ML20135E493

SALP Rept 50-341/85-27 for Oct 1984 - June 1985

ML20135E493
Person / Time
Site:	Fermi
Issue date:	09/11/1985
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20135E349	List: ML20135E346 ML20135E493
References
50-341-85-27-01, 50-341-85-27-1, NUDOCS 8509160417
Download: ML20135E493 (46)

See also: IR 05000341/1985027

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SALP 6

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SALP BOARD REPORT

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U.' S. NUCLEAR REGULATORY COMMISSION

, REGION III

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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE  !

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50-341/85027

i Inspection, Report  ;

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l Detroit Edison Company

Name of Licensee

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l ' Fermi 2

i Name of Facility  ;

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! October 1,1984 through June 30, 1985  !

!- Assessment Period I

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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

sufficiently diagnostic to provide a rational basis for allocating NRC

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

promote quality and safety of plant construction and operation.

An NRC SALP Board, composed of staff members listed below, met on June 27,

1985, to review the collection of performance observations and data to assess

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the licensee's 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.

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

at Fermt Unit 2 for the period October 1,1984, through June 30, 1985.

SALP Board for Fermi 2:

Name Title

! J. A. Hind Director, Division of Radiation Safety

1 and Safeguards (DRSS)

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R. L. Spessard Director, Division of Reactor Safety (DRS)

i C. E. Norelius Director, Division of Reactor- Projects (DRP)

i C. J. Paperiello Chief, Emergency Preparedness and

Radiation Safety Branch

L. A. Reyes Chief, Operations Branch, DRS

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N. J. Chrissotimos Chief, Reactor Projects Section ID

J. R. Creed Chief, Safeguards Section

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M. A. Ring Chief, Test Programs Section

M. P. Phillips Chief, Emergency Preparedness Section

D. H. Danielson Chief, Materials Section DRS

T. Madeda Security Inspector, DRSS

, S. G. DuPont Reactor Inspector, TPS

S. Stasek Project Inspector, Reactor Projects

Section 10

, Z. Falevits Reactor Inspector, DRS

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R. Hasse Reactor Inspector, DRS

M. D. Lynch Licensing Project Manager, NRR

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II. CRITERIA

The licensee's performance is assessed in selected functional areas

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

operating phase. Each functional area normally represents areas

significant to nuclear safety and the environment, and are normal

. programmatic areas. Some functional areas may not be assessed because  !

of little or no licensee 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

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functional area.

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1. Management involvement in assuring quality

2. Approach to resolution of technical issues from a safety standpoint

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3. Responsiveness to NRC initiatives

4. Enforcement history

i 5. Reporting and analysis of reportable events

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6. Staffing (including management)

l 7. Training effectiveness and qualification.

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

i have been used where appropriate.

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

classified into one of three performance categories. The definition of

i these performance categories is:

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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. -

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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

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reasonably effective such that satisfactory performance with respect to

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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; ljcenseenresources appear to-

be strained or not effectively used so that minimally satisfactory

performance with respect to operational safety be construction is being

, achieved.

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Trend: The SALP Board has also categorized the performance trend in each ,

functional area rated over the course of the SALP assessment period. The '

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categorization describes the general or prevailing tendency (the perfor-

, mance gradient) during the SALP period. The performance trends are

defined as follows:

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Improved: Licensee performance has generally improved over the course

l of the SALP assessment period.

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! Same: Licensee performance has remained essentially constant over i

the course of the SALP assessment period.

Declined: Licensee performance has generally declined over the course

j of the SALP assessment period.

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III. SUMMARY OF RESULTS

Overall, the licensee's performance was found to be acceptable and showed

an improving trend. The licensee was found to have aggressive management

attention and a high level of performance in the areas of Emergency

Preparedqcss,' Fueling, and Preoperational and Startup Phase Testing.

! Performnce in the Fire Protection area was found to need increased ~

management attention as well as maintenance of the' current increased NRC

staff attention during subsequent inspections.

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, , Rating't$st Rating This '

Functional Area Feriod-. ..s Period .T' end

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A. Piping. Systems 1

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j and Supports 2 2 Same

B. Electrical Power

~ p Supply / Distribution

'and Instrumentation / -

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Control Systems 3 ~2 , , Improved

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C. Fire Protection 3 3, Same

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D. Preoperational and-

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.Startup Phase Testing 2 1 Improved

E. ~ Plant Operations NR y 2 NR

F. Radiological Controls,, 2 '

2 Same

'G. Maintenance NR 2 NR

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H. , Surveillance NR 2 _

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1. Emergency Preparedness 1 ., [ '1

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Same

J. Security 2 l 2

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Same

K. Fueling '

NR 1 NR

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, Quality Programs-and

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Administrative Controis

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' ;M. Licensing Activities 2 2 .Same

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i *NR = not rated or not rated- separately.

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IV. PERFORMANCE ANALYSIS

A. Piping Systems and Supports

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1. Analysis

j Work activities in this area are essentially complete. Examina-

tion of this functional area consisted of four inspections by

regional based inspectors (50-341/84-52; 50-341/84-55; 50-341/

i 84-59; and 50-341/85-11). Areas examined included (1) actions

related to previous inspection findings, 10 CFR 50.55(e) items,

IE Bulletins and IE Circulars, (2) Sargent and Lundy design

practices, (3) effects of postulated high and moderate energy  ;

pipe breaks outside primary containment, and (4) allegations

brought to the attention of the NRC.

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Two violations were identified; Severity Level IV violation

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(50-341/85011(DRS)) - Failure to take appropriate corrective

action relating to disposition of an anchor bolt spacing deft-

! ciency report, and Severity Level V violation (50-341/85011(DRS))

- Inadequate design control for installation of anchor bolts.

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The violations are not repetitive of noncompliance identified l

during the previous assessment period and they do not appear

to have programmatic implications.

Concerns reported to the Resident Inspector relating to the

reactor vessel jet pump diffuser to adapter welds were

. inspected. Neither the governing code nor the applicable

i procedures were violated by the licensee or its agents. Based

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on satisfactory completion of appropriate examinations and

resolution of the radiographic issue, these welds were

acceptable.

! For the areas examined, the inspectors determined that the

management control systems met regulatory requirements. Except

as noted above records were found to be complete, well main-

tained and avai.lable. Discussions with licensee and contractor

personnel indicated that they were knowledgeable in their job.

No major strengths or weaknesses were noted.

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2. Conclusion

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The licensee is rated Category 2 in this area. Licensee

! performance remains the same.

3. Board Recommendations

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None.

