ML16341F634
| ML16341F634 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 03/13/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML16341F633 | List: |
| References | |
| 50-275-89-32, 50-323-89-32, NUDOCS 9003300035 | |
| Download: ML16341F634 (76) | |
See also: IR 05000275/1989032
Text
INITIALSALP BOARD REPORT
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION V
SYSTEMATIC ASSESSMENT
OF
LICENSEE
PERFORMANCE
50-275/89-32
AND 50-323/89-32
PACIFIC GAS
AND ELECTRIC COMPANY
DIABLO CANYON NUCLEAR POWER
PLANT
AUGUST 1, 1988
THROUGH DECEMBER 31,
1989
0
TABLE OF
CONTENTS
I.
Introduction
II.
Summary of Results
A.
Overview
B.
Results of Board Assessment
C.
,Changes
in SALP Ratings
III. Criteria
IV.
Performance
Analysis
~Pa
e
A.
B.
C.
D.
E.
F.
G.
Plant Operations
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/equality
Verification
7
9
12
14
17
20
Y.
Supporting Data and Summaries
A.
B.
C.
D.
E.
F.
Licensee Activities
Direct Inspection
and Review Activities
Enforcement Activity
Confirmation of Action Letters
AEOD Events Analysis
OI Status
24
24
25
25
25
25
TABLES
Table 1 - Inspection Activities and Enforcement
Summary
Table
2 - Enforcement
Items
Table
3 - Synopsis of Licensee
Event Reports
Attachment
1 - The Office for Analysis and Evaluation of Operational
Data
Input to SALP Review
0
INTRODUCTION
The Systematic
Assessment
of Licensee
Performance
(SALP) program is an
integrated
NRC staff effort to collect available observations
and data
on
a periodic basis
and evaluate
the licensee's
performance
based
on this
information.
The program is supplemental
to normal regulatory processes
used to ensure
compliance with NRC rules
and regulations.
It is intended
to be sufficiently diagnostic to provide
a rational basis for allocating
NRC resources
and to provide meaningful
feedback to the licensee's
management
regarding the NRC's assessment
of their facility's performance
in each funct)onal area.
An NRC.SALP Board,
composed of the members listed below, met on February
15, 1990, to review the observations
and data
on performance in
accordance
with NRC Manual Chapter 0516, "Systematic
Assessment
of
Licensee
Performance."
The guidance
and evaluation criteria are
summarized in Section III.ofthis report.
The Board's findings and
recommendations
were forwarded to the
NRC Regional Administrator for
approval
and issuance.
This report is NRC's
SALP Board assessment
of the licensee's
safety
performance at the Diablo Canyon Nuclear
Power Plant, for the period
August 1, 1988 through December
31, 1989.
The
SALP Board for Diablo Canyon
was composed of:
R.
P.. Zimmerman, Director, Division of Reactor Safety and Projects
(Board Chairman)
R.
A. Scarano,
Director, Division of. Radiation Safety
and Safeguards
A.
E. Chaffee,
Deputy Director, Division of Reactor Safety
and Projects
S.
A. Richards,
Chief, Reactor Projects
Branch
C.
M. Trammell, Acting Director, Project Directorate
V,
H.
Rood,
NRR Project Manager
D: F. Kirsch, Chief, Reactor Safety Branch
M.
M, Mendonca,
Chief, Reactor Projects
Section
1
P.
P. Narbut, Senior Resident Inspector
Summar
of Results
A.
Overview
The Board found that the licensee
made notable progress
on a number
of issues
and programs
discussed
in last year's
SALP report.
Specifically:
.The licensee initiated efforts to reduce engineering errors
and
to improve their overall performance
in this area.
Licensee
engineering initiatives included
commencement
of a design basis
document reconstruction effort; continuing development of the
onsite engineering
program;
and the improvement of the
interface
between
the corporate
engineering staff and the site
staff.
I
0
2
o
The number of events related to procedural
compliance
and
communication
issues
have declined considerably.
o
guality Assurance
has successfully
implemented
improved
performance
based audit programs in the areas of system design,
design
changes
and
NSSS services.
The improved programs
produced meaningful
indepth technical findings.
In the above areas,
the licensee generally demonstrated
a solid
commitment to address
problems with adequate
resources
and
conservative
approaches.
However, the
SALP, Board,
as in the previous
SALP period,
found the
licensee's
identification of some problems
and the implementation of
corrective actions to often be slow.
For these
problems continual
attention from the
NRC appeared
to be required
such that the
licensee
recognized the problem,
reviewed the problem in a
comprehensive
manner,
and initiated meaningful corrective action.
Examples
discussed
in the report included problems with valve lineup
errors
and excessive
overtime usage.
At the root of this issue
seemed to be
a lack of problem ownership.
Mhereas
problems limited to,a single department
were usually
addressed
in a timely way, it appeared
that managers
and staff were
reluctant to take ownership of problems which involved multiple
departments'herefore,
the Board recommends
continued
management
attention to ensuring that direct responsibility for addressing
any
given problem is promptly identified,
and then ensuring that timely
action is initiated to address
the problem area.
Three
NRC inspections,
which occurred after the
SALP period,
were
considered
by the
SALP Board.
The first was
a security inspection
which identified several
problem areas,
the second inspection
was
a
team inspection of corrective action programs,
and the third was
a
routi.ne emergency
preparedness
inspection.
Results of Board Assessment
Overall, the
SALP Board found the performance of NRC licensed
activities by the licensee to be acceptable
and directed toward safe
operation.
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
Rating
Last
Period
Rating
This
Period
Trende
A.
Plant Operations
B.
Radiological Controls
C.
Maintenance/Surveillance
D.
Emergency
Preparedness
Improving
0
E.
F.
G.
H.
Security
2
Engineering/Technical
Support
2
Safety Assessment/equality
2
Verification
Fire Protection
1
Improving
Improving
Improving
(No longer rated
separately)
The trend indicates
the
SALP Board's appraisal
of the
licensee's
direction of performance
in a functional area
such
that continuation of this trend may result in a change in
performance level.
Determination of the performance
trend is
made selectively
and is reserved for those
instances
when it is
necessary
to focus
NRC and licensee attention
on an area with a
declining performance trend, or to acknowledge
an improving
trend in licensee
performance.
It is not necessarily
a
comparison of performance
during the current period with the
previous period.
C.
Chan
es in SALP Ratin
s
The changes
to the
SALP ratings from the previous
SALP period were
a
Category
1 performance
in Operations
and improving trends in
Maintenance/Surveillance,
Security, Engineering/Technical
Support,
and Safety Assessment/equality
Verification.
The previous rating in the Operations
functional area
had been
a
Category
2 with an improving trend.
The Board determined that the
generally conservative
responses
by Operations
personnel
outweighed
concerns
in this area regarding
instances
of weak management
oversight
and slow problem identification and resolution,
such
as
the continuing problems
observed with valve alignments.
The improving trends in the previously mentioned functional areas
were primarily due to extensive
licensee
resources
applied in these
areas.
III. CRITERIA
Licensee
performance is assessed
in selected
functional areas,
depending
on whether the facility is in a construction or operational
phase.
Functional
areas
normally represent
areas significant to nuclear safety
and
the=- environment.
Some functional areas
may not be assessed
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 used,
as applicable to assess
each
functional area:
1.
Assurance
of quality, including management
involvement and control;
2.
Approach to the resolution of technical
issues
from a safety
standpoint;
3.
Responsiveness
to
NRC initiatives;
k
4.
Enforcement history;
5.
Operational
and construction
events (including response to, analyses
of, reporting of, and corrective actions for);
6.
Staffing (including management);
and
7.
Effectiveness
of the training and qualification program.
However, the
NRC is not limited to these criteria and others
may have
been
used where appropriate.
On the basis of the
NRC assessment,
each functional area evaluated is
rated according to three performance
categories.
The definitions of
these
performance
categories
are
as follows:
1.
Cate or
1.
Licensee
management 'attention
and involvement are
rea
1 y evident
and place
emphasis
on superior performance of
nuclear safety or safeguards
activities, with the resulting
erformance substantially
exceeding regulatory requirements.
icensee
resources
are
ample
and effectively used
so that
a high
level of plant and personnel
performance is being achieved.
Reduced
NRC attention
may be appropriate.
2.
Cate or
2.
Licensee
management
attention to and. involvement in the
per ormance of nuclear safety
or safeguards
activities are good.
The licensee
has attained
a level of performance
above that needed
to meet regulatory requirements.
Licensee
resources
are adequate
and reasonably
allocated
so that good plant and personnel
performance
is being achieved.
NRC attention
may be, maintained at
normal levels.
3.
Cate
or
3.
Licensee
management
attention to and involvement in the
per ormance of nuclear safety or safeguards
activities are not
sufficient.
The licensee
s performance
does not significantly
exceed that needed to meet minimal regulatory requirements.
Licensee
resources
appear to be strained or not effectively used.
NRC attention
should be increased
above
normal levels.
IV.
PERFORMANCE ANALYSIS
The following is the Board's
assessment
of the licensee's
performance
in
each of the functional areas,
plus the Board's conclusions for each area
and its recommendations
with respect to licensee
actions
and management
emphasis.
