IR 05000333/1993082
| ML20058Q050 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick  |
| Issue date: | 12/08/1993 |
| From: | Cowgill C, James Trapp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058Q045 | List: |
| References | |
| 50-333-93-82, NUDOCS 9312280052 | |
| Download: ML20058Q050 (34) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
JAMES A. FITZPATRICK NUCLEAR POWER PLANT OPERATIONAL SAFETY TEAM INSPECTION Report No.
93-82 Docket No.
50-333 License No.
DPR-59 Licensee:
New York Power Authority Post Office Box 41 Lycoming, New York 13093 Facility:
James A. FitzPatrick Nuclear Power Plant Inspection At:
Scriba, New York Inspection Dates:
October 4-21,1993 Inspectors:
J. Beall, Asst. Team Ixader S. Chaudhary, Sr. Reactor Engineer P. Harmon, Sr. Resident Inspector, Oconee G. Hunegs, Sr. Resident Inspector, Indian Point 2 R. I.orson, Resident Inspector, Peach Bottom J. Macdonald, Sr. Resident Inspector, Pilgrim J. Menning, Project Manager, NRR L. Prividy, Sr. Reactor Engineer D. Skeen, Reactor Systems Engineer, NRR Team leader:
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{4s James M. Trapp, Team Irader Date Engin ti g Branch,' DRS Approved By:
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Curti/J. Co gil Chief Date Projects Bran Division of Reactor Projects l.
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9312280052 931222
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TABLE OF CONTENTS I
PAGE TABLE OF CONTENTS ii
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1.0 INSPECTION OBJECTIVE AND SCOPE
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2.0 DETAILED INSPECTION FINDINGS I
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2.1 MANAGEMENT PROGRAMS AND OVERSIGHT..............
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2.1.1 Management Programs............................ 1
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2.1.2 Management Oversight
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2.1.3 Conclusion
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2.2 SELF-ASSESSMENT / IMPROVEMENT PROGRAMS
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2.2.1 Quality Assurance Program......................... 6 2.2.2 Plant Operations Review Committee
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2.2.3 Safety Review Committee.........................
2.2.4 Independet Management Oversight...................
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2.2.5 Conclusions
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2.3 PROBLEM IDENTIFICATION AND RESOLUTION............
2.3.1 Problem Identification...........................
2.3.2 Problem Assessment
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2.3.3 Corrective Actions......................,......
2.3.4 Conclusions
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2.4 ENGINEERING AND TECHNICAL SUPPORT...............
2.4.1 Engineering Organization.........................
I 2.4.2 Engineering Staff Training........................
2.4.3 Permanent Modifications and Safety Evaluations...........
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2.4.4 Modification Prioritization
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2.4.5 Temporary Modifications.........................
2.4.6 Communications
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2.4.7 Technical Services Backlog and Support to Plant Issues
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2.4.8 Master Equipment List and Configuration Control..........
2.4.9 Conclusions 30-
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3.0 EXIT MEETING
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Appendix A, Persons Contacted Attachment 1, NRC Slides Used at Exit Meeting r
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i EXECUTIVE SUMMARY
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The objective of this inspection was to conduct a performance based inspection of management programs and processes that support safe operation of the James A. FitzPatrick Nuclear Power Plant. The team conducted inspection activities in the areas of (1)
Management Programs and Oversight, (2) Self Assessment / Improvement Programs, (3)
i Problem Identification and Resolution, and (4) Engineering and Technical Support. The.
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inspection activities were conducted at both the FitzPatrick site and at the Corporate Office.
The team concluded that the corporate and plant management teams were committed to
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achieving improved performance as demonstrated by the timely implementation of the Results Improvement Program and the Business Plan goals. NYPA management has committed additional resources to support improvement programs. The plant and corporate management oversight and involvement in plant operations and problem resolution were effective.
Enhancements made to the overall corrective action program have resulted in improved response and evaluation of plant deficiencies. The daily Plant Leadership Team meeting,
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which included a discussion of plant deficiencies and corrective actions, demonstrated management's attention and involvement in resolving plant deficiencies. The implementation of a strong Management Observation Program also promoted first hand management involvement in identifying and resolving plant deficiencies. The implementation of a " Top 10" technical issues list promoted focused and effective management oversight of important
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issues. Plant and corporate management teams provided strong direction and fostered a nuclear safety work ethic that was understood at all levels in the organization. The team observed strong direction and involvement by plant managers during plant status meetings.
The team concluded that program elements that monitor and evaluate the effectiveness of
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corrective actions have been instituted, and that safety issues were being identified to l
appropriate levels of management. However, additional attention was necessary to assure
that findings were closed in a timely manner. The team further concluded that the quality
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assurance and safety oversight groups provided timely and effective self-assessment of performance to site and corporate management.
The recently implemented problem identification and evaluation systems were effective. The
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plant material condition was good and equipment deficiencies were appropriately identified.
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Substantial progress had been made in reducing the backlog of operating experience reviews.
The procedural guidance for conducting root cause evaluation and event reviews was a
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strength. In general, the quality of event reviews was good; however, weaknesses were identified in documenting the detail of some root cause evaluations. The performance of the corrective action program was mixed. The team noted that the current corrective actions taken were generally timely and comprehensive, but past corrective action program failures i
had complicated several recent plant scrams. For example, the reactor feedwater pump
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discharge check valve that contributed to the April 1993 scram had been the subject of
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Executive Summary
several unsuccessfully modification and repair attempts. In-pmgress, long term corrective actions to resolve problems associated with logic system testing and with the high pressure coolant injection system were comprehensive and had strong management oversight.
The team identified an item regarding the failure to adhere to a commitment contained in a letter sent to the NRC on December 24,1992. Specifically, a cable separation anomaly was corrected analytically, rather than physically, as stated in the letter. NYPA agreed to correct the intonnation formally on the docket.
Overall the team concluded that the engineering organization improved its support and oversight of plant activities. Improved interdepartmental communications and coordination were evident within the engineering organization as well as extemally v4 h the operations and t
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maintenance departments. Plant modification programs were being effectively implemented.
However, the planning, prioritizing, and scheduling of modifications continued to warrant improvement. The team observed the technical support to plant issues to be generally much improved. A notable exception to this involved the lack of a structured resolution plan to address numerous control room ventilation system deficiencies. Performance at resolving longstanding configuration control issues was mixed. Configuration management has effectively reduced the drawing revision backlog. However, little progress was made at addressing the master equipment list qualification backlog. The team noted a significant action item backlog that to a large extent dictates organizational agendas. A comprehensive
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data base has been developed which now enables management to evaluate backlog reduction l
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effort effectiveness. Continued management attention is needed to successfully achieve improved performance in these areas.
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1.0 INSPECTION OBJECTIVE AND SCOPE
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The objective of this inspection was to conduct a performance based inspection of
. management programs and processes that support safe operation of the James A. FitzPatrick.
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j Nuclear Power Plant. The team conducted _ inspection activities in the areas of (1)
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Management Programs and Oversight, (2) Self Assessment / Improvement Programs, (3)
Problem Identification and Resolution, and (4) Engineering and Technical Support.
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The inspection activities were conducted at both the FitzPatrick site and at the New York
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Power Authority Corporate Office in White Plains, N.Y. The inspectors for the team were l
selected based on their nuclear industry experience and diversity in backgrounds. The team
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consisted of region-based and resident inspectors and staff from the NRC headquarters office.
l The preliminary team findings were discussed with the licensee at an exit meeting that was
open for public observation on November 2,1993. The slides from that presentation are
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attached.
i 2.0 DETAILED INSPECTION FINDINGS
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l 2.1 MANAGEMENT PROGRAMS AND OVERSIGIIT j
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The team evaluated the effectiveness of site and corporate management programs and processes that promote safe plant operation. The evaluation was conducted by assessing the i
quality and performance of several management programs, direct observation of management j
direction of daily plant activities and conducting interviews with a cross section of managers
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and staff. The interviews were based on current plant issues, such as the management
'i observation program, the motor-operated valve (MOV) program, and management's response-to plant events and forced shutdowns.
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2.1.1 Management Programs a
Results Improvement Program f
The team reviewed management actions regarding the Results Improvement Program (RIP).
NYPA developed Phase I of the RIP in 1991 to correct deficiencies that were identified at that time. The plant leadership team (PLT), which is comprised of the Resident Manager-l and three General Managers, has the overall responsibility for implementing the RIP. The.
RIP action items are tracked in accordance with Administrative Procedure AP-03.09,.
"Results Improvement Program." Periodic reports are prepared by the RIP Coordinator to j
provide a status of RIP action items. The PLT authorizes the closure, status changes, and-l additions of items to the RIP. Reviews of overdue RIP items are conducted periodically at-l PLT meetings. Graphs depicting the status of RIP items are provided to department-j managers approximately bi-monthly. The team reviewed a set of RIP status graphs prepared
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on October 4,1993, which indicated that the number of overdue RIP action items had been reduced from 130 to 86, during the period September 21,1993, to October 1,1993. The.
licensee stated that they planned to reduce the number of overdue RIP items to zero by the end of 1993. The RIP Coordinator also provides monthly status reports that highlight
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overdue action items and action items that are coming due within the next six weeks. The team reviewed a recent monthly status report dated October 4,1993, and confirmed that the
report clearly focussed on overdue items. The Executive Vice President - Nuclear Generation determines the adequacy of the RIP progress through quarterly status reports from the Resident Manager and indepeacent assessments. In view of the extensive status reporting, involvement of senior management, and reduction in the number of overdue action items, the team concluded that the tracking of Phase I RIP action items had been effective.
