IR 05000482/1988014: Difference between revisions

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{{Adams
{{Adams
| number = ML20154E995
| number = ML20196C864
| issue date = 03/31/1988
| issue date = 06/23/1988
| title = Final SALP Rept 50-482/88-14 for Mar 1987 - Mar 1988. Overall Performance Acceptable
| title = SALP Rept 50-482/88-14 for 870301-880331
| author name =  
| author name =  
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
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| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-482-88-14, NUDOCS 8809190212
| document report number = 50-482-88-14, NUDOCS 8807010253
| package number = ML20154E975
| package number = ML20196C787
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| page count = 70
| page count = 41
}}
}}


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,
G FINAL SALP REPORT l
U,$. NUCLEAR REGULATORY COMMISSION        ;
REGION !Y l
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i
NRC Inspection Report 50-482/88-14 Wolf Creek Nuclear Operating Corporation
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Wolf Creek Generating Station March 1,1987, through March 31,1988 i
8809190212 000912 PDR i
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ADOCK 05000482 O pg I
 
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, 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 regulatiens. SALP is intended to be i
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.
 
1 An NRC SALP Board, composed of the staff members listed below, yet 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 summar provided in Section !! ofy of therepor this guidance and evaluation criteria is
 
l T'his 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, 198 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:
i J. M. Montgomery, Deputy Regional Administrator, Region IV A. B. Beach, Deputy Director, Disision of Reactor Projects Region IV J. P. Jaudon, Deputy Director, Division of Reactor Safety Region IV R. E. Hall, Deputy Director, Division of Reactor Safety and Safeguards, Region IV 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  i
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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    ,
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!!. CRITERIA Licensee performance was assessed in 11 selected functional area Functional areas normally represent areas significant to nuclear safety and the environmen Some functional areas may not be assessed because of
 
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;  little or no licensee activities or lack of meaningful observations.
 
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Special areas may be added to highlight significant observations.
 
l  One or more of the following evaluation criteria were used to assess each I  functional area:
1 Management involvement and control in assuring qualit . Approach to the resolution of technical issues from a safety standpoint, Responsiveness to NRC initiative . Enforcement histor . Operational events (including response to, analysis of, and corrective actions for). Staffing (including management).
 
However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categorie 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 l
a high level of performance with respect to operational safety and construction quality is being achieve Category 2. NRC attention should be maintained at normal level Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety and construction quality is being achieve Category 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 and construction quality is being achieved,
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!!I. SUMMARY OF RESULTS The SALP Board review revealed areas of strength in fire protecti*on and security with an increase in performance from the previous SALP perio Performance in the areas of emergency preparedness and surveillance remained consistent with the previous SALP period. All other areas revealed a decline in performance or a declining trend from the previous SALP period. The overall decrease in performance is due, in part, to the failureoflicenseemanagementtomaintaineffectivecontrolofmajor ottage The licensee's performance is summarized in the table below, along with the performance categories from the previous SALP evaluation perio *
Previous  Present ory Functional  Performance Category) Performance (02/1/86 to 02/28/87  Categ/88)
    (03/1/87 to 03/31 Plant Operations  2  2 Radiological Control  2  2 Maintenance  1  2 Surveillance  2  2 Fire Protection  2  1 Emergency Preparedness 2  2 Security  2  1 Outages  2  3
  !. Quality Programs and  2  3 Administrative Controls Affecting Quality Licensing Activities  1  2 Training and Qualification 1  2 Effectiveness I PERFORMANCE ANALYS!$ Plant Operations Analysis i
i  The assessment of this area consists chiefly of the activities j  of the licensee's operational staff (e.g., licensed operators
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and nuclear station operators). It is intended to be limited to i
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]  operating activities such as: plant startup, power operatio L plant shutdown, and system lineups. Thus, it includes    f
:I  activities such as reading and logging plant conditions',    .
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responding to off-normal conditions, manipulating the reactor
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and auxiliary controls, plant-wide housekeeping, and control    ;
room professionalis This area has been inspected on a continuing basis by,the NRC    ,
resident inspectors and on several occasions by NRC regional    !
4  impectors. Specific areas inspected included operational    l
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se,ety verifications, safety system walkdowns, follow up on    ,
significant events / problems, and review of licensee event    ;
 
reports (LERs),      t i  One violation was identified in this functional area and, while    !
!  it indicated additional management controls were needed,    i i  corrective action was promptly initiated by the licensee. Also,    l j  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 i  licensee in this functional area. These four LERs had no major    ;
i  effect on plint safety. One of the LERs concerned the one    i i  violation that was identified in this are The remaining three  l
;  LERs were all perscnnel errors and were indicative of a failure    ;
)  to pay attention to detai ;
l  Corrective actions initiated by licensee management included
:  requiring the use of procedures in additional areas in    !
I  operations. At the end of the SALP period the use of procedures in operations was much improve j
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!  Operational events and NRC observations showed that operations    !
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interface with other departments is lacking. There has been an    j apparent failure of operations to make effective use of    i technical support groups. In some cases even when technical    ;
l  support groups became aware of problems and provided input to    i
)  operations, the input was ignored or was lost. There are two    ,
examples. The first was when operations was not responsive to    i Nuclear Safety Engineering's information and advice concerning    ;
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. 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    i
:  section of thinwall safety-related pipe and the disposition was    l l  misplaced for approximately 3 month j i          l In general, operator performance, as observed by the NRC    1 i  inspectors, has been good. Control room professionalise has    l 1  been maintained and good operator morale exhibited. At times,
;  however, the operators failed to pay attention to detai 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 wi,thout a procedure being available to provide alternate AC power to  -
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a    the battery chargers, and without bus voltage being observed carefully or without periodically observing    ,
i    current readings and comparing them to expected value ,
j    ' 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    l l    uncontrolled aids in determining that certain manual    !
I    isolation valves were shut. The valves were, in fact    l j    open. Whenthevalveshadbeenopened,theuncontroIIed    s J
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aid had been forgotten. This resulted in the undesirable
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placing of lake water in each of the steam generators.
 
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!    The licensee continues to give strong management support to the  :
l    college degree program for operations personnel. The number of  i
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operators with engineering degrees or working toward degrees is  !
i    considered to be a plus,      t i          :
l    The number of operators with senior reactor operator licenses  !
i    exceed the number of operators with reactor operator licenses by  !
1    more than 2 to 1. This allows the licensee mo'e versatility in  :
the use of the operators, while at the same time giving    !
operators additional training and mobility.
 
l    In general, the licensee maintains a 6-shift rotation of their  !
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operating crew This allows for a better utilization of the  j crews, less overtime, and increased training.
 
;    2. Conclusions      j
<          i i    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 improve The
,    use of procedures in operations was noted to improve; however,  ,
I this occurred only after the situation had been a110wed to    '
I    deteriorate to an unacceptable level, l    The examples of inattention to detail and the lack of effective
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operations interface with other departments reflects an d
ineffective management oversight in this functional area, i
!    Staffing in this area is considered a strength, along with good control room professionalism during power operations.
 
I    The licen m is considered to be in Performance Category 2 in i    this area, with a declining tren l
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i f Board Recommendations  '
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I Recommended NRC Actions  j
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The level of NRC inspection in this functional area should !
be consistent with the basic inspection program, t i  Supplemental inspections should be performed to. focus on l I
!  operations interface with other departments.
 
I J Recommended Licensee Actions
;      I i  Licensee management should ensure that there is an adequate I
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and prompt QA, NSE, and engineering involvement in !
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operational events and in the technical resolution to !
safety issue l
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B. Radioloalcal Controls    }
i Analysis    I 1      l
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The assessment of this functional area includes the following l l areas of activity which are evaluated as separate subareas to !
l arrive at a consensus rating for this functional area: l
; (a) occupational radiation safety, which includes controls by [
J licensees and contractors for occupational radiation protection, f j radioactive materials and contasination controls, radiological l 1 surveys and monitoring, and ALARA programs; (b) radioactive I i waste management which includes processing and onsite storage l
; ofgaseous, liquid,andsolidwaste;(c)radiologicaleffluent j controls, which includes gaseous and liquid effluent controls
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L and monitoring, offsite dose calculations and dose limits, i j radiological environmental monitoring, and the results of the !
NRC's confirmatory measurements program; (d) transportation of l radioactive materials, which includes procurement and selection i
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of packages, preparation for shipment, selection and control of i shippers, delivery to carriers, receipt / acceptance of shipments
; by receiving facility, M riodic maintenance of pa:kagings and, ;
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for shipment of spent fuel, point of origin of safeguards I activitiest and (e) water chemistry controls, which includes
! primary and secondary systems affecting plant water chemistry, I water chemistry control program and program implementation, j i chemistry facilities, equipment and procedures, and chemical i j analysis quality assuranc Nine inspectiet.s were performed in the area of radiological controls during the assessment period by Region-based radiation specialist inspectors.
 
l There were five violations and one deviation identified in this j functional are . - - _  ._ _
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I a. Occupational Radiation Safety  f i  The licensee's programs for occupational radiation ;
. protection, radioactive material and contamination :
i  controls, radiological surveys and monitoring, and ALARA l
 
programs were inspected four times during the assessment !
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period. Two inspections were conducted during normal d ant l operations, one inspection during a scheduled refueling ;
outage, and one special inspection after the release (
radioactive material to the local county landfil t
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The licensee's exposure for 1986 was 142 person-rem r I
compared to the national PWR average of 3)2 person-rem.
 
