ML20206J125
| ML20206J125 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 06/23/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20206J115 | List: |
| References | |
| 50-266-86-01, 50-266-86-1, 50-301-86-01, 50-301-86-1, NUDOCS 8606270012 | |
| Download: ML20206J125 (36) | |
See also: IR 05000266/1986001
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SALP 5
SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
1
REGION III
6
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
A
50-266/86-01; 50-301/86-01
Inspection Report No.
Wisconsin Electric Power Company
Name of Licensee
Point Beach Units I and 2
Name of Facility
October 1, 1984 through March 31, 1986
Assessment Period
bk
ADock Obbbbb66
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I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data
on a periodic basis and to evaluate licensee performance based upon this
information.
SALP is supplemental to normal regulatory processes used to
ensure compliance to NRC rules and regulations. SALP is intended to be
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sufficiently diagnostic to provide a rational basis for allocating NRC
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resources and to provide meaningful guidance to the licensee's management
to promote quality and safety of plant construction and operation.
A NRC SALP Board, composed of staff members listed below, met on May 16,
1986, to review the collection of performance observations and data to
assess the licensee performance in accordance with the guidance in NRC
Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A
summary of the guidance and evaluation criteria is provided in Section II
of this report.
This report is the SALP Board's assessment of the licensee's safety
performance at Point Beach for the period October 1, 1984 through
March 31, 1986.
SALP Board for Point Beach:
NAME
BRANCH / DIVISION
C. E. Norelius
Director, DRP, RIII
J. A. Hind
Director, DRSS, RIII
N. J. Chrissotimos
Deputy Director, DRS
G. E. Lear
Project Director, PD-1, PWR-A, NRR
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T. G. Colburn
PAD-1, PWR-A, NRR
I. N. Jackiw
Chief, Section 2B, DRP, RIII
R. L. Hague
M. J. Farber
Project Inspector, DRP, RIII
R. J. Leemon
RI, Pt. Beach, DRP, RIII
B. S. Drouin
Safeguards Section, DRSS, RIII
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II. CRITERIA
The licensee performance is assessed in selected functional areas depending
whether the facility is in a construction, pre-operational or operating
phase.
Each functional area normally represents an area significant to
nuclear safety and the environment, and is a normal programmatic area.
Some functional areas may not be assessed because of little or no licensee
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activities or lack of meaningful observations. Special areas may be added
to highlight significant observations.
One or more of the following evaluation criteria were used to assess
each functional area.
1.
Management involvement in assuring quality.
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2.
Approach to resolution of technical issues from a safety standpoint.
3.
Responsiveness to NRC initiatives.
4.
Enforcement history.
5.
Operational and Construction Events.
6.
Staffing (including management).
However, the SALP Board is not limited to these criteria and others may
have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is
classified into one of three performance categories.
The definition of
these performance categories is:
Category 1: Reduced NRC attention may be appropriate.
Licensee management
attention and involvement are aggressive and oriented toward nuclear
safety; licensee resources are ample and effectively used so that a high
level of performance with respect to operational safety or construction is
being achieved.
Category 2: NRC attention should be maintained at normal levels. Licensee
management attention and involvement are evident and are concerned with
nuclear safety; licensee resources are adequate and are reasonably
effective such that satisfactory performance with respect to operational
safety or construction is being achieved.
Category 3:
Both NRC and licensee attention should be increased. Licensee
management attention or involvement is acceptable and considers nuclear
safety, but weaknesses are evident; licensee resources appear to be
strained or not effectively used so that minimally satisfactory performance
with respect to operational safety or construction is being achieved.
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III. SUMMARY OF RESULTS
Rating Last
Rating This
Functional Area
Period
Period
A.
Plant Operations
1
1
B.
Radiological Controls
2
2
C.
Maintenance
2
1
D.
Surveillance
1
1
E.
Fire Protection
2
2
F.
2
2
G.
Security
1
1
H.
Outages
2
1
I.
Quality Programs and
Administrative Controls
Affecting Quality
2
2
J.
Licensing Activities
1
2
K.
Training and Qualification
Effectiveness
NR
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IV. PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
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Evaluation of this functional area is based on the results of
routine inspections conducted by the resident inspectors. The
inspections included direct observation of activities, review
of logs and records, verification of selected equipment lineup
and operability, followup of significant operating events, and
verification that facility operations were in conformance with
the Technical Specifications, administrative procedures, and
commitments. One violation was-identified as follows:
Severity Level IV:
Failure to cause a Special Maintenance
Procedure to be generated to perform an abnormal electrical
lineup, (Inspection Reports No. 50-266/84-018(DRP);
No. 50-301/84-016(DRP)).
This violation occurred during a Unit 2 refueling outage which
included a significant amount of breaker maintenance and several
abnormal breaker alignments. Operations personnel were requested
to open the normal feeder breaker to 2A03 to facilitate
inspection and maintenance of the breaker.
In order to maintain
2A03 energized the operators attempted to parallel buses IA03
and 2A03 and close the bus tie breaker.
This is a non-routine
evolution, which had been completed successfully during a
previous Unit 1 outage using a Special Maintenance Procedure.
Despite information on breaker interlocks being readily available
to the operators in the control room, they attempted closing the
bus tie without consulting the reference material. A second
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operator, believing the bus tie had been closed, opened the
normal feeder, deenergizing bus 2A03 which resulted in the auto
start of the 3D emergency diesel generator. This violation was
not of major safety significance.
Two reactor trips and one safety injection occurred during this
assessment period. A Unit I reactor trip from 88% power occurred
on June 26, 1985, and was caused by a loss of the white instrument
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bus. The inverter supplying the instrument bus failed due to the
failure of an integrated! circuit. A Unit 2 reactor trip from
90% power occurred on December 31, 1985, and was caused by a
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loss of load generator trip / turbine trip.
The loss of load was
caused by the failure of a lightning arrestor in the switchyard.
The safety injection occurred on Unit 1 on April 5, 1985, during
a plant shutdown in preparation for a refueling outage. As a
result of performing special chemistry analyses on steam generator
water, the normal plant cooldown procedure was not being used in
that the operators were asked to stop at various hold points in
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the cooldown to allow for samples to be drawn. Normally
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temperature would be reduced to 490 degrees and the plant would
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then be depressurized to 1800 psi at which point safety injection
would be blocked. During this sampling procedure' pressure was
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being maintained while cooling down to the various hold points.
The procedure did not caution the operator to block the low
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steam line pressure safety injection prior to going below
490 degrees.
Blocking of the low steam line pressure safety
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injection is normally only required when doing a primary to-
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secondary 2000 psi integrity test and this special procedure
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was included as an addendum to the " Hot Shutdown to Cold
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Shutdown" procedure. This procedure was revised shortly after
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the incident to include the appropriate precautions.
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During this assessment period, there were three Licensee Event
Reports (LERs) involving operator error. Two of the LERs
involved improper breaker manipulations from the control room
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which caused inadvertent actuations of the emergency diesel-
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generators. These occurred in the first two months of the SALP
period. The latter of the two resulted in the above mentioned
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violation. The third LER involving operator error was classified
by the licensee as a defective procedure and resulted in the
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inadvertent safety injection described above. The inspectors
believe that the operator could have averted the safety injection
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had he been closely monitoring plant parameters.
If concurrent
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evolutions were diverting his attention, a second operator should
have been assigned to assist him in his duties. These events
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were not of major safety significance and do not represent any
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deterioration in the level of performance of the operations staff.