A.
~PP tt
tt
1.
~Anal sis
During the assessment
period, the licensee's
plant operations
activities were observed routinely by both the resident inspectors
and the regional staff.
Additionally, in December
1989,
a team
inspection
was conducted to review emergency operating procedures
k
(EOPs).
A total of more than 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> of inspection effort was
devoted to this functional area..
The licensee's
performance in this functional area during the
previous
SALP period was rated
as Category 2, improving trend.
Prominent issues of the previous
SALP requiring attention in this
functional area included the effectiveness
of management
feedback
mechanisms,
the continued
need for emphasis
in communications
and
procedural
compliance,
and the slow movement towards establishing
formal root cause
reviews for appropriate
operational
events.
In
general,
the licensee's
efforts to address
these
issues
have
been
successful,
as discussed
below.
One remaining concern,
however, is
the licensee's
occasional
apparent inability to recognize
and
address
issues
in a timely manner.
During this
SALP period,
few significant operational
events
were
attributable to causes
relevant to this functional area.
In 1989,
Unit 1 completed
a record
399 day run,
and both Units 1 and
2 each
experienced
only one automatic trip.
The Unit 1 trip, which could
not have
been foreseen,
occurred
when work was authorized
on
instrumentation
which shared
a process
line with a plant protection
channel.
A contributory factor in the Unit 2 automatic trip, was
the unavailability of a circulating water
pump due to an equipment
alignment problem.
Unit 2 operators initiated three
manual reactor trips in 1989, which were conservative
responses
to abnormal plant
conditions
such
as condenser salt water intrusions.
Additionally,
it was noted that the licensee initiated comprehensive
data
gathering efforts to identify the root cause of the more significant
events.
Very early in the
SALP period, the facility experienced
three additional automatic plant trips.
A significant management
problem which developed during this rating
period was the lack of timely corrective action taken to address
repeated
valve and equipment lineup problems.
The valve lineup
problems contributed to one unplanned reactor trip, several
engineered
safety features
actuations,
and inoperable
instrumentation.
The equipment lineup problems resulted in the
issuance
of an escalated
enforcement, action and civil penalty.
Although subsequent
corrective actions
were extensive,
valve and
equipment lineup problems continued throughout the rating period.
At the end of the period, Operations
Management
was in the process
of reassessing
the equipment alignment program.
The licensee's
approach to the resolution of technical
issues
was
generally conservative with approaches
viable and generally
sound
and thorough.
This was evidenced
by the conservative
action to
shutdown Unit 2 to repair
a leaking pressurizer
safety .valve,
and by
the fact that the licensee
has
been at the forefront of safety valve
problem reviews and testing.
Also, the licensee's fire protection
enhancements
have
been well beyond
NRC minimum requirements,
e. g.,
the
use of the Plant Information Management
System to manage fire
barriers
and system configuration control.
Other examples of
conservative
actions
included rapid operator
assessments
on three
separate
occasions
of abnormal plant conditions,
and the appropriate
0
initiation of manual reactor trips of Unit 2,in each instance.
However, operations
personnel
have not responded
conservatively
nor
displayed appropriate instincts in all instances.
For example,
during the Unit 1 refueling outage,
fuel handling building radiation
alarms were not properly responded to by operations
personnel,
which
resulted in a violation included in the radiological controls
functional area.
The licensee is generally responsive to
NRC initiatives.
As an
example,
the
EOP inspection
observed that the licensee
was
self-critical and committed to improvements in that area.
Also, the
issues of communications
and procedural
compliance,
which have
been
discussed
in the last two SALP reports,
did not contribute
significantly to plant events.
However, the major issue
and
NRC
initiative of the last SALP, the need for timely problem recognition
and the initiation of corrective actions,
remains
a concern.
During the assessment
period there were two enforcement actions,
one
Severity Level III violation and one Severity Level IV violation,
and
18
LERs in the operations
area.
Additionally, although
enforcement action was not taken until after the end of the
period,
other',.escalated
enforcement actions
were identified during
the
SALP period, which involved: (1) the failure to perform adequate
containment
sump cleanliness
inspections;
and, (2) use of an
unlicensed individual as Shift Supervisor during .the Unit 2
refueling outage.
The importance of successfully'ommunicating
management
expectations
regarding personnel
verifications was
emphasized
at the enforcement
conference for the
sump violation, and
the importance of conservative
management
decisions
was emphasized
with regard to the unlicensed Shift Supervisor violation issue.
kith respect to operations staffing,
key positions were identified
and responsibilities
defined with key vacant positions usually
filled in a reasonable
time.
As previously mentioned,
a notable
exception to the above
was the use,
during the Unit 2 second
refueling outage,
of a management
individual with an expired senior
reactor operator license to fulfillthe then newly established
operations shift supervisor
s position, which normally requires
an
active
SRO license.
While on-shift staffing normally exceeded
regulatory requirements, it was noted during the
EOP team inspection
that a shortage
of office staffing for developing
and maintaining
may have contributed to the slow resolution of identified
problems.
The licensee's
operations training program
was well defined and
implemented with dedicated
resources.
The overall pass
rate
on
qualification exams
was
94K and was considered well above average.
Also, feedback
from the training pro~ram was
used to upgrade
operations
procedures.
The licensee
s training facilities include
a
well maintained plant simulator.
The overall high quality of
operator training was consistently exhibited during not only the
inspection,
but also during emergency
preparedness
exercises.
Finally, inadequate
training was rarely the cause of plant events.
2.
3.
Performance
Ratin
Performance
Assessment - Category 1.
The
SALP Board deliberated at
length in considering whether
a Category
1 rating was warranted in
this functional area.
The Board ultimately concluded that the
overall performance in this functional area
outweighed concerns
raised primarily by valve alignment problems
and issues
involving
the operability of the containment
Board Recommendations
Licensee
management
should focus attention
on ensuring that valve
alignment errors
are minimized and should
be sensitive to promptly
addressing
other developing problem areas,
prior to those problems
causing
a significant event.
Management
should continue to require
that operations
personnel
conduct their duties in a professional
and
conservative
manner.'.
Radiolo ical Controls
~Anal sis
,A total of six routine inspections
were performed in the area of
radiological controls,
examining aspects
of occupational
radiation
safety,
management
and organization,
radiological effluent control
and monitoring, radioactive waste
management,
transportation of
-radioactive materials, training and qualifications, confirmatory
measurements,
and licensee
events.
In addition, the resident
inspectors
provided continuing. observations
in this area.
Approximately 328 hours0.0038 days <br />0.0911 hours <br />5.42328e-4 weeks <br />1.24804e-4 months <br /> of inspection effort were performed in this
functional area.
The licensee's
performance rating in this functional area during the
previous
SALP period was Category 1.
SALP Board recommendations
in
the previous
SALP included assuring
personnel fully understand
concepts,
radiological work practices,
and procedural
compliance
requirements.
In general,
the licensee's
efforts to address
these
recommendations
have
been successful,
with additional attention
needed in the management
of outage activities.
During this assessment
period, licensee
management
continued to
exhibit active involvement in the area of chemistry and radiological
controls.
Management
had developed
goals
and performance indicators
in several
areas;
including external
and internal
exposure control,
contamination minimization, material control
and waste reduction,
The staff's
awareness
of management's
goals
and expectations
was
evident.
During this assessment
period, there
was continued
management
support of the chemistry program.
For example,
the licensee
implemented
several
changes
in plant chemistry intended to minimize
crud buildup and corrosion.
These
changes
included:
use of
hydrazine in the secondary
system to scavenge
oxygen and secondary
system
low level boric acid feed to control
tube
0
denting.
The licensee
also initiated elevated lithium chemistry in
the reactor coolant to increase
the pH.
These techniques
are
intended to reduce
maintenance
and decrease
dose
rates
components.
The licensee's
continued
commitment and support for the
implementation of a strong
and effective radiation protection
rogram was evident during this assessment
period.
As a result of
RC comments during the 1988 Unit 2 refueling outage,
and the
licensee's
internal= evaluation of past performance,
the licensee
completely revised their ALARA program in time to support the 1989
Unit 1 refueling outage.
In addition, the licensee
implemented
some
innovative concepts
which included "High Impact Teams"
(HIT) and
a
Management
Incentive
Program
(MIP) to enhance their ALARA program.
The HIT concept represented
a major commitment of manpower to the
outage planning and preparation
phases
during the Unit 1 refueling
outage.
The MIP provided the licensee's, staff with various types
and
levels of awards for maintaining exposures
at or below the
established
ALARA goals.
The licensee's
overall year to end exposure
for 1989 was approximately
3X less
than the man-rem goals that were
established
by the licensee.
However,
some poor health physics
and
work practices that were apparent
in the previous
outage
were not
effectively corrected during the latest outage.
During the
SALP period, only one Severity Level IV violation was
identified as
compared to the two Severity Level IV violations and
one deviation that were identified during the previous
SALP period.
The violation, previously mentioned in the operations
functional
area,
involved the failure to adequately instruct personnel
upon
receiving
an evacuation
alarm for the Fuel Handling Building Area
Radiation Monitor (ARM), RE-58.
