ML17056A149
| ML17056A149 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 07/24/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17056A148 | List: |
| References | |
| 50-220-88-99-01, 50-220-88-99-1, 50-410-88-99, NUDOCS 8908020385 | |
| Download: ML17056A149 (94) | |
See also: IR 05000220/1988099
Text
ENCLOSURE
1
FINAL SALP
REPORT
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
INSPECTION
REPORT
NO. 88-99
NIAGARA MOHAWK POWER
CORPORATION
NINE MILE POINT UNITS
1 AND 2
DOCKET NOS. 50-220
and 50-410
ASSESSMENT
PERIOD:
March 1,
1988 to february 28,
1989
BOARD MEETING - April 13,
1989
TABLE OF CONTENTS
I.
INTRODUCTION...............................
~Pa
e
A.
Licensee Activities .....
B.
Direct Inspection
and Review Activities ..............
II.
SUMMARY OF RESULTS ....................
A
Overv>ew
.
~ ......
~
~
~
~
~
~
~
~
0
~
~
~
~
~
~
~
~
B.
Facility Performance
Analysis
Summary ................
C.
Unplanned
Shutdowns,
Plant Trips,
and Forced Outages
.
6
7
III. CRITERIA ........
IV.
PERFORMANCE ANALYSIS
10
A.
Operations
B.
Radiological
and Chemistry Controls
C.'aintenance
and Surveillance
.
D.
Emergency
Preparedness
E..Security
and Safeguards
..
F.
Engineering
and Technical
Support ..
G.
Safety Assessment/guality
Verification
.
10
15
19
25
27
29
32
V.
SUPPORTING
DATA AND SUMMARIES
36
A.
B.
C.
D.
Enforcement Activity
Confirmatory Action Letter ...
Inspection
Hour Summary ............
Licensee
Event Report Causal
Analysi s and
E
Other ............................
Summary ....
36
39
40
41
44
I.
INTRODUCTION
The
Systematic
Assessment
of Licensee
Performance
(SALP)
program is
an
integrated
NRC staff effort to collect the available observations
and data
on
a periodic basis
and to evaluate
licensee
performance
based
upon this
information.
The
SALP program is supplemental
to normal
regulatory pro-
cesses
used to ensure
compliance with NRC rules
and regulations.
The
program is
intended
to
be sufficiently diagnostic
to provide
a rational
basis for allocating
NRC resources
and to provide meaningful
guidance
to
the licensee's
management
to promote quality and safety of plant construc-
tion and operation.
An
NRC
Board,
composed
of the staff
members
listed
below,
met
on
April 13,
1989,
to review the collection of performance
observations
and
data
on performance,
and to assess
licensee
performance
in accordance
with
the guidance
in Chapter
"Systematic
Assessment
of Licensee
Per-
formance."
A summary of the
guidance
and evaluation criteria is provided
in Section III of this report.
The Board's
findings
and
recommendations
were
forwarded
to
the
NRC
Regional
Administrator
for
approval
and
issuance.
A.
Licensee Activities
Unit
1
The
assessment
period
began
with Unit
1
shut
down
and
defueled.
The
reactor
was shut
down in December
1987
as
a result of
system
induced
Following the
shutdown,
significant deficiencies
in
the
licensee's
Inservice
Inspection
(ISI)
and
Fire
Protection
Programs
were
identified,
thus
requiring
the
unit to
remain
shut
down
pending
resolution.
Throughout the assessment
period,
the majority of the activities at Unit
1
involved resolution
of the
and Inservice
Testing
( IST)
Program
con-
cerns,
concerns,
operator
requalification
and
Emergency
Operating
Procedures
(EOP) training
issues,
and resolution of
additional
specific
issues
outlined
in the
Restart
Action
Plan.
These
issues
are discussed
in further detail
elsewhere
in this assessment.
NRC
Confirmatory Action Letter
(CAL) No.
88-17
was
issued
to
summarize
the
NRC's
overall
concerns
with Unit
1
performance
and
to
formalize
the
licensee's
corrective action commitments prior to Unit
1 restart.
The
CAL was issued
on July 24,
1988
and confirmed three requirements
which
the
licensee
has
committed
to
meet before restart
authorization will be
granted
by the
NRC.
Item one of the
CAL called for Niagara
Mohawk manage-
ment to determine
the root causes
of their problems.
Item two called for
the
licensee
to develop
short-term
and
long-term corrective
actions
to
prevent
recurrence
of these
problems.
To address
these
elements
of the
CAL the licensee
developed
and,provided
to the
NRC
on
December
22, their
Restart
Action Plan
(RAP).
The
RAP was
submitted to the
NRC for review
and approval
and delineates
short-term corrective actions which the licen-
see
must
take
prior
to
Unit
1
restart.
The
NIP
was
made available for review
on site
and
contains
long-term corrective
actions
and additional
programmatic
changes
needed.
At the
end of the
assessment
period.
The
was still undergoing
NRC review.
The third
item requires
the licensee
to conduct
and document, for NRC staff review,
a self-assessment
of their readiness
to restart Unit 1.
During
the
assessment
period,
major
changes
in
the
licensee's
station
organizational
structure
were
made,
as
well
as
several
key
personnel
changes.
Additionally,
the
new
position
of Executive
Vice
President-
Nuclear
was created
towards
the
end of the assessment
period.
The major-
ity of the other
changes
were at
the site staff
level
and
took
place
throughout the assessment
period.
Unit 2
Early in the
assessment
period,
the licensee
completed
the last
phase of
the Power Asension
Test
Program
and declared
the unit available for com-
mercial
operation
on
March ll, 1988.
The unit operated
at
power until
Ap&l 29,
1988,
when it was
shutdown to support
a three
week planned out-
ag%.
During
power operations
prior to
the
outage,
the unit experienced
two scrams,
one of which was
caused
by personnel
error.
The
three
week
outage
was
completed
and the unit was returned
to power
on
May 22,
1988.
On
May 23,
1988,
a recirculation
pump
seal
leak
caused
a
forced
plant
shutdown.
The
seal
was
repaired
and
the unit
was
returned
to power
on
May 30,
1988.
During
power
operations
through
September
2,
1988,
the
reactor
scrammed
five times.
Two
were the result of problems with
the
Control
System,
two
were
caused
by deficiencies
in
the
(EHC) system,
and personnel
error resulted
in one
additional
On September
2,
1988,
the licensee
shut the plant
down
due to missed
surveillance
testing
and
a leak in the cooling coils
of the main generator.
The unit was returned
to power
on September
15,
1988 on single recircula-
tion loop operation
due to binding of the "B" loop recirculation
pump dis-
charge valve.
The unit operated
at power until September
22,
1988,
when
a
reactor
scram resulted
from a loss of Reactor Building Closed
Loop Cooling
due
'to
an
inadequate
plant
impact
assessment
for surveillance
testing.
The unit was returned
to power and operated
at power until the start of a
planned mid-cycle outage which commenced
on October
1,
1988.
The mid-cycle maintenance
and surveillance
outage
was scheduled
to be com-
pleted
by
December
1,
1988.
Outage activities continued
through the
end
of this assessment
period
on
February
28,
1989.
The outage
was
extended
primarily due to containment
isolation- valves failing Appendix J
leakage
testing criteria
and also
due to problems with the
service
water
system
cross-connect
valve
actuation
logic
not
meeting
the
single
failure
criterion.
B.
Direct Ins ection
and Review Activities
Units
1 and
2
An
NRC Senior
Resident
Inspector
was assigned
for the entire
assessment
period.
Previously
assigned
Resident
Inspectors
were
reassigned
and
replaced
in June
and November
1988.
During the
12
month assessment
period,
the
NRC expended
a total of 7756
inspection
hours;
5250
hours at Unit
1
and
2506
hours at Unit 2.
Func-
tional
area distribution
of inspection
hours is documented
at the begin-
ning
of
each
individual
functional
area
and
tabulated
in
Table
2
in
Section
V.C.
During the period,
several
major
NRC team inspections
were conducted,
most
focusing
on Unit
1 as noted below:
During the
month of 'March,
1988,
an inspection of outage activities
at both units was conducted.
The inspection
involved a comprehensive
look at plant maintenance,
modifications
and surveillance at Unit 1,
observation
of a
100% load rejection startup test for Unit 2,
and the
procurement
program
for both
units
with
emphasis
on
purchase
and
dedication of commercial
grade items.
In June,
1988,
an
in-depth
review of the
implementation
and
use of
Emergency
Operating
Procedures
(EOPs)
was
conducted
by
NRC license
examiners
and
by
NRC contractors.
The inspection
focused
mainly
on
Unit
1
EOPs,
but
as
a result of significant deficiencies
identified
'n
Unit
1
EOPs,
the
inspection
was
expanded
to include
Unit 2,
as
well.
For three
weeks in September
and October,
1988,
a Safety
System
Func-
tional Inspection
(SSFI)
was conducted
by
NRC inspectors
and contrac-
tors.
The
inspection
involved
an
in-depth
examination
of the
Core
Spray
System
and
High Pressure
Coolant Injection
(HPCI)
mode of the
system.
0
In November,
1988,
a
one
week inspection
was
conducted
to determine
the status
of implementation
of Regulatory
Guide
1.97
"Instrumenta-
tion for Light Water
Cooled
Nuclear
Power Plants to Assess
Plant and
Environmental
Conditions during. and following an Accident", at
both
units.
In
December,
1988,
a
two week Maintenance
Team Inspection
was
con-
ducted at both units
by
NRC inspectors.
The
inspection
focused
on
all
aspects
of maintenance
activities
ranging
from engineering
sup-
port to observation of activities in the field.
In
December,
1988,
a
team
inspection
was
performed
to
examine
the
status of the licensee's
Inservice Inspection (ISI) program at Unit
1
to determine if corrective
actions
were satisfactory
in response
to
previously identified deficiencies.
At the
end of the
assessment
period,
a Special
Team Inspection
(STI)
comprising
NRC personnel
and contractors
was conducted
on site and at
the
corporate
engineering
office.
Overall
focus of the
inspection
was to assess
the effectiveness
of managemert
controls
and oversight
mechanisms
in various
key functional areas.
Various
other
inspections
were
conducted
throughout
the
assessment
period by
NRC resident
inspectors,
Region I and
Headquarters
person-
nel
and
by
NRC contractors.
Most of these
were combined inspections
of a more routine nature
as
opposed
to the comprehensive
team inspec-
tions.
An exception to this was
a special
inspection
by the resident
inspectors
of wiring problems
associated
with the Automatic Oepress-
urization System
(ADS) at Unit 2.
This report is the
NRC's assessment'f
the licensee's
safety
performance
at Nine Mile Point Units
1
and
2 for the period of March 1,
1988 through
February
28,
1989.
The
SALP Board for Nine Mile Point Units
1 & 2:
TITLE
W.
Kane (Chairman)
RE
Capra
R. Conte
J
W. Cook
.
J.
Johnson
W. Johnston
M. Knapp
M. Slosson
E. Wenzinger
Director, Division of Reactor Projects
(DRP)
Director, Project Directorate
No. I-l, NRR
Chief,
Boiling
Water
Reactor
Section,
Division
of
Reactor Safety
(DRS)
Senior
Resident
Inspector,
Nine Mile Point
1
and
2,
ORP
Chief, Projects
Section
2C,
ORP
Deputy Director,
ORS
Director, Division of Radiation Safety
and
Safeguards
(DRSS)
Project Manager,
Nine Mile Point
1 and 2,
'hief,
Projects
Branch 2,
ORP
Attendees (non-voting)
M.
R.
R.
A.
D.
J.
M.
W.
R.
R.
V.
M.
M.
R.
Banerjee
Barkley
Bellamy
Finkel
Fl orek
Furi a-
Hunemiller
Lancaster
Laura.
Loesch.
McCree.
