IR 05000382/1998099
| ML20217F553 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 04/24/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217F542 | List: |
| References | |
| 50-382-98-99, NUDOCS 9804280191 | |
| Download: ML20217F553 (6) | |
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SYSTEMATIC ASSESSMENTOF LICENSEE PERFORMANCE REPORT WATERFORD STEAM ELECTRIC STATION, UNIT 3 50-382/98-99 l.
BACKGROUND The SALP Board convened on March 25,1998, to assess the nuclear safety performance of Waterford 3 for the period December 1,1996, through March 21,1998. Additionally, the SALP Board reconvened to assess the Engineering functional area on March 27,1998, following a predecisional enforcement conference on March 26,1998, to discuss the issues identified in NRC Inspection Report 50-382/97-25. The Board was conducted in accordance with Management Directive 8.6, " Systematic Assessment of Licensee Performance." The Board members included: T. P. Gwynn (Board Chairperson), Director, Division of Reactor Projects; A. T. Howell, Director, Division of Reactor Safety; and J. N. Hannon, Director, Project Directorate IV-1, Office of Nuclear Reactor Regulation. This assessment was reviewed and approved by the Regional Administrator.
Functional Areas and Ratinas Current Previous Plant Operations
2 Maintenance
2 Engineering
3 Plant Support
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PLANT OPERA ~llONS Overall safety performance in the Plant Operations functional area remained good with some improvement noted over the previous assessment. Management involvement and oversight of activities and programs was generally effective. Procedures and administrative controls were good, but some procedure weaknesses were noted. Operator performance during routine activities was mixed, with some examples of both excellent and poor performance. Operator response to plant perturbations and transients resulted in safe and effective control of the facility.
Operator training remained effective. A good, self-critical assessment process was evident.
Management oversight of the operation of the facility was generally effective, resulting in conservative decision making and good safety focus. Safety focus improved toward the end of this assessment period, as management implemented actions to address operator performance l
issues identified after the simultaneous inoperability of both auxiliary component cooling wr'ar l
trains. Management support of site activities was evident at alllevels. The involvement of l
operations management in operator training contributed to setting consistent performance L
standards among all shift operating crews.
%emil. orocedures and administrative controls were good, but some procedure weaknesses were noted. Foi exwole, the procedure for responding to the loss of the station uninterruptible power supply did not aid the operators in identifying affected equipment when the control power was lost. In another instance, an emergency operating procedure was not upgraded to reflect a 9804200191 980424 PDR APOCK 05000382 G
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-2-modification to the closing circuits for the containment spray injection valves installed in the plant.
Operator parformance during routine activities was mixed. Operator attentiveness to the plant, formality of operational practices, and professionalism improved toward the latter portion of this assessment period. However, some instances of weak shift turnovers and pre-evolution shift briefings occurred in this assessment period, as evidenced by the repeated failure to identify mispositioned control switches. In orie instance, the plant was operated for a very short period with no licensed senior reactor operator in the control room. Attention was directed toward the successfulidentification and elimination of operator work arounds. Administrative controls on overtime for operations personnel were found to be wellimplemented toward the end of the assessment period, after significant discrepancies had been identified in April 1997.
Communication practices of the on-shift crews improved over this assessment period.
Self-verification was routinely observed, and operators properly implemented the requirements of operating and surveillance procedures, with some exceptions.
i Operator response to plant perturbations and transients resulted in safe and effective control of the facility. This was particularly notable in response to the loss of a control power supply and releases from nearby chemical facilities. Nevertheless, the control of activities during the refueling outage was punctuated by two significant operating errors that resulted in the overflow of the spent fuel pool and in dropping a new fuel assembly.
Operator training remained effective with good crew evaluations and critiques. The high quality of operator training was reflected in the professional response of the operators to plant events.
However, minor weaknesses in crew directica and oversi ht by licensed senior operators in the G
control room simulator, during routine and emergency activities, were noted.
A good, self-critical assessment process was evident in the Plant Operations functional area, as demonstrated by the elimination of problems that were present during the previous assessment period. Audits and surveillances by quality assurance added value to the operations I
assessment process, particularly with respect to the performance of proficiency watches and the l
availability of corrective lenses for use in self-contained breathing apparatus, a generic industry
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issue identified at Waterford 3.
The performance rating in the Plant Operations functional area is Category 2.