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B. Electrical Power Supply / Distribution and Instrumentation / Control

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System

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1. Analysis

During this assessment period, licensee activities in this area

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were observed during ten inspections. The areas inspected

include: electrical separation requirements including design

and field installations; review of as-built electrical and I&C

, verification; deviation dispositioning programs; review of licen-

see corrective action and resolutions to the Duke Construction

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Assessment Team recommendations; independent design review of  !

drawings for adequacy; control and conformance of as-built

! configurations of installed electrical components; review of QA

installation records; review of testable check valve and breaker

, position indicators; cable routing; instrument calibration; and

investigation of allegations. Six items of noncompliance were

4 identified as follows:

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(a) Severity Level IV - Failure to assure that deficiencies in

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the control logic schematic diagrams of the RHR System were

properly identified, corrected, and controlled (Inspection

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Report No. 50-341/84-57).

(b) Severity Level IV - Failure to assure that the as-built

general arrangement drawings 61721-2281-19, Revision "J"

and 61721-2281-5, Revision "H", reflected as-built

conditions for instrument racks H21-P021 and H21-P005 in

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the following areas: discrepancies were identified in

catalog numbers, identification and location of instruments,

i valves, and tubing (Inspection Report 50-341/84-50).

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! (c) Severity Level IV - Failure to take measures to control

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the issuance of documents prescribing activities affecting

1 quality, and to assure that documents, including changes,

j are reviewed for adequacy and distribution to and used at

the location where the prescribed activity is performed

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(Inspection Report 50-341/84-62).

(d) Severity Level IV - As installed wiring of protective

undervoltage relays 27ZX, 27YZ and 27XY, mounted in

position IA of 480v safety-related switchgear 72F and

undervoltage relay 27XY, mounted in position IA of

safety-related switchgear 72E, did not conform to

connections delineated on wiring diagrams 650721-2511-50,

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Revision "K", and 650721-2511-43, Revision "H", respec-

tively (Inspection Report No. 50-341/84-62).

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(e) Severity Level IV - The inspector identified twenty-five

missing or burned out breaker position status indicating

lights in twenty-one positions of safety-related switch-

gears (Inspection Report No. 50-341/84-62). '

(f) Severity Level IV - Failure to assure that changes and

revisions to drawings were adequately reviewed and

controlled when used in Checkout and Initial Operation

(C&IO) testing of safety-related systems (Inspection

Report No. 50-341/84-68).

During this period, the licensee has initiated a comprehensive

enrrective action program as a result of NRC findings in major

areas such as: as-built configuration deficiencies of

installed electrical and I&C components as compared to the

applicable design drawings, (e.g., control logic schematic

diagrams, connection-diagrams, front elevation drawings,

specifications, etc.); sizing of safety-related fuses relative

to the design of circuit requirements, sizing of thermal

overloads and drawing control.

The implementation of corrective actions has been closely

monitored through increased NRC inspection activities. The

corrective action taken to resolve the as-built issue is still

ongoing. While most hardware deficiencies have been resolved,

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resolution of the software item deficiencies is still in

progress. The fuse and thermal overload issues have been

completed. Corrective action has been adequate in providing

more accurate as-built design drawings which reflect design

and regulatory requirements.

The NRC inspectors reviewed the licensee response to, and

corrective action taken to address the Duke Power recommenda-

tions. Corrective action was timely and effective in most

Cases.

2. Conclusion

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

was rated Category 3 in this functional area in the previous

assessment period. The licensee performance appears to have

generally improved following the previous SALP assessment

period.

3. Board Recommendations

Licensee management should continue placing major emphasis on

maintaining accurate as-built design documents and ensuring

, adequate completion of the comprehensive corrective action

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. programs now in place. Close attention should be placed on

following procedures specifically in the plant maintenance

area. ,

i C. Fire protection

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1. Analysis

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i During this assessment period, four inspections were performed i

i (50-341/84-49(DRS),50-341/85012(DRS),50-341/85014(DRS),and l

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50-341/85025(DRS)) by regional inspectors including one alle-

! gation followup. .These inspections did not overlap the previous

. SALP period. These inspections were performed to assess con-

I formance of the as-built plant conditions to FSAR commitments,

i fire protection program implementation, and post fire safe

i shutdown capability.

During the first of the four inspections-conducted, two devia-

tions were identified as follows: (1) the installation of

portable fire extinguishers having less extinguishing capability

than those portable extinguishers identified in the FSAR, and

1 (2) the failure to design and install fire detectors in

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accordance with FSAR commitments. In addition, the licensee's

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Quality Assurance (QA) program for construction was found to be

inadequate in the area of fire protection and the QA program

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governing operations was found to be inconsistent with FSAR

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commitments.

During the three subsequent inspections, the inspectors noted

that the licensee was devoting considerable attention and

resources to resolving NRC identified problems in the fire pro-

i tection area. However, despite the increased licensee effort,

the inspectors found additional examples of deficiencies in fire

detector installations and fire rated assemblies.

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There was one allegation followup inspection that pertained to

one fire protection sprinkler system having improperly installed

j horizontal sidewall sprinkler heads. It was determined that six

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sprinkler heads were questionable regarding their installed

position. These heads were replaced by the Itcensee and veri-

fied by a Region III fire protection specialist.

! Other open and unresolved items identifying varying degrees of

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deficiencies were discovered in the areas of Construction, Fire

Detection System Design, and the maintaining of emergency light-

1 ing units. The licensee has implemented compensatory measures

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in several areas of the plant as a result of a failure to provide

proper design features to limit fire damage to redundant safe

shutdown trains.

The licensee was rated Category 3 in this functional area during

the SALP 5 evaluation period. As documented in the SALP 5

report (50-341/84-23) and associated transmittal letters, the

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primary reasons for the Category 3 rating were a lack of manage-

ment attention to the development and implementation of the Fire

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Protection Program, a failure on the part of management to fully

understand its commitments to the NRC, and a failure on the part

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of management to ensure that those commitments which were under-

stood were properly implemented. It was noted in that report

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that management appeared to be taking aggressive actions to

i correct deficiencies identified by the NRC. As noted above, in

, spite of increased management attention and the expenditure of

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considerable resources, the NRC continued to identify problems

in this functional area. While many NRC identified issues were

resolved as a result of the increased management attention, the

fact that other problems were identified by the NRC is indica-

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tive of a failure on the part of the licensee to take the

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initiative in the fire protection area.

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2. Conclusion

i The licensee is rated Category 3. While evidence of increased

management attention was noted, the NRC has continued to iden-

tify examples of previously identified problems most notably in

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the areas of fire rated assemblies and fire detection systems.

Licensee performance has remained essentially constant over  ;

the evaluation period.

