IR 05000220/1989099
| ML20056A890 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 08/01/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A318 | List: |
| References | |
| 50-220-89-99-01, 50-220-89-99-1, 50-410-89-99, NUDOCS 9008090406 | |
| Download: ML20056A890 (64) | |
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, A ENCLOSURE 21 -
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- FINAL SALP REPORT' o , ,J 4,4 ,
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U.S. NUCLEAR REGULATORY COMMISSION- ,
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NIhGARAMOHAWKPOWERCORPORATION j
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' ASSESSMENT PERIOD: ~MARCH 1, 1989.:to FEBRUARY 28,'1990 ;j -.
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i;c 1 SUMMARY OF RESULTS
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II.A Overview Despite good intentions and extensive planning, the progress at Nine Mile Point ;
- Units 1. and 2 .was limited. The nigh standards and corresponding Category I ratings established in the security and emergency preparedness areas were main- l tained, . the Category 2 rating in radiological controls continued, and the !
quality of engineering work improved sufficiently.to merit a Category 2 ratin , However - the efforts to correct programmatic problems in the plant operations -!
.and . maintenance / surveillance areas did not result in sufficient overall improvements in these areas to warrant changes in the previous Category 3 rat-ings. -The inability to improve significantly was further reflected in a repeat .
Category 3 rating with an improving trend in the assurance of quality / safety , , assessment are , In the~ plant operations area, progress was noted; training problems regarding ; Unit 1 licensed operators were resolved, and Unit 2 was continuously operated i for a significant time perio However, the Unit 2 operator requalification training. progr,am was rated = unsatisf actory, and some of the Unit 1 operator ' training' problems found earlier were repeated. Further, at both units the , incidence of personnel errors and poor control of equipment was high and ' resulted in numerous operational event Good progress occurred in the surveillance area. Thorough, extensive reviews of required -testing and procedures formed the basis for better planning and implementation of Technical Specification testing, inservice testing, 'and inservice inspection. However, there was not significant progress in the main-tenance area. -and equipment problems and errors by maintenance personnel fre-quently' resulted in operational events at Unit 1 and reactor scrams, safety system actuations, and unplanned outages at Unit The improved quality of some engineering work appeared to be.a direct result of increased management involvement. However, a. number of examples of ineffective ; engine'ering and technical support were note There was an apparent turning point in Niagara Mohawk's approach to assuring quality. The Restart Action Plan was responsible for the better problem iden-i tification, more critical problem evaluation and self-assessment, and - the establishment of programs and standards to promote and sustain good perform-
, :ance. The approach appeared to have enabled the improved results noted in the i
engineering and surveillance areas and the generally improving direction in l most.other area However, the performance in several areas remained at min-imally acceptable levels, and the challenge for Niagara Mohawk management remains to utilize this better approach to produce improved results on a con-l sistent basis in all aspects of plant operations, s l'
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II' B. Facility ' Performance 'Analysi s' Summary ' ,
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1.ast Perio This Period '
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II.C Unplanned Shutdowns, Plant Trips, and Forced Outages Unit 1 Unit 1 was in an extended shutdown throughout this assessment period. Some reactor protection system (RPS) actuations occurred while the plant was shut-down and are discussed in the Maintenance and Surveillance sectio Unit 2 Loose wires in the main generator potential transformer cubicle actuated a generator protection relay causing a turbine trip and a subsequent automatic reactor scram. Vibration had loosened the screws holding down the wires. The preventive maintenance (PM) instructions for the trans-former were revised to include the screws and wires. The unit was shut-down for five day Date Power Root Cause Functional Area 4/13/89 10G% Inadequate PM Maintenance
.. During a turbine surveillance test, a licensed operator used a walkie-talkie near the electro-hydraulic control (EHC) cabinet and caused inad-vertent turbine control and bypass valve movement. This crected a pres-sure spike which resulted in an automatic reactor scram initiated by a high neutron flux tri The unit remained shutdown for two day Date Power Root Cause Functional Area 4/22/89 100% Personnel error Operations An unexpected downshift of a reactor recirculation pump resulted in reactor operational conditions in the unacceptable area of the power-to-flow map. A manual reactor scram was initiated as specified by the oper-ating procedures. Later evaluation determined that a power supply failure caused the downshift. The unit remained shutdown for 16 days for a sched-uled two week maintenance and surveillance outag Date Power Root Cause Functional Area 9/8/89 88% Random equipment failure NA*
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l An inappropriate isolation during preventive maintenance on the B conden-ser air . removal pump resulted in the loss of condenser vacuum and an automatic reactor scram. The procedure did not caution that an interlock could affect another system, and maintenance personnel did not properly assess the plant impact of the maintenanc Also, operations personnel did not identify the error during their review. The unit remained shut-down for three day Date Power Root Cause Functional Area 10/13/89 54% Procedural deficiency ' Maintenance Niagara Mohawk. initiated a plant shutdown due to increasing drywell floor drain leak rate. Inadequate control of steam loads and feedwater during the shutdown resulted in a core reactivity transient and an auton atic reactor scram caused by an upscale trip of the intermediate range monitors
[14MIT ~The unit remained shutdown for seven day Date Power Root Cause Functional Area *
10/18/89 1% Personnel errors Operations Niagara Mohawk initiated a plant shutdown to resolve high dissolved copper levels in the circulating water system. The acid used to control circula-ting water chemistry had leaked past closed isolation valves and inadver-tently corroded the copper condenser tubes. Corrective actions included design modifications of the isolation valves. The unit remained shutdown for ten days until an agreement was reached with the New York State Department of Environmental Conservation about the discharge of the copper containing circulating water to the lak Date power Root Cause Functional Area 10/28/89 4% Design deficiency Engineering / Technical Support 7, An EHC malfunction caused the turbine bypass valves to open and the tur-bine centroi valves to clos This resulted in an increase in reactor pressure and a resultant automatic reactor scram due to high neutron flux signals. A ground introduced by a minor modification had apparently caused the malfunction. The unit remained shutdown for six day Date Power Root Cause Functional Area 12/1/89 97% Personnel error Engineering / Technical Support
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shutdown. , A common design problem in the feed . pump . internal. components j
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,:The. unit remained shutdown for 40 day t Date Power Root Caus Functional Area i l 12/25/89 60*. Inadequate . Maintenance l , .
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III. PERFORMANCE ANALYSIS II Plant Operations III. Unit 1
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The previous SALP report rated Plant Operations at Unit I as Category Con- i tributing to this rating were inappropriate operator attitudes toward training, weak' operator proficiency regarding the emergency operating procedures (EOPs), and deficiencies ~ in .the licensed operator requalification training progra . NRC-was particularly concerned that station management had not been effective in identifying and correcting these deficiencies, t III.A.I a Analysis Overall, during this period, station management made substantial progress in addressing and correcting the concerns from the previous SALP report. However, other problems were noted relative to the evaluation of personnel performance, self-assessment capability and problem identifics . ion, and attainment of per- ' sonnel performance at the level described in the Nuclear Division Standards of
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Performanc The licensed operator requalification program improved. Management attention 5 to licensed operator training significantly increased, and there was evidence that 'the operations department had taken responsibility for the quality of , training. Additionally, operators demonstrated their acceptance of the respon- . sibility for the quality. of. training, which was in contrast to their attitude " towards E0P training noted in the last:SALP perio ' Operator use and proficiency with the E0Ps greatly; improved during this SALP-period. A May 1989 inspection concluded that five of the six operating crews demonstrated a satisfactory level of performance in the use of the E0Ps; how-ever, one crew and one -individual did not. Additionally, the command and con-trol of .the operating shif ts represented a generic weakness regarding crew communications and the assignment of crew member duties. A September 1989 _ inspection _ concluded that both assessed operating crews demonstrated a satis- ' fact ary level of performance, but that two senior reactor operators (SR0s) did not. The prior generic weakness in command and control was determined to be satisfactorily addressed; however, certain other generic weaknesses (inadequate assessment of power board losses, not using all available indications for dia-gnosis . of events, and occasional slow recognition of plant trends) still existed, which indicated that corrective actions had not been totally effec-tiv Further, Niagara Mohawk self-assessments prior to the NRC reviews had not found the operator problems or the generic weaknesse ,
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As the unit remained shutdown throughout the period, assessment of plant power operations was not possibl Nevertheless, licensed operators demonstrated improved performance in some other areas. For example, the operations staff's support of maintenance and surveillance activities was good, with only minor problems note Good teamwork and support existed for the numerous initial runs of inservice tests, inservice inspection hydrostatic tests and other special testing. Refueling operations were performed in a professional, appro-priately paced and competent manner by the operator However, the above good performance contrasted with many events in which licen-sed operators performed poorly. These events consisted of: accidental flush-ing of a condensate demineralizer to radioactive waste processing due to a valve misalignment; emergency ventilation (EV) initiations due to procedural and personnel errors; EV initiations due to improper tagging control; improper control of source range monitor ($RM) bypass function during refueling opera-tions over three shifts; and a valve misalignment of the reactor building closed loop cooling system. The SRM incident was noteworthy in that the impro-per position of the bypass switch was overlooked by the operators during load-ing of fuel assemblies and during two shif t turnovers. These events were the result of causes which included operator knowledge deficiencies, poor communi-
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cations, inadequate plant impact assessment, poor system status control, or inadequacies rcgarding administrative procedure Lastly, licensed operator participation in the initial set of reload system walkdowns was judged to be poor, in that the operators failed to identify numerous plant deficiencies identified during later walkdown Operations department management achieved a better approach to operations in some areas. Specifically, the October 1989 Integrated Assessment Team Inspec-tion (IATI) determined that operations personnel had been well integrated into the planning and scheduling process, cooperation between the operations and training departments had improved (the interdepartmental committee had played a major role in this improvement), and management had increased its attention to the needs and effective utilization of employees, resulting in improved team-work. Further, operators were not as isolated as they were noted to have been in the previous period. Operations management was sensitive to career develop-ment and had begun long range planning to enable more career opportunitie Licensed operator staffing was at minimal.but acceptable level However, operations management weaknesses were apparent in the improper control and tracking of overtime, the failure to verify adeqv:cy of licensed operators medical examinations, poor communications with operators regarding the requal-ification examinations, and a weak investigation into the SRM incident. Fur-ther, operations management did not aggressively perform self-assessments, and the completed self-assessments were inef fective. Operations management empha-sis on improving in the areas of operator training and E0Ps appeared to have been beneficial in these areas but had resulted in less attention being paid to day-to-day activities. Although many of these events and problems were of low safety significance, cumulatively they indicated the need for more effective management oversight of daily operation <
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' Summary l The concerns of the-last assessment involving operator training were adequately ! addressed as a result of increased management focus. However, the performance
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e of licensed' operators in the plant varied; good control of testing and . refuel- t ing, activities existed at times, but a number of minor events were caused by personnel errors._ More effective management, particularly oversight of dail '
. operations, appeared to be needed to raise overall operations department per- ,'
formance. Insufficient progress was demonstrated to warrant a ' change in the j
. previous rating, r III.A.I.b Performance Rating I
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Category 3 j III.A.I.c Recommendations i None ; III. Unit 2 l The previous SALP report rated Plant Operations at Unit 2 as Category 3. Per- ; sonnel errors caused by inattention to detail or failure to follow procedural- ; requirements had occurred at a high rate and had caused three reactor scram ; These errors had reflected station and corporate management's low expectations
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and acceptance of a low level of performance. The SALP Board recommended that Niagara Mohawk raise the performance expectations of - the Unit 2 operations department and . reduce the . number of lit annunciators on the main control panel u .; III.A.2.a Analysis 1
'Overall,.during.this assessment period, the performance of the operations staff waslinconsistent and demonstrated only limited progress. Unit 2 was contin-uously operated for 135 days during which time few personnel errors occurre However, this good performance was contrasted with the unsatisfactory rating of the licensed operator requalification program, three automatic scrams caused by personnel errors, and ~a- frequent, continued inability to control component and : system statu ' . 'The Requalification Training Program for licensed operators was rated unsatis- . factory. This was based on nine individual failures out of 24 on at least one i , portion of the examination. Also, two of six crews (recomposed for examination ,
purposes) were determined to be unsatisfactory on the simulator. Individual performance and knowledge deficiencies were noted. Further, weaknesses in the examination process implemented by Niagara Mohawk contributed to the unsatis-f actory rating. For example, the written test examination for the second week of the.-requalification examination did not reflect the generic NRC staff com-ments incorporated on the first week's examinatio . _ , .
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, 10 Niagara Mohawk's initial written response to the examination results did'not address why the training and operations departments had failed to identify the problems-in its requalification program prior to the NRC-administered examina- 'tions. Also, it appeared that a complete root cause analysis may not have been performed without prompting by NRC. The major- contributor to the identified performance problems appeared to have been unclear management expectations, in- - that crew roles during emergency situations were not clearly defined. Also, feedback by both training and operations departments and other oversight groups during preparatory evaluations had been ineffectiv It was noteworthy that these factors were also NRC concerns at Unit 1 in the same functional area dur-ing the previous assessment perio Three of_ the six reactor scrams were attributed to personnel error. An oper-ator used a walkie-talkie near the radio transmission sensitive EHC cabinets causing turbine control valves to close and an automatic reactor scram. An inadequate. plant impact assessment for preventive maintenance on a condenser ,
air removal pump breaker resulted in a loss of condenser vacuum and an auto-matic _ reactor scram. During a controlled plant shutdown, an automatic reactor scram occurred due to poor control of steam load These scrams could have been prevented,by more care and attention being paid to the impact of the oper-ator action on the uni Several personnel errors resulted in poor control of components and system The most severe was when valves in the reactor water cleanup system were left out of their normal position, resulting in an uncontrolled discharge of reactor . coolant to the liquid waste processing system. Also, a service water bay unit " cooler with a known deficiency was improperly returned to service without i repairs completed. A Division III switchgear room cooler was declared operable following maintenance, even though it was not energized and no post-maintenance 1
' test had been performed, An inadequate plant impact assessment for the tagging F of the generator hydrogen system resulted in the unexpected loss of hydrogen pressure indication in the control room and a plant shutdown. Collectively, ;
these errors indicated continuing problems with operator attention to detail .! and poor planning, as identified in the previ:es SAL Notwithstanding the above problems, Unit 2 operators displayed an overall con- > scientious attitude towards safety, licensed training, and the resolution of concerns brought to their attention by NR This safety perspective and improved problem identification was demonstrated on several occasions. While-closely monitoring containment pressure indications during a routine evolution, a control- room operator identified that suppression pool /drywell ' vacuum breakers were improperly set. Operator responses to a recirculation pump trip at 88% reactor power demonstrated their ability to quickly assess the event and , carry' out appropriate emergency response actions. During a surveillance test, ' the questioning attitude of an operator identified an incorrect leak test ! methodology for diesel generator air start system check valves.