Pasciak
Shanbaky
Temps'roject
Engineer,
Projects
Section
2C,
Reactor Engineer,
Projects
Section
2C,
Chief,
FRSS Branch,
DRSS
Senior Reactor Engineer,
Senior Operations
Engineer,
Radiation Specialist,
DRSS
Project Engineer,
Physical Security Inspector,
Resident
Inspector,
Nine
Mile Point
1
and
2,
Radiation Specialist,
DRSS
Project Engineer,
Chief,
ERPS,
DRSS
Chief,
FRPS,
DRSS
Resident
Inspector,
Nine
Mile Point
1
and
2,
SUMMARY OF RESULTS
A.
Overview
Overall
licensee
performance
during this assessment
period
has
not
shown
significant
improvement.
Even
though
the
functional
areas
of Security
Safeguards
and
Emergency
Preparedness
continue
to
be
rated
highly,
the
regainder
of the functional
areas
have
shown
marginal, if any,
improve-
ment, or have declined.
In the area of Unit
1 Operations,
early in the asse"sment
period the poor
performance
by licensed operators
as reflected
in their understanding
and
ability to implement the
new Emergency Operating
Procedures
indicated both
poor training and
a complacency with respect
to the adequacy of the train-
ing received.
Evidence of a strained
relationship
between
the Operations
and Training Departments
also
was acknowledged
during the previous assess-
ment period.
Actions
taken
during this
assessment
period to
remedy
the
situation were not successful.
This lack of effective
change
in operator
attitudes
toward training
and
the ineffective station
management initia-
tives to deal
with this situation
continue
to
be significant concerns
to
the
NRC.
In the areas
of Unit 2 Operations,
and Maintenance
and Surveillance,
the
high rate of personnel
errors
by both the
licensed
and
unlicensed
staff
and
maintenance
and
testing
personnel
continued
during this
assessment
period.
Station
and
corporate
management
efforts
to
reduce
or minimize
the frequent
safety
system
challenges
and plant transients
have
not
been
effective.
Likewise,
the direct support
to the
station
provided
by the
Engineering
Department staff has
been
inconsistent
and
not reflective of
an
overall
goal
to
improve
performance
and
enhance
long
term
station
reliability and safety.
This appears
to
be reflective of low performance
expectations
in that it is a newly licensed facility.
Corporate
and sta-
tion
management
should
assure
that
the current level of performance
for
Unit 2 is not acceptable
in light of the large
number
of unplanned trips
'and shutdowns.
The
NRC acknowledges
the licensee's
commitment to
a comprehensive
Nuclear
Improvement
Program
which
addresses
the
root
causes
and
provides
the
essential
elements
to effect overall
performance
improvements.
The
NRC
also acknowledges
the licensee's
recent
management
changes
made to provide
the
necessary
leadership
to the Nuclear Division to ensure
a thorough
and
successful
implementation
of this
Program.
These
changes
are
viewed
as
significant,
however,
because
they were
made late in the assessment
period
their effectiveness
has not been reflected in this assessment.
B.
Facilit
Performance
Anal sis
Summar
Last Period Dates
Unit
1
11/1/86 - 2/29/88
Unit 2
2/1/87
2/29/88
Present Period'ates
Unit
1
3/1/88
- 2/28/89
Unit 2
3/1/88
- 2/28/89
Functional
Category
Last
Area
Period
Category Thi s
Trend
Period
Trend
1.
Operations
1.
Unit
1
2.
Unit 2
2.
Radiological Controls
and Chemistry
3.
Maintenance
and
Surveillance
4.
Emergency
Preparedness
5.
Security and Safeguards
2
3
2
~ .....
improving
3
2 ...... declining
2
(2/2)
6.
Engineering
and
Technical
Support
7.
Safety Assessment/
Quality Verification
3 .....
improving
8.
Licensing
2 ..... declining
N/A
9.
Training and gualification
Effectiveness
N/A
10.
Assurance
of guality
N/A
N/A Indicates that the category
was not rated this period.
" .... This functional area
was not assessed
C.
Un lanned
Shutdowns
Plant Tri
s and Forced
Outa es
1.
Unit
1
Date/Event
6/25/88
2.
Until: 2
Power
Level
0%
Descri tion
Reactor
scram signal
due to lower than
normal voltage
on
protective bus.
Cause
Lightning
Strike,
See
LER
88-15
Functional
Area
N/A
Date/Event
Power
Level
Oescri tion
Cause
Functional
Area
3/13/88
43%
Low reactor water
level, due to failed
pressure
transmitter
and poor design.
Equipment Failure
ENG/TS
and Design
Deficiency,
See
LER 88-14
3/21/88
97.5%
Loop calibration
on
feedwater flow
transmitters
Personnel
error,
Inadequate
Plant
Assessment,
See
LER
88-17
MAINT/SU RV
and
5/23/88
Forced
Shutdown
6/2/88
50/
25.5%
Recirculation
pump seal
leak
High reactor
vessel
water level, failure
of feedwater control
valve feedback
linkage
Personnel
Error, due to
improper
installation
Equipment
Failure,
due to
design error,
See
LER 88-19
MAINT
ENG/TS
(SHUTDOWNS CONTINUED)
Date/Event
Power
Level
Descri tion
Cause
Functional
Area
6/22/88
98%
Low reactor water
level, feedwater
level control valve
ramp closed
Manufacturing
SAFETY/EQUAL
design
deficiency,
See
LER 88-25
6/28/88
7/11/88
8/6/88
9%
45%
53%
APRM Upscale trip
during start-up
EHC oil leak
Loss of
EHC system
pressure
due to
piping failure caused
by excessive
vibration
Personnel
error, not
controlling
steam
loads
properly,
See
LER
88-26
Personnel
error
(Fitting
not properly
torqued),
See
LER
88-28
Design
deficiency,
due to inadequate
support,
See
LER
88-39
MAINT
ENG/TS
9/2/88
Forced
Outage
100%
Generator stator
cooling water leak
Missed snubber
testing
Equi pment Fai lure
N/A
Personnel
error,
ENG/TS
See
LER 88-40
9/22/88
12/1/88
Automatic Scram while
shutdown
98%
0%
Loss of service
water
ARI system actuation
during survei1 lance
testing
Personnel
error,
inadequate
assessment
of
plant impact
Design
deficiency
See
LER
88-66
ENG/TS
III. CRITERIA
Licensee
performance
is assessed
in selected
functional
areas,
depending
on whether the facility is under construction
or operational.
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.
2.
6.
7.
Assurance of quality, including management
involvement and control.
Approach to the resolution of technical
issues
from a safety
stand-
point.
Responsiveness
to
NRC initiatives.
Enforcement history.
Operational
and construction
events
(including response
to, analyses
of, reporting of, and corrective actions for).
Staffing (including management).
Effectiveness
of training and qualification programs.
On'he
basi s'f
the
NRC
assessment,
each
functional
area
evaluated
i s
rated
according to three
performance
categories.
The definitions of these
performance
categories
are
as follows:
~Cate or l.
Licensee
management
attention
and
involvement
are
readily
evident
and
place
emphasis
on
superior
performance
of nuclear
safety
or
safeguards
activities,
with
the
resulting
performance
substantially
exceeding
regulatory
requirements.
Licensee
resources
are
ample
and ef-
fectively used
so that
a high level of plant
and
personnel
performance
is
being achieved.
Reduced
NRC attention
may be appropriate.
~Cate or
2.
Licensee
management
attention
to and
involvement in the per-
formance of nuclear safety or safeguards
activities
are
good.
The licen-
see
has attained
a level of performance
above that needed
to meet regula-
tory requirements.
Licensee
resources
are
adequate
and
reasonably
allo-
cated
so that good plant and personnel
performance is being achieved.
NRC
attention
may be maintained at normal levels.
~Cate or
3.
Licensee
management
attention
to or involvement
in the per-
formance
of nuclear
safety
or
safeguards
activities
are
not sufficient.
The licensee's
performance
does
not significantly
exceed
that
needed
to
meet
minimum regulatory
requirements.
Licensee
resources
appear
to
be
strained or not effectively used.
NRC attention
should
be increased
above
normal levels.
10
The
SALP Board
may assess
a functional area to compare
the licensee's
per-
formance during the last quarter of the
assessment
period to that during
the entire
period
inorder to determine
the
recent
trend.
The trend if
used, is defined as:
~lm rovin
Licensee
performance
was determined
to
be
improving near
the
close of the assessment
period.
~geclinin
Licensee
performance
was determined
to
be declining
near
the
close of the assessment
period.
A trend is assigned
only when, in the opinion of the
SALP Board, the trend
is significant
enough
to
be considered
indicative of
a likely change
in
the
performance
category
in the
near future.
For example,
a classifica-
tion of "Category 2,
Improving" indicates
the clear potential
for "Cate-
gory 1" performance
in the next
SALP period.
It
should
be
noted
that
Category
3
performance,
the
lowest
category,
represents
acceptable,
although
minimally adequate,
safety
performance.
If at any time the
NRC concluded that
a licensee
was not achieving
an ade-
quate
level of safety
performance, it would then
be incumbent
upon
NRC to
take
prompt
appropriate
actions
in
the
interest
of public
health
and
sa'fety.
Such
matters
would
be dealt with independently
from,
and
on
a
more urgent
schedule
than,
the
SALP process.
It should
also
be noted that the industry continues
to be subject to ris-
ing performance
expectations.
NRC expects
licensees
to use industry-wide
and plant-specific
operating
experience
actively in order to effect per-
formance
improvement.
Thus,
a
licensee's
safety
performance
would
be
expected
to
show
improvement
over the years
in order to maintain consis-
tent
SALP ratings.
IV.
PERFORMANCE ANALYSIS
A.
~0erati one
1.
~Anal sis
(2274 hours0.0263 days <br />0.632 hours <br />0.00376 weeks <br />8.65257e-4 months <br />,
29.3%)
Unit
1
(1464 hours0.0169 days <br />0.407 hours <br />0.00242 weeks <br />5.57052e-4 months <br />,
18.9%)
4
In
the
last
assessment
period,
performance
in this
area
showed little
improvement
and was rated Category
2.
Contributing to that rating was
the
noted
complacency
of operators
with respect
to overall station quality of
operations.
During the last assessment
the
NRC staff identified the
need
for corporate
and
station
management
to provide positive
incentives
to
revitalize, motivate
and better integrate
the Operations
staff with other
departments.
11
During this
assessment
period,
the unit remained
shut
down
and defueled,
thereby
prohibiting
assessment
of operators'erformance
for
at-power
operations.
However,
observations
of Operations
staff
support
of major
maintenance,
modification
and testing activities (including defueling
of
the vessel)
indicated technical
competence
and
a
good level of knowledge
of systems
operation
during the
plant
shut
down.
This
was particularly
evident
during
the
Safety
System
Functional
Inspection
conducted
in
September
1988 in the operators'upport
provided to the inspection
team.
Personnel
errors
by Unit
1 operators
were
infrequent
and
isolated
this
assessment
period.
Efforts by management
to better integrate
the Operations staff with other
departments
have
been
made during this assessment
period.
These efforts
included; initiation of the Operators
Training
Program Advisory Committee
.(OTPAC)
and
interface
meetings
between
the
Operations
and
the Training
departments;
assignment
of
oversight
responsibility
for
the
Licensed
Operator
Requalification
Training
Program
to the
Operations
Superinten-
dent; rotational
assignments
of Reactor
Operator s
(RO)
and Senior
Reactor
Operators
(SRO)
to
the Training
Department;
and
special
assignments
of
licensed
operators
to the
Maintenance
and
Engineering
staff,
as
needed
during
outages.
While several
of these
efforts
have
not
been
in place
long
enough
to provide
evaluative
results,
the
OTPAC
was
viewed
as
a
. positive step to resolve
longstanding
problems
and
has
been generally well
received
by the operators.
