ML15261A187
| ML15261A187 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/08/1998 |
| From: | Casto C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Landis K, Ogle C, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML15261A186 | List: |
| References | |
| NUDOCS 9806160234 | |
| Download: ML15261A187 (18) | |
Text
OtP~ REaL, UNITED STATES 0
NUCLEAR REGULATORY COMMISSION REGION II ATLANTA FEDERAL CENTER 61 FORSYTH STREET, SW, SUITE 23T85 ATLANTA, GEORGIA 30303-3415 May 8, 1998 MEMORANDUM TO:
Kerry D. Landis, Chief Engineering Branch Division of Reactor Safety Charles R. Ogle, Chief Reactor Projects Branch 1 Division of Reactor Projects Michael A. Scott, Senior Resident Inspector Oconee Division of Reactor Projects FROM:*.
Charles A. Casto, Deputy Directo Division of Reactor Projects
SUBJECT:
INSPECTION CRITERIA TO BE USED DURING FUTURE INSPECTION OF OCONEE ACTIVITIES To support the efforts of the ongoing Oconee Management Oversight Group.
please ensure that the guidance of the.attachment is implemented for all future inspections at Oconee.
Attachment:
Inspection Criteria cc w/att:
DRP Branch Chiefs DRS Branch Chiefs M. Tschiltz. NRR D. LaBarge, NRR H. Berkow, NRR B. Mallett, RII L. Plisco. RII B. Mallett, RII R. Carroll 9806160234 980604 PDR ADOCK 05000269 G
INSPECTION CRITERIA
- 1. Support of the MOG's function to provide oversight of Oconee activities will require modifying inspection report inputs. This applies to DRP and DRS inputs. Specifically, the MOG will need an assessment of the licensee's performance in the areas inspected in each of the applicable template areas.
- 2. To accomplish this, the conclusion of each item documented in an Oconee report including open items, will contain an assessment of the licensee's performance in each of the applicable template areas. This is in addition to any conclusion which is normally developed as part of the inspection process. Performance in each of the applicable template areas will be assessed as: excellent, good, adequate, or poor.
These will be captured using the standard PIM entry categories as shown below. The following provides assessments for each of the standard PIM entries.
PIM SHADING PIM ENTRY ASSESSMENT FOR ITEMS INSPECTED E
STRENGTH Excellent Performance G
POSITIVE Good performance - Performance is more than adequate APOSITIVE Adequate performance which at least meets regulatory requirements NEGATIVE Poor performance (For violations, LERs and NCVs, poor WEAKNESS performance is in area of violation)
VIOLATION
--- NCV Each conclusion will contain an executive summary bullet for that conclusion. The executive summary bullets must be detailed enough to ensure that the bullet (and ultimately the corresponding PIM item) is clearly understood.
- 3. PIM entries will be provided by the inspectors for each of the conclusions reached along with designation of the applicable template area designations. The Oconee SRI will retain responsibility for entering these bullets into the PIM. These will be graphically displayed on the PIM as shown above to provide visual representation of licensee performance. The attached matrix provides the template areas and subcategories. Further information is provided in the attached examples.
ATTACHMENT
CATEGORY/
I Operating Performance 2 Material Condition 3 Human Performance 4 Engineering Design 5 Problem ID/Resolution SUBCAT How the plant is operated The performance and Ilow individuals do their work How the plant design basis The recognition,
- analysis, and during both normal and condition of plant equipment, within a given environment and design are documented, resolution of material and performance transient conditions using the how they are maintained and using the programs and understood, modified and issues within the plant; including established programs and tested through the processes that support the applied and how engineering licensee effort in self-assessment.
processes; including support implementation of established work.
support is provided to the programs.
programs and processes.
facility.
A Normal Operations Equipment Condition Work Performance Design Identification Operations* during normal Observations and findings Actions of an individual Documenting, understanding, Monitoring and review of material conditions including shutdown, regarding the performance or during conduct of work maintaining, and modifying condition and performance, such as: configuration control, condition of plant equipment, activities.
the plant design and design identification of problems, and staffing/ resources, command, including housekeeping.
attention
- basis, communication of these to the control, communication awareness appropriate personnel.
- includes operation of support communication programs B
Operations During Programs and Processes KSA Engineering Support Analysis Transients Framework and implementing Issues associated with the Technical support of the plant Evaluation of identified issues to Operations* during any procedures to test and knowledge, skills, and on an ongoing basis understand their breadth and depth unanticipated change in facility maintain plant structures, abilities of individuals, including contributing factors and conditions, such as:
systems, and components.
including training.
formulation of an appropriate course activation of Emergency This includes the of action.
