IR 05000220/1989010
| ML18038A445 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/02/1989 |
| From: | Jerrica Johnson NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A444 | List: |
| References | |
| 50-220-89-10, NUDOCS 8902140304 | |
| Download: ML18038A445 (42) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
Docket No.
89-10 50-220 License No.
DPR-63 Licensee:
Niagara Mohawk Power Corporation 301 Plainfield Road Syracuse, New York 13212 Faci 1 ity:
Location:
Nine Mile Point, Unit
Scriba, New York Dates:
January 24, 1989 through January 26, 1989 Inspectors:
W. Cook, Senior Resident Inspector R.
Temps, Resident Inspector R.
Laura, Resident Inspector M. Banerjee, Project Engineer Panel Members
W. Kane, Director, Division of Reactor Projects E. Butcher, Acting Deputy Director, Division of Reactor Safety R. Capra, Director, Project Directorate I-l, NRR E. Wenzinger, Chief, Projects Branch No.
J. Johnson, Chief, Projects Section 2C R. Bores, Senior Technical Reviewer, Division of Radiation Safety and Safeguards W. Cook, Senior Resident Inspector M. Haughey, Project Manager, NRR Approved by:
. Johnso
, Chief, Reactor Projects Section 2C, DRP Date REPORT SUMMARY Areas Reviewed:
The NRC Restart Panel conducted a review and evaluation of the licensee's Restart Action Plan delivered to the NRC in a meeting on
December 22, 1988.
The inspectors also reviewed the Nuclear Improvement Plan while on site.
This review included discussions among the panel members and inspectors as well as discussions with licensee representatives and a tour of the facility.
Results:
The NRC Restart Panel concluded that the NMP Unit 1 Restart Action Plan process and approach was generally acceptable.
However,'he Panel generated a
number of questions during their detailed review.
guestions for which a written response is needed are included in Attachments 1 and 2 to this report.
The licensee acknowledged these questions and concerns and agreed to provide answers and further clarification in a future'hange to the Pla DETAILS 1.
~Pur ose During the week of January 23, 1989, the NRC Restart Panel convened at the site to conduct a detailed review of the Nine Mile Point Unit
Restart Action Plan, dated December 1988.
The purpose of this review was to verify that the Restart Action Plan satisfies conditions 1 and 2 of the NRC Confirmatory Action Letter 88-17, dated July 24, 1988.
2.
Overall NRC Assessment of the Restart Action Plan The Restart Panel found the basic approach and format for the Restart Action Plan to be generally acceptable.
General and specific questions regarding various aspects of the Restart Action Plan (RAP) are documented in the subsequent sections of this report and its attachments.
The licensee has agreed to respond to these questions.
NRC approval of the RAP is dependent on satisfactory responses to the questions in this report and its attachments.
3.
RAP Review Comments Basic A
roach and Lo ic The Restart Panel reviewed the RAP in order to understand the licensee's basic approach to restart of Unit 1 and to understand the logic used to determined the underlying root causes for licensee managment's ineffectiveness in problem identification and resolution.
The Panel concluded that the licensee's approach appeared sound.
The steps the licensee used to arrive at their conclusions include:
1) review and identification of problems via examination of various sources (internal and external audits, inspection reports, SALPs, etc.);
2) analysis of the identified problems including causal determinations and subsequent grouping of these items into underlying issues; 3) determination of the underlying root causes for these issues; 4) development and subsequent implementation of corrective actions to address these underlying root causes (RAP and NIP); S)
self-assessment of the progress and effectiveness of the corrective actions taken; and 6) final senior management and independent party review of readiness for restart.
The Panel had difficulty in understanding the logic used to determine the underlying root causes outlined in Table 1, page B-3 of the RAP.
In particular, the correlation between all of the Savannah River (SR)
Causal Trees used and the final underlying root causes of Management and Organizational Effectiveness outlined in Figure I, page B-4 of the RAP is confusing.
It is not clear how the transition was made from use o'f the Savannah River Causal Trees to the NMPC Management and Organizational Effectiveness Cause Tree.
In addition, it is not clear why all of the Savanah River Causal Trees were not used and why 25% of root causes not attributed to management and supervision (pg B-1)
seem to be missing.
In addition, the licensee indicated that the Savannah River root cause tree system was used to analyze the Specific Issues; however, in the Specific Issue Analysis section of the Plan, there is no reference to the Savannah River root cause coding.
