipe to other areas in the plant was not

addressed in a timely manner. It was not until these

i

m _

. -_ ____ _- _.

.- .-

24

issues were raised by Nuclear Safety Engineering and the

Nuclear Safety Review Committee that appropriate corrective

actions were begun. The operational response to this

problem was not timely and lacked thoroughness. The above

is one example of a lack of management involvement in

assuring quality. Other examples have been cited in other

SALP areas.

The enforcement history in the area includes seven

violations and no deviations. Four violations were related

to the environmental qualification of equipment. Ten LERs

were issued by the licensee in this area. Eight of these

LERs were related to control room ventilation isolation

system (CRVIS) actuations. Six of these were due to

problems with the chlorine monitors. The licensee has made

great strides in reducing the number of reportable events

due to CRVIS actuations; however, the reliability of the

chlorine monitors is still low. The improvement effort in

this area has been protracted. This has resulted in the

control room operators no longer trusting their chlorine

monitors.

2. Conclusions

The assessment of this functional area indicates that management

has not been effective in timely resolution of important issues.

Corporate management oversight of plant activities does not

always ensure adequate involvement of the quality and

engineering organizations in plant operations. When problems

are identified by the quality and engineering organizations they

are not always acted upon in a timely manner.

The licensee is considered to be in Performance Category 3 for

an overall rating of the SALP area of quality programs and

administrative controls affecting quality.

3. Board Recommendations

a. Recommended NRC Actions

Supplemental inspection effort should be devoted to this

area.

b. Recommended Licensee Actions

Increased corporate management involvement in site

activities is recommended. In particular, additional

corporate management involvement is needed to ensure that

proper engineering and QA involvement is maintained in all

activities.

. o

25

J. Licensing Activities

1. Analysis

During-the pre:,ent rating period, the licensee's management

participated effectively in assuring the quality of submittals

forlicensingactionsandinresponsestoNRCstaffrequests.

The licensee s reviews were generally timely, thorough, and

technically sound. The licensee's participation was evident in

the ATWS Rule (10 CFR 50.62) submittal which demonstrated that

the licensee appeared to adequately understand staff policies

and be able to make decisions based on adequate management

involvement. The licensee's submittal contained all of the

information that the staff requested for its review. An

appropriate level of management was present and significantly

involved at the review meeting held with the licensee, and the

licensee's technical presentations were technically sound.

The licensee management was involved and responsive during the

staff's review of WCNOC's request to remove the fire protection

program from the Technical Specifications. This licensing

action was the lead cause for generic technical specification

improvements and involved rapidly evolving staff requirements.

Because WCN0C involved its management in this review, they were

able to respond promptly to staff concerns to bring the review

to completion.

,

The WCNOC management has generally exhibited an adequate

understanding of the approach needed to resolve complex

technical issues involved in licensing activities. WCNOC's

June 16, 1987, submittal supporting analysis related to relaxed

outage time and increased surveillance intervals demonstrated a

clearunderstandingofthelicensingissuesinvolvedand

followed the staff s guidance exactly as provided in the related

generic documentation.

The quality and level of detail of the licensee's safety

evaluation summaries submitted pursuant to 10 CFR 50.59(b)(2)

are not always adequate to permit the staff to conclude their

acceptability. In some cases these summaries only provide a

brief description of the change followed by a conclusive

statement that the change does not generate an unreviewed safety

or environmental question; they dn not provide a summary of the

WCNOC safety evaluation that was prepared to support the change.

In review of WCN0C's submittal related to their inservice

testing program for pumps and valves, the staff met with the

licensee on September 8 and 9. During the meetings the licensee

agreed to revise their IST program in specific areas. However,

WCNOC did not make a number of revisions in their March 2, 1987,

Revision 6 resubmittal, as agreed to in the earlier meeting.

. _ _ _ _ _ _ _ _

. . . .

