IR 05000298/1998099
| ML20237C318 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 08/17/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20237C311 | List: |
| References | |
| 50-298-98-99, NUDOCS 9808210091 | |
| Download: ML20237C318 (6) | |
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COOPER NUCLEAR STATION SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE (SALP)
Report 50-298/98-99 1 BACKGROUND The SALP Board convened on July 16,1998, to assess the nuclear safety perforr%ce of the Cooper Nuclear Station (CNS) for the period January 12,1997, through July 11,1998. The Board was conducted in accordance with Management Directive 8.6, " Systematic Assessment of Licensee Performance.' The board members included: K. E. Brockman (Board Chairperson),
Deputy Director, Division of Reactor Projects, Region IV; A. T. Howell, Director, Division of Reactor Safety, Region IV; and J. N. Hannon, Project Director, Division of Reactor Projects -
lil/IV, Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by the Regional Administrato Functional Areas and Ratinas Current Previous Plant Operations 2 2 Maintenance 2 2 Engineering 3 3 Plant Support 1 2 1 OPERATIONS Performance in the operations functional area was good, overall, and improved during this assessment period. Management involvement in daily operational activities was generally e+fective, and decision-making throughout the organization reflected a strong commitment to safety. Operators properly controlled the plant during both routine and transient evolutions. The licensed operator training program improved after performance problems were ide' tified early in the period. Problems involving the adequacy of operability evaluations and the appropriateness of Technical Specification interpretations continued to challenge the organization. Developing and implementing effective corrective actions continued to be an area of focus for the entire sit By the end of the assessment period, the Operations organization had begun conducting internal self-assessments and a formal plan for corrective action improvement had been initiated. In the latter case, however, it was too early to ascertain the extent and effectiveness of the change The Operations organization became the leader for raising performance expectations and demanding adherence to those standards in day-to-day operational activities. After several instances, otrly in the assessment period, where operations did not provide a consistent vision of enhanced performance to the other organizations, management established the momentum for improvement by providing more intrusive oversight and a stronger safety focus. This demand for improvement has been especially evident in operations' emphasis on quality in the work products prepared by the maintenance and engineering organization. Examples include the correction of inadequate service water flow balancing and the development of an improved work control l process in this latter case, the inclusion of licensed operators in the newly established work l control center demonstrated the improvements that could be realized by combining resources i
from different functional discipline PDR ADOCK 05000298
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2-The operational history of the plant during this assessment period reflected a safety consciousness. There were no instances where operator performance was a contributor to an operational occurrence. During the few transient evolutions which did occur, operator performance was strong; of particular note were the responses to the failures of a circulating water system isolation valve and a feedwater pump lubricating oil pump. The decorum of the control room staff reflected a commitment to improving formality and ensuring effective communications during daily operations. Three-way communications were established as the expected performance standard. although during time-sensitive activities, their use was not consistent. Shift turnovers and work prebriefs improved and became effective barriers to process and human performance error The plant staff continued, however, to demonstrate difficulties in areas involving the interpretation and implementation of the Technical Specifications and the development and documentation of operability evaluations. For example, contrary to the Technical Specifications, operators changed the operational Mode without documenting completion of the required verification of jet pump operability and did not adequately ascertain the operationalimpact of reactor vessellevel instrumentation inaccuracies. Corrective actions established to remedy problems with operational procedures resulted in improvements; however, they were not fully effective since errors were found in procedures which had already been reviewed and revise During the previous assessment period, the licensed operator training program displayed several performance inconsistencies, including problems with crew command, control, and communications skills and with effective procedural usage. Early in this assessment period, the written examination developed for operator licensing was of marginal quality. Corrective actions for both of these issues were effective, and the most recent requalification examination reflected these effort The Operations organization began to conduct and utilize the insights from internal self-assessments during this assessment period. Many of the improvement initiatives have been narrowly focused, but the process is producing results. More substantive, however, was the i initiation of a site-wide corrective action improvement program. Early in this assessment period, the NRC identified continuing problems that existed with the Cooper corrective action program; in l this regard, weaknesses were identified in both the development of root cause evaluations and I the implementation of associated corrective actions. The program developed in response to these findings has resulted in improved problem identification. Corrective action implementation, however, continues to be an area needing attentio l Overall, performance in the Operations functional area was determined to be Category l Il MAINTENANCE l Overall safety performance in the maintenance functional area continued to be good. A number of program improvements were implemented to enhance efficiency and effectiveness; however, the implementation of other programs, particularly those involving equipment performance monitoring, was not always effective in identifying degraded hardware conditions in a timely manner. Procedural adherence was typically good; however, procedural adequacy, particularly involving surveillance testing, continued to be a problem area. The conduct of maintenance and L
