IR 05000317/1986099
| ML20236V871 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 12/03/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20236V856 | List: |
| References | |
| 50-317-86-99, 50-318-86-99, NUDOCS 8712070142 | |
| Download: ML20236V871 (76) | |
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d U. S. NUCLEAR REGULATORY COMMISSION
REGION I
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NO. 50-317/86-99; 50-318/86-99 BALTIMORE GAS AND ELECTRIC COMPANY CALVERT CLIFFS NUCLEAR POWER PLANT ASSESSMENT PERIOD: May 1, 1986 - August 31, 1987 DR 712070149 973g99 ADOCK 05000317 PDR
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SUMMARY ........... T2-1 i a
TABLE 3 - ENFORCEMENT ACTIVITY ..... ... .... T3-1 TABLE 4 - LICENSEE EVENT REPORTS . . . .......... T4-1 TABLE 5 - SUMMARY OF LICENSING ACTIVITIES ... ..... T5-1 i
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i I. INTRODUCTION l Purpose and Overview-The Systematic Assessment of Licensee Performance (SALP) is an inte-grated NRC staff effort to collect the available observations and data on a periodic basis and to evaluate licensee performance based upon this informatio The SALP program lis supplemental to normal
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regulatory processes used to ensure compliance to NRC rules and regulations. The SALP program is intended to be sufficiently. diag-
- nostic to provide a rational basis for allocating NRC. resources and to provide meaningful guidance .to the licensee's management to pro-mote quality and safety of plant operatio The NRC SALP Board, composed of the staff members listed below, met on October 16, 1987 to review the collection of performance observa-tions and data and to assess licensee performance in accordance with 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 repor This report is the SALP Board's assessment of the licensee's safety performance at the Calvert Cliffs Nuclear Power Plant for the period May 1,1986 through August 31, 1987. It is noted that the summary findings and totals reflect a 16 month assessment perio The SALP Board was comprised of the following:
Chairman W. F. Kane, Director, Division of Reactor Projects (DRP)
Members T. Martin, Director, Division of Radiation Safety and Safeguards (DRSS) (Part-Time)
' Johnston, Acting Director, Division of Reactor Safety (DRS)
(Part-Time)
R. A. Capra, Acting Director, Project Directorate I-1, NRR S. J. Collins, Deputy Director, DRP (Part-Time)
R. R. Bellamy, Chief, Emergency Preparedness and Radiological Protection Branch, DRSS (Part-Time)
J. P. Durr, Acting Deputy Director, DRS (Part-Time)
J. H. Joyner, Chief, Nuclear Materials Safety and Safeguards Branch, DRSS (Part-Time)
L. E. Tripp, Chief, Reactor Projects Section (RPS) No. 3A, DRP Foley, Senior Resident Inspector, Calvert Cliffs Nuclear Power Plant S. A. McNeill, Project Manager, Project Directorate I-1, NRR
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Other Attendees (non-voting)
D. C. Trimble, Resident Inspector, Calvert Cliffs NPP D. F. Limroth, Project Engineer, RPS 3A, DRF (Part-Time)
A. B. Sidpara, Reactor Engineer, RPS 3A, DRP (Part-Tirue)
I'. A. Carpenter, Reactor Engineer, RPS 3C, DRP (Part-Time)
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. J I CRITERIA 4 l
Licensee performance is assessed in selected functional areas. Functional '
areas normally represent areas significant to nuclear safety and the environmen j
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One or more of the following evaluation criteria were used to assess each i are ] Management involvement and control in assuring qualit . Approach to resolution of technical issues from a safety standpoin . Responsiveness to NRC initiative . Enforcement histor . Operation events (including response to, analysis of, and corrective actions for). Staffing (including management). Training and qualification effectiveness .
However, the SALP Board is not limited to these criteria and others may have been used where appropriat Based upon the SALP Board assessment each functional area evaluated is classified into one of three performance categorie The definitions of these performance categories are:
Category 1: Reduced NRC attention may be appropriate. Liccnsee manage-ment attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used such that a high level of performance with respect to operational safety is being achieve Category 2: NRC attention should be maintained at normal levels. Licen-see management attention and involvement are evident and concerned with ;
nuclear safety; licensee resources are adequate and reasonably effective
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so that satisfactory performance with respect to operational safety is <
being achieve Category 3: Both NRC and licensee attention should be increased. Licen-see management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear strained or not effectively used such that minimally satisfactory perform-ance with respect to operational safety is being achieve l I
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The SALP Board may determine to include an appraisal of the performance trend of a functional area. Normally, this performance trend is only used where both a definite trend of performance is discernible to the Board and the Board believes that continuation of the trend may result in a change of performance leve Improving (declining) trend is defined as:
l Licensee performance was determined to be improving (declining) near the
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close of the assessment perio ,
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III. SUMMARY OF RESULTS Overall Summary Our assessment of your performance during this assessment indicates that three broad problem areas were evident; (1) management control of interfaces between departments (i.e., dissemination of engineering-requirements to the field, integration of systems engineers into the plant staff, and functioning together as a team), (2) insuffi.cient resources in the maintenance and engineering departments hampering their ability to support operations (slow resolution of recurren equipment problems), and (3)' ineffective use of available tools to recognize emerging plant problems (i.e. QA audits, lack of independ-ence c'f oversight committees).
There were. additional weaknesses in surveillance testing, communica-tion of results to appropriate levels of management, and adequate followup / resolution of indicators of potential equipment operability problems. As a result, optimal equipment operability / reliability was not always achieved. Furthermore, post-maintenance and surveillance testing appeared to be oriented toward demonstrating Technical Spec-ification compliance rather than assuring equipment reliabilit Existing systems have achieved limited success in prioritizing main-tenance activities and resolving long standing deficiencie The failure to demonstrate timely decision making and protective action recommendations in the emergency planning area indicated reduced attention to this function. Housekeeping was observed to deteriorate during outages, particularly in individual contaminated area In addition to being hindered by interface, coordination, communication, and resource problems, engineering appeared to be overloaded with better direction and guidance needed regarding prioritizatio Notwithstanding the weaknesses discussed above, notable areas of strength were observed. These include (1) the Trip Reduction Task Force and a Trip Evaluation Review Group that were instrumental in helping prevent trips from recurrent causes and provided root cause i diagnosis of the cause(s) of feed pump trips, (2) performance of licensed operators, (3) the in plant radiation protection program which continued to achieve good control of exposures and a strong ALARA effort, (4) the 10 year In-Service Inspection program which was l well managed and displayed good initiative in implementing state- I of-the-art techniques that often exceeded regulatory requirements, (5) a loss of off-site power event which was handled well, (6) well
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coordinated and managed refueling and outage activities, (7) consoli- 1 dation and movement of. engineering functions to the site, (8) the i technical ability, credibility and effectiveness of the QA department by recent initiatives to add more technically oriented staff and to use outside consultants to assess performance in complex areas, and (9) well trained and highly motivated plant employees and first line supervisor In summary, although significant areas of strength were noted, overall performance slipped during this period. Recognition and resolution of deficiencies, including timeliness and comprehensiveness of root cause analyses, continued to be a problem although some progress was noted toward the end of the period. Improved interfaces between the Engineering, Operations and Maintenance Departments to assure that they work together - effectively as a team is considered to be the primary area for improvement B. Background Licensee Activities Unit 1 l Unit I was at full reactor power (825 MWe) at the beginning of
- the assessment period. From May 16 to May 19, 1986 the unit was at reduced power (790 MWe) for installation of e new type of traveling screen. On June 20, power was reduced to 1% to permit a containment entry to add oil to No 12A reactor coolant pump upper oil reservoi The unit was returned to 100% power oper-ation on June 22, 198 On July 10, a large influx of jellyfish, crabs, and marine life caused shear pins on the travelling screen motors to shear thus i necessitating a power reductio This was followed by several days where the bay oxygen concentration was below normal causing i increased marine life to accumulate at the intake structure. On i July 20, reactor coolant pump 12B tripped off, due to grounds 1 within a capacitor, also causing a plant trip. The unit was re- !
turned to service the following day.
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On August 3, the licensee reduced power to perform a temperature -
coefficient surveillance. During much of the month of August, ,
licensee personnel spent considerable time in preparation .for the upcoming ten year In-Service Inspection (ISI) and refueling outage scheduled for October 25, 1986. On October 10 an oper-ator mispositioned a condenser off gas discharge valve causing a loss of condenser vacuum and a turbine trip, resulting in a reactor tri During the restart from this trip, the unit tripped again on October 11 from 15% power due to axial flux ;
offse The plant was returned to power operations on :
October 11, 1986 and continued routine operatio !
On October 24, the unit was shut down to commence the 10 year ;
In-Service Inspection and refueling outag The licensee had requested and was granted an emergency Tech-nical Specification change to allow refueling to be conducted without an operable diesel generator specifically assigned to j that uni The unit continued the outage keeping close to '
schedule. Work activities proceeded in a systematic, harmon-ious, ar.d steady manne However, final repair of the No. 12 diesel generator (DG), repairs to the main generator collector and retaining ring and failure of the #11B reactor coolant pump shaft seal all contributed to delays (a few days each) in. outage recovery activitie l l
On December 31, the unit was refueled and ready for startup activities while awaiting resolution of the hydrogen seal and main generator bearing problem Unit I was returned to power operation on January 12, 1987. A i manual trip occurred on January 27 following a loss of instru-ment air pressure due to an operator error in returning the instrument air system to a normal valve alignment at the con-clusion of a system performance tes Two condensate booster ;
pumps were damaged during the event, which delayed unit start up until January 31. On February 1, Unit 1 was manually tripped following a ' turbine run back due to low stator cooling liquid pressure. The manual trip was in anticipation of an automatic trip on high reactor coolant system pressur The unit was returned to power on February On February 7, the unit was removed from the grid to repair an oil leak on a turbine intercept valv t l
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On March 10, the reactor coolant quench tank rupture disk rup- i tured due to a leaky pressurizer safety valve. The unit was subsequently shut down, the safety valves replaced and the pressurizer vent valves repaire The unit was returned to power operations on March 15. During the week of March 23, NRC regional specialists reviewed environmental qualification (EQ)
outstanding items and observed apparent inadequacies in the pro-gra Routine operations continued until April 1, when the licensee identified additional EQ deficiencies and the unit was shut down to correct discrepancie On April 14, 1987, containment spray was inadvertently initiated due to operator error in performing a valve lineu On April 23, 1987, the licensee informed the NRC that certain replacement items (principally threaded fasteners) not fully meeting AMSE code requirements had been used in Class 1, 2, and 3 systems on both unit While the non-conforming parts ap-peared to have been manufactured from the correct material, they-did not meet code requirements with respect to marking, certifi-cation and, in some cases, non-destructive examination. Resolu-tion of this issue coupled with the EQ problems forced Unit 1 to extend the shutdow On May 27, Unit 1 entered Mode 1 after completing surveillance, 4 Mechanical Commercial Quality and EQ post maintenance testin The unit paralleled to the grid, escalated in power on May 28 and remained at 100% power throughout the remainder of the perio Unit 2 Unit 2 began the assessment period at full reactor power (825 MWe). The unit was manually tripped on May 21, 1986 because of a loss of steam generator feed pumps (SGFP). The cause of the loss of the SGFPs was not determined. On May 23, 1986 the unit was paralleled to the gri On May 27, 1986, the unit was automatically tripped due to loss of SGFPs. On May 28, 1986, the unit was paralleled to the grid and remained at 60% power (520 MWe)' to test the SGFP instrumen-tatio Testing of the SGFP instrumentation remained in pro-gress from May 28, 1986 until June ,
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On July 25, a decision was made to shut down due to a enncern regarding increasing vibration trends on reactor coolant pump (RCP) #218. Before shut down commenced, a RCP #21A seal press-ure transmitter flex hose end fitting separated causing. a reactor coolant leak. An Unusual Event was declared as required by the site Emergency Plan due to any forced shut down required by Technical Specifications. The plant remained shut down while industry experts evaluated vibration traces from RCP #218 until August I when the unit was restarte On September 5, the unit tripped due to a failed surge capacitor on No. 21A Reactor Coolant Pump. The unit was returned to operation on September 7. Full power operation continued until September 12 when operators manually tripped the plant due to a loss of No. 21 SGFP and an impending low steam generator water level. The unit was returned to service on September 14; ;
however, power level was maintained at 60% (capacity of a single j feed pump) while the Trip Evaluation and Review Group (TERG)
directed troubleshooting efforts on 21 SGFP control system. On September 18, the unit underwent a controlled shutdown antici-pating the inability to meet a Technical Specification Limiting Condition for Operation Action Statement due to an inoperable emergency diesel generator. With NRC concurrence, the unit was returned to 60% power until September 20 when repairs were com-pleted. Full power operations were resumed. During September l considerable time was devoted to resolving problems associated with No. 12 emergency diesel generator jacket water cooling pressure oscillations, apparently caused by carbon monoxide (CO)
leaking into the cooling system. These efforts extended from September 10 through October Unit 2 operated at full power until February 28, when the unit tripped on low steam generator water level due to a level con-trol system failur The unit had been in operation for 169 consecutive day On March 13, the unit shut down to commence its 10 year In-Service Inspection and Refueling Outag On July 3, the unit was paralleled to the grid and tripped on low steam pressure due to an incorrect rheostat setting in the turbine control circuit initial valve position limite The unit returned to power operations later that day but was limited to reduced power operation due to turbine bearing vibration. It was brought to zero power and a balance shot was performed on July 8; then returned to power on July 9, 198 _ _ - - - - _ - _ _ - _ _ _
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2. Inspection Activities Two NRC resident inspectors were assigned during the inspection period. The total NRC inspection effort for the period was 4018 hours0.0465 days <br />1.116 hours <br />0.00664 weeks <br />0.00153 months <br /> (3013.5 annualized) . with a distribution in the appraisal functional areas as shown in Table ./ (Inspection Hour Summary).