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I t Limited progress.was made in reducing the large number of lit annunciators in-the control room. Towards the end of the assessment period an engineering task , force manager was assigned, and better progress tracking methods were estab-lished. In the related area of operator responsiveness to alarms, improvement was noted and operators routinely responded to alarms in a timely manner. This , l -' improved responsiveness appeared to have resulted in part from an increase in operations department management presence in the control room and involvement i in daily activitie This increased management attention to assure effective '
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corrective action was observed-in other area Niagara. Mohawk adequately implemented the requested actions of NRC Bulletin 88-07 and Supplement 1, regarding potential power oscillations. However, the following inadequacies were noted: a revised procedure included an entry con-dition that was not understood by all licensed operators; the interviewed oper-ators did not fully understand the recent procedure revision; and several pro-cedures ' did not contain . appropriate cautions. It appeared that the Niagara Mohawk verification process was . insufficient to ensure that licensed operators ; understand procedure changes and the procedure review process was not compre-
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hensive. Later, when an unexpected downshift of a reactor recirculation pump resulted in the reactor operating in the restricted area of the power-to-flow : map, the operators acted promptly and correctly to manually ~ scram the reacto A Many meaningful initiatives were implemented to improve the operations depart-ment,'but frequently had not been in place long enough to demonstrate result Examples included establishing and filling a new Deputy Station Superintendent i position to provide increased management oversight of plant activities and operator training; improved departmental goals for performance; operator incen-
; tive -programs based on operational performance; installation of annunciator response cards on the front and rear control panels; revised, detailed auxil-iary operator round -sheets; computerized tagging system; relocation of the tag- >
ging control desk to the rear of the control room to minimize congestion and * noise in the control panel area; plant labeling improvements; and video sur- - veillance systems used to monitor'inside high radiation areas. These initia-tives demonstrated management's desire to improve the control room environment, as well as, overall performanc Staffing in the operations department was adequate; however, licensed operator i career development alternatives and rotational assignments were limited by the : lack of extra licensed staff. Because of the requalification training program ! concerns and normal attrition, . the shif t crew rotation was reduced to five crews, each with two SR0 Fourteen licensed operator candidates (seven R0s and seven SR0s) were in the training program at the end of the assessment period. Operations management appeared responsive to staffing concern .
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Sumsey I The Unit' 2I operations perfcemance_ was inconsistent and showed ' limited' improve-
~ . " 'p"e- ment .over the , previous ane 1sment period.: . Operational- events caused by poor ; '
control . of - components - and systems continued at a .; high rate. The Unit' 2: ; licensed' operator ' requalification program was irated unsatisfactory, ' based on ; 1 the poor performance of: operators. Progress on- lit annunciator reduction- was ' l' slow.: -Meaningful initiatives were established but' had 'yet ;to demonstrate-e . results.,
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: !II.-A.2.b Performance Rating 1
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, ..- 13 a ! . 8 II Radiological Controls !
The previous SALP report rated Radiological Controls as Category 2. There was ] steady improvement in the overall program but radiation protection (RP) manage- l ment oversight was weak. However, Niagara Mohawk initiatives were- expected to improve ' the- accountability and oversight of ongoing work. The SALP Board recommended that Niagara Mohawk place more emphasis on Unit 1 decontaminatio In this assessment period the RP area was reviewed during the .IATI, and rad- . waste / transportation and environmental /ef fluent controls were each reviewed '! onc I III. Analysis
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Radiation Protection 0verall, during this assessment- period, radiation protection performance , remained acceptable, with limited progress in reducing contaminated areas, up- ' grading ALARA (as low as reasonably achievable) performance, .and oversight of
. ongoing work. The Restart Action Plan (RAP), an overall Niagara Mohawk assess- "
ment of management problems associated with the 1988 shutdown of Unit 1, appeared to result in increased attention to improving radiation protection program The control- of ongoing work improve Walk-around audits by management and teams of first line supervisors resulted in improved adherence to radiological j controls practices. Management involvement and control in assuring quality in i l RP programs improved. Also, audits by the corporate RP group and contractor audits sponsored by the Safety Review and; Audit Board (SRAB) improved and .! became effective in assessing program weaknesses. Management emphasis of problem identification had improved this area, but resolution of the identified problems lagged at time The control of contamination *M radiation ' improve For example, the RP' l
' ' department initiated a structured analysis of _the recurrent problem of unlocked high radiation area. doors and other recurring site RP problems, as 'well as-industry events This resulted in better resolution of RP issue For example. mnual contamination friskers were replaced with modern automated equipment. Decontamination of the turbine and reactor buildings reduced the
' number of personnel contamination events and improved the access to equipmen .The control of hot particles on the refueling floor was upgraded. Although there were improvements, some resolutions did not - fully address the root 'cause
. of 'the~ proble For example, catch basins are still extensively used to con-
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tain valve leakag .
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.. ' Radiological Controls us SALP report rated Radiological Controls as Category 2. There was 'vement in the overall program.but radiation protection (RP) manage- ' was weak. However, Niagara Mohawk initiatives were expected to countability and oversight of ongoing wor The SALP - Board Niagara Mohawk place more emphasis on Unit I decontaminatio In weriod the RP area was reviewed during the IATI, and rad-waste /1 *nd environmental / effluent controls were each reviewed onc Ill. A2 Radiation pt-ote - Overall, during . period, radiation protection performance remained acceptable, ' ogress in reducing contaminated areas, up-grading ALARA (as low P schievable) performance, and oversight of *
ongoing work. The Rest., 1 ' rap), an overall Niagara. Mohawk assess-ment. of management prot 1988 shutdown of Unit 1, appeared to result in in program c( i with the
' to improving radiation protection The control of ongoing work th., C 'ound audits by management and teams of first line supervisors rt - % ved adherce to radiological controls practices. Management inv N 9 trol in assuring quality in RP programs improved. Also, audits , %% * RP group and contractor . audits sponsored by' the Safety Revit 'ard (SRAB) improved and became effective in assessing program .
lanagement emphasis of problem identification had improved this ' ion of the identified
- problems lagged at time . The control of contamination and radiation . 4 example, the RP
' department initiated a structured analysis of the 'em of unlocked high radiation area doors and other recurring si % as well as industry events. This resulted in better resols 4 * sue For example, manual contamination friskers were replace. D automated equipment. Decontamination of the turbine and reactoi 'ced the number of personnel contamination events and improved the 'omen The cor. trol of hot particles on the refueling floor was 'ough there were improvements, some resolutions did not ful',y addrs 'se of the problem. For example, there did not appear .o be an t 3 valve packings and to use live loading on valves at 011t 1, th the source of low level contamination in some plant areas. A1, decontamination of Unit I reactor systems was postpone s
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Staffing and organization were stron The staf fing level was expanded last period by the addition of a chief technician position to improve control of field work. Since then the staffing level remained = stable. Most personnel had-many years . of service onsit All supervi sory positions were filled with . Niagara Mohawk employees, except for the superintendent, chemistry and radia- - tion protection. Also, a new, highly experienced individual was hired ' midway , through the period to fill' the ALARA supervisor position vacated last perio . ALARA performance for 1989 was good for Unit I at 464 man-rem and excellent for l Unit 2 at 61 man-rem. Management improved the use of goals as a tool to focus ' personnel and equipment changes towards achieving specific objectives, but 1 there were no management goals clearly reflecting the need for . site-wide sup- , port of RP programs. Also, tt relationship between the .RP department goals ! and the broader st'ation .and corporate goals was of ten not clear. For example, , there was no 1989 corporate ALARA goal. This could have diminished the pri-ority of RP related improvements. Reasonab'e efforts appeared to have been made during the work performance to reduce ex?osure. In response to NRC con-cerns,- management established a 1990 corporate ALARA goal of 506 man-re l
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The problem concerning the radwaste processing building subbasement being used for liquid radwaste storage was brought to the attention of the NRC during thi .SALP period; however, the event occurred several years ago with weak corrective actions initially taken to achieve a timely cleanup. The more recent Niagara ' Mohawk actions have demonstrated good management oversight and provided for a deliberate, cautious, and well supervised cleanup of this are ; Effluent. Environmental Monitoring, Radwaste and Transportation-l Niagara ..ohawk had continual problems with the operability of effluent mon- " i itors, especially at Unit 2, and corrective actions were not ef fectiv For example, the gaseou: effluent monitoring system (GEMS) remained inoperable dur-ing most of the- assessment period, placing Niagara Mohawk in an almost contin- t uous Limiting Condition for Operation. Niagara Mohawk also failed to take -) timely action in the repair of some effluent systems. For example, at Unit 1, i the service water effitent . radiation monitor was declared inoperable for five
'
months before Niagara Mohawk placed the required modification to this system on its repair and maintenance schedul This programmatic weakness was further evidenced by the five licensee Event Reports (LERs) related to the effluent monitoring systems issuec during the assessment perio , s h I
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a j, 'V lw 7 ttaffing ' andf organization were strong. The staffing level was expanded last _ J *iod by, the addition' of - a chief technician position to improve control of 4 work. Since then the staffing-level remained stable. Most personnel had ears of service onsite. -All supervisory positions were filled with
'4ohawk employees, except for the superintendent, chemistry and radia-a 3-tion. Also, a new, highly experienced individual was hired midway * '
weriod to fill the ALARA supervisor position vacateu -last perio T, ; . ' was weak and needed more visible support ofs upper managemen i
, Mr the use of goals as a tool to focus personnel and equipment a'
chah, 'eving specific - objectives, . but there were noc management goals , q the need for site-wide' support of RP programs. Also, y the rel., the RP department goals and the broader station and
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corporate $ 9t clear. For example, there was no 1989 corporate Q , ALARA goal . ' diminished the priority of RP related improve-s ments. The Ur, 9t 800 man-rem did not represent an aggressive Q iddition, although the final determination had
attempt to reduc m not'been made, it .
:that little effort s
$ 's goal- had been exceede It also = appeared
'e the -source term and to adjust the major
>> ,
planning of work to e to %ve been made during g 4 1d be met. . Reasonable efforts appeared
' nance to reduce exposure. In response ^ -to wRC concerns, managem man-re ' %o 1990 corporate ALARA goal of 506 The problem _ concerning the radw,. JY& uilding subbasement being used ' *
for liquid radwaste storage was brs N ' tion of the NRC during this SAlp period; however, the event occ N s ago with weak corrective actions initially taken to achieve a
\ The- more recent Niagara ,
Mohawk actions have demonstrated good ms St and provided for a y deliberate,. cautious, and well supervised s ea, s
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Effluent, Environmental Monitoring, Radwaste s Niagara Mohawk had continual problems with the t,, 3 ' fluent mon-itors, especia11y' at Unit 2, and corrective actio C 'iv For
. example, the gaseous effluent monitoring system (GEMS) le dur-4 ing most of the assessment period, placing Niagara Mohaw 'ntin-uousL Limiting Condition for Operation. Niagara Mohawk 'ake timely action in the repair of -some effluent systems. For t '
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the service water effluent radiation monitor was declared ino, months before Niagara Mohawk placed the required. modification to .its repair and maintenance schedul This programmatic weakness L evidenced by the five Licensee Event Reports (LERs) related to t J monitoring systems issued during the assessment perio c
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., 15 a In contrast to.the above effluent monitor problems,' Niagara Mohawk continued to have strong ;radwaste and environmental monitoring programs. Niagara Mohawk - continued to operate an extensive surveillance system for the collection and analysis' of environmental samples and for verification of the meteorciogical instrumentation. All radwaste shipments were accepted at the low level burial sites without incident. Staffing within these areas remained stable, and .the . training program for radwaste workers continued to be a strength, - Radioactive waste operations were effectively controlled, except for one minor event in .which improper annunciator response resulted in the overflow of the reactor building sump. - Radwaste management was proactive in the effort to minimize 'and- segregate radioactive waste and was observed to be actively involved in day-to-day activities in the plan The quality assurance (QA) program continued to be effectively implemented, through the use of audits, surveillances and quality control (QC), although the review of - the ef fluent monitoring systems was an exception. Findings identi-fied in audit reports and surveillances were typically resolved in a timely manner for these areas'. "
Summary Overall performance - remained goo Improvements were made in the reduction of contaminated areas, the control of ongoing work, and the ALARA control of work, Niagara Mobt.wk continued to have problems with the operability of the ef fluent monito. - as, especially at Unit 2, but radwaste and environmental monitorb n sgrams remained strong, III.B- performar e Rating Categr a
.III,r +." lons None
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r m , y+ -
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' to:the above' effluent monitor problems, Niagara Mohawk continued to-E
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radwaste; and environmental monitoring programs. Niagara Mohawk : i
; 'perate1an extentive, surveillance system for the collection e.nd c ironmental satples and for verification of' the metecrological . i '
All radwaste shipments werei accepted at the low level burial is sitt ( 2nt. - Staffing within these areas remained stable, and the - 9 train '\
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radwaste workers continued to'be a. strengt (: 9 _' 0 . .Radioact tior.;-wee effectively controlled, except for one minor < FF , event in 'annunciatnr response resulted in the overflow--of the ' reactor but 'dwa ste' ~ management was proective in the effort to
!(! minimize ano 'ioactive waste and was wserved . to be . actively .;
tln involved in day p ies in the plan v
/ The - quality assui through the use of ,
k ' ram continued to be effectively implemented,
'ances and_ quality control (QC), although the ,
review - of . the ef flue, 9 stems was an exception. Findings identi-
% fied . in audit reports \ g 'ces were typically resolved in a timely a manner-for'these area L-; (<ly
Summary 'O
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D q Overall performance remained 9 - 9ts were made in the reduction of {' contaminated areas, the control ds , and the ALARA control of wor However, upper management support \ 5 'ed to be weak. Niagara Mohawk-E :ontinued to have problems.with the the effluent monitoring sys - m e, ems, =especially at Unit 2, but radw / imental monitoring programs S remained strong, s
- it III. Performance Rating Y\ Category 2 III.B.3- Recommendations- -
None
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.W ~II Maintenance and Surveillance The previous SALP report rated Maintenance and Surveillance as Category 3. The site maintenance program was assessed to be effective; however,' weaknesses were i noted in management oversight of performance, effectiveness of corri.ctive ,
actions, and adequacy and compliance with maintenance procedure Improvement i was'noted in the Unit 1 inservice inspection (ISI) program. Various procedural and personnel deficiencies were experienced during the implementation of the
. ' , . Unit 2 surveillance program. While ISI and inservice testing (IST) activities-are reviewed in this functional area, the ISI and IST programs are assessed in the functional area of Engineering / Technical Suppor .