I During 1987, the licensee's person-rem exposure was 124 _
compared to a national PWR of 376 person re (
l The size of the radiation protection staff was dequate to l
!  support olant operations. A low personnel turnon t rate t I within the radiation protection group was experiened i during the assessment perio The licensee's approach i i  concerning the resolution of technical issues indicated ;
their understanding of issues was generally apparen *
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Acceptable resolutions were generally proposed in response !
l  to NRC initiative [
Those violations identified in the radiation protection f program were an indication of a lack of management l involvement in assuring quality and worker trainin The [
two concerns noted during the previous assessment period ;
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which included: (1) lack of steam generator mockup ;
; training and (2) lack of health physics supervisory i
:  personnel presence in the plant to oversee and evaluate i i
ongoing radiation protection activities, had not been fully [
)  resolve l t
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The licensee had made changes in the position of radiation protection manager, an individual with limited emperience [
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and not qualified in accordance with Regulatory Guide l 1  was appointed to the position. The licensee recently [
;  contracted a qualified indiv8 dual to oversee and provide
;  direction to the radiation protection program, j
 
b. Radioactive Waste Manage ent
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j  The licensee's program involving processing and onsite !
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storage of solid waste was inspected twice during the f J  assessment period. One violation was identified. The !
]  licensee released radioactive material as trash which was !
l found thd recovered froa the local county sanitary t i  landfill. The licensee had reduced the volume of !
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solidified waste generated by use of a portable l l
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demineralizer skid for liquids and processing spent resins by dewatering methods. The licensee had identified key positions and defined their responsibilities, c. Radiolooical Effluent Con _tro_1_ and_Monitorina This area includes gaseous and liquid effluent controls and monitoring, offsite dose calculations and dose limits, radiological environmental monitoring, radiochemistry ,
program, and radiochemistry confirmatory measurement esults. Three inspections were conducted during the assessment period, together they encompassed the complete program are .
The licensee has established a program concerning the cor, trol and release of gaseous and liquid effluent Liquid and gaseous effluent release permit procedures have been developed to assure that planned releases receive proper review and approval prior to releases. A review of gaseous and liquid releases indicates that offsite doses were well below Technical Specification limits. Three concerns were identified relating to: (1) liquid effluent monitor setpoints, (2) condensate storage tank analyses, and (3) radiation monitor calibration dat The offsite radiological environmental tronitoring program was inspected once during the assessment period. No violations were identified. The adiological environmental monitoring program is effectively managed from the licensee's corporate office and implemented by station personnel. The working relationship between the two groups has been exc911en The radiochemistry anri water chemistry program which
,  included onsite confirmatory measurements with the NRC Region IV sobile laboratory w4s inspected once during the assessment period. No violaHons or deviations were identified. The results of ;re confirmatory measurements indicated 97 percent agreemtn',, a slightly higher value from the previous assessment perio d. Transportation of Radioactive Materials This area was inspected twice during the assessment period in conjunction with the solid radioactive waste management progra Two violations were identified; one violation 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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taken by the licensee has generally been timely and *
effective in this are Transportation activities at the site usually involve the support and guidance from the corporate offices. The
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licensee has established an adequate quality control / quality assurance program for low-level. radioactive material shipments. Transportation activity records are complet Water Chemistry Controls This area was inspected once during the assessment perio The inspection involved the initial use of prepared water chemistry standards for confirmatory measurement
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evaluations. The results of the water chemistry confirmatory measurements indicated 84 parcent agreement between the licensee and the NRC's reference laborator These results are considered within expected industry performtnce levels. The inspection also identified four concerns involving instrument calibration and the quality control aspect of the water chemistry analysis progra . Conclusions
,    The licensee's overall performance indicated a decrease in effectiveness over the previous assessment period. Seven violations and one deviation were identified during this assessment period, as compared to no violations or deviations being identified during the previous assessment perio Inadequate management attention to NRC concerns is demonstrated by the lack of resolution to the concerns noted during the previous assessment period, which were: (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. Improvements were noted regarding the implementation of the ALARA progra The licensee's personnel radiation exposure history has been better than (less than one half) the national everage for PWR l No significant problems were identified in the functional areas of transportation of radioactive material, and radiological
. effluent control and monitoring. The licensee's program for these areas appeared adequate regarding management oversight,
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resolution of technical issues, training, procedures, and J    staffin The licensee is considered to be in Performance Category 2 in this area. However, during the SALP period, performance was
 
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decreasin Recent changes in management have not yet had time to be effectiv . Board Recommendations Recommended NRC Actions The NRC inspection effort in this area should be consistent with the basic inspection program with increased emphasis on management involvement to assure qualit Recommended Licensee Actions
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Hesith physics supervisory personnel should spend more time in the radiologically controlled areas evaluating and observing or. going radiation protection work activities to ensure compliance with station procedure Management should take action to provide training to technicians to enhance procedural complianc C. Maintenance Analysis The assessment of this area includes all licensee and contractor activities associated with preventive or corrective maintenance l  of instrumentation and control equipment and mechanical and electrical system This area was inspected on a continuing basis by the NRC resider +. inspectors and periodically by NRC regional inspector There were two violations identified in this area. These violations involved the failure of the licensee to request a code exemption when required and three examples of a failure to follow procedures. There were 11 LERs issued by the licensee in this functional area. One LER was due to inadequate post-maintenance testing on a containment isolation valve, another LER was due to an accidental mispositioning of a breaker switc The escalated enforcement action that was taken due to the problems which occurred during the fall refueling lutage revealed significant problems within the maintera organization. These problems consisted of workers failing to follow procedures, inadequate procedures, inadequate control
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over special processes, and an overall breakdown of management oversite of maintenance activities during the refueling outage.
 
i, One of the major causes for the problems which occurred this SALP period was workers failing to follow procedure _ _ __ _
 
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Three of the findings in the escalated enforcement package were workers failing to follow procedures. These included ipsuance of the wrong weld rod material, use of the wrong weld rod material, and failure to check for an energized circuit. There have been multiple occurrences of Wolf Creek event reports written for failure to follow procedure The failure to follow procedures was pervasive at the Wolf Creek sit This could only exist if it was allowed to sicwly build up over a period of months or year Licensee management was not effectiva in correcting the proble During the last quarter of the SALP eriod, the maintenance management organization underwent si nificant change *
Maintenance was combined with facili ies and modifications to form maintenance and modifications. This change combines all maintenance activities under a single manager. The superintendent of maintenance transferred to the outage planning group and the manager of facilities modifications became the manager of maintenance and modifications. In addition, some lower level managers were transferred and some positions were eliminated. These changes appear te have significantly strengthened the maintenance are . Conclusions The NRC found evidence of upper management support for a strong maintenance progra 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 significantly during the assessment period. Several examples of the results of this decline were identified. Towards the end of theSALPperiod,majormanagementchangeswereimplemente These changes appear to have significantly strengthened management oversight of maintenance activitie The licensee is considered to be in Performance Category 2 in this functional are . Board Recommendations Recommended NRP Actions The NRC inspeccion effort in this area should be consistent with the basic inspection program. The resident inspectors should increase their inspection activities in this area Recommended Licensee Actions The licensee should follow through and assess the effectiveness of their corrective actions. The licensee
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should continue the increased emphasis on procedural
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complianc Surveillance Analysis The assessment of this functional area includes all surveillance testing and inservice inspections and testing activitie Examples of activities included are: instrument calibrations, equipment operability tests, special tests, inservice inspection and performance tests of pumps and valves, and all otrer
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inservice inspection activitie This functional area was inspected on a routine basis by the NRC resident inspectors and periodically by NRC regional inspector 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 perio 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 tM previous SALP perio During the previous SALP per'od, the licensee was rated a SALP
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Category 2 in this functior.al area with a decreasing tren ,
Although the enforcement and reporting history indi G te improvement, as noted above, similar procedural and personnel errors are being repea',ed during this SALP perio . Conclusions The overall asse sment for this functional area indicates a
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program for scheduling and tracking of surveillance activities that appears adequat Procedures in some cases did not address I
all Technical Specification surveillance requirements adequately. The repeat procedural and persornel errors indicate  ;
that additional management involvement is neede The licensee is considered to be in Performance Category 2 in  l this functional are l l
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. Board Recommendations
      * Recommended NRC Action The level of NRC inspection in this functional area should be consistent with the basic inspection progra 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 involvemen.'. with surveillance activities is encourage E. Fire Protection Analysis The assessment of this area includes routine housekeeping (combustibles, etc.) and fire protection / prevention program activities. Thus, it includes the storage of combustible I material; fire brigade staffing and training; fire suppression I system maintenance and operation; and those fire protection '
features provided for structures, systems, and components important to safe shutdow 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 training department. The other change was the transfer of the fire protection group from the plant support organization to the operations organizatio The following observations were made:
  . The licensee has made significant improvement in the area l of administrative controls for fire barrier penetrations and opening Especially significant has been the reduction of missed fire watch patrol . Control of transient combustibles has been effectiv 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 9utstandin The transfer of the fire training group to the t : inh.:
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 t aggressively pursued and complete . 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 mayor reason i
for the improvement in this area has been the continu ng dedication and hard work of the well qualified fire protection engineer and training instructo .
The licensee is considered to be in Performance Category 1 in t  this are , Board Recommendations Recommended NRC Actions
'  The level of NRC inspection in this functional area should be consistent with the minimum inspection progra 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 suppor Emergency Preparedness Analysis The assessment of this area includes 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 pla During the assessment period, four emergency preparedness inspections were conducted by Region-based and NRC contractor insper. tors. One of these inspections was the observation and evaluation of an annual emergency response exercise by a team of NRC and contractor inspectors. During the exercise, four deficiencies from a previous exercise were closed and one new deficiency was identified. The deficiency identified during the exercise involved incorrect classification of the emergency as l
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an unusual event rather than an aler The licensee's overall performance during the exercise was evaluated as good. .The NRC staff concluded that licen% = emergency response personnel demonstrated their ability 'a protect the health and safety of the publi Three routine inspections resulted in identification of three violations. One violation inicivcd failure to document required communication tests of the emergency response facilities. The other two violations, one of which was a repeat violation, involved failure 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 syste 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 l
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 has 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 transition phase with the shift in '
lead responsibility for emergency program to the corporate I offic . Conclusions The violations issued in shift staffing and augmentation indicate that the personnel notification method and procedure requires additional improvement. Management attention should be devoted to meeting regulatory requirements and licensee commitment Licensee management attention and involvement are evident; ,
licensee resources are adequate and reasonably effective so that i I
satisfactory performance with respect to operational safety and construction quality is being achieved.
 
