ML17056A274
| ML17056A274 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/30/1989 |
| From: | Ash J, Hall D, Hendrie J NIAGARA MOHAWK POWER CORP. |
| To: | |
| Shared Package | |
| ML17056A275 | List: |
| References | |
| NUDOCS 8909130173 | |
| Download: ML17056A274 (150) | |
Text
g TNIA A
U NIAGARAMOHAWKPOWER CORPORATION/301 PLAINFIELOROAD. SYRACUSE. N.Y. 13212/TELEPHONE (315) 474-1511 September 7,
1989 Mr. W1111am J.
Donlon Chairman and CEO Niagara Mohawk Power Corporation 300 Erie Boulevard West
- Syracuse, NY 13202
Dear Mr. Donlon:
We, the unders1gned members of the Restart Review Panel, are pleased to transm1t to you the Restart Readiness Report (Report) related to Nine Mile Po1nt Unit l. It 1s the product of substant1al effort by many individuals both within and outside the company.
We have previously met with you to discuss our mission and methodology for our rev1ew.
Our 1ndiv1dual and collective judgments, based on 1nternal and external assessments, are that Nine Mile Point Unit l is ready for restart, subject to completion of the open items 11sted in the Report.
We thoroughly tested this conclusion and are satisfied as to its validity.
We are satisfied that sufficient attention has been given to all the restart issues such that the conclusion regarding restart can be made with confidence.
As you are aware, a number of the restart issues related to management, the so-called underlying root cause
- 1ssues, are not readily amenable to objective tests of the acceptability of their resolution.
In such cases we utilize'd our collect1ve nuclear and management expertise to analyze the extensive information that we and our staff gathered to assure that these important areas were thoroughly explored and the basis for our judgments articulated.
In summary, the Readiness for Restart Report includes:
l.
The bases for concluding that NMPl 1s ready for restart.
2, A self-assessment of the implementation of the Restart Action Plan.
3.
The bases for concluding that Niagara Mohawk's current line management has the appropriate leadership and management skills to prevent, or detect and correct, future problems.
'P092$ 0i73 890e08 PDR ADCICK 0 000244 P
Letter to Hllliam J.
Oonlon Page 2
He would be pleased to meet with you to discuss the report or to answer any questions you may have.
Respectfully submitted, RESTART REVjEH PANEL J.
T. Ash H. Hendrie R.
H. Kober AD Perry L. Burkhardt (Chairman) 0448A cmd
NINE MILE POINT UNIT I RESTART READINESS REPORT SEPTEMBER 1989 NIAGARA MOHAWK POWER CORPORAI'ION
~
RESTART READINESS REPORT CONTENTS SEPTEHBER 8, 1989 Execut ive Sunmary I.
Introduction and Suaeary A.
Bases for Assessing Restart Readiness 1.
Planning and Goals 2.
Problem Solving 3.
Organ1zat1onal Culture 4.
Standards of Performance and Self-Assessment 5.
Teamwork 6
Specific Issues 7,
NRC Generic Restart Gu1del1nes B.
Summary of Conclusions C.
Structure of Report II. Background A.
Events Lead1ng to Confirmatory Act1on Letter B.
Development of Restart Action Plan C.
NRC Review and Approval 'of RAP III Restart Assessment Process A.
Completion, Verification and Review of RAP Corrective Actions B.
Self Assessment Process 1.
Restart Review Panel Organization 2.
Development of Bases, Targets and Assessment Plans 3.
Data Collect1on Techniques 4.
Analysis and Evaluation C.
INPO Assist Vis1t D.
Executive Review
IV.
Conclusion of Restart Assessment A.
Underlying Root Causes 1.
Planning and Goals 2.
Problem Solving 3.
Organizational Culture 4.
Standards of Performance and Self-Assessment 5.
Teamwork Specifi SI-1 SI-2 SI-3 SI-4 SI-5 SI-6 SI-7 SI-8 SI-9 SI-10 SI-11 SI-12 SI-13 SI-14 SI-15 SI-16 SI-17 SI-18 c Issues Outage Management Oversight Maintaining Operator Licenses Emergency Operating Procedures Inservlce Inspection Control of Commercial Grade Items Fire Barrier Penetrations Torus Hall Thinning Scram Discharge Volume Emergency Condenser and Shutdown Cooling Valves Reactor Vessel Pressure/Temperature Curves Erosion/Corrosion Program Motor-Generator Set Battery Chargers I&C Technician Allegation Issue Safety System Functional Inspection Cracks ln Walls and Floors Feedwater Nozzles Inservlce Testing 125 VDC System Concerns C.
NRC Generic Restart Guidelines 1.
Root Causes Identified and Corrected 2.
Management Organlzatlon 3.
Plant and Corporate Staff 4.
Physical State of Readiness of the Plant 5.
Regulatory Requirements V.
Preventing, Detecting and Correcting Future Probleas Appendix 1 - Glossary of Terms Appendix 2-Nine Mlle Point Unit One Restart Readiness Bases
& Targets Matrix Appendix 3 - Assessment Bases
& Detailed Results Appendix 4-Actions to Be Taken Prior To Restart
EXECUTIVE SENARY This Restart Readiness Report affirms Niagara Mohawk Power Corporation's readiness to re-start and operate the Nine Hile Point Unit 1, The Report summarizes the results of Niagara Mohawk's self-assessment process that concluded that the Plant is physically ready to operate and that Niagara Mohawk has the management and leadership skills necessary to safely'perate ft.
The Report includes the bases for these conclusions and identifies the actions remaining to be completed prior to restart.
The limited number of clearly identified and defined actions remaining to be completed before restart are delineated ln an appendix (Appendix 4) to this report.
The Report fulfflls the third and final conditfon of the NRC's Confirmatory Action Letter dated July 24.
1988 (CAL 88-17).
In December 1987, Unit 1
was shut down due to excessive vibration in the feedwater system.
During the shutdown, Niagara Hohawk committed to resolve identified problems associated with the Inservice Inspection Program (ISI).
In the course of the outage, additional technical and programmatic deficiencies were identified by Niagara Hohawk and the Nuclear Regulatory Commission, These deficiencies led to the issuance of the Confirmatory Action Letter.
Niagara Hohawk formed a special task force to prepare a comprehensive Restart Action Plan (RAP) which was submitted to the NRC ln accordance with the Confirmatory Action Letter.
This Plan identified five underlying Root Causes for the management effectiveness problems and eighteen specific Issues.
The Plan described the identified problems, their root causes, and the intended corrective actions.
While the Restart Action Plan Corrective Actions were being implemented, Niagara Hohawk assembled a Restart Review Panel to perform the required restart readiness self-assessment and to prepare this report presenting the results of that self-assessment.
The Restart Review Panel consists of Niagara Mohawk and non-Company experts.
Collectively, the Panel represents broad experience and extensive knowledge of management practices and nuclear operation, maintenance.
engineering, quality assurance, and regulation.
The Panel fs supported by a staff consisting of a staff director, assessment area coordlnators, assessors and interviewers.
The panel sought to focus the self-assessment process on determining the effectiveness of the RAP corrective actions by developing a set of seven bases for assessing restart readiness.
Together these seven Bases describe the conditions expected when the plant fs ready for restart.
Broadly, the Panel views the seven Bases as positive descrlptlons of conditions which support safe nuclear plant operation fn contrast to the negatively stated deficiencies identified fn the RAP.
For each of these seven
- Bases, one or more Targets were developed to act as measuring criteria.
Together the Bases and Targets provide a, results-oriented method to measure the effectiveness of the corrective actions.
The Bases and Targets are contained in Appendix 2.
EXEC.
SUMMARY
-1
The self-assessment process involved gathering, analyzing, and synthesizing facts to determine the adequacy of Corrective Actions.
Several
- methods, 1nclud1ng interviews, documentation
- audits, and performance
- reviews, were employed to collect the information used for the self-assessment.
The collection and analysis of information extended over 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> and included interviews with hundreds of personnel and extensive direct observation throughout the plant, training center and other nuclear related facilities.
The results of the self-assessment confirm the appropriateness and validity of N1agara Hohawk's Restart Action Plan.
Niagara Mohawk has concluded that the Company is ready for safe restart and continued, safe and reliable operation of Nine M1le Point l.
This conclusion results from the thorough and comprehensive self-assessment performed as described in this Report.
The self-assessment has confirmed that Niagara Mohawk has satisfied the seven Bases for restart readiness that the Panel established.
The assessment of the corrective actions related to the f1ve Underlying Root
- Causes, corroborated by an assessment based on generic NRC restart guidelines, confirms that, with the additional act1ons taken as a result of the recommendations of the Restart Review Panel, Niagara Mohawk's current line management has the appropriate leadership and management skills to safely operate N1ne Mile Point l.
In particular, the assessment found that:
l.
Management has character1zed and communicated the direction for the Nuclear Division through vision, mission and goal stateme ts.
Policies and procedures have been established to provide a continu>ng process of planning to assure that plant operations will be conducted.in compliance with regulat1ons and 1n a safe and reliable manner, 2.
3.
Performance-limiting defic1encies have been identified and resolved, and a detailed plan for 1mplementing an improved problem-solv1ng process 1s in place, The upper levels of the Nuclear Division have adopted, and are using, the vision, the goals, and Standards of Performance in day-to-day operat1ons and 1n address1ng employee needs and concerns, 4.
Standards of Performance, w1th emphasis on ach1ev1ng results, have been ident1fied and coaeunlcated, and a plan for develop1ng a long-term Nuclear self-assessment process is in place, 5.
Progress toward effect1ve teamwork is being demonstrated by working together to make decisions and solve problems.
The assessment of the eighteen Spec1fic Issues, again corroborated by an assessment based on gener1c NRC restart guidelines, confirms that Nine Mile Point 1 is physically and organizationally ready to resume operation.
Each Specific Issue was thoroughly evaluated to assure that the results achieved through the 1mplementation of the corrective actions in the RAP are suff1c1ent to 'prov1de management w1th assurance that these issues concern1ng operator training and qualification, administrative process, and hardware deficiencies will not have an adverse effect on safe plant operation.
'EXEC.
SUMMARY
-2
The self-assessment also confirms that Niagara Mohawk's current line management has the appropr1ate leadership and management skills to prevent, or detect and correct, future problems.
The assessment found that the Nuclear D1vis1on and support organizations have adopted h1gh standards of performance which are being demonstrated in the 1dentification and effective resolution of problems.
The assessment also found that the corrective actions had improved the effectiveness of planning and teamwork 1n making decisions and solving problems related to performance limiting defic1encies.
Finally, the assessment identified programs and policies that had been developed to continue to enhance the assessment and improvement of the activities of the Nuclear Division.
The above conclusions are sub)ect to the completion of the identified and defined act1ons remaining to be completed before restart.
These remaining actions are delineated in an appendix (Appendix 4) to this report.
For those items 1n Appendix 4 relat1ng to Underlying Root Causes, it should be noted that they represent items not required by the RAP, but which have been expedited or added at the urg1ng of the Panel.
Niagara Mohawk will describe the completion of these actions in a letter to the NRC prior to requesting approval from the Region I Administrator for restart of Nine Mile Point l.
EXEC.
SUMMARY
-3
I 0
INTRODUCTION AND SURGERY This Report affirms Niagara Mohawk's readiness to re-'start and operate Nine Hile Point Unit 1 (NMPl).
The Report presents the results of a self-assessment process that has resulted in the conclusion that the plant is physically ready to operate and that Niagara Mohawk has the management and leadership skills necessary to safely operate it.
The Report includes the bases for these conclusions and identifies the actions remaining to be completed prior to restart.
The Report fulfills the third and final condition of the NRC's Confirmatory Action Letter dated July 24, 1988 (CAL 88-17).
Unit l was manually shutdown in December of 1987 because of excessive feedwater system vibrat1on.
Subsequently, Niagara Mohawk initiated an early refueling and maintenance outage for the Unit. Prior to the outage, Niagara Mohawk began evaluat1ng several concerns related to the Inservice Inspection Program.
During the outage, deficiencies with fire barrier penetrations and several other technical issues were identif1ed.
These issues also indicated
'that there were a number of problems associated with the effect1veness of Niagara Hohawk's management of its nuclear operat1on.
The NRC issued Conf1rmatory Action Letter (CAL 88-17) on July 24, 1988 following a meeting with Niagara Mohawk on June 20, 1988, during which Niagara Mohawk made a
number of commitments to identify and correct problems.
N1agara Mohawk formed a spec1al task force to prepare a comprehensive Restart Action Plan (RAP) wh1ch was submitted to the NRC in accordance with the Confirmatory Action Letter.
The RAP identified eighteen specific issues and five underly1ng Root Causes for the management effect1veness problems.
The RAP descr1bed the identified problems, their root causes, and the intended corrective actions.
Add1tional background 1nformation is included in Chapter II of this report.
While the RAP correct1ve act1ons were being implemented, Niagara Mohawk assembled a Restart Rev1ew Panel to perform the required self-assessment of the read1ness of NHPl for restart and to prepare this written report presenting the results of that self-assessment.
After reviewing the actions of several other util1ties involved in similar restart processes, the Restart Review Panel decided to focus the self-assessment process by developing Bases as a method to be used for concluding that NHPl is ready for restart.
The Bases for Assessing Restart Readiness are d1scussed in the following Section.
A.
Rather than merely conf1rm that all corrective act1ons had been adequately completed as 1nput to a restart report, Niagara Hohawk chose to approach the question from a d1fferent and independent tack to determ1ne if'the completion of the corrective act1ons arising from the RAP were also sufficient to assure safe operation.
To th1s end N1agara Hohawk recognized that a results oriented measurement of the effect1veness of the RAP Corrective Actions was necessary to assess whether the problems leading to the shutdown of Un1t l had been solved.
The Panel and its staff, therefore, created a model describing the state to be expected when suffic1ent progress toward achievement of the Corrective Action Objectives has been demonstrated.
The model for the desired state is described by the seven
Bases discussed in this Report.
In creating this model the panel reflected their, knowledge of current industry and regulatory standards for attributes supporting safe and reliable nuclear plant operation.
In order to test whether the desired state had been
- achieved, Targets were developed to act as qualitative measuring criter1a for each Basis.
The seven Bases for Assessing Restart Readiness and their associated Targets are summarized in a matr1x in Appendix 2.
The Panel developed the Targets such that when adequate progress was made toward meet1ng the Targets, the corresponding Basis would be met.
When the Panel dec1ded that all 'seven Bases would be satisfied, they presented their conclus1ons to Niagara Mohawk's Chief Executive Officer in th1s report.
Broadly, the Panel views the seven bases as pos1tive descriptions of conditions which support safe nuclear plant operation in contrast to the negatively stated def1c1encies identified 1n the RAP.
To emphasize the 1mportance of the f1ve Underlying Root Causes (URCs) identified in the
- RAP, an assessment Basis was developed for each of them.
Targets were then developed for each Basis.
To focus upon the correction of the 18 Spec1fic
- Issues, a s1ngle Basis was developed, that describes the desired plant and personnel status.
For each Spec1f1c
- Issue, Targets were provided to aid in assessing the effectiveness of corrective actions in resolving the Issue and prevent1ng recurrence of this or sim1lar'problems.
To prov1de add1t1onal assurance that an effective self-assessment had been performed, it was dec1ded to review progress from another perspective; this second v1ewpoint was based on the generic NRC Restart Guidelines, wh1ch were identified in an ll/23/88 NRC memorandum from Mr. V. Stello, Jr. to NRC Office Directors and Regional Admin1strators.
A Basis (with Targets for each of the f1ve sub-elements of the Guidel1nes) was developed to identify the criteria for a successful assessment from this perspective.
Presented below are the seven self-assessment Bases for the Underlying Root
- Causes, Specific Issues, and NRC Generic Restart Gu1del1nes.
They are repeated for conven1ence in the deta11ed discussions of Appendix 3.
1.
Planning and Goals "The management tasks of planning and goal setting have not kept pace w1th the changing needs of the Nuclear Division and with changes within the nuclear industry."
Assessaent Basis No. 1:
Management w1ll have assessed cr1tical issues w1th1n the Nuclear Division and fac1ng the nuclear industry.
Based on th1s assessment, and in support of Corporate mtss1on and goals, management shall have characterized and communicated the d1rection for the Nuclear Division through vision,
- mission, and goal statements.
Managers can deploy their resources consistent with the Nuclear Division vision, mission, and goals, to provide assurance that plant operations will be conducted in compliance with regulat1ons and in a safe and reliable manner.
I-2
2.
Problem Solving "The process for identifying and resolving issues before they become regulatory concerns was less than adequate, in that there was not an integrated or cons1stent process used to identify, analyze,
- correct, and assess problems in a timely way."
Assessment Basis No. 2:
3.
Past and current performance-limiting deficiencies shall have 'been 1dentified and resolved through self-assessment of past performance and implementation of appropriate corrective actions.
A detailed plan for implementing an improved problem-solving process, with provisions for:
a) problem identification, b) systematic causal
- analysis, c) corrective action plannin'g, d) implementation management, and e) assessment of results
- achieved, shall be in place and actions shall be in progress to implement this
- plan, A process based on that used 1n develop1ng the restart action plan shall be used until the long-term program is fully in place.
Organizational Culture "Hanagement's technical f'ocus has created an organizational culture that diverts attention away from the needs and effective use of employees."
Assessient Basis No. 3:
There is evidence that the upper levels of the Nuclear Div1sion organization have adopted, and are using, the vision, goals, and Standards of Performance in day-to-day operations and in addressing employee needs and concerns.
- 4. Standards of Performance and Self-Assessment "Standards of Performance have not been defined or described sufficiently for effective assessment, and self-assessments have not been consistent or effective."
Assessment Basis No. 4:
5.
Standards of Performance, with emphasis on achieving results, have been ident1fied and ccemunicated.
Plans have been developed for implementing a
comprehensive self-assessment program to assess readiness for restart has been conducted.
Progress has been demonstrated in implementing the plan for develop1ng the long-term Nuclear self-assessment process.
Teaawork "Lack of effective teamwork within the Nuclear Div1sion and with support organ1zations 1s ev1denced by lack of coordination, cooperation, and comnunication 1n carrying out respons1bilities."
Assessment Basis No. 5:
Progress toward effective teamwork within the Nuclear Division, is evidenced by working together to make decisions and solve problems,
- and, ln general, to "get the Job done, correctly and completely".
This progress will-be evidenced both within and between departments in the Nuclear Division.
6.
Specific Issues The 18 Specific Issues are:
1
~
Outage Management Oversight 2.
Maintenance of Operator Licenses 3,
Emergency Operating Procedures 4.
Inservice Inspection 5.
Control of Commercial-Grade Items 6.
Torus Wall Thinning 8.
Appendix J Testing of Emergency Condenser and Shutdown Cooling Valves 10.
Reactor Vessel Pressure/Temperature Curves ll.
Erosion/Corrosion Program 12.
Motor-Generator-Set Battery Chargers 13.
Implementation of Long-Term Programs Related to IEC Technician Allegation Issue 14.
Safety System Functional Inspection 15.
Cracks in Halls and Floors 16.
Feedwater Nozzles 17.
Inservlce Testing 18.
125 VDC System Concerns Assessment Basis No. 6:
"Results achieved through implementation of restart corrective actions for the RAP Specific Issues shall be sufficient to resolve or provide management with assurance that these issues concerning operator training and qualification, administrative
- process, and hardware deficlencles will not have an adverse effect on safe plant operations."
7.
NRC Generic Restart Guidelines
.The five NRC Guldellnes relate to:
1.
2.
3.
4.
5.
Root Causes Identified and Corrected Management Organization Plant and Corporate Staff Physical State of Readiness of the Plant Regulatory Requirements Assessment Basis No. 7:
"Results of corrective actions and plant improvement activities sufficiently address and satisfy NRC restart guidelines, such that all issues necessary to support readiness for restart and safe operation have been demonstrated and NRC approval for plant restart may be requested."
I-4
n l The results of the assessment program confirm the appropriateness and valid1ty of Niagara Mohawk's Restart Action Plan, which has been submitted to the NRC.
The NRC has acknowledged the viability of the Plan as a suitable framework for responding to the NRC's request for a self-evaluation of restart readiness.
Niagara Mohawk has concluded that, upon completion of the actions described in Appendix 4 of this Report, the Company w111 be ready for safe restart and continued, safe and reliable operation of Nine Mile Point l.
This 'conclusion results from the thorough and comprehensive self-assessment performed as described in this Report.
The self-assessment has confirmed that Niagara Mohawk has satisfied the seven Bases for Restart Readiness described in the preceding sect1on.
The assessment of the five Underlying Root Causes, corroborated by an assessment based on generic NRC restart guidelines, confirms that Niagara Mohawk's current line management has the appropriate leadership and management skills to safely operate Nine Mile Point l.
In particular the assessment found that:
1.
Management has characterized and communicated the direction for the Nuclear 01vision through vision, mission and goal statements.
Polic1es and procedures have been established to provide a continuing process of planning to assure that plant operations will be conducted in compliance with regulations and 1n a safe and reliable manner, 2.
Performance-11mit1ng deficiencies have been identified and resolved, and a deta1led plan for implementing an improved problem-solving process is in place, 3.
The upper levels of the Nuclear Division have adopted, and are using, the
- vis1on, the goals, and Standards of Performance in day-to-day operations and in addressing employee needs and concerns, 4.
Standards of Performance, with emphasis on achieving results, have been 1dentified and comnunicated, and
- a. plan for developing a long-term Nuclear self-assessment process is in place, 5.
Progress toward effect1ve teamwork is being demonstrated by working together to make decisions and solve problems.
Each spec1fic Issue was thoroughly evaluated to assure that the results achieved through the implementation of the restart corrective actions are sufficient to provide management with assurance that these issues concerning operator tra1ning and qualification, administrat1ve
- process, and hardware deficiencies will not have an adverse effect on safe plant operation.
In
- summary, the assessment of the Specific Issues, again corroborated by an assessment based on generic NRC restart guidelines, confirms that Nine Mile Point l is physically and organizationally ready to resume operation upon completion of the actions described in Appendix 4.
Niagara Mohawk w111 describe the completion of these actions in a letter to the NRC prior to requesting approval from the Region I Administration for restart of NMPl
~
I-5
The self-assessment also confirms that Niagara Mohawk's current line management has the appropriate leadership and management sk'ills to prevent, or detect and correct, future problems.
The assessment found that the Nuclear Divis1on and support organizat1ons have adopted high standards of performance wh1ch are being demonstrated in the identification and effective resolution of problems.
The assessment also found that the corrective actions had improved effectiveness of planning and teamwork in making decis1ons and solving problems related to performance limiting defic1enc1es, Finally, the assessment identified programs and policies that had been developed to continue to enhance the assessment and improvement of the activitie's of the Nuclear Divis1on.
The Report consists of five Chapters:
Chapter I, Introduction, includes a discussion of the development of the Bases for concluding that NMPl 1s ready for restart.
Chapter II (Background) 1s a
summary description of key portions of the Restart Action Plan.
Chapter III summarizes the approaches and methods used in assessing readiness for restart.
Chapter IV provides the conclusions of the restart self-assessment process.
Chapter V discusses measures to prevent, detect and correct future problems.
Appendix l is a Glossary of Terms used 1n the Report.
Appendix 2 is the "Nine Mile Po1nt Unit One Restart Readiness Bases
& Targets Matrix," wh1ch comprises the Bases and Targets whereby the effectiveness and sufficiency of the RAP Corrective Actions were assessed.
Append1x 3 provides details of'he assessment of the effectiveness of Restart Action Plan (RAP) corrective act1ons 1n correcting problems, 1mproving cond1tions, and 1nstitut1ng programmatic measures sufficient to assure that the concerns addressed in the RAP and Confirmatory Action Letter 88-17 will not recur or have a negative effect on safe 'operat1on of Unit l.
The 1nformation 1n this appendix provides results of the assessments by Basis and Target.
Append1x 4 lists those actions required to be completed prior to restart.
I-6
II. BACKGROUND In December
- 1987, Nine H1le Point Unit l was manually shut down because of excessive feedwater system vibration. At the time, it was anticipated that the Un1t would be restarted on completion of repairs and operated until the planned Spring l988 refuel1ng and maintenance
- outage, Before the December
- shutdown, however, a number of concerns were identif1ed, relating to the Inservice Inspection Program (ISI).
Niagara Mohawk committed to resolve the ISI program concerns before restarting Unit l. Further evaluation.disclosed that the problems were more extensive than originally believed;
- hence, Niagara Mohawk initiated an early refueling and maintenance outage.
In March 1988, wh1le perform1ng modificat1on work, Niagara Mohawk ident1fied a
fire barr1er deficiency under the Un1t l battery rooms.
As a result, a
program was initiated to evaluate the adequacy of all Un1t l fire barriers having regulatory requirements.
- These, and other technical issues identified during this period, also indicated problems associated with the effectiveness of Niagara Mohawk's management of tts nuclear operat1on.
The management effect1veness issues identified included concerns about the effectiveness of problem solving and implementation of previous corrective actions.
These
- problems, and other technical and management effect1veness issues were discussed with the NRC on June 20, 1988. Following that meeting, the NRC discussed the need for additional comnitments w1th Niagara Hohawk, which led to NRC's issuance of Confirmatory Action Letter CAL 88-17, dated July 24, 1988.
The CAL specif1ed the following three act1ons to be taken by Niagara Mohawk before restart of Un1t l:
- l. "Determ1ne and document your assessment of the root cause(s) of why N1agara Mohawk line management has not been effective in recognizing and remedy1ng
- problems, 1n particular the problems which were the subject of CAL 88-13 (ma1ntenance of operator licenses),
Inspection Report 50-220/88-22 (11censed operators'nowledge and use of emergency operating procedures),
and the issues d1scussed during the June 20, 1988 meeting at Reg1on I."
- 2. "Prepare a proposed Restart Action Plan, and submit it to the
- NRC, Region I Regional Adm1nistrator, for review and approval.
The Plan will 1dent1fy all actions required to be completed prior to startup and a
schedule for completion of all other act1ons to be completed after startup that are needed to address the root cause(s) identified in Item
- l. For act1ons proposed for completion after restart, you will provide Justification for why completion after restart will not have an adverse impact on safe plant operation."
- 3. "Provide a wr1tten report relative to the read1ness of NMPl for restart.
Include in this report a) your bases for concluding that NHPl is ready for restart, b) a self-assessment of the implementation of the Restart Action Plan, and c) your conclusions regarding whether Niagara Hohawk's current line management has the appropriate leadership and management skills to prevent, or detect and correct, future problems."
B.
v f
p In response to item 2 of the CAL 88-17, Niagara Mohawk submitted to the NRC a comprehensive Restart Act1on Plan, addressing the identified defic1encies and the1r root causes, and describing its intended corrective actions.
The RAP was developed by Niagara Mohawk's Nuclear Division supporting organizations and consulting experts.
Niagara Mohawk sen1or management is an integral part of the restart effort.
Leadership and direction for the restart effort is provided directly by the Chief Executive Officer and the President, who have been continually involved in the organization and review of the restart effort.
In response to CAL 88-17, senior management established three primary ob)ectives:
l.
Take aggressive yet carefully cons1dered measures to identify the issues; dev1se and implement requ1red act1on; assure that results have been documented; verify adequate completion of restart actions; and maintain auditablo.
- records, 2.
Assure that all levels of Niagara Mohawk personnel subscribe to the Plan, with line management defining the root causes and corrective actions, and taking necessary act1ons to implement and verify completion of the correct1ve actions.
3.
Assure that senior Niagara Mohawk management is actively involved in develop1ng and 1mplementing the Plan.
In developing the Plan to meet these management ob)ectives, a systemat1c approach was instituted to ensure that:
l.
The issues were 1dentified.
2.
The 1ssues were effectively analyzed to determine their root cause(s),
3.
Effect1ve corrective actions were identified to address these root causes.
4.
Appropriate accountabil1ty was ass1gned for implementing corrective actions.
5.
Follow-up evaluat1ons were performed to assess whether corrective actions were effecting desired changes in performance.
6.
Verification act1vities were 1dentif1ed in advance to assure that adequate complet1on of restart act1ons was achieved, verified and documented.
As part of the review process, the Plan was explained and discussed in numerous meetings throughout the
- Company, to gain acceptance and support at all levels.
Coordinat1ng and implementing the restart effort was the responsibility of line organizations headed by the Genera'I Superintendent
- Nuclear Generation, V1ce President Nuclear Engineering and L1censing, and var1ous support groups.
A Restart Task Force, reporting directly to the Executive Vice President-Nuclear Operations, worked with line management to develop the Plaii and facilitate its initial implementation.
An Integrated Team of selected individuals represent1ng key organization functions provided additional information and support, including resolution of issues encountered in developing, implementing, and assessing restart actions.
With line management participation and senior management oversight, the Restart Task Force reviewed selected historical documents related to Unit l
- and, as
- needed, Unit 2 operation, as well as from other sources.
While sorting issues and trends by root cause
- category, the Task Force recognized that most issues could ultimately be attr1buted to management and organizat1onal effectiveness concerns.
These problems were evidenced by the following:
Buy-in to program and policies by line management, was frequently lacking.
2.
Resources applied to Unit 2 construction activities were sometimes at the expense of Unit l act1vities.
3.
Focus was sometimes too narrow to accurately identify root causes and prescr1be appropriate correct1ve actions for identified problems.
4.
Often, 1nsuffic1ent evaluat1on time was devoted to identifying root causes of problems and devising corrective actions.
The Plan was des1gned to overcome these deficiencies.
To determine the issues to be analyzed, a three-pronged approach was used:
'I.
Prev1ously-identified issues and trends were evaluated to determine whether they were symptoms of broad underlying 1ssues, and, if so, to reveal these Underlying Root Causes.
2.
Spec1fic Issues were compiled that were already identified as restart prerequ1sites (for example, the issues discussed in CAL 88-17).
3.
A process was established to continue to identify and review new issues and to determine whether they involve matters to be addressed before restart.
Individua) root causes were grouped into the five Underlying Root Causes.
(See Append1x 8 of the RAP for details of N1agara Hohawk's process for determining root causes.)
Corrective action ob]ectives were assigned to each Underly1ng Root Cause.
These objectives characterize the desired direction and performance level for the Plan.
For each correct1ve action ob)ective, corrective actions were devised to meet the ob)ective.
The potential effect of each corrective action on safe plant operation, its priority, and other considerations affect1ng the importance of completing it or showing significant progress, were evaluated at several organizational levels representing a cross sect1on of the Nuclear Division and support groups.
Each correct1ve action was prioritized in accordance with its required completion time frame relative to Unit 1 restart:
Priority 1 corrective actions are required to support safe plant operation, demonstrate sufficient progress in weak performance
- areas, or correct significant deficiencies.
Priority l corrective actioiis are required to be completed, or sufficient progress
- shown, before restart.
Priority 2 corrective act1ons involve additional improvements in areas that are functionally satisfactory now, or, when completed, will achieve the desired cultural environment.
Priority 3 corrective actions involve longer-term enhancements to programs or processes that are currently considered to be satisfactory.
The iterative process of prioritiz1ng corrective actions was comprehensive, and provides conf1dence that the pr1ority ass1gnments are valid.
The process identified the Priority l items, which. in con)unction with other day-to-day and programmatic activ1ties, e.g.,
Technical Specification Surveillance requirements, establish necessary and suff1cient cond1tions to safely operate N1ne Nile Point Unit l.
Collectively the Priority l, 2 and 3 Corrective Actions are referred to as the Nuclear Improvement Program.
The Nuclear Improvement Program (NIP) is the overall program to improve Niagara Hohawk's nuclear performance, which encompasses both short-term and longer-term activities.
The NIP addresses all of the correct1ve actions des1gned to improve management and organ1zational effect1veness, and longer-term corrective actions associated with specific technical issues.
The Restart Action Plan (RAP) is part of the NIP and is directed to the short-term, Priority l aspects of the Program.
Justification was provided in the RAP as to why the post-restart implementation of Pr1ority 2 and 3
corrective actions w1ll not adversely affect safe plant operation (CAL 88-17, action item 2),
and the progress of those act1ons 1s not the sub)ect of th1s Report.
However, their general status may be discussed in terms of overall progress toward stated goals.
Although some Priority 2 and 3 corrective act1ons may beg1n before restart, they are not in direct support of safe plant operation and are not required before restart.
They will establish levels of performance above those necessary to support safe operation. Priority 2 and 3 issues are generally expected to be fully resolved within approximately one year and five years after restart, respectively.
- However, because the Nuclear Improvement Program is a dynamic process, periodic review, evaluation, and ad)ustment could 1nfluence pro]ected longer-term completion time frames.
After the initial NRC Staff review, the NRC submitted a list of questions on February 3,'989 regarding specific RAP and NIP issues (Attachments 1
and 2 of Inspection Report 50-220/89-10).
(A number of these questions had been discussed and the issues further clarified in a meeting held with the NRC on January 26, 1989.)
He submitted our written response to these questions on Harch 2, 1989 and revised the RAP to reflect changes described in the response.
Revision 2 of the Restart Action Plan was submitted to the NRC on July 7, 1989.
During discussions with Niagara Hohawk management and at a
public meeting on August 23,
- 1989, the NRC acknowledged the viability of the RAP as a suitable framework for responding to the NRC's request for a self-evaluation of restart readiness.
I I I.
RESTART ASSESSMENT PROCESS This Chapter discusses the restart self-assessment process and its key elements.
In addition, in order to put the self-assessment process in perspect1ve, a brief descr1pt1on of the complet1on, verification, and review of the RAP Corrective Actions 1s provided.
Also included in this chapter are descriptions of the INPO Assist Visit, conducted as part of the restart readiness act1v1ties, and the Executive Review of the Self-Assessment.
A.
Responsibility for implementing Restart Correct1ve Act1ons was generally ass1gned to functional groups w1thin the Nuclear D1vis1on, An individual was the designated "Task Manager" responsible for the action completion, for deciding when the results were acceptable, and for ensuring that the ver1f1cat1on steps provided adequate ev1dence of complet1on.
On complet1on of the corrective actions, the Task Manager conducted a review of the results.
Nhen actions were found to be sat1sfactory, the Task Manager signified concurrence on an Issues and Correct1ve Action Closure form, attaching documentat1on demonstrating that the action has been closed.
Following the Task Manager's
- rev1ew, the verificat1on steps specified in the RAP were performed by an individual or group not d1rectly responsible for the performance of the work.
Completion of the verification actions was ind1cated by signing the Verification Action Closure Form and attaching documentation demonstrating that the vertficat1on act1on had been completed.
