Text

Initial SALP Repts 50-220/91-99 & 50-410/91-99 for Period of 910401-920523
	ML17056B968
Person / Time
Site:	Nine Mile Point
Issue date:	08/25/1992
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML17056B969	List: ML17056B968;
References
	50-220-91-99, 50-410-91-99, NUDOCS 9209010185
	Download: ML17056B968 (72)
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ENCLOSURE

SALP REPORT

V.S. NUCLEARREGULATORYCOMMISSION

4

REGION I

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Cy

SYSTEMATIC ASSESSMENT OF LICENSEE

PERFOMIAINCE

REPORT NOS. 50-220/91-99 AlND50-410/91-99

NjlAGAI4kMOHAWKPOWFK CORPORATION

NIIMMILEPOINT XPlITS 1 AND 2

ASSESSMENT PERIOD: APKE 1, 1991 - MAY23, 1992

BOARD MEETINGDATE: JULY 9, 1992

9209010185

920825

PDR

ADOCK 05000220

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(1

TABLEOF CONT1PlTS

INTRODUCTION

~

1

II.

SUMMARYOF RESULTS................

II,,A

Overview

II.B

Facility Performance Analysis Summary....

~

2

4

IV.

PERFORMANCE ANALYSIS..............

III.A Plant Operations

III.A.1

Unit 1

III.A.2

Unit 2-

III.B Radiological Controls

III.C

Maintenance/Surveillance

.- .. ~.........

III.D Emergency Preparedness

III.E

Security

III.F

Engineering/Technical Support

III.G

Safety Assessment/Quality Verification.....

SITE ACTIVITIESAND EVALUATIONCRITERIA

IV.A Licensee Activities.................

IV.B

Unplanned Shutdowns, Plant Trips and Forced

IV.C NRC Inspection and Review Activities.....

IV.D Escalated Enforcement Action ..........

IV.E

SALP Evaluation Criteria.............

~

Outages

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5

7

10

12

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18

21

23

26

29

31

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It

I.

INTRODUCTION

4

The Systematic Assessment of Licensee Performance (SALP) is a periodic, integrated Nuclear,

Regulatory Commission (NRC) staff effort to evaluate licensee performance on the basis of

'collected observations

and data.

The SALP process

is supplemental

to normal regulatory

processes

used to ensure compliance with NRC rules and regulations.

SALP is to be sufficiently

diagnostic to provide a rational basis for allocating NRC resources

and to provide meaningful

feedback to licensee management

to promote quality and safety of plant operations.

An NRC SALP Board, composed of the staff members listed below, met on July 9, 1992, to

assess

the performance of the Niagara Mohawk Power Corporation (NMPC) at Nine MilePoint

Units

1 and 2.

This assessment

was based on the collection of performance observations

and

data for the period of April 1, 1991, to May 23, 1992, and was conducted in accordance with

the guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performance."

A summary of the guidance and evaluation criteria is provided in Section IV.Ein the Supporting

Data of this report.

The SALP Board was composed of:

Chairman:

J. Wiggins, Deputy Director, Division of Reactor Projects (DRP)

Members:

W. Lanning, Deputy Director, Division of Reactor Safety (DRS)

J. Durr, Acting Deputy Director, Division of Radiation Safety and Safeguards

(DRSS)

R. Capra, Director; Project Directorate I-l, Office of Nuclear Reactor Regulation (NRR)

L. Nicholson, Chief, Reactor Projects Section No. 1A, DRP

D. Brinkman, Senior Project'Manager, NMP Unit 1, NRR

J. Menning, Project Manager, NMP Unit 2, NRR*

W. Schmidt, Senior Resident Inspector, DRP

Each of the Project Managers supplied a vote in the determination of the Category Rating

for their respective units in the Plant Operations functional area,

In the other functional

areas the Project Managers provided one vote which represented

their consensus

on the

Category Rating.,

Others in Attendance

C. Cowgill, Chief, Projects Branch No. 1, DRP

R. Laura, Resident Inspector

W. Mattingly, Resident Inspector

C. Beardslee,

Reactor Inspector, Intern

II.

SUMMARYOF RESULTS

U.A Overview

During this period, performance was generally good and both plants continued to be operated

safely. However, some instances ofinattention-to-detail and failure to followprocedures caused

problems.

These instances indicated that NMPC had not been fullyeffective at correcting these

longstanding performance

issues.

While the number of reactor scrams

caused by personnel

errors was very low, the total number of scrams caused by equipment failures, particularly at

Unit 1, was high.

Good operator response

to the events ensured the continued safe operation

of the plants.

Overall the functional area

Category

2

III.A.1.3

Board Comment:

The occurrence ofproblems with procedural adherence

and

attention-to-detail suggest that the licensee's past actions to

address these long-standing performance problems have not

been

fully effective.

Continued

licensee

and

NRC

emphasis in these areas is appropriate,

III.A.2

Unit 2

The previous SALP report rated Unit 2 Plant Operations

as Category 2.

Overall performance

was good, having improved substantially. While several personnel errors occurred, they resulted

in events of low safety

significance and were not indicative of poor operating

practices.

Licensed operators understanding ofand ability to use the emergency operating procedures were

considered

strengths and indicated effective training.

III.A.2.1

Analysis

The Unit 2 operations department continued to perform well this assessment

period.

Operating

crews successfully responded

to several challenging events.

Operator response

to scrams and

forced shutdowns

was prompt and proper, however,

one scram

was the direct result of an

operator error. Routine operation ofthe plant was generally good, with only occasional isolated

instances ofoperator inattention-to-detail.

The operations department management

changes and

the assistant station shift supervisor watch station relocation, as discussed below, were positive

initiatives.

Management continued noteworthy involvement in daily activities.

The operator

training and requalification programs supported safe operation of the plant.

The operating

crews

generally

responded

well to challenging

plant transients.

A main

transformer fault in August 1991, caused

a turbine trip, reactor scram,

and a simultaneous

common-mode loss offive non-safety related uninterruptible power supplies (UPS) that powered

non-safety

related control room instrumentation

and plant equipment.

The NRC Incident

Investigation Team which reviewed this event determined that the operators correctly classified

these circumstances

as a Site Area Emergency

and properly completed

many high priority

actions in a high stress,

time-sensitive environment, while many of their normal indicato'rs,

alarms,

and communications were misleading or not available.

The operators

diagnosed

the

instrumentation losses as UPS-related and then promptly restored the UPS loads.

In summary,

the operators successfully coped with this difficultsituation.

Operators performed well during the March 1992 loss of both 115kV off-site power lines, which

caused a second loss of control room annunciators.

The operating crew correctly classified the

loss of control room annunciators

as an Alert.

Operators

relied on incomplete information

provided by technicians after the loss of the first off-site power line, that led to the total loss of

off-site power.

Operators

made reasonable

decisions to restore electrical power following the

complete

loss.

The station shift supervisor

exhibited good command

and control while

conducting plant restoration.

However, the NRC Augmented Inspection Team which reviewed

this event determined that NMPC management

had not adequately considered

the effects of a

loss of off-site power on the instrument air system while shutdown,

the need for enhanced

electrical system recovery procedures,

and the time required for a non-site operator to close the

off-site power breakers.

The team found that, because

these issues were not fully considered,

the operator's

response to this event was unnecessarily

complicated.

The operating crews demonstrated

good performance during the unit startups and shutdowns.

During the three automatic reactor scrams and one forced shutdown, the operators competently

and professionally maintained the plant in a safe configuration.

The operating crews properly

conducted the subsequent

unit startups with excellent communication and supervisory control.

Equipment failures led to two of these

three scrams.

The third scram

resulted

from an

inadequate procedure and a breakdown in communication betw'een the station shift supervisor,

the assistant station shift supervisor,

and the chief shift operator.

Operators

conducted

routine activities in a well controlled

manner.

