ML20206J125

SALP Board Repts 50-266/86-01 & 50-301/86-01 for Oct 1984 - Mar 1986

ML20206J125
Person / Time
Site:	Point Beach
Issue date:	06/23/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20206J115	List: ML20206J113 ML20206J125
References
50-266-86-01, 50-266-86-1, 50-301-86-01, 50-301-86-1, NUDOCS 8606270012
Download: ML20206J125 (36)

See also: IR 05000266/1986001

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SALP 5

SALP BOARD REPORT

U.S. NUCLEAR REGULATORY COMMISSION

1

REGION III

6

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

A

50-266/86-01; 50-301/86-01

Inspection Report No.

Wisconsin Electric Power Company

Name of Licensee

Point Beach Units I and 2

Name of Facility

October 1, 1984 through March 31, 1986

Assessment Period

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ADock Obbbbb66

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I.

INTRODUCTION

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

integrated NRC staff effort to collect available observations and data

on a periodic basis and to evaluate licensee performance based upon this

information.

SALP is supplemental to normal regulatory processes used to

ensure compliance to NRC rules and regulations. SALP is intended to be

a

sufficiently diagnostic to provide a rational basis for allocating NRC

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resources and to provide meaningful guidance to the licensee's management

to promote quality and safety of plant construction and operation.

A NRC SALP Board, composed of staff members listed below, met on May 16,

1986, to review the collection of performance observations and data to

assess the licensee performance in accordance with the guidance in NRC

Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A

summary of the guidance and evaluation criteria is provided in Section II

of this report.

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

performance at Point Beach for the period October 1, 1984 through

March 31, 1986.

SALP Board for Point Beach:

NAME

BRANCH / DIVISION

C. E. Norelius

Director, DRP, RIII

J. A. Hind

Director, DRSS, RIII

N. J. Chrissotimos

Deputy Director, DRS

G. E. Lear

Project Director, PD-1, PWR-A, NRR

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T. G. Colburn

PAD-1, PWR-A, NRR

I. N. Jackiw

Chief, Section 2B, DRP, RIII

R. L. Hague

SRI, Pt. Beach, DRP, RIII

M. J. Farber

Project Inspector, DRP, RIII

R. J. Leemon

RI, Pt. Beach, DRP, RIII

B. S. Drouin

Safeguards Section, DRSS, RIII

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II. CRITERIA

The licensee performance is assessed in selected functional areas depending

whether the facility is in a construction, pre-operational or operating

phase.

Each functional area normally represents an area significant to

nuclear safety and the environment, and is a normal programmatic area.

Some functional areas may not be assessed because of little or no licensee

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activities or lack of meaningful observations. Special areas may be added

to highlight significant observations.

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

each functional area.

1.

Management involvement in assuring quality.

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2.

Approach to resolution of technical issues from a safety standpoint.

3.

Responsiveness to NRC initiatives.

4.

Enforcement history.

5.

Operational and Construction Events.

6.

Staffing (including management).

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

have been used where appropriate.

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

classified into one of three performance categories.

The definition of

these performance categories is:

Category 1: Reduced NRC attention may be appropriate.

Licensee management

attention and involvement are aggressive and oriented toward nuclear

safety; licensee resources are ample and effectively used so that a high

level of performance with respect to operational safety or construction is

being achieved.

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

management attention and involvement are evident and are concerned with

nuclear safety; licensee resources are adequate and are reasonably

effective such that satisfactory performance with respect to operational

safety or construction is being achieved.

Category 3:

Both NRC and licensee attention should be increased. Licensee

management attention or involvement is acceptable and considers nuclear

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

strained or not effectively used so that minimally satisfactory performance

with respect to operational safety or construction is being achieved.

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III. SUMMARY OF RESULTS

Rating Last

Rating This

Functional Area

Period

Period

A.

Plant Operations

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B.

Radiological Controls

2

2

C.

Maintenance

2

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D.

Surveillance

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1

E.

Fire Protection

2

2

F.

Emergency Preparedness

2

2

G.

Security

1

1

H.

Outages

2

1

I.

Quality Programs and

Administrative Controls

Affecting Quality

2

2

J.

Licensing Activities

1

2

K.

Training and Qualification

Effectiveness

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IV. PERFORMANCE ANALYSIS

A.

Plant Operations

1.

Analysis

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Evaluation of this functional area is based on the results of

routine inspections conducted by the resident inspectors. The

inspections included direct observation of activities, review

of logs and records, verification of selected equipment lineup

and operability, followup of significant operating events, and

verification that facility operations were in conformance with

the Technical Specifications, administrative procedures, and

commitments. One violation was-identified as follows:

Severity Level IV:

Failure to cause a Special Maintenance

Procedure to be generated to perform an abnormal electrical

lineup, (Inspection Reports No. 50-266/84-018(DRP);

No. 50-301/84-016(DRP)).

This violation occurred during a Unit 2 refueling outage which

included a significant amount of breaker maintenance and several

abnormal breaker alignments. Operations personnel were requested

to open the normal feeder breaker to 2A03 to facilitate

inspection and maintenance of the breaker.

In order to maintain

2A03 energized the operators attempted to parallel buses IA03

and 2A03 and close the bus tie breaker.

This is a non-routine

evolution, which had been completed successfully during a

previous Unit 1 outage using a Special Maintenance Procedure.

Despite information on breaker interlocks being readily available

to the operators in the control room, they attempted closing the

bus tie without consulting the reference material. A second

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operator, believing the bus tie had been closed, opened the

normal feeder, deenergizing bus 2A03 which resulted in the auto

start of the 3D emergency diesel generator. This violation was

not of major safety significance.

Two reactor trips and one safety injection occurred during this

assessment period. A Unit I reactor trip from 88% power occurred

on June 26, 1985, and was caused by a loss of the white instrument

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bus. The inverter supplying the instrument bus failed due to the

failure of an integrated! circuit. A Unit 2 reactor trip from

90% power occurred on December 31, 1985, and was caused by a

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loss of load generator trip / turbine trip.

The loss of load was

caused by the failure of a lightning arrestor in the switchyard.

The safety injection occurred on Unit 1 on April 5, 1985, during

a plant shutdown in preparation for a refueling outage. As a

result of performing special chemistry analyses on steam generator

water, the normal plant cooldown procedure was not being used in

that the operators were asked to stop at various hold points in

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the cooldown to allow for samples to be drawn. Normally

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temperature would be reduced to 490 degrees and the plant would

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then be depressurized to 1800 psi at which point safety injection

would be blocked. During this sampling procedure' pressure was

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being maintained while cooling down to the various hold points.

The procedure did not caution the operator to block the low

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steam line pressure safety injection prior to going below

490 degrees.

Blocking of the low steam line pressure safety

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injection is normally only required when doing a primary to-

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secondary 2000 psi integrity test and this special procedure

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was included as an addendum to the " Hot Shutdown to Cold

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Shutdown" procedure. This procedure was revised shortly after

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the incident to include the appropriate precautions.

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During this assessment period, there were three Licensee Event

Reports (LERs) involving operator error. Two of the LERs

involved improper breaker manipulations from the control room

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which caused inadvertent actuations of the emergency diesel-

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generators. These occurred in the first two months of the SALP

period. The latter of the two resulted in the above mentioned

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violation. The third LER involving operator error was classified

by the licensee as a defective procedure and resulted in the

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inadvertent safety injection described above. The inspectors

believe that the operator could have averted the safety injection

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had he been closely monitoring plant parameters.

If concurrent

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evolutions were diverting his attention, a second operator should

have been assigned to assist him in his duties. These events

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were not of major safety significance and do not represent any

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deterioration in the level of performance of the operations staff.

