ML20141N831

SALP Rept 50-395/85-47 for Jul 1984 - Dec 1985

ML20141N831
Person / Time
Site:	Summer
Issue date:	03/12/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20141N828	List: ML20141N827 ML20141N831
References
RTR-NUREG-0737, RTR-NUREG-737 50-395-85-47, GL-83-28, IEB-83-03, IEB-83-3, NUDOCS 8603180181
Download: ML20141N831 (31)

See also: IR 05000395/1985047

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ENCLOSURE

SALP 80ARD' REPORT

U. S. NUCLEAR REGULATORY COMISSION

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SYSTEMATIC' ASSESSMENT OF LICENSEE PERFORMANCE

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INSPECTION REPORT NUMBER

50-395/85-47

SOUTH CAROLINA ELECTRIC AND GAS COMPANY

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V. C. SUMMER

JULY 1. 1984 THROUGH DECEMBER 31, 1985

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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 pracesses used to

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

sufficiently diagnostic to provide a rational basis for allocating NRC

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

promote quality and safety of plant construction and operation.

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

February 13, 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 Summer for the period July 1,1984, through December 31,

198S. <

SALP Board for Summer:

R. D. Walker, Director, Division of Reactor Projects (DRP), RII

(Chairman) <

C. A. Julian, Acting Director Division of Reactor Safety (DRS), RII

J. P. Stohr Director, Division of Radiation Safety and Safeguards (DRSS),

RII

L. S. Rubenstein, Project Director, PWR Project Directorate 2. Division of

Pressurized Water Reactor (PWR) Licensing-A, NRR

J. B. Hopkins, Project Manager Division of PWR Licensinq-A, NRR i

V. W. Panciera, Chief, Reactor Projects Branch 2, DRP, RII

R. L. Prevatte, Senior Resident Inspector, Summer, DRP, RII

Attendees at SALP Board Meeting:

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K.D.Landis, Chief.TechnicalSupportStaff(TSS),DRP,RII ,

H. C. Dance, Chief, Reactor Projects Section (RPS) 28. DRP, RII '

J. J. Blake, Chief Materials and Processes Section DRS, RII

T. E. Conlon, Chief, Plant Systens Section, DRS, RII

F. S. Cantrell, Chief, RPS18, DRP, RII

D. R. McGuire, Chief. Physical Security Section, DRSS, RII

W. E. Cline, Chief, Radiological Effluents and Chemistry Section DRSS, RII

T. Decker, Chief. Emergency Preparedness Section, DRSS, RII

A. H. Johnson, Project Inspector, RPS1B, DRP, RII

G. A. Pick, Reactor Engineer, TSS, DRP, RII

T. C. MacArthur Radiation Specialist, TSS, DRP, RII

J. K. Rausch, Reactor Engineer TSS, DRP, RII

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II. CRITERIA

Licensee performance is assessed in selected functional areas, depending

upon whether the facility has been in a construction, preoperational, or

operating phase during the SALP review period. Each functional area

normally represents areas which are significant to nuclear safety and the

environment and which are normal programmatic areas. Some functional areas

may not be assessed because of little or no licensee activities or lack of

meaningful observations. Spt.:ial areas may be added to highlight signifi-

cant observations.

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

functional area; however, the SALP Board is not limited to these criteria

and others may have been used where appropriate.

A. Management involvement and control in assuring quality

B. Approach to resolution of tect ical issues from a safety standpoint

C. Responsiveness to NRC initiatives

D. Enforcement history

E.

F. Reporting (and analysis

Staffing including of reportable events

management)

G. Training effectiveness and qualification

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

classified into one of three performance categories. The definitions of

these performance categories are:

Category 1: Reduced NRC attention may be appropriate. Licensee management

attution 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 level. Licensee

management attention and involvement are evident and are concerned with

nuclear safety; licensee resources are adequate and are reasonably effective

50 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 such that minimally satisfactory performance with

respect to operational safety or construction is being achieved.

The functional area being evaluated may have some attributes that would

place the evaluation in Category 1, and others that would place it in either

Category 2 or 3. The final rating for each functional area is a composite

of the attributes tempered with the judgement of NRC management as to the

significance of individual items.

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The SALP Board may also include an appraisal of the performance trend of a

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functional area. This performance trend will 'only be used when both a

definite trend of performance within the evaluation period is discernible

and the Board believes that continuation of the trend may result in a change

of performance level. The trend, if used, is defined as:

Improving: Licensee performance was determined to be improving near the

close of the assessmer.t period.

Declining:- Licensee performance was determined to be declining near the

close of the assessment period.

III. SUMMARY OF RESULTS

Overall Facility Evaluation

The licensee displayed an aggressive, safety conscious attitude toward

correcting problems. The level of performance was satisfactory, although

certain weaknesses were evident in the areas of plant operations and fire

protection. A strength was identified in the areas of emergency

preparedness, security, radiological controls, and maintenance during the

assessment period. It is considered significant that the identified

weakness in the fire protection area was identified during the

mid-correction period and that the licensee subsequently demonstrated a

dynamic management attitude toward nuclear safety by the implementation of

aggressive corrective actions for the identified weakness. In addition to

improvement in those areas with identified weaknesses, it was noted that

the trend of serformance was improving in the areas of alant operations and

outages. - No ' instances of declining trend was identifiec.

Mar. 1, 1983- July 1, 1984-

Functional Area June 30, 1984 Dec. 31, 1985

Plant Operations 2 3

Radiological 1 1

Controls

Maintenance 1 1

Surveillance 2 2

Fire Protection 2 3

Emergency 1 1

Preparedness

Security 1 1

Refueling / Outages Not Rated 2

Training Not Rated 2

Quality Programs and 2 2

Administrative

Controls Affecting

Quality

Licensing Activities 2 2

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IV. PERFORMANCE ANALYSIS

A. Plant Operations

1. Analysis

During the evaluation period, routine inspections were performed

by the resident and regional staffs. The licensee's performance

in the areas of housekeeping, control room behavior and discipline

was satisfactory. The plant overall cleanliness was commendable.

Operational staffing of key positions with knowledgeable personnel

was considered adequate.