One area
requiring continued
management
attention
was the matter of oper-
ators'ttitude
towards
continued
training
as
demonstrated
by their
behavior
during training
sessions.
Specific
instances
of
abusive
and
disruptive behavior
by licensed
individuals during requalification train-
ing were noted by the
NRC,
as well as
NHPC management.
There continued
to
be
resistance
by
some
operators
towards
integration
with the training
department.
In addition,
station
management's
efforts to
improve
oper a-
tors'ttitude
and
performance
were ineffective.
This concern
was iden-
tified in the previous
and continues
to
be
a significant concern
to
the
NRC.
During this
assessment
period,
the
NRC identified that Unit
1 operators
were
not
attending
the
requalification
classes
as
required.
Senior
management
was
not
ensuring
that all requalification
requirements
were
completed prior to submitting
licensed
operator
renewal
applications.
A
review of the
Licensed
Operator Requalification Training Program revealed
that
39 licensed
operators
had not completed
the required training prior
to the
end of the
annual
requalification period.
In addition, deficien-
cies
were
noted
in
the facility senior
management
involvement
in
the
requalification program,
in that the operator
renewal
license applications
contained
inaccurate
" information
concerning
the
completion
of
the
12
requalification
program requirements.
These deficiencies
led to the issu-
ance of Confirmatory Action Letter
(CAL) 88-13
which identified actions
that were to
be taken to correct the deficiencies.
Subsequent
inspection
showed that the licensee
had completed
the
immediate
actions
necessary
to
comply with CAL 88-13.
During the inspection of the Unit 1 Emergency Operating
Procedures
(EOPs),
the
NRC observed
that
the
more
experienced
operators
were
not
able
to
adequately
use
the
EOPs.
The operations
crew observed
could not properly
implement the
and lacked
an understanding
of the basis for the
EOPs.
Specific
EOP training deficiencies
included:
a fundamental
understanding
of the
EOPs,
the understanding
of the accident mitigation strategies,
the
ability to implement
the
EOPs,
poor team work and communications,
and the
recognition of emergency
system status
and degraded
plant conditions.
The
inspection
determined
that the
were generally well written
and use-
able.
The lack of operator familiarity of the
was
due to inadequate
training
during
requalification
and
the
lack of operations
management
involvement in assuring
the training
was effective.
It was
subsequently
identified that licensed
operators
had
expressed
concerns
to station
man-
agement
about the quality and quantity of training
on the
new
EOPs.
How-
ever,
neither the operators
or station
management
pursued
these
concerns
to appropriate
resolution until it became
a regulatory concern.
In
summary,
the
Unit
1
Operations
concerns
raised
during
the
previous
assessment,
with respect
to opera'or
complacency
and the strained
rela-
ti5nship with the Training Department,
were not adequately
addressed
this
assessment
period
and continue to
be of major concern to the
NRC.
Opera-
tors'ttitude
have
not significantly
changed
and
station
management's
efforts
have
been
unsuccessful
in dealing with these
concerns.
However,
it is noted that
subsequent
to the
end of this assessment
period discip-
linary action
was
taken
against
certain
individuals
in the
Operations
Department indicating that certain patterns of behavior
would no longer be
tolerated.
Unit 2
(810 hours0.00938 days <br />0.225 hours <br />0.00134 weeks <br />3.08205e-4 months <br />,
10.4%)
This
area
was
rated
Category
2 (Improving) in the
previous
assessment.
During that asessment
period,
the licensee
had
progressed
through initial
criticality and
the majority of Test Condition
6 of the
Power Ascension
Testing Program.
Minor weaknesses
were noted in the control
room environ-
ment,
the control of operator
aids,
the lack of familiarity of operators
with emergency
equipment location, the lack of emergency
diesel
generator
operating
logs
and the lack of an efficient method of tracking the oper-
ating time on special filter trains for the
purpose
of meeting Technical
Specifications
sampling
requirements.
A
more
significant
weakness
was
'(
13
identified in the
area of operator attention to detail
as demonstrated
by
numerous
personnel
errors
and procedural
compliance violations.
Improve-
ment was
noted
in the
area of operations
management
oversight of day-to-
day activities,
communications
and
responsiveness
to identified concerns.
In addition,
Operations
Department
support
of the
Power
Ascension
Test
Program
was both enthusiastic
and professional.
Operator
conduct of test-
ing
was
cautious
and
response
to
testing
anomalies
was
prompt
and
conservative.
Personnel
errors
continued
to occur at
a high rate during this assessment
period.
The majority of these errors were caused
by inattention to detail
or failure to follow procedures.
An inadequate
plant
impact assessment
for the performance of a loop calibration
on
flow transmitter
resulted
in the 3/21/88
Improper operator
control of steam
loads
during start-up
resulted
in the 6/28/88 reactor
Improper
assess-
ment of the
impact of cycling of a service water alternate
cooling outlet
valve
on
a spent
fuel
pool cooling heat
exchanger
resulted
in
a
loss of
Reactor Building Closed
Loop Cooling water
and
on 9/22/88.
Several
personnel
error s were
made during the work release
process,
which
resulted
in inadvertent
Engineered
Safety Features
actuations,
a spill of
1000 gallons of acid,
and
a temporary
loss of shutdown
cooling.
Although
these
personnel
errors
relevant
to the work release
process
resulted
in
events
of relatively minor safety significance,
the potential
effects
of
these
types of er> ors could result in more serious
problems.
Other miscellaneous
personnel
errors
occurred
during this assessment
per-
iod.
For example,
during the
performance
of
a monthly surveillance test,
an operator
performed
a switch line-up incorrectly which resulted
in a
Low
Pressure
Coolant Injection to the reactor
vessel.
Another error occurred
while securing
from an
Emergency. Diesel Generator
(EDG) surveillance test.
An operator inadvertently
opened
the offsite
power
breaker
instead
of the
EDG output breaker.
This broad
spectrum of personnel
errors exemplifies the lack of attention
to detail
and failure to follow procedures.
As
noted
i.n
the
previous
assessment
period
and
as 'discussed
above,
numerous
personnel
errors
con-
tinue to
be
experienced
by the
licensee.
Corrective
actions,
to date,
have
not
been
effective
in reducing
the
number of errors.
This lack of
effective corrective
action
to
reverse
this
trend
indicates
inadequate
management
response
to
an identified concern
and inadequate
assessment
of
the
root
causes.
More significantly,
these
continuing
personnel
errors
represent
station
and
corporate
management's
low
expectations
and
acceptance
of the present
level of employee
performance.
14
Other observations
of control
room activities indicate that the operators
are
experienced,
knowledgeable
and alert
to
off-normal
indications
or
potential
problems.
An example of this
was the performance
of Automatic
Depressurization
System
(ADS) testing
during this assessment
period.
The
control
room operators
and
technicians
conducting
the test
identified
a
significant
system wiring error that effectively disabled
the Division I
ADS and which had gone undetected
since initial fuel load.
Control
room formality was
observed
to be satisfactory;
however, there is
a large
number
(approximately
50-60)
of lit annunciators
in the control
room that exist during
normal
plant operations
and
which
could
mask
a
potential
problem.
This also reflects
an environment that accepts
a
low
standard.
The licensee
does
have
a
program to reduce
the
number of nor-
mally lit annunciators,
but progress
to date
has
been
slow.
More emphasis
should
be
placed
on . this
item
by
station
and
Engineering
Department
management.
Evidence exists
to demonstrate
that Operations
management
has
become
more
involved
and aggressive
in improving the operations
staff training,
pro-
fessional
development,
and
working environment.
Examples
include:
min-
imization
of overtime;
successful
negotiation
for five additional
positions;
approval
of
an
inter-departmental
rotation
policy for
career
development;
increased
training for non-licensed
operators,
includ-
ing simulator training;
and the development
of an improved equipment mark-
upmnstruction
for the Operations
Department.
An
example
of the
Opera-
tions staff
being
proactive
involves
the
implementation
of
BMR
Owners'roup
recommendations
for actions
to take
when experiencing
power
osci 1-
lations
subsequent
to
a recirculation
pump trip.
Procedures
were revised
and operators
trained well in advance
of the
NRC Bulletin being
issued.
The
concern
identified
at
Unit
1
regarding
operators'nability
to
understand
and
adequately
use
the
Emergency
Operating
Procedures
(EOPs)
did not exist at Unit 2 when
the Unit 2 operators
were
subjected
to the
same
type of scenarios.
The major difference
was
determined
to
be that
the Unit 2 operators
were
accustomed
to the
as part of their initial
license
training
and
conduct
more
frequent
training
on
in
the
Requalification Training Program.
In
summary,
the Unit 2 Operations
Department
is staffed with experienced
and competent
personnel;
however, closer attention to detail
by operations
staff
and
licensed
operators
is
needed
to
stem
the
numerous
personnel
errors.
More importantly, station
and
corporate
management's
performance
expectations
were
too
low and
have resulted
in complacency
as exemplified
by
the
overall
poor
performance
trend
during
this
assessment
period.
15
2.
Performance
Ratin
Category:
Unit
1 - 3
Unit 2 - 3
3.
Board Recommendations:
NRC:
Licensee:
Restart
Panel
continue to monitor licensee
performance
and assist
in directing
NRC inspection efforts at
NMP.
Unit
1 -
(See
note below)
Unit 2 Raise
performance
expectations
of the Unit 2
Operations
Department
and
closely
monitor
progress.
Develop
and
implement
a detailed
and timely
plan
to
reduce
the
number of lit annuncia-
tors
on the main control panel.
Note:
. No specific
recommendations
have
been
made for this or any
. other
functional
area, if it is addressed
in the licensee
corrective
actions
documented
in the
Restart
Action
Plan
and Nuclear
Improvement
Program
which have
encompassed
the
major areas
of concern to the
NRC.
B.
Radiolo ical
and Chemistr
Controls
(513 hours0.00594 days <br />0.143 hours <br />8.482143e-4 weeks <br />1.951965e-4 months <br />,
6.6%)
1.
~Anal sis:
The combined
Radiological
Control
Programs
at Nine Mile Point Unit
1 and
Unit 2 were rated
as Category
2 (Declining) during the previous
assessment
period.
Program
weaknesses
identified last
period
indicated
a
need
to
improve supervisory oversight of ongoing work activities; personnel
atten-
tion to detail;
the corrective
action
program
to
ensure
personnel
are
adhering
to
good
radiological
control
practices
and
procedure
require-
ments;
contamination control; ongoing job ALARA reviews
and non-radiolog-
ical water chemistry.
During this
assessment
period,
region-based
inspectors
performed
seven
routine
inspections.
Radiological
controls
were
also
examined
during
a
Maintenance
Team Inspection.
The resident
inspectors
reviewed this area
on
an on-going basis.
16
Radiation Protection
The radiation
protection
program is
common
to both units
and is imple- .
mented
through
two
separate
radiation
protection
groups
reporting
to
a
common
manager
.
During this assessment
period,
the
licensee
implemented
several
personnel
and organizational
changes,
the
most significant being
the
replacement
of the Unit
1
Radiation
Protection
Supervisor
and
the
creation of a dedicated
Site
ALARA Coordinator.
NRC
observations
late this
assessment
period
indicated
that first line
supervisory
oversight
of ongoing
work activities
has
improved
with the
addition of several
new Chief Technicians.
However,
the licensee
failed
to identify, over
an
extended
period of time,
a situation
where
perman-
ently installed ladders
allowed unauthorized
access
to the Radwaste
Sample
Tank Room,
an
area controlled
as
a
Locked High Radiation
Area.
In addi-
tion, the Radiation
Protection
Manager
and the Supervisor of Radiological
Support
had infrequently entered
the Reactor
Buildings indicating
a
con-
tinuing need for additional
management
oversight.
An
adequately
defined
personnel
training
and qualifications
program
is
maintained
and implemented.
