IR 05000382/1993099

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SALP Rept 50-382/93-99 for 920802-931030
ML20058K633
Person / Time
Site: Waterford Entergy icon.png
Issue date: 12/10/1993
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20058K477 List:
References
50-382-93-99, NUDOCS 9312150342
Download: ML20058K633 (6)


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Waterford 3 SALP Report No. 50-382/93-99

I.

Introduction

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The SALP process is used to develop the NRC's conclusions regarding a

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licensee's safety performance. The SALP report documents the NRC's observations and insights on a licensee's performance and communicates.the results to the licensee and the public.

It provides a vehicle for clear communication with licensee management that focuses on plant performance i

relative to safety risk perspectives. The NRC utilizes SALP results when allocating NRC inspection resources at licensee facilities.

r This report is the NRC's assessment of the safety performance at the Waterford-Steam Electric Station, Unit 3, covering the period August 2, 1992, through October 30, 1993.

An NRC SALP Board, composed of the individuals listed below, met on November 4, 1993, to review and assess performance in accordance with the guidance in NRC Management Directive 8.6, " Systematic Assessment of Licensee Performance." The Board developed this assessment for approval of the Region IV Administrator.

Board Chairperson S. J. Collins, Director, Division of Reactor Safety, Region IV Board Members

T. P. Gwynn, Acting Director, Division of Reactor Projects, Region IV D. D. Chamberlain, Acting Director, Division of Radiation Safety and

Safeguards, Region IV W. D. Beckner, Project Directorate IV-1, Nuclear Reactor Regulation i

II. PERFORMANCE RATINGS I

This SALP was conducted under the revised SALP process that was-implemented by the NRC on July 19, 1993. The current SALP process will assess performance in four functional areas instead of the previous seven. The four areas are Plant Operations, Maintenance, Engineering, and Plant Support.

Safety-Assessment / Quality Verification was considered for each of the four functional-areas rather than as a separate functional area. The Plant Support functional area assessed radiological controls, emergency preparedness, security, chemistry, and fire protection. Three category ratings (1, 2, and 3)

continue to be used in the assessment of licensee performance in each

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functional area. Performance trends, improving or declining, have been eliminated as a part of the ratings.

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Current functional Areas and Ratings

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Functional Area Ratino This Period

Plant Operations

Maintenance

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Engineering

Plant Support

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i Previous functional Areas and Ratings:

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Functional Area Ratina last Period Plant Operations

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l Maintenance / Surveillance

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Engineering / Technical 2.

Support i

i Radiological Controls I

Emergency Preparedness

i Security

i Safety Assessment / Quality

Verification III.

PERFORMANCE ANALYSIS A.

Plant Operations Performance in the plant operations area declined from the previous superior l

performance level but remained strong overall. Management involvement in

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daily plant operations at Waterford 3 was good but the degree of senior.

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management presence and involvement in the plant declired during the period.

The rotation of the Operations Manager to another facility also reduced senior

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management presence in the plant and involvement with site activities.

However, when significant issues developed that challenged the continued

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operation of the station, such as when the operability of the containment spray system was in question, senior management involvement increased significantly.

Operators responded in a superior manner to transients during the assessment period, including the prompt and effective response to two reactor trips and a i

reactor cutback. This performance confirmed the high level of capability

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i demonstrated during initial license and requalification training program-l evaluations conducted by NRC. Daily shift turnover activities and control i

room decorum continued to be viewed as superior. Nevertheless, plant operators exhibited a continuing weakness in attention to detail with respect

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to the control of system status and the prompt identification and correction of certain problems. An example of this lack of attention to detail involved

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an inadequate work package review by_ operators that resulted in a reactor

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cutback.

This weakness was also considered to be a causal factor that

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resulted in a decline in safety system reliability. This was particularly

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evident with respect to an emergency diesel generator air receiver valve that j

was left unlocked, and, late in this assessment period, the inoperability of the containment spray _and main steam drain isolation valves and the loss of

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wet cooling tower makeup.

The identification and resolution of issues remained good although the threshold for identification and reporting of problems changed and the i

performance of operability assessments, which had been a significant strength at Waterford 3 during previous assessments, declined during the period. There appeared to be a reluctance on the part of the plant operators to request assistance in performing required operability determinations under the

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indeterminate qu&lification process documented in Site Directive W4.101.

In addition, in at least one case, an informal precursor trending program document was initiated in lieu of a required condition identification. These.

instances indicated weaknesses in the implementation of the corrective action

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program.

It appears that management expectations were not being communicated to the plant staff after changes were made to the corrective action processes in February 1993. Management attention was appropriately focused on resolving

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these weaknesses at the conclusion of the assessment period.

The performance rating is Category 2 in this area.

B.

Maintenance The performance of maintenance activities was consistent with that exhibited during the last assessment period and assessed as superior.

Plant equipment material condition and reliability was excellent. The maintenar.ce backlog was low with middle management's involvement and support in maintenance activities a considerable strength. The peer quality control program was effective in

training maintenance personnel to perform tasks, inspect, and critique peers'

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work.

Developing maintenance personnel as quality control inspectors was an

effective means of increasing quality awareness during maintenance activities.

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The maintenance work force was highly qualified. The work environment was noteworthy and encouraged worker participation and involvement. Worker actions indicated a healthy sense of ownership, including a questioning attitude by workers which was an asset in defect identification.

For example, during an unrelated inspection of the switchgear ventilation system, craftsmen questioned the operability of a damper because its motor operator was abnormally warm. The workers documented the defect and initiated the work authorization to rework the operator.