Personnel errors noted in the previous SALP continued to plague

plant operations. A series of problems, violations, and the

concern that a negative trend might be developing led to a special

inspection in September 1985. . This inspection revealed

degradation of management control in areas that included the lack

of attention to nuclear system operating conditions, outdated and

poorly controlled procedures, inadequate methods of tracking

equipment status involving limiting conditions of operation, and a

generally relaxed attitude toward procedure compliance. Twelve

violations were identified in four separate categories. These are

violations of plant operational limits as noted in (a), (e) (h),

and (k) below,(safety

in (b), (d), f), (j ,)related

and (1)administrative

below, failurerequirements

of operationsas noted

personnel to maintain an awareness of plant status as noted in

(b), (c), (f), (1), (j), and (k) below, inadequate procedures

as noted in (g) below, and failure to follow procedures as noted

in (i) below. Violations (f) and (g) below were issued because of

the February 28, 1985 positive rate reactor trip incident which is

discussed in Section K. An enforcement conference was held in

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Region II on October 8,1985, to discuss the events associated

with violation (a) below. A Civil Penalty was subsequently issued

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on January 6,1986, and the licensee's response dated February 5,

1986, addressed the issues. Long term programatic changes are

still being reviewed.

To improve plant operations and address the above concerns, the

licensee implemented changes to provide improved control over

plant operations. These included assignment of a Duty Operations

Manager to provide oversight and assistance during plant startup

and shutdown; the addition of a seventh shift supervisor to

provide administrative assistance to the duty shift supervisor; a

control room enhancement program to provide a more professional

j atmosphere; and a team building program to improve comunications

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problems. Many of these changes are recent and insufficient time

j has elapsed to evaluate their overall impact on plant operations.

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Observations of the activities associated with the startuo after

the second refueling outage indicated that management changes and

recently initiated improvements may be accomplishing the desired

results. This startup, low power physics testing and power

ascension was a well planned and deliberate operation with no

significant problems.

The assignment of a licensed Senior Reactor Operator (SRO) with

shift supervisor experience to the planning and scheduling group

and proper utilization of the administrative operations staff,

t' 't is assigned to scheduling, has prevented schedule conflicts

during surveillance testing, maintenance, outages, and plant

operations. The establishment of train related maintenance and

testing weeks, train "A" and "B" on alternating weeks, should lead

to a reduction in maintenance and operations interface problems

and reduce the number of limiting conditions of operation problems

that have occurred in the past.

The licensee provided adequate event reports during the assessment

period. In addition to Licensee Event Reports (LERs), the licensee

submitted special reports describing particular events or main-

tenance activities in detail. The licensee's investigation,

inspection and subsequent repair of Anchor / Darling check valves

Wds timely and effective.

a. Severity Level III violation for system alignment errors that

rendered both RHR trains inoperable and for failure to

recognize the importance of jumpers in the overpower Celta

temperature trip instrumentation circuits. (85-34)

b. Severity Level IV violation for failure to follow locked

valve procedure. (84-23)

c. Severity Level IV violation for failure to identify and take

prompt corrective action for a potential deficiency on a

reactor protection instrumentation channel. (84-29)

d. Severity Level IV violation for failure to implement locked

valve control program. (84-30)

e. Severity Level IV violation for failure to demonstrate

operability of containment isolation valves. (84-37)

f. Severity Level IV violation for failure to follow procedures

while withdrawing control rods and approaching criticality.

(85-12)

9 Severity Level IV violation for failure to establish adequate

procedures for ECC calculations. (85-12)

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h. Severity Level IV violation for failure to implement the

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requirements of Technical Specifications for an inoperable

power range instrument. (85-15)

1. Severity Level IV violation for failure to follow procedures

and use the latest revision to calculate estimated critical

conditions. (85-27)

j. Severity Level IV violation for failure to adequately

evaluate plant conditions prior to performance of a surveil-

lance test resulting in both ECCS trains being inoperable.

(85-28)

k. Severity Level IV violation for an inoperable feedwater

isolation valve during Mode 3 operation. (85-37)

1. Severity Level V violation for failure to properly document

surveillance test activities. (85-04)

2. Conclusion

Rating: 3

i Board Recommendation

Recently implemented changes to provide improved control over

plant operations indicate a strong management response to

weaknesses identified by the number and nature of violations. The

Board recommends a continued high level of Licensee management

attention and increased NRC inspection activity in this area.

B. Radiological Controls

1. Analysis

During the evaluation period, inspections were performed by the

resident and regional staffs. This included confirmatory measure-

ments using the Region 11 mobile laboratory.

The licensee's health physics staffing level was adequate and

compared favorably to other utilities of similar size in that an

adequate number of ANSI qualified licensee and contract health

physics technicians were available to support routine and outage

operations. The radiological effluents control staffing levels

and staff qualifications were acceptable. Key positions in the

radwaste management program and environmental surveillance

programs were filled with qualified staff.

Two strengths of the health physics program were the quality of

the health physics technicians and the experience level of the

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corporate and site health physics staffs. The staff has a low

, turnover rate and an effective training program.

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An individual from the functional area of Radiological Control was

assigned to the Scheduling and Planning Group which resulted in

better controls of the radiologically controlled areas.

Understanding of technical issues and approach to technical

problem solving was generally adequate; however problems were

noted in - the licensee's measurements and measurements control

program. Specifically, the licensee had difficulty in meeting the

lower limits of detection for gas samples. In addition, a

systematically high bias was identified for gamma spectroscopic

analyses of particulate filters. The licensee participated in the

NRC spiked sample analysis program. Licensee analyses were in

agreement for three isotopes but were in disagreement for one.

The licensee was generally responsive at resolving these issues as

evidenced by the corrective measures for the violation and the

agreement to evaluate the high bias found in gamma spectroscopic

analyses. Additionally, prompt action was taken to . correct a

licensee identified deficiency in the computer software for

converting whole body counts to maximum permissible body burden.

The licensee submitted required effluent and environmental reports

during the rating period. Both liquid and gaseous effluents were

within limits for total quantities of radioactive material

released. Licensee estimates of air dose and dose to the maximum

exposed individual was variable between reporting periods but was

within limits as specified in the Technical Specifications. No

trends or biases were evident from reported values.

In July 1984, the licensee discontinued use of the installed

liquit radwaste processing system and began using the services of

a contractor. A review of the effluent release reports from July

1983 to June 1985, indicated a decline in the number of batch

releases, total volumes discharges, and radioactivity concentra-

tion in effluents since the initial operation of the contractors

system.

During the evaluation period, the licensee's radiation work permit

and respiratory protection programs were found to be satisfactory.

Control of contamination and radioactive materials within the

facility was excellent. From January 1985, to January 1986, the

amount of contaminated area decreased from approximately 8000 to

2800 square feet which represents two percent of the radio-

logically controlled area of the plant. In 1985, there was a

48 percent decrease in the number of clothing and skin contamina-

tion incidents when compared to 1984.

