IR 05000267/1987006
| ML20234C856 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain  |
| Issue date: | 07/01/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20234C855 | List: |
| References | |
| 50-267-87-06, 50-267-87-6, NUDOCS 8707060694 | |
| Download: ML20234C856 (40) | |
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SALP BOARD REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE 50-267/87-06 Public Service Company of Colorado Fort St. Vrain Nuclear Generating Station May 7, 1986, through April 30, 1987 i
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INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) picgram is an integrated NRC staff effort to collect available observations and data on a periodic basis and to evaluate licensee performance based upon this information.
SALP is supplemental to normal regulatory processes used to ensure compliance to NRC rules and regulations.
SALP is intended-to be sufficiently diagnostic to provide a rational basis' for allocating NRC resources and to provide meaningful guidance to the licensee's management to promote quality and safety of plant operation.
An NRC SALP Board, composed of the staff members listed below, met on June 11, 1987, to review the collection of performance observations and data to assess the licensee performance in accordance with the guidance-in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance."
A summary of the guidance and evaluation criteria is provided in Section II of this report.
This report is the SALP Board's assessment of the licensee's safety performance at Fort St. Vrain for the period May 7,1986, through April 30, 1987.
SALP Board for Fort St. Vrain:
R. E. Hall, Deputy Director, Division of Reactor Safety and Projects, RIV,(Chairman)
J. A. Calvo, Director, Project Directorate IV, NRR R. L. Bangart, Director, Division of Radiation Safety and Safeguards, RIV J. E. Gagliardo, Chief, Reactor Projects Branch, RIV J. P. Jaudon, Chief, Project Section A, Reactor Projects Branch, RIV R. E. Farrell, Senior Resident Inspector K. L. Heitner, Project Manager, NRR Attendees at all'or part of the SALP Board meeting were:
D. E. Hickman, Performance Evaluation Branch, NRR R. E. Ireland, Chief, Engineering Section, RIV P. W. Michaud, Resident Inspector, RIV W. C. Seidle, Chief, Technical Support Staff, RIV M. E. Skow, Project Engineer, Project Section A RIV E. B. Tomlinson, Project Engineer, NRR II. CRITERIA Licensee performance was assessed in 11 selected functional areas.
Each functional area normally represents an area significant to nuclear safety and the environment.
One or more of the following evaluation criteria were used to assess each functional area.
A.
Management involvement and control in assuring quality B.
Approach to resolution of technical issues from a safety standpoint
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Responsiveness to NRC initiatives D.
Enforcement history E.
Operational ever,ts F.
Staffing (including management)
However, the SALP Board is not limited to these criteria and others may have been used where appropriate.
Based upon the SALP Board assessment, each functional area evaluated is classified into one of three performance categories.
The definition of these performance categories is:
Category 1.
Reduced NRC attention may be appropriate.
Licensee management attention and involvement are aggressive and oriented toward nuclear safety; licensee resources are ample and effectively used so that a high level of performance with respect to operational safety is being achieved.
Category 2.
NRC attention should be maintained at normal levels.
Licensee management attention and involvement are evident and are concerned with nuclear safety; licensee resources are adequate and are reasonably effective so that satisfactory performance with respect to operational safety is being achieved.
Category 3.
Both NRC and licensee attention should be increased.
Licensee management attention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to
,be strained or not effectively used so that minimally satisfactory performance with respect to operational safety is being achieved.
III. SUMMARY OF RESULTS The licensee's performance showed significant improvements in outages, maintenance, security, licensing and quality programs, all of which moved from Category 3 to Category 2.
The only area which remained in Category 3
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A strong positive trend was noted in i
emergency preparedness and the next emergency drill, scheduled for i
August 1987, should establish whether or not this functional area has been improved sufficiently to consider it to be Category 2.
It was also found that plant operations continued the up trend previously noted.
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The licensee's perforn'ance is summarized in the table below, along with the performance categories from the previous SALP evaluation period:
Previous Present Performance Performance Category Category Functional Area (3/1/85 to 5/6/86)
(5/7/86 to 4/30/87)
A.
Plant Operations
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B.
Radiological Controls
1 C.
Maintenance 3*
D.
Surveillance
2 E.
Fire Protection
1 F.
Emergency P'aparedness
3*
G.
Security
2 H.
Outages
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Quality Programs and
2 Administrative Controls Affecting Quality J.
Licensing Activities 3*
K.
Training and Qualification
2 Effectiveness
- Positive trend noted by SALP Board The total NRC inspection effort during this SALP evaluation period consisted of 31 inspections including resident inspector inspections and emergency exercises for a total of 4,428 direct inspection hours.
IV.
PERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis The assessment of this area consists chiefly of the activities of the licensee's operational staff (e.g., licensed operators, shift technical advisors, and auxiliary operators).
It is intended to be limited to operating activities such as:
plant startup, power operation, plant shutdown, and system lineups.
Thus, it includes activities suct as reading and logging plant conditions, responding to off-nornal conditions, manipulating the reactor and auxiliary control;, plant-wide housekeeping, and i
control room professionalism.
i This area has been inspected on a continuing basis by the NRC resident inspectors and frequently by NRC regional inspectors.
Specific areas inspected included verification of compliance with Technical Specifications parameters and limits, walkdowns
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of safety systems, review of licensee event reports and followup on operating events.
No violations were cited during this assessment period in the plant operations area.
There were six licensee event reports (LERs) attributed-to this i
functional area. Two LERs involved reactor scram actuations, and two involved loop shutdowns (an ESF actuation); however, these all occurred with the reactor already shutdown. One LER involved the failure to meet the limiting condition for the flow during reactor strartup. The licensee took positive _ action to retrain operators in this instance. One-other LER was not considered to be of exceptional significance.
The reactor was shut down for most of this assessment period for a major outage. The operators established and maintained plant conditions to support the outage.
Significantly, this was the first outage of long duration in which there was no water ingress to the core. The reactor startup at the end of the
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assessment period was thus accomplished with no prolonged core dryout period at low power.
The licensee conducted wveral startups and shutdowns in order to train operators and meet requalification training requirements.
Management support of operations was evident both from the frequent presence of senior managers in the control' room and from the management planning team activities. The management planning team served to-focus engineering.and maintenance resources to support operations.
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I NRC inspectors monitored startup activities closely because of the prolonged shutdown. This included augmented coverage of control room activities. The licensee exhibited a conservative approach to the startup and safety issues; the licensee's solutions to problems were well thought out and acceptable from a safety perspective.
The program to identify deficiencies before and during startup was effective in identifying problems. This caused an increase in the maintenance backlog; however, the licensee worked diligently to keep the maintenance backlog manageable.
Many new procedures were promulgated under the perfonnance enhancement program, and the licensee experienced some problems with utilizing these procedures. This required the extensive use of procedure deviation reports. The situation was analagous l
to the startup of a newly licensed facility. The new procedures were considered to be better than the old ones, despite the problems with their initial use.
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The licensee has a large number of temporary configuration reports. These constitute defacto' design changes. The. licensee has established a task force to address this area.