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The team noted that Phase II of the RIP was being drafted to provide a mechanism for planning and tracking emerging opportunities for improvement. The RIP Phase II classified i
items in 5 main areas that are consistent with the NYPA Business Plan. Since the RIP Phase II document was in rough draft format, the team had no conclusions as to its appropriateness.
Business Plan The team assessed management involvement in the tracking of Business Plan (BP) goals.
During interviews with the PLT, the team observed that these managers were cognizant of
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the goals for which they have ownership and were aware of their progress toward meeting these goals. The team also noted that graphs showing performance trends for BP goals were updated and distributed to the licensee staff. Business Plan goals were routinely discussed during the morning department manager meeting. For example, the team observed from the discussion at one of these meetings that the number of reported out-of-service control room devices was higher than the BP goal (i.e.,39 versus 15). A planning department supervisor explained that 24 of these items required the plant to be shutdown for correction, and that
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only 15 could be corrected during normal plant operation. The team subsequently confirmed that the licensee had included the 24 deficiencies in their upcoming maintenance outage plans. Also, the General Manager - Operations stated that measures were being taken to i
clarify the BP goals for control room devices relative to outage and non-outage conditions.
The General Manager - Maintenance was aware of his BP goal to improve equipment performance and reliability by developing a preventive maintenance program on important valves and beginning its implementation in the 1993 maintenance outage. The team verified that this BP item was completed on October 1,1993. In view of management's awareness of i
BP goals demonstrated during the inspection and the clear focus on BP goals observed during the department manager meetings, the team concluded that the tracking of BP goals had been
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Management Observation Program i
The team assessed the effectiveness of the licensee's management observation program.
Requirements for this program were delineated in Section 8.3 of Administrative Procuiure I
AP-03.07, " Internal Appraisal." The General Manager - Operations is respon'ible for s
assigning observation tasks to plant management on a quarterly basis. Management observations are documented and forwarded to the Genemi Manager - Operations for review.
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The General Manager - Operations assigns action items to resolve identified deficiencies.
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The team reviewed program activities during 1993 and noted that management had aggressively implemented the program. For example,32 observation tasks were assigned by the General Manager - Operations during the first quarter of 1993 and 98 observations were
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actually performed. The additional, unassigned observations were performed based on marugement's decision to monitor other activities that were of particular interest. In the second quarter of 1993,32 observation tasks were assigned and 50 were actually performed.
In the third quaner of 1993, 32 observation tasks were assigned and 47 were actually per ormed.
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The team reviewed a sample of written reports for 10 management observations that were performed at various times between February and September 1993. The written reports provided observation results, conclusions, and corrective action recommendations. The team noted that the observation findings were diverse and resulted in substantive corrective action recommendations to improve procedures, enhance communications and training, and correct housekeeping and industrial safety deficiencies. All but two of the reports contained corrective action recommendations. Where necessary, action items were assigned for the corrective action recommendations.
The team discussed the management observation program with managers and first-line supervisors. The managers were knowledgeable of the program requirements and indicated that the program was of significant value to the plant. The first-line supervisors also believed that the program was valuable and indicated generally that the managers who had observed them were well-prepared in conducting the observations. They also indicated that negative findings had been discussed with them in a positive manner subsequent to the observations.
Although not specifically required by AP-03.07, the General Manager - Operations trended the management observation program findings. The team reviewed a report dated October 14, 1993, that summarized the results of observations performed during the first three quarters of 1993. The report indicated, in part, that findings related to housekeeping appeared to be increasing, the number of suggestions to improve training remained high, and the number of hardware-related issues appeared to be remaining constant. The report also stated that the program had resulted in slightly more than two recommendations for improvements per observation report.
The team concluded that the management observation program had been an effective self assessment tool in view of the demonstrated commitment of management and supervision to the program and the number of substantive corrective action recommendations that have resulted from it. The program has afforded a good mechanism for independently achieving management oversight for a range of plant activitie *
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Scram Reduction Procram i
The team reviewed the corrective actions taken in response to the reactor scrams that l
occurred in 1993.~ The team noted that the General Manager - Operations had initiated.
significant improvements to Administrative Procedure AP 03.01, " Post Trip Evaluation,"
following the February 1993 scram that occurred due to ice formation at the intake structure.
These changes were responsible for the improvement in the root cause evaluations performed for subsequent scrams. Also, team discussions with the PLT and the Executive Vice President - Nuclear Generation indicated that thorough evaluations had been conducted to
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determine if there were any common cause for these plant scrams. However, measures were not in place for the identification and evaluation of "Near Misses", such as might be expected as part of a scram reduction program. Subsequent discussion with the Resident Manager indicated that the Senior Nuclear Assessment Engineer had made a similar
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observation in August 1993, resulting in an action item being inserted into the Action
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Commitment Tracking System (ACTS). The Resident Manager stated that this action item would be detailed as a separate item in Phase II of the RIP with Nuclear Operations responsible for the resolution. The team determined that adding a scram reduction program to the RIP was a good initiative.
2.1.2 Management Oversight The team evaluated several activities involving management oversight. These activities included management direction at daily plant meetings, alkration of resources and management of work backlogs.
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Manaeement Direction Based on discussions with the various managers and their staff, the team concluded that personnel development considerations were being incorporated to improve the organization and impart a clear safety emphasis. Several managers had served as independent reviewers on INPO inspection teams at other facilities and attended industry sponsored senior manager training courses. A safety first philosophy was being promoted by management. This message was being clearly communicated and evident at all plant organization levels.
The team observed good management involvement in daily working meetings at the plant.
The PLT meeting routinely reviewed and discussed ccrrective actions for all new Deviation Event Reports. The team concluded that senior plant managers were effective in reviewing and formulating corrective actions to resolve these issues. Strong management involvement was also noted at the daily department manager meetings that discuss planned activities. For example, the General Manager - Support Serv'ces discussed an NRC Information Notice cautioning the proper control of painting in plant areas. This was a timely information item since significant painting activity was planned and ongoing in the plant. The Resident
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Manager also discussed recent changes in NYPA administrative policies. The team concluded that the managers were clearly involved in the meeting discussions and that they pmvided strong direction to the plant staff during these meetings.
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Resources
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The team concluded that sufficient resources were being allocated to support improvement programs in all working groups at the plant. Significant staff increases had been made in the operations, technical services, site engineering, and planning departments. While several technical services vacancies have occurred due to internal transfers, progress was being made to fill these vacancies. Also, the team concluded that sufficient corporate engineering resources were being allocated to FitzPatrick despite the significant demand for these resources by Indian Point 3. The team reviewed the corporate engineering support for the motor-operated valve (MOV) program. The team noted that corporate engineering was late in meeting internal commitments to resolve two MOV issues regarding the impact of degraded voltage on the stroke times for certain MOVs and the development of a uniform I
acceptance criteria for evaluating MOV overthrust conditions. This information was requested by the maintenance department to improve the MOV program activities. The maintenance manager stated that the deferral of corporate engineering action concerning these
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issues was isolated and acknowledged favorable corporate engineering support on many other issues, such as main condenser performance monitoring. The team verified this information during various interviews and concluded overall that sufficient corporate engineering-l resources were being allocated to the plant.
Work Backlocs and Meetines
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The team determined that plant managers recognized the need to reduce existing work backlogs such as those for maintenance and engineering work. Most managers stated that improved planning and scheduling of work and increased work control program efficiency were required. Action had been taken to improve the planning and scheduling for the fall
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1993 maintenance outage. The licensee initiated a scope control process in July 1993 for controlling the work to be added or deleted from this outage. Under this process the cognizant department manager concurs with a proposal to add or delete a work item from the schedule. _ The proposals are then reviewed by a Scope Control Group. Addition or deletion of an item from the outage work schedule requires the written approval of one of the general j
managers. Administrative controls for the scope control process are delineated in the Planning Department Standing Order PDSO-04, "Short Forced Outage Management." The PDSO-04 guidance was also applicable to planned maintenance and refueling outages. The team concluded that the scope control process promoted strong management involvement in
the outage planning process.
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The licensee has developed a top ten technical issues list to prioritize the technical staff's issues. The issues on the " Top 10 Technical Issues" list are discussed by all departments during the monthly engineering meetings. This list serves as a good management tool for dedicating the required resources and exercising management oversight of important issues.
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2.1.3 Conclusion The team concluded that the corporate and plant management teams were committed to
achieving improved performance. This conclusion was based on the licensee's timely implementation of the Results improvement Program and the Business Plan goals. Other factors that supported this conclusion were the commitment by NYPA management to allocate resources in the areas of operations, technical support, and site engineering for the support of improvement programs.
The team concluded that the plant and corporate management oversight and involvement in
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plant operations and problem resolution were effective. This conclusion was based on the teams observation of management enhancements made to the overall corrective action
program. The daily Plant Iradership Team meeting, that included a discussion of each new Deviation Event Report (DER), demonstrated management's attention and involvement in plant problems. The team also noted a strong Management Observation Program promoted first hand management involvement in plant activities. The implementation of a " Top 10" technical issues list promoted focus and management oversight of important issues.
Management recognized the specific need to improve the planning and scheduling of work and to reduce existing work backlogs.
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The team determined that the plant and corporate management teams provided strong direction and fostered a nuclear safety work ethic that was understood at all levels in the organization. By interviewing a cross-section of plant staff, the team determined that the
" Safety-First" philosophy was evident at all working levels. The team observed strong direction and involvement by plant managers during the daily department manager meetings.
2.2 SELF-ASSESSMENT / IMPROVEMENT PROGRAMS The team assessed the effectiveness of the licensee's self-assessment program in providing site and corporate management accurate and timely assessments of overall plant performance.
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The licensee had established several organizations and processes to perform self-assessments.
The team evaluated the performance of the quality assurance program, plant operations j
review committee, safety review committee and independent management oversight groups.
