IR 05000354/1998099
| ML20248M029 | |
| Person / Time | |
|---|---|
| Site: | Hope Creek  |
| Issue date: | 06/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20248M027 | List: |
| References | |
| 50-354-98-99, NUDOCS 9806120260 | |
| Download: ML20248M029 (5) | |
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Enclosure 1 SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE HOPE CREEK GENERATING STATION Report No. 50-354/98-99 l.
BACKGROUND The SALP Board convened on May 20,1998, to assess the nuclear safety performance of the Hope Creek Generating Station for the period from November 10,1996, through May 16,1998. The Board was conducted pursuant to NRC Management Directive (MD)
8.6 (see NRC Administrative Letter 93-20). The Board members were James T. Wiggins (Board Chairman), Director, Division of Reactor Safety, Region 1 (RI); Richard V. Crienjak, Deputy Director, Division of Reactor Projects, Rl; and Robert A. Capra, Director, Project Directorate 1-2, Office of Nuclear Reactor Regulation. The Board developed this assessment for the approval of the Region I Administrator.
The performance ratings and the functional areas used below are described in NRC MD 8.6, " Systematic Assessment of Licensee Performance (SALP)."
II.
PERFORMANCE ANALYSIS - OPERATIONS The conduct of operations has been good with operator performance showing steady improvement since the fall 1997 refueling outage. The Hope Creek facility has operated continuously since completing the outage, and licensed and non-licensed operators have operated the plant essentially error-free since completing that outage. Overall, improvement was attributed to an increased emphasis by management on high performance standards and the implementation of a peer check policy.
Operators performed very well during most major planned evolutions. For the first-ever reactor vessel drain-down in support of maintenance activities during the outage, the operations department developed and flawlessly executed the procedure. The operators also conducted an error-free reactor startup after the outage despite a number of equipment failures. Further, operators responded well to plant transients, including recent problems experienced in the electro-hydraulic control system and a control rod drive pump trip. Operators' conservative approach to plant operation was demonstrated, in one example, by initiating a manual scram during the September 1997 main power transformer f an f ailure.
In contrast, however, at various times, control room operators did not exhibit a conservative decision-making approach. A significant lapse in the judgement of the control room operators occurred when established standards for reactivity and control rod manipulations were not adhered to during a shutdown margin demonstration in November 1997. Relative to evaluating degraded equipment conditions, on three occasions, operators were slow in declaring safety-related equipment inoperable, in June 1997, l
operators also made a poor decision to remove the 'A' and 'C' residual heat removal
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subsystems from service while the operability of a high-pressure coolant injection system valve was in question.
-Operator training and requalification was generally good until the end of the assessment period. Early in the period, the operator requalification program was considered very good.
This was based on quality examinations, thorough and detailed evaluations of performance and excellent operator performance. However, problems with an NRC initial license examination in February 1998 indicated a decline in performance. Administration of the
- exam was delayed because the initial written examination was unacceptable. Also, for this exam, reactivity manipulations had to be redone by some candidates because of inefficient program controls, criteria and data recording.
Quality Assurance reviews and audits, and operations department self-assessments provided for frequent oversight of operating activities. In general, these activities were
. effective in improving performance. One important Quality Assurance lapse involved a
- missed opportunity to identify operators' failure to meet management s andards for reactivity control, while monitoring the performance of a shutdown margin test.
Subsequently, the operations department performed a comprehensive self assessment of operator performance during the test and provided prompt and objective performance feedback to station management. The offsite Nuclear Review Board met frequently and completed high-quality assessments of station activities.
' The operations area is rated Category 2.
II.