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Unit I had one forced outage during the SALP period. The
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outage lasted 7.1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and involved replacement of a defective
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circuit board in an instrument bus, as documented in licensee
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LER 266/85-003. Unit 2 had three forced outages, all due to
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equipment failure. One lasted 5.0 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> to repair a snubber.
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A second lasted 28.1' hours and involved repair of a weld in the
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component cooling' water system. The third lasted 29.7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br />,
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and was due to a phase to ground fault in the switchyard. As
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of the end of the assessment period, Unit l's availability
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factor was 79.9% with a capacity factor of 69.9%. This is a
slight increase since the end of the last SALP period. Unit 2's
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availability factor was 87.0% with a capacity factor of 79.2%.
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This represents a slight decrease since the end of the last
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SALP period.
Both units remain among the top in the nation in
plant reliability.
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Professionalism continues to be apparent in control room
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activities.
By procedure, all potentially distracting
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activities are strictly forbidden in the control room.- The
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licensee continues to adhere to the black board policy during
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power operation.
Currently, there is only one annunciator on
each unit which is in the alarm condition during operation.
~ Management attention continues to be apparent with frequent
control room and plant tours.
2.
Conclusion
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' The licensee continues to be rated Category 1 in this area.
The licensee's performance during this assessment period has
improved.
3.
Board Recommendat_ ions
None.
B.
Radiological Controls
1.
Analysis
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Seven inspections were performed during the assessment period
by regional specialists. These inspectionsecovered outage and ,
operational radiation protection, radwaste ar.d transportation
tmanagement, chemistry and radiochemistry measurements and a
sp.ecial inspection ccncerning a radiological incident.
Two
violations were identified as follows:
a.'
Severity Level.IV - Failure to use a properly calibrated
' laboratory ditect'orsfor measuring airborne concentrations
of iodine.
(50-266/85011; 50-301/85011(DRSS))
b.
Severity Level V - Failure to adhere to radiation
control procedures concerning provisions for direct
health physics coverage specified on Radiation Work
Permit.
(50:301/8401C(DRP)-
The first violation appears to be the result of a weakness
in counting room quality assurance and represents a minor
programmatical breakdown; the second violation appears to be
an isolated case of failure to follow radiation work permit
instructions ~and is not indicative of a programmatic breakdown.
The two violations represent an improvement ever the previous
two SALP assessment periods. The licensee's corrective actions
were cpdropriate and' timely for' both violations.
Staf'fing, both technician and profesfional for the radiation
protection program continued as a weakress during this
assessment period. The major staffing weaknes's results from a
poor staff stability within the radiation protection program
and the resultant loss of expertise and experience due to the
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personnel' turnover. The lack of expertise and experience results'
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in inordinate technical work and task specific supervision which
must be performed by the radiation protection foremen; this
detracts from their normal supervisory functions. The licensee
initiated actions near the end of this assessment period to
improve the radiation protection program staffing, including
authorization for two new professional positions and a commitment
to create a more professionally oriented technician staff by
upgrading the radiation protection technician position and
selection criteria. These changes are expected to encourage
improved radiation protection staff retention.
Staffing in the
chemistry and radwaste programs has been more stable than in the
radiation protection program. No changes in key supervisory
personnel and only minor turnover (two of ten) of the chemistry
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technicians permanently assigned to the chemistry laboratory
have occurred during the assessment period.
The licensee has been generally responsive to NRC concerns.
Steps to resolve the long standing problem ::encerning radiation
protection staff stability appear to have been initiated near
the end of this assessment period in response to repeated
concerns expressed by NRC, Region III personnel. Additional
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areas indicative of licensee responsiveness during this
assessment period include the counting room quality assurance
program, the QA audit program for radwaste activ1 ties, the area
contamination control program, the radiological incident report
system, the criteria for evaluating anomalous transuranic and
strontium 89 and 90 values from contractor performed analyses
cf composite liquid discharge samples, and the increased
comparison of gaseous effluent grab samples with monitor
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response.
Management involvement has been generally adequate during this
assessment period with improvement evident in management
support of the radiation protection program. However, strong
actions were not taken until the latter part of the assessment
period to correct a self-identified radiation protection
problem concerning repeat (d incidents of high radiation area
rope barrier violations. Although licensee management was
responsive to a large number of inspector identified concerns
in this area, improvement is needed in self-identification and
correction of program weaknesses.
The licensee's approach to resolution of radiological technical
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issues has generally been conservative and sound. One exception
was the handling of a radioactive filter which produced high
radiation areas which were not adequately controlled.
Investiga-
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tion of the filter incident identified several problems, the
most significant of which concerned worker attitude and
qualifications. Similar problems (worker morale, experience
level and staff stability) were evident in other areas of the
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radiation protection program as noted above, and the licensee
has initiated corrective actions. Management demonstrated a
conservative approach in relocating a Radiation Monitoring
System (RMS) communicator and in replacing one general alarm
with seven individual alarms to improve operator awareness of
RMS status.
Support for the ALARA program is adequate and improving. This
is demonstrated by management support for the contamination
control program that was implemented during this assessment
period to prevent area contamination and to reduce existing
areas controlled for contamination purposes.
It is also
demonstrated by ALARA initiatives taken during a refueling
outage and by implementation of a dose accountability system.
Total worker dose was 740 person-rem in 1984 and 440 person-rem
in 1985; the 1984 doses included the final two months of the
steam generator replacement outage. These cumulative doses
were both below the average for U.S. pressurized water reactors
and are consistent with the licensee's historical personal doses.
The licensee routinely has maintained occupational doses below
the U.S. pressurized water reactor averages.
Noble gas release rates during this assessment period have
averaged about 55 curies annually per unit which is below the
average for U.S. pressurized water reactors. Reported liquid
radioactive releases were above average for U.S. pressurized
water reactors for this assessment period primarily due to a
planned release from the Reactor Water Storage Tank (RWST)
during Unit 2 refueling in November 1984. About one curie
total (excluding tritium) was released per unit in calendar
year 1985 which is about average for U.S. pressurized water
reactors. The RWST contents were released because of high
silica concentration apparently caused by boron recycle
activities.
Iodine and particulate releases in gaseous
effluents may also be quantified and reported conservatively
in that activity on weekly filters /adsorbers is decay corrected
to start of sample period rather than the constancy mid point
of the sample period. No unplanned liquid or gascous releases
were reported. No problems were identified with the licensee's
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transportation of radioactive material.
The licensee's ability to accurately measure radioactivity in
effluents declined somewhat during this assessment period.
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Seven disagreements were observed in 36 comparisons made with
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three licensee detectors. Most of the disagreements, which
involved a newly calibrated detector, were attributable to
counting room QA weaknesses and resulted in a violation.
Licensee corrective action following inspector identification
of the problem was prompt and satisfactory.
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The licensee's performance in this area generally has improved
during this assessment period. The most significant area
requiring further improvement concerns the radiation protection
program staffing weaknesses.
Other weaknesses identified
during this assessment period appear to have been adequately
addressed, although a rather large number of the weaknesses
were inspector identified instead of being identified by the
licensee. The self identification and correction of program
weaknesses is another area reeding improvement.
2.
Conclusion
The licensee is rated Category 2 in this functional area with
an improving trend.
3.
Board Recommendations
None
C.
Maintenance
1.
Analysis
Evaluation of this area is based on the results of routine
inspections by the resident inspectors and two inspections by
Region III specialists. The inspections included such
activities as: the observation of maintenance, preventative,
general, and corrective; compliance with procedures and plant
technical specifications; adherence to radiological and fire
protection controls; replacement of control rod drive guide
tube split pins; and followup on Bulletin 80-11.
No violations
were identified during these inspections.