Table 1 lists every NRC inspection conducted at Calvert Cliffs during this perio During the period, NRC team inspections were conducted of the following areas: Actions taken relative to Generic Letter 83-28 in the area of Equipment Classification, Vendor Interface, Post Main-tenance Testing, Surveillance and QA/QC overview (Inspec-tion Report 317/86-10, 318/86-1 Emergency Preparedness Partial Scale Exercise and subse-quent remedial drill (Inspection Report 317/86-14). Follow up of licensee actions relative to deficiencies pre-viously identified regarding Post Accident Sampling capa-bilities (Inspection Report 317/87-03). ' Follow up inspection of Environmental Qualification defic-iencies, Post Maintenance Testing, use of Commercial Grade Fasteners (Inspection Report 317/87-13 and 318/87-14).
Inspection Activities are summarized in Tables 1 and 2. Enforce-ment activities are summarized'in Table This report also discusses " Training and Qualification Effec-tiveness" and " Assurance of Quality" as separate functional area Although these topics, in themselves, are assessed in the other functional areas through their use as criteria, the two areas provide a synopsis. For example, quality assurance effectiveness has been assessed on a day-to-day basis by resi-dent inspectors and as an integral aspect of specialist inspec-tio Although quality work is the responsibility of every ,
employee, one of the management tools to measure this effective- l ness is reliance on quality assurance inspections and audit )
Other major factors that influence quality, such as involvement !
of first-line supervision, safety committees, and work atti-tudes, are discussed in each are The topic of fire protection is not discussed as a separate ,
functional area because of. insufficient inspection activity. The )
available observations on fire protection and housekeeping are )
included in the various relevant functional areas.
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C. Facility Performance Analysis Summary Category Category l Last Period This Period l
Functional Area 10/1/84-4/30/86 05/1/86-08/31/87 Trend Plant Operations 2 2 Improving .; Chemistry and Radiological Controls 1 1 Maintenance 2 2 Surveillance 1 2 Emergency Preparedness 1 2 Security and Safeguards 1 1 Refueling, Outage Management 2 1 Declining Engineering Support .N/A 3 Improving Licensing Activities 1 2 10. Assurance of Quality 2 2 1 Training and Qualification 2 2 Improving Effectiveness l
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.. Unplanned Shutdowns, Plant Trips, and Forced Outages i UNIT 1 l Functional Date & Power Level Description Cause Area 07/20/86 - 100% Loss of flow-and automatic Long-standing reactor trip; reactor repetitive coolant pump surge design capacitor failure deficiency Eng /10/86 - 100% Automatic turbine / reactor trip; loss of condenser vacuum due to auxiliary operator mispositioning an off gas discharge valve Personnel error Op /11/86 - 15% Automatic reactor trip; Inadequate axial flux offset during procedure and start up training Op /27/87 - 100% Manual reactor trip due to imminent steam generator low level caused by loss of instrument air due to the same auxiliary operator as above mispositioning valves during a restoration from a performance test Personnel error Op /01/87 - 70% Manual reactor trip in anticipation of high RCS pressure following a turbine run back caused by low stator cooling liquid Inadequate pressure procedure Op /07/87 Unit was removed from the grid to repair an oil leak '
on the turbine intercept valves 03/10/87 - 100% Controlled shutdown due to a blown RCS quench tank rupture disc caused by leaky code safety valves and Component insufficient spare parts failure Op !
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l Functional l Date & Power Level Description Cause Area 04/01/87.- 100% Controlled shutdown to Implementation correct environmental of inadequate qualification program program deficiencies
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Eng /14/87 - 20% Automatic reactor trip due to high steam generator water 1 level resulting from a transient j on the 16A feedwater heater combined with operator over Personnel error /
boration training Op l 07/23/87 - 100% Total loss of offsite power l
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(tree near relay at offsite transmission line) and overly sensitive protection relay at Calvert Cliffs Other N/A
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UNIT 2
! Functional Date & Power Level Description Cause Area j 05/21/86 - 100% Manual trip due to loss of a steam generator feed Grounds in R4 pump control circuit Main /27/86 - 100% Automatic trip due to loss l of a steam generator feed Grounds in FW !
pump control circuit Main l
'07/25/86 - 100% Controlled shutdown to Random repair RCP seal flex hose component transmitter line failure Eng /05/86 - 100%. Reactor coolant pump surge capacitor failure Design Eng !
09/12/86 - 100% Manual reactor trip due to loss of a feed pump and I impending low steam Grounds in FW generator water level control circuit Main /18/86 Unit underwent a controlled shutdown anticipating the inability to meet a TS LC0 Main /28/87 - 100% Automatic reactor trip on low steam generator level resulting from the failure of control system component Random i.e., downcomer lead / lag component unit' failure 07/03/87 - 15% Automatic reactor trip on low steam pressure due to Inadequate improper setting of the vendor turbine control circuitry guidance Main /08/87 - 60% Controlled shutdown to perform a turbine balance Normal shot maintenance Main _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _
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l Functional Date'& Power level Description Cause Area 07/17/87 - 80% Controlled shutdown to repair vent.and drain valves leaking greater than-T/ Random limit and correct turbine component vibration failure
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07/23/87 - 100% Total loss of offsite power (see Unit 1, same trip) Other N/A-
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i IV. PERFORMANCE ANALYSIS I l
} Plant Operations (40.9%) q Analysis The previous SALP determined the Operations ' area to be Category 2. It concluded that management needed to be more aggressive in j pursuing recognition of safety issues and perform more thorough !
and comprehensive root cause analysis of the issue >
During the beginning of this period, inadequate pursuit of safety issues continued to be a problem as demonstrated by' the three successive reactor trips caused by multiple grounds in the feedwater control system on May 21, May 27, and August 12, 198 The utility responded to the concerns identified in the previous SALP by instituting a " Trip Evaluation Review Group" (TERG) and a " Trip Reduction Task Force". The feed pump trips were subse-quently diagnosed by the TERG. Throughout the period the TERG improved the root cause analysis of operational problem Previously, slow to recognize potential safety issues, the licensee aggressively pursued RCP subharmonic vibration prob-lems, unknown elsewhere in the industry, and an Emergency Diesel generator gassing proble In addition tu pursing root cause analysis of reactor trips (see Engineering section of this report), the licensee recognized the relatively high number of reactor trips (14) during the last period and instituted a Trip Reduction Task Force. Recommenda-tions of the task force appear to be well founded and compre-hensive, however, many which have a high potential for reducing reactor trips were slow to be implemented because of engineering delays and/or resource constraints, i.e, instrument air upgrades and replacing RCP surge capacitor Those recommendations requiring minimal time and resources have been implemente Much of the initial task force momentum now appears to have weakene A significant portion of the 14 reactor trips which occurred during this period would have been averted had all the recommendations been implemented at the start of this period (i.e. , loss of instrument air, axial flux offset, steam genera-tor feed pump trips and two RCP surge capacitor trips).
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During the sixteen month period, five personnel errors occurred within the Operations area (see Table 4). No consistent trends or management inadequacies were evident. Operations Department shift personnel have undergone " team training" sessions on the simulator and in the classroom to improve the communications, coordination and help better use synergism in the recognition of plant transient Two procedural inadequacies resulted in reactor. trips (see Table 4). These were isolated instances and-not indicative of a general proble The large rumber of licensed operators (75 active licenses; 41 SRO's, 34 RO's) allows the Operations Department to utilize experienced licensed individuals to rotate through.a " Procedures Development" group and a " Tagging Authority" group. Procedures Development has been tasked with the improving procedures in general Specific upgrades of each procedure which has' the potential for causing plant trips and improving the Emergency Operating Procedures (EOPs) were in progress. Several other ;
significant initiatives have been implemented to develop l improved procedure l In spite of the noted personnel and procedural errors, operators have responded extremely well to plant events and transient On several occasions, operators prevented unnecessary plant transients due to equipment failures (instrument air malfunc-tions) by their attentiveness and quick response, i.e.,
July 1, 1987, during a loss of No. 13 vital AC Instrument Bus causing a loss of four reactor trip breakers and one channel of ESF. Only by close adherence to procedure and maintaining com-posure did operators determine the plant had not tripped. Dur-ing the total loss of offsite power event, operators and the Operations staff performed professionally, conservatively, and demonstrated the culmination of knowledge by consolidating emergency preparedness training, emergency operation procedure training, knowledge of plant conditions and excellent use of operating instructions in responding to a single event. Opera-tors performed in a normal fashion; calm, deliberate, and per procedure Notwithstanding the licensee responsiveness to the last SALP, improvements in the effectiveness of the Plant Operations Safety Review Committees manner of doing business may be warrante The " organization" might be more effective if (1) the prepond-erance of the attending members were were not directly respon-sible to the chairman; (2) the chairman was less aggressive and influential; (3) recommendations were made independently to the plant manager; and (4) further use of subcommittees was evalu-ated. Further, a recent Quality Assurance Audit also noted this lack of independence and potential for a slight bias towards plant operation.
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l Routine tours of the facility and discussions with workers have indicated a very favorable attitude towards plant management and the compan Management was frequently involved in onsite activities, managers and the Vice President were usually in at-tendance at outage meetings and most managers were routinely seen touring the plant on housekeeping inspections. Periodi-i cally, during outages, all work was stopped in order to stress I
the importance of housekeeping. Generally, housekeeping was good, however, housekeeping areas within the contaminated, con-trolled areas were sometimes poorly maintained. Tools, hoses and debris were found in some areas with boric acid crystals and valve leakag The licensee continued to display a strong commitment toward licensed operator training, evidenced by a high success rate in NRC Reactor Operator (RO) and Senior Reactor Operator (SRO)
examinations. Written and operating examinations were adminis-tered to four SR0s, all of whom passed, and six R0s, one who i
failed the simulator portion of the examination and two who failed the written and operating section. Subsequently, two R0s were re-examined and found satisfactor During this period, the simulator was first used for examinations and performed wel The training program appears to be strong overall with some minor weaknesse For example, the requalification training program adequately covered the potential axial shape index prob-lems during start up at the end of cycle with a large xenon transient in progress, but operators had not practiced such a start up on the simulato The Shift Engineer Program was also strong. Degreed engineers obtain SRO licenses and are integrated into operational shift The prospective shift engineers must qualify on all plant oper-ator watch stations prior to the license class and serve as control room supervisors and plant watch supervisors as well as STA The 75 licensed operators provic'e a considerable depth of talent to allow for training, vacations, sickness, promotions, and spare people on shift without unnecessary overtime. The opera-tions staff is a solid stable work force with little turnove A new Assistant General Supervisor of Operations position has also been allotted and filled. Shift turnovers were thorough, one-on-one walk throughs of the control panels with review of administrative log Shift Supervisors and Control Room Opera-tors routinely demonstrated a very conservative approach to safety. They are technically knowledgeable, professional, well trained and provide an added level of assurance in safe opera-tio They typically have good morale, attitudes, and an excel-lent rapport with the facility staff.
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The operations group worked harmoniously with maintenance,. HP, and others throughout this period in the area of coc dinating maintenance and operations activities (see outage activities for engineering interface). They helped set maintenance priorities, j optimized scheduling, tagged equipment out of service at the
proper time, and ensured post maintenance testing was accom-plished. They improved their guidance on what specific ' post operational tests were required for various types of e:ainten-anc /
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The licensee placed strong emphasis on planning. Improvement in prior planning, setting priorities, and assignment of respons4'
bilities was evidenced in the establishment of pre-shif t i br147-ings to the oncoming watch section of non-licensed operators. , A recently established morning operations meeting between depart- 9;
, ment general supervisors, principal and system engineers and
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planners now sets the day's priorities, discusses delays,.coor-dinates activities, and assigns responsibilities. A revised
" Plan of the Day" now includes maintenance, surveillance, and other expected facility activities rather than a simple wtatus of each reacto The licensee's approach to the resolution of technical issues '
from a safety standpoint generally exhibited conservatism and ,
was technically sound and thorough. Reactor coolant pump shaft !
and cover cracks, LPSI header relief valve weld cracks, and RCP i suction deflector ring failure demonstrated technically sound resolutions. However, occasionally during the period, NRC intervention was necessary to cause management to be aware of deficiencies associated with surveillance testing or events relating to the operability of safety-related equipment. Occas-ionally, safety related equipment was initiated and failed to operat If attempted a second time and it operated and passed a Technical Specification surveillance test, the original fail-ure was not always recorded or identified to management. Once aware, appropriate reviews and action was taken (see Surveil-lance section referencing additional details).