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2.2.1 - Quality Assurance Program j
The team reviewed the licensee's quality assurance organization's structure, interfaces with i
other plant and corporate organizations, role in assessment of plant performance and program effectiveness, and identifying deficiencies.
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Audit Findines The team reviewed a number of site and corporate office quality assurance (QA) audits to assess the scope, findings, and the adequacy of the audit program in fulfilling the self-assessment objective. The team reviewed audits reports prepared during the past two years.
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Four audits reports in the areas of the radiation protection program, operating experience report program, Results Improvement Program, and corrective action program were reviewed -
in detail to evaluate the audit process and to assess the quality of audit findings.
Additionally, the QA department conducts unscheduled surveillances of plant activities in the areas of operations, maintenance, radiation safety, and procurement. Several of these surveillance reports were reviewed by the team.
The team determined that the audits were comprehensive, of good technical quality, and were well documented. The audits of the radiation work permit procedure and the operating experience report had good findings, and each generated approximately seventeen
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recommendations for program improvements. In the area of radiation protection, ten recommendations were made for enhancement of the radiation work permit (RWP) program, four for revising the procedure to reflect actual work practices, and one for clarifying a requirement to make the procedure more effective. The team noted that plant management recognized the shortcomings of the RWP program and initiated actions to implement the
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audit recommendations. This example indicated the effectiveness of the quality assurance program identifying and resolving plant deficiencies. The audits of the results improvement and corrective action programs were also of good quality and contained good assessment of these programs. The corrective action audit identified that, in mr.ny instances, personnel performing or directing corrective actions did not have a clear understanding of their responsibility to assure and/or improve the quality of the program or process they were implementing. The implication of program and process deficiencies were often not recognized because they were viewed as isolated instances, rather than as indicators of
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broader deficiencies. However, plant management recognized this problem and has taken steps to enhance personnel awareness in this area. The effectiveness of their efforts was evident by a reduction in rejected corrective action responses by QA, and a greater effort in establishing the root and contributing causes of deficiencies. The audit reports were widely
distributed and were provided to the senior management for their information and use.
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The team determined that the QA self-assessment process and the audit program were effective and provided management a detailed status of program effectiveness and open safety issues. The QA program is effective in identifying plant deficiencies. The team noted that i
the QA organization has recently improved in providing overall performance evaluations
i based on the QA findings. The format of the reports to upper plant management have also been improved and presently provide management with concise evaluations. The QA audits
reports reviewed were thorough.
i The team assessed the relationship of the site QA organization with other site organizations during interviews with managers. The team concluded that this relationship was strong in
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that the managers expressed respect for the competence of the QA organization and the
soundness of their findings, and endorsed QA reviews of their activities to improve f
performance in their departments.
Trend Analysis and Assessment Reoorts
The trend analysis functions at the plant site are mainly performed by the Operations Review Group (ORG); however, the QA department also independently trends selected quality
assurance issues. The quality assurance trends are maintained, analyzed, and evaluated by plant QA and the corporate QA departments. These reports are routinely provided to management.
The team reviewed the trend reports prepared by Operations Review Group and the QA department. The ORG reports reviewed were quarterly reports from the second quarter.of 1992 to the third quarter of 1993. The parameters selected for trending included:
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distribution of DERs in functional areas and systems; apparent causes; selected apparent cause trends; selected program trends; and operations department human performance.
These reports were comprehensive and of good technical quality.
In the trend report for the period of April 1 to June 30,1993, the team noted good trends in radiation protection, chemistry and protective tagging, and fire protection. The percentage of r
fire protection DERs was down from approximately 20% to about 15%; however, the DERs initiated due to work practice problems remained high at about 25%. Also, adverse trends were indicated in oversight on vendors working at plant site, and were recommended for further evaluation. The team discussed this observation with plant senior management.
Through these discussions and a review of results improvement program parameters, it appeared that the licensee had started a review of the area to identify the causes, and to
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devise an improvement strategy. The identification of an emerging problem, before it became unmanageable, was an indication of an effective trending progra.
The results of these trend analyses and evaluations are widely reported to higher management, including Executive Vice President - Nuclear Generation. These reports include monthly site reports, goality trend reports, and corrective action status reports.
Additionally, monthly performance indicator reports are also generated. These reports provide a detailed assessment of plant performance and safety. The team, however, noted that there was a substantial backlog of overdue QA findings which required corrective
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actions. The corrective action backlog was extensive in the area of engineering and technical support with some items as old as 1985. The team noted that the overall trend of resolving
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these issues was downward, and efforts were being made to reduce the backlog in this area.
The team determined that safety and programmatic issues were identified and tracked in
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many ways, such as Deviation Event Reports (DERs), event analyses, and routine and special QA audits and surveillances. The trending and assessments of these issues were generally
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thorough and properly assessed the safety significance and relative importance. The team i
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9 noted improvement in' the integration of individual findings to develop functional area
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assessments.
The trend analyses by Operations Review Group provided a detailed status of open safety and programmatic issues, and the corrective action monitoring and analysis program (windows)
was a good tool for management to assess the status of corrective actions and safety issues.
2.2.2 Plant Operations Review Committee
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The team reviewed the conduct of the Plant Operations Review Committee (PORC) to verify
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that critical, multi-disciplined reviews were being conducted of appropriate plant issues.
Additionally, the team verified that Technical Specification (TS) requirements regarding the PORC were being satisfied.
The team attended one regularly scheduled PORC meeting. The meeting agenda followed a standardized format and included discussions regarding procedural revisions, a Licensee Event Report, a technical specification interpretation, several temporary plant modifications and outstanding PORC commitments. The team concluded that the presentations were thorough and that the PORC reviews were adequate. The team verified that the TS quorum requirements were satisfied.
The team also attended an unscheduled PORC meeting that was conducted to review a safety evaluation associated with continued use of the reactor building crane while having a
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mechanical deficiency in the bridge drive. The PORC also reviewed a related_ temporary maintenance procedure that was referenced in the safety evaluation and intended to demonstrate that the expected coasting distance of the crane was consistent with the safety evaluation. The PORC's questioning of cognizant engineers during these reviews was thorough and, in part, resulted in the insertion of appropriate acceptance criteria into the temporary maintenance procedure. The team noted that PORC critically examined this issue and enhanced the proposed procedural revision and safety evaluation. The team interviewed selected PORC members following the meeting and concluded that the members had a good understanding and safety perspective of the issue.
The team reviewed the PORC open item list, the frequency of PORC meetings conducted in 1993, and selected PORC meeting minutes which occurred since August 1992. The team noted that the number of outstanding PORC commitments was low (15 items) and that no items were overdue. The team reviewed selected open PORC items and concluded that the assigned due dates were appropriate and that the issues were being actively managed. The team noted that the frequency of PORC meetings exceeded minimum TS requirements. The team's review of previous PORC meeting minutes indicated that the PORC was addressing
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appropriate plant activities. The team concluded, based on the observation of meetings,.
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review of documentation and interviewing members, that the PORC satisfied TS requirements and provided effective oversight of plant activities.
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2.2.3 Safety Review Committee The Safety Review Committee (SRC) performs an off-site review of plant activities. The SRC is required by charter and TS to review and audit the performance of the nuclear organization and to report their findings to the Executive Vice President-Nuclear Generation (EVP-NG). The SRC is composed of senior licensee management personnel augmented by an outside consultant. The team conducted document reviews, interviewed personnel, and observed a routine SRC meeting to evaluate the SRC's effectiveness.
The team examined the agenda for a routine SRC meeting and noted that the planned meeting topics satisfied TS review requirements. The team observed selected portions of this meeting i
and concluded that the presentations were thorough, and that the SRC critically reviewed the presentations. Specifically, while reviewing plant-developed safety evaluations, the SRC questioned a safety evaluation for a modification that would provide air conditioning to a battery room. The SRC noted that minimum acceptable temperatures are normally the primary concern for batteries and questioned the reason for the air conditioning installation.
This information was not provided in the material provided to the SRC and the SRC's questions were referred to the plant for response. The team also noted that the TS quorum
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require.ments for this meeting were met.
The team reviewed the meeting minutes since May 1993, and audit schedule for the past year to verify that TS requirements had been met with respect to the composition, duties, meeting frequencies, and responsibilities of the committee. The team noted that the SRC has been meeting monthly in excess of the minimum requirement to meet once every six months. The team reviewed the backgrounds of the SRC members and concluded that the SRC members had broad and extensive experience in nuclear operations.
The team noted that the SRC held a special meeting in June 1993 to develop a plan to improve their oversight of plant activities. The SRC identified several initiatives to improve their oversight function which included revision of the SRC Charter, addition of a second outside consultant to the committee, expanded SRC review of plant assessment reports, and
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increased attention to the audit program. The team's review of meeting minutes and the SRC open item list indicated that the SRC has been providing effective oversight by performing critical reviews of audits, safety evaluations, equipment issues and plant assessments. The team noted that the element of the plan involving hiring of the additional consultant has not yet been implemented. The team interviewed the SRC Chairman who indicated that NYPA
was proposing a TS change in order to add the additional outside consultant to the SRC as
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planned.
I The team concluded that the SRC satisfied its TS requirements and provided effective oversight of the plant activities. The team determined that the SRC's plan for improving l
their oversight function was sound and that the SRC was making good progress in implementing their plan.
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2.2.4 Independent Management Oversight The licensee management has instituted several independent programs that monitor and evaluate effecdveness of improvement programs and corrective actions. The four main elements of the oversight program are the QA program, trend analysis by the ORG, RIP corrective action monitoring and analysis, and the Nuclear Programs Assessment Section i
reports. In addition, a Nuclear Advisory Committee has been formed with experienced senior nuclear professionals from outside of the NYPA organization to monitor and advise the licensee's senior management.
