IR 05000454/1993001
| ML20056D560 | |
| Person / Time | |
|---|---|
| Site: | Byron  |
| Issue date: | 04/27/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20056D554 | List: |
| References | |
| 50-454-93-01-01, 50-454-93-1-1, 50-455-93-01, 50-455-93-1, NUDOCS 9308170073 | |
| Download: ML20056D560 (14) | |
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SALP 11
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INITIAL SALP REPORT
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION 111
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE i
Inspection Report No. 50-454/93001; 50-455/93001
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Commonwealth Edison Company
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Byron Stetion
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September 1, 1991, through February 28, 1993 i
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J 9308170073 930427
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PDR ADOCK 05000454
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SUMMARY OF RESULTS Overview
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lhis assessment period was from September 1, 1991, through February 28. 1993.
Your overall perfcrmance level during this assessment period was excellent.
All areas sustained excellent performance with an improvement noted in
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Engineering / Technical Support.
The performance ratings during the previous assessment period and this assessment period according to functional areas are given below:
Rating Last Rating This Functional Area Period Period-Trend Plant Operations
1 Radiological Controls
1 Maintenance / Surveillance
1 Security
1 Engineering / Technical
2 Improving Support Safety Assessment / Quality
1 Verification III.
PERFORMAtlCE ANALYSIS f'
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A.
Plant Operations 1.
Analvs's
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t Plant operations were characterized by conservative operating safety principles, implemented by a well-trained staff that benefitted from excellent management support.
Management effectiveness in ensuring quality during routine operations and
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outages was excellent. Management's expectations were clearly delineated through routine control room tours and daily orders. Communications and teamwork between departments continued to be excellent. Operating engineers (0E's) continued to be actively involved in the resolution of technical issues.
Plant perturbations due to personnel error were rare; however, an
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isolated lapse of management effectiveness resulted in a mode change.with inoperable containment spray pumps.
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Management was effective in improving shutdown risk conditions. Management improvements included the use of an outage coordinator and special shift
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briefings for high risk activities. When the Unit I station auxiliary service, management identified department coordinators transformer was out or and emergency contingency actions for Unit 2.
Also included in the shutdown risk management program were the categorization and monitoring of work
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activities by-risk factor.
Management was active in performing self-assessments of the conduct of operations, such_as, periodic OE reviews.
It used the onsite review process and root cause analysis of events to make improvements in the plant's performance. Onsite reviews of future planned activities ensured _ adequate controls. An excellent root cause analysis was performed for the mode change with inoperable containment spray pumps.
Response to events was excellent. The operations department continued to demonstrate excellent performance through teamwork, professionalism, and effective communications. The three reactor trips experienced at the two units during the assessment period were uncomplicated and were not caused by operator actions. During all of the trips, operations personnel effectively-mitigated the events. Their response to many large electrical demand changes was excellent and without incident.
The approach to identifying and resolving technical issues from a safety standpoint continued to be excellent. Operating engineers were actively involved in the resolution of technical issues, such as check valve testing, Unit 2 main generator hydrogen leakage, and emergency diesel generator (EDG)
testing.
The assignment of additional shift operations persennel during a dual-unit startup and the establishment of compensatory measures during a Unit 2 main generator hydrogen leak demonstrated a conservative and safety-oriented operating philosophy. Material condition continued to be excellent _ as demonstrated by the normally dark control room annunciators,: high~ equipment reliability and availability, and few plant perturbations caused by equipment failures.
Staffing was excellent, with management initiating steps to increase shift staffing when warranted for unusual or nonroutine plant conditions.
Training and qualification effectiveness was excellent as demonstrated by the 100-percent pass rate (23 senior reactor operators, 17 reactor operators, and 1 limited senior reactor operator) during NRC-administered requalification' and
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initial examinations.
2.
Performance Rating Performance is rated Category 1 in.this area.
Performance was rated Category 1 during the previous assessment period.
3.
Recommendations None.
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B.