The correct1ve actions were reviewed for acceptabil1ty by existing review comIittees:
the Site Operating Review Ccmeittee (SORC)
- and, on an audit
- basis, the Safety Review and Aud1t Board (SRAB).
These groups generally used the reports and presentat1on of act1on implementers and verifiers; however, the SRAB conducted some 1ndependent assessments.
Corrective actions involving specific plant activ1ties or plant cond1tions were reviewed by SORC and SRAB on an aud1t basis.
All corrective actions are required to be closed by SORC before restart.
B.
The key element of the self-assessment process
'1s the Restart Review Panel and its support staff.
The Panel 1s a temporary functional group chartered by and chaired by the Executive Vice President - Nuclear Operations.
The Panel was established to lead and direct the self-assessment effort.
The assessment process consists of gather1ng, analyzing, and'synthes1z1ng facts for each Underly1ng Root Cause, Specific Issue, and NRC Restart Guidel1ne, to determine the adequacy of Corrective Actions.
The Restart Review Panel cons1sts of Niagara Mohawk executives and non-Company experts.
The Panel members are listed below:
Hr. L.
Hr. J.
Mr. D.
Dr. J.
Hr.
R.
Hr. J.
Burkhardt, III-T. Ash-P. Hall-M. Hendrie-H. Kober-A. Perry (NHPC) Exec.
VP Nuclear Operations (Chairman)
(NHPC)
VP Consumer Services (Illino1s Power Company)
Senior VP Consultant (Rochester Gas
& Electric) President (NHPC)
VP Quality Assurance
Collectively, the Panel has broad experience and extensive knowledge of general management practices and nuclear operation, maintenance, engineering, quality assurance, and regulations.
The Panel's support staff consists of a staff director, three assessment area coordinators, nineteen primary assessors, and eleven interviewers.
Figure III-1 shows the organizational relationships of the Panel and its staff.
The assessors acted as the direct extension of the Panel members.
Requirements for selection of assessors included knowledge of the sub]ect area and independence from the l1ne function that had direct responsibility Yor executing the corrective actions dealing with the issue to be assessed.
The assessors were about evenly divided between Niagara Mohawk personnel and consultants.
Consultants were used as assessors to provide additional expertise, or expertise suffic1ently 1ndependent from the work being assessed.
Add1tional people contributed support on an as-needed basis.
The Panel members (other than the Chairman) divided the twenty-eight assessment issues and took personal responsibility to act as advisors to the members of the support staff for each of the issues.
Th1s structure allowed each Panel member to focus his attention in areas where his expertise was
- greatest, to devote the required time to guide the assessors, and to participate directly in the assessment process.
It also assured first-hand involvement of a Panel member in the assessment of each issue.
During the assessment process the Panel met several times for a total of ten
- days, Dur1ng these meetings the Panel reviewed and approved various aspects of the assessment
- process, rev1ewed the status of the assessments, rev1ewed and approved assessment
- results, and provided feedback and recommendations to the assessors and 11ne management.
Since the beginning of April, over 6000 hours0.0694 days <br />1.667 hours <br />0.00992 weeks <br />0.00228 months <br /> have been expended in assessment activities, which included the review of thousands of documents, interviews with hundreds of people and extensive direct observations throughout the plant, training center and other nuclear related fac111ties.
The Follow1ng sect1ons prov1de additional information on the act1vit1es of the Panel and its staff.
2.
One of the first act1ons of the Panel was to establ1sh a focus for the self-assessment process by developing bases for assess1ng restart readiness.
The Bases for Assessing Restart Read1ness are discussed 1n Chapter I of this report.
Assessment plans were developed by each assessor us1ng the Bases and Targets as a guide.
The assessment plans were des1gned to provide enough information to allow the assessor to ]udge whether or not the Targets associated with that issue had been met.
The assessment plans were tailored to the assessment
- issues, and as
- such, vary in the techniques used to gather the requisite data.
Each assessment plan was presented to the Panel for approval during one of the Panel meetings.
Based on results and lessons learned during the assessment
- process, refinements were made to enhance completeness,
- accuracy, efficiency, and measurability of results.
FlGURE III-1 ASSESSMENT ORGANI2ATlON RESTART REVIEW PANEL STAFF DIRECTOR ASSESSMENT AREA ADVISOR (RRP Member)
INTERVIEWERS, OBSERVERS, DOCUMENTAND SURVEY EVALUATORS MANAGEMENT EFFECTIVENESS COORDINATOR ASSESSORS SPECIFIC ISSUE COORDINATOR ASSESSORS NRC RESTART GUIDELINE COORDINATOR ASSESSORS SUPPORT) AS NEEDED
3.
Several methods were used to collect the information used for the Restart Self-Assessment.
These techniques are described in the following paragraphs.
The collection of this data was started well before the corrective actions were scheduled to be completed.
This was done so that the results of preliminary assessments could be used to provide early feedback to the line organization when the assessors saw probable shortfalls in relation to the Targets.
In addition, the early collection of data allowed the assessors to develop multiple data points in time so that trends could be observ'ed, particularly in the corrective actions associated with management effectiveness issues.
The initial data collection began in March 1989 and continued since that time.
a.
INTERVIEWS Interviews were widely used to collect data for the Restart Self-assessment.
In particular, interviews were used to collect information on the effectiveness of correct1ve actions related to management and organizational issues.
These 1ssues generally required more sub)ective means of assessment than the Spec1fic Issues and relied largely on information obtained through 1nterviews, and longer-term observations of indiv1dual and group behav1oral changes.
In contrast, for the Spec1fic Issues data collect1on on completion of corrective actions was generally available through documentation and performance reviews.
- However, depending on the nature of the issue, interviews of personnel were conducted by assessors to collect information from indiv1duals involved with the corrective action related to a Specific Issue.
b.
OOCLNENTATI ON REV I ENS The most widely-applicable assessment technique is a documentation review.
These consist of checking records and other documents that demonstrate restart action complet1on.
Although not usually suff1cient as the only assessment
- tool, a documentation rev1ew is usually part of any assessment plan.
It is generally used with one of the other techniques described 1n this section.
c.
PERFOINANCE REV I EWS Performance reviews cons1st of collecting and evaluating information gained by observ1ng individuals, equipment, or act1vities.
Examples are:
simulator exercises, component and system pre-operational or surveillance tests, system walk-downs, area tours, and activity surveillances.
This techn1que is most useful when the assessment Target requires a
demonstration of acceptable component, system or personnel performance.
A performance rev1ew, together with a documentat1on review or personal interview, is often suff1ctent to assess a restart action.
d.
PANEL HENBER ACTIVITlES In addit1on to the guidance provided at the formal Panel
- meetings, each Panel
- member, in his Advisor capacity, met with the assessor and the Task Manager to participate in the assessment analysis and the resolution of concerns identified through the assessment.
The Panel members have also observed work act1vities in the plant and inspected plant cleanliness and the overall material condition.
The Panel members also observed:
simulator training, operators in the plant; and Nuclear Div1sion personnel in various work situat1ons to determ1ne 1f the employees'xh1bit the proper skills'nd att1tudes supporting improvements in the five management effectiveness areas.
4, The foundation for the restart decision 1s the comparison of the situation found in the Nuclear Division to the state described by the Bases and the Targets.
The Targets were set beyond the commitments made in the RAP in order to be sure that each RAP comm1tment was met with some margin of confidence.
In many cases the Targets were set so that certain of the items identified in the Nuclear Improvement Program (to be completed after restart) had been started.
The Panel was thus able to be sure that a br1dge existed to get to the ob)ective descr1bed in the NIP even though the particular NIP act1vity was not complete.
Information collected was analyzed by the Panel and its assessors to determine its accuracy in showing status relative to the assessment Bases.
It was necessary to determine the following:
l)
Is the corrective action completed or fully implemented?
2)
Does the corrective action meet all the objectives of the Restart Action Plan for dealing w1th the 1dentif1ed deficiency?
3)
If the corrective action is not required to be completed or fully implemented prior to restart, has suffic1ent progress been made to
]ustify restart?
Sufficiency can be determined by the following:
a.
Has sufficient progress been made to assure that safe operation of the plant dur1ng normal and abnormal operat1ons will not be
)eopardized by any uncompleted act1on?
and b.
Is an acceptable mechan1sm in place that assures the Company that the act1on will be completed within an acceptable schedule?
Dur1ng its meetings the Panel reviewed interim and final assessment results and the status of Corrective Actions.
Each issue was discussed and the Panel made suggest1ons to the Task Managers and assessors.
In the Management Effectiveness areas there were no absolute criteria to rely on to determine adequate progress toward achieving the desired state.
In many instances, the Panel looked for the proper behavior being exh1bited by managers in the more sen1or levels of the organization and for the proper programs to be in place.
With the proper example being modeled by the senior managers and the Standards of Performance in place and be1ng given high visib111ty, the Panel was confident that the desired behaviors and skills would become the norm in the Nuclear Division.
The Panel's evaluation has indicated that th1s process 1s occurr1ng.
When the Panel had determined that adequate progress had been made toward meeting each Target, it concluded that the associated Basis had been met.
After determining that all seven Bases would be thus achieved, the Panel presented its findings to Niagara Mohawk's President and Chief Executive Off1cer.
The Panel's findings are summarized in this Readiness for Restart Report and more detailed results of the self-assessment are included in Append1x 3.
C.
When the Restart Review Panel found that the Unit was nearing readiness for restart and an initial draft of this Report had been prepared, Niagara Mohawk requested that INPO send a seven-person Assist Team to review the progress made in resolving the most s1gnificant findings of the Unit l March 1989 INPO Evaluation; in addition, the team spot-checked some of the Panel's find1ngs during the1r vis1t.
This action was to provide an external rev1ew of the progress the Company had made.
The INPO Assist Vis1t was conducted during the week of August 14-18 and concluded that substantial progress has been made 1'n resolving the performance problems noted in the March 1989 INPO Evaluation, thereby supporting the results of the Panel's assesaaent.
D.
The Execut1ve VP Nuclear Operations, on behalf of the Panel, presented the results of the Restart Self-Assessment to the President and the Nuclear Oversight Comnittee of the Board of D1rectors.
After review by the Nuclear Oversight Ceanittee and the President, this Report was presented to the Cha1rman of the Board (CEO) for final approval and transmittal to the NRC Reg1on I Administrator.
IV.
Conclusions of Restart Assessment This chapter summar1zes the Panel's findings for each Underlying Root Cause, Spec1fic Issue and the NRC Restart Criteria.
The Basis and Targets for each of these areas are provided in a matrix in Append1x 2.
Additional details concerning the assessment methods and results are contained in Append1x 3.
Act1ons that remain to be completed prior to restart are discussed in Appendix 4, specifically item l in Appendix 4 requires the completion of all remaining RAP corrective actions.
The status of the RAP corrective actions is tracked by the Outage Manager.
A.
1.
PLANNING AND GOAL SETTING The results of th1s assessment indicate that management has characterized and communicated the d1rection for the Nuclear Division through vision, mission and goal statements.
As part of the annual planning process, a strategic assessment w111 be performed to assess critical issues within the Nuclear Div1sion and facing the industry.
Interviews with department personnel indicate that managers are better able to deploy their resources consistent with the Nuclear Division vision, m1ssion and goals.
The specific actions that rema1n to be completed before restart are ident1f1ed in Appendix 4.
The following paragraphs summarize the significant corrective action results identified by the assessor's observations, interviews, and document reviews.
The Panel concludes that the signif1cant progress and the results achieved in this area support the restart of Unit l.
Meeting observat1ons and interviews indicate that Senior Management, by
- example, is continually reinforc1ng the importance of using the Nuclear Division vision, goals and Standards of Performance to focus department, group and individual work activities at all levels.
An across-the-board awareness is beginning to develop on how an employee's ind1vidual performance should support the Nuclear Division's vision, goals and Standards of Performance.
Performance Planning Worksheets, which are used for defining individual goals, are also beginning to be used to assign accountability to these goal setting efforts.
A Nuclear Divis1on Integrated Pr1or1ty System was originally identified as a
NIP item to be completed after restart.
Kowever, the Panel urged that substantial progress be achieved before restart since it concluded that the prior1ty system would help cure both planning and problem solving deficiencies.
A draft vers1on of the priority system has been approved by the Integrated Team and is being used on a pilot basis.
The Panel has concluded that. that progress has been made.
The Nuclear Improvement Program 1s 1n place and the NIP Program Administrator has been selected.
The NIP is the basis for the 1989 Nuclear Division Business Plan.
The 1990 Business Planning cycle has begun with a strategic assessment.
A draft pol1cy/procedure for the Nuclear D1v1sion planning process is being circulated for cement.
Th1s po11cy 1nstitutional1zes the process within the Nuclear Division by def1n1ng responsib1lities for the development, 1mplementat1on and tracking of specific programs in support of the Nuclear Divis1on ob)ectives and goals.
The finalized po11cy/procedure will be the foundation of the long range Nuclear Div1s1on planning activit1es.
0
2.
PROBLEN SOLV I NG The results of this assessment 1ndicate that past and current performance-limiting defic1encies have been 1dentified and are being resolved through self-assessment of past performance and implementation of appropriate corrective actions.
The specif1c actions that remain to be completed before restart are ident1fied in Appendix 4.
The following paragraphs summarize the sign1ficant corrective action results identified by the assessor's observations, interviews and document reviews.
The Panel has determined that the Nuclear Division has made sign1ficant progress toward improving the problem solving process and has established programs which will result in further enhancements.
The Panel concludes that the effectiveness of the corrective actions in this area supports the restart of Unit l.
The Panel has determined that the correct1ve act1ons taken regarding the identification and reporting of problems have been effect1vely implemented.
A substantial effort was also expended to review 11cens1ng changes and analyses since the conversion of the license in 1974.
This effort included in-depth analysis of a number of Techn1cal Specification and facility license changes and problem reports involving Techn1cal Specifications.
These analyses revealed that the techniques used to resolve regulatory issues in the past were technically sound.
This assessment focused on the identification and determination of Root Cause, prior1tizat1on, 1mplementat1on and assessment of effectiveness.
Early in the assessment, the Nuclear D1vision's ability to identify problems and establish Root Cause was determined to be adequate.
However, it was noted that there are a large number of indiv1dual systems for identification and tracking of problems.
The Nuclear Div1s1on effort to integrate these systems will result 1n procedures which prov1de the hierarchy to accomoodate lower tier-deya~nt level procedures and prov1de for evaluat1on of deficiencies.
It was also clear, early in the assessment
- process, that the back end of the problem solving process, implementat1on of resolut1ons, was not effective.
The principal def1cienc1es 1dent1fied were:
l.
An inab111ty to pr1or1tize a broad range of problems such that some could be leg1t1mately deferred and efforts be directed at those providing the most return in safety and reliab1lity; and 2,
An inability to fully implement the resolution of a problem.
The first deficiency was addressed by accelerat1ng completion of the Integrated Priority System d1scussed above under Plann1ng and Goal Setting.
The second defic1ency resulted from a tendency to pass problem resolution responsibility from one person to another without naming someone as accountable for ultimate resolution.
As a long term improvement item, a
Policy Directive is currently being formulated which will refine the framework for assuring accountability and responsibility through resolution of safety signif1cant problems.
The contents of the NIP that are 1mportant to problem solv1ng include upgrades of Root Cause and trending programs, def1c1ency report1ng, and lessons learned and operat1ng experience programs.
Following an interim assessment wh1ch 1ndicated a procedural weakness 1n the "lessons learned"
- process, a Site Administrat1ve Procedure was issued to 1mplement the Nuclear Division policy on the Lessons Learned Program.
As a res'ult of the progress made on these NIP items, some of which are Prior1ty 3, the Nuclear Div1sion's capability to implement an integrated and cons1stent problem solving process will continue to improve.
Future self-assessment of the problem solving process is scheduled to be conducted by the Independent Assessment
- Group, The responsibilities of this Group are discussed in Chapter V.
At the Panel's September 1,
1989 meeting, there was a discussion of the radwaste sp111 which occurred 1n 1981.
The Panel determined that the Company should have immediately focused management attent1on on the problem/ in order to exped1te the cleanup.
The Panel concluded that the current management attitudes would not allow a sim1lar delay in addressing a comparable problem.
The Panel Chairman directed the line organization to perform a root cause analys1s of why the spill was not cleaned expedit1ously; the analysis is to be completed before restart.
Should this analysis indicate there are additional management effectiveness issues not already covered by the Underlying Root Causes of the
- RAP, a separate NIP item w111 be added to address required corrective actions.
Additionally, cleanup of the radwaste sp111 will be added to the NIP as a separate 1tem for greater visibility.
As a result of the Panel's discussion of Specific Issue-l8, the 125 VDC
- system, the Panel Chairman directed the VP-Nuclear Engineering and Licensing to have his organization perform a root cause analysis of why SI-18 had not been closed earlier.
The result1ng root causes will be checked to confirm that they are covered by remedial action already underway.
The analysis w1ll also be used as a case study for management train1ng in the Nuclear Eng1neering Department.
3.
ORGAN IZATIONAL CULTURE The results of th1s assessment 1ndlcate that the culture of the Nuclear Divis1on 1s changing as evidenced by the adoption and use of the vision, goals and Standards of Performance by the upper levels of the Nuclear Divis1on organizat1on.
The specific actions that remain to be completed before restart are ident1fied in Appendix 4.
The following paragraphs summarize the s1gnificant correct1ve action results identified by the assessor's observat1ons, interviews and document reviews.
The Panel has determined that there are s1gnificant actions and behav1ors wh1ch demonstrate a positive change in culture as 1t pertains to the needs of employees.
The Panel concludes that the s1gnificant progress and results ach1eved in this area support the restart of Un1t l.
Early assessments of the five Underlying Root Causes, 1n the aggregate, concluded that progress was not yet satisfactory.
From an organ1zational culture po1nt of view, that unsat1sfactory grade prompted management to focus add1tional attention on making the management style changes needed to correct the def1c1enc1es 1dent1fied 1n the RAP.
On a more specific basis, there are Hanagement By Walking Around (HBWA) programs at several levels in the organization.
Dur1ng interviews, employees expressed recognit1on of the changed behav1or of their bosses (seeing him or her more often),
and appreciated the opportun1ty to interact with the boss in the work place.
HBWA is being advocated and modeled from the top of the organization.
A number of those interviewed noted the trend toward a more participative management style.
One person said that a year ago the attitude was "I am the
- boss, do 1t my way", wh1le th1s same person now feels that 1nput is solicited and given due consideration.
- Recently, a represented clerk was sent to a trade show 1n Cal1fornia since she was the person who would be able to best use the tnformat1on gathered at the show when new equipment was purchased; historically, a higher level employee would have gone on such a trip.
In this case the most appropriate person went.
Heet1ng observations indicate that the concept of self-assessment lias been widely accepted and is be1ng practiced throughout the organization.
Hanagers are being critical of their own performance; they are seeking input on how they and their groups can improve.
The results of interv1ews and other observations 1ndicate that communication has improved.
The semi-annual Town Hall meetings have given every Nuclear D1vision employee the chance to hear the Executive VP set the tone for improved teamwork and the use of the chain of command to disseminate information to the employees.
In the other direction, the attitude being fostered 1s to not )ust complain to others about a problem, but to tell your boss about it and get involved in the solut1on.
In spite of the work still remaining to get Unit l ready for restart, the Executive VP is trying to heighten the awareness of management as to quality of life aspects.
There is now a rule that if a direct report to the Executive Vice President must work after 6 p.m. or more than four hours on weekends, he or she must write the Executive VP a letter explaining why that many hours must be worked.
It 1s hoped that by example the leaders will show that the work can get done without spending every waking hour on the job.
A very important observation of the cultural change is that significant changes are being modeled at the department head level; these people are the role models for the entire D1vis1on 1n their display of teamwork, self-assessment, and their.dedication to the pursuit of excellence, This unified support at the top of the organizat1on will solidify these desirable cultural changes.
Nhile progress on chang1ng the culture has been very encouraging, there is still one area wh1ch can use improvement.
Hid to upper levels of the Nuclear Division still spend significant amounts of t1me in meetings resulting in less t1me ava1lable to work w1th the1r employees and show a greater interest in them as people.
The need for these meetings should decline as the many restart 1ssues are closed, and as the management style shifts to HBHA wherein many topics can be resolved without the need for a formal meeting.
4.
STANDARDS OF PERFORMANCE AND SELF-ASSESSHENT The results of th1s assessment ind1cate that the Nuclear Division and support organizations have identified and effectively ccemunicated the Standards of PerFormance.
Interview results indicate a high awareness of the Standards of Performance, and meeting observations have noted many examples of management modeling the Standards of Performance.
In addition, meeting observations and interview results reflect an increased awareness and use of self'-assessment processes.
The specif1c act1ons that remain to be completed before restart
are identified in'Append1x 4.
The following paragraphs summarize the significant correct1ve act1on results ident1fied by the assessor's observations, interviews and document rev1ews.
The Panel concludes that the effectiveness of the corrective actions in this area supports the restart of Unit l.
Standards of Performance with emphasis on ach1eving results have been identified and communicated to all levels of employees.
The results of interviews ind1cate that many organizations have conducted staff meet1ngs to discuss how the Standards of Performance can be utilized and measured in their functional areas.
Some managers have already incorporated Standards of Performance into the performance planning process.
The Town Hall meetings held in early June focused on model1ng the behaviors set forth in the Standards of Performance.
Many employees are indicat1ng they feel the Standards are be1ng modeled and fellow employees are working hard to improve in these areas.
Plans have been developed for implementation of supporting Performance Standards within ma)or departments.
A comprehensive self-assessment program to assess readiness for restart has been conducted as described in this report, Progress has been demonstrated on the establishment of a long-term Nuclear self-assessment process with the format1on of the Independent Assessment Group.
This Group, discussed further in Chapter V, will address the integration of its efforts with existing self-assessment functions.
Observat1ons and interv1ews indicate that there has been an improvement of the awareness for and increased use of self-assessment processes.
At the Direct Report level, for example, period1c self-assessments deal1ng w1th the management effectiveness issues are continuing.
Evidence of understanding of the self-assessment function has emerged among the Middle-level Managers.
Many managers are using the self-assessment forms 1n the1r organizations and performing self-assessments of periodic staff meetings.
A Nuclear 01vision policy has been issued wh1ch defines responsibility for contractor oversight.
In summary, the Nuclear Div1sion has set forth its expectations in terms of the Standards of Performance and is holding 1ts employees accountable in terms of self-assessing against these expectations.
The Independent Assessment Group will continuously monitor this area to help assure that this improvement will be a long-term cultural change.
5, TEAMWORK The results of this assessment indicate that s1gnificant progress toward teamwork has been made as evidenced by individuals and groups effectively work1ng together to make dec1sions and solve problems.
The specific actions that remain to be completed before restart are identified in Appendix 4.
The following paragraphs summar1ze the significant corrective action results identified by the assessor's observations, interviews and document reviews.
The Panel concludes that the significant improvement in effective teamwork within the Nuclear Divis1on and supporting organization supports the restart of Unit 1.
Interview results indicate that Nuclear 01vision employees, from the Executive Vice President to the worker level, are aware that effect1ve coordination, communication, and cooperation are essent1al to meeting the Nuclear Division vis1on and goals.
Virtually every interviewee reported that teamwork has improved dur1ng the past year.
Examples of good and bad teamwork are regularly discussed at meet1ngs of all levels of workers.
Contributions of 1nd1vidual team members are also being recognized, both at meetings and through memoranda.
Postt1ve behavior that was prev1ously taken for granted is now being recogn1zed as a model for good teamwork.
What teamwork isand 1s notis also becoming more evident to Nuclear Division employees.
In the past, various Nuclear and non-Nuclear groups were accused of lack of teamwork.
In some cases this was true, but in many others the problems stemmed from lack of effectiveness and not a lack of teamwork.
These groups have always wanted to cooperate, but may not have had the training, resources, or skills to meet the expectations of others.
Many of these "teamwork" problems are now being solved by better definition of roles and responsibilities, by additional resources, and by training.
Nuclear Division employees realize that 1t is important that all affected parties contribute to decision-making and problem-solving.
The most important element of this process is t1mely feedback to all who provided input, regardless of whether or not this input supported the ultimate decision or solution.
Based on the results of assessment interviews, this feedback process still has room for continued enhancement, especially at the supervisor/worker level.
While this assessment has concluded that the necessary teamwork has been achieved, it cannot be emphasized strongly enough that all of the efforts currently taking place to enhance and sustain the improvements in teamwork over the long term must continue.
Open and honest cooeunication in both directions and a participat1ve style of management are crucial to the successful startup of N1ne H1le l and to the ultimate ach1evement of the Nuclear Divis1on vision and goals.
- Teamwork, along w1th the other four Underlying Root Causes, will be a priority topic for the Independent Assessment Group work plan.
B, The results of the assessments for the Specific Issues indicates that the corrective act1ons have been effective and prov1de management with assurance that these issues concerning operator training and qualification, admin1strative
- process, and hardware def1cienc1es will not have an adverse effect on safe plant operation.
The specific actions that remain to be completed before restart are identif1ed in Append1x 4.
The following paragraphs suaxnarize the significant corrective action results identified by the assessor's observat1ons, 1nterviews and document reviews.
l.
Outsge Nana9eeent Oversi9ht The results of interv1ews and observat1ons ind1cate that the interim outage management organizat1on is in place and funct1oning effectively.
The required temporary procedures governing closeout of the restart related activities have
been issued and are being used.
The organization has identif/ed all actlvltles needed for restart, executes the scheduling and tracking functions, and provides the Nuclear Division management with the information to make sure that all the required work ls completed accurately.
The permanent organlzatlon has been approved and ls being staffed; that organization will be ln place for the next refueling outage.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit 1
2.
Maintaining Operator Licenses The assessors have observed operating shifts, simulator and classroom training
- sessions, OTPAC and NRC inspection exit meetings.
From these observations, it ls apparent that Operations Management has demonstrated ownership of the requallflcation training program.
The procedure for Simulator Configuration Management has been revised and simulator-plant fidelity differences are being discussed at training sessions.
The conflict between Operations and Training that was previously observed has been resolved.
The number of tralners has been increased.
In general, operators understand expectatlons regarding training attendance and conduct.
The operators have also generally demonstrated a professional attitude in identifying and resolving concerns associated with maintaining their licenses, and they understand and accept rising p'erformance expectatlons.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit 1, 3.
Emergency Operating Procedures Based on operator and instructor interviews, observation of operator performance, and review of lesson plans, training aids, examinations, simulator scenarios, and training records, the operators understand the bases of EOPs and how to enter them to respond to accident conditions, Operators are confident in using EOPs.
Because of the human factor reviews, operator involvement in EOP changes and validation, and changes that occurred at the simulator, operator attitude and understanding have greatly improved, Discussions indicate that the Operation and Training Superintendents complement and support each other ln their tasks There is stronger support by Operations and Training management ln identifying deficiencies.
The Operation Superintendent demonstrates good management in dealing with people, respects the competence of the operators, allows and encourages the operators to learn, and requires strict adherence to training programs.
Simulator exercises have demonstrated the ability of the operators to properly execute the Emergency Operating Procedures.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit l.
4.
Inservico Inspection The assessors reviewed documentation related to this issue and interviewed key individuals involved in the resolution of the issue.
The assessment actions found that the corrective actions are satisfactory.
The inspections and exam packages for the First Ten Year Interval are in compliance with ASME Code and NRC requirements, and all of the required inspections will be completed by the end of the outage.
The interim ISI organization is working well.
Procedures for the disposltlonlng of deficiencies are ln place.
The plan for the permanent ISI organization is described by the Unit 2 procedures where it will next be employed.
In the ISI area, steps have been taken to place contractors under direct Site supervision.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit l.
IV-7
5.
Control of Commercial Grade Items The assessors reviewed documentation related to this issue and interviewed key individuals involved in the control of commercial grade material.
From these assessment
- actions, the Panel concludes that a successful program for controlling commercial grade items has been developed and implemented.
The process is relatively new and personnel are becoming more familiar with the process.
As training and experience are accumulated, efficiency and responsiveness will continue to increase.
Regular meetings are held to facilitate communications among affected organizations regarding potential materials problems.
Niagara Mohawk has been initiating communications with other uti,litles to share experiences and data, and to explore the potential for cooperative ventures in commercial grade items procurement.
These activities provide strong assurance that recurrence of this concern will be prevented.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit l.
6.
Fire Barrier Penetrations The assessors reviewed documentation related to this issue and interviewed key individuals involved ln the resolution of the issue.
The assessment actions found that the corrective actions are satisfactory.
Fire Barriers and Penetratlons have been inspected and deficiencies corrected.
The design data base and drawings will be updated.
Surveillance, Breach Permits and other procedures will be revised or prepared to incorporate the RAP corrective actions.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit l.
7.
Torus laii Thinning The assessors reviewed documentation and backup calculations performed by the Company and questioned the adequacy of the data and statistical analyses.
Even though this issue was considered closed by the Company and the NRC, in order to respond to the assessor's
- concerns, the Company performed additional thickness measurements and performed more rigorous analyses on the data.
Interior inspections included visual, photographic, and surface impressions.
Area averaged ultrasonic. measurements of the thickness of each plate making up the bottom mid-bay portion of 20 torus bays were taken.
The analyses concluded that the torus wall thickness ls adequate for more than the next operating cycle.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit l.
8.
Serai Discharge Vol~
The assessors reviewed the documentation related to this issue and interviewed key individuals involved ln the resolution of the issue.
Policies and procedures governing cotNIltments are being revised to assure they are effective in addressing the need to obtain formal NRC concurrence with Niagara Mohawk actions with respect to exceptions to new or revised regulations.
A test procedure to validate the adequacy of the scram discharge volume was
- prepared, and the test was acceptably performed.
Procedures for tracking of NRC comn1tments on the Nuclear Ccemitment Tracking System were issued.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit l.
9.
Emergency Condenser and Shutdown Cooling Valves The assessors reviewed documentation related to this issue and interviewed'ey 1nd1v1duals 1nvolved in the resolution of the issue.
The assessment actions found that the NRC and Niagara Mohawk have agreed on the resolution of all Append1x J issues, N1agara Mohawk has received exemptions for testing the emergency condenser valves and the shutdown cooling systems valves.
A procedure to provide a water seal for the containment spray valves has been prepared.
IST personnel verified that all items determined to be IST 1ssues were being tested in accordance with the IST program.
For the lonj term, an Appendix J program plan is being developed to address all'aspects of Appendix J
and is to be administered by a specific department.
The Panel concludes that the effectiveness of the correct1ve actions in this area support restart of Uni t 1.
10.
" Reactor Vessel Pressure/Temperature Curves The assessors rev1ewed the documentat1on related to this issue and interviewed key individuals involved in the resolution of the issue.
The assessment actions found that Niagara Mohawk notified the NRC of the possible discrepancy in the reactor vessel pressure/temperature curves 1n a letter on June 16, 1988.
Included in th1s letter was a suomary of the 1nformation available to N1agara Mohawk.
The NRC performed a safety evaluation, transmitted to Niagara Mohawk on September 14, 1988, that concluded that the pressure-temperature limits are conservative and acceptable.
For the long term, Niagara Mohawk has established a program and engaged a contractor to determine the identity of the test mater1al in the surve11lance program and the ab1lity to ]ustify less conservative pressure/temperature limits.
The Panel concludes that the effectiveness of the corrective actions in th1s area support restart of Unit 1
11.
Erosion/Corrosion Progrm The assessors reviewed documentation related to this Issue and interviewed key individuals 1nvolved 1n the resolution of the Issue.
The assessment actions found that pipe wall thickness measurements have been made under the erosion/corrosion program.
These measurements 1ndicate that all locations inspected are with1n acceptable limits or have been evaluated against specif1c loading criteria, and have included pro)ected thinning during the next operat1ng
- cycle, and found acceptable.
Relevant procedures have been revised to address cons1stent mark1ng of piping and components to assure repeatability of measurement locat1on.
A surve11lance of the contractor's grid marking activities was conducted during the current outage.
The surveillance confirmed that grid layout spacing and or1entation were correct.
The Unit 1
basel1ne measurements have been made.
The Panel concludes that the effectiveness of the correct1ve actions 1n th1s area support restart of Unit l.
12.
Motor-Generator Sot Battery Chargers The assessors reviewed documentation related to th1s Issue and interviewed key ind1viduals involved in the resolution of the Issue.
The assessment actions found that the MG set battery chargers have been class1fied as safety related and the Q-list has been updated.
A lessons learned transmittal, detailing the concern and caut1onary statements about using inadequate documentation, has
been issued and reviewed by personnel who perform safety class determinations.
A task force reviewed and found acceptable the Appendix B
determinations that had downgraded systems or components.
Procedures for performing Appendix B determinat1ons have been augmented to provide guidance on technical aspects of the process.
Personnel who will be performing Appendix 8 determinations have been identified and have reviewed the lessons learned transmittal on the process and procedures.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit 1.
13.
18C Technician AIIegation Issue The assessors reviewed documentation related to this issue, interviewed key individuals involved in the resolution of the issue and also surveyed indiv1duals and observed meetings.
The long-term management effectiveness programs which resulted from the I&C Technician Allegations were incorporated in the RAP and most of the corrective actions associated with this issue are duplicated elsewhere in the RAP.
In order to determine if the RAP corrective actions were effective regard1ng implementation of these
- programs, the assessment focused on the area of problem solving and associated communication issues.
The assessor found that there was a consensus that significant 1mprovement had been made in problem solv1ng.
Although there 1s room for improvement in commun1cation, part1cularly between on-site and off-site
- groups, there 1s ev1dence of s1gnificant effort and improvement 1n teamwork and communication.
The Panel concludes that the effectiveness of the corrective actions 1n this area support restart of Unit l.
14.
Safety Systew Functional Inspection The assessors reviewed documentat1on related to this Issue and interv1ewed key indiv1duals involved in the resolut1on of the Issue.
The assessor noted that the required calculations and analyses have been completed and are adequate to resolve the concerns ra1sed 1n the NRC's Safety System Functional Inspection.
Necessary modifications required before restart and set point changes resulting from the calculat1ons and analyses have been 1nit1ated and will be completed pr1or to restart.
Procedures and specif1cations have been revised to strengthen the control of des1gn configurat1on in order to prevent future deficienc1es.
A comprehensive plan for design basis reconstitut1on is 1n place.
The Panel concludes that the effectiveness of the corrective act1ons in this area support restart of Unit l.
15.
Cracks in Walls and Floors The assessors rev1ewed documentation related to th1s issue and interviewed key indiv1duals 1nvolved in the resolution of the issue.
The assessment actions found that correct1ve actions are satisfactory and agree w1th the previous evaluations:
the cracking in reinforced concrete is typical for structures of this construction and type, and are not of structural concern.
