IR 05000395/1988032

Final SALP Rept 50-395/88-32 for Aug 1987 to Dec 1988

ML20245B045
Person / Time
Site:	Summer
Issue date:	12/31/1988
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20245B038	List: ML20245B036 ML20245B045
References
50-395-88-32, NUDOCS 8906220361
Download: ML20245B045 (28)

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ENCLOSURE 5 l'

FINAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION

REGION II

SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-395/88-32

' SOUTH CAROLINA ELECTRIC AND GAS COMPANY V. C. SUMMER August 1, 1987 - December 31, 1988 gg62{poIk$ 9s u

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SUMMARY OF RESULTS Summer was operated in an overall safe manne during the assessment period. Strengths were identified in the areas f Radiological Controls, Maintenance and Surveillance. A significant dec ne in performance that requires additional managerial attention was iden fied in the area of Securit Operations performance was mixe Strengths were not in training of shifts as a team and the presence of a shift engineer hift technical advisor on each shift to coordinate shift activities with ther areas and thereby permit the shift supervisor to concentrate on safe lant operatio The establishment of the University of Maryland program to tain degrees for on shift operators represents a substantive management c itment to

. improved shift expertise and safety. Corporate interest and o rsight of plant activities was very apparent. However, the use of proced es with known errors and the failure to maintain control room drawings, and acceptable sistem configuration control at all times indicated a n d for management attentio Added management attention is also needed to duce the number of reactor trips. The fire protection area requires additi nal oversight to preclude repetitious errors that have occurred during th1 perio ____ ___ -

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I On September 16, 1988, the plant shut down and entered the fourth refueling outage. Major work activities in the outage included core reload, eddy current examination of 100 percent of the steam generator tubes, tube plugging, equipment qualification upgrades, a containment integrated leak rate test, inservice inspection; and valve packing replacemen The outage exceeded the planned schedule of 75 days by 28 day The nue. lear operations division was consolidated by relocating the vice president nuclear operations and the corporate staff to the V.C. Summer plant in the last quarter of 1987. The division underwent a reorganization in the first quarter of 1988 to reduce the number of management and supervisory levels. The relocation moves were supported by constructing new administrative and support facilities and upgrading existing one Direct Inspection and Review Activities During the assessment period, routine inspections were performed at the V. C. Summer facility by the NRC staff. Special team inspections were conducted as follows:

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Equipment Qualification inspections were conducted in October 1987 and January 1988, with a follow-up inspection conducted in October 198 Operational Safety Team Inspection was conducted in November and December 198 II. SUMMARY OF RESULTS Summer was operated in an overall safe manner during the assessment period. Strengths were identified in the areas of Radiological Controls, Maintenance and Surveillance. A significant decline in performance that requires additional managerial attention was identified in the area of Securit Operations performance was mixe Strengths were noted in training of shifts as a team and the presence of a shift engineer / shift technical advisor on each shift to coordinate shift activities with other areas and thereby permit the shift supervisor to concentrate on safe plant operatio The establishment of the University of Maryland program to obtain degrees for on shift operators represents a substantive management connitment to improved shift expertise and safety. Corporate interest and oversight of plant activities was very apparent. However, the use of procedures containing errors, the failure to maintain control room drawings, and the lack of acceptable system configuration control at all times indicated a need for management attentio Added management attention is also needed to reduce the number of reactor trips. The fire protection area requires additional oversight to preclude repetitious errors that have occurred during this perio __

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The Radiological Controls area was considered a strength. The reduction of contaminated areas to less than one percent was noteworthy. However, considering the current problems associated with steam generator tube integrity and failed fuel, the licensee is faced with challenges that may require innovative approaches if personnel exposure and contamination is to be maintained as low as reasonably achievable (ALARA).

The maintenance / surveillance program was well implemented and considered a strength. The reduction in maintenance work order backlog, implementation of a predictive maintenance program, and operations support to the planning and scheduling group are considered strengths. The timely completion of surveillance tests indicates that the testing program was well staffed and supervise Emergency Preparedness activities' were conducted in an adequate manne In the area of Emergency Preparedness, the licensee demonstrated an ability to adequately implement the essential elements of their Emergency Plan. However, inspection results showed that a weakness identified in the training of key staff personnel during the previous assessment still existe The Security area, long considered a strength at this site, experienced several significant problems which resulted in escalated enforcement late in the assessment period. Organizational changes in 1988 resulted in deteriorating security force performance. Management was slow to recognize these changes until personnal performance had decreased to a marginal level. Significant management attention is required to raise the performance of this area back to its past level of performanc The Engineering / Technical Support function was performed well during the evaluation period. The engineering staff was consolidated and relocated to the plant site to provide more rapid response to plant problem However, during the assessment period instances of ina6quate engineering evaluations and a concern with the adequacy of review of contractor evaluations were identified. The system engineer program which was established in late 1987 has been slow in being implemented. Additional management attention may be required to achieve the desired benefits of this progra The Safety Assessment / Quality Verification area performance was goo .0perations, engineering and management involvement in safety issues was apparent. The licensee continued to pursue and realize positive benefits from their efforts in safety system functional inspections and development of system design bases documents. In response to the excessive reactor trip problem, a root cause identification training program has been started. Repetitious trips from the main control board reactor trip switch in 1988 indicate a need for additional management attention in this i area. QA and QC continue to provide good oversight of safety activitie I Licensee submittals to the NRC were considered acceptabl i a_______

