IR 05000244/1984099
| ML17254A353 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 05/08/1985 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17254A352 | List: |
| References | |
| 50-244-84-99, NUDOCS 8505150171 | |
| Download: ML17254A353 (92) | |
Text
ENCLOSURE
U.S.
NUCLEAR REGULATORY COMMISSION REGION SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT 50-244/84-99 ROCHESTER GAS AND ELECTRIC CORPORATION R.E.
GINNA NUCLEAR POWER PLANT ASSESSMENT PERIOD:
JULY 1, 1983 - DECEMBER 31, 1984 BOARD MEETING:
FEBRUARY 25, 1985
SUMMARY OF RESULTS A.
Overall Faci lit Evaluation This is the fourth assessment of licensee performance by the NRC Staff under the Systematic Assessment of Licensee Performance program.
The composition of this assessment differs from previous reports in that Quality Assurance/Quality Control is addressed as a separate func-tional area to summarize the NRC findings and perceptions of the
,'ack of licensee management support for the QA/QC organization.
Licensee management does not seem to use QA/QC as a viable feedback
~l,.: mechanism to measure and review station performance.
Dependence on an experienced plant staff and their consistently high level of performance has apparently precluded testing the QA/QC organization effectiveness.
Thus, the station workers and staff do not support the QA/QC organization.
This prevailing attitude of the lack of relevance of QA/QC to safety warrants prompt licensee management
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attention to assure the ability of the gA/gC organization to effectively perform its feedback role should problems develop, in the future.
Licensee performance in six functional areas including Maintenance, Surveillance, Fire Protection and Housekeeping, Security and Safe-guards, Refueling and Outage Management, and Licensing Activities exemplifies a strong commitment to safe efficient plant operation.
In the remaining three functional areas further licensee effort is required to achieve this level of performance.
The Plant Operations area improved.
Management involvement to increase the formality and effectiveness of Morning Priority Required (MOPAR) meeting and better supervisory oversight to reduce personnel errors have contributed to the longest power run in the facility's operating history during the assessment period.
Management efforts to promptly address weaknesses
~identified in the licensed operator requalification program were
"commendable.
Competent supervisory control and an efficient staff have contributed to a
general improvement in the Radiological Controls area, in spite of limited corporate staff involvement.
A lack of aggressiveness in pursuing the timely resolution of previously identified NRC concerns detracted from the overall Emer-gency Preparedness rating this assessment period although performance during the 1984 Emergency Exercise was acceptabl I
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B.
Faci lit Performance FUNCTIONAL AREA CATEGORY LAST PERIOD 1.
Plant Operations
o Operator Licensing and Training 2.
Radiological Controls o Radiation Protection o Radioactive Waste Management o Transportation o Effluent Control and Monitoring 3.
Maintenance 4.
Surveillance (Including Preoperational Testing)
5.
Fire Protection and Housekeeping
6.
7.
Security
& Safeguards
8.
Refueling/Outage
Activities ( Including Inservice Inspection)
9.
Licensing Activities
10.
Quality Assurance/
Quality Control CATEGORY THIS PERIOD RECENT TREND IMPROVING IMPROVING CONSISTENT CONSISTENT CONSISTENT CONSISTENT CONSISTENT CONSISTENT CONSISTENT NONE
- Not previously addressed as a separate category
~ t
IV.
PERFORMANCE ANALYSIS A.
PLANT OPERATIONS (51/)
1.
A~nal sis The functional area of plant operations includes operator training and licensing, design changes and station modifica-tions, committee activities and reporting systems reviewed by the resident inspector and region-based inspectors.
During the previous assessment period, problems were identified in the areas of: routine review of daily operations; communica-tions between plant staff and project personnel with respect to modification turnover; and the submission of Technical Specifi-cation required reports.
During this assessment period Plant operators have demonstrated a uniformly professional dedication to their daily responsibi-lities and responded quickly and efficiently to abnormal events.
Operations supervision was actively involved in the routine review of daily events and normally pursued problem areas to satisfactory resolution in a timely manner.
Management has demonstrated a continued sound commitment to safety in its day to day control of plant activities and generally demonstrated a
conservative approach when making decisions affecting safety.
In addition, plant staff technical and engineering reviews provided through the PORC have continued to strengthen and enhance overall plant operations.
Early in the assessment period there were NRC findings of inade-quate overview and control of plant modifications.
In particular, the installation of the Post Accident Sampling System was identified as having been placed in service and accepted by PORC without proper assurance that all testing was complete and satisfactory and all quality control concerns properly resolved.
This item was indicative of problems identified in the previous assessment period.
Commitments to revise the modification con-trol and turnover process were implemented prior to the end of this assessment period, but an inspection to evaluate the effect of the changes has not been completed.
This item will be reviewed in the next assessment period.
On two separate occasions during this assessment period, fire protection systems were partially disabled or improperly( admin: '"
,istratively controlled by 'operations=department personnel with=
out proper compensatory measures taken.
Similar occurrences were observed in the previous assessment period.
Although con-sidered to be isolated events, control of the frequent disabling and reactivation of fire protection/detection systems must be given the proper level of emphasis as important to safety.
Continued management attention in this area is warrante I II J
tf 1lf~'=i
Activities pertaining to current Spent Fuel Pool Storage Rack modifications resulted in the violation of Technical Specifica-tions prerequi sites for the handling of irradiated fuel in the Auxiliary Building.
Of particular concern to the NRC was that indications of an abnormal ventilation condition had been iden-tified, but not properly evaluated or resolved prior to the authorized movement of fuel.
An Enforcement Conference was held for this item on November 5, 1984.
Licensee response was prompt and corrective actions comprehensive.
Not only have fuel hand-ling prerequisites been substantially upgraded, but plant Morning Priority Action Required (MOPAR) meetings, (composed primarily of PORC members),
have become much more structured and formal in addressing and pursuing daily concerns and potential safety issues.
Two inspections by region-based inspectors to review selected IE Bulletin responses and periodic review by the resident inspector of technical specifications required reports and routine reports have been performed this assessment period.
In general, the licensee's responses and reports have been timely and adequate.
