ML20055F687

SALP Rept 50-285/90-24 for 890501-900430

ML20055F687
Person / Time
Site:	Fort Calhoun
Issue date:	07/12/1990
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:
Shared Package
ML20055F685	List: ML20055F684 ML20055F687
References
50-285-90-24, NUDOCS 9007190025
Download: ML20055F687 (32)

See also: IR 05000285/1990024

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INITIAL SALP REFORT

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

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S0-28S/90-24

Omaha Public Power District

Fort Calhoun Station-

May 1, 1989, through April 30, 1990'

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INTRODUCTION-

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

integrated NRC staff effort'to collect available observations and data'on

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a periodic basis and to evaluate licensee performance based upon this

information. The program is supplemental to normal regulatory processes

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used to ensure compliance with NRC rules and regulations.

It is intended

to be sufficiently diagnostic to provide a rational basis for allocating.

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NRC resources and to provide meaningful feedback to licensee's management

regarding-the NRC's assessment of their facility's. performance in each.

functional area.

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

June 13, 1990, to review the observations and data on performance-and to

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assess licensee. performance in accordance with NRC Manual Chapter 0516,

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" Systematic Assessment of Licensee Performance." The guidance and-

evaluation criteria are summarized in Section III of this report. The

Board's findings and recommendations were forwarded to the NRC Regional

Administrator for approval and. issuance.

This report is the NRC's assessment of the licensee's safety performance

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at the Fort Calhoun Station for the period May 1, 1989, through April 30,

1990.

The SALP Board for the Fort Calhoun Station was composed of:

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S. J. Collins, Director, Division of Reactor Projects (DRP), Region -IV

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Members

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

A.- 8. Beach, Director, Division of Radiation Safety and Safeguards (DRSS),

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Region IV

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D. L. Wigginton, Acting Director, Project Directorate IV-1, Office of

Nuclear Reactor Regulation (NRR)

G. L. Constable, Chief, Project Section C, DRP, Region IV

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A. Bournia, Project Manager Fort Calhoun Station, Project Directorate IV-1,

NRR

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P. H. Harrell, Senior Resident Inspector, Fort Calhoun Station

The following personnel also participated in the SALP Board

meeting:

L. J. Callan, Director, DRS, Region IV

L. A. Yandell, Deputy Director, DRSS, Region IV

B. Murray, Chief, Facilities Radiation Protection Section, DRSS, Region IV

D. A. Powers, Chief, Security and Emergency Preparedness Section (SEPS),

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DRSS, Region IV

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'I. Barnes, Chief, Materials and Quality Programs Section, DRS, Region IV

W.-C. Seidle, Chief, Test Programs Section, DRS, Region IV

T.. Reis, Resident Inspector, Fort Calhoun Station

-R. V. Azua,~ Project Engineer, DRP/C

R. P. Mullikin, Project Engineer, DRP/A

R.-A. Caldwell, Security-Specialist, SEPS, DRSS, Region IV

P. C. Wagner, Inspector,' Plant Systems Section, DRS, Region IV

P. J. Prescott,= Performance and Quality Evaluation Branch, NRP.

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II. SUMMARY OF RESULTS-

Overview

The licensee'.s performance during this assessment period indicated

increased management involvement in and attention to the safe operation of

the facility.

The evaluation of.the safety assessment / quality verification

functional area-indicated that senior management oversight and involvement

was readily evident, and emphasized, tl. rough the continuation of the

safety enhancement-program. Actions taken thus far have generally

increased the level of personne1' performance in all areas related to safe

plant operation.

Effective implementation of the programs should continue

to increase'the performance in each functional area.

Improved performance was specifically noted in the functional areas of

plant operations, maintenance / surveillance. and security. .In the

functional area of radiological controls, strong management oversight was

evident,'as' indicated by the implementation of comprehensive programs that

address the elements necessary to ensure a' high level of performance.

Continued inanagement attention is required in these areas to ensure that the

enhancement programs are fully and effectively completed.

'The:11censee's performance ratings are' summarized ~in the table below,

along'with the ratings from the previous SALP assessment period.

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Rating-Last Period

Rating This Period

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-Functional Area (05/01/88 to 04/30/89) (05/01/89 to 04/30/90): Trend

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Plant Operations'

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Radiological Controls

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Emer_gency. Preparedness

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sSecurityi

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Engineering / Technical

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Support

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Safety Assessment /.

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' Quality Verification

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• (I)' Improving-Trend - licensee performance was determined to be improving

=during the assessment period,

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III. CRITERIA

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Licensee's' performance was assessed in seven selected functional areas.

' Functional areas normally1 represent areas 1significant to nuclean safety

and1the' environment.

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3The following evaluation criteria ~were used,.as applicable, to assess each

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functional area:

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"A.

Assurance of quality,! including management.. involvement and

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B.

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

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standpoint;

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Enforcement history;

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Operational events (including response to, analyses of,

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-reporting of, and corrective actions for);

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Staffing (including management); and

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Effectiveness of the training and qualification' programs.

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However, NRC is not limited to these criteria and others may have been

used where appropriate.

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'On the basis of the NRC assessment, each functional area evaluated is

rated according to three performance categories. The definitions of these

performance categories are:

Category 1 - Licensee's management attention and involvement are readily

evident and place emphasis on superior performance of nuclear safety or

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safeguards-activities, with the resulting performance substantially

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exceeding regulatory requirements.

Licensee's resources are ample and

effectively used so that a high level of plant and personnel performance-

'is being' achieved.

Reduced NRC attention may be appropriate.

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Category.2 - Licensee's management attention to and involvement in-the

performance of' nuclear safety or safeguards activities is good.

The

licensee has attained a level of performance above that needed to meet-

regulatory requirements. Licensee's resources are adequate and reasonably

allocated.so.that good plant and personnel performance is being achieved.

NRC attention ~ may be maintained at normal levels.

. Category 3 - Licensee's management attention to and involvement in the

performance of nuclear safety or safeguards activities are not sufficient.

The licensee's' performance does not significantly exceed that needed to

meet minimal regulatory requirements.

Licensee resources appear to be

strained or not effectively used.

NRC attention should be increased above

normal levels.

IV.

PERFORMANCE ANALYSIS

A.

Plant Operations

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- Analysis

'Hiis > functional area consists of activities such as plant

startup, power operation, plant shutdown, and system lineups.

Thus,'it includes activities such as monitoring and logging

plant conditions, normal operations, response' to transient and

- off-normal conditions, manipulating the reactor and auxiliary

controls, plant-wide housekeeping, and control room

professionalism. Activities that support operations (e.g.,

training and requalification, evaluation of emergency and

abnormal operating procedures, and other similar areas)-are

assessed in'the other functional areas discussed in this report.

During this assessment period, the licensee minimized challenges

to safety systems as only one manual and no automatic reactor trips were experienced. The manual trip was appropriately

initiated by an operator because of an indicated high bearing

temperature on a reactor coolant pump. This noteworthy

performance continued a long trend, in that the licensee has

experienced only one automatic and two manual trips since

July 1984,

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The licensee continued to maintain a very experienced and

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' knowledgeable group of licensed senior reactor operators (SR0s)

end reactor operators (R0s), as has been evident during past

performance assessments. The operations staffing level was

stable during this assessment period with a very small turnover

rate of licensed operators (2 SR0s and 1 RO). On-shift staffing-

- was maintained at a level that permitted the licensee to-

maintain a six-shift rotation, except for-vacation schedules

during the summer months. The excessive use of overtime in,the

operations department has-not been identified as a concern.