Licensed operators did exhibit awareness and knowledge of temporary -
configurations in existence, and therefore these did not constitute an immediate safety problem, although they should be replaced by formal design changes.
Another area of concern was the excessive number of lighted control room annuciators that did not represent truly off normal conditions.
The licensee is aware of the potential problems of not operating to a " black board," but the correction of this area has not been assigned a high priority.
Operator performance, as observed by the NRC inspectors, has been very good with a high degree of control room decorum observed, and excellent operator morale exhibited.
During restart activities, the augmented NRC resident inspection staff maintained an almost 24-hour a day presence onsite with a very strong emphasis on control room activity. The NRC inspectors observed, among other things:
A very high level of licensee management presence in the
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control room.
Close attention to detail, including repeated checks of LC0
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compliance beyond the normal frequency of checks required by Technical Specifications and procedures.
Operators coming in on their own time or hours early for
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shift to participate in startup activities.
A very conservative approach to plant operation, a marked
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improvement over recent previous plant operation witnessed.
An apparent team spirit and cooperation not previously seen
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at FSV.
An orderly and controlled startup.
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Additionally, licensee management exhibited an improved ability to clearly identify the root causes of operational problems and to take appropriate corrective actions. The plant startu,p, which commenced on April 17, 1987, was conducted in a manner that allowed NRC regional management on April 26, 1987, to release the plant from a 10 percent thermal power hold so that the plant was then authorized to_ operate at 35 percent power (at FSV the turbine generator is not put on the line until the plant reaches approximately 28 percent of full power).
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Conclusions Overall-performance in the area' of plant operations has improved during this assessment period. Management support of operations is evident at all levels of the licensee's corporate structure.
The licensee is considered to be Performance Category 2 in this
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Board Recommendations a.
Recommended NRC Actions The NRC inspection of this functional area should be consistent with the routine inspection program, b.
Recommended Licensee Actions Licensee management is encouraged to continue the improvement effort in this functional area, including:
Eliminate the backlog of deficiency report tags
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Eliminate the procedure deviation reports
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Continue'to upgrade operating procedures
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Continue training of new operators
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Work with nuclear engineering to clear the backlog of
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temporary configuration reports Eliminate unnecessary alarms and work with nuclear
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engineering _ towards a " black board concept."
B.
Radiological Controls 1.
Analysis Five inspections concerning radiological controls were conducted during the assessment period by region-based radiation specialist. inspectors. These inspections involved the following areas:
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Radioactive Waste Management
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Radiological Effluent Control and Monitoring
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' Transportation of Radioactive Materials
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Water Chemistry Controls
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a.
Occupational Radiation Safety This area was inspected once during the assessment period.
The licensee maintains an adequate staff of well qualified i
health physics personnel to support plant operations. A turnover rate of less than 10 percent for health physics technicians was noted for this SALP period, down from the 30 percent rate noted in the previous SALP report.
Vacancies were filled in a timely manner with qualified personnel.
Management oversight and day-to-day review is pr <ided by the Support. Services Manager (Radiation Protect ir r Manager), a health physics supervisor, and two staff health physicists.
Independent licensee audits are performed by onsite and corporate audit groups, which routinely use outside technical experts on the audit teams.
In response to the last SALP period concern regarding audit checklists, the licensee had taken action to expand the audit checklists used during audits of radiological controls activities.
The licensee continues to be responsive to NRC concerns and
initiatives. The licensee had not in:plemented a permanent l
ALARA program. The ALARA program is scheduled for completion in August 1987.
The licensee keeps the NRC informed as to the status of open items.
The licentee had taken action to resolve the concern regarding the stop-work authority for health physics technicians identified in the previous SALP assessment by issuing instructions that delineated the independent authority of the technicians to stop unsafe radiological work activities.
The person rem values at FSV continues to be well below the national average for light water reactors.
The 1986 values reflect even lower values due to the extended shutdown of the plant without extensive work in radiological areas.
The external exposure at FSV during 1986 was less than 2 person-rem compared to the national average of about 500 person-rem for light water reactors.
The exposure at FSV for 1987 to date has been less than 0.1 person-rem.
No problems were identified concerning the radiological aspects of general employee training, radiation worker training, and training for the health physics staff.
b.
Radioactive Waste Management This area was inspected once during this SALP period. The licensee had implemented a radioactive waste processing
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control program that satisfied the requirements of 10 CFR Parts 61.55 and 61.56.
No problems were identified in this area, c.
Radiological Effluent Control and Monitoring This area was inspected once during this SALP period; however, the radiological environmental monitoring program was not included in the inspection during this assessment period.
The data contained in the 1986 Environmental Monitoring Report indicated that anomalies exist concerning tritium concentrations in atmospheric samples.
The licensee is developing a beta radiation monitor for the reactor building sump effluent pathway. This matter has been discussed in several inspection reports and the last SALP report.
Even though the licensee was issued two violations involving effluent releases, no significant problems were identified during the assessment period.
The licensee has implemented a comprehensive audit program involving effluent releases and environmental monitoring to assure that a high quality program is maintained.
The radiochemistry confirmatory measurement portion of this program was inspected once during the SAlp period.
No significant problems were noted.
The comparison of sample results between the NRC and the licensee were in 100 percent agreement.
This percent of agreement is above the normal industry average of about 90 percent.
Licensee audits in this area appear to be satisfactory but could be improved by use of a technical expert in water chemistry and radiochemistry on the audit team.
d.
Transportation of Radioactive Materials i
This area was inspected once during the assessment period.
No problems were identified in this area. During the assessment period, the licensee made approximately 50 radioactive material shipments, of which 22 were spent fuel shipments to the U.S. Department of Energy, Idaho.
The licensee maintains a strong program and has taken effective action to correct problems identified by the NRC.
Audits are effective and comprehensive.
No problems were identified regarding training, assignment of responsibilities, and procedures.
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Water Chemistry Controls This area was inspected once in the assessment period.
No problems were identified during this inspection. The licensee has conducted internal audits in this area; however, the audit team has not included a member with expertise in water chemistry.
2.
Co n,c', u s i o n s The licensee maintains an aggressive radiation control program.
The radiation protection staff consists of an adequate number of well qualified personnel.
The licensee maintains high quality programs in the areas of effluent controls, radioactive waste management, transportation of radioactive materials, and radiochemistry.
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program quality is maintained by day-to-day management oversight and internal audits and program reviews.
The licensee shows consistent evidence of pre planning and assignment of priorities in long range and day-to-day activities.
The licensee has demonstrated a clear understanding of the issues and technically sound judgement is exercised in most decisions. The licensee's enforcement history indicates that violations are not repetitive and not indicative of programmatic problems.
The licensee is considered to be in Performance Category 1 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions Consideration should be given to reduce the NRC inspection effort in this area.
b.
Recommended Licensee Actions Management attention is needed to assure that a permanent ALARA program is established that meets the recommendation of Regulatory Guide 8.8 and 8.10.
The audit program for chemistry and radiochemistry should include a team member with technical expertise in the areas being audited. The licensee should investigate and resolve why certain atmospheric tritium samples were above normal background levels.