III. Analysis Maintenance Overall, during this assessment period, performance in the maintenance area was again-weak. The inadequate control of maintenance activities, particularly at Unit 2, resulted in a high number of operational events. Weaknesses were noted in the areas ,of backlog reduction at Unit 2, proper diagnosis of equipment failures at both units, and unplanned shutdowns at Unit Numerous ' operational events at Unit 2 resulted from errors by maintenance per-sonne These personnel errors resulted in a - Technical Specification (TS) violation of. electrical Division III operability requirements, a. flooding event on the 250 foot elevation of the turbine building, numerous inadvertent safety - system actuations, and an inadvertent traversing incore probe insertio The majority of these errors were made during routine preventive maintenance. The causes of these errors were rooted in weak procedural adherence', poor procedure format, inadequate post-maintenance testing, poor plant impact assessments, and insufficient supervisory oversight. Some of the corrective actions taken by management- included requiring the use of a plant impact sheet and a post-maintenance test sheet for each work package. As a long term measure, station maintenance procedures were being upgraded to include more concise procedural controls. These corrective actions appeared to be an -~ appropriate approac Three unplanned outages at Unit 2 were maintenance related, and the absence of - effective preventive and corrective maintenance was of ten involved. Poor pro- ' cedural guidance on electrical preventive maintenance performed on a mechanical vacuum pump breaker directly caused a reactor scra Inadequate preventive
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maintenance on loose wires in the main generator potential transformer cubicle , caused a reactor scram. A forced outage resulted from inadequate troubleshoot- ' ing on repetitive feedwater pump problems involving excessive vibrations and ; mechanical seal failures. These equipment problenis resulted in unnecessary
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plant transients and protective system challenges. As demonstrated by the l 1y
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; 17 l
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above events, the maintenance department did not effectively maintain plant equipment to support reactor operation. Also, two valve packing leaks in the drywell, and a power supply. failure in the recirculation pump control circuitry '* caused unplanned outages. The packing leaks and the power supply failure L appeared to be random equipment failures without direct, adverse implications on the . maintenance progra Nonetheless, these events were circumstantial ; evidence of weak maintenanc l With the Unit _1 reactor shutdown, a reactor scram was caused by the failure to .I! properly plan a maintenance activity. Also, several events indicated the need to improve the. timeliness and effectiveness of corrective actions, e.g., poor _; initial troubleshooting on problems related to a motor generator set (which ~ resulted in several reactor scrams and emergency ventilation initiations), lengthy troubleshooting of stroke time problems with a cordrol valve for con-
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trol room ventilation, _ and poor troubleshooting and repair of an emergency j diesel generator (EDG) fuel -transfer pum I I In the Special Team Inspection early in the assessment period, the NRC noted i that to - the extent that the maintenance program was ef fective, it depended : largely on the skill and experience of the maintenance management and personnel !
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and not on an established maintenance program. Accordingly, the team noted j-that the program appeared to be informal in some areas with a considerable risk j of degradation if_ any of the key managers were to depart. Limited progress was ! mads in establishing these programmatic aspects bafore the statien maintenance , superintendent chose another non-nuclear Niagara Mohawk job near the middle of j ' the period. _ This loss of experience combined with the weak program, appeared- l to. contribute to the above problem ~1 Later in the assessment period the IATI noted a strong and knowledgeable main-tenance planning organization that scheduled all facets of the work activities, j _ The IATI also noted that Niagara Mohawk management had implemented performance ! indicators and a new method for prioritizing work requests to' ensure completion ! on a timely basis, especially for those work . requests required to support reload and restart ef forts at Unit 1. Realistic goals were set at Unit I for the - reduction of the backlog of work requests and at the conclusion of this l SALP period this goal had been achieved. However, the ma.intenance work request ! backlog at Unit 2 remained large and was not effectively addressed by station i or corporate management. Work practices observed in the field by the IATI were i generally carried out in a competent fashio Good procedural adherence and j teamwork was also noted by the IAT ?
'In an' effort to improve the quality of the various maintenance procedures, a maintenance support group with a staff of 38 procedure writers was forme This was a good example of management committing the necessary resources to achieve procedural and program improvements. Also, following NRC identifica-tion of problems with the post-maintenance testing (PMT) controls at Unit 2, Niagara Mohawk identified and addressed similar PMT deficiencies at Unit 1, -another example of effective corrective actio d
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LS ome - maintenance activities were well controlled. For example, the Unit 2 feedwater pump' repairs were well controlled once the design problem was deter-mined, and supervisory oversight of the repairs was eviden However, several events called into question maintenance management efforts to improve oversight of day-to-day performance, as well as, effectiveness and tic.eline s s of ' corrective actions. For example, maintenance management was largely responsible for the poor implementation of the initial set of reload system walkdowns at Unit 1. NRC identified numerous deficiencies -in the walk-downs, which demonstrated poor preparation and oversight of the walkdowns by maintenance management and unit management. Also, Niagara Mohawk investigation-
..of the Unit I reload SRM bypass incident was ineffective, in that it did not determine that electrical and I&C maintenance personnel had not adhered to tag-ging procedures while performing troubleshooting and repairs. Further, when brought to the attention of maintenance management, initial corrective actions were ineffectiv Improper diagnoses of equipment failures and repetitive failures again occurred at Unit 2 this assessment perio Examples included: hydraulic control unit nitrogen leakage; reactor core isolation cooling system af tercooler temperature " ; monitor failures; standby gas treatment system isolation valve actuator prob-lems; feedwater pump vibration and mechanical seal failures; and reactor water cleanup pump seal failures. These examples indicated poor root cause- deter-minations of equipment failures, in conclusion, regarding maintenance, although progress was made 1.n some areas, the overallo performance in maintenance did not improve. The quality of main-tenance procedures improved, work was better prioritized, and the backlog of Unit I work requests was reduced. However, the number of ~ maintenance-related scrams, safety system actuations, and unplanned outages at Unit 2 demonstrated that maintenance program was not fully ef fective. The maintenance program did not appear .to analyze, plan, and execute the maintenance work' in an ef fective -
manner to support the operation of Unit 2 and the repair and testing at Unit Management was of ten not timely and effective regarding corrective actions and investigations of equipment and personnel problems. Maintenance department staf fing. appeared to be marginally acceptable based upon the inability -to reduce the backlog at Unit Surveillance Overall, during G;s assessment period, the surveillance area improved, most notably at Unit 2 cospared to the minimally acceptable level of the previous period. The thorough review of Technical Specification (TS) requirements, previously done at Unit 2, was duplicated at Unit 1 and provided a basis for better planning and execution of the testin . . . . . . . . . .
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.- 19 A major concern identified at Unit I near the end of the last period was that frequently performed surveillance tests were not followed step by step and that attached checklists were being used without reference to their written proced-ure. As corrective action, Niagara Mohawk provided site-wide training on pro-per procedural- conduct with emphasis on strict adherence. This appeared - to have been effective as evidenced by the . large number of procedural changes initiated at both -units to correct procedures, more tests stopped due to pro-cedural concerns, and few instances of events related to -poor procedural adherenc One of the Unit 1 Restart Action Plan (RAP) commitments was to develop and implement a Unit 1 TS matrix for the purpose of tracking and scheduling TS-required surveillances. Extensive development efforts by the regulatory com-pliance group took place this period, and substantial progress was made. This type of computer-based TS matrix had been developed and successfully -imple-mented at Unit 2 during the previous assessment perio ' An adjunct to the Unit 1 TS matrix program was the performance of technical reviews of the surveillance procedures themselves. At the end of the period, 100% '-the pr,ocedures had been reviewed, and final compilation and evaluation of the esults were under wa Niagara Mohawk's decision to perform a 100%
- review of existing surveillance procedures was justified by the fact that numerous minor deficiencies were identified and corrected as a result of this review. A few examples of inadequate test methodology were identified by Niagara Mohawk and other outside organizations. Overall, the test methodology and format for the resulting surveillance procedures were good. These two-programs were comprehensive in nature and properly addressed previous deficiencie One area of concern at Unit 1 was the in:trumantation calibration program for-safety-related equipment. The NRC identified the failure to incorporate the emergency ventilation system 1 KW heater. thermostat units in the calibration program. Concurrent review by ' Niagara Mohawk of ' the balance of plant and Technical Specification equipment instrumentation identified several other calibration deficiencie There was marked improvement in the performance of surveillance testing at Unit 2, particularly of the TS-required test There was only one inadvertent safety system actuation caused by personnel error while performing surveillance Site-wide training was administered on procedural adherence, and sur-
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test veillance test plant impact statements were greatly enhance During one-unplanned outage, the maintenance organization took advantage of the available down . time and successfully schedulei and completed 38 local leak rate test Local leak rate testing crews were formed using dedicated personnel from var-ious crafts and departments. This approach proved to be successful and demon-strated effective teamwor ..
, , 20 The scheduling of Unit 2 surveillance tests improved, and missed surveillance tests were greatly reduced. Some minor surveillance test implementation prob-lems occurred resulting in TS violations of minimal significance. A missed surveillance test occurred as a result of an operations shift check oversight, '
and another ' missed surveillance occurred as a result of a chemistry department oversight. In each case, appropriate corrective action was taken. Increased
. management. oversight of the surveillance program was evident. Performance this period indicated that the corrective actions taken in response to the large i number of missed surveillance tests during the previous assessment period were effectiv Both the Unit 1 and Unit 2 ISI programs were effectively implementea. The previously addressed ISI and IST areas demonstrated continued good testing performanc In conclusion, regarding surveillance, good progress occurred in the surveil-lance area, and- thorough, ' extensive reviews of testing formed - the basis for better planning and implementation of Technical Specification testing, inser-
! vice testing, and inservice inspectio Implementation of the surveillance testing program at -Unit I was effectiv The Unit 2 Technical Specification
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surveillance program showed substantial improvement over - the last assessment period. Increased management oversight of the program was evident, a Summary Performance improved notably in surveillance; the Technical Specification test-ing programs were effective, and the previous improvements in inservice inspec-
-tion _and inservice testing continued. However, an ineffective maintenance pro-
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, gram -appeared to result in numerous maintenance related operational events at Unit .III. Performance Rating Category 3
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III. Recommendations NRC: Perform a team inspection to assess maintenance performance during the Unit 2 refueling outag Niagara Mohawk: Reassess -the adequacy of the maintenance program and man-agement/ supervisory oversight with respect to the continu-ing deficiencie y
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t k III.D' Emergency Preparedness 7' The l previous: SALP report rated Emergency Preparedness as Category 1, based on r good Niagara Mohawk performance during the partial participation exercise, good
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working relationships with State and local agencies, and progress in addressing
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items from the NRC emergency esponse facilities (ERFs) appraisa f
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During the current assessme.nt period, NRC review included observation of a full participation exercise, r routine safety inspection, and review of changes to
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& the emergency plan and 4.nplementing procedure s
:111. Analysis Overall, during this assessment period, Niagara Mohawk continued the good per-a' formance in Emergency Preparednes Performance during the emergency exercise was good, the good working relationships with State and local authorities were ,
mair.tained, and effective corrective actions were taken for problem ; b During the emergency exercise, good performance was noted in response to the accident scenario. Changes in plant conditions were readily observed by shif t staf f- and used to classify emergency conditions properly. Positive interac-tions were demonstrated among emergency response organization (ERO) members, and effective coordination with State and local response personnel was ob-served. Interface with the NRC incident response team was effective. No per-formance weaknesses were identified, and only minor improvement areas were ,
'noted. Previously . identified items were corrected and no items -recurre The routine safety inspection examined all areas of the emergency preparedness-(EP) program, including administration, EP and ERO staffing, ERFs and - equip-ment, program changes, training, and independent audits. ERFs were maintained in a state of readiness, and the Site Emergency Plan (SEP) and implementing proceduras were curren Procedure and program changes received the proper
! level of management. review, L . Site management was kept apprised of EP program activities through fonnal-staff meetings and involvement in the routine activities of the EP staf Senior managers maintained ERO position qualification, evaluated SEP and implementing , procedure changes, participated in drills and exercises, and interfaced with
' - Oswego County of ficials. Management attention to . site activities was suppor- ,
tive, -and management demonstrated a clear understanding of the issue ' The EP program was administered by the manager, emergency preparedness, who was responsible for all onsite and offsite activities. To implement all aspects of the program, nine full time technical and administrative positions were author-ized. All positions were described and responsibilities were well define Personnel changes in the last calendar quarter of 1989 resulted in replacement of the manager, EP and two additional vacancies. Although this put a temporary
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J 22 L ! strain on existing EP staff, the major program functions were being adequately maintained, including maintenance of the SEP and implementing procedures, con-duct of - drills and exercises, maintaining emergency response facilities and equipment, and interfacing with offsite support groups. Good coordination existed among other site departments as personnel were drawn from operations and training staffs to aid in development of drill and exercise scenario Niagara Mohawk was actively working to fill vacancies with qualified candidate Emergency response training was performed by the training department and was generally effective. This included general employee training as well as qual-ifying individual members of the ERO to perform response functions, A training manual described the course requirements, training matrix, lesson plans, and course contents. The ERO was fully staffed and trained in key response fune-tions. Improvements were made in the system for immediate notifications of ERO personnel, Following implementation of this new system, NRC walk-through scenarios revealed that ~ training of shif t personnel on the revised procedure had not been effective in all cases, and retraining was performe Manual records of individual training were complete, and tracking of permanent records and all ERO requalifications was upgraded via computer database file . Niagara Mohawk maintained the good working relationships with the local commun-- ities, the State of New York, and the FitzPatricK site staff in coordinating offsite emergency response activitie Following the full participation exer-cise, the Federal ~ Emergency Management Agency (FEMA) identified several defici-encies regarding offsite preparedness, which concerned development of Emergency Broadcast System (EBS) messages, notification of hearing impaired persons, and training of offsite emergency worker To address these findings, Niagara Mohawk worked closely and effectively with New York and Oswego County anc resolved all deficiencies in a Niagara Mohawk supported remedial drill held i' November 198 Niagara Mohawk showed a good ability to resolve technical issues. In response to NRC inspection findings, implementing procedures were issued via controlled distribution. Revisions were made in the areas of protective-action recommen-dations for Emergency Directors and clarification of. emergency action levels for ' fire related events. These corrective actions were ef fective, in that there wasino repetition of these findings. Also, to address problems asso- " ciated with obtaining and evaluating chemistry samples, an appropriate action plan was develope Niagara. Mohawk audits met the requirements of 10 CFR 50.54(t), and a good understanding of EP program areas was exhibited by audit team members. Audits were adequate in scope, and corrective actions on recommendations identified during audits and self-assessments were timel ' - - - ' ~ '