During this assessment period there were two LERs involving
personnel error assigned to this area. The first resulted
from an auto start of the 4D emergency diesel generator due
to maintenance personnel removing insulation during performance
of a Special Maintenance Procedure, "2A05 Undervoltage Relay
Replacement." The removal of the insulation was called for in
the procedure; however, during the removal a set of contacts
was inadvertently closed, tripping the normal feeder to bus 2A05.
The diesel started and closed in on the bus as required. The
second LER resulted from an inadvertent nuclear instrumentation
turbine runback caused by contractor persor.nel inserting fire
barrier packing into a conduit. During performance of this
activity, the insulation, on the wires supplying power to the
inverter feeding the yellow instrument bus and subsequently
nuclear instrumentation power range channel 44, was abraded on
the edge of the conduit. This caused a momentary power loss to
power range 44 which was sensed as an indication of a dropped
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rod. The turbine ran back from 100*. power to 80*(, power as
expected. As a result of this incident the licensee stopped
all work of this nature until an evaluation could be made to
determine if the fire barrier packing is necessary for
Appendix R compliance and if so, whether or not a better method
of installation could be' employed.
Although this particular instance of contractor error was the
only one resulting in an LER, there were other instances during
the evaluation period when contracters inadvertently interrupted
power to safety or control equipment. The inspectors have
expressed their concerns to licensee management over increased
instances of this type.
Safety-related maintenance performed during the period included;
replacement of the motor on component cooling water pump IP11A,
installation of new station batteries and associated inverters
and chargers, work on the auxiliary safety instrumentation panel,
replacement of Unit 2 "B" reactor coolant pump motor with spare,
steam generator tube plugging, replacemeat of source range
detectors 2N31 and 2N32, installation of primary side loose parts
monitoring system, replaced "A" residua ~i heat removal pump,
replacement of the spherical bearings on the 800 kip Anker-Holth
snubbers, replacement of the primary loop bypass manifold
resistance temperature detectors, installation of the new
auxiliary building crane, replacement of split pins with crack
indications in both units, installation of flexureless inserts
in both units, a modification to the incore detector system
that changed the cover gas from carbon dioxide to helium in an
effort to minimize detector tube corrosion, and three annual
overhauls of emergency diesel generators.
Throughout the SALP period the licensee has continued to develop
written procedures in the maintenance area. One of the findings
of an NRC QA inspection done in 1983 was that there were too few
Maintenance Procedures.
Since then, the licensee has developed
ten Maintenance Instructions and eleven Routine Maintenance
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Procedures. Uver 100 Special Maintenance Procedures were also
developed on an as required basis.
The procedures for writing maintenance work requests (MWR) and
modification request.s (MR) have Q revised substantially to
address many areas considered deficient by the NRC QA inspectors.
This was a large effort requiring several draft revisions prior
to implementation.
The new MWR procedure was implemented in
January,1985, and the new MR procedure was implemented in July,
1985. After some initial concerns that the new procedures were
too cumbersome and required too many reviews and signatures,
both have been accepted and their use is now quite routine.
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One measure of the maintenance department's proficiency is
reflected in the low number of forced outages as described in
the Plant Operations section. This proficiency is the result
of a very stable and experienced staff. As the licensee
prepares for INPO accreditation of their training programs,
additional maintenance training is being initiated. The
licensee expects this part or' the training program to be
complete by the end of 1986.
Management involvement is apparent despite the experience level
of the department.
Frequent tours of work areas by first line
supervisors and higher management personnel were evident
throughout the SALP period. Manageiuent involvement was also
evident in outage planning. Major outage activities such as
split pin replacement, flexureless insert installation, and
significrat secondary side modifications were accomplished on
or ahead of schedule.
2.
Conclusion
The licensee is rated Category 1 in this area. This is an
improvement over the last period and is based on the absence of
violations and the small number of LERs.
Licensee performance
was determined to be improving near the close of the SALP
assessment period.
3.
Board Reccmmendations
None
D.
Surveillance
1.
Analysis
Evaluation of this functional area is based on results of routine
inspections conducted by the Resident Inspectors and five inspec-
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tions t,y regiont.1 personnel.
The resident inspections included
such activities as the observation of tetting; verification that
testing was performed in accordance with adequate procedures;
that limiting conditions for operation were met; that test results
conformed with technical specifications and precedure requirements
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and were reviewed by personnel other than the individual directing
the test; and that any deficiencies identified during the testing
were properly reviewed and resolved by appropriate management
personnel. Three of the region-based inspections were in the areas
of inservice inspection of piping system components and IE bulletin
followup. One region-based inspection was in the area of startup
core performance surveillance testing and the fifth region-based
inspection was in the area of inservice testing of pumps and
valves. One violation was identified in this functional area:
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Severity Level V - Failure to use a calibrated stopwatch for
valve stroke timing during surveillance testing.
(Inspection
Reports No. 50-266/85-001(DRS); No. 50-301/85-001(DRS)).
This violation is of minor safety significance.
The inservice testing inspection indicated that the licensee
had fully implemented the inservice testing program and was
conducting pump and valve inservice tests in accordance with
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appropriate schedules and approved test procedures. Both pump
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and valve testing were generally well defined with the
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appropriate evaluation of collected data being performed by
the licensee's staff.
Licensee personnel contacted were
notably cognizant of Code inservice test requirements and
have implemented an effective program. Operations personnel
directing and conducting the surveillance tests were well
trained, understood plant and equipment requirements, and
conducted their activities in a professional manner.
A few areas were identified where program technical improvements
should be considered, including service water pump test techniques
and valve stroke time upper limits.
It was also noted that while
the pump vibration program met ASME Code requirements, improve-
ments could be made in " good practice" in this area.
One LER attributed to personnel error was submitted during the
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assessment period. During surveillance testing of the negative
rate runback setpoint on power range channel 42, an instrument
and control technician momentarily operated the wrong switch on
the front of the power range drawer while he had an artificially
induced signal applied to the circuitry.
He immediately realized
his error and returned the switch to the correct position. His
actions caused a 2.5% turbine runback from 100% power.
Licensee performance in this area remains at the high level
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evident in previous SALPs. The strong point of the program is
the communication between the personnel performing testing and
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the control room. The extremely small number of incidents
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(one) causing plant perturbations during surveillance testing
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indicates that procedures are well written and followed by
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testing personnel. Management involvement remains evident.
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The licensee contiaues to maintain the performance level and
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attributes described in the previous SALP.
2.
Conclusions
The licensee continues to be rated Category 1.
3.
Board Recommendations
None.
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E.
Fire Protection and Housekeeping
1.
Analysis
Evaluation of this functional area is based on routine assessments
by the resident inspectors which include observations of:
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control of combustible materials, control of fire barriers,
implementation of ignition control permits, Appendix R modifica-
tions, and housekeeping requirements. No violations were
identified in this area.
The licensee continues to show improvement in this area. The
absence of violations during this SALP period is indicative of
a more aggressive management attitude toward fire protection
and housekeeping. During the SALP period the plant manager
eliminated all smoking in the auxiliary building due to abuses
of the previously designated smoking areas. The fire
protection engineer works closely with contractor personnel to
ensure that they are aware of applicable procedures related
to transient combustibles, fire permits, and storage of
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combustibles. During the Unit 2 outage in 1985, major modifica-
tions to the secondary plant involved a significant amount of
cutting, grinding and welding. All of this work was accomplished
without incident.
Appendix R modifications continued throughout the SALP period
with added emphasis the last few months in order to meet an
April 3, 1986 completion commitment.