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C.
Maintenance 1.
Analysis The assessment of this area includes all licensee and contractor activities associated with preventive or corrective maintenance of instrumentation and control equipment and mechanical and electrical systems.
This area was inspected by region based NRC inspectors assisted by consultants.
Each inspection was a team inspection.
This area was also inspected on a continuing basis by the NRC resident inspectors.
There were no violations, and no licensee event reports in this area during the assessment period.
During this assessment period, the licensee appointed a new maintenance superintendent, who has appropriate experience.
Maintenance procedures are still being revised in order to improve them. Maintenance procedures to maintain compliance with 10 CFR 50.49 (Environmental Qualification of Equipment)
were promulgated.
Field walkdowns of maintenance procedures by both technicians and engineers have added to the quality of the licensee's new and revised maintenance procedures.
The backlog of maintenance requests was reduced.
Corporate and plant management knowledge, concern, and attention to the maintenance backlog was apparent and continuing.
i The licensee approached maintenance from a more systematic and generic viewpoint than has been exhibited at Fort St. Vrain in the recent past. The licensee utilized contractars during the outage but normally relies on permanent employees to perform plant maintenance.
The quality of maintenance performed increased as the percentage of maintenance performed by permanent employees increased.
The licensee's enforcement history during this assessment period has been excellent, and maintenance responsiveness to NRC initiatives has been open and enthusiastic.
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The majority of this assessment period was an outage to make EQ modifications. The maintenance staff worked long hours and was augmented by both PSC employees from other plants and contractor personnel. At the end of the assessment period there was still a substantial backlog of maintenance requests. However, maintenance management appeared to be in control of the situation and, with the assistance of station and corporate management, was addressing the above problems in order to continue to improve performance in this functional area.
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Conclusions The licensee's performance in this functional area has improved and is continuing to improve.
The licensee has made substantial changes to procedures including the addition of preventative
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maintenance and environmental qualification considerations to
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The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions NRC activity in this area should continue at a level consistent with the routine inspection program.
b.
Recommended Licensee Actions The licensee has made substantial improvement in this functional area during the assessment period.
However, continued management attention needs to address the following:
Continued reduction of the maintenance request backlog
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Completion of the maintenance procedure upgrade
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program D.
Surveillance 1.
Analysis The assessment of this area includes all surveillance testing activities as well as all inservice inspection and testing activities.
Examples of activities included are:
instrument calibrations, equipment operability tests, containment leak rate tests of pumps and valves and all other inservice inspection activities.
This functional area was inspected on a continuing basis by the NRC resident inspectors. There were two violations and five LERs in this functional area during the assessment period. Two of the LERs involved surveillances, which identified out-of-tolerance conditions on safety-related equipment. One LER involved an engineered safety feature actuation which occurred during a
surveillance. The fourth LER involved an incomplete functional j
test of effluent monitoring. The remaining LER was for inoperative snubbers. One of the violations involved failure to test newly
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installed limit switches; this was the result of poor communications j
between engineering and operations. The second violation was improper calibration of reactor pressure vessel pressure gauges.
During the assessment period, licensee management attention to surveillances has improved.
The licensee has made changes to its surveillance tracking system, generally improving the management control and monitoring of surveillances. Towards the end of the assessment period, the augmented NRC resident inspection staff observed a startup after a prolonged plant modification outage. A high level of management attention to Technical Specification compliance and surveillance test status was observed just before and during this startup. The licensee reviewed all refueling interval surveillances, performed the bulk of these surveillances and provided a technical justification for those not performed prior to plant restart.
This was a substantial effort beyond that required by the Technical Specifications and regulations.
Surveillance procedures have been and are continuing to be improved.
Licensee interpretation of surveillance test results has been conservative. The licensee has been responsive to NRC initiatives and has proposed substantial changes and improvements to Technical Specification surveillances as part of the ongoing Technical Specification upgrade program.
The two violations written in this functional area during the assessment period were not considered to be indicative of progammatic breakdowns in the area of surveillance. One was the result of a technical error on the part of a technician, and the other occurred'because of poor communication between two divisions of the licensee's organization. The licensee's attention to surveillances and knowledge of Technical Specification requirements was good. Staffing levels were adequate.
The licensee's performance in this functional area has improved during the assessment period.
2.
Conclusions The licensee performance in this functional area continues to be satisfactory. The licensee is working to improve performance in this area, and management attention in this area has increased substantially during the assessment period. The licensee is considered to be in Performance Category 2 in this functional area.
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Board Recommendations a.
Recommended NRC Actions The NRC inspection of this functional area ;hould be consistent with the routine inspection program.
b.
Recommended Licensee Actions The licensee should continue management attention in this functional area in order to improve technician performance, administrative tracking of surveillance status, and surveillance procedures.
The licensee should prepare in' advance to meet the new Technical Specification surveillance requirements, which will be implemented as a result of the completion of the Technical Specification upgrade program.
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Fire Protection 1.
Analysis The assessment of this area includes routine housekeeping (combustibles, etc.) and fire protection / prevention program
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activities. Thus, it includes the storage of comaustible material, fire brigade staffing and training, fire suppression system maintenance and operation, and those fire protection features provided for structures, systems, and components important to safe shutdown.
This functional area was inspected once by an NRC regional-based fire protection inspector and on a continuing basis by the NRC resident inspectors. There were no violations and only one LER in this functional area during the assessment period. The LER concerned missing and degraded penetration seals. The licensee had found'this problem during a self-initiated fire seal walkdown. Although housekeeping did suffer during the extended environmental qualification of equipment outage, the licensee's control of combustible materials and response to oil spills was excellent. The licensee is still working with NRR and Region IV to meet Appendix R requirements.
Licensee response to NRC's initiatives has been excellent.,
During the assessment period, the licensee added a full-time fire protection engineer to its staff. The additional expertise and management attention in this functional area has made a j
substantial improvement in the fire protection awareness and j
posture of all the licensee's staff.
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The licensee is adding a video tape on fire protection and i
individual responsibility for fire protection as part of its general employee training and is addressing improvements to fire brigade staffing and training.
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Conclusions The licensee is considered to be in Performance Category 1 in
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this functional area.
3.
Board Recommendations a.
Recommended NRC Actions A team fire inspection should be conducted during the next assessment period.
b.
Recommended Licensee Actions The licensee should continue its efforts towards meeting
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Appendix R on the schedule it has established.
F.
Analysis During the assessment period, three emergency preparedness
"h inspections were conducted by region-based and NRC contractor
inspectors.
The first inspection was a routine, unannounced
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inspection of the licensee's preparedness for an emergency.
One 394 violation and three emergency preparedness deficiencies were
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identified.
The second inspection was a routine, announced inspection of the licensee's implementation of the emergency plan and procedures during the annual emergency preparedness exercise. One violation and three emergency preparedness deficiencies were identified. The last inspection was a routine, unannounced inspection of changes to the licensee's emergency preparedness program and program audits.
One deviation from a commitment to the NRC was identified.
The licensee's response to the exercise findings and informal discussions with licensee representatives during the latter part of the assessment period indicate that the licensee has a better understanding of the problems in emergency preparedness.
