IR 05000315/1992001
| ML17334B413 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 03/16/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17329A414 | List: |
| References | |
| 50-315-92-01, 50-315-92-1, 50-316-92-01, 50-316-92-1, NUDOCS 9203200046 | |
| Download: ML17334B413 (27) | |
Text
SALP 10 INITIAL SALP REPORT U.S.
NUCLEAR REGULATORY CONblISSIOH
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE Inspection Report Ho. 50-315/92001; 50-316/92001 Indiana Michigan Power Company Dona ld C.
Cook Hu c1ear Plant September 1, 1990, through December 31, 1991 9203200046 920316 PDR
- DOCK 05000315
SUMMARY OF RESULTS Overview Overall performance at the D. C.
Cook plant during the appraisal period was characterized by steady or improving results.
In the area of Plant Operations, the rating assigned this period was Category 2, which was a decl.ine from the Category I rating of -the previous period.
The Category 2 rating in the area 'of Plant Operations is a decline from the Category I rating of the previous period.
Although overall performance in this area was strong, there were a
number of issues, some repetitive, that contributed to this lower rating.
Some weaknesses in knowledge and implementation of Emergency Operating Procedures occurred, showing your efforts to maintain superior performance in this area have not been fully effective.
Some of the fire protection requirements were not being adhered to, an issue identified in the last SALP period that showed little improvement.
Finally, there were a few examples of operator inattentiveness during shutdown periods which had not previously occurred.
Improved performance in the Maintenance/Surveillance area and in the Engineering/Technical Support area yielded Category 2 ratings for each.
These twn areas had been rated Category 3 (Maintenance/Surveillance had an
"Improving" trend} during the previous appraisal period, showing that increased attention was required.
Concerning the Maintenance/Surveillance area, the most positive changes were noted in management involvement to continue development and implementation of gradual programmatic improvements.
The problems which did occur were more frequent in the early part of the current assessment period.
There are some issues remaining in this area, and the full effects of the prog> ammatic improvements have yet to become evident.
In the area of Engineering/Technical Support, the improvements noted were also indicative of more effective management involvement.
Effects of licensee initiatives, such as the system engineer program and a stronger onsite corporate engineering presence, were becoming evident.
Again, issues remain which will require continued attention and effort.
The area of Radiological Controls was again assigned a Category 2 rating.
Stronger performance was evident in several rating attributes, however, and no performance attributes weakened.
Actions taken and underway in this functional area are notable and commendabl Doth the Emergency Preparedness and Security functional areas received repeated Category 1 ratings, indicative of continued strong performance.
The Safety Assessment/guality Verification functional ar ea was again rated Category 2.
A few positive initiatives were counter balanced by minor examples of management
'disengagement.
Overall, performance was steady at a
level considered good.
The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
Functional Area Rating Last Rating This Period Period Trend Plant Operations
Radiological Controls
'
Hiaintenance/Surveillance 3 (improving)*
'I Security I
I Engineering/Technical Support
2 Safety Assessment/qua 1 ity
2 Verification
- Rating changed from 2 to 3 (improving) by the Regional 'Administrator III.
PERFORHAHCE ANALYSIS A.
~P1 D
ti 1.
~Anal sis Evaluation of this functional area was based on the results of 12 routine inspections by resident and regional inspectors.
Enforcement history was excellent and had improved compared to that during the previous assessment period.
No violations attributable to plant operations were issued during this period, while three violations were issued curing the previous period.
As in the previous, assessment period there were few licensee event reports (LERs) in this functional area.
Hone of the LERs were symptomatic of significant safety problems.
Host of the LERS were submitted because of personnel error or procedural problems.
One involved an engineered safety feature signal generated due to hi-hi steam generator water level.
An operator failed to proper'ty monitor the water level during shutdown testing.
A second
.
involved removing the wrong train of Essential Service Water from service to perform cot rective maintenance due to misunderstanding of observed conditions compounded by a labeling error.
The labeling discrepancy existed for many months before its discovery, but was an isolated failure of an otherwise good labeling program.