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Overview Rating Last Period Rating This Period Functional Area 1/1/86 - 7/31/87 8/1/87 - 12/31/88 Trend Plant Operations 2 2 Radiological Controls 1 1 Maintenance / Surveillance 1 1 Emergency Preparedness 2 2 Security 1 2 Declining Engineering / Technical Support NR 2 Safety Assessment / 2 2 Quality Verification III. CRITERIA

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Licensee performance is assessed in selected functional areas.- depending on whether the facility is in a construction or operational phas Functional areas normally represent areas- significant to nuclear safety

'and the environmen Some functional areas may not be assessed because of little or no. licensee activities or lack of meaningful observation Special areas may be added to highlight significant observation The following evaluation criteria were used, as applicable, to assess each functional area:

1. - Assurance of quality, including management involvement and control; Approach to the resolution of technical issues from a safety standpoint; Responsiveness to NRC initiatives; Enforcement history; Operational and construction events (including the response, analyses, reporting, and corrective actions); Staffing (includingmanagement);and Effectiveness of training and qualification progra However, the NRC is not limited to these criteria and others may have been used where appropriat On the basis of the NRC assessment, each functional area evaluated is rated according to three performance categories. The definitions of these performance categories.are as follows: )

Category Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or safeguards activities, with the resulting performance substantially exceeding regulatory requirement Licensee resources are ample and

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effectively used so that a high level of plant and personnel performance is being achieved. Reduced NRC attention may be appropriat Category Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are good. The licensee has attained a level of performance above that needed to meet regulatory requirements. Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieve NRC attention may be maintained at normal level Category Licensee management attention to and involvement in the performance of nuclear safety or safeguards activities are not sufficien The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements. Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal level The SALP Board may also include an appraisal of the performance trend of a functional area. This performance trend will only be used when both a definite trend of performance within the evaluation period is discernable and the Board believes that continuation of the trend may result in a change of performance leve The trend, if used, is defined as:

Improving: Licensee performance was determined to be improving near the close of the assessment perio Declining: Licensee performance was determined to be declining near the close of the assessment period and the licensee had not taken meaningful steps to address this patter IV. PERFORMANCE ANALYSIS Plant Operations Analysis During the assessment period routine and special inspections were performed by the NRC staff. The fire protection program was examined by a special inspect ton in February,1988 and an Operational Safety Team Inspection (OSTI) was conducted in November and December, 198 The operations group is well staffed with five shifts that stand 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> watches. Each shift includes a shift engineer / shift I technical advisor, shift supervisor (SRO), control room supervisor (SRO), reactor operator (SR0/RO), a first and second assistant operator who may be SR0/R0 or in training for a license and five to six auxiliary operator All shift engineers are degreed and six of eight possess SR0 license The remaining two are currently in training for SR0 license . _ - _ _ _ _ _ _ _ _

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he shifts train and operate together as a tea The shift l,

e ineer coordinates all shift support functions and thereby fr s . the shift supervisor to concentrate on -safe plant ope tion. The reactor operators and first and second assistant oper ors routinely rotate from the control room to auxiliary opera r watch stations to maintain their proficiency-' and utilize their experience throughout the plant. The licensee has experien d only negligible personnel turnover in this are To- improve educational and engineering expertise on shift, management . itiated a college degree program for licensed operators in 98 This program is conducted by the University of Maryland an $ffers a Bachelor of Science degree in Nuclear Scienc Thirt 4o of the forty initial candidates are still participating in progra Any nuclear operations personnel may participate in is program; however, licensed operators and license candidates ggivenpriorit Administrative contro to ensure control room professionalism were established and a effective. Access to the at-the-control area is limited and we 1 controlled. Operator logs were legible and complete w1 h normal conditions, off-normal conditions, special tests and events identifie Preshift briefings were conducted an4 shift turnover forms were used by all operator Watchstander and duty technician assignments were clearly posted in the c trol room. Key controls for operator access to spaces and quipment were well organize Operator response to off-normal nditions and plant transients was prompt and thoroug This wa exemplified during a loss of reactor coolant letdown event that ccured in 1988. The rapid identification of an incorrect cont 1 signal resulted in the operator transferring control of let wn from the main ontrol board to the remote shutdown panel an thereby bypassing the faulty control circui This timely re onse prevented a plant shutdow The licensee has initiated a ogram to enhance the black board concept for alarm annunciators The OSTI identified instances where addi 'onal licensee l attention was needed tc control valve and rcuit breaker alignment limiting conditions for operation (LCO), and legibility of control room essential drawing e licensee was very responsive in revising LC0 procedures to duce the potential for reliance on inoperable systems and - corporating procedural steps to require independent verificati of valve and circuit breaker position System walkdowns the OSTI team members identified numerous technical nd typographical errors in existing system operating proce res and ,

attachments used for valve and breaker alignment hse l

procedures had been implemented and issued to the field fc use, without a good review, or validation. It was anticipated la t l operators would make the needed corrections while accomplis

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ng system lineups and verification of lineup One illegible i E______---____--_--.___---.--.------ - _ - - - - - - _ - - - -- - - - - - - - - - - - - - -- - J

