ML17250A931

SALP Rept 50-244/87-99 for Dec 1987 - May 1989.Decline in Performance in Security Area Noted

ML17250A931
Person / Time
Site:	Ginna
Issue date:	08/10/1989
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17250A932	List: IR 05000244/1987099 ML17250A931
References
50-244-87-99, NUDOCS 8908230040
Download: ML17250A931 (64)

See also: IR 05000244/1987099

Text

ENCLOSURE

SALP

BOARD REPORT

U. S.

NUCLEAR REGULATORY COMMISSION

REGION I

SYSTEMATIC ASSESSMENT

OF LICENSEE

PERFORMANCE

SALP

BOARD REPORT 50-244/87"99

ROCHESTER

GAS AND ELECTRIC CORPORATION

R.

E.

GINNA NUCLEAR POWER

PLANT

50-244

ASSESSMENT

PERIOD:

December

1,

1987 -

May 31,

1989

BOARD MEETING:

July 11,

1989

3003230040

35'03/0

PDR

ADOCK 05000244

O

PDC

TABLE OF CONTENTS

PAGE

I.

INTRODUCTION...............

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II.

SUMMARY OF RESULTS...................................................

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II.A

Overviewt

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II.B

Facility Performance Analysis Summary.

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III. PERFORMANCE ANALYSIS.................................................

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III.A

III.B

III.C

III.D

IIIi E

III.F

III.G

Plant Operations..............

Radiological Controls.........

Maintenance/Surveillance.....

Emergency Preparedness........

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Engineering/Technical

Support.

Safety Assessment/guality

Veri

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SUPPORTING

DATA AND SUMMARIES

A.1

Licensee Activities.........

A.2

Direct Inspection

and Review Activities............

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C.

Unplanned

Shutdowns,

Plant Trips and Forced

Outages

D.

Enforcement Activity...............................

E.

Inspection

Hour Summary.....

F.

Licensee

Event Report Casual Analysis..............

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o SD/S 8

TABLES

Table

1 - Enforcement/Severity

Level

Table

2 - Inspection

Hour Summary

Table

3 - Listing of LERs by Functional

Area

I.

INTRODUCTION

The Systematic

Assessment

of Licensee

Performance

(SALP) is an integrated

NRC

staff effort to collect the available observations

and data

on

a periodic basis

and to evaluate

licensee

performance

based

upon this information.

The program

is supplemental

to normal regulatory processes

used to ensure

compliance with

NRC rules and regulations.

It is intended to be sufficiently diagnostic to

provide a rational basis for allocating

NRC resources

and to provide meaningful

feedback to the licensee's

management

regarding the NRC's assessment

of their

facility's performance

in each functional area.

A NRC SALP Board,

composed of the staff members listed below,

met on July 15,

1989 to review the observations

and data

on performance,

and to assess

the lic-

ensee

performance

in accordance

with Chapter

NRC-0516,

"Systematic

Assessment

of Licensee

Performance".

The guidance

and evaluation criteria are

summarized

in Section III of this report.

The Board's findings and recommendations

were

forwarded to the

NRC Regional Administrator for approval

and issuance.

This report is the NRC's assessment

of the licensee's

safety performance at

R.

E. Ginna Nuclear Power Plant for the period December

1,

1987 through

May 31,

1989.

The

SALP Board for R.

E. Ginna Nuclear

Power Plant was composed of:

Chairman:

W. Kane, Director, Division of Reactor Projects

(DRP)

S. Collins, Deputy Director,

DRP (part-time)

Members:

B. Boger, Acting Director, Division of Reactor Safety

(ORS)

J. Joyner,

Division Project Manager, Division of Radiation Safety

and Safe-

guards

(DRSS)

R.

Wessman,

Director, Project Directorate I-3,

NRR

A. Johnson.

Project Manager,

PD I-3,

NRR

E. Wenzinger,

Chief, Projects

Branch

No 1,

ORP

C. Cowgill, Chief, Reactor Projects

Section

lA, DRP

C. Marschall,

Senior

Resident

Inspector,

Ginna

Other Attendees

N. Perry,

Resident

Inspector,

Ginna

C. Amato,

Emergency

Preparedness

Specialist,

ORSS

T. Dragoun,

Senior Radiation Specialist,

DRSS

O.

Haverkamp,

Chief, Reactor Projects Section

3B,

ORP

J. Johnson,

Chief, Projects

Branch

No. 3,

DRP

R. Keimig, Chief, Safeguards

Section,

DRSS

J. Prell, Senior Operations

Examiner,

DRS

E. Sylvester,

Senior

Reactor

Engineer,

ORSS

2

II.

SUMMARY OF RESULTS

II.A Overview

The licensee

operated

the Ginna Station safely throughout the period.

Senior

corporate

management's

commitment to safety is evident

and

a number of staffing

changes

have

been

made both at the corporate office and plant to strengthen

the

organization.

