IR 05000286/1997099
| ML100491134 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 07/02/1997 |
| From: | NRC/OE, NRC/OI/RGN-I/FO |
| To: | |
| Shared Package | |
| ML100491133 | List: |
| References | |
| 50-286-97-99, NUDOCS 9707110212 | |
| Download: ML100491134 (8) | |
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00 Enclosure 1 Systematic Assessment of Licensee Performance (SALP)
Indian Point Nuclear Generating Station Unit No. 3 Report No. 50-286/97-99 BACKGROUND The SALP Board convened on May 29, 1 997, to assess the nuclear safety performance of the Indian Point Nuclear Generating Unit No. 3 for the period from March 2, 1 996 to May 1 7, 1 997. The Board was conducted pursuant to NRC Management Directive (MD) (see NRC Administrative Letter 93-20). The Board members were Charles W. Hehi (Board Chairman), Director, Division of Reactor Projects, NRC Region I (RI), James T. Wiggins, Director, Division of Reactor Safety, RI, and Singh S. Bajwa, Acting Director, Project Directorate 1-1, NRC Office of Nuclear Reactor Regulation. The Board developed this assessment for the approval of the Region I Administrato The performance ratings and the functional areas used below are described in NRC MD 8.6, "Systematic Assessment of Licensee Performance (SALP)."
1 PERFORMANCE ANALYSIS - OPERATIONS Performance in Operations improved and was good overall. Management continued to take a conservative approach to operations as evidenced by actions taken to minimize operator challenges while addressing degraded equipment conditions. An example was when a reactor loop flow instrument became inoperable, the licensee voluntarily reduced power to eliminate the trip risk of a spurious signal from another flow instrument during severe weather conditions. Additionally, the licensee took the generator off line to repair an electrical conduit to minimize personnel and plant trip risk Management involvement continued to be a significant contributor to enhancements in operator performance. Management was notably involved in operator training, where expectations regarding operator performance were effectively communicated. Increased management oversight of the control room and plant activities resulted in improved adherence to procedures, communications, formality and questioning attitude The licensee implemented several good initiatives to better support operations, including the preparations for cold weather operations through the temporary modification process, the decontamination of areas required to be entered by operators during normal rounds, and the reduction of temporary procedure change Operators response to plant transients and equipment problems improved, particularly in the latter part of the SALP period. In one *event, the operators quickly diagnosed the impending trip of the heater drain pumps on low heater drain tank level and rapidly reduced power to preclude the need for a plant trip and associated transient. In another event, the operators quickly diagnosed the cause of and terminated a turbine runback. In addition, operators consistently displayed a conservative approach to plant operations during event PDR ADOCK 05000288 G
Enclosure 1
For example, during another turbine runback event, the operators tripped the plant when the cause of the runback was not readily apparen Although operating procedures improved significantly during the SALP period, some problems were noted in the quality of certain infrequently implemented procedures. Well written plant and system operating procedures contributed to error-free plant maneuvers and routine evolutions. However, the emergency operating procedures contained some deficiencies which reduced the assurance against cavitation of the recirculation and component cooling water pumps. The licensee made a good effort in upgrading the refueling procedures for the ongoing outage, but many procedures were implemented for the first time and some minor problems were later noted during implementatio Operations did inot consistently control equipment configuration well, principally during activities associated with protective tagouts, until late in the SALP period. Although weaknesses in the protective tagout process were being addressed late in the period, these weaknesses contributed to several plant events including an inadvertent trip of both heater drain pumps in November 1 996. Inattention to detail and informality contributed to other equipment configuration control issues including an improperly controlled containment purge fan damper in January 1 997 and a February 1997 misalignment of the holdup tanks, resulting in over-pressurization of the letdown system. Steps were taken midway in the period to address these issues; the control of plant evolutions and field activities during two outages this year demonstrated improvement in eliminating such configuration control problems and work control error Operations' identification of problems and implementation of the corrective action program were generally good. A questioning attitude usually was displayed and procedure adherence was good. The operations review group effectively monitored human performance, and actions were taken to minimize the rate of human performance error The number and significance of personnel errors have declined, but some errors with non licensed operator activities continued to occur. Although corrective actions have been generally good, there were several examples of weak corrective actions, principally when management oversight was not provided. For example, the operation of the residual heat removal system in a manner inconsistent with the final safety analysis report was not appropriately resolved when identified in early 1 99 In summary, Operations performance was generally good and improved from the last SALP period. Management continued to take a conservative approach to operation Management involvement contributed to enhancements in operator performance. Operator performance improved; responses to plant transients were excellent. Although operating procedures improved significantly, problems were noted with the quality of some infrequently implemented procedures. Operators did not consistently control equipment configuration well, particularly regarding protective tagouts; corrective actions led to better control of plant configuration as evidenced by good performance during several outages this year. Operations' identification of problems and implementation of the corrective action program were generally good, however several examples of weak corrective actions were observed.
