IR 05000220/1989026
| ML17056A475 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 11/22/1989 |
| From: | Meyer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A474 | List: |
| References | |
| 50-220-89-26, NUDOCS 8912080131 | |
| Download: ML17056A475 (48) | |
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.:
50-220/89-26 Licensee:
Niagara Mohawk Power Corporation 301 Plainfield Road Syracuse, New York 13212 Facility:
=
Nine Mile Point, Unit
Location:
Scriba, New York Dates:
September 25-29, 1989 Inspectors:
T. Johnson, Senior Resident Inspector, Peach Bottom M. Cook, Senior Resident Inspector, Nine Mile Point Approved By:
L. Plisco, Seni r A istant to the Deputy Director, NRR
/-zz-enn M. Meyer, Chief date Reactor Projects Sectio o.
1B Division of Reactor Projects Summar of Results:
The special team inspection of the Readiness for Restart Report and the Niagara Mohawk self-assessment on which the report was based concluded that the self-assessment was thorough and effective.
However, the team expressed concern to Niagara Mohawk management regarding whether the facility was ready for the planned NRC integrated assessment team inspection ( IATI) due to Niagara Mohawk identified issues and the amount of remaining work prior to restart.
An Executive Summary is provided in Section A.
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TABLE OF CONTENTS A.
Executive Summary...
Pacae B.
Background.
C.
Purpose D.
Self-Assessment Process...................
E.
Specific Area Review
1.
Underlying Root= Cause 1 - Planning 5 Goal Setting.
2.
Underlying Root Cause 2 - Problem Solving.........
3.
Underlying Root Cause 3 - Organizational Culture.......
4.
Underlying Root Cause 4 - Standards of Performance and Self-Assessment.................
5.
Underlying Root Cause 5 - Teamwork...
6.
Specific Issues 2 & 3 - Operator Licenses
EOPs..
7.
Specific Issues
8 14 - Fire Barrier Penetrations and SSFI.
12
8.
Specific Issue
Inservice Testing..................
9.
Specific Issue 18 - 125 VDC.............
10.
NRC Restart Criteria.
17
F.
Overall Conclusions.................
~.......................
Attachment
Persons Contacted Attachment
Documents Reviewed
A.
EXECUTIVE SUMMARY A special team inspection 'reviewed Niagara Mohawk's readiness
'assessment process. to evaluate its effectiveness and thoroughness.
The team reviewed specific areas of the assessment and found evidence of thorough assess-ments.
The team concluded that the Niagara Mohawk assessment process was comprehensive, thorough, and effective.
The effectiveness of field imple-mentation of corrective actions was planned to be assessed during the subsequent NRC integrated assessment team inspection (IATI).
The team identified the following assessment strengths and weakness.
~Stree the l.
Effective involvement of and interactions among line management, assessors and panel members (Section 0).
2.
Development of detailed assessment plans (including criteria) by each area assessor including the ability to modify these plans (Section D).
3.
Effective us; of performance based data collection techniques such as interviews, observations, meeting attendance and document reviews (Section D).
4.
Independence and qualifications of the assessors, the staff director, the area coordinators and panel members (Section D).
5.
Recognition by senior management of the need for the Independent Assessment Group (IAG) (section E.4).
Weakness 1.
Limited depth of assessment in the areas of quality assurance (gA)
and oversight review committees (Section D).
Also, the team concluded that the Restart Readiness Report did not totally reflect the extensive depth of the assessment process, which became evi-dent only after the team's interviews and review of backup material.
(Section 0).
The team noted that many of the corrective actions resulting from the Restart Action Plan (RAP) appeared to have been newly installed.
Accord-ingly, the team could not assess the effectiveness of such actions.
This was particularly true in the underlying root causes (URCs)
of problem solving and standards of performance/self-assessmen :
Further, there were numerous open issues identified by the self-assessment process whose associated root cause(s)
and related corrective action(s)
may not be bound by the 'Restart'Action Plan (RAP) or the Restart Readiness Report (Section E).
Examples included:
( 1)
125 VDC resolution and root cause analysis (Sections E.2, E.9),
(2)
1981 radwaste spill cleanup and root cause analysis (Section E.2),
(3) Unit
operator requalification program failures (root cause and effect on management issues)
(Section E.6),
and (4) configuration control/design bases (Sections E.7-E.9).
Any problems in implementing the corrective actions effectively and the resolution of these open issues could potentially affect the. restart schedule.
Based on thi s and the large amount of work remaining prior to restart, the team expressed concern to Niagara Mohawk management regarding the readiness of the facility for. the NRC IATI, planned for October 4-20, 1989.
B.
BACKGROUND In December 1987 Nine Mile Point Unit
(NMP-1) was shut down following excessive vibration in the feedwater system.
During the shutdown, Niagara Mohawk Power Company (Niagara Mohawk)
committed to resolve identified problems associated with the Inservice Inspection Program.