This information needs to be provided in the Plan for com-pleteness in order to understand the relationship to the "underlying" root causes and the "root causes" for the "Specific Issues."
Identification of Root Causes The NRC Restart Panel is in general agreement with the "underlying root causes" of why Niagara Mohawk management has not been effective in recognizing and remedying problems.
However, the NRC did not understand how the licensee addressed three specific areas
I) adequacy of management and leadership skills, 2) adequacy of independent assessments, including quality assurance, and 3) adequacy of personnel training in the identification and resolution process.
The licensee needs to explain in the Plan how. these fundamental topics are related to the NMPC identified "underlying root causes".
In addition, it was not clear at the January 26, 1989 meeting how the underlying root causes applied to the independent oversight functions in addition to line management.
In light of the shortcomings that existed in the apparent role that the Quality Assurance (QA) Department had in assuring that previous issues were identified and resolved, the licensee needs to explain more fully the appropriateness of the organizational and reporting relationship of that function for nuclear matters.
A clear understanding is needed of those corrective actions that will be taken to assure that QA will be an effective management tool for the Executive Vice President.
Corrective Actions and Prioritization Essential to the licensee's restart efforts are the corrective actions taken to address the underlying root causes and the proper prioriti-zation of these actions to support a restart schedule.
Although the RAP outlines the prioritization of corrective actions based upon regulatory a'nd/or impact on safe operations, the latter is not
sufficiently detailed in the RAP.
The criteria or process the licensee used to determine which items could affect safe operations (and therefore should be completed prior to restart)
was not sufficient for the NRC to understand and therefore judge acceptability.
These criteria or processes should be included in a revision to the plan.
Similarly, adequate justification was not documented for deferral of post restart or long term strategies.
The licensee needs to amplify these criteria and deferral justification in a revision to the RAP and to provide a schedule for implementation of those long term strategies that address the underlying root causes of management ineffectiveness.
Verification Actions Integral to the completion of RAP corrective actions is a verification activity, designed to be independent of the corrective action responsible party's efforts.
In multiple examples identified by the Restart Panel, the designated verification action(s)
were not con-sidered adequate to provide for a comprehensive assessment of the satisfactory completion of the corresponding corrective action.
It appeared to the Panel that this integral step of the restart process warrants further development by the licensee.
Specifically, of the various alternate verification actions available to the licensee, in a number'of cases all the appropriate verification actions have not been planned.
The Panel also requested that the RAP be revised to reflect the specific individuals (by title) assigned corrective action responsibility and verification actions'n improved explanation of the proposed use of the verification activities listed on page II-1 of the RAP was requested.
Revisions to the RAP The Restart Panel concluded that a revision to the Restart Action Plan is appropriate to satisfactorily address the general comments stated above (and in the Attachments to this report)
and to formally inform the NRC staff of any significant changes to the Plan.
~ Excluded from this revision request is the identification of a new "specific" issue or licensee closure of a "specific" issue listed on page II-11 of the RAP.
The purpose of these formal revisions is to ensure NRC recog-nition and understanding of any important changes to the Plan and to ensure appropriate review and approval of the final Restart Action Plan and substantive revisions by the NRC. It is expected that the Plan will be updated as a controlled document until restart authori-zation is granted by the NRC.
4.
Assessment of the Nuclear Im rovement Plan The NRC inspectors reviewed the licensee's initial draft of the Nuclear Improvement Program, dated January 9,
1989.
As stated in the Program introduction, the thrust of the Nuclear Improvement Program (NIP) is to improve management and organizational effectiveness in both the near and
long term.
The Nine Nile Point Unit 1 Restart Action Plan (RAP), dated December 1988, is the short term part of the licensee's improvement efforts and is incorporated in the NIP objectives as priority One items (required to be completed prior to restart).
The purpose of the inspectors'eview was to assess the adequacy and completeness of the NIP in defining the objectives of the RAP long term strategies.
Additionally, the inspectors reviewed the NIP objectives to determine if the licensee had properly prioritized the individual improvement items for completion prior to or after Unit 1 restart.
The inspectors reviewed the NIP on site and met with licensee representatives to discuss their inspection findings and questions on the program objectives.
Some of the inspectors'uestions required only simple clarifications and were sufficiently addressed during the meetings on site.