The Operations area is rated Category Enclosure 1
Ill11. PERFORMANCE ANALYSIS - MAINTENANCE Performance in the maintenance area was good. Management oversight of maintenance activities reflected strong commitment to improved plant material condition. Maintenance management and staff responded well to emergent equipment issues and identified and corrected problems in a timely fashion. When a degraded equipment condition was found, the licensee typically determined the root cause of the problem, fixed the specific component involved, and, in addition, broadened the review to determine if similar components were also degrade The plant material condition improved; the backlog of corrective maintenance items was significantly reduced. However, prior to the February 1 997 forced outage, plant performance was marred by reliability and emergent equipment issues, resulting in~ power reductions and two plant shutdowns. During the February 1 997 forced outage, a number of equipment problems were corrected. As a result, after the outage, fewer equipment problems impacting plant operations occurred. The May - July 1 997 refueling/maintenance outage scope included substantial work to improve the reliability of key plant equipmen Good performance of maintenance activities in the field was noted and achieved, in part, because of the emphasis on procedure adherence, supervisory oversight and quality workmanship. Examples of well managed and conducted maintenance evolutions included removal and replacement of the 33 service water pump in March 1997 and repair of a conduit to a generator current transformer in October 1996. The maintenance staff was knowledgeable of their assigned tasks, well trained and generally adhered well to procedures, particularly on jobs which received considerable oversight by managemen However, isolated examples of lapses in procedure adherence were noted late in the period on jobs which received limited supervisory oversight (i.e. scaffolding construction, foreign material exclusion boundaries and fuel storage building roof repairs).
The effectiveness of the work control and planning processes continue to be inconsistent, although a number of improvements were made over the SALP period. Weaknesses in the work control process, evident early in the period, included informalities in the release of work and poor quality work packages. These work control process weaknesses, as well as personnel performance errors, impacted equipment operability and plant power operation Examples included the inadvertent trip of both heater drain pumps in November 1 996 and the failure during tightening of a fitting supplying air to the 34 MSIV in May 1 996. Several aspects of the work control process improved near the end of the SALP period, including the scheduling of work and the quality of work package The surveillance program was generally effective. However, some weaknesses in the quality of surveillance test procedures were observed, most notably in ventilation system surveillance tests. The problems noted during the last SALP period with the conduct of surveillance tests in plant conditions different than those prescribed in the surveillance procedure were corrected during this perio Enclosure 1 In summary, plant material condition improved during this SALP period due, in part, to efforts to reduce the corrective maintenance -backlog. The overall quality of maintenance work and adherence to maintenance procedures continued to be good. Surveillance test program problems noted during the last SALP were corrected, although some weaknesses with surveillance test procedures were noted. Work control process problems continue in spite of significant corrective actions in this area, but measurable improvements were evident late in the perio The maintenance area is rated Category I PERFORMANCE ANALYSIS - ENGINEERING The engineering organization continued to be reactive for most of the assessment perio While the engineering work backlog was reduced in the latter half of the period, the backlog, coupled with a weak engineering work planning system and emergent equipment issues, impacted on refueling outage preparations. Coping with that situation provided a challenge to outage management activities and resulted, in part, in the deferral of a significant amount of work until after the outage due to resource constraints. It also impacted on necessary long-term performance improvement efforts such as those associated with the setpoint control program and with the design basis document update progra The performance of engineering in addressing equipment problems was mixed. Through much of the period, the contributions of engineering toward improving equipment reliability were limited by the need to frequently