During this eighteen month evaluation period, the licensee's

cumulative exposure was 598 man-rem. This compares favorably to

the national average exposure of 815 man-rem observed at similar

PWR facilities. This lower than average collective dose results

from the short operating life of the plant and from the aggressive

exposure control program established and implemented by the

licensee.

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One : inspection related to plant chemistry revealed that the

1_icensee had experienced two significant intrusions of ion-

exchange resins .into the steam generators .due to failure of an

experimental- cleanup loop on the condensate system. These

, intrusions happened when the plant was operating above 50 percent

power where . the. condensate. cleanup system .must be bypassed.

Although chemistry was controlled in an acceptable-manner during

.the latter phases of the first fuel cycle, ' difficulties were

experienced in chemistry control for several weeks during startup

-of the second fuel cycle. The licensee was revising its water

chemistry program to make it consistent with the recommendations

of the Steam Generators Owners Guidelines; however, the licensee's

resources to implement these stringent guidelines were considered

to be marginal. During a later inspection, imediately after this

evaluation period,. improvements were evident in all areas except

chemical expertise and resources.

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During the evaluation period, the licensee disposed of .27,167

cubic feet of solid radioactive waste containing 211 curies. This

is . quite close to the national average of 27,386 ' cubic feet

shipped by other utilities with similar facilities.

Two violations were identified:

a. Severity Level IV violation for failure to follow procedural

requirements for wearing protective clothing. (84-27)

b. Severity Level .Y violation for failure to achieve the

required lower limit of detection for effluent samples.

(85-19)

2. Conclusion

Category: 1

,3. . Board Recommendation

The Board recommends continued Licensee emphasis in the area of

water chemistry. Decreased NRC inspection activity in this area

is recommended with the exception of the-chemistry program.

C. Maintenance.

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1. Analysis

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During the evaluation period, routine inspections were performed

by the resident and regional staffs.

The maintenance organization had a number of accomplishments. A

uniform procedures guideline was developed to provide consistency

in maintenance procedures, including post maintenance and review

of vendor information. The guidelines and implementation program

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were established prior to receipt of the INP0's good practices

guidelines. INP0's review of the licensee's program indicated

that it met or exceeded the good practices guideline. To further

enhance this program the licensee has trained and assigned

procedure writers to cover each maintenance discipline. All

recently developed or revised procedures met the guidelines. A

two year plan was established to update all existing naintenance

procedures to the guidelines.

The licensee electrical maintenance program was well controlled by

specific procedures. The personnel participating in activities

affecting equipment on the 0-list were aware of the quality

assurance (QA) controls. The craft personnel performing

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maintenance and surveillances were knowledgeable of maintenance

procedures and plant equipment. Maintenance Work Order (MW0)

packages had all the required reviews and approvals prior to the

start of the work. The MWO indicates the proper Q-list classifi-

cation, work was completed and inspected as required, and

post-maintenance testing was conducted. The licensee established

a computer program to assemble, store and retrieve MW0s. The

actual records are stored on microfilm and are accessible by

computer.

A special team inspection was performed to assess the licensee's

compliance with Generic Letter 83-28, " Required Actions Based on

i Generic Implications of Salem ATWS Events". _The licensee's

management was adequately involved in assuring quality and was

responsive to NRC initiatives. The licensee's responses were

timely, concise, and adequately resolved technical issues.

Procurement of new equipment, motor operated valve analysis test

system (M0 VATS), infrared analysis, and ferrographic oil analysis

increased the licensees capability to test, and diagnose equipment

condition. The MOVATS equipment identifies changes in signature

trends which in turn provides for early recognition of potential

problems and provides greater accuracy in the setting of torque,

limit switches and valve position indication. The infrared

analysis has improved identification of defects and potential

problems in electrical and electronic equipment. It was instru-

mental in identifying fuse oxidation problems in electrical

circuits not ordinarily detected by resistance measurements. The

ferrographic oil analysis equipment helped determine the cause of

equipment failures i.e., diesel generator "B"'s failure in 1985.

The licensee has additionally developed the capability to perform

onsite dioctylphthalate and methol iodide testing of charcoal

filters in heating, ventilation, and air conditioning systems.

This testing had previously been performed by outside contractors.

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The expansion of naintenance facility . buildings has provided

additional space and equipment for mechanical and instrumentation

work. The addition of a radioactive instrument calibration

facility and upgrading of the radioactive materials machine shop

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has improved the capability to perform work and reduced.the time

for repairs.

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Use of the Nuclear Plant ~ Reliability Data System (NPRDs) has

increased the licensee's awareness of potential.. plant problems.

Upgrades in the Computer Historical and Maintenance Program System

(CHAMPS) and implementation of data verification has improved the

data-base used for. maintenance planning and scheduling. Staffing-

increases added maintenance planners who provided better scheduling

and coordination of the activities of each maintenance discipline.

The above improvements and increased _ maintenance engineering staff

involvement led to an overall improvement in the areas of planning,

scheduling and timely completion of maintenance activities.

The establishment of outage critiques to identify areas requiring

additional attention and tracking was evidence of management

involvement.

Three' violations were identified:

a. Severity Level IV violation for failure to follow procedure

GMP 101.008. (85-13)

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b. Severity Level IV violation for failure to comply with 10 CFR

Part 50, Appendix A, Criterion 1, in the use of an individual

cell charger on a class 1E battery. (85-15)

c. Severity Level V violation for failure to follow procedures.

(85-08)

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2. Conclusion

Category: 1

3. Board Recommendation

The Board notes indications of strong management attention in this

' area. Decreased NRC inspection activity is recommended.

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D. Surveillance

1. Analysis

During. the evaluation period, inspection were performed by the

resident and regional staffs. These included activities related

to inservice inspection and testing, tendons surveillance, con-

tainment integrated leak rate testing (ILRT), outages, and startup

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testing were conducted in addition to the more frequent surveil-

lance activities. Staffing and training was adequate and

surveillances were conducted within the proper time frame.

The surveillance procedures reviewed, tests that were witnessed,

and examinations of test results, revealed that the licensee's

surveillance procedures were technically adequate and satisfac-

torily executed. Improvements in tracking limiting conditions

for operations applicable to surveillance testing have been

implemented.

While performing containment tendon testing during the second

refueling outage, the licensee discovered that some tendons had

relaxed to values less than specified in Technical Specifications.