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3. Board Recoamendations

Management attention should be directed at ensuring continuing

compliance. An increase in the level of effort devoted to self

assessment is warranted. An increased level of NRC attention  ;

should be maintained. L

l D. Preoperational and Startup phase Testing

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) 1. Analysis I

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! The preoperational and startup phase testing efforts were ,

! inspected by both region based and resident inspectors. The i

! region based inspectors performed five inspections and the i

resident inspectors performed portions of inspections during  :

j this assessment period. This assessment period reflects

continuing improvements in the licensee's performance. The

inspection ef fort included in-depth reviews of preoperational [

and startup phase test procedures and preoperational test i

results, witnessing preoperational and startup phase test  ;

performance, reviews of administrative controls and imple- I

menting procedures, observations of corrective actions and I

independent inspection. During this assessment period there "

j were no items of noncompliance identified in the startup i

testing phase. Two violations were identified during review of (

j the containment integrated leak rate test:

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Severity Level IV - Failure to follow procedures during testing

i of personnel access hatch (Inspection Report No. 50-341/84-53).

l Severity Level IV - Failure to take adequate corrective action  ;

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to preclude repetition of incorrect valve position indication  !

, (Inspection Report No. 50-341/84-53). j

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There were no major technical problems identified during this

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assessment period with the exception of the foreign debris found

in safety-related piping systems. This problem was-discussed

j in detail in the SALP 5 assessment and one recurrence was identi-

fied during this assessment period. The licensee found debris

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in the scram discharge volume which was evaluated as being

! debris from maintenance prior to the system flush.

) Even though there has been one recurrence, the licensee's

administrative measures have prevented any new debris

j intrusions into safety-related piping.

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Management's initiatives to correct previous problems were

] thorough and aggressive. As a result of this attention, none  ;

of the previously identified problems recurred and no items of '

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noncompliance were issued for the preoperational test program. [

2. Conclusion I

The licensee is rated Category 1 in this area based on the ,

management improvements in the implementation of corrective '

actions that have prevented recurrence of problems identified

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in both SALP 4 and 5 assessments.

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l 3. Board Recommendations

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None,

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E. Plant Operations

1. Analysis

! The operational phase efforts were inspected by both region-

based and resident inspectors. The resident inspectors ,

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performed six inspections and the region-based inspectors l

j performed portions of two inspections during this assessment

period. This functional area was not assessed during the

previous SALP period.  :

! The licensee received their operating license during the  !

! assessment period. The assessment in this functional area '

j was divided into two phases - those issues required to be

i completed for the issuance of the operating license, and

j the operation of the plant af ter issuance of the license.

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The inspection effort included in-depth reviews of procedures

in preparation for the issuance of the operating license,

reviews of administrative controls and implementing procedures,

observations of corrective actions and operator actions, and

independent inspection.

Four items of noncompliance were identified as follows:

a. Severity Level IV - Failure to follow administrative

procedures (Report No. 50-341/84-40).

b. Severity Level IV - Procedures were found to be inadequate

or incomplete. (ReportNo. 50-341/84-40).

c. Severity Level V - The use of inadequate procedures to

collect battery data. (Report No. 50-341/84-46),

c. Severity Level V - An Engineering Design Package (EDP) was

not implemented in accordance with the EDP implementation

procedure (Report No. 50-341/85021).

Noncompliances a. and d. represented personnel errors in that

procedures were not followed or work was not performed in an

acceptable manner.

Noncompliances b. and c. were programmatic in nature and

represent inadequate procedural reviews.

The licensee walked through all surveillance procedures prior

to issuance and implementation. In addition, the licensee was

required to re-review all other procedures for technical

adequacy prior to operating license issuance. The result of

this action is that there have been no Licensee Event Reports

(LERs) written as a result of inadequate procedures.

Twenty-seven incidents have occurred since license issuance

which have or will result in the issuance of an LER. Seven-

teen LERs have been issued to date. These can be categorized

as follows:

7 personnel related

5 - hardware related

5 - design related

The seven personnel errors can be categorized as failure to

follow procedures and/or technical specification requirements

and communication problems. The hardware-related items have

no pattern while the design / technique-related incidents all

occurred while performing surveillances on reactor level

instrumentation. The vessel level instrumentation utilizes

a common reference leg which frequently results in a scram

signal when the reactor is not at operating pressure.

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! There does not appear to be any significant issues identified

, in the LERs nor does there appear to be any significant issues

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in the remaining ten items yet to be reported. The greatest t

i problem area has been the failure to follow procedures and/or

technical specification requirements. In addition to the seven

identified by LERs, two of the remaining ten items.that must be -

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addressed fall into this same category.  !

} The Plant Operations area is fully staffed. Senior management

overview, both onsite and from the corporate office, was evident

throughout the assessment period. l

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Currently, there are 20 senior reactor operators (SR0s) and 21

) reactor operators (R0s) onshif t. During the assessment period, .

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! NRC licensing exams were administered to four SRO candidates

! and seven R0 candidates. Of these, two SR0 candidates passed

and all of the R0 candidates passed. [

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j The operators appear to be well trained and cautious. The

j inspectors have observed their thoroughness in carrying out

j their duties. This is reflected in the lack of LERs relating  ;

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to operator error.

Region III conducted a team inspection during the assessment

j period to evaluate the licensee's ability to operate the plant ,

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in an acceptable manner. The team, which consisted entirely ,

of Resident Inspectors from operating sites, performed in-depth

j reviews of plant operations, maintenance, surveillance, and  ;

i radiation protection programs and concluded that the plant was ,

implementing these programs satisfactorily and that the licensee  ;

j was ready to support full power operation.  ;

t 2. Conclusion  :

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

was not rated in this area during the last assessment period.  ;

No trend could be established in this area. -

3. Board Recommendations

, The Board recommends that the licensee maintain a high level of

i attention to this area due to the limited amount of operating

i experience accumulated to date. Concerted effort by licensee

management may be required to ensure that indicated performance

{ remains at an acceptable level,

j F. Radiological Controls

1. Analysis l

1  !

i Licensee performance received a Category 2 rating during the I

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J SALP 5 period which ended September 30, 1984. During the

current assessment period, inspections were performed in ,

j November-December, 1984, (50-341/84043(DRSS)) and March 1985, [

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(50-341/85017(DRSS)) to review the licensee's preparations for

fuel load in the areas of radiation protection and radwaste; no

violations or deviations were identified. No inspections of the

l confirmatory measurements or environmental monitoring programs

l occurred during this period.

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It was determined that the licensee had satisfactorily completed

i activities required for fuel load. Five activities need to be

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completed before exceeding five percent power and are addressed

by open items and/or license conditions. One additional item

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concerning operability of an interim solid radwaste system is

j required to be completed prior to the warranty run.

Licensee progress on these items has been generally satisfactory.