For contract
health
physics
technicians,
the
licensee
verifies
experience,
administers
a
screening
exam
to evaluate
technical
background
and
provides
additional
site
specific
training
as
necessary.
The
program
to
maintain
-radiation
protection
personnel
cujaizant of new procedures
and
procedure
changes,
a
weakness
identified
in the previous
assessment
period, is adequate.
The appropriate
personnel
wer e trained
on the requi red procedures
in
a timely manner
and
procedure
adherence
has
improved.
The licensee's
ALARA program
management
has
shown
improvement during the
current assessment
period.
The use of detailed
isometric
diagrams
of the
drywell
helped
reduce
exposures
associated
with locating individual
com-
ponents.
In addition,
improvements
were realized
by the
use of
a
mockup
at Unit
2 in planning corrective
maintenance
on
the recirculation
loop
isolation valve
In response
to
NRC
concerns,
the
site
ALARA program
responsibilities
were transferred
from the Respiratory Protection Coordi-
nator to
a dedicated
Site
ALARA Coordinator.
To strengthen
and
upgrade
the site
ALARA program,
a consultant is currently assessing
the program's
effectiveness
and
recommending
improvements.
Improvements
included
changes
to the Radiation
Exposure
Monitoring System
(REMS),
the addition
of
hold
points
on
jobs
not initially requiring
an
ALARA review,
and
methods
to
reduce
the
person-rem
exposures
associated
with miscellaneous
RWP's.
In addition,
to
improve
corporate
oversight
of
the
program,
a
Health Physicist
from the site
organization
was transferred
to the cor-
porate staff to coordinate
ALARA improvements.
17
Licensee
exposure for 1988 totaled approximately
804 person-rem for Unit
1
(outage year)
and
85 person-rem
for the startup year at Unit 2.
Although
above
the industry's
annual
BWR average
of approximately
500
person-rem,
the
extended
outage
at Unit
1
and significant ISI rework contributed to
the higher exposures.
Licensee
performance
during 1988 was adequate
given
the additional
work scope
and high inplant source
term and
showed improve-
ment during the
second half of the
SALP period.
Goals for 1989
have
been
set aggressively
at
509 person-rem
for Unit
1 and
128 person-rem for Unit
2 (its first full operating year).
Unit
1 continues to suffer from a high
inplant
source
term.
Chemical
decontamination
efforts originally planned
for 1988
have
been
delayed
and is currently
under
consideration
for the
1990
refueling
outage.
These
delays
are
contributing to the
continued
high person-rem
exposures
at Unit l.
Adequate
internal
exposure
controls
and contamination
controls
were pro-
vided for ongoing
work.
Licensee
corrective
actions
and
assurance
of
quality
were
generally
adequate
although
occasional
weaknesses
were
exhibited.
For example,
a review this period of corrective actions
asso-
ciated with a workers ingestion of a hot particle indicated
an aggressive
approach
to both the worker's concerns
and the technical
evaluation of the
existence
of a. discrete particle
and its characteristics.
In contrast,
the
licensee
incorporated
a
new type of respiratory protection
equipment into
the emergency kits without first establishing
and
implementing
the
neces-
sary procedures.
The
licensee
took actions
to
improve
intra-departmental
coordination of
work activities.
A Work Control Center
was established
at Unit
1 for the
processing
of all
work requests
and
a
dedicated
Health
Physics
Planner
provides
a single interface with the Radiation
Protection
(RP) department
in the
processing
of required
Radiation
Work Permits
and
pre-job
reviews.
In addition,
two
RP liaisons
were assigned
to the Unit
1 Mainten-
ance department
to coordinate on-the-job support of work activities.
These
licensee
initiatives
have
improved
the
coordination
of work activities
with the
RP group during the Unit
1 extended
outage.
Radioactive Effluent Controls
The program for Unit
1 was evaluated
in the
areas
of instrument calibra-
tion, release
permits,
the Off-Site Dose Calculation
Manual
and the
semi-
annual
effluent
reports,
and
found to
be effectively
implemented.
The
program for Unit 2 has
shown
improvement
from the last
assessment
period.
As identified in the
previous
SALP, operability of the
Gaseous
Effluent
Monitoring System
(GEMS)
has
been
a continuing
problem at Unit 2.
Fur-
ther, alternate
methods for gaseous
effluent monitoring when the
GEMS was
had
been lacking.
The licensee
has taken action to improve the
18
operability of the
GEMS and
has
developed
and
implemented
procedures
for
alternate
monitoring
methods
when
the
GEMS
is
During
the
assessment
period there
were
no unplanned effluent releases,
and
planned
releases
were at levels
normal for a Boiling Water Reactor site.
Radiolo ical Environmental Monitorin
Pro
ram
The
licensee
has
contracted
with
a
vendor
laboratory
to
perform
the
analysis
of environmental
samples
required for the Radiological
Environ-
mental Monitoring Program
(REMP).
The licensee's
environmental
dosimetry
program results
show
good
agreement
with both the State of
New York and
NRC environmental
dosimeters.
Audits in this
area
of both
the
vendor
laboratory
and
the
REMP were
found to
be thorough,
with all
recommenda-
tions addressed
in a timely manner.
~Trans ortation
The transportation
program is conducted
by a site Materials Shipping group
which has
shown significant improvement
since the hiring of a group super-
visor during the
second half of the
SALP period.
Filling of this position
has
led to additional
management
review of shipments
prior to leaving the
site,
which reduces
the
chances
of errors while shipping.
There
were
no
ma'jor problems
noted during this period.
The licensee
is in the
process
of implementing
the=use of a computer code for the purposes
of determining
traRsportation
and
waste
classification
which will further
enhance
this
program by reducing calcu2ational
errors.
Solid Radioactive
Waste
Each unit at the site continues
to maintain its
own
program for the pro-
cessing
and
packaging
of radwaste.
Although
these
two programs utilize
separate
vendors
and processes,
each
has continued to improve its program.
Continued
developments
by both units in the
area of waste solidification
will 'further
enhance
these
programs.
Audits
by
the
licensee's
quality
assurance
department
were thorough,
with all recommendations
addressed
in
a timely manner.
During this assessment
period
the licensee
could not account for several
small,
non-irradiated,
local
power
range
monitor fission
chambers.
The
licensee
identified that this
small
amount
of special
nuclear
material
was missing
as
a result of an annual audit,
and believes that the fission
chambers
were disposed
of with radioactive
waste.
The discovery
of the
missing
material
is
commended;
however,
the
loss
is reflective
of
a
previously ineffective special
nuclear material control program.
19
Overall
Summar
The
licensee
made
several
enhancements
to
address
previously identified
weaknesses
and
the overall
program
has
shown
steady
improvement
over the
SALP period.
Observations
indicate that
although
supervisory
oversight
of ongoing work has
improved,
management
oversight is weak.
In addi-
tion, significant licensee initiatives which began
late in the
assessment
period
are
expected
to
improve accountability
and oversight
of ongoing
work.
2.
Performance
Ratin
Category:
2
3.
Board Recommendations:
NRC:
None
Licensee:
Place
more emphasis
on Unit
1 decontamination
C.
Maintenance
and Surveillance
(2639 hours0.0305 days <br />0.733 hours <br />0.00436 weeks <br />0.001 months <br />,
34%)
l.'Anal sis
Dumng
the
previous
assessment
period,
the
maintenance
and surveillance
alas
were evaluated 'separately
and
each
area
was rated
Category
2.
For
this assessment
both functional areas
have
been
combined
and
one category
rating is assigned.
During this assessment
period
the licensee
transferred
the responsibility
for the Instrumentation
and Controls (IEC) organization
from the Technical
Superintendent
to
the
Maintenance
Superintendent
as
part
of
a station
reorganization.
The Unit
1
and
Unit
2
Maintenance
Superintendents
and
Unit Supervisors
presently
have
a
dual
reporting'esponsibility
to the
Site
Superintendent
of
Maintenance
and
the
Station
Superintendents
of
Units
1 and 2.
Maintenance
Unit
1 and
2
During the last
assessment,
improvement
in first line supervisory
over-
sight and higher visibility and interaction of senior
maintenance
manage-
ment
in the field were
noted.
Root
cause
evaluations
and attention
to
detail
in maintenance
implementation
were
noted
as
weaknesses,
but were
showing signs of improvement.
20
Improved
management
involvement in housekeeping,
selective observation of
work in progress
and interface
and
feedback
meetings with craft personnel
indicated
management's
contribution to
an overall effectively implemented
maintenance
program
this
assessment
period.
Maintenance
Department
management
benefits
from
experienced
and
knowledgeable
personnel
who
provide continuity by their long term involvement
and
low turnover rate.
Contractor
maintenance
work
was
effectively controlled;
however,
weak-
nesses
existed in the
type of checklist
used for the surveillance
of the
contractors.
A system for maintenance
trending
and performing root cause
analysis
has
been
established
with both
corporate
and
site
personnel
trained
in the analysis
techniques.
The Nuclear Engineering Organization
has
established
a central
program
to evaluate
the effectiveness
of the
maintenance
program.
In addition to
a
sound corrective
and preventive
maintenance
program
the
licensee
has initiated
the
increased
use
of predictive
and
diagnostic
techniques.
A rotating
equipment
vibration analysis
program
and
use of
infrared thermography
techniques
are
among
the
new techniques
being
used.
An additional initiative developed
is the functional work control program.
Work is
being
planned,
prioritized
and
scheduled
in
accordance
with
directives.
Backlog monitoring
has
been
established
through
the
use of
ma'intenance
performance
indicators
and the work tracking system.
De~ite
these
initiatives,
weaknesses
in procedural
adequacy
and compli-
anCe
were
observed
this assessment
period.
The written periodic mainten-
ance
program did not appear
to include all vendor recommendations
and
some
of the periodic
maintenance
activities
were
being
performed without the
benefit of written guidance.
A review of Unit
1 waste
surge tank
pump
and
diesel fire pump
and Unit 2 emergency
diesel
generator
maintenance
indi-
cates
procedures
were either
not being complied with or were poorly writ-
ten.
Some
maintenance
personnel
appeared
to
be insufficiently trained to
properly
implement
these
procedures
or
change
them if necessary.
The
maintenance
personnel
continuing training
program
was
also
found to
be
lacking
and
inconsistently
implemented.
Concerns
regarding
procedural
compliance
were brought to the licensee's
attention early in the assess-
ment period
and periodically thereafter.
However,
the
licensee
did not
take prompt and effective action to reverse this trend.
Another
weakness
that
continues
to exist is in the area
of followup and
correction of previously identified problems.
An example
was poor follow-
up
on the maintenance
self-assessment
performed
in 1987.
A licensee
audit
identified that
no
program or responsible
organization
was
made
account-
able
for
reviewing
maintenance
self-assessment
item
resolutions
and
recommending corrective actions.
21
In contrast
to the weaknesses
addressed
above,
the repair of the recircu-
lation loop isolation valve at Unit 2 was
an example of a well planned
and
executed
maintenance activity.
The licensee
utilized
a
mock-up to ensure
proficiency
during
the
actual
maintenance
and
to fine
tune
the
work
instructions.
No significant problems
were encountered
physically or pro-
cedurally.
During the last assessment,
problems in the area of repetitive
equipment failure due to
inadequate
root
cause
determination
were
docu-
mented,
In this
assessment
period,
no
problems
of this
nature
were
observed.
During this
assessment
period
several
deficiencies
were noted with house-
keeping,
in particular with the material
condition of the
HPCI/FW, shut-
down cooling and core spray
systems at Unit 1.
In addition,
the
237 foot
elevation of Unit I reactor building including the entrance
to the drywell
and
the
CRD hydraulic
control
units
area
were
in
poor
condition
and
inhibited routine tours by plant personnel.
Typically the remote
areas
of
the plants
and the high work areas
have
been of concern;
however,
overall
improvements
in housekeeping
were
observed
during this assessment
period.