The cracking does not affect load capacity or serviceability, and the identified root causes do not indicate ongoing problems or future concerns.
A program for identifying, mapping, and assessing any add1tional cracks in concrete is planned under the Nuclear Improvement Program.
The Panel concludes that the effect1veness of the correct1ve act1ons 1n th1s area support restart of Unit l.
16.
feedwater Homilies The assessors have observed that the examinat1on requirements are documented, the procedures used to conduct the examination are adequate, and the personnel using them were effectively tra1ned on their application.
The assessor reviewed the exam records for each of the five inspections.
The method of evaluating 1nd1cations was found to be appropriate and the calculations accurate.
The crack growth calculations were revised and updated to include recently ident1f1ed 1nd1cat1ons.
The assessor found these calculations to be well founded and complete.
The calculations conclude that all indi't;ations are within the limits established by NMPC and Code Criteria.
The Company will submit the Second Ten Year Interval ISI Program Plan six months prior to the next refueling outage.
The requirement for full nozzle inspection per NUREG 0619 has been appropriately addressed and documented.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit 1.
17.
Inservice Testing The assessors reviewed documentation related to th1s 1ssue and interviewed key ind1viduals 1nvolved in the resolution of the issue.
The assessor determined that the NMPl Second Interval IST Program is acceptable and is 1n compliance w1th the regulatory codes and standards.
A consultant was hired to do an 1n-depth rev1ew of the Core Spray and Reactor Bu1lding Closed Loop Cooling systems as regards in-service testing requirements.
The consultant's report concluded that the program 1s acceptable and in compliance with regulatory codes and standards.
The report was used as part of the bas1s for the assessor's overall positive f1ndings.
The assessor noted that the NRC has given interim approval for both the IST Program and the included rel1ef requests.
The Adm1nistrat1ve Procedures are being revised to properly admin1ster the program and to mainta1n the program relative to future design and/or L1censing changes.
The Panel concludes that the effectiveness of the corrective act1ons in this area support restart of Unit l.
18.
126 VDC Systee Concerns The assessors reviewed documentation related to this issue and interviewed key individuals involved in the resolution of the 1ssue.
The assessor determined that the scope and content of the corrective act1ons are such that the technical deficiencies in the area of control circuit voltage drop and insuff1cient battery capacity w111 be resolved by appropr1ate plant modifications and procedure revisions.
Calculat1ons and analyses performed to support the resolut1on of the technical deficienc1es were acceptable and appropriately rev1ewed and approved by management.
Battery test1ng requirements have been determ1ned and documented.
Required tests have been scheduled to be conducted prior to restart.
The Panel concludes that the effect1veness of the correct1ve actions in this area support restart of Unit l.
C.
Management has developed and issued functional organization charts which establish and commun1cate responsibilit1es.
Management ob)ectives have been established and communicated to the staff, and management has initiated an MBWA program to 1mprove visibility and responsiveness in the workplace.
In
- addit1on, physical plant progress has been s1gnificant in areas such as reduct1on in outstanding work requests, maintenance
- items, and system readiness for operability.
Identification and monitoring of regulatory issues related to restart and safe operation (including Technical Specification amendments necessary for restart) are adequately controlled by Licensing.
In spite of the work still rema1ning to complete the Restart Corrective Actions and to get Unit 1 ready for restart, 1t appears that the overall program is well controlled and processes are in place to sufficiently address each of the NRC Restart Guidelines, The Panel concludes that the effectiveness of the corrective act1ons in this area support restart of Unit l.
IV-12
PREVENTING'ETECTING, AND CORRECTING FUTURE PROBLEMS The Restart Self-Assessment has resulted in the conclusion that Niagara Mohawk has the management and leadersh1p skills to prevent, or detect and correct, future problems.
The informat1on that supports this conclusion is contained in Chapter III and the appendices to this report.
In particular the assessment found that the Nuclear Division and support groups have adopted h1gh standards of performance which are being demonstrated in the 1dentification and effective resolut1on of problems.
The assessment also found that the correct1ve actions, such as "in-line" training, had 'improved the effectiveness of plann1ng and teamwork in making decisions and solving problems related to performance limiting deficiencies.
Finally, the assessment ident1fied programs and policies that had been developed to continue to enhance the assessment and improvement of the activities of the Nuclear Division.
This section of the report briefly describes some of the add1t1onal act1ons Niagara Mohawk is taking to enhance its ability to prevent, detect and correct future problems.
The programs d1scussed below are part of the Nuclear Division and supporting groups/organizations ongoing activities.
The Nuclear Improvement Program includes act1ons to develop a long-term assessment program for preventing, or detecting and correct1ng, future defic1encies that could )eopardize safe operation of our nuclear power plants.
This section of the report discusses the following major elements of the long-term assessment program:
Expanding the exist1ng assessment programs and 1ntegrating into them the concepts established during the restart effort; Establishing a separate functional assessment group; and Cont1nuing the general pract1ce of internal assessment act1vities while the permanent program is being established.
A.
A key element of the assessment program 1s to enhance exist1ng programs by incorporat1ng into them specific inter-and intra-departmental assessment activities.
Expanding existing programs is an evolutionary process, which is often more readily accepted than new programs that 1ntroduce revolutionary change from established pract1ce.
The follow1ng are two examples of program enhancements already under way:
Cceeitment Follow-up (under Nuclear Compliance and Verification) - to ensure continued implementation and effectiveness of commitments made to senior management, the
- NRC, INPO and other agencies.
Annual Strategic Assessments compare current and past performance to 1dent1fy strengths and weaknesses; identify internal and external 1nfluences on the Nuclear Division and the nuclear industry; and identify strategic init1atives for Nuclear Division Planning.
B.
The IAG is a small group reporting to the Executive Vice President Nuclear Operations.
This group conducts or facilitates independent formal, special, and 1nformal assessments of critical areas of Nuclear Division and support group programs and activities.
The assessments will help to identify strengths, weaknesses and deficiencies.
Reports will be presented to the Executive Vice President - Nuclear Operations and affected managers.
The need for improvements w111 be identified and presented to line 'management for appropr1ate action.
IAG personnel will not have line management or organization respons1bilities or have direct funct1onal responsibility in areas being assessed.
Their most important function will be to evaluate and encourage the self-assessment process within the team organization.
Specific areas of'ssessment will be operations and maintenance; technical support and engineering; radiation and environmental protect1on; support.
programs; and overall management and organizational effectiveness, such as, communication, team-building and leadership.
C.
The term "self-assessment",
as used in Niagara Mohawk's Nuclear Improvement
- Program, refers to assessment activities conducted internally by responsible members of a department or group.
Such internal assessments may be supported by contracted individuals or groups as needed.
Self-assessment activities can include:
Meeting evaluations, conducted after meet1ngs to identify strengths, weaknesses, and defic1encies, w1th recomnendations for improvement.
Meekly progress evaluations, conducted at week's end to identify strengths, weaknesses, and deficiencies, with receaaendations
- for, improvement.
Assessment of the effectiveness of corrective act1on results and their continued 1mplementat1on.
Development of performance indicators for monitoring performance and trends.
Evaluation of trends to determine acceptable performance levels and needed correct1ve actions.
Mon1toring department performance 1n comparison w1th goals, ob]ectives, and action plans.
Comparison of programs and performance with industry standards and averages.
The SRAB 1s establ1shing an ongo1ng method for cont1nually assessing the effectiveness of the Nuclear Improvement Program.
V-2
RESTART READINESS REPORT September 8,
1989 APPENDIX 1
GLOSSARY OF TERHS Action Plans - Detailed sequences of steps and resource requirements that describe how an individual will accomplish the ob)ectives for which he is responsible.
Assessment Program
<also Nuclear Assessment Program)
The aggregate of short-and long-term programs for evaluating the completeness and effectiveness of restart corrective actions, and to prevent, or detect and correct, future deficiencies.
The overall program employs self-assessment
- programs, assessors and panels, and will incorporate approved assessment practices into existing Nuclear Division programs.
Basis)
<also Restart Basis) - A description of the state expected when sufficient progress toward achievement of the Corrective Action Ob)ectives had been achieved.
Buy-In (also Subscribe to) - Ownership by personnel directly affected by a decision or set of actions.
Buy-in is achieved by involving people in decision-making or action development ln a manner that promotes their awareness, acceptance, and support (agree with the logic and feasibility of the decision or action).
Corrective Action (also Restart Corrective Action) - Heasures undertaken to resolve the cause(s) of identified deficiencies.
The Restart Corrective Actions for Nine Hlle Point 1 are delineated ln the Restart Action Plan, Corrective Action Objective - A general statement of desired level of performance to be achieved before restart, or, if explicitly stated, over a
period of time after restart.
Post-restart aspects of contlnulng issues are addressed ln the long-term Nuclear Improvement Program (NIP).
Executive Officers - Niagara Hohawk's Chief Executive Officer (CEO),
President, and Executive Vice President - Nuclear Operations Goals - Goals are specific targets, or milestones, to be achieved within established time frames, ln support of reaching designated ob)ectives.
In-Line Training - Informal training accomplished while performing work.
In-line training can involve organizational development experts who provide management coaching; facilitate staff meetings for discussion of good management practices; lead specific management and leadership skills sessions; and reinforce good management practices, as demonstrated by effective role models.
The concept involves learning by precept and example, including Standards of Performance implementation.
Independent Assessment Group (IAG) A small group of emplo'yees
<reporting to the Executive Vlcc President Nuclear Operations) that conducts or facilitates independent assessments of critical areas ln the Nuclear Division.
" The IAG will continue to function after restart.
Integrated Team - A designated group of managers representing key organizational functions associated with operating and supporting Niagara Mohawk's nuclear power plants.
Line Nanagement or Organization - Managers or elements of organizat'ions having direct responsibility and accountability for specific functions associated with managing and operating Niagara Mohawk's nuclear power plants.
These terms include support groups such as Purchasing and Materials Management.
Management Review Groups
The Site Operating Review Committee (SORC) and the Safety Review and Audit Board (SRAB). These review groups are normally responsible for the review and approval of safety and operational issues.
For this'Report, the management review groups are discussed in the context of restart corrective action assessments.
Nanagers - A generic term generally referring to lndlviduals having supervisory responsibility.
See also Line Management and Mid-level Managers.
Nid-level Nanagers - First level of line management.
Mid-level managers directly report to Senior Managers, and usually have one or more levels of management reporting to them.
Nlssion - The reason for an organization's existence, including who is served inside and outside the organization, and what is to be done for them.
Nuclear Division - The Niagara Mohawk organizational elements that administratively and functionally report to the Executive Vlcc President-Nuclear Operations.
Nuclear Improveeent Program (NIP) - The organized effort to improve Nuclear Division and support group performance, including the corrective actions to be completed before and after restart.
The Restart Action Plan (RAP) is the short term portion of the NIP, comprlslng the corrective actions to be completed,
- resolved, or adequate progress
- shown, before Unit 1 restart.
Nuclear Oversight Coeeittw (NOC) - A ceanittee of Niagara Mohawk Directors, including the Executive Vlcc President - Nuclear Operations, which is responsible for overseeing nuclear operations.
Operational Rosponsibiiities - A brief description of the overall responsibilities of an organization.
Organizational Culture The mind-sets, attitudes, and approaches shared by the individuals who, together, comprise an organization; the collective conduct and behaviors that uniquely characterize an organization's method of doing business.
When clearly verbalized, and effectively disseminated and administered, the vision, mission, goals, and Standards of Performance established by upper management are assimilated by the staff ln general, and are incorporated into the Organizational Culture.
Performance indicators Observable measures or attributes that reflect how well the vision statement, mission statement, critical issues, or ob)ectives are implemented, Performance Standards - The set of administrative, department-level, standards for day-to-day conduct, taking into account the specific needs dictated by departmental functions.
Performance standards
- support, and are collateral to, division level Standards of Performance.
In this Report, "performance standards" is in lower case to differentiate the term from Standards of Performance.
(See also Standards of Performance.)
Priority of Corrective Action - An assignment of importance for specific corrective actions related to Unit 1 corrective actions.
For example, Completion of Priority 1 corrective actions (or demonstrated sufficient progress) ls a prerequisite to restart.
(See RAP Appendix C for more details.)
Report on Restart Readiness (RRR) - This document containing the results of Niagara Mohawk's restart-readiness assessments and )ustiflcation for permitting Nine Hile Point Unit 1 to be restarted.
This Report was prepared in response to Confirmatory Action Letter (CAL) 88-17, action number 3.
Restart Action Plan (RAP) - The restart action plan (and document so titled) comprises the short-term portion of Niagara Mohawk's Nuclear Improvement Program (NIP). The RAP addresses actions 1
and 2 of CAL 88-17 ln addition to near-term performance improvement measures.
Restart Readiness Self-Assesswent The aggregate of'll assessments performed by Niagara Mohawk, including assessments by Niagara Hohawk's line organizations, independent Niagara Hohawk assessors, and external
- groups, to determine overall readiness for restart and safe operation, including progress toward long-term improvements in overall effectiveness.
(See also Seif-Assesseent)
Restart Review Panel (RRP) - A special panel of individuals chartered by and reporting to the Executive Vice President-Nuclear Operations.
The RRP ls charged with assessing and reporting the adequacy of performance improvements achieved through the Restart Action Plan.
The intent of the Panel's assessment is to establish a high level of confidence in Niagara Hohawk's readiness for Nine Hile Point Unit 1 restart.
Restart Review Panel Support Staff - A group that supports implementation of the Restart Review Panel's assessment activities.
The RRP staff consists of Company employees and supplementary consultants, headed by a full time Director who reports to the RRP Chairman.
Restart Task Force - A group chartered to consult with line management on developing the Restart Action Plan and facilitating its,development and initial lmplementatlon.
(See RAP Appendix A for more details.)
Safety Review and Audit Board (SRAB) - A board that provides independent review and audit of designated activities in nuclear power plant operations, nuclear engineering, chemistry and radiochemistry, metallurgy, instrumentation and control, radiological safety, mechanical and electrical engineering, and quality assurance.
Specific responsibilities of the SRAB are detailed in the Technical Speclficatlons.
Self-Assessment As used in the Nuclear Improvement
- Program, assessment act1v1ties that are carried out internally by responsible members of a Niagara Mohawk department or group, supplemented as needed by supplementary groups or individuals.
(See also Restart Readiness Seif-Assessment)
Senior Managers In the Nuclear Division, the Executive Vice President-Nuclear Operations.
and the individuals reporting directly to him.
(Hhen the term "direct report" is used in th1s Report, it refers only to the latter.)
Site Operations Review Committee (SORC) - The committee to advise the General Superintendent Nuclear Generation on nuclear safety issues.
Specific responsibilities and compos1t1on of the SORC are detailed in the Technical Specification.
Standards of Performance - The set of Nuclear Division values for measuring conformance with expected personnel performance in the conduct of Company bus1ness.
In this Report, the term is capitalized to differentiate it from "performance standards."
(See also Performance Standards.)
Support Groups Organizations that support management and operation of the nuclear facilities, but do not administrat1vely report to the Executive V1ce President - Nuclear Operations.
Examples are Purchas1ng, Materials Management, and Employee Relat1ons.
Target - A qualitative, non-absolute, measuring cr1ter1a used to determine when a Bas1s (Restart Basis) had been met.
Underlying Root Cause - A cewen or programmatic cause for general observed deficiencies.
An underlying root cause contributes to other deficiencies, but no other cause directly underl1es this basic defic1ency.
Verification Action - Measures taken to conf1rm that a corrective action has been sat1sfactor11y 1mplemented or completed.
Vision - The overall long-term expectat1on for an organ1zation, as promulgated by senior management.
Al-4
NINE MILEPOINT UNITONE RESTART READINESS BASES 8i TARGETS MATRIX BASES 8c TARGETS ESUL METHODS SURVEYS IHltRTlKTSk 0RiERVLTION5 m
Vl 3)
Z0x m
IV Pg mU0 37 ISSUE 4'1 REV 4'0 6/21/89 SSUED BY EDWAADF. HOFFM AESTAATASSESSMENT STAFF DIAECTOA
EEERUIEQ GE 8EKKl 0hKR IV NESS 6RQ21EHI @Ed L'KEIUMHE =~ EKEI 42K I HEY ~DS 21.1989 eEIEr,mL dSKRKE Ej5IE 6 ELBE)II% Qk SR'Hanagement will have assessed critical issues within the Nuclear Division and facing the nuclear industry. Based on this assessment and in support of Corporate Hission and goals manage.
ment shall have characterized and c~icated the direction for the Nuclear Division through vision, mission, and goal statements.
Hanagers can deploy their resources consistent with the ND vision, mission,
<<nd goals to provide assurance that plant operations will be conducted in coapliance with regulations and in ~ safe and reliable marner."
L ELEilEIER ERR SR'The management tasks of planning and goal setting have not kept pace with the changing needs of the Nuclear Division and with changes within the nuclear ndustry a DIVLSlON SPNSORT SKIP STUART 1.
a).
b) c)
d) e)
2.
a) b)
c) d)
e) 3.
a) b)
c)
TARGETS FOR CAO 'l.1 Restart Corrective Actions adequately support the Corrective Action Objectives and objectives adequately address desired change in performance.
All Restart Corrective Actions which address CAO 1.1 have been iaplemented and verified.
Hanagement will have reviewed recent SALP and lNPO evaluations to judge how NHPC rates coapared to the rest of the nuclear industry.
This review will be factored into the vision, mission, and performance expectations docuaents.
Nuclear Division eaployees are a~are of and familiar with the Nuclear Division vision, objectives,
- goals, and standards of performance.
Senior management understands the current 1989 planning process, agrees with it, and is using the Nuclear Division vision, objectives,
- goals, and standards of performance Hanagers understand the reason for incorporating the Nuclear Division vision, objectives,
- goals, and standards of performance into their department's ptaraIng process.
Supervisors are aware that there are N.O. Vision, objectives,
- goals, and understands the linkage between these and the standards that iapact their department.
Morkers are aware that there is a vision and mission and how their department's goals and individual performance supports the vision and mission Necessary policies and procedures have been developed/revised and are in place and training has been planned, as required, to begin using the 1989 Nuclear Division vision and goals as a basis for the current planning process.
TARGETS FOR CAO 1.2 All Restart Corrective Actions which address CAO 1.2 have been isplemented
<<nd verified.
Eaployees involved in inputting to and maintaining the Nuclear Coaraitment Tracking System have been trained on the program and are a~are of and respond to the needs of its users.
A person is assigned the responsibility for and held acccxatable for notifying the appropriate Nuclear Division department head that a coaaitment date has been missed.
Restart Corrective Action products are being used to plan and schedule Nuclear Division activities and have iaproved the process.
The policy and/or procedure (which includes who has the responsibility and the authority) for establishing priorities has been clearly defined, is in place and has been coaaanicated to appropriate personnel.
Actions have been identified or a program has been developed to iaplement a planing and scheduling process that defines specific performance objectives, assigns responsibilities and priorities, and integrates and aligns the activities.
Accantabi lities and schedule have been specified for iaplementing these actions TARGETS FOR CAO 1.3 Restart Corrective Action 1.3.1 has been iaplemented argf verified.
The definition of and process for strategic and tactical planning has been specifically docuaented and coarmjnicated.
Accountabi lities and schedule have been specified.
Actions have been identified to develop and iaplement a coaprehensive Business Planning Process.
FRED LARGE
L ISllt5QKIiI68Q QERHDHlQHhl EEEEHiKNEK INURE 1 IIB Q 8EbkljiEK GE EERIbSI Id'KSl&Sly MS EfbkljlERR QR KKLEI IhEKLi Q8KIBZUIQ EQK QllK 551K R MRLEI KLYLER "Past and current performance limiting deficiencies shall have been identified and resolved through the self-assessment of past performance and the Implemen-tation of appropriate corrective actions.
A detailed plan for isplementing an improved problem solving process uith provisions for a) problem identification, b) systematic causal analysis,-c) corrective ection plavling, d) implementation management, and e) assess-ment of results achieved shall be in place and actions in progress to iapiement this plan.
A process based on that used in the development of the restart action plan shall be used until the long term program ia fully in place."
2 HUBBLES KLYBUi
"'Ihe process for identify.
ing and resolving issues before they becose regulatory concerns uas less than adequate in that ther~ was not an inte-grated or consistent pro-cess used to identify, analyze, correct, and assess problems in a timely Nay."
DIVISION SPONSOR:
CARL TERRY 1.
TARGETS FOR CAO 2.1 a)
Restart Corrective Actions adequately support the Corrective Action Objective.
b) All Restart Corrective Actions uhich address CAO 2.1 have been iaplemented and verified.
c)
RCAs have been effective in developing and ispiementing an integrated and consistent intel'lm pl'oblem solving pl ocess
- RCA lessons learned are incorporated in the problem identification and solving process.
- Training consistent uith the individual's role in the application of the problem solving process has been ccepleted and the process is currently in use.
- Corrective actions identified per the process are effective in resolving the Immediate problem and prevent recurrence of the problem.
- The Implementation of corrective actions is subject to foilou up for possible further action.
. The process is being implemented by each affected department.
d)
A long-tera plan has been documented to develop and implement an integrated and consistent problem solving process.
e)
Future self-assessments of the problem solving process are scheduled to be conducted by the Independent Assessment Group.
DICK VOLLEYER
L 8MISiEHEIII hHQ QRMIZHIQHhL EEEEUIYEBEK SEblUHEG DE EEKSI IRKED INVE 1 REY Q E5IR Q QERLHIZbIItEU. QlLHHX There is evidence that the upper levels of the Nuclear Division organization hove adopted and are using the vision, goals, and standards of perforasnce in day to day operations and in addressing eapioyee needs and concerns.
QEQdlIIZHIQ88L QlLQEE "Hansgeaent's technical focus has created an orga-nizational culture that diverts attention auay froa the needs and effec-tive use of eaployees."
DIVISION SPONSOR:
JIN NILLIS 1.
a) b)
c) d)
e) 2.
a) b)
3.
a)
TARGETS FOR CAO 3.1 Restart Corrective Actions adequately support the Corrective Action Objectives and all Restart Corrective Actions uhich address CAO 3.1 have been iapieaented and verified.
Nuclear Division eaployees at all levels of the organization are auare of and faailisr uith the Noveeber 1988 Nuclear Division organizational
- changes, the status of actions on 1988 coaaitaents and the Restart Action Plan.
Eaployee feecbsck on the Restart Action Plan uas solicited, provided and incorporated, as appropriate.
Practices <<xl Policies are in place to isprove aanageaent's attention to eaployee needs, utilization and feecback Nanagers exhibit Iaproved "people" skills such as the listening part of c~ication, and conflict resolution.
TARGETS FOR CAO 3.2 Restart Corrective Action 3.2.1 hss been iaplemented and verified.
Senior aanageaent knocks uhat teea building and coaching skills look like froa a behavioral perspective, they knou uhich ones they need to uork on, and they have individually developed plans for addressing their needs.
In addition they have within their departaents an ongoing process to ensure that tern building and coaching skills, tools and accamtabiiities are in place and used.
TARGET FOR CAO 3.3 Restart Corrective Action 3.3.1 hss been iapieaented and verified.
DICK DALEKE "Standards of perforaance Nith eaphssis on achieving results have been identified, c~icated and plans have been developed for iapleaentation of supporting Perforaance Standards uithin aajor departaents throughout the Nuclear Division; a coaprehensive self-assessaent prograa to assess readiness for restart has been conducted; progress has been deaon-strated on the Iapiematation of the plan for the developaent of the long. tera Nuclear self-assessaent process."
Q QbK655 QE RQEEMK k "Standards of perforaance have not been defined or described suf ficiently for effective assessaent, and self-assessaents have not been consistent or effec-DIVISION SPONSOR:
IIARK PE IFER 1.
a) b)
2.
a) b)
TARGE'IS FOR CAO 4.1 The Restart Corrective Actions associated arith the Corrective Action Objectives have been Iapieaented and verified.
A set of Nuclear Division standards of perforaance uhich are consistent uith the division's vision for excellence exist snd have been c~icated to all levels of the organization.
TARGETS FOR CAO 4.2 An independent assessaent fute:tion is established and integrated uith other assessaent groups in the coepany, i.e.
SRAB, OA.
Self assessaent activity at the depsrtaental and prograaaatlc level has been established and/or iaproved.
Restart Corrective Actions adequately support the Corrective Action Objec.
tives.
L t$$5EHQK &K 958!llhIlQHhi EEEKIDEEER CaaL'Q KQBEI KIH5 MS EfbkUlERR GR EEKLEI MELi lMERLIUlDEQK QtllK I'VE 1 KY 9 RJ5IR 6 Ifb5KIEK "Progress touard effective turk uithin the Nuclear Division as evidenced by uorking together to aoke decisions, to solve problees, and, in general, to 'get the job done correctly and caapletely'.
This progress uili be evidenced both uithin and betueen departsents in the N~iear Division."
IQMSK "Lack of effective teaa.
uork within the Nuclear Division and uith support organizations is evidenced by lack of coordination, cooperation,
<<nd c~i.
cation in carrying out responsibi Iities.
DIVISION SPONSOR:
KIN DAHLBERG Restart Corrective Actions support the ispiaaentat ion of the Corrective Action Objective.
1.
'TARGETS FOR CAO 5.1 a)
The Restart Corrective Actions associated Nith Corrective Action Objective 5.1 have been iaplenented and verified.
b)
A deaonstration that tern efforts have been used in solving three probieas involving awitipie departaents.
c)
A deaenstration that asnageaent is coaeitted to the teaabuilding process and has begun to tronsait the spirit of teamwork through the ranks.
This deaonstration will be evidenced by behaviors uhich praaote open c~ications and by a uiliingness to uork together to attain coeaon goals.
d)
The senior aanagemnt and the Integrated Teaa are avare of shat they do as ~ grip reich prcaotes and iapedes collaboratively getting their uork done.
They are in the process of iapleeenting behaviors uhich reinforce the positive aspects of their uorking together and aanage the negative aspects of uorking together.
e)
A process is in place such that aanageaent and organizational issues are identified, discussed and either resolved or assigned to an ad hoc mlti-departaent tern for resolution (as appropriate).
ANGELA BERNAT
2 ~
P~EC:~ ~SU~
GKMKHIMEd E9iiIIQIIIIjE= LEAK Q5fElRKLL ISSUE 1
REV 0 "Results achieved through I<<piementat ion of Restart Corrective Actions for the RAP Specific Issues shall be suffi-cient to resolve or provide man-agement uith assurance that these issues concerning operator training C qualification, achinis-trative process, and hardware deficiencies will not have an adverse effect on safe plant oper-ations.
GRK%
SI 1
OUTAGE HANAGEHENT OVERSIGHT JQg QgQQ TESS IER S I-2 HAINTENANCE OF OPERATOR LICENSES Qgj QQggg RAIOALL S1.1 S1.2 S1.3 S2.1 S2.2 S2.3 S2.4 The RAP c~itments including text, corrective actions and responses to NRC questions associated uith Outage Hanagement oversight have been implemented and verified.
The Outage Hanagement process is coaprehensiveiy identifying, monitoring Iapiementation, and tracking to completion those activities required for restart.
A plan and schedule has been developed for integrating the Outage Hanagement fuetion Into the permanent Nuclear Division organization prior to the next scheduled Unit 1 refueling Outage.
The RAP Corrective Actions and cecal tments associated uith maintaining operator licenses have been i<<piemented and verified.
Operators demonstrate a professional attitude in identifying and resolving problems
<<nd concerns associated uith maintaining their operator licenses.
A process is in place vhich Mill prevent recurrence of similar issues, and uiII identify and resolve trends that could lead to violating 10 CFR 55.
The job and task analysis for requalification of RO's/SRO's and development of training mteriai based on this analysis is on schedule for completion by July 31, 1989.
C.V. HANGAN JOE LARIZZA SI -3 EMERGENCY OPERATING PROCE.
DURES~ ~ggQ RAIOALL S3.1 S3.2 S3.3 S3.4 S3.5 S3.6 S3.7 The RAP Corrective Actions and caaaitments associated uith Emergency Operating Procedures have been i<<piemented and verified.
The EOP's to be 1<<piamented in an emergency have been verified and validated.
The current set of EOP~s are adequate to assure the Cospany that the plant can be operated uithout an adverse impact on safety.
Adsinistrative processes and procedures are in place to be sure that EOP's, EOP support equipaent, and s~rting procedures are maintained effectively.
All NHp-1 operating creus have been trained in the effective use of and understand the basis for the content of the EOP's, uith respect to their assigned responsibilities.
The requalification program has been enhanced to increase operator skill and proficiency such that operating creus vill maintain a high level of performance in the use of the EOP's.
EOP instructors> qualification and certification records are up.to-date and the process for maintaining these records has been enhanced to ensure that records are maintained current.
There is a process in place for the operators and instructors to collaboratively assess the effectiveness of the EOP training.
JOE LARIZZA t
ANTHONY TOHE
/peQQQ~ (continued)
ISSUE 1
REV 0 EBKIEhi EGEST Sl 4 INSERVICE INSPECTION
~ QQjjQ
'TEAGER SI 5 C(NITROL OF COOKRCIAL GRADE ITEHS~ Qg~g PACE S4 ~ 1 S4.2 S4.3 S4.5 S4.6 S4.7 S5.1 S5.2 S5.3 S5.4 The RAP Corrective Actions and coaaitaents associated uith inservice inspection have been Ispieeented and verified.
The systea boundaries, cosponents and the necessary inspections to satisfy the requireeents of the ASHE Section XI 10 year inservice inspection are clearly identified in a Niagara Hohauk inspection plan for Nine Hile Point Unit 1 (for the past and current 10 year intervals).
All inspections required to satisfy the past 10 year inservice inspection interval have been coapleted.
The interia organization uith the necessary resources as uell as the responsibility and authority to effectively aanage the isplementation of the inservice inspection progroa is in place.
Approved interia adainistrative processes and procedures governing the iapieaentatlon of the inservice inspection program, particularly the disposition of identified deficiencies, are in place.
An appropriately detailed plan and schedule to establish and transition the responsibility for inservice inspection to a peraanent organization is in place.
Persomei in the organization using contractors are faaiiiar uith the processes and procedures relating to control of contractors.
The RAP Corrective Actions and caaaiteents associated uith the control of c~rclal grade item have been ispleaented and veri fied.
Persomei in the various organizations (Haterials Hanageaent, Purchasing, Haintenance, Ouality Assurance, Design Engineering, Operations) knou hou their ftsv:tion contributes to the control of comercial grade iteas and hou to ispieeent proactive steps to resolve probleas associated uith the control of coanerciai grade item.
The permnent staffing of Haterials Engineering and the integration of Haterials Engineering ulth interfacing organizations is proceeding on schedule.
Actions have been taken or are planned that uiii lead to the early identification and resolution of aaterial control probleas in the future.
ANTHONY TONE GLENN NIBLOCK
eEKlflg~ (continued)
ISSUE 1
REV 0 Sl 6 FIRE BARRIER PENETRATIONS fINNERTY S6.1 The RAP ccmaitments including text, corrective actions, and responses to NRC questions associated uith the fire Barrier Penetrations hove been isplemented and verified.
S6.2 The installed configurations of the fire barrier penetrstions are equivalent to those tested and meet the requirements of the fire barrier itself as defined in the fire hazards analysis.
S6.3 An effective process, including trained resources, is in place to monitor ond evaluate the condition of fire barriers.
S6.4 The design basis for fire barrier penetrations is docusented.
Processes and procedures have been isplemented that ensure that this design basis uill be maintained.
C.V. HANGAN S6.5 An effective plan is in ploce to transition the maintenance responsibility for this design basis from the task force to the permanent organization.
SI 7 TORUS MALL THINNING QQf, QggjgiI. fRANGISCO
$6.6 An effective plan is in place to ensure that future audits of the fire protection program ore appropriately coordinated ond folloued up.
S7.1 The RAP Corrective Actions <<nd c~itments associated uith torus uall thinning have been implemented and verified.
S7.2 There is a doc~ted snd scheduled progr<<s for addressing torus eall thinning.
S7.3 NRC Inspections ore being appropriately coordinated and supported.
GLENN NIBLOCK SI.B SCRAH DISCHARGE VOLOK Qg ggggQ FRANCISCO SS.2 SB.3 The organization ond fmctionsl responsibilities associated uith the interpretation, isplementation, ond management of coasitments, as uell as exception requests, is clearly determined ond understood uithin the Nuclear Division.
Persomel understand and ioplement related policies.
S5.1 The RAP Corrective Actions and c~itmnts associated uith scr<<s discharge volt<<e have been implemented
<<nd verified.
Sl 9 APPENDIX J - TESTING OF EHERGENCZ CONDENSER AND SHUTOSNI COOLING VALVES FRANCISCO S9.1 The RAP Corrective Actions and caasitments associated uith Appendix J testing of valves hos been Implemented and verified S9.2 A schedule exists for implementing the program for satisfying schedular exceptions taken to Appendix J.
S9.3 A process is in place uhich vill assure the Company that the scope ond content of the Appendix J testing progr<<s is maintained current snd Isplemented in accordance uith the NRC Appendix J safety evaluation and Technical Specifications.
TOH ROHAN
~~ ~~ <continued)
ISSUE 1
REV 0 Sl-10 REACTOR PRESSURE VESSEL PRESSURE/TEHPERATURE CURVES
~ gg~Q FRANCISCO S10.1 The RAP Corrective Actions and coamitments associated uith Reactor Pressure Vessel P/T Curves have been ispiemented and verified.
S10.2 There is a doc~ted, and scheduled program for developing correct data for refining the P/T curves to be consistent uith the actual vessel conditions.
Obtaining the Technical Specification changes should also be addressed in the schedule.
GLENN NIBLOCK SI.11 EROS INI/CORROSION PROGRAH JQg ~ggg HARSHALL S11.1 The RAP Corrective Actions and casaitments associated uith the Erosion/Corrosion Program are implemented and verified.
S11.2 Contractor procedures and instructions are clear.
S11.3 Appropriate contractor oversight actions are being effectively Ispiemented.
GLENN NIBLOCK SI -12 HOTOR GENERATOR SET QATTERY CHARGERS
~ Qg~g SKM S12.1 The RAP Corrective Actions and ccaaitments associated uith the Hotor/Generator Set Battery Chargers are implemented and verified.
S12.2 Safety classifications are performed properly.
S12.3 Persomei involved in safety classifications understand the specific issue, Niagara Hohauk policies, and regulatory requirements.