In the course of the outage, additional technical and programmatic deficiencies were identified by Niagara Mohawk and the Nuclear Regulatory Commission (NRC).
These deficiencies led to the issuance of Confirmatory Action Letter (CAL)
88-17, dated July 24, 1988.
The CAL specified that NMP-1 would not be restarted until'he root causes were determined of why Niagar'a Mohawk management had not been effective, a restart action plan had been submit-ted addressing the corrective.actions for the root causes, and a written report had been provided on the readiness of NMP-1 to restart, including a
self-assessment of 'the restart action plan.
Niagara Mohawk formed a
special task force to prepare a
comprehensive Restart Action Plan (RAP),
which was submitted to the NRC on December 21, 1988.
The RAP identified five underlying root causes (URCs)
for the management effectiveness problems and eighteen specific issues.
The plan described the identified problems, their root causes, and the planned corrective actions.
'
While the Restart Action Plan corrective actions were being implemented, Niagara Mohawk assembled the Restart Review Panel (the panel) to perform the required restart readiness self-assessment and to prepare
,a report pres'enting the results of that self-assessment.
The resulting Restart Readiness Report represented a comprehensive evaluation of the corrective actions in the RAP and was submitted on September 8,
1989.
The report stated that NMP-1 could be safely restarted and operated, subject to com-pletion of certain corrective action An NRC special team inspection of Niagara Mohawk's restart readiness assessment process and the basis for their conclusions was conducted at the NMP-1 site during the period of September 25-29, 1989.
The special inspection team (the team)
was composed of two Senior Resident Inspectors from Region I and a
Special Assistant from Nuclear Reactor Regulation.
This inspection report documents the results of the team inspection.
C.
PURPOSE The purpose of this inspection was to evaluate the thoroughness and effec-tiveness of Niagara Mohawk's readiness assessment as documented in the September 1989 Restart Readiness Report.
To evaluate the readiness assessment process, the team reviewed all five URCs and selected six of
~the eighteen specific issues to review in detail.
This detailed review involved the examination of the assessment conclusions and recommenda-tions, supporting information and data, and interviews with members of the Restart Review Panel, assessors and line management.
Further, the team evaluated Niagara Mohawk's progress toward restart, both in terms of completing work needed prior to restart and of developing its ability to self-identify and effectively correct problems, to determine whether the NRC integrated assessment team inspection ( IATI) scheduled for October 1989 remained appropriate.
The overall effectiveness of the field implementation of the RAP was planned to be assessed during the IATI.
Accordingly, the team did not review the technical adequacy nor the effec-tiveness of corrective actions.
D.
SELF-ASSESSMENT PROCESS 1.
Nia ara Mohawk Process The principal elements of Niagara Mohawk's self-assessment were the Restart Review Panel, supported by a staff consisting of a staff director, assessment ar ea coordinators, area assessors and inter-viewers.
In addition, specific line managers were assigned respon-sibilityy for specific tasks.
The panel consisted of three Niagara Mohawk individuals and three non-Niagara Mohawk individuals.
The panel's
" experience was broadly based including:
Niagara Mohawk Executive Vice President Nuclear Operations, Niagara Mohawk Vice President Consumer Services, Niagara Mohawk Vice President gA, Illinois Power Company Senior Vice President, Rochester Gas and Electric President, and a consultan The panel focused the self-assessment process on determining the effectiveness of the Restart Action Plan (RAP) corrective actions by developing a set of bases for assessing restart readiness.
Together these bases described the conditions expected prior to the plant restarting.
The panel viewed the bases as positive descriptions of conditions which would support safe nuclear plant operation, in con-trast to the negatively stated deficiencies identified in the RAP.
For each of these bases, one or more targets were developed to act as measuring criteria. 'ogether, the bases and targets provided a
results-oriented method to measure the effectiveness of the correc-tive actions.
The self-assessment process involved gathering, analyzing, and synthesizing facts to determine the adequacy of corrective actions.
The self-assessment utilized interviews, documentation audits, per-formance reviews, and direct observations throughout the plant, Training Center and other nuclear related facilities.
Niagara Mohawk reviewed and assessed three primary areas composed of the five underlying root causes (URCs),
the 18 specific issues, and five NRC generic restart criteria'ach of the areas reviewed had a
principal assessor,'
task sponsor, and a 'designated panel member, who acted as an advisor.
The effort was supported by a staff director, three primary area coordinators, and interview and assess-ment personnel.
- The panel advisors met with the area assessors, coordinators and task sponsors numerous times.
The panel met approx-imately on a monthly basis from April to September 1989.
Following identification of all of the issues requiring corrective action, the actions required to be closed prior to restart were defined.
All of the required actions, if not complete, were evalu-ated to ensure a plan was in place to correct the item and was being tracked by a
formal mechanism.
Many of the long term issues were included in the Nuclear Improvement Program.
Acceptance of delaying improvements until after restart was contingent
'upon having interim.
controls in place before restart.