The remainder of the questions, which were also discussed with the licensee, primarily involve clarification regarding the basis of prioritization of individual long-term items, and are included as the list of questions in Attachment 2 to this report.
The inspectors concluded that the Nuclear Improvement Program appears to be a comprehensive licensee effort to improve overall performance.
The program does reflect the vast majority of the RAP long-term strategies.
For the most part, the inspectors agreed with the prioritization of most of the NIP objectives.
Additional information is being requested.
Lastly, the inspectors emphasized the importance of the licensee's self-assessment effort and urged a reprioritization of the NIP objectives addressing this item.
Exit Neetin At the exit meeting held on January 26, 1989, we summarized the Restart Panel findings and conclusions following their detailed review of the RAP.
The licens'ee agreed that a revision to the RAP would be submitted, including the response to the NRC staff's questions documented in this report and Attachments 1 and 2.
Licensee personnel present at the exit meeting included the following
J. Endries, President, NMPC L. Burkhardt, Executive Vice President C. Hangan, Senior Vice President C. Terry, Vice President, Engineering and Licensing J. Willis, General Station Superintendent K. Dahlberg, Station Superintendent, Unit 1 J. Perry, Director, Unit 1 Restart Task Force
Attachment
NRC Concerns and uestions on the Nine Mile Point Unit 1 Restart Action Plan General The Panel had difficulty in understanding the logic used to determine the underlying root causes outlined in Table 1,
page B-3 of the RAP.
In particular, the correlation between all of the Savannah River (SR) Causal Trees used and the final underling root causes of Management and Organiza-tional Effectiveness outlined in Figure 1,
page B-4 of the RAP is confusing.
It is not clear how the transition was made from use of the Savannah River Causal Trees to the NMPC Management and Organizational Effectiveness Cause Tree.
For example, why the quality assurance section was deleted, and what was done with the 25% of the root causes not attributed to management and supervision (pg B-l) are not clear.
Please explain.
~
The licensee indicated that the Savannah River root cause tree system was used to analyze the Specific Issues; however; in the Specific Issue Analysis section of the Plan, there is no reference to the Savannah River root cause coding.
Please clarify.
The NRC did not understand how the licensee addressed three specific areas:
1) adequacy of management and leadership skills, 2) adequacy of independent assessments and quality assurance, and 3) adequacy of training personnel in the identification and resolution process.
Please explain how these fundamental topics are related to the NMPC identified
"underlying root causes".
Update the plan to reflect the response.
4.
It is not clear how the underlying root causes are applied to the independent oversight functions in addition to the line management.
In light of the shortcomings that existed in the apparent role that the Quality Assurance (QA) Department had in assuring that previous issues were identified and resolved, the licensee needs to explain more fully the organizational and reporting relationship to the Executive Vice President for nuclear matters.
What specific causes and corrective actions have been identified to assure that QA can be an effective management tool for the Executive Vice President?
The Restart Action Plan (RAP) does not 'adequately address the last sent-ence of item 2 in CAL 88-17.
"For actions proposed for completion after restart, you will provide justification for why completidn after restart will not have an adverse impact on safe plant operation."
The criteria or process the licensee used to determine which items could affect safe operations (and therefore should be completed prior to restart)
was not sufficient for the NRC to understand and therefore judge acceptability.
Please provide an explanation of the criteria or methods used to deter-mine potential impact on safe plant operatio.
The Plan does not address a schedule for completion of items after startup as committed to in item 2 of the CAL.
Adequate justification was not documented for deferral to post restart or long term strategies.
Please provide the deferral justification in a revision to the RAP and provide a
schedule for implementation of those long term strategies that address the underlying root causes of management ineffectiveness.
In multiple examples identified by the Restart Panel, the designated verif-ication action(s)
were not considered adequate to provide for a comprehen-sive assessment of the satisfactory completion of the corresponding corr-ective action.
It appeared to the Panel that this integral step of the restart process warrants further development by the licensee.
Please revise the RAP to reflect an improved explanation of the verification activities listed on page II-1 of the RAP.
What document(s)
assign accountability and responsibility for corrective actions and verification actions?
Add to the Plan those persons (by title) who are responsible for the corrective and verification actions'xplain how the corrective actions will be verified by both the line and independent organizations.
The Restart Action Plan needs to be updated to address (NRC) questions and concerns.
Updates (page changes)
should be provided until plant restart is authorized.
