IR 05000317/1988099
| ML20043D562 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 06/01/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20043D551 | List: |
| References | |
| 50-317-88-99-01, 50-317-88-99-1, 50-318-88-99, NUDOCS 9006080235 | |
| Download: ML20043D562 (44) | |
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. . ENCLOSURE 2 .: <- FINAL SALP REPORT U. S. NUCLEAR REGULATORY COMMISSION-
REGION I
. SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE , BOARD REPORT NO. 50-317/88-99 AND 50-318/88-99-CALVERT CLIFFS NUCLEAR POWER PLANT ASSESSMENT PERIOD: DECEMBER 1, 1988 - DECEMBER 31, 1989 BOARD MEETING DATE: FEBRUARY 28, 1990-
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- .. l SUMMARY OF RESULTS i A.
Overview At the end of the last SALP period, overall licenses performance was marked by weak interdepartmental communications and management's inability to effectively set goals and achieve the high standards necessary to ensure the effective and efficient functioning of all organizational units.
The decline in performance reported 'or the previous SALP period continued dur-ing the early part of this SALP perivi.
'here were significant problems with procedural compliance on the part of station personnel, inadequate procedures, poor vertical and horizontal communications and a management philcsophy that appeared to put greater emphasis on power production than on quality and safety.
By May 1989, the licensee had one unit in an outage and shut the second unit down for inspection.
Late in the period, the NRC noted a substan-tial change in the focus and attitude of licensee ti,3agement, which initiated an aggressive effort to improve performance.
By the end of the SALP period, the NRC noted improvement in the licensee's per-formance in those functional areas previously identified as weak. In the oper-ations area, improvement was particularly noted in a more positive attitude toward procedure compliance.
0perations management actions to communicate a philosophy of safety over production and emphasize procedure quality and pro-cedural adherence were indicative of a commitment to improve.
In the mainten-ance/ surveillance area, problems identified early in the SALP period were addressed by the licensee with improvement noted late in the period.
Particu-lar improvement was noted in the areas of maintenance procedure quality and activity control, and surveillance accountability and scheduling. The licensee also made efforts late in the SALP period to improve upon numerous weaknesses noted in the area of safety assessment and quality verification.
Recently implemented changes in the areas of independent evaluation, QA guidance, super-visory observation and feedback, planning and scheduling, and retrieval of historical information are intended to effect improvements in this' area.
In Radiological Controls, a high level of performance in the ALARA and dose . control areas was noted, but weak performance in correction of identified prob-lems and waste management caused an overall decline in performance in this functional area from that of the prior period.
Programs in the areas of Emergency Preparedness and Security were acceptable j with a high level of efficiency and performance maintained in the security area.
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Overall, the licensee has made a number of management and programmatic changes designed to improve facility performance.. Since the shutdown of both units in May 1989, senior management has emphasized a philosophy of quality and safety over production. Procedural quality and procedural compliance have improved in most areas, however, a number of weaknesses still existed at the end of the - period. The most notable of these include: lack of a centralized program for the management of corrective actions; weaknesses in communications between departments; and inadequate follow through in the resolution of identified problems. Strong senior management attention, guidance and support are needed l to correct these weaknesses in order to sustain the overall general improvement i observed late in the SALP period.
B: Facility Performance Analysis Summary j Rating Rating Last This i Functional Area Period Period Trend 1.
Plant Operations 2(Declining)
Improving 2.
Radiological Controls
2 2.
Maintenance / Surveillance
3 Improving i 4.
Emergency Preparedness 2(Improving)
1 5.
Security
1 6.
Engineering / Technical i Support
2 7.
Safety Assessment / Quality Verification
3 ' C.
Unplanned Shutdowns ' Unit 1 Date Power Level Root Cause Functional Area 1/10/89 70% Component Failure Not Applicable Description: Unplanned shutdown to repair a leaking instrument line on No.11 steam generator feedwater pump discharge piping.
2/26/89 100% Component Failure Not Applicable Description: Unplanned shutdown to repair a leaking third stage extraction steam line tra l . . .
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I Unit 1(Continued) Date Power Level Root Cau g Functional Area 3/2/89 100% Cr ent Failure Not Applicable Description: Unplanned shutdown for replacement of the No. 11 reactor coolant pump seal.
3/29/89 60% Component Failure Not Appi', cable Description: Unplanned shutdown due to significant irirusion of ion exchange resins into the reactor coolant systeti caused high concentra-tions of sulfates.
5/6/89 100% Not Applicable Not Applicable Description: Unplanned shutdown to inspect Unit 1 pressurizer for leakageL , similar to that identified on Unit 2.
The unit remained shut down for the duration of the assessment period for maintenance - activities and resolution of management and safety issues.
Unit 2 Date Power Level Root Cause-Functional Area l 1/19/89 100% Component Failure Not Applicable , I Description: Unplanned shutdown to repair the No. 22 feedwater regulating , valve instrument air line, l' i 3/7/89 100% Component Failure Not Applicable Description: Unplanned shutdown to repair a feedwater regulating valve.' 3/17/89 100% Component Failure Engineering / Technical Support h Description: Unplanned shutdown to repair a pin hole leak on the No. 22 steam l generator blowdown piping. The unit remained shut down for the i duration of the assessment period for an extended refueling out- > age and extensive repairs to the pressurizer heater sleeves.
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III, 7ERFORMANCE ANALYSIS A.
Plant Operations 1.
Analysis This area was rated Category 2 with a declining trend in the previous SALP assessment. That assessment noted some reduction in plant trip frequency and good operator response to transients. Improvements were also seen in control room professionalism but significant problems existed with the plant staff in procedure compliance-and the quality of procedures.
Des-pite some noted improvements, weakness was identified in the integration of engineering into operational and safety decision making.
The Operations Department is staffed by competent,. knowledgeable individ-uals who generally executed their duties in a professional manner.
The conduct and proced ral adherence of operations personnel were generally.
, good during high visibility activities such as plant startups and shut- ' downs. There was good licensed operator response to plant transients dur-- ing which operations staff generally applied a conservative safety per-spective.
However, other activities were not always conducted in a deliberate, step-by-step manner so as to avoid errors. The licensee was slow to recognize and acknowledge that operations performance had declined over the past few years. At the beginning of the period,' licensee manage-ment's operating style appeared to unduly focus on power production, thereby contributing to performance deficiencies at the facility.
By the t end of the period, the operating organization had become more sensitized to problem identification and exhibited an increased awareness of the importance of adhering to procedural requirements.
No reactor trips occurred during the three and one half months of power operation for each unit,- Each unit had three unplanned shutdowns; five were due to secondary system problems with the sixth due to reactor coo- - lant pump seal replacement extended by high reactor coolant system (RCS) sulfates.
Dec1:ive, timely licensed operator action was evident in coping with plant challei.ges following a loss of instrument air and a partial loss of main condenser veceum.
However, there were a series of procedural adherence problems and person-nel errors by the operations staff which resulted in failures to meet safety requirements and led to plant challenges.
These included a fail-ure of control room personnel to follow emergency procedures when a fire developed in a handswitch on a control room panel, and a failure to follow the steps in Operating Instructions (0Is), which resul',ed in a partial . locs of condenser vacuum.
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, Procedure adherence problems were attributable to deficiencies with pro-cedures as well as a previous operating philosophy that tended to treat procedures, including Emergency Operating Procedures- (EOPs), as guide-lines. By the end of the assessment period, procedure quality and upgrad-ing were being addressed through simulator evaluation and the long-range Performance Improvement Program (PIP) Procedure Upgrade Program (PUP).
In addition, management polices, statements and actions repeatedly and emphatically emphasized the need for _ rigorous procedural adherence, including improvements in sensitizing the staff to stop work when proced-ure deficiencies were encountered until such procedures could be appro-priately revised.
NRC assessments noted evidence that this change in philosophy among the operations staff was occurring.
Several managerial and administrative controls problems were identified which collectively demonstrated a weakness in the overall control of activities within the operations department.
The operations department was not aggressive in investigating minor operational events such as a , dropped rod while in Mode 3.
This was indicative of a failure to recog- ,! nize ' potential adverse safety implications.
In general, placards in use for the operation of systems in the plant were not controlled in accord-ance with the operator aids system.
Responsibilities for control of pro-cedural changes for plant operating procedures were fragmented.
This was especially true in the control of temporary changes where a clear defini-tion of intent changes was not provided. Procedural directions pertaining to E0Ps that should be entered to mitigate emergency events were inade-quate.
Standing instructions from the General Supervisor Nuclear Opera-tions were sometimes used to provide operating instructions which should have been contained in operations procedures.
The effectiveness of interfaces and communications between the Operations Department and other parts of the licensee's organization was mixed. For example, operators for the spent fuel cask crane were unaware of-licensee commitments to restrict crane movement so that the load blocks, which represent heavy loads, would not be moved over spent fuel. The mechanical stops had actually been removed.
In another case, a lack of communica-tions and coordination during tagging operations resulted in a hazardous condition for a diver.
Also, caution-tagged auxiliary feedwater system (AFW) valves were removed from service contrary to procedures.