Analysis performed by a contractor demonstrated adequate struc-

tural integrity. The licensee's procedures and records for

control of the tendon surveillance program were well defined

and explicit.

On August 29, 1985, the licensee identified through a post reactor

trip review and evaluation that jumpers for the overpower delta

temperature trip circuits had been omitted since initial plant

startup in October 1982. This violation is incorporated as

violation (a) in the plant operations section and resulted in a

Civil Penalty being issued on January 6,1986.

Inservice inspection procedures, work, and records performed by

the licensee contractor were found to be satisfactory. Inservice

inspection and inservice testing procedures, work, and records

performed by site personnel were sometimes inadequate as indicated

by violations (a) through (e) below. Also, there was indication

of weakness in the licensee program for training operations

personnel in the performance of inservice inspections.

, A weakness was noted in the licensee's responsivcness to concerns

raised by the NRC. Examples include the licensee's failure to

promptly provide information on unresolved item, " Exercising

Emergency Feedwater Discharge Check Valves to Closed Position",

their failure to provide a final response in accordance to

IEB 83-03, " Check Valve Failure in Raw Cooling Water Systems in

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Diesel Generators", and their failure to correct an NRC identified

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test procedure deficiency which ultimately resulted in

violation (a) below.

Based on the above problems, the licensee management dedication

toward improvement led to increased quality assurance / quality

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in transferring the Regulatory Support Group, which provides

administrative and technical oversight over the program, from the

Regulatory Compliance area to Planning and Scheduling. This

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change resulted in better coordination and faster resolution

of problems.

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Extensive effort had been expended by operations and engineering

personnel in developing a computerized Technical Specification

cross reference program. This program when completed and

implemented should reduce administrative burdens on operations and

provide a better tracking method to insure compliance when

conducting surveillances.

Observations of major surveillance tests such as the 18 month

diesel generator test, the engineered safety features response

time testing, and the ILRT indicates that the licensee has a

strong and well managed program. Software improvements in the

CHAMPS system coupled with assembly and incorporation of data from

new maintenance testing equipment such as M0 VATS should lead to

further program improvements.

Five violations were identified:

a. Severity Level IV violation for failing to provide procedural

criteria to examine reactor coolant piping for leakage and

assure proper functioning of check valves. (85 22)

b. Severity Level V violation for failure to test valves to

assure proper functioning of remote valve position

indicators. (84-31)

c. Severity Level V violation for failure to document the name

of individuals recording data. (85-10)

d. Severity Level V violation for failure to implement the

requirements of EMP 115.011 during performance of the monthly

battery inspection. (85-21)

e. Severity Level V violation for failure to follow procedures

for hanger inspection. (85-23)

2. Conclusion

Category: 2

3. Board Recommendation

No change in NRC inspection activity is recommended.

E. Fire Protection

1. Analysis

During the evaluation period, inspections were conducted by the

resident and regional staffs in the area of fire prevention and

protection to assess the status of the licensee's implementation

of the requirements and commitments of 10 CFR 50, Appendix R.

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The licensee attended the Appendix R workshop during the Spring of

1984. As a result of the information gained at the workshop, the

licensee decided to perform a complete review of the fire

protection program. At the time of the June 1985 inspection the

licensee had not completed their entire review.

However, the licensee did not properly implement the requirements

of 10 CFR 50, Appendix R Sections III.G and III.L. The approach

to' resolution of the technical Appendix R issues indicated that an

understanding of these issues was lacking, and the attempts to

~ meet the Appendix R fire protection requirements were lacking

thoroughness. This was demonstrated by the fact that the

licensee's Appendix R analysis did not address the following

requirements:

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Demonstrate that the alternative shutdown capability provided

for the control room, cable spreading room, and relay room

could achieve and maintain cold shutdown conditions within

72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

- Identify all the equipment, components, and cabling required

to achieve and maintain hot standby and cold shutdown

, conditions.

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The circuit analysis did not follow NRC guidance with respect

to fuse / breaker coordination, common electrical enclosures,

and spurious signals.

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Identify the analysis assumptions associated with the local

control of safe shutdown systems for fires which affect plant

c areas outside the control room complex, nor did the analysis

justify the timeliness associated with these local controls.

The licensee committed to perform an additional analysis

addressing the above discrepancies and submit the results of this

analysis along with the results of their Appendix R reanalysis to

the region and NRR by the end of the second quarter in 1986. In

addition, the licensee on May 29, 1985, identified 11 Appendix R

modifications affecting 23 plant areas to the NRC. On June 21,

1985, the licensee committed to a special two-hour roving fire

watch in the affected plant areas until the required modifications

are fully implemented.

The licensee's routine fire prevention / protection program were

found to be satisfactory except in the areas of fire barrier and

fire door integrity. The plant fire protection extinguishing

systems and detection systems were found to be in service, and the

organization and staffing of.the plant fire brigade met the NRC

guidelines. The fire brigade training and drills for the fire

brigade members met the frequency specified by the procedures and

the NRC guidelines.

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In general,.with the exception of the Appendix R discrepancies,

the site management involvement and control in assuring quality in

the routine plant fire prevention / protection program was adequate

and had resulted in increased staffing _and an upgraded training

program in the fire protection area. Software computer modifica-

tions.were implemented to assist in fire detection and location.

Two violations were identified. Additionally, four potential

violations and one potential deviation against the licensee's

implementation of Appendix R were identified and are currently

under review for escalated enforcement.

a. Severity Level IV violation for failure to prevent . fire

barrier degradation. (84-35)

.b. Severity Level IV violation for failure to establish' required

fire watch for inoperable fire door. (84-37)

2. Conclusion

Category: 3

3. Board Recommendations

The Board noted that-some NRC inspection findings occurred prior

to completion of the licensee's Appendix R reanalysis; however,

the licensee's corrective actions displayed good initiative. The

board recommends continued devotion of Licensee resources necessary

to provide early resolution of remaining issues. Increased NRC

inspection activity is recommended.

F. Emergency Preparedness

1. Analysis.

During the evaluation period, inspections were performed by the

, resident ind regional staffs. Inspections addressed the Early

Warning Siren System (EWSS), implementation of the radiological

emergency olan and procedures, and observation of a full scale

emergency preparedness exercise.

. The annual emergency preparedness exercise disclosed no signifi-

cant adverse finding in the licensee's emergency organization and

staffing. An adequately staffed corporate emergency response and

planning organization ~ routinely provided support to the plant.