Plant personnel were knowledgeable of the actions taken, records were complete, readily retrievable and.adequately documented the tasks performed and licensee findings.
0 erator Licensin and Trainin 316 hours0.00366 days <br />0.0878 hours <br />5.224868e-4 weeks <br />1.20238e-4 months <br /> Toward the middle of the assessment period a team of NRC operator licensing examiners concluded that significant weak-nesses existed in the implementation of the station's approved licensed operator requalification program.
In particular, the program review indicated a lack of depth in the annual requali-fication examinations, inconsistency in the implementation of staff licensed operator training requirements and an overempha-sis on the annual requalification examination as the sole measure of the requalification training program effectiveness.
Based on that assessment, a comprehensive and ambitious revision to the licensed operator requalification program was undertaken by the licensee.
It is recognized that further revisions to this program may be warranted because of the significant impact the changes are having on plant staff workload, however, the licensee is to be credited with the responsiveness and timeli-ness in addressing this issue.
Corporate management involvement and commitment to the resolution of this issue is evident.
With regard to Operator Licenses,
SRO and
RO licensing examinations were administered during this assessment period, with 10 of the SRO and 6 of the RO candidates receiving a
license.
This trend is indicative of a strong initial license and upgrade training program I
A review of non-licensed training by a region-based inspector concluded that the training department is adequately staffed and that management involvement was evidenced by the fact that they contracted for an independent review of maintenance training to identify areas of needed improvement.
With the exception of gC personnel, involvement of maintenance personnel, ISC technicians and R&T personnel in general plant systems training has not been observed.
Training records for both licensed and non-licensed personnel were both complete and easily retrievable.
2.
Conclusion Rating:
Category
Trend:
Improving 3.
Board Recommendations Licensee:
Continue licensed operator training upgrade initiatives.
NRC:
Review implementation of modification program corrective actions resulting from Inspection Report 50-244/83-2 IOLOGICAL CONTROLS (11Fo)
1.
nal sis D
ing the previous assessment period problems with dosimetry con rol were identified.
In addition, although improvements in site LARA and external exposure control efforts were identified, docume tation in these areas was considered to need improvement.
Ouring t assessment period there were five minor violations.
There were no escalated enforcement actions, civil penalties or confirmator action letters.
One radiologically significant event occurred and was resolved by the licensee.
There were five routine i spections by region based radiation specialists.
In-Plant Radiat n Safety was inspected twice, Waste Management and Transportatio also twice, while Effluent Control was reviewed once.
The radiological con ols organization is small and team oriented with competent and exp rienced personnel.
Most are cross-qualified in both healt physics and chemistry areas.
The site organization is generall self-sufficient without significant technical support from con ractors or the corporate staff.
This approach has allowed for a igh degree of direct site management involvement and control in m yt activities.
However, refinement and improvement in certain areas such as laboratory analysis, training, and procedure develop en's necessary.
Staffing is ample as indicated by control of vertime and minimal use of contractors.
Both routine and out ge tasks are completed on a
timely basis.
Corporate oversight has been minimal.
n increasing trend of man-rem exposure may be attributed to c rtain equipment failures, however, the lack of formal ALARA review f outage work planned and directed from the corporate level may e
a contributing factor to the exposure trend.
The recent rmalization of a corporate ALARA program has not been reviewe by the NRC staff.
Radiation Protection Within the radiation protection organization the scision making consistently occurs at a level that ensures adequat management review.
All radiation work permits are initiated by one of the HP first line supervisors.
Prior to work involving ss nificant personnel exposure, a thorough and documented ALARA re ew is completed by a management committee.
Audits of routine a d special activities are complete, timely and thorough.
We ly tours of 17 known or potential in-plant problem areas are n-ducted by HP supervisors and a formal check-off is complete and reviewed by the PORC committee.
Site guality Control personn
also conduct frequent compliance inspections with effective follow-up on finding a 10A B ~
RADIOLOGICAL CONTROLS ( 11/o)
1.
~Anal sis During the previous assessment problems with dosimetry control were identified. In addition, although improvements in site ALARA and external exposure control efforts were identified, documentation in these areas was considered to need improvement.
During the assessment period there were five minor violations.
There were no escalated enforcement actions, civil penalties, or confirmatory action letters.
One radiologically significant event occurred and was resolved by the licensee.
There were five routine inspections by region based radiation specialists.
In-Plant Radiation Safety was inspected twice, Waste Management and Transportation also twice, while Effluent Control was reviewed once.
The radiological controls organization is small and team oriented with competent and experienced personnel.
Most are cross-qualified in both health physics and chemistry areas.
The site organization is generally self-sufficient without significant technical support from contractors or the corporate staff. This approach has allowed for a high degree of direct site management involvement and control in most activities.
However, refinement and improvement in certain areas such as laboratory analysis, training, and procedure development is necessary.
Staffing is ample as indicated by control of overtime and minimal use of contractors.
Both routine and outage tasks are completed on a timely basis.
Corporate oversight has been minimal.
Man rem -exposure continues to decrease as a result of site staff efforts. While a written corporate program effecting ALARA implementation had not been developed until recently, this has not impacted site efforts to implement dose reduction.
The recent formalization of a corporate ALARA program has not yet been reviewed by the NRC staff.
Radiation Protection
Within the radiation protection organization the decision making consistently occurs at a level that ensures adequate management review. All radiation work permits are initiated by one of the HP first line supervisors.
Prior to work involving significant personnel exposure, a thorough and documented ALARA review is completed by a management committee.
Audits of routine and special activities are complete, timely and thorough.
Weekly tours of 17 known or potential in-plant. problem areas are conducted by HP supervisors and a formal check-off is completed and reviewed by the PORC committee.
Site Quality Control personnel also conduct frequent compliance inspections with effective follow-up on finding 'I Records are complete, well maintained and available.
The records of personnel exposures and radioactive waste shipments were readily available for inspector review.
Procedures and policies are rarely violated, however, minor problems have occurred in the procedures area.
The procedure for waste solidification was not reviewed by PORC or approved by the Station Superintendent.
The procedure for monitoring air-borne particulate activity does not provide clear and unambi-guous instruction for the HP technician.