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. 23 Summary Niagara Mohawk continued to implement an effective emergency preparedness pro-gram. Niagara Mohawk demonstrated good performance during the emergency exer-cise, good working relationships with State and local authorities, and ef fec-tive corrective actions to identified problem Personnel changes among EP staff did not appear to impact overall program implementation, and the training program was generally effective. An ef fective ef fort was provided in assisting the State of New York and Oswego County in resolving FEMA-identified exercise deficiencie Ill. Performance Rating Category 1 III. Recommendations None
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' Security
' II The previous SALP report rated Security -as Category 1. This rating was based upon Niagara Mohawk's implementation of an effective security program, which' exceeded regulatory requirements and NRC-approved security plan commitment The good performance was further demonstrated- by Niagara Mohawk's initiatives to improve the' program and to upgrade security systems-
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During this assessment period, two routine, unannounced physical security
' ~ inspections were conducted by region-based inspector III. Analysis Overall, Niagara Mohawk's high level of performance during the previous-assess-ment per.iod continued- through ut this perio The performance of security personnel was excellent, and ~.mprovements were made to the security program, training, and equipmen Upgrading and~ enhancements of systems and equipment continued. In particular, some aging -int,rusion detection equipment was replaced, and several' assessment aids .and security facilities were upgrade In addition, facilities, such as the access control centers and security office buildings, were very clean and ;well maintained. _The security organization was also assigned additional ^ main-tenance assistance, such that the maintenance staf f was comprised of al full-time I&C staff consisting of three supervisors and fifteen technicians, three door hardware specialists, three engineers, and one planner. These-technicians and specialists were instrumental in maintaining properly functioning and effective security systems and equipment. Repair of security equipment was generally accomplished within hours, and the _ repairs were effectively prior- -itized by the security superviso Planning- and installation of system up-grades were effective, appropriately controlled and well thought-ou Plant and corporate management continued to be actively involved in security matters as evidenced by excellent support for and cooperation with the security program upgrades and enhancement Plant and corporate security management personnel also . remained active in committees and organizations engaged in nuclear : plant security matter This involvement indicated interest in the program and support from upper level managemen The security manager and his staff were well trained and qualified security professionals with an excellent understanding of nuclear plant security objec-tive It was also evident that the security supervisors had been delegated the necessary authority and discretion to ensure that the program was being carried out effectively and in compliance with NRC regulation L
, a 25 The NRC-required annual audit _of the security program was performed by Niagara-Mohawk's Safety Review and Audit Board, augmented by security supervisors from other_. nuclear power plants. The audit was comprehensive in scope and dept Niagara Mohawk continued to conduct self-assessments of the security program utilizing _ experienced. plant' security supervisory personnel and consultant Corrective actions on findings and recommendations identified during-the audit
:and :the self-assessments were prompt and effective, with adequate follow-up to ensure their proper implementation. The NRC continued to believe that the ,
self-asstsment program that Niagara Mohawk established has been a major d contributing - factor - in Niagara Mohawk's excellent enforcement history and ' performanc t
- A review of. Niagara Mohawk's security event reports and reporting procedures found' them to be well understood by -security supervisors and consistent with - NRC - regulations. One event requiring a prompt report occurred, involving an -
unescorted visitor in the protected are Niagara Mohawk took prompt and .l appropriate. compensatory action and followed-up with effective corrective measures to prevent recurrenc The security training program was administered by a highly qualified, full-time i
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staff. .The program was consistent with and exceeded the requirements of the NRC-epproved Security Force Training and Qualification Plan. Security person- ! nel _ were provided with a modern and well maintained physical fitness room, a j
. simulator for training. alarm station operators, and state-of-the-art training :
aids for hands-on training with excellent lesson plans. Security management
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also' instituted an aggressive tactical training program for the armed security force member In general, security force members were very knowledgeable of a their post duties, procedures, and overall responsibilitie The Security, Contingency and Training and Qualification Plans were reviewed, a'nd no changes were noted that could have resulted in a degradation of Niagara !
-Mohawk commitment "
Summary Niagara Mohawk continued to maintain a very effective and performance-oriented
. program,.and the security personnel performed up to the established high stand-ards. The efforts to upgrade the operation and reliability of security systems were commendable and demonstrated Niagara Mohawk's commitment to maintaining a L very effective and high quality progra The security training program was effective, very well administered, and continually improved. Management sup-port was clearly evident in all areas of the day-to-day security operations and in the planning for upgrades and enhancement III. Performance Rating Category 1 III . E .~3 Recommendations None
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II Engineering and Technical Support
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The previous SALP report rated Engineering and Technical Support as Category 3.- There had been limited progress in resolving previous problems in the following areas: poor engineering management oversight of contractors; inconsistent per-formance by the engineering staff; slow resolution of_ design deficiencies; and significant deficiencies in the implementation of the training progra III.F.1. Analysis Overall, during this assessment period, Niagara Mohawk improved the overal 'L quality of engineering work, both design work and plant support activitie The: engineering staff resolved the previously identified design issues in an acceptable manner and improved the engineering support at the sites by- intro-ducing system engineers and increasing the site engineering group staff. Some engineering work needed improvement in quality or timeliness, . including longer-term initiatives. Control of contractors improve Niagara Mohawk management demonstrated a determination to improve their per-formance with the following: a program to address and resolve -the underlying
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root causes of identified management deficiencies before the restart of Unit 1; e a program to integrate and coordinate engineering activities; a multi-year program to recover and reconstitute the Unit 1 design basis; and a budget with - significant resources for-implementation of the above program Several 125 vde system design deficiencies had been identified by Niagara Mohawk during the previous SALP period. Initially, the resolution of these deficiencies was slow due to inef fective management attention. However, the technical deficiencies were ef fectively resolved when' appropriate management attention was provided. Niagara Mohawk assigned a task force to coordinate the necessary engineering disciplines. The establishment of a task force appeared to be effective in. resolving this issue and other Unit 1 issue Notable improvements were observed in design change activities. A number of corporate engineering activities and projects were conducted in a professional' manner, but some weaknesses in other ef forts were reflective of poor engineer-ing support. Examples of good engineering work included the establishment of IST and ISI task forces to support all activities required to implement the 10 year interval of these programs; effective implementation of a program to resolve tructural integrity concerns in the Unit I large bore pipe supports; a-thorough evaluation of engineering analysis of the Unit 2 modification to inhibit the feedwater runback signal from the reactor recirculation controls system; and thorough evaluations of the Unit 1 fuel zone level common tap issue-and the ' issue of average power range monitor (APRM) flow bias circuit isolation from computer circuits. Additionally, numerous specific design issues at Unit I were resolved in a thorough, acceptable manne ,
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, 27 However, poor performance in other areas demonstrated inconsistency ' in the
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ability of the corporate engineering staff to deliver quality-wor Examples of these included: Site Operations Review Committee (SORC) rejection of a Unit 1- emergency ventilation design modification due to poor engineering conceptual design review, inadequate independent design review and lack of proper engi- .
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r,t -ing coordination; inadequate initial engineering justification for con-
.tinued use of Satin American trf p coils for circuit breakers at Unit 1; inade-quate review to establish harsh environmental qualification for several splice-assemblies at Unit 1; and relief requests' for Unit 1 ISI programs submitted to NRC in piecemeal fashion with poor justification for some requests. In these examples of poor performance, engineering management involvement appeared to have been less than the management involvement in the examples' of better work, The previous SALP identified problems with implementation of the training pro-gram 'for the nuclear engineering 'nd licensing staff. The original program, which was~ established in late 1986, was not implemented due to insufficient classroom: space ano a shortage of instructors. In res nesses identified -.by the NRC and Niagara Mohawk QA,ponse specifictotraining specif tcfor weak-nuclear engineering and licensing personnel was begun by Niagara Mohawk in March 1989. The program covered 13 specific areas selected by Niagara-Mohawk -
based on experience and industry guidelines and was planned for completion-in March 199 Following this training, a broader based training program was planned for 19S0 and beyond. Overall, Niagara Mohawk made progress in provid-ing the needed training for the engineering staff. However, additional manage-ment.-attention is needed to assure timely implementation of the full scope of the training progra To enhance plant safety and provide better direct plant support, Niagara Mohawk established the Integrated Priority System (IPS) with six levels of prioritie .The IPS applied to- planned work in the nuclear division and support' organi::a-tions. All safety significant projects are Priority 1, and other work projects which affect safety systems are Priority 2. The effectiveness of the system was evidenced by the fact that all Priority 1 and 2 projects were on schedule and were reviewed on a weekly basis. The system for assigning priorities = to plant. modifications appeared to have the proper safety perspectiv Niagara Mohawk introduced system engineering groups to both units and-approved additional positions in the site engineering group. These additional engineer-ing resources improved the support of the plants and provided a closer working relationship between the engineering and operations personnel. Al so , improved communications between engineering at Salina Meadows and onsite engineering was established by the presence of site engineering managers in the daily status meeting and telephone conference calls to discuss the plant status and design - modifications. Examples of this improved support included good engineering work on the Unit 2 main feedwater pump repairs, Unit 2 circulating water system modifications, and Unit 1 core spray system testin . . . . . . . . _ _ _ . . . _
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However, in some instances,. these site engineering resources were not effec-tive. Specifically, Unit 2 circulating water system modifications were impro-perly initiated prior to completion of the safety evaluations, _ and modifica-tions to the EHC system. introduced a ground, which was later implicated in an EHC malfunction and subsequent reactor scram. Also, these engineering -groups ' were slow in addressing problems regarding poor isolation valves for acid addi-tion to. Unit 2 circulating water and_ resolution of long standing temporary modifications. The acid. addition valves resulted' in an unplanned shutdown due high copper concentrations in the circulating water system Engineering management improved oversight of contractors. The of fsite engi-neering' group at Salina Meadows relied heavily on contractor personnel to sup-p port the engineering work;. more than 50*4 of the ' engineering staf f was from various contractor organizations, provided on an as needed basis. Based on the generally' acceptable quality of the work, it appeared that these personnel had been- properly supervised. Further, site engineering management assumed more responsibility for the control of contractors at the site, as evidenced by 'the well structured and well executed ISI, IST, and commercial grade equipment dedication program The_ licensing group's understanding and interpretations of Technical Specifica-tions (TS) were generally sound and conservative. However, one TS interpreta-tion involving the Unit 2 high pressure core spray keep fill system was judged-to be nonconservative by NRC and operations management, and subsequently was not used by operation Summary Engineering' and technical support performance generally improved. Much good engineering work occurred, but some- engineering work needed improvement in ., timeliness and quality. Those technical issues which received increased man-agement oversight were generally resolved more expeditiously and were of better quality than issues without such management involvemen III. Performance Rating Category 2 . III. Recommendations None
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'III.G- Safety Assessment / Quality Verification e
During the previou> assessment period, Niagara Mohawk performance in. the area of Safety Assessment and Quality Verification was observed to be inconsisten . This functional area was rated Category 3 with an improving trend. Numerous ' strengths and weaknesses were noted, including identified leadership defici- ';
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l ~encies had begun to be corrected, problem identification was better, and event ' m < evaluations were more thorough, but responsibilities remained poorly defined,: corrective actions were weak, and review of industry operating experience was .
. inadequat The SALP Board cautioned Niagara Mohawk to ensure that increased "
emphasis on Unit 1 did not result in insufficient attention to problems at Unit III.G.a. Analysis Overall, during this assessment period, there was a better approach to assuring qua'"y, but limited progress was demonstrated -in producing consistent, ' good rr -t In general, the Niagara Mohawk programs to improve overall perform-(, embodied in the Restart Action Plan and Nuclear Improvement Plan, ,~ '
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appeared to be comprehensive, and both conceptually and functiondly adequat This was evidenced by the success, although sometimes marginal, of the programs established to address the five underlying root causes, o Significant ef forts were expended to upgrade the Niagara Mohawk approach to assuring the quality of operation This effort was guided by the Restart-Action Plan (RAP), which had analyzed the previous management deficiencies and determined the underlying root causes (URCs). As part of the RAP, new' stand-ards of performance for Niagara Mohawk management and working level personnel were. established. Considerable evidence was found during this assessment period that Niagara-Mohawk was striving to conduct its activities in accordance-with the revised standards. Specifically, the implementation of the RAP was
: evaluated by - the NRC's IATI midway through the rating period. The team con-cluded that there were no fundainental flaws in the RAP. Clear improvement was noted in three of the five underlying root causes of past management defici-
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-encies. These three URCs were goal setting, organizational culture, and team wor Performance in the URCs of problem solving and standards of performance /
self-assessment was weak, but showed some signs of improvemen .. Performance in the functional areas of Security and Emergency Preparedness con-tinued to be at the established high level Further, Niagara Mohawk demon-strated some progress in improving overall performance in the remaining func-tional areas. Many new initiatives and programs met with success or demon-strated a commitment to long term improvement. For example: the inservice inspection and inservice testing programs at both units; the large bore pipe support examination at Unit 1; improvements in Unit 1 operator E0P knowledge and usage; the development of computer-based TS surveillance matrices at both units; a detailed surveillance test review at Unit 1; and the staffing of systems engineers at both units.