NMPC need not update the Plan with any new
~s ecific issue unless it addresses a
new under lying root cause.
Executive Summary 10.
In the discussion of review of past initiatives "Shortcomings" in previous action plans and the self-assessment process are recognized by Niagara Mohawk.
Explain why these shortcomings took place and why they will not appear in implementing this Plan.
12.
The summary of 5 underlying root causes is silent regarding what appears to have been significant weaknesses in:
1) management and leadership skills; 2) effectiveness of independent assessment; and 3) why the plan doesn't address what appears to have been a significant knowledge, training, or sensitivity weakness with regards to timely resolution of identified deficiencies?
This questions pertains to groups such as Engineering, Quality Assurance, and Unit 2 personnel.
Root cause No.
5 involves lack of coordination and communication in carrying out responsibilities.
Why did this take place?
Is it continuing?
13.
The last paragraph on page 3 and conclusion on page I-7 indicates that all of the issues fall into the. Management and Organizational Effectiveness category and have, therefore, had a corresponding detrimental effect on morale and attitude.
In light of this what action is being taken to correct and verify correction of the "..... detrimental effect on morale and attitude....",
and why should not it be complete before restart?
15.
The plan discusses on page 4 the need for a "cultural change",
but implies this effort will be addressed only in the Nuclear Improvement Program.
What efforts to initiate a "cultural change" will be pursued/completed before restart?
What is the justification for those efforts that will not be completed until after restart?
The Outage Manager receives plans and schedules for "each issue" from the responsible manager.
What are the Outage Manager's duties and responsibilities?
How does he ensure he tracks all issues needing to be tracked?
Overview of Plan Develo ment and Im lementation 1 In several places the Plan alludes to a "previous lack of buy-in by plant staff" as a significant past problem.
Explain what "lack of buy-in" means and why it existed.
How does this Plan ensure
"buy-in" has been achieved throughout the nuclear organization, including Unit 2?
With respect to the 3rd bullet on page I-l, what involvement in identification of issues, development of root causes and corrective actions is intended for the gA organization?
18.
19.
The list of historical documents used as sources of problems on page I-2 and I-3 is,limited.
Please explain why NMPC feels this is a sufficient body of information to evaluate.
As an example why weren't the following used?
NMP2 LERs and the Self-Assessment Report.
Page I-2 mentions an "...... ongoing process for identifying and reviewing new issues......
to determine if they involve regulatory concerns.....".
How does NMPC track theses issues to resolution?
20.
Page I-5 To what degree and in what manner have the Nuclear Oversight Committee of the Board participated in the development of the Restart Plan?
What expertise wi 11 this Committee bring to its review and monitoring of the restart process?
Also, provide the qualifications and review functions of the Safety Review and Audit Board, and the-Restart Review Panel.
Page I-5:'nly a very preliminary outline of the Self-Assessment process (i.e.,
Readiness for Restart),
and Restart Review Panel are presented in the
Restart Action Plan.
When and how does NMPC plan on providing more details on this critical portion of the restart plan?
Part II - Issues/Root Causes:
22.
Describe the relationship between the root causes discussed in Tables Ul through U5 and the root causes provided for the specific issues.
Underl in Root Causes:
23.
Page II-1:
Eleven verification actions are listed, but only numbers 1, 2, 3, 5,
and 7 are referred to in the following Tables.
Where are the other verification actions applied?
Explain why more "hands on" verification actions are not planned.
24.
Page II-1, Item ¹6:
Mill interviews with personnel, in addition to testing
"knowledge and understanding",
attempt to examine attitude and morale issues, or solicit feedback on old or new issues?
What measures will be used to judge attitude and morale?
Page II-l, Item ¹9:
What does "Inspect...... for condition" mean?
Does it mean only do a visual examination for appearance of cleanliness or does it mean test the equipment to determine its operability, or what?
26.
Page II-1, Item ¹11:
What does
"check equipment status and lineups" mean?
27.
Page II-l, verification:
What will be the instructions to the person doing the verification?
Under 1 in Root Cause 1:
In part, Corrective Action Objective 1.1 is to develop and communicate senior management's vision, direction, and performance expectations.
None of the three Restart Corrective Actions discusses communicating these policies.
When and how is this to be accomplished?
- How will the "management's vision, direction and performance expectation" be made available to the NRC?
Corrective Action Objective l. 1 discusses management's vision, direction and performance expectations.