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Items involving operability of the permanent liquid radwaste

i system, operability of the post accident sampling system, and

installation of a collimator for the germanium detector used for

post accident sample counting, are essentially complete and

ready for final NRC review.

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The licensee recently submitted a Process Control Program (PCP)

< covering operation of a vendor supplied interim solid radwaste

t processing system to NRR for approval. The vendor system is

i expected to be operational before exceeding five percent power

and will be used until completion of the permanent solid

radwaste system.

Management involvement, resolution of technical issues, and

responsiveness to NRC issues have been satisfactory during this

assessment period.

l 2. Conclusion

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l The licensee is rated Category 2 in this area. This is the

same rating as in the previous assessment period. Licensee

l performance has remained essentially the same over the course

of the current assessment period.

!

3. Board Recommendations .

None.

.

14

!

_ _

-

..

.

G. Maintenance

1. Analysis

This functional area was examined by the resident inspectors

on a routine basis during the readiness assessment team inspec-

tion, and by a region based inspector during one inspection

within the assessment period. The region-based inspection was

performed to determine the adequacy of implementation of the

licensee's operating phase maintenance and modification prcgrams.

One violation was identified in this area: Severity Level V -

maintenance activities were performed using a non-approved

procedure (Report No. 50-341/85013). Two concerns were identi-

fled in the preventive maintenance (PM) program: (1) the

! current low rate of completion of scheduled PM Tasks and (2) the

potential for applying resources to lower priority PM tasks when

higher priority tasks or tasks of the same priority are overdue.

The licensee has established an 18 month calibration interval

for all calibrations not required by the Technical Specifica-

tions. The rationale for this decision was that if the interval

was too long, it would become apparent by faulty instrument

output and the calibration interval would be shortened. This

approach appears to be non-conservative and assumes an out-of-

calibration situation would be detected and corrected before any

safety impact resulted. Further review of the licensee's

program is planned to determine the adequacy of action,

j Modifications and corrective maintenance activities are being

conducted in accordance with program commitments and no items

'

1 of concern were identified. .

Maintenance is controlled with well stated and understood pro-

grams, although, as noted above, the PM program contains some

'

weaknesses. The staff is knowledgeable and well trained. #

Some understaffing is evident which has resulted in the low

completion rate of PM tasks and has resulted in some priority

work being postponed. Management attention in this area appears

to be weak as evidenced by the failure to evaluate or correct

the low rate of completion of PM tasks.

2. Conclusion

i

The licensee is rated Category 2 in this area. Insufficient

data base existed to establish a trend.

.

3. Board Recommendations

None.  ;

i

15

__

-

..

'

.

I

H. Surveillance

1. Analysis

One inspection was conducted in this functional area by a

,

region based inspector. The inspection (50-341/85026(DRS)),

was performed to determine the adequacy of implementation of

the licensee's surveillance program. In addition, a review

of procedures was performed by the resident inspectors during

,

much of the assessment period.

Management attention and staffing appear adequate. The staff

is well trained and the program clearly defined and stated.

!

No violations were identified in this area.

2. Conclusion

i'

The licensee is rated Category 2 in this area. No data base

existed to estabitsh a trend.

3. Board Recommer,dations t

None. I

l

l I. Emergency Preparedness

1. Analysis

, i

! One inspection was conducted in December 1984 and included

followup of licensee actions on previously identified items

relating to emergency preparedness and also observation and

evaluation of an assembly and accountability drill.

No violations were identified. Items examined and considered [

satisfactorily completed by the licensee included development

of a program for the surveillance, maintenance, and calibration

of the meteorological measurement system, completion of the

Prompt Public Notification System to ensure that administrative

'

and physical means exist to alert the public of an emergency l

condition, a reevaluation of certain Emergency Action Levels

(EALs) to make them more objective to include quantitative ,

.

values where applicable, and an increased effort in training '

to incorporate reactor and containment conditions in Protectic..

Action Recommendations (PARS).

These open items were satisfactorily completed. This demon-

strated decision making at a level that ensures adequate

management attention. The technical issues which needed

resolution were closed in a timely manner. The licensee's

responsiveness to NRC initiative has been viable, generally

4

sound, and thorough.

16

_ . _ _ _ _ _._ ____ ___. _ _ _ _ , _ _ _ _ _ _ _ _ _ . _ - . _ . _ _ . _ _ . _ _ _ _ _

,

i  !

-

, ..

;

!  !

!

j Staffing has been ample. The quality of staffing has been well

1 demonstrated in the Emergency Preparedness Appraisal, the 1984  :

i Emergency Exercise, and various interchanges between the inspec-

I tors and the staff in the December 1984 inspection. Positions 1

i are identified and authoritin id responsibilities are well  !

defined.

i  !

i Overall the licensee has a well organized, proceduralized l

I training program which has proven effective. This includes a  !

j matrix which identifies courses required for each of the  !

positions in the emergency organization. l

1

'

2. Conclusion  !

i

l The licensee is rated Category 1 in this area. Performance has

l remained the same during the assessment period,

t

i' 3. Board Recommendations

!

None

j J. Security ,

^

1. Analysis

1

l One special inspection and three routine preoperational inspec- f

tions were conducted by regional based inspectors prior to

license issuance. One .gacial and one routine inspection were ,

l conducted subsequent to license issuance. The allegations l

1 reviewed during the special inspection conducted prior to t

j licensing involved alleged improprieties in the licensee's ,

i background screening program and were not substantiated. One [

Severity Level IV violation - Failure to adequately control r

access to a vital area - was identified during the post  !

licensing special inspection and resulted in an enforcement l

conference being held. j

i  :

! During the early part of the preoperational phase a number of  !

deficiencies were noted in middle management's ability to ade-  !

quately implement their program. Although remaining optimistic

i that systems would initially perform adequately, repeated (

! failures caused senior management to become directly involved. l

1 For example, although ample staff resources were available they

!' did not appear to be used effectively; some items were described

as being completed / closed when they were not; technical solu- l

tions to ;.roblems such as certain door interlocking problems i

! were initially not solved; and excessive alarms were being  !

! generated. Middle management was also very reluctant to remove  ;

! certain unnecessary security equipment that was described in L

j published NRC guidance and identified as being possibly detri-  ;

i mental to optimum plant safety. ,

i l

'

\

i  !

17

I  !

,

t

___-!

_ _ _ _ _ _ _ _ . . - _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _-.

," .-

4

As a result of our inspection results and their own review,

senior licensee management became more actively involved in

the implementation and overview of the program. That activity

resulted in innovative and effective approaches, such as the

multi-disciplined committee that was established to address

system-related problems. It was only after that senior level

involvement did needed progress occur to implement the system.

