IR 05000387/1992099
| ML17158A218 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/12/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158A217 | List: |
| References | |
| 50-387-92-99-01, 50-387-92-99-1, 50-388-92-99, NUDOCS 9404180155 | |
| Download: ML17158A218 (10) | |
Text
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE SUSQUEHANNA STEAM ELECTRIC STATION I.
BACKGROUND The SALP Board convened on March 9, 1994, to assess the nuclear safety performance of Susquehanna Units 1 and 2, for the period April 19, 1992, to February 26, 1994.
The Board was conducted pursuant to U.S. Nuclear Regulatory Commission (NRC) Management Directive (MD) 8.6 (see NRC Administrative Letter 93-02).
Board Members were Charles W. Hehl, (Board Chairman), Director, Division of Radiation Safety and Safeguards, NRC Region I (RI);
Charles L. Miller,Director, Project Directorate I-2, NRC OfficeofNuclear Reactor Regulation; Wayne D. Lanning, Acting Director, Division of Reactor Projects, RI; and, Michael E.
Mayfield, Acting Deputy Director, Division of Reactor Safety, RI. The Board developed this assessment for approval of the Region I Administrator.
The performance category ratings and the assessment functional areas used below are defined and described in NRC MD 8.6, "Systematic Assessment of Licensee Performance (SALP)."
II.
PERFORMANCE ANALYSIS-OPERATIONS The plant operations area was rated a SALP Category 1 with a declining trend in the previous SALP period.
This was based on excellent day-to-day performance by operations personnel resulting in record unit availability and capacity factors;. management involvement in activities was quite evident; and, safety system availability was maximized by good maintenance planning and significant management attention.
Some weaknesses were noted in certain operator skills and in the operator training program, During this SALP period, with the exception of some aspects of the 1993 outage at Unit 1, both corporate and site management have been effective in assuring safe facility operation.
Management involvement in the investigations of operational concerns was excellent, and their safety philosophy was effectively conveyed to the staff during power operations.
Significant examples of this philosophy included the investigation of an operational problem involving the oxidation of the offgas charcoal beds, and the conservative management decisions regarding the inspection of the core shroud for cracks and the replacement of the jet pump hold-down beams.
Operators continued their strong performance during routine power operations, demonstrated a
high degree of professionalism, and maintained a strong nuclear safety-conscious approach toward plant operations.
Operators exhibited outstanding command and control in response to plant challenges during power operations throughout the SALP period.
Significant examples included prompt recognition and response to the Unit 1 turbine blade failure in July 1993, and the subsequent special, complex turbine torsional vibration testing that was necessary to support the root cause and corrective. action development for the blade failure.
During the period no plant scrams resulted from operator errors.
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The training program improved and contributed significantly toward maintaining operator qualification.
Operator license candidates were well prepared, as evidenced by the good performance during the examination.
Most licensed operators and.all initial license candidates evaluated by the NRC passed.
In contrast to the excellent performance during power operations, operations management oversight and operator performance were weak relative to some aspects of Unit 1 fuel handling activities.
Some activities were not well controlled, procedure adherence was lacking, and several minor operational problems occurred that had potential safety significance.
Many of the problems experienced during the outage with fuel handling equipment were repetitive or similar to events that had occurred previously, indicating that the licensee was not fullycognizant of the causes and had not implemented effective corrective actions.
Other performance problems were identified in the licensee's corrective actions regarding the status control of equipment restored from maintenance or surveillance activities, Although attempts were made to correct the situations as found, the overall root cause was not recognized and corrected.
Consequently, unexpected plant conditions, such as mispositioned valves, were occasionally found. Though none of the conditions was safety significant, the potential existed for more serious situations.
While human performance was a contributor, weak root cause assessment and ineffective corrective action were also involved.
The Nuclear Safety Assessment, Group (NSAG) generally provided thorough assessments of safety-related plant activities. Although NSAG activities were able to identify weaknesses in fuel handling practices and noted the frequent occurrences of status control events, the organization was ineffective in gaining management attention, recognition, and resolution of the problems.