NRC Review and Conclusions The team reviewed the Niagara Mohawk self-assessment process as follows:
Reviewed the Restart Readiness Report Reviewed backup documentation (see Attachment 2), including area final assessment reports Interviewed each panel member (in person or by phone)
Interviewed the staff director, each area coordinator and selected area assessors and task sponsors (see Attachment 1)
)
The team noted that each assessor developed detailed assessment plans in order to validate the bases and targets.
Each assessor worked closely with his panel advisor, and the assessment plans were mod-ified as necessary.
The plans and modifications are further dis-cussed in the specific area reviews of thi s report (Section E).
The tea'm concluded that the assessment plans represented a strength of the assessment.
The team reviewed the qualifications, experience and independence of the assessors, panel members, area coordinators and staff director.
The panel composition included a mix of well qualified Niagara Mohawk and non-Niagara Mohawk'ersonnel.
The assessors and area coordina-tors were also noted to be well qualified, and most were independent.
The team concluded that the independence and qualifications of the assessment personnel represented a strength of the assessment.
Based on interviews and document review, the team concluded that there was effective interaction among the panel members, assessors and task sponsors/line management.
The interactions are further dis-cussed in the specific area reviews of this report (Section E).
The team concluded that the interactions among assessment personnel represented a strength of the assessment.
Niagara Mohawk utilized independent interviewers to provide feedback to the assessors for each area.
The assessors and the panel members also interviewed personnel, attended meetings, observed activities and reviewed documentation.
The effective use of such performance based data collection techniques, independent of the line organiza-tion, was considered a strength.
The quality assurance (gA) organization was utilized in data collec-tion and the Niagara Mohawk Vice President gA was a member of the panel.
However, the gA function was not specifically assessed by the panel.
Also, oversight review committees (e.g.,
Station Operations Review Committee, Safety Review and Audit Board)
were used as a tool for the process, but they were not themselves directly assessed.
The team concluded that limited assessment of both the gA functions and oversight review committees was a
weakness of the self-assessment process.
The team was unable to fully understand the entire self-assessment process by reviewing the Restart Readiness Report.
Only after reviewing the backup documentation, primarily the final assessment reports for each area, and by interviewing the personnel involved in the process, was the team able to assess the process.
In summary, the Restart Readiness Report did not totally reflect the extensive depth of the assessment proces E.
SPECIFIC AREA REVIEW l.
Under 1 in Root Cause 1 Pl annin and Goal Settin The RAP determined that
"the management tasks of planning and goal setting have not kept pace with the changing needs of the Nuclear Oivision and with changes within the nuclear industry."
Nia ara Mohawk Review The principal assessor for this area met with the area coordi-nator, panel advisor and task manager/sponsor.
Oiscrete bases and targets were developed to ensure that the root cause had been a'ddressed and to measure the effectiveness of corrective actions.
This detailed assessment plan was then reviewed by and modified as necessary during panel meetings.
Verification actions included interviews with personnel, at.end-ance at meetings, surveys of managers and direct reports, and review of documentation.
The assessor concluded that the tar-gets were either completely met or adequate progress had been made.
Ouring the first and second panel meetings, progress was noted as being slow in meeting the targets for this URC.
How-ever, at. the final panel meetings, the assessor concluded that a
business plan was in place; printouts were established; a
~
nuclear vision, mission and goals were developed and communi-cated to the organization; management was setting a good example through leadership; and,a nuclear commitment tracking system and integrated priority system were part of the long range Nuclear Improvement Program.
Three open items for this URC were iden-tified.
These dealt with a
process for. notification of a
commitment prior to its due date, and approval and training for the integrated priority system and implementing procedures.
1.2 Niagara Mohawk concluded that the restart basis had been met by reviewing the status and progress of each target.
In particular, management had adequately communicated vision and mission goal statements, senior management had reinforced performance stand-ards for the individual, and adequate progress had been achieved towards an integrated priority system.
NRC Conclusion The assessment process for this URC appeared to be thorough.
There was effective interaction among the task manager, assessor and panel advisor.
The team interviewed the assessor in this area.
Although progress had initially been slow, Niagara Mohawk
appear'ed to have recognized this, and had taken additional and stronger actions to ensure management and personnel were making progress.
Overall, Niagara Mohawk conducted a
comprehensive
'eview of this area and provided reasonable assurance that 'the root cause was addressed.
2.
Underl in Root Cause
Problem Solvin The RAP determined that
"the process of identifying and resolving issues before they become regulatory concerns was less than adequate in that there was not an integrated or consistent process used to identify, analyze, correct, and assess problems in a timely way."
2. 1 Nia ara Mohawk Review To address this URC and provide the organization with a target for resolving the consequences of the root cause, Niagara Mohawk established a corrective action objective.
The objective was to develop and implement an integrated and con'sistent problem solving process by which issues are effectively identified and analyzed, and corrective actions are implemen'ed and assured in a timely way.
In order to assess the viability of the problem solving process, certain targets were established to measure whether the corrective action objective had been met.