In the _ latter part of the period, effective interface was noted in the use of . plant status reports. This was indicated in the agendas for daily morning j managers'- meetings. and the weekly use of this forum to discuss corrective actions and timetables for resolution of concern !' y '
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Although the Operations Department demonstrated general improvement in the use of procedures and cdministration of change processes near the end of the SALP period, the NRC identified examples of inadequate procedures that were required - for the existing plant-mode (Cold Shutdown).
The licensee ' had identified the procedure inadequacies but had improperly prioritized these procedures for correction.
In addition, the licensee had not fully implemented monitoring practices for. evaluating the effectiveness of the extensively modified safety tagging and equipment cuntrols.
By the end of the assessment period, the NRC concluded that there was an overall satisfactory level of control and knowledge of plant status and activities.
Shift briefings were ef fective with improved plant status information available to operators, including expanded use of out-of-service tags to display equipment status. With respect to procedural com-pliance, there was an increased awareness of the importance of procedures, an increased attention to change of intent in procedural changes, and operators adopted the practice of stopping plant evolutions to fix proced-ures when problems were encountered.
Significant in:rc:;es were ented in staffing for operators and the operations procedures group.
These increased resources, plus the designation of a senior reactor operator (SRO) licensed individual as post-maintenant.e testing coordinator were indicative of management's intent to strengthen operations. programs.
In summary, strong operator responses to plant transients identified - in the previous SALP were also observed in the current period.
The weak- ,' nesses previously noted in procedural adherence and procedure quality con-tinued.
Weaknesses in managerial and administrative controls for the Operations Department were also evident. Improvements were noted near the end of the period in complying with procedures, correcting and upgrading deficient procedures, and providing operators with good plant status information.
Management actions to enforce procedural compliance and increase operations staf fing were indicative of - a commitment to improve operations performance.
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Performance Rating Rating: Category 3 Trend: Improving 3.
Recommendations Licensee: None l l !!RC: None . -.. - . - - - .
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Radiological Controls ' 1.
Analysis The radiological and chemistry control program was rated Category 1 during the last assessment period. Although performance was strong, particularly ' in ALARA, some decline in performance in the areas of radwaste, transpor-
> tation, and corrective _ action for radiological deficiencies was noted.
I Radiological Controls i The licensee continued to implement the radiological protection program in ! an ef fective manner, anchored by a t: ALARA program that has been very i successful in maintaining cumulative radiation exposures at low. levels.
However, continued problems involving the correction of NRC identified-issues, such as the resolution of self-assessment findings, and the cor-rection-of radweste and transportation weaknesses, indicate a decline in i overall performance in this area.
i The licensee demonstrated continued management involvement in maintaining i a quality radiation protection program through the implementation of 'an ! improved Special Work Permit process, increased frequency of pre-job i briefings, and expanded use of. closed circuit television (CCTV) monitor-i ing.
These actions helped to maintain the consistent excellence seen in
ALARA performance and in external exposure controls.
The total site ! exposure for 1988 was' 292 person-rem while the goal for 1989 was 335 per- ! - son-rem, with both units being in an extended outage since May of 1989.
'j The lengthy outage of Unit 2, budgeted for an aggressive ALARA goal, ' includes. many high exposure jobs, such as installation of a new type -of l reactor coolant' pump seal and replacement of defective steam generator .i tube plugs. Along with these positive factors, however, several examples indicate that some weaknesses in management control and inattention - to _, procedure adherence exist. Examples include procedure changes routed to l HP. technicians which remained unreviewed for 60 days past the due date; ' job coverage surveys which were missed but not detected by _ two levels of supervisory review; field inspections to verify ALARA implementation which were not documented as required; and whole body counter operatinnal checks f that did not meet the acceptance criteria band and were not investigated.
' Also procedure changes were not managed to ensure that they were kept up-to-date with program changes and improvements.
Instances of inatten-tion to the use and maintenance of procedures in assuring quality also occurred during the period. Overall, management involvement in the assur-ance of quality is assessed as effective.
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Problems identified last period by NRC with timeliness of resolution of self-assessment findings were not resolved during this period.
For example, an audit of outage activities was not issued in a timely manner, which prevented prompt followup; a time limit for resolution of NRC and- , licensee identified radiological deficiencies and concerns has not been ! formalized in the controlling procedure; and there was~ no mechanism to I escalate deficiencies with significant safety potential to upper manage- , ment attention ~. The licensee's response to self-assessment findings and i NRC identified problems is assessed as poor.
Overall, training was generally effective,- as demonstrated by the Mcen- -) see's successful ALARA program. However,-several weaknesses were noted in i training, For example, there was no formal program for two classifica-l tions of technicians who repair, calibrate and test radiation monitoring equipment; and vendor training provided of f-site-to technicians - was not reviewed or recorded by the licensee's training department.
Remistry,RadwasteandTransportation A problem that involved chemistry, radwaste and transportation revealed - weaknesses in the licensee's programs for the assurance of quality, iden- - ! tification and resolution of technical issues, and enforcement and respon-J siveness to NRC concerns.
The incident, in which the isotopic distribu-I tion and activities associated with a shipment of radwaste clearly did not j correlate with actual plant data, was identified by the licensee's QA pro- , gram, but corrective action was not taken. Subsequently, a recurrence was i identified by the NRC and cited as a violation.
Corrective action again . was not taken, and a repeat violation occurred. Despite the continuing < failures to identify the root causes of these multiple program weaknesses q and take corrective action, the licensee continued to make shipments of radwaste.
The licensee's responsiveness to NRC initiatives was lacking in technical depth in the radwaste area during the assessment period in that the licen-see took corrective actions which failed to prevent recurrence of two violations, including the continued shipment of radwaste when the isotopic
distribution and activities could not be correlated with actual plant j data. The licensee did demonstrate better responsiveness during the water ' chemistry inspection, taking prompt actions to improve their non-radio-logical chemi stry analyses to ensure agreement with NRC test sample . results. Despite these occasional lapses, such as that described above, -i the licensee's response to NRC concerns was generally effective.
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, , The licensee reported three Licensee Event Reports related to the effluents program. Two of these events were related to procedural error, while the third was related to a lack of proper communication.
These , events were promptly and completely reported, and-properly identified and analyzed.
With regard to staffing levels and training, expertise was usually avail-able within the staf f, however, the response to violations cited in the ' area of plant radwaste scaling factors was solely dependent upon the use of a consultant, due to the licensee s.taf f's lack of expertise in this area.
Inadequate training was part of the root cause of the two trans-portation violations involving the shipment of contaminated material.
As a result, the licensee had to provide retraining to all staff members as part of its corrective actions to these violations. Staffing and training-i n the areas of the environmental monitoring, and liquid and gaseous effluent controls were determined to ' e very good.
o In summary, licensee performance in the major radiation protection func-tional areas remained generally effective, but overall performance was - not as effective during the current period.
While ALARA performance is still considered strong, declining performance appeared in the areas of i followup on identified problems, management involvement in assuring ' quality and radiological training.
In addition, the decline noted during the last assessment period in radwaste and transportation programs has continued.
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Performance Rating Rating: Category 2 Trend: None p 3.
Recommendations ! I Licensee: Identify and correct root causes for lack of timely and ' complete followup of self-identified and NRC-identified problems.
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Maintenance / Surveillance 1.
Analysis This area was. rated Category 2 in the previous SALP assessment. Improve-ments were noted in the management policy toward resolving intermittent equipment pt-oblems with initiatives in the areas of backlog reduction, , maintenance planning, procedural and equipment problems and plant material.
conditions.
Lack of attention to detail during maintenance activities coupled with insufficient control and supervision resulted in a signifi-cant number of reactor trips and equipment challenges. A decentralized surveillance organization was identified as a contributor to a lack of an overall corrective action prograr., Procedure adherence problems were also noted.
Programmatic weaknesses continued to be observed in maintenance and sur-i veillance.
Positive organizational changes were made in the second half of the period but only limited areas of good performance were evident.
Problems were noted in root cause identification, procedure adequacy, management controls and procedural adherence.
' Before the start of this assessment period, the Operations and Maintenance Departments were combined so that they both reported to the Manager of the
Calvert Cliffs Nuclear Power Plant Department. This organizational change represented an improvement, in that authorities, duties and responsibil-ities became more clearly delineated within the site organization with one manager to set priorities and make decisions regarding maintenance and , operations. Communications between operations and maintenance personnel generally improved with this new organization.
In June, 1989, the licen-see further strengthened management of the maintenance ft'nction by estab-lishing the Nuclear Maintenance Superintendent position and filling it with an experienced person from another utility.
There were a significant number of maintenance difficulties which reflec-ted adversely on the effectiveness of licensee performance. These included a series of continuing equipment problems with. auxiliary feedwater-(AFW) system components including pump overspeed trip problems, governor linkage deficiencies, steam header isolation valves stroke time difficulties, and steam header check valve failures.
These represent licensee failures to aggressively pursue, identify, and resolve the root causes of identified problems.
Also, the licensee failed to recognize that the steam header isolation check valve failure placed the plant outside its design basis.
