IR 05000315/1994001
| ML17332A650 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 12/07/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17332A649 | List: |
| References | |
| 50-315-94-01, 50-315-94-1, 50-316-94-01, 50-316-94-1, NUDOCS 9503160107 | |
| Download: ML17332A650 (8) | |
Text
Donald C.
Cook Nuclear Plant SALP 12 Report No. 50-315; 50-316/94001 I.
INTRODUCTION The Systematic Assessment of Licensee Performance (SALP) process is used to develop the Nuclear Regulatory Commission's (NRC) conclusions regarding a
licensee's safety performance.
The SALP report documents the NRC's observations and insights on a licensee's performance and communicates the results to the licensee and the public.
It provides a vehicle for clear communication with licensee management that focuses on plant performance relative to safety risk perspectives.
The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilities.
This report is the NRC's assessment of the safety performance at Donald C.
Cook Nuclear Plant for the period May 1, 1993, through October 29, 1994.
An NRC SALP Board, composed of the individuals listed below, met on November 9, 1993, to review the observations and data on performance and to assess performance in accordance with the guidance in NRC Management Directive 8.6,
"Systematic Assessment of Licensee Performance."
Board Chair erson W. L. Axelson, Director, Division of Radiation Safety and Safeguards (DRSS)
.HHdH b
G.
E. Grant, Director, Division of Reactor Safety (DRS)
E.
G.
Greenman, Director, Division of Reactor Projects (DRP)
J.
N. Hannon, Director, Project Directorate III-1, NRR II.
PERFORMANCE RATINGS The current SALP process assesses performance in four functional areas instead of the previous seven.
The four areas are Operations, Maintenance, Engineering, and Plant Support.
Safety Assessment/guality Verification was considered for each of the four functional areas rather than as a separate functional area.
The Plant Support functional area assesses radiological controls, emergency preparedness, security, chemistry, and fire protection.
Three category ratings (1, 2, and 3) continue to be used in the assessment of performance in each functional area.
Performance trends, improving or declining, have been eliminated as a part of the ratings.'503ihOi07 94i207 PDR ADQCK 050003i5
III.
PERFORMANCE ANALYSIS A.
Plant 0 erations During this assessment period, the overall performance in the plant operations area was very good with excellent performance noted in the last six months of the period.
Plant operations reflected a generally conservative, safety-oriented operating philosophy.
This was evident in the decision to reduce power to repair several balance of plant components on Unit I and by the high reliability of safety-related equipment.
The operators exhibited excellent teamwork within the shift and communicated frequently with the plant engineering department to resolve equipment problems.
Prompt identification and resolution by operators of equipment problems, which could have affected unit operation, contributed to an event free operating cycle for Unit l.
Operations shift management provided excellent supervisory oversight during plant operations, Additionally, during the second half of the assessment period, management became more extensively involved with operator training evolutions.
To improve the focus of unit supervisors on plant evolutions, management effectively used the task master position to handle administrative requests during an outage period.
Efforts to identify and resolve issues in the operations area were good with satisfactory resolution of most deficiencies identified.
However, there were some issues which required further attention by the Operations Department management.
These issues included the falsification of tours by the non-licensed operators, the inability of the operators to determine the reactor coolant system (RCS) inventory at certain periods during an RCS draindown evolution, and numerous low oil conditions on the auxiliary feedwater pumps.
All these issues were eventually resolved by the Operations Department management.
Management continued efforts to promote error-free operation, as evidenced by the low threshold for writing condition reports on operational events, and an'rror-free refueling program.
Operator performance was excellent and contributed to good operational availability for both units.
Tge operators displayed excellent command and control of all plant evolutions and also responded well to several reactor trips and balance of plant transients.
Auxiliary equipment operator performance deficiencies earlier in the SALP period with regards to control of certain valves outside the control room and maintaining proper oi.l levels on the auxiliary feedwater pumps were satisfactorily resolved.
Operator training programs and operating procedures were strong as evidenced by the excellent performance during plant trips and transients.
The performance rating is Category I in this area.
B.
Maintenance Overall, performance in the maintenance area was excellent.
A high level of equipment availability, reliability, and performance was sustained by an experienced and qualified work force.
However, there were isolated weaknesses
evident in events, primarily early in the period, attributable to maintenance department work activities.
Some concerns were noted in the area of plant procedures.