In summary, in spite of several visible events which drew atten-tion to the facility (EDG gassing, RCP shaft cracking, contain-ment spray dowa), numerous prograr.. improvements were made. Many were made in response to the last SALP, others in response to the licensee's recognition of weaknesse The Plant Operations Safety Review Committee has a potential to be biased towards operations since the structure places the Chairman in a position .
to lose objectivit Post-maintenance operational testing )
requires improvements. A formal mechanism appeared to be lack- '
ing which ensures that all failures are brought to the appro-priate level of management attention in a timely fashion. Per-formance of operating department personnel, especially licensed operators, was excellen l l
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21 i
I B. Chemistry and Radiological Controls (11.6%) Analysis
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l The Radiological Controls Program was rated Category ' l last I assessment period. Significant concerns with management control j over the PASS system were noted which led to escalated enforce-ment and issuance of a civil penalty although the root cause(s)
of this problem primarily reflected on performance in other I functional area During this period, there were seven inspections by regional !
specialists in the chemistry and radiation control areas and routine coverage by the resident inspectors. The in plant radia-tion protection program was effectively implemented during both operational and outage condition *
The radiation protection organization, particularly in the ALARA area, was well-defined and adequately staffed, with well-qualified individual An appropriate number of trained and qualified contractor technicians were used to support the out-age. The use of contractors to supplement radiation protection staff was well controlled. The licensee continued to implement an effective radiation worker training program, Both the radia-tion protection ALARA and operations groups were aggressive in assisting in the development of this program. Procedures in the radiation protection area were well-defined and well-imple-mented. A need for the proceduralization of certain non-routine activities, such. as the use of steam generator TLD phantoms or operation of non- routine survey instruments was identified as an area for improvemen The licensee's external exposure controls program continued to be effective and contributed to overall program strength. Infor-mation concerning radiological survey data and conditions was readily available to workers signing into the work area. Daily exposure tracking was well-controlled; reports of accruing exposure for each worker were reported to responsible super-visors twice daily during outage condition The licensee ef-fectively utilized their Special Work Permit (SWP) system to establish radiological control Two unrelated deficiencies occurred during this period in the area of High Radiation Area controls. During one incident iden-tified by the licensee, two individuals " jimmied" the locked door to a High Radiation Area and entered rather than waiting for the HP technician to arrive with the key. Subsequent inves-tigation, prompted by an allegation, identified that a set of
_ _ _ - _ _ _ _ - - _ _ _ _ _ -
- __ _ . _ - _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ ___
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master keys to the station's locked High Radiation Areas was uncontrolle No examples of unauthorized use were identified
- indicating a significant breakdown of controls in this area had not occurred. Licensee corrective actions were timely and comprehensiv An effective internal exposure controls program was in plac The licensee . aggressively utilized containments and portable ventilation as methods of controlling airborne activity. Post-ing of airborne areas and tracking of MPC hours were performed at action levels more conservative than those required by regu-lations. Recurring problems were noted with the auxiliary building drain system, which repeatedly backs up and causes con-tamination of previously clean floor areas. This creates a sit-uation that radiation protection personnel are forced to live with and indicates that plant management needs to be more aggressive in resolving the root causes of 'this proble Similarly, as discussed in the ' Operations functional area, more attention needs to be focused on , cleanup of individual contam-inated area The ALARA program continued to exhibit strong performance. ALARA pre-outage involvement and planning was substantial; numerous exposure / savings mechanisms (mock-up training, automated equip-ment, closed circuit TV, temporary shielding) were utilized dur-ing the outage. Actual exposure for 1986 for the two units was 347 person-rem vs. a projected goal of 390 person-rem. The 1987 i goal was only 405 man rem, although considerable high rad work '
was necessary. Experience through the end of the SALP period indicated that this goal was achievable. This experience indicates an aggressive goal setting program was in place and was used to improve ALARA performanc The solid radwaste program was effective. An aggressive program for volume reduction resulted in disposal of volumes approxi-mately one half of tho:e at comparable PWRs. The organizational responsibilities for processing, preparation and shipping solid radwaste materials were clearly defined in procedures, well understood by the responsible groups, and functioned smoothly during the assessment perio _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ -
L
.
l
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The presence of faileo 7uel pins presented a technical challenge to the solid radwaste program which was recognized, adequately analyzed and handled. Properly constituted corrective actions were taken to prevent regulatory problems; 10 CFR - 61 scaling factors were modified to reflect the new conditions. _ A high degree of quality control involvement in solid radwaste activ- ,
ities was effective in ensuring the waste classification, form, l j' and packaging requirements were being met.
L The. radioactive ef fluer.ts control program exhibited positive I
.
controls over radioactive releases and radwaste system operation
!' with well stated procedures to promote proper performance. When the plant vent wide range gas monitor (WRGM) original calibra-tion data was deemed insufficient, the licensee declared the monitor inoperable, submitted an LER, and notified the NR Management controls resulted in timely restoration; alternative sampling techniques'were used in the interi Routine surveillance of the radiation monitoring and air clean-ing systems were found to meet frequency requirements in all case In the previous assessment period the licensee had failed to take carbon samples at the required frequenc This suggests an increased level of management involvemen Routine radiochemical analysis of reactor coolant parameters was sati sf actor In one instance identified by the licensee, a surveillance was missed, due to an inadequate shift turnove Management response and mitigation efforts were timely. This event was a singular occurrence and did not suggest a program-matic breakdown of management control During the assessment period, licensee management took aggress-ive action to correct the inoperability of the PASS system iden-tified in the previous assessment. The original PASS system was taken out of service and the NSSS sample sink was modified to meet NRC requirements. The resolution of the PASS deficiencies by modifying the NSSS sample sink demonstrated a clear under- .'
standing of issues by the licensee as well as a technically sound approach. Furthermore, twelve items were reviewed during a special NRC follow up inspection and eleven, including all the violations, were closed, indicating timely and thorough resolu-tion of issue _ _ - _- _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - . _ _ _ _ _ .. . _ _ .
I l .
.
l The licensee's program for the Radiological Environmental
'
Monitoring Program was found to be generally adequate. Sampling '
frequencies, type of measurements, analytical sensitivities, and reporting schedules generally complied with Technical Specifica-tion requirement A measurement quality control program was implemented including participation in the EPA Cross Check Pro-gram. Measurement results of the collected TLDs between the NRC and the licensee were generally in agreemen In summary, the in plant radiation protection program continued to be effectively implemented during this assessment period. In particular, good controls were in place and exercised, exposures were . tracked well and maintained low, the ALARA program was strong, and radioactive effluents ' and radwaste were minimized l with appropriate monitorin . Conclusion Rating: Category 1 Trend: None 3. Board Recommendation Licensee: None NRC: None I
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C. Maintenance (13.9%) Analysis The previous SALP rated the' maintenance area as Category i Material condition weaknesses required continued effort in several areas, but increased management attention and resources- i were being devoted to these areas. Additional I&C engineering support was needed because of weaknesses in the staffing, direct line supervision, vendor support, and spare parts area The licensee was to evaluate the impact of secondary system maintenance problems on reactor trips and determine if poor maintenance and/or design weaknes ses were contributing to balance of plant related trip During this period, regional specialists conducted six inspec-tions of this area. Resident inspectors also routinely reviewed this are During this period, the I&C area significantly improved; a new general supervisor aggressively pursued issues, assigned respon-sibilities, and held personnel accountable. Systems were imple-mented which trended and provided status of control room defici-ency tag Some progress was made in reducing the number of control room MRs. Problems ider.tified last period regarding the operability of main steam isolation -valves were resolved by the replacement of those valves; a major modification performed very well. As noted in the Operations area, operators, engineers, and maintenance personnel attended factory acceptance testing and worked with the vendor to develop operational test, opera-ting and maintenance procedure Grounds on the Feed Water Control System are also under contro Several enhancements took place (separation of power supplies and replacement of numerous parts with state of the art controls). A task force to improve the feed systems reliability generated several recom-mendations not yet fully implemente The licensee installed two new and improved travelling screens at either end of the intake structure, where most jelly fish accumulat Both communications and coordination between maintenance, oper-ations, and engineering showed improvement General super-visors visited other nuclear plants to obtain alternatives in order to improve the recognized weaknesses in the MR system. A
" Perfect Planning" effort was effective i r. planning outage activities (see the Outage activities section for details).
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.
4 A
Training of both electrical and mechanical personnel improve All maintenance training programs are now INP0 accredited. All maintenance personnel receive two weeks of general training.
l Although improved, the volume of out of service instruments af-fecting the control room operators performance was excessive, about 15 per uni Additionally, several instruments that do not have MRs attached were inappropriate for operator use in that the normal operating parameters were at the top or bottom 5% of the scale. For example, 100% steam flow is recorded at the very to Similar problems exist with the surge line tem-perature and pressurizer water temperature indicators. These examples of maintenance and design / engineering inadequacies had the potential to adversely affect operator performanc Other indications of inadequate maintenance impacting operations was the safety injection tank in-leakage proble Operators must keep No. 21 charging pump in pull to lock in order to pre-vent dilution of the safety injection tanks (SIT) because of back leakage through several valves inner-connecting the sys-tems. Maintenance and testing efforts to date were ineffectiv Similarly, the Instrument Air System air dryers / regeneration :
units repeatedly failed to transfer and caused a loss of instru~
ment ai This problem has been tolerated for several years causing either plant scrams or near misse Only after NRC inspector prompting did the licensee effectuate some improve-ments to alleviate the proble Service water pumps and auxiliary feed water pump packings con-tinued to be a problem. Maintenance spent considerable time reworking these packings without significant success. Engineer-ing efforts were in progress to improve these, however, this problem has persisted several year Other equipment seemingly out of service for extended periods were: the plant air com-pressors, intake air coolers, and screen wash pump Resolution was slo Programs and efforts to address such problems have not worked very well for the following reasons:
(1) The Integrated Management System (IMS) has been implemented which provides a systematic method for prioritizing plant betterment and projects by development of benefit to cost ratio The IMS system appeared to hinder improvements in several areas by excessively cancelling or delaying many enhancements recommended by veteran supervisors, because the benefit to cost ratio requirements weie not met. Super-visors appear to have insufficient involvement in the set-ting of prioritie This caused several long standing deficiencie _ _ _ _ - _ _ _ _ _ - _ _ _ . _ . _ _ -
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_
e-27 l
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(2) During the last three years the Integrated Corrective Action Program (ICAP) was under development to assist in tracking component failures and identifying rework. Manage- '
ment has not tracked component failures or repetitive main- j tenance during this time because. ICAP was imminent. Trend- !
ing or evaluations of repetitive failures do not occur by other than supervisor recollectio (3) Currently, no consolidation program exists which, during the life of a component, reverifies vendor technical manual design requirements or FSAR requirements. Nor is component performance ascertained during post maintenance testing (PMT). Most often PMT only assures that the component operate The above problems and numerous others identified by MRs were situations which hinders plant operation They existed throughout the period and reflected the need for additional staffing and resource The licensee focused on preventive maintenance (PM). PMs existed for both safety related and non-safety related compo-nent PMs had high priorit Procedures were generally good and a feedback mechanism existed through engineering back to the maintenance procedure group. Hcwever, PM frequency was based on arbitrary -judgment or coincided with Technical Specification required surveillance frequencies. Often, routine PMs were per-formed on components seldom operated since the previous PM, i.e., ESF components, yet many ; outstanding corrective mainten-ance items were not corrected ib a timely manner. PM results were not trended or thoroughly ) valuated which could provide a better basis for frequency of ' performanc A better use of 1 maintenance history or component failure trends would also pro- '
vide an excellent tool for managing the limited maintenance resource Another area recognized by the licensee as being deficient was poor work practices apparently due to a lack of pride in owner-ship. At times tools and work-related debris were found scat-tered about after completion of maintenanc Cleanliness and housekeeping were at times also below standard Maintenance management attempted to increase craft " job satisfaction" by minimizing reassignment of people from jobs in progress to a
"more urgent job". This previous practice caused a lack of ownership of jobs and personal pride in perforr;iance. Operations
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28 E
personnel would lose confidence in maintenance personnel's abil-ity to stay with or adequately complete a jo Recognizing i maintenance problems, operations personnel were sometimes reluc-tant to _ submit MRs believing they would not be adequately ad- 3 dressed. By allowing the same people to start and finish a job, 1 more pride and ownership is expected to occur and workers will receive either positive or negative recognition for "their" jo Progress has been made despite the above problems. Grounds o ;
the feed system, gassing problems on Emergency Diesel Genera-tors, replacing two reactor coolant pump rotating assemblies, back to back ten year In Service Inspection and refueling out-ages followed by Environmental Qualification and Commercial Quality issues placed severe stress on the entire plant staf ,
Notwithstanding, since the licensee implemented its response to '
the last SALP, there has been only one maintenance related plant trip compared to eight last perio The procedure to calibrate the Turbine Generator Electro-Hydraulic Controller was deficient in prescribing a new micrometer setpoint for a newly purchased turbine simulator control device resulting in a reactor tri Meetings are now held daily to coordinate maintenance, engineer-ing, and operation Prioritizing MRs, troubleshooting, deter-mining root causes, scheduling and tracking work activities dur-ing operation has greatly improved towards the end of this period, due to the coordination by this morning meetin Nuclear maintenance tracks maintenance-related reactor trips, control room instrumentation out of service, valves repacked, Mode I corrective maintenance working backlogs and Mode 1 cor-rective maintenance orders older than three months. Maintenance orders are further divided and trended by numbers due to numer -
ous causes for dela This trending / tracking system worked wel A recently established oil analysis and vibration trending pro-gram was somewhat successful in predicting component failure Previously, problems had occurred with adding the wrong type of oil to component The licensee recognized most of the above problems as well as others. They established programs or placed these items on the Key Items List wit.h assigned responsibilities and prioritie The programs are showing improvement. As an example, the 2000 valves repacked last yea- resulted in a reduction in dissolved oxygen by a factor of 5 in Unit 2 condersate. An " Investigative Planner" has been established to troubleshoot and correct ninor deficiencies within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of the MR originatio This resulted in a 35% reduction in the MRs greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> o l d ..