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Unit I had one forced outage during the SALP period. The

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outage lasted 7.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and involved replacement of a defective

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circuit board in an instrument bus, as documented in licensee

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LER 266/85-003. Unit 2 had three forced outages, all due to

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equipment failure. One lasted 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to repair a snubber.

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A second lasted 28.1' hours and involved repair of a weld in the

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component cooling' water system. The third lasted 29.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,

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and was due to a phase to ground fault in the switchyard. As

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of the end of the assessment period, Unit l's availability

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factor was 79.9% with a capacity factor of 69.9%. This is a

slight increase since the end of the last SALP period. Unit 2's

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availability factor was 87.0% with a capacity factor of 79.2%.

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This represents a slight decrease since the end of the last

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SALP period.

Both units remain among the top in the nation in

plant reliability.

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Professionalism continues to be apparent in control room

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activities.

By procedure, all potentially distracting

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activities are strictly forbidden in the control room.- The

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licensee continues to adhere to the black board policy during

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power operation.

Currently, there is only one annunciator on

each unit which is in the alarm condition during operation.

~ Management attention continues to be apparent with frequent

control room and plant tours.

2.

Conclusion

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' The licensee continues to be rated Category 1 in this area.

The licensee's performance during this assessment period has

improved.

3.

Board Recommendat_ ions

None.

B.

Radiological Controls

1.

Analysis

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Seven inspections were performed during the assessment period

by regional specialists. These inspectionsecovered outage and ,

operational radiation protection, radwaste ar.d transportation

tmanagement, chemistry and radiochemistry measurements and a

sp.ecial inspection ccncerning a radiological incident.

Two

violations were identified as follows:

a.'

Severity Level.IV - Failure to use a properly calibrated

' laboratory ditect'orsfor measuring airborne concentrations

of iodine.

(50-266/85011; 50-301/85011(DRSS))

b.

Severity Level V - Failure to adhere to radiation

control procedures concerning provisions for direct

health physics coverage specified on Radiation Work

Permit.

(50:301/8401C(DRP)-

The first violation appears to be the result of a weakness

in counting room quality assurance and represents a minor

programmatical breakdown; the second violation appears to be

an isolated case of failure to follow radiation work permit

instructions ~and is not indicative of a programmatic breakdown.

The two violations represent an improvement ever the previous

two SALP assessment periods. The licensee's corrective actions

were cpdropriate and' timely for' both violations.

Staf'fing, both technician and profesfional for the radiation

protection program continued as a weakress during this

assessment period. The major staffing weaknes's results from a

poor staff stability within the radiation protection program

and the resultant loss of expertise and experience due to the

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personnel' turnover. The lack of expertise and experience results'

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in inordinate technical work and task specific supervision which

must be performed by the radiation protection foremen; this

detracts from their normal supervisory functions. The licensee

initiated actions near the end of this assessment period to

improve the radiation protection program staffing, including

authorization for two new professional positions and a commitment

to create a more professionally oriented technician staff by

upgrading the radiation protection technician position and

selection criteria. These changes are expected to encourage

improved radiation protection staff retention.

Staffing in the

chemistry and radwaste programs has been more stable than in the

radiation protection program. No changes in key supervisory

personnel and only minor turnover (two of ten) of the chemistry

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technicians permanently assigned to the chemistry laboratory

have occurred during the assessment period.

The licensee has been generally responsive to NRC concerns.

Steps to resolve the long standing problem ::encerning radiation

protection staff stability appear to have been initiated near

the end of this assessment period in response to repeated

concerns expressed by NRC, Region III personnel. Additional

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areas indicative of licensee responsiveness during this

assessment period include the counting room quality assurance

program, the QA audit program for radwaste activ1 ties, the area

contamination control program, the radiological incident report

system, the criteria for evaluating anomalous transuranic and

strontium 89 and 90 values from contractor performed analyses

cf composite liquid discharge samples, and the increased

comparison of gaseous effluent grab samples with monitor

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response.

Management involvement has been generally adequate during this

assessment period with improvement evident in management

support of the radiation protection program. However, strong

actions were not taken until the latter part of the assessment

period to correct a self-identified radiation protection

problem concerning repeat (d incidents of high radiation area

rope barrier violations. Although licensee management was

responsive to a large number of inspector identified concerns

in this area, improvement is needed in self-identification and

correction of program weaknesses.

The licensee's approach to resolution of radiological technical

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issues has generally been conservative and sound. One exception

was the handling of a radioactive filter which produced high

radiation areas which were not adequately controlled.

Investiga-

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tion of the filter incident identified several problems, the

most significant of which concerned worker attitude and

qualifications. Similar problems (worker morale, experience

level and staff stability) were evident in other areas of the

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radiation protection program as noted above, and the licensee

has initiated corrective actions. Management demonstrated a

conservative approach in relocating a Radiation Monitoring

System (RMS) communicator and in replacing one general alarm

with seven individual alarms to improve operator awareness of

RMS status.

Support for the ALARA program is adequate and improving. This

is demonstrated by management support for the contamination

control program that was implemented during this assessment

period to prevent area contamination and to reduce existing

areas controlled for contamination purposes.

It is also

demonstrated by ALARA initiatives taken during a refueling

outage and by implementation of a dose accountability system.

Total worker dose was 740 person-rem in 1984 and 440 person-rem

in 1985; the 1984 doses included the final two months of the

steam generator replacement outage. These cumulative doses

were both below the average for U.S. pressurized water reactors

and are consistent with the licensee's historical personal doses.

The licensee routinely has maintained occupational doses below

the U.S. pressurized water reactor averages.

Noble gas release rates during this assessment period have

averaged about 55 curies annually per unit which is below the

average for U.S. pressurized water reactors. Reported liquid

radioactive releases were above average for U.S. pressurized

water reactors for this assessment period primarily due to a

planned release from the Reactor Water Storage Tank (RWST)

during Unit 2 refueling in November 1984. About one curie

total (excluding tritium) was released per unit in calendar

year 1985 which is about average for U.S. pressurized water

reactors. The RWST contents were released because of high

silica concentration apparently caused by boron recycle

activities.

Iodine and particulate releases in gaseous

effluents may also be quantified and reported conservatively

in that activity on weekly filters /adsorbers is decay corrected

to start of sample period rather than the constancy mid point

of the sample period. No unplanned liquid or gascous releases

were reported. No problems were identified with the licensee's

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transportation of radioactive material.

The licensee's ability to accurately measure radioactivity in

effluents declined somewhat during this assessment period.

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Seven disagreements were observed in 36 comparisons made with

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three licensee detectors. Most of the disagreements, which

involved a newly calibrated detector, were attributable to

counting room QA weaknesses and resulted in a violation.

Licensee corrective action following inspector identification

of the problem was prompt and satisfactory.

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The licensee's performance in this area generally has improved

during this assessment period. The most significant area

requiring further improvement concerns the radiation protection

program staffing weaknesses.

Other weaknesses identified

during this assessment period appear to have been adequately

addressed, although a rather large number of the weaknesses

were inspector identified instead of being identified by the

licensee. The self identification and correction of program

weaknesses is another area reeding improvement.

2.

Conclusion

The licensee is rated Category 2 in this functional area with

an improving trend.

3.

Board Recommendations

None

C.

Maintenance

1.

Analysis

Evaluation of this area is based on the results of routine

inspections by the resident inspectors and two inspections by

Region III specialists. The inspections included such

activities as: the observation of maintenance, preventative,

general, and corrective; compliance with procedures and plant

technical specifications; adherence to radiological and fire

protection controls; replacement of control rod drive guide

tube split pins; and followup on Bulletin 80-11.