The third LER was submitted when a conscientious operator performing =a simulator training scenario identified a procedural discrepancy that permitted a possible small postaccident diversion of sump recirculation
flow away from the reactor coolant system.
The licensee immediately revised the affected emergency operating procedures to address this finding and notified industry groups of the possible generic concern.
Some of the personnel errors described in the LERs were related to fire protection requirements not being adhered to - an issue identified the last SALP period that showed little improvement into the current period.
Six.reactor trips, all at power, occurred this period; one in Unit I and five in Unit 2.
This compared unfavorably to the previous period, when only two non-power reactor trip signals were generated, both in Unit 2.
However, none of the trips were attributable to poor licensed operator performance.
They were generally attributable to equipment problems and are discussed in the tiaintenance/Surveillance section of this report.
llith minor exceptions, the performance of safety systems following the trips was as expected.
Operators responded very well to the reactor trips, and in one case prevented a Unit 2 trip after Unit 1 had already tripped, by quickly taking manual control of the online Unit 2 generator voltage, and raising it to compensate for a rapidly falling system voltage.
Shift team response to other operational events was also very good.
Shift performance during routine operations was good.
Shift turnover and logkeeping practices were performed well.
Control room professionalism and decorum were maintained at a high level throughout the assessment period.
Attentiveness of operators while carrying out assigned duties during at-power operations was very good.
Technical specification constraints were satisfactori ly adhered to.
Operator tours of the turbine and auxiliary building were conducted well with good attention to detail.
In one instance an attentive auxiliary operator found an emergency diesel generator air start component in a degraded state such that the engine may not have started.
The problem was promptly corrected.
Operator performance was somewhat weaker during reactor startup.
On two occasions during startup testing in October 1990, steam generator water level inadvertently reached the hi-hi set point.
In tlay 1991 a water hammer occurred in the feedwater system, partly due to a lack of complete operator awareness of the status of secondary plant equipment.
Also, during reactor coolant system fill and vent activities in August 1991 reactor coolant temperature unexpectedly decreased to the low temperature overpressure protection enable temperature
'limit.
t/anagement's effectiveness in ensuring quality was good.
The operations department supervisor kept abreast of plant status and crew performance by attending daily control room plant status meetings and by observing major planned evolutions.
Senior operations department staff and upper plant management exhibited a conservative and safety-conscious approach to both operational and shutdown plant decisions.
Throughout the assessment period management continued its efforts to minimize distractions in the control room so operators could focus on operating the units.
For example, the responsibility for writing equipment clearance forms was transferred from shift personnel to a dedicated group of operators located in an office away from the control rooms.
The identification and resolution'f technical issues was very good and reflected a strong conservative operating philosophy.
For example, in
August 1991 Unit 2 was shut down so personnel could safely repair a leaking Conoseal on the'eactor head.
In September 1991 Unit 1 was shut down, prior to time limits of a limiting condition for operation, to clear a blocked boror-injection tank recirculation line.
The licensee routinely unloaded the core completely at the start of refueling outages.
In the -few instances when the performance of licensed operators was weak, corrective actions were appropriate.'ormal critiques were conducted for significant events, and lessons-learned summaries were posted for required reading.
General plant appearance and cleanliness improved markedly during this assessment period.
Plant staffing was ample vrith a competent and experienced operating staff, well beyond TS requirements.
Shift technical advisors, although not licensed, were all certified and had the same training as the licensed operators.
VirtuaIly all of the operations department management staff were either currently or formerly licensed.
Overtime of licensed operators was adequately controlled.
The training and qualification programs for personnel were effective and contributed positively to safe reactor plant operation.
Plant routine operations were performed well and without significant error, as previously described.
There were some problems experienced in transient evolutions that may have shown some weaknesses in training.
The results of the licensed operator examinations were usually acceptable, although they showed some weaknesses in knowledge of emergency operating procedures.
This represented a
decline in performance from the previous assessment period.. Although a few individuals fai led requalification tests administered in January-February 1991, the requalification prograr" was satisfactory.
2.
Performance Ratin Performance is rated Category 2 in this area.
Performance was rated Category 1 in the previous assessment period.
3.
Recommendations None.