Similarly. -the licensee placed insufficient priority and emphasis on resolving long-standing problems with an emergency diesel generator (EDG) cooling water supply valve resulting in an adverse impact on EDG lorg term ,
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. reliability. and exce:sive, repeated outage times.
There was a failure of a feed regulating valve positioner due to inadequate preventive mainten-ance in that a gasket became brittle and degraded.
The licensee had' no gasket replacement program.despite a similar event which caused a plant trip in 1988. High fluorides in a steam generator were due to slag entry into the secondary side during inadequate controls of modifications to feedwater components.
A solenoid was taken out of service and not t restored following maintenance, thereby disabling halon cylinders provid- - ing partial fire protection for switchgear rooms.
No procedures existed f or disabling and restoring ' the halon system. Collectively, the repeated occurrence of such problems due to poor overall control of maintenance i activities adversely impacted safety system reliabi.lity.
Significant weaknesses were also identified in maintenance support activ-ities. Additionally, work instructions used for performing the majority of site maintenanc) activities did not contain adequate details to ensure that the activities were being performed correctly, or to provide meaning-ful acceptance criteria and QC inspector hold points.
Craf tsmen were required to rely on their judgement in performing most maintenance steps.
As a result of procedural deficiencies, it was-difficult to confirm that maintenance activities were performed correctly or documented accurately.
Some instances of good maintenance performance were noted during the period.
For example, good safety perspective was exhibited in resolving a connection problem between an electrical bus and a battery charger. The licensee conservatively took a main feed pump out of service and reduced reactor power for an extended period while troubleshooting existing con-trol problems.
Contractor maintenance personnel were knowledgeable of site procedures, including those for nonconformance reports (NCRs); good licansee control of such contractors was evident.
Alert, competent main-g tenance personnel identified an equipment qualification (EQ) deficiency at Unit 1 during - training on the same component _ for Unit 2.
During December 1988 January 1989, a licensee team conducted. a thorough, - effective maintenance team evaluation. However, there were only limited indications of incorporation of findings to improve maintenance perform-ance. The installation of the diverse scram system to provide anticipated transient without scram (ATWS) protection to meet 10 CFR 50.62 require-L ments and licensee commitments was observed to have a good integrated pro-gram for design, procurement, installation, and post-modification testing.
Late in the period, the level of performance in the maintenance area was judged to have been improved. The revised procedure for overall control of maintenance was evaluated as good.
Some implementation and coordina-tion difficulties existed with the new maintenance controls, but they l related primarily to work efficiency rather than current safety issues.
" The licensee recognized the need to improve the efficiency of its programs in order to support long term successful operations.
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The number and potential significance of missed and incorrectly performed surveillances were indicative of a broad programmatic weakness in the sur-veillance test program controls. Three reactor startups were performed without the required manual reactor trip channel functional tests.
This i omission was. caused by ineffective ' documentation control.
The surveil- ' lance requirement for the containment exhaust purge valves was not satis-fied for approximately a two year period due to inadequate procedural guidance.
There were three examples of. failures to conduct local leak rate testing within the required interval due to the inability to ade-quately control planning and scheduling.
Some surveillance test proced- . ures (SlP) were inadequate as written. For example, one failed to lead to the detection of a closed fire damper in the penetration ventilation .I exhaust system. Unclear requirements, inadequate technician training, and t poor documentation led to several other missed surveillances.
l At the beginning of the assessment period, the surveillance test program ! responsibilities were fragmented and diffused throughout the site organ-
ization. 'The lack of clearly defined authority contributed to the weak-nesses regarding surveillance program control and implementation. Licen-
see personnel performed many routine or repetitive surveillance test l activities without adhering to procedural requirements.
This sometimes ( resulted in unnecessary challenges to safety systems, including an emerg-ency core cooling system (ECCS) automatic start with injection.
.; Later in the assessment period, controls and accountability for surveil-lance test scheduling were improved.
The surveillance test program was mostly consolidated within engineering under a site surveillance test pro-
gr:m manager.
However, a potential problem still existed in that some ' surveillance type activities were not included in this consolidation.
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, review of the correlation between surveillance procedures and technical specifications (TS) requirements was being performed late in the period.
I In summary, the problems identified last period with respect to insuffic-I ient control and supervision of maintenance and a decentralized surveil- { lance organization were addressed by the licensee.
Although there was
evidence of good maintenance performance in some activities, there were j also many examples of poor performance which impacted safety system reli-ability. Significant programmatic weaknesses were noted in both the main-tenance and surveillance programs. There was some evidence of improvement- ! late in the period in maintenance performance and surveillance program ! controls.
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Performance Rating Rating: Category 3 Trend: Improving I $ a
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Recommendations
Licensee: None NRC: None D.
Emergency Preparedness 1.
Analysis During the previous assessment period, licensee performance in this area. l was rated as Category 2, based upon incomplete implementation of the i Emergency Plan during an event involving loss of annunciators and subse-
quent declaration of an Alert and weaknesses identified in the performance of emergency response personnel during the annual emergency exercise, i During this assessment period, two inspections of emergency preparedness I (EP) activities were conducted. The first inspection covered routine pro-grammatic areas, follow up of licensee response to previously identified items, and changes to emergency plans and implementing procedures.
The ! second inspection was the observation of the full participation emergency.
! exercise.
During the September 1989 emergency exercise, degrading plant conditions ' were readily recognized by licensee response personnel.
The licensee's accident assess'aent during the exercise demonstrated sound technical know- ! ledge of the plant. Conservatism was demonstrated by operations and tech-1.
nical support :.taff in upgrading and properly classifyinn emergency condi- ! tions.. In gentral, positive interactions were demonstrated among members ! of the Emergency Response Organization (ERO).
Further, the licensee' con-i ducted a satisf actory post-exercise self-critique which identified both procedural and performance related deficiencies and committed to take ! appropriate corrective actions, j During the exercise, the emergency on-site facility (E0F) experienced a temporary loss of both primary and backup (diesel) power during activa-
tion, thereby hindering initial response actions to escalating emergency conditions. In addition, the NRC identified a performance weakness in the area of timeliness of notifications to state and local authorities.
Nevertheless, overall exercise performance was considered adequate.
The licensee has been responsive to analyzing and correcting NRC and internally identified weaknesses.
Response to findings identified in the
routine inspection and emergency exercise was -timely.
Responses were-l viable and generally sound.
For example, to address exercise performance ' -deficiencies, comt.iitments were made to immediately provide additional emergency training.
For the 1990 annual exercise, plans are being made to use the. training simulator for emergency response training and exer-cises to further improve performance.
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Administrative and emergency response procedures are well stated and understandable.
Licensee audits conducted to meet the requirements of 10 CFR 50.54(t) were appropriate in scope and corrective actions on find-ings and recommendations identified during audits and sel f-assessments were generally prompt.
However, the NRC identified minor audit findings which had not been properly classified. These findings dealt with issues in dispute between the EP and-QA organizations.
The Manager, Quality ' Assurance and Staff Services (QASS), has direct management responsibility over both the quality assurance and emergency preparedness sta'fs. The-NRC staff concluded that this organizational arrangement had the potential to adversely affect resolution of these types of disputes.
The licensee took immediate action to designate the Vice President, Nuclear Energy as responsible for resolving disputed findings between Quality Assurance and Emergency Preparedness.
The licensee maintains a large emergency preparedness staff. This staff effectively implements critical program areas such as maintaining the Emergency - Plan, implementing procedures, emergency response facilities, designated emergency supplies and equipment, and coordination with offsite support groups.
Despite a reorganization of the emergency preparedness-staff, the corporate management staff was effectively involved in program-matic activities. The training staff supplements the EP staff for normal emergency preparedness training activities, scenario development and con- ' duct of drills and exercises. One staf f member is dedicated to of fsite interfaces and the licensee maintains a very good relationship with state - ; and local officials.
' Assessment of the licensee's training and qualification program indicated that the ERO is well staffed, with three individuals qualified for all key positions. ERO training of site personnel and offsite support groups was maintained up to date and records were readily available through database files. It was noted that the licensee attempted to change the timing of emergency preparedness training from 'the spring to the fall to have it coincide with General Orientation Training. As a result some of the ERO
' members were beyond the qualification period during the inspection.
If this had not been identified by the NRC, most of the ERO _ staff training would have been allowed to expire. During NRC training walk-throughs with selected ERO members, inconsistencies in performance directly related to training were identified.
The licensee, in response to these findings, committed to promptly retrain the ERO to ensure all training was current.
One notice of violation (NOV) was issued during the period due to lack of an Emergency Response Plan Implementing Procedure (ERPIP) for use by shift staff to perform radiological dose assessment following a steam generator tube rupture event. As a consequence, available shif t personnel assigned-dose assessment functions, specifically the interim Radiological Assess-ment Director (IRAD), was unable to calculate estimates of offsite exposures during walk-through scenarios.
The licensee proposed timely corrective actions in response to the NOV.
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In summary, the licensee maintains an adequate emergency response capa-bility.