In another instance, an individual

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trained as a peer quality control inspector identified an apparent scratch in the block of a charging pump. The scratch was subsequently determined to be a crack.

l Plant staff was proactive and thorough in troubleshooting and correcting an.

equipment degradation problem that had resulted in a reactor trip. The trip had occurred because of age-related degradation of capacitors in the plant protection system.

In response to the event, the licensee replaced frequency i

detection cards, initiated a program to increase periodic maintenance checks on frequency cards, and investigated possible failure mechanisms.

Conservatism was demonstrated in the consideration of other potentially degraded capacitors in the plant protection system.

As exceptions to the overall superior performance there were isolated instances of inadequate procedural guidance noted during this assessment

period and examples of lack of management awareness of plant conditions such

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t as easily repairable steam leaks.

The performance rating is Category 1 in this area.

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Enaineerino r

Overall performance in the engineering area was strong. Organizational

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initiatives continued with the consolidation of both the design engineering and system engineering organizations on site in the general services building.

The design engineering organizational structure was flattened with the elimination of the Design Engineering Manager position resulting in the principal engineers reporting directly to the Director, Design Engineering.

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Design engineering has a technically strong and stable staff. The Director, Design Engineering completed licensee management certification training (system oriented) and other engineering personnel are scheduled to attend the

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same training, independence is provided to System Engineering and Maintenance Engineering organizations which report to the operating organization.

The outage risk assessment completed by the licensee resulted in a significant

enhancement to safety for the refueling outage.

Engineering provided

excellent support in establishing the proper placement and connection of the temporary diesel generator.

There was a noted overall improvement in safety evaluations, both in the quality and details in the packages. The licensee's audit of screenings was found to be very objective.

The licensee's design charge program was effectively implemented and clearly identified the required actions for the origination, development, and implementation of design changes, t

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The procurement program and procurement engineering support were viewed as strong - supported by the overall effort within Entergy organization to integrate procurement by taking the best practices from each site and adopting l

the practice system-wide.

l The lack of design calculations for pressure relief valve sizing was a

weakness in the licensee's design basis for valves. A violation related to

pressurizer and steam generator safety set points being outside the Technical Specification limits was indicative of a lapse in an otherwise effective engineering program.

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The extensive reevaluation of the Waterford 3 check valve program and the j

development of a relief valve setpoint document were considered proactive and exceeded the recommendations identified in a 1991 NRC audit report.

The motor-operated valve program was capable of satisfactorily demonstrating

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the operability of motor-operated valves subject to Generic Letter 89-10, and fulfilled commitments. The licensee did a quality job in the performance of degraded voltage calculations and in the identification and correction of the differences between the degraded voltage calculations.

The engineering activities to evaluate the operability of containment spray Valve CS-125A was considered aggressive and of excellent quality once the licensee began to respond to NRC concerns. Design engineering's initial

response was not perceived by the staff to reflect the safety consciousness of

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a design organization with independence from other line organizations, but appeared to be more driven, initially, by operations considerations.

Waterford 3 has continued to have a strong engineering program with further enhancements as noted above. The challenge for design engineering is to

provide a proactive safety consciousness with respect to plant operation.

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The performance rating is Category 2 in this area.

D.

Plant Support The plant support areas generally continued with the strong performance that had been demonstrated during the previous SALP period with management support evident in all areas. Excellent training programs were implemented, and highly qualified staffs were maintained with effective working relationships established within the plant support areas and with other groups.

Excellent self-assessment capabilities had been established within the plant support areas with effective identification and resolution of problems demonstrated.

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Some problems were identified late in the SALP period in the radiological controls area with the adequacy of procedures and procedure implementation.

Also, the emergency exercise conducted during the last week of the SALP period identified two weaknesses related to prceedure implementation for protective action recommendations and slow assessment of plant conditions by the i

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engineering and technical staffs. These problems detracted somewhat from the

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high level of performance demonstrated during the SALP period in the plant

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support area.

The radiological controls area consistently demonstrated strong performance with the exception of isolated problems identified late in the SALP period i

with procedural adequacy and procedure implementation.

Effective ALARA and exposure control programs contributed to very low person-rem exposures for

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1993.

Excellent working relationships existed between the radiation protection department and other organizations. Contaminated areas were maintained at a very low level and strong, effective programs were maintained i

in the areas of liquid and gaseous radioactive waste effluents, radiological environmental monitoring, water chemistry and radiochemistry, and transportation of radioactive materials.

The emergency preparedness area continued with generally strong performance,

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I although some weaknesses were noted during the emergency exercise. Close i

working relationships were maintained with offsite radiological emergency i

response organizations.

Emergency facilities, equipment, and supplies were maintained in a proper state of operational readiness. During the annual exercise, emergency facilities were appropriately placed in a state of i

operational readiness and emergency classifications were timely and accurate.

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Facility shortcomings, which were noted with the operational support center

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and the technical support center, did not adversely affect emergency response

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activities. An excellent critique of the annual emergency exercise was l

conducted with effective identification of problem areas.

Effective implementation of the emergency plan was demonstrated in respor.se to Hurricane

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Andrew.

The security area continued to be a strength with a well-qualified staff and strong management support. A strong security training program was implemented with excellent training aids.

The fire protection area was generally good with fire protection equipment. and personnel maintained in an appropriate state of readiness. Administrative control procedures and the penetration seal replacement program were l

strengths.

Instances of improper control of transient combustibles and inadequate fire watch patrols were appropriately addressed once identified.

Housekeeping was generally very good with the decline noted following the

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refueling outage appropriately addressed.

l Self-assessment in the plant support area was considered a strength with

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corr,prehensive audits performed and the response to audit findings timely and technically correct. The identification and resolution of problems in the radiation protection area was a strength and a proactive approach to the identification and correction of problems was demonstrated-in the security area.

The performance rating is Category 1 in this area.

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