BILL I
0 'ANGELO RON HALSEY Sl-13 IHPLEHENTATION OF LONG TNI PROGRANS RELATED TO ICC TECHNICIAN ALLEGATINI ISSUE
~ /gag+
PERRY S13.1" The RAP Corrective Actions and c~itments associated uith the isplementation of long term programs related to ICC technician allegations have been isplemnted and verified.
S13.2 A Restart Action Plan for Nine Hile Point 1 has been developed and is being implemented uhich has the foilouing characteristics:
a.
A coaprehensive problem identification process has been ispiemented to provide management
~ high degree of assurance that problems impacting performance of the organization and the plant have been identified.
b.
A systematic assessment of the root causes of the problems has been conducted.
c.
Persaeei impacted by the actions in the RAP have been sufficiently involved in the development or approval process of the corrective actions such that they knou and buy.in to these actions.
DAN O'ARA
QjQQf,~ (continued)
ISSUE 1
REV 0 SI 14 SAFETT STSTBI FUNCTIONAL INSPECTION NLOSaiSn S14.1 The RAP cmaitments including text, corrective actions and responses to NRC questions associated uith the safety system functional inspection have been implemented and verified.
S14.2 The specific deficiencies identified during the NRC's safety system functional assessment, have been resolved.
S14.3 Specific deficiencies in design basis docuaentation and generic implementations identified through the problem reporting process uhich could impact the ability to operate the plant uith a high assurance of safety have been resolved.
S14.4 An approved resource loaded plan and schedule is in place to develop and Implement ~ design basis reconstitution and configuration management upgrade program S14.5 An effective plan is in place to control changes, (e.g. Alarm set points, Fiou diversion devices, system resistance calculations).
S14.6 An evalwtion of other Technical Specification systems or safety systems has been done for similar deficiencies.
C.V IIANGAN Sl-15 CRNXS IN IIALLS AIO FLOORS S15.1 The RAP Corrective Actions and coaaitments associated uith the cracks in uails
<<nd floors have been implemented and verified.
S15.2 A plan and schedule for implementing a process for the identification, reporting
~nd evalwtion of cracks has been developed.
S15.3 Foliou.up to assess the effectiveness of the repairs has been performed or is
- planned, scheduled and appropriately tracked.
JOE SCINAS SI.16 FEEOMATER NOZZLES
~ ~gjgQ.
YEACER
$16.1 The RAP Corrective Actions and camltments associated uith the feeduater nozzles have been implemented and verified.
ANTHONY TOTE
g~~Q~ (continued)
ISSUE 1
REV 0 SI.17 INSERV ICE TESTING
~ QQgQ PASTERNAK S17.1 The RAP Corrective Actions and coamiteents associated uith the Inservice Testing (IST) program have been Isplemented and verified.
DAVE
$17.2 Assure the Coapany that there are no open deficiencies or concerns associated uith PALNER the IST program S17.3 The second interval IST progrea has been developed and is in place for all ASNE Class 1, 2 4 3 safety related Imps and valves except for those uhere NRC approved relief requests exist.
S17.4 Adainistrative controls (including clear assignserii of responsibilities and interfaces) vill be in place to assure the Coapany that the IST prograa is aaintained properly shen future design (sodifications) and/or licensing ("0-list")
changes are sade.
S17.5 Appropriate persornei have been trained on the approved process for developing and aaintaining the IST progr~.
SI-1d 125 VOC STSTBI CONCERNS Jjgg QQgEI, JAKUR(NISI SIII.I The RAP Corrective Actions associated uith the 125 VOC systaa concerns have been laplcaented and verified.
SIII.2 Analyses for the 125 VOC systea have been coapleted and the results of the assessaent doc~ted.
RON HALSET S18.3 The deficiencies identified during the assesseent have been dispositioned according to their iapact on plant operations.
SI6.4 A plan for the resolution of deficiencies uhich can be delayed beyond restart hss been developed.
3
~
ASSESSMENT RELATIVE TO NRC GENERIC RESTART GUIDELINES
&KEKIIEHIdEEd CKEIHlKQE ZE 5KQEE ISSUE 1
REV 0
~ f7.
"Results of corrective actions and plant isprovement activities sufficiently address and satisfy NRC restart guide-
- lines, such that all 'issues neces.
sary to support readiness for restart and safe operation have been demonstrated and NRC approval for plant restart may be requested."
1.
ROOT CAUSES IDENTIFIED Ail CORRECTED The root cause of thc conditions requiring the shutdoun m>>t be properly identified and addressed by a c~chensive corrective
~ction plan, including isptementa-tion and verification.
Division Sponsor:
Carl Terry 2.
HANAGBKNT ORGANIZATION A qualified mnagcment organiza-tion is in place to ensure that the proper cnviraaent and resources are provided to ensure that problem and their root causes have been rectified.
The organization>>>>t demonstrate that it ~ coordinate, integrate, and c~icatc its objectives.
Division Sponsor:
Skip Stuart 3.
PLANT AIR) QPPORT STAFF The operations staff ~t recog-nize and carry out their responsi-bilities in ensuring public health and safety.
Division Sponsor:
Jim Nit lis 4.
PHYSICAL STATE Of READINESS Of THE PLANT The physicat plant, including equipment and procedures is ready to support restart and safe opera-tIon Division Sponsor:
Kim Oahlberg 5.
REGULATORY REQUIREHENTS The plant and its prospective operation is not krxwn to be in conflict uith any regutations, and the requirements of the Confirma-tory Action Letter have been met.
Division Sponsor:
Stan uitczck 1.a 1.b 1.c 2.$
2.b 2.c 3.a 3.b 3.c 4.a 4.b 4.c 4.d 4.e S.a S.b S.c A plan has been developed and Isptemcntcd to identify and address the root causes leading to the shutckwn.
Based on the root causes identified, corrective actions have been isptemcntcd such that sufficient results have been achieved to address the root causes.
A process has been established to assure that the effectiveness of the results uitt be maintained.
A qualified ructear management organization has been established for. all key management positions and has coaanicated its objectives.
Hanagcment objectives reflect a positive attitude touard assuring that safety issues are resolved in ~ timely awner.
The management organization:
i) exhibits good teaaerk among its subelemcnts; ii) provides strong engineering support for plant activities; iii) has the internal ability to recognize safety problems, develop adequate corrective actions, and verify their implementation and effectiveness; and iv) has an independent self-assessment capabitity that can identify situations not sufficiently dealt uith by the regular fwetioning of the principal organization.
An adequate nusber of qualified licensed operators shall exist to meet Technical Specifications and regulatory requirements.
The operators display a positive attitude touard safety issues.
The operators display attentiveness to duty, fitness for duty, a disciptined approach to activities,
~ sensitivity for plant trends, security auarcness, and an openness of c~ications and desirc for teaawork uith other groups.
All needed safety cquipaent has been demonstrated to be operational prior to restart.
Surveillance tests are up-to-date, and reflect modifications and other corrective actions performed during the outage.
The maintenance backlog has been reduced to nominal levels.
Procedures have been updated and plant staff trained to reflect resotution of the root causes of the shutdoun.
The as-buitt design of the plant is knoun to agree with the safety design basis as described in the fSAR.
All Technical Specification amendacnts necessary for restart and operation have been Issued.
Rcgutatory licensing coamitments (including GDC requirements, generic letters, bulletins, etc.) are knoun and have been met, as appropriate for restart.
All conditions of the CAL have been met.
KGEKQK JOE HARTORE BRUCE RQ)GERS BRUCE RIZIGERS HANS SCHIER LING JOE HARTORE
RESTART READINESS REPORT SEPTEMBER 8, 1989 Assessment Bases and Detailed Results This Appendix provides add1tional details of'the assessments of the Unit 1
restart-related Under'ly1ng Root Causes (URC), Specfffc Issues, and NRC Generic Restart Guidelines.
The associated assessment Bases and Targets are contained in Appendix 2.
The information in this Appendix summarizes the findings of the assessors which were used by the Panel 1n reaching the conclusions presented fn Chapter IV of the Report.
A.
The dfscuss1on of each URC related Basis describes the results for each Target.
Following this is a conclusion regarding restart readiness.
- 1. Planning and Goals "The management tasks of plann1ng and goal setting have not kept pace with the chang1ng needs of the Nuclear Division and with changes within the nuclear industry."
- TARGETS, AND STATUS Target 1.1.a Restart Correct1ve Actions adequately support the Corrective Action Ob]ectives and'ob]ectfves adequately address desired change in performance.
This Target has been met.
The assessor evaluated the RAP corrective actions against the Corrective Action Ob)ective.
The assessor concluded that the corrective act1ons adequately support the corrective action ob)ectfves, which adequately address the desired change 1n performance.
Target 1.1.b All Restart Corrective Act1ons which address CAO 1.1 have been implemented and verified.
0011A disk 0055c A3-1 Although the intent of th1s target has been
- ach1eved, the target will not be fully met until all supporting CAs have been closed and verified.
Vision, mission, and goals have been developed during interactive meetings among the Executive V1ce President-Nuclear Operat1ons, his senior managers, and external support personnel.
A wallet-s1ze brochure incorporating the
- vis1on, m1ssion, and goals, together with Standards of Performance and other 0
important information, has been distr1buted to all Nuclear Division employees.
The Executive Yice President and his direct reports are stressing the importance of the brochure's contents at various staff meetings.
There is an increasing awareness that the contents should be 'incorporated in Performance Planning Horksheets, which are used to define an individual's goals and
'b]ectives.
Some managers and supervisors have already done this.
The 1989 Corporate goals include Unit 1 restart and HIP goals.
Monthly goal status Ss reported Sn the S9S9 Corporate Goals section In
~NM N u -'-a per1odical that 1s d1str1buted to all Company employees.
On March 20,
- 1989, a memorandum was sent to Nuclear Division managers and superv1sors explaining the relationship between Nuclear Division goals and expectations for ind1vidual performance.
This information was further disseminated through the chain of command.
Managers and supervisors have explained the relationship between individual/group performance standards and Nuclear Division goals.
Target 1.1.c Management will have reviewed recent SALP and INPO evaluations to )udge how NMPC rates compared to the rest of the nuclear industry.
This review will be factored into the vision,
- m1ssion, and performance expectations documents.
This target has been met.
Both INPO ratings (from other utilities) and SALP ratings (publ1c information) were factored into Nuclear Division ob)ectives and goals for 1989.
A goal of improvements in both INPO and SALP ratings were also reflected 1n the Nuclear Eng1neer1ng
& Licensing Department business plan.
Target 1.1.d Nuclear Division employees are aware of and familiar with the Nuclear D1vision vision, ob)ectives,
- goals, and standards of performance.
Sen1or management understands the current 1989 planning
- process, agrees with it, and is using the Nuclear Division v1sion, ob)ectives,
- goals, and standards of performance.
Managers understand the reason for incorporating the Nuclear Divis1on vis1on, ob)ectives,
- goals, and standards of performance 1nto their department's planning process.
Supervisors are aware that there are N.D. Vis1on, ob)ectives,
- goals, and understand the linkage between these and the standards that 1mpact the1r department.
Horkers are aware that there is a vision and mission and how their department's goals and individual performance supports the vision and mission.
This Target has been met.
Senior Management 1s setting a good example through staff meetings and by example fn reinforcing the importance of using the Nuclear Div1sion v1sion, goals and Standards of Performance.
There appear to be fewer observed 1nstances of employees express1ng a lack of clear commitment and d1rection.
There also appears to be an increase 1n the attitude of gett1ng the fob done r1ght the f1rst time.
Establishing accountability through the individual Performance Planning Horksheets has begun to occur.
A3-2 00llA disk 0055c
Target 1.1.e Necessary policies and procedures have been developed/revised and are in place and train1ng has been
- planned, as required, to begin using the l989 Nuclear Division vision and goals as basis for the current planning process.
This Target has been met.
A temporary Business Planning procedure was issued for review on June 30, 1989.
The procedure describes responsibili'ties and the development, implementation and tracking of specific programs in support of the Nuclear Division ob]ectfves and goals.
Target 1.2.a All Restart Corrective Actions wh1ch address CAO 1.2 have been implemented and ver1fied.
Although the intent of this target has been achieved, the target will not be fully met until all supporting Corrective Actions have been closed and verified.
The actual work for-these Corrective Act1ons has been completed and many of the products are being used; the remaining tasks are administrative.
Target 1.2.b Employees involved in inputt1ng to and maintaining the Nuclear Commitment Tracking System have been trained on the program and are aware of and respond to the needs of its users.
A person is assigned the responsibility for and held accountable for notifying the appropriate Nuclear D1vision department head that It tdt'.
(R I dt This target has been met.
The Nuclear Correitment Track1ng System has the capability to list items coming due fn addition to noting those that are overdue.
Appropriate personnel have been trained in the use of NCTS, and they are using the system.
Two individuals have been designated to notify appropriate Nuclear Division department heads that either an NRC or an INPO ccmeitment is coming due.
Target 1.2.c Restart Corrective Action products are being used to plan and schedule Nuclear Division activit1es and have improved the process.
The intent of this target is met.
The NIP is the outline for the long term planning effort 1n the Nuclear Divis1on today.
The Integrated Priority
- System, discussed below, is nearing full implementation and will be used to select the work to be done in the 01vision.
Target 1.2.d The policy and/or procedure (which includes who has the responsibility and the authority) for establishing prior/ties has been clearly defined, is in place and has been communicated
.to appropriate personnel.
0011A disk 0055c A3-3
This Target has been met.
The Panel changed this item to Category 1
and recommended the establishment of an integrated priority system before restart.
A draft Integrated Prforfty System has been developed with input from all Nuclear Division departments at both the department head level as well as 1ower levels of management.
The System was reviewed by the Integrated Team and Senior Management, and approved for use on a pilot basis.
Based on the lessons learned during the pilot phase, the System will be ffn~lized and the appropriate people will be trained in its use.
Target 1.2.e Actions have been identified or a program has been developed to implement a planning and scheduling process that defines specific performance ob]ectfves, assigns responsibilities and priorities, and integrates and aligns the activities.
AccountabiIfties and schedule have been specified for implementing these actions.
This target has been met.
There are three actions which support this finding:
(1) the pilot testing of the Integrated Priority System, (2) the procedure issued describing the duties of the Interim Outage
- Manager, and (3) the development of the Outage Management Plan.
Target 1.3,a Restart Corrective Action 1.3.1 has been implemented and verified.
This Target has not yet been met fn total since the HIP fs ln place but has not been resource loaded for every Corrective Action.
The target will be fully met before restart when the NIP is completely resource loaded.
Target 1.3.b The definition of and process for strategic and tactical planning has been specifically documented and communicated.
Accountabllitles and schedule have been specified.
This Target has been met.
Definitions for strategic and tactical planning, accountabflftles and schedule are contained ln a sufficiently complete draft of the Nuclear Division Business Planning Procedure.
Target 1.3.c Actions have been identified to develop and implement a
comprehensive Business Planning Process.
This Target has been met.
The 1989 Business Plan consists of the NIP and the existing 1988-1989 Business Plan.
Items in the Business Plan and not in the NIP will be reviewed with the responsible managers to determine ff they should be mafntafned in the Business Plan.
The 1990 Business Planning cycle will begin with a strategic assessment.
Integrated Business
- Planning, the long range planning and scheduling process, will start ln 1989 with the naming of the Business Planning Administrator.
0011A disk 0055c A3-4
A temporary Business plann1ng procedure was issued for rev1ew on June 30, 1989.
The procedure describes responsib111ties and the development, implementation and tracking of specific programs in support of the Nuclear 01vision ob)ectives and goals.
The results of th'e assessment, when reviewed target by target, support the finding that this Restart Basis has been achieved.
Management has assessed 1ts performance relative to the general nuclear industry and operating environment.
Based on this assessment, management has characterized and communicated Nuclear Div1sion direction through vision and goal statements.
Managers have demonstrated their ability to deploy their resources consistent with the vision and goals, and to assure that plant operat1ons are safely and rel1ably conducted in compliance with applicable regulat1ons.
Senior Management, by example, are continually reinforc1ng the importance of us1ng the Nuclear Division vision, goals and Standards of Performance to focus department, group and individual work activit1es at all levels.
An across-the-board awareness is beg1nning to develop on how an employee's individual performance should support the Nuclear Division vision and goals.
The Performance Plann1ng Worksheets are also beginning to be used to assign accountab111ty to these efforts.
Significant;progress has been made towards finalizing the Nuclear Division Integrated Pr1or1ty System.
Senior Management's recognition of the need for the system was an important ingredient for 1ts ultimate success.
Implementation of the System will help relieve the employees'rustrations result1ng from working on several "top prior1ty" tasks.
Implementation will also help improve the problem resolut1on effort by. assigning people to resolve a problem and keeping them working at it until the problem is solved, rather than being taken off and put on something else while the first problem remains unsolved.
0011A d1sk 0055c A3-5
- 2. Problem Solving "The process for identifying and resolving issues before they become regulatory concerns was less than adequate, in that there was not an integrated or consistent process used to identify, analyze,
- correct, and assess problems in a timely way."
Target 2.1.a Restart Corrective Actions adequately support the Corrective Action Ob)ective.
This Target has been met.
The Corrective Actions generally implement and support the Corrective Action Objective, providing for comprehensive identification of past and current problems.
The CAs also provide for developing and implementing temporary procedures to integrate restart activities to assure completion, verification, and close-out.
- However, the CAs do not adequately specify the process by which issues are effectively analyzed and corrective actions are implemented and assessed in a timely way.
Because of this, Targets 2.1.c, 2.l.d, and 2.1.e were devised to provide assurance that the Corrective Action Ob)ective will be fully and effectively met.
As a result, this target has been met since the CAs supplemented by these Targets adequately support the CAOs.
Target 2.1.b All Restart Corrective Actions which address CAO 2.1 have been implemented and verified.
The restart CAs that address CAO 2.1 are RAP Corrective Actions 2.1.1 through 2.1.10.
Progress to date lndlcates that these CAs are being effectively implemented and that the Target will be fully met when the supporting CAs, are completed, verified and closed out by SORC.
A comprehensive effort was undertaken to identify and report problems, and a
sound program has been developed for processing, evaluating, implementing, and tracking problems.
This action has been effectively implemented.
The Problem Report master listing and the process for evaluation and implementation will continue for this purpose.
Based on implementation, verification, and review of the following programs:
Quality First Program (Q1P),
- CARs, "Tell the Superintendent,"
and Lessons
- Learned, the assessment confirms that there are no trends that lead to identification of outstanding issues affecting plant restart and safe operation.
0011A disk 0055c A3-6
Temporary Administrative Control Procedure N1-88-6.0, "Restart Requ1rements for Core Reloading", identifies and documents that the requirements for core reloading have been met, and provides for assurance of satisfactory completion.
The procedure provides for two alternative methods of closing corrective actions:
temporary procedures, or Issues and Corrective Actions Closure form.
Implementation of this procedure has been effective for issue closure.
It provides a comprehensive list of activities the verifier may use in assuring the effectiveness of a correct1ve action, includfng observations, walk-throughs, inspections.
and confirmat1ons.
These CAs are principally focused on assuring that adequate systems are in place for identifying problems, that all significant past problems have been ident1fied, and that adequate tracking and trending are in place.
Problem identification and tracking have clearly been successfully implemented under RAP.
Therefore, the elements 1n the CAs addressed by these CAs will be resolved when close out and verificat1on is complete.
Target 2.1.c CAs have been effective in developing and implementing an integrated and consistent inter1m problem solving process.
CA lessons learned are incorporated in the problem identification and solving process.
Training consistent with the 1ndfvidual's role in the application of the problem solv1ng process has been completed and the process is currently fn use.
Corrective actions 1dent1fied per the process are effective
.in resolving the immed1ate problem and prevent recurrence of the problem.
The implementation of corrective actions is subject to follow up for possible further actfon.
The process is being implemented by each affected department.
The intent of this Target has been satfsf1ed, and the Target will be fully met when the actions identified fn Appendix 4 are completed.
This Target addresses the important elements of problem solving that were not covered adequately by CA 2.1.1 through 2.1.10 in the RAP: the process for determining:
root cause and effective implementation strategies, effectiveness and timeliness of actions taken to remedy identified
- problems, 1ncluding priority act1on and effective assignment of responsibility and accountability, and longer-term evaluation of whether corrective actions have solved the problems.
0011A d1sk 0055c A3-7
In addit1on to Niagara Mohawk's evaluation that problem solving was a
management and organizational effectiveness deficiency, both the NRC and INPO remained cr1t1cal of Niagara Mohawk's problem-solving effectiveness as recently as Apr11'nd May 1989.
Some elements of the problem solving issue,
- however, were considered noteworthy.
For example, root cause trending and the problem report process, the latter of wh1ch is confirmed in this assessment.
Hith respect to the root cause
- process, some elements that need t~
be considered are:
whether problems (however identified) are consistently
- handled, and the mechan1cs of performing a root cause evaluation.
This assessment finds the determination of root causes for 1dentified problems to be effective.
However, there are many mechanisms in existence for 1dentifying and track1ng potential safety concerns.
Among them are:
Problem reports Occurrence reports Corrective action reports Non-conformance reports QC inspection reports Surveillance reports Licensee event reports CFR-21 reports Quality First Program open items NRC open items Generation open items Nuclear Compliance and Verification open items SRAB open items Hork requests Audit observations Hork is underway to evaluate relat1onships among the programs for identifying and track1ng potential safety concerns, to develop specific recommendations for simpl1fying present
- methods, and to eliminate as many deficiency-identify1ng mechanisms as pract1cal.
A Division-level procedure prov1des an hierarchy to accowedate lower-tier department-level procedures on a consistent bas1s.
This approach 1s sound, but requires longer-term 1mplementat1on.
Another activity is development of the Root Cause/Trending Interface Matr1x.
This will aid the problem solv1ng process by identifying problem areas, source documents, and procedures to be used for establish1ng root cause requirements.
This 1s a short-term, inter1m effort to'ssure consistent root cause analysis despite the many current sources of problem ident1fication.
Along w1th this effort is the issuance of Procedure S-SUP-l, "Root Cause Evaluat1on Program."
Its purpose 1s to prov1de "a set of instructions for perform1ng root cause evaluations and [for identifying] the requirement for ISEG/Technical Evaluation to evaluate the effect1veness of corrective actions assigned via the Root Cause Program".
These activities are appropriate to prov1de for consistent, interim problem solving and for identify1ng corrective actions.
'Of special importance will be the prioritizat1on and processing of requirements that emanate from the department-level procedures, to assure that issues are:
0011A disk 0055c A3-8
- dealt with tn relation to their importance to safety, followed by both Division-and department-level tracking to assure timely implementation, and revis1ted 1n the longer term to assure that the correct1ve actions were effective in preventing recurring problems.
- assurance that responsibility and accountability for each safety'ignificant problem is maintained through problem resolut1on and close-out.
Through both evaluation of the systems in place to identify and resolve problems in a timely way and through interviews with all levels of Nuclear Division personnel, it was determined that the weakest part of the process was prioritization and accountability.
That is, the methods available to sort out the multitude of problems, and focus attention on these without being distracted by less safety s1gnificant issues, as well as to assure that ownership will not be lost were inadequate.
At the urging of cne Restart Review Panel, a number of actions were initiated to provide a uniform prioritization process and to establish a mechan1sm for assuring that problems are fully and effectively resolved.
The first of these is a draft Integrated Priority System Procedure to allow consistent prioritization of all Nuclear Division work.
This procedure identifies six priority levels and a merit system for evaluat1ng the value of work in the four lower priorities to the Nuclear D1vision.
The merit system is not used for the top priorities which have near term safety significance.
The second action is a proposal to Division Managers for a system which would clarify responsibilit1es for resolv1ng problems, provide needed feedback and communication throughout the process, and assure ownership.of problem resolut1on.
While both of these 1tems are in the Formative stage, they represent a large step toward dealing with the weak po1nts of the problem solving process.
The Integrated Priority System 1s being p1lot tested; the Nuclear Division department heads have scheduled a sess1on to finalize agreement on how to track problems from ident1fication to closure and how to best assign responsibility w1th1n each phase of the problem resolut1on process.
Given the progress made to date and the clear d1rection for finishing these topics, this target 1s met.
Target 2.1.d A long-term plan has been documented to develop and implement an integrated and cons1stent problem solving process.
The Target has been met.
The basic structure of the long-term plan to develop and implement an integrated and consistent problem solving process is contained in NIP items 2.l.ll through 2.1.17.
Following is a summary discussion of progress for some of these items.
0011A disk 0055c A3-9
Development of an integrated deficiency reporting program 1s well underway with the participation of Operations, Engineering, QA, and Training.
A flow chart illustrating the process logic has been generated and inter-department comments have been received.
Based on this logic flow, a Division-level procedure has been drafted to provide a broad framework for deficiency reporting.
The procedure will facilitate preparation of conform1ng department-level procedures.
by which a broad range of 1ssues can be handled consistently throughout the Nuclear Division.
Development of a standard lessons learned program is also well underway, even though this is a Priority 3 item.
A Nuclear Division Management Policy for th1s program has been drafted and conta1ns policy directives and respons1bilities for the entire Division.
A Site Administrative Procedure has also been drafted, wh1ch implements the Division Policy on lessons learned.
The procedure applies to all personnel performing activities that affect Nine Mile Point Nuclear Station.
An aspect of note in this procedure 1s that it conta1ns a section titled "Program Effect1veness Evaluat1on",
which requires the Lessons Learned Coordinator to verify program compliance and effectiveness.
The program to improve the use of operational exper1ence data is in place.
The principal sources of Operational Experience (OE) data are:
NRC Information Notices INPO SERs and SOERs GE Serv1ce Information Letters Although there 1s a cons1derable OE backlog to be addressed, a staff of l5 is planned to accorwedate the influx of data.
To reduce the backlog, 28 contractors are in place through 12/90.
The goal is to reduce the backlog to about 25 items by this time, which can be managed by NMPC personnel, Although this Target dealt with those items that were Category 2 and 3, substantial progress has been made in development and trial 1mplementation.
Plans are in place to assure appropriate tratn1ng when these programs are shown to be effective.
This Target has been met.
When an OE resolution has been determined, any implementation action is entered in the appropriate system (e.g.,
NCTS) through wh1ch, prioritization and tracking is managed.
When an OE that is ready for closure is placed in a system, it is taken off the backlog, and resolut1on is closed out 1n the OE process.
Target 2.1. ~
Future self-assessments of the problem resolv1ng process are scheduled to be conducted by the Independent Assessment Group.
Future self-assessments of the problem-solving process are scheduled to be conducted by the Independent Assessment Group (IAG).
The charter for the IAG has been modif1ed and now includes self assessment of the problem solv1ng process in 1ts scope.
Therefore, the intent of this Target has been satisified and the Target will be fully met upon satisfactory completion of the act1ons 11sted in Append1x 4.
0011A d1sk 0055c A3-10
Performance-11mi ting deficiencies have been identified by assessing past performance and were resolved by implementing corrective actions.
A detailed plan for implement1ng an improved problem solving process is in place and sat1sfactory progress has been demonstrated in implementing the plan.
The plan elements include:
Problem 1dentification, Systematic cause analysis, Corrective action planning, Implementation management, and Assessment of achieved results.
An interim process based on the one used in developing the RAP will be used until the long-term program 1s fully in place.
At the organization level, an integrated and consistent problem solving process has been instituted and is being implemented in the Nuclear Divis1on and support1ng organizations to 1dentify, analyze,
- correct, and assess problems 1n a timely way.
At the management
- level, managers are exh1biting good problem solving skills 1n their dally activit1es.
In particular, they are making a strong effort to obta1n suffic1ent 1nformat1on to identify situations of concern, and are involving the personnel affected by them.
They are analyzing concerns to ascertain root cause, developing well-considered solut1ons, choos1ng the best solutions, and implementing them.
Managers are following up on implementation and assessing the results to determine whether further act1on is needed.
The Safety Review and Audit Board (SRAB) formed a spec1al team to determine the adequacy of methods of:
- determining root causes,
- 1dentifying underlying issues, and
- des1gntng, implementing, and ver1fying corrective actions.
The SRAB team also evaluated Corrective Action Ob)ective 4.2 (assessment against Standards of Performance),
with part1cular emphas1s regarding ongoing assessment plans.
The positive actions noted above. combined w1th the significant progress made toward implementing the Integrated Priority System and finalizing the process which ass1gns accountab111ty for problem resolution lead the assessor to conclude that Bas1s No.
2 has been met.
00llA disk 0055c A3-1 l
- 3. Organizational Cuiture "Management's technical focus has created an organizational culture that diverts attention away from the needs and effective use of employees."
TARGETS AND STATUS Target 3.1.a Restart Corrective Actions adequately support the Corrective Action Objectives and all Restart Corrective Actioiis which address CAO 3.1 have been implemented and verified.
A n
1 The assessor evaluated the RAP corrective actions against the Corrective Action Objective.
The assessor determined that the CAs have been completed and adequately support the Corrective Action Objective.
The Target has been met.
Target 3.1.b Nuclear Division employees at all levels of the organization are aware of and familiar with the November 1988 Nuclear Division organizational
- changes, the status of actions of 1988 commitments and the Restart Action Plan.
The Target has been met.
Employees are aware of the November 1988 changes to the organization.
The November 1988 organization chart was replaced by the May 1989 chart, distributed in mid-Hay.
An interim assessment noted that individual and group lntervlew questions on commitments resulting from 1988 Town Hall and other employee meetings generally had negative responses.
A major theme in the interviews was that employees felt they were "being heard but not listened to."
There was little evidence that supervisors personally discussed management responses to overall employee concerns with their subordinates, ln contrast to RAP responses, which were largely based on feedback through the chain of cceeand.
To check that management was getting better at listening, the lnterlm assessment recommended that the process for the development of the functional organization charts be assessed.
There was extensive involvement of employees throughout the Nuclear Dlvlslon during the preparation of the charts; it took several lteratlons to get them finalized.
When the charts were issued, there was a feedback form attached to facllltate the correction of any deficiencies or any future changes that occur.
Another recoaeendation ln the interim assessment focused on the use of the chain of cemend, especially as it applied to getting employee feedback.
In the instance of the organization charts discussed
- above, the charts were issued through the chain of command for comments and the comments were obtained back up through the same chain.
0011A disk 0055c A3-12
Target 3,1.o Employee feedback on the Restart Action Plan was solicited, provided and incorporated, as appropriate.
This Target has been met.
An effective process exists for communicating the RAP to employees and receiving their feedback.
Generally, employees saw the opportunity to personally contribute to a major work plan as a clearly positive change from past practice.
Approx'imately 1200 feedback forms were received, which were submitted by about 600 people.
About ten percent of the feedback issues were incorporated in the Plan.
Management action on the feedback ls generally regarded by employees as appropriate, with some exceptions.
Significantly, when respondents were
- known, management response was communicated through their supervisor.
This direct hands-on involvement by mid-level managers and supervisors appeared to enhance perceived crediblllty of the responses.
By comparison, responses to the 1988 commitments were disseminated through Company mail or publications and were regarded as being less credible.
An interim assessment receanended the use of the RAP communication process ln the future but to allow more time for feedback and to use the chain of command in soliciting the feedback.
There have been no undertakings similar to the RAP development to test the process exactly;
- however, the method used to formulate and issue the functional organization charts discussed under Target 3.l.b successfully used a process similar to that recommended here.
Target 3.1.d Practices and Policies are in place to improve management's attention to employee needs, utllizatlon and feedback.
This Target has been met.
An interim assessment found evidence that some managers are creating opportunities to increase the quality of communication with employees.
Examples:
Tell-the-Superintendent" program, Quality Teams, Round Table meetings, and-off-site team-building sessions.
- However, most interview data available for the interim assessment indicated such initiatives were the exception.
The lnterlm assessment also found that employees generally perceived a lower-and mid-level management orlentatlon that ls exclusively focused on tasks.
They perceived some indication that senior management ls trying to change this but doesn't know how.
Pockets of optimism were found ln groups where managers are moving aggressively toward positive change, and seem to have long-term, NIP goals as their target.
The lnterlm assessment recceeended improving the work atmosphere by focusing on better comaunlcatlon, collaborative problem solving, and clearly defined work standards.
There has been significant progress toward addressing each facet of this interim assessment recommendatlon in each department of the Nuclear Division.
0011A disk 0055c A3-13
Each department head now holds frequent staff meet1ngs w1th his or her direct reports; that same process is used at lower levels of the organization.
The sequence of these meet1ngs 1s also being coord1nated to facilitate the timely passing of fnformatton through the chain of command; the highest level meeting would be held on day 1, the next tier on day 2, and so on.
The organizational development specialists have fostered the use of clear, unambiguous communication with each department head.
This candid style is being modeled by Department Heads and 1s showing up at lower levels of the organization.
The spirit of teamwork, especially as it applies to problem solvin'g, has made significant strides forward.
Teamwork has been a constant theme fn the Division-wide Town Hall meetings and in each department's discussion of the Division's standards of performance.
Hid level managers from generation and eng1neering have held offsite meetings, facilitated by organizat1onal development specialists, to d1scuss the needs,
- concerns, and perceived shortcomings of each group; those sessions have helped each group to understand the needs and perceptions of the other group.
There have been numerous citations of engfneering and generation working together to solve problems relating to the close out of the RAP Specific Issues.
The establishment of site engineering has proven to be very effective fn demonstrating Engineering's determination to be responsive to the needs of generation.
Every department in the Nuclear D1v1sion has a program underway to update each management employee's performance planning worksheets to establish personal goals which are support1ve of the vision, goals and standards of performance of the Nuclear Division.
Target 3.1.e Managers exhibit 1mproved "people" skills such as the lfstenfng part of comnunfcatfon, and conflict resolut1on.
This target has been met.
An interim assessment found evidence that some managers exhibit improved people skf lls when involved as a )eader or member of a project team that is concentrating on a task.
However, there was little evidence that fmproved people skills were becoming normal, everyday aspects of management behavior.
The interim assessment recceeended use of in-line tra1ning to improve the skill level of current managers.
The organization development specialists or1ginally assigned to work with the department heads are now working with the next level of managers to improve the "people" skills of the next level of management.
Interv1ews conducted since the m1ddle of June show positive results.
The managers who are getting the training feel more comfortable us1ng the newly acquired skills, and more importantly, the people in their organizations see a greater sense of attention to the employees'eeds.
One facet of the ear11er recomnendatfon that is be1ng implemented in the NIP is to have the train1ng proceed through a programmatic approach to assure uniformity throughout the Division.
0011A d1sk 0055c A3-14
Target 3.2.a Restart Corrective Action 3.2.1 has been implemented and verified.
A This Target has been met.
Organization professionals have been assigned to the Executive Vlcc President - Nuclear Operations and his direct reports.