The licensee maintained a comparably small licensed staff that

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currently includes 27 individuals (14 on-shift and 13 staff

personnel) that hold an SRO license and 8 on-shift individuals

that hold an R0 license. This staffing level represents a net

decrease of 2 R0s when compared to the staffing 1 year ago. The

small size of the licensed staff has been discussed by NRC

during the two previous assessment periods.

Licensee's

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management has. stated that they intend to increase the number of

licensed personnel, especially in operations, by providing

three candidates for the R0 examination in May 1990 and

five additional candidates in October 1990. The licensee

maintains.a practice of producing very small operator license

classes in spite of a high success rate for recent license

examinations.(100 percent initial examination pass rate for the

last 6 site visits).

Licensed operators have.been transferred

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to other departments within the licensee's nuclear organization,

such as' outage planning, maintenance' planning, training,

simulator services, and quality assurance. The operations

expertise of these individuals has shown to have a positive

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impact on.these organizations with respect to providing support

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to the operations department.

The shift technical advisor (STA) program has provided a-

positive contribution to plant operations.

The STAS function as

an integral part of the operations crew and are very involved in-

the day-to-day operation of the plant by providing technical

assistance to the shift supervisor.

In addition to the STAS,

the systems engineers provided technical recommendations to the

shift supervisor when component or system anomalies occur that

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potentially affect the operability of safety-related equipment.

The interface between the operations staff and the departments

that provide support to operations (e.g., health, physics,

maintenance, chemistry, and training) has been effective during

this assessment period. To minimize the impact on the operating

crews during the refueling outage, the licensee assigned an

outage coordinator to act as an interface between operations and

other departments. This approach was effective in minimizing

the impact on operations during this high activity period.

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Licensed, on-shift _ operators exhibited a dedicated commitment

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toward the performance of their duties and safe-plant operation.-

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Control room professionalism and. decorum was evident during this

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assessment period, _ Plant operators;(licensed and nonlicensed)

maintained an awareness of plant conditions and work activities

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being performed under their control.

On a number of occasions',

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during this. assessment period, operations personnel responded to_-

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plant perturbations and prevented more significant problems'that.

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=may have caused challenges to safety-related systems. Examples

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include a' loss of shutdown cooling due-to the loss of offsite-

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power and a: partial loss of component cooling water flow at full

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Preplanning of activities affecting plant operations was

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apparent as evidenced during the removal of the 161-kV offsite

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power supply,.one of the two offsite. power grids, for preventive

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maintenance. -Actions were taken to ensure that the onsite and

offsite electrical distribution systems were not disturbed by'

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maintenance or:other activities. However, the same conservative'

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approach was not exhibited.toward shutdown cooling operations

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with the reactor coolant- system in a lreduced inventory.

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Licensee's management allowed removal of all power supplies,

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except for-one offsite source _and one emergency diesel

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generator,-for supplying power to the shutdown cooling pumps.

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In.this configuration, the electrical system was potentially-

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vulnerable to a single failure.

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.On two_ occasions, operations personnel actions resulted in the

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failure to comply with the zlimiting conditions for

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operation (LCO) specified by the Technical Specifications (TS);

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neither occurrence resulted in a degradation of safe plant

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operation.

The events-involved the-failure to reduce. plant

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power when two r'eactor protection system channels were declared

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inoperable, and the failure to return the isolation valves'

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properly for a component cooling water heat exchanger to; service

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following maintenance activities.

The first event resulted from-

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inadequate. directions from plant management, and the second

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event resulted from an-oversight by a nonlicensed individual. A

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review indicated that these events were isolated cases.

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A number of issues were identified during activities related to

the licensee's reconstitution of the plant design basis,

self-initiated reviews, and inspections performed by NRC

personnel.

It appeared that management generally took a

conservative approach when addressing problems of equipment and

component operability.

Some isolated cases were-identified,

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early in the assessment period, where management exhibited a

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reluctance toward timely determination of equipment operability.

In the'latter part of the period, operability determinations

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appeared to be conservative.

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On several occasions during -the early part of the assessment

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period..theilicensee experienced difficulty in making

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reportability decisions.

In the latter part of this assessment

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-period, management's performance improved with respect to

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reportability issues.

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Difficulties encountered with operability.and reportability

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issues appeared to be the result of inexperience, in-that, new

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plant and assistant plant managers were appointed early in this

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assessment period.

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The last SALP report (NRC Inspection Report 50-285/89-19)

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identified concerns in the areas of operations. personnel using

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and following procedures,. plant personnel entering the control-

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board area in the control room'for no obvious reason, and

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infrequent tours of the operating spaces by senior plant

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management. The licensee addressed the first two concerns;

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-however, management (except for radiological protection

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-personnel) infrequently. toured the plant operating spaces other

than'the control room.

The licensee took actions to increase

the frequency-of plant tours prior to the end of this assessment

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period.

Shift supervisors,'throughout this assessment period,

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. routinely toured the plant operating spaces to verify.that

equipment was operating satisfactorily.

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The licensee has made significant progress with upgrading plant

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housekeeping, labeling, and appearance.

The licensee's program

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for installing new valve and component labels has improved the

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operator's capability for. equipment identification.

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coding and labeling of system piping and painting of the plant

operating spaces (approximately'75 percent complete) has

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-significantly contributed to enhanced operations and the overall

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plant appearance.

Overall, it appeared that the operations' staff. conservatively

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operated the p.lant to ensure that the health and safety of the

public were' properly protected. The. operations' staff

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demonstr'ated their abilities to handle plant perturbations and

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events. Weaknesses _with plant management's oversight of the

operations area and 'a number of problems and concerns were

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identified to which the licensee proviend timely resolution and

took actions to prevent recurrence.

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2.

Performance Rating

The licensee is considered to be in performance Category 2 in

this functional area.

Licensee's performance was determined to

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be improving during this assessment period,

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3.

Recommendations

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a.

'NRC Actions

Inspection effort in this functional area should be

consistent'with the fundamental inspection program,

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b .'

Licensee Actions

Licensee's management should continue efforts for

increasing operator staffing. Management'should continue

to ensure that activities related-to equipment. operability

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and event reportability are performed in attimely and

conservative manner.

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B.

Radiological Controls

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Analysis

The assessment of this functional area consistsauf activities

related to occupational radiation protection, radioactive waste

management, radiological effluent control and monitoring,.

radiological environmental monitoring, water chemistry controls,

radiochemistry and water chemistry confirmatory measurements,

and' transportation of radioactive materials.

The radiation protection program inspections indicated that the

licensee had implemented a high quality radiation protection

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program.

Some minor weaknesses were identified. One

NRC-identified violation occurred in September 1989 and involved

the failure to survey visitors leaving-the site.

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licensee-identified violation was noted'in December 1989 and-

involved the failure to provide continuous health physics

coverage for a worker in _ a very high ' radiation area, and another

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in March 1990 that involved the failure of a security guard to

follow established radiation protection procedures during entry

into a high radiation area. The licensee took prompt and

effective corrective actions and the violations were not an

indication of programmatic breakdowns.