A total of seven
Licensee
Event Reports
(LERs) were received in this
functional area during this
SALP period
The
NRC inspection of these
LERs did not result in any violations.
During this assessment
period, the licensee
continued to demonstrate
management
s involvement in ensuring quality; however, corrective
actions
were not always timely or effective in correcting the root
cause of the problem.
For example,
the untimely and ineffective
resolution of problems associated
with the spent fuel pool radiation
monitor alarms during core off load operations
contributed to a
violation of 10 CFR Part 19. 12, which was previously discussed.
The
licensee
has proposed
a Technical Specification
(TS) change to
increase
the setpoint of this monitor to prevent frequent Engineered
Safety Features
(ESF)
and alarm actuations.
The documentation
developed for the proposed setpoint
changes
was thorough.
Staffing considerations
for normal plant operations
and refueling
outages
were routinely evaluated
by the licensee.
Authorities and
responsibilities of the licensee's
staff were well delineated.
The
staff was highly qualified, with certified health physicists on-site
and at the corporate office. The normal plant staff turnover rate
was low.
A minimum of contractor assistance
was utilized.
Additions
0
2.
to the professional staff during this
SALP period have
added
increased
depth
and scope.
However, staffing of contractor
radiation protection technicians for the Unit 1 refuelinq outage
appeared
to be marginal at the onset of the outage
as evidenced
by
the poor health physics
and work practices that were identified.
The licensee's
training program for the technical staff and for the
radiation protection
and chemistry technicians
was considered
to be
another strength.
An industry accredited training program for
chemistry
and radiation protection technicians
has
been
implemented.
The subjects
addressed
include both refresher
and enrichment topics.
Additionally, the licensee
has set demanding
standards
for contract
technicians
providing assistance
during outages.
Senior radiation
protection technicians
employed for outages
must take
and pass
a 2-4
hour specific knowledge examination.
The licensee
reported that
this practice resulted in an increase
in the quality of the
technicians
sent to the plant.
The licensee
has also implemented
a
five month long, full time, technical staff training program.
This
program includes all aspects
of plant operation.
It is designed to
~
~
~
~
rovide a common base of knowledge to the technical staff.
adiation protection engineering staff members
have
been included in
this program.
Performance
Ratin
3.
Performance
Assessment - Category 1.
Board Recommendation
The licensee is encouraged
to continue the current aggressive
approach
being taken towards
ALARA and to improve the quality of
health physics
and work practices
during outages.
C.
Maintenance/Surveillance
~Ana1 sis
This functional area
was observed routinely during the assessment
period by both the resident
and regional
inspection staff.
Approximately 641 hours0.00742 days <br />0.178 hours <br />0.00106 weeks <br />2.439005e-4 months <br /> of inspection effort were devoted to this
functional area.
Issues
discussed
in the previous
SALP for this
functional area,
which was previously rated
a Category 2, were the
control of the maintenance
backlog, the continuing relatively large
number of personnel
errors,
the adequacy of I8C procedures,
engineering
involvement in plant activities,
and the slow
implementation of lessons
learned.
Management oversight of maintenance activities was generally
effective.
The issues
discussed
in the previous
SALP were not a
significant contributor to plant events during this
SALP period.
An
example of management's
effectiveness
in resolving long standing
problems
was the achievement of "black" control
room annunciator
boards for both Units 1 and 2.
The "outage coordination center"
has
also
been
used
as
an effective management
oversight tool.
The
0
10
concept is simply to make available in one
room all the appropriate
management
personnel
required to make decisions
necessary
to
expedite the resolution of problems during an outage.
The licensee's
survei,llance
program appeared
to be well established
and implemented.
Although several
were
reported during the
SALP period,
most were either non-routine or
resu]ted
from mis-interpretation of Technical Specification
requirements.
The Inservice Inspection (ISI) program is likewise
well established
and implemented
by a qualified licensee staff.
However, it was noted that management
oversight
was insufficient in
the area of personnel
overtime.
That is, during the Unit 1 outage,
a large
number of plant personnel
working safety-related
jobs,
were
working hours in excess
of those allowed by the Technical
Specifications.
Periodic review of overtime records
by plant
management,
also required by the Technical Specifications,
was not
being accomplished.
The licensee
was not responsive to the
inspector
s findinq, and in the week following the first discussions
of excessive
overtime,
a number of additional
maintenance
personnel
exceeded
overtime restrictions.
Additionally, an effort to
determine
the scope of the overtime problem was not initiated for
three
weeks
and required continuing expressions
of NRC concern.
The licensee's
understanding
of technical
issues .in this functional
area
was generally apparent.
The licensee
has also taken
an
industry lead in a number of issues
related to this functional area.
Examples
include safety valve testing,
the detection of counterfeit
materials,
and the resolution of diesel
generator air start motor
problems.
Additionally, conservatism
was generally exhibited
as
was
the case
when Unit 2 was shut
down to repair
a leaking pressurizer
An understanding
of subtle technical
problems
was exhibited by maintenance
personnel
when the environmental
qualification of main steam isolation valve actuation
components
was
questioned.
t~
However,
some
known problems recur before they are effectively
addressed
and resolved.
Representative
of this was the use of
outdated
drawings to perform corrective maintenance
on the Unit 2
turbine driven auxiliary feedwater
pump overspeed
stop valve in
February
1989.
The drawings
had been previously recognized
as being
outdated during maintenance activities in November 1988.
Additionally, following identification by the inspector of a fire
door which had the latch function defeated,
corrective actions did
not preclude
maintenance
personnel
the following week from propping
the
same
door
open with a pair of pliers.
Although the licensee
tends to be slow to address
and respond to
NRC
concerns
and continued
NRC scrutiny is sometimes
necessary
to ensure
that the concerns
are appropriately considered,
responses
are
technically sound
and thorough in almost all cases.
This is
evidenced
by the licensee's
response
to issues
discussed
in the last
SALP period.
Long-standing
issues
which the licensee
had been
slow
to respond to, such
as configuration control,
IEC procedures,
and
11
the need for personnel
to stop in the face of uncertainty,
appeared
to have been well addressed
during this
SALP period.
However, the
licensee
has
been slow to address
some concerns
discussed
durinq
this period.
One example is the issue of plant material condit)on.
Although various aspects
of plant material condition had been
discussed
in a number of inspection reports in the second half of
the
SALP period,
e. g., the condition of -the intake structure
and
components,
the licensee
has not yet defined
a long range program
for dealing with such concerns.
During the
SALP period, the violations attributed to this functional
area
were minor and not repetitive,
and with the notable exception
of the overtime issue,
did not indicate
a programmatic
breakdown.
The licensee
at the start of the
SALP period experienced
a number of
less significant events
which could be attributable to maintenance
and surveillance
personnel
error-related activities.
However,
events
associated
with personnel
error were infrequent during the
second half of the
SALP period, indicating improvements in this
area,
Additionally, events attributable to procedure errors
and
procedure
compliance
were also infrequent.
In general,
the licensee
was adept at handling the root cause investigation of more
significant events
such
as reactor trips.
An example
was the
comprehensive
response
to the Unit 2 condenser
tube
1'eak of July
1989.
However, there were instances
of improperly performed maintenance
and surveillance
on safety-related
equipment.
An example
was the
improper maintenance
of the
AFM pump trip throttle valve.
Similarly, the identification of inadequate
surveillances
of
containment recirculation
sump cleanliness
by NRC inspection
activities highlighted the problem.
These findings indicate
an
increased
need for attention to assure plant design is appropriately
implemented through maintenance
and surveillance activities.
. Staffing issues
discussed
during the previous
SALP period appear to
have
been
addressed.
Specifically, noted
improvements
in
instrumentation
and control procedures,
as well as the achievement
of a "black board" for control
room annunciators
indicate that
attention
has
been placed in these
areas.
However, the need to use
extensive
overtime during outages
appears
to indicate that outage
staffing requirements
need to be reviewed if the licensee
continues
to pursue
ambitious
outage
schedules.
The licensee
maintains
a state of the art training facility for
maintenance
and testing personnel,
which demonstrates
that
management
is dedicated
to providing quality training.
One example
is the simulated solid state protection system
(SSPS).
Prior to
performing sensitive
maintenance activities
on the plant SSPS,
technicians
were able to train on the simulated
system.
Additionally, a diesel
generator similar to those installed in the
plant was purchased
dur>ng this
SALP period and
a training program
is being devised to utilize it.
Inadequate
training has not been
a
0
'12
2.
significant contributing factor to plant events
caused
during
construction,
maintenance
or surveillance
work.
Performance
Ratin
3.
D.
Emer
Performance
Assessment - Category 2, Improving Trend.
Board Recommendation
Management
should review outage activities which precipitated the
need to use extensive
overtime.
Management
should also strive to
improve oversight in the area of problem identification and
resolution with an emphasis
on taking timely action.
Given the
relative age of Diablo Canyon
and the number of problems associated
with plant material condition, plant management
should put
additional effort into addressing
the maintenance
of plant material
condition.
The licensee
should continue to take actions to
strengthen
the maintenance
and operations staffs'nderstanding
of
the plant design,
and the sensitivities of the design to
deficiencies.