Response, plant transient, implementation of these abnormal operations during programs.
shutdown, initiating events, unanticipated exposures,
- includes operation of support programs C
Programs and Processes Work Environment Programs and Processes Resolution Systems that provide the Context, programs, and The framework and The resource commitment, framework, structure, and processes that influence and implementing procedures to scheduling, tracking, completion, and implementing procedures to supports the execution of guide activities in support of assessment of actions to resolve guide specific activities in work, such as: physical engineering, design, and problems.
support of safe plant environment, workload, licensing.
operations, including the supervisory oversight, following programs:
procedure quality and Safeguards, Health Physics, completeness Emergency Planning, Security, Chemistry, Fire Protection, Personnel Safety
EXAMPLES The following is a list of examples developed by the Category Development and Criteria Develop.ment workshops. The examples are intended to be-a representative sample (not an exhau'stive list) of issues reflected in PIM entries. The examples are divided by Template subcategory and will assist a Resident Inspector and/or Branch Chief to appropriately categorize PIM entries.
IA. Normal Operations Configuration control Staffing C' -- Command, Control, Communication Execution of support programs Number of violations of LCOs Number of misconfiguration TS violations Failures in tag-outs and lock-outs lB. Operations During Transients Emergency response --Identification, Classification, Follow-up Configuration control Staffing C3 -- Command, Control, Communication Adequacy of event documentation Execution of support programs (including activation of emergency response)
I C. Programs and Processes EP Programs Fire Protection Security Program Operations Support Program Procedural Development/Quality Information Systems Number of LERs involving problems with procedure inadequacies Other Operations Examples Examples below are categorized as either 3A or 3B depending on operating condition (normal/transient) number of inadvertent safety system actuations number of problems during outages difficulty during startup number of operations-induced transients number of operations-induced scrams number of operator-generated significant events number of safety system actuations severity of transients (and consequences) number of significant events or precursors escalation of minor conditions due to inadequate or wrong operator response timeliness of response to events number of operator errors due to poor communication number of operator errors due to poor drawings number of-operator errors during response to transients due to lack of knowledge
2 number and nature of operator errors in response to transients occurrence of errors of comnmission during response to transients use of risk information to guide decisions adequacy of work package tracking (configuration awareness) adequacy of outage planning (risk-informed)
Configuration Control Eramples (3A/3B) instances in which adequate safety margins were not maintained instances in which appropriate defense-in-depth is not maintained instances in which operators demonstrated lack of knowledge of current plant configuration given plant activities instances in which operators did not effectively manage the plant's risk profile Command, Control, Communication Examples (3A/3B) up-to-date operator knowledge of current plant conditions communications in control room in accordance with standards adherence to existing programs and processes instances of procedure violations operator awareness as demonstrated by alertness and vigilance adequacy of shift turnover effectiveness of communications with other departments instances of observed crowding in the control room demonstrated clarity of decision authority and accountability involvement of appropriate personnel in event response (function allocation) 2A. Equipment Condition Equipment Reliability/Failures Repetitive Equipment Failures Safety System Reliability/Failures Availability Equipment Forced Outage Rate Safety System Actuations Annunciator status Unplanned LCOs Equipment response after scram Maintenance Rule Results Performance History MPFFs Equipment Importance Equipment Problems Common cause failure rate Cleanliness Number of (operator) work-arounds Steain, water or oil leaks painting/preservation Testing Results (touch, smell)
Material Condition Tags
Number of components in the alert range
- Environmentally induced degradation Equipment Aging Number of temporary modules/modifications Equipment vibration Control Room Deficiency 2B. Programs and Processes Maintenance Program & Procedures Surveillance Program & Procedures Maintenance/Surveillance Procedure Implementation On-line Maintenahce Maintenance Rule Program Contractor Management/Oversight Resources/Maintenance Staffing Available Parts Maintenance State --breakdown, preventive, predictive Tools & Diagnostic Methods IST/ISI Program Maintenance Program Testing properly accomplished Trending Program Results Test Pre-conditioning Work Package Quality.