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Nuclear Procrams Assessment Section The NYPA recently developed a Nuclear Programs Assessment Section (NPAS) to independently review plant performance. The assessment program was implemented in July
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1993 by assigning a Senior Assessment Engineer (SAE) to the site to provide an independent review of plant activities. The NPAS is independent of the line organization and reports to the Vice Piesident - Nuclear Operations and Maintenance.
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The team evaluated the effectiveness of the NPAS by examining the first two assessment
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reports, interviewing the SAE and reviewing management's implementation of the SAE's recommendations. The team reviewed the assessment reports and noted that the SAE was reviewing a wide range of documents relative to plant performance, observing field activities
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and inspecting the material condition of safety systems. The assessment reports were well
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written and provided specific recommendations to improve performance. The recommendations appeared to have received appropriate management attention. The team noted that the SAE was familiar with his duties, and had an extensive background in nuclear operations. Th:: team concluded that the SAE program was a positive initiative to enhance assessment of plant activities.
Nuclear Advisory Committee The NYPA established a Nuclear Advisory Committee (NAC) in June 1993 to advise the
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Board of Trustees on the operation of NYPA's nuclear facilities. The team reviewed the NAC charter and noted that the NAC is composed of a three member panel and is required to meet quarterly and visit each of NYPA's nuclear sites annually. NYPA appointed three individuals with senior management level industry and regulatory experience to the NAC.
The NAC appears to be a strong initiative for improving plant performance; however, the NAC has only had one meeting to date and the team concluded that it is premature to assess their effectiveness.
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2.2.5 Conclusions
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The team concluded that program elements that monitor and evaluate effectiveness of corrective actions have been instituted, and that safety issues were being identified to
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appropriate levels of management. However, additional attention was necessary to assure that findings were closed in a timely manner. The team further concluded that the QA and i
safety oversight groups provided timely and effective self-assessment of performance to site and corporate management.
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2.3 PROBLEM IDENTIFICATION AND RESOLUTION The team reviewed the licensee's programs and procedures with respect to the identification, assessment, and resolution and of plant deficiencies. The review included walkdowns of selected plant areas and systems to assess material conditions and personnel usage of the problem identification systems. Additionally, the team reviewed a number of equipment failure and event root cause assessments and also interviewed responsible staff concerning their knowledge of program requirements.
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2.3.1 Problem Identification Plant deficiency reporting was controlled by Administrative Procedure (AP) 03.02,
" Deviation and Event Reporting," which had been implemented in April 1993. The procedure was comprehensive and gave good guidance on the identification and reporting of deficiencies observed in the field. Operators and workers interviewed were knowledgeable of procedure methods and requirements. The team conducted plant walkdowns of the high pressure coolant injection system and the emergency diesel generators, with the cognizant system engineers. The systems were generally in good material condition and the system
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engineers were familiar with the status of the components, including posted deficiency tags.
All hardware deficiencies noted by the team had been previously identified and marked with
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problem identification tags.
During the walkdown, the team identified that the cables from conduit ICCl32RE (red train)
were in contact with cables from tray ITK018B (blue train). During a previous inspection (see NRC Inspection Report 50-333/92-82), numerous examples of cabic separation
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deficiencies had been identified. The licensee initiated corrective actions, including analyses of existing plant configurations and physical modifications. The licensee docketed the completion of corrective actions in a letter to the NRC dated December 24,1992. In the
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letter, the licensee described the various measures that had been taken to assure adequate
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cable separation. The licensee specifically discussed eleven cable layout r, ometry anomalies that did not meet the criteria for resolution contained in the more general analyses. One of the cable anomalies (R-30) involved the cables noted above. In the letter dated December 24,1992, the licensee stated that R-30 had been resolved by physically pulling
apart the cables by tie wrap, but as identified by the team, this apparently was not done.
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The team reviewed the licensee's internal documentation associated with R-30 and determined that the licensee had originally planned to use tie wraps to achieve cable separation, but had chosen to use an analysis approach which had been able to justify the existing configuration. The change in disposition method was not identified by the licensee L
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during preparation of the response to the NRC. The team noted that the licensee response had contained another similar disposition of touching cables by analysis. The team reviewed the analysis and the plant configuration and concluded that the current information, had it
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been known at the time, would not have affected the NRC decision to allow the restart of the
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FitzPatrick facility. The licensee initiated a DER to review the' event and committed to the team to correct the information formally on the docket.
Operators accompanied on their plant tours generally were aware of plant conditions and the nature of work ongoing in their assigned areas. The operators displayed a positive attitude with respect to the problem identification process. Specifically, the operators expressed confidence in the ability of the existing systems to correct the deficiencies that the operators identified and entered into the system.
The licensee tracked identified deficiencies with deviation and event reports (DERs). Each open DER was listed and reviewed by management at regularly scheduled meetings. The resolution of each DER was accomplished through AP-03.08, " Action and Commitment Tracking System" (ACTS). The process closed the DER by the approval of specific corrective actions that would be tracked to completion in the ACTS. The team reviewed AP-03.08 and noted that it provided detailed instructions related to entering new items, assigning responsibility, changing items, and closing items. The procedure also specified measures to be taken by the QA organization to escalate attention for overdue items. The escalation measures included the eventual notification of the company president. The team reviewed
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operator logs and concluded that the threshold for initiating DERs was appropriate.
The team reviewed a sample of various licensee commitments made to the NRC during 1988 - 1993. In all cases the identified actions had been completed and the commitments, such as procedure cautions and hardware modifications, were still in place. In 1992, the licensee implemented AP-02.01, " Procedure Writing Manual," which required procedure writers to list the commitments which were satisfied by the performance of the procedure.
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The applicable procedure steps were also required to reference the specific commitment number involved. The team concluded that the current licensee process gave good assurance
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that procedure steps included as part oflicensee commitments would not be inadvertently changed or deleted. The licensee stated that a plan was being developed to research the historical docket for previous commitments.
2.3.2 Problem Assessment Evaluation of plant problems and events was controlled by AP-03.03, " Deviation and Event Analysis." The procedure was comprehensive and generally provided good guidance on the
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processing and evaluation of DERs. In particular, the procedure contained detailed instructions for the various types of DER reviews, including event critiques, equipment failure evaluations (EFEs), and root cause analyses (RCAs). Operating experience (OE)
document reviews were also addressed, The OE reviews were of vendor and other industry reports as well as NRC notifications such as IE Bulletins and Information Notice.
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Operating Exoerience Document Reviews The licensee had made substantial progress in reducing the backlog of OE reviews during the preceding twelve months. In October 1992, the licensee had a backlog of approximately 650 open OE documents. The team reviewed the action plan that the licensee had developed to address the backlog. The team noted that licensee management had been actively involved in
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the effort, had assigned ample resources, and had implemented tracking systems to monitor the progress of the review. At the time of the inspection, the licensee had reduced the backlog to about 140 items. The team reviewed a sample of the OE documents and
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concluded that the licensee's reviews were adequate with no significant deficiencies identified. One example of weakness in implementing vendor recommendations was noted in the team's review of the May 25,1993 plant trip discussed later in this inspection repon.
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Event Reviews Several types and levels of event reviews were defined by AP-03.03, including event critiques, EFEs and RCAs. The procedural guidance and defined structure of the reviews was considered by the team to be a strength. The team reviewed a sample of the of the licensee's reviews and found them generally to be acceptable. The EFEs reviewed were well developed with excellent attention to historical performance and the effects of previous L
corrective actions, however, the quality of the RCAs reviewed was mixed.
The team reviewed nine RCAs, including the five that were associated with the plant trips experienced by FitzPatrick in 1993. The team noted that the licensee had conducted a good human performance review following the waste sample tank release which occurred on July 22,1993. The team considered the three RCAs associated with the plant trips which i
occurred on April 20 and May 25,1993, to exhibit weaknesses.
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The plant trip on April 20,1993, followed a feedwater system transient initiated by a control signal failure which reduced the output of one reactor feed pump. The discharge check valve for the affected pump failed to prevent reverse flow which compounded the transient. The
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RCA for the control signal failure identified the " root cause" to be a " loose electrical
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connection." A terminal screw was found stripped in the controller terminal block. The RCA for the check valve failure, which had apparently occurred prior to the event, identified the " root cause" as "due to turbulent flow within the valve which resulted in fretting between the anti-rotation pin and the swing arm and ultimately gross failure."
l The team questioned how a stripped screw could be a root cause without an assessment of other information regarding how the screw became stripped. The team noted that such a
problem could result from material or fabrication defects in the screw or the circuit board, or could have been caused by a procedure problem or a technician error. In each case, to prevent recurrence, the appropriate corrective action would be different. The team reviewed the RCA supporting documents including the records of the troubleshooting done after the event. The review and discussions with the senior engineer involved in the licensee's RCA
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indicated that the screw had not been stripped but had been found cross threaded such that the connection was tight to the touch but with imperfect contact. The licensee had evaluated applicable work packages in an effort to determine if other connections had also been affected. The senior engineer stated that although it had not been demonstrated that the bad
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connection could cause the exact failure observed during the event, the bad connection had been the only problem found during the extensive troubleshooting and he was confident that it had been the cause. The team concluded that the root cause had not been correctly stated, but that the licensee's overall event review had been adequate.
The valve that had been involved in the April 20,1993, event had failed previously numerous times. Licensee corrective actions had not been effective in preventing recurrence of the check valve failures. The team considered the ineffectiveness of previous corrective actions appeared to be a root cause of the event.
Valve replacement had been recommended by a January 1991 engineering evaluation for the January 1993 refueling outage. The valve was not replaced. The team noted that the licensee's LER of the event did contain a good discussion of the previous problems and actions associated with the failed valve.