In the case ofinadequate fuel handling equipment practices, the organization presumed corrective measures were in place without any verification or effectiveness review.
In summary, plant operational performance was generally excellent.
The operations staff's superior performance contributed to the safe operation of the plant during normal operations.
Operator training was improved and effective.
However, some aspects of performance were diminished as a result of long-standing uncorrected matters involving fuel handling equipment practices and status control of equipment restored from maintenance, which were revealed toward the end of the period.
The recurrent nature of problems in these areas indicated that management was not fullycognizant or appreciative of the ineffectiveness ofprevious corrective measures, and generally accepting of the conditions.
Accordingly, management oversight and control relative to root cause assessment and corrective action effectiveness were considered weak.
The operations area is rated a Category III. PERFORMANCE ANALYSIS-MAINTENANCE lI During the previous SALP period, maintenance was rated Category 1.
The maintenance program was effectively implemented, and the maintenance program management involvement with plant maintenance activities was excellent.
The maintenance and surveillance programs were effectively scheduled, planned, and implemented, and the programs contributed to the safe operation of the plant.
The surveillance activities were well controlled and confirmed the operability of safety-related equipment.
However, some minor deficiencies existed in the maintenance procedures, and the self-assessment processes for mechanical and electrical maintenance were not well established.
During this SALP period, the site management team continued to demonstrate a strong commitment to support the maintenance and surveillance programs.
Implementation of the Nuclear Maintenance program was very effective. The maintenance backlog was prioritized and maintained within a manageable size, with no significant work orders that would impact safe operation.
The skill, experience, and training of the maintenance staff continue to be licensee strengths.
There were no plant trips and only a few minor errors related to plant maintenance.
Corrective and preventive maintenance and troubleshooting were well-coordinated, prioritized, and executed effectively, and with appropriate supervisory oversight.
The material condition of the plant was exceptionally good.
Safety system availability and reliability were excellent throughout the period. Major activities were planned and completed in a safe manner with appropriate resources.
Plant safety systems performed well during operation and testing following the refueling outages.
Management displayed a proactive conservative approach to identification,and resolution of any equipment and system deficiencies.
Maintenance activities to support the emergent Unit 1 jet pump hold down beam replacement was accomplished in a safe, well-coordinated and controlled manner.
Strong management and supervisory oversight was evident. Maintenance personnel successfully performed the five year comprehensive overhauls of several Emergency'Diesel Generators (EDGs) during the period.
The surveillance program was effective and well-managed as evidenced by no inadvertent automatic scrams and few errors.
Scheduling and coordination continue to be strengths of the program.
The ISI program was implemented by qualified personnel to ensure that welds were acceptable for continued safe operation.
The available data were complete and properly documented permitting meaningful analysis and disposition.
While the conduct of the maintenance and surveillance programs was good, instances of poor maintenance planning, inadequate communications prior to the start of work, and failure to adhere to procedures resulted in a few minor events that challenged system operability or facility design.
For example, the Maintenance Department did not consistently perform and document-valve manipulations during the conduct of work as required by licensee procedures, This contributed to the status control (mispositioned valves) problem during the period. Additionally, corrective maintenance performed on the refueling platform mast was performed using a generic
support Work Authorization which, combined with ineffective material control and interdepartmental communications, resulted in the installation and use ofa nonconforming (non-Q) grapple without adequate post-maintenance testing. Also, the performance ofa Kaowool fire barrier surveillance test was inadequate, illustrating a weakness in the surveillance program.
In summary, the licensee continued to demonstrate a strong, well managed maintenance program.
The implementation of the overall program was effective, and demonstrated a strong influence ofprogram and site management.
However, there were a few isolated instances where the maintenance and surveillance activities did not achieve the licensee's typically high standards for safety-related activities.
The maintenance area is rated Category 1.
IV. PERFORMANCE ANALYSIS-ENGINEERING In the previous SALP period, Engineering was rated as a Category 1.
The licensee made excellent progress in reducing the number of engineering deficiencies.