Overall performance,

however,

has not yet reflected the results

of these

changes.

A significant strength continues to be the technically competent

and knowledge-

able plant and corporate staff.

Personnel

exhibited professionalism

and pride

in their performance,

and station

management

strongly relies

on this asset.

However, this reliance

has resulted in weak administrative controls

and plant

procedures.

Additionally, corporate

and site

management

have not effectively

used the guality Assurance

and guality Control organization

as

a management

tool to improve station performance.

Operator performance

and professionalism

continue to be

a strength during nor"

mal plant operations

and in emergency situations.

The operator. degree

program

is a positi

e initiative which has

been well received

by the operations staff

and'upported

by management.

Constructive

and effective daily staff meetings

have improved communication

between departments.

There is a lack of observation of staff activities by department

and first line

supervision

as evidenced

by weak adherence

to procedures

and continuing house-

keeping deficiencies.

Additionally, a lack of aggressive

response

to NRC,

INPO,

and self-audit findings was noted.

The licensee

has

made

several at-

tempts to improve the effectiveness

of the Quality Assurance

organization.

However, performance

during this period

has not shown

improvement

and there

have

been

several

areas

where

NRC findings were

made that had not been identi-

fied by the licensee's

quality organization.

Performance

in the Security area

was rated Category

1 during the last SALP.

Performance

in this area

was assessed

as Category

2 during this period due

a

lack of management

oversight

and support.

Specifically noted were inattention

to the continuing

need for security system

maintenance

and failure to maintain

a current

and effective Security Plan.

A consistent

strength in this area con-

tinues to be competent

and well trained security force.

Force

members continue

to be professional

and knowledgeable

and morale is high.

In summary,

the licensee

senior

management

is committed to excellence

in per-

formance

and improving programs to maintain

safe

and efficient operation of the

facility.

Use of quality organizations

remains

weak and;.the reliance

on the

technical

competence

of the staff has hindered

improvement in overall perform-

ance.

Improving supervisory oversight of activities, strengthening

admini"

strative controls at the station,

and improving the systems

used

by management

for identifying and correcting deficiencies at the station are necessary

to

attain

a significant improvement in performance.

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II.B Facilit

Performance

Anal sis

Summar

This SALP report incorporates

the recent

NRC redefinition of the assessment

functional areas.

Changes

include combining the previously separate

Mainten-

ance

and Surveillance

areas

and addition of the Safety Assessment/guality

Veri-

fication area.

The Safety Assessment/guality

Verification section is largely

a

synopsis of observations

in other functional areas.:

Additionally, the Fire

Protection,

Licensing, Refueling/Outage,

Training and Assurance

of guality

areas

have

been

incorporated into the remaining functional areas

as appro-

priate.

Functional

Area

Rating

Last

Period"

Rating

This

Period""

Trend

A.

Plant Operations

B.

Radiological Controls

C.

Maintenance/Surveillance""*

2/1

D.

Emergency

Preparedness

E.

Security

F.

Engineering/Technical

Support

G.

Safety Assessment/equality

Verification

H.

Licensing Activities

I.

Training 5 qualification Effectiveness

J.

Assurance of guality

June

1,

1986 to November 30,

1987

• "

December

1,

1987 to May 31,

1989

""* Previously addressed

as separate

areas.

Not addressed

as

a separate

area.

NOTE: It is important to note that

a major revision of the

SALP Manual Chapter

has

been

made which combined

some

areas

and

made

changes

to the attributes

in

the functional areas.

Therefore,

a direct comparison of the functional area

grades

cannot

be made

between

the previous

SALP and the current

one.

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III. PERFORMANCE ANALYSIS

III.A

Plant 0 erations

(2517 Hours,

52K)

III.A.I

A~nal

sos

The previous

SALP report rated this area

Category

2 with a need to assess

the

plant operations

and corporate

engineering

interface.

Strengths

noted were the

strong support of operator training improvement programs,

good operator

exam

results,

overall operator

performance

improvement,

and high plant availability.

Weaknesses

noted were the interface between plant operations

and corporate

engineering

and the lack of aggressive

management

attention toward housekeep-

ing.

This evaluation is based

on routine resident

and specialist

inspections

and

an

Integrated

Performance

Assessment

Team (IPAT) inspection.

Management oversight

and control of operations

was inconsistent

during this

SALP period.

Management

support of the college degree

program

and Morning Pri-

ority Action Required

(MOPAR) meetings

was strong;

however, control of house-

keeping

remained

a problem.

Well-qualified operators

exhibited consistent,

good performance,

but an ineffective independent verification program mani-

fested itself when valves were found out of position.

Weaknesses

were iden-

tified with training in the fire protection program.

The previously noted weak interface

between plant operations

and corporate

engineering

was addressed

through frequent attendance

at daily MOPAR meetings

by corporate

engineers.