An improved understanding
may have prevented
the
operability issues
which occurred regarding the containment
and the auxiliary feedwater
pump trip valve.
enc
Pre aredness
~Anal sis
The previous
SALP analysis
included several
strengths
and
no
specifi,c weaknesses
associated
with the licensee's
emergency
preparedness
(EP) program.
Management
support of the
EP program
and
-.
the licensee's
conservative
approach to
EP issues
were ident>fied as
strengths.
The licensee
has
been rated
as
a
SALP Category
1
performer during the last four SALP appraisal
periods.
During the
last
SALP appraisal
period, the Board
recommended that the licensee
continue to maintain management
attention to ensure
a high level of
performance in this functional area.
During this
SALP appraisal
period,
Region
V conducted
two routine
inspections
and observed
two annual
EP exercises.
A Region
V Site
Team participated in the 1989 exercise.
The routine inspections
assessed
the operational
status of the
EP program, the licensee's
response
to previous inspection findings and the licensee's
activities involving the onsite
emergency
warning system.
Approximately 270 hours0.00313 days <br />0.075 hours <br />4.464286e-4 weeks <br />1.02735e-4 months <br /> of direct inspection effort were expended
in
the
EP functional area.
Strengths identified during this assessment
period included management
support of the
EP program,
responsiveness
to
NRC initiatives,
and the thoroughness
of the licensee's
corrective actions.
Areas needing
improvement were noted,
such as,
untimely corrective action
and the level of technical
(engineering)
staffing in the Technical
Support Center
(TSC) and Emergency
Operations Facility (EOF).
The TSC/EOF staffing issues
were
identified during the 1989 exercise.
0
13
. The inspections
conducted
during this appraisal
period found
strength in licensee
management
support of the
EP program.
For
example,
management
took aggressive
steps to escalate
corrective
actions after a guality Assurance
(gA) audit report identified the
existence of a long standing, internally identified problem with the
audibility of the site emergency signal.
Licensee
management
also
took immediate,
interim corrective action until the alarm devices
could be installed
and
made operational.
Strength in this area
was
also demonstrated
when the President of the
Company issued
a letter
which communicated
expectations
concerning
emergency
preparedness
training attendance.
In general,
the licensee's
approach to resolution of issues
from a
safety standpoint
was determined to be sound.
There was,
however,
an isolated
example
where the licensee's
corrective actions
were not
considered
.to be timely and the issue could have
had
an effect on
personnel
safety.
This issue also involved the audibility of the
site emergency
signal (i.e., the signal could not be heard in
several
locations
around the site), but in contrast to the strength
identified above,
a weakness
was identified because
the licensee
did
not take correct>ve action until it was identified. by gA,
approximately two years later.
As indicated
above,
licensee
management
was very responsive after the matter was brought to its
attention;
however,
the delay in correcting the matter indicated
that the problem did not get to the appropriate
levels of management
or that the matter was not considered
to be high 'in priority.
Once
. corrective actions
were taken,
they were considered to be thorough
and well thought-out.
A strength
was also identified'ith respect to the licensee's
responsiveness
to
NRC initiatives.
This strength
was demonstrated
when the licensee
responded
to
NRC concerns
about false siren
activations.
The licensee
showed
a sensitivity to the issues
and
initiated prompt, thorough corrective actions to reduce the number
of false activations.
No violations of NRC requirements
or LERs were identified in this
functional area during this assessment
period.
The licensee
had several
opportunities to implement its emergency
plan during this appraisal
period.
The most notable
examples
were
an earthquake
and the arcing in the main generator exciter,
both of
which occurred in October 1989.
The licensee's
response
in each
case
was. timely and in accordance
with procedures.
Notifications to
the offsite authorities
were
made in a timely manner.
The licensee
has continued to maintain
a stable
and effective staff
to implement its
EP program.
An area
needing
improvement,
involving
the emergency
response
staffing,
was identified during the 1989
annual
emergency
exercise.
Observations
made during the exercise
indicated
a need to strengthen
the engineering
support in the
and
EOF.
l
k
0
14
2.
3.
The inspections
conducted
during this appraisal
period showed that
the licensee's
training and qualification program
has
been
effective.
As stated
above,
the emergency plan has
been
implemented
correctly during real events.
Dose assessment
capabilities
were
assessed
during walkthrough interviews and found to be dependable
and
no major findings were identified during the 1988 and 1989
annual
emergency exercises.
A routine inspection
was conducted
immediately following the end of this
SALP appraisal
period.
The
inspection disclosed that the licensee
had not completed
a report
for a Health Physics drill conducted in April 1989.
The failure to
issue
a timely drill report could affect the licensee's ability to
correct training deficiencies identified during drills.
The
NRC staff has reviewed the changes
made to the Diablo Canyon
emergency
plan during the appraisal
period.
The changes
are
acceptable
and the licensee
continues to meet
NRC requirements.
Performance
Ratin
Performance
Assessment - Category l.
Board Recommendations
The licensee
should ensure that problems related to
EP are corrected
in a timely manner.
Licensee
management
should take the necessary
steps to strengthen
the engineering
support in the
TSC and
EOF,
and
ensure
a high level of EP is maintained
as
a result of management's
continued support.
E.
~Securit
~Anal sis
During this
SALP period Region
V conducted three physical security
inspections
and one material control
and accounting inspection.
Over 220 hours0.00255 days <br />0.0611 hours <br />3.637566e-4 weeks <br />8.371e-5 months <br /> of inspection effort were expended
by regional
safeguards
inspectors.
In addition, the resident inspectors
provided observations
in this area.
The previous
SALP rated the
licensee
a category
2 in the security functional area.
The last two SALP reports
encouraged
licensee
management
to become
more involved and resolve
an identified safety/security
issue
involving radio communication frequencies for security and
operations
personnel.
Last year's
SALP report indicated that the
licensee
was approximately
70K complete with this project.
During
this
SALP period, the licensee
completed modifications to the
security radio communications
equipment to avoid possible
interference with the radio communication
equipment of the Units 1
and
2 operations staff.
The previous
SALP report encouraged
licensee
management
to finalize
their modifications to the protected
area barrier and the perimeter
security alarms at the Intake Structure.
As discussed
below, after
recent redesign,
the licensee
has
completed the installation of
r
~
0
approximately
90X of the protected
area barriers
and associated
security alarms.
The previous
SALP report also encouraged
licensee
management
to minimize the deficiencies
and to improve the image
clarity of their closed circuit television
(CCTV) cameras.
As
discussed
below, this has
been completed.
Overall, for this SALP, the licensee's
security program was
acceptable,
and exceeded
minimum requirements
in the area of
security officer training and satisfied
minimum requirements
in
areas of compensatory
measures,
protected
area barriers
and
detection aids,
and alarm stations.
Mith regard to management
s involvement in assuring quality,
corporate
and plant management
continued to review the operation of
the overall security program.
They have generally
implemented
remedial
measures
to correct deficiencies
and weaknesses
identified
in the course of both internal
and
NRC security inspections.
In May
1989, the licensee
completed the expansion
and remodeling of their
security access
control building.
This improved facility provided
the capability of searching
and processing
personnel
entering the
protected
area -in a more effective and efficient manner,
and
assisted
in reducing the number of security log incidents.
Additionally, during this assessment
period, the licensee
resolved
security concerns identified in an earlier
NRC information notice by
completing modifications to their heating, ventilation and air
conditioning
(HVAC) ducts.
During this assessment
period, the licensee
resolved
long term image
deficiencies with their installed
CCTV cameras.
The additional
management
attention -directed at this issue resulted in changes
that
improved the
image of all required
CCTV cameras
to an acceptable
level.
Additionally, as
a result of a previous enforcement action,
the licensee
erected
new
CCTV cameras
to allow viewing of the entire
protected
area perimeter.
As a result of a November
1987 event,
the licensee
determined that
the electrical
design
1'oad of their security emergency
power supply
system
was inadequate
and initiated action to upgrade the capacity
of this system.
At the end of this
SALP period, the licensee
had
installed the necessary
equipment to complete this project.
This
equipment is scheduled for final acceptance-testing
in early 1990.
During the past five years,
the perimeter security alarms at the
Intake Structure
have
been inoperative
and the licensee
has
continued to provide long term compensatory
measures
at this area.
During this
SALP period, the licensee total.ly redesigned
the
placement of the protected
area barriers
and required security
alarms at the Intake Structure, with installation approximately
90X
complete.
The licensee
s resolution of identified technical
issues,
while
slow, appears
to have
been
adequate.
In November
1986, the
Regulatory Effectiveness
Review (RER) report identified a security
weakness
in CCTV alarm assessment
capability.
This weakness
4
0
16
involves the manner
in which the integrated security systems
(barriers,
perimeter alarms
and
CCTV cameras)
can be defeated.
During this
SALP period,
a Region
V inspection report again
identified this weakness.
The licensee is currently evaluating
means to correct this weakness.
The 1986
RER report also identified
inadequacies
with portions of the licensee's vital area barriers at
Units
1 and
2 pipe galleries.
The licensee
has completed their
evaluation
and has identified measures
to correct these barriers.
During this
SALP period,
two information notices
and one generic
letter related to security were issued.
The licensee's
responsiveness
and actions
as reviewed to date,
were found to be
acceptable.