PERFORMANCE ANALYSIS - MAINTENANCE During the assessment period, maintenance performance was' good overall. A Maintenance intervention was conducted early in the period to address recognized maintenance performance weaknesses. However, some issues continued to challenge the organization,
" demonstrating the need for further corrective actions. Notwithstanding the maintenance performance problems and emergent issues that arose during the extended outage, the licensee completed a significant amount of maintenance and modification work. After the outage, the work control process showed notable improvement. The on-line maintenance -
program appropriately factored risk into the scheduling and performance of maintenance, and it was effective at balancing the benefits gained from preventive maintenance and the added risk associated with equipment unavailability. Key to the improvement seen in the on-line maintenance program was the use of the Work-it-Now (WIN) team to appropriately screet prioritize and work newly identified corrective maintenance (CM) items. The WIN team was successfulin reducing the CM backlog by more than half by the end of the period.
Weak management oversight of both maintenance personnel and the work control process prior to and during the startup following the outage resulted in some procedure violations, I
work coordination errors and the extended unavailability of some safety systems.
Problems includod a core spray piping leak and rework associated with the high-pressure coolant injection system, the emergency diesel generators and the reactor core isolation l
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cooling (RCIC) system. Further, several performance problems during the outage were attributable directly to poor supervisory oversight of contractor personnel.
The material condition of the facility generally improved during the period. Technically sound upgrades made to snubbers served to preclude previously experienced maintenance problems. Near the end of the period, there were some discrepancies noted regarding
- material condition and equipment control in the service water intake structure.
Self-assessments and root cause evaluations of maintenance activities and their associated l
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i corrective actions were usually good, indicating an effective management focus in these areas. For example, because of poor work performance during the outage, site management conducted a high quality and thorough self assessment. Several corrective actions were developed which appropriately focused on the identified root causes Actions to address poor contractor performance included developing a plan to maintain an appropriate outage supervisor to craft ratio and reviewing contractor qualification
documentation. In addition, the licensee established an outage organization to centralize l
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overall outage planning, scheduling and coordination.
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The technical specification surveillance program was adequately implemented. However,
- management was slow to recognize a declining trend that was largely related to not performing surveillance tests on time. ' Some additional problems were noted with procedure quality and the conduct of the tests. The Inservice Inspection program was appropriately implemented. However, a prior failure to detect and repair a core spray L
nozzle weld flaw during a focused ultrasonic inspection highlighted a significant weakness.
The Maintenance area was rated Category 2.
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PERFORMANCE ANALYSIS - ENGINEERING
.Throughout the period, management oversight and involvement in engineering activities typically produced good results. For much of the period, the licensee committed considerable engineering resources to the restart of the Salem units. Also, during the
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l second half of the period, the engineering work groups underwent extensive l
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reorganization. Nevertheless, engineering management provided appropriate leadership and
. guidance to the staff, Audits and surveillance of engineering programs, and periodic internal self-assessmer:ts were effective in identifying and resolving issues.
i The threshold for problem identification was maintained at an appropriately low level.
Engineering personnel were knowledgeable of the corrective action process and used it to I
effectively document identified deficiencies. Where safety concerns were involved, root cause analyses were usually detailed and thorough. Resolution of identified deficiencies j
was typically acceptable. There were some examples of poor performance. The engineering review of NRC Information Notice 97-53 regarding seismic qualification of low-
voltage switchgear with breakers in withdrawn position was incomplete and narrowly focused. In'another example, the operability review of Struthers-Dunn relays addressed only those relays that showed clear signs of age degradation. As a result of the heightened focus on Salem and of the staff reorganization, the backlog of engineering
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activities grew. Nonetheless, items in the backlog were properly reviewed for impact on safety and were suitably prioritized.
The quality of engirieering suppo:t providad to operations and maintenance was somewhat inconsistent. For instance, the engineering review of a reactor water cleanup pump outage was thorough and critical. However, the analysis used to support the operability of various normally energized control relays in a harsh environment was incomplete. Typically, timeliness of operability and deportability determinations was commensurate with the significance of the issues. Further, while the operating experience program evaluated and dispositioned incoming information in a timely manner, resolution of some issues was not
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The design change process was supported by comprehensive procedures, and implemented well. Sound engineering principles were generally used in design activities. However, some examp!ss were identified in which design controls were not effectively implemented.