Additionally, operation

and engineering

personnel

are

working together closely

on

a

P&ID upgrade

process.

The previously noted weak-

nesses

were not observed

during this assessment

period with the exception of

problems relating to modifications performed in the

1989 r'efueling outage which

is discussed

in the Engineering/Technical

Support analysis.

Plant management

continued to effectively use

MOPAR daily meetings,

where prob-

lems

and daily activities were discussed.

Implementation of a

Human Perform-

ance Evaluation

System

(HPES) process

by operations

management

was

a positive

initiative to improve root cause identification for human performance errors.

Another positive initiative was implementation of a six shift, forward rotating

schedule after the

1988 annual refueling outage.

Input on the

new rotation

schedule

was obtained

from operators prior to implementation;

the

new schedule

was well accepted.

The licensee

has

an effective training program for preparing operators for writ-

ten and operating examinations.

Ten of the eleven candidates

were issued lic-

enses.

Candidates

performed well on sections of the written examination cover-

ing fundamental

nuclear theory,

thermodynamics,

and components.

All candidates

exhibited weakness

during. the operations

phase of the examination;

they did not

correctly identify the proper prioritization and

use of Emergency Operating

Procedures

(EOPs).

Examples of individual weaknesses

included

improper priori-

tization and

use of "Reactor Trip on Safety Injection" and "Loss of All AC

5

Power"

EOPs.

Candidates

were also unable to properly prioritize the Functional

Restoration

Procedures.

However, inplant use of the

EOPs

was performed

smoothly

and effectively during a loss of normal offshift power,

and following the June

I, 1989 plant trip.

Disposition of EOP change

requests

was

an identified weakness;

approximately

400 outstanding

proposed

changes

were not resolved or dispositioned

in a timely

manner.

In response,

the licensee

developed

and assigned

a task force to as-

sist the

EOP Committee in resolving the backlog of outstanding

EOP change re-

quests.

The validation process for the recently enhanced

EOPs

was completed;

however,

implementation will not occur until July 1989, after the annual re-

fueling outage,

due to required training of operators.

.An inspection of the

licensed operators training records indicated records

were maintained

as de-

scribed in their procedures

and specific tasks

such

as complicated surveillance

tests,

major pl'ant systems tests,

refueling operations,

and abnormal

and emer"

gency operations

were addressed

with the personnel.

Operator'raining for modifications

and other plant conditions was,

in general,

effective and well-documented.

Training in preparation for the

1989 annual

.refueling outage

was comprehensive,

especially with respect to operations at

low loop levels.

However, while starting the plant

up after the

1988 refueling

outage,

a lack of training on

an unusually positive moderator temperature

co-

efficient resulted

in a plant trip.

Additionally, the plant tripped from 53

percent-',power

on June

1, 1989,

because

of an incomplete understanding

of the

ATWS Mitigation System Actuation Circuitry (AMSAC), a

1989 refueling outage

modification.

Problems

in communicating modification-related

information from

engineering to operations

personnel

are further discussed

in the Engineering/

Technical

Support Section.

Management

support of the college degree

program continued to be

a strength,

with eight licensed operators

earning degrees

during this assessment

period.

Presently

29 plant personnel

are enrolled in the program.

Control

room operators effectively dealt with four plant trips and'everal

plant transients.

Operator actions

were timely, appropriate

and procedures

were

used effectively.

In particular, operator actions dealing with two steam

generator

pressure

transmitter

sensing

lines freezing,

were conservative

and in

the interest of safety.

Weakness

were identified in the licensee's

program for verifying and tracking

proper implementation of corn'mitments,

and administrative controls for handling

and tracking valve positions.

Operators

were manipulating valves without pro-

per tagging

and adequate

independent verification of alignments

was not rou-

tinely performed

and

a commitment, addressing

verification of pr'oper system

alignment per

NUREG 0737,

was not properly interpreted

and implemented.

Control of housekeeping,

identified as

a weakness

in the prior SALP report,

continued to be

a weakness.

Plant management

was deficient in touring plant

spaces

including safety-related

areas;

plant conditions reflected the weak man-

agement

involvement and low management

standards

for housekeeping.

During both

6

refueling outages,

housekeeping

was cyclic in the Containment

and Auxiliary

Buildings.

Though improved since the Auxiliary Building was

opened to access

in street clothes in November

1988, control of extraneous

materials

remains

a

problem.

To address this problem management

is constructing

a Contaminated

Storage Building addition to the Auxiliary Building.

New programs

were

implemented to enhance plant operations.

A PAID upgrade pro-

cess

was initiated requiring

a coordinated effort between

engineering

and opera-

tions personnel.

The initial phases

are complete.

A labeling program, to at-

tach permanent

labels to all plant components

was developed.

Operations

man-

agement

receives

monthly status

reports of labeling progress.