The enforcement history for the
SALP period included one non-cited
violation related to the licensee's
discovery of a sleepinq security
officer who was acting as
a compensatory
measure for a perimeter
alarm at the main protected
area.
During the
SALP period,
each of the licensee's
eleven safeguards
events
were reported in the Licensee
Event Report
(LER) format;
seven
(64K) of these
events
were caused
by personnel
errors.
These
eleven events related to:
degraded
operation of alarm stations(4);
degraded vital area barriers(3);
drug related events(2);
failed
security compensatory
measures(1);
and miscellaneous
events(l).
The four LER's relating to the degraded
operation of the alarm
stations
were caused
by two instances
of temporary malfunctioning
computer equipment,
and two situations
involvinq extended
personnel
errors.
These personnel
errors included the failure to reactivate
(for several
hours)
a vital area
door alarm after testing;
and
allowing a security officer to repeatedly
respond to an incorrect
door
upon receipt of vital area door alarms.
Additionally, during
this
SALP period,
Region
V determined that the security alarm
station operators,
during their performance of assigned
duties in
the central
and secondary
alarm stations,
were rarely observed
by
their supervisors.
The licensee's
corrective action required
each
security shift lieutenant
and sergeant
to visit both alarm stations
once per'shift.
The overall effectiveness
of this corrective action
has not been evaluated
by the
NRC.
With respect to staffing,
key positions
and responsibi'lities
were
generally well defined.
The licensee's
overall security training
program exceeded
minimum requirements,
as evidenced
by their
development of a Tactical
Team Response
Training Course.
This 5-day
course
has
been presented
to all security officers.
Additionally,
the Fitness for Duty training was observed to be comprehensive
and
well presented.
In February
1990, six weeks following the end of this
SALP period,
a
routine security inspection included
a review of the licensee's
Safeguards
Events
Logs, from April through December
1989.
Events
recorded in these
logs identified multiple examples of weak
performance, i.e., lack of positive access
control, failed
/
0
17
2.
3.
compensatory
security measures,
and inadequate
protection of
safeguards
information.
. Initial review of inspection results also
indicate
a possible reduction in the overall safety/security
awareness
and attitude of plant employees.
Performance
Ratin
Performance
Assessment - Category 2, Improving Trend
Board Recommendations
Generally,
licensee resolutions
and corrective actions for hardware
items
have
been acceptable,
however,
licensee
management
is
encouraged
to finalize these matters
on a more timely basis.
Specifically, licensee
management
is encouraged
to resolve the
identified weakness
with the integrated security system (barriers,
perimeter
alarms
and
CCTV cameras).
Additionally, the licensee
is
encouraged
to finalize measures
to correct identified inadequacies
with portions of vital area barriers at Units
1 and
2 pipe
galleries.
Further, in an effort to reduce
extended
personnel
errors,
licensee
management
is encouraged
to examine the
effectiveness
of supervision of alarm station operations.
Based
upon the last
NRC inspection,
additional
management
attention is
also required in employee
awareness
towards compliance with
es.
~
~
~
~
safety/securi ty pr ocedur
'F.
En ineerin /Technical
Su
ort
~Anal sis
The licensee's
performance
in this area
was rated
as Category
2
during the previous
SALP period.
Significant issues
discussed
in
that evaluation included:
implementation of the design basis into
operations
and maintenance activities including various aspects
of
design
bases
documentation
and the availability of design
documents
to appropriate plant personnel;
implementation of the system
engineering
program,
including improving the interface
between the
corporate
and site engineering organizations;
and the
need for
management
to ensure that the fundamentals
of nuclear plant
operations
are more clearly understood
by engineering
personnel.
The above issues
were specifically addressed
during the
SALP period
by an
NRC SSFI team inspection.
The team identified continuing
weaknesses
in the following areas:
plant staff did not fully
This functional area
was reviewed routinely by both regional
inspectors
and the resident staff.
In this functional area,
a
Safety System Functional Inspection
(SSFI) was conducted in January
1989.
A total of 679 inspection
hours
was expended
in this
functional area.
These
reviews primarily focused
on the
San
Francisco
based
Nuclear Engineering
and Construction Services
(NECS), which is responsible for plant design activities,
and the
plant engineering
group, which includes
system engineering.
0
18
understand
the plant design basis;
the interface
between
NECS and
the site was weak;
and
some engineering
work was found to be
incomplete or inadequate.
Several violations resulted
from these
weaknesses
and escalated
enforcement
was taken,
based
upon findings
by both the team and the resident inspectors.
Licensee corrective
actions included:
reemphasis
of a comprehensive
configuration
management
program, including design basis
document construction;
reemphasis
of closer system engineer ties with their design
engineerinq counterparts;
a complete review of the
FSAR and other
design basss
correspondence
to assure
commitments
are being met;
and
a review of vendor manuals to ensure
important maintenance
activities are being accomplished.
The licensee
has dedicated
extensive
resources
towards the implementation of these corrective
actions;
however, the
SALP board concluded that continued strong
management
attention is needed in these
problem areas.
With respect to the assurance
of quality by engineering
management,
NECS has
lagged behind the plant in terms of developing
an attitude
of self-crit>cal assessment.
Nore emphasis
was put on this area in
1989, with greater
involvement by engineerinq quality services,
stronger ties. between
NECS and site engineer)ng
personnel,
and
PGEE
engineering
and corporate
management
spending
more time at the site
and more time with engineering
personnel.
Understanding of technical
issues
was generally apparent
and
conservatism
was generally exhibited.
One commendable
example
was
the Long-Term Seismic
Program.
However, in some instances
NECS'ngineering
failed to understand all implications of what were
viewed as minor changes
on actual plant operations.
An illustration
of this was the failure to recognize that the upgrading of sections
of heat tracing from non-safety related to safety related
on the
g-List had implications on the heat tracing already installed,
which
had not been treated
as safety related for several
years (e.g., this
raised considerations
of seismic qualification, procurement,
and
application of the quality assurance
program).
There
have
been
examples
where system engineering
has taken
a less
than thorough
approach to solving problems.
Problem investigations
have not
consistently
included fundamentals
such
as fact gathering,
proceduralizing,
organizing,
and documenting.
An example
was the
investigation of vibration in the charging
pump suction line, which
was ultimately attributed to a misapplied suction stabilizer for the
positive displacement
charging
pump.
The investigation took months
to complete
and was not considered well planned or controlled.
Engineering
has
been generally responsive
to
NRC and industry
initiatives and, while resolution is not generally timely, products
are of good quality.
In this regard,
the licensee
embarked
upon
improvement initiatives in the areas of Design Bases
Document
reconstruction,
Configuration Management,
and Plant/Systems
Engineering,
and
has
expended
considerable
resources
to make these
initiatives substantial
contributors to improved engineering
and
technical
work quality.
Although it took over a year from the time
that the licensee first initiated a design basis
document
program to
issue the first document,
the licensee
has
now completed
0
19
reconstruction of the design
bases for several
safety related
systems.
This work appears
to be a substantial effort to improve
design understanding
and consolidation.
Concerns identified during
the reconstruction
are being resolved in a responsible
manner.
Following the completion of the first 'few documents,
the licensee
conducted
SSFI type inspections
on certain systems
as part of the
verification and validation process.
These
SSFI examinations
appeared
to be substantial
and resulted in several
important
improvements.
Other licensee initiatives, such
as the onsite engineering
program,
have also received increased
attention.
In particular, the licensee
has
implemented
a number of initiatives to improve the performance
of Plant/System
engineers
in monitoring the performance of plant
systems,
improving relationships
between plant engineering
and
design engineering,
and involving design engineering
more fully into
day-to-day plant operations.
Most notable
among these
are:
(1)
quarterly system walkdowns by the plant system engineer
and the
design engineer,
with a state-of-the-system
report to licensee
management;
(2) rotation programs
between the plant system engineer
and design engineer;
(3) joint plant and design engineer
review and
consensus
on walkdown checklists
and trending program attributes;
and (4) more centralized trending
and tracking of system problems
and improvements.
In contrast to these initiatives, however, plant
management
appears
to be slow in focusing attention
on the issue of
plant material condition, although precursors
of this issue
have led
'to equipment inoperability (e.g., corrosion problems with the
system,
degradation
and failure of ASM cable,
and degradation
of the
centrifugal charging
pump lube oil systems).
Although conducted after the conclusion of this
SALP assessment
period,
a team inspection in January
and early February
1990 also
made observations
in this functional area.
The system
engineer/design
engineer effort was recognized
as
a significant
licensee initiative which had been substantially
implemented,
although the potential;for additional
improvement
was noted in some
cases
regarding system/design
engineer training and qualification,
definition of responsibilities,
and the interaction of design
engineers
with the system engineers
and the plant hardware.
The
team also noted that
NECS had more than
a year's worth of design
engineering
work identified for accomplishment
(about 25K related to
long-term capital
improvements),
although preliminarily this work
inventory appeared
to be well-managed
and effectively prioritized by
,NECS management.
The licensee
received
one escalated
enforcement action in this
functional area,
as discussed
ear1ier,
which indicated the
need for
programmatic attention to the design basis
and its implementation.