It appears that not all
items were completed in accordance with this schedule. This
issue was referred to headquarters for resolution. The
licensee could have prevented exceeding the commitment date by
either doing a better job of establishing realistic commitment
dates or by closer tracking of the job progress such that a
schedular exemption could be requested in a timely manner. The
subject items were completed by May 19, 1986.
Housekeeping remains above average despite major work activities
during the period. Again, close management oversight in this
area is evident.
2.
Conclusion
The licensee is rated Category 1 in this area.
3.
Board Recommendations
None.
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F.
1.
Analysis
Two inspections were conducted during the assessment period to
evaluate the licensee's performance with regard to emergency
preparedness. These included observation of the licensee's
annual emergency preparedness exercise and an annual routine
inspection of the licensee's emergency preparedness program.
One violation was identified as follows:
Severity Level IV - Failure of Shift Superintendents to determine
when and what type of protective measures should be taken to
protect the health and safety of the public.
(Inspection Reports
No. 50-266/85005; No. 50-301/85005)
The above violation was a repeat violation from a July 1984
inspection (Inspection Reports No. 50-266/84013;
No. 50-301/84011). The violation was the result of a lack
of licensee responsiveness to NRC concerns. The inability
of the Shift Superintendents to make adequate protective action
recommendations was primarily the result of inadequate
procedures that the licensee addressed through increased
training. Weaknesses in the licensee's procedures and the
inability of the Shift Superintendents to make protective
action recommendations have been identified in NRC Inspection
reports since 1983. This violation was discussed in the SALP 4
report, to which the licensee responded by stating that the
violation was " inappropriate". Once the repeat violation was
identified, the licensee responded very quickly to revise
procedures and retrain personnel to ensure the problem would
finally be resolved to the NRC's satisfaction and prevent a
recurrence of this type of problem in the future.
The previous SALP report stated that the problems associated
with the violation regarding the Shift Superintendents inability
to make adequate protective action recommendations was apparently
the result of inadequate staffing.
Based on the licensee's
performance in resolving the repeat violation, it appears
the staffing level to resolve emergency preparedness concerns
is acceptable, once management gives it sufficient attention.
When management supports the issue, reviews and responses to
.
'
NRC concerns are generally timely, thorough and technically
sound.
During the last SALP period, a new emergency preparedness
coordinator was appointed and has been assisted by the previous
,
individual holding the position to ensure continuity and avoid
degradation of the program.
Examination of shift staffing and
'
augmentation during the routine inspection determined that
adequate staffing is available to fulfill the obligations of
the emergency organization in an incident.
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The emergency preparedness training program in general has been
good.
Procedures are.in place to ensure all members of the
emergency organization have the opportunity to periodically
).
participate in the emergency drills. The main weakness
identified in the training program was in keeping personnel
up-to-date on changes in the emergency plan and procedures.
An example of the adequacy of the program was demonstrated
'
by an acceptable performance during the 1985 annual exercise.
During the assessment period two instances of apparent
incomplete reporting occurred. Although no violations with
10 CFR 50.72 were identified, the lack of complete information
caused concern that the NRC might not fully understand the
significance of a reported event. The first event occurred
on July 25, 1985, and was reported to the Headquarters duty
,
officer as an unusual event due to the loss of the low voltage
station transformer. The initial not:fication of the unusual
event was made by a security guard per the licensee's emergency
plan. The security guard could not provide the additional
information requested by the NRC duty officer. The duty
officer subsequently called the control room and was informed
that there had been a lock-out of the low voltage station
transformer for Unit I and the unit was being shutdown per
'
Technical Specifications.
It was not known by headquarters nor
the region until after securing from the unusual event that
,
this transformer supplied offsite power to the unit. After
!
this event, the licensee revised their reporting procedures to
require that the ENS notification be made by someone in the
control room.
'
i
The second event occurred on December 31, 1985, and was reported
to the headquarters duty officer as an unusual event due to a
j
loss of load to the Unit 2 generator. The loss of load was
j
caused by a failed lightning arrestor in the switchyard.
The
l
report was made by the duty and call superintendent who was
able to answer all of the questions asked by the duty officer.
The full significance of this event was not initially understood
by the duty officer or the region.
Loss of load.to the generator
without an auto bus transfer causes a loss of reactor coolant
pumps, circulating water pumps, steam generator feed pumps, and
condensate pumps. An attempt to close the main steam isolation
valves from the control room was unsuccessful and one of the
source range instruments failed. This information was not
volunteered by the licensee. After this event the licensee
again modified their reporting format to include any equipment
malfunctions which would help the NRC to appreciate tne actual
plant conditions whether the equipment was safety-related or
not.
1
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The NRC's concerns in this area were made known to the licensee
management by the resident inspectors, a regional inspector and
during a routine visit to the site by the division director.
The licensee acknowledged the necessity to ensure that NRC
notifications are accurate and comprehensive.
2.
Conclusion
The licensee is rated Category 2 in this area. The licensee
received a rating of Category 2 in the last SALP period.
3.
Board Recommendations
None.
G.
Security:
1.
Analysis:
One routine and one special inspection were conducted by region-
based inspectors during the assessment period. A second special
inspection was conducted four days after the conclusion of the
assessment period to evaluate an event that occurred just prior
to the end of the period. A region-based inspector also
participated in an Office of Nuclear Materials Safety and
Safeguards Regulatory Effectiveness Review in December 1985.
The first special inspection involved an unauthorized discharge
of a weapon. The second inspection resulted in escalated
enforcement action being initiated and two violations being
identified.
a.
Severity Level III - A vital area barrier was degraded for
approximately 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (266/86005-01; 301/86005-01).
b.
Severity Level IV - A security event was not reported in a
timely manner (266/86005-02; 301/86005-02).
Work on a modification request resulted in the degraded vital
area barrier. The modification request did not undergo a
security review and the lack of security review was a major
contributing factor to the event. The licensee considered such
a possibility in response to IE Information Notice No. 85-79,
" Inadequate Communications between Maintenance, Operations and
Security Personnel." However, the licensee did not address
modification requests which had been approved three months or
more prior to the issuance of the notice. The degraded barrier
event involved a previously approved modification.
Upon identification of the degraded barrier, the licensee took
prompt and unusually extensive corrective action consisting of
revised security and employee training, improving the modification
request system and fixing security responsibility for modification
requests.
17
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Management involvement in assuring quality was evident in the
licensee's actions aimed at exceeding minimum security plan
requirements. The licensee improved security lighting, upgraded
_
vehicle gates, installed a physical fitness obstacle course,
and upgraded the weapons firing range. These are all examples
of the licensee's continuous approach towards improvements and
,
their dedication to excellence. Corporate management is
frequently involved in site activities concentrating on the
long range improvement of the security program. The licensee's
enforcement history and the professional and thorough manner in
which the security force training program is administered are
also indicative of a quality program. However, the degraded
barrier event identified a tendency towards inadequate attention
to detail.
Inattention to detail contributed to the degraded
>
barrier event in several respects.
For example, although many
modification requests were reviewed for security impact, several
predating IE Notice 85-79 were not.
Because one of those
modifications requests was not reviewed, a vital area barrier
was degraded by workers performing current maintenance.
Inattention to detail also delayed the identification of the
degraded barrier by multiple members of the security organization
and several plant personnel. An inadequate classification of
the specific significance of the event resulted in the untimely
reporting of the event.
This lack of attention to detail is the
most significant detractor to an otherwise overall quality
program.
Technical issues were usually resolved in a sound and timely
manner. The upgrade of the vehicle gates resulted from the
licensee's review of IE Information Notice No. 84-07 " Design
Basis Threat and Review of Vehicular Access Control." Technical
issues resulting from the unauthorized discharge of weapons
event and the degraded barrier event were resolved promptly and
thoroughly.
