ML16341E412
| ML16341E412 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 09/09/1987 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341E414 | List: |
| References | |
| 50-275-87-29, 50-323-87-29, NUDOCS 8711060222 | |
| Download: ML16341E412 (80) | |
See also: IR 05000275/1987029
Text
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
SYSTEMATIC ASSESSMENT
OF
LICENSEE
PERFORMANCE
FOR
PACIFIC GAS
AND ELECTRIC COMPANY
DIABLO CANYON NUCLEAR POMER
PLANT
REPORT
NOS. 50"275/87"29
AND 50-323/87-29
EVALUATION PERIOD:
08/01/86 - 07/31/87
BOARD ASSESSMENT
CONDUCTED:
SEPTEMBER 9,
1987
8711060222
871021
ADOCK 05000275
TABLE OF
CONTENTS
Introduction
~
~Pa
e
1.
2.
Purpose
and Overview.
SALP Board for Diablo Canyon.
Criteria
.
Summary
and Results.
l.
2.
3.
Management
Overview
.
Inspection Activities
.
Results of Board Assessment
.
2
3
3
IV.
Performance
Analysis
.
l.
2.
3.
5.
6.
7.
8.
9.
10.
11.
Plant Operations.
Radiological Controls
.
Maintenance
.
Surveillance.
Fire Protection
.
Emergency
Preparedness.
Security
and Safeguards
.
Outages ...
equality
Programs
and Administrative Control
Affecting equality
.
Licensing Activities.
Training and qualification Effectiveness.
~
~
~
~
~
~
7
9
11
12
13
15
17
18
20
22
V.
Supporting Data
and Summaries.
23
1.
2.
3.
4.
5.
6.
7.
8..
10.
11.
12.
13.
14.
Licensee
Event Reports
(LERs)
.
Part 21 Reports (Letters)
.
Investigations.
Escalated
Enforcement Actions
.
Management
Conferences
Held
.
Special
Reports
.
NRR Meetings with Licensee.
Commission Meetings
.
Schedular
Extensions
Granted.
Reliefs Granted
.
Exemptions
Granted.
Emergency Technical Specificatio
License
Amendments
Issued
.
Issues
Pending.
ns
C
~
~
~
~
hang es.
~
~
~
~
~
23
25
25
25
25
25
26
27
27
27
27
27
27
29
TABLES
Table 1-
Table 2
Table 3-
Tabl e 4-
Tabl e 5-
Tabl e 6-
Inspection Activities and Enforcement
Summary, Unit 1
Inspection Activities and Enforcement
Summary, Unit 2
Enforcement
Items, Unit 1
Enforcement
Items, Unit 2
Synopsis of Licensee
Event Reports,
Unit 1
Synopsis of Licensee
Event Reports,
Unit 2
I.
INTRODUCTION
1.
Pur ose
and Overview
The Systematic
Assessment
of Licensee
Performance
(SALP) is an
NRC
staff integrated effort to collect available observations
and data
on a periodic basis
and evaluate
licensee's
performance
based
on
this information.
SALP is supplemental
to normal regulatory
processes
used to ensure
compliance with NRC rules
and regulations.
SALP is intended to be sufficiently diagnostic to provide
a rational
basis for allocating
NRC resources
and to provide meaningful
guidance to licensee
management
to promote quality and safety of
plant construction
and operation.
An NRC SALP Board,
composed of the members listed below, met in the
Region
V office on September
9, 1987, to review the collection of
performance
observations
and data to assess
the licensee's
performance
in accordance
with the guidance of NRC Manual Chapter 0516, "Systematic
Assessment
of Licensee
Performance,"
dated
July 25,
1986.
A summary of the guidance
and evaluation criteria is
provided in Section II of this report.
This report is the
SALP Board's. assessment
of the licensee's
safety
performance at the Diablo Canyon Nuclear Power Plant,
Units 1 and 2,
for the period August 1,
1986 through July 31,
1987.
2.
SALP Board for Diablo Can
on
Board Members:
A
- Q
- ~ C
)k*
R
- )k R
F
A'* M
Q
- S
- R.
- A p
- A J
- C
" K.
C
E. Chaffee,
Deputy Director, Division of Reactor
Safety
and Projects
(Board Chairman)
W. Knighton, Director, Project Directorate
No. 5,
M. Trammell,
NRR Project Manager
A. Scarano,
Director, Division of Radiation Safety
and Safeguards
P.
Zimmerman, Chief, Reactor Projects
Branch
A. Wenslawski, Chief,
Emergency
Preparedness
and
Radiological Protection
Branch
M. Mendonca,
Chief, Reactor Projects
Section I
P.
Yuhas, Chief, Facilities Radiological
Protection Section
D. Schuster,
Chief, Safeguards
Section
A. Richards,
Chief, Engineering Section
F. Fish, Chief,
Emergency
Preparedness
Section
P. Narbut, Senior Resident
Inspecto~
F. Burdoin, Project Inspector
Hooker, Radiation Specialist
M. Prendergast,
Emergency
Preparedness
Analyst
B.
Ramsey,
Reactor Inspector
"Denotes voting member in area of specialty.
- "Denotes voting member in all areas.
CRITERIA
Licensee
performance is assessed
in, selected
functional areas,
depending
upon whether the facility is in a construction,
preoperational,
or
operating
phase.
Functional
areas
normally represent
areas significant
to nuclear safety
and the environment.
Some functional areas
may not be
addressed
because
of little or no licensee activities, or lack of
meaningful
observations.
Special
areas
may be added to highlight
significant observations.
The following evaluation criteria were applied for each of the eleven
functional areas
as appropriate:
1.
2.
3.'.
6.
Management
involvement in assuring quality.
Approach to resolution of technical
issues
from a safety standpoint.
Responsiveness
to
NRC initiatives.
Enforcement history.
Reporting
and analysis of reportable
events.
Staffing (including management).
To provide
a consistent
assessment
of licensee's
performance,
attributes
were applied for each of the above criterion that described
the
characteristics
of Category j., 2, or 3 performance,
in accordance
with
NRC Manual Chapter 0516, Part II and Table 1,
as follows:
.
~Cate or
1:
Reduced
NRC attention
may be appropriate.
Licensee
management
attention
and involvement are aggressive
and oriented toward
nuclear safety;
licensee
resources
are
ample
and effectively used
so that
a high level of performance with respect to operational
safety is being
achieved.
~Cate or
2:
NRC attention
should
be maintained at normal levels.
Licensee
management
attention
and involvement are evident
and are
concerned with nuclear safety;
licensee
resources
are adequate
and are
reasonably effective so that satisfactory
performance with respect to
operational
safety is being achieved.
~Cate or
3:
Both
NRC and licensee attention
should
be increased.
Licensee
management
attention or involvement is acceptable
and considers
nuclear safety,
but weaknesses
are evident; licensee
resources
appear to
be strained or not effectively used
so that minimally satisfactory
performance with respect to operational
safety is being-achieved.
SUMMARY AND RESULTS
1.
Mana ement Overview
Pacific Gas
and Electric Company
(PG8E) .has
made significant
enhancements
to some programs in response
to the previous
SALP's
recommendations
and to inspection findings during the current
period.
Examples of these
program enhancements
are in the areas
of
radiological protection,
surveillances
and outages.
Additional
enhancements
have
been
made or are planned
as outlined in a June
15,
1987, letter from PG8E.
The key issues
developed
during the
SALP period were the subject of
the licensee's
letter to the
NRC of June
15,
1987.
The licensee
generated
the June
15,
1987, letter in response
to a series of
violations
and
a recognition that comprehensive
management 'action
was required to correct
a potentially declining trend.
The issues,
that were addressed
in the June
15,
1987 letter, applied to all
functional areas
in general
and included formality of
communications,
procedural
compliance,
root cause identification and
resolution,
and late event reporting.
The licensee
has committed to
improvement programs in all the areas
discussed.
As highlighted in a Region
V management
meeting with PG8E on
August 17,
1987,
implementation of the programs
described
in PG8E's
June
15, 1987, letter has provided
and will continue to be
a major
challenge to PG8E's
management.
The recommendations
in each of the
functional areas
reinforced this finding with specific areas
where
improvements
may be made.
Specifically, in the operations,
maintenance,
surveillance,
and quality programs functional areas,
the
SALP Board found that PG8E's
management
should put high priority-
on improving performance
in root cause analysis,
procedural
compliance,
and formality of communications,
as well as, continuing
strong
management efforts in the other aspects
of the licensee's
June
15 letter.
In the areas
of radiological controls,
emergency
preparedness,
outages,
and 'training, continued strong
management
support
has
been
recommended.
In the other functional areas,
specific recommendations
for management
consideration
are provided,
which could result in improved p'erformance.
Overall, the
SALP Board
concluded that PG8E's
management
was aggressively
involved and
concerned with nuclear safety,
and that licensee
resources
were
ample
and reasonably effective -in assuring
operational
safety.
Ins ection Activities
Approximately 6,827 onsite inspection
hours were spent in performing
a total of 44 inspections
by resident,
region-based,
headquarters,
and contract inspectors.
Inspection activity in each functional
area is summarized
in Tables
1 and 2.