B. Radiolo ical Controls 1.
~Ass1 sis Evaluation of this functional area was based on the results of seven routine inspections by resident and regional inspectors.
Enforcement-related performance was good with one severity level IV violation concerning failure to follow radiological controls at the radiological controlled area (RCCi).
Management's effectiveness in ensuring quality was generally good.
Good performance was evidenced by improved corporate support for maintaining occupational dose as low as reasonably achievable (ALARA), including a
.-
controlled shutdown method which removed about 400 curies of radioactivity from plant systems during a forced outage and the approval of an experimental chemical decontamination method for the resistance temperature detector lines
for the next outage.
Other signs of management effectiveness included support for the volume control tank room source term reduction project, installation of new shielded monitoring booths, construction of a new hot tool storage crib; and the support of a-certification program for radiation protection technicians.
h1anagement was less effective in. addressing operability problems with effluent monitors and, on a few occasions, compensatory grab samples were missed.
Effluent monitor unreliability is an aging issue.
The liquid monitors are scheduled for replacement starting in 1993.
The licensee was also slow to remedy access control weaknesses at one of two points of egress from the RCA.
The approach to identifying and resolving technical issues was generally good.
Total station dose and the number of personal contamination events (PCEs)
were both low, about 410 person-rem and 190 PCEs, respectively, over the 16-month assessment period, which included a full refueling outage.
The licensee's contamination controls have improved considerably; the area posted as contaminated during non-outage periods was low.
Effective use of the radiological awareness program continued, as demonstrated by the identification of radioactive material outside the RCA.
Subsequent event followup was also good as evidenced by the appropriate reporting and submittal of a material exemption request.
Weaknesses were observed; however, in investigating and documenting jobs with higher than expected doses and in tracking and trending modesty garment contaminations.
However, good radiological awareness was demonstrated by the identification of'adioactive material outside the RCA.
Subsequent followup was also good as evidenced by appropriate reporting and submittal of a material exemption request.
t/o transportation or burial site problems were reported during the assessment period.
Radioactive effluents were typical for U.S. pressurized-water reactors.
The radiological environmental monitoring program was appropriately modified by the addition of six onsite environmental wells to follow tritium released to ground water from the turbine building sump.
Other.accomplishments during this assessment period included improvements to the radiation work permit system, completion of the high radiation door modification program, and initiation of aggressive programs for hot particle control, contamination control, and waste reduction.
Also, considerable progress was made in reducing leakage containment device in the auxiliary building.
Staffing and qualification of the radiation protection and radwaste department were good.
While radiological protection technician (RPT) experience onsite is comparatively limited, recent good staff stability is improving the experience level.
A strength in this area is the significant number of RPTs that are voluntarily participating in the professional technician certification program.
The performance of the ALARA and RPT staffs improved and is considered to be good.
The RPT training program, which includes plant operating systems was adequate.
The results of radiological measurements comparisons between the licensee and the HRC were exce'llent; of 93 comparisons there were 93 agreements, The results of the licensee's independent comparisons with those of an outside vendor were also in good agreemen.
Performance Ratin Performance is rated Category 2 in.this area.
Performance was rated Category
in the previous assessment period.
3.
Recommendations None.,
C.
Maintenance/Surveillance l.
~Aaa1 sis Evaluation of this functional area was based on the results of 12 routine inspections by resident inspectors and 3 special inspections by regional inspectors.
Enforcement history was good; only two Severity Level Itt violations were issued during the assessment period.
One violation involved multiple examples of fai lure to properly provide or follow procedures during maintenance activities.
The second violation was issued because of failure to perform a required leakage test on a valve, which placed both units in a limiting condition for operation.
There were few LERS in this functional area.
Several involved 'component failures or degradation, which may show evidence of plant aging.
For example, the failure of. a rod control multiplexing relay, a degraded containment divider barrier seal, and the failure of a main generator output breaker current transformer.
s Management's effectiveness in the maintena'nce area was good and has improved from the last assessment period.
For example, the reduction in the number of steam, water, and oil leaks and the improvement in housekeeping of-the auxiliary building were evidence of strong management attention and focus to maintaining the'verall material condition of the plant.