They support management tn such functions as:
meeting facl'Ittation, issue identification, problem solving, action planning, team building, conflict resolution, third-party intervention for interpersonal
- issues, individual coaching and mentoring Currently, an organization development plan is being prepared for management approval.
The overall organization development plan will help managers to focus on the requirement to role-model behaviors that are consistent with the desired culture, and to coach their subordinates ln doing likewise.
Target 3.2.b Senior management knows what team building and coaching skills look like from a behavioral perspective, they know which ones they need to work on, and they have individually developed plans for addressing their needs.
In addition they have within their departments an ongoing process to ensure that team building and coaching skills, tools and accountabllitles are in place and used.
This Target has been met.
An interim assessment found evidence of senior managers'ntent to do what lt takes at their level to create a more people-oriented culture.
They appeared to be sincere in subscribing to an
- evolving, shared mission for routinely using and maintaining team concepts.
The interim assessment recomnended translating the stated intentions of the department heads into action, starting with a personal self-assessment of the person's skills.
Recent interviews have found that, ln addition to the department heads themselves, many levels of all departments are using the self-assessment forms lnltlally used by the department heads.
The forms focus on the five management effectiveness areas and are being used to critique both personal and group behaviors.
Each of the department
- heads, working with the assigned organizational development specialist, has made significant progress in the team building area.
The offslte meetings with the Executive VP and the department heads have identified specific problem areas needing better teamwork; follow-up sessions with various levels of the appropriate departments have made strides to upgrade the teamwork among those groups.
Specific examples include:
OTPAC continues to improve the relationship between Tralnlng and Operations; 0011A disk 0055c A3-15
meetings between Engineering and Generation have improved the working association between these two departments; the Procurement Process Review Team has helped the understanding and the effect1veness of the support function provided by Haterials Hanagement, Materials Eng1neering, Quality Assurance, and Purchasing to operations and maintenance.
It is now commonplace to see letters from a person tn one department to someone in another department thanking someone for the1r help in getting some gob done; these notes provide pos1tive feedback and build the sense of value of good teamwork.
There have been 1nstances of improvements in the coaching area.
B'ased on feedback from the inter1m assessments, one department head counseled a manager that many people felt that the manager did not like them because he never smiled at them; the perception has been changed due to the coaching'he engineering department head has worked with several of his managers to modify their communication style to improve the perception, as seen by their employees, of not be1ng approachable.
The ma1ntenance department supervision undertakes periodic observation tours and reviews the results with the crews to enhance future performance.
These coaching activities will also be emphasized as part of the management review process.
Work is continuing 1n order to pass the skills 'down to lower levels of the organization in concert with the earlier recommendations, but the senior group is already perform1ng properly.
Target 3.3.a Restart Corrective Act1on 3.3.1 has been implemented and verified.
This target has been met.
An interim assessment found that the Standards of Performance were commun1cated throughout the cha1n of command in most departments;
- however, lower levels of the organization, and, to a large
- extent, mid-management, were confused as to how they should be implemented.
Host employees felt the Standards of Performance are of intrinsic value, but in their current form are only "words on paper," without an action plan to hold people accountable for specific behaviors.
The 1nter1m assessment recoamended translat1ng the Standards of Performance into observable behaviors so that employees knew what the standards meant for them.
The most recent interviews and observat1ons show that the effort to give personalized meaning to the standards 1s ongoing at staff meet1ngs in every department and at all levels of the organizat1on.
A discuss1on of the standards of performance 1s a typ1cal agenda item at staff meetings.
There is widespread effort to 1dentify the behavior that the standards expect from each employee.
OollA disk 0055c A3-16
The results of the assessment, when reviewed target by target, support a
finding that this Basis has been achieved.
There are significant actions and behaviors which demonstrate a positive change in culture.
There are formal Management By Walking Around programs at several levels in the organizat1on.
Our1ng interviews employees expressed recognition of the changed behavior by their bosses, and appreciated the opportunity 'to interact with the boss in the work place.
HBWA is being advocated and modeled from the top of the organization.
Several interviews noted the trend toward a more participative management style.
One person said that a year ago the attitude was "I am the boss, do it
, my way", while this same person now feels that input is so'Iicited and given due consideration.
- Recently, a represented clerk was sent to a trade show in California since she was the person who would be able to put to use the informat1on gathered at the show when new equipment was purchased; historically, a high level employee would have gone on such a trip.
In this case the most appropriate person went.
The concept of self-assessment has been w1dely accepted and is being practiced throughout the organizat1on.
Mangers are being critical of the1r own performance; they are seeking input on how they and their groups can improve.
Communication has improved.
The sem1-annual Town Hall meetings have given every Nuclear Division employee the chance to hear the Execut1ve VP set the tone for improved teamwork and chain of command communication.
There is a
much greater use of the chain of comnand to d1sseminate information to the employees.
In the other direct1on, the attitude be1ng fostered is to not just grumble about a problem, but to tell your boss about it and get involved in the solution.
In spite of the work still remaining to get Unit 1 ready for restart, the Executive VP is trying to heighten the awareness of management as to quality of life aspects, There is now a rule that if a direct report of the Executive Vice President must work after 6 p.m. or more than four hours on weekends, he or she must write the Executive VP a letter explaining why that many hours must be worked.
It is hoped that by example the leaders w111 show that the work can get done without spending every waking hour on the job.
The most important aspect of the cultural change is that the most significant changes are be1ng modeled at the department head level; these people are the role models for the entire Division in their display of teamwork, self-assessment, and their dedicat1on to the pursuit of excellence.
This un1fied support at the top of the organization will solidify these desirable cultural changes.
00llA disk 0055c A3-17
- 4. Standards of Performance and Self-Assessment "Standards of Performance have not been defined or described sufficiently for effective assessment, and self-assessments have not been consistent or effective."
TARGETS AND STATUS I
Target 4.1.a The Restart Corrective Actions associated with the Corrective Action Ob)ectives have been implemented and verified.
This target has been met.
The Standards of Performance were developed and communicated to Division personnel.
The CA was verified and reviewed and approved by SORC on June 16, 1989.
A Nuclear Division Policy has been developed and issued to more accurately define responsibility regarding contractor oversight.
This Policy was reviewed and discussed during the August expanded staff meeting of the Executive Vlcc President-Nuclear Operations.
The Executive Vice President-Nuclear Operations has approved the policy and lt is scheduled to be disseminated using appropriate procedures on September 15, 1989.
Target 4.1.b A set of Nuclear Division standards of performance which are consistent with the division's vision for excellence exist and have been communicated to all levels of the organization.
This Target has been met.
A set of Nuclear Division Standards of Performance has been developed and it ls consistent with the Division's vision for excellence.
Based on a review of assessment interviews held with individuals,
- groups, and Senior Managers, the Standards of Performance have been communicated throughout the organization.
The Standards were communicated in personal discussions, correspondence, and newsletters.
Additionally, wallet and "Franklin Planner" inserts have been distributed to employees.
These documents summarize the Nuclear Division's Standards of Performance, Vision, Mission, Critical Issues, Ob]ectives, and 1989 Goals.
The Executive Vice President - Nuclear'perations and his direct reports have challenged their employees to hold the leaders accountable for exhibiting the Standards of Performance.
Interviews indicate that many organizations have conducted staff meetings to discuss how the Standards of Performance can be utilized and measured ln their functional areas.
Some managers have incorporated the Standards of Performance into the performance planning process.
The Town Hall meetings held in early June focused emphasis on modeling the behaviors set forth in the Standards of Performance.
Interviews and phone surveys indicate that many employees are seeing the Standards of Performance being modeled.
0011A disk 0055c A3-18
An interim assessment ident1fied a lack of awareness regard1ng the Standards of performance at the worker level.
Subsequent efforts have had a pos i tive
- impact, and, for the most part, employees at all levels of the organization are aware of and understand the Standards of Performance.
Target 4.2.a An independent assessment function ts established and integrated w1th other assessment groups in the company, i.e.
- SRAB, QA.
A comprehensive self-assessment program to determine restart readiness has been developed and is being implemented.
The Restart Read1ness Report describes the Restart Self-Assessment process and results.
In addition, an Independent Assessment Group (IAG) has been established and a
manager appointed.
An Independent Asses.sment Group (IAG) Charter has been drafted and comments from the Executive Vice President's direct reports have been solicited.
After incorporat1on of these
- comments, a formalized charter will be issued.
An action plan describing the process that will be utilized to integrate the IAG with other assessment groups including SRAB and Quality Assurance has been developed and reviewed.
The IAG integration plan calls for completion of the required 1ntegrat1on actions prior to restart.
Hhen the plan is completed, th1s target will be fully met.
Target 4.2.b Self assessment act1vity at the departmental and programmatic level has been established and/or improved.
This Target has been met.
There has been an improvement in the awareness for and increased use of self-assessment.
At the Direct Report level, the trend identified in an interim assessment continues.
For example, periodic self-assessments deal1ng with the Management effectiveness areas have continued.
At the middle management level, understanding of the self-assessment function has emerged.
Many managers are using the self-assessment forms in their organizat1ons.
Heekly staff meet1ngs have 1ncluded self-assessments of the effectiveness of the meeting as well.
The link between self-assessment and the Standards of Performance is more defined.
Managers and supervisors are asking to be held accountable for modeling the Standards of Performance, as well as holding their employees accountable.
At the worker level, the 11nk between Standards of Performance and self-assessment 1s less clear.
Some pockets at lower levels indicate they are unaware of formal self-assessment programs;
- however, when asked, "How do they know they are doing a good )ob?",
many are able to explain a method of self-assessment wh1ch, for the most part, "resembles" assessing themselves against the Standards of Performance.
0011A disk 0055c A3-19
The results of the assessment indicate that, although not all targets have been met in total, a positive trend has been observed and is expected to continue.
Standards of Performance w1th emphasis on achieving results have been ident1fied and communicated to all levels.
Many employees are 1ndicating they feel the Standards are being modeled and fellow employees are working hard to improve in these areas.
Plans have been developed for imnlementation of supporting Performance Standards within major departments.
A c'Umprehensive self-assessment program to assess readiness for restart has been conducted.
Progress has been demonstrated toward the establishment of a long-term Nuclear self-assessment process with the format1on of the Independent Assessment Group.
In summary, the Nuclear D1vision has set forth its expectations in terms of the Standards of Performance and is hold1ng its employees accountable for self-assessing against these expectations.
The establishment of the Independent Assessment Group will cont1nually monitor this area to help assure that this improvement will be a long-term cultural change.
The Nuclear Divis1on's Standards of Performance have been defined and described sufficiently to enable effective assessment.
Senior managers are modeling the Nuclear Division's Standards of Performance in the performance of the1r day-to-day business.
Line managers have demonstrated that they are aware of the behaviors that reflect adherence to the Standards of Performance.
00llA disk 0055c A3-20
5.
Teamwork "Lack of effective teamwork within the Nuclear Division and with support organizations is evidenced by lack of coordination, cooperation, and communicat1on in carrying out responsibilities."
TARGETS AND STATUS Target 5.1.a The Restart Corrective Actions associated with Cori ective Action Ob)ective 5.1 have been implemented and verified; Meet1ngs were held with Senior Management,
- managers, and supervisors, to promote teamwork and to identify and resolve management and organizational issues.
Team building sessions were held w1th the Direct Reports
- and, in many
- cases, with levels below the Direct Reports.
The Direct Reports held expanded staff meetings for all levels of supervision; both the need for teamwork and for improving the effectiveness of the Chain of'ommand were stressed at these meetings.
Interviews at the worker level indicate that supervisors are emphasizing the need for teamwork and for using the Chain of Command and that these workers feel that they are see1ng positive results.
Two series of Town Hall meetings were held.
As a result of the first meeting, held in December 1988, over 1200 feedback forms were received.
A "Special Ed1tion" newsletter was publ1shed to address the most cowen concerns and questions.
Individual responses have
- been, and continue to be, sent out.
Most of those interv1ewed in the assessment felt that these meetings provided an excellent opportunity to receive information and provide feedback.
- However, a
few expressed dissat1sfaction with the time taken to issue responses.
A second series of Town Hall meetings were conducted 1n June.
Mr. Burkhardt stressed the need for teamwork ("be your brother's or sister's keeper")
and for using the Chain of Cmeand.
He actively solicited both verbal and written comments and questions.
Meeting assessment forms were comp1led and 1ndicated that most workers were appreciative of the informat1on disseminated at the meeting
- and, more 1mportantly, of the opportunity to listen to and ask questions of Larry Burkhardt and his D1rect Reports.
The Nuclear D1v1s1on vis1on and goals were formally coneunicated by memorandum to Nuclear D1vision managers and supervisors on March 20, 1989.
These 1nd1viduals were instructed to "ensure that each employee reporting to you, both represented and non-represented, receives a copy and understands how his or her work activ1t1es support the ob)ectives and contributes to the achievement of the goals."
The interim assessment noted that compliance with these instructions varied, and that communication of the vision and goals to workers was spotty.
Issuance of the wallet-size pamphlets containing the vision, goals, etc.
helped to ensure that the message got to all Division employees.
The follow-up assessment indicated that the Nuclear D1v1sion vision and goals had been vigorously promoted.
Employees were asked to hold up their wallet-sized cards at the Town Hall meetings.
Many employees did not have their cards with them and some had not yet received them.
This deficiency was 00llA disk 0055c A3-21
followed up on by the Direct Reports and their managers and supervisors.
It 1s now not uncommon for employees to be asked to hold up their cards at regular staff meetings Attempts are also being made to translate the vision and goals to everyday work activities.
Performance plann1ng worksheets are being modified to show the relationship between individual goals and the Nuclear Division vision, goals, and Standards of Performance.
The Restart, Task Force was established.
The RAP feedback process was effective and evoked positive reactions by most interviewees; people appreciated the opportunity to contribute to the Plan.
The required response time for RAP review and comment was a problem for some; by the time it reached the worker level, many had only a day or two for review and comment.
An Integrated Team of selected Nuclear Division, support group, and Restart Task Force representatives was establ1shed.
The Integrated Team consists of Hid-level managers from line organizations, and meets bi-weekly to review and approve NIP action plans, provide input to the restart effort, and resolve issues encountered in developing, implementing, and self-assessing restart actions.
The Team has been effective in executing 1ts charter and is recognized throughout the Nuclear Division as a model for inter-departmental cooperation.
Assessment observations at meetings revealed that team members openly and cand1dly communicated and tried to understand one another' viewpoint.
The last Correct1ve Action associated with this target (Communicate to the organization the importance of timely identification and resolution of deficiencies using spec1fic issues 4, 6, and 17 as examples of the need to resolve potential system operability issues in a more timely manner) has not yet been completed.
A draft document has been produced and is under review.
When th1s draft document is finalized, before restart, th1s target will be met in total.
Target 6.1.b A demonstration that team efforts have been used in solving three problems involv1ng mult1ple departments.
This target has been met.
Throughout the assessment
- period, evidence of team efforts to solve problems has been apparent; for example, inter-departmental problems were solved rout1nely in the Integrated Team and Wednesday scheduling meetings.
Examples of problems in which representatives from different departments contributed to the solution include the Hain Steam Line Radiation Honitor1ng System, Feedwater Nozzle,and Bellows leak.
All of these instances demonstrated teamwork between Operations and Engineer1ng; depending on the problem, other departments, such as QA, contributed as appropr1ate.
There is a pervasive spirit of willingness, cooperat1on, and commitment at the worker level toward improving the nuclear program by working together to achieve success.
0011A disk OOSSc A3-22
Target 5.1.o A demonstration that management is committed to the team-building process and has begun to transmit the spirit of teamwork through the ranks.
This demonstrat1on will be evidenced by behaviors wh1ch promote open communications and by a willingness to work together to atta1n common goals.
This target has been met.
As indicated during the interim assessment and confirmed during the follow-up assessment, many noticeable improvements have occurred in the spirit of teamwork during the past several months.
The formation of the Integrated
- Team, composed of middle managers, and of OTPAC, composed of Operators and Trainers, has been very effective in creating an atmosphere of open communications between departments.
The relationship between operators and trainers and between operators and their supervisors has shown improvement, as evidenced by many individual and group interviews, by observations, and by an NRC exit interview.
Most workers throughout the Nuclear Division feel free to openly express their opinions,
- ideas, disagreements, and feelings:
they also 1ndicate that they are usually asked to participate 1n decision-making and problem-solving which involves them.
Teamwork w1thin work groups has improved
- somewhat, although the workers feel that intra-group teamwork has always been good.
Off-site team building sessions are being conducted to promote teamwork between
- groups, especially between those groups which have historically had difficulty 1n working together effectively.
The management/union relationship has also been 1mprov1ng.
All of the meet1ngs observed.
although quite long, were well-run, had agendas, included a self-assessment, and demonstrated an open exchange of ideas and concerns; posit1ve feedback (e.g..
"good idea",
"good point" )
was a
common occurrence at meetings.
The interim assessment suggested several areas where improvements in teamwork were needed.
During the past three months, progress has been realized in v,irtually all of these areas.
Hhile the barriers between certain organizations (Engineering/Generation, Engineering/QA, Nuclear/Materials Management, Nuclear/Employee Relations) have not disappeared, members of all of these groups are working together to clarify the1r ind1vidual roles and responsibilities, to resolve
- issues, and to solve problems.
Off-site team build1ng sessions have been held between some of these groups (Eng1neering/Generation, Engineering/QA), while detailed action plans have been developed for other groups (Employee Relations, Materials Management).
Interviews with members of all of these organizations have indicated that working relationsh1ps are 1mprov1ng as understanding of and appreciat1on for the other organ1zation's responsibilities increase.
At the time of the inter1m assessment, not all managers and supervisors had accepted ownersh1p of the management and organizational effectiveness 1ssues.
As a result of the Town Hall meetings and'1rect Report expanded staff meet1ngs, all supervisory personnel were made aware of what is expected of them in these areas.
Based upon follow-up interv1ews, supervision is becoming more aware of the need to include the workers in dec1sion-making and problem-solving activities.
They are regularly emphasiz1ng the need to improve teamwork both with1n and between work groups, and are provid1ng ample opportun1ties for the workers to raise issues and concerns either at regularly scheduled meetings or on a "walk-in" basis.
0011A disk 0055c A3-23
Heet1ngs continue to consume a significant port1on of managers'ime; most
- managers, wh1le they feel that, they spend too much t1me in meet1ngs, also feel that the meetings are necessary.
They do try to improve the effectiveness of these meet1ngs by 1nsisting upon an agenda, by actively trying to keep the meeting focused on the agenda,
- and, in some cases, by asking to leave the meeting if they feel that their presence is no longer contributing to the meeting.
Implementation of an effective Hanagement By Walking Around program may help to decrease the need for so many formal meetings.
Since the inter1m assessment, the functional organ1zation charts liave been revised and reissued.
A review of this latest version indicates that much of the overlapping confusion has been elim1nated.
Document reviews also indicate that teamwork was exemplified 1n the creation of these charts.
All organizations provided input and comments prior to this latest release.
A feedback form was included with the charts to allow people to suggest modifications and improvements.
As indicated
- above, understanding of roles and responsibilities 1s a necessary first step to achieving teamwork.
Target 5.1.d The senior management and the Integrated Team are aware of what they do as a group which promotes and impedes collaboratively getting their work done.
They are 1n the process of implementing behaviors which reinforce the positive aspects of their working together and manage the negative aspects of working together.
This target has been met.
The Integrated Team serves as a model for 1nter-departmental cooperation and cceeunication.
They openly express their opinions and concerns with one another, they are well-prepared for their team meetings.
they provide pos1tive feedback for one another's
- 1deas, and there is 11ttle evidence of d1scord dur1ng the meet1ngs.
Their self-assessment process has resulted in suggestions of ways in wh1ch they can improve the effectiveness of the Integrated Team; many of these suggestions have been implemented.
S1nce an interim assessment, the sen1or management team has made great strides in working together effectively.
As a result of that 1nterim assessment, they began meet1ng and working together as a team to try to determine how they can improve their management and organizational effectiveness.
Several action 1tems resulted and were assigned to one or more members of the senior management team.
During the last few months, the Direct Reports have not only become more aware of what they do as a group which promotes and impedes getting the work done, they have also made a more conscious effort to model the teamwork standards of performance.
Although teamwork difficulties between Engineering and Generat1on were recognized dur1ng the interim assessment, the leaders of these two groups have demonstrated to their organizations that they need and want
-- to work together as a team to atta1n cereon Nuclear Division goals.
At both the Eng1neering and Generation Expanded Staff meet1ngs, demonstrations of an improving relationsh1p were evident (cceeents such as "Jim did a great fob" and "his direction is great").
The presence of these two 01rect Reports at one of the Engineering/Generation team building sessions was also viewed as a
positive sign by those who attended this session.
001 l A d1sk 0055c A3-24
A process is in place such that management and organizational issues are identif1ed, discussed and either resolved or assigned to an ad hoc multi-department team for resolution (as appropriate).
mn 1
Hhi le 1 t wi 1 1 obviously take time for the perception of a lack of teamwork on the part of senior management to completely disappear, interviews indicate that people at all levels are aware that teamwork is 1mproving among the-D1rect Reports.
t Target 5.1.e This target has been met.
The interim assessment indicated that there is no process in place for discussing and resolving management and organizational concerns.
This finding was based on concerns raised in some of the group interviews, where the interviewees felt that they had legitimate problems and concerns and that no one was listening to them.
Senior management indicated that the process to be used should be the Chain of Command and, during the past,few months, the use of this chain has been emphasized at meetings at all levels of management.
Larry Burkhardt made it very clear at the Town Hall meetings that he expects the Chain of Command to'e "our main channel for communication and action".
Follow-up interviews at all levels indicated that the Chain of Command is becoming more and more effective.
Although there is still some confusion regard1ng when it should be
- bypassed, the proper use of the chain of command is frequently discussed at the Executive Vice President's staff meet1ngs.
Follow-up was done on the specific groups who raised concerns during the initial assessment.
In all cases, act1on was taken to further define and to resolve these issues.
The results of this assessment ind1cate that this Basis has been achieved.
Hhile, admittedly, there are still some areas where further teamwork improvements should be made, there has definitely been significant "progress toward effective teamwork with1n the Nuclear D1vision as evidenced by working together to make decisions, to solve problems, and in general, to get the job done correctly and completely."
Nuclear D1vision employees, from the Executive Vice Pres1dent to the lowest level worker, are aware that 'effective coordination, coaeunicatfon, and cooperat1on are essential to meeting the Nuclear Div1s1on vision and goals.
Examples of good and bad teamwork are regularly discussed at meetings of all levels of workers.
Contributions of individual team members are also being recognized, both at meet1ngs and via memos; what was once behav1or that was taken for granted is now being used as a model for good teamwork.
0011A disk 0055c A3-25
What teamwork is and is not -- is also becoming more evident to Nuclear D1vision employees.
In the past, various Nuclear and non-Nuclear groups were accused of lack of teamwork.
In some
- cases, this was true but in many tk,tk ki t
d k ~,
d 1
k teamwork.
These groups have always wanted to cooperate, but may not have had the train1ng, resources, or skills to meet the expectations of others.
Many of these "teamwork" problems are now being solved by better definit1on of roles and respons1bilit1es, by additional resources, and by training.
Nuclear Divis1on employees now realize that teamwork does not mean that there must be common agreement on all issues.
They realize that it is important that all affected parties contribute to dec1sion-making and problem-solving, but that the ultimate decision or solution may not be the one that they may have chosen.
The most important element of th1s process is that t1mely feedback be provided to ~ who provided input, regardless of whether or not this input supported the ultimate decis1on or solution.
Based on interviews, this feedback process is still an area which needs improvement, especially at the supervisor/worker level.
Perhaps one of the most important lessons that the Nuclear Division is learning is that teamwork does not necessar1ly mean meetings or group
- efforts, There is now a realization that you can demonstrate teamwork in many 11ttle ways by passing memos along to people you think may be 1nterested in
- them, by say1ng "hello" to your co-workers in the hall, by making your colleagues aware of s1tuations that you have )ust learned about and which could affect them, etc.
An excellent example of where teamwork does not mean working together is the disagreement that Carl Terry had w1th the Integrated Team over a NIP 1tem.
In resolving the 1ssue (after rece1v1ng 1nput from several others),
Carl wrote:
"The Integrated Team had a concern that two plans would indicate a lack of teamwork.
I don't agree.
Teamwork 1ncludes understanding each other's strengths and weaknesses and roles and responsib111ties."
While this assessment has concluded that the teamwork bas1s has been achieved, it cannot be emphasized strongly enough that all the efforts currently taking place to improve and to sustain the improvements 1n teamwork must continue.
Open and honest comaunication in both directions and a participat1ve style of management are crucial to the successful startup of Nine Hile l and to the ult1mate achievement of the Nuclear Div1sion vis1on and goals.
0011A disk 0055c A3-26
Following is a description of the format for the Specific Issues.
The numbering system is the same as that used in the RAP.
The basic Specific Issues are numbered SI-1 through SI-18.
To assist the reviewers, the issue itself is briefly described in the Issue Description.
Additional information on each speclflc issue can be found in the Issue Sub-element and Root Cause discussion included in the RAP.
The assessment targets for each issue are contained in the matrix ln Appendix 2.
After the issue description the Assessment Results are presented.
Assessment Basis Ko. 6 Following is the basis on which the 18 Specific Issues addressed in the Plan were assessed:
"Results achieved through implementation of restart corrective actions for the RAP Specific Issues shall be sufficient to resolve or provide management with assurance that these issues concerning operator training and qualification, administrative
- process, and hardware deficiencies will not have an adverse effect on safe plant operations."
The effectiveness of corrective actions demonstrated by the results described ln the following summary descriptions of the assessments of the eighteen Specific Issues support the conclusion that Basis ¹6 ls met.
S1-1 Outage Management Oversight A plan had not been developed for management oversight of outage activities, including work scope identification, planning and scheduling, and verification of items identified as prerequlsltes to Unit 1 restart.
Items contained in the maintenance/modification backlog that are required to be completed to support the restart of Unit 1
have not been formally identified and addressed in an effective management plan (including a summary of repairs and modifications to the feedwater system).
Target Sl.i:
The RAP cofinitments including text, corrective actions and responses to NRC questions associated with Outage Management have been implemented and verified.
The two CA's requiring the establishment of the interim outage management organization and the issuance of the temporary procedures 88-6, 88-7 and 88-8, have been implemented and verified.
The third CA requires SORC to review.all CA's; this will not be completed until )ust before restart.
The last two CA's require the submission of this RRR and its ultimate approval by the NRC Region I Administrator; the last one will not be achieved until Just before
- restart, This target is met to the extent possible at this time.
It will be fully met when the Company receives permission to restart the Unit.
Target SJ.2:
The Outage Management process is comprehensively identifying, monitoring and implementing and tracking to completion those activities required.for restart.
A3-27 0012A di".k 0056c
The Outage Manager has ident1fied, scheduled, and is tracking most of the items needed to be completed prior to restart.
A tracking system for items needed to complete this self-assessment is being developed.
When th1s system is 1mplemented, the Outage Hanager will be tracking all items to be completed prior to restart.
At the f1nal Panel
- meet1ng, the Panel suggested that all INPO and NRC commitments with a due date before restart be tracked by the Outage
- Manager,
'even though the commitments may not be directly related to restart.
This suggestion will be done.
This target will be met with the completion of the act1ons to 1ncorporate the Panel's suggestion..
e Target SI.3:
A plan and schedule has been developed for integrating the Outage Management function into the permanent Nuclear Division organization prior to the next scheduled Unit 1 refueling outage.
The Manager Nuclear Pro)ects Outages has been filled.
This person will incorporate the lessons learned by the Outage Hanager during the current outage.
A plan is 1n place to develop all the required procedures describing the duties of the new organ1zation so that the new organization can prepare for the next refueling outage.
This target is met.
The interim organization 1s in place and funct1oning effectively.
The required temporary procedures governing closeout of the restart related activities have been 1ssued and are being used.
The organ1zation has identified all activities needed for restart and executes the scheduling and track1ng functions and provides management with appropriate data.
The permanent organization has been approved and staffing is in progress.
The permanent organtzat1on has 1nit1ated act1v1ties to make the transit1on from the interim to the permanent structure; the lessons learned by the interim organization will be passed on to the permanent group.
Ool 2A disk 0056c A3-28
Sl-2 Maintaining Operator Licenses Operator licenses were not maintained in accordance with 10CFR55.
TARGET S2.1:
The RAP Corrective Actions and commitments associated with maintaining operator licenses have been implemented and
- verified, This target has not been fully met.
Ten of the seventeen RAP Corrective Actions have been closed out and the remaining are in progress and scheduled for completion prior to restart.
Based on the current status and progress to date the assessor concludes that all the RAP Corrective Actions associated with maintenance of operator licenses should be effect1vely implemented and verified and this target will be fully met.
Based on interviews, d1scussions, and observations, it is apparent that operations management has demonstrated ownersh1p of the operator train1ng programs.
Operator competency has improved and the training operation is running more smoothly.
Operators understand expectations regarding tra1ning attendance and conduct.
Operators also feel that operations management listens more to their problems, and they cons1der the environment to be more conducive to learning than it was a year ago.
Operators believe that forming OTPAC was one of the best things the Company could have done.
Operat1ons and Training were formerly adversar1al; now, they work together to resolve problems.
OTPAC meet1ng minutes are d1stributed to all shifts. Operators and 1nstructors believe management part1cipation occurs at the decis1on-making level. Operators have a better understand1ng of the fact that some things take time to correct.
An OTPAC meeting attended for assessment was well structured and held substantive discussions on a number of s1gnificant issues.
- Overall, a
profess1onal attitude was evident, the d1scussions were appropriate and maintained good 1nteraction, d1d not raise false
- hopes, and the cost of doing business was taken into account in discussing actions.
The Superintendent of Tra1n1ng assures tra1ning qual1ty by taking his own training and through discussions with tra1ners and operators.
As a member of
- OTPAC, he evaluates the tra1ning program, reports information to the Operation Superintendent, and conducts 1nteractions with the NRC and INPO.
He has discussed with senior management the problem of getting and retaining qualified operators in the Training department.
Additional pos1tions have been authorized and filled.
Of eleven positions authorized for training, eight have been filled, with three remaining open. If these pos1tions cannot be filled by Operations personnel, it may be necessary to use contractors.
0012A disk 0056c A3-29
The Supervisor of Simulator Technology reviews all modifications performed at the plant for simulator change applicability.
The 1ntent 1s for simulator modlficatlons to be implemented within 12 months following operations acceptance at the plant.
Simulator-plant fidelity differences are being discussed at training sessions.
Instructors are professional, knowledgeable on the sub)ect matter, welcome questions, stimulate the interest of operators, and, if answers cannot be given immediately, they are f~llowlng up appropriately.
Operator self-critique and instructor critique of operators'imulator activities appear to increase their attention and skill.
Procedure NTP-ll, "Licensed Operator Retraining and Continuing Training," was revised as a follow-up to an NRC exit discussion on the definition of responsibility.
Procedure NIT-2.1, dealing with records, was also revised to reflect the uniqueness of licensed personnel requirements.
- he assessor interview with the Training Records Supervisor indicates that the record-keeping requirements of 10CFR55 are being met by the present staff, and that the training dlrectlves of entering data within 10 days after activity completion are also being met.
An upgrade to the computerized record-keeping system is being implemented.
Target S.2.2:
Operators demonstrate a professional attitude in identifying and resolving problems and concerns associated with maintaining their operator licenses.
Based on personal observations of operators ln classroom and simulator training, personal dlscusslons with operators, review of the Quality Assurance interview feedback, and attendance of an OTPAC meeting, the Assessor,corlcl,uded that operators have demonstrated a professional attitude ln identifying and resolving problems and concerns associated with maintaining their licenses.
Operators understand and accept the general rising expectations of performance.
The conflict between operations and training that was observed and documented by regulatory agencies has been resolved.
The Assessor did not witness adversary or antagonistic relationships between operations and training.
Both operations and training management appear to be taking effective corrective steps ln resolving this issue.
This target has been met.
Target S2.3:
A process is ln place which will prevent recurrence of similar
The process to prevent recurrence of similar issues and to identify and resolve trends that could lead to NRC violations ls ln place.
Niagara Mohawk procedures have been established to meet regulatory requirements and provide proper controls.
Inconsistencies that exist between procedures, general
- orders, and definitions of responsibilities have been corrected or the specific corrective action is nearing completion.
This target will be met upon completion of the remaining RAP Corrective Actions and the actions identified ln Appendix 4.
0012A disk 0056c A3-30
Target S2.4:
The job and task analys 1 s for requal 1 f 1 cation of RO'/SRO' and development of training material based on. this analysis is on schedule for completion by July 31, 1989.
Based on discussions and observations, the assessor concludes that the development of training material resulting from the )ob task analysis is being appropriately prepared.
This target will be fully met when the actions are completed' A
mn Based on the preceding observations and discussions, the Corrective Action results provide management with assurance that operator license concerns dealing with operator training and qualification, procedures, administrative processes, and hardware will not have an adverse effect on safe operation of Unit l.
The conflict between Operations and Training that was observed and documented by regulatory agencies has been resolved.
During the assessment there was no evidence of an adversarial relationships between Operations and Training.
Operators have demonstrated a professional attitude ln identifying and resolving concerns associated with maintaining their license and they understand and accept rising performance expectatlons.
0012A disk 0056c A3-31
Si-3 Emergency Operating Procedures Implementation of Emergency Operating Procedures (EOPs) to respond to simulated plant transfents was 1ess than adequate.
Target S3.1; The RAP Corrective Actions and commitments associated w1th Emergency Operating Procedures have been implemented and verified.
I'his target has not been fully met.
Thirteen of the nineteen RAP Corrective Actions have been closed out and the remaining are fn progress and scheduled for completion prior to restart.
Based on the current status and progress to date the assessor concludes that all the RAP Corrective Actions associated with maintenance of operator licenses should be effectively implemented and verified and this target will be fully met.
Based on operator and instructor interviews, observation of operator performance, and review of lesson plans, training aids, examinations, simulator scenarios, and training records, the operators understand the bases of EOPs and believe that good guidance fs being given for plant responses to accident condftlons.
Operators are more confident ln using EOPs.
They consider the EOP flow-charts to be a significant improvement.
Tralners began to see progress during EOP tralnlng in the last quarter of 1988.
Because of the human factor reviews, operator involvement in EOP changes and validation and changes that occurred at the simulator, operator attitude and understanding have greatly improved.
Tralners believe the operators are becoming part of the solution for training and operatfng concerns.