No violations

were identified during these inspections.

During this assessment period there were two LERs involving

personnel error assigned to this area. The first resulted

from an auto start of the 4D emergency diesel generator due

to maintenance personnel removing insulation during performance

of a Special Maintenance Procedure, "2A05 Undervoltage Relay

Replacement." The removal of the insulation was called for in

the procedure; however, during the removal a set of contacts

was inadvertently closed, tripping the normal feeder to bus 2A05.

The diesel started and closed in on the bus as required. The

second LER resulted from an inadvertent nuclear instrumentation

turbine runback caused by contractor persor.nel inserting fire

barrier packing into a conduit. During performance of this

activity, the insulation, on the wires supplying power to the

inverter feeding the yellow instrument bus and subsequently

nuclear instrumentation power range channel 44, was abraded on

the edge of the conduit. This caused a momentary power loss to

power range 44 which was sensed as an indication of a dropped

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rod. The turbine ran back from 100*. power to 80*(, power as

expected. As a result of this incident the licensee stopped

all work of this nature until an evaluation could be made to

determine if the fire barrier packing is necessary for

Appendix R compliance and if so, whether or not a better method

of installation could be' employed.

Although this particular instance of contractor error was the

only one resulting in an LER, there were other instances during

the evaluation period when contracters inadvertently interrupted

power to safety or control equipment. The inspectors have

expressed their concerns to licensee management over increased

instances of this type.

Safety-related maintenance performed during the period included;

replacement of the motor on component cooling water pump IP11A,

installation of new station batteries and associated inverters

and chargers, work on the auxiliary safety instrumentation panel,

replacement of Unit 2 "B" reactor coolant pump motor with spare,

steam generator tube plugging, replacemeat of source range

detectors 2N31 and 2N32, installation of primary side loose parts

monitoring system, replaced "A" residua ~i heat removal pump,

replacement of the spherical bearings on the 800 kip Anker-Holth

snubbers, replacement of the primary loop bypass manifold

resistance temperature detectors, installation of the new

auxiliary building crane, replacement of split pins with crack

indications in both units, installation of flexureless inserts

in both units, a modification to the incore detector system

that changed the cover gas from carbon dioxide to helium in an

effort to minimize detector tube corrosion, and three annual

overhauls of emergency diesel generators.

Throughout the SALP period the licensee has continued to develop

written procedures in the maintenance area. One of the findings

of an NRC QA inspection done in 1983 was that there were too few

Maintenance Procedures.

Since then, the licensee has developed

ten Maintenance Instructions and eleven Routine Maintenance

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Procedures. Uver 100 Special Maintenance Procedures were also

developed on an as required basis.

The procedures for writing maintenance work requests (MWR) and

modification request.s (MR) have Q revised substantially to

address many areas considered deficient by the NRC QA inspectors.

This was a large effort requiring several draft revisions prior

to implementation.

The new MWR procedure was implemented in

January,1985, and the new MR procedure was implemented in July,

1985. After some initial concerns that the new procedures were

too cumbersome and required too many reviews and signatures,

both have been accepted and their use is now quite routine.

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One measure of the maintenance department's proficiency is

reflected in the low number of forced outages as described in

the Plant Operations section. This proficiency is the result

of a very stable and experienced staff. As the licensee

prepares for INPO accreditation of their training programs,

additional maintenance training is being initiated. The

licensee expects this part or' the training program to be

complete by the end of 1986.

Management involvement is apparent despite the experience level

of the department.

Frequent tours of work areas by first line

supervisors and higher management personnel were evident

throughout the SALP period. Manageiuent involvement was also

evident in outage planning. Major outage activities such as

split pin replacement, flexureless insert installation, and

significrat secondary side modifications were accomplished on

or ahead of schedule.

2.

Conclusion

The licensee is rated Category 1 in this area. This is an

improvement over the last period and is based on the absence of

violations and the small number of LERs.

Licensee performance

was determined to be improving near the close of the SALP

assessment period.

3.

Board Reccmmendations

None

D.

Surveillance

1.

Analysis

Evaluation of this functional area is based on results of routine

inspections conducted by the Resident Inspectors and five inspec-

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tions t,y regiont.1 personnel.

The resident inspections included

such activities as the observation of tetting; verification that

testing was performed in accordance with adequate procedures;

that limiting conditions for operation were met; that test results

conformed with technical specifications and precedure requirements

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and were reviewed by personnel other than the individual directing

the test; and that any deficiencies identified during the testing

were properly reviewed and resolved by appropriate management

personnel. Three of the region-based inspections were in the areas

of inservice inspection of piping system components and IE bulletin

followup. One region-based inspection was in the area of startup

core performance surveillance testing and the fifth region-based

inspection was in the area of inservice testing of pumps and

valves. One violation was identified in this functional area:

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Severity Level V - Failure to use a calibrated stopwatch for

valve stroke timing during surveillance testing.

(Inspection

Reports No. 50-266/85-001(DRS); No. 50-301/85-001(DRS)).

This violation is of minor safety significance.

The inservice testing inspection indicated that the licensee

had fully implemented the inservice testing program and was

conducting pump and valve inservice tests in accordance with

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appropriate schedules and approved test procedures. Both pump

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and valve testing were generally well defined with the

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appropriate evaluation of collected data being performed by

the licensee's staff.

Licensee personnel contacted were

notably cognizant of Code inservice test requirements and

have implemented an effective program. Operations personnel

directing and conducting the surveillance tests were well

trained, understood plant and equipment requirements, and

conducted their activities in a professional manner.

A few areas were identified where program technical improvements

should be considered, including service water pump test techniques

and valve stroke time upper limits.

It was also noted that while

the pump vibration program met ASME Code requirements, improve-

ments could be made in " good practice" in this area.

One LER attributed to personnel error was submitted during the

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assessment period. During surveillance testing of the negative

rate runback setpoint on power range channel 42, an instrument

and control technician momentarily operated the wrong switch on

the front of the power range drawer while he had an artificially

induced signal applied to the circuitry.

He immediately realized

his error and returned the switch to the correct position. His

actions caused a 2.5% turbine runback from 100% power.

Licensee performance in this area remains at the high level

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evident in previous SALPs. The strong point of the program is

the communication between the personnel performing testing and

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the control room. The extremely small number of incidents

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(one) causing plant perturbations during surveillance testing

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indicates that procedures are well written and followed by

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testing personnel. Management involvement remains evident.

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The licensee contiaues to maintain the performance level and

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attributes described in the previous SALP.

2.

Conclusions

The licensee continues to be rated Category 1.

3.

Board Recommendations

None.

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E.

Fire Protection and Housekeeping

1.

Analysis

Evaluation of this functional area is based on routine assessments

by the resident inspectors which include observations of:

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control of combustible materials, control of fire barriers,

implementation of ignition control permits, Appendix R modifica-

tions, and housekeeping requirements. No violations were

identified in this area.

The licensee continues to show improvement in this area. The

absence of violations during this SALP period is indicative of

a more aggressive management attitude toward fire protection

and housekeeping. During the SALP period the plant manager

eliminated all smoking in the auxiliary building due to abuses

of the previously designated smoking areas. The fire

protection engineer works closely with contractor personnel to

ensure that they are aware of applicable procedures related

to transient combustibles, fire permits, and storage of

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combustibles. During the Unit 2 outage in 1985, major modifica-

tions to the secondary plant involved a significant amount of

cutting, grinding and welding. All of this work was accomplished

without incident.

Appendix R modifications continued throughout the SALP period

with added emphasis the last few months in order to meet an

April 3, 1986 completion commitment.