The licensee mcde significant. improvements in the radiation

protection area during the last part of the previous assessment

period and continued to make additional improvements'during this

assessment period.

These improvements included items such as

staffing, procedures, equipment and instrumentation,

coordination with other departments, training, and

self-identification of problem areas.

The staffing level in the radiation protection department

increased from 22 to 54 personnel during the previous assessment

period, and this level was maintained during this assessment

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period. The' licensee only used contract radiation protection

personnel during outages and relied on the permanent staff

during routine operations. Within the current staffing level,

three new supervisor positions were authorized and filled.

Each

individual selected for the supervisor positions holds a Masters

degree in health physics or nuclear engineering, along with

several years of applied health physics experience.

The

licensee experienced a low turnover rate in_the radiation

protection department, as only two individuals have left the

department _since 1988.

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The licensee implemented a comprehensive training program for

the rubiation protection staff-at both the technical level and

for professionals and supervisors.

An effective program was in

. place'for the evaluation, screening, and-training of contract

radiation-protection technicians that were. brought on site

during outage activities.

The licensee demonstrated initiative

to increase the technical expertise in the radiation protection

department in that_about 50 percent of the licensee's radiation

protection technicians have been certified by the National

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Registry of Radiation Protection Technologists.

A high level of cooperation was achieved between the radiation

protection department and other departments-such as operations

and maintenance.

However, one area, self-identified by the

licensee, was noted where the plant staff (nonradiation

protection department personnel), on two occasions, did not ,

follow established radiation control procedures.

To reduce the

numbers of radiological occurrences, it appeared that department

supervisors needed to increase the emphasis for the plant

personnel compliance with radiation protection procedures.

The licensee completed construction of new facilities for access

. control into the radiation controlled area, office and work

areas for the' health physics and chemistry staff, and clothing

change areas for radiation workers.

These new facilities were

completed just before the 1990 refueling outage and some final

arrangements remained to be completed such as personnel flow

paths and work stations at the access control point.

Improvements were made in the as-low-as-reasonably-

achievable-(ALARA) area since the previous assessment.

Strong.

support for the ALARA program was demonstrated by the formation

of an ALARA executive committee that is chaired by the senior

vice president, and includes representatives from various

corporate divisions, the plant manager, and the supervisor,

radiation protection.

Improvements were also noted in ALARA

activities such as the technical evaluation of ALARA work,

processing of ALARA packages, purchase of video equipment, and

better coordination between the ALARA group and other

departments.

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The person-rem for 1989 was approximately 93; however, this

period did not involve a refueling outage. The annual average

person-rem for 1986 through 1989 was-208, as compared to a

national, average of approximately 300 person-rem. This low

person-rem was an indication of-an effective program for the

control of external exposure.

The licensee established a

conservative, 250 person-rem goal for the 1990 refueling outage.

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'As of April 30, 1990, 214 person-rem had been expended and it

appeared that the outage would be completed under the

established goal. The licensee set a conservative personnel

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skin _-contamination goal of 23 for 1990,. but 36 events had

occurred as of late March 1990.

Management oversight was evident by the performance of

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comprehensive audits and surveillances, and progress in the area

of self-assessment. The 1990 audit of the radiation protection

program included an auditor in the quality assurance (QA)

organization with several years of experience as a senior

radiation protection technician, along with a consultant that

also had.several years of radiation protection experience. The

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audit report included verification that work was performed in

accordance with established procedures and,also included

suggestions concerning program improvement items. The responses

to the audit findings by the radiation protection department

were made in a timely manner and indicated a good understanding

of the technical issues. Except for some ongoing revision of

. procedures, the licensee completed work on approximately.

375 improvement items identified as part of the radiation

protection enhancement program.

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'The radioactive waste management and-radioactive effluent

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control and monitoring programs were inspected and no violations

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were-identified. An effective liquid and gaseous < release permit

program was established. No: problems'were identified concerning

staffing, training, or qualifications of the personnel

responsible for operating the radwaste systems. The licensee

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1mplemented a radwaste management program that demonstrated

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compliance with the Radiological Effluent. Technical

Specifications and the Offsite Dose Calculation Manual.

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The radiological environmental monitoring program was inspected

and no significant problems were identified. Regulatory

requirements were met regarding sample collection, analyses, and

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resulting dose calculations. Well qualified personnel, with at

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'least 10 years of experience, were assigned to implement the

environmental monitoring program.

However, a formal training

program had not been established for personnel assigned to this

group.

The radiochemistry and water chemistry programs were inspected,

no problem areas were identified, and continued improvements

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were noted in this area. The staffing level in the-

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radiochemistry and water chemistry remained at 19 positions, the

same number as during the previous assessnient period.

Four new

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supervisor positions were authorized within the existing staf#

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organization. Management oversight included comprehensive QA

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audits.

New chemistry laboratory and radiochemistry counting facilities

were constructed and scheduled to be in use by the end of 1990.-

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Vendor recommendations and EPRI guidelines for primary and

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' secondary water- chemistry parameters were incorporated into the

station chemistry procedures and were being followed. . Water

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, chemistry and radiochemistry confirmatory comparison measurements

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were performed. The radiochemistry confirmatory results showed

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98 percent agreement, which was consistent with the 97 percent

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agreement obtained during-the previous assessment. Water

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chemistry confirmatory measurements indicated 97 percent

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agreement, which was an improvement over the 88 percent agreement

noted during the previous assessment, The confirmatory

measurement results indicated that the licensee's performance

was above the industry average in this area. The licensee made

improvements-in the quality control (QC) araa, including the use

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of QC charts to trend daily analyses of chemical parameters and

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reactor coolant and secondary water quality'results.

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The transportation of radioactive materials and solid radwaste

programs were inspected and no violations were identified.

The

licensee completed-construction of a new solid radwaste

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processing and transportation facility, which is scheduled to be

. fully operational in 1990.

The 1icensee established

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implementing procedures that addressed waste classification and

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characterization,' procurement and selection of packages,

preparation of packages for shipment, and delivery of the

completed packages to the carrier. The staffing level-assigned

to handle solid radwaste and transportation activities was

satisfactory. 'It was noted that the most recent QA audit of the

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solid radwaste and trarfsportation area, conducted in

November 1988, did not include transportation activities.

Overall, the licensee made progress during the previous

assessment period to improve performance in the radiological

controls area and this effort carried over into this assessment

period.

Improvements made in the radiation protection and

chemistry / radiochemistry areas were-particularly noteworthy.

Strong management oversight of the activities in this functional

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area was evident.

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2.

Performance Rating

The. licensee is' considered to be in Performance Category 1.in

this functional area.

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Recommendations

a.

NRC Actions

. Inspection effort in this functiona.1 area should be

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consistent.with the fundamental-inspection program.

b.

Licensee Actions

Licensee's, management should continue efforts to implement

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a strong self-assessment program, ensure that radwaste-

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' personnel complete specified training, and consider

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transportation activities in the QA audit program.

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Emphasis on compliance with radiological. protection

procedures should be stressed by. management.

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C.