It also appears that licensee management has an understanding of what is needed to attain improvement and has a program and schedule in place to implement those improvements.
Discussions with licensee management and staff during the period also indicate a positive shift in attitude in regard to the need for and maintenance of a strong emergency response capability.
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l A recent review of the emergency preparedness status indicates l
that the licensee has completed short term items and has scheduled other items to be completed prior to the next j
emergency exercise, currently scheduled for August 1987.
l During the assessment period, the Federal Emergency Management Agency (FEMA) determined that the public alert and notification i
system had been improved to the point that it satisfies the
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notify the public in the event of a radiological emergency at l
the site. This verified that the deficiency in this system had been corrected by the licensee.
2.
Conclusions The licensee's performance during the first part of the period appeared to be unimproved over the weak performance identified in the previous SALP report.
The licensee's poor performance in the 1986 annual exercise and failure to effectively correct previous exercise deficiencies indicated weak management commitment to a quality emergency preparedness program.
During the latter part of the period, however, the licensee demonstrated an increased management involvement in the problems and the establishment of both short and long term improvements l
to'the program.
Moreover, the perceived positive shift in I
licensee attitude regarding emergency preparedness indicates I
that a better environment for program improvement has been
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established.
The licensee's emergency preparedness program was considered to be in Performance Category 3 in the last SALP report.
The current assessment is that improvement has taken place, but that assessment cannot be verified until observation of the 1987 annual exercise.
The licensee is considered to be in Performance Category 3 in this area.
3.
Board Recommendations a.
Recommended NRC Action The NRC should give special attention to the 1987 emergency preparedness exercise inspection to verify the effectiveness of corrective actions and improvements to the licensee's emergency preparedness program.
b.
Recommended Licensee Actions Management attention to the improvement of the emergency preparedness program should be maintained at a high level.
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Security 1.
Analysis This area was inspected on a continuing basis by the NRC resident inspectors and periodically by region-based NRC inspectors.
During the assessment period, six violations were identified in the functional area of security.
These violations were Level IV and V violations. They do not indicate any adverse trends during this assessment period.
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systems. They are in compliance in all of these areas and currently have what is considered to be one of the best perimeter systems in Region IV.
The licensee has been and continues to be hampered by a lack of security staf f.
This lack of security staff has adversely impacted such areas as training, l
records, maintenance, and morale.
The licensee depends on shif t-working Lead Security Officers to accomplish most of the l
tasks that should be accomplished by job specific staff members l
who are trained, qualified, and not hampered by shift i
requirements.
There is no specific training staff for example.
Training officers are assigned to shift work and the training l
effort becomes far too decentralized to be as effective as it l
should be.
The licensee security manager has proposed a complete reorganization of assets in order to create a staff
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organization.
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Conclusions l
Many identified problem areas of the past SALP period have been resolved.
The licensee has made major modifications to all perimeter security systems and currently is in full compliance.
If the licensee security department is reorganized into a more efficient staff arrangement those areas mentioned in paragraph 1 above should show signs of immediate improvement.
The licensee is considered to be in Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions
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The NRC inspection effort should be consistent with the l-routine inspection program.
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b.
Recommended Licensee Actions The licensee should develop its security staff based on current initiatives.
Efforts should be made to solve the morale problem among members of the security force as part of this initiative.
H.
Outages 1.
Analysis The assessment of this area is intended to include all licensee and contractor activities associated with major outages.
Thus, it includes refueling, outage management, major plant modifications, repairs or restoration to major components, and all post-outage startup testing of systems prior to return to service.
This functional area was inspected on a continuing basis by NRC resident inspectors and four times by Regional based inspectors.
There were no violations or licensee event reports in this functional area during the assessment period. A substantial increase in management involvement and decision. making was evident during the extended outage that occurred during this assessment period.
Corporate management was involved in site activities on a constant and continuing basis.
The licensee exhibited improved conservatism in addressing technical issues and demonstrated an increased understanding of problems requiring generic solutions.
Responsiveness to NRC initiatives was generally timely with usually sound and thorough responses to NRC questions.
Due to coordination and scheduling problems early in the outage, the licensee greatly mcdified the approach to and control of the outage as the assessment period progressed.
The licensee finally adopted a " war room" concept where decision makers from all disciplines potentially required to resolve problems were located in one area with the resources and authority to address and to solve problems as they arose. The licensee added staff resources to accomplish the tasks of the outage, and this in combination with the " war room" concept was successful as evidenced by the satisfactory NRC environmental qualification of equipment inspection during this assessment period.
2.
Conclusions The licensee has successfully completed an 11-month outage during this assessment period. The licensee's method of controlling outage activities changed throughout the assessment
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The licensee is considered to be in Performance Category 2 in this functional area.
3.
Board Recommendations a.
Recommended NRC Actions-The NRC inspection of this functional area should be consistent with the routine inspection program.
b.
Recommended Licensee Actions
The licensee should examine and assess various techniques I
used for outage control such as the " war room" concept during the next assessment period.
The licensee should formalize those aspects of outage control that can be used to facilitate refueling and modification outages in the future.
I.
Quality Programs and Administrative Controls Affecting Quality I
1.
Analysis The assessment of this area includes all management control, verification and oversight activities which affect or assure the quality of plant activities, structures, systems and components.
This area may be viewed as a comprehensive management system for controlling the quality of verification activities that confirm that the work was performed correctly.
The evaluation of the effectiveness of the quality assurance system is based on the results of management actions to ensure that necessary people, procedures, facilities, and materials are provided and used i
during the operation of the nuclear power plant.
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emphasis is given to evaluating the effectiveness and I
involvement of management in establishing and assuring the effective implementation of the quality assurance program along with evaluation the history of licensee performance in the key areas of:
committee activities, design and procurement control, control of design change processes, inspections, audits, corrective action systems, and records.
In order to more clearly define the specific strengths and weaknesses noted in this functional area, the analysis is divided into three areas as discussed below:
a.
Administrative Controls This area has been inspected routinely by NRC resident inspectors and regional inspectors.
e m__
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ ____ _ _ __ _ _ _ _ _ _ _ _. _ _. _ _ _
_. _ _ _ _ _. _ _ _ _ _ _. _ _ _ _ _ _. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. _ _ _ _. _ _ _ _ _ _ _ _ _ _ _
_____
-
.
i There was one violation.during the assessment period in the area of administrative controls. This violation was for inadequate and slow response to corrective action requests.
This violation occurred near the beginning of the assessment period and was based on the licensee's past performance in this functional area. The licensee has taken major steps in this area to correct the problems.
The licensee reorganized the corporate structure during this assessment period to increase the attention devoted to nuclear operations by its chief executive officer.
Additionally the position of vice-president of nuclear operations, which is a new executive position within the corporate structure, was filled.
Previously, the vice-president responsible for FSV was also responsible for all other electrical generating stations in the licensee's system. The vice-president of nuclear operations is responsible only for FSV.