The licensee's review of IE Information Notice No. 85-79, although technically sound was not comprehensive in
that it did not include all modification requests. As mentioned
previously, work on a modification request, which did not
receive a security review, resulted in a degraded vital area
.'
barrier.
The licensee was responsive to all NRC initiatives addressed in
the two security inspections. All issues were resolved in a
timely and thorough manner.
Licensee action on IE Information Notice No. 84-07 was resolved in a timely manner and was
technically sound. However, licensee action or IE Information Notice No. 85-79 was timely, but not thorough.
There were two events reported during the rating period involving
a security computer failure and a degraded vital area barrier.
The latter was a major loss of security effectiveness. The
major loss of security effectiveness event was improperly
18
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identified as a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> report rather than a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report,
which precipitated an untimely official notification to the NRC.
The security organization is properly resourced and responsi-
bilities are well defined. Security force members are motivated,
technically competent and well equipped. The smooth functioning
of the security program is testimony to the appropriate staffing
of the security organization.
The security force training program represents an innovative
approach to satisfying security plan commitments.
The licensee
has contracted with a local community college to develop and
administer a security force training program.
The college
y_ faculty and staff reviewed all security plan commitments and
developed a 120 hour0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> course which ensures that security
pe.rsonnel are properly trained to effectively execute security
plan commitments.
Successful completion of the course awards
security personnel three college credit hours. The faculty
is very professional and technically competent. The contractual
arrangement to administer and evaluate security training
provides a more objective evaluation of individual security
officer qualification. The quality of the Security Training
Program is reflected in the continued high performance of the
security force. The security training program will enhance the
overall quality of the security program.
2.
Conclusion
The licensee is rated Category 1 in this area based on enforce-
ment history, training initiatives, and the demonstrated high
performance of the security force. The inattentiveness to
detail demonstrated during the latter part of the assessment
period was indicative of a declining trend.
3.
Board Recommendation
A minimum inspection program is recommended.
H.
Outages
1.
Analysis
Evaluation of this functional area is based on the results of
inspections conducted by the resident inspectors. The inspection
activities included observation of fuel movements; verification
that surveillance for refueling activities had been performed;
that refueling containment integrity requirements were met; and
observation of outage controls and activities. One violation was
identified:
19
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Severity Level IV - Fail'ure to comply w'ith Technical
Specification 15.5.4.4 in that three spent fuel assemblies,
subcritical less than a year, were stored adjacent to
'
the spent fuel pool east wall.
(Inspection Reports
'
No. 50-266/85-015; No. 50-301/85-015(DRP))
The licensee identified this violation during a quality assurance
'
!
audit of the spent fuel pool records.
It appears that the
,
assemblies were inadvertently placed adjacent to the wall four
months after they were removed from the core during a spent fuel
4
j
pool shuffle in preparation for an upcoming outage.
The licensee
'
verified that the fuel pool wall did not incur ar.y structural
j
damage due to the thermal load induced by the assemblies. The
LER submitted on this event was classified as a personnel error.
j
No other personnel error LERs were assigned to this area.
Licensee management is kept abreast of outage activities through
1
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a three times a week major items work list meeting.
The outage
!
schedule is fed into a computer program with target dates'for
i
completion of the major outage tasks. 'At the meetings the
cognizant individuals for the different tasks report on the
,
progress toward completion and revised target dates are
.
i
established if necessary. The new schedule is then printed out
by the computer, reproduced, and distributed to all plant
management. This method of controlling outage activities has
>
proved to be very effective.
l
At the completion of the outage, as systems are turned back over
to the operations group, a series of operational readiness
-
j
tests are conducted. During these tests, all safety systems
are tested and verified as operational prior to plant startup.
,
'
During monitoring of this testing the inspectors have found few
if any instances of systems which were not properly returned to
service or which did not function as required. This indicates
>
1
that maintenance performed during the outage was properly
~
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accomplished and that valve lineups after maintenance were
.
!
correct and properly verified. This again is indicative of the
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high level of professionalism exhibited by the maintenance and
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operations groups.
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During this SALP Period several modifications and inspections
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were accomplished during refueling outages. These included:
!
i
inspection and replacement-of guide tube split pins, removal of-
!
]
flexure pins and installation of flexureless inserts on the
guide tubes, reactor vessel nozzle' inspections and inspection
!
of baffle plate joints. The licensee has made plans to do a
,
baffle plate flow modification on both units during the fall
l
1
1986 and spring 1987 refueling outages. Prior planning and
!
management involvement were evident in coordinating these extra
activities.
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Actual fuel movement is accomplished by experienced and well
trained licensee personnel.
Procedures are strictly adhered
to and no significant problems were encountered during the
three outages in this SALP period.
2.
Conclusion
The licensee is rated Category 1 in this area.
Licensee
performance was determined to be improving near the close
of the SALP assessment period.
3.
Board Recommendations
None.
I.
Quality Programs and Administrative Controls Affecting Quality
1.
Analysis
Quality Assurance (QA) pregrams and general administrative
controls were routinely assessed during the period by the
resident inspectors.
Two region-based inspections were
conducted covering followup of concerns identified during a
comprehensive QA inspection conducted during the previous
SALP and an inspection involving equipment qualification (EQ).
The NRC Office of Inspection and Enforcement conducted a special
team inspection to review the implementation of the licensee's
EQ program in accordance with the requirements of 10 CFR 50.49.
Two violations were identified as follows:
Severity Level IV - Failure to review the use of, or provide
a justification for, continued operation with auxiliary
feedwater flow transmitters which had been determined to be
unqualified.
(Inspection Reports No. 50-266/85-013(DRS);
No. 50-301/85-013(DRS)).
Severity Level IV - Failure to perform a complete test sequence
on specimens of Rockbestos coaxial cables or provide an
analysis of the discrepancy in support of the qualification
of this cable.
(Inspection Reports No. 50-266/85-013(DRS);
No. 50-301/85-013(DRS)).
The EQ special team inspection reviewed the program as required
by 10 CFR 50.49. The inspection also included examination of
selected procedures and records, interviews with personnel, and
observations by the inspectors. The inspection determined that
the licensee has implemer,ted a program to meet the requirements
of 10 CFR 50.49.
During the SALP period, the licensee continued to resolve issues
generated during the comprehensive QA inspection at a generally
acceptable rate.
The items closed represented both program and
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implementation problems, primarily in the areas of work control,
document control, and audits. One open issue involving
10 CFR 50.59 safety evaluations was being addressed by adequate
interim measures pending final program revision.
Resolution of
these items has considerably strengthened the licensee's
performance in the QA area.
One issue from the QA inspection remains open. This issue
involves the failure to train personnel involved in inspection
activities in the inspection process and inspector responsibili-
ties and the failure to document inspector qualifications.
While the issue is being addressed, progress has been very slow.
A special region-based EQ inspection was conducted and limited
to reviewing the qualification of Limitorque motor-operated
valve operator internal wires identified as potentially
deficient by IE Information Notice No. 86-03. Two items of+
concern were identified:
the adequacy of qualification for
two types of insulation used and the lack of emergency
procedures for manually stroking valves in the event of motor-
operator failure during an accident.
Both concerns are being
reviewed by NRR.
The licensee's response to the qualification issue was acceptable
with all unqualified wires to be replaced during the next unit
outage. The emergency procedure issue has not been resolved nor
corrective action initiated.
During the SALP period the resident inspectors attended meetings
of the offsite review committee and reviewed minutes of the
manager's supervisory staff meetings. Meeting agendas are
appropriate with highest priorities given to safety-related
issues.