26

The failure to follow up on the agreed upon technical resolution

delayed the completion of the licensing action on the inservice

testing program.

The licensee had been generally responsive to NRC initiative

during this rating period, with few longstanding regulatory

issues being attributable to_the licensee.

On occasion, the licensee's response had not been adequate to

permit the staff to resolve the technical issue without the need

for additional interaction with the licensee. The staff's

review of WCN0C's submittal related to the main steam line break

outside of containment issue required multiple requests for

additional information, and the licensee's responses to these

requests were not expeditious.

.

The licensee reported 53 nonsecurity events to the NRC

!

operations center pursuant to 10 CFR 50.72. These events were

almost always reported in a timely manner.

The licensee also submitted 49 nonsecurity Licensee Event

Reports (LERs) during the reporting period. The LERs were well

written and almost always timely.

There have been 8 LERs during this reporting period that have

been caused by malfunctions or spurious actuations of the

chlorine monitors. These LERs follow up on 18 previous LERs

that have occurred since Wolf Creek was initially licensed.

This continuing series of LERs is indicative of a failure to

identify the root cause of these failures and an ineffectual

corrective action program for the chlorine monitor problems.

The plant has experienced seven unplanned scrams during this

rating period. All of the scrams occurred during Cycle 2 which

ended in September 1987. There were three Safety System

Actuations, no Significant Events and five Safety System

Failures during this rating period.

2. Conclusion

The licensee continues to maintain a competent, knowledgeable

'

licensing staff; however, during this rating period there were

occasional instances of lack of timely response to staff

requests and a decline in content of summaries of safety

evaluations submitted by the licensee in response to

10 CFR 50.59. The licensee is considered to be in Performance

Category 2 in this area.

_______.

. .

27

3. Board Recommendation

a. Recommended NRC Actions

None

b. Recommended Licensee Actions

The licensee should improve the quality of the safety

evaluation summaries submitted pursuant to 10 CFR 50.59 and

should improve the content of licensing submittals to

preclude the need for staff requests for additional-

information that could have been foreseen by the licensee.

K. Training and Qualification Effectiveness

1. Analysis

The assessment of this functional area includes all activities

relating to the effectiveness of tne training / retraining and

qualifications program conducted by the licensee's staff. This

area was inspected on a continuing basis by the resident

inspectors. This area was also the subject of an inspection

which was performed during the appraisal period to look into the

training of both the licensed and nonlicensed staff. During the

appraisal period, licensing examinations were administered by

the NRC to seven (7) reactor operator (RO) candidates and to

seven (7) senior reactor operator candidates. Five (5) of the

R0 candidates and six (6) of the SR0 candidates passed the

examinations and were subsequently issued licenses. The

licensee currently has 36 individuals who hold an SR0 license

and 15 individuals who have an R0 license. During the

administration of the above examinations, the examiners found

that the trainees had been adequately informed of the

significant events that had occurred during the week of

October 18, 1987. The trainees had also been schooled on the

lessons learned from these events.

The inspections in the operator requalification training area

indicate that the management oversight in this area has not been

sufficiently thorough. This is evidenced by:

The section of the procedure (ADM 06-224) on licensed

operator requalification training which relaxed a

requirement of 10 CFR 55 without Commission approval.

.

An operator who had failed the annual requalification

'

examination and was therefore reouired to enter into an

l accelerated requalification program was allowed to continue

j to stand watch and perform watch standing duties prior to

his completion of the accelerated training.

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28

The required reactivity manipulations had not been

completed in the 1985-1986 requalification cycle for at

least six licensed individuals. The correction of this

problem had not been formally addressed, but an informal

effort by the simulator instructors is to track the

performance of the manipulations by each licensed

individual.