Once begun the program was adequately implemented. l

'

l

Subsequent to license issuance, compliance with the security  !

plan becomes mandatory. A violation of that plan was identified  !

and reported by the li ensee shortly (32 days) thereafter. This

I single incident involved breakdowns in several fundamental j

security subsystems and was considered significant. It demon-  ;

-I

strated deficiencies in vital area access controls, responses, I

j alarm station operations, first line supervisory support and i

,

guard training programs. It appeared that although proper l

attention had been oaid to complying with specific requirements, j

some performance objectives had been overlooked. The signifi- l

cance and corrective actions for the event were well addressed I

by the licensee during the enforcement conference. The tech- l

nical review, analysis and approach to resolving the problem

along with the status of the plant at the time mitigated the

significance of the event and enforcement actions. The actions

taken should prevent recurrence of the violation and better

ensure that performance objectives will be met.  !

The licensee has expended considerable effort to complete j

needed upgrades of some security equipment and alleviate other l

marginally acceptable security practices such as removing  !

i systems that were identified as possibly being detrimental to  !

plant safety. Security management personnel have been success- I

j ful in reducing the turnover of security personnel by closely

t monitoring personnel actions and changes. This increated

monitoring appears to have had a beneficial effect on morale

and reduced turnover. Additional resources have been committed

to strengthen a segment of the security training that was weak i

, and contributed to the violaticq. Although difficulties were  !

identified during the assessment period, senior corporate manage-

'

.

ment actions and involvement have resulted in acceptable levels i

of protection. l

i 2. Conclusion

The licensee is rated Category 2 in this area. Licensee per-

formance has remained essentially constant over the course of

this SALP assessment period. i

3. Board _ Recommendations

,

None.

.

<

18

._ _ _ __ _ _ _ _ _ _ _ . _ . - _ _ _ . _ _ . ._ _.

__ ,_ _ _ -- - _ . _ _

. .

.

K. Fueling

1. Analysis

j The licensee received an operating license for Fermi 2 on

March 20, 1985, and initial fueling commenced within ten hours

'

I

after license issuance. Fueling was completed on April 4, 1985.

This activity was observed on a three shift basis by the

resident and regional inspectors during fuel movement and no

items of noncompliance were identified. Delays which occurred

during fuiling resulted from those associated with the refueling

bridge. The licensee completed fueling in less than the sched-

uled time with no personnel errors.

1

l Licensee management was closely involved with the fueling acti-

'

vities and all issues which were brought to their attention

received quick resolution. Staffing, training, and qualifi-

cations were ample to support safe, efficient completion of

fueling activities. The licensee was responsive when the

inspectors identified minor concerns.

j 2. Conclusion

j The licensee is rated Category 1 in this area. The licensee

]

was not rated during the last SALP period.

l 3. Board Recommendations

T

'

None.

L. Quality programs and Administrative Controls Affecting Quality

_

1. Analysis

1

This functional area was inspected on a routine basis by the

j resident inspectors and during three inspections by region-based

personnel during the assessment period. The region-based inspec-

'

tions were performed to determine the adequacy of operational

,

Quality Assurance programs for startup activities, audits,

receipt, storage, and handling of materials, document control,

4

procurement, QA/QC administration, records, and handling of

i preoperational test program records. In addition, considerable

inspection effort was expended in evaluating licensee corrective

actions for previously identified deficiencies and items of

i concern which were also documented in the reports noted above.

Two violations were identified in this area. One of these

was in the area of quality control: Severity Level IV (50-341/

84-65) - QC inspectors failed to execute an adequate inspection

of activities affecting quality,

i

1

19

i

I _ - -__ - - -__ _ -_ _____-__-_

-

. .

.

I

The other violation was identified in the procurement area:

Severity Level V (50-341//84-48-02) - failure to ensure t at

the source inspection procedures used by the Purchasing Inspec-

tion Division were approved by the Nuclear Quality Assurance

Department. This item did have potential significance, in that

deficiencies identified during source inspections may not have

been properly tracked and resolved. The licensee took prompt

,

and extensive corrective action and the item was closed during

{

the assessment period.

.

Two concerns were identified in the audit area. Failure to

track vendor audit findings and schedule vendor audits in '

cordance with approved procedures, was identified and

resolved during the assessment period.

j The relatively large percentage of overdue actions in response

to internal audit findings was also a concern. The licensee

has taken corrective action in this area and the item remains

to be reviewed. Both items were of minor safety significance.

No violations or items of concern were identified in the

remaining areas.

I

During these inspections, 44 NRC items were closed. Many of

these items were related to construction phase activities. The

promptness and extent of licensee corrective action in resolving

these items indicates adequate management involvement.

In summary, management has been deeply involved in the correc-

tion of quality related issues. Quality programs are well

defined and stated. This functional area is adequately staffed

by knowledgeable personnel.

]

2. Conclusion

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

the same rating as given in the last SALP period, the licensee's

j performance trend has improved.

3. Board Recommendations

4

NRC inspection activity in this area should remain the same with

emphasis on program implementation.

M. Licensing Activities

1. Analysis

The staff concluded on March 20, 1985, that the licensee had

satisfied all the requirements for issuance of a low power

. license. The Commission briefing for a full power Itcense

i was held on July 10, 1985.

'

.

20

.

.- . . -. - -.-.- -- . .

-_ - ._.

c

-

<

, ..

4

i

i The licensee's management demonstrated active participation

i in licensing activities and kept abreast of all current and

i anticipated licensing actions. The staff found consistent

i evidence of prior planning and assignment of priorities.

! However, the licensee's management at times demonstrated a

lack of understanding of staff policy. This tended to delay

the resolution of important matters such as fire protection.

'

The licensee's management and its staff demonstrated a sound

technical understanding of the issues involving licensing

actions. This continues to be the strongest element in the

licensee's performance.

e

i The licensee has responded pronptly to staff requests for t

additional information in most cases. However, some documen-

i tation has been submitted in a tardy manner requiring an

. expedited staff review to maintain the licensing schedule.

! With some effort by the licensee in the areas of management

control and responses to NRC initiatives and continued good

performance in the other rating categories, an overall rating

j of above average could be achieved since the licensee's rating

,

is slightly better than a 2 and is trending up. The licensee '

i

'

received an overall rating of 2 in the last SALP evaltation by

NRR.

I r

i

1 2. Conclusion

J l

'

The licensee is rated Category 2 in this area.

f 3. Board Recommendation I

I

l The licensee should continue to address their licensing activity ,

with an enhanced understanding of staff policy and positions and j

l attempt to submit all documentation in a timely fashion. l

l

y

i i

1  !

i

i

f  !

!  !

>  :

i

[

i [

] -

i

21 r

i r

l

I

-

..

.