Radiological Controls
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Analysis
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Radiological controls were characterized by excellent management and inter-departmental support, which resulted in low dose expenditures and generally accessible safety-related equipment. The overall excellent operation-of the
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radiological controls program resulted in few program challenges, and those
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that occurred were handled effectively-I Management effectiveness in ensuring quality was excellent.
Support of
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efforts to maintain exposure as low as reasonably achievable was excellent as i
demonstrated by early boration and hydrogen peroxide addition, use of remote video monitoring and inspection equipment, development of a detailed inservice inspection and snubber work schedule, and use of robotics and mechanical
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tool s.
Further indication of management support was the development of an alternative cnurse of action to repair valve seal leaks to avoid work inside the missile barrier while at power.
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standpoint was excellent. Communications between the radiation protection and i
chemistry departments and other departmental staffs continued to be effective
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as demonstrated by the dose reduction results and the excellent control of primary coolant pH. The total station dose in 1991, including the contribution from one refueling outage, was low - 268 person-rem. Total
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station dose for 1992, during which there also was one refueling outage, was lower - 199 person-rem. The high number of personnel contamination events j
identified in the previous assessment period (497 in 1990) was significantly
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reduced (258 in 1991; 156 in 1992). The radiological environmental monitoring program was effectively implemented and chemistry laboratory performance in the NRC radiochemistry confirmatory measurements program was excellent with
agreements in all 71 radiological comparisons. The quantity of radioactive material in liquid and gaseous effluents remained approximately the same as
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that in previous years and was well below regulatory limits. An isolated event was caused by poor communications, which resulted in the inadvertent transfer of several drums that contained small amounts of radioactive material
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to a vendor who was not authorized to receive the material.
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Staffing and training in the radiation protection and chemistry departments were excellent. The staffs were knowledgeable, experienced, and maintained a low turnover rate. Additional training was provided to personnel in preparation for the National Registry of Radiation Protection Technologists (
examination, which a large percentage of the staff passed.
2.
Performance Rating Performance is rated Category 1 in this area.
Performance was rated Category 1 during the previous assessment period.
3.
Recommendations None.
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C.
Maintenance / Surveillance
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1.
Analysis Performance in this functional area was characterized by effective management
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working through an experienced and qualified staff to sustain high equipment availability and performance.
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Management effectiveness in ensuring quality was excellent and' remained a strength. The maintenance department played a significant role-in maintaining the good material condition of both units. The effective use'of predictive and preventive maintenance resulted in a low' forced-outage rate, few reactor trips, low maintenance backlog, and high availability of equipment. Daily work planning meetings resulted in effective use of personnel by prioritizing maintenance activities.
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Two well-planned and -executed refueling outages occurred during this
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assessment period. During both outages, outage management maintained the-
overview required to ensure the safety of the plant and personnel involved in the various work activities.
Specific measures included the identification of-high-risk activities, the discussion of shutdown risk activities at every shift briefing by the outage coordinator, and the assignment of a risk factor for each outage activity. The control of switchyard work was well managed by the operations and work planning departments.
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The surveillance program was well managed and implemented. The post-
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maintenance test program was excellent with responsibility' assigned to the maintenance superintendent and the system engineer to ensure that the correct testing was performed and that equipment was returned to service only after-
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successful testing. However, at the beginning of the evaluation period, there j
were minor isolated instances of the failure to identify concerns related to the surveillance program: failure to document support equipment problems i
during surveillances, lack of steps in procedures to restore a system after
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i testing, failure to test pump discharge check valves, and' unnecessary actuations' of equipment during surveillances. However, once the NRC-identified these concerns, the corrective actions were thorough and timely.
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The preventive and predictive maintenance program was effective in ensuring-excellent availability of equipment with few plant perturbations caused by -
equipment problems.
Excellent use of thermography, vibration monitoring, and lube oil analysis was made in the predictive maintenance program.