Post-Maintenance Testing Work Control/Execution Foreign Material Exclusion Maintenance Backlog Overdue PMs Rework Rates Anticipated Deterioration Corrective Maintenance Backlog Instrumentation and Control Support 3A. Work Performance Good communication, communication breakdown Procedure adherence, use of procedures, procedure use errors Job performance aids Work hand-off
- of transients that involve latent errors Team performance, teamwork Questioning attitude, pro-active vs. reactive Formality in control room Stop, Think,;Act, Review (STAR)
Attention to detail Cooperation Excessive overtime
4 Stop work in questionable situation
-HRA in-PRA Good job brief Sleeping on duty Overconfidence Conscious vs. automatic Fitness for duty Unmotivated personnel Wrongly motivated personnel Appropriate people making decisions, decision making, timely decisions Malicious compliance/non-compliance HP contributes to event initiation Inattention to duties, attentiveness, vigilance Cognitive errors, 0% errors, personnel error rate Safety focus Number of events involving the lack of use of procedures Number and nature of operator errors in response to transients Occurrence of errors of commission during response to transients Number of work arounds 3B. KSAfTraining KSA's, knowledgeable of job tasks, systems knovledge Adequacy of work package Exam failure rate Worker task qualification process OJT process Training Rcqualification failure rate Use of mock-ups and dry runs Requal program Simulation Use SAT, Training program deficiency, incorporated lessons learned in training Conduct job briefings Contractor qualification Number of operator errors during response to transients due to lack of knowledge Operator training up-to-date Adequacy of pre-briefings and training for infrequent tasks 3C. Work Environment Shift schedule Environmental related human errors, stress induced problems, environmental conditions Supervision, management oversight Task allocation, function allocation, workload Procedure quality (generic)
Understanding, clear accountability Operator aids Habitual use of overtime
5 Rate of staff turnover Number-of staffing level exceptions or violations 4A. Design Environmental Design -- heat issues, lighting issues, noise issues Environmental Qualification (EQ)-- seismic, environmental Maintainability FSAR updates Up-to-date drawings Quality of calculations, Design calculations Response to engineering requests Design basis reconstitution Manual operator response time measures Digital/Analog integration CR redesigns Maintenance CDB (Current Design Basis)
Design Issues -- Human Errors (HSI), Design of hardware Plant computer issues SPDS redesign Design basis understanding Accessibility of design information.
Maintenance CLB (Current License Basis)
Instances of a mismatch between current as-built plant and dravings and other documentation 4B. Engineering Support Reactor Engineering Fuel cycle management Technical support Mfaterial certifications JCOs (Justification for Continued Operations)
Technical adequacy of procedurcs Quality of operability evaluations Test review and analysis 50.59 Reviews USQ (Unresolved Safety Question)
Control of engineering backlog Appropriate operating limits in procedures Trend system-performance PRA Development OER quality Quality of safety evaluations System Engineering Ownership System engineer knowledge of system status Corporate engineering Engineering design backlog System reviews Plant efficiency -- steam losses, etc.
- 6.
Responsiveness to engineering support requests Motor-Operated Valve Follow-up evaluation of plant modifications -- Testing following design changes 4C. Programs and Processes Temporary modification System to prioritize engineering requests Technical specifications Quality of exemption requests Documentation issues Quality of amendment requests Modification control issues Maintenance of vendor documents Quality of module packages Engineering organization intrusiveness Licensing issues Perform Part 21 reviews Set point control Vendor/contractor oversight OER program Maintenance/Surveillance Technical Adequacy 5A. Identification Self assessment QA findings Peer evaluations OER reviews, industiy feedback Questioning attitude Problem identification criteria/threshold Potential Problem Analysis Process (PPA)
Performance trending Problem report levels adhered to Quality Control/Assurance (QC/QA)
Workers initiate problem reports, problem ID available at all levels of personnel of problem ID problems - many or single event Problem ID tag Human performance issues are addressed Performance observation methods Systemic thinking/ approach Improvement programs Role of QA in the site (reporting level)
Independent review/ oversight, ISEG, PORC, off-site committee effectiveness Corporate culture Opennes's with NRC Management knowledgeable of problems.
Employee grievances, employee-management relations
- 7.