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8 The shifts train and operate together as a team. The shif t engineer coordinates all shift support functions and thereby frees the shift supervisor to concentrate on safe plant operation. The reactor operators and first and second assistant operators routinely rotate from the control room to auxiliary operator watch stations to maintain their proficiency and utilize their experience throughout the plant. The licensee has experienced only negligible personnel turnover .n this are To improve educational and engineering . expertise on shift, management initiated a college degree program for licensed operators in 1987. This program is conducted by the University of Maryland and offers a Bachelor of Science degree in Nuclear Scienc Thirty-two of the forty initial candidates are still i participating in the program. Any nuclear operations personnel may participate. in this program; however, licensed operators and license candidates are given priorit Administrative controls to ensure control room professionalism were established and are effective. Access to the at-the-control area is limited and well controlle Operator logs were legible and complete with normal conditions, off-normal conditions, special tests and events identifie Preshift briefings were conducted and shift turnover forms were used by all operators. Watchstanders and duty technician assignments were clearly posted in the control roo Key controls for operator access to spaces and equipment were well organize Operator response to off-normal conditions and plant transients was prompt and thorough. This was exemplified during a loss of reactor coolant letdown event that occured in 1988. The rapid identification of an incorrect control signal resulted in the operator transferring centrol of letdown from the main control board to the remote shutdown panel and thereby bypassing the faulty control circuit. This timely response prevented a plant shutdown. The licensee has initiated a program to enhance the black board concept for alarm annunciator The OSTI identified instances where additional licensee attention was needed to control valve and circuit breaker alignment limiting conditions for operation ( LCO) , and legibility of control room essential drawings. The licensee was very responsive in revising LCO procedures to reduce the potential for reliance on inoperable systems and incorporating procedural steps to require independent verification of valve and circuit breaker position System walkdowns by the OSTI team members identified numerous technical and typographical errors in existing system operating procedures and attachments used for valve and breaker alignment These procedures had been implemented and issued to the field for use, ,

without a good review, or validation. Operators had to make the needed corrections while accomplishing system lineups and verification of lineups. One illegible drawing was identified 1_ ____ _

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i during the OSTI inspection; a resulting followup review by the 'l licensee identified 28 ~ additional drawings with inadequate or marginal clarity. These items were the subject of violation j l belo Over the assessment period, plant housekeeping was considered average. The control room and main control board were repainted and new carpet was installed during the 1983 refueling outag In general plant areas, a program to upgrade painting, appearance and protective coatings has resulted in an ' improved appearanc However, it is noted that the number of leaks from non-radioactive and radioactive systems, although wrapped with herculite and routed to drains, have . increase Operation should pursue the timely correction of these deficiencie Regular plant tours are accomplished by the Vice president Nuclear Operations, the plant manager and the plant ranager's staf Corporate interest and oversight of the plant was evident from frequent visits and plant tours by senior managemen Monthly trend reports and performance indicators are published to keep plant and corporate management appraised of plant status and potential plant.probl' em The plant capacity factor for the SALP period was 72.4 percent even with a 103 day refueling outage at the end of 1988. A comparison with the previous SALP shows that the unit forced outage rate increased from 4.01 to 6.20 percen The outage rate-is above the industry mid 1988 one year median of 4.8. The reactor trips, when compared with the previous SALP increased from seven to eight. The trip rate, even though some improve-ment was shown in 1988, is still above the industry one year median of approximately two. A review of the reactor trips

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determined that four trips were related to equipment failure, two trips were due to equipment design and two trips were the result of personnel errors. Five of eight trips occurred during the performance of surveillance test Management responded to the excessive reactor trip problem by initiating actions to improve labelling of procedural steps that present trip hazards and providing dditional technical training on surveillar.ce tests which expose the unit to high trip ris l Studies are <:urrently underway to justify a reduction in periodicity of high trip potential surveillanc The adequacy of the licensee's post trip reviews was questioned in May 1988 as the result of a reactor trip and reduced service water flow to the reactor building cooling units during a subsequent safety injectio The reduced service water flow problem was not detected during the post trip review. The

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I diligence of the Independent Safety Evaluation Group resulted in the identification of this problem after the plant restarte This item was the subject of a severity level III violation 3 i

issued in August 198 (See violation a. below).

A problem was identified on the previous SALP concerning the correct alignment of swing pumps. The corrective actions taken and discussed in the previous SALP appeared to be effective and no new or repeat problems were identified in this are Control of combustible and flammable materials in safety related related areas of the plant was considered good. An identified exception included an area in the auxiliary building where approximately 4.5 tons of combustible charcoal had been temporarily store (See violation g below).

The required drills and training of Fire Brigade members were conducted within the frequency outlined in plant procedure Satisfactory performance of the Fire Brigade in an unannounced drill witnessed by NRC staff demonstrated the effectiveness of the Fire Brigade training progra The licensee has experienced events where compensatory fire watches were not established for degraded fire barriers or inoperable fire e These events were the subject of five violations (quipmen c through g) and five LER's during the evaluation period. Extensive management attention was directed to this area. A Fire Protection Officer was placed on each operating shift to monitor and provide improved response for degraded fire barriers and protection equipment. This single point accountability had additionally resulted in improved communications and better equipment status contro Staffing in the fire protection area increased in 1988 from a fire protection supervisor and five technicians to a fire i protection supervisor; a fire protection coordinator; two specialists who supervise fire protection officers and surveillance testing; three technicians and five operation shift fire protection officer These changes occurred in the last quarter of 1988 and have not been implemented long enough to allow full evaluatio Seven violations were identified of which five involved inadequate fire protection or compensatory actions.

L Severity level III violation for making a mode change with

{ both trains of RBCU's inoperable. (395/88-13-01)

t Severity level IV violation for illegible control room

! drawings and incorrect valve lineup procedures.