Tabulation of enforcement
items during the
SALP period is contained in Tables
3 and 4;
and
a
synopsis of Licensee
Event Reports for each Diablo Canyon Unit is
contained
in Tables
5 and 6.
Results of Board Assessment
Overall, the
SALP Board found the performance of NRC licensed
activities by the licensee
acceptable
and directed toward the safe
operation of both units of the Diablo Canyon plant.
The
SALP Board
has
made specific recommendations
in most functional areas for
licensee
management
consideration.
The results of the Board's
assessment
of the licensee's
performance
in each functional area,
including the previous
assessments,
are
as follows:
Functional
Area
Assessment
Last
Period
Assessment
This
Period
Trend*
A.
B.
C.
D.
E.
F.
G.
H.I.
J.
K.
Plant Operations
Radiological Controls
Maintenance
Surveillance
Fire Protection
Emergency
Preparedness
Security and Safeguards
Outages
equality
Programs
and
Administrative Controls
Affecting Safety
Licensing Activities
Training and qualification
Effectiveness
2
2
1
,2
1
1
1
2
2
2'
2,
2
2
1
2
1
"2
.None apparent
Improving
None apparent
Improving
None apparent
None apparent
None apparent
None apparent
None apparent
2
None apparent
1
None apparent
The trend indicates
the
SALP Board's appraisal
of the
licensee's
direction of performance
in a functional area
near
the close of the assessment
period
and continuation of this
trend
may result in a change in performance
level. It is not
necessarily
a comparison of performance
during the current
period with the previous period.
IV.
PERFORMANCE ANALYSIS
~
~
~
1.
Plant
0 erations
~Anal aia
During this
SALP period the licensee's
plant operations
were
inspected
on a routine basis
by the
NRC resident
and regional
inspectors.
Also, the annual
team inspection
was conducted
in
February
1987 and included
an assessment
of auxiliary operator
response
to events.
In addition,
an Augmented Inspection
Team (AIT)
was conducted in April 1987 in response
to the April 10, 1987 loss
of
RHR event.
The teams'fforts
included
an evaluation of
operational
aspects
of the event.
A total of 3401 inspection
hours
were expended in this area.
This evaluation
recognizes
the fact that this is the first SALP
period in which both units were in a full operational
status for the
entire
SALP period.
There were eight enforcement
items
and
twenty-four reportable
events
consider ed applicable to the plant.
operations
area,
In the plant operations
area,
management
has
shown generally
improving involvement during the
SALP period.
Senior corporate
management
became directly involved in the more significant events
during the
SALP period; specifically the Unit 1 oil fire in December
1986 and the loss of RHR event of April 1987.
Additionally, during
the
SALP period, the licensee initiated and strengthened
plant
management
involvement programs
such
as requiring senior management
on-shift coverage for critical plant evolutions during startup
and
senior
management
walkdowns of plant areas prior to post refueling
closeout,.
There
has
been evidence of prior planning and control of activities
in the operations
area,
and improvements
have
been initiated in
response
to errors.
For example,
the licensee
had generally
adequate
procedures
for defining and controlling the operability
status
of safety systems
during normal operation,
but these
procedures
were not effective in handling the large
amounts of
out-of-service
equipment that occurred during the Unit 1 refueling
outage.
Management
was not sufficiently involved to identify this
problem early-on, but did take aggressive
action to prevent
a
recurrence
during the Unit 2 refueling outage.
The licensee's
corrective actions in the operational
area are usually effective,
but not always
so.
For example,
the licensee's
actions
have not yet
proven to be effective in the area of late telephone
reporting to
the
NRC (10 CFR 50.72 -reports)
and
an additional violation was
issued after the end of the
SALP period.
The licensee's
approach to technical
resolutions of plant problems
generally demonstrated
an understanding
of the issues,
and
conservatism
was usually exhibited.
This was notably demonstrated
in the licensee
response
and corrective actions initiated subsequent
to the loss of RHR event of April 10,
1987 and the reactor trip and
safety injection event of July 14, 1987, involving a positive
moderator temperature coefficient.
Although in both events,
the
inspectors
concluded that there
was sufficient information available
to the licensee
such that aggressive
action
and followup could have
prevented
the events; after the events,
the licensee
did initiate
and execute detailed action plans for corrective actions prior to
restart.
Early in the
SALP period the licensee
had demonstrated
a
reluctance
to formulate clear
formal action plans for events
and
consequently
did not consistently provide an adequate
focus for root
cause identification and correction.
An example of this was the
Unit 1 oil fire where the action plan was largely verbal.
The
licensee's
performance
in formulating action plans
had clearly,
improved later in the
SALP period.
The licensee's
responsiveness
to
NRC initiatives has
been generally
timely and acceptable
resolutions
are generally proposed.
There
was
one isolated instance
demonstrative
of uncooperative
behavior toward
the
NRC inspectors,
during an event,
by both operations
personnel
and management.
Specifically, the operations
personnel
attempted to
exclude the inspector
from the observation of plant parameters
after
a reactor trip and attempted to exclude
him from post-trip review
discussions.
A recent
example of good responsiveness
to
NRC issues
is the June
15,
1987 letter that responded
to several
violations and
Region
V initiatives.
The response
appeared
to be
a well thought
out, integrated
program to address
licensee
performance
weaknesses.
Finally, in regard to responsiveness
to
NRC initiatives, written
reports required to be submitted to the
NRC were 'consistently timely
and the information provided was generally clear
and thorough.
The licensee's
enforcement history in the operations
area
shows
multiple and repetitive minor violations in the areas
of procedural
compliance
and late reporting indicating corrective action
has not
been fully effective in those
areas.
Examples of lack of procedure
compliance include the fai lure to follow administrative
procedures
for system operability on snubber work, and two examples of not
following procedures
during reactor vessel
draining.
Examples of
late reporting included failure to report two ESF actuation
events
The licensee's
lack of fully effective actions indicated
a weakness
in root cause analysis,
which the licensee
addressed
in their
June
15,
1987 letter.
An additional
area of repetitive enforcement
has
been the occasional
lack of formal communication
between
departments
interfacing with operations.
These
cases
have led to
violations discussed
in other sections
of this report,
and involve
verbally reporting the completion of work or testing to operations.
The acceptance
of informal communications
regarding the status of
safety equipment clearly indicates that the operations staff's
attitude,
toward discipline in all activities, requires
improvement.
There
have
been occasional
significant operational
events
attributable to causes
under the licensee's
control, in particular
the loss of
RHR event which was primarily caused
by failure to
follow procedures.
There
have
been frequent events largely caused
by inherent characteristics
of the hardware
involved which the
licensee
has not yet fully resolved,
but is actively working toward
resolution.
These include the inadvertent
ESF ventilation
actuations
caused
by radiation monitor noise spikes,
control sensitivity at low power levels
and steam
dump valve erratic
response
characteristics.
The licensee
reported
24 events
in the
operations
functional area,
but a significant portion of the events
were entirely avoidable if the precepts
of procedure
compliance
had
been followed.
Examples
included not adhering to the reactor vessel
water level requirements
resulting in the April 10,
1987 loss of
RHR,
and failure to comply to Technical Specification requirements
for containment isolation when
a blowdown isolation valve was
repaired.
The licensee's
qualified and licensed operational staffing,
on shift
and otherwise available,
was outstanding.
The number of on shift
licensed
person~el
exceeds
minimum requirements
of five and
generally is eight or nine licensed individuals.
Operations
personnel
generally appeared
to be knowledgeable
of plant systems
and performance,
and generally
responded
to significant and
complicated events effectively and professionally.
There was
an
isolated
instance of unprofessional
behavior regarding
an
annunicator
marking,
and there
have
been occasional
examples of
improper attitudes in regards to procedure
compliance;
but licensee
management
has initiated programs
aimed at more successfully
communicating their expectations
to operations staff.
Conclusion
Performance
Assessment
- Category
2.
There
was
no apparent overall trend.
However, the effectiveness
of
actions to correct the root cause
ot problems,
such
as procedure
compliance
issues identified early in the
SALP period,
were
improving but no results in terms of reduced trips or events
were
noted at the end of the
SALP period.
Board Recommendation
Licensee
management
should work to effectively implement the-
improvements
defined in their June 15,
1987 letter to the
NRC,
emphasizing
continued
improvements
in root cause analysis,
procedure
compliance, formality of communications
and elimination of late
reporting.
Radiolo ical Controls
~Anal aia
A total of six routine
NRC inspections
related to radiological
controls were performed during this appraisal
period.
Also,
inspections
by the resident
inspectors
focused
on the implementation
of the radiation protection program.
In excess
of 385 hours0.00446 days <br />0.107 hours <br />6.365741e-4 weeks <br />1.464925e-4 months <br /> were
.
expended
in the following -functional areas:
A.
B.
C.
D.
E.
F.
Occupational
Radiation Safety
Radioactive
Waste
Management
Radiological Effluent Control
and Monitoring
Transportation of Radioactive Materials
Water Chemistry Control
Licensee
Event Reports
(LERs)
Two Severity Level IV and three Severity Level
V Violations were
identified during the previous
SALP period (August 1, 1985, through
July 31, 1986).