5B. Analysis Event investigations Prioritization of problems Self assessment criterion defined Root-Cause Analysis, events and causal factors analysis, document reasons for Terminating RCA Trended including MIS, methods for capturing trend information Operability evaluations are performed Communications of priorities Analysis/ evaluation criteria Identify conditions that the corrective actions are intended to achieve Qualifications of RCA evaluations Specify links between root causes and corrective actions Extent of condition review Use of lessons learned from near misses PRA: to evaluate resolutions, prioritize problems, identify precursors PRA to communicate issues Auditable Trending data includes human performance categories Quality of LER preparation Document conclusions of RCA SC. Resolution Timeliness, average time to implement fixes External commitments, response to NRC concerns Management support, adequate dollars to fix problems Repetitive issues, repeat failure rates Corrective action program Inter-departmental communication of issues Validation and verification, post-modification testing Corrective action backlog Planning, manpower requirements considered, CA plan development, intermal commitments Determined measurable objectives, measures of effectiveness of CA's Monitoring corrective actions Tracking
- of operator work arounds IPE follow-up Feedback to originator Allegations Employee concerns program, safety concerns program
OCONEE ROLLUP 5/4/98 PERFORMANCE Work Performance KSA Analysis N
N Work Environment Program and Processes*
ROLLUP CRITERIA The following are the criteria which will be used during assessment of Oconee performance:
Excellent:
Performance exceeds regulatory standards in the subject area and is critically assessed for improvement. There are no significant NRC-identified implementation problems.
Good:
Performance in subject area meets regulatory standards with minor exceptions.
Adequate:
While performance in subject area meets regulatory standards, problems exist which indicate that additional licensee attenti-on is warranted.
Poor:
Significant problems exist in the subject area or there are numerous examples therein which indicate systemic or pervasive problems. Significant means or results in (1)
Severity level III (or higher) identified violation: (2)
Safety or risk significant events; (3)
Systematic management breakdown; (4)
Willful acts: or (5)
Major variance from requirement.
C:MEL(10CD 9tE1110LL P.CR I
Recovery Plan Issue Owner Closure/Success Criteria Projcctcd Current Focus Area Closure Date Status Design Basis HPI System Tracy Complete and submit reliability study 12/22/97 Green Review Saville Complete procedure change to isolate LDST Complete during ECCS recirculation SITA HPI/LPI Tracy Complete SITA 12/11/97 Green System Review Saville' Close 94 PIP corrective actions (see curve) 12/31/98 OSRDC Steve Event scope for QA-5 5/15/98 Green Nader Develop QA-5 screening criteria
.6/18/98
- QA-5 Program definition 8/3/98
- Develop QA-5 implementation plan 12/10/98
- Begin implementation of QA-5 program 1/99 (see curve for status)
Resolve ECCW Steve Complete U2EOC16 mods and integrated test 6/1/98 Red Suction Supply Capps Complete U3EOC17 mods 11/1/98 to LPSW -
Complete UIEOC18 mods 5/1/99 OSW (see curve for status)
UFSAR Steve Accuracy and completeness review of all 12/31/98 Yellow Nader chapters of UFSAR DE&S Resolution of discrepancies identified 4/30/99
- ONS Resolution of discrepancies identified 6/30/99 (see curve for status)
SQUG Outlier Ray Submit outlier resolution plan 6/30/98 White McCoy Implement outlier resolutions 2002 (see curve for status)
Em Pwr Project Terry Duke completes remaining items/mods 5/1/99 White Ledford GL 96-06 Lenny.
- Perform LOCA/LOOP analysis to support Unit 7/10/98 Red Azzarello 3 operability Implement modifications (if necessary)
U3EOC18 EFW SSEI George Self Initiated Engineering Inspection 8/7/98 White McAninch Action plan for results complete 30 days after report entered
___in PIP Config Mgt Lanny Numerous efforts as defined in initiative 12/31/98 Wilkie o Ongoing cConfiguration management Ongoing ate ta Enclnqujrp I
System/Equip.
CRDM Rod Implement CRDM replacement modifications U3EOCl9 Yellow Reliability Replacement Emory TEPR Mano TEPR process implemented 12/97 Yellow Nazar MEPR Resolutions support improved Ongoing sys/equipment reliability System Teams Leland Initial meetings held for all system teams 1/6/98 Green Hawthorn
- Assess effectiveness 6/15/98 Temp Mods Jim Reduce # temp mods outstanding to 15 4/15/99 Yellow Groves Secondary George Recommendations from phase I 2/3/98 Green System McAnincl
- Evaluate secondary systems for single failure 6/17/98 Component vulnerabilities Reliability Human HP Measures &
Paulette Achieved Consistent Understanding of Error 12/31/98 Yellow Performance Org Direction LeCroy Reduction Tools/Behaviors
- Achieved Consistent Application of Error Reduction Tools/Behaviors
- Achieved Consistent Implementation of Key Supervisor Behaviors (Observation &
Reinforcement)
- Effective Implementation of Real Time Behavior Based Monitoring Job Paulette Sustained Maintenance Of Established 12/31/98 Gree Observations LeCroy Milestones n
Self PIP Activity Rick Planned Milestones Met 12/31/98 Yellow Assessment Backlog Bond Achieve 200 or less PIPS > 6 Months Old PIP Quality Rick Sustained maintenance of - 10% re-opened 7/31/98 Green Bond PIPs
- Recognition of acceptable PIP quality from review Mgt Obs. &
Rick Sustained maintenance of milestones 12/31/98 Green Grp Self Bond established Assessment PIP Problem Rick Bon Planned milestones met and maintained 12/31/98 Red Evaluation > 30 Days Old RCA &
Rick Root Cause quality at 85% or better as 12/31/98 Yellow Corrective Matheson measured by the Root Cause Quality Checklist Action on a three month rolling average
Operational Material Jim Area Owners Established 9/1/98 Red Focus Condition Hunnicutt
- Expectations Communicated with Station 100% of Rooms/Areas at Pre-Standard Fluid Leak Mgt Program Defined and Producing Results Operations Graham
- 300 or less Outstanding Change Requests 1/1/99 Red Procedures Davenpor 12/31/98.