Actions in response to the Organizational Effectiveness Review (OER) provided increased efficiency and focus in the engineering organization as was evidenced by the significant strengthening of Systems Engineering.
However, certain recurrent problems continued to require management attention to assure effective and timely resolution.
During this SALP period, effective engineering management support and involvement were evident.
Engineering management effectively integrated most of the system engineering functions into the nuclear engineering department in accordance with the OER recommendation and was directly involved in the regular plant system status and performance reviews.
Management expectations were openly and clearly communicated to the engineering personnel.
For example, weekly plant system reviews focused on performance and status information and allowed management direction to system engineering staff to be relayed in a direct and timely manner.
In addition, monthly seminars were conducted to keep engineering personnel abreast ofdepartment programs, performance, issues and concerns.
Corporate engineering management presence onsite was frequent and contributed to the quality, control, and productivity of the on-site engineering organization.
Timely resolution of technical discrepancies and associated corrective actions was strengthened during the period. The engineering discrepancy reporting process was substantially revised and improved to address reportability, operability, and employee concerns in a more effective and timely manner.
The treatment of,safety issues ofa generic nature demonstrated a conservative safety perspective.
For example, substantial modifications were performed in Unit 1 and planned in Unit 2 to replace fibrous piping insulation in containment to eliminate the potential for emergency core
cooling system strainer plugging during post-LOCA conditions.
Also, engineering promptly initiated evaluations and corrective actions to replace jet pump holdown beams to preclude failures experienced at other 'facilities.
During the period, several potential safety issues regarding spent fuel pool cooling were brought to the attention of the NRC through the submittal of a report filed pursuant to 10 CFR Part 21.
The NRC review of the safety significance and licensee management of these issues is ongoing.
Technical evaluations were generally comprehensive and thorough.
Licensing submittals and 50.59 safety reviews were usually of high quality and reflected a good understanding of the technical issues involved. A significant upgrade in the motor-operated valve (MOV) program was undertaken to address 10 CFR Part 21 notices, power uprate, MOV weak link evaluations, and degraded voltage conditions.
However, PP&L failed to inform NRC of its complete cessation of the GL 89-10 program implementation during the upgrade.
Root cause analysis was generally complete and accurate as was demonstrated by the analysis following the Unit 1 turbine failure.
However, the apparent lack of system performance trending of some previous problems and ineffective corrective action resulted in repetitive occurrences of the same or very similar conditions.
For example, trending and system'onitoring would have revealed that three radioactive gas leaks through the auxiliary boiler were from essentially the same leak path, a fact that was not immediately recognized and resulted in recurrence.
Similarly, conditions that resulted in multiple occurrences of control rod drive motion without a demand signal (resulting from transponder card failures) could have been-subject to more timely engineering assessment, analysis, and resolution ifthe adverse conditions were more effectively monitored and trended.
In summary, the engineering organization demonstrated strong and conservative safety perspective and provided an effective interface with site activities.
Management oversight in support of the station was very evident.
Technical evaluations were almost always found to be technically accurate, thorough and of high quality. Inadequate attention due to lack of trending led to a few repetitive events that potentially could have been prevented.
The engineering area is rated as a Category 1.
V. PERFORMANCE ANALYSIS-PLANT SUPPORT This functional area is new, representing a significant change from the previous SALPs.
The plant support functional area covers all activities related to plant support functions, including radiological controls, emergency preparedness, security, chemistry, fire protection, and housekeeping controls.
In the previous SALP the radiological controls functional area was rated as Category 2, and the emergency preparedness and security functional areas were rated as Category 1.
Performance in radiation protection was strong relative to personnel exposure tracking and control with good
supervisory oversight.
Additionally, the effectiveness of the quality assurance audits was enhanced by a high degree of management involvement.
The solid radioactive waste and transportation programs demonstrated excellent performance.
Weaknesses were identified in communicating radiological conditions to workers both in posting practices and in radiation work permits.
The effectiveness of the as-low-as-reasonably achievable (ALARA) program was hindered by the lack of criteria for temporary shielding.