NRC bulletins and information notices as well as INPO
significant operating events are reviewed by the entire staff
and routed to appropriate individuals for action. The licensee
developed its own lessons learned check list after the Davis-Besse
event of June 9, 1985, and assigned various staff members with
the task of assuring similar events would not occur at Point
Beach.
The licensee's quality programs are geared toward the
safe operation of the plants.
There is evidence of management involvement in the resolution
of identified concerns; however, resolution of problems is
occasionally slow.
Corrective actions, when accomplished,
are generally appropriate.
2.
Conclusion
The licensee is rated a Category 2 in this functional area.
3.
Board Recommendations
None.
22
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J.
Licensing Activities
1.
Analysis
This evaluation represents the integrated inputs of the Project
Manager (PM) and those technical reviewers who expended
significant amounts of effort on PBNP licensing actions during
the current rating period.
The basis for this appraisal was the licensee's performance in
support of licensing actions that were either completed or had a
significant level of activity during the rating period. There
were a total of 96 active actions at the beginning of the rating
period. Seventy actions were added during the rating period for
a total of 166 actions. Ninety-six actions were closed during
the rating period and seventy actions remain active at the end
of this rating period. These actions and a partial list of
completions consisting of amendment requests, exemption requests,
responses to generic letters, TMI items, and licensee initiated
actions are:
52 Multi-Plant Actions (28 completed).
Some of the completed
actions in this category are:
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Detailed Control Room Design Review Program Plan (MPA F-08)
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Diesel Generator Reliability (MPA D-19)
,
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Seismic Qualification of the Auxiliary Feedwater System
(MPA-C-14)
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Appendix I (MPA-A-02)
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Many Salem ATWS Items
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Appendix I Tech Spec Implementation Review (MPA A-02)
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Appendix R Fire Protection Review (MPA B-41)
Control of Heavy Loads Phase II (MPA C-15)
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86 Plant-Specific Actions (60 completed).
Some of the
completed actions in this category are:
Westinghouse Optimized Fuel Design
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Repeal of Confirmatory Orders (Unit 1 Steam Generator)
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Heavy Loads Handling Technical Specifications.
,
Various NUREG-0737 Supplement 1 Order Modifications
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Various Environmental Qualification deadline extensions
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Overpower and Overtemperature Delta T Technical
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Specifications
Second Ten Year Interval ISI relief
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E8 TMI (NUREG-0737) ACTIONS (8 completed).
Some of the completed
actions in this category are:
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Detailed Control Room Design Review In-Progress Audit
NUREG-0737 Technical Speci fications (GL 83-36 and 83-37)
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(MPA B-83)
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NUREG-0737 II.K.3.30 Small Break LOCA Outline
The licensee's performance evaluation is based on a consideration
of the six attributes specified in NRC Manual Chapter 0516.
In addition, the licensee was evaluated in the area of
" Housekeeping".
a.
Management Involvement and Control in Assuring Quality
During the present rating period, the licensee's management
generally demonstrated active participation in licensing
activities and an openness to communicate with the staff as
demonstrated by their participation in a Licensing Action
Review meeting with the Director, Division of Licensing in
February 1985 and more recently in a Licensing Action status
meeting with the Project Manager and Project Director in
March 1986. This enabled the staff to conplete reviews of
a large number of licensing actions. Management was also
almost always available to attend necessary technical
review meetings with the staff when required for resolution
of licensing actions with the staff and frequently remains
involved in site activities.
However, some weaknesses have been noted. All license
amendment requests contained a discussion of significant
hazards considerations provided by the licensee in
accordance with 10 CFR 50.91. However, when changes have
been made to the initial application the accompanying
significant hazards consideration has merely asserted that
the initial discussion was still valid, without specifically
discussing each of the changes.
Some significant hazards
considerations discussions have also required further
discussion with the licensee to ensure that the standards
of 10 CFR 50.92 have been met.
Some requests for Technical
l
Specification changes were requested on the basis that they
i
would " increase operational flexibility" without adequate
discussion of the safety considerations.
24
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Several requests for extensions of completion dates, most
notably in environmental qualification of safety related
electrical equipment and NUREG-0737 Supplement 1 Order
dates, required additional extensions, some very shortly
after the initial reviews were completed. This shows a
weakness in controlling and tracking due dates and tho
need for improvement in this area was discussed during
the previous SALP.
The level of additional information required by the staff
to support licensing action reviews following the licensee's
initial submittal was considered average.
b.
Approach to Resolution of Technical Issues from a Safety
Standpoint.
The licensee's resolution of safety issues initiated by
the staff generally exhibited a viable, sound and thorough
approach, although frequently additional infornation was
required to achieve completed resolution. An understanding
of the safety issues was generally apparent and some
,
conservatism in the safety analysis is generally exhibited.
'
Licensing actions initiated by the licensee, most notably,
schedular relief requests, were somewhat deficient as to
discussions supporting " good faith effort" to comply and
compensatory measures proposed in support of the request.
However, the licensee usually has committed adequate staff
resources to resolve these issues is a satisfactory manner.
c.
Responsiveness to NRC Initiatives
The licensee has generally responded to requests for
information and other correspondence within the timeframe
requested. On a few occasions the licensee has required
additional time which in a small number of cases has
delayed the NRC completion of the review effort. The
licensee has frequently required extensions of time to
complete modifications, qualifications or submission of
reports in accordance with dates contained in the
Commission's Regulations and 0-ders.
Not all requests
for schedular relief were submitted on a timely basis
and though most requests proposed a viable approach,
they were somewhat lacking in depth and thoroughness.
Even in instances where the licensee's-initial submittal
and requests for schedular relief were considered " timely",
considerable NRC staff effort and in some cases repeated
submittais were required to resolve the issues in order
to avoid the licensee becoming in noncompliance with the
schedules.
In one instance the licensee indicated that
they would be in noncompliance with the schedule required
i
by 10 CFR 50.48, yet neither requested the required
25
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schedular relief nor provided arguments concerning good
faith effort to comply or compensatory measures while
ir noncompliance. Several minor noncompliances have
occurred because of the licensee's inability to meet
schedules contained in the Commission's Orders and
Regulations or otherwise obtain timely relief.
d.
Staffing
Staffing at Point Beach Nuclear Plant was small but highly
effective as evidenced by the high availability achieved
by both units during the rating period. The plant and
corporate staff generally exhibit a high degree of
professionalism and dedication and morale is high at the
site.
The small size of the corporate and plant staff
reduces the licensee's flexibility to respond to NRC
initiatives and periodic losses of key personnel due to
vacations, illness or attrition results in occasional
difficulties in completing priority assignments within
the assigned schedules.
Summary of Results
Overall, the licensee has exhibited good performance during the SALP
period; however, the licensee has not been able to effectively meet
schedules for completion of modifications and submittals as required
by the Commission's Regulations and Orders. This has resulted in an
above average number of schedular relief requests and 3 cases of
failure to meet these schedules.
This weakness was discussed with
the licensee during the previous SALP. More management attention in
this area is warranted. Staffing at both corporate offices and at
the plant is of high quality, but relatively small.
This reduces
flexibility in responding to NRC initiatives and temporary or
permanent loss of a few key employees can significantly delay review
efforts. The licensee has in most cases been effective in dealing
with significant safety problems. Morale is high at the site.
Communication between the operating staff and management at the site
is well defined and established.
Communication between the corporate staff and the site is above
average.
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2.
Conclusion
An overall performance rating of 2 has been assigned by NRR for
the current SALP rating period of October 1, 1984 to March 31,
1986.