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29
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In summary, maintenance faced a great work load and still demon-strated slow improvements as compared to last period. Manage-ment programs effectiveness appeared constrained by limited. man-power and resources and engineering support. Use of the IMS to prioritize resource use appeared to be ineffective in resolving long standing deficiencies. Lack of effective use of trending, maintenance history and component failures reduces resource efficienc Some poor work practices continued to exist due to lack of attention to detail and insufficient supervisio Post maintenance testing requires improvemen . Conclusion Rating: 2-Trend: None 3. Board Re' commendation Licensee: Review adequacy of programs for prioritizatio NRC: None
,
i i
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. Surveillance (8.2%) Analysis The previous SALP determined performance in this area to be Category 1. Conservatism was noted in licensee policies for entering and interpreting Technical Specification action state-ment It was concluded that the program was effectively managed utilizing good procedures which were rarely violated. It was noted that a significant problem existed with erosion of steam piping and that a more aggressive corrective action pro-gram was neede The resident inspectors examined surveillance activities as part of the routine inspection program. Three inspections by region based personnel examined activities associated with two plant ten year In Service Inspections (ISI). Surveillance activities related to specific areas of inspection were reviewed during several adJitional inspections conducted by NRR and region based personne l The surveillance /ISI program continued to be effectively managed with only one minor instance of a missed surveillance (radio-chemical analyses) as discussed in Section I Methods for scheduling tests improved. In addition to the normal surveil-lance testing /ISI workload, additional effort was required to successfully complete two ten year in service inspections. In-creased effort and resources were dedicated to the secondary piping corrosion / erosion inspection and replacement progra There were no instances of low pressure steam line ruptures, as had occurred previously, during this perio As noted in previous SALP reports, workers performing tests and inspections were knowledgeable of the systems and testing requirements, and QC involvement was eviden Licensee policies and procedures did not adequately address intermittent equipment failures or significant degradations when the equipment, without underguing corrective maintenance, was retested and functioned properly. Those procedures permitted such equipment to be declared operable without first requiring either root cause determinatica and correction or, in cases where the root cause cannot be immediately identified, thorough evaluation of operability and need for compensatory action They also were weak in requiring documentation of these failures and degradations. This allowed a problem with intermittent
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L 31 e
i
- tripping 'of the, steam driven auxiliary feedwater pumps to per-i
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sist for an extended period without being recognized by plant management and de~monstrated that the surveillance program was not being used as effectively as possible in identifying equip-ment performance and reliability problem Such experiences indicate that equipment operability has been adversely affected by inadequate recognition and communications of surveillance '
problems as well as a lack of thoroughness in troubleshooting and root- cause analysi POSRC review and plant management actions on operability issues appear to have been more - keyed '
towards Technical Specification compliance than on reliability and safet The following deficiencies were noted durin'g the perio They appeared to be unrelated in nature and not indicative of any significant programmatic weaknesses. Problems were noted by the NRC and the licensee's QA group with improper segregation and storage of out-of-calibration measuring / test equipment. Three inadequacies of a more significant nature were found by the licensee and NRC in surveillance test procedures. One resulted in long term inoperability of the wide range noble gas monitors, the second in inadequate testing of a dynamic response circuit in the Reactor Protective System, and the third in a failure to periodically verify closure of certain containment penetrations prior to movement of irradiated fue As discussed in the Engineering Support functional area, th licensee has become more proactive in identifying deficiencie Examples in the surveillance area of this overall trend in-cluded: system engineer discovery of two of the surveillance test procedure deficiencies noted above, the conduct of a steam generator tube inspection program that exceeded regulatory requirements, and continued conduct of an aggressive secondary piping inspection and replacement program. Another example of particular note was licensee adaptation, as an industry first, of current state of the art ultrasonic examination technology to the field (UDRPS system) and successful use of this system dur-ing two ten year In Service Inspections. The use of this system enabled the licensee to conduct inspections which, in many cases, exceeded regulatory requirement The In-Service Inspection (ISI) group and the metallurgical engineering group which supports ISI activities have histor-ically been staffed by very technically competent individual This strength continued throughout this assessment perio In
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addition to ISI activities, both groups provided valuable sup-port to the plant in assessing emerging problems such as reactor coolant pump shaft and cover cracking indications. One area for improvement the licensee was requested to _ consider, and which may assist an already very capable ISI staff in achieving superior performance, would be the addition of an independent Level III Examiner to review all ISI dat In summary, the surveillance /ISI program was well manage Workers oerforming tests and inspections were knowledgeable of the sy. *e:ns and testing requirements. The ISI program was carried out and supported by particularly well qualified per-sonnel and went beyond regulatory requirements. However, licen-see policies and procedures do not adequately address inter-mittert equipment failures 'or degradation. Also, the surveil-lance program was not - being used as effectively as possible to identify equipment performance and reliability problem . Conclusion Rating: 2 Trend: None 3. Board Recommendation Licensee: Assess overall controls (policies, procedures, reporting requirements, decision making, trending, and assign-ments of responsibility) for identifying and resolving inter-mittent equipment failure problem An NRC/ Licensee meeting should be scheduled to discuss the results of this assessmen NRC: None i
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E. Emergency Preparedness (7.7%) Analysis Licensee performance in this area was rated as Category 1 during the previous assessment period based upon good exercise performance and the licensee's own - initiatives in emergency preparednes ,
During the current assessment period, there were three region-based inspections of emergency preparedness activities which included a routine safety inspection, observation of the annual exercise, and observation of a follow up remedial drill-, Obser-vations regarding implementation of the site emergency plan during an approaching hurricane in August 1986 and during the loss of offsite power event in July 1987 are include Emerg-ency planning was also one of the key areas examined during the
.
Operational Safety Review Team (0SART) revie The licensee- adequately addressed deficiencies in previous exercise performance through appropriate program changes and retraining. Concerns remained in the areas of emergency notif-ications and issuance of protective action recommendations (PAR)
for sheltering, evacuations, and authorization of: potassium iodine (KI) to personnel. During the partial participation exercise held on September 9,1986, NRC observed several signif-icant weaknesses in the licensee's performance. A recurring deficiency occurred relating to an inadequate decision making process for PAR The recommendations made to offsite author-ities were untimely and did not exhibit conservatism primarily due to problems in overall direction and control of the accident and dose assessment staff Dose assessors were observed to have difficulty in obtaining proper information for input into the dose assessment model. Additional inaccuracies were ob-served in determination of source terms, release pathways, and calculation of integrated offsite dose. The lack of efficiency in information flow between the radiological assessment staff together with a complacent attitude displayed by key response personnel were the contributing factors in inadequate and untimely recommendations for protective measure Scenario difficulties and inconsistencies may have contributed to this dela I
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i 34 e
A Confirmatory Action Letter (CAL) was issued following the ;
exercise which outlined the major deficiencie The CAL re-quested that the licensee take corrective measures by conducting a review of the ineffective portions of the Emergency Plan and Implementing Procedures and provide specialized training in weak areas. On October 16, 1986, a remedial drill was held to deter-mine licensee responsiveness to initiatives in the areas of protective action recommendations, dose assessment, and infor-mation flow during emergencies. Licensee performance in the deficient areas was acceptable during the remedial drill. Acci-dent assessment, notifications, communications, and protective action recommendations were timely, but concerns remained about the effectiveness of the dose assessment program. The licensee subsequently implemented changes to radiological assessment procedures and staff direction ana control assignments for evaluation and communication of dose projection The licensee emphasized the dose assessment area after the remedial drill through specialized training and drills; improvements were shown in subsequent drill The licensee had ample full-time onsite and corporate staff assigned. Assistance was also provided by the Training Depart-ment staff to integrate corrections of deficiencies in exercise performance or programmatic areas into emergency response train-ing. Emergency Response Facilities (ERF) were dedicated for emergency preparedness and were adequately maintaine The overall capability of Emergency Operations Facility is excel-lent. However, improvements could be made in the size and space availability of the Technical Support Cente During an approaching hurricane in August 1986, the licensee declared an Unusual Even Timely, conservative measures were taken for hurricane preparatio In July 1987, the plant experienced a significant loss of offsite power event resulting in the tripping (shut down) of both units, operation in natural circulation core cooling conditions for an extended period (approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />), and declaration of an " Alert" condition in accordance with the site emergency plan. During the event, operations and plant staff personnel responded correctly and properly implemented emergency operation procedures and the emergency pla Communications to the NRC were notably excel-len This event demonstrated the effectiveness of the emerg-ency plan as well as operations and emergency plan training program . - _ _ - _ _ _ _ _ _ - _ .
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-4 J
The licensee has established a close working ' relationship with off site officials and support groups. Evidence of a strong commitment to train and inform these groups as well as member of the general- public regarding site activities is eviden In summary, the level of staffing and training to administer basic emergency preparedness program functions appears adequate, however, performance of response personnel during the annual exercise was marginal. The poor performance appeared to be due to' a complacent attitude and inadequate management attention rather than a programmatic problem. The licensee immediately recognized the weakness and performance has improved consid-erably since the annual exercise. This improved performance was demonstrated during the recent loss of all offsite power even . Conclusion Rating: Category 2 Trend: None 3. Board Recommendation Licensee: None R
N_RC : None
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,. Security and Safeguards (2.2%)
. Analysis During the previous SALP period, the licensee's performance in this area was Category 1. No major regulatory issues were identifie There was one physical security and one material control and accounting inspection conducted by region-based inspectors dur-ing this nsessment perio A management meeting, at the request of the licensee, was held to discuss the circumstances of a repetitive violatio Both plant and corporate security management continue to be aggressively involved in the security program at Calvert Cliffs and in nuclear power plant security, in genera This wa demonstrated by the licensee's continuing attention to program improvements, e.g., providing a firearms range on owner control-led property adjacent to the site to facilitate the maintenance of firearm skills by members of the security force between requalification periods, the installation of two new explosive detectors to facilitate searches at the main entry point to the protected area, and training program initiatives that are dis-cussed later in this assessment. Additionally, the licensee was actively following up on the concerns identified during the Regulatory Effectiveness Review that was conducted in October 1985 by the NRC. Even those findings that were not NRC reuire-ments were actively pursued by the licensee in an effort to enhance and upgrade the security systems and were included with the licensee's previously planned security program upgrades that
'
began in 1982. Security management also continued to actively interact with other utilities regarding security matters, by membership in the Region I Nuclear Security Association and other groups engaged in nuclear plant security matter Security supervisors were well trained and contiraed to provide effective supervision over security force members who performed their assigned duties in a competent and professional manne Security force members were very knowledgeable and actively encouraged to participate in program implementation and enhance-ments by making recommendations, particularly during critiques after drills and exercise The licensee also ensured that feedback was provided on all routine security duties. These initiatives were very effective in sustaining the high level of morale exhibited by members of the security forc . - _ _ _ _ _ - _ _ _ _ _ _
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l l
o The licensee developed and implemented a specialized security
,
training course for members of the- site quality assurance staff I to enable them to conduct a more effective audit of the person-nel and security equipment performanc In addition, the licensee continued to maintain effective interface and liaison with local law enforcement and emergency services agencies through periodic meetings and on site drills and familiarization tours. Both of these provided valuable feedback to the training program during this assessment period and were further evidence of the licensee's interest in implementing an effective security progra During this assessment period, a repetitive violation occurred involving the control of vehicles while inside the . protected are The licensee requested a management meeting to discuss the previous and additional proposed corrective action The licensee's corrective actions were extensive and adequate to prevent recurrenc No similar problemt. were identified during the remainder of the assessment period. The violation identi-fied in the material control and accounting area involved the licensee's failure to maintain adequate records to demonstrat that physical inventories of special nuclear materials were con-ducted in accordance with NRC regulation The licensee took immediate and appropriate action to correct an omission in the accounting procedure to prevent recurrenc Neither of the i violations were indicative of a programmatic problem. The prompt I and effective corrective action undertaken was evidence of the licensee's- interest in implementing high quality security and !
eftective safeguard program :
i Five security event reports were submitted in accordance with the requirements of 10 CFR 73.71. Three reports were required as a result of a recurrent hardware problem with the security computer early in the assessment period. That problem was pur- i sued by the vendor and no recurrence has been experienced. A .
fourth report, involving the computer, resulted from an error !
made by a maintenance technicia The fifth report resulted when a fake bomb-like object was found in a building inside the plant protected are The five events were properly responded to by the security force and appropriate compensatory measures were implemented in each cas The licensee's Security Con-tingency Plan (SCP), as interpreted by NRC, committed to report-ing of events, such as the three computer related hardware events, to the NRC, but two such previous events had not been reported when they occurred. However, NRC regulations do not require reports of such event The licensee corrected some ambiguous language in the SCF that caused the confusion in the reporting commitments. Each report was clear and concise and provided an adequate explanation of the event to enable NRC analysi This demonstrated proper management oversight and review of events and reports submitted to NRC.