In filling the vice-president of nuclear operations position, the licensee obtained a highly skilled, experienced nuclear industry executive, whose almost constant presence onsite, attention to detail, and commitment to a high level of quality has already affected all levels of the organization in a positive way.
The licensee's committee functions,' observed by NRC resident and regional inspectors, improved during the assessment period, and the licensee continues to seek means of further improvement in these review functions.
The previous SALP report identified that the quality assurance organization had many dedicated, talented people, at the working level, who performed well but appeared to lack management backing and resources to do their job. The new management team has provided resources, motivation, and backing allowing the personnel involved in quality programs at FSV to perform their jobs in a manner that is not only regulatorially acceptable, but is also thorough and technically sound.
b.
Quality Assurance This area has been inspected on a continuing basis by the NRC resident inspectors and regional based inspectors.
There were two violations in the quality assurance area during this assessment period.
The first violation was very early in the assessment period and was the result of past performance in this functional area. The violation was for the lack of verification by the licensee of contractor quality assurance lead auditor's qualifications.
The second violation came late in the assessment period and was for a deficient quality control hold tag procedure.
In
. _ _ _. - _
a
...
20; both cases, the licensee took prompt.and substantial corrective action and action to prevent recurrence.
During the assessment period, the licensee who has hired a new.
manager of quality assu e.nce who has experience in both the.
Navy and commercial nuclear power. The quality assurance
. division has also-been strengthened by the addition of a new supervisor of auditing and several new auditors.
The licensee's audit function, considered to be weak in the i
previous assessment period, has been made markedly stronger. 'The current assessment period began with an enforcement conference on audits and corrective actions.
The NRC resident inspectors have during the latter half of this assessment period observed a substantial improvement
'in the audit and corrective action functions at FSV. The presence of the vice-president of nuclear operations at audit exits and, as observed by the NRC resident inspectors, his presence at audit planning meetings has contributed _ to. an audit perspective of identifying problems, correcting problems, and preventing recurrence.
The quality control function of quality assurance, as observed by the NRC resident inspectors and regional inspectors during the assessment period, was satisfactory and improving as the perception of strong management backing for quality assurance permeated the organization.
c.
Engineering This area of quality assurance and administrative controls affecting' quality was inspected on a continuing basis by the NRC resident inspectors and regional based inspectors.
During th'e assessment period, there were six violations'in this area. The violations ranged from modification control procedures not reviewed by plant operations review committee to records checklist not included for records receipt control to improper documentation of design l
verification, failure to review associated areas for similar discrepancies when discrepancies were identified between installed equipment and as-built drawings and improper 10 CFR 50.59 review of design modifications. The extent of these violations coupled with the problems of processing design changes, as noted in the operations section of this report, are a cause of concern. The design control process at FSV is complex and often slow as evidenced by the number of temporary change reports on the logs due to the inability to get a tinely design change processed.
l The licensee became aware of the design change control problems and formed a task force assigned to address the
,
I
-
,
problems of engineering organization, design change control, and backlog of design change requests that exist.
The licensee was unable to address these problems
_
'
completely during the assessment period because of the amount of work involved in the environmental qualification of equipment outage.
During the last part of the assessment period, the licensee did take steps to have these problems addressed arid resolved during the next assessment period.
The licensee has demonstrated, during the assessment
.
'
period, the ability to process design changes and to do high quality, safe engineering in support of the plant.
The licensee, however, lacks a design control system that minimizes the administrative burden. The design control process does not facil". tate prompt response to plant operating requirements.
2.
Conclusions The licensee began this assessment period as a weak Performance Category 3 in this functional area. A team inspection by NRC inspectors in this functional area, and an enforcement conference in this functional area were held early in the assessment period.
The licensee has shown continued and rapid improvement during the last half of the assessment period.
The licensee would be considered to be in Performance Category 1 in this functional area if the area included management and quality assurance only. The problems in design control decrease the overall rating of this functional area to be Performance Category 2.
The licensee has demonstrated a strong upward trend
,
in this functional area.
l 3.
Board Recommendations i
a.
Recommended NRC Actions The NRC inspection effort should be consistent with the routine inspection program except in the Engineering area, where consideration should be given to conducting a team inspection focused on the area of design control.
b.
Recommended Licensee Actions j
The licensee should continue its high level of attention in this inspection area in order to improve the quality performance of all functional areas of nuclear operation and alleviate the backlog of corrective actions yet to be accomplished.
Particular emphasis should be give to i
revising the design control process to make it both effective and efficient.
j
p m
.
?^
'
po J.
Licensing 1.
-Analysis L
Management involvement in the preparation of licensing
'
submittals varies.
Coordination of the licensing staff with nuclear engineering and plant operations is not always K
effective. Continued strong management involvement is required.
[
The licenene's approach to resolution of technical issues generally. improved during this performance period.
However, in
'
some critical problem areas, the approach to resolving probems was not effective.
Thus, PSC has to consider improving its
- ,
.overall aproach to problem resolution with the NRC.
PSC's responsiveness to NRC initiatives in general continues at a very high level.
PSC's staffing of licensing actions and
'
handling of reportable events is good, during this performance
,
period..
PSC's licensing staff has continued to improve in recognizing and resolving licensing issues with the NRC.
Progress made in returning the plant to power operation'and closing some long term licensing issues indicates effective licensing capabilit M. hever, because of the number of licensing issues still open, PSC should continue to upgrade and strengthen
'
its licensing staff.
Emphasis should be placed on continuing to develop Wareness throughout the PSC nuclear organization of s
regulatory requirements and guidance. All licensing activities should strive to become more int.egrated with the associated activities in the nuclear engineering and plant operations programs to assure effective program and project results.
PSC efforts at organizational integration, such as the Senior
.
Planning Team, address this area, and are commendable.
The detailed NRR evaluation is attached as Enclosure 1.
2.
Conclusions Although it is recognized that PSC's 0fforts in this functional area continue to improve, it remains WRR's postion that FSV's future performance will require a constant, high level of attention by both the licensee and the staff.
Based on the assessment described above, the NRR SALP evaluation effort assigns an overall performance rating of 2 to PS _...
<
.
,, _
,
!'
3.
Board Recommendations a.
Recommended NRC Actions Because of the special licensing problems with this plant, continue to devote addtional resources to licensing activities and associated inspection activities.
b.-
Recommended Licensees Actions PSC should_ focus on maintaining on adequate level of licensing staff resources and work towards better integration between licensing nuclear engineering and plant operations. This should include a conscious effort to
..
improve organizational problem solving abilities.
K.
Training and Qualification Effectiveness 1.
. Analysis The assessment of this area includes all activities relating to the effectiveness of the training, retraining, and qualifications program conducted by the licensee's staff and contractors for non-licensed operators, control room operators, senior control. room operators,. shift supervisors, shift technical advisors, instrument and control technicians, electrical maintenance personnel, mechanical maintenance personnel, radiological protection technicians, chemistry technicians, and technical staff and managers.
This area was inspected once by regional based NRC inspectors and separately by regional based operator licensing examiners.