For
example,
the
condenser
bay
and
refueling
floor
areas
were
much
improved.
Increased
management
and
station
employee
attention
to this
area
was evident.
Su'rveillance - Unit I
Dumng
the
previous
assessment
period,
the
Technical
Specification
sur-
"vetllance testing
program
was
determined
to
have
been effectively imple-
mented
with only minor
problems
identified.
However,
numerous
problems
identified in the Inservice Inspection
( ISI) Program demonstrated
the
need
to strengthen
corporate
and station
management
oversight of the
program.
During this
assessment
period,
missed
surveillance tests
and surveillance
related
problems
remained at
a low level.
Licensee corrective actions for
the
known ISI problems
resulted
in the identification of more ISI Program
deficiencies.
Additionally, 'problems
were identified by the
licensee
in
the
Inservice
Testing
(IST) Program this assessment
period.
Problems
in
the ISI and
IST Programs
are attributed to past
management
ineffectiveness
in the oversight of these
programs.
Followup
NRC inspections
early in the
assessment
period identified addi-
tional
weaknesses
in
the
area
of
licensee
overview of contractor
activities
involving thickness
measurements
of piping
systems
and
the
torus
shell.
Additionally,
the
licensee's
own Quality
Assurance
(QA)
Department
issued
a Stop Work Order
on contractor's
ISI activities because
of the
poor quality of examination
documentation
and result
evaluation.
This action,
although
indicative
of
good
QA oversight,
indicates
weak
oversight
by the
Engineering staff
who were responsible
for revising
and
implementing the ISI Program
and associated
corrective actions.
22
Throughout the assessment
period,
licensee
management
devoted considerable
resources
to resolve
the
issues
related
to ISI
on Unit
1.
NRC reviews
near
the
end of the
assessment
period
determined
that
the licensee
had
established
satisfactory
control
systems
and
a
new organization
staffed
with appropriately qualified individuals to effectively implement the
new
ISI Program.
The
Unit I Safety
System
Functional
Inspection
(SSFI)
team
found
some
examples
where
the
surveillance
testing
data
collection,
results
review
and acceptance
criteria
would not adequately
support
system
operability
decisions.
This weakness
appeared
to be
a direct result of poorly defined
system
design
requirements.
A
subsequent
team
inspection
identified
examples
of poor procedural
compliance
and adequacy.
Frequently performed
surveillance
tests
were not followed step-by-step
and
in
some
instances
the
attached
checklists
were
used
without
reference
to
the
written
procedure.
Surveillance - Unit 2
During
the
previous
assessment
period,
several
surveillance
tests
were
missed
because
of inattention to detail
and insufficient supervisory over-
sight.
In'ddition,
numerous
unanticipated
events
occurred
during
the
performance
of
surveillance
testing.
These
events
were
generally
the
result of test procedure
inadequacies
or personnel
errors.
The implemen-
taVon of the Surveillance
Testing
Program
was found to be adequate
during
tlTh initial phase
of power operations;
however,
closer
management
atten-
tion was needed.
During this assessment
period,
the licensee'
failure to perform required
surveillance
tests
was
again
a
concern.
Examples
of
missed
tests
in-
cluded:
failure to record
surveillance
data
during reactor
cooldown sub-
sequent
to
a reactor
due
to operator
error; failure to perform
a
surveillance
test
on
a
due to personnel
error;
missed
surveillance
tests
due
to
an
inadequate
list of
and
missed
Average
Power
Range Monitor surveillance
due to pro-
gr'ammatic deficiencies.
As in the previous
assessment
period,
this
high
number of missed
surveillance
tests
indicates
inattention
to detail
and
insufficient supervisory
oversight.
The
missed
surveillance
tests
were
spread
between
the
different
station
departments
and
the
Engineering
staff.
The unit again
experienced
many unanticipated
events
during the perform-
ance
of surveillance
testing
during this
assessment
period.
The pre-
ponderance
of
these
events
was
caused
by
procedural
inadequacies
or
personnel
error.
23
Examples
of events
caused
by procedural
problems
include
an inadvertent
actuation
of the
standby
liquid control
system
(SLS)
discharge
valves
during
SLS surveillance
testing
and
a temporary
loss of shutdown
cooling
during
leak
detection
surveillance
testings
These
test
procedure
inadequacies
were not considered
to be
a significant problem, but indicate
technical
procedural
development
could be improved.
Examples of events
caused
by personnel
errors include
a high pressure
core
spray
(HPCS)
system initiation during
surveillance
testing
when
an
IKC
technician failed to follow the procedure
by measuring
resistance
across
an
open contact
vice measuring
voltage
as specified in the procedure,
and
a reactor
scram which resulted
from an
inadequate
plant
impact
assessment
before
performing loop calibrations
on feedwater
flow transmitters.
These
procedural
problems
and personnel
errors collectively indicate poor station
management
oversight,
especially
since
the
same
concerns
were identified
during the last assessment
period.
Corrective actions
to address
these
concerns
include the development of a
more
formalized
tracking
system,
the
implementation
of
an
Engineering
Department
control
program
for Technical
Specification
equipment surveil-
lance lists,
and
(subsequent
to
the
end of the
assessment
period)
the
clarification of,
and training
on,
the
procedural
compliance policy and
re'quirements
documented
in Station General
Order 89-03.
NRC-review of the Unit 2 ISI Program iden;ified that, staffing was adequate
and
personne'1
were
experienced
and
knowledgeable.
Examination
data
were
well documented,
licensee
reviews
were
thorough
and professionally
done.
The disposition
of results
was technically justified and
the closeout
of
findings
was
based
on
sound
engineering
analysis.
Implementation
of the
Unit 2 ISI Program
was considered
good.
The
Power
Ascension
Testing
Program
(PATP)
was
completed
during
the
assessment
period.
The results
indicated that
the testing
occurred with-
out major .exceptions
and
was consistent with the good quality of the
PATP
as discussed
in the previous
assessment.
The minor exceptions
were
ade-
quately
analyzed
and
resolved.
The
program
was
closed
with
no
major
technical
problems.
Fire Protection
Units I and
2
During
the
previous
assessment
period
frequent
and
recurring
personnel
errors
were
noted
in the
implementation
of the
station
Fire Protection
Program
with
an
improving
trend
at
the
conclusion
of
the
assessment
period.
This trend did not continue
throughout this assessment
period as
similar personnel
errors
occurred.
In addition,
the
licensee
identified
a
significant
breakdown
in their
Technical
Specification
24
surveillance
program
which led to the discovery of a multi-
tude
of improperly
designed
and/or
installed fire barrier
seals
at Unit 1.
Further, this Unit
surveillance
problem,
was
identified
to
the
licensee
in
1985
as
the result of
a contractor
audit;
however,
comprehensive
corrective
action
was not taken until this
assessment
period.
Although personnel
errors
have persisted
and
management
followup of pre-
viously identified concerns
was
inadequate,
the
licensee's
Fire Protec-
tion/Prevention
Program for both units
was
observed
to
be generally
ade-
quate.
The deficiencies
identified during this assessment
period
by the
licensee
and
NRC
inspectors,
and
inspector's
review of the
licensee's
corrective
actions
indicated that the
Fire Protection/Prevention
Program
requires
improved overall day-to-day coordination
and management
guidance.
Overall
Summar
The licensee
has
implemented
an effective maintenance
program.
The mate-
rial condition of the plant,
the
experience
and
knowledge of onsite
per-
sonnel,
the controls
for
+he performance
of maintenance,
the interaction
between
Maintenance
and Operations staffs,
and
the documentation
of main-
tenance activities
were considered
adequate.
However,
corporate
and sta-
tion
management
attention
is required
to
address
improved
oversight
of
performance,
effectiveness
and timeliness
of corrective actions,
and ade-
quicy and compliance with maintenance
procedures.
The surveillance
program at Unit
1 is adequate.
The ISI program which was
considered
poor at the beginning of the
assessment
period
shows signifi-
cant
improvement,
thus
demonstrating
that
the
licensee's
management
is
capable of ensuring correction of identified problems
once their attention
is focused
on it.
This
same
focus
by management
needs
to
be
applied
to
ensure
the
IST program is properly implemented
and that surveillance pro-
cedures
are adequate
and adhered to by station
employees.
Implementation of the Unit 2 surveillance testing experienced
various pro-
cedural
and personnel
deficiencies during this assessment
period.
Follow-
up of technical
testing
problems
has
generally
been
good.
The
licensee
has
implemented
more stringent control
in the surveillance
testing
area,
effectiveness
of which
has
not
been fully determined.
In
summary,
per-
formance in the surveillance
area
was minimally acceptable.
Overall,
performance
in the fire protection
area
has declined
over this
assessement
period.
25
2.
Performance
Ratin
Category:
3
3.
Board Recommendations:
NRC:
None
Licensee:
None
D.
Emer
enc
Pre aredness
(224 hours0.00259 days <br />0.0622 hours <br />3.703704e-4 weeks <br />8.5232e-5 months <br />,
2.9%)
'1.
A~nal sis
During the previous
assessment
period,
licensee
performance
in this area
was rated
Category
1.
This assessment
was
based
upon
good exercise
per-
formance
and the licensee's
own initiatives in routine emergency
prepared-
ness activities.
During the current
assessment
period,
one partial-participation
emergency
exercise
was
observed,
a routine safety
inspection
was
conducted,
and
a
special
Emergt.ncy
. Response
Facility
(ERF)
Appraisal
was
conducted
to
verify licensee
implementation of NUREG-0737,
Supplement
1 orders.
In-"%he partial-participation
exercise
held
on August 2,
1988,
the primary
.
objective of the scenario
was to test the interface
between
the licensee's
Emergency
Plan
and
Security
Contingency
Plan.
The licensee's
execution
and participation
demonstrated
thorough
response
and
a strong
commitment
to emergency
preparedness.
The
NRC team found that personnel
demonstrated
complete
knowledge
of procedures
under
emergency
conditions,
interfaced
well with the security force,
and
implemented
the
emergency
plan effic-
iently.
Analysis and classification of events
were timely and
command
and
control
exhibited
by
managers
of each
emergency
response
facility were
effective.
No significant deficiencies
were
identified
and
only minor
facility and
performance
weaknesses
were
noted.
The
licensee
concurred
with
the
NRC-identified
findings
and
initiated
appropriate
corrective
action.
In
conjunction
with
the
annual
exercise,
the
ERF Appraisal
was
also
performed.
Results of the appraisal
identified certain
programmatic
areas
which were either
incomplete
or in need of increased
licensee
attention.
Of primary concern
was the licensee's
dose
assessment
model.
The
NRC team
found that
improvements
were
needed
in all aspects
of the
dose
assessment
program
including
undefined
isotopic
distributions
and
release
rates
associated
with all Unit 2
FSAR accidents
and post-accident
sample results
not
properly
incorporated
into
dose
calculations.
Other
identified
26
deficiencies
were found in the storage
capacity of the Unit I Plant
Computer
System to report pre-event
and post-event
plant data,
and
Emer
gency Operations Facility habitability.
In response
to
NRC initiative
the licensee
addressed
all appraisal
findings and committed to resol
ng
each
item to the next scheduled refueling outage.
Following the
appraisal,
on September
25,
1988,
a separate
concern
was identifi
with
Technical
Support Center habitability when dampers within the
TS
ventilation system failed.
This problem was not corrected
unt
the
end
of the period.
'
During the routine safety inspection
conducted
in February
1989, all
major areas
of the licensee's
emergency
preparedness
pro
am including
program changes,
emergency
equipment,
organization
and
anagement
control,
training,
program audits
and follow-up of open items
re reviewed.
No
significant deficiencies
were found regarding
the
r grammatic
changes
or
walkthroughs (training) of key emergency
respon
p
sonnel with the
excepti on of licensed
operator
knowledge of th
ope
tion and capability
of the
Tone Alert System.