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During the assessment period, the licensee submitted three revisions to the security plan and a revision to the SCP cnder the provisions of 10 CFR 50.54(p). Some minor modifications were necessary to several changes but only two changes required additional information. Plan changes were of high quality and demonstrated management's continuing oversight of the program to ensure it was consistent with NRC performance objectives. Per-sonnel involved in maintaining plans current and consistent with NRC objectives were very knowledgeable of NRC requirement During the assessment period enhancements of the personne screening program were made by implementation of the Nuclear Employee Data Syste In summary, the licencee continued to maintain an effective physical security and safeguards program. Efforts to improve and upgrade the operation and reliability of system and equip-ment and the performance of personnel were continuin . Conclusion Rating: Category 1 Trend: None 3. Board Recommendation Licensee: None R
N_RC : None l
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G. Refueling, Outage Management (6.7%) '
l Analysis l
The previous SALP included Engineering Support within this area and rated this area as Category Routine activities were well. planned and coordinate Strong management influence in decision making was evident. Good communications and orchestra-tion of activities were demonstrated resulting in meeting of schedules and minimizing man rem exposure. Two areas, post accident sampling, and environmental qualification of equipment lacked sufficient management attention and required NRC involve-ment to identify deficiencies.
l There were two ten year In Service Inspections and refuelings l
conducted during this evaluation period. Outage activities mon-itored included: pre-outage planning meetings, responsible engineer presentations on Facility Change Requests (FCRs) and major modifications, morning coordination / status meetings, steam I generator eddy current testing, reactor vessel level instrumen-tation modifications, refuelings, in service inspection of the 3 reactor vessel, replacement of reactor coolant pump rotating assembly, replacement of main steam isolation valves, numerous other refueling activities, i.e., leak rate testing, nozzle dams work, hydrostatic tests, and human factors improvements made in the control roo Refuelings typically were characterized by good communications, excellent planning, good control over contractor personnel, and a strong management involvemen Engineering's onsite presence demonstrated a notable strength by providing responsible engineers to brief general supervisors and principal engineers at pre-outage meetings on all the sched-uling, support coordination, responsibilities, potential problem areas, and details of the more complex evolutions planned to occur during the outage. This process called " Perfect Planning" brought together all facets of job planning including ALARA engineering, mock up training, procedures and spare part status, and ensured all invoiced personnel were aware of their assigned responsibilitie This planning technique was used primarily for critical path high impact items and jobs that have never been performed before, jobs with significant potential man rem exposure, or with interfaces between many groups. This technique improved the efficiency and reduced exposure for MSIV replace-ment, core exit thermocouple modifications and RCP rotating i
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assembly replacemen The outage ' coordination meetings held
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daily tracked critical paths for primary work, secondary work, refueling and other major job efforts, ensuring delays for any reason were minimized and necessary support was provided. These meetings facilitated strict adherence to the schedule of activ-ities. Good communications existed between departments and con-L tractor Site management were regularly in attendance. The morning meeting and specific technical meetings thereafter were succinct and effectiv The outage management section, a division of the Operations Department,. utilized senior reactor operators as operations /
maintenance coordinators to facilitate the availability of equipment, to ensure operations was aware of ongoing maintenance and to expedite the isolation of equipment though the tagging authorit Another good initiative was the use of shift and area coordinators / facilitatory who facilitated material, coor-dinated and assigned priority to jobs within an area when con-flicts arose, i.e., containment coordinato Outage meetings were periodically supplemented with " pep talks" from the Vice President stressing quality work, safety first and doing the job right the first time. Management conveyed clearly that plant operation was second to safety and quality wor Beyond a normal refueling, the two ref ueling outages involved the following: two In Service Inspections of reactor vessel components; a problem with #12 Emergency Diesel Generator gas-sing; main generator collector ring cracks; failure of #118 reactor coolant pump seal after replacing all of the other RCP seals; replacement of two reactor coolant pump rotating assem-blies; replacement of about 2,000 feet of secondary steam piping and repacking about 2,000 valves with a constant load Chesterton packings; replacement of the MSIVs on each unit; and installa-tion of a new plant computer. These were accomplished with a site person rem exposure of less than the tight goals despite additional required work and no individual receiving more than 2 rem thereby exhibiting good planning and control. During these events, numerous technical problems faced the licensee. Each in time was resolved in a technically sound and thorough manne Despite the problems experienced beyond a normal refueling, both the refueling and ISI portions were successfully completed. The added complications, generator collector ring cracking, environ-mental qualification and mechanical commercial quality issues extended each outage, however these did not appear to influence the licensee's well coordinated persistent pac Personnel attitudes and morale remained high despite the setbacks.
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l Some problems, however, appeared to be persistent. Upon return- I ing to power operations, an excessive number of maintenance requests remained outstanding. Some of this was attributable to the marginal post maintenance test program and the limited )
resources in maintenanc However, another contributing factor was the licensee's tolerance to live with out of service or deficient equipment upon return to power operation (see also maintenance functional area).
Another area of concern was the amount of debris in the reactor coolant system. During the current fuel cycle, coolant activity
,
i on Unit 2 has been relatively high, 5 micro curies per cubic centimeter gross activity and 0,3 micro curies per cubic centi-meter dose equivalent Iodine 131. This appears to be caused by debris within the RCS causing fuel pin failure The failure mechanism appears to be debris-related fretting, indicating that material control practices during outages while systems were open were wea Clean area controls during refueling were strictly adhered too around the reactor vessel . However, the controls was not so strict around other areas where the primary system was open. The licensee first clearly recognized this problem after examining the fuel during this outage. As an initial corrective action step the licensee stressed cleanliness controls in the Calvert Cliffs News Letter to heighten employees sensitivity to the issu Further procedural controls are planned for future outage Similarly, overall housekeeping significantly declined during the outages, particularly in some contaminated areas as discussed in previous functional area In summary, outages and refuelings were well managed. Opera-tions perscanel and othe r outage coordinators / facilitatory were effective in achieving good coordination of activities including unexpected problems encountered late in the refueling outage In particular, planned maintenance, in-service inspections, modifications and major outage tasks were effectively scheduled, coordinated and managed. Despite the good overall management of outages, problems were noted near the end of the period as housekeeping in contaminated areas deteriorated and the plants were returned to service with an excessive number of maintenance requests outstanding and equipment out-of-servic . Conclusion Rating: Category 1 Trend: Declining Board Recommendation Licensee: Set goals for minimizing out of service equipment before returning to power operation NRC: None
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H. Engineering Support (6.8%) k Analysis Although this area was not rated separately in the previous SALP, . problems were identified with (1) a lack of management attention in the establishment ~of a viable Equipment Qualifica- -i tion (EQ) program and (2) inadequate orchestration of multi-disciplined tasks in that responsibility and authority were not vested in individuals in such a manner to ensure effective task completion. This area was covered as a part of several individ-ual and team inspections during this assessment period. Further-evidence of the above concerns was seen during this assessment perio Specifically, they were the root causes of significant deficiencies identified in the EQ program. Those deficiencies primarily involved the use of unqualified taped electrical splices. The second problem continued to exist in that the roles and responsibilities of systems engineers (individuals who are key coordinators in assuring proper maintenance, perform-ance, and design improvement of plant systems) were found to be poorly addressed in plant procedures and appeared to be too broad, thus reducing the effectiveness of this functio Related to the above. problems, communications, both formal and
. informal, between engineering and other . plant groups were wea For example, important mechanisms for communicating engineering requirements to the field were unclea Similarly, the engi-neering personnel were not made aware of the fact that the set-points for certain Reactor Protection System (RPS) constants were not being adjusted to values recommended by the NSSS vendor following core reloads. The licensee has experienced difficulty in getting engineers out of their office area and into the plant and communicating with operational and maintenance personnel to more fully realize the benefits of the relocation of all engi-neering functions to the sit The EQ issue pointed out a failure of engineering department and <
plant management to give credence to and heed the advance warn-ings of both the QA group and the NRC of program weaknesse It aisc pointed out a need for management to more frequently utilize third party expertise to provide assessments of the ade-quacy of more specialized or technically complex program I I
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During - this period, the licensee pursued an emergency diesel generator gassing problem which was originally thought to be only slightly excessive. As the licensee pursued the problem, it became worse and more complicated - during repair attempts requiring several changes to the Technical Specifications. The licensee was candid and responsive to NRC concerns which facil-itated an acceptable and timely resolution, however, communica-tion with NRC on the issues exhibited a lack of coordination between engineering and operation During the assessment period, a great deal of licensee manage-ment and NRC attention was focused on the engineering depart-men Licensee managers now recognize that the engineering function was operating under resource constraints that, at least in part, prevented (1) the timely close out of Facility Change Requests for which physical . work has been completed (approxi-mately 400 changes outstanding near the end of the SALP period),
(2) better root cause analysis of plant maintenance problems, (3) timely engineering of facility modifications, and (4) needed improvements in engineering tools (e.g., improved means for determining and maintaining design basis information). Resource constraints additionally slowed the development of a performance based training program for the engineer The fact that the general experience level of the systems engineers was low added emphasis to the need for such a training program. Additionally, the engineering department had internal and/or external commit-ments to complete final corrective actions for the EQ and MCQ issues, complete upgrades in the Q-list, and to develop master calibration data sheets in support of I&C maintenance activitie While performance in the engineering support area was hindered by work overload, it also suffered from inefficient control and use of existing resources due to insufficient prioritization and poor coordinatio Immediately prior to and during the assessment period, all engineering support functions for the plant, with the exception of the metallurgical engineering group, were moved to the site and consolidated under one Nuclear Engineering Services Depart- ,
ment. At the same time, the systems engineer function was implemented. The consolidation, coupled with two 10 year ISI and refueling outages and several plant problems as discussed previously placed considerable stress on the engineering organ-izatio In spite of this and extending beyond response to crisis situations, there were notable accomplishments which benefitted the plant and which indicate strong potential for ^.he engir.eering group, with proper development, to furtner contribute to the overall improvement of plant operation and maintenanc !
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l (1) The Engineering Department directed the efforts of the
= " Trip Evaluation Review Group (TERG)". As noted in the operations section, this group successfully identified problems in the feedwater control syste Two reactor i trips were caused by failures of reactor coolant pump (RCP) I capacitors. Engineering performed testing to determine if the capacitors could be replaced with an alternative. Cur-rently, a modification is in progress to replace the capacitors with inductors. There have been no repetitive
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reactor trips due to the same cause or unidentified root cause since TERG establishment except for the RCP capacitor failure (2) The organization has become more proactive in identifying
[ deficiencies. For example, engineering personnel identi-( fied the MCQ fastener and the RPS set point problems, and they discovered a significant error in vendor guidance for calibration of the wide range noble gas monitors. This was partially due to systems engineers being available to pro-vide focused attention on assigned system (3) The engineering group provided two useful tools for pre-dictive maintenance through development of the oil analysis j program and enhancements in the equipment vibration mon- 1 itoring and analysis progra ]
l (4) The engineering department's ISI group and the metallur- l gical laboratory group took state of the art ultrasonic l examination technology and, as an industry first, adopted it to the field (UDRPS system). This system was then very ,
successfully used during two 10 year ISI inspections. Also, l for the first time, a zero channel head entry device l (SM-10) was used on a CE designed plant for steam generator l tube eddy current inspection which resulted in an estimated l 10 man rem exposure reduction per unit. The ISI group and the metallurgical laboratory group have historically been j staf fed by very technically competent individua' These
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individuals also provided valuable support to the plant in analyzing reactor coolant pump shaft and cover cracking problem (5) The licensee's secondary piping inspection / replacement pro-gram continued to receive high priorit (6) Upon the initiative of the QA group, immediately following the SALP period the licensee performed a proactive, in-house inspection similar to the NRC Safety System Func-tional Inspection (SSFI) to examine engineering configura-tion controls. A contractor familiar with SSFI techniques !
assisted them in this effor i l
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(7) 500 safety-related loop drawings were , developed .to better support Electrical & Controls maintenance activitie (8) Although progress was slow, some of the long-standing tech-nical problems have . been resolved or appear to be on the path to resolution. Examples include: replacement of high maintenance requirement main steam line isolation valves with components of superior design, improved packing per-formance for the charging pumps, improved reactor coolant pump ' seal rebuild capability, intake structure traveling screen / screen wash system improvements, and updating of Unit 2 main feedwater controls. _
In summary, the consolidation and movement of all engineering functions to the site and the implementation of the systems engineer concept were positive steps toward improving engineer-ing support of the plan Problems still existed with: (1)
full integration of the Nuclear Engineering Services Department into the plant staff which includes improved communications as well as systems engineer training and involvement with opera-tions/ maintenance personnel to improve engineer credibility and 4 effectiveness; (2) assessment and, where needed, redefinition of '
the roles / responsibilities of systems engineers; (3) for multi-discipline tasks, lack of clear assignment of responsibility; (4) providing the necessary resources to complete corrective actions for past problems (e.g., EQ, MCQ, FCR backlog) and to providing better maintenance support and to resolve long stand-ing technical problems; and (5) ensuring appropriate management attention is given to identified deficiencies (e.g., QA findings
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and recommendations). Several corrective actions have been initiated (e.g. , team training for managers, daily operations /
maintenance / engineering meetings). Accomplishment of such a large agenda of improvement efforts will require dedicated and skillful management attention. During the latter part of the assessment period, areas of improvement were note These included system engineer identification of problems, self-identification and correction of MCQ problems, the SSFI initia-tive to evaluate engineering configuration controls and improved engineering support for the licensing functional area . Conclusion
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Rating: Category 3 Trend: Improving
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4 Board Recommendation Licensee: Perform independent assessment of the engineering organization which identifies engineering functions and includes a review of the overall system for establishing priorities, assigning responsibilities, and obtaining resource NRC: None i
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I Licensing Activities (1.9%) Analysis This licensee was rated Category 1 in this functional area for the previous SALP evaluation period. Management involvement and control of licensing activities, as well as licensee responsive-ness to NRC initiatives were viewed as strengths because the licensee assisted in resolving several NRC initiatives and its submittals were of high quality with noted improvement in the no significant hazards analysis provided in support of Technical Specification (TS) amendment requests. Weakness was noted only in the communications between the operations and licensing staffs concerning the reliability of equipment controlled by T During the current SALP evaluation period, a number of signifi-cant occurrences had a decided impact upon the evaluation of the licensee in this functional area. These occurrences included (1) the degradation of the #12 emergency diesel generator (EDG)
which necessitated one exigent and two emergency TS amendment requests, (2) the licensee's shift to a 24-month operating cycle which necessitated submittal and review of a wide range of TS amendment requests, and (3) the licensee's discovery of environ-mental qualification deficiencies and of the improper use of uncertified material replacement part Licensing activities are summarized in Table In responding to these occurrences and to other issues and events over the course of the SALP rating period, the licensee
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demonstrated generally good management overview with respect to I
licensing activitie The senior engineering management l actively participated in these actions by prioritizing these actions with the concurrence of the Manager of Nuclear Opera-tions. Assignment of priority was based upon the impact on cur-rent or future planned plant operations and upon the licensee's evaluation of the safety significance of the ite Generally, the licensee responded to the NRC in a timely manner, particularly, with regard to requests for additional information made to obtain technical support for licensee requested activ-ities. Licensee responses to NRC initiated issues were normally thorough and of high technical qualit Response was not as prompt to NRC issues of generic concer Due to a staffing shortage, the licensing activities prioritization scheme adver-sely impacted the timeliness of NRC requested and required licensing activities which the licensee often viewed as a lower priorit As a result, senior management diverted manpower l
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a resources away from these NRC initiated activities to those deemed to be more in the interest of the utilit The licensee requested extensions for responding to several NRC . generi letters and deferred action on SPDS operability, Dedicated Control Room Design Review and the annual FSAR updat Senior management attention towards NRC licensing requirements during this rating period was found to be inconsistent with regards to ensuring licensee compliance with the various report-ing requirements. Several required reports were filed late and some annually required reports (e.g., challenges to and failures of the pressurizer PORV's and code safety valves) had not been filed. for several year No licensee unit was tasked with the responsibility for or the authority to ensure that these reports were submitted as require The licensee possesses significant technical capabilities in most of the engineering and scientific disciplines necessary to resolve issues of concern to the NRC and the licensee. However, in several instances these capabilities were not reflected ' in the quality of the submittals. Most of the licensee's evalua-tions of the significant hazards considerations were accurate though brief, thus routinely requiring additional information to justify the reques The licensee has characterized every amendment request submitted during the rating period as not presenting any possible significant hazards consideration In three instances, however, the NRC determined that these charac-terizations of the amendment requests were not justifiable based upon technical fact Several instances of poor senior management review and/or inade-quate engineering analysis occurred during this rating perio These instances included: (1) a requested TS main steam isola-tion valve closure time limit, tested under no steam flow condi-tions, that would have placed the plant outside the analyzed bounds of the steam line break design basis event; (2) a change to the NRC approved peak reactor coolant system (RCS) pressure limit for the feed line break (FLB) event from 110% design RCS pressure to 120% design RCS pressure in the FLB event's safety analysis. This was made to justify a proposed increase in the moderator temperature coefficient limit. This change in peak pressure was not indicated in the licensee's TS amendment re-ques This peak pressure change was not reviewed by the licensee's safety review committees; (3) the justification for continued Unit 1 operation with an existing flaw in the main steam line was technically deficient; and (4) numerous technical inconsistencies and regulatory inadequacies existed in the licensee's submittals of the exigent and the first of two emergency TS amendment requests for the #12 EDG.