It appears that not all

items were completed in accordance with this schedule. This

issue was referred to headquarters for resolution. The

licensee could have prevented exceeding the commitment date by

either doing a better job of establishing realistic commitment

dates or by closer tracking of the job progress such that a

schedular exemption could be requested in a timely manner. The

subject items were completed by May 19, 1986.

Housekeeping remains above average despite major work activities

during the period. Again, close management oversight in this

area is evident.

2.

Conclusion

The licensee is rated Category 1 in this area.

3.

Board Recommendations

None.

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F.

Emergency Preparedness

1.

Analysis

Two inspections were conducted during the assessment period to

evaluate the licensee's performance with regard to emergency

preparedness. These included observation of the licensee's

annual emergency preparedness exercise and an annual routine

inspection of the licensee's emergency preparedness program.

One violation was identified as follows:

Severity Level IV - Failure of Shift Superintendents to determine

when and what type of protective measures should be taken to

protect the health and safety of the public.

(Inspection Reports

No. 50-266/85005; No. 50-301/85005)

The above violation was a repeat violation from a July 1984

inspection (Inspection Reports No. 50-266/84013;

No. 50-301/84011). The violation was the result of a lack

of licensee responsiveness to NRC concerns. The inability

of the Shift Superintendents to make adequate protective action

recommendations was primarily the result of inadequate

procedures that the licensee addressed through increased

training. Weaknesses in the licensee's procedures and the

inability of the Shift Superintendents to make protective

action recommendations have been identified in NRC Inspection

reports since 1983. This violation was discussed in the SALP 4

report, to which the licensee responded by stating that the

violation was " inappropriate". Once the repeat violation was

identified, the licensee responded very quickly to revise

procedures and retrain personnel to ensure the problem would

finally be resolved to the NRC's satisfaction and prevent a

recurrence of this type of problem in the future.

The previous SALP report stated that the problems associated

with the violation regarding the Shift Superintendents inability

to make adequate protective action recommendations was apparently

the result of inadequate staffing.

Based on the licensee's

performance in resolving the repeat violation, it appears

the staffing level to resolve emergency preparedness concerns

is acceptable, once management gives it sufficient attention.

When management supports the issue, reviews and responses to

.

'

NRC concerns are generally timely, thorough and technically

sound.

During the last SALP period, a new emergency preparedness

coordinator was appointed and has been assisted by the previous

,

individual holding the position to ensure continuity and avoid

degradation of the program.

Examination of shift staffing and

'

augmentation during the routine inspection determined that

adequate staffing is available to fulfill the obligations of

the emergency organization in an incident.

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The emergency preparedness training program in general has been

good.

Procedures are.in place to ensure all members of the

emergency organization have the opportunity to periodically

).

participate in the emergency drills. The main weakness

identified in the training program was in keeping personnel

up-to-date on changes in the emergency plan and procedures.

An example of the adequacy of the program was demonstrated

'

by an acceptable performance during the 1985 annual exercise.

During the assessment period two instances of apparent

incomplete reporting occurred. Although no violations with

10 CFR 50.72 were identified, the lack of complete information

caused concern that the NRC might not fully understand the

significance of a reported event. The first event occurred

on July 25, 1985, and was reported to the Headquarters duty

,

officer as an unusual event due to the loss of the low voltage

station transformer. The initial not:fication of the unusual

event was made by a security guard per the licensee's emergency

plan. The security guard could not provide the additional

information requested by the NRC duty officer. The duty

officer subsequently called the control room and was informed

that there had been a lock-out of the low voltage station

transformer for Unit I and the unit was being shutdown per

'

Technical Specifications.

It was not known by headquarters nor

the region until after securing from the unusual event that

,

this transformer supplied offsite power to the unit. After

!

this event, the licensee revised their reporting procedures to

require that the ENS notification be made by someone in the

control room.

'

i

The second event occurred on December 31, 1985, and was reported

to the headquarters duty officer as an unusual event due to a

j

loss of load to the Unit 2 generator. The loss of load was

j

caused by a failed lightning arrestor in the switchyard.

The

l

report was made by the duty and call superintendent who was

able to answer all of the questions asked by the duty officer.

The full significance of this event was not initially understood

by the duty officer or the region.

Loss of load.to the generator

without an auto bus transfer causes a loss of reactor coolant

pumps, circulating water pumps, steam generator feed pumps, and

condensate pumps. An attempt to close the main steam isolation

valves from the control room was unsuccessful and one of the

source range instruments failed. This information was not

volunteered by the licensee. After this event the licensee

again modified their reporting format to include any equipment

malfunctions which would help the NRC to appreciate tne actual

plant conditions whether the equipment was safety-related or

not.

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The NRC's concerns in this area were made known to the licensee

management by the resident inspectors, a regional inspector and

during a routine visit to the site by the division director.

The licensee acknowledged the necessity to ensure that NRC

notifications are accurate and comprehensive.

2.

Conclusion

The licensee is rated Category 2 in this area. The licensee

received a rating of Category 2 in the last SALP period.

3.

Board Recommendations

None.

G.

Security:

1.

Analysis:

One routine and one special inspection were conducted by region-

based inspectors during the assessment period. A second special

inspection was conducted four days after the conclusion of the

assessment period to evaluate an event that occurred just prior

to the end of the period. A region-based inspector also

participated in an Office of Nuclear Materials Safety and

Safeguards Regulatory Effectiveness Review in December 1985.

The first special inspection involved an unauthorized discharge

of a weapon. The second inspection resulted in escalated

enforcement action being initiated and two violations being

identified.

a.

Severity Level III - A vital area barrier was degraded for

approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (266/86005-01; 301/86005-01).

b.

Severity Level IV - A security event was not reported in a

timely manner (266/86005-02; 301/86005-02).

Work on a modification request resulted in the degraded vital

area barrier. The modification request did not undergo a

security review and the lack of security review was a major

contributing factor to the event. The licensee considered such

a possibility in response to IE Information Notice No. 85-79,

" Inadequate Communications between Maintenance, Operations and

Security Personnel." However, the licensee did not address

modification requests which had been approved three months or

more prior to the issuance of the notice. The degraded barrier

event involved a previously approved modification.

Upon identification of the degraded barrier, the licensee took

prompt and unusually extensive corrective action consisting of

revised security and employee training, improving the modification

request system and fixing security responsibility for modification

requests.

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Management involvement in assuring quality was evident in the

licensee's actions aimed at exceeding minimum security plan

requirements. The licensee improved security lighting, upgraded

_

vehicle gates, installed a physical fitness obstacle course,

and upgraded the weapons firing range. These are all examples

of the licensee's continuous approach towards improvements and

,

their dedication to excellence. Corporate management is

frequently involved in site activities concentrating on the

long range improvement of the security program. The licensee's

enforcement history and the professional and thorough manner in

which the security force training program is administered are

also indicative of a quality program. However, the degraded

barrier event identified a tendency towards inadequate attention

to detail.

Inattention to detail contributed to the degraded

>

barrier event in several respects.

For example, although many

modification requests were reviewed for security impact, several

predating IE Notice 85-79 were not.

Because one of those

modifications requests was not reviewed, a vital area barrier

was degraded by workers performing current maintenance.

Inattention to detail also delayed the identification of the

degraded barrier by multiple members of the security organization

and several plant personnel. An inadequate classification of

the specific significance of the event resulted in the untimely

reporting of the event.

This lack of attention to detail is the

most significant detractor to an otherwise overall quality

program.

Technical issues were usually resolved in a sound and timely

manner. The upgrade of the vehicle gates resulted from the

licensee's review of IE Information Notice No. 84-07 " Design

Basis Threat and Review of Vehicular Access Control." Technical

issues resulting from the unauthorized discharge of weapons

event and the degraded barrier event were resolved promptly and

thoroughly.