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standpoint was e'xcellent as demonstrated by the investigation and repair of a; l
seal injection filter and diesel-driven auxiliary feedwater pump. Resolution of significant technical issues routinely utilized a team approach involving appropriate station departments with the cognizant operating engineer as a focal point for coordination. The onsite review meeting process was-i effectively used as the control process to resolve significant technical
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issues.
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The work request backlog was effectively controlled and managed to ensure that j
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the scheduling of significant work was based on equipment availability and L;-
reliability. Daily work planning meetings were effective in prioritizing the l
backlog.
I Staffing and training were excellent.
Few personnel errors and high-quality maintenance work were evidence of the effectiveness of the training of the stable work force of both craft and supervisors.
2.
Performance Ratino Performance is rated Category 1 in this area.
Performance was rated Category-1 during the previous assessment period.
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Recommendations
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None.
D.
Emergency Prenaredness 1.
Analysis Performance was characterized by strong management support.for the program and excellent exercise performance to a challenging scenario.
Emergency preparedness was maintained through an emphasis on conservative, safety-based principles.
Management effectiveness in ensuring quality was excellent. Monthly emergency preparedness (EP) training sessions, which supplement the required annual training, continued to be held to enhance the knowledge and skills of the emergency response organization (ERO).
Recent improvements to the program included the use of new radios in the environmental monitoring vans.
Emergency response facilities were maintained in an excellent state of readiness.
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identified violation, resulted from a lack of administrative control in revising the Emergency Plan resulting in inconsistencies between the Emergency Plan and the Emergency Plan Implementing Procedures. These inconsistencies
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could have resulted in the underclassification of a security event. The initial corrective actions did not include immediately revising the documents nor did they address the lack of administrative control. Untimely emergency
operations facility _ staffing was a generic concern identified related to all l
six Commonwealth Edison Company nuclear stations and resolution was ongoing at the end of the assessment period.
The EP response to operational events was excellent as was demonstrated by the-proper classification of three unusual events. The notifications associated
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with these events were detailed and timely.
During the 1992 exercise, performance was excellent with only two minor concerns identified. This
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exercise was extremely challenging and included dual unit events, the use of real meteorological data, extensive secondary system damage, and the loss of power to one unit.
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The EP staffing and qualification was excellent. A new EP instructor was
assigned to the EP training program and reported to the EP Coordinator to
ensure proper implementation _of the training program.
The onsite and offsite'
ERO staffing levels remained excellent, with at least three persons qualified l
for each key position.
j The onsite ERO training program was excellent. To prevent recurrence of a
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concern identified in the previous assessment period, emergency preparedness training was consolidated to require tracking of only one training date. This
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i tracking method ensured that all ERO members received the required training and the effectiveness of this training was demonstrated through excellent exercise performance.
2.
Performance Rating Performance is rated Category 1 in this area.
Perfnrmance was rated Category 1 during the previous assessment period.
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Recommendations None.
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Security 1.
Anal ysis Performance was characterized by excellent management attention and-support.
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Management effectiveness in ensuring quality was excellent. The use of..
monthly trending reports provided a tool to monitor and evaluate the effectiveness of the security program. An example of site management support is the upgraded perimeter intrusion detection system.
In addition, excellent technical staff and maintenance support ensured security equipment
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availability. Site management's liaison with local law enforcement agencies was demonstrated in the joint contingency exercise conducted on site during the operational safeguards response evaluation (OSRE).
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The approach to identifying and resolving technical issues from a safety
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standpoint was excellent. The perimeter intrusion detection system upgrade has reduced the resources expended on compensatory measures. Access control design deficiencies, identified in an NRC violation during the previous assessment period, were corrected.
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Response to events was excellent. Security operational events were properly identified, analyzed, and documented during the assessment period. An exception was the initial response to an event involving a simulated explosive device.
Staffing was excellent. The experience level of the staff continued to be high because of a low turnover rate. Security personnel were knowledgeable ard competent in performing assigned duties.