Additionally, the previous
assessment
period
identified an apparent
weakness
by plant personnel
in attention
to detail
and adherence
to procedures
in the area of radiological
controls
and
a lack of program direction involving procedural
changes
and data'collection
in the radwaste
startup testing program
for Unit 2.
During this appraisal
period, significant improvements
were
made in
management's
involvement in ensuring quality in C&RP areas.
Specifically, the licensee
met.the challenge of initial refueling
outages
for both Units without the occurrence
of any significant
radiological incidents.
-During 1986, the licensee
only had 304
person-rem for both Units.
The 1986 national
average for PWR plants
was
392 person-rem
per Unit.
Through June
30, 1987,
DCPP had about
310 person-rem.
DCPP anticipates that less than
350 person-rem will
be accumulated for both Units during 1987.
The low exposures
are
a
reflection of an effective
ALARA program.
Other examples of
management's
involvement in ensuring quality include:
the
anticipatory
and effective implementation of a program to control
personnel
exposures
from radioactive particles,
implementation of
water chemistry control measures
including a
new secondary
chemistry
laboratory provided with state-of-the-art
equipment
and the
effectiveness
of their contamination control program in maintaining
the plant clean.
The licensee
resolved
most technical
issues with appropriate
conservatism,
technical
expertise
and supporting documentation.
Two
long-term issues
regarding the reporting of radioactive effluents
released
from their hot chemistry laboratory
hood exhaust
system,
and effluent sampling requirements
of their new radioactive laundry
and respirator cleaning facility were effectively resolved.
Additionally, the licensee
recognized
the
need
and effectively
reduced the quantity of radioactive material
released
in liquid
effluent releases.
Responses
to
NRC initiatives have
been timely and conservatism
was
routinely exhibited when the potential for safety significance
existed.
One example involving the release
of workers from the
radiologically controlled areas
who had alarmed the licensee's
new
sensitive
personnel
contamination monitors
was conservatively
resolved
by the
C&RP management
and engineering staff.
Two Severity Level
V violations were identified during this
assessment
period.
The violations involved the failure to
adequately
post
and adherence
to
administrative controls concerning the use of procedures
(Note-
this violation was against
both Units and is so indicated in Tables
1 and 2).
The violations represented
a need to improve management
oversight
and attention to detail in these
areas.
The violations
were minor in nature
and not indicative of a programmatic
breakdown
in radiological controls.
Only one
LER was submitted in this functional area during this
period.
Effective corrective action was taken in a timely manner.
Key positions
were identified and responsibilities
defined.
Expertise is available within the plant and corporate staffs
and the
use of outside consultants
is minimal.
Experience
levels for
management
and technician staff meet and/or exceed
commitments
made
by the licensee at the time of licensing.
Corporate
management
oversight
and technical
support
was observed during most of the
inspections
and especially during the Unit 1 and
2 refueling
outages.
Conclusion
Performance
Assessment
Category
1.
The licensee
has
shown
an
improving trend in this functional area.
Board Recommendations
The licensee
should continue the high level of management
and staff
awareness
and corporate
support to maintain the present
performance
level.
Attention to administrative controls,
use of procedures
and
further reduction of radioactivity in liquid discharges
should
be
given more emphasis.
Maintenance
~Anal ala
During this
SALP period the maintenance
and instrumentation
and
controls
(I&C) work programs
were inspected
on a routine basis
by
resident
and regional staff.
In addition,
a team inspection in
February
1987 focused,
in large part,
on maintenance activities.
A
total of 769 inspection
hours were expended
in the functional area
of maintenance.
There were two enforcement
items
and fourteen
reportable
events
considered attributable to the maintenance
functional area.
The licensee's
actions
addressed
in their June
15,
1987 letter to
the
NRC generally apply to the maintenance
and
I&C work areas,
as
well as operations
and other functional areas.
In particular,
actions to improve formality of communications,
and procedure
compliance
are applicable
and appropriate.
For example,
a Level IV
violation for ineffective corrective action
was issued
because
of
repeated
containment airlock door failures.
At least
one instance
of failure was caused
by. informal communications
regarding
maintenance
done
on the door.
Likewise,
a section of Unit 2
piping had been flame heated
"as
an experiment"
(rendering it
inoperable or at least questionable
in its integrity), but the
maintenance
engineer in charge
had not formally prevented
reuse of
the pipe.
Work, in fact, continued toward reuse of the pipe before
the integrity of the pipe was formally questioned.
Other problems
identified during the
SALP period included
I&C personnel
not
following their procedures,
maintenance
engineering
personnel
providing erroneous
information to maintenance
foremen verbally and
without proper design authority or evidence of having involved the
engineering organization.
Another example of poor; or insufficiently
controlled work authorization occurred at the end of the
SALP period
and, although unresolved,
involves maintenance
personnel
changing
the support configuration of reactor vessel
head area
cables in Unit
2 without formal work authorization.
These
occurrences
underscore
the importance of formal communications,
adherence
to proper work
authorization procedures,
and personnel
attitudes to these
fundamental
concepts
of nuclear plant operation.
Other specific maintenance- weaknesses
identified during the
period included the team inspection findings of a lack of
preventative
maintenance
on manual
valves
and
a lack of effective
tracking of maintenance
backlogs.
10
Management
involvement in the maintenance
and
I8C work areas
showed
consistent
evidence of prior planning
and provided defined
procedures
for the control of activities.
The I&C Manager
has
demonstrated
an innovative technique of working with his technicians
on a regular basis.
The maintenance
manager
was regularly involved
in significant maintenance
tasks.
The work planning department
is a separate
organization at Diablo
Canyon which is involved in the maintenance
functional area.
The
work planning department
demonstrated
an overall capability of
dealing with large outage workloads
and developed
contingent work
plans for unexpected
outages.
In all three areas
of maintenance
control (maintenance,
I8C, and
work planning) evidence
suggested
that decision making was not at a
level which ensured
adequate
management
review.
Examples
included
maintenance
engineers
making design decisions
regarding
washers,
performing unqualified heating experiments
on
RHR piping,
and
I8C technicians
going beyond procedure
bounds during annunciator
testing.
Problem reviews were not always timely and sound;
because
the lack
of formal documentation,
as previously discussed,
did not provide
for detailed action plans,
and complete,
well maintained
records.
Maintenance
management
has taken effective action in hardware
oriented problem areas,
but the recurrence
of problems in personnel
activity and attitudinal
areas
(such
as informality of work control)
indicated that an adequate
root cause
analysis
had not been
performed.
Several
licensee
commitments in the June
15,
1987 letter
are designed to address
these
issues.
The licensee's
approach to maintenance
department
technical
issues
has
been generally conservative
and sound.
For example,
the
licensee
devised
a unique method of radiography of main steam
stop
valves to verify operability in Unit 2.
The licensee's
responsiveness
to
NRC initiatives in the maintenance
area
have
been generally timely and acceptable
as, for example,
in
verifying Unit 2 Main Steam isolation valve operability by
radiography.
The licensee
has
shown responsiveness
in improving
personnel
attitudes
and formality in the maintenance
area.
The licensee's
enforcement history in maintenance
has not
demonstrated
repetitive violations, although the problems
encountered,
which did not rise to the level of a violation, have
shown the
same repetitive attitudinal cause;
an apparent
breakdown
of formal controls
and procedural
compliance.
There were two
violations directly associated
with maintenance
involving an
unauthorized
material for an oil ring (Severity Level IV) and
a lack
of lubricant controls (Severity Level V).
Licensee staffing in this area
appeared
adequate
to perform
.
necessary
immediate work.
The team inspection identified the fact
that there were
a large
number of long standing minor tasks
which
I
11
were not being corrected
or trended.
The number of such items
may
indicate inadequate
staffing, however, the licensee is developing
trending information and is committed to taking appropriate
actions.
Conclusion
Performance
Assessment
- Category
2
Board Recommendations
Licensee
management
should
implement corrective actions in the
maintenance
area with particular emphasis
on procedure
compliance,
formality of controls,
and the trending
and reduction of maintenance
backlogs.
Surveillance
~Anal sis
During this
SALP period the licensee's
surveillance activities were
inspected
by the resident
and regional inspectors,
and by an
NRC
team inspection in February
1987.
Additionally, licensee activities
in nondestructive
examination surveillances
were examined in a
special
inspection during the Unit 2 refueling outage which included
independent
measurements
and examinations
by qualified
NRC personnel
using
NRC test equipment.
A total of 456 inspection
hours were
expended
in thi.s functional area.
There were three enforcement
items
and fourteen reportable
events
assigned
to the'surveillance
area.
The problems
and events that occurred during this
SALP period,
assigned
to surveillance activities, largely were
due to operations
and
I&C surveillance
personnel
not following procedures
and
'exercising faulted informal communications
regarding the status of
testing.
These subjects
were addressed
by licensee
management
in
their June
15,
1987 letter to the
NRC.
Overall
management
involvement in the surveillance
area
has
been
evident.
During the last SALP, problems in missed surveillances
were noted;
however, during this
SALP the surveillances
missed
were
greatly reduced in number
and the root causes
were identifiable to
subtle data entry errors
from the previous
SALP period,
Management
involvement in the resolution of missed surveillances
was evident.