Exercise performance demonstrated the licensee's ability to , implement the Emergency Plan. However, the NRC determined that the licen-s e r. ' s control room staff did not have the capability to perform dose assessment for an event involving a steam generator tube rupture.. Train-ing and performance weaknesses in emergency response were identified dur-
ing both the routine inspection and annual exercise. Corporate management ~ involvement is evident to support onsite and offsite program activities.
Resolution of self-identified and NRC-identified technical issues was generally sound and timely.
Considerable effort was provided to ensure a a gooi working relationship with state and county authorities. Overall, the lic ansee maintains an emergency response organization capable of providing adequate protective measures in the event of an emergency.
2.
Performance Rating Rating
Trend: None 3.
Recommendation Licensee: None NRC: Nor,e E.
Security 1.
Analysis During the previous assessment period, the licensee's performance was rated as Category 1.
That rating was based on several program improve-ments made during the period, an excellent enforcement history, and the continued implementation of an ef fective, performance-based security pro-gram that clearly indicated a thorough understanding of the NRC's security objectives.
During this assessment period there was one routine unannounced security inspection by ' region-based inspectors, and routine inspections by the resident inspector continued throughout the period.
The on-site nuclear security group reports to the corporate security organization, which is under the Vice President, General Services.
Nuclear security expertise is apparent in both of these organizations.
The NRC attributes the continued effectiveness of this program to the knowledge, experience and professionalism of site security management per - sonnel who implement the program and to the corporate involvement in a.. financial support for the program.
Licensee management cortinued to
actively support coordination with local law and emergency services orgarizations.
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' . Staffing of the proprietary security force was consistent with program - , needs as evidenced by the limited use of overtime during the period.
' Effective-- supervisory oversight resulted in few personnel errors, none of which rose -to the significance of a reportable event, and there were no j violations of NRC requirements.
As further evidence of the licensee's j attention to the program the proprietary force was supplemented by con-tract watchpersons, during the plant outages,- to preclude stress and fatigue on the proprietary force.
Programs of promoting from within both the company and the security organization have been effective in main-taining a high level.of experier.ce and good morale throughout the security organization, and a high level of performance.
The site security supervisor and his staff are well trained and qualified security professionals who have been vested with the necessary authority and discretion to ensure that the security program was carried out effec-l tively.
Both site and corporate security management continued to be attent1ve to and aggressively involved in the security program. This was i demonstrated by the licensee's timely planning for correcting any problems i identified in the security-program.
i ! The licensee also continued to demonstrate responsiveness to NRC concerns.
' This was evidenced when several potential weaknesses were ' identified by j the NRC during the assessment period. These weaknesses primarily involved j system and equipment aging which was indicated by increases in down -time,-
compensatory measures and maintenance support.
As a result, the licensee j developed' appropriate plans and a timely schedule for upgrading and/or > replacing many of the protected area systems and equipment. These efforts . represented a proactive management approach in that the licensee con-i tinually-seeks to improve the effectiveness-of the program.
l l The security force training and requalification program was well-developed j and administered by an experienced staff.
Facilities were provided on- ' site for training and requalifications, and were well-equipped and very i well-maintained. In addition, weekly contingency drills were effectively l used for training purposes by conducting comprehensive critiques that were ' fed back into the formal training and requalification program..The plant-
operations organization participated in these ' drills when appropriate, j The licensee also continued to budget resources for special, off-site
training courses for members of the security organization.
Such efforts I to provide effective training for the security force are indicative of a
licensra that is intent on implementing a high quality security program.
j i The licensee's event reporting procedures were found to be clear and con- , sistent with the NRC's reporting requirements. No adverse security trends were indicated during this period.
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l - During the assessment period, the licensee submitted five revisions to the i security program plans under the provisions of 10 CFR 50.54(p).
In I general, these revisions were of high quality and technically sound, and l reflected well-developed policies and procedures.
However, some of the revisions contained multiple administrative errors that necessitated NRC inquiries to resolve.
This was indicative of inattention to detail in preparing plan revisions. When this was brought to the licensee's atten-tion, corrective actions were promptly initiated.
The effectiveness of - these corrective actions has not yet been assessed by the NRC.
In summary, the licensee continued to maintain a very effective. and performance-based security program that exceeds regulatory requirements.
Significant enhancements were made to the program which demonstrated both corporate and site management attention to and interest in the program.
. The licensee's initiative in identifying and correcting potential weak- ' nesses in systems and equipment during this period are commendable and demonstrated the licensee's commitment to maintain an effective and high quality program.
Additionally, management's responsiveness to NRC-l identified concerns demonstrated a positive commitment to an aggressive and effective program.
i ! 2.
Performance Rating ! ! Rating: . Category 1 j l Trend: None l I 3.
. Recommendations j > Licensee: None i NE: None ! F.
Engineering / Technical Support k-1.
Analysis , This functional area was rated Category 2 in the previous SALP. The pre-vious SALP identified numerous weaknesses in the area of engineering and technical support.
Areas of concern included: (1) systems engineering staffing and qualifications (2) communication between engineering and i operations, (3) modification packages not prepared sufficiently in arivance > of outages by engineering, (4) lack of necessary tools for scheduling and tracking. work, (5) slow progress in resolving trip reduction task force ' recommendations, (6) a long and growing list of outstanding items requir-ing review by the Plant Operations Safety Review Committee (POSRC), (7) lack of clear step by step instructions for the facility change pro-cess, and (8) inconsistent evaluation of corrective actions taken under the Facility Change Request (FCR) process for reportability to the NRC.
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. During the present SALP period,. licensee management -and the engineering department have taken steps to address problems identified in the previous SALP and to resolve issues identified during the current SALP assessment period. While progress in these areas is not complete, inspections have found that the ',1censee is making progress in resolving these issues and improving engineering performance.
Problem areas identified during the current assessment period that in-volved engineering included: (1) low temperature overpressure protection
(LTOP) of the primary system, (2) resolution of long term problems with
the service water supply valves for cooling the emergency diesel genera-tors (EDG), (3) repetitive failures of the auxiliary feed water (AFW) , system, (4) poor communication between the engineering and chemistry department in regard to analysis of EDG fuel oil, (5) the instrument air system outside the design basis due to operability concerns, and (6) justification to start up and run Unit 2 with an unisolatable leak in the steam generator 2-inch diameter secondary side blowdown line.
In the last instance, poor technical and engineering support was provided to the operations staff resulting in the decision to start up and operate Unit 2 with an identified through wall leak in a steam generator two inch secondary side blowdown line.
The decision to restart and justification to continue operation for approximately four days af ter the leak rate increased more rapidly than projected is indicative of a poor safety perspective.
The licensee's actions to address problems identified =in the last SALP and their performance relative to issues identified during the current assess-ment oeriod are discussed below.
' Staffing in engineering has increased by 45 persons during this SALP - period with a similar increase planned for 1990.
The number of authorized engineering positions-has been increased yearly as has the number of engineers on staff.
Engineering contractors are used to supplement the engineering staff. Communication between engineering and the plant including operations has been improved by effective daily morning meetings that include management representatives from each department and are usually attended by engineering group super-visors and principal engineers. An increased presence of engineering personnel in the plant also was noted during this. assessment period.
For the planned Unit 2 outage in March 1989, modification packages were generally available to support planned outage work.
However, due to the length of the Unit 2 outage, the effectiveness of changes in engineering organization and staffing in supporting routine outage work was not assessed.
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, Efforts by engineering to provide for adequate review of-facility ~
- change requests and NCRs to identify reportable issues were initi-ated.
For example, procedures regarding NCRs and FCRs were revised , extensively, i The list' of significant outstanding issues which includes LTOP, EDG service water (SW) supply and AFW failures is indicative of.the need for engineering to establish schedules for those. tasks-that are pre-sently incomplete and provide for timely resolution. This includes identification and prioritization of those problems that were iden-tified during the plant operating history but not resolved (such as LTOP).
In addition to the above actions taken in response to identified weak-nesses, the licensee took the following initiatives to improve performance in this area.
The licensee designated a dedicated fire protection engineer and allocated supporting resources. The efforts resulted in the self-identification of several fire protection deficiencies and their resolution.
Licensee efforts in upgrading the environmental qualification (EQ) program were evident in the revisions made to EQ files and the restructuring of the EQ organization. New personnel assigned-to the EQ organization appear knowledgeable and dedicated to the FQ effort.
Communication of EQ main-tenance instructions is enhanced by revisions whien designate an EQ design engineer to review and assure that requirements from the EQ files and related to the specific application are included in the work package.
The licensee took.the initiative to perform an audit of the EQ program in November 1999. This audit found that the EQ program.was generally ade-quate and had improved.
However, some communication weaknesses still exist among design, systems and maintenance organizations.
The licensee's Safety System Functional Inspection (SSFI) of the low pressure safety injection (LPSI) system we s of high quality and the licen-see's program to perform a SSFI annually is a noteworthy initiative.
The audit. found the LPSI system to be functional, but ideneified a number of weaknesses that could degrade system performance.
These weaknesses were effectively corrected, but no plan to review the findings for potential
applicability to other systems was in place.