The licensee's review of IE Information Notice No. 85-79, although technically sound was not comprehensive in

that it did not include all modification requests. As mentioned

previously, work on a modification request, which did not

receive a security review, resulted in a degraded vital area

.'

barrier.

The licensee was responsive to all NRC initiatives addressed in

the two security inspections. All issues were resolved in a

timely and thorough manner.

Licensee action on IE Information Notice No. 84-07 was resolved in a timely manner and was

technically sound. However, licensee action or IE Information Notice No. 85-79 was timely, but not thorough.

There were two events reported during the rating period involving

a security computer failure and a degraded vital area barrier.

The latter was a major loss of security effectiveness. The

major loss of security effectiveness event was improperly

18

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identified as a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report rather than a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report,

which precipitated an untimely official notification to the NRC.

The security organization is properly resourced and responsi-

bilities are well defined. Security force members are motivated,

technically competent and well equipped. The smooth functioning

of the security program is testimony to the appropriate staffing

of the security organization.

The security force training program represents an innovative

approach to satisfying security plan commitments.

The licensee

has contracted with a local community college to develop and

administer a security force training program.

The college

y_ faculty and staff reviewed all security plan commitments and

developed a 120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> course which ensures that security

pe.rsonnel are properly trained to effectively execute security

plan commitments.

Successful completion of the course awards

security personnel three college credit hours. The faculty

is very professional and technically competent. The contractual

arrangement to administer and evaluate security training

provides a more objective evaluation of individual security

officer qualification. The quality of the Security Training

Program is reflected in the continued high performance of the

security force. The security training program will enhance the

overall quality of the security program.

2.

Conclusion

The licensee is rated Category 1 in this area based on enforce-

ment history, training initiatives, and the demonstrated high

performance of the security force. The inattentiveness to

detail demonstrated during the latter part of the assessment

period was indicative of a declining trend.

3.

Board Recommendation

A minimum inspection program is recommended.

H.

Outages

1.

Analysis

Evaluation of this functional area is based on the results of

inspections conducted by the resident inspectors. The inspection

activities included observation of fuel movements; verification

that surveillance for refueling activities had been performed;

that refueling containment integrity requirements were met; and

observation of outage controls and activities. One violation was

identified:

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Severity Level IV - Fail'ure to comply w'ith Technical

Specification 15.5.4.4 in that three spent fuel assemblies,

subcritical less than a year, were stored adjacent to

'

the spent fuel pool east wall.

(Inspection Reports

'

No. 50-266/85-015; No. 50-301/85-015(DRP))

The licensee identified this violation during a quality assurance

'

!

audit of the spent fuel pool records.

It appears that the

,

assemblies were inadvertently placed adjacent to the wall four

months after they were removed from the core during a spent fuel

4

j

pool shuffle in preparation for an upcoming outage.

The licensee

'

verified that the fuel pool wall did not incur ar.y structural

j

damage due to the thermal load induced by the assemblies. The

LER submitted on this event was classified as a personnel error.

j

No other personnel error LERs were assigned to this area.

Licensee management is kept abreast of outage activities through

1

.

a three times a week major items work list meeting.

The outage

!

schedule is fed into a computer program with target dates'for

i

completion of the major outage tasks. 'At the meetings the

cognizant individuals for the different tasks report on the

,

progress toward completion and revised target dates are

.

i

established if necessary. The new schedule is then printed out

by the computer, reproduced, and distributed to all plant

management. This method of controlling outage activities has

>

proved to be very effective.

l

At the completion of the outage, as systems are turned back over

to the operations group, a series of operational readiness

-

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tests are conducted. During these tests, all safety systems

are tested and verified as operational prior to plant startup.

,

'

During monitoring of this testing the inspectors have found few

if any instances of systems which were not properly returned to

service or which did not function as required. This indicates

>

1

that maintenance performed during the outage was properly

~

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accomplished and that valve lineups after maintenance were

.

!

correct and properly verified. This again is indicative of the

j

high level of professionalism exhibited by the maintenance and

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operations groups.

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During this SALP Period several modifications and inspections

l

were accomplished during refueling outages. These included:

!

i

inspection and replacement-of guide tube split pins, removal of-

!

]

flexure pins and installation of flexureless inserts on the

guide tubes, reactor vessel nozzle' inspections and inspection

!

of baffle plate joints. The licensee has made plans to do a

,

baffle plate flow modification on both units during the fall

l

1

1986 and spring 1987 refueling outages. Prior planning and

!

management involvement were evident in coordinating these extra

activities.

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Actual fuel movement is accomplished by experienced and well

trained licensee personnel.

Procedures are strictly adhered

to and no significant problems were encountered during the

three outages in this SALP period.

2.

Conclusion

The licensee is rated Category 1 in this area.

Licensee

performance was determined to be improving near the close

of the SALP assessment period.

3.

Board Recommendations

None.

I.

Quality Programs and Administrative Controls Affecting Quality

1.

Analysis

Quality Assurance (QA) pregrams and general administrative

controls were routinely assessed during the period by the

resident inspectors.

Two region-based inspections were

conducted covering followup of concerns identified during a

comprehensive QA inspection conducted during the previous

SALP and an inspection involving equipment qualification (EQ).

The NRC Office of Inspection and Enforcement conducted a special

team inspection to review the implementation of the licensee's

EQ program in accordance with the requirements of 10 CFR 50.49.

Two violations were identified as follows:

Severity Level IV - Failure to review the use of, or provide

a justification for, continued operation with auxiliary

feedwater flow transmitters which had been determined to be

unqualified.

(Inspection Reports No. 50-266/85-013(DRS);

No. 50-301/85-013(DRS)).

Severity Level IV - Failure to perform a complete test sequence

on specimens of Rockbestos coaxial cables or provide an

analysis of the discrepancy in support of the qualification

of this cable.

(Inspection Reports No. 50-266/85-013(DRS);

No. 50-301/85-013(DRS)).

The EQ special team inspection reviewed the program as required

by 10 CFR 50.49. The inspection also included examination of

selected procedures and records, interviews with personnel, and

observations by the inspectors. The inspection determined that

the licensee has implemer,ted a program to meet the requirements

of 10 CFR 50.49.

During the SALP period, the licensee continued to resolve issues

generated during the comprehensive QA inspection at a generally

acceptable rate.

The items closed represented both program and

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implementation problems, primarily in the areas of work control,

document control, and audits. One open issue involving

10 CFR 50.59 safety evaluations was being addressed by adequate

interim measures pending final program revision.

Resolution of

these items has considerably strengthened the licensee's

performance in the QA area.

One issue from the QA inspection remains open. This issue

involves the failure to train personnel involved in inspection

activities in the inspection process and inspector responsibili-

ties and the failure to document inspector qualifications.

While the issue is being addressed, progress has been very slow.

A special region-based EQ inspection was conducted and limited

to reviewing the qualification of Limitorque motor-operated

valve operator internal wires identified as potentially

deficient by IE Information Notice No. 86-03. Two items of+

concern were identified:

the adequacy of qualification for

two types of insulation used and the lack of emergency

procedures for manually stroking valves in the event of motor-

operator failure during an accident.

Both concerns are being

reviewed by NRR.

The licensee's response to the qualification issue was acceptable

with all unqualified wires to be replaced during the next unit

outage. The emergency procedure issue has not been resolved nor

corrective action initiated.

During the SALP period the resident inspectors attended meetings

of the offsite review committee and reviewed minutes of the

manager's supervisory staff meetings. Meeting agendas are

appropriate with highest priorities given to safety-related

issues.