The three Corrective Actions discuss:
Nuclear Division vision and goals; Corporate objectives; and senior management expectations.
The Long-Term Strategies discuss goals,
objectives and operating principles?
How are all of these items related to each other?
30.
Regarding Corrective Action 1. 1.3, why is verification action 6 not included to be sure expectations of management are known and understood by subordinates?
Concerning the long-term strategy, why is it not necessary to improve linkage between organization goals and individual performance before plant restart?
33.
Concerning the following restart corrective actions:
1. Why should not existing procedures be reviewed for adequacy and needed improvements made?
1. How can verification action 1 (review procedure)
assure that responsibilities are understood.
Concerning corrective action 1.2.5, how will it be assured that all preventive maintenance, surveillance testing, or other operational requirements on the controlled lists have been completed before restart?
Under 1 in Root Cause
34.
How is the identification and the reporting of problems discussed in restart corrective action 2. 1
~ 1 to be accomplished in an "integrated and consistent process"?
How will the "processing, evaluation, and implemen-tation" of the problem reports discussed in item 2. 1.2 be accomplished?
35 'oncerning restart corrective action 2. 1.8, which personnel are to be interviewed and why?
Please explain.
36.
Concerning restart corrective action 2. 1.9, will Niagara Mohawk assess the effectiveness of the current Problem Report program?
Explain how this corrective action includes training.
37.
Concerning restart corrective action 2. 1.9, clarify the problem report process.
Long term strategies include training and accountability issues.
As discussed above, why do not corrective actions in this area need to be done before startup?
Why delay improving the capability of employees to recognize and respond to problems until after restart?
How will Niagara Mohawk measure the effectiveness of corrective actions in this regard?
What will be considered success?
How measured?
38.
Restart corrective action 2. 1.7 states,
"Review lessons learned from NMP-2 that may identify issues applicable to NMP-I that may relate to restart."
Please clarify what specifically will be reviewe Underl in Root Cause
39 Regarding Underlying Root Cause 3,
how will employee needs be determined or acted on?
40.
Concerning corrective action objective 3.2, what will be the criteria for measuring success of efforts to improve interpersonal management, teambui lding and coaching skills?
What improvement will be sought prior to startup?
What could be considered success?
How is it measured?
41.
42.
Concerning corrective action objective 3.3, what degree of improvement in training and recruiting practices will be sought prior to startup?
How will success be measured?
Regarding corrective action objectives 3.2 and 3.3, describe why an
"Increased Focus on Training" is not required for restart based on the significance of the findings discussed in specific issues 2 and 3.
Underl in Root Cause 4:
Does Restart Corrective Action 4. 1. 1 include standards of performance for individuals?
45.
Describe the difference between Restart Corrective Action 4. 1. 1 and the Long-Term Strategy associated with Corrective Action Objective 4. 1.
How much of ".... develop and communicate standard of performance..."
is intended to be completed prior to startup?
Underlying root cause 4 states "..... self-assessments have not been consistent or effective.....".
Please clarify, "self-assessments" of who, or what?
Why have they not been effective?
'I 46.
For restart corrective action 4.2.1 shouldn't all verification actions 1-11 be used?
Underl in Root Cause 5:
47.
48.
In order to improve communications, where are corrective actions to address the past problem of untimely resolution of identified deficiencies?
(time constraints on resolving potential system operability issues)
Ci Restart corrective action 5. 1. 1 through 5. 1.5:
Why should observation of the effectiveness of these activities through observing work or training in progress not be used to verify success (verification actions)?
Please explain.
Regarding the long-term strategies, who will be performing the "follow-up assessment"?
(Third party or internal NMPC)?
S ecific Issue
Outa e
Mana ement-Oversi ht:
50.
Page'
I-14, Sube1 ement 1. 2:
What criteria will be used 'to determine which maintenance backlog items must be completed prior to restart?
~
S ecific Issue
Maintenance of 0 erator Licenses:
51.
Regarding the long-term strategy, what is the basis for allowing upgrades to the operator requalification program to go beyond restart?
52.
How many licensed individuals will be trainers by 12/31/89?
53.
Are staff license holders presently attending requalification training, pending the determination of the need for their license?
54.
55.
56.
57.
Regarding corrective action 2.A.2, how will operator feedback on program content be incorporated in the operator training program?