Response to Tom Being Addressed Through Work Control Process 10/1/98 Operational Curtis Initiative Deliverables:
Concerns Weekly Work Process Mgt Mtg Established w/Ops lead & Driven by Station Health Report WO Backlog Goals Achieved (< 25 WOs >
180 days Old & Corrective Innage WOs <400 by 91/98)
CRIP Reduction Goal Achieved (< 15 Innage Workable by 9/1/98)
Daily C/R Schedule Resulting in High Quality C/R Environment WAPR Goal Achieved Risk Charlie Being Addressed Through Work Control Process:
10/1/98 Assessment Boyd Control Room Daily Schedule of Safety Significant Items.
Work Backlog Charlie
< 25 WOs > 180 Days Old 9/1/98 Red Mgt Boyd Corrective Innage WOs <400 Fluid Leak Mgt Jim Fluid Leak Mgt Program Established 11/1/98 Yellow Twiggs Coordinator In Place Reduction Goal Met (backlog of 700 requests significantly reduced)
CRIP Charlie Innage Workable CRIPs < 15 by 9/1/98 9/1/98 Red Reduction Boyd Outage Dave 100% of Unit 3 Pre-Outage Milestones 8/30/98 Red Readiness Deatherag Achieved Propose MOG Closure as once processes are in place & significant sustained progress is achieved for each item toward the above goals
Temporary Mgt Oversight Tom APA Accountability Included for All Ops Mgt. To Complete Defenses Observation Curtis Conduct 6 Hours of Observation Per Shift of Ops Core Values and Key Expectations. These are documented per NSD607.
Mgt Oversight Tom Program for pre and post-job briefs of these and all Complete Of Startup &
Curtis infrequent tests & evolutions developed, in place Shutdown and cited as a strength in SOER 96-01 assessment.
Inventory Tom RCS Inventory Tracking Program defined, in use Complete Monitoring Curtis and no inventory control problems encountered since implementation.
Eng/Ops/Maint Mano Meetings established and functioning since Complete Interface Nazar 7/15/97. Action Register Used to Document Meetings.
Improved Dean MP and IP Procedure Changes Completed 11/5/97 Complete Trouble Hubbard With 50.59 Reviews Completed 11/17/97.
Shooting Technician Training complete. Three Level Risk Assessment added. PMT requirements are more specific and must be documented in the trouble shooting plan & corrective action plan. Ops must approve all plans for medium & high risk activities.
Post Mod Dean Short term recommendations from PMT 8/30/98 Red Testing Hubbard Improvement Team implemented for Unit IEOCl6 Outage and long term recommendations, including new prototype procedures, implemented for Unit 2 Outage.
Chem/Ops George Establish processes to prevent human performance Complete Interface Hamrick errors in communications between Ops &
& Tom Chemistry.
Curtis
EXIT STRATEGY Prior to the MOG suspending activities, the following will be satisfied:
Issues checklist:
All licensee recovery plan actions appropriately inspected.
Licensee actions complete or planned licensee actions captured in an auditable tracking system.
All NRC areas of concern have been inspected with minimum adequate performance demonstrated.
PIM Review:
Ongoing licensee performances as reflected by PIM entries shows adequate performance on the part of the licensee.
Open Items:
All recovery essential identified open items appropriately resolved. Where planned licensee actions exist, they are captured in an auditable tracking system.
When the above items are satisfied, the MOG will recommend to the Regional Administrator an assessment of licensee performance by a PPR or SALP panel.
Exit from the MOG will occur if this assessment indicates that licensee performance is adequate in all template areas with no template subcategory areas evaluated as poor.
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