The principle assessor for this issue developed a detailed assess-ment plan, clearly defining the approach to assess each of the specific targets.
The assessment consisted of documentation reviews, interviews, audits and observations of activities.
The assessment focused on the identification and determination of root cause, prioritization, implementation and assessment of effectiveness.
Early in the assessment, the assessor determined that the corrective action end of the problem solving process was not effective.
The assessor found that the principle deficiencies were:
I) an inability to prioritize a broad range of problems; and 2)
an inability to fully implement the resolu-tion of a problem.
During the'reliminary assessment, the assessor noted that the corrective actions established for the RAP provided for a
com-prehensive identification of past and current problems, but these corrective actions did not adequately specify the process by which issues are effectively analyzed and corrective actions are implemented and assessed in a
timely way.
In response, additional targets were formulated to provide assurance that the objective would be fully and effectively met.
The preliminary assessment also found that the Independent Assessment Group (IAG) charter did not indicate a
focused emphasis on problem solving.
The final IAG charter was revised to explicitly iden-tify that problem
. solvin'g was a
target of the evaluation proces Later in the assessment process, the panel discussed two issues which were added as open items.
At the September 1,
1989 panel meeting, there was a
discussion of the radwaste spill which occurred in 1981.
The panel determined that management atten-tion should have been immediately focused on the problem to expedite the cleanup.
Following the discussion, the panel directed the line organization to perform a root cause analysis prior to restart of why the spill was not cleaned up expedi-tiously.
The panel also discussed Specific Issue 18, which had experienced delays in completing corrective action milestones, and directed that a root cause analysis be performed to deter-mine why the issue had not been closed earlier.
Niagara Mohawk stated that the resulting root causes would be checked to con-firm that they were covered by the remedial action already underway.
Niagara Mohawk determined that the results of the assessment indicated that past and currert performance limiting deficien-cies had been identified and were being resolved through self-assessment of past performance and implementation of appropriate corrective actions.
The asses;ment concluded that substantial progress had been made relative to problem solving.
The final assessment found that certain enhancements were still.in the early stages, but the problem solving process had developed enough to meet the intent of the targets, and therefore, sup-ported restart of Unit 1.
2.2 NRC Conclusion The assessment process for this URC included interaction between the task manager, principle assessor, and panel advisor.
There was evidence of probing questions from the panel advisor and assessor and of the addition, of issues to the open items, indi-cating a
thorough assessment of the problem areas.
The review was of broad scope and was not limited to the.specific correc-tive actions in the Restart Action Plan.
A large number of individual systems for identification and tracking of problems remained.
Niagara Mohawk was making efforts to integrate the systems in order to provide the hier-archy to accommodate lower tier department level procedures and to provide for evaluation of deficiencie Actions were, initiated to provide a
uniform prioritization process and to establish a mechanism for assuring that problems were fully and effectively resolved.
These activities included an integrated priority system and classification of responsi-bilitiess for resolving problems.
These activities represented a
significant enhancement in the tools available for problem solving, but were predicated on effective implementation of the initiatives in place.
Niagara Mohawk conducted a comprehensive review of the problem solving process and provided reasonable evidence and assurance that 'these issues were appropriately addressed.
,However, many of the. corrective actions had been only recently implemented, or deferred into the Nuclear Improvement Program, and the effec-tiveness of the upgraded program had not been assessed.
The IAG appeared capable of performing an important role in continuing to assess the implementation of this program.
The team was concerned that two open items which involved the performance of root cause analyses could potentially exceed the scope of the five URCs
~
Since the analyses had not been com-pleted, it could not be verified that the causes of the two
'events were bounded by the actions already taken in the RAP.
3.
Underl in Root Cause
Or anizational Culture The RAP determined that
"management's technical focus has created an organizational culture that diverts attention away from the needs and effective use of employees."
3.1 Nia ara Mohawk Review The principal assessor for this area met with the area coordi-nator, panel advisor and the task manager/sponsor.
Discrete bases and targets were developed to measure the effectiveness of corr'ective actions.
A detailed assessment plan was
'then pre-sented to the panel.
The assessment process included interviews with personnel, and attendance at town hall and employee meetings.
Employee feed-back on the RAP was initiated.
Managers'kills in the area of personnel practices were assessed and determined to be satis-factory.
Communication skills and conflict resolution were noted as showing improvements.
Team building and, coaching skills were noted as being improve Niagara Mohawk concluded, that the restart basis and targets were met.
There were significant actions taken'bserved behavior demonstrated a positive change in culture.
A
"Management By Walking Around" program was being advocated from senior manage-ment.
Self-assessment=was accepted and practiced throughout the organization.
The communication process had improvements up and down the chain of command.
3.2 NRC Conclusions The assessment process for this URC appeared to be thorough and adequate.
The team interviewed the assessor, task sponsor and panel members.
All individuals, noted an improvement in organ-izational culture as reflected by a
change in behavior by the entire organization.