The licensee has previously received Performance Category 2 ratings in this functional area but started the assessment period with an unsatisfactory rating for the operator requalification program because of poor performance by licensed operators on requalification examinations. This performance rating has since been upgraded to satisfactory because of good performance on subsequent operator licensing requalification i
examinations. The licensee is continuing to work towards
!
accreditation by INP0. The licensee has received INP0 accreditation for the three operator programs and is still working on qualification in the other seven areas.
General employee training has been steadily improving during the
,
assessment period with an increased emphasis on quality and individual responsibility for quality at Fort St. Vrain.
Fire protection and security has received increased emphasis in
. general employee training.
Problems which arise during the j
'
course of operations in the plant are addressed as appropriate in either general employee training or licensed operator
]
l
.
...
l
training.
The licensee has worked well with the NRC resident e
inspectors and the regional based operating licensing examiners and has shown an openness to suggestions.
2.
Conclusions
!
The licensee is considered to be in Performance Category 2 in this area.
3.
Board Recommendations a.
Recommended NRC Actions The NRC inspection effort should be consistent with the routine inspection program.
b.
Recommended Licensee Actions Licensee activities towards implementing craft training and systems training for all personnel responsible for engineering and maintenance at Fort St. Vrain should continue.
V.
SUPPORTING DATA AND SUMMARIES A.
Licensee Activities This assessment period was very eventful. Major activities included:
10 1/2-month outage to do modifications required to meet
.
equipment environmental qualification requirements of 10 CFR 50.49 Modifications to safe shutdown cooling systems to support
.
operation at up to 82 percent of rated power Removal of plant from utility rate base
.
The reorganization of corporate structure to support plant
.
operations more effectively
>
Rewrite of virtually all procedures
.
INPO accreditation of reactor operator training programs
.
Restart of plant on April 17, 1987
,
The licensee at the end of this SALP period was operating the reactor at approximately 29 percent of rated power, pending completion of NRR reviews allowing the plant to ascend to 82 percent of rated power.
,
i.
.
25.
B.
Inspection Activities NRC inspection activity during this SALP evaluation period included 30 Region IV inspections and 1 I&E team inspection of the environmental qualification of equipment. These inspections involved 4,428 direct inspection hours. The NRC Region IV inspections included a team inspection of maintenance, a major team inspection of quality assurance, a major team assessment of management effectiveness, and several team. inspections of environmental qualification work.
Table 1 provides a tabulation of NRC enforcement activities for each functional ares evaluated.
Table 2 provides a listing of inspection findings in each SALP category.
C.
Investigations and Allegations Review No major investigation activities were conducted during this assessment period.
D.
Escalated Enforcement Actions 1.
Civil Penalties Two notices of violation and imposition of civil penalties were issued during the assessment period.- Both were uncontested by the licensee and involved violations occurring in the previous assessment period. A $75,000 civil penalty was essessed for a i
Level III violation for exceeding the authorized pnwer level on May 6, 1986. A $65,000 civil penalty was assessed for a Level III and a Level II violation in the area of security. All of these violations occurred during the previous assessment period.
2.
Enforcement Orders None E.
Management Conferences Held During Assessment Period 1.
Conferences Two enforcement conferences were held at the NRC Region IV office durir.g this assessment period.
The May 9, 1986, conference dealt with matters that occurred during the previous assessment period. The July 22, 1986, enforcement conference dealt with problems in quality assurance, which appeared to have been corrected later in this assessment period.
The date and subject for each conference are listed below:
May 9, 1986:
exceeding authorized power limit
.
July 22, 1986:
inadequate or untimely corrective action
.
_ _ _ _ _ - _ _. _ _ _ _ _.
t
In addition to the above conferences, a quarterly meeting with NRR and Region IV personnel was held to inform NRC of licensee progress on the performance enhancement prog am.
Additionally, several meetings were held between NRR, Region IV, and the licensee to assist the licensee and inform the NRC of licensee progress towards meeting the requirements of 10 CFR 50.49,
" Environmental Qualification of Equipment."
2.
Confirmation of Action Letters (CALs)
None F.
Review of Licensing Event Reports and 10 CFR Part 21 Reports Submitted by the Licensee 1.
Licensee Event Reports (LER)
The NRC resident inspectors and project inspector reviewed LERs submitted by the licensee throughout the assessment period and noted corrective actions. Additionally, a NRC inalysis of the licensee's LERs was forwarded to the licensee on May 20, 1987, noting an improvement during this assessment period of the quality of LERs submitted by the licensee.
A SALP review panel was convened in the NRC Region IV office on April 30, 1987, to review inspection findings of LERs for I
I proximate causes and trends.
The review panel inputs were factored into the analyses of SALP areas.
Table 3 provides a listing of LERs by SALP category and subject.
2.
Part 21 Reports There were no 10 CFR Part 21 reports submitted by the licensee during this SALP assessment period.
H.
Licensing Activities (See Attachment)
l
_ _ _ _ _. _
-
..
TABLE 1 ENFORCEMENT ACTIVITY SUMMARY Functional No. of Violations in each Severity level
]
Area V
IV III II I
Deviations /
Deficiencies
!
A.
Plant Operations B.
Radiological Controls
C.
Maintenance D.
Surveillance
E.
Fire Protection F.
1/6 G.
Security
5 H.
Outages I,
Quality Programs and
Administrative Controls Affecting Quality J.
Licensing Activities K.
. Training and Qualification Effectiveness Total
20 1/6 l
,1
..
..
_ _ - -
- - _.
-
.
TABLE 2 ENFORCEMENT ACTIVITY TABULATION OF VIOLATIONS, DEVIATIONS, AND EMERGENCY PREPAREDNESS DEFICIENCIES
,
BY-PERFORMANCE CATEGORY i
!
A.
Plant Operations Violations
None I
.
Deviations None B.
Radiological Controls Violations Noble gas release monitor setpoints above ODCM values (Severity
.
Level IV, 8621-01)
Unmonitored liquid radioactive effluent release (Severity Level IV, 8707-01)
Deviations None
.
.
C.
Maintenance Violations None l
Deviations l
l l
None
'
O.
Surveillance Violations i
Failure to periodically test flow orifice valve limit trip
.
(Severity Level IV, 8625-04)
Improper calibration of reactor pressure vessel pressure gauges
.
(Severity Level IV, 8708-01)
)
,
_
_____
_
-
__
+
}'
.
l peviations None
.
E.
Fire Protection Violations None
.
Deviations None
.
F.
Emergency Preparedness Violations 1985 EP exercise deficiencies not corrected (Severity Level IV,.
.
8622-01)
Two individuals not given required EP training (Severity
.
Level IV, 8615-01)
Deviations Failure to implement action to preclude' violation recurrence
.
(8630-01)
Deficiencies Improper implementation of_ requirements for notifying the NRC
.
immediately after state or local agencies and within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of an emergency classification (8615-02)
No unannounced drill conducted to demonstrate emergency staffing
.
augmentation (8615-03)
No procedural methods provided to incorporate radiological field
.
monitoring data into dose assessment and projections (8616-04)
Shift supervisor not informed in a timely manner of status of
.
accountability, staffing of personnel control center, or dispatch of onsite monitoring team (8622-02)
Forward command post (emergency operations center) not activated
.
and operational within 90 minutes after declaration of an alert emergency classification (8622-03)
RERP implementing procedures not followed at forward command post (8622-04)
.