NRC bulletins and information notices as well as INPO

significant operating events are reviewed by the entire staff

and routed to appropriate individuals for action. The licensee

developed its own lessons learned check list after the Davis-Besse

event of June 9, 1985, and assigned various staff members with

the task of assuring similar events would not occur at Point

Beach.

The licensee's quality programs are geared toward the

safe operation of the plants.

There is evidence of management involvement in the resolution

of identified concerns; however, resolution of problems is

occasionally slow.

Corrective actions, when accomplished,

are generally appropriate.

2.

Conclusion

The licensee is rated a Category 2 in this functional area.

3.

Board Recommendations

None.

22

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J.

Licensing Activities

1.

Analysis

This evaluation represents the integrated inputs of the Project

Manager (PM) and those technical reviewers who expended

significant amounts of effort on PBNP licensing actions during

the current rating period.

The basis for this appraisal was the licensee's performance in

support of licensing actions that were either completed or had a

significant level of activity during the rating period. There

were a total of 96 active actions at the beginning of the rating

period. Seventy actions were added during the rating period for

a total of 166 actions. Ninety-six actions were closed during

the rating period and seventy actions remain active at the end

of this rating period. These actions and a partial list of

completions consisting of amendment requests, exemption requests,

responses to generic letters, TMI items, and licensee initiated

actions are:

52 Multi-Plant Actions (28 completed).

Some of the completed

actions in this category are:

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Detailed Control Room Design Review Program Plan (MPA F-08)

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Diesel Generator Reliability (MPA D-19)

,

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Seismic Qualification of the Auxiliary Feedwater System

(MPA-C-14)

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Appendix I (MPA-A-02)

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UPI ECCS Injection (MPA D-05)

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Many Salem ATWS Items

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Appendix I Tech Spec Implementation Review (MPA A-02)

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Appendix R Fire Protection Review (MPA B-41)

Control of Heavy Loads Phase II (MPA C-15)

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86 Plant-Specific Actions (60 completed).

Some of the

completed actions in this category are:

Westinghouse Optimized Fuel Design

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Repeal of Confirmatory Orders (Unit 1 Steam Generator)

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Heavy Loads Handling Technical Specifications.

,

Various NUREG-0737 Supplement 1 Order Modifications

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Various Environmental Qualification deadline extensions

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Overpower and Overtemperature Delta T Technical

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Specifications

Second Ten Year Interval ISI relief

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E8 TMI (NUREG-0737) ACTIONS (8 completed).

Some of the completed

actions in this category are:

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Detailed Control Room Design Review In-Progress Audit

NUREG-0737 Technical Speci fications (GL 83-36 and 83-37)

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(MPA B-83)

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NUREG-0737 II.K.3.30 Small Break LOCA Outline

The licensee's performance evaluation is based on a consideration

of the six attributes specified in NRC Manual Chapter 0516.

In addition, the licensee was evaluated in the area of

" Housekeeping".

a.

Management Involvement and Control in Assuring Quality

During the present rating period, the licensee's management

generally demonstrated active participation in licensing

activities and an openness to communicate with the staff as

demonstrated by their participation in a Licensing Action

Review meeting with the Director, Division of Licensing in

February 1985 and more recently in a Licensing Action status

meeting with the Project Manager and Project Director in

March 1986. This enabled the staff to conplete reviews of

a large number of licensing actions. Management was also

almost always available to attend necessary technical

review meetings with the staff when required for resolution

of licensing actions with the staff and frequently remains

involved in site activities.

However, some weaknesses have been noted. All license

amendment requests contained a discussion of significant

hazards considerations provided by the licensee in

accordance with 10 CFR 50.91. However, when changes have

been made to the initial application the accompanying

significant hazards consideration has merely asserted that

the initial discussion was still valid, without specifically

discussing each of the changes.

Some significant hazards

considerations discussions have also required further

discussion with the licensee to ensure that the standards

of 10 CFR 50.92 have been met.

Some requests for Technical

l

Specification changes were requested on the basis that they

i

would " increase operational flexibility" without adequate

discussion of the safety considerations.

24

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Several requests for extensions of completion dates, most

notably in environmental qualification of safety related

electrical equipment and NUREG-0737 Supplement 1 Order

dates, required additional extensions, some very shortly

after the initial reviews were completed. This shows a

weakness in controlling and tracking due dates and tho

need for improvement in this area was discussed during

the previous SALP.

The level of additional information required by the staff

to support licensing action reviews following the licensee's

initial submittal was considered average.

b.

Approach to Resolution of Technical Issues from a Safety

Standpoint.

The licensee's resolution of safety issues initiated by

the staff generally exhibited a viable, sound and thorough

approach, although frequently additional infornation was

required to achieve completed resolution. An understanding

of the safety issues was generally apparent and some

,

conservatism in the safety analysis is generally exhibited.

'

Licensing actions initiated by the licensee, most notably,

schedular relief requests, were somewhat deficient as to

discussions supporting " good faith effort" to comply and

compensatory measures proposed in support of the request.

However, the licensee usually has committed adequate staff

resources to resolve these issues is a satisfactory manner.

c.

Responsiveness to NRC Initiatives

The licensee has generally responded to requests for

information and other correspondence within the timeframe

requested. On a few occasions the licensee has required

additional time which in a small number of cases has

delayed the NRC completion of the review effort. The

licensee has frequently required extensions of time to

complete modifications, qualifications or submission of

reports in accordance with dates contained in the

Commission's Regulations and 0-ders.

Not all requests

for schedular relief were submitted on a timely basis

and though most requests proposed a viable approach,

they were somewhat lacking in depth and thoroughness.

Even in instances where the licensee's-initial submittal

and requests for schedular relief were considered " timely",

considerable NRC staff effort and in some cases repeated

submittais were required to resolve the issues in order

to avoid the licensee becoming in noncompliance with the

schedules.

In one instance the licensee indicated that

they would be in noncompliance with the schedule required

i

by 10 CFR 50.48, yet neither requested the required

25

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schedular relief nor provided arguments concerning good

faith effort to comply or compensatory measures while

ir noncompliance. Several minor noncompliances have

occurred because of the licensee's inability to meet

schedules contained in the Commission's Orders and

Regulations or otherwise obtain timely relief.

d.

Staffing

Staffing at Point Beach Nuclear Plant was small but highly

effective as evidenced by the high availability achieved

by both units during the rating period. The plant and

corporate staff generally exhibit a high degree of

professionalism and dedication and morale is high at the

site.

The small size of the corporate and plant staff

reduces the licensee's flexibility to respond to NRC

initiatives and periodic losses of key personnel due to

vacations, illness or attrition results in occasional

difficulties in completing priority assignments within

the assigned schedules.

Summary of Results

Overall, the licensee has exhibited good performance during the SALP

period; however, the licensee has not been able to effectively meet

schedules for completion of modifications and submittals as required

by the Commission's Regulations and Orders. This has resulted in an

above average number of schedular relief requests and 3 cases of

failure to meet these schedules.

This weakness was discussed with

the licensee during the previous SALP. More management attention in

this area is warranted. Staffing at both corporate offices and at

the plant is of high quality, but relatively small.

This reduces

flexibility in responding to NRC initiatives and temporary or

permanent loss of a few key employees can significantly delay review

efforts. The licensee has in most cases been effective in dealing

with significant safety problems. Morale is high at the site.

Communication between the operating staff and management at the site

is well defined and established.

Communication between the corporate staff and the site is above

average.

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2.

Conclusion

An overall performance rating of 2 has been assigned by NRR for

the current SALP rating period of October 1, 1984 to March 31,

1986.

26

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3.