The licensee's
approach to resolution of technical
issues
and
response
to
NRC initiatives in this area were generally
sound,
thorough,
and timely.
For example,
instances
of informal turnover
of the status of I&C work were corrected procedurally in a timely
manner.
The enforcement history in this area involved three violations,
attributable to not following procedure
and informal communications,
which are the
same general
management
issues
discussed
in other
functional areas
in this report.
Four of the fourteen reportable
12
events
are attributable to informal communication
and
a lack of
procedure
compliance in the surveillance
area.
An example of this
was the failure to meet the Technical Specification action statement
for an inoperable
RCP under-frequency
relay.
The root causes
were
procedure
compliance
and informal communication.
Staffing in general
appeared
adequate.
Further, the licensee's
nondestructive
examination staff was determined to be highly
qualified for their positions
based
on inspection efforts by the
NRC's
NDE staff.
Conclusion
Performance
Assessment
Category
2
An improving trend was noted in a significant reduction in the
number of missed surveillances.
Board Recommendation
Licensee
management
should continue to implement corrective actions
regarding personnel
not following their procedures
and improve the
formality of communication.
Fire Protection
~Anal aia
During this assessment
period,
one inspection
was conducted in the
area of fire protection.
This inspection consisted of an assessment
of the licensee's
compliance with the
NRC's fire protection program
requirements
and whether the facility continues
to be capable of
achieving post-fire safe
shutdown using the existing plant
configuration,
procedures
and trained personnel.
A followup was
also
made of previous licensee
and
NRC identified open items.
In
addition, the project and resident
inspectors
provided continuing
observations
in this area.
In general,
the licensee's
implementation of fire protection program
requirements
was determined to be satisfactory in the areas
assessed.
The inspector's
assessment
recognized
the conscientious
effort expended
in these
areas,
by the licensee,
citing strengths
in
staffing for program implementation,
management
commitment and
involvement, clear definition of the program requirements
and
assignment
of responsibilities
to qualified individuals.
The
professionalism
and dedication of the full-time fire protection
staff was also noted
by the resident
inspectors
during several
small
fire situations
and drills.
However,
a number of deficiencies
and
areas for improvement were identified.
Three areas of particular
concern
were:.
The responsibilities
assigned
to the site fire brigade
appeared
to be broader than firefighting in the immediate plant area;
specifically, responding to fires in the large owner-controlled
13
area outside the plant protected
areas.
This problem is
complicated
by potential
delays for'ffsite fire department
response
due to the remoteness
of the site
and the potential
that the offsite fire departments
may be occupied with other
firefighting activities.
The plant fire detection
and fire suppression
system
annuniciation,
located in the control
room,
was considered
as
a
potential
area for improvement.
The licensee
has recognized
the problem and is considering
enhancements
for better
utilization of personnel
and other resources,
as well as,
modifications to centralize fire annunciation
in the control
room area.
Some delays in the maintenance activities (10 Action Requests)
to assure fire door integrity have
been observed.
The licensee
should consider actions to assure
timely maintenance activity
in the fire protection functional area.
One
LER was submitted in the fire protection area during this
period.
Also, corrective action to
LER No. 86-03 from the previous
SALP period was determined satisfactory
and closed out during this
period.
Conclusions
Performance
Assessment
- Category
2
Board Recommendation
The board
recommends
that the licensee
continue to devote
comprehensive
management
attention to its commitments
and
responsibilities
in this area.
The focus of management
attention
and involvement in this area
should extend into effective
implementation of all aspects
requirements
and their interface with other elements
of plant
operations.
Particular
emphasis
should
be denoted to strengthening
weaknesses
identified in the areas of manual firefighting capability
and design deficiencies
in the fire alarm system.
6.
Emer enc
Pre aredness
During this
SALP period, approximately
157 hours0.00182 days <br />0.0436 hours <br />2.595899e-4 weeks <br />5.97385e-5 months <br /> of direct
inspection effort were devoted to the assessment
of the emergency
preparedness
(EP) program for the Diablo Canyon Nuclear
Power Plant.
In addition,
some of the inspection effort of the resident
inspectors
was in the area of EP.
The 1986 and
1987 annual
emergency
preparedness
exercises
were not within this
SALP period.
However, the 1986 exercise
performance
was commensurate
with a SALP
Category
1 rating.
Licensee
performance
during this assessment
period demonstrated
that
management
had been actively involved in achieving
a quality
program.
This is the result of assuring that the appropriate
level
14
of management
has
been assigned
the review responsibility.
Management
review of items affecting
EP have
been thorough
and
technically sound.
Corporate
management
has
been actively involved
in matters affecting site
EP and
has provided the support necessary
to assure
an ability to readily respond to emergencies.
Records
and
documents
related to the
EP p'rogram were easily accessed
and well
maintained.
The licensee's
approach to the resolution of technical
issues
from a
safety standpoint
has always
been conservative
and in the cases
reviewed
was technically'sound.
The licensee
has evaluated
technical
issues affecting safety thoroughly.
Resolutions
are
conservative
and timely.
One recent
example in this area
was
improvements to the Appendix Z's of the Emergency
Procedures.
These
are also
used for accident classification.
During April of 1987,
the licensee
encountered
problems with the
RHR -system while
operating in a half loop configuration.
Shortly after that event,
some questions
were brought
up regarding the classification of the
event.
The licensee
evaluated
the concerns
and
made
changes
to tPe
Appendix Z's.
The changes
were more conservative
and provided the
Shift Foreman with better definition and guidance for accident
classification.
Licensee
management
has
been very responsive
to concerns identified
by the
NRC.
Timely and thorough corrective actions
have
been
initiated when concerns
were brought to their attention.
As an
example,
questions
were raised regarding the assembly of plant
personnel
downwind of the plant during an accident.
Assembling
downwind of the plant was determined to be the most expedient
direction for quickly evacuating plant personnel.
However, the
adverse effects of assembling
downwind of a release
of toxic or
radioactive material
was discussed
with Plant Management.
Shortly
after the discussion,
the issue
was quickly resolved.
The emergency
procedures
were quickly modified to provide guidance
for the
Emergency Coordinator to consider
assembling
in areas
to the North
or East of the plant under certain conditions.
Only one severity level IV violation which dealt with the failure to
notify the County of an unusual
event
was identified during this
assessment
period and it was not,indicative of any programmatic
breakdown.
Licensee
management
quickly evaluated
the problem and
corrective action was prompt and effective.
o
The staffing and training in the functional area of emergency
preparedness
continues to be excellent.
This is evidenced
by an
extensive training program for the corporate
support organization,
as well as the site personnel,
and by extensive
use of the simulator
to train control
room staff in the response
to an accident including
mitigation, notification, classification
and protective action
recommendations.
A review of numerous
LERs and documentation
regarding
two "unusual
events"
performed during this
SALP period,
disclosed all events
examined
were appropriately classified
according to the
DCPP emergency
procedures.
15
EP training was current
and records
were well maintained
and
available.
Conclusion
Performance
Assessment
- Category l.
H
Recommendations
Continued
management
attention
and commitment in maintaining
EP.
Securit
and Safe
uards
~Anal aia
During this assessment
period of August 1, 1986, through July 31,
1987,
Region
V conducted three physical security inspections
at the
Diablo Canyon Nuclear Power Plant.
A total of approximately
290
hours of direct inspection effort were conducted
by regional
inspectors.
In addition, the resident
inspectors
provided
continuing observations
in this area.
There were
no material
control
and accounting
inspections
conducted
during this assessment
period.
With regard to management
involvement in assuring quality, corporate
and plant management
have
been involved in the implementation'nd
review of the overall security program and have
implemented
remedial
measures
to correct deficiencies'dentified
in the course of the
physical security inspections.
During the first half of this
assessment
period,
Region
V observed
maintenance difficulties with
assessment
aids
and with equipment inside the alarm stations.
After
discussing
these
observed deficiencies with security
and plant
management,
Region
V observed
an improvement in these
areas.
Additionally, the security organization
demonstrated
their ability
to effectively manage
a 55-hour guard strike at Diablo Canyon.
During this strike, the security managers
and members of the
proprietary security force filled required vacancies
of the striking
contract guard force.
Further,
during this assessment
period, the
capability of the plant security computer
was incr eased,
and efforts
are presently
underway to replace the present security card readers
with more reliable units throughout the plant.
The security management
demonstrated
a coordinated effort with other
plant staff in preventing safety/security
problems at, Diablo Canyon.
Currently, the security
management
is in the process
of correcting
a
situation identified by a Region
V inspector in which the security
departments'se
of assigned
radio communication frequencies
could
interfere with the radio communication
equipment assigned
to the
Units
1 and
2 operations staff.
During the current
assessment
period, six information notices
related to security were issued.
The licensee's
actions,
as
reviewed to date,
were generally found to be appropriate.
Upon
reviewing Information Notice 86-88, titled:
Compensatory
Measures
16
for Prolonged
Periods of Time, it was noted that portions of the
licensee's
implementing procedures
for their required program of
providing compensatory
measures
for breached
or degraded barriers
were not-consistent with NUREG-1045.
The inconsistency
occurred
because
the licensee's
procedures
allowed the use of unarmed
security officers at deficient vital area barriers
when compensatory
posts
were established.