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In addition, there: were instances of behaviors or actions which demonstrated Niagara Mohawk's implementation of the enhanced standards of performanc For i_nstance, a Unit 2. station shif t supervisor (SSS) was observed declining to implement - a temporary modification for which no safety evaluation had been done. A decision was made to replace all of the Satin America Corporation cir-cuit breakers prior to reload rather than place reliance on a justification for operation, ' Also, operators appropriately displayed a questioning attitude and identified several surveillance tests- that- needed improvement, Further, Niagara Mohawk. identified a design error in the Unit 2 service water actuation logic and proceeded cautiously in the evaluation and resolution of the error, In contrast to the above examples of improved performance, numerous events reflected continued poor performance, and some new initiatives were poorly-implemented, For example: unsatisfactory Unit 1 initial reload systems walk-down procedure implementation; poor progress in reducing the numerous Unit 2 control room annunciators; numerous maintenance related events at Unit 2; poor performance on Unit 2 requalification examinations; slow resolution of 125 VDC system concerns ' at Unit 1; and unsatisfactory progress in reducing the large number of inoperable effluent and process radiation monitoring systems at both units. These examples of good and bad performance demonstrated the inconsis-tency in overall performance and the broad range of recent gains and continued - performance concerns, However, an overall improving trend was note Niagara Mohawk's Nuclear Division management staff was relatively unchange Two significant changes later in the period were the addition of a Unit 2 deputy station superintendent and a new director of regulatory compliance. The addition of a deputy station -superintendent at Unit 2- was viewed as a positive step to more effectively deal with the numerous technical and personnel related issues at Unit 2 and to provide more dit ect, senior line management oversigh Increased staffing -on the Unit 1 operations events assessment group and Unit 2 independent safet.y engineering group reflected a Niagara Mohawk commitment to reduce the industry events review backlog and become more proactive, Simil-arly, the development of the independent assessment group, reporting to the Executive Vice President, reflected a Niagara Mohawk commitment to improve self-assessments, The overali ef fectiveness of these recent changes could not be measured during this SALP period, but demonstrated good initiatives to improve station performanc The onsite regulatory compliance group continued to b2 an asset to the day-to-day administration of operation of the station, Licensee Event Reports and Special Reports processed by this group were generally well written and timel ' The Nuclear Commitment Tracking System managed by the group appeared to func- ! tion properly. A new initiative under the cognizance of regulatory compliance was the Unit 1 Technical Specification (TS) Surveillance Matrix Program. This new program appeared to have gotten started well, with TS preparation for core reload in January 1990 properly verifie . . 31
! ' Licensing issues were evaluated with varying degrees of effectiveness for dif-ferent. issues. The' engineering ~ and licensing organizatior.s appeared to: have difficulty in addressing needs beyond those necessary.to support Unit I restart -
and the-upcoming Unit-2 refueling outage. This was apparent from the exten-sions to complete' the responses to NRC generic letters, on issues such as the hardened wet well vent, several TMI action item related _ Technical Specif1;a-tion changes, the instrument air system for Unit 1, and Technical Specification operational mode changes on Unit 2. On the other hand, Niagara' Mohawk provided virtually all license amendment submittals to-the staff sufficiently in advance
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of the requested action to allow a timely staff review. Niagara Mohawk gener-ally provided advance notice to the NRC staff of expected schedule delays and their basis. Submittals ranged from marginal to detailed and thorough, also indicative of occasionally strained resources or insufficient management oversigh Onsite (Site Operations Review Committee) and offsite (Safety Audit and Review Board) review committees ' have provided adequate oversight of licensed activ-
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ities. The efficiency of- the SORC and SRAB meetings appeared to be improving with better planning and preparation by the committee members and support staffs, although the 50RC occasionally got bogged down in detailed technical review Recent committee safety reviews appeared to be thorough and conservativ The quality assurance department was generally effective. The QA operation-surveillance program was well structured and effectively implemented and pro-vided relevant performance data to station managemen The QA audit group was severely . understaffed early in the period, and the training program required improvement. Lattr in the p: Mod, a sample of. QA audits appeared to serve effectively as one of the methods to b ntify problem Summary The functional areas.of Emergency Preparedness and Security continusd to main- i tain the high standards of performance reflective of sound programs, good implementation and aggressive management oversight. The remaining functional areas again demonstrated inconsistency in performance, but an overall improving trend. There was an apparent turning point in Niagara Mohawk's approad to a ssurieg ' quali ty, and performance improved in some areas. The improvement appeared to be ' based on better problem identification,- more critical self-assessment, and the institutionalization of processes necessary to sustain good performanc i III. Performance Rating Category 3 Trend: Improving i III. Recommendations None
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(p 32 IV. ' SUPPORTING DATA AND SUMMARIES IV.A Licensee Activities a During 'the majority of this assessment period Unit I remained shutdown' and :defueled. In. January 1990, the core was reloaded following an extensive rever-ification -of . systems and procedure readiness by the station staf Reload activities were conducted competently and professionally' with only one . minor error; By the end of the assessment period in February 1990, the unit was preparing for restart, ,
Aththe beginning of this assessment period, Unit 2 was in a prolonged mid-cycle- ,
-maintenance and surveillance outage due to the necessity to repair and retest a number'of containment isolation valves which failed their local leakage' rate test Following the completion of this outage the unit was operated for a unit record 135 consecutive days between April and_ September 1989. Following this record run and planned maintenance outage -the unit suffered a number of - scrams and forced shutdowns due to personnel errors and equipment problem These ' specific events are discussed further in Sections II.C. and III.A. of this repor .
IV.B Direct Inspection and Review Activities Three NRC resident inspectors were assigned to the site throughout the assess-ment period. Region based inspectors performed routine inspections throughout the assessment period. Several NRC team inspections were conducted in the following areas: Unit 1
-. Restart Pane; review of Restart Action Plan --
Licensed Ogerator Requalification Program review
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Operator Proficiency with E0Ps followup _(I) >
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Operator Proficiency with E0Ps followup'(II)
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Annual EP Exercise (full Region I participation)
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Allegation followup
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SSFI followup
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Special_ team to assess potential harassment and intimidation
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Self-Assessment / Readiness for Restart Report review
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Augmented Inspection Team - Radwaste Building 225 Spill
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Integrated Assessment Team Inspection Unit 2
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Operator Requalification Examination
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Operator Requalification Reexamination
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IV.C Enforcement Activities [-
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Unit:1-f- Number of Violations 'by Severity Level i."y h< w = '
. - . Functional Area V I III II- I Total Plant Operation I 1 2 SRadiological Controls 1 1
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Maintenance / Surveillance 1 1 j Emergency Preparedness 0 i< Security' 1* 1-M Engineering / Technical 2 2
'~g . Support ,!s Safety Assessment / Quality 1 1 , Verification in Totals 6 2 8 i
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.*Also issued to Unit 2 but not included in Unit 2. table-
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f Number of Violations by-Severity Level I Functional Area V IV III II .I . Total-
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Plant Operations 2 2- 1 Radiol _ogical- Control s - 0 Maintenance / Surveillance 1 1; Emergency Preparedness 0 'l Security- 0 J'
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Safety Assessment / Quality Verification 1 1 _;
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, 34 IV.D Licensee-Event Report Causal Analysis Unit 1-This analysis includes LERs 89-02 through 89-17, 89-19, and'90-01,=a total ~of 18 report Functional Area
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.A B C D_ E X Total-Operations ~ -6 1 2 9 Radiological: Control s 1 1 2 Maintenance / Surveillance 1 3 4 Emergency _ Preparedness'-
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' Securi ty-- - . 0 Engineering / Technical Support 2 1 3 Safety Assessment / Qualit O Verification '
Totals- 10 2 0 6 0 0 .18
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Cause Codes * 1 Type of Events A .- ~ Personnel _ Error . . . . . . . . . .... 10 B; Design / Man /Constr./ Install . . . .... 2 ,_ ' External'Cause . . . . . . . . . .... 0 ' ~ Defective-Procedure . . . . . . . .... 6 . Component Failure . . . . . . . . .... _ Total 18
* Root causes; assessed by;the SALP Board may differ from those listed in the LER-The majority of the. LERs' were the result of various personnel errors. Atten-tion-to detail appeared to be a major contributor, t
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Thisfa~nalysis= includes LER 89-08 through'90-04,*a total-oft 39 report ' r 4
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{ Furictional Area .A B C)-D E: X Totali
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. Operation :2: 7 1- 19 :- d Radiological = Controls l: 2: l' 1- l' 5- ,
: Maintenance / Surveillance' 5 ~2; - g f: Emergency.PreparednessV 0 :
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I Totals z 17 4 0 8 8 2 39- , , Cause' Codes * g ! Typev of' Events; .
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L Personnel l Error ...... . . . . . . . . . . 17
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E.- Component Failure . . . . .. . . .. ..,. 8 ; Xi Other . . . .-. . , . . . . . ... . . .
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J-Total =39: "
,.g * Root causes assessed by the;$ ALP Board _ma'y; differ from-those-listed in;the LER .
j There werel25 fewer LERstissued this period:than-during!the' previous assessment!
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. ' 7 period.. .However,1there was still a large ' number of events caused by. personnel 1 t error,0. indicating ~ that ?the ' corrective actions taken for similar problems 11ast'
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w < ,, - assessment period were . inef fective. The majority..of .the personnel errors were ' "l' rooted in in' attention to detai ' 3:7-
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ATTACHMENT 1 i t i . . . .
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'SALP' Evaluation Criteria
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~ Licensee . performance' is ' assessed in selected functional areas, depending 'on L whether - the facility is under construction or operationa Functional areas -
normallyE represent areas; significant to c nuclear safety and = the. environmen Some~ functional' areas- may ' not bei assessed because of little or no licensee ~
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~ activities or: lack of-meaningful. observations. Special' areas may be added to.' l highlight significant observation .; -cThe following evaluation. criteria were used, as applicable, ;to assess each i functional l area: " ' Assurance of. quality,. including management involvement and control; 1 = Approach to' the resolution of technical . issues from a safety standpoint; > ~ Responsiveness to NRC initiatives; Enforcement history; perational 'and construction events (including response to, analyses -of, O reporting of, and corrective actions for);
o 6.. : Staffing (including management); and
' Effectiveness N training and qualification program .c J0n the = basis- of the NRC assessment, 'each functional area evaluated is rated
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accordin'g to:- three . performance categories. The -definitions of these ' perform- :l
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ance categories are as follows: z}
} : 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-requirements. Licensee resources are ample and effectively used so:that a high '
11evel of plant and personnel' performance is being achieved. Reduced NRC'atten-- ' tion'may.be appropriate.' ! Category'2. . Licensee management attention to and involvement in the perform- l ance- of nuclear safety or safeguards activities are good. The licensee has '
" attained a level of performance above that needed to meet regulatory require-ments. Licensee resources. are adequate and reasonably allocated so that. good =
plant and personnel performance is being achieved. NRC attention may be main- , tained at normal levels, i l
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, # Attachment 1= 2 ,
Category 3. ' Licensee management attention to or involvement in the performance of nuclear safety or safeguards activities are not sufficient. The-licensee's performance does not significantly exceed that needed to meet minimum regula-
- tory requirements. Licensee resources appear to be-strained or not effectively 'used. NRC attention should be increased above normal level The SALP Board may assess a functional area to compare the licensee's perform-ance during the last quarter of the assessment period to that during the entire' -
period in order to determine the recent tren 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 f of the assessment perio ;t
- A trend is assigned sonly when, in the opinion of the SALP Board,- the trend is significant enough_ to be considered indicative of a likely change in the per- ,
formance estegory in the i. ear future. For example, a classification of "Cate-
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gory 2, Improving" indicates the clear potential for " Category 1" performance in the next SALP perio It should be noted that Category 3 performance, the lowest category, represents acceptable, although minimally adequate, safety performance. If at any time the NRC . concluded that the Llicensee was not achieving an adequate level of safety performance, it would then be incumbent upon NRC to take prompt appro-
.priate actions in the interest of public health and safety. Such matters would be dealt with independently from, and on a more urgent schedule than, the SALP '
proces t t
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/ Yacee,_ \ UNITED STATES
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NUCLEAR REQULATORY COMMISSION
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,. - 'r 476 ALLENDALE ROAD g' s * * ' [ ' KING OF PRUSSIA. PENNSYLVANIA 19404
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Docket Nos..: 50-220 ; 50-410 liAY 0 71990 Niagara, Mohawk Power Corporation-ATTN: Mr. J. Endries 4 President- ! 301 Plainfield Road 1-Syracuse, New York ; 13212 ' * Gentlemen: Subject: Systematic Assessment of Licensee Perfo+mance ($ ALP): Initial L Report Nos. 50-220/89-99 and 50-410/89-99 ' / ( h An NRC SALP Board reviewed and evaluated the performance ~ of your, Nine Mile Point Units 1 and. 2 for the period of . March 1,1989 to February 28, 1990. The results of this assessment are docurented in the enclosed Initial SALP Report.
l- , A meeting will be scheduled to discuss t'ais assessmen i At the SALP meeting you. should be prepared to discuss our assessment and your i plans to improve performance. The meeting is intended to to be a candid dia-logue in which any. comments you 'may have regarding nur report are discussed.