Board Recommendations

The board recommends that additional management attention be

expended by the licensee in tracking completion dates for

modifications and submittals described in staff safety

evaluations and for schedular requirements contained in the

Commission's Orders and Regulations. Should schedular relief be

required, the request should be submitted enough in advance to

allow sufficient time for staff review prior to the required

completion date and should contain all necessary discussions to

support the relief request.

K.

Training and Qualification Effectiveness

1.

Analysis

Resident and regional inspectcrs have evaluated training and

qualification effectiveness during inspection of specific

program areas. No violations were identified in this area.

The training and qualification program in effect results in a

highly qualified, effective, and highly motivated operator.

This allows for relatively small site and corporate staffs,

achieving a high availability with very few personnel errors.

During the period, examinations were administered to four

reactor operator candidates and two instructor certification

candidates. All candidates passed the examinations. This

passing rate is significantly above the national average

passing rate. Operator feedback is strongly encouraged.

A defined, comprehensive, task oriented training program has

'

been developed and initiated during this assessment period for

the radiation protection technicians and trainees. ~ This

training program was a considerable improvement over the

program provided during the previous assessment period and

should upgrade the technical level of the radiation protection

staff.

Events are reviewed for training implications and the

results of the review are used to improve the training program.

Excellent on-the-job training has been a strong point at Point

Beach in all disciplines. With the extremely low turnover of

personnel, trainees benefit from the many years of experience

available to instruct them in accomplishing their tasks.

The

results of the effectiveness of this type of training is

evidenced in the excellent reliability of the plant.

Classroom training includes a task analysis of events occurring

at Point Beach and at other plants throughout the industry.

Each event is analyzed to determine if any lessons could be

27

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learned to promote safer operation of the plant. Once these are

established, a lesson plan is developed and all affected

departments are given the training.

The licensee is making good progress towards INP0 accreditation

of training programs. Accreditation of the Senior Reactor

Operator, Reactor Operator, Radiation Protection Technician,

and non-licensed operator training programs are expected in

the near future. Self evaluation reports for the remaining

training programs are expected to be submitted during 1986.

2.

Conclusions

The licensee is rated Category 1 in this functional area based

on their above average license exam pass rate and well-defined

task oriented program.

3.

Board Recommendations

None.

1

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V.

SUPPORTING DATA AND SUMMARIES

A.

Licensee Activities

1.

On October 1, 1984, at the beginning of the SALP assessment

period, Unit 2 was in a refueling shutdown which started on

September 28, 1984.

2.

On November 20, 1984, Unit 2 generator was phased to the line

ending the tenth refueling shutdown. Major activities during

the outage were:

changing out and balancing the "B"

reactor

coolant pump motor; modifying the reactor trip breakers;

installation of new incore thimbles; and replacement of reactor

coolant system RTD's.

3.

On December 11, 1984, Unit 2 was taken off line to replace a

leaking snubber discovered during a containment inspection.

The unit was returned to power on December 12, 1984.

4.

On April 5,1985, Unit I was taken off line for refueling. The

unit operated during 360 of the possible 361 days since the

previous refueling, with the last 257 days being contin:uous.

5.

On June 19, 1985, Unit I was placed back on line. Major

activities during the outage included:

control rod guide tube

flexureless insert and split pin modifications; secondary heat

exchanger sludge lancing and tube plugging; repairing the "A"

and "B" main feed pump rotating assemblies; inspecting fuel

assemblies for evidence of " baffle jetting"; and investigation

into the sticking of control rods F12 and J4 with rod drop

testing.

6.

On June 20, 1985, Unit I was removed from service for turbine

overspeed tests. The unit was placed back on line ten ho.Jrs

later.

7.

On June 26, 1985, a circuit board failure caused a blown tuse

in an inverter causing power to the white instrument bus to

be lost. Unit 1 experienced an immediate turbine runback to

80% power due to loss of power to nuclear instrumentation

channel 42 and then experienced a reactor trip on low stean.

generator level with a coincidental steam flow / feed flow

mismatch. The unit was placed back on line June 27, 1985.

8.

On August 31, 1985, Unit I was shutdown to replace a failed

nuclear instrument channel. The unit was returned to power

on September 1, 1985.

9.

On October 5, 1985, Unit 2 was taken off line to begin the

eleventh refueling outage.

The unit operated during all of

the 319 days since the previous refueling, with the generator

being taken off line only once for about six hours.

The unit

operated for the last 298 consecutive days without any

significant power reductions.

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10. On November 24, 1985, the Unit 2 generator was placed on line.

The following day, the generator was taken off line temporarily

for overspeed testing. Major activities during the cutage

included:

steam generator eddy current testing which revealed

that ten tubes of "A" steam generator and 44 tubes of the "B"

steam generator required plugging; replacement of main

condenser tubes and various feedwater heaters; and a failed

fuel rod was found in two fuel assemblies. The fuel failure

was caused by fuel rod vibration resulting in fretting wear at

the fuel rod grid supports.

11. On December 27,1985, Unit 2 was taken off line to repair a

small crack in a weld on a component cooling water to the "A"

reactor coolant pump lube oil cooler. The unit was returned

to power on December 29, 1985.

12. On December 31, 1985, Unit 2 tripped because of a phase-to ground

fault in the "A" phase lightning arrester in the switchyard. The

unit was placed back on line on January 1,1986.

B.

Inspection Activities

During SALP 5 assessment period October 1,1984 through March 31,

1986, 29 inspections were conducted. Among these inspections were:

1.

A team inspection was conducted during the period July 22

through 26, 1985. The team reviewed implementation of a

program as required by 10 CFR 50.49 for establishing and

maintaining the qualification of electric equipment within

the scope of 10 CFR 50.49 and potential enforcement. This

team inspection also included evaluations of the implementation

of equipment qualification corrective action commitments made

as a result of the December 22, 1982, Safety Evaluation Report

and the September 28, 1982, Franklin Research Center technical

evaluation report.

2.

Emergency Preparedness Exercises, conducted September 9 through

11, 1985, (85-012;85-012).

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INSPECTION ACTIVITY AND ENFORCEMENT

POINT BEACH, UNITS 1 and 2, DOCKET NOS. 50-266, 50-301

Inspection Reports No. 84018 through 84022

No. 85001 through 85023

No. 86002 and 86004

FUNCTIONAL

NO. OF VIOLATIONS Ill EACH SEVERITY LEVEL

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I

II

III

IV

1

DEV.

Plant Operations

1

Radiological Controls

1

1

Maintenance

Surveillance

1

Fire Protection

Emergency Preparedness

1

,

Security

Outages

1

Quality Programs and

Administrative

Controls

2

1

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Licensing Activities

u

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Training and Qualification

Effectiveness

.

Totals

6

2

1

1

.

Violations reflect total violations for the site rather than violations

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associated with each unit.

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C.

Investigations and Allegations Review

No allegations were received during the SALP 5 assessment period.

No investigations were conducted during the SALP 5 assessment period.

D.

Escalated Enforcement Actions

No Escalaced Enforcement cases were conducted during the SALP 5

assessment period.

E.

Management Conferences Held During Appraisal Period

December 18, 1984, Management meeting with Wisconsin Electric Power

management representatives in Milwaukee, WI to discuss the Systematic

Assessment of Licensee Performance (SALP 4) for Point Beach Nuclear

Power Plant.

F.

Confirmatory Action Letters

No Confirmatory Action Letters were issued during the Point Beach SALP

5 assessment period.

G.

Review of Licensee Event Reports and 10 CFR 21 Reports

Three different reviews of LERs were conducted by different

organizations. (i.e., Region III, AE00, NRR).

1.