A long standing potential airborne contamination concern resulting from a
positive containment pressure during drywell maintenance periods had not been resolved.
The chemistry, effluent and environmental monitoring programs remained highly effective with demonstrated strengths in the quality assurance/quality control activities, detailed and well written procedures and a highly skilled and knowledgeable staff.
Performance in the emergency preparedness area was excellent with effective responses to actual events, a high quality drilland exercise program, good involvement with off-site agencies, and appropriate staffing levels.
Weaknesses were identified in the timeliness of staffing the emergency operations facility (EOF) and in the turn-over of functions from the technical support facility to the EOF.
The licensee maintained a very effective, high quality performance oriented security program.
Highlighted in the security area were excellent plant and corporate support and a well trained and professional security force.
During the current SALP period, the licensee's radiation protection program continued to improve.
Communications of radiological conditions to workers greatly improved through creative plant postings, reformatting of radiation work permits, and increased health physics staff/worker interface. Worker radiological performance was further enhanced through training and surveillances of radiological work briefings.
The effectiveness of these improvements was clearly demonstrated during the Fall 1993 refueling outage.
Dose goals were improved, even though the outage was significantly extended to address several equipment concerns, Radiological housekeeping remained excellent with conditions improved in several areas of the plant through implementation of a valve packing upgrade program.
The reactor building ventilation systems were modified to provide a negative drywell pressure during maintenance periods, which effectively resolved a longstanding airborne contamination concern.
There were improvements in maintaining occupational exposures ALARAdue to additional use ofshielding; however, the ALARA program continued to be limited by difficulties in scheduling and engineering interfaces.
Performance in the radiological environmental monitoring and effluent control programs continued to be a licensee strength.
Highly effective programs for measuring radioactivity in process and effluent samples were identified.
Quality assurance audits were thorough and of excellent technical quality. Review and oversight of the chemistry program were excellent and resulted in continued outstanding performance.
The licensee continued to maintain an effective transportation and solid radwaste processing'rogram.
Significant resources and management attention were directed to the emergency preparedness program in support of preparations for participation in a Full Field Exercise (FFE) scheduled for the Spring 1993.
Although the FFE was cancelled, preparations for this exercise resulted in significant enhancements to an existing excellent emergency preparedness program.
The
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emergency response organization (ERO) was appropriately staffed, with four-deep in most positions.
Senior ERO managers were well trained and were actively involved in drills and exercises.
The licensee implemented a strong audit and corrective action program with thorough and comprehensive audits coupled to the station corrective action program, giving EP items appropriate attention.
Performance during the annual emergency exercise demonstrated the effectiveness of this program.
Despite a very challenging scenario, the exercise was characterized by good command and control in all emergency response facilities, good teamwork in the recognition and mitigation of adverse plant conditions, and excellent interface between onsite and offsite organizations.
The exercise critiques were effective with good offsite feedback.
One exercise weakness involving assessment of an unmonitored release pathway was identified.
The licensee continued to implement a very effective, high quality performance oriented security program. Management attention and involvement continued at a high level, evidenced by further program improvements and enhancements.
Upgrades included access control and detection systems, and the addition of a tactical weapons course.
Maintenance support of security equipment was aggressive, demonstrated contingency capabilities were excellent, and the audit and self-assessment programs were effective.
The security staff was well trained and highly professional.
There were several focused NRC observations regarding implementation of the fire protection program during this period.
NRC observations during fire brigade drills.noted continued successful performance in this aspect of the program.
However, the licensee experienced some difficultyimplementing compensatory measures for inoperable fireprotection systems in a timely manner.
Weaknesses were identified regarding installation and testing of fire barrier materials that had existed since construction.
Once identified, appropriate compensatory measures were prom'ptly implemented.
The plant support functions significantly contributed to safe plant performance.
Performance in the radiation protection area continued to improve.
Improvements in HP/worker communications and increased use of shielding contributed to low station doses.
There was continued strong performance in the emergency preparedness area with a number of important improvements implemented in preparation for the FFE.
Security program performance continued to be a outstanding.
The plant support area is rated as Category 1.