Additionally, you are requested to provide written comments on our assessment within 30 days af ter the_ meeting with particular emphasis on your planned cor- r , rective actions in functional areas rated Category 3.. l We appreciate your cooperatio ! D
Sincerely, [ iffd Thomas T. Martin
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-Regional Administrator i
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Enclosure: Initial SALP Report Nos. 50-220/89-99 and 50-410/89-99
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.; ' Niagara Mohawk _ Power Corporation 2 7g cc.w/ encl:
* W. Donlon, Chief Executive Of ficer and Chairman of the Board L. Burkhardt, Executive Vice President, Nuclear.0perations GT Wilson, Senior Attorney lJa Perry, Vice President,_ Quality Assurance C. Mangan, Senior Vice President', Nuclear Generation C. Terry,' Vice President, Nuclear Engineering and Licensing - -
J. Willis,_ General Superintendent
.K. Dahlberg, Station Superintendent, Unit 1 R. Abbott, Station Superintendent, Unit 2 '
M. Colomb,. Unit 2 Superintendent, Operations
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W. Hansen,' Manager, Corporate Quality Assurance C. Beckham, Manager, Nuclear Quality Assurance Operations M. Peifer, Manager, Nuclear Service C. Stuart, Manager, Nuclear Projects Connor & Wetterhahn Director, Power Division, Department of Public Service, State of New York J. Warden, New York Consumer Protection Branch State of New York, Department of Law
. ,... Public Document Room (PDR)
local Public _ Document Room (LPDR) NuclearSafetyInformationCenter(NSIC) NRC-Resident inspector State of New_ York, SLO Designee
.K. Abraham, PA0 (23 copies)
Chairman Carr
. Commissioner Roberts Commissioner Rogers . Commissioner'Curtiss Commissioner Remick
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* ENCLOSURE NMM
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. NINE MILE PotNT NUCLEAR STAT 10N/P.O BOX 32 LYCOMING, N Y,13093/ TELEPHONE (315)343 2110 - ,
?!s * NMP67591-j b July.2, 1990 , .
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? United States Nuclear. Regulatory Commission !
; Attention: Document Control Desk i ~ Washington, DC 20565 1'
s RE: Nine Mile' Point Unit Nine Mile Point Unit 2 l Docket No. 50-220 Docket No. 50-410 l L ~DPR-63- NPF-69 i L_.^4 Systematic Assessment of Licensee Performance ! l
' -Gentlemen:
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' This. letter-transmits Niagara Mohawk Power Corporation's response to L 'the NRC's Systematic Assessment of Iicensee Performance (SALP): Report l -- dated May 7, 199 These written comments incorporate the. oral ,
responses and discussion provided during our , meeting of June 14, 1990, ~
;at'the Nine Mile Point site.
.. We are ini basic agreonent with the report's findings and concur that ,
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improvements were sti .1 necessary .in key areas of both nuclear unit , L c at the conclus' ion of the, period covered by the SALP report.. As you'are
- - aware, . many of. the enhancements and corrective actions which iwere j '
' undertaken, both in reference to the specific matters identified-in e the-SALP and in the implementation of the Restart Action Plan and the i, Nuclear Improvement Program, occurred too-late to be fully effective during the: assessment perio However, significant results'from these measures are now eviden '
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Equally important, and certainly encouraging to us, is the NRC Staff's: 1 observation that our Restart Action Plan is working at Nine Mile Point ! E Unit 1,'and that greater management involvement is making a difference at both units. We believe the Restart Action Plan was responsible for the better problem identification, more critical problem evaluation and self-assessments, and the establishment of better programs and .,
-standards to promote and sustain good performanc This approach '
appears to be responsible for the improved results noted in the engineering-and surveillance areas, and the generally improving trend in most other area ,
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United July 2, States 1990 Nuclear Regulatory Commi ; ssion In summary, the NiagaraofMohawk's management t highest standards excellence
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[< aspects of operations and goa will takeon the neces. eam a consistent is in basis committed all t ' ! sary actions to reach that
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\b ; Very truly yours, \
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. y N" L. Burkhardt, III -
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Executive Nuclear Vice President operations i i cca Reg'ional Administrator, Region I
. -Mr. R. A.-Capra, Director i
Mr. Robert E. Martin, Project Manager ! M W. Manatament Records A. Cook, Senior Resident Inspector i
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SPECIFIC COMMENTS RND RESPONSE TO RECOMMENDATIONS l OPERATIONS
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Unit i I Niagara Mohawk was pleased to note NRC's recognition that Station management has made substantial progress in addressing and corre ting concerns from the previous SALP raport (i.e., for the period March 1, 1988 to February 28, 1989), and concurs with NRC's assessment of performance during the period covered by this.present SALP repor The Cotrpeny's own assessment is that this latter period was characterized by inconsistent performanc The SALP report appropriately identifies a number of areas in which significant
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improvement was evident, such as the Licensed Operator Requalification l Program, management attention to licensed operator training, increased Operations Department responsibility for the quality of training, t Operator use of and proficiency with the Emergency Operating Proced Jres (EOPs), licensed Operators' improved support of maintenance and l
' surveillance activities, and other instances of licensed operators demonstrating improved performance.
' Operations Department management was also credited with having achieved a better approach to operations in certain areas. Nevertheless, Station management concurs with the i
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SALP findings concerning specific weaknesses cited in the report and 1 has taken aggressive corrective actions in each cas For example, in the area of personnel performance (page 8, SALP report):
* , Crew communicatJons discipline has been improved by the- [
implementation of a communications protoco In addition, communications practices are now being routinely evaluated during simulator trainin * The roles of Reactc.r operators (Ros) have been standardized by ' an Operations Instruction on use of EOPs that directs the Station Shift Supervisor (SSS) to assign the Operators to
.- specific panels, and provides guidance on the role of the chief Shift operator (CSC) during emergencies. Simulator training continues to stress th a standardized approac .
Four applicable procedur's have been revised to strengthen Operator response to e1Ntrical problems, and additional training on electrical distribution and circuit breaker interlocks has been provided to operator In addition, additional emphasis has been placed on proper assessment of
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electrical powerboard malfunctions during simulator training,
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* . To help ensure that all available indications will be used for diagnosis of events and expedite recognition of plant trends, additional guidance in these areas is now provided by the E0P User's Guide. In addition, performance in the diagnosis of events is now being evaluated by use of guidelists during simulator trainin *
A formal self-assessment program has been implemented, which includes detailed guidelists for evaluating effectiveness of classroom, simulator and on-the lob trainin This program should improve management's early recognition of Operator problems and/or generic weaknesse . Inadequate work practices and communication eficiencies were identified as the causes of the accidental flushing of condensate domineralizer to radioactive waste processing (page 8, SALP report). As a result, procedural improvements have been made and verification of markup points is now required prior to reissue of a markup. In addition, the importance of clear and accurate communications has been emphasized in training sessions and department meeting . . All shifts have received training in the area of procedural
. adequacy and compliance so as to prevent a recurrence of the procedural and personnel errors which led to Reactor Building Emergency Ventilation System initiations (page 8, SALP report) .
Personnel are now required to stop activities when procedural' deficiencies are identified and take corrective actions to resolve the deficiencies before continuin Two operations procedures were revised to correct specific deficiencie In a dditi r:,n , applicable training material was revised, and a L.. sons Learned Transmittal was generated to inform operators
'of these event ' * 'A plant impact statement on all Markup Request Forms is now required prior to submission to the control Room; an independent review of potential plant impact is now required by both operations and the markup man; and, the Chief Shif t operator and the Station Shift Supervisor responsibilities with respect to markups have been clarifie These actions should correct the situation with respect to Reactor Building Emergency Ventilation System initiation due to improper tagging control (page 8, SALP report).
Fuel Handling Procedures were revised to specifically recognize the applicable Technical Specification requirement relating to the Source Range Monitor (SRM) bypass function (page 8, SALP report). Also, a Shift Check Procedure was revised to assure that the SRM Technical Specification's requirements are checked once per shift. In addition, operations management met with all shifts to discuss the Lessons Learned Transmittal, and corrective actions were taken to correct the tagging deficiencie I
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8 ALP RESPONSE 4 JULY 1990
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Addressing the valve misalignment of the Reactor Building Closed Loop Cooling System (page 8, SALP report), a list of valves identified as non-conventional is being developed to aid operators in valve lineups, and the operations' directive on markups was revised to minimize the potential for valve misalignment due to application and restoration of equipment markup .
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With regard to deficiencies noted during the initial set of reload system walkdowns (page 8, SALP report), the lessons learned regarding improvement of management oversight and implementation- of management self-assessment have been incorporated into the Walkdown Procedure and utilized during the reperformance of system walkdown In addition to the foregole a number of other actions have been taken to provide greater managt At oversight of daily operations and more
- effective overall management contro These include
* Management tracking and control of overtime (page 8, SALP report) have been improved by the issuance of a new , Administrative Procedur * Licensed operators' medical examinations (page 8, SALP report)
cre now scheduled quarterly and a new procedure is being developed to help management assure that these examinations are : performed in accordance with the ANSI /ANI - 3.4 Standar * Management conducted meetings with Operators to explain the ! " systems approach" to ttaining for requalification examinations (page 8, SALP report), and to discuss a new examination proces Weekly examinations using questions from the exam bank are now included in the training progra * Management has acted decisively to correct deficiencies noted ; in connection with the SRM incident (page 8, SALP report). The ; manner in which investigations are conducted has been i strengthened by immediately convening a fact-finding meeting and involving the Incident Investigation Group (IIG).
- A number of actions were taken by management to improve the ef fectiveness of self-assessments (page 8, SALP report) . These actions included: (i) development of detailed guidelists for participation by all assessingmanagement operations operationspersonnel activities,in(ii)
the self-assessments, and (iii) periodical assessment of the effectiveness of the self- , assessment effort * organization changes were made to enhance management oversight of day-to-day operations, which included: (i) reassignment of a Unit 1 SRO-licensed manager as Assistant Superintendent of operations in charge of operations outage coordination; (ii) reassignment of an Assistant Superintendent of operations as L SALP RESPON8E 5 JULY 1990
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full-time department training coordinator; (iii) reassignment of a rotational SSS to the Training Department for training duties; (iv) assignment of a rotational SSS as Work Control Center Technical Reviewer of work requests; and (v) reassignment of the Assistant to the Superintendent of Operations as Work control Center Operations Planner / Schedule Collectively, the foregoing corrective actions and procedural and organ'.zational enhancements greatly strengthen operational capability of che Unit and provide for more effective management control, particularly in the oversight of daily operations, to help achieve the company's goal of safe, error free, operatio ,, Unit 2 Niagara Mohawk concurs with the SALP assessment of Unit 2 Operations,
. including the finding- that performance was inconsistent for the report perio Many of the factors which contributed to this inconsistent perfornance are discussed below, along with identification of corrective actions and other ennancements, where appropriat * .
The SALP report identified events attributable to personnel errors (page 10) which have been addressed as follows: For those errors associated with inadequate control of system and component configuration, a significant contributing factor was lack of direction in the administrative program which addresses control of components and systems placed in an off-normal conditio As a result, changes were made to the Administrative Procedures to require that when components or systems are discovered or placed in a condition other than as described in the appropriate procedures, such components and systems must either be " tagged out" via the equipment markup process, or appropriate changes to procedures must be immediately implemented to reflect the altered configuratio In either case, the duty shift Supervisor must be informed of the situation to ensure that appropriate controls have been establishe Another significant contributing factor to the personnel errors was a lack of direction in the Administrative Program to specify responsibilities .for plant impact review of work activities including equipment markups. Programmatic changes have been instituted, initially by administrative directive and revisions to Operating Department Instructions, and later by revisions to Administrative Procedures, to delineate responsibilities of the working department, the Control Room Operator and the Shift Supervisor to develop, verify and approve the plant impact of work to be performed on equipment markups that are to be hun The program now in place requires that for corrective and preventative maintenance activities, a " Work In Progress" form must be included with all work packages to indicate specific I
8 ALP RESPONSB 6 JULY 1990
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plant impact. This is reviewed by a qualified operations person as well as by the shift Supervisor prior to performance of the wor For surveillance activities, the applicable procedure must contain a specific plant impact statement which is reviewed by the Shif t Supervisor prior to performance. For equipment markups, plant impact is researched and determined by a !
' qualified operations person, double verified, and reviewed by both the chief Control Room Operator and Shift Supervisor prior to implementatio Another programmatic improvement made was the strengthening.of the Post Maintenance Test (PMT Program. Failure to perform a proper PMT resulted in a compo)nent being declared operable in accordance with the Technical Specifications without having been properly restored for standby servic This would have been prevented had a PMT been performed. Included on the Work In
, ' Progress form is a section to specify post maintenance testing requirements. These are established by the working department i and reviewed by a qualified operations perso Prior to i returning a component to service, the PMT results are reviewed by the Shift Supervisor to assure operability requirements are
* ' satisfie There have been no incidents of inadequate or improper PMT maintenance testing of systems or components since this programmatic improvement was mad Eliminating personnel error is a high priority matter with Ntagara Mohawk.
' Accordingly, Niagara Mohawk has taken several further actions to eliminate personnel error: !
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l (i) Increased management oversight and direction of Operations activitie a. Operations management has reviewed events in 1989 and l l conducted special meetings in November to focus ) l specifically on personnel error I b. A Deputy Station Superintendent has been added to the ! plant etaff, and the vacant position of Assistant : Superintendent of operations has been filled. These l additions result in increased management oversight, c. A Senior Monitoring And Recognition Tours (SMART) program provides greater management assessment of ,
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plant activitie (ii) Increased emphasis on personnel accountability, a. Periodic Operations management meetings with Station I Shift Supervisors and crews stress personal accountability and management expectations of error ] free Operator performanc '
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., , I SALP RESPON8E 7 JULY 1990 !
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b. Maintenance management meetings with crews. enforce ' procedural complianc ! c. Greater use of remedial assignments brings about improved performanc , d. Disciplinary action is employed when appropriat '
(iii) Development and implementation of Operations Department '
Instructions, in the areas listed below, which establish , standards and expectations: a
a. Self-assessment practicas b. Tour requirements and reports by SSS and ASSS c. Improved communications d. Good practices for Operators (iv) Expanded goals for 1990 that incorporate the goals and '
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philosophies of the Divisio . , (v) Improved training programs, including the development of - ! ! the Systematic Approach to Training (SAT) - based requalification program for licensed Operators, and implementation of a comprehensive on-the-job training-progra "
(vi) Development of an Incident Inve stigation Group to assist *
in root cause determinations and to develop trends and analyze plant events, i (vii) Procedure improvements. The procedures are being revised ' to a new Site Writer's Guide for improvement in human
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factor usag This will reduce the possibility of - personnel erro i l."