Key positions in the corporate and plant emergency response

organizations were filled. Corporate management continued to

demonstrate a strong commitment to maintenance of an effective

emergency response program. Corporate management was directly

4

involved in the 1985 annual emergency preparedness exercise and

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followup critique. The licensee continues to promptly and

effectively respond to NRC initiatives regarding emergency

preparedness issues.

The licensee continued to demonstrate a strong commitment to

emergency response training. Accordingly, the 1985 annual

emergency preparedness exercise disclosed that personnel assigned

to the emergency response organizations were adequately trained

and demonstrated the required familiarity with the designated

areas of emergency response. Emergency preparedness familiariza-

tion training was conducted in accordince with the emergency

response plan and implementing procedures. As a result, emergency

response personnel were cognizant of their responsibilities and

authorities and demonstrated a full understanding of their

assigned functions during simulated emergency events.

The essential elements of emergency response, demonstrated during

the referenced exercise, were determined to be acceptable.

Observation and critique of the annual emergency preparedness

exercise disclosed that the Emergency Preparedness Plan and

procedures could be effectively implemented by the licensee,

although several minor areas for improvement were observed by the

licensee and NRC. These items were formally documented and the

licensee committed to correction consistent with regulatory -

requirements and guidance.

Siren test procedures and guidelines had been implemented and

assured that operation of the early warning siren system (EWSS)

was consistent with the licensee's prompt notification require-

ments.

During routine operations, however, it was noted that the Shift

Supervisor failed to promptly classify and declare a Notification

of Unusual Event (NOUE), and initiate notification of offsite

organizations and agencies attending loss of both emergency diesel

generators for greater than one hour. Upon recognition of the

arror, required declaration and notifications were made. This

violation was reviewed and closed by the resident staff. The

violation was not indicative of a programmatic breakdown.

Severity Level IV violation for failure to promptly declare

an NOUE and initiate notification of offsite organizations.

(85-21)

2. Conclusion

Category: 1

3. Board Recommendation

Decreased NRC inspection activity is reconnended.

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G. Security and Safeguards

1. Analysis

During the evaluation period, inspections were performed by the

resident and regional staffs. Security force staffing was

adequate and consistent with that of plants of similar size. The

security staff had been satisfactorily trained to perform required

duties. The training program was intensive, innovative, and

produced a security force of high quality. Members of the

security force who were interviewed are highly motivated and very

knowledgeable of their duties and responsibilities. The security

force and plant personnel interacted well as indicated by

observation during personnel processing at shift change and

further evidenced by cooperation given security during non-routine

security situations. Plant personnel displayed good security

awareness as was evident by the low number of security incidents

dealing with lost badges, inadequate escorts, and misuse.of the

access control systems.

Site management demonstrated a supportive role in maintaining the

security program through their knowledge of security requirements

and actions and approval of program improvements.

Design work had been completed and work was in progress for the

installation of a low-frequency grounding network to reduce

disturbances on electronic intrusion monitoring systems. These

modifications should enhance this system's capability to

discriminate between actual intrusions and minor disturbances.

Work was also begun on security computer upgrades to enhance

personnel accountability within the plant site.

Two violations were identified. These violations are not

indicative of a breakdown in the licensee's overall security

program. The licensee provided prompt and effective corrective

ac ion for issues raised.

a. Severity Level IV violation for failure of the access control

officer to remain within a bullet-resistant enclosure.

(85-14)

b. Severity Level V violation for inadequate test procedure of

intrusion detection systems. (85-33)

2. Conclusion

Category: 1

3. Board Recommendation

The Board noted that the spirit and morale of the Security

organization is exemplary. Decreased NRC inspection activity is

recommended,

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H. Outages

1. Analysis

,

During the evaluation period, inspections were performed by the

resident and regional staffs. Refueling activities observed from

the control room, refueling floor, and spent fuel pool were found

to be satisfactory.

The licensee commenced the first refueling outage on September 28,

1984. Major activities accomplished during the 83 day outage were

completion of the TP' and Licensing Conditions modifications;

inspection and maintenance of the main turbine, main generator

rotor, and selected vc ves; 100 percent eddy current testing of

steam generator tubes; and three year maintenance on reactor

coolant pumps "A" and "B" seals. The activities associated with

refueling occurred without major problems. Some problems were

incurred during the outage with scheduling and interface

conflicts. As a result, licensee management established an

extensive ' lessons learned" program with an action item list that

required tracking and responses from affected areas.

The plant commenced the second refueling outage on October 5,

1985. This third fuel loading placed the core in an 18 month fuel

cycle. Major work accomplished during this 72 day outage included

changes to the condensate system to provide constant speed pumps

and flow control valves, main turbine five year inspection,

rotopeening and 100 percent inspection of steam generator tubes,

sludge lancing and internal inspection of the steam generator

secondary side, modifications to the isophase bus duct, removal of

the boron injection tank, equipment upgrades for environmental

qualification, and Appendix R modifications.

The licensee has strengthened the planning and scheduling group by

adding SRO, HP, and administrative staff personnel to assist in

scheduling. These changes significantly improved the interface

between operations, maintenance, and health physics.

The second refueling outage demonstrated that management attention

directed toward preventing problems that occurred in the first

outage was successful. This outage showed good preplanning,

coordination and prior training for the activities that were

accomplishec The startup, low power physics testing, and power

ascension after the outage was closely monitored by the staff and

licensee management. The deliberate and methodical startup

without problems was indicative of good management control.

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In August 1984, while performing spent fuel rack drag testing of

the new spent fuel racks, the licensee failed to adequately

calibrate the load cell, to perform the pre-operational crane

inspection, and to have a qualified crane operator during crane

usage. These violations are indicated as (a) and (b) below.

Three violations were identified.

a. Severity Level IV violation for failure to perform adequate

calibration of load cell used for spent fuel rack drag

testing. (84-25)

b. Severity Level IV violation for failure to have a qualified

crane operator during crane use and to perform pre-opera-

tional crane inspections. (84-25)

c. Severity Level V violation for failure to follow procedure

during receipt, inspection, and storage of new fuel assemblies.

(84-29)

2. Conclusion

Category: 2

3. Board Recommendations

The Board noted 'that innovative management is providing an

improving trend in this area. No change in NRC inspection

activity is reccmmended.

1. Quality Programs and Administrative Controls Affecting Quality

i

1. Analysis

During this evaluation period, routine and special inspections

were performed by the resident and regional staffs. The following

areas were reviewed: QA program, QA/QC administration, audits,

procurement, receipt, storage and handling, surveillance testing

and calibration, measuring and test equipment, offsite support

staff, and offsite review committee.