Although the.

labeling program is

a positive initiative, lack of label verification is consi-

dered

a weakness

in the labeling program.

A partially implemented computerized

tagging hold system is in the main control

room and is expected to be fully

implemented late in 1989.

At the close of the

SALP period,

a process

was for-

malized for operations

personnel

to implement

an internal self-check of opera-

tions activities.

While these

programs

are considered

positive initiatives

their effectiveness

has not been

assessed.

Two weaknesses

were identified in the fire protection

program indicating

a de-

ficiency in management

support.

Fire barriers

were not installed to design

specification criteria and installation was not verified; this is addressed

in

the Engineering

and Technical

Support section.

Preplanned

quarterly fire

drills Here not conducted

during three quarters

in 1988; 'credit was documented

for responding to false alarms.

The fire protection

program does

not account

for a staff with varying levels of fire training and expertise.

Individuals

with no previous fire fighting experience

were expected

to fight fires after

receiving only four hours of hands

on practice; this is considered

very mini-

mal.

However, fire brigade

members exhibited

a good knowledge of fire fighting

system operations.

Management

support of the college degree

program

and effective use of MOPAR

meetings continued to be licensee

strengths.

Operator training, license

exam

results,

and overall operator

performance

were also noted

as licensee

strengths'oor

housekeeping

persisted

and management

tours,

which could have identified

the problem,

were few.

Control of system alignments

and independent verifi-

cation program weaknesses

were identified as problems.

The fire protection

program also evidenced

some training weaknesses.

III.A.2

Performance

Ratin

Category 2.

III.A.3

Recommendations

Licensee:

Assess

the adequacy of housekeeping

standards

expected

by management,

and the effectiveness

of the communication of those

standards

to the

staff.

NRC:

None.

7

Radiolo ical Controls (229 Hours,

5X)

III.B.I

~Anal sls

The Radiological Controls Program

was rated category

2 last assessment

period.

Although the program was judged to be effective, overall weaknesses

included

the ineffective policies

and procedures

to control activities,

and the lack of

challenging

exposure

goals in the

ALARA Program.

III.8

During the current assessment

period, three radiation protection inspections

(two outage

reviews,

one review of ALARA and

open items) were conducted.

The

resident inspectors

also routinely reviewed the radiation protection area.

One

inspection

was conducted of the radwaste

and transportation

program.

The area

of chemistry

and effluents was reviewed

as part of the

IPAT team inspection.

The licensee's

Radiological Protection

(RP) organization

was stable

and well-

qualified.

The level of staffing was adequate

to support implementation of the

RP program during routine operations.

Weaknesses

were noted,

however, with the

level of

RP management

oversight of field activities during the

1988 and

1989

refueling outages.

Tours of the work areas

by

RP supervision

and management

were infrequent.

The licensee's

contractor technician workforce, brought in to

support the

1988 outage,

exhibited weakness

in technical

knowledge

and perform-

ance.

While the licensee's

training programs partially addressed

the technical

knowled)e area, it could not make

up for weaknesses

in technician experience.

These

weaknesses

cont> ibuted to observed deficiencies

in procedural

compliance,

High Radiation Area (HRA) control,

and radiological posting

and labeling during

the

1988 outage.

For the extended

1989 outage the licensee

applied

more re-

strictive qualification criteria for hiring technicians

and implemented

a pre-

test screening

program to more effectively train technicians.

As

a result,

contractor technician

performance

improved.

However,

management

oversight of

field activities remained

weak.

Audits of the

RP area

are performed

by the

gA group, with technical

assistance

from the corporate

HP staff and consultants.

Scope of the audits

was adequate.

However,

response

of the

RP group to the gA audit findings, as well as

NRC in"

spection findings,

was often delayed or inappropriate.

NRC concerns with in-

strument'ation

control charts

had previously been identified in repeated lic-

ensee audits,

but not corrected.

Also, NRC-identified weaknesses'ith

job-

related

survey procedures

remained

unresolved

since the previous )ALP.

And the

RP group revised the wrong procedure

in an attempt to correct

NRC identified

deficiencies

regarding calculation

and recordkeeping

of extremity doses.

Five procedural

violations were noted in the

RP area during the assessment

period.

These

included violations of the Special

Work Permit

(SWP)

'and

HRA

controls,

and routine survey

and counting instrument

gC procedures.

This ap-

pears

due,

in part, to

a failure by

RP management

to require procedural

com-

pliance.

Weaknesses

were also noted regarding

procedure

adequacy;

specific-

ally, the lack of procedural

guidance relating to the performance

and documen-

tation of job-related

surveys.

8

Insufficient management

oversight

and weakness

in procedural

compliance re-

sulted in repeated

instances

of improper posting

and labeling of radiological

areas

during the

1988 outage.

Specific examples

included the inconsistent

posting of the containment

HRA access,

and the obscuring of significant 'radio-

logical signs

(HRA, Airborne area) with additional postings or tape.