react to emerging plant equipment problems and weaknesses in the management of engineering backlogs early in the period. Equipment problems caused a number of plant transients, shutdowns and forced outages. Some components, such as control room ventilation fans and service water piping, experienced multiple failures during the period. Further, problems with the control room air conditioning compressors and the instrument/station air compressors challenged operations. A number of longstanding design deficiencies and operator workarounds were resolved by the end of an extended forced outage in February 1 997; as a result, the overall material condition and operation of the plant improved toward the end of the period. However, the material condition of ventilation systems for several plant areas such as the control room and the fuel storage building was found to be poor late in the period, indicating continued attention is needed to the material condition improvement progra Midway through the period, steps were taken to improve management and prioritization of the engineering work backlog. Steps were also taken to improve system engineering effectiveness through development of system health reports for many systems and the implementation of system improvement plans. Additional resources were provided in the latter half of the period to support system engineering efforts. Understanding and ownership of maintenance rule programmatic activities by systems engineers indicated these initiatives are having some positive effects. Some improvements were noted in the performance of the corrective action program, as it related to the identification, root cause assessment and resolution of engineering problems. However, the problems noted late in the period with the fuel storage building ventilation system indicate continued attention is
Enclosure 1 needed to consistently enforce management standards and expectations. Testing programs, such as the inservice testing program and the erosion-corrosion programs, were, in general, well-implemente Some problems were noted with plant modifications, including temporary modifications, and safety evaluations, but the quality of this work improved over the period. In some instances, communication of deficient conditions needing engineering solutions was not timely, and operability determinations and corrective actions associated with those deficiencies were weak. For example, degraded service water system conditions were improperly evaluated in the first half of the SALP period. Further, an August 1 996 event involving overpressurization of the diesel generator water jacket was not thoroughly assessed for its effect on component operability. In contrast, an assessment of a February 1 997 overpressurization event involving the letdown system was comprehensive and timely. Also, the heavy loads analysis in support of a service water pump replacement and an analysis of the effects of a high energy line break on electrical equipment operability were goo Some important weaknesses were noted associated in the maintenance of the plant's design and licensing bases and the translation of those bases into plant procedures. While calculations and other design and licensing bases information for plant electrical systems were reasonably retrievable and well-understood by the plant staff, significant problems existed associated with information related to mechanical systems. Also, because design bases documents (DBD) were compiled several years ago, but not maintained, those documents contained errors. In one instance, a significant operability question in April 1 997 involving the component cooling water (CCW) system could not be readily resolved as a result of the licensee not being able to readily retrieve design information that pertained to that question. The lack of awareness by your staff of design information resulted in important information not being correctly translated into the emergency operating procedures (EOPs). Additionally, this lack of design basis information translated into weaknesses in the scope and depth of surveillance testing activities. However, there were two noteworthy examples where the engineering staff identified or resolved long standing design deficiencies involving single failure criteria of diesel generator cubicle fans and the use of a spare battery charger which resulted from a good questioning attitude and followu In summary, engineering performance over the period was mixed. Improvement during the assessment period was noted, but continued management attention is needed to reduce the backlog of engineering work, strengthen support of material condition improvements and address weaknesses related to maintenance of the design and licensing basis.