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11 Severity level IV violation for failure to take adequate compensatory action for inoperable fire detection equipmen (395/88-24-01)

, Severity level IV violation for failure to take adequate

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compensatory action for inoperable fire detection equipment and a breached fire barrier. (395/88-03-01) Severity level IV violation for failure to take adequate L compensatory action for inoperab'e fire suppression

equipmen (395/88-10-01) Severity level IV violation for failure to take adequate action for equipment. compensatory (395/88-19-01) inoperable fire detection Severity level IV violation for failure to establish adequate compensatory fire protection measures for increased transient fire loading due to temporary storage of 4.5 tons of combustible charcoal and for-failure to have an important procedure at a control panel. (395/88-26-01) Performance Rating

I Category: 2 Previous rating - Operation: 2 Fire Protection: 2 Recommendations:

Management support of operations needs to be improve This need is indicated by procedures being issued that still contain errors that should have been identified by a procedure review / verification program. Another indication is control room drawings issued for operations use when numerous drawings were illegibl Operations personnel need to be more aggressive in raising these type problems to management's attention and in pursuing a satisfactory resolution of identified problem B. Radiological Controls Analysis During the assessment period, inspections were performed by the resident and regional inspection staff Inspections were conducted in the areas of radiation protection, radiological '

effluents, and confirmatory measurement During the assessment period, the licensee reorganized the chemistry and Health Physics departments in the first quarter of 198 A chemistry and health physics manager position was established and filled with a former corporate health physicis _ _ _ _ . - - _ _ _ _ - - _ _ . _ . .

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.~ plant was assigned to the position .of. Corporate Manager of Health ~ Physics.: The licensee also-established the position of

, Radwaste Coordinator and filled the_ position with an engineer

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who had been serving as a shift technical adviso The;11censee's' health physics (HP) and radwaste staffing levels

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appear; to be slightly lower than other. utilities having a

, facility of similar siz In additior. .to the regular plant HP technicians,.-the licensee retains 14 ' to 16 contract HP technicians to augment the HP staff for routine operations. The smaller-permanent staff has not had any deleterious' effects on the performance of the HP staf Tha knowledge'and experience

' level' off the HP- staff were excellent. The overall quality of the staff was a program strengt Radiation protection training was considered good. .Th licensee's general, employee training in radition protection was well defined. The licensee enhanced training by establishing a training program for HP supervisors. 'Since this program is in addition to regulatory requirements, it -indicates management's support for and commitment to high training standard Management support and involvement in . matters related to radiation protection were demonstrated by upgrading the whole body counters with germanium detectors and the procurement;of a standup whole body counter. . Inspection during the evaluation period indicated that the . radiation protection program received strong support from other plant department At the.end of 1988, the contaminated area of the plant was less than one percent of the total . areas monitored. Ma licensee's aggressive -contamination control program allows plant personnel to . access containment without protective clothing. Resulting benefits are a reduction in the amount of radioactive waste generated and less restrictions on workers and supervisors during performance of their assigned task In 1987, the collective dose was 562 person-rem with 547 person-rem being attributed to a refueling outage and maintenance on steam generators. In 1986, the collective dose was'23 person-rem, however, there were no outages in 1986. In 1988, the licensee expended 18 person-rem for normal operations and 503 person-rem for outage related wor Primary contributors to the high collective dose in the last two years have been the increase in reactor coolant system (RCS)

radioactivity and increased steam generator maintenanc In some high traffic areas of the plant radiation in the residual heat removal-(RHR) lines has caused dose rates in adjacent areas to increase by a factor of 2 Significant increases in dose rates'were also observed during reactor head work, fuel movement

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-e 13 and reactor cavity decontamination. The collective doses' for 1987 and 1988 are representative for plants experiencing steam generator and fuel problem .The licensee has a number of initiatives underway to limit and reduce dose rates within the plant including elimination of the resistance temperature detector bypass- manifold, evaluation of the replacement of primary system filters with smaller mesh filters to reduce the particulate in the RCS, evaluation of raising the pH of the RCS, and chemical decon of various RHR/RCS-systems and/or components in 198 The licensee's respiratory protection and radiation work permit programs .were found to be satisfactor The licensee experienced a total of 130 personnel contaminations in 1987, l 76 skin contaminations and 54 clothing contaminations. In 1988, the number of personnel contaminations increased 240 percent to 141 skin and 171 clothing contamination The licensee experienced 52 discrete radioactive particle contaminations in 1988, due' to failed fuel and the increased amount of system-maintenanc Previously, the licensee had only three hot particle contaminations with the majority of the particles being fission products. The licensee has an aggressive program for the identification and control of discrete radioactive particle During the assessment period, the licensee contracted with a vendor to perform super compaction of dry radioactive waste to reduce the volume of dry radioactive waste shipped to a low level waste burial facilit Participation in the NRC spiked sample analysis program for beta emitting radionuclides showed agreement with NRC results for all four nuclide Liquid and gaseous effluents were within regulatory limits for concentrations of radioactive material releases. There were slightly increasing trends in the annual quantities of radioactive material effluent releases for the past three year Annual effluent releases are summarized in the Supporting Data L

and Summaries,Section V.K. Licensee estimates of doses to

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maximum exposed individuals were well below the limits in the L technical specification Radiological audits and surveillance conducted by the licensee were comprehensive and sufficiently in-depth to identify problem areas and trends. Management was responsive to the problems identifie '

No violations or deviations were identified.