Overall, Niagara Mohawk appeared to ade-quately assess this area.
Underl in Root Cause 4 - Standards of Performance and Self-Assessment The RAP determined that
"standards of performance have not been defined or described sufficiently for effective assessment and that self-assessments have not been consistent or effective."
4.1 Nia ara Mohawk Review The standards of performance were established earlier this year and published for broad dissemination to all Nuclear Division personnel.
The assessors for this URC determined early in the self-assessment that the Division's chain of command was not fully embracing the standards and were neither communicating nor overtly incorporating these standards into their day-to-day routines.
Towards the end of the self-assessment process, the assessors were observing m'ny examples of management modeling the standards of performance and workers challenging their supervisors on their implementation of these standards.
The level of awareness of the standards was determined to be much higher via interviews performed later in the self-assessment process.
Similarly, the a'ssessors found that in the early phases of the assessment, the majority of Nuclear Division personnel were not utilizing the self-assessment processes.
These findings were di scussed at "the June and July Restart Review Panel meetings and at subsequent Executive Vice President's direct report meeting In later phases of the assessment, the assessors and panel members identified improvement in this URC.
However, to ensure continued progress in this area the Chairman called for.the formation of the Independent Assessment Group (IAG).
The pur-pose of the IAG was to act as a catalyst to incorporate self-assessment into Nuclear Division daily routines, and to monitor the effectiveness of the same thorough independent assessments
~-
4.2 NRC Conclusion Niagara Mohawk's assessment of the effectiveness of their cor-rective actions and progress in the resolution of this URC was thorough.
Interviews with the assessors and panel members sup-ported the conclusion that these URC corrective actions have been slow in being implemented and integrated into the daily work practices.
The progress in achieving any success in this area has come at the prompting of the panel and self-assessment team.
This was further evidenced by the development of the IAG, which appeared capable of emphasizing the need for continuous self-assessment and, for a certain period of time, formalizing.
that process.
The team concluded that senior management's recognition of the need for the IAG represented a
strength of the assessment process.'n summary, Niagara mohawk conducted a
thorough assessment of this URC and has taken measures to reasonably ensure a lasting change in the overall performance standards and self-assessment abilities of the Nuclear Division.
5.
Underl in Root Cause 5 - Teamwork The RAP determined that
"lack of effective teamwork within the Nuclear Division and with support organizations is evidenced by the lack of coordination, cooperation,
'and communication in carrying out responsibilities."
5. 1 Nia ara Mohawk Review The assessors and panel members identified significant progress towards teamwork.
This was evidenced by individuals and groups observed to be effectively working together to make decisions and solve problem I Assessment team interviews 'demonstrated that Nuclear Division employees were aware that effective coordination, communication and cooperation are essential to meet the Nuclear Division visions and goals.
Virtually every interviewee reported that teamwork had improved during the past year.
Although progress had been observed, additional enhancement was needed in the area of timely feedback, especially at the supervisor/worker. level.
5.2 NRC Conclusion The assessment process for this URC appeared to be thorough.
The team determined that the assessor, task manager and panel advisor worked closely together to evaluate and accurately assess the progress in this area.
Based on review of the backup material, preliminary, interim and final assessments, and an interview with the task manager and assessor, the team concluded that Niagara Mohawk had exhibited continuous progress throughout the self-assessment process.
The Integrated Team, consisting of middle managers, and Operations Training Program Advisory Committee (OTPAC),
consisting
. of operators and trainers, modeled, early on, the teamwork standards desired in the entire Division.
The senior management team was observed to be slower to improve their team building abilities.
In summary, Niagara Mohawk conducted a comprehensive assessment.
of this URC with numerous observations to support their final conclusion that.this area was satisfactory for unit restart.
6.
.S ecific Issues 2 and 3 - 0 erator Licenses and Emer enc 0 eratin The RAP determined that operator licenses were not maintained in accordance with regulations and that implementation of EOPs in response to events was less than adequate'.
Nia ara Mohawk Review The principal assessor met with the area advisor and the task sponsor/manager.
targets were established and accepted detailed assessment plan was modified implemented.
coordinator, the panel Discrete, measurable by the panel.
This as required and then
Verification actions included direct observation in the control room, training classes, simulator evolutions, and operator/
training meetings; interviews with operators, training personnel and operations/training management; reviewing revised adminis-trative procedures and EOPs; verifying training records, includ-ing instructor qualifications; and verifying that processes were in place to prevent recurrence.
6.2 Niagara Mohawk -concluded that there was assurance that operators have demonstrated a
professional attitude in identifying and resolving concerns associated with maintaining their licenses, and they understand and accept rising performance expectations.
The conflict between operations and training personnel has been resolved.
Niagara Mohawk also concluded that results are suf-ficient to provide assurance to management that EOP issues related to operator training and qualification, procedures and processes, and hardware deficiencies will not have an adverse effect on safe plant operation.
NRC Conclusion The assessment process for these specific issues appeared to be thorough.