26
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3.
Board Recommendations
The board recommends that additional management attention be
expended by the licensee in tracking completion dates for
modifications and submittals described in staff safety
evaluations and for schedular requirements contained in the
Commission's Orders and Regulations. Should schedular relief be
required, the request should be submitted enough in advance to
allow sufficient time for staff review prior to the required
completion date and should contain all necessary discussions to
support the relief request.
K.
Training and Qualification Effectiveness
1.
Analysis
Resident and regional inspectcrs have evaluated training and
qualification effectiveness during inspection of specific
program areas. No violations were identified in this area.
The training and qualification program in effect results in a
highly qualified, effective, and highly motivated operator.
This allows for relatively small site and corporate staffs,
achieving a high availability with very few personnel errors.
During the period, examinations were administered to four
reactor operator candidates and two instructor certification
candidates. All candidates passed the examinations. This
passing rate is significantly above the national average
passing rate. Operator feedback is strongly encouraged.
A defined, comprehensive, task oriented training program has
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been developed and initiated during this assessment period for
the radiation protection technicians and trainees. ~ This
training program was a considerable improvement over the
program provided during the previous assessment period and
should upgrade the technical level of the radiation protection
staff.
Events are reviewed for training implications and the
results of the review are used to improve the training program.
Excellent on-the-job training has been a strong point at Point
Beach in all disciplines. With the extremely low turnover of
personnel, trainees benefit from the many years of experience
available to instruct them in accomplishing their tasks.
The
results of the effectiveness of this type of training is
evidenced in the excellent reliability of the plant.
Classroom training includes a task analysis of events occurring
at Point Beach and at other plants throughout the industry.
Each event is analyzed to determine if any lessons could be
27
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learned to promote safer operation of the plant. Once these are
established, a lesson plan is developed and all affected
departments are given the training.
The licensee is making good progress towards INP0 accreditation
of training programs. Accreditation of the Senior Reactor
Operator, Reactor Operator, Radiation Protection Technician,
and non-licensed operator training programs are expected in
the near future. Self evaluation reports for the remaining
training programs are expected to be submitted during 1986.
2.
Conclusions
The licensee is rated Category 1 in this functional area based
on their above average license exam pass rate and well-defined
task oriented program.
3.
Board Recommendations
None.
1
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V.
SUPPORTING DATA AND SUMMARIES
A.
Licensee Activities
1.
On October 1, 1984, at the beginning of the SALP assessment
period, Unit 2 was in a refueling shutdown which started on
September 28, 1984.
2.
On November 20, 1984, Unit 2 generator was phased to the line
ending the tenth refueling shutdown. Major activities during
the outage were:
changing out and balancing the "B"
reactor
coolant pump motor; modifying the reactor trip breakers;
installation of new incore thimbles; and replacement of reactor
coolant system RTD's.
3.
On December 11, 1984, Unit 2 was taken off line to replace a
leaking snubber discovered during a containment inspection.
The unit was returned to power on December 12, 1984.
4.
On April 5,1985, Unit I was taken off line for refueling. The
unit operated during 360 of the possible 361 days since the
previous refueling, with the last 257 days being contin:uous.
5.
On June 19, 1985, Unit I was placed back on line. Major
activities during the outage included:
control rod guide tube
flexureless insert and split pin modifications; secondary heat
exchanger sludge lancing and tube plugging; repairing the "A"
and "B" main feed pump rotating assemblies; inspecting fuel
assemblies for evidence of " baffle jetting"; and investigation
into the sticking of control rods F12 and J4 with rod drop
testing.
6.
On June 20, 1985, Unit I was removed from service for turbine
overspeed tests. The unit was placed back on line ten ho.Jrs
later.
7.
On June 26, 1985, a circuit board failure caused a blown tuse
in an inverter causing power to the white instrument bus to
be lost. Unit 1 experienced an immediate turbine runback to
80% power due to loss of power to nuclear instrumentation
channel 42 and then experienced a reactor trip on low stean.
generator level with a coincidental steam flow / feed flow
mismatch. The unit was placed back on line June 27, 1985.
8.
On August 31, 1985, Unit I was shutdown to replace a failed
nuclear instrument channel. The unit was returned to power
on September 1, 1985.
9.
On October 5, 1985, Unit 2 was taken off line to begin the
eleventh refueling outage.
The unit operated during all of
the 319 days since the previous refueling, with the generator
being taken off line only once for about six hours.
The unit
operated for the last 298 consecutive days without any
significant power reductions.
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10. On November 24, 1985, the Unit 2 generator was placed on line.
The following day, the generator was taken off line temporarily
for overspeed testing. Major activities during the cutage
included:
steam generator eddy current testing which revealed
that ten tubes of "A" steam generator and 44 tubes of the "B"
steam generator required plugging; replacement of main
condenser tubes and various feedwater heaters; and a failed
fuel rod was found in two fuel assemblies. The fuel failure
was caused by fuel rod vibration resulting in fretting wear at
the fuel rod grid supports.
11. On December 27,1985, Unit 2 was taken off line to repair a
small crack in a weld on a component cooling water to the "A"
reactor coolant pump lube oil cooler. The unit was returned
to power on December 29, 1985.
12. On December 31, 1985, Unit 2 tripped because of a phase-to ground
fault in the "A" phase lightning arrester in the switchyard. The
unit was placed back on line on January 1,1986.
B.
Inspection Activities
During SALP 5 assessment period October 1,1984 through March 31,
1986, 29 inspections were conducted. Among these inspections were:
1.
A team inspection was conducted during the period July 22
through 26, 1985. The team reviewed implementation of a
program as required by 10 CFR 50.49 for establishing and
maintaining the qualification of electric equipment within
the scope of 10 CFR 50.49 and potential enforcement. This
team inspection also included evaluations of the implementation
of equipment qualification corrective action commitments made
as a result of the December 22, 1982, Safety Evaluation Report
and the September 28, 1982, Franklin Research Center technical
evaluation report.
2.
Emergency Preparedness Exercises, conducted September 9 through
11, 1985, (85-012;85-012).
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INSPECTION ACTIVITY AND ENFORCEMENT
POINT BEACH, UNITS 1 and 2, DOCKET NOS. 50-266, 50-301
Inspection Reports No. 84018 through 84022
No. 85001 through 85023
No. 86002 and 86004
FUNCTIONAL
NO. OF VIOLATIONS Ill EACH SEVERITY LEVEL
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I
II
III
IV
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DEV.
Plant Operations
1
Radiological Controls
1
1
Maintenance
Surveillance
1
Fire Protection
1
,
Security
Outages
1
Quality Programs and
Administrative
Controls
2
1
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Licensing Activities
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Training and Qualification
Effectiveness
.
Totals
6
2
1
1
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Violations reflect total violations for the site rather than violations
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associated with each unit.
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C.
Investigations and Allegations Review
No allegations were received during the SALP 5 assessment period.
No investigations were conducted during the SALP 5 assessment period.
D.
Escalated Enforcement Actions
No Escalaced Enforcement cases were conducted during the SALP 5
assessment period.
E.
Management Conferences Held During Appraisal Period
December 18, 1984, Management meeting with Wisconsin Electric Power
management representatives in Milwaukee, WI to discuss the Systematic
Assessment of Licensee Performance (SALP 4) for Point Beach Nuclear
Power Plant.
F.
Confirmatory Action Letters
No Confirmatory Action Letters were issued during the Point Beach SALP
5 assessment period.
G.
Review of Licensee Event Reports and 10 CFR 21 Reports
Three different reviews of LERs were conducted by different
organizations. (i.e., Region III, AE00, NRR).