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The inspection findings for this evaluation period indicate, overall, that the licensee's einergency preparedness program is adequate to protect the health and safety of the publi The licensee is considered to be in Performance Category 2 in this are . Board Recommendations  - Recommended NRC Actions NRC attention should be maintained at riormal level Attention should be directed to licensee action taken
*
toward correcting the call-out drill response and shift augmentation response time 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 shif t augmentation concer Management should review the distribution of onsite and offsite emergency program areas of authority and responsibilitie G. Security Analysis The category of security relates to all activities whose purpose it is to ensure the protection of the plan Specifically, it !
covers all aspects of the security program including ancillary
      '
efforts such as fitness for duty and access authorization program Examples are: the licensee's overall management involvement in establishing protective policies; designing physical security systems; submitting the security plan and ,
implementing associated procedures; selecting, training, equipping, and supervising personnel maintaining the hardware thatsupportstheprogram;andauditIngandmeasuringthe performance of the security progra 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 perio Four violations were identified, two by the )
license I
 
    .  - ,
* '
 
htcre was evidence of prior planning and assignment of p ioritie Policies and procedures are wil stated, ap repriately disseminated, and understandable. Decisionmaking was sually at a level that ensured adequate management revie The , w corporate structure, which includes a repositioning of
        '
the Qu lity Assurance Department, is committed to continuing an
,
indepen ent and effective oversight of security related matter Manageme t reviews of identif: 4d security matters were timely, thorough, nd technically sound. The initial review of security incidents s improved and further examination for generic  ,
significance has been enhanced. Records were generally complete, wel maintained, and available. Rarely were procedures and olicies violated. However, some cases of l  personnel failu have occurred and these appear to be j  associated with  mporary employee hiring practice Corrective action on licensee identified violations was generally
:
effectiv f 4  A clear understanding  security issues was demonstrated and subsequent decisions r  ected reasonable and prudent judgement on the part of man  . These kinds of judgements were also demonstrated in the - in'  nd Human Relations Departments
-
where security's a  y forts, such as fitness for duty, continual observation o m  e's behavior, and the access authorization programs we  . e _ There has been a major organiz  on 1 restructuring of the
  -
QualityAssurance(QA)Depar e changes have been too recent to evaluate their impa  e heretofore strong
'
  -
security oversight.' effort. Th  . e concern that these l
-
changes will not provide the le 1, audit expertise previously  <
h provided. A review of these cha  nd the quality of the  ,
audits performed will be necessar  he futur <
The licensee has been usually respon  .e o NRC initiatives, but ,
there continues to be two long standing r ulatory issues  i attributable to the licensee. These are co trol room access and alarm assessment capabilit Technically so nd and acceptable resolutions were proposed initially in most c ses, but timeliness of resolution for these outstanding issues is slo !
t After considerable discussion, the licensee agr d that their CCTV system had degraded and proposed proper cor ctive actions.
:  One major violation concerning security personnel a tentiveness
'
was directly attributable to a member of the securit    {
organization. It was promptly and effectively correc d. A few
;  minor procedural mistakes by security personnel have o urred, but were not repetitive. These mistakes appear to be in icative  i
 
of a need to enhance the selection process for temporary  l l  security personnel and to be persistent in programmatic
:  training.
 
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. .
 
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 connitted to continuing an independent and effective oversight of security-related matters. Management reviews of identified
; secu.*ity matters were timely, thorough, and technically soun ;
The initial review of security incidents has improved and i further examination for generic significance has been enhance Records were generally complete, well maintained, and available. Rarely were procedures and policies violate However, some 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 effectiv 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 manage There has been a major organizational restructuring of the Quality Assurance (QA) Department. The changes have been too recent to evaluate their impact on the heretofore 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 futur The licensee has been usually responsive to NRC initiatives, but there continues to be two long-standing regulatory issues i in need of resolution. 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, s After considerable discussion, the licensee agreed that their CCTV system had degraded and proposed proper corrective actions.
 
; One major violation concerning security personnel attentiveness J was directly attributable to a member of the security organization. It was promptly and effectively corrected. A
!
few 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 security personnel and to be persistent in
} progranmcic training.
 
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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 manne Security organization positions were clearly identifie 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 officers and to make them available for more critical task . 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 performanc The licensee manroement's attention and involvement with nuclear securt y is evident. Licensee resources were appropriate and effective so that there was very '
good performance with respect to site physical and personnel securit i The licensee is considered to be in Performance Categorf 1 in this are i i Board Recommendations I
' 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 i
selecting, training, equipping, posting and supervising security personnel; and changes to the QA function where audits are performed to measure the performance of the i  security program rid its ancillary efforts.
 
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19 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 n ineering responses appropriately. The organizational a ustments made in the QA area should be closely monitored to nsure that the high quality of the security oversight pro am continue H. Outage Analysis The assessment this area includes all licensee and contractor activities associ ted with major outages. It includes refueling, outage ment,majorplantmodifications, repairs or restoration to components and all post-outage startup testing of systems p r to return to servic This area was inspecte n a continuing basis by the NRC resident inspectors riodically by NRC regional inspectors. In addit n, spection was performed by a safety system outa if ion inspection (SSOMI) team. The inspections included r el g activities, outage management,
-
planning and scheduling, ta majorcomponents/ systems repairs and modifi, cation, up testin ~  '
~
The licensee had two major o  ring this SALP perio There was a refueling outage c lasted approximately 101 days and an outage to replace leaki r ctor vessel 0-rings which lasted approximately 16 day fU ing outage activities included replacement of Raychem s '
s, replacement of eroded essential service water pipe, annu , spection of the diesel generators, removal of heaters from  torque valve operators,
    ' umber one seal, replacement of reactor coolant pump replacement of the trip mechanism sha s  the reactor trip breakers, replacement of the tube bundle i thejacketwater heat exchanger for diesel generator "A", re rk of Valcor valve operators, cleaning of condenser tubes and in ections for thin wall pipes. There were numerous significant o erational events which were attributable to causes under the lic see's control in this functional are There were four violations identified in this funct onal are Two of the violations involved escalated enforcement action and a proposed imposition of Civil Penalty. There were t o LERs issued by the licensee in this functional area. The t LERs were on events that resulted in violations being issue .  . -  - -
      , . .._
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.
k Recommended Licensee Actions d
The licensae should continue to probe the causative  i factors of security events for broader implications and adjust programs, training, disciplinary actions,  ,
maintenance, and engineering responses appropriately. The L
<  organizational adjustments made in the QA area should be _'
1  closely monitored to ensure that the high quality of the '
security oversight program continues,  i
      !
j Outage    [
a Analysis    !
 
The assessment of this area. includes all licensee and f  contractor activities associated with major outages. It  i includes refueling, outage ' management, major plant
      '
,
!
modifications, repairs or restoration to major components, and
!  all post-outage startup testing of systems prior to return to j servic '
I      l 4 J  This area was inspected'on a continuing basis by the NRC i
resident inspectors, and periodically by NRC regional inspectors. In addition, an inspection was performed by a safety system outage modification inspection (550HI) team. The 4  inspections included refueling activities, outage management,
;  planning and scheduling, staffing, major components / systems
;  repairs and modification, and startup testin '
!  The licensee had three major outages during this SALP perio :  There was a refueling outage which lasted approximately  ;
j  101 days, an outage to replace leaking reactor vessel 0-rings l
)  which lasted approximately 10 days, and a generator / exciter outage which lasted 16 days. Refueling outage activities  ,
j  included replacement of Raychem splices, replacement of eroded essential service water pipe, annual inspection of the diesel  I i  generators, removal of heaters from Limitorque valve operators, l l  replacement of reactor coolant pump "B" number one seal, j  replacement of the trip mechanism shafts on the reactor trip  j i  breakers, replacement of the tube bundle in the jacket water  4 j  heat exchanger for diesel generator "A", rework of Valcor valve l operators, cleaning of condenser tubes, and inspections for  !
]  thin wall pipes. There were numerous significant operational  i events which were attributable to causes under the licensee's j control in this functional area, j      i j  There were four violations identified in this functional area, i  Two of the violations involved escalated enforcement action and i  a proposed imposition of Civil Penalty. There were two LERs
 
issued by the licensee in this functional area. The two LERs l
were on events that resulted in violations being issue l i
 
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i The two violations that resulted in escalated enforcement involved examples of procedural control weaknesses that the NRC ,
considered significant. These weaknesses indicate mantgement failed to provide an appropriate level of .unagement oversight of safety-related activitie This is evidenced by the examples sited below as well as other areas in this repor Management oversight of outage activities was less than adequate as pointed
',
out by the six examples of failure to follow proceduras and foi examples of inadequate procedures listed in the escalated enforcement packag 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 correr'.ive actions was a noted weaknes During repair efforts on thin vall pipe due to erosion / corrosion the licensee experienced some 'ifficulty. The licensee had on site a contractor workforce knr..iledgeable and experienced in the forming, fitting, rigging, and aligning uf heavy pipe. The licensee decided to repair the thin wall pipe with their '
permanent maintenance workforc The maintenance workforce was not as experienced in this area as the contractor workforc This resulted in significant problems due to failure to follow procedures, failure to follow work instructions, and failure to
,  accomplish work activities by appropriately qualified personne Maintenance management failed to realize the scope of work was beyond their expertis !
      !
The licensee was generally responsive to NRC concerns, however, there was a lack of aggressive response to identified problens 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 major outage of the year, indicated that the
;  licensee failed to control the 0-ring cleanliness. The licensee decided to restart the plant after the first outage with known inner 0-ring leakag ,
t 2. Conclusions    c
      :
. 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 believe in and enforce strict procedural compliance. Aggressive management
 
involvement to address problems that occurred during the outage was ,
i lacking,    i
      !
The licensee is considered to be in Performance Category 3 in this I are !
a      l
 
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J
 
4
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      ,
 
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      '
 