NUREG-1045 specifies that armed security
officers are to be used.
The enforcement history for this assessment
period identified a
total of three violations.
Two Level-IV violations pertained to the
licensee's
failure to properly search certain material entering the
protected
area,
and the licensee's
failure to properly respond to a
security alarm.
The Level
V violation pertained to the licensee's
failure to provide adequate
assessment
coverage to the protected
area perimeter.
The three physical security inspection reports
issued
during the
assessment
period discussed
137 security events that had been
previously identified by the licensee,
and were properly reported to
the
NRC operations
center pursuant to 10 CFR 73.71(c).
The majority
of these
events pertained to security card
keys that
had either been
lost, found, misissued
or misread
by the card readers
at the vital
area portals.
Eight of these security events related to unsecured
or degraded vital area barriers;
and were primarily caused
by plant
maintenance
personnel.
In spite of a previous
NRC initiative, as
documented
by
NRC Information Notice No. 85-79, related to
inadequate
communication
between
maintenance,
operations
and
security organizations,
three,(of the above eight) barrier problems
resulted
from plant work crews
removing portions of vital area
barriers without considering the security implications of their
actions.
Mith respect to staffing, the licensee's
total security staff was .
adequate
to fulfill commitments.
The licensee
continues to utilize
a uniformed security force comprised of both proprietary
and
contract personnel.
The security training and qualification program
was adequate
to provide security personnel
with the knowledge
and
practical application of their responsibilities
necessary
to conduct
the security program in accordance
with established
commitments.
Conclusion
Performance
assessment
- Category
2.
Recommendations
Licensee
management
is encouraged
to be more pro-active
and become
more involved in the areas
of:
internal coordination
between
security,
maintenance,
and operations;
management
review of
Information Notices
and referenced
NUREG's;
and resolution of the
safety/security
issue involving radio communication frequencies for
security
and operations
personnel.
t
f
17
~0nta es
~Anal sis
During this
SALP period the licensee
outage activities were examined
by the resident inspector staff.
A total of 994 inspector
hours
were expended
in this functional area.
No violations were
identified and four reportable
events
were considered
assignable
to
the outage functional area.
The licensee
had two refueling outages
during this
SALP period.
The
first refueling outage of Unit 1 was from August to December
1986
and the first refueling outage of Unit 2 was from April to July
1987.
The outage
scopes
were ambitious
and included major
modification work such
as replacing feedwater
heaters
and retubing
main steam reheaters,
replacement
feed ring
nozzle J-tubes,
and replacement'f
RCP,. seals.
Additionally, during
the Unit 1 refueling,
a court decision
mandated
the reinstallation
of the low density fuel racks which caused
the licensee to
reschedule
significant amounts of work with little prior notice.
The licensee's
overall performance
in outage
management
appeared
to
be good in that the number of problems
encountered
were not
excessive,
considering the scope of the outages
and the licensee's
limited outage experience.
Additionally, the licensee initiated a
lessons
learned
program at the
end of the first Unit 1 refueling
outage
and did,not repeat
the mistakes
during the Unit 2 outage.
Management
involvement in the outage activities
showed consistent
evidence of prior planning and corrective action was
shown to be
effective by the lack of repetition of specific outage
problems
and
the lack of radiological
problems which are often. associated
with
licensee's first refueling outages.
Also, the work planning
department's
effort showed foresight and assured
correct performance
of outage activities.
The licensee's
approach to the resolution of technical
issues
demonstrated
a clear understanding
of the issues
and conservatism
was generally exhibited.
Specific examples
included the licensee's
actions
regarding
a tilted fuel assembly
encountered
during Unit 1
refueling operation
and licensee, actions regarding investigation for
missing disk nuts
on the main steam isolation valves.
The most
significant event during the outages
was the loss of
RHR in Unit 2
on April 10, 1987.
However, that event
has
been deliberately
discussed
in other functional areas in this report (such
as
operations)
since the root cause
problems identified were more
accurately attributable to those
areas
rather than the outage
area.
The licensee's
responsiveness
to
NRC initiatives was
good as
demonstrated
by their cautious actions in response
to the tilted
fuel assembly
during the Unit 1 refueling.
No violations were directly attributable to the outage
area.
The
violations that occurred during the outage period were caused
by
18
weaknesses
in the basic attitudes
toward formality of communciations
and control of, work exhibited by the involved departments'.
These
areas
have
been previously addressed
in other sections
of this
report.
Operational
events
uniquely attributable in root cause to outage
activities include only the tipped fuel assembly situation
on Unit 1
which was not repeated
in Unit 2's outage.
Licensee staffing for outage
management
appeared
to be well thought
out and adequate.
The assignment
of dedicated
department
outage
coordinators
and twice daily outage
meeting appeared
to be
effective.
Conclusion
Performance
Assessment
- Category l.
Board Recommendation
Licensee
management
should continue to apply their lessons
learned
program to outage activities,
and continue to demonstrate
carefully
coordinated
and scheduled
complex work activities.
ualit
Pro
rams
and Administrative Controls Affectin
ualit
~Anal sis
During this
SALP period,
the licensee's
quality programs
and
administrative controls affecting quality were examined
on
a routine
basis
by the
NRC residents
and regional
inspectors.
In addition,
a
special
team inspection
was conducted in February
1987
which'ncluded
a specific assessment
of QA/QC effectiveness.
Further,
an
investigation of allegations
dealing with the procurement of spare
parts afforded
an opportunity for senior regional
inspectors
to
examine
QA/QC actions
and interfaces.
An AIT review of the .Unit 2
loss of
RHR event also involved an examination of the
QA/QC
involvement in that event.,
A total of 285 inspection
hours were
expended
in this functional area.
Six violations and three
reportable
events
were considered attributable to this functional
area.
In the area of quality programs
and administrative controls
affecting quality, the licensee
has
shown both strongly positive and
some notably negative
examples of performance,
as explained
below.
Early in the
SALP period, licensee
management
response
to events
was
perceived to be too informal and lacking depth.
Action and
investigative plans were verbal in nature
and did not adequately
determine root causes
and, therefore,
did not identify meaningful
corrective action.
Examples of this type of informality were
experienced
in the Unit 1 containment
door failure in August 1986
and the Unit 1 high pressure
turbine oil fire in December
1986.
However, in balance of the above,
corporate
level involvement was
19
evident in several
of the significant events
and the licensee's
approach to event analysis
and actions
was formalized and improved
during the appraisal
period.
The licensee's
response
to the loss of
RHR event
was judged to be excellent in formality, management
involvement and.depth.
Although the licensee
has
had policy requirements
to follow
procedures,
there
was continued evidence throughout the
SALP period
of failure to follow procedures
in the performance of duties.
These
procedural
issues
were largely identified by the
NRC rather than
through the licensee's
quality programs.
The licensee,
in their
June
15, 1987, letter,
committed to aggressively
address
the
procedural
compliance
issue.
Although further examples of
procedural
noncompliance
occurred after the June
15,
1987 letter,
actions
toward improving the licensee's
adherence
to procedures
were
showing
some effectiveness
in that the licensee's
staff was noted to
be involved in procedure
improvement
and clarification activities.
The examination of procurement allegations
determined that, although
the licensee
has
a comprehensive
and in-depth audit program
and the
audit program
has identified meaningful findings, the management
response
to resolve those=findings
has not always
been aggressive
or
timely.
Additionally, there
appeared
to be
a lack of effective
cooperation
between site management
and corporate
gA.
Likewise,
NRC inspection findings regar ding the Unit 1 containment
door event indicated
a lack of timely resolution, primarily due to
the quality programs
and administrative controls programs failing to
identify the root cause
and failing to follow through
on
resolutions.
The failure to identify root cause
led to additional
door failures in 1984,
1985 and 1986.
The inspection
program also identified a situation regarding the
closing of the
RHR crosstie
valve in Unit 2.
In this case,
the
licensee's
administrative controls
and quality programs
were not
sufficiently timely to implement preventive
measures
regarding
a
potential
RHR system operability concern before it actually
occurred.
The potential for the situation
was identified by
licensee
personnel
and information was provided by an
NRC
information notice prior to the event,
but failure to implement
actions resulted in closing the crosstie
valve because
operations
personnel
had not been forewarned.
Other
examples of weaknesses
identified in the quality programs
and
administrative controls area were identified by the AIT team
including:
a failure to inspect the temporary Reactor Vessel
Refueling Level Indicating System;
lack of a 10 CFR 50.59 review for
an
RHR cavitation test;
and poor control
on the installation and use
of temporary
systems
in use at the time of the event.
The licensee's
responsiveness
to
NRC initiatives in the quality
programs
area
has
improved during the
SALP period.
Specifically,
the licensee readily committed to improvements
in tracking and
trending guality Evaluations,
and improvements
in temporary
system
control.
20
The enforcement history in this area
had
no major violations but the
four Level IV violations indicated programmatic
weakness
in the
identification and timely resolution of problem areas.
Operational
events directly attributable to weak guality programs
and administrative controls largely covered the
same
events
which
led to violations already discussed.
Specific'ally, this included
the Unit 1 containment
door opening
and closing the
RHR crosstie
valve.