Region III

On January 1,1984, NUREG-1022 " Licensee Event Report System"

was amended incorporating a new rule in proximate cause codes

and definitions of the proximate causes.

This new rule tends

to project a different picture of events which resulted from

personnel errors. Therefore, a separate review of all the

LERs submitted by Point Beach, during this assessment was

conducted by Region III, to provide meaningful comparative

information of these events. Those LERs are discussed in the

,

appropriate functional area analysis section of this report.

The LERs for this assessment period include Unit 1;85-001

through 85-010 and 86-001, Unit 2 84-005 through 84-008 and

85-001 through 85-005.

PROXIMATE CAUSE*

SALP 5

Personnel Error

7 (0.39)**

Design, Manufacturing,

1 (0.06)

Construction / Installation

External

1 (0.06)

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Defective Procedures

2 (0.11)

Component /0ther

9 (0.50)

Total

20 (1.11)

• Proximate Cause is the cause assigned by the licensee in

accordance with NUREG-1022, " Licensee Events Report System".

• • Numbers in parentheses are_ average number of events per month.

It snould be noted that Point Beach submitted 20 LERs during

this assessment period. This is a relatively low number when

compared to other operating multi-unit sites. This low number

of LERs is another exemple of the high quality plant performance

at Point Beach as seen throughout this assessment period.

Among the 20 LERs, there were 3 Inadvertent Starts of Emergency

Diesel Generator Events,1 Inadvertent Safety Injection,

2 Reactor Trips and 6 Nuclear Instrumentation Turbine Runbacks.

2.

Analysis and Evaluation of Operational Data AEOD

An evaluation of LERs was made by the Office of Analysis and

Evaluation of Operational Data (AEOD).

I.n general the licensee

submittals were found to be of average qualitp based on the

requirements of 10 CFR 50.73.

The complete document, which

provides the details of each LER evaluated has been sent to the

licensee under a separate cover letter dated May 21, 1986.

This evaluation process was divided into two parts. The first

part of the evaluation consisted of documenting comments

specific to the content and presentation of each LER.

Second

part consists of determining a score (0-10 points) for the

text, abstracts, and coded fields of each LER.

The weaknesses identified were mainly that of document processing

(i.e., filling out the LER form); in that, some components were

inadequately identified; the licensee failed to reference previous

similar events in the text; and the licensee failed to provide an

adequate safety assessment for every event.

These inconsistencies prompt concerns that possible generic

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problems may go unnoticed by the industry for a longer time

period if component failures are not identified properly; that,

the plant may not be documenting all its events in a manner

which will enable it to identify possible trends or recurring

problems; and as to whether or not each event is being evaluated

for the possible consequences of the event, had it occurred

under a different set of initial conditions.

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It was suggested that the station should consider the use of an

outline format for their LERs such as the one recommended in

Appendix C of NUREG-1022, Supplement No. 2. to prevent future

incpnsistencies in preparing and evaluating LERs.

It was concluded by AE00 that the licensee ranked 36 and 37th

out of a possible 53 units (i.e. licensees), giving Point

Beach 1 and 2 an overall average LER score of 7.4 out of a

possible 10 points. A strong point for the Point Beach LERs

is that information concerning the failure mode, mechanism,

and effect of each failed component, required by

50.73(b)(2)(ii)(e), was well written for the LERs that were

evaluated.

3.

Office of Nuclear Reactor Regulation (NRR)

A third input to the Licensee Event Reporting area was provided

by NRR and consisted of all types of reporting including LERs.

Reportable events at Point Beach Nuclear Plant appeared to have

been reported promptly and accurately.

Some minor inadequacies

in prompt notification were noted during the reporting period.

However, the licensee had taken prompt action to correct these

inadequacies. Thus, the licensee received high grades from

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that perspective, as reflected in the Plant Operations functional

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area.

4.

10 CFR 21 Reports

The licensee submitted a report on July 24, 1985, which described

a single failure potential in the safety injection recirculation

path. The licensee determined that the failure of a single

component in the control circuitry for the safety injection

recirculation path isolation valves could result in the failure

of both safety injection pumps. The licensee included a detailed

description of this deficiency and proposed corrective actions.

H.

Licensing Actions

,

1.

NRR/ License Meetings

Control Rod Guide Tube Flexureless Inserts

11/1/84

Upper Plenum Injection - Evaluation Model

1/10/85

Upper Plenum Injection - JAERI Meeting

3/13/85

Upper Plenum Injection - Status Meeting

6/28/85

Upper Plenum Injection - Evaluation Model

11/20/85

Licensing Action Status / Organizational Orientation

3/25/85

Meeting

2.

NRR Site Visits / Meetings

Fire Protection

12/13/84

SALP 4 Meeting

12/18/84

Operator Requalification Program Meeting

1/16/85

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Envirormental Qualification Audit-

7/22-26/85

Site Visit.. Japanese Visitors

11/03/85

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Site Visit Appendix R Exemptions

r?11/25/S5

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Regulitary Effectiseness Review

12/2-6/85

Detailed Control Room Design Review

12/2-6/85

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3.

Commission Meetings

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Environmental Qualification (EO) Deadline Extension

10/25/85

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4.

Schedular Extensions Granted-

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EQ Deaalire Extens. ion

11/5/84

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NUREG-0737 Supolnment 1 Order Modification

2/5/85

(TSC Power Suply)

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NUREG-0737 Supplement 1 Order Modification

2/5/85

,,

(EOP implementatien)

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EQ Dea'iline Extension

7/17/85

NUREG-9737 Supplement 1 Order %dification

10/16/85

(DCK3R Summary Report)

,

EQ Deadline Extension

11/20/85

NUREG-0737 Supplement 1 Order Modification

1/6/86

(SAS, EOF, R.G.~1.97)

NUREG-0737 Supplement 1 Order Modification

(DCRDR Summary Report)

3/21/86

5.

Reliefs Granted

,

,

IST Interim Relief

~/

3/4/85

Modification of IST Interim Relief

6/11/85

,

ISI 2nd 10 year interval relief

10/31/85

's

IST Interim Relief Extension

2/26/86

6.

Exemptions Granted / Denied

,

,

Appendix R Fire Protection (Granted)

7/3/85

4160V Switchgear Room, Appendix R (Denied)

8/21/85

7.

, License Amendments Issued

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Amendment No.

Title

Date

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86 and 90

Optimized Fuel Design

10/5/84

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91 (Unit 2)

Overpower, Overtemp-

11/16/84

erature Delta T

87 and 92

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Tech Spec Effective

12/27/84

Date Change

88 and 93.

Control Rod Insertion

3/7/85

Limits

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89 and 94

Containment Tendon

3/7/85

Surveillance

90 (Unit 1)

Overpower, Overtemp-

4/4/85

erature Delta T

91 and 95

Heavy Loads Over Spent

4/8/85

Fuel

92 and 96

NUREG-0737 T. S.

7/18/85

93 and 97

Reactor Coolant Gas

7/22/85

Vents

94 and 98

Reactor Coolant Pump

7/22/85

Underfrequency Trip

95 and 99

Steam Generator ISI,

7/26/85

Auxiliary Feedwater

96 and 100

Single Failure Proof

9/3/85

Crane

97 and 101

Radiological Effluent

10/3/85

Tech Specs

98 and 102

Reactor Vessel Capsule

10/22/85

Removal Schedule

99 (Unit 1)

Steam Generator Leakage 11/4/85

Limit

8.

Emergency Technical Specifications

Amendment 91, Overpower, Overtemperature Delta T issued 11/16/84

for Unit 2

9.

Orders Issued

None

10.

NRR/ License Management Conferences

DL Division Director Briefing

2/5/85

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