- The systems engineering group is now located inside the protected area to provide better opportunities to interface with the operations and mainten-ance departments and to be more accessible to the plant staff.
The up-dated system engineer assignments and the expanded system engineer job
description issued in mid-1989 provided a formal listing of the respon-sible system engineer for each system and a statement of the work respon-sibilities for system engineers.
The training program, which included-engineering theory, system history and practical f actors, was long in development but once implemented represented a notable strength which , should produce highly skilled and knowledgeable system engineers.
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The licensee's Performance-Improvement Program (PIP) encouraged the iden-tification of problems so that they could be resolved and appropriate cor-rective actions taken. Also, the PIP encouraged plant employees, includ-ing engineering, to apply a questioning attitude toward plant components, systems, procedures and methods of operation. This portion of the PIP was successful in that a significant number of problems were identified.
These were documented by the non-conformance report (NCR) process and.
resulted in a large number of NCRs being issued during 1989. ' NCRs. that restrain plant mode change were tracked separately from other NCRs. While there is noteworthy progress, the NRC has not yet evaluated the licensee's capability to fully resolve the identified issues.
During this assessment period, the NRC reviewed selected engineering mod-ifications such as replacement of the reactor coolant pump seals, replace-ment of safety related-instrumentation per Regulatory Guide 1.97, replace-ment of service water flow control valves for the diesel generators, and other minor modifications.
The modification-packages were found to be well organized, complete and !n accordance with procedures.
Applicable design inputs were correctly incorporated into _ the changes. The safety
evaluations for the subject modifications were found to be thorough and to I adequately address 10 CFR 50.59 considerations, In summary, licensee management has been responsive to the identified need to correct existing problems and improve engineering performance. Manage-ment has provided support to engineering in' the form of staffing, train-ing, meetings and procedure revisions to improve the capability of engi-neering to support plant operations and maintenance, Engineering has taken initiatives toward correcting previously identified problems. How-ever, the overali effectiveness of these changes has-not been assessed.
Some interdepartmental communications weaknesses still exist.
. 2.
performance Rating ' Rating: Category 2 Trend: None ' 3.
Recommendations Licensee: None ' NRC: Review the licensee program to correct the cracking within the Unit 2 pressurizer prior to the restart of Unit. ,, .
22 . G.
Safety Assessment / Quality Verification 1.
Analysis J This functional area assesses the effectiveness of the licensee's programs and management processes in assuring tne safety and quality of plant oper-ations and activities.
Although substantive improvements were noted in the effectiveness of the licensee's Quality Assurance (QA) audit function during the previous SALP period, overall performance was evaluated as Category 3 in this functional area. It was noted that, while improvements had been realized during the SALP period, there continued to be instances of: 1) poor coordination and prioritization of tasks, 2) inadequate interdepartmental communications and interfaces; 3) weaknesses in the identification and correction of personnel and equipment deficiencies.
During the initial portion of the assessment period, undue focus appeared to be placed on power production which contributed to a number of perform- , ance deficiencies in the operations and maintenance areas as previously { discussed in this report. Weaknesses in the implementation of the plant safety review committee (POSRC) process and questions with regard to the independence of the QA organization within this process resulted in j excessive reliance being placed on the skill and experience of operating and maintenance staffs to assure safe plant operation.
Throughout the assessment period examples of lack of attention to detail; procedural inadequacies; failure to follow procedures; communications problems between organizational units; slow identification and resolution of safety issues; and weaknesses in managing and resolving corrective actions have been identified.
{
Inadequate communications between the operations, engineering and licen-sing portions of the organization resulted in some of the more significant safety concerns as evidenced by: 1) failure to maintain adequate low temperature overpressure protection (LTOP); 2) failure to perform required local leak rate tests on a containment penetration; and, 3) operation with an unisolable leak in a steam generator secondary side blowdown line.
During the latter part of the assessment period, senior management empha-sized safety over production, Safe'y and quality were emphasized as the primary goal of the organization and corrective action programs were initiated in an attempt to ensure that appropriate program guidelines and administrative controls are generated which establish continuing support for this philosophy.
Results of both the short term and the long term
corrective action programs and pioni demonstrated the effectiveness of this emphasis.
Positive initiatives were taken by the licensee during the assessment period, including a self assessment of performance and an independent assessment of restart readiness.
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Several licensing actions were reviewed by NRC during the assessment period, including amendment requests; exemption and relief requests; responses to generic letters, bulletins and information notices: TMI issues; multi plant issues; and other regulatory initiatives. While most submittals were generally acceptable and supported resolution of the requested action, there were several instances where the licensee did not , demonstrate a thorough understanding of the issues from a regulatory per-spective.
This lack of understanding resulted in submittals that were neither timely, comprehensive, nor technically sound. This inconsistency indicated lack ei effective management involvement in assuring quality of licensing actisities.
Examples of licensing actions requiring additional information, changes in the initial request, an extension of time, or clarification included: 1) the proposed technical specifications relating to the heating, vet.tila-tion and air ennditioning systems lacked sufficient detail to allow a significant hazards determinatiun to be made; 2) the proposed technical specifications to support an increase in the auxiliary feedwater actuation time delay did not provide adequate supporting analysis and required an extension for responding to the staff's request for the additional infor-mation; and 3) the one-time request for extending the snubber surveillance requirement for Unit 2 provided information in support of the request which was later determined to be incorrect.
Weaknesses in the licensee's 10 CFR 50.59 tafety evaluation process were still evident.
Changes to procedures have been implemented without an appropriate safety assessment as required by 10 CFP 50.59.
For example, a change to an operating ins'-uction for the salt water system was made without a safety assessment or plant operations safety review committee (POSRC) approval.
In addition, the NRC identified several concerns with the licensee's temporary modification program which resulted in inappro-priate or no safety assessments being performed.
Thi licensee has mod- ! ified the procedures which control plant changes. Additional training has also been performed to improve program control and to increase plant pe-rsonnel awareness of the 10 CFR 50.5! safety assessment processes.
The effectiveness of these changes had not been evaluated at the end of the period, t In general, the onsite and offsite safety review committees, POSRC and OSSRC, respectively, exhibited a good safety ethic. Meetings of both com-mittees were observed and items were freely discussed and probing ques-tions were generally asked. Some weaknesses in the structure and rela-tionship to line manager.ent in the POSRC existed during the assessment period.
The deficinicies included an excessive use of alternates to t assure a quorum.
Also, the use of the General Superintendent-QA as an-alternate POSRC chairman provided an inappropriate relationship between QA i
and plant line management. This POSRC relationship potentially impacted , ' the independence of the QA function within the organization.
These i deficiencies have been corrected, <
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The Licensee's Significant Incident Finding Team (SIFT) followup investi-gation of operational events was detailed and thorough as demonstrated following the fire in the auxiliary feedwater pump trip circuitry and the high reactor coolant system sulfate concentration event. SIFT investiga-tions were introspective and self-critical of licensee performance. How-ever, the licensee's overall corrective action process continued to demon-strate weaknesses in tracking and resolution of routine corrective actions. A multiplicity of systems, a large backlog, and inconsistencies in the methods used for prioritizing, tracking, and management review of the status of corrective actions existed.
Additionally, late in the period, a significant programmatic weakness in the licensee's ability to track and meet commitments was identified. An example of this failure to , comply with commitments resulted in both units operating for an extended period of time potentially without adequate low temperature overpressure protection.
QA audits and evaluations were generally thorough and effective in identi-fying areas or items requiring corrective action. However, programmmatic weaknesses in many cases resulted in the lack of timely or adequate reso-lution of necessary corrective action. _ The root causes and safety signif-icance of identified deficiencies also lacked timely and thorough deter-minations.
For example, closure of a Nonconformance Report (NCR) for a containment spray pump bearing failure attributed the causes to the low oil level without. identifying the root causes of the low oil level or determining appropriate corrective actions.
Further, no formal review process was in place to determine if an NCR was required as the result of QA findings and there were weaknesses in the screening process used to determine if an NCR was needed for operational events or identified problems.
The NRC also identified several deficiencies in the QC program. The lack of approved written instructions for controlling, implementing, and docu-menting QC inspections was identified as the primary cause of the QC pro-gram deficiencies. This, coupled with the weakaesses in the experience and expertise of QC inspectors, impaired the effectiveness of the QC func-tion.
In response to this deficiency, the licensee has restructured the QC unit to improve oversight, increase technical support, and improve the l technical skills of the QC staff. The QC procedures are being upgraded i and the upgrade will continue as part of the licensee's Procedures Upgrade Program. These changes were completed late in the period but their effec-tiveness has not been assessed.
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In summary, although some improvements were noted, problems continue to be ..' identified in the areas of procedural quality and compliance, management
involvement in assuring the quality of licensing activities, and continu-ing. weaknesses in the corrective action and commitment management pro-cesses. Licensee management was ineffective in consistently incorporating safety and quality in the overall plant operation and activities during the initial portion of.this assessment period due to a philosophy which inappropriately emphasized power production.
Management clearly empha-sized safety and quality as the licensee's primary goal during the latter part of the assessment period, 2.