Additionally, the team identified one significant omission with respect to the LER and root cause analyses. The previous corrective actions had specified a modification which added a
" foot" to the valve swing arm, but this modification was not restored during valve rework in
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May 1992. The team concluded that the failure to reinstall this previous corrective action was a major causative factor to the event, but was neither included in the LER nor identified during the RCA. Failure to identify this potential root cause precluded corrective actions to prevent recurrence of similar mistakes during maintenance activities.
A plant trip occurred on May 25,1993, due to a " spike" in the "E" channel average power range monitor (APRM) on one reactor protection system (RPS) channel while the other RPS channel was tripped for an unrelated reason. The team reviewed the performance history for
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APRM E and noted that it had spiked previously in January 1993 and in April 1993. A total
of four instruments, local power range monitors (LPRMs), supply inputs to APRM E. The
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same LPRM had caused the January spike while a different APRM had caused the April t
spike. The vendor for the APRMs had reported the occurrence of spiking problems at other facilities and recommended actions to be taken should spiking be observed (GE SIL 500).
The licensee had not implemented all the recommendations following the spiking in January
or April 1993. The licensee stated that the observed spiking was dissimilar to that intended to be covered by GE SIL 500 and that the actions taken were sufficient. The licensee had not documented any basis for the decision not to implement the vendor recommendations nor
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was any indication provided that there had been any discussions on the topic with the vendor.
l The team was unable to rule out the possibility that the steps recommended by the hardware vendor would have prevented the spiking recurrence that caused the scram. The team concluded that the RCA was weak in that it did not address the potential cause of incomplete implementation of vendor recommendations. The licensee stated that GE SIL 500 would be reviewed for possible changes in implementation.
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2.3.3 Corrective Actions Specific corrective actions were generally controlled through the ACTS but there were other systems, such as the formal QA open item list and the informal refueling outage critique.
The team concluded thzt the licensee adequately controlled items related to commitments and
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corrective actions. The team noted, however, that the QA open item backlog appeared to be excessive (see Section 2.2.1).
Corrective Action Effectiveness The operating review group (ORG) was directed by AP-03.03, " Deviation and Event
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Analysis," to trend corrective action information and also to perform effectiveness reviews under certain conditions. The team reviewed the trend reports developed by the ORG and
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concluded that they provided good information to management on potential adverse trends.
The ORG had not conducted any activity that could be identified separately as an
" effectiveness review" as defined by AP-03.03. The ORG chairman stated that neither the format nor the content of an effectiveness review had been defined in the approximate six months since AP-03.03 had been implemented. The team considered the lack of definition of the effectiveness review to be a weakness in the corrective action process. The ORG Chairman stated that the definition of the effectiveness review would be established.
The team was unable to assess the overall effectiveness of the licensee's DER and corrective actions with respect to preventing recurrent events due to the very recent implementation of
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the processes contained in AP-03.03. The team noted that the plant trips and other events that had occurred since AP-03.03 implementation and were recurrent in nature appeared to be related to older problems. For example, one contributor to a trip involved using drawings that had been identified in 1978 as being not adequate for troubleshooting. Another case involved a valve with a long history of failures.
HPCI Model System Plan Performance problems associated with the high pressure coolant injection (HPCI) system had contributed to several plant events. The licensee developed an initiative, the HPCI model i
system plan, to improve system reliability. The team reviewed the plan and concluded that it represented a comprehensive, long term corrective action which addressed the root causes of
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many previous system problems. Many of the plan actions had already been completed but
about half of the planned modifications were scheduled for future outages. The material condition of the system was good at the time of the inspection and the assigned system engineers were knowledgeable of system and plan status. The team also noted that HPCI system performance and availability had shown substantial improvement during the current fuel cycle compared with previous cycles.
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Surveillance Testine The team reviewed several instrument surveillance procedures and witnessed the conduct of
i two surveillance tests. The procedures were reviewed to verify that the detail provided in the surveillance test procedures was adequate to conduct the tests. The team witnessed the performance of surveillance testing to assess the knowledge of the technicius and to verify that the surveillances were conducted in accordance with the procedures, in general, the surveillance procedures provided adequate detail. However, the team noted l
that the level of detail provided in ISP-75-1, "RCIC CST Iow Water level Switch
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Functional Test / Calibration," was not adequate. To conduct this test, a standpipe drain valve (Valve # 898) was required to be opened; however, the procedure did not provide a step to
open this valve. The procedure also did not have instructions for closing this valve. This valve provides the quality assurance class boundary for the condensate storage tank and if left open could drain the condensate storage tank. The independent valve verification sheet (Attachment 1) also did not provide explicit instructions to verify that this valve had been -
closed. The team also noted that a similar procedure deficiency existed in ISP-75, "HPCI i
CST Iow Water Ixvel Switch Functional Test / Calibration."
The team discussed the procedure inadequacy with licensee management. The licensee initially issued a procedure change request to correct die deficiency during the next scheduled procedure revision. The procedures would have been used "as-is" a number of times prior to i
the next revision of the procedure. The team felt that these procedure would more
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appropriately be revised prior to the next performance of the surveillance test and expressed this concern to licensee management. The licensee agreed and revised both procedures. In addition, the licensee revised ICSO-26, "I&C Department Procedure Validation Procedure,"
to provide explicit instruction for operating valves. The team reviewed several additional surveillance test procedures where process f'uids were used to conduct surveillance test and concluded that this procedure deficiency appeared isolated. The team concluded that th::
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actions taken to correct the procedures were acceptable.
The team witnessed the performance of the RPS instrument functional test / calibration (ISP-100D-RPS) and the RCIC condensate storage tank low water level switch functional test / calibration. The technicians and supervisors conducting the test were knowledgeable and
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establish gocxl communications among the test team. The technician supervisor conducted
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thorough pretest briefings and informed the operations personnel of the test objective and expected plant system response. The tests were conducted in accordance with the test procedures.
The team noted that five recent Licensee Event Reports (LERs) identified deficiencies in logic system functional testing. The team reviewed the corrective actions taken to resolve this i ; sue.
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A review of the Technical Specification logic system functional tests had been initiated by the licensee in June of 1993. A Technical Service Department Standing Order TSSO-18, "
Surveillance Test (LSFT) was issued to provide instructions for conducting a review on LSFT. At the time of the inspection, five LSFT reviews had been completed using TSSO-18 and the project was scheduled for completion by the end of 1993. The reviews were conducted independently by personnel from operations, instrument and controls and system
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engineering. The elementary and logic drawings were marked-up and a matrix was generated to verify that appropriate components were tested by the logic system functional test procedure. The reviewers then convened and collectively discussed findings. The team i
reviewed the documentation of LSIT tests and witnessed the meeting that discussed the primary containment isolation system functional tests.
The procedure for conducting the LSFT reviews was detailed and provided appropriate guidance. The technical reviews performed by the licensee staff were thorough. The actions taken to review the LSFT had been thorough and were well documented. The corrective actions taken by the licensee to resolve the deficiencies identified with LSFT were thorough and timely. Strong management involvement was observed in correcting these issues.
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2.3.4 Conclusions The recently implemented problem identification and evaluation systems were of very good quality, were well understood by licensee personnel, and were widely used. Substantial progress had been made in reducing the backlog of operating experience reviews. The procedural guidance and defined structure for event reviews was a strength. Generally the quality of event reviews was good, although weaknesses were identified in some RCAs.
Trending of corrective actions was good, but the failure to conduct the effectiveness reviews identified in AP-03.03 was a potential weakness in the corrective action program. The team identified inaccurate information in a letter sent to the NRC in December 1992 regarding cable separation. The failure to provide accurate information to the NRC was the subject of escaltted enforcement action in 1992 and appears to be an issue that requires additional management attention. The team also identified that several recent plant scrams were complicated by the past corrective action program failures. For example, the reactor feedwater pump discharge check valve that contributed to the April 1993 scram had been the subject of several unsuccessful modification and repair attempts. The team noted recent improvements in the corrective ection program. In-progress, long term corrective actions to resolve problems associ;.ted with curveil%ce testing and with the HPCI system were detailed and comprehensive with strong management oversight.
2.4 ENGINEERING AND TECIINICAL SUPPORT Engineering and technical support was identified as an area of weakness by an NRC Diagnostic Evaluation Team (DET) during the Fall of 1991. A Restart Assessment Team Inspection (RATI) conducted in October 1992 concluded that significant improvements had been made, but many of the programs were not fully implemented at the time of the
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i invection and could not be assessed. The latest NRC Systematic Assessment of Licensee Performance (SALP) mport for the period from April 19, 1992, through April 17, 1993, acknowledged that while substantial effort by the licensee resulted in improvement in this
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area, there were still some weaknesses.
The team assessed the effectiveness of the engineering departments at the site as well as at the corporate office through reviews of organizational structure and staffing changes,
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engineer training, permanent plant modifications, and the temporary modification process, and observance of the day to day workings and communications among the various engineering groups. The team also interviewed engineering personnel at all levels of responsibility.
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2.4.1 Engineering Organization
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The New York Power Authority (NYPA) engineering organizational structure is delineated in NYPA Nuclear Administrative Policy (NuAP) 3.7, Revision 0. The team focused inspection
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activities on the Nuclear Engineering Division at corporate headquarters, and the Site Engineering and the Technical Services Departments on site. The Technical Services Department provides day to day support to the operations and maintenance departments via the system engineering function. The systems engineers are concerned with the welfare of an entire system, while the operations and maintenance engineers concentrme on the operability of individual components. The Site Engineering Department acts as Gie onsite design authority for minor modifications and design changes requiring immediate action. The Nuclear Engineering and Design section is the corporate design authority for any major modifications at both Fitzpatrick and Indian Point 3.