The licensee's responsiveness to NRC initiatives is generally viable, sound and thorough.
Although the Post Accident Sampling System installation was completed within the established commit-ment dates, system operability verifications and proper testing documentation, as controlled by the administrative modification pr'ocesses, were found to be inadequate.
Corrective action relative to enforcement initiatives was prompt and effective.
Improved control of access to high radiation areas was commendable.
The training and qualification program makes a positive contri-bution to the HP staff's understanding of the work. Interviews with the staff, permanent and contractor technicians indicate a
knowledge of the required procedures and policies which reduces the number of personnel errors.
Radioactive Waste Mana ement and Trans ortation The administration of the Quality Assurance Program for trans-portation activities occurs at the corporate level.
However, corporate management is usually not involved in site activities and the annual audits of transportation were somewhat lacking in depth.
In contrast, the inspections of shipments by the on-site QC personnel have been complete and thorough.
Records related to the transportation and burial of waste were complete and well maintained.
Oocuments relating to the ship-ping containers, pertinent burial site regulations and shipping manifest were readily available for review.
The licensee demonstrated a clear understanding of the issues related to the implementation of 10 CFR 61 regulations for waste classification and characterization.
This resulted in timely and thorough implementation of the regulations.
Similar per-formance was noted in response to the IE Bulletins, Circulars and Branch technical positions that were issued in conjunction with the transportation regulation l
A training and qualification program is well defined and imple-mented for the personnel associated with transportation activ-ities.
However, the qualification of gC inspectors was not clearly defined.
This problem was subsequently resolved.
Effluent Control and Monitorin (EF)
The policies for the Radiological Environmental Monitoring Program (REMP) program are generally well stated and under-standable.
As a result, the data required by the Technical Specifications is readily available.
Within the REMP organization there is only one dedicated Environ-mental Technician.
The licensee had not clearly defined the responsibility and qualifications for this position.
However, all HP and chemistry technicians are trained in REMP techniques and provide back-up capability for the environmental technician.
This reserve of qualified personnel ensures that the REMP moni-toring results are complete, well maintained and available.
The licensee review of monitoring results is technically sound and thorough in most cases.
Some discrepancies with EPA results were resolved but lacked adequate documentation.
Also, test data to qualify the TLD system for environmental monitoring was not available on site.
2.
Conclusion Rating:
Category
Trend:
Improving 3.
Board Recommendations Licensee:
Consider role of corporate staff ALARA program in support of site staff.
NRC:
Determine involvement of corporate staff in achieving ALARA during next scheduled plant outag I
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C.
MAINTENANCE (65)
l.
A~nal sos During the previous asssessment period poor communications between the Maintenance and Testing Departments was identified as a weakness.
In addition, improper maintenance control on the containment personnel hatch resulted in the performance of inappropriate post maintenance testing which could have led to a violation of containment integrity.
During the current period this functional area was under fre-quent review by the resident inspector and periodic review by a region-based inspector.
In general, maintenance practices have been carried out with good regard for plant and personnel safety and in accordance with prescribed administrative and procedural requirements.
The station benefits from having strong Instru-mentation
& Control, Electrical and Mechanical Maintenance Departments which have experienced personnel in key roles and low turnover rates.
Improvements in communications between Maintenance and Testing Departments have been observed and may be attributed to both improved procedures and more formal plant staff meetings.
As a result of an NRC finding in the previous assessment period regarding the failure to perform proper post-maintenance testing on the containment personnel hatch, a thorough review of safety-related equipment maintenance procedures was performed to ensure post-maintenance testing requirements were properly identified.
Coordination of plant evolutions has been enhanced by more structured MOPAR meetings.
The station preventive maintenance program continues to be a
strong asset, contributing to the longest generating run of the facility in its operating history.
Day 213 was surpassed on January 1,
1985.
A special review of station maintenance practices and equipment history records by the'esident inspec-tor, concluded that periodic preventive and emergency mainte-nance has maintained or improved plant equipment performance and not contributed to subsequent failures.
On September 20, 1984, a non-safeguards breaker (Westinghouse DB-25) failed and resulted in a minor fire.
Investigation by electrical maintenance personnel to determine the fai lure mode identified the cause.
The licensee promptly inspected identical safeguards breakers for similar problems.
On May 30, 1984, an unscheduled outage resulted from an electrical fault in the main generator exciter.
Repairs were affected by station maintenance personnel and the generator restored to service in three day l[
The resident inspector observed portions of emergency mainte-nance to repair a
steam leak on valve 431A, pressurizer spray valve.
Procedure adherence was adequate and ALARA practices were satisfactory.
Team work and cooperation between the different departments involved in the evolution was excellent.
As demonstrated by the above examples, the station maintenance activities are conducted in a competent, professional manner and supervised by experienced, well-organized managers.
2.
Conclusion Rating:
Category
Trend:
Consistent 3.
Board Recommendations Licensee:
None NRC:
None
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0 SURVEILLANCE (7/o)
1.
~Anal sl s During the previous assessment period weaknesses were identified in this functional area with respect to poor communications between the Testing and Maintenance Departments and occasional inattentiveness in the performance of surveillance testing.
General improvement in both areas has been observed this SALP period.
The bulk of surveillance activities is performed by Results and Test, Instrumentation 5 Control and Operations Departments, Surveillance scheduling continues to be followed and planned manually by all departments concerned.
Computerized scheduling is planned but not implemented to date.
Duplication of sur-veillancee tracking has ensured no tests have been missed this assessment period.
Each department generally, adheres to a strict guidance for dual verification and thorough post-testing reviews.
On one occasion this period, final review of a periodic test identified an error missed by previous reviewers.
On October ll, 1984, operations personnel performed Periodic Test, (PT)-1,
"Rod Controls System",
and incorrectly logged test data which was outside the acceptance criteria.
Immediate supervisory review missed the error, but final review by the Results
& Test Supervisor identi-fied the error.
Proper reverification of the test results was performed.
Subsequent review of the same periodic test identi-fied a procedural ambiguity which resulted in operators failing to properly test the Rod Control System.