The operating

staff

satisfactorily controlled component and system status, monitored plant conditions, and identified

problems'during

maintenance,

surveillance,

and

outage

activities,

A diligent operator,

investigating a hissing sound, identified a shattered main generator sight glass leaking hydrogen

into the turbine building. In another example, an operator demonstrated good system knowledge

and a questioning attitude in identifying a problem with the air start receiver pressure during a

tour of an emergency diesel generator room.

Excellent shift crew turnovers, log keeping, and

proper use of the deviation/event report system provided management

with a good awareness

of daily problems and operating concerns.

l

(

In contrast to the above,

several minor instances of personnel

inattention-to-detail occurred

which resulted in several engineered

safety feature actuations,

a configuration control problem

with a secondary containment unit cooler, and a loss of condenser vacuum due to an operator

not following an approved procedure.

Although these instances were minor they indicated that

the actions taken previously by NMPC to address

these performance problems have not been

fully effective, and that there is a continued need for heightened supervisory and management

oversight.

Operations department management demonstrated good performance through aggressive problem

identification and resolution.

Corrective actions developed from event critiques were generally

thorough and appropriately implemented.

NMPC management successfully implemented a self-

assessment

program to detect and correct performance

issues.

Although management

changes

were made, including a new department manager and several new supervisors,

a high level of

experience

and

technical

knowledge

was

maintained.

Moving the assistant

station shift

supervisor from the station shift supervisor's

office to the control room floor enhanced

the

supervisory presence in the control room and allowed both the assistant station shift supervisor

and

station shift supervisor

a more broad

and independent

perspective of the operational

conditions affecting plant safety.

Management

committed

adequate

resources,

regularly

reviewed,

and made satisfactory progress

in reducing the number of nuisance control room

alarms.

The implementation of the operator training and requaliflication programs were effective this

period.

Operator performance following the failure-of the station transformer and the loss of

off-site power events reflected positively on the training department.

Overall, licensed personnel

performed

well during

an NRC-administered

requalification

examination.

Planning

and

administration of the examination

and crew teamwork in the simulator were good.

Ample

staffing existed this assessment

period with the operators in a five-shift crew rotation and a

permanent day-shift relief crew.

ummar

- Unit 2 Plant 0 erations

In summary, the operations department demonstrated

good performance with the exception of

some minor instances of inattention-to-detail.

The operating staff encountered

and successfully

met a number ofsignificant challenges to their capabilities, caused mainly by equipment failures.

Operations department

management

was strongly involved in daily activities.

Staffing levels

were ample and the training department performed well.

III.A.2.2

Performance Rating:

Category

2

t

4

10

III.BRadiological Controls

In the previous SALP period, this functional area was rated as Category 2. Performance in the

area of ALARAwas generally good with some ALARA shortcomings identified during the

Unit 2 first refueling outage.

Radioactive

waste

(radwaste)

processing

and transportation

remained a strength.

Radiological chemistry controls were good and progress was noted in the

area of effluent monitoring.

III.B.1

Analysis

Radi lo ical Controls

NMPC continued to maintain an effective radiological controls program at both units. ALARA

performance was good with notable improvements in the program and performance at Unit 2.

Minor areas of mixed performance

were noted at both units.

Radiation protection staffing

remained good with several organizational changes.

Training remained highly effective.

The

external and internal dosimetry and respiratory protection programs performed well. The quality

assurance

program continued to be a notable strength in this area.

The radwaste programs at

both units performed very effectively.

Significant improvements were made by NMPC in its corporate ALARAprogram and in its

ALARAperformance at Unit 2, while maintaining an outstanding ALARAprogram at Unit 1.

NMPC senior management

developed

a corporate ALARA policy, which included specific

performance goals for all major departments

at the site, and clearly demonstrated

its support of

the ALARAprogram to all workers.

During the second refueling outage, Unit 2 established

a

challenging ALARAgoal which was one-third lower than its total dose during the first refueling

outage.

This outage was completed with a total dose 10% lower than this goal.

Strong support

for the ALARAprogram and its goals by the major department

heads and plant manager was

observed.

While performance was generally good, several instances of poor performance occurred.

Both

units had problems in late 1991 with operations department personnel making improper High

Radiation Area entries.

At Unit 2, plant personnel were observed exiting the Radiologically

Controlled Area (RCA) without properly frisking and in one case radiation protection technicians

did not properly assess

the cause for alarming airborne activity monitors in the Unit 2 reactor

building. Radiological safety postings and surveys ofareas within the RCA were generally good

at both units.

However, radiological housekeeping

was a problem at Unit 2, where multiple

instances of poor worker housekeeping

practices were noted.

11

NMPC internal dosimetry and respiratory protection programs were determined to be generally

good, and the licensee took corrective actions to upgrade its procedures in this area to address

concerns raised during the previous SALP period.

The external dosimetry program was also

conducted well.

Late in the assessment

period, NMPC began a program to fully review all

dosimetry records to validate data in preparation for the implementation of a computerized

radiation protection

records

system.

Errors identified by the end of the period involved

improperly prepared and documented worker dosimetry forms.

Staffing levels remained good, with all key positions filled by competent professionals.

In late

1991,

NMPC disestablished

the

site radiological

support

organization,

which had

been

implementing the transportation, dosimetry and respiratory protection programs for both units

and gave responsibility for these programs to the unit Radiation Protection Managers (RPMs).

This move improved the RPMs'ontrol over all areas of the radiation protection program.

No

changes in staffing levels within these functional areas occurred as a result of this action.

Each

unit now has responsibility for its own transportation activities, while Unit 1 supports both units

for internal dosimetry and respiratory protection, and Unit 2 supports both units for external

dosimetry..

Ahighly effective training program forboth radiation protection and radwaste personnel was also

continued.

A minor weakness identified during the last assessment,

involving training of the

training department staff, was corrected during this assessment

period. Awell developed training

program for contractor radiation protection

technicians

was also implemented

during this"

assessment

period, as demonstrated by the lack of personnel errors.

The NMPC quality assurance program in the radiological protection and radwaste areas continued

to be a notable strength, with exceptional scope and technical depth in the audit and surveillance

program. NMPC management continued to utilize this program to improve its own performance

by taking prompt actions on all findings and recommendations

contained in these reports.

NMPC continued to implement a very effective radwaste program at both units.

Radwaste

operators maintained strict access control of personnel and oversight ofactivities in the radwaste

buildings,

A new radwaste general supervisor position provided increased

oversight of that

group. Allshipments were made in accordance with the applicable DOT and NRC

'regulations,

and all waste shipments were found to be acceptable to the disposal sites.

NMPC also exhibited

a high degree of sensitivity with regard to problems involving a shipping cask utilized in the

transport of highly irradiated reactor components

from the Unit

1 spent fuel pool.

Despite

significant problems associated

with the use and decontamination of this shipping cask,

the

licensee made several successful shipments.

12

R

i

1

i

1Environmen

1

nd Effl ent M ni

rin

Pr

rams

NMPC continued to implement a strong radiological environmental monitoring program. NMPC

operated

an extensive surveillance program for the collection and analysis of environmental

samples and for the meteorological monitoring instrumentation.

A programmatic weakness involving the operability of effluent monitors was identified during

the last two SALP periods, with several effluent radiation monitoring systems (RMS) out of

service due to design deficiencies.

Special management attention was provided, and initiatives

to improve the operability of effluent monitors were developed.

Management's commitment to

maintaining the operability and reliability for all effluent RMS was demonstrated

effectively

during this SALP period, with significant improvement noted in the operability of the effluent

RMS. Liquid and gaseous effluent sampling, analysis, and reporting were good. Aircleaning

systems were well maintained and tested.

Quality assurance

audits covered the stated objectives and were of excellent technical depth to

assess the off-site dose calculation model radiological environmental monitoring, and radiological

effluent monitoring programs.

ummar

- Radiolo ical Controls

In summary, NMPC has made significant improvements in its ALARAprogram at Unit 2, while

maintaining

a very effective ALARA program at Unit 1, together with strong

radwaste,

transportation

and

radiological

environmental

monitoring programs

at both

units.