The Technical Services department has significantly increased its staff since the RATI and has filled seven of fifteen newly created system engineering positions. The increased staff has reduced the number of systems assigned to a single engineer from 6 or 7, to 3 or 4. The addition of these positions should allow the individual system engineers to be more knowledgeable of their assigned systems, but since most of these positions have been filled within the last six months and the new engineers are still undergoing training, the team could not assess their impact.
2.4.2 Engineering Staff Training
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The onsite engineering personnel training program is currently governed by Indoctrination and Training Procedure (ITP) 11, Revision 10. All engineering personnel must complete
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five weeks of general classroom training within twelve months of entry into the program. In
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addition, a number of position-specific tasks must be completed and a qualification card must be signed off by senior onsite engineering management before an engineer is fully qualified
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in a position. The number of tasks to be completed varies with the specific position to which j
an engineer is assigned. All but one of the engineering personnel who were employed at the i
beginning of 1993 have completed the classroom training and that individual is scheduled to j
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complete the training before the end of the year. The newly hired engineers are on schedule to complete the classroom training within a par of their respective hiring dates. The team
determined that the training program was thorough and generally well tracked and noted additional licensee improvements were planned.
2.4.3 Permanent Modifications and Safety Evaluations The team reviewed the plant modification implementation process. Closed and open modifications were examined. The responsible engineers were interviewed and all proved to
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be knowledgeable of their assigned modifications and the modi 6 cation process. The team reviewed three open modifications packages and one recently closed modification to assess the modification process. The review included the following modifica* ion packages:
F1-92-109 E/W Cable Tunnel Fire Protection M 1-92-187 Screenwell level Indication M1-92-214 HPCI/RCIC Remote Manual Closure Capability F1-93-075 Reactor Vessel Water Level Backfill Modification
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The packages were prepared in accordance with the licensee's modification control manual and were well organized. The safety evaluations were generally good and satisfied 10 CFR
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50.59 requirements.
Engineering Change Notices (ECNs) against each modification were reviewed for any design deficiencies. Only one package showed an inordinate number of changes due to design i
problems. The cable tunnel fire protection modification (F1-92-109) showed a lack of
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engineering design on the front end. The modification, which changed the fire protection in both the east and west cable tunnels from a dry system to a wet system, has to date, required 110 design changes due to inadequate walkdown prior to the design of the pipe routing and support layout. While it is acknowledged that available spacc in the cable tunnels is very
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limited, the number of design changes is extremely high, and it appeared to the team that
many may have been avoided with sufficient conceptual design stage plant walkdowns.
In addition to the modifications above, the team reviewed several nuclear safety evaluations to assess the quality of the safety evaluations and to establish if an adequate basis was documented to determine if an unreviewed safety question was involved.
Plant safety evaluations are documented in accordance with Modification Control Manual Procedure MCM-4, " Nuclear Safety and Environmental Evaluations." The team reviewed j
the following nuclear safety evaluations:
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JAF-SE-93-023, " Removal of Cable Tunnels Pressurization From Service."
.l JAF-SE-93-027, " Power RCIC Pump Enclosure Exhaust Fan 13FN-2A From LPCI
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JAF-SE-93-005, " Downgrading the QA Category of the Refueling Interlocks for QA
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Category I to M."
JAF-SE-93-020, " Safety Related N2 Pressure Boundaries."
e The safety evaluations reviewed were detailed and technically sound. Each safety evaluation documented an adequate basis for determining that an unreviewed safety question was not involved with these modifications.
2.4.4 Modification Prioritization The team reviewed Work Activity Control Procedure (WACP) 10.1.39, which describes the process for prioritizing proposed plant modifications and observed a meeting of the licensee Engineering Prioritization Committee. The process of prioritizing work was generally good.
The committee, which is made up of representatives from the maintenance, I&C, operations, performance, planning, site engineering, system engineering, and the work control center departments, met to discuss proposed modifications, some of which have been pending for several years. The modifications were prioritized based on the results of bene 6t/ cost questionnaires that evaluate the impact of the modification on plant safety, performance, and regulatory compliance. The results were converted into dollar based benefits and risks by algorithms used by the planning department. Any modification with a benefit / cost ratio greater than three was put on the active work list of modifications to be prioritized.
Currently, there are 600 proposed modi 6 cations, all of which have now been screened by the committee.
The process worked well in general but the team noted that there still seemed to be some minor concerns. The flow chart in WACP-10.1.39 was rather complicated and discussions with the site engineering department revealed that a simplified version of the chart was used in actual practice but had not yet been incorporated into the procedure. This procedure.
revision is an overdue work item that had been scheduled for completion in March 1993.
The team also noted f hat a safety significant modification had not been scheduled to work and was given a low yisrity by the work control center. The rnodification to the control room ventilation system was first proposed in 1987 but was not screened by the committee until the meeting observed by the team. When questioned by the team on why it took so long to screen the modification, the licensee explained that the modification ww part of a large backlog of proposed modifications that developed during years of weak performance of project management completion. The team also questioned why the modification was not scheduled to be worked. The licensee stated that the modification would be worked during the next refueling outage.
The team reviewed the screenwell level modification package (M1-92-187) and noted that it was first proposed in 1992. Discussions with the cognizant engineer indicated that the modification was first proposed by the system engineer in November 1990 following a plant trip due to leaves and debris clogging the travelling screens. The proposed modification
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package was prepared in March 1992 but was not scheduled to work, even though it had a high benefit / cost ratio. The modification was prioritized and put on the work schedule in i
March 1993 by the prioritization committee at the request of management following the February 1993 plant scram due to icing of the intake structure that resulted in low screenwell level. Had the modification been installed following the 1990 scram, the control room operators would have had additional indication of intake level, which may have improved the response to the February 1993 frazzle ice scram.
The team concluded that the prioritization process is much improved over years past, but it appears that additional improvements in this area are warranted.
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2.4.5 Temporary Modifications The team reviewed the temporary modification (TM) process. Previous NRC inspection activities had expressed concern regarding the control and use of TMs as well as the number of outstanding TMs that remained installed for extended periods. Currently, jumpers, lifted leads, and temporary modifications are controlled by station procedure WACP-10.1.3. The team determined that the procedure provided appropriate definition, review and evaluation, installation and restoration controls, and periodic auditing of the TM process. Additionally, team discussions with selected managers and staff members of the operations and technical services sections concluded that management expectations and TM process requirements were well understood by station personnel most responsible for implementation control.
At the time of the inspection, the installed TM backlog had increased to 68, with 35 items outstanding for greater than six months. Approximately ten recent TMs were issued to control leak scalant repair activities for balance of plant equipment. The team noted that permanent modifications were either being designed or had been issued as appropriate for outstanding TMs. Additionally, specific outage and operating plant conditions necessary to accomplish installation of permanent modifications were identified. However, because scheduling and planning programs were still evolving during the inspection, the licensee was not able to project specific long term closure schedules for TMs that would include specific staffing, procurement, and funding readiness. Temporary modification closure to permanent
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modifications are scheduled using the two week and thirteen week rolling work and system window scheduling process. Notwithstanding the current lack of long term scheduling -
capability, the team review of the licensee TM summary report concluded the backlog was well tracked and managed and was a visible indicator of high priority for senior station management.
The team reviewed the jumper, lifted lead, and temporary modification log and determined the index was current and all control forms were present and properly documented.
Additionally, the team conducted a detailed review of the following active TMs:
TM 93-074: Safety relief valve high tailpipe temperature TM 93-026: Intake bay level indication
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TM 93-084: HPCI valve stem extension j
TM 93-089: RBC portable demineralizer
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The TMs were prepared in accordance with procedure WACP-10.1.3. The team verified the Geld installations, control tagging, procedure revisions, and drawing annotations.
Additionally, team discussions with selected licensed operators determined proper knowledge of the TMs and affected procedures and drawings was evident. TM 93-074 was of specinc note Previously, safety relief valve (SRV),02RV-71K had exhibited a high tail pipe.
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temperature causing centinuous annunciation of control room alarm 09-04-1-16, "SRV leaking". The continuous presence of the alarm had the potential to mask leakage from any of the remaining SRVs. Therefore, TM 93-074 was issued to increase the high tailpipe temperature alarm setpoint for SRV 02RV-71K to its maximum setting as recorded on back panel recorder 02TR-166, such that annunciator 09-04-1-16 cleared. Compensatory measures were established to utilize acoustic monitor indication to determine SRV 02RV-71K status.
Additionally, annunciator 09-(M-1-16 alarm response procedure was revised indicating the setpoint change to the affected SRV.
The team also reviewed the results of the three most recently conducted semi-annual TM status audits conducted by the operations section. The audits completed on June 12, 1992,
November 3,1992, and May 14, 1993, were conducted in accordance with Operations Surveillance Test-lQ, Protective Tagging and Jumper / Block / Leads Lifted Verification. The audits ensured proper administration of TM documentation and also required field walkd. owns to ensure TM configuration control had been maintained.
The team concluded that the TM process was being effectively implemented. Station management was sensitive to the usage of TMs and placed priority on managing and minimizing the existing backlog. Implementing procedures were determined to be adequate and established appropriate administrative and performance controls.
2.4.6 Communications
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The team observed the interface among the engineering organizations at the site and at the corporate office and interviewed several engineering personnel. The team followed the development of emergent issues that occurred during the inspection period to assess the interdepartmental communications and coordination. Communications between the various site groups were enhanced by the recent move into the new administration building that was ongoing during the inspection. The onsite personnel stated that communications were much improved among the departments and they were receiving adequate support from the corporate office.