The Engineering area is rated Category Enclosure 1 PERFORMANCE ANALYSIS - PLANT SUPPORT The licensee continued to implement effective programs for radiological protection, including the programs for occupational exposure control, radioactive waste management and transportation, effluents control, and environmental monitoring. Licensee management continued to provide oversight and support which resulted in overall effective programs to protect the safety of workers in radiological areas. Personnel radiation exposures continued to decrease over the last three years due to effective work planning, oversight, and control. The radiation protection staff was maintained at a nearly constant staffing level, with well-qualified and well-trained personnel. Excellent performance was noted in the area of problem identification, root cause assessment, and corrective actions. Self asses sments, program audits, and appraisals effectively identified minor program weakness and areas for program improvement. Minor deficiencies were noted during the period, but prompt and effective corrective actions were taken by the licensee's staff to prevent recurrenc Performance in the emergency preparedness program area continued to be very good, a s demonstrated by the results of drills and exercises. Key positions in the emergency response organization remained filled by qualified and well-trained individuals. Initial staff training was implemented effectively and requallification training was performance-base Emergency response facilities were well maintained and equipment was in a very good state of operational readiness. Audits of the emergency preparedness program were thorough and demonstrated a significant commitment of resources. Audit teams members had significant expertise and reports contained numerous recommendations for program improvement. The licensee's corrective action program for emergency preparedness items was generally good, but corrective actions for problems with the tone alert radio system were slowly implemente Management support for the security program was evident through the purchase and installation of new security equipment. Security personnel were knowledgeable of their duties and responsibilities. The training program for security personnel was effective as demonstrated by a reduction in security-related events during the current assessment period. The licensee had excellent controls for identifying, resolving, and preventing programmatic problems in the area of securit Fire protection equipment conditions and program implementation were good. Performance of fire brigade members during drills was excellent, reflecting on the effective training for fire brigade members. Fire protection design and engineering documents, including the design basis documents, fire engineering standards, plans, and records, were complet Minor weaknesses were identified associated with oversight of controls for combustible and flammable materials within the facility and with the annual training program requirement for practice sessions in fire extinguishmen Housekeeping deficiencies, indicative of poor implementation of housekeeping standards, were noted during the beginning of the assessment period. Improvement was noted toward the end of the assessment perio Enclosure 1
In summary, performance in the radiation protection area continued to be excellent. The radioactive waste processing, handling, storage and transportation programs were effectively implemented. Radioactive effluent controls and the environmental monitoring program were effective in ensuring that the impact on the public and the environment was minimal. The emergency preparedness program performance continued to be very good, including performance during drills and exercises. Management support was evident for the security program and security personnel effectively performed their duties. The fire protection program implementation was good, but some areas of minor weakness were identified associated with controls for combustible and flammable materials and with the annual training progra Housekeeping in various areas of the plant was identified as a weakness early in the period, but improvement was noted toward the end of the assessment perio The Plant Support area was rated Category ENCLOSURE 2 INDIAN POINT UNIT 3 PLANNED NRC INSPECTIONS JULY 1997 - JULY 1998 RI Regional Initiative CO Core Inspection (NRC Program Inspections, excepting Resident Core Activities)
PROCEDURE NUMBER TITLE DATE CO 81 700 Physical Security Program 7/7/97 CO 37550 Engineering Visit #1 11/10/97 CO 84750 Radioactive Waste Treatment & Effluents 12/01/97 CO 86750 Solid Radwaste Management 1 2/1 5/97 CO 83750 Occupational Radiation Exposure 2/9/98 CO 37550 Engineering Visit #2 2/1 6/98 CO 71750 Plant Support Activities 4/4/98 CO 37550 Engineering Visit #3 - 2 weeks 6/1/98 C0.40500 Effectiveness of Licensee Controls in TI 2515/1 09 Identifying, Resolving and Preventing Problems MOV Testing - Generic Letter 89-10 Closeout 7/1 3/98 TBD