1.
Region III
On January 1,1984, NUREG-1022 " Licensee Event Report System"
was amended incorporating a new rule in proximate cause codes
and definitions of the proximate causes.
This new rule tends
to project a different picture of events which resulted from
personnel errors. Therefore, a separate review of all the
LERs submitted by Point Beach, during this assessment was
conducted by Region III, to provide meaningful comparative
information of these events. Those LERs are discussed in the
,
appropriate functional area analysis section of this report.
The LERs for this assessment period include Unit 1;85-001
through 85-010 and 86-001, Unit 2 84-005 through 84-008 and
85-001 through 85-005.
PROXIMATE CAUSE*
SALP 5
Personnel Error
7 (0.39)**
Design, Manufacturing,
1 (0.06)
Construction / Installation
External
1 (0.06)
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Defective Procedures
2 (0.11)
Component /0ther
9 (0.50)
Total
20 (1.11)
- Proximate Cause is the cause assigned by the licensee in
accordance with NUREG-1022, " Licensee Events Report System".
- Numbers in parentheses are_ average number of events per month.
It snould be noted that Point Beach submitted 20 LERs during
this assessment period. This is a relatively low number when
compared to other operating multi-unit sites. This low number
of LERs is another exemple of the high quality plant performance
at Point Beach as seen throughout this assessment period.
Among the 20 LERs, there were 3 Inadvertent Starts of Emergency
Diesel Generator Events,1 Inadvertent Safety Injection,
2 Reactor Trips and 6 Nuclear Instrumentation Turbine Runbacks.
2.
Analysis and Evaluation of Operational Data AEOD
An evaluation of LERs was made by the Office of Analysis and
Evaluation of Operational Data (AEOD).
I.n general the licensee
submittals were found to be of average qualitp based on the
requirements of 10 CFR 50.73.
The complete document, which
provides the details of each LER evaluated has been sent to the
licensee under a separate cover letter dated May 21, 1986.
This evaluation process was divided into two parts. The first
part of the evaluation consisted of documenting comments
specific to the content and presentation of each LER.
Second
part consists of determining a score (0-10 points) for the
text, abstracts, and coded fields of each LER.
The weaknesses identified were mainly that of document processing
(i.e., filling out the LER form); in that, some components were
inadequately identified; the licensee failed to reference previous
similar events in the text; and the licensee failed to provide an
adequate safety assessment for every event.
These inconsistencies prompt concerns that possible generic
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problems may go unnoticed by the industry for a longer time
period if component failures are not identified properly; that,
the plant may not be documenting all its events in a manner
which will enable it to identify possible trends or recurring
problems; and as to whether or not each event is being evaluated
for the possible consequences of the event, had it occurred
under a different set of initial conditions.
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It was suggested that the station should consider the use of an
outline format for their LERs such as the one recommended in
Appendix C of NUREG-1022, Supplement No. 2. to prevent future
incpnsistencies in preparing and evaluating LERs.
It was concluded by AE00 that the licensee ranked 36 and 37th
out of a possible 53 units (i.e. licensees), giving Point
Beach 1 and 2 an overall average LER score of 7.4 out of a
possible 10 points. A strong point for the Point Beach LERs
is that information concerning the failure mode, mechanism,
and effect of each failed component, required by
50.73(b)(2)(ii)(e), was well written for the LERs that were
evaluated.
3.
Office of Nuclear Reactor Regulation (NRR)
A third input to the Licensee Event Reporting area was provided
by NRR and consisted of all types of reporting including LERs.
Reportable events at Point Beach Nuclear Plant appeared to have
been reported promptly and accurately.
Some minor inadequacies
in prompt notification were noted during the reporting period.
However, the licensee had taken prompt action to correct these
inadequacies. Thus, the licensee received high grades from
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that perspective, as reflected in the Plant Operations functional
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area.
4.
10 CFR 21 Reports
The licensee submitted a report on July 24, 1985, which described
a single failure potential in the safety injection recirculation
path. The licensee determined that the failure of a single
component in the control circuitry for the safety injection
recirculation path isolation valves could result in the failure
of both safety injection pumps. The licensee included a detailed
description of this deficiency and proposed corrective actions.
H.
Licensing Actions
,
1.
NRR/ License Meetings
Control Rod Guide Tube Flexureless Inserts
11/1/84
Upper Plenum Injection - Evaluation Model
1/10/85
Upper Plenum Injection - JAERI Meeting
3/13/85
Upper Plenum Injection - Status Meeting
6/28/85
Upper Plenum Injection - Evaluation Model
11/20/85
Licensing Action Status / Organizational Orientation
3/25/85
Meeting
2.
NRR Site Visits / Meetings
Fire Protection
12/13/84
SALP 4 Meeting
12/18/84
Operator Requalification Program Meeting
1/16/85
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Envirormental Qualification Audit-
7/22-26/85
Site Visit.. Japanese Visitors
11/03/85
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Site Visit Appendix R Exemptions
r?11/25/S5
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Regulitary Effectiseness Review
12/2-6/85
Detailed Control Room Design Review
12/2-6/85
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3.
Commission Meetings
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Environmental Qualification (EO) Deadline Extension
10/25/85
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Request
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4.
Schedular Extensions Granted-
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EQ Deaalire Extens. ion
11/5/84
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NUREG-0737 Supolnment 1 Order Modification
2/5/85
(TSC Power Suply)
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NUREG-0737 Supplement 1 Order Modification
2/5/85
,,
(EOP implementatien)
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EQ Dea'iline Extension
7/17/85
NUREG-9737 Supplement 1 Order %dification
10/16/85
(DCK3R Summary Report)
,
EQ Deadline Extension
11/20/85
NUREG-0737 Supplement 1 Order Modification
1/6/86
NUREG-0737 Supplement 1 Order Modification
(DCRDR Summary Report)
3/21/86
5.
Reliefs Granted
,
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IST Interim Relief
~/
3/4/85
Modification of IST Interim Relief
6/11/85
,
ISI 2nd 10 year interval relief
10/31/85
's
IST Interim Relief Extension
2/26/86
6.
Exemptions Granted / Denied
,
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Appendix R Fire Protection (Granted)
7/3/85
4160V Switchgear Room, Appendix R (Denied)
8/21/85
7.
, License Amendments Issued
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Amendment No.
Title
Date
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86 and 90
Optimized Fuel Design
10/5/84
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91 (Unit 2)
Overpower, Overtemp-
11/16/84
erature Delta T
87 and 92
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Tech Spec Effective
12/27/84
Date Change
88 and 93.
Control Rod Insertion
3/7/85
Limits
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89 and 94
Containment Tendon
3/7/85
Surveillance
90 (Unit 1)
Overpower, Overtemp-
4/4/85
erature Delta T
91 and 95
Heavy Loads Over Spent
4/8/85
Fuel
92 and 96
NUREG-0737 T. S.
7/18/85
93 and 97
Reactor Coolant Gas
7/22/85
Vents
94 and 98
Reactor Coolant Pump
7/22/85
Underfrequency Trip
95 and 99
7/26/85
96 and 100
Single Failure Proof
9/3/85
Crane
97 and 101
Radiological Effluent
10/3/85
Tech Specs
98 and 102
Reactor Vessel Capsule
10/22/85
Removal Schedule
99 (Unit 1)
Steam Generator Leakage 11/4/85
Limit
8.
Emergency Technical Specifications
Amendment 91, Overpower, Overtemperature Delta T issued 11/16/84
for Unit 2
9.
Orders Issued
None
10.
NRR/ License Management Conferences
DL Division Director Briefing
2/5/85
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