IR 05000397/1997099
| ML17292A776 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 04/03/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17292A775 | List: |
| References | |
| 50-397-97-99, NUDOCS 9704070060 | |
| Download: ML17292A776 (11) | |
Text
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE REPORT WNP-2 50-397/97-99 I.
BACKGROUND The SALP Board convened on March 12, 1997, to assess the nuclear safety performance of the WNP-2 Station for the period September 3, 1995, through March 1, 1997.
The Board was conducted in accordance with Management Directive 8.6, "Systematic Assessment of Licensee Performance."
The Board members included:
K. E. Perkins, Director, Walnut Creek Field Office, (Chairperson);
K. E. Brockman, Acting Director, Division of Reactor Safety; and W. H. Bateman, Director, Project Directorate IV-2, Office of Nuclear Reactor Regulation.
This assessment was reviewed and approved by the Regional Administrator.
Functional Areas and Ratin s
'urrent Previous Operations Maintenance Engineering Plant Support II.
OPERATIONS Overall safety performance in Operations improved during this assessment period.
Plant operations during routine activities improved as was evidenced by an extended run going into Refueling Outage R11, numerous successful power level changes during economic dispatch periods, and a relatively error-free Refueling Outage R10.
However, when
'onfronted with nonroutine situations during the recovery from Refueling Outage R11, operators did not consistently show expected levels of performance.
In particular, the failure of Operations to assure that Technical Specification requirements were met prior to changing operational modes was an area of concern.
Operation at power since the startup was good even when challenged by plant tra'nsients caused by malfunctions of the adjustable speed drive and digital feedwater modifications.
During the assessment period, operations management and staff assumed more leadership in day-to-day activities.
An attitude of ownership over the plant activities was apparent, and management provided improved oversight of routine activities.
However, management involvement with nonroutine activities coming out of Refueling Outage R11 lacked a critical and questioning attitude.
Management responded to identified problems, but was not consistently proactive in approaching potential issues, e.g., problems in establishing an estimated critical position on a station startup.
Management actions produced notable improvements in command, control, and communications as well as in the control room environment.
Control room supervisors were more directly involved in the oversight of 9704070060 970403 PDR ADOCK 05000397
-6-plant operations which contributed to the improved command and control.
A change in Operations management was not sufficiently reviewed to assure qualification requirements were satisfied.
Generally, operators responded well to plant transients and infrequently performed evolutions.
However, there continued to be instances of procedural adherence problems and clearance control problems which required additional management attention.
On completing Refueling Outage R11; several Technical Specification operational mode restraints were not met prior to transitioning from one mode to another.
Further, two reactivity management events occurred which demonstrated a lack of consistent, conservative decision making and a need for rigorous control of potential reactivity manipulations.
Operators demonstrated good control of operations throughout numerous power level changes due to load following. Overall, the conduct of operations appeared to be professional and demonstrated a safety conscious approach.
The licensee's licensed operator requalification training program was considered to be good, but changes made to administrative procedures in the operations training area lowered the specificity and presented a vulnerability in the administration of the program.
Initial examinations prepared by the training staff for the pilot licensing examination program needed considerable work by NRC license examiners to meet acceptable standards.
Future examination preparation will require an improvement in quality.
Operator performance during requalification examinations was good.
The licensee's investigations and assessments were often too narrowly focused, particularly with determining root causes.
The ability of the licensee's organization to recognize problems was inconsistent, as evidenced by the early criticality and reactivity change events.
However,'the licensee's August 1996 self-assessment provided particularly self-critical observations and insights.
That self-assessment included a number of nonlicensee personnel, which app'ears to have contributed to the objectivity of the assessment.
The corrective action program continues to have problems with generating effective and comprehensive corrective action, largely due to the lack of depth in root cause determinations and weak implementation of corrective actions.
The performance rating in the Plant Operations area is Category 2.
III.
IVlAINTENANCE Overall safety performance in the Maintenance area was determined to be good.