Results and Test staff are to be credited for their identification and correction of this deficiency.
While performing the calibration of Power Range Neutron Monitor N-43, on June 27, 1984, the Instrumentation and Control tech-nician conducting the test inadvertantly pulled the control power fuses instead of the instrument power fuses.
The tech-nician immediately recognized his error and reinstalled the fuses, however, a short duration turbine runback resulted.
Response of control room operators was commendable in handling the run back.
This incident of momentary inattentiveness appears to an isolated event and does not indicate a trend.
Management attention in this functional area appears to be adequat J
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Two inspections were conducted of the restart testing program by two region-based inspectors.
The inspections focused on startup physics testing for cycle NIV.
Management involvement and con-trol in assuring quality was evidenced by a well defined startup test program.
The test program described the sequence of tests, plant conditions under which the tests were to be performed, recautions and prerequisites, and administrative controls b
ore power was increased between test phases.
Tests 'were pe ormed with approved procedures by qualified individuals.
Revi of test results performed by the engineering staff and the sa ety committee were technically sound and timely.
The licen e exhibited a conservative approach to nuclear safety.
F example, upon identification of a 0.2X error in the calculation r core thermal power, the licensee decided to operate at sl> htly less than rated power with conservative reactor power t 'p settings, resulting in not exceeding licensed core thermal powe limits.
Key positions and re onsibi lities for the restart physics test program are well defi d.
Adequate technical support was pro-vided for the test prog m.
However, QA/QC surveillance and followup only covered the refueling program and did not extend to the startup physics tes
'ng program.
No inadequacies were identified in the startup te t program as a result of this lack of QA/QC coverage.
The licens has committed to provided QA/QC coverage during future startup ysics testing.
2.
Conclusion Rating:
Category
Trend:
Consistent 3.
Board Recommendations Licensee:
Monitor implementation of non-licens d training.
NRC:
None
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a 16 A Two inspections were conducted of the restart testing program by two region-based inspectors.
The inspections focused on startup physics testing for cycle XIV.
Management involvement and con-trol in assuring quality was evidenced by a well defined startup test program.
The test program described the sequence of tests, plant conditions under which the tests were to be performed, precautions and prerequisites, and administrative controls before power was increased between'est phases.
Tests were performed with approved procedures by qualified individuals.
Review of test results performed by the engineering staff and the safety committee were technically sound and timely.
The licensee exhibited a conservative approach to nuclear safety.
For example, upon identification of a O.Vo'rror in the calculation for core thermal power, the licensee decided to operate at slightly less than rated power with conservative reactor power trip settings, resulting in not exceeding licensed core thermal power limits.
Key positions and responsibilities for the restart physics test program are well defined.
Adequate technical support was pro-yided for the test program.
However, QA/QC surveillance and followup only covered the refueling program and did not extend to the startup physics testing program.
No inadequacies were identified in the startup test program as a result of this lack of QA/QC coverage.
The licensee has committed to provided QA/QC coverage during future startup physics testing.
2.
Conclusion 3.
y Rating:
Categoryi
Trend:
Consistent Board Recommendations Licensee:
Monitor implementation of non-licensed training.
NRC:
None
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E.
FIRE PROTECTION/HOUSEKEEPING (3/o)
1.
A~nal sis During the previous assessment period poor communications between the Fire Protection Staff and Operations Department resulted in inappropriate compensatory measures being taken for fire protec-tion systems being disabled, however, improvement towards the end of the previous assessment period was observed.
During this asessment period one inspection of the fire protec-tion program was conducted by a region-based inspector.
The resident inspector observed fire protection and housekeeping practices throughout the assessment period.
Staffing levels are satisfactory with a full time Fire Protec-tion and Safety Coordinator, knowledgeable in fire protection and nuclear safety, in charge of the program.
Fire brigades were adequately trained in accordance with require-ments.
The fire brigade consists of personnel from the Operations and Security departments.
Due to different shift rotations of the two departments, members of the fire brigade continually change.
Although not considered to be a significant weakness, the effectiveness of the fire brigade as emergency firefighting teams may be reduced due to continually changing members and the inability to drill as a regular team.
Inspector review of the Project guality Assurance storage areas early in the assessment period identified problems with clean-liness, inventory control and access control.
Prompt management attention corrected these deficiencies and subsequent inspec-tions of these areas have indicated satisfactory compliance with requirements.
Fire protection equipment was well maintained and in good working condition, except as noted in section IV.A.2. 'lant cleanliness and housekeeping are considered a strength and management atten-tion continues to be effective in the prevention of fires in the plant.
Following completion of the 1984 refueling outage, plant house-keeping in the nonradiologically controlled areas was identified as not being consistent with normal licensee standards.
Prompt management attention resulted in a rapid improvement and con-tinued emphasis on plant cleanliness.
2.
Conclusion Rating:
Category
Trend:
Consistent
l
3.
Board Recommendations Licensee:
None NRC:
None
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F.
EMERGENCY PREPAREDNESS ( 10%)
l.
~Anal sis During the previous assessment period, a problem was identified regarding the excessive time taken to address the deficiencies identified as part of the the November 1981 Emergency Prepared-ness Implementation Appraisal (EPIA).
Corrective actions had not been
~taken on four of the deficiencies as of November 1983.
The four "items were:
a program for high level waste management; a study of the uncertainties of the plume trajectory due to the lake breeze; Emergency Plan and procedure revisions to describe a complete and functional emergency organization; and, to pro-vide guidance to the Emergency Coordinator.
These items were finally resolved late in this assessment period.
The excessive time to resolve these deficiencies is apparently due to marginal staffing in the emergency preparedness area.
One person, located in the corporate office, is assigned to this area, It should be noted that the approaches to resolution of these problems were technically sound.
A violation was issued during this assessment, period for the failure to conduct the required annual emergency preparedness training.
Three persons designated as qualified Emergency Coordinators had not received the required annual refresher training.
During this assessment period, three region-based inspections were conducted, inclusive of the observation of the annual
'mergency Exercise conducted on September 12, 1984.
The inspections included routine review of the licensee's Emergency Plan and the effectiveness of its implementation, as well as, follow-up of previously identified inspection items.