Signi-

ficant improvements

in postings

were noted during the operational

period after

the

1988 outage

and-during the

1989 outage.

The improvements

were

a direct

,

result of the licensee's

response

to

NRC concerns.

The licensee's

training program for contractor

HP technicians

and radiation

workers was satisfactorily implemented.

Lesson

plans were noted to be gene-

rally adequate.

One strength

was noted in that all levels of radiation worker

training (i.e., initial and requalification) include

a practical factor seg-

ment.

As noted above,

for the

1989 outage the licensee initiated pretesting

as

a method to evaluate

and screen contractor

HP technicians

in order to better

focus training.

Late in the period, after significant decontamination

and survey efforts, the

licensee

released

the major ity of the Auxiliary and Intermediate Buildings from

contaminated

area controls.

This substantial

licensee effort, which came about

after

NRC and

INPO had identified the problem and strongly urged corrective

action, allowed easier

access

and better oversight of work activities while

reducing hazards to workers.

Licensee

performance

in the ALARA area

showed

improvement since the last as-

sessment.

The licensee's

1988 exposure

goal of 300 man-rem

was noted to be

more aggressive

than the

1987 goal of 375 man-rem.

Licensee

actual

exposure

for 1988 equaled

approximately

270 man-rem,

the lowest recorded

annual

exposure

for a full operational

year at Ginna.

Although the licensee exhibited excel-

lent planning

and control of repetitive work, such

as

steam generator

inspec-

tion, goal setting

and planning for one-time-jobs,

such

as plant modifications,

were routinely found to be weak.

Oqe reason for the poor planning during the

1989 outage

was that engineering

packages

for plant design

changes

arrived

on

site just before the start of the outage,

allowing little time to mock-up the

job and train workers.

In addition, illness caused

the loss of the highly ex-

perienced

ALARA Program Coordinator

who had

been

responsible for program im-

plementation.

The licensee'continued

to maintain

an effective transportation

and solid rad-

waste

programs.

Improvements

were

made in the Quality Control

(QC) procedures

for resin dewatering

and in a proceduralized

retraining program for radwas'te

workers.

These

were areas identified during the previous

assessment

period

as

being minor weaknesses.

Ouring the

IPAT inspection,

the

NRC identified

a persistent

weakness

regarding

QC surveillance of chemistry activities.

As part of the corrective action, the

licensee

recently created

the position of QC Specialist

in order to strengthen

the laboratory

QC/QA program.

A noted licensee

strength

was the control of

9

steam generator

chemistry.

The program established

by the licensee

includes,

items

such

as the

Steam Generator Reliability Committee,

the installation of a

catalytic oxygen removal

system,

and

a secondary

plant data trending

system.

The licensee'

Radiological Controls programs

were adequately

implemented dur-

ing the current period.

Weaknesses

were noted in management

oversight of field

activities,

ALARA planning during the

1989 outage,

resolution of identified

problems,

and procedural

compliance.

The licensee's

use of pretesting to evalu-

ate

and screen

contractor

HP technicians

was

a good initiative.

Training of

radiation wor kers, particularly by use of a practical factors

segment,

was

a

strength.

Control of steam generator

chemistry was another

noted strength,

as

was implementation of the

ALARA program during 1988.

III.B.2

Performance

Ratin

Category 2.

III.B.3

Recommendations:

Licensee:

None.

NRC:

Conduct

a special

inspection of the licensee's

corrective action programs.

III.C

Maintenance/Surveillance

(802 Hours,

17%)

III.C.I

~Anal

sos

Maintenance

and Surveillance

were evaluated

in separate

sections of previous

SALP reports.

This section

has

been created

to consolidate

the two sections

and to assess

all activities associated

with diagnostic,

predictive, preventive

or corrective maintenance

of plant structures,

systems

and components.

It

evaluates

procurement,

control

and storage of components;

installation of plant

modifications;

and maintenance

of the plant physical condition.

It also in-

-'cludes surveillance testing

as well as Inservice Inspection

and Testing acti-

vities.

In the previous

SALP, maintenance

was rated category 2, improving; surveillance

was rated category

1.

Maintenance

weaknesses

included two failures to control

maintenance activities,

a need for continued aggressive

implementation of main-

tenance training, insufficient operations

involvement in outage

and maintenance

planning,

and further progress

needed

in programs for maintenance

upgrade.

Positive steps

taken to upgrade

the maintenance

program

and improve its effec-

tiveness,

and aggressive

management

atte'ntion to maintenance

were noted strengths.

Surveillance

weaknesses

identified were personnel

errors resulting in a missed

test

and poor test control; supervisory level review and data trending,

strong

management

involvement,

and the Inservice Inspection

program were strengths.

This evaluation is based

on routine resident

and specialist .inspections,

a re-

start

team inspection,

a'special

team inspection for Inservice Testing,

and

an

Integrated

Performance

Assessment

Team ( IPAT) inspection.