There was also evidence of improved planning and prioritization of maintenance activities.
Plant management 'closely monitored those maintenance activities which had the potential to adversely impact plant safety or reliability.
They also discussed these issues with corporate management, who provided support when needed.
The corrective action taken for equipment problems was adequate, but'ddressing root cause was not always effective as evidenced by some repetitive failures of components.
Overall, implementation of the maintenance program had improved since the last assessment period.
The planning and scheduling section was centralized and reorganized",
the computerized nuclear plant maintenance system was implemented to process action requests and initiate and track resulting corrective maintenance job orders, preventive maintenance activities were consolidated under one technical group, and a procedural upgrade effort resulted in
'mprovements.
Maragement appeared committed to long-term improvements, but the
effectiveness of these programmatic improvements was not yet evident.
A few programmatic issues identified in the last assessment period, such as the large number of non-outage corrective job orders, remained.
The quality of maintenance performed by the crafts was good.
There were few.
recurring component problems resulting from poor workmanship.-
However, there were instances early in the assessment period of individuals failing to adhere to procedures.
For example, maintenance on the Unit 2 North Safety Injection" Pump was performed incorrectly and without use of a procedure.
On another occasion, installation of a diaphragm in a pressurizer PORV was performed without an approved procedure.
Also, written procedures were not always provided for performing maintenance on safety-related equipment resulting in some rework.
Other minor maintenance discrepancies included improperly planned job orders that had to be returned to the planning department, some discrepancies in test procedures that required correction before implementation, lack of preventive maintenance on sacrificial zinc plugs, and some deficiencies in the documentation of postmaintenance tests.
Responsiveness to technical issues was good.
System engineers were actively involved in maintenance on their.assigned systems.
The content and timely performance of preventive maintenance improved.
The quality of corrective maintenance varied, and was somewhat dependent on root cause analyses.
The adequacy of root cause analyses varied with the extent of management involvement.
The licensee was usually successful in identifying and correcting maintenance problems tracked for resolution in'he daily pIanning meeting.
On the other hand, there were instances of repetitive problems involving spurious opening of. the Unit 2 north control rod motor generator set output breaker, spurious opening of the Unit 2 "B" reactor trip breaker and recurring operational problems with the emergency boration valve.
These showed that root cause analyses were not performed in the depth necessary to prevent recurrence.
f/aintenance-reIated audits and survei Ilances were thorough and were performance oriented.
The surveillance program and procedures continued to be effective with one LER resulting from a missed surveillance.
Survei llances were performed with minimal personnel error or procedural problems.
Although not caused by surveillance testing, three of the reactor trips involved surveillance activities in some manner.
Equipment failures caused or were involved in five of the six reactor trips, but they were nonrepetitive and they were not. caused by repair deficiencies.
Staffino in the maintenance department was satisfactory.
Staffing in the maintenance department increased and control of overtime for the maintenance personnel was satisfactory.
No equipment damage or other incident was attributed to excessive use of overtime.
The training and qualification of personnel appeared to be adequate.
2.
Performance Ratin Performance is rated Category 2 in this functional area.
Performance was rated Category 3 with an improving trend in the previous assessment perio.
Recommendations None D.
Emer enc Pre aredness 1.
~Anal s is Evaluation of this functional area was based on the results of two inspections.
Enforcement-related performance was excellent; no violations were identified.
11anagement's effectiveness in ensuring quality remained very good.
fhonthly training drills continued to supplement the emergency preparedness (EP)
training program.
The scenario development-committee, comprised of plant personnel from different disciplines, created challenging scenarios for drills and the annual exercise.
New mobile rad'ios were added to the operational staging area to improve communications between field teams and the other emergency response facilities.
The identification and resolution of technical
.issues remained excellent.
Emergency Plan revisions were done well, and adequate justifications were provided for each change.
Seven Unusual Events were declared during this assessment period.
The evaluation of the events that occurred before the routine EP inspection confirmed that the declarations were conservative and that the licensee had notified offsite officials in a timely manner.