The team interviewed the assessor, the task sponsor and the panel advisor.
The assessor's qualifications included previous operations management experience and a
senior reactor operator (SRO)
license.
The assessor verified operations man-agement ownership of these two issues.
The team noted that the assessor used various performance based techniques to arrive at his conclusion.
The team questioned why the 'Unit
operator requalification failures were not reflected in the Unit 1 oper-ator assessment.
The assessor stated that the final assessment reports for these two issues did address this concern; however, the Restart Readiness Report did not address this issue.
This was another example where'he report did not reflect the depth of the assessment.
Also, a root cause analysis for these Unit
failures was still in progress.
Any root causes and corrective actions may not be bound by the URCs in the RAP.
This appeared to,be a
potential problem regarding Niagara Mohawk restart schedules and the planned NRC IATI.
7.
S ecific Issue 6 - Fire Barrier Penetrations and S ecific Issue 14-Safet S stem Functional Ins ection While installing a modification in March 1988, a wooden plug was dis-covered in a fire barrier under the Unit 1 battery rooms.
Further investigations identified additional fire barrier penetrations that deviated from the design requirements.
In some cases the material used to fill the penetrations was inadequate, and in other cases the
design of the penetration itself was either inadequate or untested.
In September 1988, an NRC Safety System Functional Inspection (SSFI)
was conducted at Unit 1.
This inspection identified 'deficiencies in the Core Spray System.
Both of these specific issues involved com-plex design bases issues.
7.1 Nia ara Mohawk Review The principal assessor for these issues developed detailed assessment plans, following review of the applicable documenta-tion and commitments.
The corrective actions and verification actions were broken into discrete elements in the plans and were clearly defined.
Tge assessor identified several commitments which were not specifically included in the Restart Action Plan and additional verification actions to further define the ade-quacy of the verification actions.
The plans were further modified to ens'ure that the established restart readiness tar-gets were met.
The assessor reviewed the plans and targets with the task managers and met with those assigned verification actions to ensure the expected conditions were understood by the verifiers.
The assessor had discussi ns with the lead panel members for the issues, as well as the Restart Review Panel.
Comments from the panel members were included in the assessment plans.
For the fire barrier penetration issue, the assessment included review of the walkdown specification, work packages, computer data bases, drawings, and procedures.
The assessment process included interviews with individuals involved with fire protec-tion to determine if additional problems existed.
The results of the interviews were reviewed by the assessor and several additional issues were identified for followup.
In addition, problem reports were reviewed, gA involvement was assessed, and a Safety Review and Audit Board audit was reviewed.
During the fire barrier penetration assessment, the assessor determined the need for an independent consultant.
The consultant was used to review the results of the fire barrier walkdowns and to evaluate the adequacy of the issue resolutions.
For the SSFI issues, the assessor reviewed documentation related to the issue and interviewed key individuals involved in the resolution of the issue.
The assessor found the required calcu-lations and analysis completed and adequate to resolve the con-cerns.
Necessary modifications required before restart and set-point changes resulting from the calculations and analysis were
initiated and scheduled to be completed prior to restart.
Pro-cedures and specifications were revised to strengthen the con-trol of design configuration in order to, prevent further deficiencies.
A comprehensive plan for design basis recons'ti-tution was established.
Supplemental reviews were performed by independent parties of the SSFI documentation and the history of the loss of coolant accident (Appendix K) calculations.
During the course of the evaluations, periodic feedback to the task manager was provided concerning findings and results of interviews.
Where appropriate, supervision was made aware of the assessors findings.
The assessment found that the corrective actions for both issues were satisfactory.
All of the findings required for restart were resolved to the point where the assessor was confident that restart would not be affected.
The panel concluded that the effectiveness of the corrective actions in the area supported restart of Unit l.
7.2 NRC Conclusion The assessment process for these issues included interaction between the task manager, principal assessor, and panel advisor.
There was evidence of probing questions from the advisor and assessor and the addition of issues to the open items, indica-ting a thorough, assessment of the problem areas.
The reviews appeared to have a
broad scope, not limited to the specific corrective actions in the RAP.
The use of an independent con-sultant to review and validate conclusions for the fire barrier i ssue was a good initiative of this assessment.
Another strong point noted was the review performed by the assessor of the URCs in this specific area reviews.
For example',
problems were identified with the problem report process, which were properly referred to the appropriate area for follow-up.
Niagara Mohawk conducted a comprehensive review of the fire bar-rier penetration and SSFI issues and provided reasonable evi-dence and assurance that these-issues were appropriately addressed.
However, a
large number of open issues related to these issues remained to be closed prior to restart.
The open items were being tracked adequately by a
formal mechanis.
S eci fic Issue 17 - Inservice Testin Niagara Mohawk implemented the first ten-year interval of the Inser-vice Testing (IST)
Program in December 1979.
In December 1985 a
'evision to the Unit 1 Q-list was made; however, the IST Program was not revised to reflect this Q-list change.