The

1988 (34 days)

and

1989 (74 days) refueling outages

were completed during the current assess-

ment period.

10

Maintenance

management

was strengthened

during the current

SALP period through

reorganization

under the Superintendent,

Ginna Support Services,

and

a newly

appointed

Maintenance

Manager.

The maintenance

Superintendent

and Manager are

formerly SRO licensed,

have extensive

experience,

and

have

a stated

goal. of

"achieving the highest

long term equipment reliability and unit availability

consistent with achieving

a low forced outage rate, while not compromising nuc-

lear safety,

and maintaining radiation exposures

As Low As Reasonably Achiev-

able."

Overall, control of outage related

maintenance

and surveillance activi-

ties

was

a licensee

strength

although failure to identify defects during eddy

current testing in the

1988 refueling outage resulted in a forced outage to

plug additional tubes.

Few difficulties were attributed to maintenance

or sur-

veillance activities during restart after the

1989 refueling outage.

Observa-

tions of maintenance

and surveillance activities indicated personnel

were

thoroughly qualified and technically competent.

In addition, staffing levels,

considered

adequate

in the previous

SALP, have increased

during the current

assessment

period.

Two trips, two unplanned

shutdowns

and one generator trip attributed to

maintenance activities occurred during this

SALP period.

A trip on low steam

generator

level with steam flow/feed flow mismatch

was caused

by a blown fuse.

The licensee

does

not have

a formal program to address

component

ag'.'ng,

and did

not investigate the possibility of an age-related

failure until prompted

by the

NRC.

An unplanned

shutdown also occurred

when

a bushing failed in the main

substation.

Formal preventive maintenance

in the substation

could have

identified failure of the bushing oil level indicator.

The main generator

tripped because

of the failure to properly install the sliding links following

the

1989 outage.

Licensee

weaknesses

in programmatic control of preventive

maintenance

may have caused

both of unplanned

outages

and the generator trip.

Management reliance

on technical

competence

and pride in performance within

maintenance

and surveillance organizations

contributed to lack of cooperation

at times with the Quality Control

and Quality Assurance

departments.

An ex-

ample is the problem identified during tensioning of the 'B'team Generator

manways,

when lack of management

support for activities of the site

QC organi-

zation resulted

in a delayed reactor restart.

The reluctance

to accept

and

integrate findings by Quality Control personnel

was

a problem identified in the

previous

SALP and has not yet been adequately

addressed.

Reliance

on highly motivated

and technically capable

personnel

also resulted

in

weak administrative control over safety-related activities.

In many areas

procedures

and controls were not specific and required extensive

knowledge

and

experience

to be properly implemented.

Examples of these. problems include:

surveillance

procedures,

previously considered well-written, needed

change;

maintenance

procedures

required extensive rewrite,

and multiple instances

of

failure to adhere to procedures

were observed.

Corporate

and senior station

management

acknowledged

the problem.

However,

some middle level

and lower

level managers

and workers did not acknowledge

the importance of strong

administrative controls of activities.

The maintenance

backlog

was small;

however,

a manual tracking system,

used to manage

the backlog,

was not always

11

current,

and did not provide useful information to managers.

The g-list was

inadequate,

as identified by the

NRC; licensee

long. term response

was appro-

priate; however,

interim measures

to provide

a means of determining

g parts

was not considered until prompted

by the

NRC.

Inadequate

reviews resulted

in

several

safety related

valves being omitted from the IST program,

inadequate

testing of the main steam line check valves,

and escalated

enforcement.

Physics testing

performed during cycle

18 start-up

was closely coordi nated with

the reactor engineer,

operations,

testing,

I&C and Westinghouse

test personnel.

Direction and control of rod drop measurements,

initial criticality, all rods

out boron concentration

measurement,

moderator

temperature coefficient measure-

ment and control rod worth testing,

by the assigned

reactor engineer

was

a

noted licensee

strength.

Licensee action in response

to identified weaknesses

was generally timely and

thorough.

In response

to procedural

adherence

failures, instructions providing

clarification were issued

and training was conducted for plant personnel;

a

comprehensive

procedures

upgrade

program, requiring several

years for comple-

tion, was undertaken

to rewrite calibration

and maintenance

procedures;

compu-

terized systems to track the maintenance

backlog are under development;

an in-

terim instruction

was written to supplement

the g-list unt-:1 a rewrite is com-

pleted;

a schedule

for corrective action in response

to Inservice Testing (IST)

program inadequacies

was formulated

and reported to the

NRC within five days of

the inspection exit meeting.

In some cases,

identification of technical

issues

was weak in the area of sur-

veillance.

Examples:

inadequate

engineering

support for the IST program re-

sulted in check valves test procedures

which were not consistent with require-

ments of ASME Section XI; inadequate

plant reviews resulted in several

safety

related valves being omitted from the

IST program;

and inadequate

testing

was

performed

on main

steam line check valves.