Performance Rating: R,jLt_i_ng : Category 3 Trend: None 3.
Recommendations: Licensee: Re-evaluate the Performance Improvement Program to ensure that organizational and communications weaknesses are pro-perly addressed.
N3: Conduct an integrated Performance Assessment Team inspec-tion about three months prior to the end of the current SALP assessment period.
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$UpPORTING DATA AND SUMMARIES A.1 Licensee Activities Unit 1 Unit I began the SALP period at 100*; power.
The unit experienced two brief forced outages due to different secondary system leaks.
A third forced outage was caused by the need to replac" a reactor coolant pump (RCP) seal and attempts to recover from this four week outage were inten-tionally delayed for an additional three weeks to deal with high reactor coolant system (RCS) sulfate.
The unit was shut down on May 6,1989, to investigate possible RCS pressurizer heater sleeve leakage (see Unit 2).
No leakage was identified but the unit remained shut down to address cer-tain management and safety issues. The unit operated at power for approx-imately three and one half months of the thirteen month SALP period.
Unit 2 Unit 2 began the SALP period at 100% power.
The unit experienced two brief forced outages due to main feedwater regulating valve problems. The unit shut down on March 17, 1989, due to an unisolable steam leak and began the Cycle 8 refueling outage. On May 5, 1989, indications of numer-ous RCS leaks were found on Unit 2 pressurizer.
The unit remained shut down for the rest of the SALP period for repairs to the pressurizer. The unit operated at power for approximately three and one half months of the thirteen month SALP period.
A.2 Direct Inspection and Review Activities During the assessment pe. iod, NRC inspection coverage was provided by a combination of visiting, temporary and permanently assigned inspectors.
Five major NRC team inspections were conducted during the period.
From February 27 through March 31, 1989, a Special Team Inspection was con-ducted to determine the causes of a general decline in licensee perform-ance.
The adequacy of emergency operating procedures was reviewed in a team inspection on May 15-26, 1989.
An r.ua ' site emergency drills were witnessed by inspection teams on December 6,1988 and September 14, 1989.
The fif th NRC team inspection was conducted on November 7-20,1989, to assess licensee readiness to restart Unit lg_. ( > <.. . . [:l ..c
[. Four' Special. Inspections were conducted during the period.
Failure to ,. [ maintain containment integrity and review temporary modifications. was inspected on April 17-27, 1989. Weaknesses in administrative control were the suWects of an inspection. on May 22-26 and June 9-16, 1989.
Post-accident monitoring measures were reviewed on August 7-11,1989.. The fourth Special Inspection was on deficiencies in licensee actions to assure, adequate low - temperature overpressure protection (LTOP). for the . reactor vessel.
.There were a total of 7284 inspection hours during the period or 6724.on an annual basis.
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Criteria ! Licensee performance is assessed in selected functional areas, depending
on whether the facility is in a construction or operational phase. Func- , tional areas normally represent areas significant to nuclear safety and - the environment.
Some functional areas may not be assessed because of
little or no licensee activity or lack of meaningful observations in that ! area.
Special areas may be added to highlight significant observations.
i; The following evaluation criteria were used, as applicable, to assess each' [ functional area:
1.
Assurance of quality, including management involvement and control; 2.
Approach to the resolution of technical issues from a safety standpoint; 3.
Responsiveness to NRC initiatives; 4.
Enforcement history; 5.
Reporting and analysis of-reportable events; 6.
Staffing (including management); 7.
Training and qualification effectiveness.
E% sed upon the SALP Board assessment, each functional area evaluated is > classified into one of three performance categories. The definitions of > r , these performance categories are as follows: > Category 1: Licensee management attention and involvement are readily evident and place emphasis on superior performance of nuclear safety or ' , r: safeguards activities, with the resulting performance substantially exceeding regulatory requirements.
Licensee resources are ample and effectively used so that a high level of plant and personnel performance is being achieved.
Reduced NRC attention may be appropriate.
Category 2: Licensee management attention to and involvement in the per-formance of nuclear safety or safeguards activities is good. The licensee has attained a level of performance above that needed to meet regulatory requirements.
Licensee resources are adequate and reasonably allocated so that good plant and personnel performance is being achieved, NRC atten-tion may be maintained at normal levels, s
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Category 3: Licensee management attention to and involvement in the per-formance of nuclear safety or safeguards activities are not sufficient.
The licensee's performance does not significantly exceed that needed to meet minimal regulatory requirements.
Licensee resources appear to be strained or not effectively used. NRC attention should be increased above normal levels.
The SALP report may include an appraisal of the performance trend in a functional area for use as a predictive indicator.
Licensee performance during the assessment period should be examined to determine whether a trend exists.
Normally, this performance trend should only be used if both a definite trend is discernable and continuation of the trend may result in a change in performance rating.
The trend, if used, is defined as: Improving: Licensee performance was determined to be improving during the i assessment period.
Declining: Licensee performance was determined to be declining during the assessment period and the licensee had not taken meaningful steps to address this pattern.
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Enforcement Summary No. of Violations in Each Severity Level n Functional Area DEV V IV III II.
I Total
! Plant Operations * .2
'l
' Radiological Controls
5 l i-Maintenance / Surveillance *
9
11 l f 'I E Emergency Preparedness
1
, ! Security 'i ! Engineering / Technical Support
1 i kafety Assessment /
Quality Verification **
1
1 , Total
1
2
3' - . ! . One inspection report (50-317/89-15; ' 50-318/89-16) categorized violations
in.>these areas - as a Level III violation.in the aggregate in the
Maintenance / Surveillance Functional Area.
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One inspection _ report (50-317/89-31; 50-318/89-32) contained violations still under review in this functional area. at the end of the pe-iod.
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Licensee Event Report (LER) Causal Analysis i Function Area A B C D E X Total Operations-
4
, Maintenance / Surveillance
1 6'
13 Engineering / Technical Support
10
1
' Totals
11
4 38.
Unit 1 LERs 88-13 through 89 25; Unit 2 LERs 89-01 through 89-11.
, Cause Codes * i
Type of Events ! A-Personnel Error
B.
Design / Man /Constr./ Install
. C.
External Cause
D.
Defective Procedure
^ E.
Component. Failure
X.
Other
' Total
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Root causes assessed by the SALP Board may differ from those listed in the LER.
Four events were caused by unrelated component. failures.
The eleven
reports attributed to design related aspects had no apparent common cause.
Several of the deficiencies were identified during Equipment Qualification-review activities and maintenance.
Inadequate attention to detail was a -, major contributor to seven LERs (Unit 1: 89-01, 03, 04 and 12; Unit 2: i 89-01, 05 and 08). The number of reports concerning defective procedures i was much greater than during previous periods.
During the previcus i period, two instances of defective procedures were noted and the period ! before that contained four.
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l '- e . ENCLOSURE 3 UMTED STATES .[ NUCLEAR REQULATORY COMMIS$60N , I & ReOION i 476 ALLeNDALE ACAD
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KING OF PAUSSIA. PENNSYLVANtA 16aot {' l APR 0 41990.
I Occket Nos.: 50-317 50-318 Baltimore Gas and Electric Company ATTN: Mr. George C. Creel Vice President - Nuclear Energy Calvert Cliffs Nuclear Power Plant.
Md. Rts. 2 & 4 Post Office Box 1535 - Lusby, Maryland 20657 Gentlemen: i . Subject: Systematic Assessment of Licensee Performance ($ ALP) Report Nos. 50-317/88-99 and 50-318!88-99 The NRC SALP Board has assessed the performance activities of the Calvert
Cliffs Nuclear Power Plant, Unit I and Unit 2, for the period December 1,1988, through December 31, 1989.
The results are documented in the enclosed SALP Board Report.
A meeting to discuss this assessment will be scheduled by separate correspondence.
At the SALP meeting you should be prepared to discuss our assessments and your plans to. improve performance.
In particular, we are interested in your plans , for improvement in the areas of operations, maintenance and surveillance, and safety assessment and quality verification.
This meeting is intended to be a candid dialogue wherein any comments you may have regarding our report may be discussed.
Additionally, you may provide written comments for our considera-tion in draf ting the final SALP report during the 20 day period af ter the meeting.
This report has been placed in the Public Document Room. Following our meeting and receipt of your response, the final SALP Report and your response will be placed in the Public Document Room.
Your cooperation is appreciated.