As a result, certain ASME class 1,
2 and 3 safety related pumps and valves were not included in the first ten-year program testing.
Niagara Mohawk decided that rather than correct the deficiencies in the first 10-year program they would -finalize and implement the second 10-year IST program prior to startup from the 1987-1990 refueling outage.
The second 10-year program would correct all of the identified deficiencies of the first 10-year interval and imple-ment the necessary administrative controls to ensure the program remained current and accurate.
8. 1 Nia ara Mohawk Review To review this speci.fic issue (SI)
the assessor developed a
detailed assessment plan which was close',y adhered to throughout
.the self-assessment process.
In addition, the assessor used an experienced engineer who -had been responsible for the Unit
Inservice Testing Program.
This engineer conducted an inde-,
pendent review of the second 10-year interval program.
For further verification, the assessor contracted-Bechtel Corpora-tion to perform a detailed review of the core spray and reactor building closed loop cooling systems to ensure adequate inser-vice testing had been established.
The results of this review indicated no errors by the Niagara Mohawk IST staff.
The assessor met with the primary panel advisor and responsible task managers frequently throughout the self-assessment process.
8.2 NRC Conclusion The team found that Niagara Mohawk conducted a thorough assess-ment of Specific Issue 17.
Interviews with the assessor and primary panel advisor indicated that the five targets identified to assess this issue were comprehensive and sufficient to evalu-ate the corrective actions taken to address the deficiencies previously identified with the Unit 1 IST Program and its imple-mentation.
The team determined that the assessor was planned to be retained to evaluate the adequacy of the resolution of the self-assessment open items for SI-1.
S ecific Issue 18--
125 VDC A December 1987 root cause analysis of a rapid degradation of the 125 VDC batter'ies 011. and 812 revealed the principle cause was the appli-cation of a low float and low equalizing charge since initial instal-lation in 1981.
During the preparation of the
CFR 50.59 review for a proposed resolution of this problem, the Niagara Nohawk staff identified the need for a complete review and verification of the 125 VDC electrical systems design basis.
This design basis reconstitu-tion effort =identified several concerns regarding the ability of the installed batteries to perform their design function and thus, became a specific issue for Unit 1 Restart.
9. 1 Nia ara Mohawk Review As discussed in the Restart Readiness Report, the resolution of Specific Issue 18 (SI-18) was slow and remained to be completed.
As a
result, the Chairman requested the Vice President of Nuclear Engineering and Licensing perform a root cause analysis of why SI-18-had not been closed earlier.
Extensive review.of the Restart Panel's assessment of this SI identified the following:
Although the lack of effective 'action to resolve this SI was representative of many of the URCs identified for cor-rective action by the RAP, the panel concluded that this example was an isolated case and not representative of the overall progress and general improvement made to date.
'I The panel concluded that the reasons for the slow resolu-tion of SI-18 were bound by the URCs and their associated corrective actions.
The Chairman requested the root cause analysis be. performed and to reinforce the lessons learned from this specific management effectiveness concern.
"The panel observed that,'pon recognition of the slow progress in resolving SI-18, Niagara mohawk line management took appropriate corrective action, in their view, to address the immediate concern.
This demonstrated to the panel, to some degree; the effectiveness of the URCs'or-'ective action.2 NRC Conclusions The team concluded that Niagara Mohawk conducted a
thorough assessment of the resolution, or lack thereof, of Specific Issue 18.
The self-assessment process identified the lack of progress being made to appropriately resolve this concern.
The assessor identified several additional action items concerning SI-18 that should be performed prior to restart.
In addition, the assessor identified a long term programmatic enhancement to be incorporated after restart.
The interaction of the assessor, primary panel advisor, and task manager appeared to have been effective in critically assessing the readiness to support restart of this specific issue.
Although characterized as pun-itive action and reinforcement of the lessons learned, the for-mal root cause analysis to be conducted by Nuclear Engineering and Licensing could result in root causes and corrective actions not currently bound by the RAP.
This appeared to be a potenlial problem regarding Niagara Mohawk restart schedules and the planned NRC IATI.
10.
NRC Restart Guide'.ines As part of Niagara Mohawk's overall assessment of Unit 1 Readiness for Restart, the five NRC guidelines for plant restart were con-sidered.
These guidelines were taken from an NRC memorandum,
"Staff Guidelines Concerning Plant Restart Approval" by the Executive Director of Operations to the NRC Office Directors and Regional Administrators, dated November 23, 1988.
These guidelines include the review of:
Restart Plan (root causes identified and corrected);
management organization; plant and corporate staff; physical state of readiness of the plant; and regulatory requirements.
10. 1 Nia ara Mohawk Review Niagara Mohawk took these five areas and formed one readiness for restart basis to judge whether the unit was ready for restart.
This basis was,
"Results of corrective actions and plant improvement activities sufficiently address and satisfy NRC restart guidelines, such that all issues necessary, to sup-port readiness for restart and safe operation have be'en demon-strated and NRC approval for plant restart may be requested.",
Similar to the assessments of the URCs and 18 Specific Issues, Niagara Mohawk established specific targets for the five guide-lines to measure 'rogress and plant readiness.