Maintenance / Surveillance

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Analysis

This functional area includes all activities associated with

either diagnostic, predictive, preventive, or corrective

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maintenance of plant structures, systems, and components;

procurement, control,~and storage of components, including

qualification controls; installation of plant modifications; and

. maintenance of the plant. physical condition. - It also includes

conduct of-all surveillance testing activities and inservice

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inspection and testing activities.

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This area was inspected on a routine basis by the resident

inspectors and-periodically by regional inspectors.

A special

inspection was performed in the area of systems entry

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retest (SERT) by personnel from Region IV.

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The licensee has maintained a stable and well-qualified

maintenance work force with little turnover. .The staffing level

in the-instrumentation and control (I&C) area was a concern

+

identified in the previous SALP report. . The licensee's current

full-time I&C staffing level has been increased to 29 employees

(24 licensee and 5 contractor personnel) and appears to be

satisfactory.

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The quality of maintenance procedures was previously identified

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as a concern with respect to the level of detail and the

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technical content. To address this concern, the licensee

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established a procedures upgrade project as part of the Safety

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Enhancement Program. This project is currently scheduled to be,

completed by the end of 1990. Maintenance personnel have

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performed their activities' satisfactorily and in accordance with'

the existing procedures, as the knowledge level and experience

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of the crafts has compensated for marginally acceptable

procedures _.

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The licensee has implemented a good maintenance program as

e

evidenced, in part, by all equipment functioning properly during

engineered safeguards actuations, and no plant shutdowns have

'

resulted from equipment maintenance problems. The operations

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department . identifies equipment needing maintenance attention to -

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the maintenance department each morning at the plan-of-the-day-

meeting. This interface has resulted in prompt attention to the

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repair of safety-related equipment.

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The SERT was conducted in the areas of design changes, temporary

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alterations, and maintenance activities. The 3ERT inspection

determined that planned retesting of structures, systems, and-

components, that have been modified or subjected to maintenance,

properly verified equipment operability and ensured that the

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design basis was met. The licensee has a strong program for

i

determining required retests and for the identification of the

1

appropriate retest method. The licensee's program for

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development of procedures and performance of these procedures

for retest of structures, components, and systems, following

plant modification and maintenance activities, was.found to be

. satisfactory. A weakness'was identified in the assignment of.

review responsibilities to ensure that correct retests were

o

included in postmaintenance and temporary modification work

packages. The licensee strengthened this area by administrative

procedure revisions,

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- Systems. engineering developed and performed, during -this

assessment. period, comprehensive raw water (RW) system testing-

that demonstrated that pump and heat exchanger performance had

,

degraded from the original design basis assumptions. With the

implementation of administrative controls ,the.RW system

remained operational and met.the design basis. . A reactive

inspection.was conducted to review the test results and

operability status of the RW system.. The inspection indicated

'

that the-four RW pumps had become degraded as a result of

deficient preventive maintenance, system testing, and erosion of

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the pump bell housing because of pumping silt laden Missouri

,

river water.

System engineering's performance in developing

integrated testing procedures to demonstrate F 2er system

"

performance was noteworthy.

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An inspection of the installation of plant modifications

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determined that the licensee's modification program contained

very good controls and procedures, and is considered to be a

strength.

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Inspections were performed in the area of inservice

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inspection (ISI) and inservice testing (IST) and included the

surveillance, visual inspection, repair, and testing of

snubbers.

Implementation of the IST program' upgrade: appeared to

be consistent with the licensee's committed schedule.

Surveil. lance testing of pumps and valves was consistent with the

requirements of Section XI to the ASME Code and the criteria

outlined;in NRC Generic Letter 89-04. The ISI and snubber.

,

programs contained sufficiently detailed procedures to govern-

the work, provided easily retrievable records, and had'

sufficient qualified personnel. Management involvement in these

areas-was evident. An exception to this performance was=noted:

during. followup of the turbine-driven auxiliary feedwater- pump

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event, as discussed in'the engineering / technical support

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functional area.

.The systems engineering organization provided field oversight

activities for equipment and component maintenance. The

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presence of the engineers provided for the timely resolution of.

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technical issues that were identified.during maintenance

activities to minimize equipment down time.

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-In the last SALP report, concerns were identified with

administrative controls of maintenance work orders, predictive

,

and preventive maintenance programs not=being fully implemented,

independent review of core physics testing data, and procedural

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compliance by maintenance personnel. The licensee has taken.

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actions-to address these concerns, except for predictive and

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= preventive maintenance programs.- Actions have been implemented

by the Safety Enhancement Program to address the ,redictive and

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preventive maintenance programs.and are currently scheduled to

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be: completed by the end of 1990.

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In the. area of surveillance, tests were being scheduleJ and-

performed as required by the TS.

During an inspection, it'was

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noted that the- systems engineers had unilateral authority to

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' waive procedural requirements, and justification for waiving-

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procedural steps'and' acceptance criteria may not always be

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given. Although no examples were identified where testing

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requirements were inappropriately waived, the inspector was

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concerned that. the existence of this authority could result in-

unauthorized changes to procedures. The licensee addressed this

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concern by-providing guidance in a revised administrative

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procedure,

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Inspections indicated that the licensee's surveillance test

p

control program had significantly improved, only one test was

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not performed within the prescribed interval.

This was

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previously an area where licensee's performance was a concern.

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Overall, it' appeared-that the= licensee has initiated programs to

strengthen the_ maintenance area by upgrading the IST program,

addressing the technical adequacy of procedures, and initiation-

of preventive and predictive maintenance activities. The

staffing, especially in the I&C area, has been increased to a

satisfactory level. A surveillance program has been implemented

that ensures testing is performed in a timely manner.

2.

Performance Rating

~

The . licensee'is considered to be in Performance Category 2 in

this-functional. area.

Licensee's performance was determined to

be improving during this assessment period.

3.

Recommendations

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a.-

NRC Actions

'The NRC inspection effort should be consistent with the

, fundamental inspection program.

In addition, regional

inspection lnitiatives should be performed for core physics

testing, observation of plant startup activities from-the-

refueling outage, maintenance team inspection' followup, and

evaluation of the procedure upgrade program.

a-

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.b.

Licensee Actions

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~The licensee should continue emphasis on improving

maintenance activities through the' upgrade programs.that

have been established. Management attention should ensure

that the activities contained 1inLthe Safety Enhancement

_ Program are completed on schedule,'and the IST program

upgrades are completed in accordance:with commitments.

D.

Emergency Preparedness

1.

Analysis

This functional area includes activities related to the

establishment and implementation of the emergency plan and

implementing procedures, licensee performance-during exercises-

and actual events that test the emergency plan, and interactions -

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with onsite and offsite emergency response organizations during-

'

exercises and actual events.

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During this assessment period, region-based and NRC contract

inspectors conducted two emergency preparedness inspections.

The first inspection consisted of the observation and evaluation

of the annual emergency response exercise. The second

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inspection-involved a review of the operational status of the

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emergency preparedness program. No actual ~ events occurred

during this assessment period.

During the July 1989 emergency response exercise, the licensee's

- overall response was determined to be acceptable. The. control

room and technical support center staffs properly detected,-

classified, and declared emergencies, and made prompt

notifications to offsite agencies. -Although the,11censee's

overall performance during the course of the exercise

demonstrated an acceptable licensee proficiency to protect the

health and safety of the public, concerns were. raised by NRC

~

regardingspecificissues. One of the concerns involved the

licensee s over staffing of emergency facilities.with extraneous

personnel. Also, NRC expressed concern that the licensee's

staff had not been able to ascertain the hypothetical source of

the containment radiation leak and that licensee's management

failed lto devote an acceptable level of attention to the offsite

radiological consequences associated with the plume.