The Qual.ity Assurance Department maintained an adequate QA program

with the exception of one continuing program deficiency identified

in the previous SALP period. This problem was the prompt

resolution of audit findings. The July 1984 inspection indicated

that the QA audit organization was not providing corrective action

due dates, resolution of findings were not well managed by site QA

staff, and escalation procedures were inadequate. These concerns

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were expressed to . licensee man'agement during the inspection 'and-

also during a telephone conversation conducted- on July '16.1984,

'

with the Vice President - Nuclear Operations (VP-NO). .In response

to these concerns, the .VP-NO stated that a management directive

'(MD-16) would be revised to clarify what measures were'needed to

assure _that conditions adverse to quality were promptly corrected.-

A reinspection in this area identified that MD-16'had been revised

'

but some responses to QA findings were < still being delayed; .

~

however, this delay was administrative ~ (i.e., mail delays).

Continued implementation of MD-16 should prevent ~ future problems

in this area.

All pha'ses of material control met or exceeded regulatory require-

.ments. Licensee response to QA findings in this area was timely

with adequate corrective action.

The ~ surveillance testing and calibration program was well

organized and executed. Personnel were well trained and records

properly maintained. The measuring and test equipment (M&TE)

program exhibited several weaknesses. The. system devised to

control and account for M&TE was weak with respect to equipment.

• status lists, which were often found to be inaccurate. Excessive

time was taken to complete evaluations of out-of-tolerance field

standards and lab personnel were unable to demonstrate the'

completion status of individual evaluations. These problems were ,

the basis for violation b. below.

The offsite support staff was well organized. Communication was

good between the support staff and the site, and the support staff

was cognizant of on-going plant conditions. The ' staff was

professional and well trained. Responsibility and line of-

..

authority were clearly defined in procedures and policy manuals.

The offsite review comittee activities generally met organiza-

tional and administrative requirements. Potential discrepancies

were resolved in a timely manner. The committee had demonstrated

a high degree of resolve to conscientiously review the technical

merit of all review comitments, despite the enormous volume.

This was shown by meeting more often than required and by

delegating review responsibilities.

p' The licensee was developing a QA finding trend program to provide

improved methods for classifying and tracking deficiencies. The

program should provide assistance in identification and control of

recurring items. It should additionally provide better informa-

tion to management for problem identification. It is anticipated

that the program will be fully implemented in early 1986,

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The licensee has procedural controls that require that a safety

review and evaluation be performed prior to procedure approval and

implementation. An example was identified where this process was

not followed and is the basis for violation a. below.

Two violations were identified:

a. Severity Level IV violation for failure to provide documented

safety review and evaluation prior to procedural approval.and

implementation. (84-25)

b. Severity Level IV violation for failure to establish measures

to assure prompt evaluations of out-of-calibration measuring

and test equipment. (85-11)

l

2. Conclusion

Category: 2

3. Board Recommendations

The Board noted good management initiative in this area, however

weakness in the corrective action area should be monitored closely

by the Licensee and NRC to insure'the initiatives are effective in

producing the desired improvements. No change in NRC inspection

activity is recommended.

J. Licensing Activities

! 1. Analysis

The performance evaluation was based on NRC evaluation of the

licensee's performance in support of licensing actions involving a

significant level of activity during the current evaluation

period.

In general, management involvement continued to improve. There

was evidence of prior planning and a:signment of priorities, ,

especially in the area of refueling activities as discussed in ,

Section H. Good management involvement and control was also

evident in the areas of spent fuel pool reracking, response to

Generic Letter 83-28, and the rod control system electrical prob-

r- lems. The area where management involvement and control needs

to be improved was in contractor oversight. Two license amend-

ments were examples of this. Shutdown margin for modes 3, 4, and

5 and thermal design flow reduction were both changed after

submittal to the NRC. This was due to the contractor's analyses

being incorrect and not up-to-date.

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The licensee had a good understanding of the technical and safety

issues, while proposed resolutions were conservative and sound.

Examples of this . technical approach and resolution were the

installation of the P-9 interlock and the power lockout capability i

for the RHR suction line isolation valve. The RHR suction line

isolation valves power lockout capability was an especially

difficult area to resolve due to the conflicting impacts of fire

protection, low' pressure system protection, and low temperature

overpressure protection. Overall, an improvement had been seen in

this area in both quantity and quality of submittals describing

the licensee's~ approach to resolution of technical issues from a

safety standpoint. There were just two instances where the

licensee's approach was lacking. In one instance, full load

rejection capability, the licensee's resolution was very good, but

the initial submittal did not contain a sufficient description of

the resolution. In the other instance, RCS flow measurement

uncertainty change, the submittal had to be withdrawn because the

analysis was based on a 4-loop Westinghouse plant instead of a

3-loop.

The licensee had been consistently responsive to NRC initiatives.

The licensee met deadlines with respect to requests for additional

information, such as confirmatory order requirements for

NUREG-0737 Supplement 1 Technical Specification submittals

including special reports, and environmental qualification of

electrical equipment. The responses were technically sound and

thorough in almost all cases. The licensee had also been working

to improve their significant hazards determinations with

noticeable improvement.

The licensee has shown improvement in all areas of the licensing

activities.

2. Conclusion

Category: 2

3. Board Recommendations

The Board recognizes an improving trend in this area.

K. Training

1. Analysis

During the evaluation period, inspections were performed by the

resident and regional inspection staffs. Training was not

evaluated separately during the previous SALP assessment period

but was discussed under the various functional areas such as

operations, maintenance, etc.

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A special training assessment that was conducted the week of

February 11, 1985, concluded that the plant training programs were-

adequate to support the licensed activities. Management attention

and involvement was apparent by their support of programs and

staffing increases in the functional training areas. General

employee training was adequate and ongoing. Training of

contractor personnel during outages appeared well planned and

organized.

A limited training review was conducted on July 22 and 23, 1985,

by NRC staff from headquarters and a Region II inspector. Of

particular interest was the involvement of licensee training in

the February 28, 1985, high startup rate and subsequent positive

rate reactor trip incident. The initiating factor in the

incident was determined to be an incorrect estimated critical

position (ECP) calculation performed by the shift technical

advisor (STA). In addition, senior reactor operator (SRO)

supervised on-the-job training was being conducted. The SR0

assumed that the STA's ECP calculation was correct, and failed to

observe instrumentation while the trainee was pulling control rods

to 100 steps (reactor tripped at 75 steps). Training implications

in the above incident include the need for the licensee Training

Department to (1) maintain administrative control over sequencing

the total training program so as not to allow a trainee to perform

a critical task while in the initial training stage, and

(2) ensure that SR0s are properly prepared for duties and

responsibilities as on-the-job training instructors. The

licensee's corrective actions included clarifying the techniques

for calculating an ECP and developing a training segment to

address the incident. Further, licensee management, in a letter

dated November 19, 1985, asserted that on-the-job training is now

a cooperative effort between the Operations and Training

Department.

