IR 05000266/1997001
| ML20198N878 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 01/14/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20198N875 | List: |
| References | |
| 50-266-97-01, 50-266-97-1, 50-301-97-01, 50-301-97-1, NUDOCS 9801210244 | |
| Download: ML20198N878 (7) | |
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l PolNT BEACH NUCLEAR PLANT
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SALP 13
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. Repod No. 50 266/97001; 50-301/97001 1.
INTRODUCTION
' The Systemmic Assessment of Licensee Performance (SALP) process is used to develop the.
Nuclear Regulatory Commission's (NRC) conclusions regarding a licensee's safety performance.
Four functional areas are' assessed: Plant Operations, Maintenance, Engineering, and Plant Support.- The SALP report documents the NRC's observctions and insights on a licensee's -.
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- performance and communicates the results to the licensee and the public, it provides a vehicle for clear communication with licensee management that focuses on plant performance relative to
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safety risk perspectives. The NRC utilizes SALP results when allocating NRC inspection
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. resources at licensee facilities.
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- This report is the NRC's assessment of the safety performance at the Point Beach Nuclear Plant
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for the SALP 13 period from April 28,1996, through November 29,1997.
An NRC SALP Board met on December 17,1997, to review the caservations and da?a on
. performance and to assess performance in accordance with the guidance in NRC Management Directive 8.6, " Systematic Assessment of Licensee Performance." The Po!nt Beach SALP Board members included:
Board Chairman
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J. A. Grobe,' Director, Division of Reactor Safety, Rill
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Spard Members
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J. N. Hannorf, Director, Project Directorate ill-1, NRR M. L Depas, Acting Deputy Director, Division of Reactor Projects, Rlli ll.
PERFORMANCE ANALYSIS
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Plant Operations Performance in the functional area of operations improved and was good toward the end of the Assessment period. Significant deficiencies in the conduct of control room activim 4dentified eartf in the assessment period were adequately addressed through implementation of cffective
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Limprovement initiatives. Also, in the latter portion of the assessment period, operational decision
- making was observed to be conservative and appropriately focused on safety; procedural quality.
Land adherence improved; and equipment configuration controlimprovemants were noted. In
- addtion, improvement in the quality assurance and self-assessment programs was observed.
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Sign 4icant improvement in the implementation of the condition reporting system was identified, but because of the large increase in the number of issues being identified, challenges remained
'with the prioritization and ' city completion of related corrective actions.
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Early in the assessment period, NRC and Point Beach staff identified significant deficiencies in the conduct of control room activities, including an on-shift crew viewing a training video in the control room; a control operator leaving his normal watch station with no designated relief; mandatory shift technical advisors lect ng the site; and an operator failing to respond to an i
alarm. As a result of these proolems, operations personnel developed and implemented an effective standard for the conduct of operations, hired new staff for some key positions, and brought in experienced operators from other reactor facilities to provide mentoring and feedback to the operating crows. The conduct of operations during the last three unit startups and two unit shutdowns was marked by good command and control, effective communications, operator awareness of plant conditions, and thorough shift tumovers.
Operational decisions made later in the assessment period were conservative aid appropriately focused on safety. Unit 2 was shut down once to corrcct a potential design deficiency and a second time to correct a test deficiency. Both shutdown decisions were made in a timely manner. Unit i restart was delayed to repair an inoperable intermediate range nuclear detector, a repair not required to satisfy Technical Specification (TS) requirements. The problems with nonconservative TS requirements, and nonconservative interpretations of otherwise appropriate TS requirements, that were seen early in the assesstnent pariod, were not evident later in the period.
Ope, rations personnel stopped work and had procedures corrected on a number of occasions during unit maneuvering late in the assessment period. No procedure violations were observed during extensive NRC irtspector observations. This good performatico reflected improved sensitivity to y ;edural adherence requirements. Earlier, operators had tolerated inadequate procedures and did not demand that they be corrected. This problem was addressed after the NRC took enforcement action for inadequate procedures associated with safety-related battery lineups, auxilbry feedwater pump operation, and leakage of a small amount of coolant inventory through a reactor coolant pump seal water injection vent valve. Point Beach management subsequently committed to upgrade normal, abnormal, and emergency operating procedures.