- An exercise weakness was Jentified with poor coordination,

'

, direction, and technical support provided to the control room

. staff by the technical support center staff. A similar weakness

i

involved the lack of coordination with the operational. support

center response.

Three of the other exercise weaknesses

involved, to some extent, repeated aspects from the=two prior

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exercises. A significant, repeated weakness involved the

licensee's inability to demonstrate personnel accountability.

within-30 minutes.

Scenario problems were found to be an

exercise weakness due to the_ inadvertent prompting of a player

by a-controller, which was a repeat-finding. Also, simulation

detracted from the extent of free play and, hence, diminished the

realism of the scenario.

'

Following the exercise, the licensee conducted a self-critique

and was able to appropriately identify and characterize a number

of exercise weaknesses, improvement items, and examples of good

performance.

Several of these findings coincided with those of

the NRC observers.

An inspection of the operational status of the emergency

preparedness program identified weaknesses with the training of

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emergency response personnel responsible for performing early

dose assessments from the control room. As a result of this

finding, the licensee made a prompt commitment to simplify the

dose assessment procedure and to retrain responsible users to

ensure that accurate and timely dose assessments could be made

from the control room. The licensee completed these corrective

actions prior to the end of i.his assessment period.

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It was noted that some aspects of the emergency preparedness

program met all requirements and were considered strengths.

Emergency facilities, equipment, and instrumentation was

maintained in a good state.of readiness. Aside from control

room dose assessment, the knowledge and performance of the

duties of emergency-response personnel interviewed were good.

The licensee implemented an aggressive drill sched:le and

condut:ted-the drills in an'ef fective manner. Corporate

management involvement was' apparent in various aspects of the

implementation of the emergency preparedness program.

The' licensee initiated changes to the emergency-preparedness

program to implement significant improvements in the future.

Organizational changes were made to upgrade the position of

+

supervisor, emergency planning such that this individual repo"ts

directly-.to the division manager, nuclear services. Additiou i

. technical-staff positions were added to the-emergency plannin;

and-training staffs.

In addition, duties of certain emergency

response -positions have been proportioned to enhance response

capabilities.

~A major effort to upgrade the effectiveness of the emergency

plan implementing procedures was initiated, primarily through

contract resources, to improve their useability. -The licensee

has.also initiated an effort to redirect the-training in-

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emergency preparedness toward a performance-oriented approach-

that will better prepare emergency-response personnel to perform

assigned functic ns during an emergency.

An effective QA pr) gram was implemented in the area of emergency

preparedness. . Indapendent audits met requirements, were well

coordinated and planned, and utilized satisfactory resources and

personnel. Audit findings.were properly characterized and

corrected. The licensee increased the number and frequency of

emergency preparedness-surveillances and made use:of. functional

-area experts in performing QA audits and surveillances.

Overall, the' licensee has initiated efforts to upgrade the

emergency preparedness program; including the emergency plan,

the emergency plan implementing procedures, and the staffing and

organizational reporting of the emergency planning staff. While

NRC recognizes this effort as a significant move toward

strengthening the licensee's emergency preparedness program,

4

there has not been sufficient timt for NRC to fully assess the

impact of these changes.

2.

Performance Rating

The licensee is considered to be in Performance Category 2 in

this area.

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Recommendations

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a.-

NRC Actions

-NRC effort should'be consistent with the fundamental-

-inspection program with regional initiative inspections 'in-

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the areas.of training, protective action decisionmaking,

and dose calculations and assessment.

b.-

Ocensee-Actions

Management should continue to emphasize efforts to

eliminate'the underlying root causes of licensee- and _

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NRC-identified weaknesses, Management's efforts should

also be directed toward maximizing realism in future-

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scenario development.

E.

Security

'1.

Analysis

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The assessment of this functional area includes activities that

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ensure the security of the plant, including all aspects of

access control, security checks, safeguards, and

fitness-for-duty activities and controls.

During this assessment period,.this area was routinely reviewed

by the resident inspectors;and. periodically by region-based

physical security -specialists.

Throughout the majority of this assessment period, the licensee

was' involved in implementing.a major upgrade'of the entire

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physical. security program.

The upgrade program,{ completed o_n

March 31, 1990g was-a well-designed effort that'was instituted

as a result of NRC and licensee-identified findings of

programmatic deficiencies during_ previous assessment periods,

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The licensee now has a redesigned, closed-circuit

television 4 (CCTV) perimeter surveillance system, protected and

vital area intrusion detection systems (IDS),~and a computer

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support system for the CCTV and IDS systems. The licensee

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currently plans some minor additions in the areas of protected _

1

area access control of packages and vital area access control of

personnel.

In September.1989 the licensee decided to establish a unified

'

proprietary security officer force instead of utilizing a mixed

force of contract and proprietary security officers.

Because of

the transition and the uncertainties as to which contract

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security officers would be retained, the licensee experienced

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some marginal personnel performance.

Personnel errors resulting-

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from excessive use of overtime for required compensatory

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measures contributed to this problem.

In addition, management

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has not been accessible to the security force members to

alleviate.the officers' concerns about the restructuring of the

security force. Consequently, security-officer morale has been

low,_some officers have exhibited a poor attitude, and, in some

instances, job performance has been adversely affected.

The?1icensee has made adjustments to improve security officer

-morale and performance.

Positive adjustments include the

,

recognition of the need to complete the transition from contract

7to proprietary security officer force as soon as possible,

.providing new uniforms for security officers..and increasing

security officer training. The nuclear security officer

,

training program.has been restructured and an acceptable number

of personnel.has been assigned to supervise the' program.

-Two issues confronting the licensee during this assessment

period, because of the upgrade program, involved proficiency

training for central / secondary alarm station (CSS) operators.and

. performance-based contingency training.

For CSS operators to

achieve proficiency; formal, on-the-job training with crucial

task testing was necessary. Unfortunately, this effort was

' impeded by delays in the installation of other equipment.

Consequently, alarm station operators were uncomfortable with-

.their experience' level on the CSS. As a result of the extensive

use of compensatory measures associated with the upgrade

program', the licensee has not yet been able to implement the.

performance-based contingency training that is a part of their

- upgrade program initiatives.

During this assessment period, the following violations occurr'ed,

some-of which-were self-identified by the licensee (including

the two significant-violations):

failure.to log / report certain

security events; some access searches were inadequate and'

consequently allowed a handgun and ammunition to enter the

warehouse within the protected area (Severity Level III

' violation), and allowed a food stuffs. van to enter the protected

area without a proper search; on occasions, the protection of

safeguards'information was inadequate (. Severity Level III

violation);.an on post, sleeping security officer was found and

a problem was identified with the inability to post out; a

problem was found with assessment aids due to CCTV and perimeter

IDS electronic misadjustments; and inadequate control of a vital

area keys was identified. The licensee self-identified

m,

violations were cited because the individual violations were

considered significant events, because of the need to improve

.

individual performance, or because the violations were repetitive.