Management demonstrated a continued high level of involvement in the maintenance area with a conservative safety focus.
In general, management involvement with specific activities produced a successful maintenance program, such as, the high quality of the ISI and erosion/corrosion program.
Regular planned facility observation and investigation into process improvements, contributed to a strong program.
Hanagement's involvement contributed to a high degree of equipment availability.
Identification and resolution of issues was excellent.
Problem and root cause investigation led to effective corrective maintenance measures.
guality Assurance audits and surveillances were performance oriented and effective in identifying maintenance related problems.
Experience and expertise of the maintenance staff contributed to effective trouble shooting which led to the self-identification of problems during work activities.
Continued efforts to improve maintenance planning and scheduling were effective.
Utilization of effective work planning has reduced the maintenance backlog to a manageable level.
Early in the assessment period, weaknesses were noted in the control and implementation of the preventative maintenance program.
However, these weaknesses were effectively addressed with no problems noted during the latter part of the period.
The quality of and adherence to procedures during the latter part of the assessment period in maintenance activities was generally excellent.
Two examples involving procedure control problems were noted early in the assessment period.
Management focused on the problems of deferrals and the question of completing Preventive Maintenance tasks (PHs) in a timely manner through establishment of plant PH goals.
Although the licensee had not yet met their goals of zero safety-related and 10 non-safety-related PHs deferred, the program appeared to be effective based on the small percentage of PHs deferred and progress made to date.
Housekeeping and the material condition of the plant continued to be strengths.
Housekeeping was noted as being very good throughout the period.
Significant equipment out-of-service time was low and forced outages due to equipment condition were few.
The quality of the maintenance performed was good overall.
Positive examples included replacement of the hand/auto controller for a Unit I feed regulating valve, repair of the Chemical Volume Control System letdown valves, and replacement of the regenerative heat exchanger letdown safety valve.
The quantity of rework required was low.
There were several instances of personnel errors while conducting maintenance, particularly by I & C technicians, resulting in a trip of all pressurizer heaters, a letdown isolation, and a reactor scram caused by the failure to use a procedure during reassembly of the main steam stop valve dump valve.
The performance rating is Category I in this are ~E" i" The overall performance in the engineering area was considered to be good and was characterized by generally proactive and direct involvement by management in engineering programs and issues, good quality of engineering activities, and effective integration of engineering with other departments.
There was a
noted improvement in the identification and resolution of safety related issues.
However, in a few instances, the resolutions were not timely.
In addition, there were instances where a weak knowledge of the design basis, or the lack of a questioning attitude impacted the quality or effectiveness of the engineering process.
Overall, management and staff exhibited a good safety focus in approaching engineering issues.
Typically, the resolution of engineering issues was characterized by decisions that sought a net safety improvement such as the approach taken in the replacement of balance of plant components and upgrades to fire protection equipment.
On the other hand, lapses in this approach were evident in the resolution to problems pertaining to increasing component cooling water temperature to reduce reactor coolant pump seal leakage and the loose reactor head penetration funnel guides.
While apparently not typical, the responses to these issues demonstrated the need to assure that the full impact on safety is understood prior to proposing solutions that seem, on the surface, to be acceptable.
Hanagement involvement and oversight of engineering activities was considered very good.
Active and effective involvement in engineering processes ensured overall good quality.
Hanagement emphasis on continuing improvement was demonstrated by the use of multi-disciplined investigation teams for problem solving, and the guidance provided for setpoint methodology.
Another positive management initiative was the completion of an engineering self-assessment of system engineering, designed to confirm current issues and identify new problems.
However, management oversight of some aspects of engineering programs was found to be less effective, such as portions of the motor operated valve (HOV) program.
Another examp>>
was a lack of definition of certa";n duties and responsibilities for system engineers, resulting in some system engineers not being involved in post maintenance testing and not always being informed of relevant condition reports.
Performance in the identification and resolution of technical issues was considered to be very good.
The resolution of long standing issues was noteworthy and was the result of effective engineering coordination between the site and corporate engineering organizations.
Examples included the elimination of electrical noise in the reactor protection system and the investigation of the cause of weld failures in the core exit temperature nozzle assemblies.
Additionally, effective engineering support to the plant resulted in a high reliability of safety related equipment and close communication between plant engineering and operations staff.