The

radiological controls program was generally good at Unit 1, while continued weaknesses

in this

area

at Unit 2 were

observed,

with examples

of this

weakness

evident in radiological

housekeeping,

a High Radiation Area entry, and improper RCA exiting. The operability of the

effluent RMS was significantly improved, while continuing to maintain very effective liquid and

gaseous effluent control programs.

III.B.2

Performance Rating:

Category

2

III.B.3

Board Comment:

The Board recognized that significant improvement in the

performance of the Unit 2 ALARAprogram was achieved.

III.C Maintenance/Surveillance

During the last assessment

period the combined

Maintenance/Surveillance

functional area

received a Category 2 Rating.

At Unit 1, maintenance performance improved, in part, due to

good procedural adherence. 'owever, some instances of poor maintenance practices resulted in

unplanned

shutdowns.

Progress

in reduction of the work request

backlog

was

made.

Performance in the surveillance area demonstrated

improvement.

Good planning and effective

management

oversight resulted in proper execution of the start-up test program.

1

4-

~

13

Unit 2 demonstrated

generally

good performance

in maintenance

and efforts to improve

procedural controls and personnel procedural adherence were evident.

Maintenance personnel

significantly reduced operational events involvingpreventive or corrective maintenance.

Progress

was noted in reducing the work request backlog,

Surveillan'ce testing was generally good.

The

maintenance

department

satisfactorily implemented inservice inspection and inservice testing

programs during the period.

III.C.1

Analysis

IH.C.1.1

Unit 1

Maintenance

The Unit 1 maintenance staff demonstrated generally good performance during this assessment

period.

Maintenance personnel performed well during corrective and preventative maintenance

activities. A few noteworthy instances of poor maintenance performance occurred due to weak

procedural adherence

and inattention-to-detail.

These included a significant breakdown in the

implementation of the work control program leading to the temporary isolation of the unit from

its ultimate heat sink.

Strong management

oversight maintained a low maintenance

backlog,

improved in-field supervision, and good overall plant material condition.

Several operational

events resulted from various causes including age-related degradation of non-safety equipment.

The outage planning organization functioned well over the period.

Maintenance workers generally demonstrated good performance during corrective and preventive

maintenance.

During preventive maintenance on containment spray heat exchangers and on the

emergency

diesel generators,

maintenance

personnel exhibited good work practices and good

safety perspective..

Maintenance

personnel

exhibited

a questioning

attitude by identifying

improperly operating equipment and potential problems during plant tours.

Staffing remained

at a suitable level. Detailed post-maintenance

tests verified effective completion of maintenance

work.

Excellent housekeeping

practices and the overall condition of the plant equipment and

areas reflected a conscientious

attitude.

The painting of the walls and floors in the reactor

building represented

a significant effort to improve plant housekeeping.

A few instances of poor performance occurred due to inattention-to-detail and poor procedural

adherence.

Also, a significant breakdown in the implementation of the work control process

occurred in February 1992, which resulted in the temporary isolation ofthe unit from its ultimate

heat sink. This latter event resulted from failure to follow established work control processes,

inadequate

management

attention in assuring that procedures were being followed, inadequate

communications between several NMPC organizations, and from inadequate consideration of the

risks associated with the activities being performed.

Other minor examples ofpoor performance

also occurred, which reflected weaknesses in supervisor and management oversight. In contrast,

good management oversight led to maintaining preventive and corrective maintenance backlogs

.

low. Further, managers

and supervisors were frequently present in the field to oversee work

practices.

4

a

~

14

NMPC management took prompt and thorough corrective actions to address the causes for the

breakdown in the work control process discussed above.

These actions included a high quality,

self-critical assessment

that developed

corrective actions for the identified causes.

NMPC

implemented a monitoring process which provided management

assessments

of work control

activities.

Managers

and supervisors

conducted

this activity at both units to develop

an

understanding of the weaknesses

and the need for more management oversight of the process.

The overall scope ofthis program appeared good; however, its long term effectiveness remained

a concern.

Failures of balance-of-plant equipment challenged plant operators by causing five of the six

. reactor scrams, the one forced outage, and.several forced reductions in power. NMPC identified

the need to increase the effectiveness of preventive maintenance performed on balance-of-plant

equipment and initiated short and long-term corrective actions. The effectiveness ofthese actions

in reducing plant scrams and transients has yet to be demonstrated.

Aggressive planmng and scheduling during routine operations

ensured

the safe and effective

completion of work. During forced outages the planning department quickly developed detailed

work and contingency schedules.

Pre-planned

outage work was coordinated and implemented

effectively.

Increased

management

oversight, during outages,

resulted from the addition of a

shift manager responsible for tracking work and maintaining an overall status.

urv illance - Unit I

The NMPC staff effectively implemented the Unit 1 surveillance test program. Testing identified

conditions needing correction before equipment failure occurred.

The NMPC staff conducted

testing well, in accordance with approved procedures.

Scheduling and tracking of surveillance

tests

continued to be effective.

The inservice testing /ST) and inservice inspection

(ISI)

activities were properly scheduled

and conducted.

During the period, surveillance testing was properly conducted and led to the identification of

equipment

needing

repairs.

The NMPC staff effectively documented

surveillance

testing

problems on work requests

and/or deviation/event

reports

as necessary

to allow corrective

actions. A review of the reactor building emergency ventilation system testing identified that the

test acceptance criteria during a secondary containment drawdown test was not in conformance

with the design requirements of the system fans.

Prompt actions to develop a new acceptance

criteria resolved this issue.

The NMPC staff generally used properly prepared test procedures

and correctly recorded test

data.

Three inadvertent engineered safety feature actuations occurred relating to testing.

These

actuations

were minor, not directly related

to personnel

errors,

and did not i'ndicate any

programmatic

problems.

However,

in one instance

maintenance

personnel

installed

test

instrumentation on several core spray system pressure control valves. This installation was done

informally, not in accordance with the temporary modification procedure, and without regard for

~ ~

15

the impact on system operability. NMPC took adequate actions to ensuie the installation of test

equipment in accordance with an approved procedure.

In another instance NMPC identified and

properly dispositioned

an issue that timers in the automatic initiation logic for the reactor

building emergency ventilation system had not been tested.

The scheduling and tracking of sur veillance testing remained very good.

A computerized data

base provided an effective management tool.

The ISI/IST program was generally effective over the period,

Changes to the structure of the

programs occurred during efforts to streamline the nuclear division. The ISI/IST group, which

previously reported to site engineering, divided such that ISI reported to the quality assurance

department,

and IST reported to the operations department.

There have been no observable

impacts of these changes

on performance in the surveillance test area.

During the period ISI

activity was low because of the unit outage scheduling.

NMPC enhanced

the program by

providing dedicated IST personnel to perform the ultrasonic flow and vibration measurements

on all equipment.

This action and special technician training- on the use of ultrasonic flow

instrumentation significantly reduced the possibility for inaccurate data.

III.C.1.2

Unit 2

Maintenance

The Unit 2 maintenance department continued to demonstrate good performance this assessment

period. Maintenance personnel knowledgeably performed activities and demonstrated the proper

safety perspective;

although, inattention-to-detail resulted in several operational events.

The

maintenance work request backlog remained high; with few exceptions, management effectively

tracked

and properly dispositioned

work requests

to ensure

system

operability.

Material

condition throughout the plant remained good.

Maintenance supervisors generally performed

well and satisfactorily monitored daily maintenance activities.

The training and qualification

programs

were effective and

maintenance

staffing levels remained

stable.

The planning

department provided good support for planned and forced outage work.

Maintenance

personnel

were knowledgeable

and experienced

and they generally performed

corrective and preventive maintenance in a professional manner.

However, performance overall

was inconsistent.

While there were no plant transients related to performance of maintenance

activities, maintenance personnel performance was poor related to the dropping oftwo new (non-

irradiated) fuel assemblies.

In addition, several other personnel errors occurred that caused

engineered

safety feature actuations.

NMPC took good corrective actions in response to these

events.