Licensee execution and participation in the full-scale Emergency Exercise held on September 12, 1984 was considered to be satis-factory as evaluated by the NRC inspection team.
No major dis-crepancies were noted and few recommendations for improvement were identified. It is noted that the corporate coordinator for Emergency Prepardness retired near the end of this assessment period.
The NRC will monitor the licensee's actions to ensure continuity and effectiveness during the personnel transition in this functional area.
2.
Conclusion Rating:
Category
Trend:
Consistent
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3.
Board Recommendations Licensee:
The licensee should be sensitive to the maintenance of continuity in the corporate coordinator for emergency preparedness position.
NRC:
Monitor corporate support of the emergency preparedness program staffin C
G.
SECURITY AND SAFEGUARDS (4/o)
l.
~Anal sis During the previous assessment period no significant weaknesses were observed in this funtional area.
.Corporate management involvement on site was noted as being commendable and the security force attrition rates had shown continued improvement since 1979.
This assessment period corporate management involvement in the Physical Security Program was demonstrated by: adequate funding for program improvements including vehicle barriers in response to an NRC Information Notice; new N-ray equipment with improved imagery for package searches; a recording and monitoring system for the security radio network; and the establishment and imple-mentation of a goals program which focused on compliance with regulatory requirements.
Additionally, significant effort was expended during this assessment period to provide better liaison with local, county, and state law enforcement organizations by holding formal meetings.
The meetings focused on improving emergency response capabilities.
One such meeting, outside the assessment period, was attended by a region-based physical security inspector who found that the meeting was well attended and covered pertinent topics of mutual interest to the licensee and law enforcement organizations.
State police officials have expressed an interest in attending a radiological emergency response course.
Site security management has undertaken a review of security procedures in an effort to provide better distribution of work-loads, and a general updating.
About 60K. of the procedures have been revised and reissued.
A review by a physical security inspector found the procedure review process was comprehensive, with good attention to detail evident, and responsive to program needs.
Records were found to be complete, well maintained and accessible.
The licensee submitted two
CFR 73.71 security event reports during this period.
The reports were accurate and timely and compensatory actions were initiated in accordance with the Safequards Contingency Plan.
The licensee's security staffs, both corporate and site, were found to be adequate and effective in carrying out the program.
Position responsibilities are well defined to meet program needs and all duties are carried out in a professional and dedicated manner.
The effectiveness of the contract security management staff was demonstrated by the improved reliability and operating perfor-mance of security equipment, the professional attitude and appearance of personnel, knowledge of task assignments and general overall perforinance.
Contract supervision, as well as licensee management representatives conducted frequent, un-
k I
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announced, audits and surveillances of program activities during all shifts.
The contractor's staff has been augmented by establishing and filling the position of Operations Officer to provide better oversight of shift operations.
The incumbent is well qualified, experienced and appears to be effective.
The licensee's security organization continues to demonstrate unprofessional and effective implementation of the Security Plan.
2.
Conclusion Rating:
Category
Trend:
Consistent 3.
Board Recommemdations Licensee:
None NRC:
Continue implementation of minimum inspection progra I I
H ~
REFUELING AND OUTAGE MANAGEMENT (3/o)
1.
A~aal sis During this assessment period the annual 1984 refueling outage was accomplished between March and May.
The resident inspector and region-based inspectors reviewed outage activities.
This functional area includes review of the Inservice Testing Program.
As in previous assessment periods, planning and control of ou-tage activities continues to be a noteworthy strength.
Computer tracked planning coupled with aggressive supervisory control of plant activities, contributed to a smoothly organized outage in spite of earlier encountered problems.
During fuel transfer system pre-refueling checkout, the 'dummy'uel assembly was inadvertently dropped, damaging the fuel transfer car and a
portion of the drive system.
Damage to the fuel transfer car resulted in a major rescheduling of critical path primary system work items which the licensee effectively implemented.
Maintenance and surveillance activities conducted during the refueling outage were pursued with the same high level of integrity and expertise observed throughout the assessment period.
In response to NRC inspection findings identified early in the assessment period, the licensee embarked on an extensive revi-sion to the Inservice Testing Program for (}uality Group A, B, and C components and systems.
Although one of the inspector's immediate concerns for the timeliness of the required inspec-tions has been resolved, the licensee is still working on the final revision to the Inservice Testing Program, and incorpora-tion of up-to-date isometric drawings for leakage examination has not yet been completed and reviewed.
This NRC finding was preceded by a similar 1980 corporate guality Assurance Audit finding which was not addressed in a timely manner.
2.
Conclusion Rating:
Category
Trend:
Consistent 3.
Board Recommendations Licensee:
None NRC:
None
I.
LICENSING ACTIVITIES 1.
A~nal sl s In general, the RG&E performance in the area of licensing shows evidence of high level management involvement, clear understanding of the technical issues and a responsiveness to NRC initiatives.
During this SALP period a total of 61 licensing actions were completed.
Included were some complex actions such as the con-version of the Preliminary Operating License to an Full-Term Operating License, spent fuel pool rerack, and the introduction of a new fuel design for use in the reactor.
The successful completion of the actions is indicative of good management and control.
The licensee has exhibited a clear understanding of the issues in the resolution of technical problems.
A conservative approach is routinely employed when a potential for safety significance exists.
Technically sound and thorough approaches are presented in almost all cases.
Mith respect to responsiveness to NRC initiatives, deadlines are met.
Responses are technically sound and thorough in most cases.
Staff questions regarding the licensee submittals are usually resolved quickly by telephone followed by written documentation when requested.
Acceptable resolutions are pro-posed initially in most cases.
Reportable events are usually identified and reported in a timely manner.
2.
Conclusion Rating:
Category
Trend:
Consistent 3.
Board Recommendations Licensee:
None NRC:
None
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UALITY ASSURANCE/ UALITY CONTROL (5%)
l.
A~nal sis ality Assurance (QA) and Quality Control (QC) are addressed as a
eparate'functional area this assessment period in order to hig light indications of significant shortcoming in this area.
Regi I staff has evidence to conclude that QA and QC do not recei aggressive management support.