V. SUPPORTING DATA AND SUMMARIES

A. Licensee Activities

For the first six months of the assessment period, Fermi 2 was con-

sidered to be in the construction /preoperational testing phases prior

to assuming any type of startup/ power operations. On March 20, 1985,

a low power operating licensed was issued by the NRC, and initial

fuel loading began approximately six hours later. At that time, all

systems that were required to support safe startup and operation of

the unit were operable. Fueling was completed with no significant

problems and ahead of schedule. Startup testing continued with

initial criticality occurring on June 21, 1985. For the remainder

of the assessment period, the unit has been operating at less than

5% power with the low power testing portion of the startup program

continuing.

B. Inspection Activities

Throughout the assessment period, NRC Region III conducted inspec-

tions to assess the readiness of Fermt 2 for power operations.

Included in this program were reviews of the plant fire protection

program; procedures; Technical Specifications; Final Safety Analysis

Report (FSAR); As-Built configuration comparisons; adequacy of

operating shifts; and adequacy of management and engineering support

activities. In addition, a team inspection was conducted at the end

of the assessment period to assess the readiness for operation of

each working department directly involved with the unit. These

included Maintenance, Radiation Protection, Operations, and

Surveillance groups.

22

}

.

..

.

TABLE 1

INSPECTICN ACTIVITY AND ENFORCEMENT

No. of Violations in Each Severity level

Functional Areas I II III IV V Deviations

A. Piping Systems

and Supports 1 1

8. Electrical Power

Supply / Distribution

and Instrumentation /

Control Systems 6

C. Fire Protection 2

D. Preoperational and

Startup Phase Testing 2

E. Plant Operations 2 2

F. Radiological Controls

G. Maintenance 1

H. Surveillance

I. Emergency Preparedness

J. Security 1

K. Fueling

L. Quality Programs and

Administrative Controls 1 1

M. Licensing Activities __ _ _

TOTALS 13 5 2

23

. _. ~. - . ._ ._. . - ~ _ . _ _ _ _

-

.

.' ..

l

.

C. Investigations and Allegations Review

!

Nine inspections were performed during the-assessment period to

review allegations. None of the findings were significant. No

., investigations were conducted during the assessment period.

l D. Escalated Enforcement Action

l None.

E. Management Conferences Held During Appraisal Period

1. Management Conferences

a. October 4, 1984, Glen Ellyn, IL. Meeting to discuss

Fermi's-radiation protection program status.

'

'

b. October 23, 1984, Fermi plant site. Meeting to discuss

the status of the Fermi facility,

j c. October 31, 1984, Fermi plant site. Meeting and tour

regarding DECO's response to the CAT team findings and

j the status of plant readiness for fuel loading.

I

d. November 2, 1984, Bethesda, MD. Meeting to discuss

general topics.

1

e. December 5, 1984, Glen Ellyn, IL. Meeting to discuss

4

concerns regarding as-built drawing discrepancies and

} safety-related instrumentation calibration and setpoint

'

selection. i

i -

j f. December 10, 1984, Glen Ellyn, IL. Meeting to discuss

j the design documentation control,. calibration of instru-

4

ments, and separation of redundant electrical channels.

,

,

g. December 12, 1984, Fermi plant site. Meeting to discuss  !

operational readiness review.

h. December 13, 1984, Fermi plant site. Meeting and tour

,

with Commissioner Zech.

!

i. December 31, 1984, Glen Ellyn, IL. Meeting to discuss

'

as-built drawings.

J. January 3,1985, Glen Ellyn, IL. Meeting to discuss

i SALP.

k. February 3, 1985, Fermi plant site. Meeting to discuss

corrective action regarding as-built drawings.

t

'

24 i

,

, - _ _ . _ . _ . - _ - . -

...___ -_ ,,-.._. _. _ _ _ _ _ _ . . _ . - - . _ . _ , - _

-

..

.

1. April 4, 1985, Fermi plant site. Meeting to discuss NRC's

perspective on potential problem areas during startup and

testing. Also used to discuss NRC's inspection and

enforcement practices for operating reactors,

m. May 15, 1985, Fermi plant site. Meeting to discuss bi-

weekly visit to discuss full power licensing readiness

at Fermi.

n. May 21, 1985, Glen Ellyn, IL. Meeting to discuss

physical security findings.

2. Confirmation of Action Letters

None.

F. Review of Licensee Event Reports, Construction Deficiency Reports,

and 10 CFR 21 Reports Submitted by Licensee

1. 10 CFR 50.55(e) Reports

Eight 10 CFR 50.55(e) reports were generated from the Fermi

plant during the appraisal period. Six of the eight reports

have been resolved. Two reports remain unresolved from the

previous SALP period. The first deals with a potential design

deficiency in the buried portion of the fire protection system

and the second deals with an apparent design deficiency on the

RHR Reservoir.

2. 10 CFR 21

Five Part 21 reports were resolved for the Fermi plant during

the appraisal period. There are no unresolved items at this

time.

25

, - . . _ - . _ - _ , - ~_ ._ .- .

,.

. .

gs.n tscg UNITED STATES

• g

,,

NUCLEAR REGULATORY COMMISslON

,

[ Te( g REGION til

f

!

3 V E

799 ROOSEVELT ROAD

l, N " 8 cLEN ELLYN. ILLINOIS 60ln

gv f .

....-

,

JUN 281985

,

Docket No. 50-341

Detroit Edison Company  :

ATTN: Dr. Wayne H. Jens i

Vice President

Nuclear Operations

2000 Second Avenue

l

Detroit, Michigan 48226 L

Gentlemen: l

4 ,

j Enclosed for your review, prior to our scheduled meeting of July 2,1985, is

,

the SALP Board Report (summary) for the Enrico Fermi Nuclear Station covering i

the period October 1,1984 through June 30, 1985. l

,

During the assessment period, your emphasis has shifted from construction to (:

preoperational testing and operational readiness. With this shifting emphasis

'

I and considering your schedule for requesting full power authorization, we  !

have evaluated your programs related to these areas and have included our l

findings in this assessment report.  ;

.

"

During this assessment period your regulatory perfomance at the Fermi station

was considered to be acceptable and showed an improving trend. You were rated i

Category 1 in 3 areas (Fueling, Emergency Preparedness, Preoperational and

Startup Testing), Category 2 in 9 areas, and Category 3 in one area. The  !