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Management has implemented extensive changes to enhance the
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Operator Requalification Program (Page 9, SALP report), obtain 4
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l' meaningful feedback and improve examination results. In this-effort, appropriate " lessons-learned" from Unit 1 were extracted to improve the Unit 2 progra Some of the specific changes incorporated include: l (i) Operations Department Instructions 'nre written and j" incorporated in the requalification program, covering -
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roles, responsibilities and communications. A period of training was pursued for all Department personne ' Significant improvements in performance were subsequently noted, including the recent successful examination of Operator SALP RESPON8E 8 JULY 1990
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* (ii) A Unit 2 operations Training' Program Advisory Committee (OTPAC) was established. The Committee is chaired by an i SSS and has a Reactor operator as Vice Chairman,
, Participation exists at all management levels and L includes both licensed and non-licensed operator ,
i-Issues involving training are openly discussed and plans j l are developed and acted on. The Committee also provides opportunity for " feedback" and has helped promote greater operations " ownership".
. L (iii) A Training Advisory Board (TAB) was established. It-is chaired by the General Superintendent and reviews all ; issues af fecting training programs. It'also ensures that ; lessons are learned, and that training receives high ' priority and visibilit (iv) A Station Shif t Supervisor has been assigned to the position of Unit 2 operations Training Supervisor to . promote operations " ownership" of the progra .!
(v) The shift crew training concept has been re-established :
and enhanced. Crews are no longer broken up'for exam- f
.. ination purposes, but train and tesc as a cre ' (vi) The examination and validation processes have been l strengthene A major cause- of the earlier requal- t ification program failure was poorly developed and validated examination As a result, management has '
committed extensive resources to develop and validate an l ' examination " bank", and has committed to strengthen it each year with new questions and scenario (vii)
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Information is now exchanged between Station Superin- i tendents to ensure both training programs are "on track". ,
(viii) Senior management has undertaken simulator observation i periods, f (ix) Cross plant observations by operations management and instructors now take place to assure that lessons are ;
learned and that both programs benefi ;
(x) Instructors are being trained in techniques asigned to improve the students' simulator performanc (xi) Station Shift Supervisors lead critique sessions to ;
strengthen training through greater operator involvemen (xii) There is increased and improved use of video tapes in the operator Requalification Program to highlight strengths and weaknesses for the Operators to personally revie i
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I 8 ALP RE8PONSE 9 JULY 1990 1
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it e'- 4 . The SALP report also identified deficiencies in the Power Oscillation Training (page 11, SALP report), of which the major l " ites concerned the lack of understanding by several interviewed operators of the meaning of " sudden decrease in core flow" in Operating Procedure, H2-OP-29, " Reactor Recirculating System"'. Niagara Mohawk' instituted a number of changes to correct this situation, including developing a new operating Procedure N2-OP-101D, " Power Changes" for all power charges above 40% power, thereby centralizing all power change issues; revision to operating confusion; Procedure, N2-OP-29 to clarify points of possible more classroom and simulator training; and examination on concepts and procedure ,
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The SALP report expressed some concerns in the area of staffing (page 11, SALP report). Management has given a high priority to staffin The creation of eleven new operator trainee positions, g.combined with an ongoing Reactor operator / Senior Reactor operator license program, provides for career
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development opportunities, assignment of rotational Station Shif t Supervisors to other positions, and the future restoration of the six shift rotatio In addition, Shift Technical Advisors are being added to the Operations staf f to enhance
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Control Room operation during emergency events and provide engineering expertise on shif Station management remains committed to improving shift working conditions, enhancing career opportunities for operations personnel, and maintaining an adequate staff for shift operator Niagara Mohawk believes strongly in personal career developmen The last two license classes were the l,argest in the history of either unit, with the exception of cold license As a result, operators can see career opportunities arising from promotions to positions in Engineering, Technical Services, Training, Safety, Regulatory Compliance, and Quality Assuranc In addition, the movement of operations personnel to other departments strengthens those departments and should ultimately improve overall Division performanc * Limited progress was made in reducing the number of lit annunciators in the control room (page 11, SALP report) . In January 1990, a task force, headed by an operations Department Engineer, was formed to assess the scope, define the corrective actions, and provide a means of tracking progress in this are Progress to date has been achieved by implementation of some design changes and continued maintenance work on failed component Since February, the number of lit annunciators has been reduced from approximately ninety to about sixt Operations, Maintenance, and Engineering management attention to this matter remains at a high level and it is anticipated that most lit annunciators will be corrected during the Fall 1990 refueling outag .
SALP RESPON8E 10 JULY 1990 _ _ . . . . . . . . . . . . . .- - - - --
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The foregoing description of changes, enhancements and corrective actions taken at Unit 2 to improve that Unit's performance is not intended to be all-inclusive; rather, it is indicative of the vigor with operatio which management is committed to bring about excellence in RADIoLOGI N CONTROLS Niagara Mohawk agrees that, as stated in the SALP report, Radiation Protection performance has remained acceptable and has improved in many area However, some of the conclusions drawn in the report may have been affected by some incorrect or incomplete information that was discussed at the June 14, 1990, meeting and is repeated belo The items which should be clarified are as follows:
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The SALP report stated that "AIARA performance was weak and ! needed more visible support of upper management". Niagara ~ Mohawk believes this conclusion does not accurately characterize the status of the AIARA program or management support for the
, program. The conclusion may have stemmed, at least in part, on a belief that the Unit 1 goal for 1989 was 800 man-rem and, thus, did not represent an aggressive attempt to reduce exposur In fact, the 800 man-rem figure was a 1988 goal. The o 1989 goal was aggressively set at $10 man-re The Unit's i l
actual performance for 1989 was 464 man-rem, even though the Unit was in an outage for the entire year and the scope of outage work, especially Inservice Inspection, expanded during the yea This compares well to the 442 man-rom average for all * BWRs during 1989, and to other facilities in similar situation .This performance was a direct result of proactive identification * of the potential for improvement on the established goal, and : the involvement of all levels of Station management. Niagara Mohawk also believes the Unit 2 performance was excellent for i ' 1989 in that only 61 man-rem were expended, as compared with a , pre-established goal of 128 man-re . During 1989, there were specific ALARA goals for the site, each ' unit, and each department. Progress towards meeting these goals was closely followed by Division management by means of performance monitoring reports and AIARA committee meetings.
' Further visible support by upper management is evident by the inclusion of an ALARA Standard in the Nuclear Division Standards of Performance, by Management Policies on Radiation Protection and ALARA that were revised and approved in 1989, and by the establishment of a Nuclear Division ALARA Goal for 199 Additionally, the General Superintendent, Nuclear Generation chairs the site ALARA committee, and the Station Superintendents chair their respective Unit ALARA committees.
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The intent of Niagara Mohawk's commitment to evaluate chemical decontamination of Unit 1 systems has not changed from the previous SALP response. Last year's SALP response was made with ' an expected mid-1989 Unit startup, and an expected outage in 199 However, in the interin, Unit schedules have slippe The commitment continues to be evaluation of chemical decontamination for the Unit during the first major outage following startu The scope of this decontamination will be determined once the work planned for the outage is define A number of. corrective actions and programmatic enhancements have been undertaken to bring about improved Radiological Protection performance, including the following:
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Control of contamination and radiation improved, and the use of automated contamination detection equipment increased. Also, as noted in the SALP report (page 13), reduction of contaminated areas and improved hot partLcle controls were realized during the yea For example, the contaminated area (i.e., > 1000 dpm/100 cm2) in Unit i decreased from 13 percent in March 1989
,to 8 percent in February 199 This accomplishment surpassed , the Unit 1 goal of 10 percen Plant accessibility due to posted contaminated areas has improve However, the actual extent of improvement realized has been limited by the relatively conservative posting level Use of a low contamination posting limit is consistent with the company's goal, and that of the industry, in reducing all personnel contaminatio This practice also helps to reduce the number of. false alarms from the sensitive Whole body contamination monitors used in the plan Ongoing contamination and leakage control programs have been established and are expected to . result in cont inued improvement in this are *
With regard to the SALP comment regardidg valve leakage (page 13), many valves were repacked during 1989 with an EPRI-recommended graphite ribbon packing to reduce packi'. g leak .This packing is designed mainly for valves that are not routinely cycled, which includes most of the valves in the plan A velve enhancement program is currently being developed with the expectation that live load packing replacement will commence in 199 * Because of a concern for the operability of the Effluent Monitoring Systems, management has focused attention in this area and established a task force to address the long term solution to the overall proble A root cause evaluation is currently in progres In the interim, the Integrated Priority System is being used to help assure that these monitors recalve appropriate attention to keep them operabl The Gaseous Effluent Monitoring System (GEMS) at Unit 2, and the Service Water Monitors at Unit 1, have been made operabl SALP RE8PON8E 12 JULY 1990
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Hingara Mohawk believes that continued improvement has been shown in i the Radiological protection progra Actions have been taken and l additional actions are planned to increase even further support for ALARA by upper management, and to improve availability of effluent monitor The Company further believes that plans and resources applied to the Radiological Controls programs will ensure that l continued improvement is achieved. In light of the above discussions, ! Niagara Mohawk requests that NRC reconsider the rating category ' assigned to the Radiological Controls are l
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!- MAINTENANCE AND SURVIILthCE ' , l- ! Niagara Mohawk's assessment of the Maintenance and Surveillance
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l performance is in basic agreement with che SALP repor Specifically, i the company recognizes the need to improve performance in the areas of ) management oversight, effectiveness of corrective actions, and adequacy '
l of and compliance with Maintenance Procedures. Beginning late last !- year, management has taken a number of corrective actions to address L each of the areas of weakness cited in the SALP report. These are described below:
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Maintenance
* New programs have been instituted in recent months that categorize and trend " backlog". These new programs lead to more effective item use of resources to work off " critical" backlogged Increased staffing at the Work Control Center, the development of an operations Suppor.t Group, and increased participation in work planning by operations are a few of the actions taken recently by management to reduce the backlog. The i
use of the Work Request backlog tracking system, along with j j published goals, also assists in the backlog reduction effor * Niagara Mohawk management recognized the concern regarding implementation of the initial set of reload system walkdowns at Unit 1 (page 18, SALP report and stopped further walkdowns until the necessary improve)ments had been mad These i improvements consisted of interviews with the personnel
.- involved, reassessment of the scheduled times for the walkdowns, improved communications, clarification of inspection criteria, and increased management oversigh The Walkdown Procedure was rewritten, including management's expectations and " lessons learned". Later, the walkdowns were resumed, this time, with greatly improved result > *
The SALP report noted that the investigation of the Unit 1 reload SRM bypass incident was ineffective in that it did not , determine that Electrical and I&C Maintenance personnel had not adhered to tagging procedures while performing troubleshooting
.c and repairs (page 18). The Company's review of this problem disclosed that the root cause was personnel error. Inadequate SALP RESPON8E 13 JULY 1990 L
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guidance in Administrative Procedure AP-4.2, " Control of Equipment Markups", regarding the use of " human . markups" and > personnel tags, was a contributing facto A Lessons Learned Transmittal has since been issued and the AP's are being revised I to control the use of personnel tags. Also, training on the revisions to AP-4.2 and the use of " human markups" will be provided after. issuance of the revised documen * A new Administrative Procedure, AP-5.4.2, " Troubleshooting", was issued recently to strengthen diagnosis of equipment failures at both units (page 18, SALP report)3 This procedure formalizes the use of System Engineers / Site Engineering for- l system and component troubleshootin The SALP report also cited poor initial troubleshooting on problems related to a Motor Generator Set (page 17) as one of several events which indicate the need to improve the timeliness ( and effectiveness of corrective actions. Use of Administrative l I Procedure AP-5.4.2 should also correct this weaknes , In addition, management's new commitment to
* assign " Task
, Managers" to problems of this nature further enhances the i overall troubleshooting progra * Poor troubleshooting and repair of an Emergency Diesel Generator-fuel transfer pump were also cited in the SALP report (page 17) . This particular problem is addressed by a new
" Temporary
!. Modification Process" which was recently issued to enhance controls in this are * l It has been determined that many of the unplanned outages noted l , ' in the.SALP report (page 16) for Unit 2 resulted from improper - assessment of plant impacts and post maintenance testing.
l Accordingly,- a new Administrative Procedure, AP-5.2.5, " Work In i Progress", places improved controls on plant impact and post ! l-maintenance testing assessments. These assessments are required l to be performed prior to the conduct of work. The new procedure { l ' also enhances individual accountability and promotes teamwork ' between Operations and Maintenance personnel during plant impact determination Recent reports from Unit 2 indicate that the. number of Licensee Event Reports (LERs) attributable to Maintenance personnel errors have been reduced. Similarly, the number of alarms in the Control Room have been reduced during this perio ! ! * Niagara Mohawk's review of the SALP finding that numerous p operational events at Unit 2 resulted from errors by Maintenance personnel (page 16) revealed that the cause of these errors was l rooted in weak procedural adherence, poor procedure format, )
inadequate post maintenance testing, poor plant impact
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!' 8 ALP RE8PONSE 14 JULY 1990 * T
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essessment, and insuf ficient supervisory oversigh Corrective : actions taken in this regard includes (i) The new Administrative P*ocedure, AP-5.2.5, " Work In Progress", is being used as well as other programs to reduce the potential for this class of proble (11) A new Site Maintenance Administrative Instruction, S-MAI-5.4-007, " Establishment and Maintenance of System cleanliness", has been issued to solve the " flooding" problem cited in the SALP report (page 16). This ; document places controls on close-out of large vessels.- 1 (iii) Additional layers of safeguards were added to procedures which relate to the inadvertent Traversing Incore Probe insertion incident (page 16, SALP report) .
(iv) A major rewrite of Maintenance Procedures is currently !
in progress, intended as a general upgrade of these document ,
(v) Several new programs have been initiated which increase the effectiveness of supervisors in the fiel A new -
Site Maintenance Administrative Instruction, S-MAI-5.4-006, " Maintenance Self-Assessment", requires weekly t documented observations of crews in the field by ' supervisors.