This lack of support has manifes d itself in the development of a station attitude that QA and Q
are not considered to be important to safety by plant management One inspectio was conducted by two region based inspectors in the QA area.
is inspection involved 95 inspection hours.
The two severity Le 1 IV violations identified during this inspec-tion were:
(1)
ilure to include Nonconformance Reports in the Technical Specific tion (TS) required semiannual audits of corrective actions nducted during 1983 and 1984 and (2) fail-ure to maintain cont lied access to four Level 0 storage areas.
Corrective actions by t licensee for the violations were:
( 1)
to include Nonconformance Reports as part of their semiannual audits and (2) the clarifi tion of Level 0 storage area access control requirements as des ibed in their Quality Assurance Manual and A-1303 Guide Proce ure and the installation of storage area perimeter fencing.
These corrective actions are acceptable and responsive to th concerns identified in the notice of violation.
a An analysis of inspection results in icates a general lack of understanding of the QA requirements ong the Corporate and Site personnel and Supervision.
For e
mple, a
QA auditor's failure io recognize the importance of nconformance Reports (NCRs)
as a means to achieve prompt 'corre ive actions for significant deficiencies resulted in the f lure to include these reports in the TS required semiannual udits.
This lack of coverage of NCRs also went unnoticed by co orate auditors, the offsite review committee and several level of management.
Similarly, QA personnel and several levels of ma agement failed to recognize and implement the QA program require nts for level 0 storage areas even though these areas were easi
observable on a day to day basis.
This inspection also identified lax attitudes of QA, p
nt supervision and management personnel toward maintaining written and disciplined administrative control program.
r example, i
required well over one year to revise and reiss e
procedures affected by a licensee reorganization.
Managemen attention is required in this area to assure that QA program requirements are known and met by personnel and all levels of management at both site and corporate offic A J
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UALITY ASSURANCE/ UALITY CONTROL (5jo)
l.
A~nal sis Quality Assurance (QA) and Quality Control (QC) are addressed as a
separate functional area this assessment period in order to highlight indications of significant shortcomings in this area.
Region I staff has evidence to conclude that QA and QC do not receive aggressive management support.
This lack of support has manifested itself in the development of a station attitude that QA and QC are not considered to be important to safety by plant management.
One inspection was conducted by two region based inspectors in the QA area.
This inspection involved 95 inspection hours.
The two severity Level IV violations identified during this inspection were:
( 1) failure to include Nonconformance Reports in the Technical Specification (TS) required semiannual audits of corrective actions conducted during 1983 and 1984 and (2) failure to maintain controlled access to four Level D storage areas.
Corrective actions by the licensee for the violations were: (1) to include Nonconformance Reports as part of their semiannual audits and (2) the clarification of Level D storage area access control requirements as described in their Quality Assurance Manual and A-1303 Guide Procedure and the installation of storage area perimeter fencing.
These corrective actions are acceptable and responsive to the concerns identified in the notice of violation.
An analysis of inspection results indicates lack of understanding of these QA requirements among the corporate and site personnel and supervision.
For example, a
QA auditor, who did not recognize the importance of Nonconformance Reports (NCRs)
as a means to achieve prompt corrective actions for deficiencies, did not include these reports in the TS required semiannual audits.
This lack bfI coverage of NCRs also went unnoticed by other QA auditors. Similarly, QA/QC personnel failed to recognize and implement the QA program requirements for level D storage area access control even though these areas were observable on a day to day basis.
This inspection also identified lax attitudes of QA, plant supervision and management personnel toward maintaining a written and disciplined administrative control program.
For example, it required well over one year to revise and reissue procedures affected by a licensee reorganization.
Management attention is required in this area to assure that QA program requirements are known and met by personnel and all levels of management at both site and corporate offic I J
In addition to the above findings, an extensive investigation was conducted into statements made by a
QA auditor who alleged that he had been pressured to delete valid audit findings from his audit reports and that he had been discriminated against in pay and performance evaluations because he identified too many deficiencies during his audits and resisted the pressure to suppress his findings.
A special inspection was performed to determine whether,'in fact, specific audit findings had been deleted from the audit report.
The audit findings in question involved deficiencies in administrative controls.
Although in two cases, deletion of audit findings was substantiated, they were of minor safety significance, and differences of opinion existed as to validity or whether they should have been handled outside the scope of the audit.
The investigation into.the allegations of discrimination and harassment failed to identify sufficient evidence to substan-tiate the claims.
The investigators interviewed personnel at all levels of management and the QA/QC organization, revealing a
pattern of indicators of a pervasive site and corporate manage-ment attitude that QA/QC are unimportant to safety of operation.
These indicators include:
lack of support for QC inspectors, placement of inexperienced personnel in key positions in the QC organization, and the appearance of a lack of thoroughness and aggressiveness of corporate QA in the performance of audits.
These attitudes are reflected by the crafts and technicians who appear to barely tolerate the efforts of QC personnel to oversee their activities.
In spite of the apparent lack of management support, QC inspectors have continued to perform their duties in a professional and competent manner.
The bulk of the QC inspector force, providing coverage of routine plant activities and station modification activities, is comprised of contractor personnel.
During this assessment period one contractor inspec-tor was hired as an RG&E employee.
As the result of the per-sonnel initiatives of the QC Supervisor, a significant increase in QC inspector training has been realized, improving QC inspec-tor performance, plant operating knowledge and credibility with plant personnel.
Although significant safety problems have not been identified as a result of these deficiencies, prompt management intervention is necessary to provide the appropriate support for the QA/QC programs at all levels in order to make the programs more meaningful and effective.
2.
Conclusion Rating:
Category
Trend:
None
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3.
Board Recommendations Licensee:
Review management objectives with respect to QA/QC organization and implement program to improve station program and its status.
NRC:
Perform program review to determine effective-ness of QA/QC program implementation and manage-ment involvemen l I
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V.
SUPPORTING DATA AND SUMMARIES A.
Investi ations and Alle ations Review In October 1983, several allegations were made to the NRC in regard to work performed by Bell-Schneider Corporation pertain-ing to the installation of the Post Accident Sampling System and modifications made in the Seismic Upgrade Program.