Sincerely, [ Thomas T. Martin Regional Administrator Enclosure: SALP Board Report Nos. 50-317/88-99 and 50-318/88-99 l
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/$f9904ggsg7 Baltimore Gas and Electric Company
, , ' cc w/ enc 1: ' W. Lippold, General Supervisor, Technical Services Engineering T. Magette, Administrator, Nuclear Evaluations
J. Lemons, Manager, Nuclear Outage Management R. Denton, Manager, Calvert Clif fs Nuclear Power Plant r ' ' J. Walter, Engineering Division, Public Service Commission of Maryland K. Burger, Esquire, Maryland People's Counsel - P. Birnie, Maryland Safe Energy Coalition Public Document Room (PDR) ' Local Public Document Room (LPOR) Nuclear Safety Information Center (N$1C) NRC Resident Inspector State of Maryland (2) , Chairman Carr ' Commissioner Roberts . Commissioner Rogers Commissioner Curti;s
Commissioner Remick K. Abraham, PA0 (24) - , i
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-'- - - - - - -, _,,, ,,,,, , _ ,,,.... - < , ENCLOSURE 4 bat.TIMO RE OAS AND Et.ECTRIC CH ARLES CENTER. P. 0. 60X 147s. BALTlWOR t. M ARYLAND 21203 c,,, ' April -19,1990 " " vi s pe bc6saa ter 400a + 446s U. S. Nuclear Regulatory Commisalon Region 1 475 Allendale Road King of Prussle, PA 19406 ATTENTION: Mr. Thomas T. Martin Regional Administrator SUBJECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50 317 & $0 318 1 ALP Reoort initial Resnonse Gentlemen: We have reviewed your Systematic Assessment of Licensee Performance (SALP) Report of April 4, 1990, it has provided substantial feedback for our consideration in the operation of Calvert Cilffs Nuclear Power Plant. We look forward to a full discussion at our scheduled public meeting on April 23, 1990. This letter is intended to further the usefulness of that discussion by providing our initial assessment of-the points and their relationship to the current status of the plant. A . identified in your report formal response to the SALP will be provided after the - April 23 meeting.
As your report makes clear, 1989 was a year of major change at Calvert Cliffs.
Conditions today are far different from those reflected in the grades for the performance for the full year of this SALP report. The rate of change at Calvert Cliffs confronts any evaluator with the difficulty of measuring a rnoving target.
Nonetheless, there are some key points from the SALP report which are important for us to acknowledge.
First, it is clear that there were many changes nee <!cd at the start of 1989. Your assessment closely paralleled one which we did in August 1989. Both identified significant symptoms which welghed heavily in the low grades in Operations, in and Surveillance, and in Safety Assessment / Quality Verification, The T Maintenance ratings in each of 'hese areas indicate how far we have had to come and still have to 30.
Second, we are pleased to note the recognition provided in the report of the substantial improvements which have been made. The many statements acknowledging effective corrective measures taken during the latter half of the year provide a balance in the report's perspective. These improvements were the result of a concerted management effort to address not just the problem symptoms, but the root causes which broad array of action plans was developed to analyze the led to their existence. A the defined actions, and measure problems, devise a strategy for correction, implement - - - ____ _ ___ __ "-------.m - _., _, _ _ _, _ _ _ _ _ _ _ _ _ _ _
. . ~,. , , Mr. mmas T. Mkrtin o April 19,1990 Pese 2 the results. To assist us in controlling this effort and to communicate its content both inside and outside the company, these action plans were consolidated into the Performance Improvement Plan (PIP). It has been management's challenge to prove that the PIP is a well-designed and effective tool--not simply a public relations ploy or a shell of empty promises. The PIP describes a dynamic program. We have submitted one revision, and you will be receiving the second at the end of this month. We are continually analyr.ing the effectiveness of our improvement efforts and will modify our plans to ensure that the desired end results are achieved. The SALP provides valuable evidence that PIP is working, and that its results are visible in the plant today.
Examples include: In Maintenance and Surveillance, the report credited advances in organizational - structure, communications between Operations and Maintenance, safety perspective, and controls and accountability for survei!1ance testing. These relate directly to PIP Action Plans for Resource Allocation POSRC, Surveillance Test Program, Visiting Other Plants, and Post-Maintenance Testing.
In Operations, the SALP report identified improvement in adherence to procedures, - Operations' staffing levels, procedure quality, and operator awareness of-plant status.
These stem from PIP Action Plans for Communleations, Resource Allocation, Procedure Upgrade, and Daily and Outage Work Control. All these plans were developed and initiated last spring, and their gesults are now opparent.
Other accomplishments, such as Quality Control improvements, Quality Assurance - Internal Assessment Improvements and establishing the Independent Safety Evaluation Unit, were noted. Each was initiated usias the PIP as a management tool, The improvements did not stop at the end of the SALP period, in 1990, NRC reports have recognized the System Engineer training program as a notable strength, and the february Maintenance Team inspection showed substantial improvement over a similar BG & E evaluation a year ago. Preparations for the current operating period of Unit I show similar evidence of sustained strong performance. These preparations were accomplished with minimal injuries, no damage to plant equipment, and no significant schedule setbacks attributable to planning or personnel errors. These are truly noteworthy achievements of which we are proud.
This is not to say that we have mis-read your report to Indleate that our work is done.
You have clearly stated your continuing concerns regarding procedure quality and compliance, management involvement in licensing activities, and corrective action / commitment management systems. Regarding conective actions we believe the initiatives undertaken have been effective in documenting problems. A natural outcome of this effort is a backlog of items requiring resolution. We recognize that a major effort will be required to address this issue. Additionally, you have noted that careful observation of many instituted changes is still required. These intentions and concerns are consistent with our expectations. The PIP, which will be incorporated in the existing Nuclear Program Plan, includes several major assessments to measure its effectiveness in correcting these concerns. We are confident of and committed to ensuring that these issues are effectively addresse *oc r00 3Ded 7e201 4.
- . .. , , o Mr. Thomas T. Martin April 19,1990 Page 3 Baltimore Gas and Electric Company has devoted substantial senior management attention and resources to improving Calvert Cliffs' performance, We are firmly committed to continuing our efforts to attain higher Standards of safety and quality. We expect that these improvements will be reflected in markedly improved SALP scores in the current evaluation period, and that in the longer term that we will restore Calvert Cliffs to our goal of excellent performance.
Should.you have any furthcr questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours.
C GCC/GLD/JMO/bjd cc: D. A. Brune, Esqulre J. E. Silberg, Esquire R. A.Capra.NRC D. O. Mcdonald, Jr., NRC l . L. E. Nicholson, NRC T. Magette, DNR B. A.Boger,NRC ! ! i i . ? --- - -- -,-. _,
.. ;... i .:. 7 T.: ^^... T.^. ^: ~ ~. T: ". ^^ ^ ^ .. ...... . ,. ) . ENCLOSURE 5 BALTIMORE OAS AND , ELECTRI l CHARLES CENTER P.O.90X1475. BALTIMORE, MARYLAND 21208 Geomot C. Catti Vtti ottaibreet i w n asto... . c..o ...u.. !
May 14,1990 . U. S. Nuclear Regulatory Commission Washington, DC 20$$5 i
ATTENTION: Document Control Desk , SUBJECT: Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 60-317 & 50-318 1 ALP Report Resnonse Gentlemen: We have completed a detailed review of your Systematic Assessment of Licensee Performance (aALP) Report of Apri! 4, 1990. We have carefully considered its findings. and concludri that it accurately describes our performance during 1989. We are pleased that it notes many of the substantial !=;:rovements we have made, especially - those that occurred during the latter half of the SALP period. However, we acknowledge and agree that the Category 3 ratings in the areas of Plant Operations, Maintenance / Surveillance and Safety Assessment / Quality Verification are indicative of the need for sustaineti oversil general improvement.
The SALP is useful for its perspective in categorizing deficiencies and assessing-plant performance for broader trends and root causes. We use the the NRC's assessment for comparison with our internal assessment as a means to enhance management's efforts at performance Improvement. In this year's report, the SALP is very consistent with the internal BG&E evaluations performed during the year. SALP comments concerning performance early in the year have been compared-to the initial root causes we analyzed in developing the Performance improvement Plan (PIP). Both ! the specific symptoms and broader categories match closely with those considered in developing our PIP. The self SALP we conducted at mid. year was also very consistent , with the NRC report in both grouping of deficiencies and functional area grades.
l These facts tend to confirm that the PIP was based on appropriate considerations.
b The description of activities in the latter half of the SALP period also provides i valuable feedback on our ' plant improvement efforts. Many significant improvements are ' specifically cited in the SALP that we can directly tie to efforts captured under PIP. Action Plans. When coupled with our internal verification efforts, these provide substantial evidence that the management actions under PIP are measurably contributing to safer plant operation. In the areas where continuing weakness was L i l
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noted in the report, we are actively assessing our current efforts to See whether we have met our expected progress or whether additional st,ps are appropriate. In some areas, the PIP has already been revised to incorporato these concernt. In other areas, the concern was discussed in the site Spring Planning Conference for coluidera- ' tion in a future PIP revision and inclusion in the corpolate Nuclear Program Plan.
The remainder of the concerns are assigned for resolution by the responsible department.
The specific deficiencies noted in the SALP report had all been previously identified In correspondence between BGAE and the NRC.
Individual corrective actions, including root cause analysis and measures to prevent recurrence, had already been initiated and, in most instances, completed. Therefore, these specifies will not be discussed in this response.
While the PIP is our primary mechanism for focusing management attention and correcting weak areas such as those noted in the SALP, some specific comments are provided in this report on major concerns identified in your report.
DYERALL , Concern was expressed at the lack of centralized management of corrective actions.