However, surveillance test proce-

dures developed

to implement the IST program were generally well written and

easy to follow.

During the IST program test personnel

were knowledgeable

and experienced

as

demonstrated

during the turbine-driven Auxiliary Feedwater

pump test.

Opera-

tional performance of the staff was

a licensee

strength.

Licensee

implementa-

tion of the Inservice Inspection (ISI) program,

including twenty-year ISI acti-

vities, conducted during the

1989 refueling,

Qas thorough

and well-controlled.

Overall the licensee

has effectively conducted

Maintenance

and Surveillance

activities at the plant.

Personnel

additions

and

changes.

have

been

made to

strengthen

the organization.

The maintenance

staff is experienced

and com-

petent.

Maintenance

backlog is low and there are

few missed surveillances.

Technical

competence

of maintenance

and surveillance

personnel

was

a strength

tempered

by weakness

in administrative control of safety-related activities.

The identified procedural

weaknesses

are being addressed

through

a general

up-

grade of procedures.

Lack of supervisory observation

of surveillance

and main-

tenance activities was

a weakness,

while aggressive

management

and established

goals

were

a strength.

Although valves omitted from the IST program resulted

in escalated

enforcement,

IST surveillance

implementation

was

a licensee

12

strength.

The ISI program

was thorough,

and reactor

physics testing

was well-

controlled and coordinated.

Staffing was adequate,

training effective,

and

efforts to continue training program upgrades

were

a strength..

Licensee re-

sponse

to

NRC concerns

was, in general,

timely and appropriate.

III.C.2

Performance

Ratin

Category 2.

III.C.3

Recommendations:

None.

III.D

Emer enc

Pre aredness

(103 Hours,

2X)

III.D.I

~Anal sls

During the previous

assessment

period, licensee

performance

in this area

was

rated category

1.

This rating was based

upon evaluation of performance

made

during

a full and

a partial participation exercise,

and the results. of two

routine safety inspections.

No exercise

weaknesses

were identified.

The lic-

ensee

demonstrated

good emergency

response

capability.

Results of the routine

inspections

indicated the licensee

was taking steps to improve emergency re-

sponse capability.

The emergency

preparedness

staff consisted

of one person

supported

by other plant and corporate

personnel.

During the current assessment

period,

a partial participation exercise

was ob-

served

and one routine safety inspection

was conducted.

Personnel

of the

New

York State

Emergency

Management Office, Monroe and

Wayne Counties participated

in the exercise.

Operators

recognized

symptoms

and events,

and correctly

selected

Abnormal

and

Emergency Operating

Procedures.

Accident classification

was correct, offsite notifications were

made within the prescribed

time and

State

and local government participants

were involved in the development of

Protective Action Recommendations.

A Notice of Violation was issued

in the

EP area during the assessment.

The

licensee did not include in the

EP (Emergency

Preparedness)

Program Audit an

evaluation of the adequacy

of State

and local government interface for a number

of years

and did not make these results available to the State

and Counties for

several

years

when this audit was performed.

A review of EP implementing pro-

cedures

revealed that field procedures

that would be

used for collection of

iodine'amples

during off site releases

specifies

inordinately long collection

times.

While this appears

to be conservative, it fails to recognize that ex-

cessive

exposures

to field team .members'nd

that excessive

sample activity

could incapacitate

a laboratory analyzer.

The licensee

could not provide

a

basis

document for this procedure at the time of the inspection,

but committed

to develop

one.

However, at the time of this report,

the basis

document still

was not available.

This delayed

response

to an

NRC concern is considered

iso-

lated and not indicative of a programmatic degradation.

13

The licensee

has demonstrated

several

good initiatives with respect

to the

EOF

(Emergency Operations Facility).

for example,

during construction

by the

Rochester City Government in the vicinity of the

EOF, the licensee

took appro-

priate interim steps to maintain

EOF functionality.

To further improve the

EOF, the licensee

recently reconfigured it and increased its area.

An evaluation of licensee

response

to an actual

Unusual

Event involving Secur-

ity and Operations

Departments

indicated that plant staff responded well.

Security officers recognized

the event

and reported it to the control

room,

and

the reactor operator s accurately classified it as

an Unusual

Event.

These ac-

tions demonstrated

effective Security-Operations

interface

and effective train-

ing of security officers in non-security event

response

actions.

The response

by operations

personnel

to this and other Unusual

Events indicates that train-

ing has

been effective.

The plant simulator

has

been

improved with the addition of communications

equipment to permit its use for training drills and exercises.

This eliminates

the risk'of exercise

players

impacting normal operations

and enable

reactor

operators to place real

and simulated calls to off site authorities while

undergoing training.

The result is enhance

exercise

and drill realism.