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Category: 1 Previous rating: 1 Recommendations The Board recognized your continuous high level of performance in this are The Board does note that there have been increases in fuel leakage in the recent past with the resultant potential for increase in radiation levels and contaminatio The Board recommends you continue a high level of management attention to this area because of this increased challeng Maintenance / Surveillance Analysis During the assessment period routine and special inspections were performed by the NRC staff. Equipment Qualification (EQ)

team inspections were conducted in October 1987, January 1988, and October 1988. A Containment Integra.ted Leak Rate Test (CILRT) inspection was conducted in September, 1988. An OSTI in November and December 1988, evaluated maintenance support of operation The maintenance organization is adequately staffed and trained to support operation of the plant. The staff is supplemented by contractors, as needed, to support plant outages. This unit has experienced a very low turnover of maintenance personne The corrective maintenance and preventive program was planned and performed in accordance with established procedure Supervisors provided adequate direction and assistance, as needed, to complete activities. QC provided adequate coverage of safety related activitie Maintenance activities were scheduled and tracked with a history maintained by computerized system The predictive maintenance program used vibration analysis, temperature monitoring, ferrography (lube oil), infrared surveys and motor operated valve analysis and tests systems (M0 VATS) to determine the need for equipment maintenance. Success experienced in this program included vibration monitoring of the main feed pumps which led to early identification and correction of coupling grease loss and alignment problems. The use of vibration analysis and ferrography on the reactor coolant pumps (RCP) permitted the licensee to extend the scheduled maintenance on "B" RCP to refueling outage This extension will allow concurrent motor tear down and seaI replacement on the RCP's for

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11 future outages. The M0 VATS equipment has been upgraded and t e data bank has been expanded to approximately 80 percent of th installed motor operator valve The erations Section of Scheduling was staffed with three SR0s and on R0. The application of licensed expertise was a strong point i the maintenance scheduling process. Another strong point wa the daily preparation of a " trip package" which contained lanned maintenance activities requiring a duration of less than ight hours to perfor Additionally, a "short duration out e package" was also planned for those activities which could b completed in the event plant trip recovery took longer than ei t hours but less than 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A weakness was i ntified in the previous SAll' in the area of first line superv ory involvement on planning and directing maintenance activit Management has provided team building '

and additional trai ' to those supervisor The shift engineer program has so improved operations interface with maintenance activities. However, it is still evident from the excessive time required complete some task, such as M0V lubricant change and dur the refueling outage, that first line supervisors are stil ot sufficiently involved in work planning activities. Altho this weakness was noted, and it is apparent that licensee se eduled more work than they were able to accomplish during the time allotted for the fourth refueling outage, they are comm ded for not cancelling scheduled work, and for extending the outa to insure that essential work ,

was complete During a Phase I review of Environm tal Qualification (EQ) of Electrical Equipment in January 1988, a problem was identified in the area of EQ maintenance. The EQ aintenance rcanirements for the lubrication of the Emergency F dwater Pump were not accomplished for two consecutive 12 mont periods. In response to the violation "c" below, the licensee rformed an indepth review of all EQ maintenance requirements a d incorporated the requirements into a comprehensive EQ Mainten nce Manual which will schedule specific maintenance task over o tage period A maintenance self-assessment program using INP0 utdelines was completed by the licensee in March 198 Base upon that ,

assessmat the licensee concluded that they met he INPO criteria through their established programs. A sma' number of weaknesses were identified in the area of planning an outages.

l These items have been assigned to a task manager to nsure l timely completio .

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l The maintenance backlog contained approximately 600 mainte nce l work requests (MWR) at the end of the SALP period. The bac og had been reduced by approximately 20 percent in the past 1 month Nonoutage MWR's that are over three months old are

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all future outage The M0 VATS equipment has been upgraded and the data bank has been expanded to approximately 80 percent of the installed motor operator valve The Operations Section of Scheduling was staffed with three SR0s and one R0. The application of licensed expertise was a strong point in' the maintenance scheduling process. Another strong-point was the daily preparation of a " trip package" which contained planned maintenance activities requiring a duration of less than eight hours to perfor Additionally, a "short duration outage package" was also planned for those activities which could be completed in the event plant trip recovery took longer than eight hours but less than 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> A weakness was identified in the previous SALP in the area of first line supervisory involvement in planning and directing maintenance activities. In response to this item, management implemented additional training and a team building program for those supervisors. The shift -engineer program has lead to improvement in operations and maintenance. work and communications interface. However, it is apparent- from the increased amount of time taken to complete scheduled outage work, that adequate input from the field and feedback to the work scheduling process are not being considered i establishing schedules. 'The time allotted for MOV lubricant changeout during the outage, far exceeded the time allotte Improved use of maintenance history data for task time requirements and training exercises on new tasks could provide more realistic . planning data. Although this weakness was noted, the licensee is comended for not cancelling scheduling work, and extending the outage to insure that essential work was complete During a Phase I review of Environmental Qualification (EQ) of Electrical Equipment in January 1988, a problem was identified in the area of EQ maintenance. The EQ maintenance requirements for the lubrication of the Emergency Feedwater Pump were not accomplished for two consecutive 12 month periods. In response to the violation "c" below, the licensee performed an indepth review of all EQ maintenance requirements and incorporated the requirements into a comprehensive EQ Maintenance Manual which will schedule specific maintenance task over outage period A maintenance self-assessment program using INP0 guidelines was completed by the licensee in March 198 Based upon that assessment the licensee concluded that they met the INP0 criteria through their established programs. A small number of weaknesses were identified in the area of planning and outage These items have been assigned to a task manager to ensure l timely completio {

The maintenance backlog contained approximately 600 maintenance work requests (MWR) at the end of the SALP period. The backlog had_been reduced by approximately 20 percent in the pas,t 18

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trended for management attention. The timely review of the MWR backlog and the relatively small number of MWRs older than three months were considered strength The licensee's overall CILRT program was conducted in a controlled and acceptable manner. The CILRT showed evidence of