Training attendance fs good, operators arrive on time, and they show a
professional attitude.
Most of the Station Shift Supervisors advocate
- training, and the goal ls excellence.
At training sessions for each of the five operating shifts and one staff shift there was good participation by Operations and Tralnlng management.
During management crftlques there was some tenseness;
- however, a professional attftude was generally maintained.
Operators were interviewed at random to verify the existence of a written EOP policy, their awareness of it, and their familiarity with its intent.
Procedure Nl-ODI-1.03 was covered ln Cycle II training and fn "Night Orders."
It appears that the policy was not well cmeunfcated fnftfa11y, but following training coverage of the issue, lt was well communicated.
The Operation Superintendent understands hfs responsibility and accountability for the EOP training program.
The Training Superintendent and instructors understand their responsibilities fn support of the EOP training program.
The Assessment indicated that the Operation Superintendent and Training Superintendent complement and support each other ln their different tasks.
0012A disk 0056c A3-32
There is stronger support by Operations and Training management in identifying deficiencies.
Implementation of the Systematic Approach to Training (SAT) is expected to result tn major changes.
Training supervfston reviews all course evaluation sheets and solicits direct feedback from operators.
Training has recently revised procedure NTP-11 to address delinquencies, deficiencies observed in operations shifts or individuals, and discipline problems.
Supervision in Training and Operations plans to rotate an SRO in t'i aining, to work with instructors, make observations and evaluations, give status reports on the simulator, and have daily meetings with training supervision.
The Training Superintendent works closely with the General Superintendent-Generatlon and the Executtve Vice President Nuclear Operations to resolve major issues. If training defici.encies occur, notices are sent to appropriate managers.
Htth installation of the computerized record-keeping
- program, the Operatton Supertntendent will be able to directly access pertinent training information.
The procedure AP-2.0 has been revised to include QA in the review of EOP procedures.
the QA Operations Surveillance group will be responsible for QA issues relating to EOPs.
Assessment interviews indicated that appropriate personnel are aware of the changes.
The Operation Superintendent is responsible for assuring that operators are tratned.
The Operation Superintendent demonstrates good management fn dealtng with people, respects the competence of the operators, allows and encourages the operators to learn, and requires strict adherence to training programs.
Operating procedures (OPs) are reviewed to ensure that sections referenced by EOPs address the tntended subject.
This has been an ongoing process that was lnitlally completed ln 8/88; however, because of changes made to EOPs,
- OPs, and special operating procedures (SOPs),
the process has continued, and is being tracked by the Outage Manager.
During walk-downs, ft became apparent that many tools to be used for performing OPs and SOP directives under emergency conditions were not properly identified, and there was not an available inventory of these special tools and equipment.
This situation ts befng corrected, and fs befng tracked by the Outage Manager.
An Operations Supervisory Instruction (OSI) to control EOPs has been issued and implemented.
This assures that procedures referenced by EOPs are not revised without first assessing the impact on EOPs.
A Human Performance Evaluation was completed on 2/1/89 and addressed 21 suggested corrective actions.
As revealed during interview feedback and personal discussion, one of the reasons for past problems was that operator training appeared to be Training's problem rather than Operattons'roblem.
In the past, trainers sometimes felt they were "operating fn a vacuum."
Presently, the Operations Superintendent is clearly responsible and accountable for operator training, and the Training Department provides the training. Further, the operators believe they share responsibility for their training.
0012A disk 0056c A3-33
Hith the change-over to flow-chart EOPs, operators are more confident in dealing with emergency condit1ons.
The orig1nal EOPs were confusing and extremely difficult to follow.
Target S3.2:
The EOP's to be implemented in an emergency have been verified and validated.
The current set of EOP's are adequate to assure the Company that the plant can be operated without an adverse impact on safety.
This Target will be fully met when all the RAP Corrective Actions 'are completed.
- However, based on review of the issues, personal observations, and planned actions by Niagara Mohawk, the assessor concludes that the EOP's are being effectively addressed to assure that the plant can be operated without any adverse impact on safety.
Target S3.3:
Administrative processes and procedures are in place to be sure that EOP's, EOP support equipment, and supporting procedures are maintained effectively.
This target has been met.
The assessor has determined that the process and procedures are in place for effective maintenance of the EOP's and their supporting procedures and equipment.
Target S3.4:
All NMP-1 operating crews have been tra1ned in the effective use of and understand the basis.for the content of the EOP's, with respect to the1r assigned responsib111ties.
This Target has been met.
As stated
- above, the operators understand the basis of the EOP's and they believe that proper guidance is being given for plant responses to acc1dent conditions.
Operator involvement in EOP changes and validation have had a positive effect on their usage and understanding of EOP's.
All the NMP 1 operating crews have been trained in the effective use of, the EOP's.
Target S3.5:
The requalification program has been enhanced to increase operator skill and prof1ciency such that operating crews will maintain
.a high level of performance in the use of the EOP's.
This Target has been met.
The process of enhancement of the requalification program is in place.
The attendance at training is good; operators appear at training 1n time and generally show a professional att1tude.
The Training Superintendent and Train1ng Instructors understand their responsibilities in support of the EOP train1ng program.
The Operat1ons Superintendent and Train1ng Instructors understand the1r responsibilities in support of the EOP training program.
The Operations Superintendent and Training Superintendent complement and support each other's ac1tivity, and training deficiencies are quickly 1dentified.
The Operations Superintendent meets with each shift at the completion of the training cycle to discuss areas of 'concern and how to improve the program.
A method is in place for evaluation of trainers and simulator scenarios.
This whole process will assure that operating crews maintain a high level of performance.
0012A disk 0056c A3-34
Target 83.6:
EOP instructors'ualification and certification records are up-to-date and the process for maintaining these records has been enhanced to ensure that records are maintained current.
This Target has been met.
All required records related to instructors'ual1fication and certification records are in place and fully satisfy procedural requ1rements.
Procedures have been revised to ensure that these records are maintained current.
Target S3.7:
There 1s a process 1n place for the operators and instructors to collaboratively assess the effectiveness of the EOP training.
This Target has b'een met.
Based on interview feedback and personal d1scussion, the Assessor concluded that previous problems in this area ex1sted because operator training was perceived by the organization to be the responsibility of the Training Department and not Operations Department.
At present, it is clear that the Operations Superintendent is responsible for the
,training of h1s operators, that the Training organization is the means by which operators receive the necessary
- train1ng, and that the operators also bel1eve that training is their responsibility. 'he operators appear to be part of the solution to problems.
Other factors that support the conclusion that this Target has been met are included in the previous discussions for Targets 1
and 5.
Based on the preceding observations and d1scussions, Spec1fic Issue 3 results are sufficient to resolve EOP related
- problems, and to prov1de assurance to management that EOP issues relat1ng to operator tra1ning and qual1fication, procedures.
administrative processes, and hardware deficiencies will not have an adverse effect on safe plant operation.
0012A disk 0056c A3-35
Sl-4 Inservice Inspection The Unit 1 first 10-year In-Service Inspection (ISI) interval ended in June 1986, concurrent with completing the
'l986 outage.
Two months later, a concern about a through-wall leak on the reactor building closed loop cooling heat exchanger was 1dentif1ed to management.
Investigation of this concern led to discovering an incorrect disposition of a defect reported during I'SI hydrostatic testing.
In July 1987, QA conducted an audit of ISI deficiency procedures.
This audit 1dentified several deficiencies in the Deficiency Corrective Action (DCA) process.
Further investigation disclosed that a number of components listed in the ISI program were either not examined or were missing records for the examinations by the end of the interval.
The investigation scope was expanded, and it was determined that other examinat1ons required by the ASHE Code were not included in the program plan.
Subsequent Niagara Hohawk reviews identified several omissions or errors 1n the first and second l0-year-interval program plans.
Target S.4.1:
The RAP Corrective Actions and conmitments associated with inservice inspect1on have been 1mplemented and verified.
The intent of this Target has been satisfied;
- however, the Target will be fully met upon close out of the remaining RAP CAs.
The ISI organization and assignment of responsib1lities has been completely revised.
The original contractor st111 performs many of the Unit l examinat1ons, but they are now completely under Niagara Hohawk's QA Operations NDE (NQAO-NDE) Supervisor.
Their remaining respons1bilit1es are also under the ausp1ces of Niagara Hohawk personnel.
Currently, the site ISI Coordinator is responsible for developing the ISI program plan and scheduling examinations.
The NQAO-NDE group is responsible for:
writing examination procedures performing examinations record1ng results evaluating results issuing NCRs review1ng the disposition of NCRs As part of the correct1ve action program, Niagara Hohawk committed to verifying that all exam1nat1ons comm1tted to be performed in the first 10-year-interval program have been completed by the end of this outage.
The process 1nvolved rev1ewing the first 10-year-interval program plan and delineating the exam1nat1on requirements.
Data packages were assembled for each required exam1nation.
Through interv1ews and selected review of process documents, it is evident that the process was well planned and executed, reviews were thorough, personnel were well qualified and dedicated, and results were well documented.
0012A disk 0056c A3-36
Target S.4.2:
The system boundaries, components and the necessary inspections to satisfy the requirements of the ASHE Section XI 10 year lnservice inspection are clearly identified in a Niagara Hohawk lnspectlon plan for Nine Mlle Point Unit 1 (for the past and current 10 year intervals).
This Target has been met.
The ISI program requirements were established from Sections IWA, IWP, IHV, and IHF of ASHE XI. The requirements of Sections
- IHB, IHC, and IHD establish the inspection requirements and are discuss'ed later.
In addition, the requirements of 10CFR50.55a were examined and compared with our ISI program. Finally, the ISI program was compared to the Inspection Requirements of NRC Inspection Procedure
- 73051, The requirements of ASME XI were compared to two top-level documents (XI-P and AP-8.3) to see if each Code requirement had an analogous requirement in both of these documents.
A comparison of these documents was also made for consistency in the assignment of responsibilities to various Niagara Mohawk organizations.
Unit 1 is exempt from the requirement of IHA 1500 by 10CFR50.55a.
Responsibility for meeting all of the remaining requirements has been assigned by ASHE XI-P.
Target S.4.3:
All inspections required to satisfy the past 10 year inservlce inspection interval have been completed.
The intent of this target has been met ln that all inspections have been identified and scheduled.
Based on the results of CAs 4,A.5, 4.B,4, 4.D.2, and the response to operative CARs, all of the inspections required by the first 10-year-interval program plan will be completed by the end of this outage.
The completion of these inspections will satisfy this target.'arget S.4':
The interim organization with the necessary resources as well as the responsibility and authority to effectively manage the implementation of the inservice inspection program is ln place.
This Target has been met.
Interviews with key supervisors indicated their satisfaction with the resources at their disposal to implement the ISI program.
Although some growing pains have been experienced, the interim organization is functioning very well.
Target S.4.S:
Approved interim administrative processes and procedures governing the implementation of the inservice inspection program, particularly the disposition of identified deficiencies, are ln place.
This Target has been met.
The assessor has reviewed all applicable procedures and has found that they comply with the appropriate sections of the ASHE Codes and NRC requirements.
The assessor found some instances where clarification could make the procedures easier to use, There were places where lt was not apparent whether the procedure applied to Unit 1
or Unit 2.
The assessor recommended that the Company review the way procedures are related and clarify them where required.
This suggestion for improvement will be pursued after restart.
0012A disk 0056c A3-37
I An appropriately detailed plan and schedule to establish and transition the responsibility for inservice inspection to a permanent organization is in place.
The intent of this target has been met.
Although there is no written plan in
- place, the permanent ISI organization is described quite accurately by the Unit 2 procedures, although the detailed roles and responsibilities of some members of the organization are different from the roles described in these procedures.
The roles and responsibilities have continually evolved during the course of the assessment.
The creation of a permanent ISI organization is a specific requirement of the NIP.
The permanent organization ls to be in place for the next scheduled Unit 1 outage.
The ob]ective of the NIP ls being achieved through the creation of roles and responsibilities in developing the ISI field organization as it evolves from an interim into a permanent organization.
Target S.4.7:
Personnel in the organization using contractors are familiar with the processes and procedures relating to control of contractors.
NMPC Policy NHPD-30 has been developed for the control of contractors to NMPC and will be issued during September 1989.
Hhen issued, this target will be sati sf 1 ed.
As a result of the comprehensive document review, interviews with key NMPC personnel involved in the ISI program, NHPC response to the CA's.
and the results of the independent vertical slice on the Core Spray System, it can be concluded that all of the regulatory requirements for the First and Second Ten Year Intervals have been satisfied and that the CA's and Targets specified to be achieved prior to restart will be met by that time.
0012A disk 0056c A3-38
SI-5 Control of Cominercial Grade Items During a Niagara Mohawk QA audit in October
- 1986, commercial grade items were identified that had been accepted without an adequate engineering evaluation.
This allowed items to be avat'lable for tssue tn safety related systems for which acceptability could not, be demonstrated.
I A
m 1
Target S.5.1:
The RAP Corrective Actions and commitments associated with the control of commercial grade items have been implemented and verified.
This Target has been met.
The assessment of the evaluation of previously-procured commercial grade items fs based on sample-basis verifications and INPO exit briefing comments.
INPO commented that the Materials Engineering group fs "performing exceptionally well and will be noted for a 'good practice.'his fs further attested by the following SALP report statement:
"The licensee has developed a detailed commercial grade dedicated program to upgrade equipment to safety-related status.
This program was developed based upon discovery by the licensee of weaknesses ln the
[NSSS vendor's]
coneerctal grade items dedication processes and the necessity to resolve potenttal electrical equipment safety concerns prior to Unit 2 initial licensing.
The licensee's pr'ogram employs the EPRI guidelfnes and the documented engineering evaluations were determined to be thorough and technically sound."
(SALP Report no. 50-220/88-99 and 50-410/88-99)
Target S.5.2:
Personnel ln the various organizations (Hatertals Hanagement, Purchasing, Maintenance, Quality Assurance, Oestgn Engineering, Operattons) know how their function contributes to the control of ccxwnercfal grade items and how to implement proactive steps to resolve problems associated with the control of coinercfal grade items.
This target has been met.
Control of coinercfal grade items is assured;
- however, because the process and procedures are relatively new, many of the lndtvlduals fn supporting organizations are learning how their function contributes to the control of cownercfal grade
- ttems, and how to implement proacttve steps to resolve problems associated wtth this control.
In interviews, specific examples of inefflcfencfes or delays in the material control process were cited, but strong control of commercial grade items was acknowledged.
Improved coanuntcatton among Hafntenance, Material Control, Procurement, and Haterlals Engineering were suggested by each of these groups as a means of improving the efftcfency and effecttveness. of the process.
0012A disk 0056c A3-39
Maintenance personnel also indicated that setting and communicating priorities sometimes contributed to frustration based on unavailability of parts.
Interviewed personnel related some of the technical issues that complicate such issues.
The Supervisor - INC indicated that some of the slow response in getting parts was because of lack of automatic re-stocking, The Manager Nuclear Generation Haterial Management indicated that the system ls capable of automatic economic order points, but historical information for order points does not yet exist.
This information is being accumulated and will be input to the system as acquired.
Based on the results of interviews, organizations outside of Materials Management and Materials Engineering are near the top of their learning curve on the commercial grade material program.
The program ls effective in controllfng commercial grade
- items, but has not yet matured to the point of achieving rapid response and high efficiency.
Target S.5.3:
The permanent staffing of Haterials Engineering and the integration of Haterlals Engineering with interfacing organizations is proceeding on schedule.
This Target has been met.
The Haterlals Engineering group was formed more than a year ago and has been staffed with a few key permanent employees and a
relatively large number of contractors.
The Hanager-Haterials Management indicated that the large staff of contractors will be required for some time, and permanent employees will be added to the staff as the equilibrium staff level becomes better defined.
The assessor considers this to be a prudent approach'arget S.5.4:
Actions have been taken or are planned that will lead to the early identification and resoiution of material controi problems fn the future.
This Target has been satisfied.
Regular materials management meetings are held at the site and Salina Meadows.
The Hanager Haterials Engineering meets regularly with senior management and the Outage Hanager to facilitate cemunfcations for potential materials problems.
He has been lnltlatlng cceeunfcatfons with other utllltles to share experiences and data, and to explore the potential for cooperative ventures ln coaeercial grade items procurement.
These activities assure that recurrence of this concern will be prevented.
A successful program for controlling cceeercfal grade items has been developed and implemented.
The process ls relatively new and personnel are learning the process.
As training and experience are accumulated, efficiency and responsiveness will continue to increase.
0012A disk 0056c A3-40
r Sl-6 Fire Barrier Penetrations Hhlle installing a modification on 3/26/88, a wood plug was discovered in a fire barrier under the Unit 1 battery rooms.
Further investigation identified additional fire barrier penetrations that deviated from design requirements.
Therefore, Niagara Mohawk initiated a program to evaluate the adequacy of fire barriers having regulatory significance.
Ourlng the root cause evaluation of the fire barrier penetration discrepancies, Niagara Mohawk discovered that open items remained from an audit conducted by Gage-Babcock between 1984 and 1986.
These open items covered other areas of the Fire Protection
- program, beyond fire barrier penetrations.
Therefore, Niagara Mohawk extended the restart program to include the fire barrier evaluation and close out all open items from the Gage-Babcock audit.
Target S6.1:
The RAP commitments including text, corrective actions, and responses to NRC questions associated with the Fire Barrier Penetrations have been implemented and verified.
The RAP comnitments are in varying stages of completion; they will all be completed before restart.
As the assessment was carried out, several questions and suggestions for improvement were raised by employees,, All questions regarding the adequacy of the work performed were resolved; the suggestions for improvement will be factored into the long term program for maintaining the adequacy of the fire barriers.
This target will be fully met before restart when all CA's and associated items in Appendix 4 are closed.
Target S6.2:
The installed configuration of the fire barrier penetrations is equivalent to those tested and meets the requirements of the fire barrier itself as defined in the Fire Hazards Analysis.
The existing program was reviewed by a consultant.
It was found that the existing penetration seals were acceptable or had been repaired and were ln conformance with the current seal designs.
The physical condition of the existing penetration seals was found acceptable.
Addltlonal field checks or calculations will be completed prior to restart, ln order to get the statistical confidence level to the desired level.
Hhen these actions are complete this target will be fully met.
This target will be fully met before restart when all CA's and associated items in Appendix 4 are closed.
Target S6.3:
An effective process, including trained resources, is in place to monitor and evaluate the condition of fire barriers.
The assessment brought forth criticisms of the existing procedure and the drawings ln that they are cumbersome to work with since the drawings have too much detail and the procedures could be clearer.
The procedures will be 0012A disk 0056c A3-41
clarified and the Company will determine whether it is feasible to produce a
simpl1fied drawing from ex1st1ng drawings for the fire department to use during inspect1on walk-downs.
It should be noted that the fire department personnel d1d consider the existing documents usable as they stood today.
A consultant reviewed the Company's program and recommended strengthening programmatic controls and technical informat1on regarding percent fill, maximum opening
- s1ze, and maximum separat1on.
The existing program is effective, but the recommendations for improvement will be factored into the program after restart.
Th1s target is met based on the adequacy of the ex1sting program.
Target S6.4:
The design basis for fire barrier penetrations is documented w1th necessary revisions incorporated and actions have been implemented that assure that this des1gn basis will be mainta1ned.
Engineering Procedure NEL-046 has been issued.
It covers interfaces within Engineering and the need for multi-discipl1nary review.
The assessment determined that the current design basis documentat1on was adequate, but that concerns regarding drawing control and barrier definition would be included in the Configuration Management Upgrade Program discussed under Specific Issue 14.
Th1s target is met in principle as a result of the determination that the current design bas1s is adequate.
It will be met in total before restart when the breach perm1t procedure is final1zed and the data base maintenance resources are finalized.
Target S6.6:
An effective plan is in place to transition the maintenance respons1bility for this design basis from the task force to the permanent organization.
A program manager has been appointed and a plan is in place to capture the lessons learned from the fire barrier task force.
This target is met.
Target S6.6:
An effective plan is 1n place to ensure that future audits of the fire protection program are appropriately coordinated and followed up.
Engineering Procedure NEL-046 addresses future QA audits includ1ng the responsibility for execution of the aud1t and for any requ1red follow-up.
The procedure w111 be revised to handle all future audits.
This target w111 be met before restart when the procedure is changed.
The problem, associated root causes and corrective actions as described in the RAP were found to be adequate and comprehensive.
The ex1sting penetration seals were acceptable or had been repaired and are in conformance with the current seal des1gns.
The phys1cal condition of the existing penetration seals was found to be acceptable.
During the course of the assessment.
there were several findings and resultant recommendations.
All of the findings required for restart have been resolved to the po1nt where the assessor is confident that restart will not be affected.
0012A disk 0056c A3-42
SI-7 Torus Wall Thinning During an inspection conducted in 4/88 and 5/88 (combined Inspection Report 50-220/88-09 and 50-410/88-09),
the NRC performed independent measurements of torus wall thickness.
The NRC's measurements were close to the minimum wall thickness required by our original stress calculations and NMPC's Mark I containment program calculations.
The NRC inspectors believed it was necessary for Niagara Mohawk to take action before the next (1990) outage, and requested us to provide justification for operation until 1990.
Target S7.1:
The RAP Corrective Actions and commitments associated with torus wall thinning have been implemented and verified.
This target ls met.
The Niagara Hohawk position on Torus wall thinning was presented in a 4/26/88 meeting with the NRC.
The presentation included statlstlcal analysis of the wall thickness reduction trend, analysis of the increase in margin that might be gained by considering actual plate material
- strength, and evaluation of the effect of local areas of less than general area minimum wall thickness.
Evaluation of the effect of local thinning had been performed by Teledyne as part of the overall analysis of torus wall strength requirements.
In a subsequent 6/17/88 letter (NHP1L 0272),
Niagara Mohawk committed to torus shell thickness measurements approximately every 12 months, Niagara Mohawk's letter of 1/12/89 (NHPlL 0343) revised this interval and states that torus wall thickness measurements will be performed every six months (beginning after 4/30/89) until the long-term corrective actions have been completed.
Responsibility for Site NRC inspections was assigned to Regulatory Compliance, and Salina Meadows inspections to Licensing.
Hall thickness measurements were made in 4/88. at the locations previously monitored, and again in 11/88, at two locations that had previously been monitored (135/ azimuth at bottom and waterline) and established additional locations f'r measurements of torus wall thickness at 0, 90,
- 180, and 270 azimuth.
An NRC inspection was conducted ln 12/88, in which wall thickness measurements were again made by the NRC.
The results were summarized as follows:
"Thickness measurements of three grid areas...on the torus for minimum overall thickness were performed.
No violations were identified and no discernible change in the torus wall thickness occurred since previous NRC inspections were conducted ln April, 1988." (IR 50-220/88-81)
The same report noted the cmeltment to submit a letter to the NRC by 1/31/89 defining the schedule for long-term corrective action and stating an intention of perform wall thickness measurements approximately every six months until those actions have been implemented.
0012A disk 0056c A3-43
Target S7.2:
There is a documented and scheduled program for addressing torus wall thinning.
The torus wall thickness
- program, which documents and schedules the long-term approach for tracking torus wall thickness, was approved in early 4/89.
This plan was the bas1s for the 4/89 measurements discussed 1n the preceding paragraphs. It also specifies that measurements will be taken approximately every six months, starting from 4/89, Niagara Mohawk's 2/14/89 letter informed the NRC of a decision to install mid-bay saddle supports on each of the 20 torus bays.
The letter also stated the following:
The plan was to complete the 1nstallation by the end of the next scheduled refueling outage.
There was some uncertainty regarding the schedule because of incomplete engineering status.
Niagara Mohawk may (at some future t1me) want to delay saddle support installation until a later refueling outage, based on analysis of actual material properties.
Analysis of allowable stress intensity based on cert1fied material test reports (CHTRs) indicates the init1al design margin is greater than indicated by allowable stress intens1ty values from the ASHE Code.
CHTRs for the mater1al used for the construct1on of the torus are available although 10 to 15 percent of the certifications cannot be identified to spec1fic plates used in the construction of the torus.
The company has been able to determine that materials for which CHTR's could not be identified were not used 1n the thinnest reg1ons in the bottom of the torus.
The thinnest plates are those for which the CHRS's are positively identified.
The addit1onal margin which would result from actual mater1al properties would permit operation beyond the next refueling outage.
It is the assessors understanding that work by Teledyne, Inc. under this program has led to alternat1ve structural modifications (straps or lateral beams) that may be more effect1ve than saddle supports.
The data acquired in the inspect1on indicate that the design evaluation program being conducted by Teledyne incorporating alternative des1gn mod1f1cation approaches will be effect1ve in addressing the torus thinning issue from a structural perspective.
The program referred to above constitutes completion of the corrective action and has provided the basis for a comprehensive follow-up on the assessors'bservations.
The second target is considered as having been achieved.
Target S7.3:
NRC inspect1ons are being appropriately coordinated and supported.
The ass1gnment of coordinat1on respons1b111ty, together with positive feedback from the NRC, 1ndicates that NRC 1nspect1ons are be1ng appropriately coordinated and supported.
Therefore, the third target 1s considered to have been accomplished.
0012A disk 0056c A3-44
mm r m
n
-7 The assessor reviewed documentation and backup calculations performed by the Company and questioned the adequacy of the data and statistical analyses.
The Company performed additional thickness measurements and performed more rigorous analyses on the data.
Interior inspections included visual, photographic, and surface impressions.
Area averaged ultrasonic measurements of the thickness of each plate making up the bottom mid-bay portion of 20 torus bays were taken.
The analyces, performed by HPR Associates, Inc.
and accepted by the assessor, cv'ncluded that the torus wall thickness is adequate for more than the next operating cycle.
Based on this assessment all the targets have been achieved.
0012A disk 0056c A3-45
Sl-8 Scram Discharge Volume In 12/87, a concern was identified with Niagara Mohawk conformance to the 6/24/83 Confirmatory Order relating to the scram discharge volume at Unit l.
The items under question dealt with level instrument taps location and performance of a 50 percent control rod density test.
Through discussions and meetings with the NRC, these items have been satisfactorily resolved, with.the exception of a periodic testing 'program to assure continued operability of the scram discharge volume.
The periodic testing issue will be resolved by submitting a Technical Specification change to require a fill and drain test of the scram discharge volume each refueling outage if a scram has not occurred during the previous operating cycle, or if the pressure boundary has been breached.
Target S8.1:
The RAP Corrective Actions and commitments associated with scram discharge volume have been implemented and verified.
This target has been met.
A revision to Nuclear Division Policy No.
3 was approved by the Executive Vlcc President - Nuclear and issued on February 27, 1989.
This revision addressed the need to obtain formal NRC concurrence on Niagara Mohawk Actions with respect to exceptions to new or revised regulations.
A test on June 17, 1989 demonstrated the adequacy of the Scram Discharge Volume.
On October 12, 1988.
the NRC issued a letter concurring with the test method.
Target S8.2:
The organization and functional responsibilities associated with the interpretation, implementation, and management of ccemitments, as well as exemption requests, is clearly determined and understoo'd within the Nuclear Division.
This target will be met.prior to restart with the completion of the actions identified in Appendix 4.
The policy for control of NRC comnitments,
- DCP3, will be revised, and the functional organization charts reissued to ensure clarity of responsibility for making comaltments to the NRC.
Target S8.3:
Personnel understand and implement related policies.
This target will be met prior to restart with the completion of the actions to address Target S8.2 and coneunication of these actions to appropriate personnel.
A procedure for tracking comnltments on the NCTS by Licensing staff has been developed and issued.
A test of the. adequacy of the Scram Discharge Volume was conducted and the NRC concurred with the test method.
A revision to NDP3 has been drafted and agreed to by the assessor.
Functional organization charts will be revised to be consistent with this policy and will describe the responsibilities associated with the interpretation, implementation, and management of comnltments.
Implementation of the NCTS will help to ensure that personnel understand and implement related policies.
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Si-9 Emergency Condenser and Shutdown Cooling Valves Niagara Hohawk made several commitments to the NRC to resolve the Appendix J
issue for Unit 1, and revise the Technical Specifications and FSAR to be consfstent with Appendix J requirements.
Exemption requests were submitted for certain valves; however, it was not followed up with the NRC to ohtain their approval of our Appendix J problem and exemptions, The main issues to be resolved for Appendix J are testing the emergency condenser condensate return valves and the valves in the suction isolation
- valves, which had to be local leak rate tested ln accordance with Appendix J.
These were considered to be extensions of containment and/or closed systems.
Based on this consideration, Niagara Mohawk had not performed Type C local leak rate tests on them.
Target S9.1:
The RAP CAs and commitments associated with Appendix J testing of valves has been implemented and verified.
The exemption requests have been submitted to the NRC.
Review of the NRC responses confirmed that the exemption requests for the emergency condenser valves and the shutdown cooling system valves were approved.
A water seal procedure for the containment spray valves has been prepared.
A Safety Evaluation and modification necessary to implement the procedure are being developed.
These actions and approval of the procedure by the NRC must be completed prior to restart.
An exemption request for the containment spray discharge line isolation valves must be submitted only lf the procedure being developed for the containment spray system is not approved by the NRC.
In addition to verifying the specific CAs, the assessment plan verified agreement between the NRC and Niagara Mohawk on all Appendix J issues.
Review of the
- SER, Niagara Mohawk's clarification letter, and the NRC response letter confirmed that the NRC and Niagara Nfohawk have agreed on the resolution of all Appendix 3 issues.
IST personnel verified that all items in the SER that were determined to be IST issues rather than Appendix J issues were being tested in accordance with the IST program.
Licensing confirmed that all agreed-upon Technical Specifications changes are being developed, none of which are required for restart.
Target S9.2:
A schedule exists for implementing the program for satisfying schedular exemptions taken to Appendix J.
Modification Requests to replace these valves ln order to make them testab1e in accordance with Appendix J requirements are presently in the review and approval process.
The modifications are currently scheduled for the next refueling outage.
0012A disk 0056c A3-47
Target S9.3:
A process is in place which will assure the Company that the scope and content of the Append1x J testing program is maintained current and 1mplemented in accordance with the NRC Appendix J safety evaluation and Technical Specifications.
0 This Target has been met.
NMPC personnel have partic1pated in the BWROG effort to develop a program plan to implement Appendix J.
This program has been completed by the BWROG and is being prepared for submission to the NRC for their review and approval.
Using this program plan, NMPC is developing a
NM-1 Appendix J Program Plan.
In addition, a Containment Specialist position has been created in the Systems Engineering group within Nuclear Generation.
It is intended that this person will be the single point of accountability for the Appendix 3 program.
Having a defined program plan and single point accountability should result in an up to date Append1x J program and assure that the program is mainta1ned current and implemented properly.
Based on observat1ons and d1scussions, Niagara Mohawk and the NRC are in agreement regarding Appendix J at Unit l.
To maintain the Appendix J program current, Niagara Mohawk is are developing an Appendix J program plan.
This plan will address all aspects of Appendix J
and w111 be adm1n1stered by a specific department and person, similar to the IST program.
0012A disk 0056c A3-48
SI-10 Reactor Vessel Pressure/Temperature Curves 1
n:
The chemical composition of vessel material surveillance coupons removed from the vessel was compared with the vessel base metal.
This revealed that the original coupons might have been made from a different heat number than marked.
Target S.10.1:
The Restart Action Plan,(RAP) Corrective Actions associated with Reactor Pressure Vessel P/T curves have been implemented and verified.
This target has been met; both corrective actions associated with this target have been closed out, verified and deemed acceptable by the assessor.
A letter was submitted to the NRC on June 16, 19SS to notify them of the possible discrepancy by the Company, to summarize the information available to the Company, and to )ustify the use of the existing pressure-temperature curves.
After receipt of the Niagara Mohawk letter the NRC performed a safety evaluation which was transmitted to the Company on September 14, 1988.
The evaluation concluded that the pressure-temperature limits are conservative and therefore acceptable, completing the corrective action.
Target S.10.2:
There ls a documented and scheduled program for developing
'orrect data for the PIT curve.
This target has been met.
Activities associated with this effort are in the lnltlal stages and address the NRC concern that the Company should determine the ldentlty of the test material ln the surveillance program and submit revised pressure-temperature limits before the current limits expire at the end of thirteen effective full power years.
One of the actlvltles which ls underway is an investigation at Battelle-Ohio to resolve the possible discrepancies in the identification of surveillance capsule materials.
That investigation will rely on chemical and metallurgical evaluations and various documentation related to construction of the pressure vessel.
The results of this investigation should permit a determination of whether the pressure-temperature limits might be revised, based on identification of the vessel material, to be less conservative.
These activltles are being performed as part of the NIP Program Item N.6.1.11.
The exchange of letters between the Company and the NRC dealing with the RAP Corrective Actions constituted completion of the corrective actions
- and, therefore, of the first target.
The second target deals with the longer term (after restart) where technical questions related to reducing the conservatism ln the current operating constraints are to be resolved.
A NIP program has been established to address this long-term need; based upon the assessor's review of this NIP item, the requirements contained in the second target are satisfied.
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Sl-11 Erosion/Corrosion Program In combined Inspection Report 50-220/88-09 and 50-410/88-09, the NRC identified a concern regarding implementation of the Unit 1 Erosion/Corrosion Program.
As noted ln 50-220/88-09, the NRC examiner felt that procedures for taking balance-of-plant piping measurement data did not establish adequate controls over the process to provide meaningful data and assure re'peatabllity of thickness measurements.
- However, the NRC examiner had been given incomplete raw data, which had not been reviewed or accepted by Nuclear Engineering and Llcenslng.
The concerns did, however, reveal the need for improving the oversight of contractor activities.
Target S11.1:
RAP Corrective Actions associated with the erosion/corrosion program are to be implemented and verified.
This target has been met.
All RAP corrective actions for this issue have been completed, verified and closed by SORC.
Target S11.2:
Contractor procedures and instructions are clear.
This Target has been met.
The assessor believes that the CB&I pipe marking procedure that led to difficulties in assuring repeatable measurements is, ln the present revlslon, reasonably clear.
Target S11.3:
Appropriate Contractor oversight actions are being effectively implemented.
This Target has been met.
The Erosion/Corrosion program definition model's the approach recommended by NUMARC, but in the current revision does not specify organizational responsibilities.
The organizational responsibilities for the program are defined ln a draft version of the Unit 2 program.
Oversight of contractors has been addressed by a recently issued Nuclear Division Policy.
The next inspections will be performed during the next refueling outage.
The assessment actions found that pipe wall thickness measurements have been made ln conformance with the erosion/corrosion program.