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Over the last six months, marked improvement has been observed with respect to senior management involvement in and the quality of the technical responses to non routine licensing activities,
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particularly the environmental qualification and replacement parts certification deficiencies arising at Calvert Cliff Licensing issues were carried out by three dif ferent groups in the Technical Services Engineering section of Nuclear Engineer-ing Services. Primary NRC/ licensee interface was with the Fuel Cycle Management unit, and the Licensing and Operational Safety unit. The third group that carried out licensing activities was the Analytical Support unit. NRC interface with this unit was mi niinal .
The Licensing unit was capably staffed though there was a staff I
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turnover of approximately 45*4 during this rating period. Though the level of experience appreciably declined, this unit's work ,
product continually and significantly improved due to the per-sistence and dedication of the unit's staff and to the quality of training provide NRC communications with the Licensing unit were marked with good relations, a high degree of coopera-tion and a free exchange of informatio This unit actively sought to improve communication The Fuel Cycle Management unit had an experienced staff with significant expertise in the technical issues of fuels manage-ment. Staff turnover was low. The quality of this unit's work product remained adequate during this period with no signifi-cant decline or improvement noted. However, many tasks assigned to this unit remained incomplete over periods of several years.
l For example, the Fuel Cycle Management Facility Change Request (FCR) process is used to initiate TS changes, core reloads and ;
other related changes; and modifications, tests and experiments as permitted under 10 CFR 50.59. No FCRs have been completed by this unit since April 1983 although 24 such actions, including 5 core reloads and 10 TS amendments (9 of which were approved by J the NRC) were initiated since this date. The licensee attri- l buted this failure to insufficient manpower. The licensee also attributed this unit's failure to maintain its training records to this manpower shortage. Communications with this unit were adequate though they were hesitant to inform the NRC of problems with licensing actions in a timely manne In summary, the licensee's greatest strengths were the signifi-cant technical capabilities that its staff possesses and the '
management's recently demonstrated determination to improve the quality of their licensing actions, as particularly demonstrated through the improvements in performance level made by the Licen- !
sing and Operational Safety uni Still, improvement is needed '
in (1) in the quality and level of management overview, (2) the
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l l quality and comprehensiveness of the hazards analyses provided I by the various engineering units to support licensing's develop- -l ment of justifications for TS amendment requests, . and (3) the .!
staffing level required to permit response to NRC initiatives in l a more timely fashion and to permit the staff to perform all tasks that are required, particularly for Fuel Cycle Managemen . Conclusion l Rating: Category 2 l
Trend: None
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l 3. Board Recommendation Licensee: None NRC: None i
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a J. Assurance of Quality (0.0%) Analysis The primary purpose of this functional area is to assess the effectiveness of the licensee's program for identifying and cor-recting problems. It includes management control, verification and oversight activities which affect or assure the quality of plant activities, structures, systems, and components. It also assesses the attitude and performance of plant staff personne Various aspects of this area were routinely examined as part of the resident inspector and region-based specialist inspection programs. A specific QA program review was performed as part of one team inspectio The previous SALP noted that although an extensive quality pro-gram existed throughout the organization, its effectiveness in incorporating quality into such important plant activities as identification of root causes of plant trips and installation of the Post Accident Sampling System was not clearly visible. QA audits were often quite superficial and were not identifying -
real problems and root cause A Category 2 rating was assigned.
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In response to these concerns, immediately before and during I this assessment period, several improvements were mad More technically-oriented personnel with a wide variety of plant and
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engineering experience were added to the QA uni The former l General Supervisor, Operations was assigned to manage the QA l unit and has helped to refocus attention more on technical and performance aspects of areas reviewed rather than just on QA programs. The findings and recommendations included in several audit reports during the period were candid and demonstrated that deeper levels of insight were being gained into subject area The " Trip Evaluation Review Group" concept was imple-mented, and that group was ef fectively utilized in identifying root causes of plant trip Increased emphasis was placed on interdepartmental coordination and planning for major modification During the previous SALP period the licensee consolidated all departments with nuclear responsibilities under one vice president and moved all of these departments to the plant sit One objective of the move was to improve communications and interfaces between departments. The consolidation has had t
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beneficial effects this period as evidenced by increased involvement of engineering in resolving daily plant problem The Operations department began to better prioritize and commun-icate its needs for support to both the-maintenance and engi-neering departments. Many examples were noted where inter-departmental interfaces were effective such as in the conduct of outage activities and in response to emergent equipment problems such as reactor coolant pump shaft cracking. However, the dis-covery of major deficiencies in the Equipment Qualification (EQ)
program and, later, the discovery by the licensee of problems with use of mechanical commercial quality (MCQ) fasteners demon-strated that some of the interdepartmental interface problem'
that had existed prior to the reorganization were still present and were significan For example, documents providing engi-neering guidance to craft personnel were inadequate. Engineer-ing personnel were not aware of improper as-built or as-maintained conditions in the fiel Additionally, it was noted that the licensee was experiencing problems in fully integrating engineering personnel into the plant staff and in defining their responsibilitie Senior management involvement and oversight was weak throughout the establishment of EQ program. Although clear warnings of problems were provided (before and following the reorganization)
by both the NRC and the licensee's QA group, sufficient manage-ment attention was not paid to the The fact that the licensee has often demonstrated their capa-bility to work as a team in successfully resolving plant prob-lems once those problems are fully recognized by senior plant management suggests that the more significant weakness of management may lie in their tools and abilities for perceiving problem For example, management did not recognize the need for third party expertise to provide an independent assessment of the EQ program. In the area of safety review committees, the Off Site Safety Review Committee (OSSRC) was principally made up of on site managers. With such strong day to day involvement in plant activities, members are less likely to be able to provide independent views on plant activities and may be slow to recognize emerging plant problem The high proportion of operations department membership on and control of the Plant Operations and Safety Review Committee (POSRC) has the potential for unduly biasing that committee toward operation and may thereby lessen its effectiveness in identifying safety concern In the area of plant operation, the licensee lacks a policy to uniformly ensure aggressive pursuit of the root cause of inter-mittent f ailures of plant equipmen Very little trending of equipment performance is done to identify impending failure _ _ _ _
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53 The licensee has taken several new initiatives which address some of these problems. The QA unit recently began using out- i side consultants in specialty area For example, immediately following the SALP period, a consultant was used to perform an inspection similar in nature to the NRC's Safety System Func-tional Inspections (SSFI) . Additionally, QA personnel were being used to investigate plant events and make corrective action . recommendations to the POSR In combination, these i efforts appear to improve the credibility of the QA unit with i line organizations as well as adding effectiveness to QA func-tions. The upgrades in QA helped the licensee to become more proactive in identifying their problems. Evidence was also seen of other plant groups becoming increasingly proactiv For example, problems with the use of commercial quality fasteners in rode class systems and insertion of improper values for cer-tain constants in the Reactor Protection System were identifie i New programs were developed to provide early indication of ;
impending equipment failures (oil analysis and vibration pro- .
grams). There was strong management support for using state of
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the art equipment in perf.orming ISI inspections which exceeded code requirements and increased resources were expended on iden-tification and precautionary replacement of secondary piping subject to erosion / corrosion problems. Of significant note, the licensee volunteered for and participated in the first Inter-national Atomic Energy Agency (IAEA) Operational Safety Review Team (0SART) Inspection conducted in the United State In general, plant employees are well trained, highly motivated and well supervised at the first line leve However staffing constraints appear to hamper the ability of the maintenance and engineering departments to support operations in areas such as j final close out of Facility Change Requests (FCRs), timely up- 1 date of engineering construction standards, timely engineering f of needed facility modifications, and correction of control room !
deficiencie In several areas such as outage management and control, radia- {
tion protection and security, effective programs and initiatives have been implemented thereby assuring quality in these areas as discussed earlier in this repor For example, the licensee's l
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radiation protection and ALARA programs continued throughout the period to be effective in reducing overall personnel exposure The quality of personnel screening was enhanced through imple-mentation of the Nuclear Employee Data System which is a coop-erative effort by several utilities to exchange security and health physics information on employees and contractor personne ____--___a
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In summary, weaknesses were noted in senior management control of interfaces between departments and ability to get departments to function together more effectively as a tea Although significant improvements have been made in the QA group, manage-ment was not effectively utilizing the information they pro-vided. Potential weaknesses were seen in the ability of licen-see senior management to perceive plant problems and determine root causes and in the safety committees' abilities to provide independent views on plant activities to management. Resource constraints are hampering the ability of the maintenance and engineering departments to support the operations grou Several initiatives were taken by the licensee during the period to help the organization become more proactive in identi fying plant problems. These included participation in the first OSART inspection conducted in the United States. Plant personnel are highly motivated and, in general, well qualified and well supervised at the first line leve . Conclusion Rating: Category 2 Trend: None 3. Board Recommendation Licensee:
(1) Review composition of POSRC and OSSRC to determine if they are sufficiently independent from plant operations to pro-vide objective assessment and root cause analysi (2) Senior corporate management attention is needed to assure proper functioning of the operations-maintenance-engineering on-site interfac NRC: Perform an integrated performance appraisal inspection l concentrating on the functioning of departmental j interface J l
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K. Training and Qualification Effectiveness (0.0%) Analysis The previous SALP recognized that the licensee had expended significant resources in upgrading training facilities and pro-gram It pointed out that significant improvements were made in a previously weak maintenance training program, however the effectiveness of those improvements was not yet apparent. Appro-priate management attention was being devoted to training. A Category 2 rating was assigned.
l Although attributes of this topic are discussed in other SALP functional areas, the topic is segregated here because of its importance, and to provide a synopsis of the training and qual-ification programs. Training effectiveness was assessed pri-marily by observations of performance of licensee personnel and reviews of non-licensed staff training and training associated with the post accident sampling system, solid radwaste handling, and health physics activities. An NRC team inspection, in part, assessed engineering staff training. NRC licensing examinations were administered twice during the assessment perio During this assessment period, the licensee continued to dedi-cate significant attention and resources to trainin In May 1987, the final five training programs requiring INP0 accredi-tation were accredited. With all 10 of their training programs accredited, the licensee is now a member of the National Academy for Nuclear Trainin Beyond accreditation the licensee is continuing to upgrade training programs. For instance, the 1986 operator requalifi-cation examinations more accurately assessed operator capabil-ities to perform job functions by greater usage of questions dealing with real-life situation In cooperation with the University of Maryland, the licensee is developing an educa-tional program, offered on site, which will lead to a Bachelor's degree in Nuclear Scienc Some courses in the program have already been provided to interested employees. Based upon an analysis of systems engineer job functions (i.e., performance-based analysis), training needs were assessed, and a systems engineer training prog am was developed. Implementation of this program began immediately following the SALP period. During outages, maintenance and technical staff training instructors joined plant maintenance crews, thereby contributing their expertise and example to craft activities as well as enhancing their credibility with field personnel and updating their knowledge of current plant problem _-__
,
L 56
-.