(vi) Several vacant positions were Tilled and a Maintenance Support Group was added to reduce the administrative duties of supervisor *
The SALP report correctly observed that the Maintenance Program * appeared to be informal in some areas with risk of degradation if any of the key managers were to depart (page 17). Some progress has been made in recognition of this vulnerabilit For example, steps have been taken to " capture" the knowledge of senior managers by preparation and issuance of increasing numbers of Maintenance Instructions, and AP-5.0 series l Maintenance Procedures. Also, contact is maintained with any key individuals who vacate their position. In addition, the use of the Preventive Maintenance / Surveillance Test (PM/ST) database to schedule and control preventative maintenance has increased substantially over the past year, with the result that less reliance is placed on key individuals. All senior Maintenance management positions are now filled, and a transition plan is in place to implement the changes underwa * A number of examples were cited in the SALP report (page 18) illustrating improper diagnosis of equipment failures and repetitive failures at Unit 2 during the assessment period. In each case, Engineering was consulted for assistance in the
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SALP RESPONSE 15 JULY 1990
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failure analysis, and the root cause of each individual problem has now been identified. All of these problems were complex and resulted from many causes or failure mode (There was no
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common root.cause.) Some of the specific problems identified have been corrected; while, for the balance, management is ; committed to resolve the remainder in a timely and adequate manner, and to continue to improve the root cause proces Niagara . Mohawk management recognizes the need for improvement in ; overall Maintenance performance, and in staffing this department. Many l improvements have already been accomplished and the company believes ' the trend is now in a positive directio With the management attention this area is now receiving, and through the process of goal- ' setting, Maintenance activities will continue to improve steadil Surveillance i
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Niagara Mohawk believes the SALP assessment of the Surveillance program is accurate and positive. The few deficiencies noted have received appropriate " follow up" and are considered i resolved. The Station's Surveillance personnel remain dedicated j
, to achievement of high standards of excellence in their work.
l Recommendations
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l The recommendation contained in the SALP report for the licensee (page 20) regarding the need to " reassess the adequacy of the Maintenance program and management / supervisory oversight with respect to continuing deficiencies", has been effectively implementred by reassessments which 1 resulted in the many new programs referenced above. These include l
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Senior Management Audit and Recognition Tours I
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Procedure upgrade efforts
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Training program upgrades As a result of increasing management oversight and the ongoing upgrade , offorts, the Maintenance program will continue to improve. Niagara Mohawk's commitment to the Restart Action Plan, and the Nuclear Improvement Program, requires concomitant success in the Maintenance and Surveillance areas.
l EMERGENCY PREPAREDNES8 Niagara Mchawk concurs with the SALP evaluation of Emergency i Preparedness and will continue to strive for excellence in this I i progra The good performance achieved is indicative of the company's ! comm# %cnt to Emergency Preparedness, both in maintaining the program l l
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fostering the teamwork which was evident during drills and exercise The strength of this program continues to be the support received from throughout the Niagara Mohawk organization, and from State and local agencie The. Emergency Preparedness goals and objectives for 1990 and beyond continue to stress those areas the Company believes are essential to ! maintaining the performance noted in the SALP report. These include maintaining effective working relationships, fostering teamwork, maintaining excelling during f acilities drills and andexercise procedures in a state of readiness, and
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SECURITY , Niagara Mohawk is pleased that the SALP assessment of Nine Mile Point Security reflects its own views of this progra The Nuclear Security Department's mission is to provide a secure and safe environment for the operation of the units at the site. It accomplishes this mission by maintaining a proactive security program
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consisting of an efficient integration of state-of-the-art hardware, and highly professional, dedicated safcquards personne The department will continue to take the initiative in changing the security program to address, as appropriate, changing conditions; perceived changes in the external environment; perceived changes in the level of threat; and, perceived areas where program improvements can be obtaine ' l The Security Department - remains committed to being a leader in the nuclear security field and appreciates the NRC's recognition of this commitmen .
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ENGINEERING / TECHNICAL .UPPORT Niagara Mohawk agrees with the overall SALP assessment of Engineering and Technica' support and is pleased that the NRC recognized improvement overall and, in particular, for the resolution of previously identified concerns regarding design issues and engineering-support at the plant sit ,- The Company shares the NRC's view of the need to improve the timeliness and quality of engineering work, as well as to strengthen the engineering training progra A team of Nuclear Engineering & Licensing and Nuclear Generation managers has been established to regularly. assess technical issues and the overall effectiveness of engineering support. This team has been helpful in clarifying roles , l and- responsibilities among engineers in Nuclear Generation, Site Engineering, and Nuclear Engineering. As a result of these efforts, senior management for Nuclear Engineering & Licensing and Nuclear l
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Generation have issued a criteria document to clarify bounding criteria for handling resolution of technical issues. This will assure a clear understanding of when engineering support should be requested and ;
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provide In addition, the strengthening of safety evaluations and establishing increased on-site capability to handle design changes should prevent recurrence of the specific problems cited in the SALP repor i Niagara Mohawk also agrees with the need to improve review of technical issues, particularly in preparation for site operation Review Committee '
(SORC) meetings, and conceptual reviews in general. A training program '
has been developed and the first classes are. planned, following Unit ' 1. restart, for preparation and presentation skills for SORC meeting Also, the department is strengthening its Conceptual Engineering Group with additional experienced manpower to improve early planning and analysis of issues. Eight positions have already been fille * i The company concurs that there is need for continued mana attention to Nuclear Engineering & Licensing training programs.gement The majority perio of the Critical Needs Training was completed during the SALP Both the Vice President, Nuclear Engineering & Licensing and
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the Manager, Nuclear Services have increased their personal attention i- in implemente this area to assure that long term training improvements are ! Actions have been taken to expedite completion of the L Nuclear Engineering & Licensing training needs assessment to identify engineering training requirements. This is planned to be completed by September 199 Management attention will continue to be fc,cused on this this proces area to assure timely implementation "of training identified by In summary, Niagara Mohawk is taking action and providing continued management attention to assure that progress continues in those areas-where significant improvements have been made, as well as to assure improved performance in all area .
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g&ZEXI_—BEEltT/lLUALITY VERIFICATION Niagara Mohawk is in basic agreement with the SALP assessment in this
.- area and concurs that there is need for continued improvement, which is the foundation of our vision of excellence for the futur However, the Company was disappointed with the rating in this are Before
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focusing on the specific responses to the weaknesses noted in the SALP report, some discussion of the many positive initiatives Niagara Mohawk has undertaken is appropriate. The fundamental changes in the areas of staffing, performance monitoring and management effectiveness self-l assessment have created an environment in which continued improvement in areas affecting Safety Assessment and Quality Verification are
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expecte . First, the Company believes that the emphasis in the Safety Assessment and Quality Verification area has been substantially increased, and ; I , 1 ( SALP RESPONSE 18 JULY 1990
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the number and quality of personnel assigned to this area have. improved considerabl Second, the resolution tracking and monitoring of operations experienca, open issues and backlogs have improved significantly and the safety culture and professionalasm of the organization has changed dramatically for the better. Finally, a Restart Readiness Assessment, and follow-on assessments, have been completed that represent a significant management effectiveness improvemen Each of these areas will be discussed in more detai Staffina ,, Niggara Mohawk has added senior qualified personnel to System and Site Engineering, Operation's Experience (Technical Assessment), Quality Assurance, Independent Safety Engineering Group, and the Independent Assessment Group. During the timeframe of the SALP period, about 200 people were added to the Nuclear Division, most of whom have 8 or more years of nuclear experience; some have over lo years. Some of the key changes in these areas have been previously discussed with NRC during ACRS and Commission meeting However, a brief review is in order:
* F rsonnel changes have been made, and the organization ,
strengthened by focusing key elements of the organization within the Nuclear Divisio These changes have occurred since February 1989 and include (i) The entire Quality Assurance organization has been moved into the Nuclear Division to make QA a more integral
"part of the team", and to provide additional visibility of QA concerns to senior Nuclear manager (ii) A new Assessment Group has been established that helps promote the development of self-evaluation within nuclear. This group looks at management effectiveness, including the underlying issue (iii) The Nuclear Generation Department has been reorganized, with the addition of several key personnel:
a. An Operations support Group, having three people, was establishe b. Operator positions were established enabling six rotating shifts, plus a relief shift, instead of the five previously, c. Shift Engineer positions were establishe Positions were established for five rotational SSSs, in addition to shift requirement '8 ALP RE8PONSB 19 JULY 1990 -
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e. The Fire Protection Group was assigned to Operations, t
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f. A painting crew was established as part of a
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(iv) Twenty System Engineers have been adde (v) Within each department, Organizational Development Specialists have been providing in-line management effectiveness trainin !
The reporting level of the Independent safety' Engineering Group
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A new Site Engineering organization was established to improve the support of the operating organizatio i These organization changes have made an impact on the ability of management to " stay tuned" to performance. (This is clearly noted in the SALP assessment of Engineering, for example.)
Performance Monitorina During the SALP period, Niagara Mohawk established goals and standards for key operating performance indicator For example, the backlog of Quality Assurance corrective Action Requests. (CARS), . and Non- ' Conformance Reports (NCRs), and the operating experience information review backlog at both units, have been substantially reduce In addition,- the evaluation of Operations Experience Assessment (OEA) Open < Items for Unit 2 has been reduced from 1600 to 600s while, at Unit 1, Open Items were reduced from 225 to 9 Other examples of increased performance are the reduction of Work Request backlogs on both units, and the reduction of Work Request backlogs on both units, and the reduction of open Problem Reports, Occurrence Reports and Nuclear commitment Tracking items. These backlogs have continued to be reduced subsequent to the SALP period. ?. substantial effort has been made to ! close these open issues during a period of changing culture, returning Unit 1 to operation and continuing operation of Unit Rangggment Effectiveness Self-Assessment In addition to the physical improvements, the company has continued to monitor management effectiveness. The Restart Readiness Report and follow-on assessments continue to show clear improvements in problem ,- solving, planning, teamwork, culture and self-assessment. Positive and l negative examples. of this performance exist in the follow-on
- assessments and provide a track record of continuing improvemen Another significant change is the higher Standards of Performance shown on the 1990 " wallet cards", as compared with the 1989 listin positive example of the continuina pursuit of excellence is theA development of a new Standard of Performance - self-assessment -for 199 Thousands of hours of Niagara Mohawk staff assessment of
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e SALP RESPON8E 20 JULY 1990
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performance have resulted in improved internal assessment capabilit Examples of.these improvements includet ;
(1) An Integrated Priority System was developed which has been pilot tested and implemente This will help
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improve planning effort (ii) A Division-wide effort was undertaken to identify and resolve problems. . Over 1400 Problem Reports were dispositioned during the Unit 1 outag ,
(iii) Under development, but not yet fully implemented, are a ;
Nuclear Division Integrated Defici^ency System, an ' upgraded root cause trending program, and a " Lessons-Learned" syste (iv) A Division-wide desire to continue to seek improvement has b e e n c r e a t e d ,' at least in part, by management's i
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walkarounds and solicitations of subordinate input ' The Company still continues to learn about its performance, but I e-believes that substantial progress has been made during the SALP period, are and that the company will continue to improve in thig important These examples have made a substantial improvement in the ,
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L diagnostic capability of management effectivenes S.ge_cific Resnonses
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t Although an important area, Niagara Mohawk's actions with regard ! ! to system walkdowns is discussed earlier in this response. This comment appears in several SALP report sections (ogs page 30). I The company's response is provided in the Unit 1 operation's
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Performance of the Unit 2 Operator Requalification Training (page 30, SALP report) was promptly addressed by successfully remediating the Operators who failed to perform adequately. A detailed plan was implemented to assure that Operator requalification training efforts were fully adequate to meet the standard * Niagara Mohawk acknowledges that the annunciator window corrective actions have not moved as rapidly as desired (page 30, SALP report) . The Com Unit 2 Operation's section.pany's response is provided in the
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The Company also acknowledges that the initial identification and problem solving of the 125 VDC matter was not timely (page 30, SALP report), and so stated in its Restart Readiness Repor However, the company believes that resolution of the 125 VDC problem before the Unit restarts is adequate to assure the public health and safet The schedule for that work was as l
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aggressive as could be achieved without affecting the safety -)
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l 8 ALP RESPONSE 21 JULY 1990 I
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related elements of the desig The concern was given the proper attention after identification by correcting the breaker l problem before refueling, and the battery and motor generator problems before restar Also, in some instances, management asked for more study on certain items, which had an effect on schedule. Niagara Mohawk will continue to strive to do better in the future, but doing it right will always take priority over doing it quickl summary Niagara Mohawk agrees with the SALP assessment that,it has passed a turning point in the approach to assuring Safety Asseissment and Quality Verification, and is confident that the changes and enhancements already in place will result in consistently high organizational performanc The are SALP report contained no recommendations for improvement in this Although there is considerable room for additional improvement, Niagara Mohawk believes it has achieved substantial progress. In view of this, as well as the marked improvement NRC noted during the recent Readiness Assessment Team Inspection, Niagara Mohawk suggests NRC
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reconsider its SALP rating of our performance in Safety Assessment and Quality Verification.
!. Niagara Mohawk's plan for the future is to continue to improve * performance through activities such as self-as,sessment, management by walking Progra around, and effective implementation of the Nuclear Improvement
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O SALP RESPONSE 22 JULY 1990
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ENCLOSURE 5 i
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L' SALP Board Report' Revision Sheet
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; P_aJLe Line 'Now Reads Should Read *
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c , 13- 33-36; ...., th'ere did not
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... catch' basins are still appear ... postponed,
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extensively used to contain valve 3
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F Basis: Statement regarding treatment of valve leakage, changed and sentence ! W, '
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on postponement of decontamination deleted in response to Niagara , Mohawk comment ;
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14' 8 ALARA performance was ALARA performance for 1989 was .
' . weak... good for Unit 1 at 464 man-rem and -
y excellent for Unit 2 at 61 .
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it " Basis:- . Previous assessment on ALARA performance was in error and was revised ' in - response to_ Niagara Mohawk comments on 1989 ALARA . . performanc %
~ 14 - 15-19 The Unit 1 goal of (Sentence Deleted)
about 800 man-rem... , ( Basis: Sentence deleted in response to Niagara Mohawk clarification of 1989 ALARA goals and performanc However, upper manage- (Sentence Deleted) . ment support... '
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-Basis: Sentence deleted and previous assessment retracted based on the above '
clarifications-regarding 1989 ALARA performanc l
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