Performance during the annual exercise was excellent, and no weaknesses or concerns were identified.
This was an off-hours exercise with a lengthy scenario timeline designed to challenge the procedures for staffing the emergency response organization (ERO).
In addition, this scenario was technically challenging because a loss of power to a.large selection of equipment and instrumentation had been simulated.
The EP staffing level was ample.
Management approved a full-time assistant to the EP coordinator; previously the EP coordinator had relied on radiation protection personnel for assistance.
Also, at the beginnino of this assessment period, a
new corporate EP coordinator was assigned.
The EP program remained strong.
Staffing levels of the ERO remained good.
The licensee maintains a
roster with at least three qualified personnel available to fillall key positions in the ERO.
The EP training program remained very good.
Personnel assigned to the ERO received classroom and drill training.
The combination of these two types of training was successful in preparing these personnel to perform their duties as demonstrated by the excellent performance during the exercise.
2.
Performance Ratin PerforfilafIce is rated Category 1 in this area.
Performance was rated Category
in the previous assessment perio.
Recommendations f/one; E.
~Securit l.
~Anal sis Evaluation of this functional area was based on the results of three security inspections and one fitness-for-duty (FFD) inspection.
Enforcement related performance remained the same as that during the previous assessment period and was excellent.
No violations were identified.
Management's effectiveness in ensuring the quality of the security program remained excellent.
Installation of the upgraded perimeter intrusion detection, system, which began in the previous assessment period, was completed.
Security system upgrades included completion of the closed circuit television (CCTY)
fiber optics system, and the addition or relocation of CCTY cameras in an attempt to resolve sun glare problems.
All cameras were added to the uninterruptable power supply to prevent power-up delays.
Management's dedication to improving security was demonstrated through the continued reduction in personnel errors and improved implementation by plant personnel of security requirements and continues to be a program strength.
a The approach to identifying and resolving technical issues was excellent.
Security management continued to demonstrate a clear understanding of security issues throughout the assessment period as shown by the planning, preparation, and implementation of security requirements associated with outages.
Extensive overview, self-audits, and surveillances conducted by quality assurance and security personnel were a program strength.
Additionally, the licensee contracted for an independent evaluation of its current security system.
This evaluation was performed to assist them in making decisions for increased efficiency, improved human factors, and security program enhancement.
Significant remodeling and upgrading of the onsite firearms range were completed.
A comprehensive tracking and trending system continued to provide information necessary to ensure problem areas were identified and preventive measures taken to reverse negative trends.
Repair of protected area lighting, identified as a concern in the previous period, was resolved this period.
The licensee implemented a preventive maintenance program to ensure timely replacement of lighting.units before they reached the end of normal life.
The security staff remained ample.
The experience level of the guard force was high because of the low turnover rate.
The security staff resources were effectively used, and a high level of security awareness was evident.
'ersonnel were added to manage and implement the FFD program.
A close and-effective liaison continued among local law enforcement agencies and licensee security management.
Communications among senior station management, the maintenance department, and the licensee security staff were excellent.
During th.is assessment period, security management kept both resident inspectors and regiona I personnel fully informed of site security issues.
Security
operational events were properly identified, analyzed, and documented.
Required logs and, records were accurate, complete, well maintained, and readily available.
The licensee implemented a timely and comprehensive program to heighten security awareness during the Persian Gulf conflict.
a The training and qualification program for the security force was excellent.
Contingency response training was improved by completing a vulnerability analysis to identify the most critical plant areas necessary for shutdown.
This included training all security personnel on a predeployment contingency plan that better utilizes concealment and cover techniques for protection of
'ersonnel.
The tactical response training was thorough and increased armed response capabilities.
Security personnel were competent in the execution of their duties.
They also routinely received supplemental security training by outside agencies.
The FFD program satisfied the general performance objectives of 10 CFR 26.10.
Program strengths included strong management support and oversight, aggressive involvement in assuring quality assurance FFD audits, an active canine program for detection of controlled substances, employee assistance program benefits for site contractors, and an aggressive proactive alcohol "odor identification" program.
2.
Performance Ratin Performance is rated Category I in this area.