Minor concerns
wer
d tified with the
licensee's
recent revisions to and distribu
the
Emergency
Plans
and
Implementing Procedures,
personnel
used t
gn
ct independent
program
reviews,
and information provided in gen
al
ployee training.
Coordination of onsite
and offsite
em
preparedness
activities are
administered
by the
Emergency
Coordi
from the site.
The training
department
is responsible
for inst
of most emergency
response
personnel
and scenario
develoment
reparation
is provided through
~coatract
support.
During. the r
nt
eorganization
of the Nuclear
Services Division, two additio
1-time equivalent staff members
were authorized for the
emer
r eparedness
program.
In addition,
the
Emergency
Coordinator
p
n has
been
upgraded to
a manager
level
with direct access
to the
r, Nuclear Services.
Such changes
are
an
indication of strong
pro
upport from upper-level
corporate staff.
Each calendar quarter
icensee
coordinates
with the State of New York
and other power rea
censees
within the State
concerning offsite
emergency
prepare
s
ssues.
The
EP staff also maintains
membership
on the
Oswego
Co
arming Committee
and is currently assisting
the
State
and local
a
rities in the development of procedures
for meteoro-
logical forecas
ng.
During an accident, this process
would ensure that
inputs into th
dose
assessment
model
are identical at each jurisdictional
level.
Promp
notification ( siren)
system capability was degraded
on
several
occ
ions during the period and the licensee notified
NRC
immediatel
after identification of these
problems.
26 A
deficiencies
were
found
in
the
storage
capacity
of the
Unit I Plant
Computer
System to report pre-event
and post-event
plant data,
and
Emer-
gency
Operations
Facility habitability.
In
response
to
NRC initiatives
the
licensee
addressed
all appraisal
findings
and committed to resolving
each
item
to
the
next
scheduled
refueling
outage.
Following
the
appraisal,
on
September
25,
1988,
a separate
concern
was identified with
Technical
Support Center habitability when dampers within the
TSC ventila-
tion system failed.
This problem
was not corrected
until the
end of the
period.
During the routine safety inspection
conducted
in February
1989, all major
areas
of the licensee's
emergency
preparedness
program including program
changes,
emergency
equipment,
organization
and
management
control, train-
ing,
program audits
and follow-up of open
items were reviewed.
No signif-
icant deficiencies
were found regarding
the
programmatic
changes
or walk-
throughs (training) of key emergenc>
response
personnel
with the exception
of licensed operator
knowledge of the operation
and capability of the Tone
Alert System.
Minor concerns
were identified with the licensee's
recent
revisions
to
and distribution
of
the
Emergency
Plans
and
Implementing
Procedures,
personnel
used
to
conduct
independent
program
reviews,
and
information provided in general
employee training.
Co'ordination
of onsite
and offsite emergency
preparedness
activities are
administered
by
the
Emergency
Coordinator
from the site.
The training
department is responsible
for instruction of most
emergency
response
per-
soltnel
and
scenario
develoment
and
preparation
is provided through
con-
tract support.
During the recent
reorganization
of the
Nuclear
Services
Division,
two additional full-time equivalent staff
members
were author-
ized for the
emergency
preparedness
program.
In addition,
the
Emergency
Coordinator
position
has
been
upgraded
to
a
manager 'level with direct
access
to the
Manager,
Nuclear Services.
Such
changes
are
an
indication
of strong
program support
from upper-level
corporate staff.
Each calendar
quarter
the licensee
coordinates
with the State of New York
and other
power
reactor
licensees
within the
State
concerning
offsite
emergency
preparedness
issues.
The
EP staff also maintains
membership
on
the Oswego
County Planning
Committee
and is currently assisting
the State
and
local
authorities
to
assure
meteorological
forecasting
methods
are
consistently applied
and understood for accurate
input to the dose assess-
ment
models.
During
an
accident,
this
process
would ensure
that inputs
into the dose
assessment
model
are identical at each jurisdictional level.
Prompt
notification
( siren)
system
capability
was
degraded
on
several
occasions
during
the
period
and
the
licensee
notified
NRC
immediately
after identification of these
problems.
27
In
summary,
the licensee
has
demonstrated
a positive continued
commitment
to emergency
preparedness.
The relationship
between
the licensee
and off-
site authorities continues to be strong.
Training of all levels of emerg-
ency
response
personnel
was effective
as
evidenced
by exercise
perform-
ance.
Although
items identified during
the
ERF Appraisal
remain
incom-
plete,
responsiveness
to
NRC initiatives has
been timely and
the licensee
has
made progress
in correcting most
NRC concerns.
Management
involvement
is of the level
necessary
to ensure
that the
emergency
preparedness
pro-
gram can
be efficiently implemented.
2.
Performance
Ratin
Category:
1
3.
Board Recommendation:
NRC:
None
Licensee:
None
E.
Securit
and Safe
uards
(137 hours0.00159 days <br />0.0381 hours <br />2.265212e-4 weeks <br />5.21285e-5 months <br />,
1.8:.')
l.'Anal sls:
Du~ng
the
previous
assessment
period,
the
licensee's
performance
was
raYed
as
Category
1.
No regulatory
issues
were
identified
by
either
region-based
or resident
inspectors.
During
the
assessment
period
the
licensee
continued
to
demonstrate
a
thorough understanding
of NRC security objectives
and maintained
an excel-
lent enforcement history.
One
unannounced
routine security inspection
was
performed
by region-based
inspectors.
Routine inspections
by the resident
inspectors
continued throughout the period.
Corporate
management
involvement
and
interest
in
the
security
program
remained
evident during this
assessment
period
by
the
continued
on-site
presence
of the
Security
Manager
who reports directly to the
corporate
Executive Vice President for Nuclear
Generation.
The Security
Manager
and his supervisory staff are well-trained and qual-
ified security professionals
who are
vested with the
necessary
authority
and discretion
to ensure
that the station's
nuclear
security
program is
carried out effectively and in compliance with NRC regulations.
Security management
also continues
to actively participate
in the Region I
Nuclear Security Association
and in other
groups
engaged
in nuclear plant
security matters.
28
The licensee
continued to enhance
the security program during this assess-
ment period.
All search
equipment
in both
access
control portals
was
up'-
graded,
vehicle barriers
and double
fences
are
being erected
at the pro-
tected
area
boundary,
the Unit
1 intrusion detection
system
was
upgraded
and plans
have
been
developed
to upgrade
the Unit 2 instrusion detection
system.
Security
systems
and equipment
are tested
and maintained
by dedi-
cated
instrumentation
and controls
( I&C) and maintenance
groups
(a total
of 22 personnel)
~
These
are indications of the licensee's
commitment
to
maintain
a quality and highly effective program.
To
ensure
a
comprehensive
annual
audit of the
security
program,
the
licensee's
Safety
Review
and Audit Board
used
the
services
of nuclear
security consultants.
The licensee
continued to implement the Commitment
to
Excellence
Program
in security.
The
program
centered
around
three
areas:
1) performance testing of security force members;
2) conducting
an
in-house
regulatory
effectiveness
style
review;
and
3) daily
audits/
surveillances
of security
posts
including at least twenty-percent
inspec-
tions
on
backshifts.
These
are
further
indications
of the
licensee's
commitment to the program.
A review of the licensee's
security event reports
and reporting procedures
found
them to
be consistent
with
NRC regulations
There
were
two security
event
reports
submitted
during
the
assessment
period.
One event
involved the loss of offsite local
law enforcement
communica-
ticms capabilities
and
the other,
the discovery
of drugs
on-site.
The
licensee
took prompt and effective compensatory
and/or corrective
measures
for each event.
Staffing of the proprietory
security
force
continues
to
be
adequate
as
evidenced
by
a limited use of overtime.
The security force training
and
qualifications
program is well-developed
and is administered
by an experi-
enced
staff of five, full-time individuals
(including
the
supervisor).
Facilities for training
and requalification
are available
on site or on
adjacent,
owner-controlled
property.
These facilities are
well-equipped
and
maintained.
Security
contingency
response
drills are
conducted
at
least
once
each
month.
These drills are effectively
used
for training
purposes
and the drill critiques
are
integrated
into the
formal training
program.
The
licensee
instituted
a
procedure
during
this
assessment
period to ensure
the participation of the operations
organization
during
contingency drills if the scenario
could affect plant operation..
During the
assessment
period,
the
licensee
submitted
one revision to the
Physical
Security
Plan
under
the
provisions
of
This
revision
was
of
high quality,
technically
sound,
and
reflected
well-
developed
policies
and
procedures.
Security
personnel
involved in main-
taining the
program
plans
are very knowledgeable
of
NRC requirements
and
objectives.
29
In summary,
the
licensee
continues
to maintain
a very effective
and per-
formance-oriented
security
program.
Significant
enhancements
to
the
program
continued
during this
assessment
period
which is indicative of
management
attention
to
and
support
for the
program.
The efforts
to
upgrade
the operation
and reliability of systems
and equipment during this
period
are
commendable
and
demonstrate
the
licensee's
commitment
to
maintain
an effective and high quality program.
2.
Performance
Ratin
Category:
I
3.
Board Recommendations:
NRC:
None
Licensee:
None
F.
En ineerin
and Technical
Su
ort (523 hours0.00605 days <br />0.145 hours <br />8.647487e-4 weeks <br />1.990015e-4 months <br />,
6.7%)
l.
~Anal sis
Du'ring
the
previous
assessment
period,
the
licensee's
performance
was
rated Category
2 in this functional area.
Problems
were identified in the
foRowing areas:
insufficient station-to-engineering
department
interface;
in0dequate
involvement of engineering
in the
resolution
of ISI
program
concerns;
and,
inadequate
control over contractors.
In
order
to
improve
station-to-engineering
department
interfaces,
the
Engineering
Department
now includes
a
permanent
site
engineering
group
that
reports directly to
the
Vice President
of Nuclear
Engineering
and
Licensing.
This group was established
during the middle of the
SALP cycle
and is
responsible
for coordinating
and
implementing
engineering
modifi-
cations
and expediting corporate
engineering
support for plant operations.
Greater
engineering
staff participation
in routine
station
meetings
was
evident
and
appears
to
have
a
positive
impact
on
the
assignment
and
accountability for Engineering
Department action items.
One
area of particular
concern
during this
SALP period
was the reverifi-
cation of the first 10 years of the Inservice Inspection (ISI) Program for
Unit 1.
Early in the
SALP period
numerous deficiencies
were identified in
the
program involving many required
inspections
which
had
not
been
per-
formed because
of improper development
and implementation of the ISI Pro-
gram by
a contractor
and insufficient licensee
oversight of that contrac-
tor.
However,
an
NRC team inspection
conducted
near
the
end of the
period concluded that the licensee
has effectively corrected
deficiencies
previously identified in the ISI Program.
As
a result of increased
man-
agement attention to these deficiencies,
the program is presently
defined,
structured
and
adequately
staffed
with qualified individuals
to effec-
tively implement the
new program.
30
Problems
previously identified regarding
the
adequacy
of the licensee's
control
over
contractors
were
also
noted
during this period.
Specific
problems
noted during this period included:
weaknesses
in the
licensee's
review
of
contractor
procedures
and
inspection
results;
deficiencies
regarding
contractor dedication
of commercial
grade
items for Unit 2
and
oversight of Unit
1 ISI program contractors.
These deficiencies
indicate
poor
engineering
management
oversight
to
assure
adequate
control
of
contractors.
To
enhance
plant
safety
and
provide
better
direct
plant
support,
the
licensee
has established
a priority system
whereby all safety significant
projects
are Priority
1
and other work which affects
safety
systems
are
Priority 2.
All Priority
1 and
2 projects are
on schedule.
Additionally,
the Vice President,
Engineering
and Licensing holds
a weekly staff meeting
to discuss
the status
of each project.