Difficultics in coordinating and prioritir.ing efforts both at the site level and within some departments were noted. This concern had also been specifically noted when reviewing the preparations for Unit I restart. We concur that this is a valid problem
area, and we have substantial efforts in progress to remedy it.
l We have progressively reduced the number of diverse systems by which separate l organizations and processes are controlled. A significant step was the development of the Plant Manager's Startup List to control and coordinate plant material and administrative requirements associated with startup. Another step was implementation of a alte-wide computerized Commitment Tracking System to integrate action tracking of various sources (such as Quality Assurance Audit Findings, NRC items, and POSRC ! l Items) to all Calvert Cliffs departments. Many redundant, stand-alone systems were eliminated. A common Problem Report for identification of a wide range of plant conditions was implemented. This iterative modification of corrective action processes is planned in PIP Action Plan 4.2.1 (Issues Management) and elements of several other plans. This evolution will continue, with each change designed to permit simpler, more , I centralized control. Current processes are adequate but cumbersome, and management is keenly aware of the need for improvement.
Continued improvements, including introduction of additional information systems technology, will be pursued as rapidly as they can be controlled. We are, however, moving at a deliberate pace so as to manage these changes more effectively.
Continuing weaknesses in communications between departments were noted. Many of the same measures noted under centralizing management of corrective actions are equally a part of the program to ensure adequate information flow between departments. Other aspects are being addressed by Quality Circles, Teamwork & Interfaces, improved Performance Standards, Leadership Conferences, and Project Management training.
Efforts such as relocating System Engineers closer to the plant were also directed at reducing th!s problem. While we agree that this is a problem area, our assessment is .
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that communleations hase clearly improved. We are increasingly able to identify specific processes and interfaces which are problem points. These will be aggressively corrected.
We also realize that this area requires continning management support.
. Inadequate follow through in resolving identified problems is the third overall weakness cited. We concur that this has been a problem area. While we see progress in this area, it remains a key fevus of management's concern. A broad array of efforts hu been employed to improve in this area. These actions include PIP Action Plans 2.2 ' (Management Expectationt), 2.4 (Resource Allocation), and 6.2 (Feedback Yerification), with contributions from several other plans.
These efforts can be generally categorized as ensuring adequate resources are available and improving accountability.
By every measure of resources--staffing, operations and maintenance tapenditures, or other--we have substantially increased the resources devoted to Calvert Cliffs. There has been a commensurate effort to increase accountability. Management has constantly i emphulzed line organization responsibility for quality, including rigorous self assessment within each activity. This has been backed up by a substantial program of site-wide and functional self-assessments, nese included the self-SALP at mid-year, an internal maintenance team in: Yetion, a Safety System Functional Inspection of the Low Pressure Safety injection System, several Human Performance Evaluation System and Significant Incident Finding Team investigations of plant events or near misses, and a variety of audits to supplement our existing Quality Assurtnce program. These increased resources and expectations have resulted in our ability to handle more work without sacrificing quality or safety. Preparations for Unit 1 startup demonstrated that plant supervisors are able to follow through and close out l short-term actions adequately. A substantial amount of effort has been devoted to simultaneous long-term improvements, and more and more of those activities are nearing completion to a point that will allow evaluation of their effectiveness.
Management will be closely scrutinizing and following-up on these results to ensure that the program objectives are fully met.
l ' OPERE11QNS The key weaknesses noted in the Operations functional area were in procedural adherence and procedural quality and in managerial and administrative controls. We recognize the procedures area as a critical one for improvement. The PIP Procedures Upgrade Program is a major, full-scope effort to turn this around. We have recently assigned additional BO&E project management supervisors to ensure this project's progress. We have also aggre:sively corrected many procedures to make workable, correct procedures a realistic expectation. Procedural adherence is expected and enforced, and we see substantial progress in this area.
In Operations management and administrative controls, we have revised the organization to improve effectiveness. Coordination between shift operators, Maintenance technicians, and safety tagging personnel has also been improved by revising procedures and staff work locations. Supervisory field observations have been emphuized to improve feedback on performance changes. We l evaluate our current Operations staff proficiency to be a strength, as was evidenced by our recent 100% successful requalification rate. Based on these measures, we expect to substantially improve in Operations performance during the current SALP period.
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, ,, ,, e .. . .. ' Docume:t Control Desk o May 14,1990 ! Page 4 i MAINTENAhlCE/RURWir1ANCE The SALP's major concerns in maintenance and surveillance were the etamples of poor ' performan e indiesting continuing deficiencies la management effectiveness. The report noted that organirational changes and the new procedure controlling maintenance , appeared to be having a positive effect. We concur in that assessment. Management is closely reviewing maintent.nce performance to identify remaining specific problem areas.
A thorough review of surveillance procedures is continuing, and supervisory obseivations are being emphasized as a mears to identify further problems. Expanded root cause training is expected to improve the effectivene6s of corrective actions.
Further adjustmer..s to ensure sufficient efficiency of maintenance to support operations will be made as more experience under our new procedures is gained. We will devote close manabement attention to continued improvement in this area.
SAFETY ASSL1SMFEI/OUALITY VERIFICADQM i The significant weaknesses noted in this functional area were procedural quality and compliance, managemee. involvement in assuring the quality of licensing activities, and continuing wekknesn . corrective action and commitment management processes. We ' agree with these ( mons. As noted in the Operations and Overall areas above, we recognize tioth the g,cedure and corrective action areas as significant ones requiring plant wide improvement. In the area of licensing activity management, your conclusion matches one we reached late in the SALP period. We substantially revised the licensing organization in order to provide it with better staffing and oversight. In addition, we evaluated the problem of quality of line organization inputs to Licensing for regulatory communications at our Spring Planning Conference. This area also requires upgrading, and we are currently developing a plan for its accomplishment. We believe that the area of safety assessment and quality verification will be of vital importance to us during this SALP period, as many of our improvement initiatives reach fruition, it is at this stage that prompt and accurate feedback is essential in order that resources can be utilired effectively in resolving performance issues. We have devoted substantial management attention to this verification already, and we are confident in our ability to objectively and successfully accomplish this key task.
ENGINEERING /rECHNICAL SMITQK[ The SALP concluded that Engineering had implemented many measures to correct problems noted in the previous period, but that there was not yet sufficient evidence to ensure that the changes were fully effective. We concur in this evaluation. The specific earlier concerns included system engineer staffing and qualification, lack of advance preparation for outages, and inconsistent review of Facility Change Requests for reportability.
We have planned further staff increases, established feedback mechanisms to improve training, and are revising our 10 CFR 50.59 screentos procedure and training. In addition, all of the measures discur.std as Overall issues pertain directly to Engineering in the areas of controlling corrective actions, communicating with other departments, and following through on correcting identified problems. We will assess our progress and modify our efforts as necessary to attain continued improvements this year, s . . . ..
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o .. ' o Docume:t Co: trol Desk May 14.1990 i Page 5 I ! SECURTIWilADIOLOGICAL CONTROLEEMERGENCY PR.EPAREDNESS , in the Security area, we have undertaken a careful re-evaluation of our internal review procedures which has shown several areas in which further improvements can be made. In Radiological Controls, we feel that we have a strong ALARA and radiological protection program with demonstrated good results, and that the recurring deficiencies in redwaste and transportation were not representative of our overall effectiveneas. We have taken , action to correct the training and radwaste deficiencies identified. We are committed to improving our self-assessment and root cause determination to prevent continuation of defielencies as they are found. In Emergency Preparedness, we have implemented some . revised training techniques which should improve our proficiency and have also t increased our staffing to in. prove coordination of some Emergency Preparedness activities. We agree with the SALP conclusions in these categories, and we are determined to energetically pursue improvements in each.
SUMMARX The 1989 SALP report provides a balanced view of Calvert Cliffs' performance which details both the deficiencies and improvements in terms very parallel to our own conclusions. We feel that the report substantiates that BG&E management correctly analyzed the root causes for past performance problems, and it provides corroboration of our progress in making improvements. We successfully secomplished the many short term goals which were tied to safely starting up Unit I in April, and we expect to return soon to further safe, successful operation. We have also implemented many long-term improvements as part of our PIP, and the SALP appropriately credits these efforts. The current year will be marked by substantial self-assessment of these initiatives to ensure their effectiveness.
We have planned a mid term internal SALP-style assessment, another SSFI, an laternal maintenance inspection and a PIP ' vertical slice' assessment in addition to the first PIP vertical slios and an independent start-up assessment already conducted. These efforts will provide us substantial feedback to ensure our performance continues to improve.
Calvert Cliffs' management is firmly committed to restoring the plant and all its support systems to our goal of excellent performance. We have the full attention, guidance, and support of corporate management. We are confident in our ability to succeed. We also do not have any illusions that this work is done. We realize that we must follow-through on the uptrends we have all seen.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
Very truly yours, i GCC/JMO/dtm .-. - .. .- . .
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May 14, IMIO ' Page 6 cc: D. A. Brune, Ebquire J. E. 511 berg, Exiulte R. A.Capra NRC D. O. Mcdonald, Jr., NRC T. T. Martin, NRC L. E. Nkholson, NRC R. McLean, DNR . i ,
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