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-3-surveillance activities was generally good. The material condition of the plant was good overall; however, a number of hardware problems challenged the plant. Self-assessments were effective in identifying problems and maintenance personnel significantly increased the number of problem identification reports that they initiated; however, corrective actions were not always timely or effectiv The implementation effectiveness of maintenance and testing related processes and programs was mixed. The changes to work control processes and programs were effective in reducing the corrective maintenance backlog and addressing concerns involving postmaintenance testing. On the other hand, implementation of the heat exchanger monitoring and erosion / corrosion monitoring programs was not fully effective. it did not predict the development of a leak in the service water piping to the lube oil heat exchanger for an emergency diesel generator. Further, preventive maintenance of certain 4160 volt circuit breakers was not effective in preventing breaker failure The conduct of maintenance was generally good, with improvement noted during the latter half of the assessment period. Corrective maintenance was typically performed promptly. Good communications and self-checking techniques were routinely employed by maintenance personnel. Early in the assessment period, there were a number of problems involving inadequate planning, workmanship, and troubleshooting, which resulted in inadequately performed maintenance; however, significant improvement was noted by the end of the assessment perio The conduct of surveillance activities was also good overall, with a slight improving trend note Procedural adherence was typically good; however, earlier in the assessment period, there were a number of personnel errors which resulted in minor unanticipated equipment responses, such as an inadvertent start of an EDC. Some surveillance tests did not adequately demonstrate equipment operability becauso of inadequate acceptance criteria. For example, the surveillance procedures associated with the 125 vdc and 250 vdc systems did not contain acceptance criteri In general, the material condition of structures, systems, and components was good. However, there were a number of hardware problems, some of which were long-standing and a few of which were significant, that were indicative of ineffective performance monitoring or ineffective maintenance practices. For example, degraded service water system isolation valves, which leaked for a prolonged period, provided a path for silt to deposit on the suction side of the service water booster pumps. This condition was not detected in a timely manner even though silting of cooling water systems is a well known phenomenon at the facility.
l Problem identification improved significantly. Maintenance department self-assessments and quality assurance audits were effective in identifying areas for improvement. The maintenance
! department developed a maintenance improvement plan which identified, for example, actions to l address supervisory oversight of work in the field. A quality assurance audit revealed multiple problems in implementing the measuring and test equipment program. Of particular note, was the significant improvement in the initiation of problem identification reports by maintenance department personne Notwithstanding the improvements in problem identification, ineffective corrective actions, a problem noted in previous assessments, continued to be identified in a number of instances i
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throughout the assessment period. For example, several 4160 volt circuit breakers were not overhauled as intended. Additionally, the failure to recognize the safety and regulatory implications of a blocked RHR heat exchanger was indicative of a significant lack of a questioning j attitude on the part of plant personnel and managers and resulted in a delay in implementing l appropriate corrective action Overall, performance in the Maintenance functional area was determined to be Category 2.
I ENGINEERING Overall safety performance in the engineering functional area was again determined to be
- acceptable. This assessment reflected continuing problems with CNS management's ability to effectively correct long-standing programmatic weaknesses. Throughout much of this assessment period, problems were evident in the areas of corrective action, understanding and application of design basis information, and quality of engineering support. Near the end of the period, a "CNS Strategy for Achieving Engineering Excellence" was developed; however, it was too early to assess the results of this initiativ Engineering programs and procedures were generally adequate and progress was noted in reducing the engineering backlog. There was, however, a concern with the translation of design
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basis requirements into procedures and instructions. This was demonstrated by: (1) the l inconsistency between accident condition core spray flow requirements as defined in operating l
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procedures and the Updated Safety Analysis Report; (2) engineering's failure to provide clear emergency operating procedures guidance for controlling the electrical load profile; and (3) the failure of test procedures to consistently account for instrument uncertaintie The program and procedures for conducting safety reviews, screens, and evaluaties for changes to the facility in accordance with 10 CFR 50.59 improved since the last assessment. While several older safety evaluations were found to be lacking, in that they did not fully address all of the criteria of 10 CFR 50.59, with a few exceptions, the quality of recent evaluations was goo A number of deficiencies were noted in the design engineering area. They appeared to result from weaknesses in understanding the design bases of systems, the use of nonconservative ]
assumptions and inputs in calculations, and a lack of comprehensive standards and control over design work. Examples of this problem were the nonconservative assumptions and design inputs )
- used in the calculations for estimating the RHR pump room temperature and for verifying the l capability of the service water system to provide adequate back-up cooling for safety-related I equipment. Discrepancies were also noted in the Updated Safety Analysis Report, Technical J Specifications, and system design criteria document I Engineering support to operations and maintenance remained inconsistent. The engineering staff l
, did not always identify the potential impacts of modifications on plant systems or equipment, nor I did they consistently consider the regulatory implications of their actions. For example, a modification to the reactor equipment cooling system rendered it inoperable under accident conditions for a prolonged period. Engineering support in the preparation of operability assessments also lacked consistency, as was demonstrated by the assessments associated with the potentially degraded 4160 vac breakers and a stuck service water check valv '