. For example, when the design margin in a battery capacity calculation dropped below the value specified in the FSAR, engineering failed to recognize the purpose of the margin, and inappropriately pursued an FSAR change. In another example, temperature sensors for detecting steam leakage in the high pressure coolant injection and reactor core isolation cooling (RCIC) rooms were relocated to address nuisance system isolations. However, the review of the design changes failed to address their impact on the system isolation setpoiats defined in technical specifications. Safety evaluations were usually thorough and
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supported by good technical bases. However, some examplos existed, such as the modification to delay the RCIC turbine trip on high reactor vessel water level, where insufficient attention to detail resulted in the safety evaluation applicability review conclusions being inaccurate. The number of temporary modifications has been reduced and the safety evaluations for them were typically acceptable.
Partly due to personnel changes during the recent licensee consolidation efferts, system.
. engineering underwent a transition and the effectiveness of system monitoring varied. For example, no component level monitoring of the traveling screens was taking place, despite the evidence that their poor performance was the largest contributor to the station service water system unavailability. On the other hand, a thorough analysis of recorded inservice
- testing data for a service water pump identified a degraded condition without the need for an intrusive inspection of the pump. In addition, while initial efforts to impeement the Maintenance Rule were not successful, the licensee completed a comprehensive effort that resulted in the establishment of a high-quality program.
In.the licensing and design basis area, licensing submittals were usually timely and technically correct. In addition, in response to an NRC enforcement action, the licensee
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completed a detailed review of the scope of surveillance testing and the adequacy of test procedures. Also, the licensee identified and corrected several noteworthy design issues, such as the potential unmonitored release path through the service water system and the ability to lose both trains of control room ventilation on a loss of control air. However, in the latter example NRC involvement was necessary to ensure proper testing and
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configuration of the design change. The existence of these design issues reinforced the need for the licensee to carry through on its commitments in response to the NRC 10 CFR 50.54f letter.
The Engineering area was rated Category 2.
IV.
PERFORMANCE ANALYSIS - PLANT SUPPORT The radiation protection program was established, implemented and maintained effectively.
In particular, surveys, radiological postings and control of high radiation areas, ALARA i
reviews, dosimetry control, and adherence to radiation protection procedures by the station i
workforce were excellent. Radiation protection self-assessments demonstrated acceptable problem identification and resolution. The solid radwaste transportation program was effectively implemented, with only minor deficiencies identified with respect to audits of offsite processing vendors.
j The radioactive liquid and gaseous effluent control programs along with the radiological environmental monitoring program and the meteorological monitoring program were successfully maintained and implemented. The chemistry program was effectively implemented however, occasional performance deficiencies caused by inadequate communications were observed with respect to maintaining appropriate standby liquid control storage tank boron concentration.
Positive changes made during the period upgraded performance in the emergency preparedness program, in 1997, the Emergency Preparedness area was reorganized.
i Performance improvements were supported by senior management. Senior managers a!so provided more oversight of program implementation. As a result, the emergency exercise training program was significantly upgraded as evidenced by very good performance during a March 1998 emergency exercise.
In addition, the licensee significantly upgraded and strengthened the security program.
Management support for the security program was evidenced by the procurement of new radios to improve communication capabilities, new weapons, upgrades to the firing range, the installation of new x-ray machines, and installation and implementation of an improved personnel access control system. Work requests for security equipment and repairs were normally completed within the same day, with compensatory measures promptly instituted when needed. Security equipment problems were appropriately tracked and trended.
The fire protection program was effectively implemented. Combustibles were well controlled. The fire brigade was well staffed, trained and qualified. Quality asnrance audits in the area were focused appropriately and timely corrective actions taken for l
identified deficiencies. However, fire protection technicians did not identify and correct l
inoperable emergency lighting units in a timely manner. Station housekeeping was acceptable, but declined somewhat during the refueling outage.
The Plant Support area was rated Category 1.
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