During 1986, at least nine licensed individuals had failed

to review all of the emergency and off-normal procedures as

required by the requalification program. The licensee

revised the appropriate procedure to specify the aff-normal

and emergency procedures to be reviewed. The procedures

requested after the revision were also incomplete and the

procedure had to be further revised at the prompting of the

NRC inspector,

The licensee had not provided procedures for irplementing

the 10 CFR 55 rule change issued by the NRC on May 27,

1987.

The above examples are indicators that the training department

arrangement had not provided the attention tc detail necessary '

to assure adequate oversight of this area.

There has also teen evidence of inattention to detail on the

part of the training staff. Examples of this are:

minor uncorrected errors in the lesson plans that were

reviewed;

failure to have lectures scheduled for 10 CFR Parts 2, 21,

50, and 55 in the operator requalification program;

failure to revise a procedure to reflect a new requirement

instituted by a rule change; and

failure to delete a procedure requirement which was dropped

by a ruie change.

No deficiencies were identified in the area of training of the

nonlicensed staff. The procedures and policies in this area

were adequately stated and understood. Training records in this

area were generally complete and well maintained.

2. Conclusions

,

The initial training of licensed operators and the training of

! the nonlicensed staff is effectively controlled and the

licensee's performance in licensing examinations has been good.

The area of requalification training for licensed operators has

l

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. _ _ _ _ - . . _ _ .__ _ . _____ _ _ _ _ _ _ - _ _ _

,

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29

suffered from an apparent lack of management oversight and

. inattention te detail on the part of the training staff. The

licensee is considered to be in Performance Category 2 in. this

area.

3. Board Recommendations

a. Recommended NRC Actions

The NRC inspection effort in this area should continue at

the level prescribed by the basic inspection program.

b. Recommended Licensee Action

The licensee should further emphasize the need for

oversight of operator requalification training and the need

for the training staff to be more attentive to details in

the performance of their activities. Licensee management

should continue their oversight and support of the training

of the nonlicensed staff.

V. Supporting Data and Summaries

A. Licensee Activities

Major Outages

. The unit was shut down on April 19, 1987. The cause was an

inadvertent trip due to control rod logic card f:ilures. The

outage duration was 13.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />,

. The unit was shut down on April 23, 1987. The cause was an

inadvertent trip due to control rod logic card failures. The

outage duration was 33 hours3.819444e-4 days <br />0.00917 hours <br />5.456349e-5 weeks <br />1.25565e-5 months <br />.

. The unit was shut down on May 28, 1987. The cause was an

inadvertent trip due to a loss of power to the main turbine

electro-hydraulic control system. The outage duration was

22.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

. The unit was shut down on June 29, 1987. The cause was an

inadvertent trip due to a loss of a main feedwater pump. The

outage duration was 38 hours4.398148e-4 days <br />0.0106 hours <br />6.283069e-5 weeks <br />1.4459e-5 months <br />.

. The unit was shut down from July 20, 1987, to July 26, 1987.

The cause was an inadvertent trip due to a loss of a main

feedwater pump. The outage was extended to repair a containment

cooling fan. The outage duration was 129.3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />.

, --_ ___ _

. .

,

30

. The unit was shut down on September 10, 1987. The cause was an

inadvertent trip due to a failure of a main transmission line.  ;

The outage duration was 33.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.  ;

. The unit was shut down on September 27, 1987. The cause was an

inadvertent trip due to a mispositioned rod control switch. The

licensee decided to remain down and enter refueling outage II *

early. The outage duration due to the inadvertent trip was j

93.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />. The refueling outage duration was 2,418.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />.

. The unit was shut down on January 21, 1988. The cause was a

manual shutdown to replace failed reactor vessel 0-rings. The

outage duration was 379.2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. During startup following this

outage, two turbine trips without reactor trips occurred. The

duration of each of these two outages was 9.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />.

B. Inspection Activities

NRC inspection activity during this SALP evaluation period included .

49 inspections performed with 6031 direct inspection manhours

expended. These inspections included team inspections of the

equipment qualification program and a SSOMI. This inspection effort

represents an approximate 50 percent increase over the previous SALP

period.