These maintenance errors were not indicative ofprogrammatic maintenance failures, but

were isolated examples of poor work practices and inattention-to-detail.

I

IL

16

The maintenance request backlog remained high throughout most ofthe assessment

period. Plant

events and the increased

scope of the refueling outage precluded a net reduction in the total

backlog, however,

management

prioritized and dispositioned the work requests in a manner

consistent with continued safe operation of the plant.

Oversight of activities by maintenance

management

and supervision was generally good this

assessment

period, but with notable exceptions.

The maintenance management established clear

standards for supervisor work observations.

First line supervision positively contributed to the

work quality by clearly communicating management expectations and consistently observing daily

maintenance activities.

The supervisor's knowledge and oversight were considered

strengths,

especially during the recirculation loop sample line corrective maintenance.

Maintenance management

demonstrated

a good safety perspective during the emergency diesel

generator cylinder liner replacements

due to tin smear.

However, maintenance

management

oversight was not fully effective at preventing significant errors as evidenced by the event in

which new fuel bundles were dropped and by the events in which offsite power and control room

alarms were lost.

The maintenance technical training and qualification programs functioned well as exemplified by

a strong maintenance welding training program.

The mechanical maintenance training program

was good.

In general, the material condition of plant equipment was good.

The maintenance

staffing levels remained stable this period.

urv ill nce- Unit 2

The Unit 2 staff appropriately implemented

the surveillance testing program and positively

contributed to the continued

safe operation of the plant.

Knowledgeable

and professional

personnel successfully completed technical specification surveillance tests within the specified

frequencies with few exceptions.

However, inattention-to-detail contributed to several minor

errors.

For example, a technician error caused

an inadvertent start of the high pressure core

spray pump and its associated

emergency

diesel generator.

Once identified, NMPC took

adequate corrective actions to address each of these instances. The surveillance testing prob!ems

encountered over the period were isolated and of minor safety consequence.

The surveillance testing program, including IST, properly demonstrated

the operability and

availability of safety

systems

to perform their intended

function.

Management

properly

dispositioned equipment deficiencies identified during surveillance test. A service water system

check valve failure identified during an IST reverse flowtest was properly resolved.

Testing and

subsequent

troubleshooting

on the standby

gas treatment

system

allowed identification and

correction of a condition which could have caused

system valves to fail in a non-conservative

position.

~ g

17

Review of the ISI program for the recirculation system piping and a sample of nondestructive

examination data indicated that the program met the applicable requirements

and was well

managed.

These instances

were evidence of good quality control of inspector qualifications,

proper procedures,

and resolution of indications.

The erosion/corrosion

program for high

energy piping systems properly addressed

the effects of flow assisted phenomena.

The snubber

testing and local leak rate testing (LLRQ programs continued to be implemented well.

v rail

umma

- Main

n n

n

urv illan

ni

1

nd 2

The maintenance

staff at Unit l generally performed well with some

notable exceptions.

Increased

supervisory and management

presence in the field, low work request and preventive

maintenance

backlogs,

and good team work between

the maintenance

department

and other

working groups

indicated

generally

good management

oversight.

However,

a significant

program

implementation

breakdown

during maintenance

activities

on a screenhouse

gate

occurred which resulted in a temporary loss of the ultimate heat sink which challenged

the

operations staff.

Although short and long term corrective actions were initiated to address

the

high number of maintenance-related

scrams and events, their continued occurrence indicates that

the efforts have been less than fullyeffective. The surveillance test program, including ISI and

IST activities, was effective at identifying and correcting equipment deficiencies.

The maintenance department at Unit 2 continued to demonstrate

generally good performance.

Maintenance

personnel

knowledgeably

performed

maintenance

and

surveillance

activities,

demonstrating the proper safety perspective.

However, a poor plant impact assessment

led to

a loss of off-site power and poor supervision contributed to the dropping of two new fuel

bundles.

The plant material condition and overall management of work planning was good.

Maintenance department

management

oversight was considered

a strength.

The surveillance

testing program, including the ISI and LLRT programs, consistently confirmed the operability

of safety systems.

III.C.2

Performance Rating:

Category

2

Trend:

Declining

III.C.3

Board Comment:

In general, the station performance in the maintenance area

was good, but inconsistent.

Based on repeated instances of

maintenance-related

scrams and events, which occurred at

both units throughout the period, the board concluded that

overall effectiveness of the program was declining.

~ 1

18

III.DEmergency Preparedness

For the last SALP period, Emergency Preparedness

was rated as Category 1. Strengths included:

appropriate and timely classification of six Unusual Events, sufficient emergency planning (EP)

department staffing, Emergency

Response

Organization (ERO) depth, and effective training.

One exercise

weakness

resulted from failure of an ERO manager

to request

core damage

assessments

and another resulted from failure to consider plume trajectory variability when

calculating projected doses.

Subsequent inspection found that appropriate corrective action was

taken for these matters.

Slowness in resolving 1988 Emergency Response Facility Appraisal

items indicated a lack of proper management attention to certain items.

Analysis

NMPC implemented

an excellent EP program over the period.

When challenged by actual

events, including a Site Area Emergency (SAE), the emergency

plan functioned effectively.

Further, each event was analyzed by the EP staff and actions were taken to address

areas for

improvement.

Management, including EP, site and corporate, involvement in this program was

good.

However, actions to address deficiencies identified related to the drill/exercise program

were

not fully effective.

Additionally, no

assurance

of periodic

Emergency

Response

Organization member participation in drills/exercises was identified.

Emergency facilities and

equipment were properly maintained, and the resolution to facility issues was acceptable.

The

quality assurance

program remained effective in auditing this area.

The Nine MilePoint Site Emergency Plan (SEP) was shown to be effective during several actual

events, including a SAE at Unit 2 as a result of a plant transient with a loss of control room

annunciators

and a partial loss of plant instrumentation.

During these events operator and

management

response

was excellent, and event classifications were timely and proper.

There

was good assignment of emergency responsibilities by the Shift Supervisor and overall actions

taken by response

personnel

were effective.

Personnel

accountability

was not, however,

accomplished for about three hours (as'compared

to a 30-minute goal). Also, notification of the

Emergency Response

organization was initiated one hour after SAE declaration.

The licensee

critiqued its response,

compiled a comprehensive list of items for corrective action, and made

good progress on item correction.

An Alert and several Unusual Events also required Unit 2 SEP implementation.

Again, event

classifications and operator and management

responses were proper.

During the Alert, turnover

of Emergency

Director duties

from the

station

shift supervisor

to Emergency

Response

Organization Emergency Director was conducted well, and personnel in the Technical Support

Center functioned effectively.

Timely corrective actions initiated to address

weaknesses

identified by NMPC's self-critique

following the SAE indicated effective management

control.

Good progress

was made in the

resolution of the SAE action plan high priority items. In particular, the licensee tasked Security

I ~

19

with personnel

accountability

instead of that responsibility

being

shared

by Operations,

Maintenance,

and Security.

This change appeared beneficial to ongoing accountability and the

licensee reported that three drills have since found accountability is not a problem.

However,

the NRC has not yet had the chance to observe accountability effectiveness during an exercise

,or actual event.

Two station drills were conducted in 1991 in addition to the smaller scale drills required by the

emergency. plan, meeting NRC requirements.

However, drill/exercise weaknesses

were evident.

The licensee did not effectively review repetitive problems identified during these drills/exercises

for common cause factors; an example was the late notifications for the February 26,

1991

licensee drill, the August 1, 1991 licensee drill, and the August 13, 1991 SAE.

In addition,

ERO member participation in drills was voluntary, with no assurance of peribdic participation

identified.

Based on the actual response to the Unit 2 SAE, NMPC requested and was granted an exemption

from the required 1991 annual emergency exercise.

The request and the response to the NRC

staff request

for additional

information were thorough,

complete,

and

timely.

NMPC

demonstrated

an understanding of the regulatory issues involved as well as the method and bases

for their satisfactory resolution.