As a result of a special inspection, significant weaknesses were identified in administrative practices relating to modification processes and subsequent plant turnover and acceptance.
Final review of the licensee's revised modification program will be conducted in the next assessment period.
In February 1984 a special safety inspection was concluded which reviewed allegations presented to the NRC with regard to apparent (}uality Assurance audit improprieties.
The allegations were partially substantiated and an Enforcement Conference was convened on April 6, 1984 to discuss the inspector's findings with licensee management.
In addition, an investigation was conducted by the Office of Investigation into allegations of intimidation, harassment and discrimination of a gA auditor.
There was insufficient evidence to substantiate these claims.
Further details of these items may be found in section IV.J. of this report.
During June 1984, a former employee of Bell-Schneider Corpor-ation made allegations to the NRC concerning quality assurance improprieties in the modification documentation turnover.
Although inspector review of these allegations did not substan-tiate any wrongdoing, a concern for the proper handling of modification processes and turnover paperwork was identified and will be followed-up in the review of the revised program as discussed above.
B.
Escalated Enforcement Action None.
C.
Mana ement Conferences Held Durin the Assessment Period Enforcement Conference held at NRC Region I office on April 6, 1984, regarding follow-up of guality Assurance Allegation.
Enforcement conference held at NRC Region I office on November 5, 1984, regarding violation of Technical Specifications for handling of irradiated fuel in the Auxiliary Buildin i l
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Management meetings on February 3,
1984, March 1, 1984 and March 15, 1984 were held at the NRC Region I office to discuss the licensed operator requalification program.
D.
Licensee Event Re orts (LERs)
Tabular Listin Number A.
Personnel Error
B.
Design/Man./Constr. /Install
C.
External Cause D.
Inadequate Procedure
E.
Component Failure
X.
Other
.
Licensee Event Re orts Reviewed:
I Total (
-22
"I Reports Nos.
83-22 to 84-13 Only three sets of common mode events were identified:
a.
LERs 84-02 and 84-05 reported problems with MOV-700 (RCS loop A RHR suction valve) failing to stroke to the open position.
b.
LERs 83-30 and 84-13 reported the identification of Technical Specification changes improperly reflected in station proce-dures.
c.
LERs 83-27 and 84-06 reported personnel errors resulting in inadvertant automatic actuation of ESF or Reactor Protection System I I
TABLE 1 TABULAR LISTINGS OF LERS BY FUNCTIONAL AREA R.
E.
GINNA NUCLEAR POWER PLANT Area A.
Plant Operations Number/Cause 6/A, 1/B, 1/0, 4/E, 2/X Total
B.
Radiological Controls NONE C.
Maintenance 0.
Surveillance E.
Fire Protection 1/E, 1/B 2/0, 4/E NONE F.
Emergency Preparedness NONE G.
Security and Safeguards NONE H.
Refueling I.
Licensing Activities J.
guality Assurance/
guality Control NONE NONE NONE Total
Cause Codes:
A - Personnel Error B - Design, Manufacturing, Construction, or Installation Error C - External Cause 0 Defective Procedures E Component Failure X - Other
TABLE 2 INSPECTION HOURS SUMMARY 7/1/83 " 12/31/84 R.
E.
GINNA NUCLEAR POWER PLANT Hours
% of Time A.
Plant Operations
.
.
.
.
.
.
.
.
.
.
.
1841
B.
Radiological Controls
.
.
.
.
.
.
.
.
388
C.
Maintenance
.
.
.
.
.
.
.
.
.
.
.
.
.
220
D.
Survei 1 lance.............
255
E.
Fire Protection/Housekeeping
.
.
.
.
.
119
F.
.
.
.
.
.
.
.
.
346
G.
Security and Safeguards.......
141
H.
Refueling 5 Outage Management....
112
I.
Licensing Activities.........
J.
Qual ity Assurance/Qual ity Control..
176
Total 3598 100
- Hours expended in facility license activities and operator license activities are not included with direct inspection effort statistic TABLE 3 Violation Summar 7/1/83 12/31/84 R.
E.
GINNA NUCLEAR POWER PLANT A.
Number and Severit Level of Violations Severity Level I Severity Level II Severity Level III Severity Level IV Severity Level V
B.
Violation Vs. Functional Area FUNCTIONAL AREAS A. Plant Operations B. Radiological Controls C. Maintenance D. Surveillance E. Fire Protection
& Housekeeping F.
Emergency Preparedness G. Security Safeguards H. Refueling 4 Outage Management I. Licensing Activities J. Quality Assurance/Quality Control
0
14
20 Severity Levels I II III IV V OEV
1 Total s
6
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C.
~Summar (TABLE 3 Continued)
Inspection Report No.
83"19 83"22 83"23 83-23 83-23 83-24 84-02 84-02 84-02 84-02 84-05 Inspection Date 8/8-9/11 9/12"10/31 10/18-11/18 10/18-11/18 10/18-11/18 11/1-1/15 3/6"3/9 3/6"3/9 3/6-3/9 3/6-3/9 3/27-3/30 Subject Severity Level Failure to perform IV prompt corrective action Failure to address IV need for corrective action Failure to review IV SN procedure Failure to maintain V
good housekeeping practices Failure to adhere V
administrative procedures Failure to perform IV surveillance test Failure to measure IV ai rborne radioactive concentrations Failure to review IV procedure Failure to establish IV gualification program Failure to adhere to IV established procedure Failure to adhere to IV Inservice Inspection program Functional Area
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2/13-3/1 Inadaquate number at V
PORC quorum 2/13-3/1 Failure to use approved procedure 2/13-3/1 Failure to document IV adverse conditions 4/23-4/27 Failure to insure Radiation Emergency training IV 5/7-5/11 Failure to provide suitable measurements of airborne radioactive concentrations 5/14-5/18 5J14-5/18 Failure to include Nonconformance Reports Failure to control access to storage areas IV IV 6/9-7/31 10/5-10-19 Failure to identify inoperable system Failure to establish IV required prerequisites for irradiated fuel handling
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TABLE 4 INSPECTION REPORT ACTIVITIES REPORT INSPECTOR HOURS 83-17 Resident 138 83-18 Specialist
R.