Performance was rated Category 1 in the previous assessment period.
3.
Recommendations None.
F.
En ineerin /Technical Su ort 1.
~Aaa1 sis Evaluation of this functional area was based on the results of 7 inspections-by regional inspectors, 10 inspections by resident inspectors, and 2 operator licensing examinations.
Enforcement performance was good and consisted of two Severity Level IV violations.
Further, a Severity Level III violation was issued due to problems in fire protection safe shutdown.
This was discussed and evaluated during the previous SALP cycle.
Both Severity Level IV violations dealt with inadequate design change activities early in the SALP period.
One resulted from incorrect drawings and instructions that erroneously identified the classification of one motor control center.
The other was the result of failure to provide adequate design control and functional verification for several modifications.
In the latter case, two examples were a continuation of previously identified problems concerning design interface.
This violation was identified early in the assessment period.
Corrective actions to address these violations are discussed below and appeared to have been effective.
Few reportable events related to this functional area occurred during this assessment period.
The more significant events involved an inadequate original design, a personnel error during a design change, and a preventable reactor trip due to a set point error.
Although weak in some areas at the beginning of the assessment period, management's effectiveness in ensuring quality was improving.
By the end of the assessment period, management's effectiveness was good.
Early in the assessment, period, management instituted a detailed and comprehensive plant status document, updated daily, which included those issues that required an engineering resolution.
During the assessment period, improvements were made in the overall modification control process.
Following NRC concerns identified early in the assessment period, the licensee upgraded design procedures and implemented a
new postmodification group with the overall responsibility of ensuring adequate postmodification testing.
As a result of these initiatives, plant electrical and instrumentation and control modifications showed an improvement.
Corporate engineering was becoming increasingly involved with the implementation of modifications, and communications between the engineering staffs at the corporate office and the site were improving during the assessment period.
A significant improvement in design verification was noted as evidenced by the improved quality of design packages.
After weaknesses were noted early in the assessment period, the system engineering program improved with increased staffing and involvement in support of maintenance.
A new test requirement manual was developed to assist planners in specifying postmaintenance testing.
Other initiatives included the reliability centered maintenance program, the development of a program to control. Zebra mussels, and identificatiot> of problems associated with the iso-phase bus duct cooling system.
The system engineering responsibilities and interfaces with corporate engineering were c'larified.
However, a lack of attention to detail was noted in some design reviews, in documentation of postmodification testing, and in control of the quality and content of modification packages.
Examples included lack of separation between safety and non-safety buses, failure to incorporate updated electrical relay set points (which had a potential to cause breaker miscoordination), failure to correctly translate'a trip set point, failure to incorporate test guidance into a postmodification testing procedure, and failure to update the operations annunciator manual to reflect an installed system design change.
Although most of these examples occurred early in the assessment period, isolated examples occurred at the end of the period.
The approach to identifying and resolving technical issues was mixed.
On the positive side, issues were promptly identified and normally assigned to appropriate departments for resolution.
Once identified, most were resolved satisfactorily.-
One item successfully resolved involved problems with the governor on a turbine-driven auxiliary feedwater (TDAFW) pump.
f'ositive actions taken in the upgrade of the wide-range steam generator level instrumentation were conservative.
Because of deficiencies identified with their previous review activities, the licensee undertook a large-bore piping
reconstitution program.
The engineering'ctivities associated with this effort went beyond the minimum standards, and the responsible staff demonstrated a
clear understanding of the technical issues.
Very rigorous analytical approaches were used with regard to piping and support system interaction.
On the negative side, there were some examples of weak root cause analysis.
These included electrical overspeed problems with the TDAFW pump, repeated spurious tripping of motor generator output breakers and one of the reactor tr ip breakers, and incomplete starting of diesel generators caused by failure of pneumatic valves.
Although these examples did not affect operation 'of either unit, the failure to identify root causes of the initial problem resulted in repetitive component failures.
Staffing for engineering and technical support was adequate.
A need was identified during the previous assessment period for additional engineering resources at the site.
The licensee continued to hire engineering staff for the site.