. prior planning and management. involvement in the use of detailed-O test controls and experienced leak rate test consultant A conservative approach to . technical issues was observed in the resolution of instrumentation and leakage problems encountered during the performance of the test. The conduct and quality of the testing was acceptable. Surveillance test records were complete, legible, and readily retrievable. Local leak rate .'

test personnel were well qualified for their job functions and were knowledgeable in procedural and regulatory requirement Staffing in this area was adequate for the level of activit . The instrument calibrations facility was found to have well organized records and well maintained and calibrated equipmen The licensee's control, issue and accountability of tools showed a significant improvement during the recent refueling outag Tools were more readily available for work performanc Approximately 9,000 surveillance were conducted during the SALP period and only two were not documented as have being completed within the prescribed time limit Both of the' tests were on the diesel fire pump batterie These deficiencies were identified and corrected by the licensee in a timely manne These results indicate a strong and effective program with good management oversight of this area. However, it is noted that five of the eight reactor trips occurred during surveillance test Three violations were identifie Severity Level IV violation for failure to properly implement Administrative Procedure SAP-134 thereby performing an inadequate post-test review of test results for surveillance test procedure STP-210.00 (395/88-07-01) Severity Level IV violation for failure to maintain plant procedures which provide instructions for operation of the service water "A" pumps screen wash pump and traveling l

scree (395/88-15-01) Severity Level V violation for failure to perform EQ '

maintenance requirements for lubrication of the emergency i feedwater pump for two consecutive twelve month period l (395/88-01-01)

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17 Performance Rating Category: 1 Previous rating - Maintenance: 1 Surveillance: 1 Recommendations D. Emergency Preparedness Analysis The inspections conducted during this assessment period by NRC staff included one routine EP inspection in M6y 1988, and an Emergency Response Facility (ERF) Appraisal conducted in March 198 Based on the inspection activity noted above, the licensee demonstrated an ability to adequately implement the essential  ;

elements of the Summer Emergency Plan during a simulated or

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actual emergency event. However, declining performance in the area of Emergency Plan required trair.ing was identified as noted  !

belo The routine inspection, conducted in May 1988, disclosed a recurrent licensee problem involving the failure to follow their Emergency Plan with re. sect to requirements for training. A violation was identifieo for failure to provide required training to two key members (Radiological Assessment Supervisor and Maintenance Supervisor) of the onsite emergency organization assessment staff in accordance with Emergency Plan procedure The licensee's planned corrective action appeared adequate. All other training of key members of the emergency organization appeared to be consistent with approved procedures. However, a similar violation was identified during the preceding assessment period involving training of key members of the emergency organization on the fission product barrier approach to emergency event classificatio During the ERF Appraisal walkthroughs, a Shift Supervisor made an untimely event classification, as well as an incorrect emergency declaration in response to a postulated casualty presented by the inspector. It was noted that an artificiality in the scenario may have been a contributing factor. However, the licensee acknowledged that improvements were needed in the Emergency Plan training program. The General Manager for Operations connitted to provide additional training for Emergency Directors to include, as a minimum, event classification and protective action recommendation The March 1988 ERF Appraisal disclosed that the emergency i response facilities, including the Control Room, Technical

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Support Center (TSC), and Emergency Operations Facility (EOF),

fully met the regulatory criteria, orders, and license

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conditions issued to implement Supplement 1 to NUREG-0737. The ERFs provided all necessary equipment, systems, documents, and supplies to assist the licensee in the identification and 1 mitigation of plant emergency events, and implemented all elements of the Emergency Plan required to protect onsite personnel and the public within the assigned emergency planning zon The licensee maintains the ERFs, and all equipment and systems 4 therein, in an adequate state of operational readiness for responding to emergencies.. The licensee also established an effective management and control program fer the Early Warning Siren System, and installed a redundant transmitter and encoder for the . system. Shift staffing augmentation appeared to be  ;

i consistent with regulatory requirements and guidance. Although no violations were identified during the Appraisal, the licensee committed to review several dose assessment followup items and to provide a response. The licensee's response has been reviewed and determined to be acceptabl During the assessment period, five revisions were submitted to

'the Emergency Plan for NRC review and approva The proposed revisions were determined to be consistent with regulatory requirements and guidanc One violation was identified. Although the finding was not indicative of a significant programmatic breakdown in the EP program as a whole, it is clear that performance in Emergency Plan required training has declined. The licensee continued to demonstrate overall the capability to fully implement key elements of the Emergency Plan during simulated or actual plant emergency event Severity Level IV violation for failure of two key members of the onsite emergency response organization to complete training in accordance with Emergency Plan Procedure EPP-018, Emergency Training and Drill (395/87-23)

2. Performance Rating Category: 2 Previous rating: 2 3. Recommendations The Board note: that during an inspection after the close of the assessment period (in January 1989) there was another finding of failure to provide training to members of the emergency response tea We encouragt. licensee management to give increased emphasis to emergency response training and retraining and recommend increased NRC inspection resources be provided in this area.