E.
GINNA NUCLEAR POWER PLANT AREAS INSPECTED Routine inspection of plant operations; surveillance testing; maintenance; followup on Integrated Plant Safety Assessment Items; followup on Bulletins &
Circulars; Inservice Inspection Program Review; annual emergency exercise review and Licensee Event Reports Pipe Support Base Plate Designs Using Expansion Anchor Bolts; Seismic Analyses for As-Built Safety-Related Piping Systems and Masonry Wall Design 83-19 Resident 124 Routine 83-20 Specialist
83-21 Specialist
83-22 Resident 130 83-23 Resident; 159 Specialist Transport and receipt of radioactive materials Security Procedures, Organization, Audit, Records 5 Reports, Training/gualification and Safeguards Contingency Plans Routine, followup on NUREG 0737, Item II.B.1 Special, Allegations-inadequate contractor gC of modifications 83-24 Resident 155 Routine 83-25 Specialist
Emergency Preparedness 83-26 Specialist
Training and requalification 84-01 Resident 125 Routine, TMI Lessons Learned
(
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84-02 Special ist
Tran sportati on acti vities 84-03 Specialist
Allegations-gA audit findings 84-04 Specialist
Post Accident Sampling System 84-05 Speci al ist
84-06 Resident; 218 Specialist Inservice Inspection Program Routine 84-07 Region I 24~
Operator Licensing Examinations Management effectiveness gA program 84-08 Specialist
Emergency Preparedness 84-09 Specialist
Nonradiological chemistry program 84-10 Resident; 282 Speci al ist 84-11 Region I Routine, Reactor Coolant System Vent modification Operator Licensing Examinations 84-12 Specialist
Radiation protection program 84-13 Specialist
84-14 Region I 280 gA program-onsite, offsite review committees, program changes Licensed Operator Requalification Assessment 84-15 Specialist
Startup testing 84-16 Resident; 241 Specialist Routine, Allegation fol lowup 84-17 Specialist
Radioactive waste program 84-18 Special ist
Fire Protection/Prevention Program 84-19 Resident 209 Routine, TMI Action Plan Items 84-20 Specialist
Radiological environmental monitoring program 84-21 Specialist 161 Emergency Preparedness 84-22 Resident 137 Routine, TMI Action Plan Items, Simulator construction, calorimetric calculation and DB-25 breaker
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84-23 Resident;
Specialist Fuel handling in Auxiliary Building 84-24 Resident 278 Routine 84-25 Deleted 84-26 Specialist
Reactor Physics testing 84-27 Examiner 12*
Licensing Examination 84-28 Specialist
"Not included in director inspection effort
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LER Number 83-022 83-023 Type TABLE 5 LER SYNOPSIS 7/1/83 -12/31/84 R.
E.
GINNA NUCLEAR POWER PLANT Summary Description 30 day Block Valve MOV 516 Closed Due to Indicated Leakage through PORV-430 30 day CV Isolation Valve, AOV-846 Inoperable 83-024 83"025 83-026 83-027 30 day 30 day 14 day 30 day Steam Generator Flow Transmitter found out of tolerance Leak on Upstream Side of V-056E, Pressurizer Liquid Sample Manual Isolation Valve Boric Acid Storage Tanks Out of Specification A Unit Trip due to Personnel Error Resulting in a Loss of Reactor Coolant Loops with the Reactor Coolant System Temperature greater than 350 degrees F
83-028 83-029 83-030 84-001 84-002 30 day CVCS Boric Acid System Leakage 30 day Calibration of Nuclear Power Range 30 day Permissive Circuit, P-10 Less Conservative than Technical Specifications 30 day Inoperable Residudal Heat Removal (RHR)
System 30 day Inoperable Safety Injection Accumulators 84"003 30 day Potential Loss of Residual Heat Removal (RHR) Capability 84-004 30 day Inoperable Waste Gas Oxygen Analyzer
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84-005 84-006 84-007 30 day 30 day 30 day Inoperable Residual Heat Removal (RHR)
System Automatic Actuation of the Engineered Safety Feature (ESF)
Automatic Actuation of the Reactor Protection System (RPS)84-008 84-009 84-010 84-011 30 day Automatic Actuation of any Engineered Safety Feature 30 day Inoperable Fire Suppression System 30 day Inoperable Rod Position Indicating System 30 day Inoperable Fire Suppression System 84-012 84-013 30 day 30 day Damper on 1C Auxiliary Building Exhaust Fan Closed During Fuel Movement Failure to Exercise Control Rods in Bank D during monthly Surveillance Test
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Docket No 50-244 ENCLOSURE
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION I
631 PARK 'AVENUE KING OF PRUSSIA, PENNSYLVANIA19406 laR 0 8 SSS Rochester Gas and Electric Corporation, ATTN:
Mr. Roger W. Kober Vice President Electric and Steam Production 49 East Avenue Rochester, New York 14649 Gentlemen:
Subject:
Systematic Assessment of Licensee Performance (SALP)
The NRC Region I SALP Board conducted a review on February 25, 1985 and evaluated the performance of activities associated with the R.
E. Ginna Nuclear Power Plant.
The results of this assessment are documented in the enclosed SALP Board report.
A meeting has been scheduled for March 18, 1985 at your offices to discuss this assessment.
This meeting is intended to provide a
forum for candid discussions relating to this performance.
At the meeting, you should be prepared to discuss our assessment to improve performance.
Any comments you may have regarding our discussed at the meeting.
Additionally, you may provide written within 20 days after the meeting.
and your pl ans report may be comments Following our meeting and receipt of your response, the enclosed report, your response, and a
summary of our findings and planned actions will be placed in the NRC Public Document Room.
Your cooperation is appreciated.
Sincerely, Thomas E. Murley Regional Administrator Enclosure:
As stated cc w/encl:
Harry H. Voigt, Esquire Central Records (4 copies)
Director, Power Division Public Document Room (PDR)
"
Local Public Document Room.(LPDR)
Nuclear Safety Information Center (NSIC)
NRC Resident Inspector State of New York
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