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Training and qualification effectiveness was excellent. The tactical response I
training program improved with assistance from a security consultant. On i
short notice the security force demonstrated an effective contingency response i
capability during the OSRE; also impressive were the level and quality of
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operations involvement. A weakness identified during the previous assessment-
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period regarding response techniques' and lack of formalized critiques during certain drills was corrected.
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2.
Performance Ratinq
Performance is rated Category 1 in this area.
Performance was rated Category
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Recommendations
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Engineering / Technical Support 1.
Analysis Engineering and Technical support performance was good and continued to improve.
The e.'fectiveness of the organization in the performance of routine
and reactive site activities was excellent.
Isolated lapses in support of the
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station detracted from the overall performance in this area. None of the
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reportable events were caused by current engineering activities.
J Management effectiveness in ensuring quality was excellent.
There was ample evidence of assessment and prioritization capabilities for design change l
packages, the ISI program, and the appropriate use of temporary modifications.
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Response to generic issues, such as the degraded voltage issue and the non-
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conservative assumptions for the boron dilution analysis, was good. The.
Onsite Review process effectively assessed operability issues and non-routine i
plant conditions. System engineers were actively involved in:the preventive and predictive maintenance of assigned systems.
Improved communications l
between the different site technical groups, corporate engineering, and other
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CECO sites was good and resulted in better data evaluation, trending, and more
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effective corrective actions. An example was the additional testing of diesel
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generator electrical circuitry identified from the LaSalle Electrical
Distribution System Functional Inspection. Management was effective in
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communicating performance expectations to the technical staff. To improve technical support, management conducted a survey of plant personnel and took steps to correct identified concerns. Operator licensing training and t
requalification was excellent as evidenced by the quality of the examination l
pre-reviews, simulator support, and the 100 percent passing rate of NRC i
administered examinations.
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However, some minor weaknesses existed in modification work plans. For example, a centrifugal charging pump modification could not be completed
initially because pipe bend radius dimensions could not be achieved. -In another case, the modification review process did not identify errors in the auxiliary building dampers low and high flow alarm set points.
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The identification and resolution of technical issues was good.
In most
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cases, technical evaluations and corrective actions were technically sound,
timely, and displayed an understanding of the safety implications, an
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improvement from the last SALP period.
One example included the evaluations
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and corrective actions taken regarding industry diesel generator problems.
Additional examples included the identification of an error in the vendor
supplied over-temperature delta-temperature setting design, and results from
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the trending program.
However, at times, identification and resolution of
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problems was not timely.
Examples included the problems with the essential
service water supply valves for the diesel driven auxiliary feedwater pumps l
and the errors in the calculated flood level in the containment following a
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design basis loss of coolant accident.
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Engineering and technical support staffing was good.
System engineers had a sense of ownership and accountability for assigned systems, generally possessed good system knowledge, and were adequately trained. Management's survey of plant personnel indicated that some important systems had been assigned to relatively inexperienced engineers. Management took immediate
steps to correct this and other survey identified concerns.
The number of
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qualified nuclear engineers was sufficient to perform the assigned tasks.
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A good staffing level was maintained within the training organization. The operator license training and requalification program was excellent; the
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training and qualification program for the engineers was good.
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Performance Rating
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Performance is rated Category 2 with an improving trend in this area.
Performance was rated Category 2 during the previous assessment period.
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Recommendations None.
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Safety Assessment /0uality Verification 1.
Analysis
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Performance in this area continued to be effective, and management support was excellent.
Improving performance was noted in all functional areas.
Management effectiveness in ensuring quality was excellent.
Examples include the effective use of the performance monitoring group, onsite nuclear safety group (0NSG), on~ site review (OSR) committee, Byron Excellence Review Team (BERT), and self-assessments and the continued good material condition of the plant.
Plant management actively communicated expectations to plant staff as evidenced by effective interdepartmental coordination and communication.
Resolution of technical issues by the OSR committee was excellent.
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of an effective OSR process include the review of the 18 auxiliary feedwater
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pump starting history and the-assessment of Unit I containment floor drain j
sump level indicator operability.