In addition, task managers/sponsors, assessors and primary panel advisors were assigned for each guideline.
The assessment processes were much the same as the other issue The assessment concluded that in spite of the work still remain-ing to complete the RAP corrective actions, it appeared that the overall program was well con'trolled and processes were in place to sufficiently address each of the NRC restart guidelines.
10.2 NRC Conclusions
=
The assessment by Niagara Mohawk of this area was thorough.
Based upon interviews with the area coordinator and the primary assessor and review of the supporting assessment documentation, the team concluded that this area assessment was effective in identifying some broader programmatic items requiring resolution prior to restart.
The outstanding items are documented in Appendix
to the Restart Readiness Report.
One item with significant impact on the restart schedule is the development of an engineering staff. justification to provide assurance that the as-built design does not conflict with the safety design bases.
The scope of this self-assessment area was broader than the Restart Action Plan corrective actions and appeared to have pro-vided further assurance that the unit will be ready 'for restart, both physically and programmatically.
This initiative appeared to have been a
good second,
.independent check of restart readiness.
F.
OVERALL CONCLUSIONS The team identified noteworthy strengths in the Niagara Mohawk readiness assessment process.
A strength of the approach chosen by Niagara Mohawk was that it required independent assessors to develop bases and targets in their action plans to independently measure corrective action effective-ness.
There was effective interaction between the assessors, line manage-ment, and panel members.
The assessors used performance based criteria in.
finalizing their conclusions.
The assessors, area coordinators, panel and staff director were well qualified with noted independence.
The panel also conducted in-plant visits, personnel interviews or records reviews in the areas considered in order to make their own independent assessment of readiness.
Some reliance was also placed on the quality assurance personnel to fulfill this function.
However, the depth of the assessment in the areas of gA and oversight review committees was limite The NRC team noted that a
number of open issues were identified by the self-assessment process.
The associated root,causes and related correc-tive actions for these open issues may not be bound by the RAP or the Restart Readiness Report.
These items may have an impact on the readiness for Unit I to restart.
The inspection team concluded that the September 8,
1989, report lacked sufficient detail and clarity to support the conclusions made by the assessors, Restart Review Panel and line management.
Based upon further document review and interviews, the team determined that the readiness assessment process was much more detailed and thorough than described by the report.
In summary, based on the specific areas reviewed, the NRC team concluded that Niagara Mohawk had the essential components to self-assess activ-ities.
This was based on reviewing the Restart Readiness Report, asso-ciated final assessment reports, and by interviewing all panel members, all area coordinators, the staff director, and selected area assessors and task sponsors.
The team did not review the technical adequacy nor the effectiveness of corrective action ATTACHMENT I Persons Contacted Panel Members
J.
D.
J.
R.
Ash NMPC VP Consumer Services Hall Illinois Power Company Senior VP Hendrie Consultant Kober Rochester Gas
& Electric President Perry NMPC VP guality Assurance Others
" A.
W.
- R.
- F.
J.
C.
- J D.
- A R.
- J
" W.
" R.
- M.
- D B
- J K.
- Bernat, Manager, Information & Client Services D'Angelo, Manager, Nuclear Consulting Services Halsey, Manager, System Protection Eng Kammerzell, Integrated Management Solutions Lange, Manager, Business Planning
'rizza, Rochester Gas
& Electric Mangan, Sr.
Vice President Nuclear Martore, Tenera Palmer, Manager Non Nu gA Operations Tudury, Management Analysis Company Vollmer, Tenera Zimmerman, Director, Corp.
Performance Services Spadefore, NMPC Drews, NMPC Richards, NMPC Dooley, NMPC Stein, NMPC Colomb, NMPC Wolken, NMPC Burtch, NMPC Terry, NMPC Wi 1 1 i s, NMPC Dahlberg, NMPC Roenick, New York State Public Service Commission
- Present at Entrance/Exit Meetings
~
~
~
'
ATTACHMENT 2 Documents Reviewed Restart Readiness Report, September 1989 SALP Report 220/88-99, 410/88-99, May 22, 1989 Special Team Inspection Report 220/89-200, 410/89-200, May 20, 1989
=Assessment Matrix, Revision 2, September 11, 1989 Status of RAP Corrective Actions, dated September 19, 26, 1989 NRC Restart Guidelines Assessment Handout Final Assessment Reports:
Underlying Root Cause No.
Underlying Root Cause No.
Underlying Root Cause No.
Underlying Root Cause No.
Underlying Root Cause No.
5, August 29, 1989 Specific Issue 2, August 30, 1989 Specific Issue 3, August 30, 1989 Specific Issue 6, August 30, 1989 Specific Iss e 14, August 30, 1989 Specific Issue 17, August 30, 1989
.
Specific Issue 18, August 30, 1989
0