In general, the licensee's final corrective actions were prompt

and effective.

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Thel 11censee implemented an initiative to establish a general

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plant employee awareness program of security requirements by

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placing secur.ity awareness issues in the company newspaper.

-In regard to the licensee's annual audit of the security

m

2 program, an outside organization and a person with security

"

expertise were employed. .The audit was, performed within the

specified time period, the findings-were appropriately

documented,-and security management was responsive to the

findings.

'

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The licensee'has an ample number.of supervisors, qualified

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security officers, and support personnel assigned to the

security department. -In June-1989 the position of supervisor,

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nuclear security operations was filled.

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0verall, the licensee continued to make improvements in the

4

physical security program. -In spite of the difficulties

i

described above, the licensee developed a technically sound and

.'

acceptable upgrade of the facility and the program.

Licensee

resources are appropriate for effective nuclear-security

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performance in the future. 'It appeared that the licensee has

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established the basis and necessary ground work .for a security

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program that is capable of operating- at improved performance

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levels.

2.

Performance Rating

4

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The licensee is considered to be in' Performance Category 2 in

>

this functional area. ' Licensee. performance was determined to be

7

.

improving,during the assessment period.

3.-

. Recommendations

a.

NRC Actiers

3

.

NRC effort should.be consistent-with the' fundamental inspection

program as augmented with regional.1.11tiatives in.the areas of

records and reports, training, testing and maintenance,

compensatory measures, access control personnel, access

control packages, and audit activities.

b.

Licensee Actions

,

Licensee's management should continue to provide support to the -

phy:1 cal security program to ensure that improved performance in

it

.this functional area continues. Attention to the involvement

with and oversight of security officers' duties should be

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emphasized by management.

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F.

Engineering / Technical Support

1.

Analysis

The purpose of this functional area is to address the adequacy

of technical and engineering support for all plant activities.

It includes all licensee activities associated with the design

of plant modifications;-engineering and technical support for

,

operations, outages, maintenance, testing, surveillance, and

'

procurement activities; and training.

.This functional- area was inspected on an ongoing basis by the

resident inspectors, periodically by region-based personnel, and

by the, probability risk assessment (PRA) team from Region IV.

The engineering organization has experienced a significant

transition, from one relying extensively on contractors, to an

.orgutization with a substantial in-house engineering capability.

,

This has resulted in an increase in the staffing levels in the

onsite and corporate engineering organizations.

Early in this assessment period, it was discovered that the

lice 6see had not included, in the group of safety-related

procedures to be upgraded, the alarm response, station

electrical system (includint safety-related electrical

distribution systems), main steam system, and main feedwater

system operating procedures.

The licensee corrected the scope

of th'*- -f fort to include those procedures in the above

grew 4 . that had a potential safety impact on the operation of

the plant.

The abnormal operating procedures were in the process of being

upgraded under a Safety Enhancement Program effort.

However,

tne abnormal operating procedure upgrade was not included in the

w' iter's guide issued for other safety-related procedures, and

the scope of the abnormal operating procedures had not included

the loss or degradation of most of the safety-related ac- and

de-electrical distribution systems.

As discussed above, and in other functional areas, the licensee

encountered problems with the technical content of safety-related

procedures. To address this concern, the licensee is in the

process of revising the technical content of procedures through

implementation of the procedures upgrade program contained in

the Safety Enhancement Program.

In the interim, the licensee is

self-identifying procedure implementat W issues. This program

is currently on schedule and is expected to be completed by the

end of 1990.

An inspection in the control of special processes noted that the

licensee, through its procedures, welding manual, and quaiity

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control manual, provided, for the most part, comprehensive

instructions for the control of special processes.

However, two

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examples were identified for the failure to provide adequate

instructions for controlling heat input-within the proper range,

j

and failure to qualify the full range of material thickness

!

specified in the welding procedure specification. Also, as a

welding program enhancement, the licensee committed to correlate

the settings on the welding machines to actual welding amperage

before making safety-related welds.

A special, announced team inspection in'the area of PRA was

performed.

This inspection covered the critical components of

'

the plant and the operational activities relating to dominant

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accident sequences developed by a generic-based assessment.

The

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generic PRA study identified the important systems, components,

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and activities that could contribute significantly to core melt

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accident sequences or mitigate the consequences of such events.

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The NA inspection team concluded that the emergency operating

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procedures, when used by experienced and trained operators,

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provided an acceptable level of direction to mitigate the

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consequences of an accident. The team also concluded that the

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risk-important systems and components were generally tested and

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maintained commensurate with their importance to risk.

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The PRA team identified violations that involved inadequate

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emergency and abnormal operating prucedures, and a licensee-

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identified failure to have an adequate design control program

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for electrical circuit fuses. An NRC-identified deviation

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involved the failure to conduct an emergency operating procedure

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validation as committed to in a licensee submittal to NRC,

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Other items of concern from this inspection included the lack of

I

a' fuse / breaker coordination study, the lack of a fuse control

program, and the lack of a stroke test for the power-operated

l-

relief valves. These items of concern were indicative of

weaknesses in the licensee's design control program.

'

The licensee continued to show improvement in other areas of the

design change control program.

Several inspections were

conducted that involved the review of the preparation of design

changes.

The reviews confirmed that modification packages

continue to be complete, concise, and contained the appropriate

elements.

1

Concerns were previously identified by NRC with the licensee's

l

capability to adequately resolve technical issues that are

identified during operation of the f acility.

To address these

concerns,.the lisensee established the systems engineering

organization. This engineering group has proven to be a

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valuable asset in the resolution of problems. The systems

engineers are involved in the day-to-day activities related to

the performance of the surveillance and maintenance functions,

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and the trending of the results of these functions.

This aspect

of the systems engineering effort has,provided technical

expertise in the field for early identification of component and

equipment problems. The contribution of the systems engineering

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organization toward overall plant safety was viewed as a

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strength.

At the end of.this assessment period, the plant was in a

'

refueling outage.

Activities performed during the outage were

completed satisfactorily.

Operations personnel removed and

!

replaced all fuel assembites in the reactor vessel without

'

incident.

The performance of the integrated leak rate test was

completed in accordance with the appropriate requirements.

Performance of eddy-current testing indicated that no steam

generator tubes required plugging. This was the third

,

consecutive outage where no tubes were plugged and the results

,

were attributed to the strict secondary water chemistry program

maintained by the licensee.

The licensee has completed the issuance of the design basis

!

documents for plant systems.

Through this effort, the licensee

I

identified instances where components and systems did not comply

with the design basis requirements stated in the Updated Safety

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Analysis Report.

The licensee's engineering organizations

provided timely resolution of the identified problems.

This

d

effort was identified as a strength.

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During several NRC inspections, design-related problems were

i

identified. A review of the leak-rate testing of containment

isolation valves identified two penetration labeling errors and

)

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incorrect valve position labeling on piping and instrumentation

drawings. An inspection'of the implementation of commitments

,

made relative to Regulatory Guide 1.97 " Instrumentation For

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Light-Water-Cooled Nuclear Power Plants to Assess Plant and

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Environs Conditions During and Following an Accident,"

l

identified problems with design documents.

The inspectors

i

experienced significant difficulty in extracting required

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information from design documentation.