Category 3 rating was in the area of fire protection and was primarily

based on management's failure to identify problems and effectuate timely  !

resolution. The performance trend within the assessment period improved

i

in 3 areas, remained the same in 6 areas and has not declined in any of i

j the remaining areas trended. A trend could not be determined in 4 areas.  ;

The enclosed SALP Board report is a brief sumary of the final SALP I

report which will be issued at a later date. This summary report j

includes all functional areas assessed during the SALP 6 period, your ,

ratings in each functional area, and a brief sumary of our findings used

in determining the associated ratings, i

t

While you will have sufficient opportunity to present your coments at L

the meeting on July 2,1985, you may also provide written coment within l

30 days after the meeting. We will evaluate any written comments and  :

provide you with our conclusions relative to them. '

In accordance with Section 2.790 of the NRC's " Rules of Practice". Part  ;

,

2, Title 10, Code of Federal Regulations, a copy of this letter and the l

SALP Sumary Report will be placed in the NRC's Public Document Room.  ;

4

[

,

i

Y f &,$

u r r i s- w my

- -

. - _ _- . _ _ , -. - - .. - . - - , - - - - - - - _ - -__ - . - _ .

- - .

.

,

Detroit Edison Company 2 . ,,

ho reply to this letter is required at this time; however, should you have any

, questions concerning the SALP Report, we would be pleased to discuss them with

you.

Sincerely,

i crictnal signed by

Jaxs G. KePpler

j

-

James G. Keppler

Regional Administrator

Enclosure: SALP Summary Report

No. 50-341/85027

'

cc w/ enclosure:

' L. P. Bregni, Licensing

Engineer

) P. A. Marquardt, Corporate

Legal Department

i

DMB/ Document Control Desk (RIDS)

, Resident Inspector, RIII

Ronald C.nllen, Michigan

Public Service Comission

i

I

Harry H. Voigt, Esq.

Nuclear facilities and

Enviror. mental Monitoring

Section

!

J. M. Taylor, Director, IE

I

H. R. Denton, Director, NRR

i Regional Administrators

RI, RII, RIV, RV

i N. J. Palladino, Chairman

i J. K. Asselstine, Comissioner

i T. M. Roberts, Comissioner

L. W. Zech, Comissioner

NRR Project Manager

H. L. Thompson, NRR

J. Axelrad. IE

,

RI!! PRR

'

RIII SGA

State Liaison Officer, State of

Michigan

INPO

,

6

l l

.

i

_________ - - - - - - - - - - - - - - - - - - - - - - - -

'

'

.

.

T

SALP BOARD REPORT

U. S. NUCLEAR REGULATORY COPFISSION

REGION III

.

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

50-341/85027

Inspection Report No.

Detroit Edison Company

Name of Licensec

l

Fermi 2

Name of Facility

October 1, 19_84 throuch lune 30,,1985

Assessment Period

P

,

,C43- ,, e m

w 7 7,w

-

-

y/a --

c /, -

__

.-

,

[

.

I. INTRODUCTION

The Systematic Assessment of Licensee Performance (SALP) progran is

an integrated NRC staff effort to collect available observations and

data on a periodic basis and to evaluate licensee perfornance based

upon this information. SALP is supplemental to nomal regulatory

processes used to ensure compliance to NRC rules and regulations.

SALP is intended to be sufficiently diagnostic to provide a rational

basis for allocating NRC resources and to provide meaningful guidance

to the licensee's management to promote quality and safety of plant

construction and operation.

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

June 27, 1985, to review the collection of performance observations

and data to assess the licensee's performance in accordance with the

guidance in NRC Manual Chapter 0516 " Systematic Assessment of

Licensee Performance." A sumary of the guidance and evaluation

criteria is provided in Section II of this report.

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

performance at Fermi Unit 2 for the period October 1,1984, through

June 30, 1985.

SALP Board for Fermi 2:

Name Title

J. A. Hind Director, Division of Radiation Safety

and Safeguards (DRSS)

R. L. Spessard Director, Division of Reactor iafety (DRS)

C. E. Norelius Director, Division of Reactor Projects (DRP)

C. J. Paperiello Chief Emergency Preparedness and Radiation

Safety Branch

L. A. Reyes Chief, Operations Branch, DRS

N. J. Chrissotimos Chief, Reactor Projects Section ID

J. R. Creed Chief, Safeguards Section

M. A. Ring Chief, Test Programs Section

M. P. Phillips Chief Energency Preparedness Section

D. H. Danielson Chief, Materials Section, DRS

T. Madeda Security Inspector, DRSS

S. G. DuPont Reactor Inspector, TPS

S. Stasek Project inspector, Reactor Projects

Section 10

Z. Falevits Reactor Inspector, DRS

R. Hasse Reactor Inspector, DPS

M. D. Lynch Licensing Project Manager, NRP

?

__ . . . - - - _ _ . . - - - _ _ . .-_-...- - - - . -. - - ._ -- . . . -

t .

-

j. .

1

!* i

,

II. CRITERIA

t

i The licensee's perfornance is assessed in selected functional areas  ;

depending whether the facility is in a construction, pre-operational

'

j

!

or operating phase. Each functional area normally represents areas  !

! significant to nuclear safety and the environment, and are normal j

programatic areas. Some functional areas may not be assessed because

'

j

i of little or no licensee activities or lack of meaningful observations.

l Special areas may be added to highlight significant observations.

!

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

{;

each functional area. ,~

j 1. Management involvement in assuring quality  !

2. Approach to resolution of technical issues from a safety standpoint  :

1 3. Responsiveness to NRC initiatives

i

'

j 4 Enforcement history

l 5. Reporting and analysis of reportable events l

l  !

'

l 6. Staffing (including naragement)

i

'

I

7. Training effectiveness and qualification.

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

j may have been used where appropriate.

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

is classified into one of three perforriance categories. The definition

of these performance categories is:

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

1

nanagement attention and involvement are aggressive and oriented '

toward nuclear safetyt licensee resources are ample and effectively

)l

i

used so that a high level of performance with respect to operational

safety or construction is being achieved,

i

4

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

! Licensee management attention and involvement are evident and are .

'

1 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.

f

l ,

1 Category 3: Both NRC and licensee attention should be increased. -

! Licensee management attention or involvement is acceptable and

i considers nuciear 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. l

I

3

i .-_._, _ ,.- _ _ .. - _ __. - ~. - ,,_ _ _. . -..__ ___ __, , , _ . . _ _ _ - _ - _ ~ . _ . _ - _ , _ -

. .- .-_ . _ . . . _ - . -. . - . - .- - -

-

..

.. .

1

i

{

'

Trend: The SALP Board has also categorized the performance trend

i in each functional area rated over the course of the SALP assessment

i period. The categorization describes the general or prevailing

j tendency (the performance gradient) during the SALP period. The

i performance trends are defined as follows:

3

I Improved: Licensee perfornance has generally improved over the

course of the SALP assessment period. '

Same: Licensee perfornance has renained essentially constant

i

over the course of the SALP assessment period.

I

,

'

! Declined: Licensee performance has generally declined over the

course of the SALP assessment period.