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MAINTENANCE Overall safety performance in the Maintenance functional area was good, with improvements noted in some areas. A number of program and process enhancements were implemented to improve maintenance effectiveness and efficiency. The Maintenance Rule Program was generally implemented in accordance with requirements; however, a number of deficiencies were identified by the NRC. While the conduct of maintenance was generally good, a number of wekling program implementation problems were identified. The implementation of surveillance testing was typically good; however, the licensee identified a number of surveillance procedure deficiencies that rest!ted in some improperly performed surveillances. Overall, the material
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-3-condition of the plant was good. In-depth and critical self-assessments identified a number of areas for improvement; however, corrective actions were not always fully effective.
The implementation of maintenance-related programs was mixed. The inservice inspection program and the eddy current testing program for steam generator tubing were well implemented; however, problems with other programs detracted from that performance, and indicated a need for enhanced management oversight. For example, the licensee assessed the we; ding program, identified numerous deficiencies and concluded, in part, that these problems were caused by weak management oversight of the program. The Maintenance Rule Program was generally implemented in accordance with requirements; however, a number of deficiencies, involving scoping and performance monitoring, were identified by the NRC.
The licensee implemented a number of program and process enhancements to improve planning and scheduling effectiveness, as well as the management of work backlogs and emergent work. These enhancements, which included a 12-week rolling schedule, had not been implemented for a sufficient period of time to assess their effectiveness.
TM conduct of maintenance was good. Observed maintenance activities were generally performed in accordance with procedures and achieved acceptable results. Workers often displayed a questioning attitude. For example, during troubleshooting, an instrumentation and controls technician identified a significant potential safety concem regarding the interaction between the controlled ventilation area system and refueling water storage poollevelindicator.
One significant exception to this good conduct involved the improper setting of the travel stop nuts on certain diaphragm valves, which contributed to the overflow of the spent fuel pool.
The surveillance program was generally well implemented. With few exceptions, surveillances were properly scheduled and performed in accordance with procedures. However, a number of procedure deficiencies, most of which were licensee identified, resulted in some surveillances not being properly performed. Additionally, a number of surveillance tests associated with safety-related equipment, for example, the high pressure safety injection and containment spray systems, did not take into account the appropriate instrument uncertainties. In a few cases, unsatisfactory or marginally satisfactory test results were not identified or appropriately evaluated.
The overall material condition of the plant was good. The plant operated reliably and continuously since starting up from an extended refueling outage in July 1997. A painting and l
coatings program was implemented throughout this assessment period, resulting in some l
improvement in plant preservation. There were a number of safety-system hardware l
deficiencies that detracted from the overall material condition of the faciiity. While a number of l
these problems were resolved during this assessment period, other long-standing or recurring problems have not been fully corrected. Examples included recurring problems involving Channel C of the core protection calculator, the essential chillers, and safety-related manual valves.
Overall, safety assessment and quality verification activities were good. The threshold for initiating condition reports was appropriately low. The maintenance organization identified a
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-4-number of areas for improvement as a result of conducting an in-depth and self-critical assessment. However, actions to resolve deficiencies were not always timely, fully effective, or appropriately prioritized.
The performance rating in the Maintenance functional area is Category 2.
IV.
ENGINEERING Overall, safety performance in Er.gineering improved during this assessment period and was considered good. Several old, existing design problems were effectively resolved by the licensee. The engineering organization was moving toward a more rigorous application of the design and licensing bases. However, they had not been fully effective in resolving several emerging design issues. While improvements in the identification of problems were l
noted, the effectiveness of corrective actions remained a major challenge for this licensee.
I The engineering staff was technically competent and effectively addresse:j a number of long standing design deficiencies. Modifications installed during the refueUng outage were I
well prepared and properly implemented. In addition, the emergent work, caused by an unexpected failure of a startup transformer, was designed and installed appropriately.
Nevertheless, the engineers continued to be challenged by problems in maintaining the as-built facility consistent with design requirements specified in the Updated Final Safety Analysis Report. Inattention to design details resulted in a few potential equipment operability concerns. For example, the licensee failed to properly consider instrument uncertainties in analysis for several safety-related systems.
The licensee significantly improved its ability to identify design deficiencies. For example, engineering personnelidentified a design vulnerability with the hydrogen analyzer l
containment isolation valves and a single-failure vulnerability for the condensate makeup
pumps. Even though some good findings were identified, the engineering organization was l
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still less effective than the other site organizations in identifying conditions adverse to j
l quality. Additionally, corrective actions were sometimes narrowly focused and were not always prioritized correctly.
I Early in this assessment period, engineering support for the plant, particularly in the area of l
surveillance testing, was poor. For example, the surveillance test to verify adequate
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component cooling water flow to containment fan coolers was not representative of l
system alignment during accident conditions. Engineering support dunng both the refueling outage and the later portions of this assessment period improved and was good.