While improvements in procedure content and use were noted at the end of the assessment period, the large number of required procedure changes continued to challenge the facility's procedure development and review capabilities.
Equipment configuration control and valve mispositioning events occurred early in the period.
These events included: incorrectly isolating a Unit 1 condenser steam dump valve, resuhing in a 3-degree rise in reactor coolant system temperature while shutdown; incorrectly isolating the Unit 1 crossover steam dump system, causing a 50 mega-watt electric load decrease during unit operation; and running a residual heat removal pump for 38 minutes with the discharge valve closed. No significant configuration contml or mispositioning events occurred during unit maneuvoring late in the assessment period. Operations management placed a high priority on eliminating configuration control and mispositioning events, sind was implementing a new computer generated danger tagging process to further decrease the likelihood of these types of events at the end of the assessment period.
Long-term improvements were noted in the quality assurance function and several insightful self-assessments perforrN in the latter portion of the assessment period were indicative of a commitment to continued improvement. This represented an improvement from performance early in the assessment period, and followed personnel, organizational, and safety focus
. changes. Significant quality assurance audit findings received the attention of senior management, but a system to completely integrate and properly prioritize corrective action
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. commitments was not complete at the~end of the assessment period. Substantial improvements -
- were noted in the implementation of the condition reporting system.L The review and assessment J
_of condition reports was considered to be good, but challenges remained with the prioritiration
- and timeliness of completing corrective actions, in part, due to the large number of lasues J
identified during the assessment period.
4 The performance rating in Operations is Category 2.
J 8,1 Maintenance Maintenance personnel demonstrated high q1ality workmanship and surveillance tetting was
( performed in a thorough and complete manner to ensure equipment operability.1The -
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improvements in Point Beach staffs identification of plant problems resulted in a large increase.
"i in the number of maintenance work requests, an improvement in the overall material condition of-
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- the plant as the more signifi
- : ant maintenance items were addressed, and an increase in the :
backlog of lower priority work requests. Some self-identified weaknesses were noted in tne q
- l maintenance program, particularly in the area of work control, which were being addressed i
1 through several program enhancements that were underway at the end of the assessment -
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- : Period.
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- The maintenance s'aff was experienced and work acSvities were generally performed in a
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thorough and professional manner. Equipment problems were documented in appropriate
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. work requests and use of the corrective Etion process by the mainter ance staff improved.
c The maintenance backlog increased significantly duing this period.. The increase in the -
backlog was, in part, the prodoet af increased ide:ntification of equipment in need of repair and
identification of a large numbW (4 design Ismes. The work control process contained
weaknesses in prioritizing less significant work ordeti; und coordinating activities to develop workable schedules. This led to emergent and routine items not being appropriately planned and scheduled for completion.~ The lack of work plans and prc:adures for a two year
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preventive maintenance activity resulted in the G03' emergency diesel generator being out-of-
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service for over three weeks prior to work starting. Additionally, the program for planning and scheduling forced outage work contained weaknesses and did not fully meet the current -
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procedural guidelines at Point Beach.
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- Several self-initic d reviews identified the need for programmatic improvements in the
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. f.mintenance area.: Program enhancements already underway are intended to improve
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prioritization, improve trending of equipment availability and required rework, designate
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- protected equipment during maintenance, increase maintenanco supervision oversight, and clearty establish maintenance quality standards and expectations. Management has -
- undertaken a long-term initiative to improve maintenance procedures to ensure experience of
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the craft is supported by the new, more detailed procedures.
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LThe efforts to identify and address equipment issues resulted in the resolution of many equipment problems and improvement in the material condition of the plant. Equipment issues
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- of past work activities, and by conditio.) reports generated to document equipment deficiencies.
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The identification' of these equipment issues was considered a positive aspect of the -
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,lmprovement processes being implemented at Point Beachc Installation of new steam
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generators and modifications installed to address design bases issues, such as the installation '
of accumulators for the feedwater control valves and new emergency diesel generator govemors, contributed to an improvement in the overall material condition of the plant.
The performance rating in Maintenance is Category 2.
C.
Ennineerina Performance in the engineering functional area during this assessment period was acceptable.