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III. SUMMARY OF RESULTS

' Overall, the licensee's performance was found to be acceptable cnd

showed an improving trend. The licensee was found to have aggressive

'

management attention and a high level of performance in the areas of

Emergency Preparedness, Fueling, and Preoperational and Startup Phase

,

Testing. Performance in the Fire Protection area was found to need

'

increased management attention as well as maintenance of the current

increased NRC staff attention during subsequent inspections.

Rating Last Rating This

Functional Area Period Period Trend

A. Piping Systems

- and Supports 2 2 Same

B. Electrical Power

Supply / Distribution

i and Instrumentation /

j Control Systems 3 2 Improved

C. Fire Protection 3 3 Same

1

0. Preoperational and

Startup Phase Testing 2 1 Improved

E. Plant Operations NR 2 NR

< F. Radiological Controls 2 2 Same

i G. Maintenance NR 2 NR

H. Surveillance NR 2 NR

I. Emergency Preparedness 1 1 Same

J. Security 2 2 Same

Fueling

'

K. NR 1 NR

l L. Quality Programs and

+

Administrative Controls 2 2 Improved

,

M. Licensing Activities 2 2 Same

} *NR = not rated or not rated separately,

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_-. . . .- _ -

.- . -

- _ _ _ _

-

..

. _

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PIPING SYSTEMS AND SUPPORTS

CATEGORY 2 PERFORMANCE

TREND WITHIN SALP PERIOD 'SAME

• Inspections focussed on closecut of items.

Two Violations:

'

!

. Nonrepetitive..

. Not Programmatic.

• Management Controls, Adequate.

l

• Records Complete and Well Maintained.

'

• Know!cdgeable Staff.

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ELECTRICAL POWER SUPPLY AND DISTRIBUTION

AND

INSTRUMENTATION / CONTROL SYSTEMS

CATEGORY 2 PERFORMANCE

TREND WITHIN SALP PERIOD IMPROVED

• Major inspection effort / utility effort.

• Six Violations.

* Hardware and drawing changes required.

• 3rawing control improved.

• Comprehensive corrective action.

.

- --

. - _ . -____ _ _ _

-

..

..

.

FIRE PROTECTION

CATEGORY 3 PERFORMANCE

'

TREND WITHIN SALP PERIOD SAME

• Acceptable Program Implemented.

• Adequate Plant Systems and Procedures.

'

• Adequately Trained Operations Personnel

• Major Management Concerns on 3roblem

Identification.

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PRE 0PERATIONAL AND STARTUP TESTING  !

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!

CATEGORY 1 PERFORMANCE l

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TREND WITHIN SALP PERIOD IMPROVED

• Extensive NRC Involvement.  ;

• Early Problems Resolved.

• Progressive Improvement.

• Aggressive Management Initiatives.

• Two minor violations concerning

leak rate testing. l

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- . , _ _ - . - . _ . . -- - - - _ _ _ _ _ - - ,

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.

PLANT OPERATIONS

CATEGORY 2 PERFORMANCE

NO TREND - FIRST ASSESSMENT

,

• Four Violations.

'

• Seventeen L Rs.

• NRC License Pass Rate High.

• Operational Readiness inspection.

• Good Management Attention.

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RADIOLOGICAL CONTROLS  :

.

!

CATEGORY 2 PERFORMANCE

TREND WITHIN SALP PERIOD SAME

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• No Violations.  !

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,

• Management involvement Satisfactory.

• Responsiveness to NRC Issues Satisfactory.

• Radwaste Systems Status Acceptable.

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.. . - _ .

. . _ _ _

-

..

.

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MAINTENANCE

CATEGORY 2 PERFORMANCE

NO TREND - FIRST ASSESSMENT

• One Violation Identified.

• Maintenance Program Well Defined.

• Corrective Maintenance Activities Adequate.

• Preventative Maintenance Concerns:

. Low Completion Rate.

. Prioritization.

. Management Attention.  !

!

.- - _ _ - -

-

..

. .

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SURVEILLANCE  :

!

>

CATEGORY 2 PERFORMANCE

.

'

NO TREND - FIRST ASSESSMENT ,

i

i

• Management Attention Acceptable. l

• Staffing Adequate.

l

• Surveillance Walk-throughs.  !

• No Violations.  ;

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,

,

- - - - _ . -- .. -_ . _ - - .

. _- ..

.

EMERGENCY PREPAREDNESS

CATEGORY 1 PERFORMANCE

TREND WITHIN SALP PERIOD SAME

• No Violations.

• Demonstrated Decision Making.

• Well Qualified Staff.

• Program Well Defined.

• Responsive to NRC Initiatives.

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SECURITY

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CATEGORY 2 PERFORMANCE j

i

TREND WITHIN SALP PERIOD SAME

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• Senior Management Actively involved.

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• Middle Management Deficiencies.

!

. Program Implementation. l

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. Technical Solutions.

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• Security Event - Enforcement Conference

l

. Management Aggressiveness. f

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- --

. .

- - - _ _

!

__

. . - - - . _

-

. -

. _

1

6

FUELING

CATEGORY 1 PERFORMANCE

'

NO TREND -

FIRST ASSESSMENT

• Management involvement.

• No Personnel Error.

• No Violations.

• Conservative Approach.

-

_

.' ..

p

QUAUTY PROGRAWS AND ADMINIS1RATIVE CONTROLS AFFECTING QUAUTY I

CATEGORY 2 PERFORMANCE

TREND WITHIN SALP PERIOD IMPROVED

• Program Well Defined.

'

* Adequate Staffing.

• Responsive to NRC concerns.

'

• Two Minor Violations.

• Backlog of Internal Audit Findings.

!

.._ . _. . .. . . - _ - .

. _- ..

-

!

l

LICENSING ACTIVITIES

CATEGORY 2 PERFORMANCE

TREND WITHIN SALP PERIOD SAME

• Active Management Participation.

• Prior 3lanning.

• Technical Understanding of Issues.

• nconsistent Information Exchange.

l

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,

1

- - .- ..

j

'

...

.

.

TABLE 1

No. of Violations in Each Severity Level

Functional Area I II III IV V Deviations

Operations 2 2

Radiological-Controls  ;

!

Maintenance 1

Surveillance

Fire Protection 2 ,

i

Emergency Preparedness

Security 1 j

Fueling ._ l

Piping Systems l

and Supports 1 1  !

Electrical Power

Supply / Distribution

and Instrumentation /

Control Systems 6' -

Preoperational and  !

Startup Phase Testing 2 -

Quality Programs and

Administrative Controls 1 1  !

'

Licensing Activities

!

I

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19

u _ __ _ _ __ _ _ _ _-- _