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'l E. -Security l ' Analysis Two routine and one reactive inspections were conducted by the

.NRC staf ~

The licensee - expended extensive resources ~ in constructing a secondary access portal, installing a new security computer, a new access control system, a' new . secondary alarm statio upgrading the closed circuit TV system and central alarm station

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and providing additional protection for the secondary power supply syste Historically, this licensee has been one of the Region's

+ ' outstanding . security performer The problems discussed below became' apparent during the last half of the rating perio The ' security organizat'on, after the loss of- the security manager and the captain in charge of security personnel in late 1987,.was reorganized and incorporated into the Nuclear Protec-tion Service lwith a new manager, associate manager and several supervisory changes brought about by attrition. . Changes in management, supervision style and philosophy were not readily accepted by the security force. Management was also slow in recognizing situations which resulted in a deteriorating security morale and perfonnance. As a result, certain viola-tions were. identified in the latter part of the SALP period _and-an Enforcement Conference was held on January 6, 1989 to discuss the following items: failure to control access .to vital and protected areas; failure to control access to the area; failure to control access to a vital area (protected sleeping guard); failure to rotate locks and cores after terminating

- members of the security force; failure to implement contingency

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measure; inadequate perimeter intrusion detection system; and

. inadequate-reporting of safeguards event Serious management attention to these weaknesses was provided after.this series of events which occurred in the last quarter of 198 These events and a resulting NRC inspection indicated that security performance in the area of personnel access control had reached a level of marginal performanc The repetitive access control violations indicate: a. breakdown in the supervisory oversight of the security force; a failure on the part -of the security force to recognize and correct problems; and a failure of management to implement effective corrective measures. The root cause analyses for the first access control problem was not effective in preventing recur- i rence. Management also demonstrated a lack of familiarity with !

basic security requirements as evidenced by the failure to e

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search a vital area when the security force member posted to control area access was discovered asleep. Further examples of lack of. familiarity with requirements was evident when the licensee failed to rotate security locks following the termination of members of the security' force on several occasion Although the licensee employs a dedicated security maintenance staff, a lack of attention to detail.a lack 'of technical

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' expertise or incorrect implementation of regulatory requirements, was' found by the NRC in the areas of intrusion detection equipmen Critical self-assessment was lacking, therefore problems were not identified at an early stag After initial identification of the above problems, the licensee responded by assigning a new General Manager Station Support and redefinition of responsibilities for licensee and contractor employees has been implemented.

I One violation was identified during this assessment perio .However, subsequent to the end of the assessment period, escalated enforcement action involving multiple examples of security deficiencies was issue Severity level IV violation for inadequate perimeter intrusion detection capability. (395/87-31-01) Performance Rating Category: 2 (Declining) Previous rating: 1

- Recommendations The Board has noted that during the first half of this SALP period the licensee enjoyed a favorable security program without .

the negative impact of enforcement issues. However, a serious degradation during the second half of this SALP period that could result, if unchecked, in a SALP 3 rating. In order to alleviate this situation the Board recommends that a high level of management attention continue to be given to this program are Engineering / Technical Support Analysis The Engineering Technical Support functional area addresses the adequacy of technical and engineering support for all plant activities. To determine the adequacy of support provided, specific attention was given to the identification and resolu-tion of technical issues, responsiveness to NRC initiatives, enforcement history, staffing, effectiveness of training, and qualificatio The scope of this assessment includes all

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, , . icensee activities associated with plant modifications, t hnical support provided for. operation, maintenance, testing an surveillance, operator training, procurement, and configu-rat n contro The li nsee has initiated or continued several major efforts to improve r maintain the quality of engineering performance. The Corporat Nuclear Operations Division relocated to the plant site,in 1 e 198 This move consolidated engineering proce-dures, work activities and placed the design expertise close to plant activi ies. The relocation provides an enhancement to the operations /en neering interfac In conjunction with the relocation, a organization initiated a system engineering progra This ogram is designed to improve overall system performance tren and provide a designated system interface for operational an etechnical issue However, the licensee's progress in impleme g this program has been slo The licensee's progra Yrto document and verify major systems design bases was contin from the previous assessment perio The design basis docume jion (DBD) effort integrated system and component requirement actual as-built information, project commitments, and engineeri accident analysis and margin Sixteen DBDs were completed his assessment period. The DBDs have provided a good referenc resource for engineering activity and contributed to the identi cation and correction of plant problem This design base ef rt is a long term continuing activity with approximately 50 BDs planned for future completio The licensee's steam generators co tinue to exhibit the deleterious effects of primary water tress cracking corrosion as evidenced by the number of tubes r uiring plugging during the fourth refueling outage. Steam ge rators A, B and C presently have 6.0, 10.9 and 6.5 percent their tubes plugge Although preventive measures such as Roto ening, shot peening and stress relieving have been accomplished during previous outage These measures and engineering st ies which have reduced plugging requirements have not provi d an ultimate solution to this proble Engineering performance on specific technical iss es has been good and overall performance resulted in a modific ion backlog reduction. Engineering provided timely assistance problem definition, solution, corrective action, and develo ent of Justifications for Continued Operation when required t support plant activitie Specifically, engineering support to apera-tions and maintenance was effective in the evaluation o' the hydraulic lock-up of the pressurizer and steam generator vel transmitters, and re-evaluation of Intermediate Building s am line break analysis. Response and evaluation to NRC bulleti related to nonconforming materials from Piping Supplies In __

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licensee activities associated with plant modifications, technical support provided for operation, maintenance, testing and surveillance, operator training, procurement, and configu-ration contro The licensee has initiated or continued several major efforts to improve or maintain the quality of engineering performance. The Corporate Nuclear Operations Division relocated to the plant site in late 1987. This move consolidated engineering proce-dures, work activities and placed the design expertise close to plant activities. The relocation provides an enhancement to the operations / engineering interfac In conjunction with the relocation, a reorganization initiated' a system engineering