The site project engineering design group was fully staffed, and the expanding plant engineering group was approximately SO percent staffed.
The system engineering group was strained at the beginning of the assessment period; however, additional staff were added as partial relief.
Although there were not enough system engineers for all systems, system engineers were assigned to the systems with the most problems.
Positions and responsibilities were well defined.
Technical design expertise within the corporate engineering group was good.
The use of consultants was at an appropriate level, and technical oversight was good.
Training and qualification effectiveness for the engineering staff was good.
System engineers routinely attended reactor operator training on assigned systems.
The corporate engineering staff was weIl qualified and knowledgeable of design control provisions.
However, the operator initial licensing examinations had a Iow pass rate, which had declined from the previous assessment period.(i.e., from 75 percent to 67 percent).
In addition, one senior reactor operator failed three NRC-administered requalification examinations.
Two failures followed remediation by the licensee.
2.
Performance Ratin Performance is rated Category 2 in this area.
Performance was rated Category 3 in the previous assessment period.
3.
Recommendations None.
G.
Safet Assessment/gualit Verification l.
~Anal sis Evaluation of this functional area was based on the results of 12 routine inspections by resident inspectors, several inspections by regional inspectors, and one special team inspection (fire protection).
In addition, licensee requests for amendments, exemptions, and reliefs, responses to generic communications, and other interactions with NRC staff were considere The enforcement history improved during this assessment period and was adequate.
Two Severity Level IV violations were issued during this period as compared to one Severity Level III and four.Severity Level IV violations during the previous period.
One of these violations was the result of failure to promptly correct self-identified deficiencies in the area of fire protection, specifically, emergency lighting.
This weakness was noted during the previous
-,assessment period, but the violation was issued during the current one.
'The-other violation concerned activities related to implementation of 10 CFR
.50."59 and appeared to be programmatic in nature.
Multiple examples were identified of failure to properly evaluate modifications and procedure changes to determine whether an unreviewed safety question existed.
There were some reportable events in this area during this assessment period.
These involved inadequate control of Maintenance/Surveillance related evolutions, procedural errors, and design deficiencies.
- Management's effectiveness in ensuring qua'1ity was good.
For example,
.management was aware of all important and potentially safety significant issues through its involvement in the corrective action program.
Additionally, the newly revised plant status document allowed management to improve its focus and better prioritize the more significant issues at-the plant.
- The licensee also identified ard resolved nonconforming design conditions, which indicated effective management involvement.
These included the problem of the Unit 2
'afety injection pump discharge pressurization and the EDG tornado wind loading design deficiency.
Management continued to support various self-improvement initiatives, including improving material conditions in the auxiliary building, computerizing the-maintenance work process, and use of technical consultants to perform various self-assessments.
Audits and survei Ilances conducted in the areas of security, radiological controls, emergency preparedness, and maintenance were generally good to excellent, were performance oriented, and adequately assessed technical performance and compliance with requirements related to these functional areas.
Responses tc audits and surveillance findings were generally thorough and technically sound.
Management's effectiveness in resolving technical issues was mixed.
On the positive side, deci ions were conservative,and reflected a conscientious safety philosophy toward operation of a nuclear power plant.
For example, ir,'efueling outages management chose to off-load the core before personnel performed maintenance activities affecting core cooling systems.
On three occasions the licensee performed operabi lity determinations on nonconforming equipment and conservatively declared the equipment inoperable.
On the other hand, technical resolutions did not always prevert recurrence of similar events; in some instances the initial investigation failed to,identify and assess all aspects of a problem.
Root cause analyses focused on the most likely causes and all possible contributing factors were not always considered.
Examples included repetitive problems with a TDAFW pump, and reactor trip breakers.
Additionally, the reactor protection system analog-to-digital instrument replacement did not adequately address technical issues and neither anticipated nor adequately provided contingencies for resulting delay The Nuclear Safety Design Review Committee (offsite review committee)
and Plant Nuclear Safety Review Committee (onsite review committee)
were we'l staffed and met more frequently than required by technical specifications (TS).
The meetings were well run and organized and appeared to meet all assigned TS responsibilities.