How will training program ownership by the operators, as well as management, be encouraged?
With reference,to corrective action 2.A.2, what actions are planned to control (and limit) the assignment on shift to those personnel who have properly participated in or completed the requalification program?
Verification action 2.A. Should this be limited to observation of a ~one) training session?
Is this a typographical error?
Verification action 2.A.4. 1 - Should this be limited to attendance of a ~one)
OTPAC meeting?
Explain.
Corrective action 2.A.4, item (2) - What is management approval required for?
59.
Concerning corrective action 2.B.3:
What is the schedule for 1) identifying-simulator deficiencies, 2) correcting simulator deficiencies (installing and verifying modifications),
and 3) training the operators using the improved simulator?
What is the nature and extent of simulator changes to be performed prior to startup?
'1.
Root cause 2.B states, in part, that the quality of training in some instances was not adequate due to inadequate management oversight.
Corrective action 2.B. 1 directs the superintendent of training to provide management oversight to assure quality of training's the superintendent of training the only individual assigned the responsibility or providing oversight on the quality and effectiveness of training?
Will QA participate?
Regarding verification action 2.B.5.2, what percent of the operators will be interviewed to assess the quality and effectiveness of the training?
62.
Regarding root cause 2D, what will be done to assure that individual operators are knowledgeable of their own responsibilities for getting the required training?
63.
Regarding verification action 2.D.3. 1, what will be done to verify that the training was effective?
S ecific Issue
Emer enc 0 eratin Procedures:
64.
Please describe how the Restart Action Plan addresses the following concerns:
65.
Inspection Report Findings 50-220/88-22-06 and the portion of 88-22-08, item 8, regarding instructor training, do not appear to be adequately addressed in Specific Issue 3.
Corrective action 3.D. 1 seems to say "operations line management" is responsible.
Corrective action 3.C.2 says "operations superintendent" is responsible.
Which is correct?
66.
Regarding verification action 3.C.4. 1, should training department supervisors also be interviewed?
69.
70.
Regarding corrective action 3.E.6, which items will not be completed prior to restart?
Why is that acceptable?
Regarding 'verification action 3.E. 1. 1, why limit the review to only a ~one)
EOP?
Is this a typographical error?
Regarding verification action 3.E.2. 1, why not check a number of procedure changes to confirm that the applicable EOP's were not affected or, if they were, that EOP's were appropriately changed.
Root chuse 3F is not used to address any of the sub-elements (1, 2 or 3)
of Specific Issue No. 3.
Identify the applicability of Root Cause 3.F
~
71.
Regarding root cause 3F and actions 3.F. 1, 3.F. 1. 1, what procedural requirements are referred to here?
S ecific Issue 4 Inservice Ins ection:
72.
The issue description addresses that 1) Engineering, gA, and the ISI group did not recognize that undispositioned DCA's affected component operability and failed to report these conditions to operations management.
How is this problem being corrected?
Also have all missing (or otherwise improper) examinations in the ISI program been reported to the NRC in LER 88-01 or a supplement?
Regarding long term strategies why is oversight of contractors not a
short term item?
74.
In sub-element 4. 1 reference to root cause 4.B suggests that the lack of management oversight was manifested only by failure to adequately assess resources.
Was this the only manifestation of lack of oversight?
75.
Corrective Actions 4.A. 1 and 4.A.4 discuss procedure revisions and personnel retraining.
Explain why the verification actions include verifying that the procedures are revised, but do not include verifying retraining is completed.
Corrective Action 4.A.6 discusses the performance of a maintenance walkdown of large bore safety-related piping system. not included in the ISI Program.
What is the specific purpose of these walkdowns?
Regarding verification action 4.A. 1. 1, why is it limited to NCRs issued during outage?
S ecific Issue
Control of Commercial Grade Items".
78.
Were all purchase orders reviewed for safety-related and commercial grade items back to 1985, or just a
sample":
If just a,sample, justify.
What other documents were reviewed for each piece of equipment to determine what items needed to be re-evaluated?
Regarding items procured prior to August 1985, what was done on those items; where recorded; what were the results?
80.
Regarding long-term strategies C.2 and C.4, what will be the schedule to complete these items.
How can the commercial grade process proceed without the required training prior to restart?
81.
None of the three corrective actions described in Table 5 address procedure changes or training:
Does this imply that current procedures and training for the control of commercial grade items are satisfactory?