Table 1 provides a tabulation of NRC enforcement activity for each i

functional area evaluated. Table 2 provides a listing of inspection

findings in each SALP category.

C. Investigations and Allegations Review

There was one investigative activity conducted during this assessment

period. The results have not been formally issued yet.

D. Escalated Enforcement Actions

1. Civil Penalties

A Notice of Violation and Proposed Imposition of Civil Penalty

was issued on March 17, 1988. A $100,000 civil penalty was

proposed for two Severity III violations involving a failure to

follow procedure and a failure to have appropriate procedures.

2. Enforcement Orders

None

_ _ _ _ _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ _ _ _ _ _ ._ ___ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _

_

s- l4

-

31

E. Management Conferences Held During Assessment Period

1. Conferences

A management meeting was held on October-21, 1987, to discuss

the events which occurred during the refueling outage. An

enforcement conference was held on January 11, 1988, to discuss

violation which had occurred during the refueling outage.

2. Confirmation of Action Letters

None

F. Review of Licensee Event Reports and 10 CFR Part 21 Reports

Submitted By the Licensee

1. Licensee Event Reports

The SALP Board reviewed the LERs for the period March 1, 1987,

through March 31, 1988. This review included the LERs listed by

SALP category in Table 3.

2. Part 21 Reports

There were no 10 CFR Part 21 reports submitted by the licensee

during this SALP assessment period.

,

4

4

!

l

L

. .

Table 1

Enforcement Activity

FUNCTIONAL AREAS NUMBER OF VIOLATIONS

IN EACH LEVEL

DEFICIENCIES / DEVIATIONS V IV III

A. Plant Operations 1

B. Radiological Controls 0/1 1 4

C. Maintenance 2

D. Surveillance 2

E. Fire Protection 1

F. Emerger.cy Preparedness 1/0 2 1

G. Security 4

H. Outages 1 1 2

1. Quality Programs and 1 9

Administrative

Controls Affecting

Quality

J. Licensing Activities

K. Training and 2

Qualification

Effectiveness

Total 1/1 7 25 2

._________ _-_ _ _

_

, ,

Table 2

ENFORCEMENT ACTIVITY-

TABULATION OF VIOLATIONS, DEVIATIONS, AND-

EMERGENCY PREPAREDNESS DEFICIENIES

PERFORMAN CATEGORY

A. Plant Operations

Violations

. Failure to enter Technical Specification 3.0.3 when both trains

of CRVIS were inoperable. (Severity Level IV, 87?0-01)

Deviations

. None

B. Radiological Controls -

Violations

. Failure to properly control, store and protect quality records.

(Severity Level V, 8708-01)

. -Radiation Protection Manager not fully qualified. (Severity

level IV, 8712-01)

. Failure to properly evaluate radiological surveys of two

,

contaminated persons. (Severity Level IV, 8728-01)

. Unauthorized disposal of contaminated material. (Severity

Level IV, 8736-01)

. Failure to lor;k high radiation door. (Severity Level IV,

8809-01)

Deviations

. Repeated failure to implement a continuous airborne monitoring

program. (8712-02)

C. Maintenance

Violations

! . Failure to comply with TS 4.0.5 by not obtaining a relief request

from NRC. (Severity Level IV, 8715-01)

. Three examples of failure to follow procedure. (Severity

Level IV, 8807-38)

_ _ - _____________ _ _

--

. . .

2

Deviations

. None

D. Surveillance

Violations

. Failure to demonstrate automatic isolation of the containment

purge pathway. (Severity Level IV, 8715-02)

. Failure to alternate starting locations for the motor driven fire

pump. (Severity Level IV, 8722-01)

Deviations

. None

E. Fire Protection

Violations

. Fire door inoperable by being blocked open. (Severity Level IV,

8706-01)

.