The material condition of the plant continued to be good.
Management attention was evident, but several programs had implementation problems.
The skill-of-the-craft remained a
strength.
There were, however, several instances of individual inattention to detail.
The conduct of surveillance activities continued to be inconsistent, a fact that was noted in the previous SALP period.
Plan'ning and scheduling effectiveness improved significantly, but prejob briefings did not always provide the desired direction.
Efforts to integrate the consideration of risk into the planning, conduct, and testing of maintenance activities were evident, but not consisten Maintenance continued to upgrade the material condition of the facility. Equipment, including balance of plant, was generally well maintained.
The September 1996 failure of steam intercept Valve MS-V-185C to open was an exception where an in service equipment failure complicated plant operations.
Licensee management continued to improve maintenance and surveillance activities, although several programmatic weaknesses were identified.
The licensee's implementation of the Maintenance Rule was acceptable, but several weaknesses were identified.
This included failing to monitor three risk-significant systems for unavailability, not establishing appropriate criteria for monitoring reliability, and several procedural weaknesses.
Craft personnel continued to display good individual skills; however, the training provided for the newly installed recirculation and feedwater control systems was neither timely nor comprehensive.
This resulted in an over-reliance on vendor personnel and two instances where a vendor engineer inappropriately impacted plant operations.
In addition, there were several instances where craft personnel either failed to comply with procedural guidance or performed tasks beyond the scope of the governing work control process.
The surveillance program continued to exhibit sporadic lapses.
These weaknesses included procedural inadequacies, ineffective test criteria, and failure to conduct required surveillance tests which resulted in the licensee failing to comply with the requirements of the Technical Specifications during mode changes.
This was a problem area during the previous SALP period.
The overall planning and scheduling of work activities improved greatly.
The licensee implemented a 12-week work planning concept which used an integrated team to develop and implement individual jobs.
The completion rate for work activities improved significantly.
The Fix-it-Now team became a successful vehicle for performing simple, noncomplex tasks which had previously challenged the maintenance department's efficiency.
There were instances, however, such as the post-installation test of the digital feedwater system, where inadequate prejob briefings contributed to performance and interface errors.
In addition to the audits and surveillances conducted by quality assurance, the licensee initiated a program of self-assessments.
These assessments included individual performance observations and programmatic evaluations by personnel outside of the Supply System organization.
The performance rating in the Maintenance area is Category 2.
IV.
ENGINEERING Overall performance in the Engineering area improved during this assessment period.
Engineering management established a strategic plan that ensured engineering's goals were clearly identified and complemented those of other site organizations.
Management effectively used performance indicators to emphasize and assure expectations were me Particular improvement was observed in the performance of system engineering.
Although several weaknesses identified in previous SALP periods remained, they were not to the same degree.
Several problems were identified involving design basis document inconsistencies and use of the 10 CFR 50.59 process.
Engineering's strategic plan was effective, in identifying management's goals and objectives and the performance indicators provided a measure of the extent to which management expectations were achieved.
System engineering benefitted through an increase in the number of system engineers, a decrease in the number of systems for which each engineer had responsibility, and an increase in the amount of operations and systems training provided, e.g., the 13-week certification training.
As a result, system engineers were more knowledgeable and demonstrated improved performance.
A probabilistic safety assessment group was established to manage risk associated with work activities.
Engineering's involvement in the development of the Improved Standard Technical Specifications was sound as was Engineering's senior management involvement in the Corrective Action Review Board, a management initiative to improve the quality of root cause analyses and corrective actions.
A critical multidisciplined self-assessment was performed in August 1996, and initiatives to upgrade the Final Safety Analysis Report and improve design processes were begun.
An exception to the improved training noted above was the poor Maintenance Rule training provided to system engineers that resulted in their inability in some instances to identify maintenance preventable functional failures.
Inconsistent engineering quality, occasionally weak root cause analyses, late identification of problems, and untimely corrective actions continued from previous SALP periods.