This
system is effective
as evi-
denced
by all priority safety significant projects
being
on
schedule
and
the observation
that there
was
no appreciable
backlog of projects
during
the Unit 2 and ongoing Unit
1 outages.
The
licensee's
Engineering
and
Technical
Support
staff
were
generally
effective
in resolving
engineering
concerns
at
both units
with
notable
improvement
in
design
change
activities.
However,
during this period,
performance
by the Engineering staff was inconsistent
and is
a matter of
concern
to the
NRC
and merits attention
by management.
While a number of
activities
and
specific
projects
for which
the
engineering
staff
had
control
over were
conducted
in
a professional
manner,
weaknesses
in other
areas
were detrimental
to the overall
assessment
of the engineering
sup-
port function.
Examples of both are discussed
below.
The licensee
has
developed
a detailed
commercial
grade dedication
program
to upgrade
equipment to safety-related
status.
This program
was developed
based
upon discovery
by the licensee of weaknesses
in the General Electric
commercial
grade
items
process
and
the
necessity
to
resolve
potential
electrical
equipment
safety
concerns
prior to Unit
2 initial
licensing,
The
licensee's
program
employs
the
EPRI guidelines
and
the
documented
engineering
evaluations
were
determined
to
be
thorough
and
technically sound.
Several
design
and
replacement
activities
were
performed
well including
the replacement
of the Unit
the Unit 1 Antici-
Alternate
Rod Injection modification,
and
the
upgrade
of
the
Unit
1
Mark I
containment
to
meet
the
acceptance
criteria of
The
licensee
addressed
all of the
significant
31
technical
aspects
of the Bulletin 85-03,
"Motor Operated
Valve
Common
Node
Failures During Plant Transients
Due to Improper Switch Settings" at both
.
units.
The
necessary
corrective
actions
were
properly coordinated
with
the maintenance
and operation staffs.
However,
poor
performance
in other
areas
indicates
an inability of the
engineering
department
to consistently deliver quality work.
Examples of
these
inconsistencies
include: the
numerous deficiencies identified in the
implementation
of Regulatory
Guide
1.97 for Unit 1; the failure to report
the
125 Vdc design deficiencies
in a timely manner for Unit 1; the failure
to detect
and
resolve
an
automatic
depressurization
system
(ADS) wiring
error which rendered
one division of ADS inoperable for Unit 2; inadequate
corrective actions to identify all improperly sealed
and con-
duits for internal
flooding for Unit 2;
and
the inadequate
resolution of
post-accident
sampling
system divisional
power supply problems at Unit 2.
Slow resolution of design deficiencies
at Unit 2
have
resulted
in plant
and
unnecessary
safety
system
actuations.
Examples
included
the reactor building ventilation problems,
reactor
vessel
instrumentation
common
reference
leg sensitivity concern
and
the
control
valve
problems.
A 'Safety
System
Functional
Inspection
(SSFI)
performed
by
an
NRC
team at
Unit
1 concluded that design
information for both the core spray
and HPCI/
FW~ys:ems
was
not
adequately
controlled
or
supported
by sufficiently
detailed
analysis.
This
lack of defined
design
analysis
for the
core
spray
and
HPCI/FW
systems
degraded
the quality of
system
operating
and
surveillance
procedure
guidance.
A specific
concern
was
the Appendix
K
reload analysis.
Inadequate
analyses
led to operation
of the plant out-
side
of
the
design
basis
on
two
separate
occasions'hese
potential
problems
were
known by the licensee
in early
1987,
but were not resolved
until brought to the
licensee's
attention
by the
NRC.
This
was another
example of inadequate
licensee
followup to identified deficiencies.
The licensee
has developed
a comprehensive
training program for individuals
at all levels
in the
Engineering
organization.
The
permanent
training
staff is supplemented
by individuals
from various disciplines
assigned
as
instructors.
If required,
consultants
are
retained for specific courses.
At the end of the
SALP period,
the
NRC identified significant deficiencies
in the implementation
of the licensee's
engineering
training
program.
A
review of the training records
and
licensee
gA audits
revealed
that most
of the
engineers
were
not receiving
adequate
training
according
to the
projects training program.
While the licensee
has
developed
a comprehen-
sive training program,
the
program
has
not
been
effectively
implemented.
32
In
summary,
the
licensee
has
made
limited
progress
in
addressing
engineering
and
technical
support
deficiencies
that
were
identified
during the last
SALP period.
While
some engineering activities exhibited
strong
engineering
control,
numerous
examples
of
poor
performance
of
engineering
activities
were
identified.
These
examples,
collectively,
indicate
poor
control
and
coordination
of
engineering
efforts
and
inadequate
management
oversight
of
the
engineering
function
to
assure
consistency
of
performance
of the
on
and off site
engineering
staff.
Performance
in, this
area
contributed
to
the
issuance
of Confirmatory
Action Letter 88-17
and
continues
to
be
of
concern
to
the
NRC staff.
2.
Performance
Ratin
Category:
3
3.
Board Recommendations:
NRC:
None
Licensee:
None
G.
Sa et
Assessment/
ualit
Verification (1446 hours0.0167 days <br />0.402 hours <br />0.00239 weeks <br />5.50203e-4 months <br />,
18.7%)
l.
A~aal sis
This
new
functional
area
assesses
the
effectiveness
of the
licensee's
programs
provided to assure
the safety
and quality of plant operations
and
activities.
It is a compilation of the Licensing
and Assurance
of guality
functional
areas
provided
in the previous
SALP reports,
but also
incor-
porates
relevant
indications
discussed
in all other current
functional
areas.
During the previous
SALP period,
the licensee
was evaluated
as Category
3
in the area of Assurance
of guality and Category 2, declining, in the area
of Licensing.
Performance
in the Assurance
of guality area
was
noted to
be
inconsistent.
Improvements
occurred
in
problem
identification
and
resolution,
effectiveness
of the guality Assurance
organization,
Unit
2
operations,
staff
performance,
and
Technical
Specification
interpreta-
tions.
Weaknesses
were identified
in station
and
corporate
management
oversight
and coordination,
radiological controls,
teamwork
and
communi-
cation,
and
housekeeping.
In the
licensing
area it was
noted
that
the
technical
approach
to,
and resolution for issues
were generally
sound
and
conservative;
however,
on occasions,
the licensee
demonstrated
a lack of
understanding
of regulatory
requirements
and
a
reluctance
to
make inde-
pendent
conservative
decisions
on
issues
involving regulatory
compliance.
33
During this assessment
period the licensee's
performance
in correcting the
SALP identified weaknesses,
in responding to plant events,
and in conduc-
ting other activities
and functions impacting quality and safety assurance
has
been
inconsistent.
However,
at
the
end of the
rating
period,
the
licensee
took significant action to demonstrate
senior
management's
com-
mitment to identify
and
resolve
long-standing
problems
in
the
Nuclear
Division.
In response
to
CAL 88-17,
a
number of assessment
programs
and
corrective
actions
were initiated including the
Restart
Task
Force,
the
Restart
Action
Plan
(RAP),
and
the
Nuclear
Improvement
Program
(NIP).
Particularly noteworthy is that the licensee
established
a
new position of
Executive
Vice President
Nuclear Operations.
The hiring of a senior indi-
vidual
from outside
the
organization
broke
a
long-standing
tradition of
promoting
from within and demonstrated
that senior
management
is serious
about
breaking
down
the
organizational
"culture"
and
correcting
the
leadership
deficiencies
that
have contributed
to
many of the
problems at
Nine Mile Point.
The licensee
has
made
several
additional
organizational
changes
in
an attempt
to strengthen
the organization
including the estab-
lishment of a Regulatory
Compliance
Group.
This group provides
a continu-
ity to the organization
which was
not previously observed.
It has facil-
itated
improvements
in:
1) tracking
and timely resolution
of identified
problems,
concerns
and
commitments;
2) interdepartmental
communications;
3) defined responsibilities
and
accountabi lities;
and
4) consistency
in
operations
and administration
between Units
1 and 2.
The- licensee
has
also
requested
independent
organizations
to assist
them
in evaluating
the
effectiveness
of
the
Nuclear
Organization
and
has
scheduled
a self-evaluation
before restarting Unit 1.
These efforts indi-
cate
that
Niagara
Mohawk is
making
a
concerted
effort to correct
the
leadership
weaknesses
identified in the previous
SALP.
The effectiveness
of the above
changes
is still being evaluated.
Throughout
the
period
the licensee
has
demonstrated
increased
effective-
ness
in problem identification,
both programmatic
and technical.
However,
corrective
actions
in general
have
not
been
properly
implemented
to pre-
vent recurrence.
This is evident for both units and is attributed to the
inability to clearly identify the applicable
root cause
and
the
lack of
defined responsibility
and accountability within the organization.
In contrast,
the licensee's
recent corrective actions with respect
to the
Unit
1 Inservice Inspection
Program deficiencies
represent
a true commit-
ment
to develop
and
maintain
an effective
Inservice
Inspection
Program.
Significant
technical
manpower
resources
have
been
dedicated
to this
effort, increased
management
attention
and control
have
been
observed
and
there is evidence of a heightened sensitivity
by all station
employees
of
the proper implementation of the program.
The licensee's
actions concern-
ing the identification of the
ADS logic circuitry deficiencies,
and ser-
vice water system single failure corrective actions
were also
commendable.
34
The
licensee's
approach
to
the
resolution
of technical
issues
from
a
safety
standpoint
has
not
always
been
timely
and
conservative.
For
example,
the
licensee
has
not
been
effective at
reducing
the
number of
Engineered
Safety
Feature
(ESF) actuations,
and
personnel 'errors
experienced
at
Unit
2 following the
completion
of the
Power
Ascension
Testing
Program
early
in
the
rating
period.
This
problem
appears
to
result
from the licensee's
(inappropriate)
willingness to accept
the high
number of events
as
being
normal
and
acceptable
for
a
newly
licensed
facility.
In addition,
the
licensee
has
not
always
been
aggressive
in
pursuing safety issues it did not perceive to be restart
issues
on Unit 1,
such
as
resolution
of
a vital area
question
regarding
the diesel
gener-
ators
and
the development
and
implementation
of
a
long-term
program for
the torus wall thinning issue.
The station Quality Assur ance
(QA) Surveillance
Group is an aggressive
and
thorough
oversite
group.
It is
particularly
flexible
and
active
in
responding
to recognized
independent
oversight
needs.
Corrective actions
resulting
from the
QA Surveillance
Group effort
now
appear
to
reverse
negative
trends prior to the development
of major problems.
This repre-
sents
a measurable
improvement
over previous
assessments.
However,
weak-
nesses
have
been identified in the technical quality of the
QA audits per-
formed
by the
QA Audit Group.
Audits
have
been
noted
to
be
weak
and
shallow despite
past
NRC criticism in
The
licensee
is
aware of
this
and is taking
steps
to strengthen
the
group's
technical
abilities.
Weaknesses
have
also
been identified in the threshold for highlighting QA
id5ntified deficiencies
and significant adverse
trends
to senior
station
and
corporate
management.
Added corporate
management
attention
should
be
given to ensuring that significant findings are properly escalated
so that
prompt and effective action
can
be taken.
One instance
observed
during this assessment
period indicated
a reliance,
by the line organization,
on
the
QA organization
to identify problems.
Corrective
actions
taken
by the Engineering staff to address
Unit I ISI
program deficiencies
were too dependent
upon the
QA staff to ensure
proper
implementation.
This ultimately resulted
in
a
QA Stop Work Order because
of ineffective program implementation.
Increased
Engineering
and contrac-
tor supervisory oversight resulted.
During the
assessment
period,
the Site Operations
Review Committee
(SORC)
and the Safety
Review
and Audit Board
(SRAB)
have
not demonstrated
their
effectiveness
in overviewing station activities.