Deviations

. None

F. Emergency Preparedness

Violations

'

. Failure to document a communication test. (Severity Level V,

8714-01)

l . During an unannounced call-out drill, the communicators could not

l- be reached. (Severity Level IV, 8714-02)

. Repeat violation of a failure to meet call-out time limits.

(Severity Level V, 8812-01)

Deviations

. None

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

.. ,-

3

Deficiencies

. During an emergency plan exercise, an incorrect classification

was made. (8721-01)

G. .Segurity

Violations

. Failure to follow compensatory procedures. (Severity Level IV,

8716-01)

. Inadequate compensatory measures. (Severity Level IV, 8723-01)

. Failure to maintain assessment aids. (Severity Level IV,

8734-01)

. Failure to maintain control of security badge. (Severity

Level IV, 8805-01)

Deviations

. None

H. Outages

Violations

. Six examples of failure to follow procedures. (Severity

Level III, 8731-A)

If

. Four examples of failure to have appropriate procedures.

(Severity Level III, 8731-B)

. Two examples of inadequate procedures. (Severity Level IV,

8806-01)

. Failure to make inservice test log entries. (Severity Level V,

l

,

8811-02)

Deviations

. None

I. Quality Programs,

Violations

. Failure to have qualified electrical splices. (Severity

Level IV, 8724-01)

. _ _ _ _ _ _ .

.- u-

4

I

.

Connection boxes mounted below post-accident containme d water

level. (Severity Level IV, 8724-02) i

(

. Space heaters operating in motor operated valves. (Severity.

Level IV, 8724-03) i

. Use of unqualified terminal blocks. (Severity Level IV, 8724-04)  !

,

. Failure to evaluate temporary modification. -(Severity Level V,

8801-01)

. Inadequate acceptance criteria for reactor vessel 0-rings.

(Severity Level IV, 8804-01)

i

. Purchase order failed to specify code requirements. (Severity

Level IV, 8815-01)

'

. Purchase request did not document Spec levels. (Severity x

Level IV,8815-02) .

. Unqualified code boundary part. (Severity Level IV, 8815-03) (,

Deviations

.- None

is:

J. Licensing Activities

Violations

. None

Deviations

. None

K. Training and Qualification Effectiveness

Violatior l

. Failure to provide health physics retraining. (Severity Level V,

8717-01)

. Failure to maintain health physics training records. (Severity

Level V, 8717-02)

Deviations

L

, None

"

.

\

4

$

_ .-- __. _ _ _ . _ -- -.

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,

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' Table 3 '

'

-OPERATIONAL EVENTS

j pBULATIOROFLICENSEEEVENTREPORTS L)t

a qv

.

4 .,

PERFORMANCI CATEGORY

g.

A. Plant' Operations

3

L \d T

, ' Error while placing bis k switch in ' permit' results in aux.

.feedwater actuation. (87-013) ,

,

Failuretocommunicateallepedanopendoorcreatingapressure

boundarybreac( (31-034)

! . . ' Errors result in loss of< power to control rod moveable gripper

4 coils which causes a rea; tor trip. (87-041)

{'

'

. Error leads to Hi-Hi S/G level resulting in feed isolation ,

signal. (87-042) ,

!

B. Radiological Controls

. Inadvertert release of secondary liquid waste mbaitor tank

without pribe sampling. (87-036)

. Inadequate control results in loss of licensed naterial.

(87-056)' ,

. C. Maintenance

. Logic cabinet cards overheated causing reactor trip. (87-017) J

. Containment purge isolation due to , signal spike on radia't'.'on

monitor. (87-019) ,

. Reactor trip caused by loss of power to main turbine '

<

electro-hydraulic control system. (87-022)  !