In contrast to this performance was a flush performed to clear the essential service water supply piping that resulted in debris buildup and pipe blockage.
Also, there were isolated examples of less effective root cause evaluations or corrective action Overall, engineering programs and procedures were acceptable.
Several programs were determined to be partially implemented, or not at all.
Among them was the oil analysis program which, while scheduled to be in place by the end of 1993, had not been implemented by the end of the SALP period.
Other examples were the lack of a methodology to incorporate old test data uncertainties into the HOV design assumptions, and the use of non-conservative grid voltage values for evaluating the design basis HOV motor terminal voltages.
At times, procedures were found to be lacking required statements including adequate precautions and sufficient detail to support technical evaluations.
However, significant programs such as erosion/corrosion identification and control and the inservice test program were considered very good.
Overall, the staff had a good understanding of plant design as illustrated by the trouble-free modification of the reactor protection system and the replacement of obsolete radiation monitors.: However, at times, lack of plant system design knowledge resulted in an inability to effectively troubleshoot instrumentation problems and engineering judgements that were provided to the plant without a good understanding of system design limits.
Examples included the information provided by corporate engineering to justify an increase in CCW operating temperature limits and the lack of plant specific Instrument and Controls knowledge of corporate engineers which limited their effectiveness in troubleshooting instrumentation problems.
While the overall quality and thoroughness of engineering work was considered good, some areas could use improvement.
Good performance was demonstrated by the effort to resolve a station battery ground and the replacement of a regenerative heat exchanger safety valve.
However, 'weaknesses were noted in the quality of the calculations used for some reactive events, including the calculations used to inject Furmanite into Class I valves and some of the ISC calculations used to justify deviations from installed configurations.
The performance rating is Category 2 in this area.
0.
~P1
The overall performance in the plant support areas was excellent.
Low personnel collective dose, an experienced and knowledgeable staff, emergency response readiness, control of combustibles, radiological housekeeping, security staff performance, and strong management support were significant strengths.
The radiation protection program was excellent.
Management was aggressively supportive of dose reduction programs and source term reduction initiatives.
Station dose had been continuously declining and is considerably below the four year median dose for PWRs.
There was a stable, experienced and technically qualified staff, effective implementation of revised
CFR Part 20, and a strong self-assessment/corrective action program.
There were few radiological impediments in the auxiliary building thus improving operator round access and eFfectiveness.
The radiological environmental monitoring program (REHP)
was well-managed and was conducted by knowledgeable personne Chemistry performance improved during the assessment period, however it was weak early in the assessment period.
Personnel errors that occurred early in the assessment period decreased during the last six months.
These early performance issues had been identified by plant and corporate management, and were resolved by restructuring chemistry department management.
Management support for chemistry was evidenced by new laboratory equipment, which provided increased analytical capability and improved laboratory efficiency, and by employing outside consultants to review the program.
Analytical performance was very good due to the outstanding technical capability of chemistry technicians, with a number of these individuals holding chemistry degrees.
Chemistry and Operations management maintained optimum operating conditions which helped to minimize corrosion.
The Emergency Preparedness program continued to be a strength, with continuing initiatives to improve facilities and procedures.
Overall management support, training, and facility maintenance remained excellent.
Modifications to the Control Room benefited from Emergency Preparedness considerations, and Technical Support Center/Emergency Operations Facility projector status boards enhanced staff performance in both facilities.
Strengths included the annual audit of the Emergency Preparedness program, and the relatively stable and experienced staff.
Performance during the 1993 full-participation exercise and the 1994 utility only exercise was very good.
Both exercise scenarios were acceptably challenging.
Strong management support was demonstrated in maintaining an excellent security program.
Program strengths.included highly qualified and dedicated security staff personnel and management oversight of the program.
Performance improvements included tactical response capability through a more reliable and capable weapon, establishing onsite drug testing capability to improve turnaround time resulting in efficient identification of potential problems, and replacing the security uninterruptible power supply system to improve system reliability.
The high quality of the drills, exercises, and weapons demonstrations observed by the Operational Safeguards Response Evaluation team indicated an excellent contingency response capability.
The fire protection program was considered excellent and improving, with numerous efforts to improve the program.
Strengths included a low number of impairments; a dedicated and well-trained fire brigade; staff that was proactive in improving and maintaining fire protection equipment; and audits that were of good quality.
The performance rating is Category 1 in this are ta0