Other violations, although
more minor in nature,
indicated
a need
for additional attention in certain areas
(e. g., corrective action
follow-up, and training on applicable administrative
procedure
revisions prior to their implementation).
0
20
2.
3.
The licensee
engineerinq organization
was well staffed
as indicated
by the scope of work being performed in house.
The commitment to
the system engineering
program was also demonstrated
by assigning
the function of plant engineering to a separate
manager.
The licensee
has
made notable efforts to train technical staff in a
number of areas.
A large effort was
made to provide technical staff
with training in the application of 10 CFR 50.59 and root cause
determinations.
The licensee
also continues
to. commit resources
to
providing a sixteen
week plant system operation course to technical
staff.
Management
has demonstrated
significant interest in
engineering
improvement initiatives.
However,
a January
1990
corrective action program inspection
team identified weaknesses
in
the establishment
of a formal training program for design
system
engineers.
Performance
Ratin
Performance
Assessment - Category 2, Improving Trend.
Board Recommendation
The licensee
should continue to place
emphasis
on established
long
term programs
such
as the configuration management
and system
engineering
programs.
Attention should also continue to focus
on
the interface
between corporate
engineering
and the plant,
and the
formal resolution of plant problems.
Additionally, the licensee is encouraged
to be self critical,
emphasizing
the identification of problems early on and the
establishment
of aggressive
schedules
for corrective actions.
The
issue of plant material condition should also
be aggressively
assessed.
G.
Safet
Assessment/ ualit
Verification
~Ana1 sis
This functional area
was observed routinely during the assessment
period by both the resident
and regional inspection staffs.
Approximately 708 hours0.00819 days <br />0.197 hours <br />0.00117 weeks <br />2.69394e-4 months <br /> of inspect)on effort were devoted to this
functional area.
The performance of equality Assurance,
equality
Support (the onsite
gA branch),
onsite equality Control, the Onsite
Safety
Review Group
(OSRG),
and the Plant Staff Review Committee
were included in this assessment,
as well as the licensee
organizations
involved in the review of regulatory
and industry
in>tiatives.
During the previous
SALP period, the licensee's
performance
in this
area
was rated
as Category
2.
Issues
addressed
included:
the
need
to perform thorough evaluations
of plant problems;
the development
and implementation of well thought-out corrective
action/investigation
plans, with appropriate
assignment
of
management
responsibility; the
need to better include quality
21
organizations
in the review of events;
the need for improvements in
the quality of licensing submittals;
and the need for programmatic
assessments
of regulatory safety initiatives identified by
inspection findings to ensure
thorough and timely consideration.
Mith respect to management
involvement and control in the assurance
of quality, the gualsty Assurance
organizations
demonstrated
extremes of involvement and effectiveness.
On the one hand, the
gA
organization
has
been
on the forefront of the development of
performance
based
inspection activities with the implementation of
the Safety System Functional Audit and Reviews
(SSFAR) and the'audit
of their NSSS vendor.
On the other extreme,
management failed to
properly control
and monitor the performance of gA program audits of
safety related equipment suppliers.
This resulted
from a breakdown
of management
control
and overview within the gA department,
resulting in numerous audits which were inadequate
in both scope
and
content to meet
NRC requirements.
These deficiencies
also
emphasized
the failure of licensee
gA personnel
to implement
appropriate corrective action program requirements
(e.g.
issuance
of
NCRs) in that audit program deficiencies
had been noted over a
several
month period without implementation of any formal corrective
action program review.
Additionally, management failed to recognize
that allowing a non-licensed shift supervisor to stand watch
contradicted Technical Specification requirements.
Mith regard to resolution of technical
issues
from a safety
standpoint,
root cause
reviews appeared
to be technically sound
and
thorough in most cases.
A specific improvement,
which was apparent
in the quality of licensee
gA audits,
has
been the use of auditors
with direct experience
in the technical
areas
being audited.
This
has
been demonstrated
specifically in the
SSFARs
and
some recent
vendor audits.
On the other hand,
although
a clear understanding
of
technical
issues is normally demonstrated,
the Plant Staff Review
Committee failed to recognize
the significance of allowing work to
calibrate
a containment
sump indicator with the
sump access
open.
The licensee
has
been generally responsive
to
NRC initiatives.
One
NRC concern
from the last
SALP period that was well addressed
by the
licensee
involved the initiation of root cause evaluations
(equality
Evaluations
and Non-conformance
reports) for problems
on non-safety
related
systems
which could potentially challenge safety systems.
Also, the licensee
has continued to develop the Event Investigation
Team methodology for major events
and,
when used, results in good
products.
Overall, the licensee
has
implemented
a viable program
for conducting'in-depth
Event Analyses/Root
Cause evaluations.
The
licensee
has
been refining their criteria for screening
events to
more closely conform to industry standards.
This effort is expected
to result in selection of the more deserving
events for analyses,
appropriately exclude those
events of lesser significance,
and
improve the quality of event evaluations.
.Additionally, the
licensee
has assured that personnel
responsible for conducting event
evaluations
are appropriately trained
and qualified in the
techniques
of root cause
analy'ses.
\\
0
22
However, without the formal structure of an Event Investigation
Team,
where clear management
ownership
was defined, there
have
been
examples of problem reviews which have
been limited in scope
and
which have involved inadequate
corrective actions
and less than
timely implementation.
For example,
although
an
NRC inspector
had
identified overtime
usage in excess
of technical specification
limits, overtime abuses
continued for at least the following week
and management
did not initiate a review of the implementation of
the technical specification requirement for another three weeks.
An
additional
example involved incomplete
and untimely follow-up of NRC
concerns
dealing with safety evaluations
and administrative controls
for fire protection program components.
The licensee
responsiveness
to equipment lineup problems,
repeatedly the cause of minor events
and the subject of several
inspection reports,
was considered
inadequate,
resulting 'in escalated
enforcement action,
as previously
discussed.
The licensee
provided
a large amount of highly technical
information
in response
to staff questions
on the Long-Term Seismic
Program
(LTSP), which was conducted to completely reevaluate
the seismic
design basis for the plant, using state-of-the art seismic data
and
analysis
techniques,
including a full level I Probabilistic Risk
Assessment
(PRA).
Although the licensee's
efforts to provide the
staff with voluminous and detailed information about this program
have required
a significant allocation of company resources,
the
licensee
has
been quite responsive
to the NRC's requests
and
information has
been provided in a timely manner.
Although conducted after the conclusion of this
SALP assessment
period,
a team inspection in January
and early February
1990 focused
particular attention
on the licensee's
corrective actions
program.
This program is managed
on the Plant Information Management
System
(PIMS), a computer-based
tracking and communications
system
used for
essentially all types of items,
issues,
or problems which require
corrective action.
Malkdown of plant systems,
numerous
interviews,
and substantial
reviews of licensee
logs and records did not
identify any items reqUiring corrective action which had not been
entered into the
PIMS program.
Preliminarily, the team also did not
identify any safety-significant
problems which had not received
appropriate
and timely corrective action.
However, action on
several
items of apparent
lesser individual significance
had been
pending or under evaluation for as
much as
a few years,
and it was
not apparent that the licensee
had fully evaluated
the safety
significance of these
items.
The team also noted that each
organizational
group was responsible
for acting on items assigned
to
it (unless
or until it was reassigned),- but that
no group or person
appeared
to feel responsibility or "ownership" for managing the
overall
system.
Plant management
stated at the end of the team
inspection that,
based
on an assessment
previously in progress,
a
new organizational
group was being established
to provide oversight
of the corrective actions,
root cause, trip reduction,
and other
similar programs.
0
23
During this appraisal
period, the licensee
submitted nineteen
requests
for license
amendments,
and
a total of eighteen
license
amendments
were issued.
In addition, the licensee
resolved safety
issues
related to six generic letters
and three
NRC bulletins
requiring
NRR technical
review.
Also, three
review were resolved.
In general,
the licensee's
understanding
of
the technical
issues
involved in these actions
was apparent,
and in
most, cases,
the resolution
was timely.
Although there were
no enforcement
items specifically attributable
to this functional area during the
SALP period, aspects
of
enforcement
items discussed
in other functional areas
emphasize
the
need for management
and quality verification organizations
to more
fully involve themselves
in assuring that programmatic
problems
are
discovered early and addressed
in a comprehensive
and timely manner.
Examples of this have
been discussed
previously in this report and
include: the adequacy of vendor audits;
the use of excessive
overtime; the assignment of an unlicensed shift supervisor;
and
providing for effective corrective action,
as it related to valve
lineup problems.
Also symptomatic of a potential
problem in the
performance of the management
and quality verification groups is a
noted decline in plant housekeeping.
The quality verification organizations
appeared
to be adequately
staffed
and have evaluated
a substantial
percentage
of site
activities,
such
as engineerinq,
design
changes,
and operations.
Additionally, the gA organization
used contracted
help on a number
of audits to it s advantage,
finding technically qualified
individuals to round out audit teams
and utilize that expertise to
train their employees.
The licensee's
training and qualifications program
made
a positive
contribution in this functional area.
The licensee
continued to
emphasize training in the area of root cause identification and
corrective actions.
Additionally, personnel
qualification was
a
contributor to the qual.ity of many gA and
gC audits.