Engineering coordination and support of the Unit 2 steam generator replacement project was very good; however, the failure to have an approp.iate Ivvel of understanding of the design banes affected the engineering department's ability to provide adequate day-to-day support and to property respond to operationalissues. Point Beach management initiated actions in response to identified problems and toward the end of the assessment period some engineering improvement was seen. Identification of safety issues improved considerably after NRC inspectors identified significant problems early in the assessment period. While the safety evaluation process improved over the assessment period, programmatic concems with inservice testing continued throughout the period.
Early in the assessment period, significant weaknesses were identified in the engineering area.
In response to the number of issues identified by the NRC, Wisconsin Electric management brought in outside resources to help assess the extent of the engineering problems.
Substantial additional staff and contractors were hired to assist with the resolution of issues, including extensivo review of past activities to ensure safety issues were properly identified.
At the beginning of the assessment period, engineering work lacked rigor, resulting in poor operability determinations that failed to recognize when equipment was inoperable. Whi!e improvements were seen toward the end of the perioc;, sufficient justification to support operability conclusions was stilllacking in several cases. Several operability determinations required for restart of Unit 2 were not ade.quately bounded and lacked rigorous engineering justification; however, the weaknesses did not result in inoperable equipment. Examples included operability determinations on fire protection, seismic and cable separation issues, the service water system, and the turbine-driven auxiliary feedwater pump. Some safety evaluations were also weak, with examples of unreviewed safety questions being identified by the NRC in the beginning of the assessment period. Two notable examples of safety evaluations that incorrectly concluded that a TS change was not required or that ~1 unreviewed safety question did not exist were the issues involving the number of service watvr pumps required during a loss of coolant accident and the use of manual operator action for the motor-driven auxiliary feedwater pumps during an accident. The pdur quality of ufety evaluations and the lack of sufficient supporting information hampered the NRC's ability to make an informed independent determination of the acceptability of proposed license amendments.
Toward the end of the assessment period, the quality of safety evaluations had substantially improved, although inadequacies in the final safety analysis report still continue to be identified.
Toward the end of the assessment period, examples of non-rigorous engineering work continued to surface. For example, engineering staff were involved h a series of changes to safety injection system valve lineups, including the sequence in which the valves were opened and shut in an opelating procedure, resulting in steam void formation in the residual heat removal system piping. In another example, engineering personnel incorrectly determined that a spare component cooling water pump motor had a wrong sized enuplig and could not fulfill
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Appendix R safe shutdown requirements? After further review, it was recognized that the?
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y coupling was conect.
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At the beginning of the assessment period, the ability to identify safety issues was wouk.L NRC
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involvement was necessary to ensure adequate confidenca tt,at the design bases of the plant
- were being maintained. Engineers appeared to not recognize thWr role in maintaining and o
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protecting the design bases. This was evident in the number of aux!!iary feedwatwr system 1 deficiencies identified by both the NRC and Point Beach staff.- The deficiencies were
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L determined to be caused by inadequate design reviews during modifications to the system.
Corrective actions, including the formation of the System Enginoonng Review Board, resulted in a detailed system-by system review of the facility and identification of numerous design -
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issues, several of which were substantial. :These included, among others/ discovery of si
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. potential common mode failure in the direct-current supply system which could have disabled
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J the auxiliary feedwater system, and discovery that non-environmentally-qualified materials were i
used in the containment hatch. The planned resolution of the design issues was satisfactory.
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L Problems with the inservice testing program surfaced throughout the assessment period. For
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L exampio, surveillance testing did not adequately encompass design bases requirements. : This -
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.'was first identified for the service water pumps, but later was found to impact all safaty-related j
- pumps. Instrument inaccuracies were not properly incorporated into acceptance enteria and.
changes to the acceptance criteria were not controlled. This latter concem was evidenced by a-
' proposed change to a service water pump testing requirement to move a bearing vibration
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value out of the alert range. In other programmatic areas, improvements were noted in training
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- on 10 CFR 50.5g safety evaluations and in the overall 50.5g process. Wisconsin Electric -
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' committed to a final safety analysis report upgrade program to incorporate design bases
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information into the licensing basis. When completed, this program should be an important aid
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to the engineering staff in understanding and maintaining Point Beach's design bases.