Licensee personnel

,

acknowledged these problems and indicated that in-house efforts

'

had been initiated to improve the drawing quality and

usefulness, and the computer data base content and accuracy.

q

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Inspections performed of the instrumentation calibration program

L

identified violations that involved inadequate calibration of

i

instruments utilized for postaccident monitoring and inadequate

environmental qualification of an instrument channel.

,

During a test of the turbine-driven auxiliary feedwater pump,

i

the pump failed to rs: pond to manually injected air signals to

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the pnuematic-hydralic speed governor. The licensee determined

that the pump may not have been operable prior to the test

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because of the failed speed governor components.

The licensee's

response to this problem was deemed appropriate; however,

subsequent followup by an inspector determined that the pump had

been inoperable over an extended period because of deficient

testing, maintenance, and control system calibration. The

licensee's actions were aggressive in resolving the programmatic

and technical deficiencies in this instance.

Prior to the establishment of a formal procurement program for

commercial grade items-in 1988, the licensee experienced

deficiencies in traceability, establishment of critical

characteristics, insufficient in vection and testing, and vendor

qualification.

Subsequent to th> astablishment of a formal

program, a significant reduction in these problems were noted.

The results of an inspection indicated that, while improvement

had occurred, more awareness for the need of an hdepth review

during the evaluation and dedication process was required.

Licensee management oversight of the training of licensed

operators and applicants for license improved.

Management has

become more aggressive in identifying and correcting problems.

However, a recent self-identified f ailure to properly track

medical conditions for a licensed operator was a repeat of a

prior program failure. The licensee has implemented

comprehensive training programs for the technical, professional,

and maintenance staffs.

During this assessment period, the licensee installed a' control

room simulator to provide enhanced training for licensed

operators.

raining on the simulator commenced just prior to

T

the end of this assessment period. This training enhancement

was viewed as a positive contribution toward safe plant

operation.

Historically, the licensee has experienced difficulty with the

implementation of TS-required firewatch patrols.

During this

assessment period, problems were identified in this area.

To

address this continuing problem, the licensee has established a

group that is dedicated to the performance of fire patrols. The

security organization previously performed this function.

Since

iLplementation of the dedicated group, no problems have been

identified.

On February 26, 1990, a loss of offsite power (LOOP) occurred

which resulted in a 2 minute loss of shutdown cooling. The LOOP

was caused due to the under-voltage trip relays not

automatically shedding the operating low pressure safety

injection (LPSI) pump. A special inspection was conducted

following the event.

It was determined that during manual

operation of the LPSI pumps, the automatic load shed and

automatic ciesel generator output breaker closure features would

i

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be inhibited when an undervoltage event on vital electrical

!

buses occurred. The licensee analyzed the event and determined

that design of the electrical system complied with the plant

design basis and did not affect safe plant operation. As a

system enhancement, the licensee has decided to modify the

design in order for the emergency diesel generator to

automatically load in the event of the design basis accident and

a LOOP when a manually-loaded LPSI pump is operating. This

modification will be completed by the end of the 1991 refueling

outage.

In summary, several strengths, positive actions, and weaknesses

were identified during this assessment period.

The licensee has

undertaken an extensive program for upgrading safety-related and

abnormal operating procedures, including technical content,

through the efforts of the Safety Enhancement Program. The

licensee continued to show improvement in the design change

control program as evidenced by the results from several

inspections conducted during this assessment period.

Concerns

regarding the licensee's capability to adequately resolve

technical issues identified during plant operation were being

effectively addressed by the recently established systems

engineering group.

During the recent refueling outage, the

eddy-current testing conducted on steam generator tubes

indicated that no tubes required plugging. This was the third

consecutive outage during which no tubes were plugged. The

results were attributed to a strict secondary water chemistry

program. The licensee's engineering organizations have provided

timely resolution to problems identified by the issuance of the

design basis documents for plant systems.

Difficulties

experienced with the implementation of firewatch patrols appears

to be resolved by the establishment of a group dedicated to the

performance of fire patrols.

Several items of concern

identified during a PRA inspection were indicative of weaknesses

in the design control program.

2.

Performance Rating

The licensee is considered to be in Performance Category 2 in

this functional area.

3.

Recommendations

a.

NRC Actions

NRC inspection effort should be consistent with the

fundamental inspection program.

Regional initiative should

include an inspection to evaluate the licensee's

engineering capabilities.

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b.

Licensee Actions

Licensee management should focus their efforts on the

completion of the safety-related procedures upgrade

project. Management should take the appropriate actions to

ensure that the weaknesses identified with emergency and

abnormal operating procedures are resolved in a timely

-

manner.

G.

Safety Assessment / Quality Verification

1.

Analysis

The assessment of this functional area includes all licensee

review activities associated with the implementation of Itcensee

safety policies; licensee activities related to amendment,

exemption, and relief requests; response to NRC Generic Letters,

Bulletins, and Information Notices; and resolution of TMI items

and other regulatory initiatives.

It also includes licensee's

activities related to resolution of safety issues,

10 CFR Part 50.59 reviews, 10 CFR Part 21 assessments, safety

committee and self-assessment activities, root cause analyses of

plant events,_use of feedback from plant QA/QC reviews, and

participation in self-improvement programs.

It includes the

effectiveness of the licensee's quality verification function in

identifying and correcting substandard or anomalous performance,

in identifying precursors of potential problems, and in

,

monitoring the overall performance of the plant.

Inspection of licensee self-assessment activities identified an

overall effective performance by the Safety Audit and Review

Committee (SARC) and the Plant Review Committee (PRC).

The-

licensee had identified and corrected the failure of a SARC

subcommittee to review recent plant modifications and their

associated safety evaluations. Additionally, the licensee

observed that neither group had performed any self-assessment

activity in regard to the safety-related procedure upgrade

effort.

It was noted that PRC activities were not well

documented and it appeared that handling of action items could

be improved.

It was also noted that one F,tC standing

subcommittee was not submitting the results of its reviews to

the PRC for approval.

The licensee instituted immediate actions

to correct the cbserved PRC deficiencies.

To address a broad spectrum of concerns and weaknesses

previously identified by NRC, and an independent appraisal by a

licensee contractor of the FCS nuclear organizations, the

licensee developed and implemented the Safety Enhancement

Program. This program provides a comprehensive listing of

licensee actions related to safe plant operation and the

activities that support operations.

Implementation of the

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actions contained in the program has received a high level of

corporate and plant management attention and support. The

licensee has demonstrated positive steps toward improving their

overall performance by implementation of the items contained in

the Safety Enhancement Program. This overall improvement

indicates that the licensee is improving their capability to

provide management leadership and oversight of the diverse

elements related to the conservative operation of the FCS.

Although all items have not been completed, the effort to

complete the remaining open items is on schedule.

$atisfactory programs were found to be in place with respect to

implementation of the 10 CFR Part 21 review program and the

control of measuring and test equipment (M&TE).

Positive

actions were observed.to have been taken by the licensee to

correct a prior weakness in regard to control of M&TE used by

the 1&C maintenance group.

The licensee implemented a training program for those

individuals invol u d in the preparation, review, and approval of

10 CFR Part 50.59 evaluations.

Personnel completing the

training are the only individuals authorized to process

Part 50.59 evaluations. This approach has been a positive

contribution towards the licensee's satisfactory completion of

Part 50.59 evaluations.