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Day-to-day engineering support for operations and maintenance was also noted to be
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improving, with the exception that surveillance testing procedures still required additional attention.
In general, the licensee's engineering procedures and programs were good. The licensee continued to upgrade the core program documents. The licensee implemented a program to correct and update the design basis for the facility, resulting in the identification of several design deficiencies. During this assessment period, the licensee also recognized i
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I that a programmatic upgrade of the control of calculations was needed. This issue is being resolved as part of the design basis reconstitution project. The 10 CFR 50.59 safety evaluation procedure was revised to include a screening review for calculations that were not part of a modification package. The 10 CFR 50.59 written safety evaluations were generally satisfactory; however, some examples of inadequate safety evaluations and problems with supporting documentation were identified, indicating the need for additional management attention in this area.
The quality of license amendment requests noticeably declined at the beginning of this assessment period. Many licensing submittals reflected lack of attention to detail, which required additional submittals, as exemplified by the condensate storage pool amendment request. During the latter part of this assessment period, the licensee had taken steps to improve its performance. However, it was too early to assess the effectiveness of the remedial actions.
i Quality assurance audits provided critical, effective oversight of the engineering organization.
In some instances, the licensee either did not identify conditions adverse to quality or the
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problem was not fully scoped and the resolution was narrowly focused. For example, the j
licensee missed several opportunities to prevent operation outside of the licensing basis j
because of flow uncertainties in the high pressure safety injection system. While some progress was noted in the implementation of the corrective action program during this assessment period,
opportunities for continued improvement in this area remain.
The performance rating in the Engineering functional area is Category 2.
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V.
PLANT SUPPORT Overall safety performance in the Plant Support functional area was good. Performance in the areas of radiological controls and emergency preparedness remained good, with some inconsistencies identified. Performance in the area of security was acceptable, with continuing problems noted with the implementation of the access authorization program. Fire protection performance continued to be good. Plant housekeeping improved throughout this assessment period, but some areas were not consistently maintained. Quality assurance audits and self-assessments were critical and effective in identifying areas for improvement.
Overall, a good radiation protection program was implemented. Radiation protection personnel provided good support for plant activities, which were performed consistent with as-low-as-reasonably-achhvable (ALARA) principles. The 3-year average person-rem exposure was less than the pressa.ad water reactor national average, indicating an effective ALARA program. The radiation protection staff was adequately trained and qualified. Generally, controls of radioactive materials, surveys, and personnel monitoring were good. Effective liquid and gaseous radioactive waste effluent, solid radioactive waste management, and transportation programs were implemented. However, several implementation problems were identified during
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-6-this assessment period, which indicated inconsistent performance in the areas of surveying radioactive material and controlling contaminated material. Intemal and external exposure controls continued to be good, but some problems were identified in this area.
- Implementation of the emergency preparedness program declined slightly from the excellent level of performance that was noted during the previous SALP period, but remained very good.
Emergency response facilities were well maintained and included special provisions for hurricane response. Actual events were properly classified and offsite agency notifications were timely.. During the biennial emergency plan exercise, the control room and technical support center successfully implemented all assigned omergency plan functions and demonstrated good performance; however, two exercise weaknesses were identified in the operational support center and one exercise weakness was identified in the emergency operations facility. The operational support center staff performed very well during a subsequent redemonstration exercise.
Performance in the area of security was acceptable. Senior management support for the j
security program continued. The testing and maintenance of security equipment and the
security event reporting program were noteworthy strengths. However, a number of problems involving access control of personnel and vehicles, security officer attentiveness, security l
lighting, and failed equipment detracted from the overalllevel of performance.
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Although not specifically assessed, fire protection performance continued to be good. The licensee effectively identified a fire protection common-mode failure vulnerability with the station uninterruptible power supply; however, the NRC identified that licensee personnel lacked an understanding of design basis assumptions made to satisfy certain fire protection requirements.
Plant housekeeping improved throughout this assessment period and was good overall.
Radiological housekeeping was also effectively maintained. However, there were some areas of the plant in which housekeeping was not consistently maintained. For example, the reactor auxiliary building floor drains were not routinely cleaned. A number of these drains, which had the potential to affect safety-related equipment, were found by the NRC to be clogged with debris.
Self-assessment and quality verification activities were typically good; however, corrective actions were not comprehensive in all areas. Emergency preparedness audits and self-critiques effectively identified areas for improvement. Quality assurance audits, surveillances, and self-assessments provided effective and proper management oversight in all radiological control areas. The quality assurance audit of the security program was thorough; however, continuing problems involving the access authorization progrcm were also identified during this assessment period.
The performance rating in the Plant Support functional area is Category 2.