Observations
indicated
that these
committees
get
bogged
down
in too
much detail.
Nany of the
presentations
made to these
committees
have
been ill-prepared
and ineffec-
tive.
SRAB consultants
were
observed
to
be
very active
and
provided
excellent
input to the
SRAB meetings
and reviews.
Observations
made of
the Independent
Safety Engineering
Group
(ISEG) indicated that this group
was also
not fully effective.
Members of the
group
were
too far removed
from day-to-day station activities
and their
assessments
appeared
to
be
lost at too low a level in the organization.
35
A review of the
Licensee
Event Reports
(LERs) submitted during the period
indicates that the reports were thorough, detailed,'ell
written and
easy
to understand.
The root cause of the event
was clearly identified in most
cases.
The
LERs presented
the event information in
an organized
pattern
that led to a clear understanding
of the event information.
Significant weaknesses
in the area of reportability were identified during
the Safety
System
Functional
Inspection.
As
an
example,
delayed
correc-
tive actions
for
an
improper
Technical
Specification
Limiting Condition
for Operation
allowed the plant to
be placed
in
an
unanalyzed
condition
and
resulted
in
untimely
reporting.
Additional
corporate
management
attention
is
needed
to
improve
the
prompt
evaluation
and
reporting
of
significant potential
safety issues.
Responses
to bulletins,
generic letters
and multi-plant action
items
such
as'eneric
Letter 83-28,
and
the
Rule
have
been
generally timely and complete.
The licensee's
requests
for amendments
and
reliefs
have
been
adequate
and indicate appropriate
planning
and
assign-
ment of priorities.
The quality of the reviews performed
by the licensee
under the
requirements
of 50.59
has
also
improved
over
the last rating
period.
However,
the licensee's
analysis of industry operating
experience
has
been
slow and in some
cases
inadequate.
In summary,
licensee
performance
in the areas
related to Safety Assessment
and-Quality Verification has
been inconsistent.
Strengths
have
been
noted
in the
areas
of:
1) demonstration
by
management
that it
has
begun
to
aggressively
pursue
correction
of identified
leadership
deficiencies;
2) increased
effectiveness
in problem identification; 3) establishment
of
the Regulatory
Compliance
group; 4) an aggressive
and thorough
QA surveil-
lance
group;
and
5) detailed
and
thorough
LERs.
In contrast
weaknesses
have
been
identified
in the
areas
of:
1) defined responsibilities
and
accountability;
2) implemenation of corrective actions;
3) continuing high
event rate at Unit 2 attributable to
a complacent attitude with respect
to
new
plant
operations;
4) aggressiveness
in
pursuing
potential
safety
issues;
5) shallowness
of
QA audits;
and 6) inadequate
review of industry
operating experience.
2.
Performance
Ratin
Category:
3
Improving
3.
Board Recommendation:
NRC:
None
Licensee:
Management
attention
should
be
focused
to ensure
that the
increased
emphasis
on
correcting
deficiencies
at
Unit
1
does
not result
in insufficient attention
to
problems
at
Unit 2.
36-
V.
SUPPORTING
DATA AND SUMMARIES
A. Enforcement Activit
Table 1.1
Unit
1 Enforcement Activities
Violations Versus Functional
Area
~B
~Severit
Level
Functional
Area
No. of Violations in Each Severity Level
V
IV
III
II
I
Total
Plant Operations
Maint/Surv
Eng/Tech Support
Emergency
Preparedness
Security
8
Safeguards
Radiological
Controls
Safety
Assessment
guality
Verification
TOTAL
1
6
0
0
0
7
Note:
There are five apparent violations pending final staff review.
37
Table 1.2
Unit 2 Enforcement Activities
Violations Versus Functional
Area
~B
~Severit
Level
Functional
Area
No. of Violations in Each Severity Level
V
IV
III
II
I
Total
Plant Operations
Maint/Surv
Eng/Tech Support
Emergency
Preparedness
Security
and
Sqfeguards
1
1
1
0'adiological
Control s
Safety
Assessment/guality
Verification
TOTAL
17
1
4
1
0
0
23
Escalated
Enforcement Action
An Enforcement
Conference.
was
held
on July 11,
1988 for Unit
1 to discuss
an apparent
violation of
Appendix
R "Fire Protection
Program for
Nuclear
Power
Facilities
Operating
Prior
to
January
1,
1979".
Two
severity level
IV violations were
issued
on
September
19,
1988 citing the
licensee
against
Appendix
R
and
Appendix
B, "guality Assurance
Criteria
for Nuclear
Power Plants
and
Fuel
Reprocessing
Plants".
An Enforcement
Conference
was held
on February 2,
1989 for Unit 2 to dis-
cuss
a wiring error
in the Automatic Oepressurization
System Oivision I
actuation
logic.
A Notice
of Violation
was
issued
on
Harch
13,
1989
citing
an
aggregate
severity
level III violation with no civil penalty.
38
An Enforcement
Conference
was held
on March 30,
1989 for Unit 1 to discuss
Licensed Operator Requalification Training Program deficiencies identified
early in this
assessment
period.
Potential
violations
from the
Safety
System
Functional
Inspection,
and Inservice Testing deficiencies
and
125
'OC battery
concerns
are
being
included
in this
action.
Enforcement
actions
are pending.
B.
Confirmator
Action Letters
On
March 28,
1988,
the
NRC issued
CAL 88-13 which documented
the licen-
see's
commitment that Unit
1 would not restart until Operator Requalifica-
tion deficiencies
were corrected.
On July 24,
1988,
the
NRC issued
CAL 88-17 which documented
the licensee's
commitment that Unit
1 will not
be restarted
until
problems
in several
areas
are resolved
and
NRC approval is obtained.
CAL 88-17 superseded
88"13.
39
C.
Ins ection
Hours
Summar
Unit
1
TABLE 2
Unit 2
Area
Hours
% of Time
Hours
% of Time
Plant Operations
1464
Radiological
Controls
232
27.9
4.4
810
32.3
281
11.2
Maintenance
and
Surveillance
2041
38.9
598
23.9
Emergency
Preparedness
117
Security
and Safeguards
70
Engineering
and Technical
Support
413
2.2
1.3
7.9
107
67
110
4.3
2.7
4.3
Safety Assessment/
equality Verification
913
17.4
533
21.3
TOTALS
5250
100.0
2506
100.0
40
D.
LICENSEE EVENT REPORTS
CAUSAL ANALYSIS
TABLE 3
Cause
Determined
~b
SALP Board
An assessment
has
been
conducted to determine
the root cause of each event from
the perspective
of the
NRC.
The
causes fell into the following categories
and
sub-categories.
Personnel
Errors
~PE
1.
Lack of Knowledge
(LK) - the individual
was not properly trained or
provided with instructions
from supervision.
2.
Inattention
to Detail
( ID) -
the
individual failed to
pay
proper
attention to a task
and was careless.
3.
Poor
Judgement
(PJ) -
the
individual
failed to
make
the
correct
assessment
with the proper
amount of training and attention to facts.
~E'ui ment Malfunction/Failure ~EN/F
1..Random
(R)
isolated
component
problem
not of generic
concern.
2.
Design Deficiency (00) - poor design
was the
cause
of the
malfunc-
tion/failure.
3.
Construction Deficiency (CD) - improper installation during construc-
tion/modification
caused
or
could
have
caused
the
malfunction
failure.
4.
Maintenance
Deficiency
(MD) -
improper
preventive
or
corrective
maintenance.
Procedural
Error ~PROE
The procedure failed to provide adequate
instruction,
was poorly worded or
was not properly reviewed for use.
ineffective Corrective Action ~ICA
Action
was
not
taken
by
management
or the
action
taken
on
a previously
identified
item
was
not timely or did
not
correct
the
root
cause
and
allowed this occurence.
41
TABLE 3 (Cont'd)
LICENSEE EVENT REPORTS
Unit
1 ~Summar
of Cause
Determined
~b
SALP Board
~b
Functional
Areas
CAUSE
RAD
MAINT/SURV
ENG/TS
SEC
SAFETY/(AV
PE/LK
PE/ID
PE/PJ
EM/F/R
1
EM/F/DD
EM/F/CD
EM/F/MD
PROE
TOTAL
TOTAL
9
0
0
0
24
"Total is greater
than the number of LERs since
some
LERs have
more than
one cause
code assigned.
The licensee
issued
a total of 16
LERs this
assessment
period.
42
TABLE 3 (Cont'd)
LICENSEE EVENT REPORTS
Unit 2 ~Summer
of Cause
Determined
~b
SALF Board
~b
Functional
Areas
CAUSE
RAD
MAINT/SURV
ENG/TS
PE/LK
2
1
2
PE/ID
4
2
11
SEC
SAFETY/(AV
TOTAL
18
PE/PJ
1
EM/F/R
1
EM/F/DD
EM/F/CD
EM/F/MD
PROE
16
19
3
TOTAL
10
3
35
23
0
0
0
71*
- Total is greater
than the number of LERs since
some
LERs have
more
than
one cause
code assigned.
The licensee
issued
a total of 65
LERs
this assessment
period.
43
E.
Other
Investi ations
and Alle ations
Summar
An Office of Investigation
(OI) Review was
prompted following a
Region I
inspection of the Unit
1 Licensed
Operator Requalification Training Pro-
gram which identified potential
material
false statements
made
on License
Renewal
Form 398s.
The OI Report concluded that there were
no intentional
material
false
statements
made
by
licensee
management
or
licensed
operators.
During this
assessment
period,
a total of nine allegations
were received
and
reviewed
by the
NRC.
Six allegations
were determined
to be unsubstan-
tiated
and one allegation
was
a valid concern.
The
two remaining allega-
tions were still under review at the end of the assessment
period.
Mana ement Conferences
On April 26,
1988,
the licensee
gave
a presentation
to
NRC Management
on
torus thinning and Inservice Inspection
issues
for Unit 1.
On
May 4,
1988,
a meeting
was
held to discuss
the licensee's
approach
to
is'sues
requiring resolution prior to Unit
1 restart.
On-May 10,
1988,
SALP management
meeting
was conducted on-site.
On. July 25,
1988,
the
Regional Administrator,
Executive Director of Oper-
ations,
and the Associate Director for Projects,
NRR met with the licensee
on-site to discuss
NRC's
concern
over the licensee's
continued
poor per-
formance
and issue Confirmatory Action Letter (CAL) 88-17.
On
August 18,
1988,
the
Regional
Administrator
was
on-site
to
discuss
corrective actions concerning
CAL 88-17 with site
and corporate officials.
On October
18,
1988,
a meeting
was
held in Region I to review progress
in
resolving restart
issues.
On October 21,
1988,
NRC
senior
staff
met with the
licensee
to discuss
restart
issues for Unit 1.
On October 27,
1988,
the licensee
made
a presentation
in Region I concern-
ing the
status
and
scheduling
of Unit
1
Inservice
Inspection
Program.
On
November 25,
1988,
a
management
meeting with the Executive Vice-Presi-
dent
was held concerning
the Restart Action Plan.
44
On
December 6,
1988,
NRC
management
met with the
President
of Niagara
Mohawk to discuss
the Restart Action Plan.
On
December
20,
1988,
the
licensee
gave
a 'presentation
to
NRC staff in
Headquarters
concerning
improvements
made in the Unit
1 Inservice
Testing
Program.
On
December
22,
1988,
the
licensee
presented
the
Restart
Action Plan to
the
NRC for review in a management
meeting in Region I.
On
January
19,
1989,
the
NRC
Restart
Panel
was on-site
to present
the
licensee with comments
on the Restart Action Plan.
On January
31,
1989,
the
licensee
made
a presentation
to the
NRC staff
regarding details concerning
Conformance
with Regulatory
Guide
(RG) 1.97.
On February
21,
1989,
the licensee
made
a
second
presentation
to the
NRC
staff in Headdquarters
concerning