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program. This program is designed to improve overall system performance trending and provide a designated system interface for operational and technical issue However, the licensee's progress in implementing this program has been slo The licensee's program to document and verify major systems design bases was continued from the previous assessment perio The cesign basis documentation (DBD) effort integrated system and component requirements, actual as-built information, project commitments, and engineering accident analysis and margin Sixteen DBDs were completed this assessment perio The DBDs r-have provided a good reference resource for engineering activity and contributed to the identification and correction of plant problems. This design base effort is a long term continuing activity with approximately 40 DBDs planned for future completio 'The licensee's steam generators continue to exhibit the deleterious effects of primary water stress cracking corrosion as evidenced by the number of tubes requiring plugging during the fourth refueling outage. Steam generators A, B and C presently have 6.0, 10.9 and 6.5 percent of their tubes plugge Although preventive measures such as Roto peening, shot peening and stress relieving have been accomplished during previous'

outage These measures and engineering studies which have reduced plugging requirements have not provided an ultimate solution to this proble Engineering performance on specific technical issues has been good and overall performance resulted in a modification backlog reduction. Engineering provided timely assistance in problem definition, solution, corrective action, and development of Justifications for Continued Operation when required to support plant activitie Specifically, engineering support to opera- ,

tions and maintenance was effective in the evaluation of the ;

hydraulic lock-up of the pressurizer and steam generator level "

transmitters, and re-evaluation of Intermediate Building steam l line break analysis. Response and evaluation to NRC bulletins related to nonconforming materials from Pipina Supplies Inc. of

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l rsey, Steam Generator Crack Propagation, Fastener Testing, and P e Wall Thinning was timely and aggressive. Engineering su ort and program management to complete all modifications poss ' le at power, has resulted in a 17 per cent reduction in outst ding modification e 1987 refueling outage the as-found Pressurizer Safety During Valves (P V) setpoints were significantly higher than allowed by technical )ecifications. In order to determine the cause of the high ou'. of tolerance PSV setpoints, the licensee performed extensive res arch into the effects of test temperature and test medium on PSV setpoin The licensee's approach to the resolution of e setpoint deviation demonstrated a clear understanding of he issue. The licensee's present PSV and Main Steam Safety Valve (MSSV) setpoin; test program utilizes one of the most advanced est methods presently availabl This program exceeds the irements of the test code to which the licensee is committe Toward the end of the as sment period, it was identified that the licensee performed a Jnadequate design evaluation and modification that changed fire protection deluge sprinkler control valves for charcoal hterunitsfromtheopenposition,

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as described in the FSAR, to 1. e closed position. These changes were made without adequate e luation and initiation of appropriate actions to revise he FSAR and operational procedures where required. These examples suggest an apparent weakness i_n engineering support th has the potential to leave an important safety question unre iewed er inadequately reviewe Licensee efforts have been directed the control of microbiologically induced corrosion, cor cula and soft water attack in service water piping. EPRI an consultants have provided assistance in resolving this item. The licensee has submitted an application to the state depar nt of health and environmental control requesting permission to chemically treat this system. With this treatment the license expec ts to prevent future occurrence of problems such as he reduced service water flow to the RBCU discussed in the op ations are V. C. Sunener has a strong procurement progra The ocurement staff includes 15 engineers, nine technicians, three i pectors, and 29 administrative and warehouse personnel. This gr p has a fully operational commercial grade procurement program ith testing equipment and technicians to verify material ad equipment critical parameter This program has allowed e licensee to upgrade such parts as transformers, circuit breakers, switches, relays, fasteners, insulation, and Bellvi e washer m_,_m_n. _ , .u.+-:-.-,------ . - --:---a-- -- - - - - - - - -

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Jersey, Steam Generator Crack Propagation, Fastener Testing, and Pips Wall Thinning was timely and aggressiv Engineering support and program management to complete all modifications

.possible at power, has resulted in a 17 per cent reduction in outstanding modification During the 1987 refueling outage the as-found Pressurizer Safety Valves (PSV) setpoints were significantly higher than allowed.by technical specification In order to determine the cause of the high out of tolerance pSV setpoints, the licensee performed extensive research'into the effects of test temperature and test medium on PSV setpoint. The licensee's approach to the resolution of the setpoint deviation demonstrated a clear understanding of the-issue. The licensee's present PSV and Main Steam Safety Valves (MSSV) setpoint test program utilizes one of the most advanced test methods presently availabl This program exceeds the requirements of the test code to which the licensee is committe Toward the end of the assessment period, it was identified that the licensee performed an inadequate design evaluation and modification that changed ten fire protection deluge sprinkler control valves for charcoal filter units from the open. position, as described in the FSAR, to the closed position. These changes were made without adequate evaluation and initiation of appropriate actions to revise the FSAR and operational procedures where require These examples suggest an apparent weakness in modifications control that has the potential to leave an important safety question unreviewed or inadequately reviewe .

Licensee efforts have been directed at the control of microbiological 1y induced corrosion, corbicula and oft water attack in service water piping. EPRI and consultants have provided assistance in resolving this item. The licensee has submitted an application to the state department of health and environmental control requesting permission to chemically treat this syste With this treatment the licensee expects to prevent future occurrence of- problems such as the reduced service water flow to the RBCU discussed in the operations are V. C. Sunner has a strong procurement program. The procurement staff includer 15 engineers, nine technicians, three inspectors, and 29 administrative and warehouse personnel. This group has a fully operational commercial grade procurement program with testing equipment and technicians to verify material and equipment critical parameter This program has allowed the licensee to upgrade such parts as transformers, ci rcuit breakers, switches, relays, fasteners, insulation, and Bellville washers.

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