The licensee,
also included
gA and
gC personnel
in the technical staff training
program, contributing to system understanding.
Performance
Ratin
Performance
Assessment - Category 2, Improving Trend.
Board Recommendations
The licensee is encouraged
to maintain the emphasis of the quality
verification programs
on performance
based audits,
using technical
expertise
and in depth reviews to identify problems.
The licensee
is also encouraged
to continue to increase
the emphasis
placed
on
the identification of problems.
In view of the recent problems
identified with the performance of vendor audits,
the licensee
should consider
actions to ensure that similar problems
do not exist
in other areas of the gA organization.
24
V.
SUPPORTING
DATA AND SUMMARIES
A.
Licensee Activities
In general,
both units operated
acceptably
during the assessment
period.
Specific operational activities are summarized
as follows:
Unit 1
At the beginning of the
SALP period, Unit 1 had just completed its.
second refueling outage.
Two automatic reactor trips were
experienced
in rapid succession
on August 30 and September
1, 1988.
Following these trips, Unit 1 operated for 399 continuous
days,
setting
a record for Westinghouse
four loop plants.
A trip on
October 6, 1989,
ended the run and the licensee initiated its third
refueling outage
a week early.
The refueling outage included
refueling the core with higher enrichment fuel, reactor coolant
pump
motor modifications, continuation of the snubber reduction program,
feedwater control system modifications,
and routine maintenance
work.
The outage
concluded
on December
14,
1989 and the Unit
returned to power operation.
Unit 2
Unit 2 commenced
the
SALP period at 100K power, experienced
a
reactor trip on September
1, 1988,
and was shutdown
on September
17,
1988, to commence its second refueling outage.
The refuelinq outage
scope
included reactor
coolant
pump motor modifications,
aux> liary
saltwater
pump overhauls,
routine maintenance,
and unplanned
maintenance
on one safety injection pump, which was
damaged
due to a
lineup problem.
The outage
concluded
on December 8, 1988.
Unit 2
operated
through the remainder of the
SALP period at essentially
100'ower with the exception of an outage to repair
a leaking
pressurizer
safety valve,
one automatic reactor trip, and three
Plant status at end of SALP
eriod
Diablo Canyon
ended the evaluation period with both units operating
at full power.
B.
Direct Ins ection
and Review Activities
A total of approximately
4450 hours0.0515 days <br />1.236 hours <br />0.00736 weeks <br />0.00169 months <br /> of direct inspection
were
performed during this
SALP period.
Table
1 provides
a summary of
those inspection activities.
Forty inspections,
including a Safety
System Functional
Inspection Overview team inspection,
two Emergency
Preparedness
exercise
team inspections,
an Emergency Operations
Procedures
team inspection,
and four management
meetings,
were
conducted
during this period.
Two resident inspectors
were assigned
during the
SALP assessment
period.
0
25
C.
Enforcement Activit
Along with a summary of inspection activities,
a summary of
enforcement
items resulting from those inspections is provided in
Table 1.
A description of the enforcement
items is provided in
Table 2.
During the
SALP period,
a two part escalated
enforcement
action ($75,000 Civil Penalty)
was identified concerning the failure
to implement or maintain design
bases
through engineering,
and the
failure to resolve identified problems in a timely, effective
manner.
Subsequent
to the
SALP period, but related to events within
the period,
an enforcement action ($50,000 Civil Penalty)
was issued
concerning the construction
and cleanliness
of the containment
Additionally two level IV violations, regarding vendor
gA
audits,
and one level III violation (no civil penalty),
regarding
a
non-licensed shift supervisor,
were issued
subsequent
to the end of
the
SALP: period.
D.
Confirmation of Actions Letters
No CALs were issued during the appraisal
period.
E.
Office of Anal sis
and Evaluation of 0 erational
Data
AEOD) Event
~na
sos
AEOD reviewed the licensee's
events
and prepared a report which is
included
as Attachment l.
AEOD reviewed
LER s and significant
operating
events for quality of reporting and effectiveness
of
identified corrective actions.
F.
Office of Investi ation
OI) Status
On August 1, 1988,
relevant to Diablo
December
31, 1989,
December
31, 1989,
relevant to Diablo
OI had three matters that were open
and pending
Canyon.
During the period August 1, 1988 to
OI opened
two new investigative matters.
As of
five investigations
were open
and pending
Canyon.
t~
r
Table
1
INSPECTION ACTIVITIES AND ENFORCEMENT SUMMARY
08/01/88 - 12/31/89)
DIABLO CANYON UNIT 1
Inspections
Conducted
Enforcement
Items
Functional
Area
Inspection
Percent
Hours*
of Effort
Severit
Level**
D
1.
Plant Operations
2.
Radiological
Controls
3.
Maintenance/
Surveillance.
4.
Emergency
Prep.
5.
Security
789
203
362
76
160
34
Engineering/
Technical
Support
340
Safety Assessment/
396
equality Verification
Total s
15
17
2
2
Allocations of inspection
hours to each functional area are
~
approximations
based
upon
NRC form 766 data.
These
numbers
do not
include inspection
hours
by NRC contract personnel.
Severity levels are in accordance
with NRC Enforcement Policy (10 CFR Part 2, Appendix C).
r
0
Table 1 (continued)
INSPECTION ACTIVITIES AND ENFORCEMENT SUMMARY
08/01/88 - 12/31/89
DIABLO CANYON UNIT 2
Inspections
Conducted
Enforcement
Items
Functional
Area
1.
Plant Operations
Inspection
Percent
Hours*
-
of Effort
817
38
Severit
Level"*
D
2.
3.
Radiological
Controls
Maintenance/
Surveillance
125
279
13
4.
Emergency
Prep.
5.
Security
194
63
c
3
6.
Engineering/
Technical
Support
339
Safety Assessment/
312
equality Verification
16
15
8,
Fire Protection
Totals
Allocations of inspection
hours to each functional area are
approximations
based
upon
NRC form 766 data.
These
numbers
do not
include inspection
hours
by NRC contract personnel.
Severity levels are in accordance
with NRC Enforcement Policy (10 CFR Part 2, Appendix C).
0
TABLE 2
DIABLO CANYON UNIT 1 ENFORCEMENT ITEMS
08/01/88 - 12/31/89
Inspection
Re ort No.
~Sub 'ect
Severity
Level
Functional
Area
88-25
Failure to meet commitment to issue
Deviation
administrative procedure
on reading
test instruments.
89-01
89-01
89-01
89"15
89-15
A design
change
was modified by
General
Construction without
submitting
a field change to Diablo
Canyon
Power Plant
(DCPP) for approval.
480V power cable were installed
in the plant and attached to instru-
mentation cable without a safety
evaluation.
No information was available to
operators
on the buildup of carbon
dioxide in the control
room
Component Cooling Water/Auxiliary
Saltwater
(CCM/ASM) Systems
design
basis
not incorporated into plant
procedures;
(AFM) pumps out of service greater than
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />;
ASM pump overcurrent relay not
operable for design basis
reduced
bus
voltage;
ASM pump .,impeller replacement
did not consider Diesel
Fuel Oil (DFO)
storage for increased
horsepower;
AFM
overspeed trip mechanism - failure to
implement vendor recommendations
in
test
and preventive maintenance
procedures
Steam driven
AFM pump inoperable for
30 days
due to open
gauge line root
valve; untimely correct)ve actions
for compensatory
measures
for
missing
DFO transfer
pump vault
drain backwater
IY
IV
Deviation
TABLE 2 (continued)
DIABLO CANYON UNIT 1
ENFORCEMENT ITEMS
08/01/88 - 12/31/89
Inspection
~Re ort Ro.
89-23
89-23
89-23
89-25
~Sub 'ect
Work was performed
on heat tracing
without applicable
gA requirements
translated
into the work specifica-
tions
Plant maintenance
personnel
perform-
ing safety related work worked in
excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a 7 day period.
Valves for Hydrogen Purge
System did
not have power removed to satisfy
Containment Isolation Technical
Specification.
Inadequate
response
to fuel handling
building radiation monitor alarms.
Severity
Level
IV
IV
IV
IV
Functional
Area
0-
TABLE 2 (continued)
DIABLO CANYON UNIT 2
ENFORCEMENT ITEMS
08/01/88 - 12/31/89)
Inspection
~Re ort Ro.
89-29
89-01
89"01
89-01
89"01
89-01
89-01
~Sub 'ect
Failure to follow administrative
procedures
for oscillating gauge
during surveillance
and testing.
The
GE/GW ventilation system
was
declared operational
although
a
partial closure of the design
change
had not been completed
and a field
change
had not been
approved.
The Operations
Valve Identification
Diagrams for the auxiliary building
ventilation system were not updated
to include
a recent modification.
A Class
1 support
was not located
in accordance
with the approved
design.
Four flange bolts on Safety Injection
(SI) cooling water line and damper
fasteners
did not have full thread
engagement.
Bolts were replaced in the
GE/GW
ventilation system without written
work orders.
Nine GE/GW welds were not inspected
prior to the system being declared
= operable.
An anchor bolt on the ventilation
system
was identified as not meeting
the required torque - no action was
taken to evaluate
the discrepancy.