The exemption request justification contained sound technical

judgements based on thorough analysis.

Ample ERO staffing was maintained, with all positions filled at least three deep.

Also, at the

end of the period, the NMPC EP Branch was creating a scenario development committee to

prepare the 1992 emergency exercise scenario, which was a good initiative. Classroom training,

held throughout the year, was well defined and lesson plans were properly controlled, accurate

and well detailed. Apositive initiative to shift from classroom-based

toward performance-based

training was in progress.

NRC walk-through drills of on-shift dose assessors

confirmed training

effectiveness in that function.

The EP program was administered by the Director, Emergency Planning, with good station and

corporate management

involvement in EP activities.

The EP staff held regular meetings with

State and local officials, and maintained a good, close relationship with off-site groups.

The EP

department was sufficiently staffed by eight individuals, including an SRO-qualified individual

(responsible for drill/exercise development)

and a meteorologist.'he

EP staff implemented

essential program tasks.

Although there was no assigned health physicist in the EP Branch, the

obstacle of obtaining

health

physics

support for drill/exercise

scenario

development

was

overcome

by the use of temporary

contractor

support

and

good EP staff knowledge of

Emerg'ency

Plan

Implementing

Procedures

(EPIPs)

~

Station

and

corporate

management

maintained

emergency

response

qualifications,'eviewed

and approved

emergency

plan and

procedure

changes,

participated in drills and exercises,

and interfaced with State and local

agencies.

Senior management

assumed both Site Emergency Director and support roles during

the SAE and the March 1992 Alert and performed well.

J

~I

20

Emergency response facilities, equipment, and supplies were well maintained.

The Operations

Support Center,

which was a multiple use facility, became

dedicated

solely to emergency

response

and improved in-plant response

activities.

EPIPs were well-stated.

EPIP changes

initiated in response to areas needing improvement from the SAE were generally appropriate,

properly reviewed, approved, and distributed.

Resolution ofthe 1988 Emergency Response Facility (ERF) appraisal items continued to progress

acceptably.

Three items were closed in April 1992.

Three other items (safety parameter signal

isolation, plant computer reserve capacity, and Emergency Operations Facility shielding) remain

open.

Safety parameter isolation and plant computer reserve capacity items appear to be on track

for completion during 1995.

The commitment to complete a revised EOF shielding analysis is

now scheduled for completion by the end of 1992.

NMPC's quality assurance program conducted effective EP audits.

Unannounced QA checks of

EP, e.g., carrying of Oswego County cards for expedited transit through roadblocks,

were

assessed

as a strength.

The technical specification audit was combined with the 10 CFR 50.54(t)

review and was appropriate in scope, thorough, and received wide management distribution. The

audit report was provided to state and county officials.

NRC review noted opportunities for

improvement in the information contained in the audit/review plan, such

as the absence of

specific direction as to the evaluation of the adequacy of off-site interface required by 10 CFR

. 50.54(t).

umma

- Emer enc

Pre aredne

s

NMPC continued to implement an effective EP program as demonstrated by responses

to actual

plant events.

Management involvement in EP was good.

Audits/reviews, quality assurance

checks, and readiness ofemergency response facilities were strengths.

EP staffing was sufficient

to support overall response activities. Resolution ofERF appraisal items progressed acceptably.

However, weaknesses in the drill/exercise program, including the indication ofinadequate review

of repetitive problems for common cause factors, were noted.

III.D.2

Performance Rating:

Category

1

Trend:

Declining

III.D.3

Board Comment

Although no specific performance problems have been identified, the Board was concerned with

the voluntary nature of participation of ERO personnel in drills and exercises.

II

III.E Security

During the previous assessment

period; the licensee's performance was rated Category 1. That

rating was based on excellent security practices; a sound performance-oriented training program;

. effectively installed and well-maintained equipment; and a very competent management team who

assured implementation of a high quality program..

III.E.1

Analysis

During this assessment

period, the security program continued to be carried out effectively and

in accordance

with NRC requirements

and NMPC commitments.

Corporate

and plant

management

support continued

to be a notable strength

as evidenced by the planning and

budgeting for program upgrades, active participation in groups engaged in nuclear plant security

matters,

and continued

excellent rapport and liaison with state and local law enforcement

agencies.

Although a corporate staff reduction policy resulted in a significant reduction in

security staffing, previously planned upgrades were completed on schedule, which indicated the

ability of the NMPC security program to adjust to changing circumstances.

The more significant

of these upgrades

was the addition of state of the art equipment to the assessment

system, the

installation of a card reader system to enhance vehicle and driv'er access to the protected area,

and the enhancement of the tactical firearms training course.

A notable strength in this program area was the continued assignment of instrumentation

and

controls g&C) technicians

to the security organization

to maintain security equipment

and

implement upgrades.

The ISAAC technicians effectively maintained systems and equipment and

thereby reduced

the need for compensatory

measures

and personnel overtime.

Although the

number of technicians was reduced, the licensee maintained an excellent testing and maintenance

program.

The training program

was well developed

and

administered

by a staff of experienced,

knowledgeable professionals.

Training facilities and training aids were appropriate and well

maintained.

The effectiveness of training was apparent by the limited number of personnel

errors.

However, exterior patrol officers did fail to detect, for an indeterminate period,

damage'o

the intrusion detection

system

caused

by inclement weather.

The Training Department

promptly reemphasized

patrol officer duties during shift turnover in an effort to prevent

~ recurrence.

The Training Department also enhanced the contingency response training by placing

emphasis on tactics and weapons handling. Additionally, all lesson plans and crucial tasks were

revised to be more performance-based

and a new tracking system was implemented to ensure all

requalification requirements

were met.

The Training Department was actively involved in all

security drills and utilized the feedback from the drills to enhance

the effectiveness of the

program.

Interviews of security officers indicated that the training received was effective and

directed to ensuring that security objectives were properly met. Security officers displayed high

morale and were knowledgeable of their post assignments

and responsibilities.

II

I

22

Based on the initial inspection of the licensee's

Fitness-for-Duty (FFD) program during this

period, it was determined

that the development

and implementation of, the program

was

aggressive,

comprehensive,

and directed toward public health and safety.

Management support

for the program was demonstrated by the high quality of the facilities and personnel responsible

for program implementation.

Corrective actions taken to resolve potential program weaknesses

were prompt and effective, indicating a quality program with appropriate management attention.

NMPC quality assurance

audit program for security audit was comprehensive

in scope and

performance-based.

The licensee used a consultant to provide technical expertise to the Quality

Assurance audit team.

No adverse

findings were identified and recommendations

made to

strengthen the=program were promptly and effectively implemented.

Additionally, the licensee

continued the initiatives of self-assessments

and appraisals

to provide oversight of security

program implementation and personnel performance.

A review of the loggable events demonstrated

that the self-assessments

and appraisals

were

effective in that few events were repetitive and personnel errors were rare. In addition", loggable

events were appropriately analyzed, tracked and corrective actions, where required, were timely

and effective.

Event reporting procedures

were clear and consistent

with NRC reporting

requirements.

No prompt reportable security events occurred during the period.

The reporting

procedures

were well understood

by security

supervisors

and were consistent. with NRC

regulations.

The licensee submitted two revisions to the Physical Security Plan, one revision to the Training

and Qualification Plan and one revision to the Contingency Plan under the provisions of 10 CFR 50.54(p).

The revisions were technically sound

and reflected well-developed policies and

procedures.

Summa

- Securit

The licensee continued to maintain a very effective and performance-based

security program.

Management support and effective program oversight continued to be evident throughout the

period.

The continuing efforts expended

to upgrade

the

security

program,

to resolve

discrepancies

before they became

problems,

and to maintain an effective training program

demonstrated

the licensee's commitment to maintaining a high quality program.

III.E.2

III.E.3

Performance Rating:

Category

1

Board Comment:

The

Board

noted

the

consistent

excellent

security

performance over the last several SALP periods.