In addition, tb5 OSR for the Unit 1 outage
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core alteration and residual heat ' removal train swap focused on shutdown risk.
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~ Well-documented 10 CFR 50.59 reviews demonstrated sufficient technical
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Safety evaluations for temporary alterations demonstrated that there
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were no unreviewed safety questions.
The ONSG performed in-depth assessments of plant' engineering safety issues,
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which were incorporated into the plant outage schedule.
For example, the 0NSG
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performed several studies before and after outages to assess shatdown risk so-as to provide viable recommendations to improve future outages.
Response to events was excellent with management actively involved in the
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evaluation and formulation of corrective actions. An example was the well-l managed and coordinated response to a lack of testing of several pump-l discharge check valves in the component cooling and residual heat removal
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systems. The subsequent root cause investigation was thorough and identified areas for improvement by the technical staff.
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The regulatory assurance staff was effective in ensuring licensee event reports were of high quality. The group also performed many activities that
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contributed to the self-assessment area.
For example, BERT evaluated 114 events and identified symptoms and common causal factors, which were subsequently corrected.
Quality assurance (QA) audits and surveillances were effective and continued i
to be performance based.
The surveillance program was' effective in analyzing
performance.- For example, findings were given an ' attribute-ranging from exceptional performance to a significant deficiency and assigned a corresponding numerical value. The numerical values from all surveillances within a particular discipline were used to provide an overall performance indicator for that group and appropriate recognition or' additional attention-is provided.
Responses to the audit findings were thorough, timely, and
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technically sound.
QA audits were a positive contributing factor in the
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continued excellent plant performance.
fiost licensing submittals were of excellent quality, technically sound, well documented, and timely.
Examples include a technical specification amendment
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request related to boron dilution analyses, and setpoint revision for low steam generator level reactor trip and auxiliary feedwater initiation.
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Although an inservice test program submittal required several corrections and clarifications, this did not indicate programmatic weakness.
Staffing and training of the quality assurance, quality control, and regulatory assurance organizations were good. Auditors and inspectors were well qualified and technically competent.
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Performance Rating Performance is rated Category 1 in this area.
Performance was rated Category 3 during the previous assessment period.
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Recommendations'
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IV.
SUPPORTING DATA AND SUMMARIES
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Major Licensee Ar.tivities Significant outages ar,d other major events are listed belew:
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1.
On November 7,1991, Unit I was returned to service following a
scheduled 62-day refueling outage.
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On November 7, 1991, Unit 2 returned to service following a shutdown due i
to unidentified reactor coolant system leakage.
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On November 23, 1991, Unit I was returned to service following a-l shutdown to repair an unisolable leak on the ccmmon discharge-header of
the condensate pumps.
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On January 10, 1992, Unit I was returned to service following a shutdown
to repair a steam leak.
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On January 30, 1992, Unit I was returned to service following a reactor trip caused by a mislabeled valve-being closed for maintenance.
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On April 30,1992, Unit 2 was synchronized.to the grid following a
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scheduled 62-day refueling outage.
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On June 11,1992, Unit 2 was synchronized to the grid following a manual J
trip caused by a failed-closed feedwater regulator valve.
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On June 15,1992, Unit 2 was synchronized to the grid following repairs
to a feedwater check valve.
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On July 25, 1992, Unit 2 was returned to service following an 8-day
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maintenance outage.
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On February 5,1993, following 372 days of continuous operation, Unit I was shut down for the fifth refueling outage.
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On.Februarf 28, 1992, following 218 days of operation, Unit 2 continued at power.
B.
Inspection Activities The inspection reports discussed in this SALP are listed below:
Unit 1, Docket Number 50-454, inspection Report Numbers:
91020-91030, 92002-92004., 92006-92019, 'and 92021-92025
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- 1 Unit 2, Docket' Number 50-455, Inspection Report Numbers:
91020-91024, 91026, j
91028-91030, 92002-92019, and 92021-92025 i
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