The licensee had received INP0 accreditation for the Operator,

Health Physics and Chemistry Programs. The licensee had a site

specific simulator in place and had increased the time for

operator and shift technical advisors (STAS) on the simulator with

more emphasis on events and problems occurring at the plant. The

simulator was also used in the 1985 emergency preparedness drill

to provide more realism to the drill. The training department was

in the process of developing a training program for engineers and

managers. A comprehensive training program, which follows INPO

guidelines, had been developed for mechanics, electricians, and

instrumentation and control technicians. The mechanical,

instrumentation and control and electrical maintenance programs

are scheduled for INP0 accreditation review in 1986. Maintenance

personnel training has been expanded to include training on motor

operated valve analysis test system (M0 VATS), infrared analysis,

and ferrographic oil analysis as discussed in Section C.

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The security staff training program was intensive, innovative, and

produced a security - force of high quality as discussed in

Section G.

The licensee continued to demonstrate a strong commitment to

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emergency response training as discussed in Section F.

Management attention in the fire protection area resulted in an

upgraded training program. Regular training drills were conducted

for fire brigade members and annual realistic training was

corducted for all brigade members at the South Carolina Fire

Academy. Programs were being developed for training of fire

protection technicians and tracking of all areas. These programs

are scheduled to be implemented in early 1986.

The _NRC conducted three site visits to examine replacement

licensee candidates. Sixty percent of the Reactor Operators (R0s)

(12 of 20) and 67 percent of the Senior Reactor Operators (SR0s)

(8 of 12) passed the examinations. These percentages are slightly

below the natio al average.

One violation wa identified.

Severity Leal IV violation for failure to insure that a

control room supervisor possessed a valid Senior Reactor

Operators li anse. (85-13)

2. lAnclusion

Category: 2

3. Board Recommendation

The Board noted that significant resources have been expended on

the training facility and program. However, the low pass rate on

licensing exams when compared to the national average can be

attributed to training and should see improvement during the next

SALP period. No change in NRC inspection activity is recommended.

V. SUPPORTING DATA AND SUPMARIES

A. Licensee Activities

During this evaluation period, major licensee activities included

normal power operations, two refueling outages, and extensive

modifications and repairs as follows:

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First Refueling - September 28, 1984

Upgrading Incore RTD circuitry

Modification to cold overpressure protection system (COPS)

Relocation of RCS wide range pressure transmitters outside

containment

Relocation of Diesel Generator instrumentation due to

vibration

Added acoustical monitors to pressurizer safety valves

Alarm lights in high noise areas

Alternate source range detector to shutdown panel

Modifications of main generator rotor

100% eddy current testing of steam generator t"bes

Second Refueling - October 5, 1985

Modifications to condensate system-

Main turbine five year inspection

Rotopeening of steam generator tubes

Boron injection tank removal

Steam generator secondary maintenance

Modifications to isophase bus duct

Appendix R modifications to B diesel generator

EQ limit switch replacement on heating, ventilation,

and air conditioning (HVAC) dampers

Reactor building tendon inspection

B. Inspection Activities

During the evaluation period, routine inspections were performed by the

resident and regional -inspection staffs. In addition, a number of

special team assessments and inspections were conducted during this

period:

plant operatior.s team inspections

radiological control / mobile laboratory inspection

training assessment

.

containment integrated leak rate testing

I Salem ATWS event inspection

containment tendon surveillance inspection

fire protection team inspection

emergency preparedness

early warning siren system inspection

quality assurance inspection

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C. Licensing Activities

The basis for the appraisal in this area 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. Actions that

involved a significant level of activity during the current rating

period are listed below:

Major Licensing Actions

- Low Temperature Overpressure Protection System

- Spent Fuel Pool Rerack

- P-9 Interlock

-

Thermal Design Flow Reduction

-

Full Load Rejection Capability

- Class IE and Non-1E Cable Tray Separation '

- Control of Heavy Loads, Phases I & II

-

Electrical Rod Control Problems

- Response to GL 83-28, Salem ATWS

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Shutdown Margin, Modes 3, 4, & 5

-

BIT Tank Removal

-

Type C Leak Rate Tests

-

Service Water Intake Structure

-

Fire Protection

-

ICC Instrumentation

-

ASME Section XI Relief Requests

License Amendments Issued

Amend.

No. Date Description

25 July 2, 1984 Surveillance requirement and action

statement added to Hydrogen Monitors

T.S.

26 Sept. 24, 1984 Changed the low temperature

overpressure protection system from

a PORV-system to a RHR relief valve

system

27 Sept. 27, 1984 Spent Fuel Pool Rerack

28 Oct. 12, 1984 Changed time constants T1 and T in

overpressure and overtemperature DT

equations

29 Oct. 15, 1984 Power lockouts RHR suction line

isolation valves

30 Oct. 24, 1984 Reactor Bldg Cooling Unit Fan Motors

Eddy Current brakes - Containment

Penetration Conductor Overcurrent

Protection Device test (CPCOPD)

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31 Oct. 24, 1984 MOV Thermal Overloads

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32 Nov. 8, 1984 Seismic Monitoring Instrumentation

33 Nov. 13, 1984 Reactor Bldg Sump. Iso valves - CPCOPD

34 Nov. 30, 1984 P-9 interlock

~35 Jan 2, 1985 10 CFR 50.73 Reporting Requirements

36 Jan. 24, 1985 Clarificatior, of SR0 qualification

requirements

37 Jan. 31, 1985 RCS Fl ow - adds Region III of

operation

38 April 1, 1985 Non-class IE cable requirements

39 April 1, 1985 TS change repurge exhaust monitor

40 April 30, 1985 Change in overtemp delta-T trip -

setpoint equation and in steam

generator water level low-low trip

setpoint

41 May 6, 1985 Deleted snubber TS Tables

42 May 14, 1985 Modified surveillance freq. for

Spent Fuel Pool Ventilation System

43 June 24, 1985 Permits 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> for repair before

shutdown, when more than one control

rod is electrically inoperable

44 August 26, 1985 Deletes Boron Injection System

45 Sept. 25, 1985 Thermal Design Flow Reduction of

1.9%

46 Nov. 7, 1985 S/D Margin - Modes 3, 4, and 5

47 Nov. 23, 1985 Type C Leak Tests

48 Dec. 20, 1985 Service Water Intake Structure

D. Investigation and Allegation Review

Two allegations were received during the assessment period. Neither

was of any safety or health significance.