. Board Recommendations
      . Recommended NRC Actions Supplemental NRC inspections should be performed prior to and during the next major outag * 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 contro I. Quality Programs and Administrative Controls Affecting Quality 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 component This area may be viewed as a comprehensive management system for controlling the quality of verification activities that confirm that the work was performed correctl 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 assurarce program 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 record 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: Engineering
,
      '
'
This crea has been inspected on a routine basis by the NRC J  residerd inspecurs and by a SSOHI team inspection during the assessseni, perio '
i
      '
The staffing in the engineering urea is generally adequate in terms of numbers, but it is weak in experience and j  training. Further, the weaknesses identified by the SSOMI l
Inspection are indications that the communications between the plant operating staff and the engineering organizations t
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were poo In one case, engineering made a change to the cooling system for an electrical equipment room, @ich 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 verify the temperature should have been instituted but was not. As a consequence, the qualified life or performance of the equipment may have been affecte 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
  ,
i introduction of lake water into the secondary side of the
'    steam generator The 550MI 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 l
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 operabilit There were also three LERs that were at least in part attributable to engineering activitie In each case, the LERs became necessary because there were errors in design documents such as drawings, specifications, and instrument set point data, i Quality Assurance This area has been inspected by both the NRC resident inspectors and regional inspectors. In addition, the 550MI ;
team inspected the areas of procurement, material storage, and audit activitie 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 Q '
The licensee had received, accepted, and installed a noncode part which formed a portion of the reactor coolant system boundar An audit after the plant restarted disclosed this, and subsequent waiver to the code was granted, i
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The reactor vessel head 0-ring seals were not correctly inspected prior to installation. Although this wa's not the major contributor to the 0-ring leak, it showed a tendency '
for quality performance to be at pro forma leve During the outage, there were problems with the weld repairs to the essential service water systems. .These 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 earlie *
The licensee's vendor audit program did identify a problem with the certification of fuses purchased from a supplie The licensee reported the facts to the NRC. Follow up action by the NRC resulted in the issue of an Information Notic 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 cause For example, when a four-way valve on the MSIV actuator failed, the original root cause determination 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 manufacture c. Management and Administrative Controls
      '
This area has been inspected on a routine basis by NRC resident inspectors and regional inspector 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 J sound in that it was made by plant management without input ,
from engineerin Management did not reassess system !
; '
operability even after engineering made the determination ,
that the pipe did not meet code requirements. Plant '
'
management comunications with engineering was not )
adequate. The second concern was with long term corrective i actions. Plant management's narrow focus on the issue of l 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 manne It was not until these
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issues were raised by Nuclear Safety Engineering and the Nuclear Safety Review Committee that appropriate corrective tions were begun. The operational response to this p blem was not timely and lacked thoroughness, The above is ne example of a lack of management involvement in
;  ass ing quality. Other examples have been cited in other SALP rea !
;  The enf rcement history in the area includes seven  .
I  violatio and no deviations. Four violations were related to the ens ronmental qualification of equipment. Ten LERs  !
were issue by the licensee in this area. Eight of these  '
LERs were re ated to control room ventilation isolation  i system (CRVIS actuations. Six of these were due to  .
problems with e chlorine monitors. The licensee has made l great strides i reducing the number of reportable events  i
,  due to CRVIS act ; however, the reliability of the [
>
chlorine monitors still lo The improvement effort in ,
this area has be otracte This has resulted in the ;
!  control room ope o longer trusting their chlorine l
!  monitor !
r 2. Conclusions  p i
 
The assessment of this func n ea indicates that management l j  has not been effective in ti y lution of important issue ;
!
  . Corporate management oversigh f t activities does not always ensure adequate involve .t he quality and ;
engineering or.gantiations in pla  erations. When problems '
i .
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are identified by the quality and n neering organizations they are not always acted upon in a tim  anner,  i
      ,
}  The licensee is considered to be in Perf rmance Category 3 for
"
an overall rating of the SALP area of qua ity programs and  l administrative controls affecting qualit .
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,  3. Board Recommendations    j
!
L i
a Recommended NRC Actions    ;
L
;  Supplemental inspection effort should be dev ed to this
;  are !
i Recommended Licensee Actions    !
Increased corporate management involvement in site  l activities is recommended. In particular, addition  l corporate management involvement is needed to ensure hat  1
 
proper engineering and QA involvement is maintained in all  '
{  activities.
 
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O O
 
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'l issues were raised by Nuclear Safety Engineering snd the Nuclear Safety Review Committee that appropriate corrective actions were begun. The operational response to this problem was not timely and lacked thoroughnes l The above is one example of a lack of management i involvement in assuring quality. Other examples have been cited in other SALP area ;  The enforcement history in the area includes seven .
violations and no deviations. Four violations were '
related to the environmental qualification of equipmen l Thirteen LERs were issued by the licensee in this are ,
,  Eleven of these LERs were related to control room ventilation isolation system (CRVIS) actuations. Nine of
,
these were due to problems with the chlorine monitor ;  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 i
improvement effort in this area has been protracted. This '
has resulted in the control room operators no longer l  trusting their chlorine monitors.-  ,
t 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 operation When problems are identified by the quality and engineering
. organizations they are not always acted upon in a timely '
1 manne l l'
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 qualit ,
3. Board Recomendations
; Recomended NRC Actions a
<
Supplemental inspection effort should be devoted to this l  area.
 
;
! Recomended Licensee Actions
 
a Increased corporate management involvement in site I
 
activities is recomende In particular, additional
;  corporate management involvement is needed to ensure that ,
I  proper engineering and QA involvement is naintained in all l l  activitie I i      l l      l
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J. Licensing Activities  . . Analysis During the present rating peri 6d, the 1(censee'5 Panagement participated effectively in assuring the quality of submittals ,
forlicensingactionsandinresponsestoNRCstaffrequest 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 .
      '
l the licensee appeared to adequately understand staff policies
!  and be able to make decisions based on adequate management l  involvement. The licensee's submittal contained all of the
~
information that the staff requested for its revie 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 soun !
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.
 
i Because WCNOC involved its management in this review, they were l
able to respond promptly to staff concerns to bring the review
'
to ccmpletio The WCNOC management has generally exhibited an adequate understanding of the approach needed to resolve complex technical issues involved in licensing activitie WCNOC's June 16, 1987, submittal supporting analysis related to relaxed i
outage time and increased surveillance intervals demonstrated a l
      '
l  clearunderstandingofthelicensingissuesinvolvedand
!  followed the staff s guidance exactly as provided in the related generic documentatio ;
i
,
!
The quality evaluation and levelsubmitted summaries of detailpursuant of the licensee's safety )(2)
to 10 CFR 50.59(b !
I  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 i or environmental question; they do not provide a summary of the '
WCNOC safety evaluation that was prepared to support the chang In review of WCNOC'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 l l  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 meetin l
 
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The failure to follow up on the agreed upon technical rasolution !
delayed the completion of the licensing action on the itservice l testing progra l The licensee had been generally responsive to NRC initiative -
during this rating period, with few longstanaing regulatory '
issues being attributable to the license . l
<
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 WCNOC's submittal related to the main steam line break :
j  outside of containment issue required multiple requests for additional information, and the licensee's responses to these requests were not expeditiou P j  The licensee reported 53 nonsecurity events to the NRC 1  operations center pursuant to 10 CFR 50.72. These events were j  almost always reported in a timely manne I The licensee also submitted 49 nonsecurity Licensee Event ,
. Reports (LERs) during the reporting period, ihe LERs were well !
'
written and almost always timel I
'
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 license This continuing series of LERs is indicative of a failure to
!j  identify the root cause of these failures and an ineffectual corrective action program for the chlorine monitor problems.
 
1  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 l Actuations, no Sign'ficant Events and five Safety System ;
I Failures during this rating period,  i 2. Conclusion l
..
The licensee continues to maintain a competent, knowledgeable l j  licensing staff; however during this rating period there were '
'
i  occasionalinstancesofIackoftimelyresponsetostaff  ;
requests and a decline in content of summaries of safety -
1  evaluations submitted by the licensee in response to l
{  10 CFR 50.59. The licensee is considered to be in Performance i Category 2 in this are ;
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Board Recommendation Recommended NRC Actions hone    l
. Recommended Licensee Actions  !
e licensee should improve the quality of the safety l e luation summaries submitted pursuant to 10 CFR 50.59 and
'
r i  sho ld improve the content of licensing submittals to  :
prec ude the need for staff requests for additional infor tion that could have been foreseen by the license ,
      ,
, Training and Qual ication Effectiveness  : Analysis i
i The assessment of s functional area includes all activities f  relating to the eff tiveness of the training / retraining and
-
qualifications progr ucted by the licensee's staff. This ;
I  area was inspectede ontinuing basis by the resident ,
,
inspectors. This a 150 the subject of an inspection ;
-
which was performed i appraisal period to look into the ;
,  training of both the e d and nonlicensed staff. During the ,
 
appraisal period, lice ing nations were administered by
:
, the NRC to seven (7) rea r ator (RO) candidates and to j  seven (7) senior reactor  candidates. Five (5) of the
      .
      !
)  RO candidates ,and fix (6)  candidates passed the
,.
-
examinations and were subseg issued licenses. The !
!  licensee currently has 36 ind is who hold an SR0 license !
j and 15 individuals who have an cense. During the l l
administration of the above exam ons, the examiners found i i  that the trainees had been adequa 1 informed of the  I
;  significant events that had occurred d ing the week of j  October 18, 1987. The trainees had als been schooled on the lessons learned from these event l l  The inspections in the operator requalifica on training area  l
-
indicate that the management oversight in thi area h&s not been sufficiently thorough. This is evidenced by:  '
)
  '
j  The section of the procedure (ADM 06-224) o licensed j  operator requalification training which relax d a
,  requirement of 10 CFR 55 without Commission ap oval.
 
l  *
 
An operator who had failed the annual requalific ion  !'
examination and was therefore required to enter in o an
}  accelerated requalification program was allowed to ntinue
,
to stand watch and perform watch standing duties pri to
{  his completion of the accelerated trainin !
l      l
:
 
. .
27 Board Reconnendation Recomended NRC Actions None Reconinended Licensee Actions The licensee should improve the quality of the safety evaluation sunnaries 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 license K. Training and Qualification Effectiveness Analysis
    ~
The assessment of this functional area includes all activities relating to the effectiveness of the 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 staf During the appraisal period, licensing examinations were administered by the NRC to six (6) reactor operator (RO)
candidates and to seven (7) senior reactor operator candidates. Four(4)oftheR0candidatesandseven(7)ofthe SRO candidates passed the examinations and were subsequently issued licent 1. The licensee currently has 34 individuals who hold an SRO cense and 17 individuals who have an R0 licens During the aaministration 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 baen schooled on the lessons learned from these event 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 Coninission approva *
An operator who had failed the annual requalification examination and was therefore required to enter into an accelerated requalification program was allowed to continue to stend watch and perform watchstanding duties prior to his completion of the accelerated trainin . .
. .
 
  *
The required reactivity manipulations had not been completed in the 1985-1986 requalification cycle for at least six licensed individual The correction of this i  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 errergency and off-normal procedures as a  required by the requalification program. The licensee ,
revised the appropriate procedure to specify the off-normal and emergency procedures to be reviewe The procedures i
-
requested after the revision were also incomplete and the procedure had to be further revised at the prompting of the i NRC inspecto *
The licensee had not provided procedures for implementing the 10 CFR 55 rule change issued by the NRC on May 27, 1987.
 