.,
.G.
Security Violations Inadequate access control personnel (Severity Level IV, 8614-01)
Failure to escort visitors (Severity Level IV, 8614-02)
.
Unbadged person in the protected area (Severity Level IV,
.
8614-03)
Failure to document maintenance (Severity Level V, 8628-01)
.
Failure to turn over vital area and critical valve keys
.
(Severity Level IV, 8625-01)
Failure to wear picture badge ID within the protected area
.
(Severity Level IV, 8632-01)
Deviations None
.
H.
Outages Violations None
.
Deviations None
.
I.
Quality Programs and Administrative Controls Affecting Quality Violations Contractor lead auditor's qualifications not documented
.
(Severity Level IV, 8623-02)
Hold tag placed without shift supervisor concurrence (Severity
.
Level IV, 8705-01)
Records checklist not included for records receipt control
.
(Severity Level IV, 8623-03)
Modification in control procedures not reviewed by plant
.
operations review committee (Severity Level IV, 8625-02)
Design verification not documented in sufficient detail
.
(Severity Level IV, 8625-03)
-
<
Failure to review associated areas for similar discrepancies
!
.
(Severity Level IV, 8625-05)
Improper 10 CFR 50.59 review of plant modification (Severity
.
Level IV, 8708-03)
Inadequate and slow response to CARS (Severity Level IV, 8619-03)
Two schematic drawings used by maintenance not up to date
.
(Severity Level IV, 8609-01)
Deviation None
.
J.
Licensing Activities Violations None
.
Deviations None
.
K.
Training Qualification Effectiveness Violations None
.
Deviations None
<
.
.
!
TABLE 3 OPERATID'.'AL EVENTS TABULATION OF LICENSEE EVENT REPORTS BY
'
PERFORMANCE CATEGORY A.
Plant Operations Reactor scram on reactor building high temperature (86-029)
.
Reactor scram on undervoltage while performing CN2191 (87-003)
.
Inoperative reactor building pressure switch (87-007)
.
ESF actuation, loop shutdown (87-008)
.
ESF actuation, loop shutdown (87-011)
.
Operation prohibited by LCO 4.1.9, low power minimum flow requirement (87-013)
i B.
Radiological Controls Radiation monitors found out of calibration (86-023)
.
Reactor building sump release not continuously sampled (86-025)
.
Reactor building sump release not continuously sampled (86-027)
.
Unanalyzed liquid waste release (87-004)
.
C.
Maintenance None
.
D.
Surveillance PCRV rupture disk found out of tolerance (86-024)
.
Three circulator pene'. ration safety valves found with relief pressure
.
exceeding Technical Specification limits (87-001)
Loop 2 shutdown (87-005)
.
Inoperable mechanical snubbers (87-009)
.
Functional test for radioactive effluents not completely performed
.
(87-012)
E.
Fire Protection Missing and degraded fire barrier penetration seals (87-006)
.
.
-
.
.,-
F.
.
G.
Security None
,
.
i H.
Outages None
.
I.
Quality Programs and Administrative Controls Affecting Quality Reactor scram actuation on neutron flux rate of change high
.
(inadequate modification control) (86-028)
Reactor scram actuation on neutron flux rate of change high (87-010)
.
.!
J.
Licensing
!
Reanalyses of steam generator cooling with firewater following LOFC j
.
(86-020)
!
Single f ailure points identified in firewater cooling flow paths
.
.
(86-021)
'
Effects on 480V essential switch gear due to loss of DC Bus 1
,
(86-022)
.
i FSAR EES firewater cooldown analyses invalid (86-026)
i
.
Emergency diesel exhaust temperature controller not seismically
,
.
l qualified (86-030)
Single failure to diesel generator logic circuitry (87-002)
.
K.
Training and Qualification Effectiveness None
,
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
,
ATTACHMENT Licensing Activities l
i I.
INTRODUCTION l
This report contains NRR's input to the SALP review for the Fort St. Vrain Nuclear Generating Station (FSV). The assessment of the licensee's performance was conducted according to NRR Office Letter No. 44, "NRR Inputs to SALP Process," dated January 3, 1984, and NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance," as revised.
II.
SUMMARY I
NRC Manual Chapter 0516 specifies that each functional area evaluated will be assigned a performance category (Category 1, 2 or 3) based on a
,
composite of a number of attributes.
The overall performance of the Public i'
Service Company of Colorado in the functional area of Licensing Activities l
is rated Category 2.
While PSC's efforts in this functional area continue l'
to improve, it is also recognized that the constant attention of both PSC ('
and the NRC is still required to assure consistent performance.
III.' CRITERIA l
l The evaluation criteria used in this assessment are given in NRC Manual Chapter 0516 Appendix, Table 1, Evaluation Criteria with Attributes for Assessment of Licensee Performance.
IV. METHODOLOGY l'
This evaluation represents the integrated inputs of the Project Manager (PM) and those technical reviewers who expended significant amounts of effort on FSV licensing actions during the current rating period.
Using the guidelines of NRC Manual 0516, the PM and each reviewer applied specific evaluation criteria to the relevant licensee performance attributes, as delineated in Chapter 0516, and assigned an overall rating
,
category (1, 2, or 3) to each attribute.
The reviewers included this l
informations as part of the safety evaluation for each review. The PM, after reviewing the inputs of the technical reviewers, combined this information with his own assessment of licensee management and techncial performance and arrived at a composite rating for the licensee.
A draft evaluation was then prepared by the PM and circulated to NRR management for comments, which were incorporated in the final evaluation. The basis for this appraisal was the licensee's performance in support of licensing actions that were either completed or had a significant level of activity during the current rating period.
These consisted of responses to routine
licensing actions and approval for the plant to operate at 35 percent of l
full power.
The specific licensing actions which were completed. during i
this rating period and were considered the bases for input into this appraisal are as follows:
Equipment Qualification (inclucing temperature profiles and the steam line rupture detection / isolation system (SLRDIS)),
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _
-
-
,
Fuel Surveillance Program,
.
CRD0A Maintenance Program,
.
Review of ODCM,
.
Chernobyl Report, and
.
EDG Test Frequency.
In addition, the Project Manager has evaluted the licensee's progress during this assessment period in resolving major long-term licensing issues.
These efforts include:
Safe Shutdown Cooling, Fire Protection and the Technical Specification Upgrade Program.
V.
Assessment of Performance Attributes The licensee's performance evaluation is based on consideration of six of the seven attributes specified in NRC Manual Chapter 0516.
Those considered are:
-
Management Involvement and Control in Assuring Quality
-
Approach to Resolution of Technical Issues from a Safety Standpoint
-
Responsiveness to NRC Initiatives
-
Staffing (of Licensing Actions)
Reportable Events
-
Training Effectiveness and Qualification
-
A.