Explain.
82.
Regarding corrective action 5.A. 1, what will be done to assure that potentially inadequate parts are not installed in the plant?
S ecific issue
Fire Barrier Penetration:
83.
84.
Long-term strategies indicate that the Fire Department's surveillance test is being revised.
Why is this not done prior to startup?
Root causes 6.A thru 6.K do not address the "root" cause.
Please explain.
85.
Regarding root cause 6.D, what is the commitment mentioned?
Regarding verification actions 6.B.3.1 and 6.C.1
~ 1, shouldn't verifica-tions include inspection of work completed to assure that the work was done satisfactorily as well as assuring that the paperwork is proper?
87.
Regarding corrective action 6.B.5, please explain the "confidence level" being achieved during destructive examinations on the penetrations and the justification for this level.
88.
Regarding verification actions 6.E.1.1 and 6.I.1.1, shouldn't proper procedure use be verifi ed?
S ecific Issue
Torus Wall Thinnin
8 What are the long-term plans for preventing corrosion of the torus wall beyond one cycle?
90.
Table 7 of the plan indicates the root cause of this issue was failure to resolve the NRC inspector's concerns before they left the site.
This is not a valid assessment.
Inadequate technical review and possible understaffing are contributors; although, management's approach of determining how much more corrosion allowance can be used up, rather than trying to preserve as much margin as possible, is probably the largest contributor to this problem.
Please address these concerns.
S ecific Issue
A endix J Testin of Emer enc Condenser and Shutdown Coolin Valves:
Changes to Technical Specifications that involve Appendix J testing requirements are not "administrative" and would be expected to affect plant operations.
This item should be clarified.
Discussion of this open item is incomplete.
Refer to NRC letter dated 11/15/88.
~
S ecific Issue
Erosion/Corrosion Pro ram 93.
The licensee's proposed corrective actions appear to adequately address the issue; however, it should be noted that problem in the erosion-corrosion procedures and data acquisition process still existed during the December 1988 NRC inspection in this area.
(See Inspection Report 88-81).
Please address these concerns.
S ecific Issue
MG Set Batter Char ers 94.
95'.
What was the basis for originally changing the battery chargers to non-safety related?
Provide details of your close out of this issue for NRC review.
96.
Regarding corrective actions 12.A.2 and verification action.12.A.2.1, who are the "involved personnel" ?
What is the Niagara Mohawk corporate's understanding of "Safety-related" ?
Is an overall review of the g list for completeness and accuracy needed?
97 Regarding corrective action 12.A.4, provide details of dedication plans for the MiG set battery chargers.
S ecific Issue
Im lementation of IKC Technician's Alle ation 98.
Regarding corrective action objective 2. 1. 1, what is the Niagara Mohawk corporate policy on how employee's concern and problems are identified and brought to management attention, evaluated and acted upon?
S ecific Issue
SSFI:
99.
Regarding corrective action item 14.A.4, for what purpose will the
"one-time test of each core spray system" be run?
100 101:
Corrective action 14.A.7 states "...... to prevent annunciation and.....".
Why 0revent annunciation?
Under what conditions?
Clarify what are the corrective actions for sub-elements of item 14 102.
103.
Regarding corrective action 14.A. 11, are not different graphs needed for flow in the common discharge line.
(Rather than relabeling existing graphs)?
Regarding corrective action 14.A.
14, what else will be done in addition to evaluating
"system" capabilities?
Is this a reference to the system discussed in 14.14?
104 General The corrective action(s) applicable to each sub-element should be explicitly stated, e
~ g. does 14.A.14 apply to 14.14?
14.A.18 to 14.18?
Please explain.
105.
Regarding corrective action 14.B. 1, justification should be provided for any vendor recommended maintenance activity not included in Niagara Mohawk Procedures.
106.
Regarding root cause 14.0 and subelement 14. 18, it is not clear how
"audits/evaluation lacked technical depth" caused excessive use of furmanite as discussed in 14. 18.
107.
Please review and clarify how the specific actions address each sub-element (problem)
and root cause.
Three items from the SSFI "quick look" letter were missing from the list.
The missing items may not need to be resolved before restart, but they should be evaluated and addressed.
S ecific Issue
Cracks in Walls and Floors:
108.
The licensee's proposed corrective actions appear to adequately address the specific conditions identified.