;
j The above examples are indicators that the training department i
'
arrangement had not provided the attention to detail necessary to assure adequate oversight of this are There has also been 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; a
failure to revise a procedure tc reflect a new requirement I
,
instituted by a rule change; and  ,
      -
  *    '
 
failure to delete a procedure requirement which was dropped i  by a rule chang No deficiencies were identified in the area of training of the i j nonlicensed staf The procedures and policies in this area ;
were adequately stated and understood. Training records in this area were generally complete and well maintaine ,
I      t l 2. Conclusions l
The initial training of licensed operators and the training of I the nonlicensed staff is effectively controlled and the 1
: licensee's performance in licensing examinations has been goo l The area of requalification training for licensed operators has
,      :
i
!
'
      \
 
;. '
.
_
i . .
 
.
suffered from an apparent lack of management oversight and inattention to detail on the part of the training staff, The licensee is considered to be in Perforniance Category 2 in this area.
 
l Board Recommendations
      -
! Recommended NRC Actions The NRC inspection effort in this area should continue at the level prescribed by the basic inspection program, 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 staf ,
V. Supporting Data and Summaries Licensee Activitiej Major Outages l
  . The unit was shut down on April 19, 198 The cause was an
'
inadvertent trip due to control rod logic card failure The l  outage duration was 13.1 hour . The unit was shut down on April 23, 198 The cause was an I  inadvertent trip due to control rod logic card failure The outage duration was 33 hour . The unit was shut down on May 28, 198 The cause was an inadvertent trip due to a loss of power to the main turbine l electro-hydraulic controi system. The outage duration was 22.3 hour . The unit was shut down on June 29, 198 The cause was an inadvertent trip due to a loss of a main feedwater pum The ;
outage duration was 38 hour l
  . The unit was shut down from July 20, 1987, to July 26, 198 '
The cause was an inadvertent trip due to a loss of a main feedwater pum The outage was extended to repair a containment I cooling fa The outage duration was 129.3 hour ;
  .I    i
      ;
l      1
 
    . _  -. .
.
. .
I 30  l
 
The unit was shut down on September 10, 198 The cause was an :
inadvertent trip due to a failure of a main transmission line, j
;
The outage duration was 33.7 hour . e unit was shut down on September 27, 198 The cause was an !
ii dvertent trip due to a mispositioned rod control switch. The ;
lic see decided to remain down and enter refueling o.utage II i i      earl The outage duration due to the inadvertent trip was !
>      93.5 h ur The refueling outage duration was 2,418.7 hours, j
'
i
      . The unit s shut down on January 21, 198 The cause was a ; manual shu own to replace failed reactor vessel 0-rings. The !
t      outage durat on was 379.2 hours. During startup following this !
4  -
outage, two t bine trips without reactor trips occurre The i duration of eac of se two outages was 9.5 hour l t
Inspection Activities
) NRC inspection activity  his SALP evaluation period included l
]      49 inspections performe i 31 direct inspection aanhours expende These inspe s ed team inspections of the
,
equipment qualification p ra d a SSON This inspection effort I i      represents an approximate 5 r increase over the previous SALP i j      perio l J
l Table 1 provides a tabulation of RC, nforcement activity for each i
            '
    -
functional area evaluated. Table pt vides a listing of inspection i      findings in each P LP categor '
  ~
InvestigationsandAllebationsReview
'
-
C.
 
)      There was one investigative activity conducte during this assessment period. The results have not been formally iss d ye !
.
'
            ! Escalated Enforcement Actions j Civil Penalties    !
1            l 1      A Notice of Violation and Proposed Imposition of Ci il Penalty '
i      was issued on March 17, 1988. A $100,000 civil pena ty was
.
proposed for two Severity III violations involving a failure to t i      follow procedure and a failure to have appropriate proc ure ! Enforcement Orders
            ;
i            '
'
None I
            !
I i
 
4
-_ . - _ _ _ _ _ _ . _ - - _ _ _ _ _ - _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _
 
.-
      .
L
, .
,
 
i
'
. The unit was shut down on September 10, 1987. The cause was an inadvertent trip due to a failure of a main transmission lin ,
. The outage duration was 33.7 hour . The unit was shut down on September 27, 1987. The cause was an ;
inadvertent trip due to a mispositioned rod control switc l
 
The licensee decided to remain down and enter refueling I
;
outage II early. The outage duration due to the inadvertent j  trip was 93.5 hours. The refueling outage duration was
,  2,418.7 hour ,
L      ;
-
. The unit was shut down on January 21, 198 The cause was a -
. manual shutdown to replace failed reactor vessel 0-ring l  During startup following this outage, generator / exciter
'
problems were experienced and two turbine trips without reactor i  trips occurre .
I l Inspection Activities e
j NRC inspection activity during this SALP evaluation period included 49 inspections perforned with 6031 direct inspection manhours expended. These inspections included team inspections of the j equipment qualification program and a SSOMI. This inspection effort
. represer.ts an approximate 50 percent increaso over the previous SALP perio l
'
Table 1 provides a tabulation of NRC enforcement activity for each functional area evaluated. Table 2 provides a listing of inspection ,
j findings in each SALP categor ;
,
! Investigations and Allegations Review  ,
i j There was one investigative activity conducted during this
:
assessrmnt period. The results have not been formally issued ye t 1 Escalated Enforcement Actions Civil Penalties l      l l  A Notice of Violation and Proposed Imposition of Civil Penalty l j  was issued on March 17, 1988. A $100,000 civil penalty was i
;
proposed for two Severity III violations involving a failure to i
follow procedure and a failure to have appropriate procedure [
]      i j Enforcement Orders i
 
j  None    j
 
)
      .
1      !
4      !
i      l
!
      '
      -
 
..  .
'
. .
'
. .
31 Manaaecent Conferences Held During Assessment Period
      . Conf.rences i
      '
A management meeting was held on October 21 1987, to discuss theeventswhichoccurredduringtherefuelIngoutag An :
enforcement conference was held on January 11, 1988, to discuss violations which had occurred during the refueling outage, i Confirmation of Action Letters Nont i., Review of Licensee Event Reports and 10 CFR Part 21 Reports Submitted By the Licensee
]
I Licensee Event Reports i
'
The SALP Board reviewed the LERs for the periori March 1,1987, through March 31, 1988. This review included the LERs listed by
.i  SALP category in Table . Part 21 Reports
      [
There were no 10 CFR Part 21 reports submitted by the licansee j during this SALP assessment perio ;
;l
      .
4      I j      !
      !
i
      '
 
i i      !
;
      }
.      .
I
      ;
f
*
i
      ;
,
i
'
i j
.
      !
'
      !
l'      !
 
. .
Table 1 Enforcament Activity FUNCTIONAL AREAS  NUMBER OF VIOLAT.10NS IN E>'.CH LEVEL
\  DEFICIENCIES / DEVIATIONS V IV III A. Plant Operations    1
      *
B. Ra ological Controls  0/1  1 4 C. Mainte ce    2 D. Surveillanc    2 E. Fire Protection    1 F. Emergency Preparedne  1/0  2 1 G. Security -  4
  '
H. Outages    1 1 2 I. Quality Programt and Administrative h, g 1 9
    '
Controls Affecting Quality J. L-icensing Activities
  '
K, Training and -
  '."  2
-
Qualification Effectiveness Total  1/1  7 25 2 i
l
 
i l
l
. .
l Table I Enforcement Activity-l FUNCTIONAL AREAS  NUMBER OF VIOLATIONS
      '
IN EACH LEVEL l
l  DEFICIENCIES / DEVIATIONS V IV III
 
1
'
A. Plant Operations    1 B. Radiological Controis 0/1  1 4 i
C. Maintenance    2 D. Surveillance    2 '
E. Fire Protection    1 F. Emergency Preparedness 1/0  2 1 G. Security    4 t
H. Outages    1 1 2 I, Quality Programs and  1 7 Administrative Controls Affecting Quality J. Licensing Activities
 
K. Training and Qualification  2 Effectiveness    :
      ,
TOTAL  1/1  7 23 2
      :
l l
 
c
. .
      '
. .
Table 2 ENFORCEMENT ACTIVITY
      = i TABULATION OF VIOLATIONS, DEVIATIONS, AND EMERGENCY PREPAREDNESS DEFICIENIES  t PERFORMAN CATEGORY
      '
A. Plant Operations Violations
. Failure to enter Technical Specification 3.0.3 when both trains of CRVIS were inoperable. (Severity Level IV, 8720-01) ,
.
Deviations
      >
. None B. Ra.hological Controls Violations    f
      !
. Failure to properly control, store and protect quality record ;
  (Severity Level V, 8708-01)  l
. Radiation Protection Manager not fully qualifie (Severity Level IV, 6712-01)
. Failure to properly evaluate radiologichl surveys of two !
contaminated persons. (Severity Level IV, 8728-01)  {
. Unauthorized disposal of contaminated material.- (Severity l Level IV, 8736-01)    ;
      ;
. Failure to lock high radiation doo (Severity level IV, f 8809-01)
Deviations
. Repeated failure to implement a continuous airborne monitoring progra (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 procedur (Severity Level IV, 8807-38)
 
  . -- - .  .  . -_  - _ __ - -_ -.  . - -._ .
          ,
-
. .        !
-
. -
l
 
f
-
i a          !
Deviations        j
:!
.
        *
j  None
  .
f I          ;
i Surveillance      t
          ,
          .
,
Violations i  . Failure to demonstrate automatic isolation of the containment i  purge pathwa (Severity Level IV, 8715-02)
i
  . Failure to alternate starting locations for the motor driven fire    [
pum (Severity Level IV, 8722-01)    ;
i Deviations        l l  None
  .
          (
!  t Fire Protsetion l  Violations        !
.          ;
)  . Fire door inoperable by being blocked ope (Severity Level IV, l j  8706-01)      ;
l          i
,  .        ,
4          :
j  Deviations        !
          !
  . None        l
;          i l Emergency Preparedness      ;
!          >
l  Violations        l i          ,
          '
l  . Failure to document a communication tes (Severity Level V, l  8714-01)
.
l  . During an unannounced call-out drill, the communicators could not j  be reached. (Severity Level IV, 8714-02)    !
t          i i
  . Repeat violation of a failure to meet call-out time limit l i  (Severity Level V, 8812-01)
 
l  Deviations        -
i          {
j  . None
          [
          ;
I
          !
i I          -
I
          .
I
  - _ _ _ _ _ _ _ _ _ _ _ _ _  _ _ _ _ . _ _  __-_____--__________
 
_ _ _ _ _ _ _ _ _ _ __
. ..
-
. .
 