The team attended the daily morning meeting of the Technical Services department and found it to be an effective way of keeping everyone within that organization abreast of the important day to day issues. The meetings were attended by lead system engineers and the Technical Services Manager. A daily report was generated for the meeting that highlighted
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plant status, high priority emergent plant deficiencies, engineering work issues, various
department action items, and staffing issues. The meetings were brief, structured, and well focused but still maintained an cpen forum for discussions on topic issues. The manager was
updated on all pertinent issues so that he was prepared for the daily morning Department Managers meeting. The team also observed this meeting and found it to be effective in
identifying and resolving issues involving the integrated operation of the plant.
i The team was present at the weekly conference call between the site engineering department t
and the corporate office. There was good exchange ofinformation between the two groups
concerning the status of currently ac.tive tasks as well as emergent issues. The team also attended the monthly engineering meeting that included representatives from all the
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The team concluded that overall interdepartmental communications and coordination were much improved, with onsite and offsite organizations aware of issues concerning other organizations and proper support was being provided as necessary.
2.4.7 Technical Services Backlog and Support to Plant Issues t
Technical Suncort to Plant Issues The team assum 2 lechnical services section support to emergent issues identified during the inspection period as well as selected technical issues that had been under extended evaluation.
As was discussed previously in Section 2.4.6, significant improvements in interdepartmental communications have resulted in a better flow of real time information between plant operations and the various technical support disciplines. Consequently, the technical services section has been more involved in the support and resolution of emergent plant issues.
Specifically, good interdepartmental communications and technical information exchange was
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noted regarding potential electrical separation and single failure concerns regarding missing face plates on two reactor protection system relays. System engineering promptly evaluated
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electrical hot short circuit potential from external wiring. Additionally, corporate engineering evaluated potential single failure scenarios and seismic qualification. The
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evaluations concluded the as-found condition did not present an operability issue. The team j
determined the licensee analysis of this condition was comprehensive with sound technical
bases.
The team also reviewed several longer term technical evah2ations of plant deficiencies. Two separate issues involved anomalous operational performance of the shutdown cooling mode of
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the residual heat removal (RHR) system and a third issue involved several design and
operational deficiencies in the control ventilation system. Initially, technical services has l
conducted a long term evaluation of numerous automatic shutdown cooling system (SDC)
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isolations that have been experienced intermittently throughout plant life. The isolations have
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occurred due to SDC system pressure switch actuations in response to high pressure signals that have not been reflective of actual reactor vessel pressure. System engineering has i
conducted an extended evaluation of these events that included system design, instrument configuration, component maintenance history, and operational procedure compatibility with design. The evaluation has preliminarily concluded the isolations have been caused by air in
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the instrumentation tubing to the pressure switches that in turn cause brief pressure spikes l
upon dynamic changes to the system. The team reviewed the draft evaluation report, i
reviewed system drawings, performed walkdowns of accessible portions of the system, and j
interviewed the cognizant lead engineer. To date, the evaluation has been comprehensive, supported by sound causal analysis and diagnostic testing.
More recently, system engineering has been supporting the evaluation of a motor failure on
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the actuator of RHR injection valve 10MOV-25A. The motor failed on July 22,1993, during SDC system isolation logic testing. Root cause analysis has initially concluded the
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motor failure was the result of an inadequately sized actuator brake mechanism. The review further identified a potential common mode failure concern. Specifically, when in the SDC mode of operation, the SDC system isolation logic seals in a close signal to the 10MOV-25A&B valves upon receipt of a low reactor water level or high drywell pressure isolation signal. The valves will stroke full closed and the motor will deenergize on torque switch actuation. However, because the actuator brake is insufficiently sized, the actuator gearing may relax, causing the torque switch contacts to reclose and the motor to reenergize although the valve disk remained fully in the closed seat. This iteration may continue until motor failure occurs. The team reviewed the initial licensee operability determinations, reportability evaluations, and the action plan for short term and long term corrective actions.
The team concluded the licensee evaluations to date had referenced appropriate design bases documentation, including applicable Technical Specifications, FSAR description, and design bases dacumentation.
Additionally, the team reviewed the control room ventilation system to assess the quality and timeliness of the technical support provided to resolve several system deficiencies. Durir.g a review of an industry operating experience report, the licensee identified a single failure vulnerability in the control room ventilation system. The single failure vulnerability was caused by an open manual bypass damper that allows flow around a motor-operated inlet isolation damper (Licensee Event Report 93-19). The manual bypass damper was not included in the plant drawings. On July 9,1993, the licensee took appropriate interim corrective action and placed he control roem ventilation system in the isolate mode of operation. During the next two months, several additional system deficiencies were identified by the licensee. On September 13,1993, the licensee identified that the supply and exhaust isolation valves did fully close. On September 25,1993, the leaks in the valves were scaled. The System Engineering group had developed an action plan to place the control room ventilation system back to the normal mode of operation. Since July 1993
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there have been 5 Deviation Event Reports, approximately 18 PIDs,1 Design Document Open Item, and several action plans and action plan updates issued as a result of various deficiencies on this system.
Team reviews identified discrepancies in the Final Safety Analysis Report (FSAR) Section 9.9.3.11, " Control and Relay Room Air Conditioning System," regarding the operation of the control room ventilation system. The FSAR states that if the operating control room air handling unit fans or the recirculation exhaust fans fail, then the complete spare system automatically starts." However, the system installation is such that only the redundant fan and support equipment automatically start. The licensee stated that a safety evaluation and FSAR revision would be documented.
The team also identified a discrepancy between the FSAR and the plant operating procedures.
The FSAR states that the emergency air intake should be switched from the secondary to the
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primary in the event of a LOCA or a tornado. Abnormal operating procedures for tornadoes
incorporate this change, but the procedures for LOCAs did not. The licensee stated that the PORC had determined that switching of the intakes during a LOCA event was not required.
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However the FSAR update was not revised. The licensee stated that the FSAR would be revised to correctly describe for which conditions the intakes would be switched.
The team noted that the automatic start of the recirculation exhaust fans had been disabled by placing the standby exhaust fan in pull-to-lock. The cognizant engineer stated that a problem with the design of the associated actuating differential pressure switch was the most likely cause for this deficiency. A work request was written to implement a design change to correct this problem in 1987. A modification to correct this problem has not been initiated due to a previous lack of a comprehensive modification prioritization system. The work request was recently prioritized and the current plan is to implement a design change to correct this problem during the next refueling outage.
The licensee identified that the differential pressure indicating controller (DPIC-100), that maintains the 0.125 inch pressure in the control room was not being surveillance tested and was not operable. The licensee repaired the differential pressure controller and included this instrument in the preventative maintenance program. Technical specification 4.11.3 states that the differential pressure switches must be tested each cycle but does not specifically require surveillance testing of differential pressure controllers. The differential pressure switches, which provide alarms for high filter differential pressure and detect fan failures, are tested each cycle in accordance with ISP-85, " Control Room Ventilation Temperature and Differential Pressure Instrumentation Calibration." The team noted that the preventative i
maintenance interval was two years which was in excess of the once per cycle requirement for the differential pressure switches. The licensee stated that a complete evaluation of the control room ventilation system instrumentation would be conducted as part of the control room ventilation action plan to assure that the appropriate instruments were being routinely
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surveilled. In addition, the licensee stated that a technical specification interpretation would be generated to clarify the control room ventilation technical specification and the associated -
surveillance requirements.
At the time of this inspection, the control room ventilation system is operating in the isolate mode with the inlet and exhaust dampers closed and scaled. In this configuration, the system will perform it's intended safety function. However, the team concluded that the management attention provided to operation, maintenance, and testing of this system had been weak. While recent improvements were noted in the technical support provided to this system, the overall progress in restorh g this system to its intended design basis configuration i
has been slow. The team noted that a lack of detailed design-basis documentation had contributed to the delay in returning this system to the normal mode of operation. The design-basis documentation schedule was revised to increase the priority for completing the design-basis for ventilation systems. Additional management attention is warranted to ensure that this system is restored to its normal mode of operation and the system is maintained and
tested to assure that it can perform its design-basis function.
Evaluation and resolution of each cf the RHR technical issues above were ongoing at the conclusion of the inspection period; however, the team concluded the technical services department had displayed proper safety and regulatory perspectives in the development of preliminary plans of action for final resolution. The team concluded that the licensee had not aggressively pursued resolution to the numerous existing control rc ventilation system design and operational deficiencies. Further, due to the diversity of the technical, operational, and procedural weaknesses, it appeared that a well coordinated multi-disciplined analytical approach would be necessary to ensure the comprehensive restoration of the design and operational system bases.
Technical Services Backlog The team also reviewed the technical services department action item backlog. As discussed previously, the engineering organization and the technical services department are evolving structurally and in actual staffing levels. Tecimical services department has historically maintained a large workload and backlog of action items. Recently, the department initiated a comprehensive data base tracking program for action items. The data base was the first effective effort to clearly defime all department responsibilities and was being reviewed by
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other sution departments for applicability. The team concluded the data base to be a powerful management tool that was complete, with a software program that was extremely flexible in its capability to trend, highlight, and differentiate closure responsibility for each
item. However, the data base clearly demonstrates that the department continues to have a very large backlog of items that remains a significant management challenge. While it appeared that the department had recently accomplished a leveling of backlog growth, the team was unable to assess the full impact of the additional resources provided by the recently hired system engineers on actual backlog reduction due to extended initial qualification
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training requirements. To department management credit, initial training has been maintained as the highest priority for the new engineers, a commitment clearly at the expense of short term department productivity.
The team concluded the data base tracking program was a good initiative that provides management with an effective performance indicator capability. Additionally, the team recognized the effect of management commitment to new hire system engineer training on action item backlog status. Notwithstanding, the team concluded continued management attention is necessary to ensure organizational changes are well controlled and the action item backlog is effectively reduced. Finally, the team concluded the vast majority of the technical services department resources are currently devoted to emergent issue response and action backlog item closure to the extent that the department is largely reactive and not yet in a position to establish an independent agenda of proactive initiatives and special projects to enhance safety system performance.