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a 5-Improvement wss noted in the area of problem identification. Examples include the engineering staff identification of an error involving the seismic qualification of valve operators and the ongoing review of unauthorized modifications. In contrast, however, instances of poor problem identification continued as was shown by the failure to recognize the operability impact of water collection in the stendby gas treatmsnt system Z-sum Early in the assessment period, engineering failed to promptly address the potential safety impact of severe plugging of the RHR heat exchanger tubes, and the heat exchanger test program was not administered in accordance with commitments. Engineering was not aggressive in correcting known design and operational discrepancies, as demonstrated by their not properly correcting known errors in a surveillance procedure before it was re-used. Later in the assessment period, a slight improvement in the development and implementation of corrective actions was noted. The final technical evaluation associated with the potential effects of high torus water level on emergency core cooling system strainers and the pursuit of the generic imp (ications of this issue demonstrated that effective and comprehensive engineering work could be accomplishe The CNS Strategy for Achieving Engineering Excellence has involved the planning and implementation of many broad-scale corrective actions. The strategy includes actions for:
(1) reviewing the adequacy and effectiveness of past corrective actions for significant conditions adverse to quality; (2) conducting an engineering self-assessment; (3) attaining appropriate staffing levels, particularly in system engineering; and (4) expanding the training program. New measures to monitor performance have also been incorporated into the strategy. The strategy represents a comprehensive effort by management to address engineering performance problems; however, its long-term results and effectiveness have yet to realize Overall, performance in the Engineering functional area was determined to be Category PLANT SUPPORT Overall safety performance in the plant support functional area improved to an excellent level, with significant improvements noted in the radiological protection and emergency preparedness programs. While implementation of the physical security program remained excellent, a number of implementation problems in the fitness for duty program were indicative of a need for increased oversight, implementation of the fire protection program remained good. Plant housekeeping was very good overall, having improved significantly during the assessment period. Self-assessments and audits were self-critical. Corrective actions were effective and timely, with a few exceptions note The radiation protection organization performed at a superior level during this assessment period, with notable improvements in some areas. Training programs in all areas of radiological controls were good. Controls of radioactive materials and contamination were effective. Radiation
- protection technician and radiation worker performance was excellent, as was evidenced by the l
lack of implementation errors. Source term remained relatively low, and the latest three-year person-rem exposure average was one of the lowest boiling water reactor averages in the nation.
l t Effective radioactive effluent and solid radioactive waste, radiological environmental, and meteorological monitoring programs were implemented.
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-6 Performance in the emergency preparedness area was good overall and improved during the latter half of the assessment period. Emergency response facilities were maintained operational, and emergency preparedness staffing was strengthened. The emergency response organization training program was enhanced to increase emphasis on drill participation and performance evaluation. Response to actual events was effective, but an assessment of emergency plan implementation was not performed for one event. During control room simulator walkthroughs, orie crew failed to effectively implemerit key elements of the emergency plan. Effective remedial actions were implemented for the affected crew. Emergency response facility personnel successfully implemented essential emergency plan functions during the biennial exercise. The biennial exercise critique process was strengthened by using an independent peer group from other sites to evaluate exercise performance. The use of mock-ups, pictures, and staged props enhanced the training value of the exercise. An exercise weakness was identified in the operational support center for failure to imp!ement proper contamination control Overall, implementation of the physical security program was excellent. Strong performance was identified in the areas of access authorization, assessment aids, alarm stations, barriers, detection aids, communications, compensatory measures, security officer training and qualifications, package and material control, safeguards event reporting, and security plans and procedure With respect to the fitness-for-duty program, there were a number of instances in which '
supervisors or managers failed to comply with behavioral observation procedures. This indicated a need for increased oversight of this progra Performance in the fire protection area was good. Previously, the licensee re-evaluated its 10 CFR Part 50, Appendix R, safe shutdown analysis and identified a number of deficiencie These deficiencies, with a few exceptions, were effectively corrected. Effective corrective actions to address transient combustible material deficiencies, which were primarily identified early in the assessment period, were implemente l Plant housekeeping improved significantly during the assessment period and was very good overall. The facility was well lighted, and usua!!y maintained free of debri Critical self-assessments in the Plant Support area were conducted throughout the assessment period, and corrective actions werC WJally effective. The 1998 quality assurance audit and the )
1997 radiation protection self-assessment were self-critical, and the timeliness of corrective
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actions implemented by the radiation protection organization improved during the assessment period. Emergency preparedness management expanded the use of performance indicators to focus on areas of weak performance, program audits, and surveillance, and self-assessments identified a number of areas for improvement. In the security area, assessments and audits were effective in identifying issues for resolutio Overall, performance L Plant Support functional area was determined to be Category I l
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