Numerous
obvious discrepancies
existed
with electrical conduits,
loose pipe
hangars
and missing nuts
and washers
on pipe hangers
on SI pump 2-2 that
were not reported
on an Action Request.
Severity
Functional
Level
Area
IV
6
IV
IV
IV
IV
IV
IV
IV
L
J
0'
TABLE 2 (continued)
DIABLO CANYON UNIT 2 ENFORCEMENT ITEMS
08/01/88 - 12/31/89
Inspection
~Re ort No.
89-05
89-21
~Sob 'ect
A spl it washer to the Unit 2
pump over-
speed
stop valve FCV-152,
was
modified without being processed
as
a design
change.
The fire door to the Unit 2
Residual
Heat Removal
(RHR)
Heat Exchanger
room was impaired.
Severity
Functi onal
Leve1
- Area
IV
IV
0
TABLE 3
DIABLO CANYON UNIT 1
SYNOPSIS
OF LICENSEE EVENT REPORTS
Functional
Area
SALP Cause
Code"
A
B
C
D
E
X
Totals
1.
Plant Operations
2.
Radiological Control s
3.
Maintenance/Surveillance
4.
Emergency
Preparedness
5.
Security
6.
Engineering/Technical
7.
Safety Assessment/
equality Verification
Totals
Cause
Codes:
1
1
5
1
6
2
1
1
4
10
. A:- Personnel
Error
8 - Design, Manufacturing or Installation Error
C - External
Cause
D - Defective Procedures
E - Component Failure
X - Other
0
TABLE 3
DIABLO CANYON UNIT 2
SYNOPSIS
OF LICENSEE EVENT REPORTS
Functional
Area
SALP Cause
Code*
A
B
C
D
E
X
Totals
1.
Plant Operations
2.
Radiological Controls
3.
Maintenance/Surveillance
4.
Emergency
Preparedness
5.
Security
6.
Engineering/Technical
7.
Safety Assessment/
equality Verification
Totals
3
3
1
1
1
3
2
12
13
3
Cause'Codes:
A..-, Personnel
Error
8 - Design, Manufacturing or Installation Error
C - External
Cause
0 " Defective Procedures
E - Component Failure
X - Other
/gj~
0
0
'
Attachment
1
AEOD Input to SALP Review for Diablo Canyon
During the assessment
period 54
LERs were reviewed:
Unit 1: 88-23 through 89-13
Unit 2: 88-08 through 89-10
l.
Important Operating
Events
L
Utilizing AEOD s screening
process,
the following seven Unit 1 and Unit 2
LERs were categorized
as important events:
Unit 1
50-275/88-28 "Entry Into Technical Specification 3.0.3
When
Two of Four
t'I
Iqtly)IM
I
p
bl
II
t
I
dq
t
Environmental gualification of Electrical Connections."
Two of four main
steam isolation valves
on each unit were declared
due to
inadequate
environmental qualification of electrical
surge suppressors
located across
terminal connections for the
MSIV solenoid control valves,
Short circuiting of surge
suppressors
could potentially blow control
power fuses
and preclude operator action to close the HSIVs during
certain accident scenarios.
Failure to meet the applicable technical
specification
(TS) action statement
resulted in entry into TS 3.0.3.
The
subject
surge
suppressors
and electrical
connections
were
removed
and
replaced with environmentally qualified splices.
50-275/89-02 "Failure to Reinstall
Backwater
Check Valves in Fuel Oil
pp
ItD
I gyt
D
I
I dq t
I t
tt
t
Contractor
Personnel."
Drain lines in the diesel fuel oil transfer
pump
vaults did not have backwater
check valves installed.
The backwater
described
in the Updated Final Safety Analysis Report,
provide back flood protection for the diesel fuel oil transfer
pump
vaults in the event of blockage in the drain line concurrent with
flooding in another
headered
vault.
Loss of the transfer
pumps
due to
flooding would prohibit transfer of diesel fuel oil from the storage
tanks to the diesel
generator
day tanks.
As partial corrective action,
backwater
check valves were installed in drain lines from the transfer
pump vaults.
50-275/89-09 "Safety Injection and Reactor Trip From Steam
Line
P
gp
I
gig
I ."
A
t
tt
I ty I d tt
and reactor trip was initiated as
a result of plant personnel
creating
pressure
oscillations in a sensing line during testing.
The importance of this event is that at the time of the reactor trip, two
of the four atmospheric
steam
dump valves
(ADVs) had been
removed from
service.
This is permissible
by the plant technical specifications,
but
plant emergency
operating procedures
specified that the
ADVs be used for
reactor coolant system cooldown.
AEOD is evaluating the generic aspects
C~
0
of permitting equipment required by EOPs to be removed from services
without appropriate
clearance
controls.
50-275/89-10
"Thimble Tube Thinning Due to Flow-Induced Vibration."
In
~pgtt
0
11 tt
88-09,
ddy
t I
9 tl
f '
monitoring system thimble tubes
revealed
28 tubes exceeding
50 percent
through-wall degradation,
due to flow-induced vibration.
As partial
corrective action,
33 tubes
were replaced
and 12 tubes were repositioned.
Unit 2
50-323/88-08
"Reactor Trip and Subsequent
Safety Injection Following an
d
L
t
t
R
t
L
I tP 9220
t
Galling on the Threads of an Aluminum Stud."
Deterioration of a galled
aluminum electrical
connector for reactor coolant
pump (RCP) 2-2,
resulted in an electrical
ground fault, a manual reactor trip, and
a
2-2 manual trip.
Loss of 12
kV start-up (offsite) power was also
experienced
during the event.
Investigation of the trip revealed
several
associated
problems.
These
included 1) defective welds
on a fuse block for a grounding transformer,
2) routing of the heutral
cable for start-up transformer 2-1 grounding
bank along the top of the resistor
bank (subjecting the cable to intense
heat,
which resulted in burning of the cable insulation),
and 3)
inadvertent
blockage of air cooling to the resistor
bank.
Licensee corrective actions
included analyzing grounding resistor
heat
loadings,
cable rerouting, infa-red surveillance of RCP high voltage
connections,
and improved housekeeping
controls in the resistor
bank
area.
50 323/88-14 "Anchor Darling Check Valve Retaining Block Stud Breakage
g
I
St
0
I
0
kl g" (IRSCCP.
A
h
k
located in the residual
heat removal
(RKR) hot leg injection line, was
found to have two broken retaining block studs.
Incorrect manufacturer
heat treatment of the block.,studs
caused susceptibility to IGSCC.
The
licensee's
analysis
concluded the valve would remain operable with broken
studs.
The failed valve was repaired,
and other similar valves were
inspected for the
same concern.
50-323/88-15
"Residual
Heat Removal
Pump 2-2 Lower Motor Bearing Housing
t
I
d
8 t
8
8
g
t f th
Sh ft
N t L
kl
8 II
8
RHR pump 2-2 was declared
when
a lock tab washer
on the
vertical motor rotor shaft rotated,
allowing the shaft thrust bearing nut
to loosen.
The loosened thrust bearing nut allowed the shaft to drop
axially and create
metal to metal contact with the lower motor bearing
housing causing mechanical failure of the oil reservoir
and subsequent
oil leakage
and
smoke generation.
Inadequate
design
and preventative
maintenance
were identified as root causes
of the failure.
Preliminary Notifications
Eight preliminary notifications
(PNs) pertaining to Units 1 and
2 were
issued
by Region
V during the assessment
period.
For those
events
r
O.
described in the
PNs which warranted
LERs from the licensee,
the
LERs
were verified to have
been submitted.
. No omissions
were identified.
3.
LER Overview
Causes
o
e even
s are
f th
t
distributed
among various categories,
however
on
U t 1
inordinate
number of the
LERs were associated
w>th p
ersonnel
nl
an lnor
error.
Procedural
inadequacies
were also prominent.
On Uni
U it 2
the
largest
number of events
were also personnel
errors,
and many were
similarly associated
with inadequate
procedures.
4.
5.
LER Timeliness
and guality
LERs submitted
by the licensee
were timely and of high quality, w>th the
exception of the following:
LER 50-323/88-20
"Containment Ventilation Isolation and Fuel Handling
Building Ventilation Shift to the Iodine Removal
Node," utilized terms
such
as
FCV-128,
FCV-111A, and
RH 28A without providing further component
t
'n
diaorams.
Additional clarification should
be
provided in the fElt when pTant specific designations
are utilized.
I
LER 50-323/87-20 "Entry Into Technical Specification 3.0.3
Due to Both
T
'
Auxiliary Building Ventilation Being Inoperable," indicated
a
supplement
would be issued.
The event dsd not
'
rains
0
evaluation period,
however, the supplemental
report was not issue
un
>
July 28, 1989.
This appears
to be
an inordinate
amount of time to
determine root cause
and corrective action,
and provide the supplemental
information to the
NRC.
Abnormal Occurrences
and Other Events of Interest
durin
this assessment
period were classified
as
th
NUREG-0090 report to Congress.
Abnormal Occurrences
for inclusion sn
e
6.
AEOD Reports
No AEOD reports
were issued
regard>ng
events occurri
g
rin
at Diablo Canyon
during this evaluation period.