2.4.8 Master Equipment List and Configuration Control Master Eauipment List The team reviewed the Component Classification Upgrade Procedure, EDP-31 and observed a backlog of 5,200 component evaluations that were not yet completed. The RATI performed in October 1992 had identified 6,000 evaluations that were not completed but stated that programs were in place to address the backlog. The licensee stated that a contractor was hired to perform the evaluations but after a few months had not made satisfactory progress in evaluating the components, and the contract was cancelled.
Discussions with the licensee indicated their intent to hire an individual familiar with the qualification process and to oversee reduction of the backlog; however, as yet the individual has not been hired. The team also reviewed a report by the licensee's quality assurance department (QA Audit No. 810, QA Classification Program) and found that, in addition to the untimely completions of the backlog, some documentation requirements were not being s
met, including concerns such as personnel with no formal training performing the evaluations, individuals signing off forms without documented authorization, and the use of unauthorized position papers to clarify the procedure in lieu of procedural revisions.
The team identified the implementation of the QA Classification Program as weak and concluded additional management attention is necessary to ensure components already evaluated were properly classified and the remaining 5,200 component evaluations are completed in a timely manner.
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Confieuration Cqnimi The team review of IN eonfiguration control program was primarily focused on the drawing
control and revis6n process and the design basis documentation program. Previously, NRC inspection actis 1 ties have noted an excessive number of plant drawings with modification and
change notice revisions outstanding. Additionally, in light of recent plant issues including the frazzle ice reactor trip and the identification of various control room ventilation deficiencies, the team assessed the effectiveness of the systematic reconstruction of selected system design bases.
Revisions to drawings are generated either by permanent modifications and associated field changes or by cocument (drawing) change requests (DCRs) that have identified drawing discrepancies with existing system installations. The drawing revision program is implemented in accordance with station procedure AP-02.07, Drawing and Design Document control. The team discussed the current drawing backlog with corporate and station configuration management. Currently, there are a total of 1,107 outstanding drawing revisions of which,260 are related to DCRs, that are awaiting site engineering or technical services screening for field verification. Corporate configuration management trends the closure status of drawing backlog timeliness after the revisions are received from the responsible plant discipline. At the time of the inspection, configuration management was trending the remaining 847 drawing revisions, with a total of 89 revisions outstanding beyond required update period. The team also reviewed the flowchart process for the computer aided design " Red Line" drawing revision process. The system established positive controls, with several reviews and independent verifications, that ensure drawing and plant fidelity.
The team concluded thu the configuration management section was effectively managing and minimizing the drawing revision backlog. However, it appeared that the management attention to the onsite technical services and site engineering departments is warranted to reduce the backlog of proposed revisions awaiting field verification.
Additionally, the team reviewed design basis consolidation program. The program is implemented via configuration management program manual, CMM 2.1, Control of Design Basis Documents (DBDs) and Fire Protection Reference Manuals (FPRMs). The procedure established appropriate licensee controls, technical expectations, and writer's guidance to ensure consistent contractor performance in the development of DBDs. To date, the licensee
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has completed six system DBDs at JAF. Three additional system DBDs are projected to le completed in the remainder of 1993, with two more systems to be completed in 1994. The team discussed program objectives with the cognizant project manager and concluded the-expectations of the implementing procedure were being properly executed. Additionally, the
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team reviewed the completed DBDs for the residual heat removal and service water systems.
The documents were consistent with the writer's guide and were technically complete with supporting references and calculations clearly delineated. The team noted the use of DBD information in the development of initial technical positions in response to the RHR injection
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valve actuator motor failure event discussed in section 2.4.7 above. The team concluded the design basis consolidation program is a positive licensee initiative and is being effectively integrated into station production organizations.
2.4.9 Conclusions In summary, the team concluded the licensee maintained previous performance while continuing or implementing programs to improve engineering and technical support functions. Specifically, improved interdepartmental communications and coordination were evident within the engineering organization as well as externally with the opemtions and maintenance departments. Increased staffing of the system engineering position in conjunction with a strong initial training program were viewed as strong initiatives. Overall, the permanent and temporary modification programs were being effectively implemented.
Associated safety evaluations were determined to be detailed and technically sound.
However, the planning, prioritizing, and scheduling of modifications was an area that continued to warrant improvement. Technical support to plant issues was observed to be generally much improved. However, weaknesses in development of a structured resolution plan to numerous control room ventilatior. system deficiencies was a notable exception.
Performance at resolving longstanding configuration control issues was mixed. Little progress was made at addressing the master equipment list qualification backlog. However, configuration management has effectively managed the reduction of the drawing revision backlog. Additionally, the design basis consolidation program has developed high quality design basis documentation manuals that appeared to have been effectively implemented into station organizations. Overall, engineering management continues to be challenged by a significant action item backlog that to a large extent dictates organizational agendas.
However, technical services has developed a comprehensive data base that for the first time provides department management with a powerful tool to trend reduction effort effectiveness and identify areas that warrant further attention.
3.0 EXIT MEETING The team met with those denoted in Appendix A on November 2,1993, to discuss the preliminary inspection findings that are detailed in this report. The exit meeting was open to the publi,
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APPENDIX A PERSONS CONTACTED
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New York Power Authority B. Barrett, General Manager-Operations
R. Beedle, Executive Vice President-Nuclear Generation
P. Borer, Acting Vice President-Nuclear Engineering
M. Colomb, General Manager-Support Services
R. Flynn, Chairman-NYPA
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W. Josiger, Vice President-Nuclear Support
D. Lindsey, General Manager-Maintenance
H. Salmon, Jr., Resident Manager-FitzPatrick
Nuclear Regulatory Commissina_fNRC)
C. Cowgill, Chief-Projects Branch 1
J. Menning, NRR Project Manager
J. Tappert, Resident Inspector, FitzPatrick
Denotes attendance at the public exit meeting held at James A. FitzPatrick Nuclear
Power Plant, November 2,1993.
Note: The list of NYPA persons contacted does not include every individual contacted during this inspection. The key persons involved in the inspection are included in the list.
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z ATTACHMENT l'
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OPERATIONAL SAFETY TEAM INSPECTION JAMES A. FITZPATRICK NUCLEAR POWER PLANT
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NRC INSPECTION 50-333/93-82
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EXIT MEETING
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NOVEMBER 2,1993 e EXIT MEETING BETWEEN NRC AND LICENSEE.
- NRC WILL ADDRESS PUBLIC QUESTIONS REGARDING TEAM FINDINGS.
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OPERATIONAL ~ SAFETY TEAM. INSPECTION'-
JAMES A. FITZPATRICK NUCLEAR POWER PLANT
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NRC INSPECTION 50-333/93-82 EXIT MEETING INSPECTIO'N OBJECTIVE i
e CONDUCT A PERFORMANCE-BASED INSPECTION-TO EVALUATE THE EFFECTIVENESS AND l
MANAGEMENT SUPPORT OF PROGRAMS THAT i
PROMOTE SAFE PLANT OPERATION.
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- AREAS REVIEWED:
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MANAGEMENT PROGRAMS.
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SELF-ASSESSMENT.
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o CORRECTIVE ACTION PROGRAM.
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ENGINEERING AND TECHNICAL SUPPORT.
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MANAGEMENT PROGRAMS
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- PLANT AND CORPORATE MANAGEMENT TEAMS ARE COMMITTED TO ACHIEVING IMPROVED PERFORMANCE.
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- STRONG MANAGEMENT INVOLVEMENT IN
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RESOLUTION.
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- MANAGEMENT FOSTERED A STRONG NUCLEAR SAFETY WORK ETIIIC.
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SELF-ASSESSMENT
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- EFFECTIVE MONITORING OF CORRECTIVE j
ACTION PROGRAM.
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- SAFETY ISSUES BEING IDENTIFIED TO
APPROPRIATE LEVELS OF MANAGEMENT.
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- QUALITY ASSURANCE AND SAFETY OVERSIGHT-l GROUPS PROVIDE TIMELY AND EFFECTIVE j
SELF-ASSESSMENT.
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- SIGNIFICANT RECENT ORGANIZATION CHANGES l
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AND SEVERAL IMPROVEMENT PROGRAMS -ARE
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CURRENTLY IN PROGRESS.
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CORRECTIVE ACTION PROGRAM
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- EFFECTIVE PROCESS FOR THE IDENTIFICATION
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OF PLANT DEFICIENCIES.
- PERFORMANCE OF THE ROOT CAUSE EVALUATION PROCESS IS MIXED.
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- COR~RECTIVE ACTION PROGRAM HAS IMPROVED AND IS CURRENTLY WELL DEFINED.
- PAST WEAKNESS IN THIS AREA IS STILL AFFECTING PLANT PERFORMANCE.
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ENGINEERING A'ND l
TECHNICAL SUPPORT
.i e MANAGEMENT OF THIS ORGANIZATION IS CURRENTLY IN TRANSITION.
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- IMPROVEMENTS NOTED IN COMMUNICATION
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AND CORPORATE SUPPORT OF PLANT.
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- BACKLOG OF-WORK ARE HIGH. MANAGEMENT.
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ATTENTION STILL REQUIRED IN THIS AREA.
- TECHNICAL RESPONSE TO EMERGENT ISSUES-
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IEQUIRES CONTINUED MANAGEhENT I
ATTENTION.
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- STRONG MODIFICATION PROGRAM.
- PRIORITIZATION, PLANNING AND SCHEDULING 1 j
OF ENGINEERING WORK NEEDS CONTINUED l
MANAGENENT SUPPORT.
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