)

23

III.F Engineering/Technical

Su pport

Last period this functional area was rated

as a Category 2.

NMPC showed evidence of

increased management involvement in engineering activities compared to the previous assessment

period. The addition'of the system engineers to each of the plant staffs was shown to have been

an asset to the overall quality of engineering support,

However, a few examples during the

assessment

period indicated performance inconsistencies and minor shortcomings in engineering

management

oversight.

The following areas

were identified

as

needing

improvement:

implementation of a technical training program; quality and review of engineering work; and

engineering management oversight. Overall, engineering and technical support performance was

good and generally improved.

III.F.1

Analysis

The NMPC engineering organization generally provided high quality work products, in support

of safe operation of both units.. Effective actions were taken to address previous concerns over

the quality and review of work, amount of oversight by engineering

management,

and the

adequacy of the technical training program.

However, there were weakness

noted in the

administration and implementation ofthe temporary modification process.

The system engineers

continued.to perform well in addressing day-to-day issues and the interface between them and

the other engineering organizations was good.

The modification and design control processes

functioned well.

Inconsistencies

were noted in the quality of the engineering basis for some

submittals to the NRC.

Engineering/technical

support to assure safe plant operation was provided by the site, system,

and corporate engineers for each unit. The site engineering group with design authority stationed

at each

unit provided

good

representation

of corporate

engineering

which expedited

the

engineering and technical support for the station.

The engineering support for the Unit 2 second

refueling. outage was good and design changes needed for the upcoming Unit 1 refueling outage

were on schedule.

The system for assigning priorities to plant nuclear projects had the proper

safety emphasis.

Priority safety significant projects were on schedule

and completed

when

necessary.

Engineering

management

took effective actions

to improve the timeliness

and quality of

engineering work through a performance monitoring and measurement system and an independent

assessment

process.

The engineering organizations,

dedicated to each unit, properly set goals

and measured their performance.

However, the backlog of deficiency/event reports, temporary

modifications, and plant change requests requiring engineering review and disposition remained

high and required continued management

attention.

Improvement was demonstrated

by the

capability to resolve technical

issues

and to deliver quality engineering

products.

Notable.

examples at Unit 1 include:

a sound safety evaluation for operation above 80% power with only

two feedwater heater strings operable; and the investigation of the root cause and scope of cracks

in the emergency cooling system valves. AtUnit 2, some notable examples include: resolution

tg

24

of a crack in the high pressure core spray safe end extension nozzle weld; good evaluation and

corrective action for a recirculation loop sample line failure; and very effective analysis and

corrective actions following determination of a design deficiency in the cooling water system

which supplies the Division IIIemergency diesel generator.

Increased management oversight of engineering work was evidenced by the implementation and

monthly review of the top 10 list of issues at each unit. The configuration management program

at Unit2 was also effective. Task managers and a senior engineering review team were assigned

to resolve

and followup the technical

issues

developed

during the Unit

1

design

basis

reconstitution effort, which was well controlled.

The completed

system design descriptions

clearly addressed

the system

design

requirements,

operating limits, test

and surveillance

requirements,

maintenance considerations,'and

regulatory requirements.

Increased engineering

management involvement, controls and initiatives to assure quality ofengineering products were

observed

during this assessment

period.

A Safety Review and Audit Board engineering

subcommittee

was

formed to assess

the engineering

activities.

The Independent

Safety

Engineering Group monitored engineering work activities and performance. Further, when the

deviation/event report process was used it was effective at identifying and correcting problems.

While the above actions were generally effective, the backlog of temporary modifications for

both units remained high and in need of,continued management attention.

The NRC found that

there have been instances ofinadequate controls over temporary modifications at both units. For

example, the installation of temporary ventilation equipment in the reactor building at Unit 1 was

not processed

as a temporary modification.

Also, temporary equipment installed between the

make-up water system

and service water radiation monitors in Unit 2 was not removed

as

required by the temporary modification procedures.

A technical training and qualification program was effective at ensuring the technical competency

and familiarityof the corporate and site personnel with their responsibilities.

In response to the

previous weakness

in this area, NMPC established

and implemented

a broad-based

technical

training program for the corporate engineering staff in January 1992. This training program was

comprehensive

and enhanced the knowledge and skills of engineering personnel.

A continuing

training program for corporate

engineers

was being developed

by an engineering

training

. advisory committee.

System

engineers

continued to provide good support for the operation of both units.

For

'xample,

system engineers

demonstrated:

excellent knowledge of the loss of uninterruptible

power supplies (UPS) during the event at Unit 2 and provided clear explanation of their design

during several

meetings

with the NRC; good support during system

troubleshooting

and

determination

of root

causes

.following reactor

scrams

and

unexpected

events;

timely

identification ofcylinder liner tin smear during the emergency diesel generator (EDG) overhauls

at Unit 2; and good determination of control rod drives needing replacement and establishment

of an EDG reliability enhancement program at Unit 1. The reactor engineering group conducted

post scram reviews ofconsistently high quality, and provided effective oversight of the spent fuel

pool cleanup effort and fuel performance activities.

J

25

An effective interface between the station and corporate engineering personnel existed at both

units.

The staffing of site and system

engineering

groups for each plant to support

the

engineering/technical

needs ofthe plant contributed to the effectiveness ofthis interface. NMPC

effectively improved

communications

between

the corporate

engineering

staff and other

organizations on-site, through routine meetings to resolve issues.

The active participation of

management

representatives

from different organizations at these meetings facilitated effective

communication.

However, poor engineering involvement was noted during NRC review of the

inadvertent isolation of the ultimate heat sink at Unit 1.

Modifications and design changes were of good quality and technically accurate.

Engineering

management

involvement, project team oversight, and oversight of consultants

used to resolve

issues

were

observed

to be

good.

Engineers

and

project

team

members

were

very

knowledgeable of their modifications and design changes and the 10 CFR 50.59 process.

The

Station Operation Review Committee (SORC) review, engineering

technical reviews,

post-

modification testing, and adherence

to the procedures for the modifications were found to be

good.

Good interaction between system engineers

and corporate engineers were noted during

this process.

Examples of good modifications included:

a snubber reduction program

and

resolution of the feedwater stratification issues

at Unit 2; and feedwater flow control valve

inspection/modification and the installation of the static invertor battery chargers at Unit 1. Both

units developed a comprehensive approach to limitthe impact of zebra mussel intrusion on plant

water systems.

Inconsistencies in the quality of engineering submittals to the NRC were identified during this

period.

For example,

the

calculations

supporting

a proposed

revision

to

the Unit

1

pressure/temperature

limits were well prepared.

Also, analysis of the flaw in the Unit 2 high

pressure core spray nozzle safe end extension weld was excellent and responses

to requests for

additional information on this issue were promptly provided.

However, in contrast to this good

performance,

the no significant hazards consideration analysis in the Unit 2 license amendment

request related to the automatic depressurization

system test pressure contained only a minimally

adequate analysis.

The license amendment request to operate with a control rod uncoupled did

not have an adequate

safety evaluation.

Furthermore,

the NRC staff found the repair plan for

the cracking identified in the Unit 1 emergency cooling system condensate valves did not provide

sufficient engineering

basis to allow non-ASME code repair to the reactor coolant pressure

boundary.

Ip

26

mrna

- En ineerin

nd T hni

I

u

In summary,

the engineering

and technical 'support organization

continued to provide good

support to the station.

The quality of engineering

and management

involvement improved

compared

to the previous SALP period. System

engineers

have continued

to provide good

support at both units.

There have been some instances of inadequate control over temporary

modifications.

Inconsistencies

in the quality of engineering

submittals

to the NRC were

identified during the period.

III.F.2

Performance Rating:

Category

2

III.G

Safety Assessment/Quality Verification

The previous SALP report rated Safety Assessment/Quality

Verification as

a Category

2.

NMPC demonstrated

an'improved

approach

to assuring

quality and

assessing

the safety

significance of issues

affecting plant operations.