The . license training program for operators was effective in preparing candidates for examination (further detail is provided in the plans operations analysis section). The training program for shift engineers was excellent in that it included senior operator training / examination as well as shift technical advisor trainin Additionally, those individuals received further on-the-job training by virtue of being fully utilized on shift as control room supervisor In July 1987, the plant experienced a significant loss of off-site power event resulting in the tripping (shut down) of both units, operation in natural circulation core cooling conditions for an extended period (approximately 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br />), and declaration of an " Alert" condition in accordance with the site emergency plan. During the event, operations and plant staff personnel responded correctly and properly implemented emergency operating procede es and the emergency plan. Communications to the NRC were excellent. This event demonstrated the effectiveness of the-operator and emergency plan training program Effective training was also evident in two very specific areas,
'
post accident sampling and steam generator nozzle dam installation / removal (which resulted in low man rem exposures).-
The general experience level of system engineers was low. As noted above a training program for these individuals was only in-the initial stages of implementation. Although NRC inspections have not specifically identified plant problems attributable to engineer training deficiencies, inspectors did note that oper-ators and technicians generally lack confidence in the level of '
knowledge of the system engineer Therefore, the engineers were not typically viewed as a useful source of expertise in solving technical problem Training weaknesses contributed to two major problems in the maintenance area. Maintenance planning, QC and craft personnel were not sufficiently aware of engineering requirements for replacement mechanical fasteners. As a result, commercial qual-ity fasteners were improperly installed in ASME Code Class I, II, and III sy stems . Similarly, Electrical and Controls per-sonnel lacked sufficient guidance and training to properly install electrical splices for equipment included in the elec-trical equipment qualification (EQ) program.
- _ - - _ _ _ .__ _
-__ - _-_ - ._ _. _ _ _ _ _ . __ - _ _
,
.
57 l
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!
.Three reportable events, although not principally caused by
'
training deficiencies, did indicate- weaknesses in (1) non-licensed operator understanding of the safety significance and administrative controls associated with refueling water tank 1 level switches, (2) non-licensed operator understanding of the J operating princip'le of the condenser air removal system which {
caused a unit trip, and (3) licensed operator ability to fully l anticipate - and control axial flux distribution during plant '
start up near end of core lif In summary, the licensee continued to provide the necessary resources and management attention to training. Emphasis is needed in training craft and QC personnel on engineering requirements, Because craft training programs have only been recently finalized and accredited, their effectiveness could not be fully assesse Adequate training was not provided for engineering personnel and was a significant weaknes . Conclusion Rating: Category 2 Trend: Improving 3. Board Recommendation Licensee: None N_RC : None l
t
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1 a
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.
V. SUPPORTING DATA AND SUMMARY Investigations and Allegations Review Two allegations were . received in April 1986 regarding personnel
" jimmying" a high radiation door and that additional keys to high radiation areas were maintained by several people within the plant and were generally uncontrolle These were substantiate A violation was issued and licensee response was prompt and effectiv Escalated Enforcement Actions Civil Penalties Non . Orders l I
Non . Confirmatory Action Letters October 1, 1986 Confirmatory Action Letter issued concerning deficiencies identified in Emergency Preparedness exercise. A remedial drill was held with acceptable result Licensee Conferences Held During The Assessment Period April 28, 1987 - Enforcement Conference at Region I to discuss de-tails of the isolation of the refueling water tank level switches resulting in the loss of the automatic feature of the RA May 6, 1987 - Enforcement Conference at Region I to discuss under-lying causes of violations noted in the Environmental Qualification Progra July 13, 1987 - Senior NRC management met with senior BG&E management <
at Bethesda, Md. to discuss indicators of declining performanc !
1 Review of Licensee Event Reports Submitted by the Licensee The overall quality of Licensee Event Reports (LERs) is good. Over j the assessment period there was a significant improvement noted in i the discussions of safety consequences. Improvements were also noted in discussions of corrective actions and operator actions. Areas ]!
which would benefit from added attention include descriptions of personnel / procedure errors, component failures and safety system responses.
_ _ _ _ - _ - _ _ _ -
_ _ _ _ - _ _ _ _ - __-___-
I L 59 )
. 1
!
Two LERs (317/86-04 and. 318/86-06) concerned failed reactor coolant pump surge capacitors. Those failures led to reactor trips. A mod-ification to remove the capacitors and use inductors for surge sup- ]
pression is nearing the end of the engineering design phas Two LERs (318/87-03 and 318/87-04) reported repeat cracking on a branch line for a relief valve for the Low Pressure Safety Injection Syste Three LERs (318/86-04, 318/86-07, and 318/87-02) involved grounds and component failures in Unit 2 feed water control systems. Corrective actions taken in this area may have largely resolved the problems as evidenced by no recurrences for a major portion of the SALP perio Two LERs (317/87-07 and 317/87-09) describe problems with improper electrical splices on components in the Equipment Qualification pro-gram and use of improper fasteners in code class systems. Both prob-lems largely resulted from inadequate engineering guidance to field personne Four LERs (317/87-03, 317/87-05, 317/87-08, and 317/87-11) involved personnel errors and three LERs (317/86-07, 317/87-04, and 318/87-05)
involved procedure errors,
. _ _ _ _ _ ___ _ _ _ _ _ _
_ _ - - - - _ - _ _
.
.
l TABLE 1 j i
INSPECTION REPORT ACTIVITIES REPORT NUMBERS TYPE TOTAL INSPECTION DATES INSPECTION HOURS DESCRIPTION i 86-09 86-09 . RESIDENT 247 ROUTINE RESIDENT INSPECTION 05/01/86 06/30/86 l
86-10 86-10 SPECIALIST 24 GENERIC LETTER 83-28 EQUIPMENT 06/16/86 06/20/86 CLASSIFICATION, VENDOR INTERFACE, POST MAINTENANCE TESTING, PLANT SURVEILLANCE AND QA/QC OVERVIEW 86-11 86-11 RESIDENT 261 ROUTINE RESIDENT INSPECTION 07/01/86 08/31/86 86-12 86-12 SPECIALIST 40 WRITTEN AND OPERATING EXAMINATIONS 08/11/86 08/15/86 ADMINISTERED TO SIX REACTOR OPERATOR AND FOUR SENIOR REACTOR OPERATOR CANDIDATES 86-13 86-13 SPECIALIST 40 EMERGENCY PREPAREDNESS EXERCISE 07/21/86 07/25/86 86-14 86-14 SPECIALIST 260 EMERGENCY PREPAREDNESS EXERCISE AND 09/08/86 10/17/86 REMEDIAL DRILL 86-15 86-15 SPECIALIST 24 SURVEILLANCE AND CALIBRATION TESTING 08/18/86 08/22/86 PROGRAM AND CONTROL OF MEASURING AND TEST EQUIPMENT 86-16 86-16 RESIDENT 206 ROUTINE RESIDENT INSPECTION 09/01/86 10/17/86 86-17 86-17 SPECIALIST 74 IMPLEMENTATION OF RADIATION 09/15/86 09/19/86 PROTECTION PROGRAM AND OUTAGE I PREPARATIONS INCLUDING ALARA EXPOSURE AND RADI0 ACTIVE MATERIAL CONTROL 86-18 86-18 RESIDENT 209 ROUTINE RESIDENT INSPECTION 10/18/86 11/30/86
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
,
. __ -
.
Table 1 T1-2 s
i REPORT NUMBERS TYPE TOTAL 1 INSPECTION DATES INSPECTION HOURS DESCRIPTION 86-19 86-19 RESIDENT 289 ROUTINE RESIDENT INSPECTION 12/01/86 01/12/87 86-20 86-20 SPECIALIST 94 PLANT OPERATIONS AND SURVEILLANCE ;
11/03/86 11/07/86 PROGRAMS FOR CONTAINMENT INTEGRITY, ISOLATION VALVES AND AIR LOCKS, HYDROGEN CONTROL AND OTHER SYSTEMS 80 21 86-21 CANCELLED I 86-22 86-22 MEETING NA LICENSEE REQUESTED MEETING-86-23 SPECIALIST 24 REVIEW 0F THE ISI PROGRAM, OBSERVATIONS 11/17/86 11/21/86 0F ULTRASONIC AND EDDY CURRENT EXAMINATIONS AND REVIEW 0F NDE PROCEDURES 86-24 86-23 SPECIALIST 30 MAINTENANCE PROCEDURES, ELECTRICAL, 11/17/86 11/21/86 MECHANICAL AND INSTRUMENTATION MAINTENANCE AND MODIFICATION TASKS AND QA/QC CONTROL INTERFACES 86-25 SPECIALIST 32 RADIOLOGICAL SAFETY INSPECTION -
12/01/86 12/05/86 IMPLEMENTATION OF RADIOLOGICAL CONTROLS DURING UNIT 1 OUTAGE 87-01 87-01 RESIDENT 196 ROUTINE RESIDENT INSPECTION 01/12/87 02/28/87 87-02 87-02 SPECIALIST 32 FOLLOWUP ON SECURITY PROGRAM EVENT 02/17/87 02/20/87 REPORTS AND A PREVIOUSLY IDENTIFIED VIOLATION, MANAGEMENT EFFECTIVENESS AND INDEPENDENT INSPECTION 87-03 87-03 SPECIALIST 84 PASS SAMPLING OF REACTOR COOLANT &
02/24/87 02/27/87 CONTAINMENT ATMOSPHERE, NOBLE GAS EFFLUENT MONITORS, EFFLUENT MONITORING, IN PLANT RADIO-IODINE MEASURES 87-04 87-04 SPECIALIST 32 NON-LICENSED STAFF TRAINING 02/23/87 02/27/87 l
_ _ . - - - _ _ . _
- - - - - - - - - - - - - -
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)
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Table 1 TI-3
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i REPORT NUMBERS TYPE TOTAL INSPECTION DATES INSPECTION HOURS DESCRIPTION 87-05 87-05 SPECIALIST 40 WRITTEN AND OPERATING RETAKE 04/20/87 04/24/87 EXAMINATION ADMINISTERED TO ONE REACTOR OPERATOR AND RETAKE OPERATING EXAMINATION TO ONE OTHER R0 CANDIDATE 87-06 87-0 RESIDENT 202 ROUTINE RESIDENT INSPECTION 03/01/87 04/13/87 87-07 SPECIALIST 40 UNANNOUNCED OCCUPATIONAL RADIATION
'03/23/87 03/27/87 PROTECTION INSPECTION AT UNIT 2 1
'
DURING DNIT OUTAGE 87-07 87-08 SPECIALIST 40 UNANNOUNCED INSPECTION OF LICENSEE l
.03/23/87 03/27/87 ACTIVITY IN RESPONSE TO INFORMATION NOTICE 86-03 AND INFORMATION NOTICC 86-53 87-08 87-09 SPECIALIST 40 UNANNOUNCED INSPECTION OF THE LIQUID AND 03/01/87 04/03/87 GASEOUS RADI0 ACTIVE EFFLUENTS CONTROL PROGRAM REPORT 87-09 RESIDENT 24 SPECIAL INSPECTION'TO ASCERTAIN 03/26/87 03/30/87 CIRCUMSTANCES' INVOLVING ISOLATION OF ALL RECIRCULATION ACTUATION SYSTEM LEVEL SWITCHES - LER 317/87-05 87-10 SPECIALIST 40 INSPECTION OF IN SERVICE INSPECTION 04/06/87 04/10/87 PROGRAM AND STEAM GENERATOR INTEGRITY 87-10 87-11 RESIDENT 187 ROUTINE RESIDENT INSPECTION INCLUDING 04/.14/87 05/18/87 DEFICIENCIES IN EQ PROGRAM, REPETITIVE BRANCH LINE CRACKING AND CQ REPLACEMENT PARTS 87-11 87-12 SPECIALIST 40 INSPECTICN OF NUCLEAR MATERIAL CONTROL 04/28/87 05/01/87 AND ACCOUNTING 87-12 87-13 SPECIALIST 40 MECHANICAL, ELECTRICAL, AND I&C '
.
04/27/87 05/01/87 MAINTENANCE INCLUDING PROCEDURE MODIFICATIONS, EQUIPMENT HISTORIES, TRANSFORMER REVIEWS & QA INTEPFACE
.
- - _ _ _ _ _ _ - _ - _ _ _ _ - _ _ _ _ . - - - - - -
.
Table 1 T1-4 s
l I
REPORT NUMBERS TYPE TOTAL INSPECTION DATES INSPECTION HOURS DESCRIPTION 87-13 87-14 SPECIALIST 308 SPECIAL INSPECTION REVIEWING EQ 05/11/87 05/15/87 DEFICIENCIES, COMMERCIAL QUALITY MECHANICAL FASTENERS, PM TESTING, ENGINEERING REQUIREMENTS AND QA (
87-15 SPECIALIST 40 INSPECTION OF IN SERVICE INSPECTION 05/11/87 05/15/87 REVIEW 0F ISI DATA AND QA COVERAGE, REPAIR ACTIVITIES ON 2-RV-439, EROSION /
CORROSION EXAMINATIONS 87-14 87-16 RESIDENT 312 ROUTINE RESIDENT INSPECTION 05/19/87 06/30/87 87-15 87-17 SPECIALIST 39 SOLID RADI0 ACTIVE WASTE PROCESSING, 07/13/87 07/17/87 PREPARATION, PACKAGING AND SHIPPING PROGRAM 87-17 87-19 RESIDENT 276 ROUTINE RESIDENT INSPECTION 07/01/87 07/31/87 87-16 87-18 SPECIALIST 32 RADIOLOGICAL ENVIRONMENTAL MONITORING 07/13/87 07/17/87 PROGRAM l 87-18 87-20 SPECIALIST 8 SENIOR MANAGEMENT MEETING HELD AT NRC 07/13/87 07/13/87 HEADQUARTERS 87-20 87-22 SPECIALIST 32 INTERNATIONAL ATOMIC ENERGY AGENCY 08/17/87 08/21/87 VISITATION 87-22 87-24 RESIDENT 80 ROUTINE RESIDENT INSPECTION 08/01/87 08/31/87 87-19 87-21 SPECIALIST CANCELLED 87-21 87-23 SPECIALIST CANCELLED
- _ _ _ _ _ - _ - _ _ _ _ _ _ - _ - _ - - - _ _ _ - _ _ _ _ _ - _ _ - _ _ - - _ _ _ _ _ _ - _ _ - - - - - - - - .- _ - _--
!