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improvements were also seen in the area of self-assessment. This was evidenced not only by j
the large number of design defsiencies identified, but also by a rigorous review performed on r
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the inservice testing ' program.
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(1 The performance rating in Engineering is Category 3.
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D.
Plant Support L
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, Performance in the plant support area was good, but declined during the assersment period
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due to initially ineffective corrective actions for high radiation area control problems, radiation L
instrument and self-reading dosimeter calibration problems, and problems with security.
L compensatory actions and vehicle searches. Fire protection strengths were noted in sweral
. areas; however, significant safe shutdown issues were identified as a result of Wisconsin Electric's extensive fire protection safe shutdown rebaselining initiatives. Performance in m
< emergency preparedness (EP) was very good with the EP staff being proactive _in
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- self-identifying deficiencies and initiating corrective actions. Performance in the chemistry, c
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environmental monitorint,, radioactive waste, and radioactive materials transportation programs
. was goodi s-Radiation protection performanco declined during the assessment period due to repeat high
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radiation area boundary control incidents and ineffective corrective r.ctions. A common cause ianalysis was performed and identified several causes, including siack of management expectations for worker performance, lack of communication, and inadequate work oversight.
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Once identified, corrective actions werr. Implemented and appeared to be effective during the last six months of the assessment period. Deficiencies in the instrument calibration program were self identified, but corrective action development and implementation have been slow.
Poor radiation worker practices were identified by the NRC and the health physics staff during the assessment period. Howf ver, good radiation protection performance was exhibited during the steam generator replacement project with a total radiation exposure of 188 person-rem for the project. The radiological environmental monitoring, solid radioactive waste, transportation, and effluent programs were allimplemented wel!.
Overall performance in the chemistry area was good and reactor water quality was very good.
Some weaknesses were identified in this area regarding tracking and trending of daily checks for radiologicalinstruments and documenting corrective actions when chemical parameters were exceeded. in addition, corrective actions for previous valve mispositionings were not effective in preventing a reactor coolant system sample bypass valve from being mispositioned open.
Security performance was adequate. Repeat problems involving vehicle searches, implementation of compensatory measures, and vehicle barrier effectiveness were identified.
On two occasions, vehicles were not properly searched; on three occasions compensatory measures were not implemented in a timely manner; and on three occasions, the vehicle barrier system was degraded. These events resulted from weak oversight and implementation of basic security practices. Contributing to the search and compensatory measures deficiencies were weak corrective action and root cause analyses. Staff shortages also affected the licensee's ability to conduct comprehensive tactical drills. However, security program actions involving control of har'd-carried packages and personnel access controls were effectivelv implemented.
The operational readiness of Wisconsin Electric's EP program was very good. The EP staff were picactive in identifying several concems requiring corrective action, in addition, those concerns identified by quality assurance staff, items identified during critiques of training activities, and actual emergency plan activation were appropriately addressed. Corrective action strategies were appropriate. Progress on resolving NRC and self-identified concems was very good. Program staffing issues from the prev'ous SALP have been resolved.
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Overall, implementation of the fire protection program was good. The fire protection staff was experienced and knowledgeable and was taking effective corrective actions for identified fire protection problems. Program strengths included a low number of fire protection impairments requiring a fire watch, control of transient combustibles, evaluations of fire protection problems, and good material condition of fire protection equipment. Audits and quality assurance work monitoring reports cont!sted of performance-based observations of conditions in the plant and were effective in identifying problems in the fire protection program. Through extensive fire protection safe shutdown rebaselining initiatives, several deficiencies in the safe shutdown program were identified. These deficiencies resulted in four violations which have been corrected or were scheduled for correction. Additional violations were identified for failure to adsquately implement emergency lighting surveillances, failure to have adequate procedures to perform emergency lighting surveillances, and failure to ensure that the fire brigade members were meeting training requirements. Also, weaknesses were identified regarding fire brigade
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drills, with an excessive number of people on drills who were credited for meeting tra'ning
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requirements, and fire brigade critiques that. wore not always effective in identifying fire brigade.
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- drill problems.
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The performance rating in Plant Support is Category 2.
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