Self-assessment

programs

became

more

effective during the latter portions of the assessment

period. The new standards ofperformance

and their methods of implementation were found to be effective in articulating management

expectations

and requirements

and to be generally well understood

and followed by Nuclear

Division personnel.

Licensing action submittals were generally considered

to be technically

adequate and timely. Overall performance in this functional area improved during the previous

'ALP period.

III.G.1

An~al ~

While NMPC demonstrated

generally good performance in this functional area during this

assessment

period, the implementation of programs and policies for correcting the causes for

repeated

inattention-to-detail

and procedural

adherence

errors

has not been fully effective.

Management involvement in day-to-day events was evident, but not fully effective in reducing

the number of scrams or significant operating events.

Activities of the off-site, on-site, and

independent engineering review groups were good.

QA audits and surveillances were generally

effective in the identification of problems; however, management failed to take action on some

identified problems.

NMPC actions in response

to industry information were good.

Self-

assessment

and other performance review activities provided effective evaluations of facility

operations.

Submittals and reports made to the NRC were generally of good quality.

The NMPC Nuclear Division Policy and associated

Nuclear Division Directives were well

written,

assisted

in clarifying management

expectations,

and

defined

responsibilities

and

accountabilities.

However, implementation of these directives in some cases

has not been fully

effective.

For example, the inadvertent isolation of Unit 1 from its ultimate heat sink and the

dropping of two new fuel assemblies

at Unit 2 were due to breakdowns in the control of work

activities.

These

events

and others

discussed

in the operations,

radiological control,

and

Ci

27

maintenance/surveillance

sections of this report demonstrated

that station management

was not

fully effective in ensuring that supervisors

and managers

enforced the expectations

defined in

these procedures.

Significant corrective actions were taken in response

to these and other

events.

However, these issues continued to adversely affect performance and are indicative of

longstanding problems.

The Executive Vice President-Nuclear moved his office from Syracuse,

New York, to the site in late February

1992,

as

a positive initiative to increase

senior

management

oversight of site activities.

Management involvement in day-to-day events has been good and there has been a significant

level of supervisory presence in the field. Despite this involvement, communications within and

among organizations participating in work activities have not always been fully effective,

For

example,

the on-duty station shift supervisor

was not informed of operations

department

concerns about performing the Unit 1 screenhouse

gate tests which led to the loss of ultimate

heat sink event.

Likewise, the loss of off-site power at Unit 2 was caused by a combination of

inadequate

work package

plant assessment

and the reliance by control room operators

on

incomplete information provided by the relay technician after loss of the first off-site line.

Further, there were six automatic scrams in Unit 1 and three automatic scrams in Unit 2 during

this assessment

period.

Seven of the nine automatic scrams

were attributed to equipment

failures, The number of scrams indicates that management

focus on the area of scram reduction

is needed.

The safety oversight committees

(Site Operations Review Committee and Safety Review and

Audit Board) continued to perform thorough and effective reviews of issues

and exhibited a

strong safety perspective.

Most members actively participated in committee discussions

and

exhibited

conscientious

and questioning attitudes.

Topics presented

for review, including

significant operational events, were thoroughly evaluated.

The

Independent

Safety

Engineering

Group

gSEG)

continued

to provide NMPC with

comprehensive

and effective self-assessments

and root cause evaluations.

ISEG review of the

dropped new fuel event at Unit 2 was an example of this, as was the thorough root cause

analysis of temporary modification process

at both units.

The results of these reviews were

presented in an organized manner and the root causes were correctly identified.

NMPC responses

to 10 CFR Part 21 notifications and other industry notifications were prompt,

thorough, and proactive.

When NMPC management

was informed by the NRC staff of a

10 CFR Part 21 notification to the NRC from another licensee regarding potential defective fuel

injectors in Cooper-Bessemer

diesels, the NMPC technical staff had already been apprised of

the issue and had preliminary indications that the suspect injectors were not installed in the Unit

2 diesels.

NMPC also made a proactive decision to immediately verify the Unit 1 EDG rotor

pole mounting bolt torques rather than waiting to perform this check during an upcoming

refueling outage.

Likewise, NMPC took prompt action to inspect the Cooper-Bessemer

diesels

in Unit 2 for tin smearing

following the receipt of new inspection

guidance

from the

manufacturer,

C

<

~

28

Self-assessments

performed during the period provided objective and thorough assessments

of

performance to management.

The operation department self-assessment

programs were excellent

initiatives, which require some enhancements

to be fully effective.

The NMPC assessment

of

the Unit

1 loss of ultimate heat sink event was good.

Generally, the deviation/event report

system functioned as an effective tool to improve plant performance.

However, this system was

not utilized by site personnel to identify and correct a piecursor event to the dropping of the two

new fuel assemblies,

nor to identify the inoperability of the two turbine first stage pressure

sensors,

When the system was used, corrective actions were appropriate and the system was

properly monitored and audited for effectiveness.

Quality Assurance (QA) audits and surveillances were generally good;

The scope and number

of QA surveillances of radwaste activities were exceptional.

However, QA activities in some

cases were not fullyeffective in obtaining performance improvements.

During evaluation of the

loss of ultimate heat sink event, it was determined that NMPC had not been fully effective in

correcting the root causes of instances of failure to follow procedures

and inadequate

work

requests after these types of problems had been repeatedly identified in QA surveillances.

The

root causes ofQA-identified problems were in some cases not effectively corrected or acted upon

by site and corporate management.

With some exceptions as discussed in the Engineering and Technical Support area, a significant

number of licensing actions were effectively processed

by NMPC during this assessment

period.

These effectively processed actions included license amendment requests, exemptions, code relief

requests,

responses

to generic letters and bulletins, multi-plant issues,

and other regulatory

initiatives. Generally, these submittals reflected good safety perspective, were technically sound,

and supported resolution of the requested

actions or safety issues.

However, weaknesses

were

noted in the administrative review of retyped technical specification pages.

Licensee Event Reports (LERs) continued to be well-written and adequately described details of

the subject events.

For one report, however,

several key points were not fully developed.

When this issue was identified, NMPC promptly developed these points'and issued a supplement

to the LER.

29

umm

-

afe

Assessment/

uali

Verifi

i n

In summary,

management

oversight and supervisor involvement in day-to-day activities have

been extensive.

However, the high number of reactor scrams and significant events indicated

that management

had not been

fully effective at addressing

equipment

failures

and

the

longstanding personnel performance problems associated with attention-to-detail and procedural

adherence.

The safety oversight committees continued to perform a thorough and effective

~

review of issues.

The ISEG provided comprehensive

and effective self-assessments

and root

cause evaluations.

Responses

to 10 CFR Part 21 notifications and other industry notifications

'ere prompt, thorough, and proactive.

Although QA audits and surveillances were generally

good, the root causes of QA-identified problems were in some cases not effectively acted upon

by site and corporate management.

Most licensing actions continued to be technically sound,

and supportive of resolution of the requested action or safety issue; however, several exceptions

were noted which required additional interaction.

ID.G.2

III.G.3

Performance Rating:

Category

2

Board Comment:

NMPC should implement a focused effort to monitor and

reduce the number of scrams and significant events.

C

30

IV.

SlTEAC~

IV.ALicensee Activities

ANDEVALUATIONC

During this assessment

period Unit 1 operated at power until July 18, 1991, when increasing

unidentified drywell leakage resulted in an unplanned shutdown.

The cause of the leakage was

identified and repaired, and the unit was returned to power operations.

A number of additional

forced shutdowns occurred as highlighted in Section IV.B. Following a May 1, 1992, reactor

scram

the unit remained

shutdown through the end of this assessment

period due to the

identification of significant cracks in the emergency cooling system condensate

return valves.

Reactor fuel was off-loaded to facilitate weld repairs and-replacement of the valves.

Unit 2 began the SALP period shutdown in an unplanned outage to facilitate repair to a leaking

reactor coolant system pressure boundary flexible hose.