. Reactor trip resulting from personnel error ftr not correctly

tightening instrument sensing lines. (87-027)

p \

. Potential transformer failure causes partial loss of offsite '

power and reactor trip. (87-030)

. Inoperable containment isolation valvh aue to incomp14.e

retestir.g following maintenance. (87-033) x ,

. High Voltage: transmission line failure causes generator

trip /reactur '(. rip. (87-037)

,

. Accidental mispositioning of breaker switch causes inoperability '

,

of one power operated relief valve. (87-039)

l \

e ,

s +,

,I

.s

-

,

l

• - -. _ , _ _ _

,_ 'I

-/

'

-

.

/

.!

g

.; I

. Omission of snubber from inspection procedure. (87-044)

. Inadequate hydrostatic pressure tests due to procedural

inadequacy. (87-045)

. Containment purge-isolation caused by moisture induced cc,rrosion

of an electrical connector. (87-054)

D. Surveillance

. TS violation caused by missed surveillance procedure. (87-014)

. Shaft seal on contd ament air lock failed during testing causing

total leakage above allowable. (87-023)

. Cor.tainment purge isolation due to personnel error during

radiatian monitor testing. (87-025)

Late performance of spent fuel building vent tritium analysis.

(87-026)

. Inoperable Class 1E batteries due to inadequate post-test review

of surveillance test. (87-028)

. Required testing deleted from surveillance procedures. (87-029)

. Failure to properly verify operability of fire pumps due to

procedural inadequac. '(87-038)

. Noncoaservative error in containment purge radiation monitoring

setpoint. (87-040)

. Surveillance ' power range low setpoint & P-8, P-9, and P-10

interlocks noi.' performed properly. (87-043)

. Containment isohtion valve failed during testing causing total

path leakage to be above allowable. (87-050)

. Procedural deficiency causes two feedwater isolations & an an eux

j feed actuation. (87-051)

. Procedural inadequacy resulting in TS violation. (87-060)

E. Fire Protection

l- . Four fire dampers not actuated ;ue to drawing error. (87-013)

. Failure to maintuin fire wutch as required by TS. (87-016)

l

. Hourly fire watch performed late due to personnel

error / individual overlookcd one impairment. (87-021)

l .

l

t

... . - - - - -

____ . _ _ _ - _ _ __ . _ _ _ _ _ - - _ _ - .

o. <.w

3

. Spent fuel pool heat exchanger room doors not 3-hour fire rated.

(87-031)

. Failure to fully' understand the requirements causes TS violation

for hourly _rather than continuous fire watches. (87-057)

. Wired glass insert discovered in fire door causes loss of 3-hour

fire rating. (87-059

F. Emergency Preparedness

. None

G. Security

. Unauthorized vital area entry. (87-046)

. Vital door unsecured. (87-047)

. Security officer inattentive to duty. (87-055)

H. . Outages

. Improper maintenance causes fatality. (87-048)

. Low battery bus voltage. (87-049)

I, Quality Programs and Administrative Controls Affecting Quality

. CRVIS caused by chlorine monitor spike. (87-012)

. CRVIS caused by paper tape bunching up on chlorina monitor.

(87-015)

. CRVIS caused by paper tape breaking on chlorine monitor.

(87-020)

. 'FA-CRVIS caused by loss of power to chlorine monitor because of

faulty sample pump. (87-024)

,

'

. CRVIS caused by paper tape breaking on chlorine monitor.

(87-032)

,.

L . CRVIS - two events caused by malfunctions of the chlorine

L

monitors. (87-035)

!

l . I strument termination splices installed which fail to meet

-

L v vironmental.qualificction requirements. (87-052)

. CRVIS caused by paper tape bunching up on chlorine monitor.

(87-053)

- ~ , . _ .-- _ _ _ _

.

, . -

4

. TS Violation, due to error in design document. (87-058)

. Radiation monitor spike causes fuel building ventilation

isolation. (88-001)

. Probable transient in power supply for radiation monitor causes

containment purge isolation. (88-002)

. CRVIS from chlorine monitor spike. (88-003)

. CRVIS from chlorine monitor spike. (88-005)

,