Management Involvement and Control in Assuring Quality PSC's management has shown increasing attention to planning and prioritization in the conduct of its licensing activities and has been able to prioritize and schedule many of its licensing submittals effectively. Almost all licensing correspondence that supported the recent (April 6,1987) plant restart was submitted in a timely fashion.
Some lower priority items, such as the Procedures Generation Package, and the resubmittal of LCO 4.1.9 were delayed, but PSC was cognizant of the delays and they were minor.
However, PSC did not appear to carefully coordinate implementation of fire protection modifications with the equipment qualification outage, and some program delays have resulted. The overall program goals remain attainable.
PSC's work on restart related items was generally of acceptable quality. However, examples of potential lack of management involvement in assuring quality could be found for some submittals.
The maintenance procedures submitted for the CRD0A's lacked specific acceptance criteria for critical steps, such as visual inspections.
m
.
- d
The PSC staff's proposals for Technical Specification, on i
instrumentation for (SLRDIS), reflected a lack of awareness of the
!
accepted standards for 4 channel protective systems, which are the industry standard and reflected in the Standard Technical Specifications. PSC management needs to constantly assure that technical submittals to the NRC reflect appropriate accepted industry standards.
In summary, management involvement in the preparation of licensing submittals varies. Although each submittal is signed by one of the three division managers, coordination with the licensing staff is not always effective. Although the NRC staff believes management involvement was generally acceptable, a few licensing actions obviously reflected a. lack of adequate involvement to assure quality.
Continued strong management involvement is required.
On the basis of the above observations, a rating of 2 is assigned to this attribute.
B.
Approach to Resolution of Technical Issues from a Safety Standpoint PSC's approach to resolution of technical issues has generally improved during this performance period.
PSC's best work was done in the process of implementing the equipment qualification program.
In general, the PSC staff explored each major problem area, and where appropriate, requested NRC staff guidance.
In meetings with the staff, PSC was generally well prepared to discuss proposed resolutions and make a special effort to obtain acceptable approaches. There was less concern about potential delays and more concern about meeting and exceeding regulatory requirements.
In general, PSC's performance in this area was good.
However, in one area, development of the temperature profiles for equipment qualification, a significant organizational weakness was noted. This weakness was reflected in PSC's approach to resolve the apparent differences that arose in evaluating the heat transfer coefficients which governed the generation of the temperature profiles. PSC's initial efforts to resolve this problem focused only on trying to prove that the heat transfer coefficient's they had used were conservative. They initially failed to bring to the staff's attention that there were other conservatisms in calculated building volumes and surface areas, and in radiation heat transfer. Although the problem was admittedly complex, the staff concludes that PSC initially failed to consider all possible methods of resolving this problem.
PSC must continue to improve its organizational problem solving capability, especially on complex technical issues.
The degree to which PSC involves the staff in resolving technical problems also is inconsistent. As noted, Above, in resolving the problems with the equipment qualification program, PSC worked closely with the staff. By contrast, in dealing with the safe shutdown
.
.
cooling, PSC has proceeded to proposed resolutions with a great deal less contact with the staff. Other submittals, such as the requalification of the control rod drives for higher temperatures, also reflected little contact with the staff prior to submittal.
In the safe shutdown cooling case, the PSC approach has made it more difficult, until recently, for the staff to understand PSC's position.
Indeed, we subsequently agreed with PSC that to pursue the 39 percent reheater cooldown was not advantageous. The case of the control rod drive control rod drive requalification resulted in the staff completely rejecting PSC's submittal and requesting a new report. Thus, PSC has to carefully consider improving its overall approach to problem resolution with the NRC.
<
Based on the performance described above the rating of 3 is assigned to this attribute.
C.
Responsiveness to NRC Initiatives PSC responsiveness to NRC initiatives in general continues at a high level.
In areas where PSC has approached the staff with problems, they have generally followed staff guidance and the problems have been resolved.
PSC has also been responsive to staff requests for additional information, and in keeping the staff informed about ongoing activities. There have been some delays in handling routine licensing actions, but this can be considered acceptable in light of PSC's overall high licensing work load.
PSC's responsiveness on major program areas, such as, equipment qualification and the technical specification upgrade program have been good. This appears to reflect improved internal communications within PSC.
Complex responses to licensing questions are handled rapidly. However, PSC also needs to maintain management cognizance of less visible licensing issues to assure they are handled in a timely fashion.
Based on the performance described above, the rating of 1 is assigned to this attribute.
D.
Staffing (Of Licensing Actions)
PSC'.s staffing of licensing action responses continues to be adequate on most issues. At meetings with the NRC staff, PSC management, technical staff and consultants usually are well organized and prepared. This reflects a clear definition of roles and responsibilities on licensing issues. PSC's licensing staff generally has handled the responses to licensing issues in a timely fashion. As noted earlier in the Management Involvement attribute, major long-term submittals have been on schedule.
However, some schedule slippage has occurred in responding to other licensing actions.
L
,.
'
Licensing review of documents prior to submittal appears to be generally adequate, except for the most complex submittals. On complex licensing issues, PSC should strive to assure a stronger licensing input at the time of a submittal's development, rather than i
have licensing review serve as a corrective porcedure after the
'
technical work is complete.
Licensing staff resources should also be devoted to assuring that the technical staff has adequate awareness of the relevant regulatory requirements and guidance prior to the beginning of the work itself.
Based on the performance described above, the rating of 2 is assigned to this attribute.
E.
Reportable Events The most significant reportable event of this SALP period was the discovery by PSC of inadequacies in the Safe Shitdown cooling analyses for the plant.
In general, PSC's handling of this event was good.
PSC promptly reported the relevant findings and took immediate corrective actions.
In general, both the event reporting and subsequent corrective actions reflected a high level of internal coordination.
Information provided to the NRC was generally well organized and complete. However, PSC should have provided a stronger overview document, explaining more fully each detailed report.
Based on the performance described above, the rating of 2 is assigned to this attribute.
F.
Training Effectiveness and Qualification In the 1986 SALP report, the staff noted the PSC had made significant efforts in this area, and that good results should result from these efforts.
PSC's overall licensing performance continues to improve, and we believe this can be attributed in part to comprehensive personnel training. We recommend PSC continue these efforts.
Based on the performance described above, the rating of 2 is assigned to this attribute.
VI.
Conclusions PSC's licensing staff has continued to improve in recognizing and resolving licensing issues with the NRC.
Progress made in returning the plant to power operation and closing some long term licensing issues indicates effective licensing capabilities. However, because of the number of licensing issues still open, PSC should continue to upgrade and strengthen its licensing staff.
Emphasis should be placed on continuing to develop awareness throughout the PSC nuclear organization of
,
regulatory requirements and guidance. All licensing activities should
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.
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strive to become more integrated with the associated activities in the nuclear engineering and plant operations programs to assure effective
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program and project results.
PSC efforts at organizational integration, such as the Senior Planning Team, address this area, and are commendable.
Based on the assessment described above, the NRR SALP evaluation effort assigns an overall performance rating of 2 to PSC.
Although it is recognized that PSC's efforts !n this functional area continue to improve, it remains NRR's position that FSV's future performance will require a constant, high level of attention by both the licensee and the staff.
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