A modification replaced the flexible

hose with piping that contained an expansion loop and the unit returned to power operations on

April 12, 1991. A number of forced shutdowns occurred as highlighted in Section IV.B. The

unit was shutdown on March 4, 1992, to commence

the second

refuel outage.

The unit

remained shutdown through the end of this assessment

period.

IV.B Unplanned Shutdowns, Plant Trips and Forced Outages

IV.B.1

nit 1

Date

1.

7/18/91

Power Level

3%

Root Cause

Unknown

Functional, Area

N/A

Increasing unidentified drywell leakage resulted in the initiation of a plant shutdown.

At 3%

reactor power a high neutron flux reactor scram occurred due to either a pressure surge caused

by isolation of an auxiliary steam load or due to a spurious spike of the intermediate range

neutron monitor (LER 91-08).

The unidentified drywell leakage initiated from a recirculation

pump motor cooler mechanical joint, main steam isolation valve packing, and the packing of a

recirculation loop isolation valve.

2.

9/26/91

97%

Equipment Failure

Maintenance

A reactor scram resulted from a turbine trip/generator load reject caused by a failed generator

phase differential current transformer (CT) (LER 91-12).

The failed CT was replaced.

Date

3.

12/4/91

Power Level

96.5%

31

Root Cause

Equipment Failure

Functional Area

Maintenance

A low water level reactor scram occurred following the failure of a solder connection in the

feedwater level control total steam flow meter.

The steam flow signal went to zero, which

generated

a large flow/error signal and closure of the feedwater control valves.

The total steam

flow meter was replaced with a new meter which had a shunt across

the input.and output

terminals to prevent reoccurrence of a zero output signal (LER 91-14).

4.

2/16/92

94%

Equipment Failure

Maintenance

A reactor

scram

resulted

from a turbine

stop valve

10%

closure

signal

during weekly

surveillance testing of turbine stop valves.

A sticking pivot point and worn pin connection on

turbine stop valve 13 initiated the event (LER 92-04).

5.

4/18/92

98%

Equipment Malfunction

Maintenance

A high neutron flux reactor scram occurred due to failure of the mechanical pressure regulator

in the turbine control system (LER 92-08).

6.

5/1/92

97%

Equipment Malfunction

Maintenance

A high neutron flux reactor scram occurred due to failure of the electronic pressure regulator

in the turbine control system (LER 92-03).

IV.B.2

U~ni 2

Date

1.

8/13/91

Power Level

100%

Root Cause

Random Failure

Functional Area

N/A

An internal fault in the "B" phase main transformer caused

a turbine trip/generator load reject

resulting in a reactor scram,

The transformer fault created an electrical disturbance throughout

the normal electrical system, resulting in the loss offive non-safety related uninterruptible power

supplies.

As

a result,

the control room lost annunciation

and

most

balance of plant

instrumentation.

A Site Area Emergency was declared.

(LER 91-17)

2.

12/7/91

N/A

90%

Equipment Failure

During performance of the weekly turbine valve cycling surveillance,

the turbine stop and

combined intermediate valves inadvertently closed resulting in a reactor scram.

The most

probable cause of the event was a malfunctioning relay in the speed select circuit of the turbine

electro-hydraulic control system.

(LER 91-22)

lp

32

Date

Power Level

3.

12/12/91

55%

Root Cause

Personnel Error

Functional Area

Operations

During the start of a second feedwater pump to support raising plant power, a condensate

and

feedwater system transient occurred resulting in the loss of both feedwater pumps.

The loss of

all feedwater to the vessel resulted in a reactor scram on low vessel level.

The cause of this

event was attributed to poor work practices

and mis-communications

between operating shift

personnel.

Specifically, an inadequate

number of condensate

and condensate

booster pumps

were running to support operation of a second feedwater pump.

(LER 92-23)

4.

1/25/92

65%

Equipment Failure

Maintenance

A manual shutdown

was initiated due to excessive

leakage

from degraded

pump seals

on

feedwater pumps B and C.

IV.C NRC Inspection and Review Activities

Three NRC resident inspectors were assigned

to Nine MilePoint during the assessment

period.

NRC team inspections were conducted in the following areas:

Safety

valve

audit

performed

at

Unit 2

during

the

week

of

August 5, 1991.

Augmented inspection coverage of the Unit 2 site area emergency which occurred

on

August

13,

1991.

The augmented

inspection

team was

supplanted

by an incident

inspection team.

Restart

readiness

inspection

at Unit 2 conducted

the week of September

3,

1991

concerning restart following the site area emergency.

Electrical distribution system functional inspection conducted at Unit 1 from October 9

through 25, 1991.

. Augmented inspection coverage from February 22 through 28, 1992, at Unit 1 following

the loss of the ultimate heat sink event.

Reactive inspection conducted intermittently between March 28 and April 18, 1992, at

Unit 1 to assess

the effectiveness of NMPC short term corrective actions

taken in

response

to the loss of the ultimate heat sink event.

Augmented inspection coverage at Units

1 and 2 between March 24 and 27, to inspect

the Unit 2 loss of control room annunciators

and subsequent

loss of all off-site power.

4T

33

IV.DEscalated Enforcement Action

An enforcement conference was held on October 17, 1991 to discuss the ability of the Unit 2

'tandby gas treatment system to perform its containment drawdown function with a secondary

containment unit cooler inoperable.

A Severity Level IV violation was issued for loss of

configuration control on the unit cooler service water values during the markup process.

An enforcement conference

was held on February 6, 1992 in NRC Region I to discuss

the

dropping of two new fuel bundles at Unit 2.

A Severity Level IV violation was issued for

failure to follow procedural instructions.

'Two Severity Level IIIviolations and civilpenalties were issued on May 21, 1992 at Unit.1 near

the end of the period.

One violation concerned the failure of maintenance workers to implement

written procedures which resulted in the loss of the ultimate heat sink event. A $75,000.00 civil

penalty was issued.

The second violation concerned

operating

the unit with less than the

minimum number of operable instrument channels ofprotective instrumentation, and inadequate

corrective actions.

A $ 125,000.00 civilpenalty was issued.

IV.E SALP Evaluation Criteria

Licensee performance is assessed

in selected functional areas, depending on whether the facility

is in a construction or operational phase.

Functional areas normally represent

areas significant

to nuclear safety and the environment.

Some functional areas may not be assessed

because of

little or no licensee activities or lack of meaningful observations.

Special areas may be added

to highlight significant observations.

The following evaluation criteria were used,

as applicable, to assess

each functional area:

1 ~

Assurance of quality, including management involvement and control;

2.

Approach to the identification and resolution of technical issues form a safety standpoint;

3.

Enforcement history;

4.

Operational events (including response to, analysis of, reporting of, and corrective action

for);

5.

Staffing (including management);

6.

Training and qualification effectiveness.

Based upon the SALP Board assessment,

each functional area evaluated is classified into one of

three performance categories.. The definitions of these performance categories

are:

1

34

~C:

Ll

g <<'l l

l

yy

safeguards

resulted in a superior level of performance.

NRC will consider reduced levels of

inspection effort..

ogdgddgg: L'

<<

'

yly

yg

d

activities resulted in a good level ofperformance.

NRC willconsider maintaining normal levels

of inspection effort.

ggttggry 3: Licensee management attention to and involvement in nuclear safety or safeguards

activities

resulted in an acceptable

level of performance;

however;

because of the NRC's

concern that a decrease in performance may approach or reach an unacceptable level, NRC will

consider increased

levels of inspection effort.

The SALP report may include an appraisal of the performance trend in a functional area for use

as a predictive indicator.

Licensee performance during the assessment

period is examined to

determine whether a trend exists.

Normally, this performance trend would only be used ifboth

a definite trend is discernable

and continuation of the trend would result in a change

in

performance rating.

The trend, ifused, is defined as:

~Im rovin:

Licensee

performance

was determined

to be improving during the assessment

period.

D~ectinin: Licensee performance was determined to be declining during the assessment

period

and the licensee had not taken meaningful steps to address

this pattern.

HJ

I

IE

ML17056B968

Text

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