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E. Escalated Enforcement Actions

1. Civil Penalties

Severity Level III violation for system alignment errors rendering

both trains low head safety injection inoperable on August 23,

1985, and omitted jumpers from the overpower delta temperature

trip circuits since initial plant startup in October 1982. Civil

Penalty: $50,000. (Issued Date: January 6, 1986)

2. Orders

None.

F. Management Conferences Held During the Evaluation Period

An enforcement conference was held at the corporate office on August 6,

1985, to discuss deficiencies in the implementation of the fire

protection plan.

An enforcement conference was held in the Region II office on

October 8, 1985, to discuss isolation of both trains of low head safety

injection, the jumpers omitted from overpower delta temperature circuit

cards, and .the construction strainers in the suction of both reactor

building spray pumps.

G. Confirmation of Action Letters

None.

H. Review of Licensee Event Reports and 10 CFR 21 Reports

Submitted by the Licensee

1. Licensee Event Reports (LERs)

During the evaluation period, a sample of 46 LERs submitted by the

licensee were evaluated by the NRC staff to detennine the event

cause.

The distribution of these events were as follows:

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Cause Number

Component Failure 14

l Design 5

Construction, Fabrication,

or Installation 0

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Personnel

- Operating Activity. 5

- Maintenance Activity 5

- Test / Calibration Activity 11

- Other 3

Out of Calibration- 0

Other 3

TOTAL 46

2. 10 CFR Part 21 Reports84-029 Defective Brown Boveri Speed & Transfer Switch

'84-030 Defective HVAC Unit

85-016 Feedwater Isolation Valve

85-017 Separation of Vital Power Cable Trays85-032 Failure of Diesel Generator Exciter Regulator

I. Enforcement Activity

FUNCTIONAL- NUMBER OF DEVIATIONS AND VIOLATIONS

AREA IN EACH SEVERITY LEVEL

0 V IV III II I

Plant Operations 1 10 1

Radiological Controls 1 1

Maintenance 1 2

Surveillance 4 1

Fire Protection 2

Emergency Preparedness 1

Security 1 1

Refueling / Outages 1 2

Quality Assurance and 2

Administrative Controls

Affecting Quality

Licensing Activities

Training 1

TOTAL 9 23 1

J. Reactor Trips

Eleven unplanned trips and six manual shutdowns occurred during this

evaluation period. The unplanned trips are listed below:

1. July 29, 1984 - Trip on Lo-Lo Steam Generator Level B caused by

feedwater control valve erratic operation. The erratic operation

of the valve was attributed to the deadband adjustment on the

control valve's volume booster. Corrective action taken to

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prevent recurrence was to adjust the volume booster so that it

would not function except during large signal demands.

2. September 28, 1984 - During power reduction for initial refueling,

intermediate range (N-35) High Flux Trip Bistable did not reset

prior to power being reduced to less than 10%. The intermediate

range high flux trip setpoint has been adjusted to a higher power

level.

3. December 27, 1984 - Trip caused by improper connection of test

equipment. An I&C technician advertently imposed a test signal on

the output of N-44 power range channel. This signal caused the

feedwater control valves to close. This condition in coincident

with B Steam Generator low level bistables being tripped caused

the reactor trip. Corrective action taken to prevent recurrence

was to train I&C technicians on the installation and use of test

equipment on plant equipment.

4. February 28, 1985 - A positive rate trip occurred from approxi-

mately 6% power following a premature power range criticality.

The reactor protective system functioned as required. The

premature criticality was caused primarily by the failure of the

shift supervisor to be fully aware of plant status, to closely

monitor instrumentation and to anticipate criticality whenever

rods were being withdrawn as required by station procedures.

Contributing to the failure was a calculated estimated critical

position, which was in error by more than 100 rod steps. Improved

procedures have been provided.

5. March 17,1985 - Trip caused by A main steam isolation valve

(MSIV) closing during testing. A faulty test switch caused the

closure of A MSIV which cause a shrinkage of A Steam Generator

level to the 10-10 level setpoint causing the reactor trip.

Corrective action taken was to replace the test switch and test

all MSIVs.

6. April 18, 1985 - Trip caused by dropped rod during troubleshooting

of rod control system. The dropped rod caused a rriactor trip on

the power range negative rate trip signal. The rod control system

failure was determined to be a defective slave cycler counter

card. The card was replaced and a preventive maintenance program

was established for the rod control system cabinets to prevent

recurrence.

7. April 29,1985 - Trip on Lo-Lo Steam Generator Level B caused by

feedwater isolation due to a low feedwater temperature and a low

feedwater flow condition. The feedwater transients during a down

power ramp were attributed to two failures. First, the load

decrease circuitry for the Main Turbine failed to function

properly and this condition was further complicated by a failure

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of the Steam Dump System to respond properly. Corrective action

to prevent recurrence was to replace the load decrease circuit

board and repair the steam dump system, along with a scheduled

preventive maintenance program.

8. August 20, 1985 - Reactor trip from 100% power on a false signal

for loss of reactor coolant system flow. An I&C Technician

replacing FT-345 caused a pressure spike to redundant flow trans-

mitters.

9. August 24, 1985 - Reactor tripped from 10% power on Intermediate

Range High Flux. Following replacement N36 detector, setpoints

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were not properly reset prior to a power increase. The licensee

initiated improved procedural controls to ensure hold points are

clearly Jefined and tracked.

10. August 24, 1985 - Reactor tripped from 25% power on Low Low Level

in steam generator A. Trip was caused by feedwater isolation on

low feedwater temperature and flow during power ascension.

Feedwater isolation was caused by a transient in the dearator tank

level. The licensee has implemented procedural controls and

increased operator training to reduce the potential for similar

events.

11. September 20, 1985 - Trip from turbine trip caused by loss of all

main feedwater pumps during testing of the condensate system. The

loss of all feedwater pumps was caused by the loss of all

condensate pumps by unknown cause during condensate pump testing.

Corrective action to prevent recurrence was to require review and

approval of the Director of Nuclear Plant Operations for special

or integrated testing outside the normal surveillance and

maintenance testing program,

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