However, does a licensee program for
continued periodic monitoring of the condition of masonry and concrete structures exist or will one be implemented?
109.
Regarding root cause 15.B, what is the basis for speculation that the source of the water is the spent fuel pool?
What is the basis for the conclusion that the cracks are not the result of overstress?
What is the cause?
110.
Regarding corrective action 15.C. 1, on what basis has Niagara Mohawk concluded that no corrective action is required?
S ecific Issue
Feedwater Nozzles:
The licensee's proposed corrective actions address the specific items identified but not the root cause of the problem which appears to be poor oversight of contractor activities.
The proposed actions don'
appear adequate to prevent similar problem in the future.
S ecific Issue
IST:
112.
Sub-element 17. 1 states that the IST Program does not include all ASME Class 1, 2, and 3 (safety-related)
pumps and valves.
Corrective Action 17.A. 1 states that NMPC will finalize and implement the 2nd Interval IST Program.
Con'firm that Corrective Action 17.A. 1 means that the 2nd Interval IST Program will include all ASME Class 1, 2, and
(safety-related)
pumps and valves.
What will be tested prior to restart?
113.
NMPC recently reported that the IST program only included about 50io of required components.
Explain the basis for plans to request "interim relief" from the NRC.
Why should missed safety related components not be tested before startup?
S ecific Issue
125V DC S stem Concerns:
114.
The long-term strategy states that several enhancements to the 125 VDC system have been identified and that reviews are expected to be completed within a year after restart.
Regarding'he long-term strategies, when will the decision on priority and resource assignments be made.
If some modifications are needed to assure safety they should be done prior to startup.
Clarify that prior to restart, the 125 VDC system will meet its design and functional operability requirements.
115.
Regarding corrective action 18.A.2, why should Niagara Mohawk not complete the modification and perform tests to verify design calculations prior to startup?
A endix C Criteria to determine if an issue is a
re ulator concern:
116.
Immediate safety concerns should not be limited to items a through l.
We note emphasis on "regulatory concern(s)"
and compliance.
The issue should be safet *
Attachment
NRC uestions Concernin Nine Mile Point -Unit
Nuclear Im rovement Pro ram
,
The NIP establishes three priority levels to Program objecti.vps (priority one - items must be completed prior to restart; priority'wo completed near term following restar t; and priority three completed longer term after restart).
Neither the RAP or the NIP adequately defines the criteria for these prioritizations.
Further clarification of these criteria is requested.
Objective 1. 1. 1.A "integrate, align and develop goals, objectives, critical issues, and operating principles from top down to the first line supervisor with action plans developed from bottom up.
Provide linkage between the organization goals and individual performance expectations" is assigned priority (2).
Provide the basis for not making this objective a priority (1).
Objective 1.1.7 - "Develop Nuclear Division policy on developing procedures including: (sub-steps 1 through 6)" is a "non-regulatory" objective, but appears to be fundamental to improving performance in
"regulatory" areas.
Clarify and justify the classifications and prioritizations.
V Critical Issue 2.1 - "Develop and implement an integrated and consistent problem solving process by which issues are effectively identified and analyzed, and corrective actions are implemented and assessed in a timely way," does not have a specific objective which addresses
"assess(ment)
in a timely way."
Please explain.
Objectives 3. 1.8 and 3. 1.8.A, and their respective priorities appear to be in conflict.
Explain why critical training needs of Engineering personnel are "non-regulatory" priority (1) and "regulatory" training needs are priority (3).
Objective 4. 1.3 - "Establish performance expectations and define responsibility for contractor oversight, administratively and technically."
Explain why this is a priority (2) vice priority (1) item, in light of the current outage efforts and past problems with contractor oversight.
Objective 4.2. 1 - "Develop and implement a comprehensive self-assessment program to determine readiness for restart" is a priority (1); however, objectives 4.2.2, 4.2.3 and 4.2.4 are priority (2) and appear essential elements/prerequisites to a comprehensive self-assessment.
Explain reasoning for this prioritization.
Long Term Strategies for RAP Underlying Root Cause 5 addresses the performance of a followup assessment of these activities.
The inspectors could not find a corresponding NIP objective for this long-term ite Identify or explain how this long-term strategy is accomplished per the NIP.
9.
Objective 6. 1.3 - "Continue with corporate research and development program to improve the man-machine interface."
Provide the basis for this objective and specific NMPC objective(s)
in this regard.