The licensee staffing in this area
was determined to meet regulatory
requirements
and the qualifications of gC personnel
was determined,
by
NRC gA specialists
during the team inspection,
to represent
a
high caliber of gC personnel.
The onsite review groups appeared-
adequately
staffed.
The licensee,
in response
to
NRC findings, committed to improve the
timeliness
and quality of root cause
analysis
as described
in their
June
15, 1987, letter.
In that regard,
the licensee
has initiated
some innovative programs
and actions including a "top ten" list of
problem areas
to focus licensee
management
attention
and special
training sessions
for root cause
analysis
groups.
Conclusion
Performance
Assessment
- Category
2
Board Recommendation
Licensee
management
should effectively implement the improvements
defined in their June
15, 1987, letter and continue to emphasize
aggressive
problem identification and timely resolution
from all
organizations
involved in quality programs
and administrative
controls affecting quality.
Additional emphasis
should
be placed
on
timely evaluation
and implementation of problems
areas identified
through industry experience.
10.
Licensin
Activities
Licensing activities were dominated
by three major areas
during this
SALP period:
the Long-Term Seismic
Program,
in which the most
recent
seismic information is being evaluated;
the spent fuel pool
rerack proposal,
involving free-standing
racks
and public
intervention by the Sierra Club;
and routine license
amendment
requests
and resolution of generic issues,
license conditions, etc.
In the
Long-Term Seismic
Program it is the consensus
of the
NRC
staff and its consultants
that
PG&E is conducting
a professionally-
oriented, objective program that is addressing
the requirements
of
~ the Unit 1 license condition.
The program received staff approval
and is proceeding
on schedule.
By letter dated
September
24, 1987,
PG&E requested
an amendment to the Diablo Canyon Unit 1 Operating
License to extend the submittal
date for the final report from
~July 31,
1988 to not later than July 31,
1989.
PG&E is conducting
21
k
numerous
in-process
workshops to both keep the staff and its
consultants
abreast of the program
and to allow comments
as the
program is implemented.
The spent fuel pool rerack proposal
has involved intensi've licensing
activity due both to the complexity of some of the issues
raised
(e.g., multi-rack impact analyses)
and the tight (and= changing)
schedule for implementation..
Few license 'amendments
were issued during the first half of the
period
due to the emphasis
on the spent fuel pool rerack review and
hearing.
The second half saw eight amendments
reviewed
and
approved,
resulting in a few general
and specific comments.'-
PG8E license
amendment
requests
(LAR) could be improved by providing
a better
and more complete safety basis for the change.
For
example,
in LAR 87-02,
PG8E did not present
an adequate
basis for
changing the setpoint for the
S/G low level reactor trip to 15K and
failed to demonstrate initially that it understood that this circuit
is used for accident mitigation,, although not at the
25K setting.
In other words,
PG8E confused the setpoint with the trip function.
In LAR 87-07 regarding
a minor change to a biological sampling
point,
PG8E did not provide
an adequate
description of the change
or
an adequate
basis for its acceptance.
On May 22,
1987,
PG8E discussed
the possibility of reducing
RHR flow
to 1500
gpm in preparation
for an upcom'ing 1/2 loop evolution.
A
month or more later,
PG8E requested
an emergency
Technical
Specification
change to do so but withdrew the request
when it was
apparent that the request
had not. addressed
the boron dilution
accident
aspects
described
in the basis of the Technical
Specification.
These
examples of some of the
PG8E
amendment
requests
suggest that
the review process
could be improved by a more critical look at
amendment
requests
both by the onsite
and offsite review committees.
On the positive side,
PG8E is well staffed both at its headquarters
and at the site with capable
personnel
and both are responsive
to
NRC requests.
PG&E has
been especially cooperative
in the licensing
area during and after the transfer of Diablo Canyon to a new project
manager
and the
new
NRR organization.
Conclusion
Performance
Assessment
- Category
2
Board Recommendations
1
The Board
recommends that
PG8E put more emphasis
on providing an
adequate
basis for amendment
requests
and perform more critical
reviews by the on-site
and off-site review organizations.
22
Trainin
and
ual if i cation
Effecti veness
~Anal sis
During the reporting period,
two Replacement
Examinations
and one
Pilot Requalification Examination were conducted.
A total of ten reactor operator candidates
and nine senior operator
candidates
were administered written and operating tests
during two
replacement
examinations.
Nine reactor operator candidates
and nine
senior reactor operator
passed
these
examinations.
One reactor
operator candidate
passed
the written examination but failed the
operating examination.
No generic
weaknesses
were observed
during
either of these
examinations.
The Requalification
Program evaluation
conducted
was
based
on the
NRC Pilot Test Program
as defined in a memorandum
from W. T.
Russell,
Director, Division of Human Factors
Technology,
NRR, dated
May 22,
1986.
This program
used the criteria of NUREG-1021,
Revision 0, for evaluation of the facility performance.
The
evaluated
program must fall in one of three categories;
"satisfactory," "marginal," or "unsatisfactory."
Based
on this
evaluation of the Requalification
Program,
the licensee
was
evaluated
as "satisfactory."
Based
on the observed pass/fail
rates,
the requalification
examination evaluation
and the specific events listed below, the
performance of this facility in the area of licensed operator
training appears
to be "satisfactory."
Management
personnel
were
responsive
in addressing
minor criticisms of their oral
and written
requalification examinations
and have consistently
been involved
with any positive or negative
comments
regarding their qualification
and training programs.
A procedure
step requiring clarification,
identified during an examination
was promptly resolved
by facility
management.
The facility has
used the
NRC Examiner Standards
for
their own examination format and content.
They have also
been
responsive
to
NRC initiatives for developing
a facility question
bank for facility and
NRC use;
and they have continued to improve
simulator examination in the area of documentation
and expected
candidate
performance.
The facility's training programs for both licensed
and non-licensed
operations
personnel
have
been accredited
by INPO.
The facility
simulator has generally'erformed
well'and properly models almost
all scenarios
used to date
by the
NRC.
In addition, the facility
has constructed
an additional training building containing training
facilities for Instrument
and Control Technicians,
Chemists,
Health
Physics
pe'rsonnel,
and mechanical
maintenance
personnel.
Conclusion
Performance
Assessment
- Category
1
23
Board Recommendations
Licensee
management
should continue to improve simulator examination
preparation
by the facility in the areas of documentation
and
expected
candidate
performance.
V.
SUPPORTING
DATA AND SUMMARIES
1.
Licensee
Event
Re orts
LERs
Office of Analysis and Evaluation of Operational
Data
(AEOD)
reviewed
a sample of 15
LERs (9
LERs for Unit 1 and
6 for Unit 2)
reported during this assessment
period.
The evaluation consists of
a detailed review of each selected
LER to determine
how well the
content of its text, abstract,
and code fields met the requirements
of NUREG-1022 and its supplements.
The
LER discussions
concerning
the root cause,
the assessment
of the
safety consequences,
the failure mode,
mechanism,
and effect of
failed components,
and personnel
error were well written. However,
there are
some areas
needing improvement--text,
abstract
and coded
fields.
They are
summarized
as follows:
A.
Text
Four of the
LERs were considered
to lack in detailed safety
assessment:
86-013-01,86-022,
87-004 and 87-007.
An assessment
of the consequences
and implications of the
event including specifics
as to why it was concluded that
there were "no safety consequences," if such
was the case.
It is inadequate
to simply state "this event
had
no safety
consequences
or implications" without explaining
how that
conclusion
was reached.
A safety assessment
should discuss
whether the event could
have occurred
under
a different set of conditions.
Finally, a safety assessment
should
name other
systems (if
any) that were available to perform the function of the
safety
systems that were unavailable during the event.
The requirement to provide adequate
identification for failed
components
was considered deficient in one of the three
LERs
involving a failed component.
In most cases,
this requirement
can
be met by simply providing the manufacturer
and model
number for each failed component.
The Energy Industry Identification System (EIIS) codes
were not
provided for the components
or systems
mentioned in seven of
the
15
LERs.
These
codes
should
be provided for all components
and systems
referred to in the text, not just those that fail.
24
B.
Abstract
While there are
no specific requirements
for an abstract,
an
abstract
should
summarize
the following information from the
text:
Cause/Effect
Responses
What happened
that
made the event
reportable.
Major plant,
system,
and personnel
responses
as
a result of the event.
Root/Intermediate
The underlying cause of the event.
Cause
What caused
the component
and/or
system failure or the personnel
error.
Corrective Actions
What was
done immediately to restore
the plant to a safe
and stable
condition and what was
done or planned
to prevent recurrence
of the event.
While .these
requirements
were, in general,
adequately
addressed
in the abstracts
of the
LERs reviewed, four of the abstracts
were deficient in the area of presentation.
The use of a more
concise
summary would have
improved the abstract
score for the
four LERs that exceeded
the specified
maximum length of 1400
spaces.
C.
Coded Fields
The main deficiency in the area of coded fields involved the
titles.
Seven of the
15 titles failed to include adequate
cause
information,
two failed to include the result of the
event
and one failed to include the link between
the cause
and
the result.
While the result is considered
to be the most
important part of the title, cause
and link, information must
be included to make
a title complete.