Relevant procedures have been revised to address concerns about consistent marking of piping and components to assure repeatability of measurement location.
A review of the contractors practices, and the Company's oversight, indicates that they are now appropriate.
0012A disk 0056c A3-50
Sl-12 Motor-Generator Set Battery Chargers In preparation for a 10CFR50.59 review, Engineering.
Operations, and Licensing began a complete review and verification of the 125 VDC electrical system design basis.
During this rev1ew, it was discovered that the safety classificat1on of the motor-generator set battery chargers (M-G sets) did not properly reflect their intended post-acc1dent function.
In 1983, M-G sets l61 and l71 had been reclassified to non-safety related.
Consequently, for approximately five years, work had been periodically performed without requiring application of 10CFR50 Appendix 8.
Target S12.1:
The RAP Correct1ve Actions and commitments associated with the Motor/Generator Set Battery Chargers are implemented and verified.
The intent of this Target has been satisfied, but the Target will not be fully met until all RAP CAs are closed out.
Append1x B determ1nation documentation has been prepared and the Q-List updated to reclassify the M-G sets as safety related components.
A Lessons Learned Transmittal that details the concern and includes cautionary statements about using inadequate documentation has been issued and reviewed by personnel involved in Append1x B determinations.
A cross-disciplinary review was conducted of system and ma)or component-level determinations that have downgraded components from safety related to non-safety related to ensure adequate Justification and accuracy, and to document the results 1n a report.
The cross-disciplinary review report is completed.
Sixteen Appendix B
determinations for downgrading systems or components were reviewed by a task force cons1sting of consultants from Licensing, Techn1cal
- Services, Mechanical
- Design, and Electrical Des1gn.
Task force results were positive in terms of accuracy of determinations.
- However, several open items remain in the report, and reccmlendations were made for improving Appendix B determinations in the future.
The MG set components installed after 1983, and maintenance work that has been done were 1nvestigated to determine whether qual1ty requirements of 10CFR50 Appendix B and qualif1cation requirements were met.
The results were documented in a report. Also, non-conforming items were corrected by dedicating them or replacing them with items procured as safety related as specified in NCRs based on report findings.
An Engineering Report has been prepared that includes the design basis for the Battery Chargers,
- however, the report is being rev1sed to incorporate Justification for the ratings of the Battery Chargers.
Change documentation has been prepared to update the FSAR and other documents to reflect that the Battery Chargers are now classified as safety related.
0012A disk 0056c A3-51
Target S12.2:
Safety classifications are performed properly.
This Target has been met.
Procedures are in place that provide a framework for guiding personnel through the process of Append1x B determinat1ons in a consistent manner.
As a supplement to these procedures, a methodology has been developed covering both the gathering of documentation pertinent to the safety evaluation being performed and review of the validity of that documentation for use by the performer as the bases for the evaluation be1ng conducted.
The methodology will provide for cross-disciplinary rev1ews of safety evaluations to aid in preventing insufficient documentation from influencing the outcome of the safety evaluation.
Target S12.3:
Personnel involved in safety classificat1ons understand the specif1c
- issue, Niagara Mohawk policies, and regulatory requirements.
This Target has been met.
A Lessons Learned Transmittal has been prepared and issued to Licensing personnel which describes what is considered to be good engineering practice in performing Append1x B safety evaluation determinations for Nine Mile Point Unit 1.
The assessment found that the MG set battery chargers have been classified as safety related and the Q-11st has been updated.
A task force reviewed and found acceptable the Appendix B determinations that had downgraded systems or components.
Procedures for performing Appendix 8 determinations have been augmented to provide guidance on the technical aspects of the process.
Appropriate training wi,ll be provided, Hhen the training is completed and all open items are closed, the causes of this issue will be appropriately addressed.
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Sl-13 18C Technician Al legation Issue As a result of 14 allegations made by an I&C technician in 7/86, Niagara Mohawk conducted an ln-depth evaluation of the specific allegations and their programmatic lmpllcatlons.
The evaluation indicated four programmatic areas common to the issues:
Root cause evaluation Procedure compliance Material control Management effectiveness A task force was formed to evaluate the specific technical issues.
Additionally, an advisory committee was established to evaluate the outcome of the technical issues review and to assess the programmatic areas.
Based on this evaluation, Niagara Mohawk developed short-term and long-term programs to correct the specific programmatic
- areas, If all of these long-term programs had been implemented, Niagara Mohawk would still have fallen short of resolving the problems relating to this area.
Target S13.1:
The RAP CA's and commitments associated with the implementation of long term programs related to I&C technician allegations have been implemented and verified.
Based on interviews conducted by the assessor, responses received from a questionnaire, review of progress made on Underlying Root Cause 4'2 (Problem Solving),
and personal observation on the effectiveness of getting employee buy-in as part of executing the RAP CA's, the assessor
)udges that this target has been met.
Target S13.2:
A RAP for Nine M11e Point 1
has been developed and is being implemented which has the following characteristics:
a.
A comprehensive problem identification process has been implemented to provide management a high degree of assurance that problems impacting performance of the organization and the plant have been identified.
b.
A systematic assessment of the root causes of the problems has been conducted.
c.
Personnel impacted by the actions ln the RAP have been sufficiently involved ln the development or approval process of the corrective actions such that they know and but-in to these actions.
It ls the assessor's opinion that the RAP satisfies this target.
0012A disk 0056c A3-53
Several individuals were 1nterviewed and questionnaires were randomly distributed 1n the effort to determine the effectiveness of these CAs.
The main focus was to ascertain whether individuals were familiar with the methods available for br1ng1ng their concerns to the attention of appropriate personnel and organizat1ons. If so, it was important to ascertain whether they were satisfied w1th the outcome, and whether they had provided input to the resolution.
This was an opportunity to discuss people's feelings
~n how well the efforts to promote teamwork were progressing.
The following observations seem to be the consensus of the Nuclear Division's thoughts.
All responding or interviewed personnel were aware of the problem identification process and were not reluctant at this point to identify a concern.
- However, some indicated that they were discouraged with the timeliness of corrective actions.
Host of the interviewers and respondents felt great improvement had been made in the problem identification and resolution process.
Most people indicated that they had an opportunity to offer their input and acceptance for RAP items affecting them.
Several were pleased with the progress made 1n opening up communications in their discipline. Notably, QA and Hechanical Maintenance were recipients of favorable comments on their efforts to improve communication and teamwork.
Host of those surveyed or quest1oned felt communicat1on with other departments was 1mproving, but 1mprovement is needed 1n cceeunicating with off-site groups.
The majority of people were 1mpressed w1th the improvement made to promote teamwork and cemunication.
Overal.l it appears that the actions taken will prevent s1m1lar problems from happening in the future.
0012A disk 0056c A3-54
S!-14 Safety System Functional inspection A Safety System Functional Inspection (SSFI) was conducted at Unit 1
by the NRC from 9/12/88 through 10/7/88.
By letter dated 10/26/88, the NRC provided a
summary of t;he significant SSFI findings tn advance of the formal SSFI Inspect1on
- Report, so that appropriate corrective actions could be incorporated into Unit 1 restart planning act1vtties.
On 2/1/89, the NRC provided Inspection Report 50-220/88-201, which added two new open items. Other open items are consistent w1th the NRC Quick Look Letter.
These two new open items are also included tn this assessment.
Target S14.1:
The RAP commitments including text, corrective act ons and responses to NRC questions associated with the SSFI have been implemented and verified, There are twenty-seven CA's associated with th1s tssue.
The CA's are in various stages of completion, verification, and SORC acceptance.
The tasks to be completed prior to restart are listed tn Append1x 4.
In addition to the closure of those items in Appendix 4, the assessment has generated many suggest1ons for 1mprovement.
The improvements include making clarification on system descriptions, revising procedures, enhancing
- tratn1ng, and augmenting programs to review industry information.
Where these improvements are judged as needed for safe operation, they are scheduled for completion prior to restart; when they do not compromise the safe operation of the plant they are slated for completion after restart.
There has been sign1ficant progress toward completing the CA's to know that all issues have been resolved to the point of being confident that when the remaining items listed tn Appendix 4 are complete.
this target w111 be completely met.
Target S14.2:
The specific deficiencies identified during the NRC's SSFI have been resolved.
All of the def1ctenc1es identified by the NRC are included in the RAP.
As noted under the target
- above, some of the actions to resolve the deficiencies are included tn Appendtx 4 for completion prior to restart.
Target S14.3:
Specific deficiencies in Oesign Basis documentation and generic implications identif1ed through the problem reporting process which could impact the ab111ty to operate the plant with a high assurance of safety have been resolved.
Specific deficienc1es tn Oes1gn Basis documentation have been reported through the problem report process; several of these have been resolved and the rest are being evaluated.
All problem reports concerning this topic w111 be evaluated prior to restart.
Any reports wh1ch cause a safety concern will be resolved pr1or to restart.
This target ts met tn principle and will be met completely before restart with the conclusion of the problem report review.
A3-55 0012A disk 0056c
Target S14.4:
An approved resource loaded plan ls in place to develop and implement a design basis reconstitution and configuration management upgrade program.
As the assessment of this and other issues progressed, several. recommendations were developed to make the configuration management program more useable and useful.
Recommendations for improvement in the control of setpoint changes and calculation inputs for licensing documents will be implemented.
Other recommendatlons are being included in the overall configuration ma'nagement upgrade effort.
An approved plan exists for performing Design Basis reconstitution'ue to the expansion of scope and the desire to implement some of the recommendatlons immediately, less progress had been made toward getting the resource loaded plan ln place as compared to the targeted position.
Hith the completion of the resource loading of the plan recently, this target has been
- met, Target S14.5:
An effective plan is in place to control
- changes, e.g.
alarm setpolnts, flow diversion devices, system resistance calculations.
As part of the response to the SSFI, the Company has performed a comprehensive review of all alarm setpolnts and has provided engineering guidance for their control.
Control of flow diversion devices and system resistance calculations will be addressed as part of the Configuration Management upgrade program discussed under Target S14.4.
In the meantime, lnterlm measures have been or will be put ln place.
The target is partially met now and will be fully met when the Configuration Management upgrade plan is complete prior to restart.
Target S14.6:
An evaluation of other technical specification or safety systems has been done for similar deficiencies.
Other systems and related issues have been checked and some deficiencies were noted.
The deficiencies are being corrected.
Nuisance alarms covered by the SSFI have been resolved; other examples of nuisance alarms provided by the operators are not safety related, but they will be resolved after restart.
Inconsistencies and errors ln the Technical Specifications have been valuated.
The specific changes required by the SSFI have been incorporated.
Two systems have been reviewed in detail with no significant problems resulting.
A complete review of other systems has been added to the NIP for completion after restart.
A review of the Automatic Depressurization System Design Basis versus Emergency Operating Procedures has shown instances where the operator was instructed to take actions which compromised the Design Basis.
A review plan has been developed, and, before restart, EOP's will be reviewed to determine if there are other similar instances.
If so, the procedures will be changed and the operators will be trained in the corrected procedure.
0012A disk 0056c
'3-56
This target has been met in principle with two exceptions.
For restart.
further work is needed to check potential flow diversion and consistency of EOP's with the Design Basis.
The items for longer term enhancement should be addressed as part of the NIPS The response to the SSFI has been comprehensive and appropriate.
The Task Manager and others have taken a positive approach to resolving the specific def1c1encies noted by the NRC.
They have also broadened their response to cover other systems and similar problems.
The problem, associated root causes and corrective actions as described in the RAP were found to be adequate and comprehensive.
During the course of the assessment, several findings and recommendations were made.
Those necessary for restart have been or will be implemented before restart; others dealing with long term improvement will be included in the
- NIP, Sufficient progress has been made or will have been made by restart to give the assessor confidence that problems such as those ar1sing from the SSFI will not have an adverse impact on safe plant operations.
0012A d1sk 0056c A3-57
Sl-15 Cracks in Walls and Floors Specific Issue No, 15 raised concerns regarding the effect of cracking on the structural, and shielding integrity of masonry and reinforced concrete walls and floors at Nine Mile Point Unit ¹1.
Specific Issue No.
15 can be divided into two (2) separate categories:
- 1) actions required prior to Unit ¹1 restart and 2) long-term strategies.
The actions required for res'l:art consists of five (5) specific issues as ldentlfied in the RAP.
These issues are the following:
1.
Cracks ln Reactor Building wall along Column Row K, 2.
Cracks ln Turbine building wall along Column Row 3, 3.
Apparent cracks and leakage of the Spent Fuel Pool, 4.
Cracks in concrete celllng and walls of the steam tunnel; and 5.
Cracks in masonry walls.
Long-term strategies entail actions to preclude a future recurrence of this issue and require implementation within six (6) months after unit start up.
The cracks in concrete were intially identified by individual problem reports, while the cracks ln the masonry walls were lnltially identified during the Fire Protection Haik Down.
The occurrence of these cracks <l.e.,
immediately after construction, recently, etc.) is unknown as no systematic program for the reporting, identification and/or tracking of cracks existed prior to this issue arising.
Target S.15.1:
The RAP Corrective Actions and commitments associated with the cracks in walls and floors have been implemented and verified.
This target has been met; all corrective actions have been implemented and verified.
This assessment concurs that the cracking identified in reinforced concrete structures ls cosmetic in nature and does not impact the load capacity or serviceability of these structures.
Additionally, the root causes identified do not indicate ongoing problems for future concern.
- Further, structural degradatlon due to leakage through cracks ln the spent Fuel Pool is also not a long-term concern.
These conclusions were based on selective review of existing documentation and no new calculations were performed.
Collection of leakage from the Spent Fuel Pool tell-tale pipes from 1/2/89 to 3/18/89 established the following:
- 1) the Spent Fuel Pool as the likely source of the leakage based on chemical analysis of the collected water and 2) the magnitude (one liter/day) and daily varlatlons of the leakage through the
- cracks, Future monitoring of leakage ls planned after unit start up, and may also be performed during reloading.
0012A disk 0056c A3-58
The assessment found that the program with regard to masonry wall cracking was well-conceived,
- thorough, and well-executed; the assessment also concurs with the methodology used to resolve th1s issue.
The inspection, evaluation, and repa1r of the masonry wall structures are adequately addressed by the existing procedures rev1ewed as part of this effort.
Ourfng this particular assessment
- phase, several items of concern were identified but were resolved to the satisfact1on of the assessor (for example, a concern regarding the effectiveness of surface groutfng was resolved by restricting its usage to non-structural cracks).
Target S.15.2:
A plan and schedule for implementing a process for the identification, reporting and evaluation of cracks has been developed.
Th1s target has been met.
A program for identifying, mapping and assessing cracks in concrete and slabs (other than the four (4) cracks identified in RAP) and masonry walls is planned under the Nuclear Improvement Program (NIP).
This provides an acceptable means of tracking the development and ensures the implementat1on of this program.
The scheduled completion date of 10/31/89 and 2/28/90 for masonry walls and concrete, respectively, satisfies the commitment in RAP for implementat1on within six months following unit start up.
This fulfills the requirements for this restart target.
Target S.15.3:
Follow-up to assess the effectiveness of the repairs has been performed or is planned, scheduled and appropriately tracked.
Incorporation of a procedure for assessing the efFectiveness of the recent repairs within the overall crack inspection and evaluation program being developed under NIP satisfies the requirements of this target.
As such, the NIP track1ng and schedule comnitments apply.
This assessment finds the corrective act1ons are sat1sfactory and agrees with the previous evaluations:
the cracking fn reinforced concrete is typical for structures of this construction and type, and are not of structural concern.
The cracking does not affect load capacity or serviceability, and the identified root causes do not indicate ongoing problems of future concerns.
No structural repairs are necessary, but cosmetic repa1r may be appropriate.
A program for ident1fying, mapping, and assess1ng and add1t1onal cracks fn concrete (other than the three cracks 1dentffied in the RAP) is planned under the Nuclear Improvement Program (NIP).
This satisfies the RAP requirement for long-term strategies and fs essential to preventing recurrence of this Issue.
No additional actions are required before startup.
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SI-16 Feedwater Nozzles Since 1981, feedwater nozzle examinations have not covered the full volume required by NUREG 0619. Additionally, calculations to resolve findings on the SE nozzle were based on erroneous wall thicknesses.
Target S16.1:
The RAP CAs and commitments associated with the feedwater nozzles have been implemented and verified.
This Target has been met.
Feedwater nozzle examinations are performed in five
- parts, to examine the total volume required by ASME Section XI and NUREG-0619.
Aside from the requirements specified ln ASME XI, which are well defined, NUREG-0619 required a UT examination of nozzle safe ends and bores.
Through the assistance of General Electric. Niagara Mohawk established complete feedwater nozzle examination requirements and made ad]ustments to the procedures.
Final examination requirements are documented in NQA089-223.
Examination records for each of the five inspections performed on each of the four nozzles were reviewed for completeness and information quality.
A number of indications were found in the safe-end weld and nozzle bore area of the "A" feedwater nozzle.
The method of evaluating these indications was reviewed and compared to Code requirements, The results were accurate and within acceptance Code standards.
The MPR calculation performed in 1977 after cracks were discovered and repaired ln the Southeast and Southwest feedwater nozzles were revised.
This calculation was performed to predict crack growth ln the inner radius, assuming a nominal flaw size.
In the calculation, the nominal nozzle wall thickness of 4.5 inches was
- assumed, rather than the post-repair thickness of 3.0 inches.
The wall thickness assumption was found to have no effect on the calculation results.
The most recent examinations have found the inner radius of the nozzles to be free of indications.
The Second 10-Year-Interval ISI Program Plan is not finalized. Niagara Mohawk has committed to the NRC to submit the revised Program Plan six months before the next refueling outage.
Requirements for the nozzle examinations were identified ln the response to CAR88.2031 and are documented in MD-88577 Revision 4.
0012A disk 0056c A3-60
Based on this assessment, the feedwater nozzles have been exam1ned in accordance with the requirements of ASME Section XI (1983 Edition with Summer 83 Addenda) and NUREG 06lg. All indicat1ons have been evaluated and found to be acceptable in accordance with code requ1rements.
No further actions are required before restart.
The examination requirements are documented, the procedures used to conduct the exmainations are adequate, and the personnel using them were effectively trained.
The method of evaluating ind1cations was found to be appropriate and the calculations accurate.
The crack growth calculations were revised and updated to 1nclude recently 1dentified indications.
The original concerns identified in this issue have been addressed.
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Sl-17 Inservlce Testing Niagara Hohawk began implementing the In-Service Testing (IST) Program in 12/79.
The program was revised twice to address NRC comments;
- however, an NRC Safety Evaluation Report was never issued.
In 12/85, the Unit 1 Q-list was substantially revised and reissued.
- However, the IST Program was not revised to incorporate modifications and Q-list changes.
Therefore, certai'n safety related components were not included in the program.
Target S.17.1:
The RAP Corrective Actions associated with the Inservice Testing (IST) Program have been implemented and verified.
This target has not yet been met since none of the five Corrective Actions have been formally completed.
The nature of this target.
- however, is such that it is not expected to be completed until the IST tests are completed; this target will be met by Restart.
Although not formally closed, two of the corrective actions already have been satisfied.
NRC approval has been obtained for Relief Requests required for the Second Interval IST Program.
The NRC indicated that there is no need for a separate NRC Interim Relief Request; Generic Letter 89-04 suffices as Nine Hile Point Unit 1 Interim Relief Request.
The NHPC IST Program is acceptable based upon review of the IST Program and the vertical slice samples of core spray and reactor building closed loop cooling systems as performed by the Bechtel Corporation.
The actual implementation of the Second Interval IST Program will be accomplished only as the IST tests are completed over the next couple of months and will, therefore, be the last item closed ln the IST Corrective Action Program.
IST Administrative Procedure Training has been discussed and the scope of the IST Planned Training has been defined.
All IST personnel will be trained, including appropriate Nuclear Engineering and Operating personnel.
A list of specific personnel requiring training and the training to be accomplished is planned to be issued, training will be accomplished by September 30, 1989.
Target S.17.2:
Assure that there are no open deficiencies or concerns associated with the IST Program.
This target has not been met, although it will be met by Restart.
Potential IST safety classlflcation problems were identified by Site Engineering during the IST Program Development.
The ldentlfled potential problems were forwarded to the Nuclear Llcenslng Department for resolution.
Approximately 125 Q-list concerns were identified; the IST organization with the Nuclear Licensing group have determined and documented that a "Conservative Direction" safety determination was made on all submitted Q-list problems.
0012A disk 0056c A3-62
Generally, the Q-list concerns addressed clarification of existing components, whether they were safety or non-safety related.
The IST Second Interval
- Program, as written and submitted to the NRC, took the conservative approach and where a classification question existed always assumed the component as being safety related.
Therefore, the Licensing interpretations and resolutions would be a "relief" to the existing Second Interval Program and not an lmposltlon of new criteria.
Any Q-list IST safety classification problems will be resolved as a long-term NIP 1 tern.
There now exists compatibility between the IST Pump and valve Program and the Appendix J
Type C Valve List. It has been committed that this compatibility will be maintained throughout startup.
To maintain this compatibility for the long term, an interface procedure will be developed after restart.
Target S.17.3:
The second interval IST Program has been developed and is in place for all ASHE Classes 1,
2 and 3 safety-related pumps and valves except for those where NRC approved relief requests exist.
This target has been met.
While the Second Interval IST Test has not been completed, the P ogram has been developed and ls in place.
The assessment has concluded that tne Second Interval IST Program ls an acceptable program ln compliance with regulatory codes and standards.
Target S.17.4:
Administrative controls (including clear assignment of responsibilities and interfaces) will be in place to assure that the IST Program is maintained properly when future Design (modifications) and/or Licensing ("Q"-List) changes are
- made, This target has not been met.
Based upon assessment review, the procedures appear to be adequate to administer the program and to maintain the program relative to future Oeslgn and/or Licensing changes.
A commitment has been made to have the procedures finalized, approved, and issued by restart.
When that ls done, the target will be met.
Target S-17.5:
Appropriate personnel have been trained on the approved process for developing and maintaining the IST Program.
This target has not been met.
As stated under Target 1,
IST Administrative Procedure Training has been discussed, but not implemented.
All IST personnel, lncludlng appropriate Nuclear Engineering and Operating personnel, will be trained by September 30,
- 1989, and the target will then be met.
Although all of the targets associated with SI-17 have not been
- met, they are all progressing such that they will be accomplished by restart.
All of the
,Assessment ob]ectlves have well-defined activities to achieve their closure.
The Second Interval IST Testing (Targets 1
and 3) will most likely be the last ob]ective to be met.
0012A disk 0056c A3-63
St-18 125 VDC System Concerns During evaluat1on of the 125 VOC system, several concerns were identified regarding the ability to demonstrate operability and functional capability.
These concerns generally relate to an inability to immediately identify design basis requirements and assumptions.
Evaluations and modificat>ons are being performed, as appropriate.
Target S.18.1:
The RAP Corrective Actions associated with the 125 VDC system concerns have been 1mplemented and verified.
The 1ntent of this Target has been satisfied, but the Target will not be fully met until all RAP CA's have been completed and verified.
Revised des1gn bases scenario load profiles have been developed, battery sizing and safety system circuit voltage drop calculations have been performed and an engineering analysis is being conducted to demonstrate the capability of the 125 VOC-system to meet des1gn and functional requirements.
Verification and approval of the analysis and.calculations remain to be completed before restart.
Technical defic1encies have been identif1ed 1n the areas of control circuit voltage drop problems and suffic1ent battery capac1ty to meet the design bases.
Voltage drop problems are being resolved by plant modif1cations and capacity problems are being resolved by manual load shedding.
The ERV control circuit voltage drop modificat1on remains to be completed and tested.
Modification procedures were followed 1ncluding adherence to all applicable rules and regulations.
Personnel who require tra1ning in 125 YOC system capability have been identified and a tra1ning course and schedule are being established.
Target S.18.2:
Analyses for the 125 VDC system have been completed and the results of the assessment documented.
The intent of this Target has been sat1sfied, but the Target will not be met until all open items have been completed and verified as described in Appendix 4.
The design bases for the 125 VDC system was reconst1tuted and the capability of each battery train was analyzed against the new design bases.
Battery sizing calculations were performed using the new battery load profiles that were developed dur1ng the analysis of the design bases.
It was determined that the Appendix R eight hour scenario presents the worst case duty cycle to the batter1es.
Safety system voltage drop calculations were performed which resulted in the identification of several modif1cations to be performed to install larger size cable to relieve the low voltage condit1ons.
Battery testing will be performed to augment the calculations to prove capability of the batteries to meet the new design bases.
The results of the analysis will be documented in the "125 VDC Stat1on Battery Design Evaluation Report" with attachments which w111 be revised,
- approved, presented to SORC, and integrated into a document and design bases control system.
A3-64 0012A d1sk 0056c
Target S.18.3:
The deficiencies identified during the assessment have been dispositioned according to their impact on plant operations.
This target has been met.
All technical deficiencies identified as a
requirement for the 125 VOC system to meet the new design bases have been resolved and are targeted for completion, verification, and testing prior to restart.
Target S.18.4:
A plan for the resolution of deficiencies which can be delayed beyond restart has been developed.
The intent of this Target has been satisfied, but the Target will not be fully met until all open items have been completed and verified as described in Appendix 4.
Deficiencies whose resolution can be delayed beyond restart have been properly assessed.
Completion plans will be developed which identify the technical work
- scope, provide for necessary funding and contain resource loaded work schedules.
The analysis and reconstitution of the 125 VOC system design bases have been completed and approved.
Necessary actions have been taken to enhance the capability of the present 125 VDC battery system.
Engineering analysis of the 125 VDC system, augmented by testing; will show that the existing batteries are adequate to meet the new design bases when all of the open items have been
- closed, the causes of this Issue will be appropriately addressed.
0012A disk 0056c A3-65
C.
The Unit 1 restart readiness assessment 1n this Report addresses the Underlying Root Causes and Spec1fic Issues identif1ed 1n the RAP.
As part of Niagara Mohawk's assessment of restart readiness, these NRC Guidelines are also being considered.
The Gu1delines indicate areas of NRC review before authorization of a plant restart from an extended shutdown.
- Together, these
- Guidelines provide one of the restart bases being used to justify Unit 1
read1ness for restart.
(These Guidelines were provided 1n an ll/23/88 NRC memorandum from Hr. Victor Stello, Jr. to NRC Office Directors and Regional Administrators.)
Assessment Basis No.
7 Following is the bas1s on wh1ch the five NRC Generic Restart Guidelines were assessed.
"Results of correct1ve act1ons and plant improvement activities sufficiently address and sat1sfy NRC Restart Guidel1nes, such that all issues necessary to support readiness for restart and safe operation have been demonstrated and NRC approval for plant restart may be requested."
The effectiveness of correct1ve actions demonstrated by the results described in the following summary descriptions of the assessments of the five NRC Guidelines support the conclusion that Basis No.
7 is met.
General Assessment Plan In general.
the five Guideline assessments were based on information and data from the follow1ng sources:
Documentation rev1ews Interviews Observat1ons Cmeunication among this Report's assessors The data were reviewed and evaluated against the restart Targets established for each Gu1deline, using industry and regulatory norms based on the exper1ence and )udgment of the assessors.
The assessors had available to them input, gu1dance, and review from the Restart Review Panel (RRP) and its individual members.
That support, and the results of individual RRP member assessments are also reflected herein.
- 1. Root Causes Identifled and Corrected "The root cause of the conditions requir1ng the shutdown must be properly 1dentified and addressed by a comprehens1ve corrective action plan, including implementation and verification."
0013A d1sk 0056c A3-66
Target 1.a:
A plan has been developed and implemented to identify and address the root causes leading to the shutdown.
The issue of root cause identificat1on and corrective actions is being addressed separately for the following five Underlying Root Causes identified in the Restart Action Plan with respect to Management and Organizational Effectiveness:
1.
2.
3.
4, 5.
Planning and Goals Problem Solving Organ1zation Culture Standards of Performance and Self-Assessment Teamwork Specific corrective actions have been identified in the Restart Action Plan as required to be completed pr1or to plant restart and as part of the long term Nuclear Improvement Program.
The results of this assessment, based on reviews of a number of NRC and INPO documents and 1nterviews w1th management, indicate that the process described in the RAP to 1dentify and correct the root causes of the cond1tions leading to the shutdown has been developed and is well underway.
Based on the assessment performed, the RAP adequately addresses the root causes leading to the shutdown.
Target i.b:
Based on the root causes ident1fied, corrective actions have been 1mplemented such that suff1cient results have been achieved to address the root causes.
The assessment of th1s target has been based essentially on discussions with other assessors and review of those assessments related to the five Underlying Root Causes and the eighteen Specif1c Issues.
Those assessments have focused on the individual restart corrective actions identified in the RAP.
Based on the results of those assessments, in general, corrective actions have been found to be implemented. such that sufficient results have been achieved to address the root causes.
In those cases where corrective action implementat1on is not yet complete, the assessments indicate that the process in place should lead to sat1sfactory results when comp)eted.
Target 1.c:
A process has been established to assure that the effectiveness of the results w111 be maintained.
A process has been established (i.e.,
the long term NIP corrective actions) to assure that the effect1veness of the results achieved as a result of the restart corrective actions will be maintained, after restart.
In addition, management cceeitment 1n support of this process is apparent, based on the d1rection given and progress achieved to date in resource planning for the NIP 1tems.
0013A disk 0056c A3-67
2.
Management Organi mat ion "A qualified management organizat1on is in place to assure that the proper environment and resources are provided to assure problems and their root causes have been rect1fied, including the coordination, integration, and communication of ob]ectives."
Target 2.a A qualified nuclear management organization has been established for all key management positions and has communicated its objectives.
Since the shutdown, signif1cant changes have been made in the Nuclear Division management staff.
Several pos1tions in the chain of command are filled by people who are new to the position.
From the Super1ntendent of Operations, Unit l, up through the Executive Vice President Nuclear Operations, positions are filled by new people:
Un1t l Station Superintendent, Manager of Nuclear Services, and Superintendent of Operations are new to that position.
Execut1ve Vice President - Nuclear Operations, General Superintendent-Nuclear Generation, Superintendent of Training, and Manager of Chem-Rad are new to the Company.
Ass1stant to the Executive Vice President Nuclear Operations is a
new position, f1lled by an experienced employee.
The new Executive V1ce Pres1dent - Nuclear Operations, has strong people skills, experience with restart of troubled plants, a Navy nuclear background, and good relationships w1th the NRC.
He is also demonstrat1ng the qualifications expected of the nuclear management organization through his leadership and direct1on.
Based on the results of 1nterv1ewsand other observations, the quallificat1ons of the nuclear management are be1ng demonstrated.
Ob)ectives have been developed by the Executive Vice President and distributed to his direct reports with clear direct1ons for the1r d1sseminat1on.
Our assessment has establ1shed that the ob)ectives and their intent have been communicated throughout the organization although it has taken a substantial management effort and all-employee Town Hall meetings to accomplish.
This assessment concludes that programs,
- systems, and pract1ces that are 1mportant to successful nuclear programs are adequately addressed in the corrective actions contained in the RAP and NIP.
THose items important to Management and Organ1zat1onal effectiveness include self-assessment procedures, an independent self-assessment group, mission-vision-ob]ectives statements, strategic
- planning, standards of performance, senior management expectations statements, nuclear commitment tracking system, mandatory supervisor training, Management-By-Halking-Around
- programs, and numerous communication tools 1nclud1ng "Tell the Superintendent",
Integrated Team
- meetings, and Town-hall meet1ngs.
Systems being improved include OEA.
prioritization, problem solving, performance
- rev1ews, pos1tion descriptions, recruiting and training.
In summary, the management organization appears to be adequate to support restart and safe operation.
A3-68 0013A disk 0056c
Target 2.b Management ob)ectfves reflect a positive attitude toward assuring that safety issues are resolved in a timely manner.
The Nuclear Division ob]ectfves clearly reflect a posit1ve attitude toward assuring that safety issues are resolved in a timely manner, and thus meet the restart target.
The ob]ectfves include consideration of safety and quality (as would be reflected by NRC SALP and INPO ratfngs),
and call foi'he implementation of Standards of Performance that would result in quality and timeliness of performance.
Data from the interviews ind1cate a proper attitude toward safety.
Management appears to have a proper attitude toward the timely resolution of safety
- issues, which 1s also reflected in the Nuclear Division ob)ectives.
Target 2.c The management organization:
- 1) exhibits good teamwork among its sub-elements;
- 11) provides strong engineer1ng support for plant actfvit1es; 111) has the internal ability to recognize safety
- problems, develop adequate corrective actions, and verify their implementation and effectiveness; and iv) has an independent self-assessment capability that can identify situations not sufficiently dealt with by the regular functioning of the prfnc1pal organization, Target 2.c(i)
Analysis of teamwork relies primarily on the assessment of Underlying Root Cause 5, prov1ded separately.
There is some perception that management fs isolated from lower levels and is not seen by the line organ1zatfons to 'the extent desired.
The Town Hall meetings helped to allay this percept1on.
There is also a NIP item that addresses specff1c "walking around" criter1a.
The assessment data indicate that substant1al progress has been made indicating a healthy trend toward teamwork throughout the organization that would support restart.
Target 2.C (li)
In reviewing Niagara Mohawk and external documentat1on, 1t appears that on occasions fn the past, NMPC had either insufficient technical resources (in number or capab1lity), or did not apply ava1lable resources to review contractor performance.
Several instances have been ident1fied, both by Niagara Mohawk (1n the RAP) and the NRC, in which contractor work was not adequately rev1ewed.
Based on our interviews with Eng1neer1ng management, it fs our understanding that ft is intended that future considerations w111 be given to establishing fn-house staffing levels consistent with supporting normal and planned day-to-day work loads.
Non-routing or unexpected work will be performed by 0013A disk 0056c A3-69
contracting.
Engineering management bel1eves this w1ll result in about 25'/ of the work being contracted out, and w111 require the addition of about 150 engineers to the 269 currently authorized positions, over 70 of which are are currently vacant.
Based on our assessment of current staffing levels and vacancies in the Nuclear Division, and our interviews with Nuclear Division management, this pro]ected increase in staffing to support Engineering objectives will require a significant effort.
- However, what is key to this restart target is whether strong engineering support for plant activities is provided.
It is d1fficult, in a non-operating environment, to predict what support the operations will receive.
Based on the management attention and priority given to operational activities, the recognition of operations as the "client" of engineering, and the resources available, including consultants, we bel1eve that th1s restart target can be met at restart.
However, continuing dedication of engineering support and fostering of teamwork between these two Departments will be required.
Clearly the situation is 1mprov1ng.