A comprehensive corrective action program was established that

appropriately provides for identificatien, tracking, correction,

and trending of safety-related problems. The licensee was also

observed to have implemented surveillance programs to provide

additional oversight of inservice inspection contractors and

in process welding.

The licensee has established and implemented a Nuclear Safety

Review Group (NSRG), an independent organization that reviews

plant events and occurrences to determine the roat cause(s) and

recommend corrective actions. The establishment of the NSRG was

a licensee self-initiated action that parallels the independent

safety review group required by the TS for newly licensed

facilities. The NSRG has been fully staffed by experienced

individuals with diverse backgrounds, and is managed by an

individual that previously served as supervisor, operations.

The NSRG completed, during this assessment period, ten root

cause analysis reviews on plar.t events such as inadvertent

overflow of the spent fuel pool, failure of the turbine-driven

auxiliary feedwater pump speed controller, and the loss of

offsite power during the refueling outage. The reviews

performed by the NSRG have been comprehensive and have provided

the appropriate recommenJations for corrective actions to

prevent recurrence.

The establishment and performance of the

NSRG was viewed as a strength.

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The licensee has upgraded the staf fing of the QA organization by

the addition of experienced QC inspectors and technical auditors

with working experience in the areas of operations, health

physics, security, and chemistry.

The staffing level in the QA

organization was satisfactory.

In the previous SALP report, a

concern was identified with the performance of audits by QA.

The audits were noted to be compliance-based rather than

performance-based. The licensee has taken actions to address

this issue. A review of the licensee's audit program indicates

that performance-based audits are now being performed. As noted

in the discussions of the other functional areas, the licensee's

audit program has been comprehensive, thoroughly performed, and

corrective actions taken in response to audit findings were

appropriate and timely.

The licensee has established and issues, on a monthly basis, a

comprehensive set of performance indicators. These indicators

provide management with a tool that can be used for early

identification of adverse trends so that corrective measures can

be taken to reverse the trend.

In addition, the QA organization

publishes a detailed quarterly trend report that summarizes the

results of their audits.

During this assessment period, eight license amendments were

issued. These amendments included incorporation of surveillance

and operability requirements for the citernate shutdown panel,

generic specifications incorporated into the TS, surveillances

and limiting conditions for operation for a contrci room

modification to alleviate air in-leakage, and some

administrative changes.

In addition, safety evaluations were

issued that addressed TMI actions, Salem ATWS items, and actions

requesting reliefs from the ISI and IST programs.

The licensee's submittals, in general, indicated an acceptable

level of understanding of the technical issues from a safety

standpoint and acceptable approaches were used.

However, in the

latter part of this assessment period, weaknesses were

identified in both the schedular aspects of the licensee's

submittals and fully addressing the requirements of the proposed

TS changes.

Six submittals were required prior to th approval

of a license ameMment request for the boric acid heat tracing

system. This can be attributed to factors related to the

refueling outage, many ongoing actions being performed

siPtaneously, recent new employees joining the organization

(almost doubling the work force), and pressure to meet the

schedule. The licensee has incorporated chnges that should

rectify some of these problems.

The licensee's responsiveness to NRC Bulletins and Generic

Letters was timely and technically complete.

Responses during

this assessment period included NRC Bulletins 88-03, " General

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Electric HFA Relays"; 88-10, " Nonconforming Molded Case Circuit

Breakers"; and 89-03, " Potential Loss of Required Shutdown

Margin During Refueling." The licensee's response to_NRC

,

'

Bulletin 88-10 had to be revised because four breakers, which

were to be replaced during the 1990 refueling outage, could not

be obtained from the vendor.

The licensee indicated that these

breakers would be replaced during the 1991 outage and that a

justification for continued operation would be in place which

'._

the NRC subsequently found acceptable. The responses to Generic

Letters included 89-06, " Safety Parameter Display System";

89-07, " Power Reactor Safeguards for Surface Vehicle Bombs";

89-08, " Erosion / Corrosion"; and 90-01, "NRC Regulatory Impact

Survey."

8

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A review of the licensee event reports submitted to NRC

!

indicated that the reports described the major aspects of each

event, including the causes of system failures that contributed-

to the event and the significant corrective actions taken or

planned to prevent recurrence.

Overall, the licensee's programs that provide for the assessment

and verification of activities related to the various aspects of-

>

safe plant operation have received a high level of senior

management attention and involvement and have placed emphasis on

superior personnel performance. These programs provide a solid

basis for increased overall performance and the attendant

philosophy contained in the programs should be implemented

i

through all levels of the nuclear organization.

These programs

include self-identification of problems through the

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implementation of QA audits effective performance of the SARC,

and the root cause analyses performed by the NSRG. The actions

i

implemented through the Safety Enhancement Program provided an

increased level of management oversight with respect to plant

operations.

!

2.

Performance Rating

The licensee is considered to be in Performance Category 1 in

,

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this functional area.

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3.

Recommendations

,

a.

NRC Actions

NRC inspection effort should be consistent with the

fundamental inspection program. An assessment of the

'

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licensee's implementation of the items contained in the

'

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Safety Enhancement Program should be performed.

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b.

Licensee Actions

Licensee's management should take actions to ensure that

all submittals made to NRC are timely and address all

technical aspects of the subject. Management should

provide the appropriate oversight to ensure that the items

in the Safety Enhancement Program are completed on schedule

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and in accordance with the licensee commitments.

V.

SUPPORTING DATA AND SUMMARIES

A.

Licensee Activities

1.

MajorOutages

The licensee commenced the thirteenth refueling outage on

February 17, 1990. At the end of this assessment period, the

outage was still in progress.

2.

License Amendments

During this assessment period, eight license amendments were

issued.

Some of the more significant amendments were:

o

Extension of the interval for performance of surveillance

tests by 25 percent - Amendment 122

o

Operability and surveillance testing requirements for the

alternate shutdown panel - Amendment 125

3.

Significant Modifications

o

Installation of a third auxiliary feedwater pump to improve

reliability of the auxiliary feedwater system.

o

Major upgrade of the security system.

o

Construction of 'a new radiological waste building, a

radiological protection / chemistry office, and locker room

complex.

B.

Direct Inspection and Review Activities

NRC inspection activity during this SALP cycle included 52

inspections performed with approximately 4855 direct inspection hours

expended.

C.

Enforcement Activity

The SALP Board reviewed the enforcement history for the period May 1,

1989, through April 30, 1990.

The enforcement history is tabulated

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in the enclosed table. One civil penalty was issued in the area of

security. No orders were issued.

TABLE

ENFORCEMENT ACTIVITY

NUMBER OF VIOLA 110NS

'

FUNCTIONAL AREA

IN SEVERITY LEVEL

Weaknesses Dev* NCVs**

IV

III

A.

Plant Operations

2

3

B.

Radiological Controls

2

1

C.-

Maintenance / Surveillance

2

1

D.

Emergency Preparedness

6

3

E.

Security

1

8

2 ***

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F.

Engineering / Technical Support

4

3

7

1 ****

G.

Safety Assessment /

4

2

Quality Verification

TOTAL

6

5

13

25

3

Deviations

Noncited violations

m.

Combined Civil Penalty cf $25K

No Civil Penalty Issued

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