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TABLE 2 CALVERT CLIFFS 1&2 INSPECTION HOUR SUNMARY AREA HOURS HOURS ANNUALIZED PERCENT OPERATIONS 1646 123 .9 RADCON/ CHEMISTRY 465 34 .6 MAINTENANCE 559 41 .9 SURVEILLANCE 332 24 .2 EMERGENCY PRE .0 SEC/ SAFEGUARDS 88 6 .2 OUTAGES 271 20 .7 ENGINEERING 275 20 .8 LICENSING 74 5 .9 ASSURANCE OF QUALITY .0 TRAINING / QUALIFICATION 0 .0 TOTALS: 4018 301 .0
-
_ _ _ _ - - - - . _ _ _ _ _ _, .
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TABLE 3
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CALVERT CLIFFS 1&2 '
,
ENFORCEMENT ACTIVITY zi
. Violations versus Functional Area by Severity Level n
.No. of Violations in Each Severity Level AREA 1 2 3 4 5- DEV TOTAL
,
= = ==
OPERATIONS 1 1 RADCON/CHEMISTPY 1 1 MAINTENANCE- 'l 1 2 1 SURVEILLANCE 2 2 EMERGENCY PRE O SEC/ SAFEGUARD OUTAGES 0 ENGINEERING SUPPORT 1*
LICENSING 0 ASSURANCE OF QUALITY 0 TRAINING & QUALIFICATION O FIRE PROTECTION-HK 0 f6TALS: T ~~3 l*
- 0ne or more violations pending in EQ
_ -_
_ . _ _
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Table 3 T3-2 !
.
B, Summary of Violations INSPECTION REPORTS REQUIREMENT SEVERITY FUNCTIONAL !
'
INSPECTION DATES VIOLATED LEVEL AREA DESCRIPTION 8'6-09 T.S. 6.1 RADCON FAILURE TO MAINTAIN 05/01/86 06/30/86 CONTROL OF LOCKED HIGH RADIATION ~ AREA KEYS 86-10 T.S.6. MAINTENANCE FAILURE TO FOLLOW 06/16/86 06/20/86 PROCEDURES AFFECTING SAFETY-RELATED ACTIVITIES 86-15 10 CFR 50, 4 SURVEILLANCE I&C TECHNICIANS 08/18/86 08/22/86 APPX B USING TEST EQUIPMENT NOT WITHIN THE CALIBRATION DATE AND STORAGE POTENTI0 METERS OUT OF CALIBRATION 86-16 SECURITY 4 SEC/SAFEGRDS FAILURE TO FOLLOW 09/01/86 10/17/86 PLAN SECURITY PLAN PROCEDURES FOR VEHICLE KEY CONTROL 86-20 T.S. SURVEILLANCE FAILURE TO PROPERLY 11/03/86 11/07/86 REVIEW COMPLETED SURVEILLANCE AND TAKE CORRECTIVE ACTION FOR OUT OF SPECIFICATION TEST RESULTS
_ _ _ _ - _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _
.
Table 3 T3-3
.
INSPECTION REPORTS REQUIREMENT SEVERITY FUNCTIONAL INSPECTION DATES VIOLATED LEVEL AREA DESCRIPTION
__ _
87-07 87-08 10 CFR 50.49 *
ENGINEERING FAILURE TO ESTABLISH 03/23/87 03/27/87 ADEQUACY OF THE MAINTENANCE PROCEDURES
- Pending - no violation issued ye FOR MAINTAINING LIMITORQUE MOV'S FAILURE TO ESTABLISH QUALIFICATION OF ASCO VALVE LICENSEE FAILED TO ESTABLISH QUALIFICATION OF WRAP-AROUND TAPE SPLICES USED IN PIG-TAIL LEADS FOR SOLEN 0ID VALVES 87-09 -
TS 3.3. OPERATIONS FAILURE TO COMPLY 03/26/87 03/30/87 WITH THE PRECAUTIONS OF A SURVEILLANCE TEST PROCEDURE ISOLATING RAS FUNCTION FOR ECCS & CSS 87-12 87-13 10 CFR 50 5 MAINTENANCE FAILURE TO FOLLOW 04/27/87 05/01/87 SAFETY TAGGING ADMINISTRATIVE CONTROLS DURING MAINTENANCE ACTIVITY 87-11 87-12 10 CFR 4 SEC/SAFEGROS FAILURE TO 04/28/87 05/01/87 70.51(D) MAINTAIN AND KEEP PHYSICAL INVENTORY RECORDS TO SUPPORT THAT INVENTORIES OF SNM WERE CONDUCTED BETWEEN 4/30/81 AND 3/30/85
_ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
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.
e TABLE 4 CALVERT CLIFFS 1&2 LICENSEE EVENT REPORTS A. LER by Functional Area Number by Cause Codes FUNCTIONAL AREA A B C D E X TOTAL OPERATIONS 5 3 2 10 RADCON/ CHEMISTRY - I MAINTENANCE 1 1 1 3 6 ,
"
SURVEILLANCE 1 1
'
EMERGENCY PRE SEC/ SAFEGUARDS -
OUTAGES -
ENGINEERING SUPPORT 8 8 LICENSING -
ASSURANCE OF QUALITY -
TRAINING AND
'
QUALIFICATION -
TDT ^L$i T id l 7 7 1 3 '
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Table 4 T4-2 g
l LER Synopsis l
CALVERT CLIFFS 1 LER NUMBER EVENT DATE CAUSE CODE DESCRIPTION 86-03 04/30/86 A BATTERY WATER LEVEL EXCEEDED HIGH LEVEL LIMIT 86-04 07/20/86 B REACTOR TRIP CAUSED BY REACTOR CCJLANT PUMP SURGE CAPACITOR 86-05 10/01/86 0 MAIN VENT WIDE RANGE NOBLE GAS EFFLUENT MONITOR INOPERABLE DUE TO DEFICIENT PROCEDURE 86-06 10/10/86 A REACTOR TRIP DUE TO TURBINE TRIP FROM LOSS OF CONDENSER VACUUM 86-07 10/11/86 D REACTOR TRIP CAUSED BY HIGH AXIAL SHAPE INDEX 87-01 12/10/86 D VIOLATION OF TECHNICAL SPECIFICATION FOR OPERABLE SHUTDOWN COOLING LOOPS 87-02 12/03/06 B MAIN STEAM PIPING FLAW 87-03 01/27/87 A REACTOR TRIP AS A RESULT OF LOSS OF INSTRUMENT AIR 87-04 02/01/87 D REACTCR TRIP AS A RESULT OF TURBINE RUN BACK 87-05 02/17/87 A INADVERTENT ISOLATION OF ALL RECIRCULATION ACTUATION SYSTEM LEVEL SWITCHES 87-06 03/10/87 X PRESSURIZER SAFETY VALVES 200 AND 201 SET POINTS OUT OF SPECIFICATIONS 87-07 04/01/87 B ENVIRONMENTAL QUALIFICATION DISCREPANCIES REQUIRING SHUT DOWN 87-08 04/14/87 A IMPROPER VALVE LINEUP RESULTING IN SPRAYING BORATED WATER IN CONTAINMENT BUILDING r
_ _ _ _ _ _ _ _ _ _ _ _ _ _
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Table 4 T4-3
,
LER NUMBER EVENT __DATE CAUSE CODE DESCRIPTION 87-09 04/23/87 B USE OF FASTENERS (BOLTS, STUDS, THREADED R0D & NUTS) IN ASME CLASS 1, 2, & 3, SYSTEMS WITH;UT PROPER CERTIFICATION, SPECIAL NDE OR MARKING 87-10 05/22/87 B PRESSURIZER SPRAY VALVE BONNET WELD DESIGN DEFICIENCY 87-11 07/14/87 A LOSS OF FEED WATER HEATER AND DVERBORATION EVENT WITH REACTOR TRIP 87-12 07/23/87 X FAULTY 500KV CIRCUIT BREAKER OPERATION LEADS TO LOSS OF NON-EMERGENCY AC POWER CALVERT CLIFFS 2 86-04 05/21/86 E MANUAL AND AUTOMATIC TRIPS ON LOW STEAM GENERATOR WATER LEVEL 86-05 07/25/86 0 FLEX HOSE FITTING FAILURE ON 21A RCP REQUIRED UNIT SHUTDOWN AND UNUSUAL EVENT 86-06 09/05/86 B REACTOR TRIP CAUSED BY REACTOR COOLANT PUMP SURGE CAPACITOR FAILURE 86-07 09/12/86 B MANUAL REACTOR TRIP DUE TO PARTIAL LOSS OF FEED WATER F;0W TO STEAM GENERATORS 87-01 CANCELLED 87-02 02/28/87 :
FAILURE OF !EAD/ LAG CIRCUIT IN FEED WATER REGULATING VALVE CONTROL SYSTEM LEADS TO LOW STEAM GENERATOR WATER LEVEL REACTOR TRIP 87-0 /24/87 B FAILURE OF INLET PIPING TO RELIEF VALVE (2-RV-439)
87-04 05/07/87 B FAILURE OF INLET PIPING TO RELIEF VALVE (2-RV-439)
87-05 07/03/87 E FOLLOWING THE CALIBRATION OF THE TURBINE GENERATOR CONTROLLER, EXCESS LOAD RESULTS IN A LOW STEAM GENERATOR PRESSURE REACTOR TRIP
_ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - .
. _ . . . . . . . . . . . _ _ _ _ _ _ _ _ . _ - - _ - - _ _ _ . _ . _ _ _ _ _ _ _ . _ _ _ _ _ _ _ . . _ _ _ _ . . _ _ _ _ _ _ . _ _
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Table 4 T4-4
.
<
C. Licensee Event Reports (LERs)
Tabular Li; ting Type of Events Unit 1 Unit 2
. Personnel Error. . ......6 ......0 J Design / Man.Constr./ Install . . . 5 ......5 External Cause . . . ... ..0 ......0 l Defective Procedure ......4 . ....0 .1 ( Component Failure . .. ...0 . ....3 Other . . . . . . .. ...2 ......0 - - - -
Total . 17 ... ...8 ,
Licensee Event Reports Reviewed:
.s
Unit 1 LER 86-03 through 87-12; Unit 2 LER 86-04 through 87-05.
l i
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_ - . _ _ - . - - _ _ _ _ _ _ _ _ - _ - . - - . - _ _ _ - _ - _ _ - - - - - - - - - _ - - - - - . - - - - _ _ .- - - _ - - _ _
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l TABLE 5 SUMMARY OF LICENSING ACTIVITIES NRR LICENSEE MEETINGS September 19, 1986 Request for Emergency TS Amendment for #12 EDG September 26, 1986 24-month Cycle Reload October 3, 1986 CD in-leakage into #12 EDG Jacket Cooling Water Systein December 10, 1986 Unit 1 Main Steam Line Flaw January 7,1987 Future Licensing Actions May;5, 1987 Materials Qualification Deficiencies l NRR SITE VISITS l
July 14,1986 Site familiarization and training for new ORPM ,
i July 18,1986 SALP Meeting )
August 1, 1986 Discuss licensing actions status August 7, 1986 Investigate #12 EDG C0 in leakage October 2, 1986 Follow up information on #12 EDG November 3-7, 1986 Containment Integrity Inspection April 1,1987 ATWS Modification Review May 11-15, 1987 Restart Inspection (joint Region I/NRR team)
June 10, 1987 SG Tube ISI Amendment Request August 10-28, 1987 OSART COMMISSION BRIEFINGS None.
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o Table 5 T5-2 o SCHEDULAR EXTENSIONS GRANTED September 30, 1986 Order for operable SPDS, Units 1 and 2 RELIEFS GRANTED
'
March 26, 1987 ASME Section XI Relief - Unit l Main Steam Line Flaw May 11, 1987 ASME Section XI Relief - Units and 2 Class 1 and 2 Bolting and Control Rod Drive Housing i
May 29, 1987 ASME Section XI Temporary Relief - Unit 2 Auxiliary Feed Water Hydrostatic Test EXEMPTIONS GRANTED None LICENSEE AMENDMENTS ISSUED Date Unit 1 Unit 2 Title June 17, 1986 118 100 Miscellaneous TS Changes June 30, 1986 119 101 Miscellaneous TS Changes August 6, 1986 120 102 Miscellaneous TS Changes Sept. 8, 1986 '121 103 Exigent DG LC0 Change Sept. 23, 1986 122 104 Emergency Change #12 DG Oct. 6, 1986 123 105 DFOST Outage Time Nov. 28, 1986 124 ---
Emergency Change Refuel without an EDG Dec. 19, 1986 125 106 RCP Flywheel' Inspection /
Snubber Table Deletion Feb. 25, 1987 126 ---
MSIV Replace Closure April 29, 1987 --- 107 MSIV Replace Closure June 30, 1987 ---
108 Cycle 8 Reload Request
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Table 5 T5-3 !
e l
July 7, 1987 127 109 CEA Misalignment / l Purge Valve Isolation ORDERS ISSUED September 30, 1986 Modification of Order on Emergency Respons Capability Schedules (Generic Letter 82-33)'
providing a schedular extension for SPDS Operability.
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