.
Deficiencies
      *
  . During an emergency plan exercise, an incorrect classification was mad (8721-01) Security Violations    *
  . Failure to follow compensatory procedure (Severity Level IV, 8716-01)
  . Inadequate compensatory measure (Severity Level IV, 8723-01)
  .' Failure to maintain assessment aid (Severity Level IV, 8734-01)
  . Failure to maintain control of security badg (Severity Level IV, 8805-01)    ,
Deviations    ;
i
  . None l Outages Violations
  . Six examples of failure to follow procedure (Severity Level III, 8731-A)
  . Four examples of failure to have appropriate procedure (Severity Level III, 8731-B)
  . Two examples of inadequate procedure (Severity Level IV, 8806-01)
      {
  . Failure to make inservice test log entri's (Severity Level V, 8811-02)
Deviations
  . None Quality Programs Violations
  . Failure to have qualified electrical splice (Severity Level IV, 8724-01)
_
 
, . . _ - - .. . . _ . - - _ . - - - _ . . . . .-.
.
j i .
 
l i        t
,
a I  Connection boxes mounted below post-accident containment water  .
l  leve (Severity Level IV, 8724-02)  .
l
;  . pace heaters operating in motor operated valve (Severity f vel-IV,8724-03)    !
        .
a 1  . Use f unqualified terminal block (Severity Level IV, 8724-04) l l        }
  .
Failur to evaluate temporary modificatio (Severity Level V, j 8801-01      :
        ,
!i  . Inadequate cceptance criteria for reactor vessel 0 ring :
1  (Severity Le el IV, 8804-01)    ;
        ,
i
.  .
Purchase order alle to specify code requirement (Severity ;
 
Level IV, 8815-0    ;
i f
.  . Purchase request di document Spec level (Severity  i Level IV,8815-02)    !
!
t        l Unqualified code a (Severity Level IV, 8815-03) ;
l  .
{  Deviations      f j        i q
  , None      j
        .
    .
 
l Licensing Activities  .
I
:
        !
    '
. .
Violations  .
    -
    -
    ''
l
,
l
  . None      ;
        '
i
;  Deviations      ;
-        i
  . None      j j Training and Qualification Effectiveness
!  Violations j
  . Failure to provide health physics retrainin (ieve ty Level V, ,
B 8717-01)      l Failuit tt, maintain health physics training records. (Se erity l  .
Level V, 9717-02)
 
I        l Deviations      I l
  . None      j l
'
i
        !
        !
l        I
:        !
        '
I
!        !
 
. .
 
. Connection boxes mounted below postaccident containtnent water leve (Severity Level IV, 8724-02)
. Space heaters operating in motor operated valve (Saverity Level IV, 8724-03)
! . Use of unqualified terminal block (Severity Level V, 8801-01) i
- Failure to evaluate temporary modificatio (Severity Level )
,
. Inadequate acceptance criteria for reactor vestel 0-rings.
 
Severity Level IV, 8804-01)  ,
. Failure of procurement program with three example (Severity Level IV, 8815-01)
I Deviations 4 . None
      :
. J. Licensing Activities
, Violations
. Noiie I
i Deviations
. None
.      1 I K. Training an'. Qualification Effectiveness Violattens
  ~
l
. Fai' e to provide health physics retrainin (Severity l Level V, 8717-01)
!
. Failure to maintain health physics training record (Severity !
,
Level V, 8717-02)    !
Deviations    l
. None
 
:
;
.
 
_ _ _ _ _ _ _ _ _ _ -_ .___ ___ - - _ _ _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _
. *<
-
.  .
,
Table 3 OPERATIONAL EVENTS TABULATION OF LICEN5EE EVENT REPORTS
              =
PERFORMAN      CATEGORY A. Plant Operations
  . Error while placing block switch in ' permit' results in aux, feedwater actuatio (87-018)      .
  . Failure to communicate allowed an open door creating a pressure boundary breac (87-034)
  . Errors result in loss of power to control rod moveable gripper coils which causes a reactor trip. (87-041)
  . Error leads to Hi-Hi 5/G 1evel resulting in feed isolation signa (87-042)
B. Radiological Controls
  .
Inadvertent without release of secondary)
prior samplin (87-036  liquid waste monitor tank
  . Inadequate control results in loss of licensed materia (87-056)
C. Maintenance
  . Logic cabinet cards overheated causing reactor tri (87-017)
  . Containment purge isolation due to signal spike on radiation monito (87-019)
  . Reactor trip caused by loss of power to main turbine electro-hydraulic control system. (87-022)          l
              !
  . Reactor trip resulting from personnel error in not correctly        ,
tightening instrument sensing lines. (87-027)          l
              !
  . Potential transformer failure causes partial loss of offsite        ,
power and reactor tri (87-030)
  . Inoperable containment isolation valve due to incomplete retesting following maintenance. (87-033)
  . High Voltage transmission line failure causes generator trip / reactor trip. (87-037)
  . Accidental mispositioning of breaker switch causes inoperability of one power operated relief valve. (87-039)
 
      . .
..-    . -_ -
, ..        i
. .
l      2
        !
l
  . Omission of snubber from inspection procedur (87-044) ;
        .
  . Inadequate hydrostatic pressure tests due to procedural inadequac (87-045)    j
  . Containment purge isolation caused by moisture induced corrosion i of an electrical connecto (87-054)  ,
        ' Surveillance
  . TS violation caused by missed surveillance procedur (87-014) !
        :
  . Shaft seal on containment air lock failed during testing causing ,
  , total leakage above allowable. (87-023)  l t
Containment purge isolation due to personnel error during
        '
  .
,
I    radiation monitor testing. (87-025)
        >
  . Late performance of spent fuel building vent tritium analysi !
    (87-026)    j
  . Inoperable Class 1E batteries dLe to inadequate post-test review C of surveillance tes (87-028)  !
I
  . Required testing deleted from sureeillance procedure (87-029)
  . Failure to properly verify operability of fire pumps due to procedural inadequac (87-038)  ;
        ,
  . Nonconservative error in containment purge radiation monitoring I setpoint. (87-040)    !
        !
  . Surveillance of power range low setpoint & P 8, P-9, and P-10 l interlocks not performed properly. (87-043)  {
  . Containment isolation valve failed during testing causing total path leakage to be above allowabl (87-050)  g i
  . Procedural deficiency causes two feedwater isolations & an an aux !
feed actuation. (87-051)    {
t
  . Procedural inadequacy resulting in TS violatio (87-060) l Fire Protection      f i
  . Four fire dampers not actuated due to drawing erro (87 013) ,
r Failure to maintain fire watch as required by T (87-016)
l
  .
  . Hourly fire watch performed late due to personnel  I error / individual overlooked one impairment. (87-021)  j i
. . - . ,- . - - - - - , , - - , . , , _ . . . ,
 
  -_  _ . .-
. .* a o , ,
I &
 
i
  .
Spent fuel pool heat exchanger room doors not 3-hour fire rg,te >  (87-031)
  .
Failure to fully understand the requirements causes TS violation l
for hourly rather than continuous fire watches. (87 057)
!  . Wired glass insert discovered in fire door causes loss of 3-hour
:  fire ratin (87-059 F. Emergency Preparedness
  . None G. Security j
j  .
Unauthorized vital area entr (87-046)
i  . Vital door unsecure (87-047)
j  . Security officer inattentive to dut (87-055) Outages j
  . Improper maintenance causes fatalit (87-048)
l  . Low battery bus voltag (87-049)
I, Quality Programs and Administrative Controls Affecting Quality I
i  . CRVIS caused by chlorine monitor spik (87-012)
l CRVIS caused by paper tape bunching up on chlorine monitor, l  .
j  (87-015)
l  . CRVIS caused by paper tape breaking on chlorine monito (87-020)
)
.
  . FA-CRVIS caused by loss of power to chlorine monitor because of
:  faulty sample pump. (87-024)
J
)  . CRVIS caused by paper tape breaking on chlorine monitor.
 
4  (87-032)
 
j  .
CRVIS - two events caused by malfunctions of the chlorine
!,  monitor (87-035)
I  .
Instrument termination splices installed which fail to meet environmental qualification requirement (87-052)
l CRVIS caused by paper tape bunching up on chlorine monitor.
 
)j
  .
.
  (87-053)
I l
      )
 
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ __________ _________ __- _ ___ ______________ _ _ . . ______________ - __ __________________ _
  .
.'
.' .  .
 
.
    .
    '
  ,' . TS Violation, due to error in design documen (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)    i
    . CRVIS from chloriria monitor spik (88-003)
    . CRVIS from chlorine monitor spik (88-005)
l
 
i
          '
 
          >
,
          '
l
.
          ;
l l
l
 
'          l l
,
          '
I i
.
,.I
!
 