~Summar
This is the second
time the Diablo Canyon
LERs have
been evaluated
using this methodology.
The results of this evaluation indicated
that the overall quality of the Diablo Canyon
LERs, for the three
areas that are evaluated
(ime., the text, abstract,
and coded
fields),
has
remained virtually unchanged
from the previous
evaluation of an overall average
LER score of 9.3.
The previous
industry average
was 7.8 as
compared to the current industry average
which had increased to 8.4.
The quality of the discussions
concerning root cause,
corrective actions,
and safety system
responses
has increased
since the previous evaluation.
The areas
requiring improvements
are
as identified.
2.
Part
21
Re orts
Letters
87-13-P
Retainin
Nut Problem
Investi ative Matters
b
Office of Investi ation
NRC inquiries open
and pending
as of August 1, 1986.
NRC inquiries closed during SALP period (August 1,
1986
through July 31,
1987.
NRC inquiries opened during this timeframe and pending
on July 31,
1987
.
~
~
~
4
~
~
~
3
4..
Escalated
Enforcement Actions
A.
Civil Penalties
None
B.
Orders
Issued
None
C.
Confirmation of Action Letters
EA-87-67, dated
May 6, 1987, "Returning Diablo Canyon Unit 2 to
mid-loop operation."
5.
Mana ement
Confer ences
Held
November
1986 -
A management
meeting
was held to discuss
a number
of recent events that had occurred at Diablo Canyon
Nuclear
Power Plant.
Some of the events
discussed
were containment
door mechanical
interlock problems,
snubber control problems,
pin problems
and main steam line isolation valve
check valve nut problems.
The meeting focused
on
improved cause analysis of events,
managements
followup and awareness
of measures
to correct
events,
and actions
taken to reduce
the
number of
events.
March 1987
A management
meeting
was held to discuss
recent
plant events
such
as reactor trips; four for Unit 1
and two for Unit 2; main turbine oil fire (Unit 1);
and T.S. violations.
Also discussed
were the
backlogs of action request
and Unit 1 refueling
"Lessons
Learned."
Report 50-323/87-18
(NUREG-1269) dated
June
19, 1987,
"Augmented
Inspection
Team - Inspection at Diablo Canyon Unit 2."
26
7.
NRR Meetin
s With Licensee
Date
August 15-16,
1986
August 19-21,
1986
September
10,
1986
September
19-23,
1986
September
25-26,
1986
October 21-22,
1986
October 23-24,
1986
November 20,
1986
November
21,
1986
December
10-12,
1986
December
16,
1986
January
22,
1987
February 17-18,
1987
February
18,
1987
March ll, 1987
~Pur oee
LTSP-Geology/Seismology/Geophysics
Field
Trip, San Luis Obispo, California
LTSP-Plant Visit and Workshop
on
PRA;
San
Luis Obispo, California (August 19, 1986)
and Newport Beach, California
(August 20-21,
1986)
Meeting with NRC Staff.
First meeting
on
reinstallation of Original Spent
Fuel
Pool
Racks
Meeting with NRC Staff.
.Second
meeting
on
Reinstallation of Racks
Meeting with NRC Staff.
Third meeting
on
Reinstallation; As-built Welds
LTSP-Geology/Seismology/Geophysics
Workshop,
San Francisco,
LTSP-Ground Motions Workshop,
San
Francisco,
LTSP-ACRS Subcommittee
on Extreme External
Phenomena
Meeting, Washington,
D.C.
Meeting with NRC and its
BNL Consultants,
PGEE,
and Westinghouse.
Discussion of the
BNL Evaluation of the Natural Circulation,
Boron Mixing, and Cooldown Tests
Performed
by PG8E on Unit 1
LTSP-Soil-Structure Interaction Workshop,
San Francisco,
LTSP-Ground Motion Workshop,
Bethesda,
Meeting with NRC Staff on Wet Reracking
LTSP-Workshop
on
PRA, Fragi lities Analys is,
Seismic
Hazard Analysis,
Bethesda,
Meeting with NRC Staff and its Consultants
on Rack Interactions
One-day Workshop
on the NRC's Incident
Investigation
Program (IIP) - Invitational
Workshop
I
27
March 26,
1987
Meeting with NRC,
FRC,
and
BNL on Rack
Interaction Parametric
Studies
May 5-8,
1987
LTSP-Geology/Seismology/Geophysics
Workshop
and Field Trip, San Luis Obispo, California
May 6,
1987'une
9-11,
1987
Meetings with NRC,
BNL on Rack
Interactions;
Six Close-out guestions
LTSP-So il-Structure Interaction Audit, San
Francisco,
July 15-16,
1987
LTSP-Ground Motions Workshop,
San
Francisco,
8.
Commission Meetin
s
None
9.
Schedular
Extensions
Granted
One schedular
extention
was granted
by license
amendment
during this
SALP period.
Amendment
No.
12 to the Unit 2 license
extended
the
time for submittal of an improved steam generator
tube rupture
analysis
from startup
from the first refueling outage
(June
1987) to
April 1988.
10.
Rel iefs Granted
None.
-PG8E
has requested
numerous reliefs both in its ISI and IST
Program that are under review as part of NRC's review of the 'first
10-year
inspection interval for both units.
This review should
be
finished in 1987.
ll.
Exem tions Granted
None
12.
Emer
enc
Technical
S ecification Chan
es
One emergency technical specification
change
was requested
but
withdrawn.
The proposed
change
involved plant operations
in Mode
6
(refueling) with less
than
3000
gpm flow in the
RHR system
(discussed
more fully in performance analysis).
13.
License
Amendments
Issued
Amendment
No.
(Unit 1/Unit 2)
Date
~Sub 'ect
10/8
10-21-86
Revises
the T/S to 1)
redefined the moderator
temperature
coefficientN
limits; 2) revise the f
28
-delta-
H partial power
multiplier; and '3) delete
the design feature
description of the total
weight of uranium in a fuel
rod.
11/9
01-07-87
Changes
1) T/S 3.6. 2. 3 to
assure that two containment
fan cooler units are
available
assuming
a single
failure; 2) T/S 3.6. 1.4 and
its Bases to specify
a
maximum positive containment
internal pressure
of 1.2
psig and
a maximum positive
pressure
of 46.65 psig in
the event of a loss of
coolant accident
(LOCA); and
3) Bases 3/4.6.1.6 to
specify
a maximum
containment
pressure
of
46.65 psig in the event of a
LOCA.
12/10
13/11
--/12
14/13
15/14
01-30-87
06-08-87
06"12-87
06"02-87
07-24-87
Changes
TS Section 3/4.2. 1
"Axial Flux Difference,'" to
implement for Unit 2 the
developed
relaxed axial offset control
(RAOC) methodology after
Unit 2 has
reached
a burnup
of 8000
MWD/MTU in the first
cycle.
Fuel Assemblies
Extends the time for
submittal of a steam
generator
tube rupture
analysis to April 1988
To accommodate
Cycle 2 and
later operation of Unit 2
and Cycle
3 and later
operation Unit 1
Diesel Generator
Surveillance Testing
16/15
07-27-87
Provides for operability and
surveillance tests for
certain
check valves in the
29
residual
heat
removal
and
safety injection systems
to
ensure
adequate
pressure
isolation between the
and
thes'e
lower pressure
support
systems
At the
end of this
SALP period, there were 28 amendments
and
37
other licensing issues
under review by NRR for both units.
TABLE 1
INSPECTION ACTIVITIES AND ENFORCEMENT SUMMARY 8/1/86 - 7/31/87)
DIABLO CANYON UNIT 1
Functional
Area
Ins ections
Inspection"
Hours
Conducted
Enforcement
Items
Percent 'everit
Level ""
of Effort I
Dev
1.
Plant Operations
1491
42. 5
2.
Radiological Controls
3.
Maintenance
4.
Surveillance
5.
Fire Protection
243
398
282
13
6.9
11.3
8.0
0.4
1
1
6.
Emergency
Preparedness
40
7.
Security
and Safeguards
180
8.
Outage
627
9.
guality Programs
and
212
Administrati ve Controls
5.1
17. 9
6.0
1
2
10.
Licensing Activities
ll.
Training and
gualification
Effectiveness
N/A
30
N/A
0.8
TOTAL
3516
100
8
4
Allocations of inspection
hours to each functional area
are
approximations
based
upon
NRC Form 766 data.
Severity levels are in accordance
with NRC Enforcement Policy (10 CFR Part 2, Appendix C).
Data reflects Inspection
Reports
86-22 through 87-30.
TABLE 2
INSPECTION ACTIVITIES AND ENFORCEMENT SUMMARY 8/1/86 - 7/31/87)
DIABLO CANYON UNIT 2
Functional
Area
1.
Plant Operations
2.
Radiological Controls
3.
Maintenance
4.
Surveillance
5.
Fire Protection
Ins ections
Inspection"
Hours
1910
371
174
12
Conducted
Enforcement
Items
Percent
Severit
Level ""
of Effort I II III IV
V
Dev
57.7
4.3
ll.2
5.2
0.4
6.
Emer gency Preparedness
117
7.
Security
and Safeguards
112
.3.5
3.4
8.
Outage
9.
guality Programs
and
Administrati ve Control s
10.