In add1tion, the existence of a site engineering group has increased respons1veness and availability of engineering support.
Based on the results of the interviews with generation management at the site, engineering support for plant activit1es has improved and is adequate to support restart and safe operations.
Target 2.c (lii)
The assessment of th1s area is being performed separately under Underlying Root Cause 2.
Target 2.c (iv)
The assessment for this area is being performed separately under Underlying Root Cause 4.
- 3. Plant Staff "The operations staff must recognize and carry out their responsibilities in ensuring public health and safety."
Target 3.a:
An adequate number of qualified licensed operators shall exist to meet Technical Specifications and regulatory requirements.
Current Unit 1 practice is to provide for five shifts and a relief shift, each made up of the required Technical Specifications complement of operators.
Some overtime seems to be required
<to compensate for a current vacancy of one SRO), to fully staff all shifts.
0013A d1sk 0056c A3-70
As additional operators become available, management intends to add a sixth shift (similar to Unit 2).
Management also expressed a desire to significantly increase the operator staff to provide for flexlbllity, attrition, and career development.
However, specific plans and schedules for this are not yet developed.
The plan should include consideration of each level of operator entry and progression, which currently includes:
ASSS/STA (SRO)
CSO (RO)
NAO-E (RO)
AO-C AO-8 The assessment indicates an adequate current staff of licensed operators to meet Technical Specifications requirements.
In a 5/10/89 letter, the NRC agreed with this and stated that "Unit 1
had an adequate number of licensed operators to support a five-crew shift-rotation schedule ln accordance with the NRC requirements."
Although this ls true in the short term (restart),
management recognizes the need to increase the number of licenses in the future.
Target 3.b:
The operators display a positive attitude toward safety issues.
Operators generally have a positive attitude toward safety.
Historically, there have been some attitude problems;
- however, they were isolated cases that did not represent a general problem.
Interviewees at the plant believe their procedures are in good shape and control room drawings are kept current.
EOP training indicated a possible attitude problem and lack of communication.
This did not seem to be a negative attitude toward safety, but rather, operators'verconfidence in their own knowledge.
In review, the resolution was apparently educational and helpful, and there appears to be a new appreciation of the importance of EOPs.
The assessment indicates that the exl.sting staff display a positive attitude toward safety issues.
Previous attitudes resulting ln non-compliance with procedures are improving.
Target 3.c:
The operators display attentiveness to duty, fitness for duty, a disciplined approach to activities, a sensltlvity for plant
- trends, security awareness, and an openness of communications and desire for teamwork with other groups.
No data were found to suggest that attentiveness to duty was even suspected to be a problem.
The Fitness for Duty program is moving ahead and will be implemented this year (1989).
Management has been working with the union and has agreement from them on the program.
Based on our interviews, the program appears to be accepted by most operators'013A disk 0056c A3-71
In the past, problems apparently existed in this area.
Based on interviews with current management, these problems are being resolved.
This assessment indicates that this target ls satisfactorily met for restart
- 4. Physical State of Readiness of the Plant "The physical plant, including equipment and procedures, is ready to support restart and safe operation."
The results and conclusions regarding Physical State of Readiness of the Plant cover a range of issues.
In general, this assessment indicates that the process to prepare the physical plant for restart ls well under way.
A number of items are not yet ready for restart, which was expected.
Certain process improvements may result ln expediting the resolution of these items.
In all cases, these items appear to be appropriately ldentlfled and managed in the current process.
Target 4.a:
All needed safety equipment has been demonstrated to be operational prior to restart.
The turnover status ls being tracked by Outage Management on separate schedules for each system and depicted on separate Reload and Restart Status Boards.
Final acceptability of a system is certified by the Unit 1 Station Superintendent on one of the applicable Temporary Procedures 88-6.0, 7.0 or 8.0, on one of the subprocedures for a system or for a certain comnodity, or by completing a completion certlflcatlon form signed by the Task Manager, SORC and verified by an independent party.
Overall Reload and Restart Readiness is certified and approved by the Station Superintendent by slgnlng Temporary Procedure 6.0 and 7.0, respectively.
Target 4.b:
Surveillance tests are up-to-date, and reflect modifications and other corrective actions performed during the outage.
Preoperational surveillance tests must be conducted prior to or as part of the system turnover from Outage Management to Operations, who participates in these tests or performs the tests as part of the acceptance of a system.
Surveillance tests for equipment and systems that are the sub)ect of one of the 18 Specific Issues ln the RAP are being tracked on the Outage List as part of the Corrective Actions.
Approximately 20 addltlonal surveillance tests were established as the result of the ISI Specific Issue.
For the last Outage of Unit 2 a deliberate approach had been taken regarding the completion of surveillance tests.
A Unit 2 specific procedure was developed to assure that all required surveillance tests would be conducted and a list of these required tests was developed.
Regulatory Compliance is currently developing a slmllar procedure for Unit 1 (a draft does exist at this time) also including scheduled preventive maintenance items.
In
- addition, a list of all surveillance and preventive maintenance items ls being generated, including schedule (post restart items are also included).
0013A disk 0056c A3-72
The Engineering Divis1on is develop1ng a list of surveillance requirements for equipment and systems that will serve as input to the list.
These actions are responsive to Underlying Root Cause Corrective Actions 1.2.4 and 1.2.5.
This list of surveillance tests (somet1mes also referred to as the "list of lists" )
will be maintained by Regulatory Compliance to assure that applicable surve1llance test requirements in the Techn1cal Specifications have been met.
Target 4.c:
The maintenance backlog has been reduced to nominal levels.
The three ma)or categor1es of maintenance 1tems to be completed pr1or to restart are Work Requests (HRs), Post Maintenance Surveillance Tests (PMSTs) and Modificat1on Work Requests (MHRs).
At this time Operations is systematically reviewing and prioritizing the pre-restart WRs in accordance with Temporary Procedure N1-88-6.5.
The WRs are tracked on the Outage List under this procedure, but not as individual items.
They are tracked individually on the systems turnover 11st.
Readiness with respect to maintenance items will be by the Ma1ntenance Department signing Temporary Procedure Nl-88-6.5 for reload and the corresponding subprocedure to N1-88-7.0 for restart.
Implementation of Temporary Procedure N1-88-6.5 has improved the track1ng of maintenance items.
It is the overall goal of the Ma1ntenance Department and the Operations Department to achieve a maintenance backlog as low as possible;
- however, they have recogn1zed the d1ff1culty 1n reducing the backlog s1gnificantly 1n the short term.
Based on the importance management has assigned to this issue and the procedural controls and prioritization establi'shed, the process in place should assure that the maintenance backlog will be sufficiently reduced to support restart and safe operation.
Target 4.d:
Procedures have been updated and plant staff trained to reflect resolution of the root causes of the shutdown.
Spec1f1c Temporary Procedures for the reload, restart and power ascension for this outage have been developed or are being developed by Outage Management.
These procedures are not intended to prescribe the "how to" for the Corrective Actions in the RAP but to provide a means of documentation and authorization for the var1ous activities.
Presently there exist more than 5000 different procedures at the s1te.
In accordance w1th the Nuclear Improvement Program Corrective Action Item 1.1,6 and 1.1.7, a Procedure Services Group is being formed to review and update these procedures;
- however, th1s is an effort not scheduled to be completed prior to restart.
Already ongoing is an update of Operating Procedures in accordance with the procedures wr1ters guide.
General Electric Company 1s performing this task, and Operations w11l rev1ew and approve all updated procedures.
1 As part of a system turnover,. Operations will also review and concur in each procedure that was affected by a corrective action or modification that was made.
Tra1ning in new and revised procedures is conducted per1odically (about every five weeks).
As appropriate, operator training will also be provided on the simulator or during power ascension.
0013A disk 0056c A3-73
Target 4.e:
The as-built design of the plant is known to agree with the safety des1gn basis as described in the FSAR.
N1agara Mohawk init1ated early this year an Engineer1ng Program Integration (EPI) effort wh1ch includes a configuration management and a des1gn basis reconst1tution program.
The EPI is scheduled to be a five year program and has been budgeted for this year.
N1agara Mohawk does not intend to take cred1t for this program in demonstrating that the as-built plant meets the des1gn bases.
This effort is being administered and tracked under the Nuclear Improvement Program Corrective Actions 6.1.13A and B.
Management has recognized that at th1s time there does not exist a well documented data base for the design bases.
Thus the demonstration that the as-built design of the plant agrees with the design bases must rely on engineering judgment.
The situation is different for NMP Unit 2 which is a
more recent plant.
An engineering evaluation is be1ng performed to establish that the as-built condition of the plant is satisfactorily represented by the design documents and is consistent with the safety design bases of the plant.
This includes identify1ng the significant inspections, testing evaluation and analyses programs which have been completed that provide increased confidence in the adequacy of s1gn1ficant systems to satisfy the1r funct1onal requ1rements, as def1ned in the FSAR and Technical Specifications Systems and components at NMPl for which their readiness is particularly important to safe operation w111 be 1dentified and addressed.
The engineering judgement w111 be based to some extent on the results of and the correct1ve actions taken with respect to the SSFI recently conducted by the NRC for the HPSI and core spray systems (details of the effort are covered under Specific Issue 014 and the results of that assessment will be reviewed and factored into the final report for this assessment).
For example, as a
result of the SSFI the setpoints for selected ESF systems were reviewed to verify system operability and compliance w1th the design bases relying on ava1lable records and documents such as specif1c operating procedures; the NPSH and the potential for vortex1ng was evaluated for pumps that take suction from the torus us1ng available records and in some instances redoing calculations to demonstrate that the des1gn bases are met.
Based on the informat1on obta1ned dur1ng interviews, the awareness expressed for the need for an eng1neering judgement, the data and results obtained as a
result of the SSFI corrective actions, and the 1n1t1al steps taken by Engineer1ng to prepare the eng1neering judgement the assessor concludes that an adequate engineering evaluation will be prepared to support the as-built condit1on of NMPl prior to restart.
- 5. Regulatory Requlreeents "The plant and its prospect1ve operation is not known to be in conflict with any regulat1ons, and the requirements of the Confirmatory Action Letter (CAL 88-17) have been met."
0013A disk 0056c A3-74
Target 5.a:
All Techn1cal Specification amendments necessary for restart and operation have been issued.
Licens1ng is responsible for evaluating requests for changes to the Technical Specifications made by any Nuclear Division organization, for preparing the appropriate license amendment request (LAR) for submittal to the
- NRC, and for assuring timely process1ng and issuance of the license amendment.
LARs are being tracked with NCTS, as is any other licensing and regulatory issue (discussed further at Target 5.b following). Licensing issues a monthly "Status of Techn1cal Specification Amendment Requests" list to the Unit 1
and Unit 2 Station Superintendents, identify1ng all Technical Specifications Amendments in process.
Feedback to the status and prlor1ty of changes is provided.
The Technical Specifications list of July 13, 1989 identified 27 Techn1cal Specifications LARs for Unit l, of which four are required to be issued by the NRC before restart.
As part of this assessment, various members of the Nuclear Engineering and Licensing organization were 1nterviewed to obtain an understanding of the Technical Specification amendments which were needed to support restart.
Input from each of the Specific Issue assessors was also obtained to determine if, as a result of Spec1fic Issue correct1ve
- act1ons, additional Technical Specif1cat1on amendments were appropriate.
Based on the interv1ews and review of the status of amendment requests to the NRC, all necessary Technical Specificat1on amendment requests have been submitted.
To satisfy this restart target.
these amendments must be received from the NRC pr1or to restart.
The Technical Spec1fications status is also addressed in CA 1.2.3 and 1.2.4 of Underlying Root Cause l. Also, Regulatory Compliance is reviewing all Technical Spec1fications and establ1shing a list of surve1llance tests that must be performed before restart.
Target 5.b Regulatory licensing cooeitments (includ1ng GDC requirements, generic letters, bulletins, etc.)
are known and have been met, as appropriate for restart.
The most direct impact on, and contr1but1on to, the restart effort by the L1censing and Regulatory Compl1ance Groups 1s their combined respons1b1lity for RAP CA 1.2.2, which states, "Review and verify that regulatory and licensing cmeitments are entered onto the Nuclear Cmeitment Tracking System (NCTS) data base tracking system.
Complete items required before startup."
The NCTS has been established and all current regulatory licensing commitments have been entered.
New cmeitments and changes to commitments are entered under rigorous Licensing and Regulatory Compl1ance controls.
In early Hay 1989, there were approximately 160 open restart licensing items ident1fied on the NCTS; about half of them required closure before fuel load.
The open items on NCTS cover a wide spectrum and 1nclude, for example, the Safety System Functional Inspection (SSFI) performed in late 1988, certain specific issues listed on the RAP, surveillance tests and procedures.
00l3A disk 0056c A3-75
For Unit 1, Niagara Hohawk, not unlike most other utilities with plants of similar vintage, does not have a process or program fn place that can easfly identify all applicable NRC regulations and requirements and how they are met.
- However, both the Hanager of Licensing and the previous Director of Regulatory Compliance have considered this issue and concluded that, based on the process controls fn place and the many recent reviews, there is reasonable assurance of compliance with the regulations.
Specific considerations that were applied fn reaching that determination include the following:
Hany of the Technical Specifications license amendments since 1974 were reviewed to ensure that the plant and all documentation meet these amendments'uring development of the Restart Action Plan potential weaknesses were systematically reviewed using, for example, LERs and exception reports.
Items on the NCTS list are being evaluated specifically with respect to meeting applicable regulations.
The activities performed under Temporary Procedures Nl-88-6.0, -7.0, -8.0 and their sub-procedures take into consideration how applicable regulations are be1ng meet.
Some complex programmatic regulatory areas were reviewed (e.g.,
equipment qualification) to evaluate regulatory compliance.
The assessors believe that adequate consideration has been given to this
- issue, and that reasonable assurance of compliance with the regulations can be provided.
Target S.c:
All conditions of the CAL have been met.
Confirmatory Action Letter (CAL) 88-17 ldentlffes three actions that Niagara Hohawk agreed are prerequisltes for restartfng Unit 1.
The first two, relating to a root cause analysis and preparation of a restart action plan, were the sub)ect of the Restart Action Plan, Revision 1, 3/89.
The third action requires the submittal to the NRC of a Restart Readiness Report which is to include: "your bases for concluding that NMP1 is ready for restart, a
self-assessment of the lmplementatlon of the restart action plan, and your conclusions regarding whether Niagara Hohawk's current line management has the appropriate leadership and management skills to prevent, or detect and correct, future problems."
These actions are also the sub]ect, in part, of NRC Guideline 4 (Restart Readiness) and RAP CAs with respect to Underlying Root Causes 2, 3, and 4, (in particular Corrective Action Ob)ectfves 3.2 and 4.2).
Completion of this third target fs met'y the assessments being provided, and submittal of this Restart Readiness
- Report, 0013A disk 0056c A3-76
5.
Control of Commercial Grade Items The assessors reviewed documentation related to this issue and interviewed key individuals involved in the control of commercial grade material.
From these assessment
- actions, the Panel concludes that a successful program for controlling commercial grade items has been developed and implemented.
The process is relat1vely new and personnel are becoming more familiar w1th the process.
As training and exper1ence are accumulated, efficiency and responsiveness w1ll continue to increase.
Regular meetings are held to facilitate communications among affected organizations regarding po'tential mater1als problems.
Niagara Mohawk has been initiating communications with other ut1lities to share experiences and data, and to explore the potential for cooperative ventures in commercial grade items procurement.
These activities provide strong assurance that recurrence of this concern will be prevented.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Un1t l.
6.
Fire Barrier Penetrations The assessors reviewed documentation related to this issue and interv1ewed key individuals involved in the resolution of the issue.
The assessment actions found that the correct1ve actions are satisfactory.
Fire Barriers and Penetrations have been inspected and defic1encies corrected.
The des1gn data base and drawings will be updated.
Surveillance, Breach Permits and other procedures will be revised or prepared to incorporate the RAP corrective act1ons.
The Panel concludes that the effectiveness of the corrective act1ons in this area support restart of Unit l.
7.
Torus Wali Thinning The assessors reviewed documentation and backup calculat1ons performed by the Company and questioned the adequacy of the data and stat1stical analyses.
Even though this issue was considered closed by the Company and the NRC, in order to respond to the assessor's
- concerns, the Company performed additional thickness measurements and performed more rigorous analyses on the data.
Interior inspections included visual, photograph1c, and surface impressions.
Area averaged ultrasonic measurements of the thickness of each plate making up the bottom mid-bay port1on of 20 torus bays were taken.
The analyses concluded that the torus wall thickness is adequate for more than the next operating cycle.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit l.
8.
Sory Dischargo Vol The assessors reviewed the documentation related to this 1ssue and interviewed key ind1viduals involved in the resolut1on of the issue.
Polic1es and procedures governing comnitments are being revised to assure they are effective in addressing the need to obtain formal NRC concurrence with Niagara Mohawk actions with respect to exceptions to new or revised regulations, A
test procedure to validate the adequacy of the scram discharge volume was
- prepared, and the test was acceptably performed.
Procedures for tracking of NRC ccemitments on the Nuclear Commitment Track1ng System were 1ssued.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit l
~
9.
Emergency Condenser and Shutdown Cooling Valves The assessors reviewed documentation related to this issue and 1nterviewed key individuals involved in the resolution of the issue.
The assessment actions found that the NRC and Niagara Hohawk have agreed on the resolution of all Appendix J issues.
Niagara Mohawk has received exemptions for testing the emergency condenser valves and the shutdown cooling systems valves.
A procedure to provide a water seal for the containment spray valves has been prepared.
IST personnel verified that all items determined to be IST issues were being tested ln accordance with the IST program.
For the lonj term, an Appendix J program plan ls being developed to address all aspects of Appendix J
and ls to be administered by a specific department.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unl t 1.
10.
Reactor Vessel Pressure/Temperature Curves The assessors reviewed the documentation related to this issue and interviewed key individuals involved ln the resolution of the issue.
The assessment actions found that Niagara Mohawk notified the NRC of the possible discrepancy ln the reactor vessel pressure/temperature curves ln a letter on June 16, 1988.
Included ln this letter was a summary of the information available to Niagara Hohawk.
The NRC performed a safety evaluation, transmitted to Niagara Hohawk on September 14, 1988, that concluded that the pressure-temperature limits are conservative and acceptable.
For the long term, Niagara Hohawk has established a program and engaged a contractor to determine the identity of the test material ln the surveillance program and the ability to )ustify less conservative pressure/temperature limits.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit 1
11.
Erosion/Corrosion Program The assessors reviewed documentation related to this Issue and interviewed key individuals involved ln the resolution of the Issue.
The assessment actions found that pipe wall thickness measurements have been made under the erosion/corrosion program.
These measurements indicate that all locations inspected are within acceptable limits or have been evaluated against specific loading criteria, and have included pro)ected thinning during the next operating cycle, and found acceptable.
Relevant procedures have been revised to address consistent marking of piping and components to assure repeatability of measurement location.
A surveillance of the contractor's grid marking actlvltles was conducted during the current outage.
The surveillance confirmed that grid layout spacing and orientation were correct.
The Unit 1
baseline measurements have been made.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit l.
12.
Motor-Generator Set Battery Chargers The assessors reviewed documentation related to this Issue and interviewed key individuals involved ln the resolution of the Issue.
The assessment actions found that the HG set battery chargers have been classified as safety related and the Q-list has been updated.
A lessons learned transmittal, detailing the concern and cautionary statements about using inadequate documentation, has
been issued and reviewed by personnel who perform safety class determinations.
A task force reviewed and found acceptable the Appendix B
determinations that had downgraded systems or components.
Procedures for performing Append1x B determinat1ons have been augmented to provide guidance on technical aspects of the process.
Personnel who will be performing Append1x 8 determinat1ons have been identified and have reviewed the lessons learned transm1ttal on the pro'cess and procedures.
The Panel concludes that the effect1veness of the corrective actions in th1s area support restart of Unit l.
13.
184 Technician Allegation Issue The assessors reviewed documentat1on related to this
- 1ssue, interviewed key individuals involved in the resolution of the issue and also surveyed ind1viduals and observed meetings.
The long-term management effectiveness programs which resulted from the IEC Technician Allegations were incorporated in the RAP and most of the corrective act1ons associated with this issue are duplicated elsewhere in the RAP.
In order to determine if the RAP corrective act1ons were effective regarding implementation of these
- programs, the assessment focused on the area of problem solving and associated communication issues.
The assessor found that there was a consensus that significant improvement had been made in problem solving.
Although there is room for improvement in communication, particularly between on-site and off-s1te
- groups, there 1s evidence of significant effort and improvement in,teamwork and commun1cat1on.
The Panel concludes that the effectiveness of the corrective actions in this area support restart of Unit l.
14.
Safety System Functional Inspection The assessors reviewed documentation related to this Issue and interviewed key 1ndividuals 1nvolved in the resolution of the Issue.
The assessor noted that the required calculations and analyses have been completed and are adequate to resolve the concerns raised in the NRC's Safety System Functional Inspection.
Necessary mod1fications required before restart and set point changes resulting from the calculations and analyses have been initiated and will be completed prior to restart.
Procedures and spec1ficat1ons have been revised to strengthen the control of design configuration in order to prevent future deficiencies.
A comprehensive plan for des1gn basis reconst1tution is in place.
The Panel concludes that the effect1veness of the corrective actions in this area support restart of Unit l.
15.
Cracks in Walls and Floors The assessors reviewed documentation related to this issue and interv1ewed key individuals 1nvolved 1n the resolut1on of the 1ssue.
The assessment act1ons found that corrective actions are satisfactory and agree with the previous evaluations:
the cracking in reinforced concrete is typical for structures of this construction and type, and are not of structural concern.
The cracking does not affect load capac1ty or serviceability, and the 1dentified root causes do not indicate ongoing problems or future concerns.
A program for identifying, mapping, and assessing any additional cracks in concrete is planned under the Nuclear Improvement Program.
The Panel concludes that the effectiveness of the corrective actions in'his area support restart of Unit 1.
16.
Feedwater Nozz Ies The assessors have observed that the examination requirements are documented, the procedures used to conduct the examination are adequate, and the personnel using them were effectively trained on their application.
The assessor reviewed the exam records for each of the five inspections.
The method of evaluating indlcatlons was found to be appropriate and the calculations accurate.
The crack growth calculations were revised and updated to include recently identified indlcatlons.
The assessor found these calculations to be well founded and complete.
The calculations conclude that all indi'cations are within the limits established by NMPC and Code Criteria.
The Company will submit the Second Ten Year Interval ISI Program Plan six months prior to the next refueling outage.
The requirement for full nozzle inspection per NUREG 0619 has been appropriately addressed and documented.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit 1.
17.
Inservice Testing The assessors reviewed documentation related to this issue and interviewed key individuals involved in the resolution of the issue.
The assessor determined that the NMPl Second Interval IST Program ls acceptable and ls in compliance with the regulatory codes and standards.
A consultant was hired to do an in-depth review of the Core Spray and Reactor Building Closed Loop Cooling systems as regards ln-service testing requirements.
The consultant's report concluded that the program ls acceptable and in compliance with regulatory codes and standards.
The report was used as part of the basis for the assessor's overall positive findings.
The assessor noted that the NRC has given interim approval for both the IST Program and the included relief requests.
The Administrative Procedures are being revised to properly administer the program and to maintain the program relative to future design and/or Licensing changes.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit l.
18.
125 VDC Systee Concerns The assessors reviewed documentation related to this issue and lntervlewed key individuals involved ln the resolution of the issue.
The assessor determined that the scope and content of the corrective actions are such that the technical deficiencies ln the area of control circuit voltage drop and insufflclent battery capacity will be resolved by appropriate plant modifications and procedure revisions.
Calculations and analyses performed to support the resolution of the technical deficiencies were acceptable and appropriately reviewed and approved by management.
Battery testing requirements have been determined and documented.
Required tests have been scheduled to be conducted prior to restart.
The Panel concludes that the effectiveness of the corrective actions ln this area support restart of Unit l.
C.
Management has developed and issued functional organization charts which establ1sh and commun1cate responsibilities.
Management objectives have been established and communicated to the staff, and management has initiated an MBHA program to improve visibility and responsiveness in the workplace.
In addition, physical plant progress has been s1gnificant in areas such as reduction in outstand1ng work requests, maintenance
- items, and system readiness for operability.
Identification and monitoring of regulatory issues related to restart and safe operation (including Technical Specification amendments necessary for restart) are adequately controlled by Licensing.
In spite of the work still remaining to complete the Restart Corrective Actions and to get Unit l ready for restart, it appears that the overall program is well controlled and processes are in place to sufficiently address each of the NRC Restart Guidelines.
The Pane) concludes that the effectiveness of the corrective actions in this area support restart of Unit l.
IV-12
V PREVENT I NG i DETECT I NG i AND CORRECT I NG FUTURE PROBLEMS The Restart Self-Assessment has resulted in the conclusion that Niagara Mohawk has the management and leadership skills to prevent, or detect and correct, future problems.
The informati'on that supports this conclusion is contained in Chapter III and the appendices to this report.
In particular the assessment found that the Nuclear Division and support groups have adopted high standards of performance which are being demonstrated in the identification and effective resolution of problems.
The assessment also found that the corrective actions, such as "in-line" training, had 'improved the effectiveness of planning and teamwork in making decisions and solving problems related to performance limiting defic1encies.
Finally, the assessment identified programs and polic1es that had been developed to continue to enhance the assessment and improvement of the activities of the Nuclear Division.
This section of the report briefly descr1bes some of the additional act1ons Niagara Mohawk is taking to enhance its ability to prevent, detect and correct future problems.
The programs discussed below are part of the Nuclear Division and supporting groups/organizations ongoing activities.
The Nuclear Improvement Program includes act1ons to develop a long-term assessment program for preventing, or detecting and correcting, future defic1encies that could jeopardize safe operation of our nuclear power plants.
This sect1on of the report d1scusses the following major elements of the long-term assessment program:
Expand1ng the exist1ng assessment programs and 1ntegrating into them the concepts establ1shed during the restart effort; Establishing a separate functional assessment group; and Continu1ng the general practice of internal assessment activities while the permanent program is being established.
A.
A key element of the assessment program 1s to enhance existing programs by incorporating into them specific inter-and 1ntra-departmental assessment activ1ties.
Expanding ex1sting programs 1s an evolut1onary
- process, which is often more readily accepted than new programs that introduce revolut1onary change from established pract1ce.
The following are two examples of program enhancements already under way:
Comnitment Follow-up (under Nuclear Compliance and Verification) - to ensure continued 1mplementation and effect1veness of comm1tments made to senior management, the
- NRC, INPO and other agencies.
Annual Strateg1c Assessments
- compare current and past performance to identify strengths and weaknesses; identify internal and external influences on the Nuclear Div1sion and the nuclear industry; and identify strategic init1at1ves for Nuclear Division Planning.
V-1
B.
The IAG is a small group reporting to the Executive Vice President - Nuclear Operations.
This group conducts or facilitates independent formal, special, and informal assessments of critical areas of Nuclear Division and support group programs and activities.
The assessments will help to identify strengths, weaknesses and deficiencies.
Reports'ill be presented to the Executive V1ce President - Nuclear Operations and affected managers.
The need for 1mprovements will be identified and presented to line 'management for appropriate action.
IAG personnel will not have line management or organization respons1bil1ties or have direct functional responsibility in areas being assessed.
Their most important function will be to evaluate and encourage the self-assessment process within the team organization.
Specific areas of assessment will be operations and maintenance; technical support and engineering; radiation and environmental protection; support programs; and overall management and organizational effectiveness, such as, communication, team-bu1lding and leadersh1p.
C.
The term "self-assessment",
as used in Niagara Hohawk's Nuclear Improvement
- Program, refers to assessment activities conducted internally by responsible members of a department or group.
Such internal assessments may be supported by contracted individuals or groups as needed.
Self-assessment activities can include:
Heeting evaluations, conducted after meetings to identify strengths, weaknesses, and deficiencies, with recemendations for improvement.
Weekly progress evaluations, conducted at week's end to ident1fy strengths, weaknesses, and deficiencies, with recommendations for improvement.
Assessment of the effectiveness of corrective act1on results and their cont1nued implementation.
Development of performance 1ndicators for monitoring performance and trends.
Evaluat1on of trends to determine acceptable performance levels and needed correct1ve actions.
Hon1toring department performance in comparison with goals, ob)ectives, and act1on plans.
Comparison of programs and performance with industry standards and averages.
The SRA8 is establishing an ongoing method for continually assessing the effectiveness of the Nuclear Improvement Program.
V-2
4
APPENDIX 4 ACTIONS TO BE TAKEN PRIOR TO RESTART SEPTEHBER 8, 1989 This Appendix identifies those assessment recommendations for which actions remain to be completed prior to restart of Nine Hile Point l.
Complete, verify and close out remaining RAP corrective actions.
Incorporate assessor long term recommendations ln the NIP or on NCTS.
(PLANNING AND GOAL SETTING - URCI)
Revise policy to require communication to appropriate personnel that the department manager must be notified that a commitment ls due.
Executive Vice President approve the Nuclear Division Integrated Priority System and lmplementlng procedures.
Develop and implement a training plan on the application of the Integrated Priorltizatlon System.
(WOSLEH SOLVING - URC2)
Develop a plan for coaeunlcation of the problem ownership process.
IAG coordinate the development (with line management) of a plan to assess the effectiveness of the problem resolution process.
Perform a root cause analysis of why 1981 radwaste spill was not cleaned up expeditiously.
Perform a root cause analysis of why Specific Issue 18 was not closed earlier.
(STANDARDS OF PERFORNANCE AND SELF-ASSESSNENT-URC 4)
Complete actions required to integrate the Independent Assessment Group into existing functions.
0444A disk 055c A4-1
(S I -1 OUTAGE MANAGEMENT)
Develop an action plan and schedule to involve the Unit 1 Outage Manage directly in the development of the permanent Outage Management Plans and to use the lessons learned from the current outage.
Complete the review of the seven SOER recommendations identified by INPO hav1ng to do with plant startup and operations.
Change startup procedure to include tracking of all INPO and NRC commitments which become due before the date of startup.
Upgrade the restart procedure to include all NRC commitments.
Implement a track1ng system to track closure of assessment open items.
Track to completion the near term improvements identified by INPO, including seven SOER recommendat1ons dealing with plant startup and operations.
(S1-2 MAINTENANCE OF OPERATOR L I CENSES)
Complete SRAB audit of training/operator 1nterface.
(SI-6 FIRE BARRIERS)
Check and verify that all Design Change Requests and reissued drawings have been walked down.
Identify and assign resources for data base ma1ntenance.
Revise and issue applicable s1te administrative procedures.
Document technical )ustification for existing penetrat1on seal design and supporting Engineering evaluations.
Issue engineering procedure to evaluate breaches of fire barriers.
Develop acceptable level of confidence for results of penetrat1on walkdowns includ1ng resolut1on of seal classif1cat1on 1nconsistencies.
Establish statistical adequacy of penetration destruct)ve testing.
Implement controls for the coating of'ables.
Implement controls for the use of drawings after discrepancies are ident1fied 1n the f1eld.
Document justification of Gage Babcock issues.
0444A disk 055c A4-2
Revise Electrica)
Maintenance procedure S-EMP-GEN-001, "Maintenance of Penetrat1ons",
to be consistent with current penetration seal design details.
Implement resolution of SER commitment discrepancies.
Complete acceptance of calculations for structural steel during credible fire.
Revise NEL-046 to address all audits.
Rev1se Engineering procedures to address penetration fill requirements.
(SI-7 TORUS WALL THINNING)
Document the logic for Justifying that the torus wall thickness is adequate for cont1nued operation based on thickness measurements.
(Final Report expanding information contained in MPR summary letter.)
(SI-8 SCRAM DISCHARGE VOLUME)
Revise NDP-3 to address assessor identif1ed deficiencies regarding delegation of author1ty, Revise functional organization charts to establish clear responsibility for responding to NRC correspondence.
(Sl-12 MG Battery Set Chargers)
Develop documentat1on that describes the des1gn bases for the MG set battery chargers and that demonstrates the capab1lity of the chargers to meet the design bases.
Incorporate this documentation in the Design Bases Documentation and Configuration Control Systems.
Revise the or1ginal Appendix 8 downgraded component cross-disc1plinary review report to 1ndicate resolution of all open items.
Document the disposition of the suggested recomnendations ment1oned in that report.
Update the FSAR to reflect the new design basis described in the revised "125 VDC Stat1on Battery Design Evaluation Report".
0444A d1sk 055c A4-3
(Sl-14 SSFI)
Complete documentat1on for the electrical capability of the high pressure coolant in]ection system, Issue the specification (or revised procedure) for controlling the use of furmanite and similar mater1als.
Develop a plan and schedule for relieving the program manager of the design basis reconst1tution plan of other duties, Complete and accept calculations for the containment spray strainer pressure drop.
Revise procedure and complete training for the core spray high pressure alarm.
Complete training of operators on core spray pump suction graphs in the Emergency Operating Procedures.
Revise the procedure and complete training on new water level indication.
Complete the validation test for the high pressure coolant injection system pump curves.
Complete the test of the core spray keep fill system.
Implement procedure changes to resolve pump motor cycling concern.
Complete train1ng of involved personnel on pump curve control.
Implement changes requ1red from the review of vendor manuals.
Implement control measures for configuration management for necessary parameters.
Revise necessary calculations to incorporate flow diversion potent1al.
Revise procedures and train operators for those situations where an operator may defeat automat1c functions.
Complete training of operations personnel on revis1ons to the Core Spray low suct1on pressure alarm.
Modify maintenance procedures to require pump curve revalidation after ma)or maintenance.
0444A disk 055c A4-4
(S 1-17 I NSERV ICE TESTING)
Approve and 1ssue associated Administrative Procedures.
(SI-18 125 VDC)
The "125 VDC Station Battery Design Evaluation Report" requires revision in support of open 1tems.
The requirement to complete short circuit and fuse coordination stud1es should be reviewed.
Develop a Nuclear Improvement Program action plan wh1ch indicates actions to be taken to resolve deficiencies which can be delayed beyond restart.
(Root Causes Addressed - NRC Generic Issue)
Reduce the OEA backlog to an acceptable and defined level.
(Physical Plant Readiness - NRC Generic Issue)
Clearly identify and complete all necessary ma1ntenance items.
Develop eng1neering evaluat1ons wh1ch prov1de assurance that the as-built des1gn does not confl1ct w1th the safety design
- bases, such that the schedule for the long term program is ]ustified.
(Regulatory Requirements - NRC Generic Issue)
Identify and obta1n from the NRC all necessary Techn1cal Specification amendments.
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0