. .
SALP MEETING SUMMARY Date: July 20, 1988 Licensee: Wolf Creek Nuclear Operating Corporation (WCNOC)
Facility: Wolf Creek Generating Station (WCGS)
License: NPF-42 Docket: 50-482
      "
SUBJECT: SALP MEETING AT WCGS On July 20, 1988, the Regional Administrator, NRC Region IV, members of the Region IV staff, and NRR representatives met with representatives in an open meeting at WCGS to discuss the SALP Board Report covering the period March 1, 1987, through March 31, 1988. The NRC material presented at the meeting and a list of attendees are attached. The meeting was held at the request of NRC Region I ,
! After opening remarks by the Regional Administrator, the Director, Division of Reactor projects, presented each of the functional areas evaluated in the SALP Board Report using Attachment 1 as an outline. The WCNOC Senior Vice President and other licensee representatives discussed planned actions to improve performance and/or respond to NRC recommendations in each of the SALP ;
categorie [
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Attachments:    (
, NRC Material Presented at Meeting
; Attendance List    .
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INTRODUCTION ROBERT D. MARTIN, EGIONAL
}      f ADMINISTRATOR NRC EGION IV a
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I SALP PESENTATION J0E CALLAN, DIECTOR, DIVISION OF i      i
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i EACTOR PROJECTS, NRC EGION IV !
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i WOLF CEEK NUCLEAR OERATING LICENSEE MANAGEENT AND STAFF l, t
; CORKRATION ESKitSE AND  l
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i 1 CLOSING PEXARKS ROBERT D. MARTIN  !
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l      I j  LNilED STATES NUCLEAR EGULATORY C0ft!SS10fi  l i
i i  SYSTRATIC ASSES 9ENT OF LICENSEE PERF0WANCE  l
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WDLF CREEK NUCLEAR OPERATING CORPORA 110N  l r
r WOLF CEEK GEERATING STATION
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i j  MARCH 1, 1987 - MARCH 31, 1988
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W)LF CEEK GEERAT!?$ STATION JULY 20, 1988 9 l
 
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SALP PROGRAM OPJECTI\ES j
IMPROVE LICENSEE PERFORMANCE
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PROVIDE A PASIS FOR ALLOCATION OF NRC ESOURCES l
IMPROVE NRC EGULATORY PROC.W1
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i    ERFORMANT ANALYSIS AREAS FOR WOLF CRFFK EERATING STATION
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;        A. PLANTOERATIONS    l
 
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i        D. SURWILLANCE      !
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I        E. FIRE PROTECTION    !
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F. EERGENCY PREPAREDESS (
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:        G. SECURITY      l
 
j I        H. OUTAGES      !
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r i        1. QUALITY PROGRAMS AND    ;
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AFFECTING QUALITY j        J. LICENSINGACTIVITIES    !
i K. TRAINING AND OUALIFICATION f
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FUNCTIONAL AEA KRF0mANCE CATEGORY CATEGORY 1 EDUCED NRC ATTENTION PAY E APPROPRIATE, LICENSEE MANACDENT ATTENTION AND INVOL\9ENT AE AGGRESSIVE AND
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ORIENTED TOWARD NUCLEAR SAETY: LIENSEE ESOURCES AE #ftE AND EFFECTlWLY USED S0 THAT A HIGH LEWL OF ERFOR%NE WITH ESECT TO OPERATIONAL SAFETY IS EING ACHIEVE .
 
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}  CATEGORY 2  [
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; NRC ATTENTION SHOULD E MAINTAIED AT NORMAL LEWLS, i
: AND AE CONCERNED WITH NUCLEAR SAFETY, LICENEE ESCORCES
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j  SATISFACTORY ERF0W#CE WITH ESECT TO OERATIONAL SAFETY l l  IS EING ACHIEED,  [
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BOTH NRC AND LICENSEE ATTENTION SHOULD E INCEASED. LIENSEE  !
MANAGDENT ATTENTION OR ltWOLWeiT IS ACCEPTABLE AND CONSIDERS NUCLEAR SAFETY, BUT EAKESSES AE EVIDENT: LICENSEE ES00RES
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APEAR TO E STRAltED OR NOT EFFECTlWLY USED S0 THAT MINIMALLY SATISFACTORY ERF0WAE WITH ESPECT TO OERATIONAL SAFETY IS  [
EING ACHIEW !
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EVALllt. TION CRITERIA    l J            !
 
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i MANAGEENT INVOL\ DENT AND CONTROL IN ASSURING QUALITY
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J l APPROACH TO ESOLUTION OF TECHNICAL ISSLES Ff01 A SAFETY  j l      STANDPOINT      !
            ! ESPONSl\0ESS TO NRC INITI ATlWS
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i      '4 . ENFORCDENT HISTORY i            l i            i OPERATIONAL EWNTS (INCLUDING ESPONSE T0, ANALYSIS OF,  ;
j j      AND CORECTlW ACTIONS FOR)    f I STAFFING (INCLUDING f%%GEENT)    l
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FIE PROTECTION AND SECLRITY AE STRONG AEAS  j i
i (EE OF PROCEDURES IN OPERAi!0NS WAS MIH IPPROVED TOWARD TE l
i END OF ERIOD f
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ERSONEL RADIATION EXPOSURE HISTORY HAS BEEN ETTER
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THAN TE NATIONAL AVERAGE FOR FHRs (LESS THAN 50% OF AWRAE)
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PAJOR MANAGEENT CHANGES MADE IN TE MAINTENANCE AEA APPEAR  :
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EAKESSES  i I
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ACTUAL OERALL DECLIE OR DECLINING TEND IN TE ERF0 WANCE FOR T E FOLLOWING FUNCTIONAL AREAS:  !
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PLANTOKRATIONS  I
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RADIOLOGICALCONTROLS
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PAINTENANCE  ;
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Ll&NSING ACTIVITIES
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MIN! PALLY SATISFACTORY ERF0WANCE IN TE  i t
AREAS OF QUAllTY F90 GRAMS AND OUTA T S  l i
LACK OF EFFECTlW C00 ERAT 10N AND COORDINATION  j ETEEN TE PLANT OPERATIONS STAFF AND TE  l vARiOUS TtcaCAt sum cR0ueS  !
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PLANT OKRATIONS
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TERE IS CONTINtED STRONG MANAGDENT SUPPORT FOR
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TE COLLEGE DEGEE PROGRAM FOR OPERATIONS PERSONNEL    !
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l    USE OF PROCEDUES IN OEPATIONS WAS MUCH IEROWD    I TOWARD TK END OF TE SALP KRIOD    l i
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j    OKRATIONS INTERFACE WITH OTER DEPARTENTS IS A    l 1    TOTED EAKtESS      !
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AT TIES, OKRATORS Fall TO PAY ATTENTION TO DETAIL    !
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!    LICENSEE MANACBENT SHOULD ENSURE THAT TEE IS AN i            :
.'    ADEQUATE AND PROPT 00AllTY ASSURANCE, NUCLEAR SAFETY    i
 
,    ENGlEERING, AND ENGlEERING INVOLWENT IN OPERATIONAL    !
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;    BENTS AND IN DE ECmlCAL WET!0N TO SAFETY ISSLES,    ;
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TE LICEfEE'S KRSON'EL RADIATION EXPOSUE HISTORY HAS BEEN BETTER
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    (LESS THAN OE-RALF) THAN TK NATIONAL AW. RAGE FOR FVRS
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i    OERALL KRFORMANCE INDICATED A DECEASE IN EFFECTIESS OWR TE      ;
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PEVIOUS ASSES 9ENT KR100
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f    INADEQUATE F#iAGEENT ATTENTION TO NRC CONCERNS IS DOONSTRATED BY      (
TE LACK OF ESOLUTION TO TE CONCERNS NOTED DURING TE PEVIOUS      !
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LACK OF STE#4 EfERATOR MDCX UP TRAINING f
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LACK OF EALTH PHYSICS SUKRVISORY KRS0ffEL PESENCE IN      !
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EC0tENnFT) LIERTF ACTION      .
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;    EALTH FWSICS SLFERVISORY KRS0ffEL SHOULD SEND M)E TIE IN TE
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RAD 10 LOGICALLY CONTROLLED AEAS EVALUATING #0 OBSERVING ONGOING      !
i RADIATION PROTECTION WORK ACTIVITIES TO ENSUE C&PLIANCE WITH
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l    PANAGEENT SHOULD TAKE ACTION TO PROVIDE TRAINING TO TEONICIANS TO
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ENHANCE PROCEDURAL C&PLIME.
 
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GE@RY 2
 
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TOWARD TE END OF TE SALP KRIOD, PAJOR MANAGDENT CHANGES HAVE EEN  l
}  IWLEEfffED, AND APEAR TO HAW SIGNIFICANTLY STENGTEED TE  !
PAINTENM AREA 1        :
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3  FANACHENT HAS SHOWN STRONG SUPPORT FOR TE PAINTENANCE PROGRM, BUT  !
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IWLEE? RATION OF THIS PROGRAM WAS NOT ALWAYS ADEQUATELY CARRIED OUT
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i  ESCALATED ENFORCEENT ACTION REWALED SIGNIFICANT PROBLEMS WITHIN TK
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PAINTENANCEORGANIZATION, INCLUDING:    l l
 
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WOFERS FAILING TO FOLLOW PROCEDUES l        ,
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ACTIVITIES DURING TE FALL EFLEllNG OUTAGE l
1        i EC0tEhTFD LIERW ACTION i        I
<        i j  TK LIENSEE SHOULD FOLLOW THROUGH AND ASSESS TE EFFECTlWESS OF  (
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TEIR CORECTIVd ACTICtG. AND CONTlhE TE INCEASED EMEASIS ON
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PFOCEDURALCOPPLIANCE.
 
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SURVEILLANT      l l
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l j    ADE00 ATE PROGRNi EXISTS FOR SCEDULING At0 TRACKit4G OF SURWILLMEE l
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i ENFORCDENT AND EPORTING HISTORY INDICATE ITRO\9ENT OVER TE      !
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i    PEVIOUS ASSES 9ENT ERIOD, RTT ERAT PROCEDURAL AND ERSONNEL      j ERRORS INDICATE THAT ADDITIONAL PANAGDENT INVOLN9ENT IS EEIED      !
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)            I PROCEDURES IN SCPE CASES DID NOT ADDESS ALL TECHNICAL SKCIFICATION      j l
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TE LIENTE IS ENC 00RAED TO KRFORM INDEPTH EVIEW OF TE TECmlCAL
,    SKCIFICATION SURNEILLANE EQUIRDENTS MD ENSUE THAT TE      :
 
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i SUR\EILLA'CE PROEDURES ADDESS TESE EQUIEENTS,      j i
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:    ADDITIONAL PAVEENT lit.0LMENT WITH SURWILLANCE ACTIVITIES IS a            ,
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EN000 RAGED,
 