Licensing Activi ties
ll.
Training and
gualification
Effectiveness
367
73
N/A
31
ll.1
2.2
N/A
1.0
TOTAL
3311
100
Allocations of inspection
hours to each functional area are
approximations
based
upon
NRC Form 766 data.
12
2
Severity levels are in accordance
with NRC Enforcement Policy (10 CFR Part 2, Appendix C).
Data reflects Inspection
Reports
86-22 through 87-30.
INSPECTION
REPORT
NO ~
86-29
TABLE 3
DIABLO CANYON UNIT 1
ENFORCEMENT ITEMS
(08/01/86 - 07/31/87
SEVERITY
FUNCTIONAL
SUBJECT
LEVEL
AREA
FAILURE BY SHIFT
FOREMEN TO CONTROL
IV
1
SNUBBER WORK AND SYSTEM OPERABILITY
86-29
INADEQUATE CORRECTIVE ACTION FOR
CONTAINMENT AIRLOCK FAILURE
IV
87" 01
87-02
87-02
87"06
FAILURE TO MAINTAIN CONTROL OF
IV
LUBRICANTS CONTRARY TO PLANT PROCEDURES
FAILURE TO COMPLETE MATERIAL
VERIFICATION FORM
FOR ITEMS ENTERING
PROTECTED
AREA
FAILURE OF
TO
RESPOND
TO A
IV
SECURITY ALARM
FAILURE TO NOTIFY OFFSITE
ORGANIZATIONS IV
IN REQUIRED TIME LIMIT FOR
UNUSUAL
EVENT OF JANUARY 2,
1987
87-08
FAILURE TO
FOLLOW PROCEDURES
FOR
INSTALLATION BRONZE OIL SLINGER RING
VERSUS
BRASS SLINGER RING
ON AFW PUMP
1-2
IV
87-13
87-19
87-23
87-28
FAILURE TO PLACE INOPERABLE CHANNEL OF
IV
RC
PUMP
UNDERFREO.
REACTOR TRIP SYSTEM
IN TRIPPED
POSITION WITHIN PRESCRIBED
SIX HOURS
FAILURE TO MONITOR ALL AREAS OF
PROTECTED
AREA PERIMETER VIA CCTU
CAMERAS
FAILURE TO POSITION
UNVOLTAGE
TEST
SW TO THE OFF POSITION PRIOR
TO
REMOVING LEADS TO THE MULTIMETERS.
FAILURE TO IDENTIFY AMPHENOL TYPE
HN
IV
CONNECTOR
ON Eg MASTER LIST AND
FAILURE TO MAINTAIN A COMPLETE
QUALIFICATION FI LE.
INSPECTION
REPORT
NO.
87-30
'
DIABLO'CANYON UNIT 1
ENFORCEMENT ITEMS
08/01/86 - 07/31/87)
SUBJECT
SEVERITY
FUNCTIONAL
LEVEL
AREA
IMPROPER
USE
OF
TEMPORARY INSTRUCTION
V
2
AND FAILURE TO DESTROY
OBSOLETE
A SUPERSEDED
TEMPORARY
INSTRUCTION.
NOTE:
THERE ARE
FOUR POTENTIAL VIOLATIONS FROM THE ENVIRONMENTAL
QUALIFICATION INSPECTION
REPORTED
IN IR 86-33.
TABLE 4
DIABLO CANYON UNIT 2
ENFORCEMENT ITEMS
INSPECTION
REPORT
NO.
'7-12
87" 12
87-18
87-18
87-18
87-18
87-18
SUBJECT
INATTENTION TO DUTIES, MISUSE OF
CONTROL
ROOM ANNUNCIATOR ALARM DROP.
FAILURE TO TAKE PROMPT
CORRECTIVE
ACTION TO PREVENT CLOSING
CROSSTIE
VALUE 8716B.
FAILURE TO
FOLLOW PROCEDURES
IN
ESTABLISHING PROPER
OPERATING LEVEL
OF
DURING MID-LOOP OPERATION
RESULTING IN VORTEXING/CAVITATION
OF
RHR,PUMP IN SERVICE.
FAILURE OF
RC INSPECTOR(S)
TO
PROPERLY
FOLLOW EQUALITY CONTROL
INSPECTION
PLAN FOR INSTALLATION OF
TEMPORARY REACTOR VESSEL REFUELING
LEVEL INSTRUMENTATION SYSTEM (RVLIS).
FAILURE TO
FOLLOW PROCEDURES
IN
DOCUMENTING REVIEWS
FOR
AN
UNREVIEWED SAFETY QUESTION IN
PREPARING
TEMPORARY PROCEDURE
FOR
PUMP CAVITATION TEST.
CONTRARY TO T.S.,
INADEQUATE
PREPARATION OF
PROCEDURES
FOR
MALFUNCTION OF THE
RHR SYSTEM
DURING MID-LOOP OPERATION.
CONTRARY TO T.S.,
INADEQUATE
PROCEDURES
FOR CONTROL. OF RVLIS
SCALE INSTALLATION.
SEVERITY
FUNCTIONAL
LEVEL
-
AREA
IV
1
IV
IV
IV
IV
IV
IV
87-20
FAILURE TO
LOG MOMENTARY'JUMPER
IV
PLACED ACROSS
TERMINALS OF
EMERGENCY
START RELAY OF D-G 2-1 AS REQUIRED
BY PROCEDURE.
87-20
FAILURE TO MEET "FOUR-HOUR REPORT"
REQUIREMENT ON ESF ACTUATION, FOR
INADVERT. START OF 0-G 2-1.
IV
87-20
OPERATING OUTSIDE SCOPE
OF
ESTABLISHED
IV
PROCEDURES
WHILE USING
PUMP TO
DRAIN REFUELING CAVITY.
INSPECTION
REPORT
NO.
87-21
87-26
87-28
87-30
TABLE 4
CONTINUED
DIABLO CANYON UNIT 2
ENFORCEMENT ITEMS
SUBJECT
SEVERITY
FUNCTIONAL
LEVEL
AREA
FAILURE TO
POST
AT PERSONNEL
ACCESS
TO'
BOTTOM OF PRESSURIZER
AS HIGH RADIATION
AREA.
FAILURE TO
REPORT
ACTUATION WITHIN
IV
PRESCRIBED
FOUR HOURS.
FAILURE TO IDENTIFY AMPHENOL TYPE
HN
IV
CONNECTOR
ON
EQ MASTER LIST AND
FAILURE TO MAINTAIN A COMPLETE
QUALIFICATION FILE.
IMPROPER
USE
OF
TEMPORARY INSTRUCTION
V
AND FAILURE TO DESTROY
OBSOLETE
A SUPERSEDED
TEMPORARY
INSTRUCTION.
NOTE:
THERE
ARE
FOUR POTENTIAL VIOLATIONS FROM THE ENVIRONMENTAL
QUALIFICATION INSPECTION
REPORTED IN IR 86-31.
Functional
Area
+TABLE 5
DIABLO CANYON UNIT 1
SYNOPSIS
OF
LICENSEE
EVENT REPORTS**
SALP Cause
Code"
A
B
C
0
E
X
Total s
1.
Plant Operations
2.
Radiological
Control s
3.
Maintenance
4.
Surveillance
5.
Fire Protection
6.
Emergency
Preparedness
7.
Security and Safeguards
8.
Outages
9.
equality
Programs
and
'Administrative Controls
Affecting Safety
10.
Licensing Activities
ll.
Training and qualification
Effectiveness
Cause
Codes:
4
6
2
1
1
0
0
0
0
0
0
0
1'
0
0
2
0
4
0
0
1
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
1
0
0
2
0
0
0
'0
0
0
0
0
0
0
0
0
0
0
0
0
0
12
8
2
3
4
0
14
'0
29
A - Personnel
Error
.
B - Design, Manufacturing or Installation Error
C - External
Cause
D - Defective Procedures
E - Component Failure
X - Other
- "
Synopsis
includes
LER Nos.
86-09 through 87-11
Functional
Area
TABLE 6
DIABLO CANYON UNIT 2
SYNOPSIS
OF
LICENSEE
EVENT REPORTSA"
SALP Cause
Code*
A
B
C
'D
E
X
Total s
1.
Plant Operations
2.
Radiological Controls
3.
Maintenance
4.
Surveillance
5.
Fire Protection
6.
Emergency
Preparedness
7.
Security
and Safeguards
8.
Outages
9.
equality
Programs
and
Administrative Controls
Affecti ng Saf ety
10.
Licensing Activities
ll.
Training and qualification
Effectiveness
Cause
Codes:
6
1
0
1
1
1
1
0
0
0
0
0
5
3
0
1
0
0
5
0
0
2
1
0
1
0
0
0
0
0
2
0
0
1
0
0
0
0
0
0
0
0
1
0
0
1
0
0
0
0
0
1
0
0
0
0
0
0
0
0
1
0
0
1
0
0
22
4
0
8
2
1
10
,
2
37
A-
B-
C-
D
E-
X-
Personnel
Error
Design, Manufacturing or Installation Error
External
Cause
Defective Procedures
Component Failure
Other
Synopsis
includes
LER Nos.
86-22 through 87-17