A key example of inconsistent engineering quality was the weak initial engineering support of digital feedwater modification testing and the poor contractor control during adjustable speed drive testing.
Subsequent engineering involvement was, however, aggressive in developing technical expertise on the systems and attempting to solve the problems identified during post-installation testing.
An example of late identification of problems was Engineering's failure to promptly notify management of procedure weaknesses for estimating critical rod position.
Some root cause analyses lacked breadth and depth.
There were instances where the first plausible explanation of the root cause for a problem was accepted without eliminating other possibilities or expanding the root cause to other related components.
Procedural adherence and quality was inconsistent in the design modification review process and configuration management control was not consistently implemented.
For example, a reduced scope process was used to process three permanent plant modifications.
In addition, there were several examples of failure to update the Final
.Safety Analysis Report and of inconsistencies between calculations and other design documents.
Safety evaluations required by 10 CFR 50.59 were not always performed and were not consistent in their qualit 'I Continued management attention is needed to ensure increased consistency in the quality of engineering work.
The performance rating in the Engineering area is Category 2.
V.
PLANT SUPPORT Performance in the Plant Support functional area maintained the good level of performance noted in the previous SALP assessment.
Radiological controls'erformance improved slightly, as previous efforts to reduce the radiological source term began to show benefits.
Performance issues were identified concerning the control of high radiation areas and the attention paid by individual workers to radiological work practices.
The emergency preparedness area did not display the level of performance noted previously.
Deficiencies in both the planning of the biennial exercise and the communication of offsite recommendations were noted.
The security function was noted to have improved.
Fire protection remained satisfactory and housekeeping was excellent overall.
In the area of radiological controls, performance continued to be good.
Implementation of the radiological effluent and chemistry programs was excellent, and the initiatives that were instituted to reduce the source term, such as zinc and iron injection, began to show benefits.
However, it was noted that the position of Radiation Protectioh Manager had been filled by four different persons during the rating period, and this contributed to instability within the organization.
While nonoutage exposure rates were significantly reduced, their 3-year average exposure normalized for annual outages was still above the national average for boiling water reactors.
On several occasions, the proper control of high radiation areas challenged the licensee, and several jobs were impacted by an inconsistency in the quality of ALARAplanning and prejob briefings.
These shortcomings were particularly noteworthy since the licensee's corrective action program had opportunities to preclude the repetitive occurrences which were noted.
A change in the Effluent Minimization Supervisor was not sufficiently reviewed to assure qualification requirements were met.
As a result of the deficiencies noted during the biennial exercise, the emergency preparedness area was determined to have declined in performance when compared to the previous SALP period.
Emergency response facilities were maintained in a state of operational readiness, but the incorrect calibration of the accident noble gas monitor resulted in the loss of a required emergency assessment capability.
Additionally, the annual program audit and the biennial exercise displayed weaknesses in the licensee's ability to make timely offsite notifications, appropriate dose assessment calculations, and proper protective action recommendations.
Performance in the security area was improved.
The organization received excellent management support and direction.
Program strengths were identified in the areas of communications capabilities, records systems, compensatory measures, and access
I'
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Assessment.
aids and lighting for the protected area were effective.
Only isolated deficiencies, such as an instance where security officers failed to ensure unauthorized materials did not enter the protected area, were noted.
No significant problems were noted in the fire protection area.
There were, however, instances where corrective actions for identified deficiencies were not properly implemented.
One example was the failure, for over a.year, to implement corrective actions to an agency-identified violation.
Mousekeeping was generally considered to be excellent.
Self-assessments and corrective actions were not successful in precluding repetitive problems.
There were repetitive instances of high radiation a ea control problems.
Poor planning and a lack of managerial oversight were contributors to the inadequacies associated with the biennial emergency exercise scenario.
Also, the lack of an adequate review before considering moving the backup emergency operations facility indicated inattention to detail.
The performance rating in the Plant Support area is Category P