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SIGNIFICANT IPPROMENT IN TE FIE PROTECTION, PEWNTION PROGRAM i  HAS BEEN ACCGftlSKD  i
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]  FIE BRIGADE / WATCH TRAINING IS OUTSTANDING I      .
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l CONTROL OF TRANSIENT CCNBUSTIELES HAS BEEN EFie .E '
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!  EQMENDED LICENSEE ACTIONS  !
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TE LIENSEE SHXJLD ASSURE THAT TE EENT ORGANIZATIONAL 0%NGES I
;  THAT HAW TE FIE PROTECTION EN31EER EPORTING TO A DIFFEENT i      .
! GROUP AND AT A L0ER LEWL DOES NOT ESttT IN A REDUCTION OF J      .
i MAVGEENT SUPPOR !
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EMERGENCY PREPAPEDNESS l
fATEGORY2
!    TE ANNUAL EERGENCY ESPONSE EXERCISE WAS VIEWED BY TE EVALVATICH TEAM AS GOOD PERSONNEL NOTIFICATION ETHOD AND PROCEDURE REQUIES ADDITIONAL IEROVEENT FOR CALL-0UT AND SHIFT AlRENTATION RESPONSE TlWS l
EC0 WENDED LICENSEE ACTION TE LEVEL OF MANAGEENT ATTENTION TO TE IELEENTATION OF TE
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l    EERGENCY PREPAREDNESS PROGRAM SHOULD BE INCREASED TO ENSURE PROPER l    ESPONSE TO NRC IDENTIFIED CONCERNS ELATING TO CALL-0UT DRILL RESPONSE AND SHIFT AUGENTATION ESPONSE TI TE LICENSEE SHOULD EXEDITE CORRECTION OF TE CALL-0UT DRILL
        '
RESPONSE AND SHIFT AUGENTATION CONCERN,
 
MANAGEENT SHOULD REVIEW TE DISTRIBUTION OF ONSITE AND OFFSITE EERGENCY PROGRAM AEAS OF AUTHORITY AND ESPONSIBILITIES,
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SECURIT(
CATEGORY 1
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FOLICIES AND PROCEDURES ARE WELL STATED, APPROPRIATELY DISSEMINATED AND UNDERSTANDABLE A NEW SOUAD MANNING STRUCTURE HAS ALL0kED FOR TRAINING AND PRACTICE IN SOUAD RESPONSE TACTICS MINOR PROCEDURAL MISTAKES INDICATE A NEED TO ENHANCE TE SELECTION PROCESS FOR TEFPORARY SECURITY PERSONNEL AND TO E 5RSISTENT IN PROGPMATIC TRAINING REC 0 WENDED LICENSEE ACTION M LICENSEE SHOULD CONTINUE TO PROE TE CAUSATIVE FACTORS OF SECURITY EVENTS FOR BROADER IMPLICATIONS AND ADJUST PROGRAMS, TRAINING, DISCIPLINARY ACTIONS, MAINTENANCE, AND ENGINEERING RESPONSES APPROPRIATELY, TE ORGANIZATIONAL ADJUSTENTS MADE IN TE 0A AREA SHOULD E CLOSELY MONITORED TO ENSURE THAT THE HIGH QUAllTY OF TE SECURIT( OVERS!Giff PROGRAM CONTINUES,
 
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DUTAGES CATEGORY 3 SIGNIFICANT WEAMESSES WERE IDENTIFIED IN TE LICENSEE'S ABILITY TO PLAN, MANAGE, AND MAINTAIN CONTROL OVER COMPLEX OUTAGE' EVOLUTIONS AND ESULTED IN ESCALAiED ENFORCEENT TE LICENSEE'S INWSTIGATION OF OUTAE-RELATED EVENTS INDICATED A LESS THAN AGGESSIVE APPROACH TO TE ESOLUTION OF TECHNICAL ISSUES WEAKNESSES WEE IDENTIFIED IN PROCEDURAL COMPLIANCE
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RECCitENDED LICENSEE ACTION TE LICENSEE SHOULD ENSURE THAT LESSONS LEARNED FROM TE PEVIOUS OUTAGES AE IDENTIFIED AND REVIEWED FOR PROGRAM IMPROV9ENTS TE ESULTS OF THIS REVIEW SHOULD E INCORPORATED INTO OUTAGE PLANNING AND CONTRO . .' * ."
.
QUALITY PROGRAPS AND A mlNIS"RATIVE CONTROLS AFFECTING G_AL TY CATEGORY 3 FANAGEENT HAS NOT BEEN EFFECTIVE IN CONSISTENTLY ENSURING TIELY RESOLUTION OF IDENTIFIED SAFETY PROBLEMS TE STAFFING IN TE ENGINEERING AREA IS GENERALLY ADEQUATE, BUT THERE AE WEAK? ESSES IN EXERIENCE AND TRAINING TE LICENSEE'S ABILITY TO ERFORM ROOT CAUSE ANALYSIS AND IMPLEENT
,
TIE LY AND APPROPRIATE CORRECTIVE ACTIONS WAS A NOTED WEAKNESS CORPORATE FANAGEENT OVERSIGHT OF PLANT ACTIVITIES DOES NOT ALWAYS ENSURE ADEQUATE INVOLVEEtU OF TE QUALITY AND ENGINEERING ORGANIZATIONS IN PLANT OERATIONS REC 0ftENDED LICENSEE ACTION INCREASED CORPORATE MANAGEENT INWLVEENT IN SITE ACTIVITIES IS
'
RECCttENDED,
,
ADDITIONAL CORPORATE MANAGEENT INVOLVEENT IS NEEDED TO ENSURE THAT i
PROKR ENGINEERING AND QUALITY ASSURANCE INWLVEENT IS MAINTAIED IN ALL ACTIVITIE .-
 
, ...
, ,  ,
.
LICENSING ACTIVITIES CATEGORY 2 THE LICENSEE'S EVIEWS WERE GEERALLY TIELY, THOROUGH, AND TECHNICALLY SOUND
      ,
TE QUALITY AND LEWL OF DETAll 0F TE LICENSEE'S SAFETY EVALUATION
      '
SlfEARIES SUMITTED PURSUANT TO 10 CFR 50,59(B)(2) ARE NOT ALWAYS FULLY ADE00 ATE TO PERMIT TE STAFF TO CONCLUDE TEIR ACCEPTABILITY l
OCCASIONALLY, TE LICENSEE'S RESPONSES HAVE NOT BEEN ADEQUATE TO ERMIT TE STAFF TO RESOLVE TECHNICAL ISSUES WITH0lfT TE NEED FOR ADDITIONAL INTERACTION WITH TE LICENSEE REC 0 WENDED LICENSEE ACTION TE LICENSEE SHOULD IMPROVE TE QUALITY OF TE SAFETY EVALVATION SlfEARIES SUBMITTED PURSUANT TO 10 CFR 50.59,
'
      !
TE LICENSEE SHOULD IMPROVE TE CONTENT OF LICENSING SUBMITTALS TO PRECLUDE TE NEED FOR STAFF REQUESTS FOR ADDITIONAL INF0fEATION THAT
 
COULD HAVE BEEN FORESEEN BY TE LICENSEE,
 
l l
 
. _ - - - - - - - - - - - -
 
  '
' '
, . .
.
.
TRAINING AND QUALIFICATION EFFECTIVENESS CATEGORYJ TE INITIAL TRAINING OF LICENSED OERATORS AND TE TRAINING 0F TE NONLICENSED STAFF IS EFFECTIVELY CONTROLLED AND TE LICENSEE'S PERFORMANCE IN LICENSING EXAMINATIONS HAS EEN GOOD TRAINING RECORDS WERE GEERALLY COMPLETE AND WELL MAINTAINED TE AREA 0F EQUALIFICATION TRAINING FOR LICENSED OPERATORS HAS SUFFERED FROM AN APPARENT LACK 0F PANAGE E NT OVERSIGHT AND INATTENTION TO DETAIL ON TE PART OF TE TRAINING STAFF REC 0ftENDED LICENSEE ACTION I
TE LICENSEE SHOULD FURTER EMPHASIZE TE NEED FOR OVERSIGHT OF OPERATOR EQUALIFICATION TRAINING AND TE NEED FOR TE TRAINING STAFF TO E MORE ATTENTIVE TO DETAILS IN TE RF0WANCE OF TEIR ACTIVITIES,
 
i s
e i
- - - .      .__
_ _ __ . _ _ _ _ _ , _ _ _ _ . . _ _ . _ _ _
 
.- . --. . -.  - -- , .
k
. .
l
      -
ATTACHMENT 2 ATTENDEES
,
,
Name  Affiliation
  .
t
'
R. Martin  NRC - RIV  ~
'
L. Callan  NRC - RIV  t J. Milhoan-  NRC - RIV D. Chamberlain  .NRC - RIV Calvo  NRC - NRR  i
'
P. O'Connor  NRC - NRR B. Bartlett  NRC - RIV  l M. Skow  NRC - RIV
'
G. Boyer  WCN00 F. Rhodes  WCNOC  i B. Withers  WCNOC  !
J. Bailey  WCNOC  !
i  W. Wood  . WCf'0C J. Houghton  WCNOC
      '
B. Hagan  WCNOC
'
B. McKinney  :WCNOC
      ;
H. Chernoff  WCNOC-  l C. Parry  WCNOC l  0. Maynard  WCNOC a  T. Morrill  WCNOC
 
^
K. Moles  WCN00 R. Holloway  WCNOC  l C. Estes  WCNOC T. Deddens, J WCNOC
>
R. Hackman  WCNOC D. Fehr  WCNOC 4  A. Freitag  WCNOC P. Potter  WCNOC i  C. Sprout  WCNOC
<
G. Rathbun  WCNOC  .
 
M. Grimsley  WCNOC  l R. Smith
      '
;    WCNOC J. Pippin  WCNOC  :
J. Johnson  WCNOC  !
i M. Williams  WCNOC 1  H. Dyer  Dan Glickman's Office
,
M. Johnson  KG&E  i
:  J. Kramer  KCPL  !
 
i  B. Gashom  KEPCO
'
T. Ryan  KEPC0  i J. Hays  Wichita Eagle Beacon  l l  S. Kempin  Kansas City Star  I i  S. Swartz  Topeka Capitol - Journal !
l  P. Wenske  Kansas City Times  I i
l
 
!
 
)
}}
}}

Revision as of 12:21, 5 November 2020

SALP Rept 50-482/88-14 for 870301-880331
ML20196C864
Person / Time
Site: Wolf Creek Wolf Creek Nuclear Operating Corporation icon.png
Issue date: 06/23/1988
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20196C787 List:
References
50-482-88-14, NUDOCS 8807010253
Download: ML20196C864 (41)
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