However, management was not always.involved in oversight of the resolution of open items identified in the
CFR 50.59 screenings or safety evaluations.
Thus, many
CFR 50.59 screenings and safety evaluations were conditional or premature.
Management promoted increased communications with the NRC staff.
Regularly scheduled meetings between the nuclear safety and licensing group and NRC headquarters staff were held to discuss licensing issues, new initiatives, and long range design proposals.
These meetings resulted in some improvement in the quality of license amendment applications.
Licensing submittals were usually satisfactory.
Notification of and justification for delays in schedule and implementation of NRC commitments continued to improve.
The technical basis supporting license amendment applications was generally well thought out and sufficiently conservative.
In a few instances, however, significant effort was needed to obtain additional information to support licensee submittals.
Responses to NRC bulletins and generic letters (GL) were timely, although alternate proposals did not always meet the intent of the generic letters and bulletins.
Efforts in response to GL 88-20 on individual plant examinations exceeded the minimum requirements.
The licensee's response to GL 88-14 on air compressor system design and monitoring did not adequately reflect the plant specific operating conditions.
The 'licensee's requests for temporary waivers of compliance were of mixed quality.
Staffing remained sufficient and stable.
Personnel appeared trained and qualified to identify problems.
However, inconsistent standards were maintained within the maintenance department for accomplishing independent verifications by the peer inspection process.
Specifically, the I and C group practices were much less formal.
2.
Performance Ratin Performance is rated Category 2 in this area.
Performance was rated Category 2 in the previous assessment period.
3.
Recommendations None.
IV.
SUPPORTING DATA AND SUMMARIES
e A.
Major Licensee Activities Significant outages and events are described below:
Unit I From October 20, 1990, through January 26, 1991, the unit was removed from service for a planned refueling outage.
From April 20 through Nay 5, 1991, a planned outage was conducted to repair the main transformer because of elevated levels of combustible gas.
On May 12, 1991, a reactor trip was caused by a malfunction of the main generator automatic voltage regulator.
The unit was returned to service on l1ay 16, 1991.
On June 10 and 11, 1991, an unplanned shutdown to Node 2 occurred to investigate and repair the source of electrical arcing in the main generator exciter.
From September 15 through 19, 1991, a planned shutdown was conducted to clear a blocked boron injection tank recirculation line.
Unit 2 The unit began the period in a refueling outage that ended on November 10, 1990.
On December 12, 1990, the unit tripped because of a loss of a main feed pump.
The unit was returned to service on December 14, 1990.
On December 15, 1990, an unplanned shutdown began because the AB train battery was inoperable.
The reactor tripped during the shutdown due to an incorrect setpoint; it was returned to service on December 20, 1990.
On triarch 13, 1991, the unit tripped because of an external electrical disturbance caused by downed transmission lines.
It was returned to service on triarch 15, 1991.
On August 1, 1991, the unit tripped because of a switchyard breaker failure.
1!hile the uriit was shut down, a'eak was discovered on the reactor vessel head instrument penetration Conoseal.
Following repairs, the unit was returned to service on August 25, 1991.
On November 15, 1991, the unit tripped when a leak in the main turbine control fluid pressure indicator sensing line caused the main turbine control valves to close.
The unit was returned to service on November 20, 1991.
B.
Major Ins ection Activities The inspection reports discussed in the SALP are listed below:
Docket Nos:
50-315 (Unit 1)'and 50-316 (Unit 2)
Inspection Reports (same number applies to both units):
90018, 90022 through 90027, 91002, 91003 (Unit 1 only), 91004 through 91019, 9102'3 through 91028
S ecial Ins ection Summar From December 3 through 7, 1990, the NRC conducted a Followup Maintenance Team Inspection (IR No. 90024/024).
From August 12 through 21, 1991, the NRC conduc'ted an Evaluation and Assessment of Maintenance Inspection (IR No. 91018/018).
From September 4 through 13, 1991, the NRC conducted a Design Changes Inspection (IR No. 91023/023).
From December 10 through 12, 1991, the NRC conducted a Large-Bore Piping
"
Reconstitution Program Inspection (IR No. 91028/028).
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