EP remains

a staff function performed

by one person

supported

by site organi-

zation and licensee

management.

As a short term response

to

NRC concern re-

garding'the

EP staffing, the licensee

recently created

the position of Direc-

tor, Corporate

Radiation Protection.

This position also

has responsibility for

EP and has

been filled by a Health Physicist experienced

in EP.

While

excellent past

performance

in the

EP area did not decline during this

evaluation period, consideration

should

be given to additional staffing in this

area,

as previously

recommended

by a licensee

audit committee.

In summary,

the licensee

maintains

an overall excellent

EP program.

Training

of the emergency

response

personnel

and emergency

response facility operation

is adequate

as demonstrated

during the exercise

and response

to actual

events.

The licensee

does

need to assure

that

EP procedures

are given adequate

review

to provide

a basis

document justifying or revising current field sampling

procedures

for iodine.

An isolated instance of lack of management

control

was

indicated

by the fai lure to provide local governments

copies of audit reports.

III.D.2

Performance

Ratin

Category l.

III.D.3

Recommendations:

None.

14

III.E

~Secur<t

(187 Hours,

4%)

III.E.1

A~oa1

sos

During the previous

assessment

period, the licensee's

performance

was rated

Category 1.

No major regulatory issues

in the area of physical protection were

identified by either region-based

or resident

inspectors.

During this assessment

period, there were two routine unannounced

security in"

spections

performed

by region-based

inspectors.

Routine inspections

by the

resident inspectors

continued throughout the period.

As a result of the in-

spections,

five Severity Level IV violations were identified involving alarm

system testing, vital area barriers (2), alarm assessment

and inattentive

security officers.

The licensee

took timely and effective action to correct

the alarm system testing deficiency,

and has

scheduled

modifications to upgrade

the barrier at one vital area.

Corrective actions for the other deficiencies

are currently under review by the licensee.

It is not apparent that corporate security management

has continued to ade-

quately monitor the site security program.

There are indications that the suc-

cess of the program in previous

as.'essment

periods

may have resulted in a com-

, placent attitude

by the licensee.

The onsite licensee

security staff is com-

posed of a supervisor

and

a training coordinator,

both of whose strengths

and

efforts!appear

to be directed toward effectively supervising

the training and

performance of the contract guard force.

Because

of the lack of effective cor-

porate

management

oversight

and the emphasis

placed

on the personnel-related

aspects

of the program by onsite licensee

security personnel,

attention to the

performance

and maintenance

of the physical security

systems

have

been

inade-

quate.

No major upgrades

were

made to security

systems

during this assessment

period,

and

some

systems,

notably those related to intrusion alarm assessment,

have

been neglected

to the point that they are marginally effective,

For ex-

ample,

a major degradation

of the assessment

system

was identified by instru-

mentation/control

personnel

and contract security force members

about three

years

ago.

The correction of this problem was not pursued

by onsite licensee

security personnel,

and apparently

no system is in place for either corporate

management

or the onsite supervision to track such degradations

or other

security-related

issues.

Onsite licensee

management

continued to be effective in supe'rvising

the con-

tract security force.

This is evidenced

by the positive attitude toward secur-

ity displayed,

and the support afforded to the security organization

by all

plant personnel.

The site security organization maintains

an active liaison

with the local

law enforcement

agencies,

and conducts

an annual orientation

and

briefing for Federal,

State

and local law enforcement officers.

Effective

security supervision is demonstrated

in personnel-related

aspects

of the secur-

ity program, especially with regard to the development

and implementation of

physical protection procedures,

security force training and personnel

access

control.

However,

systems

and equipment

and the security plan appear to have

been neglected.

15

The annual audit of the security program,

performed

by the licensee's

quality

assurance

group, identified no program deficiencies.

This is in contrast to

the concerns identified by

NRC personnel.

The licensee

committed to evaluate

the effectiveness

of the audit process

and the security expertise

of the audi-

tors in the course of the contractor review of the security program.

Review of the licensee's

security event reports

and reporting procedures

found

them to be consistent with the NRC's regulation,

10 CFR 73.7l,

and implemented

by personnel

knowledgeable

of the reporting requirements.

Three reports

were

aade during the assessment

period.

One involved a loss of security

system

power supply,

and the other two were related to inattentive security force mem-

bers while on post.

The licensee's

and contractor supervisor's

actions in each

case

were prompt and appropriate,

and reflected proper management

involvement

and excellent contingency training.

However, the reports did not identify the

root cause for the inattentive officers or long term corrective actions.

Licensee

management

of the contract security force continued to be effective,

as evidenced

by the continued

low turnover rate (8X), high morale,

a profes-

sional attitude toward job performance

by members of the security force and

good enforcement

record relative to the performance of security force members.

Staffing of the contract security force is sufficient to meet the commitments

of the NRC-approved security plan.

However, during certain shifts,

guard

staffing could be strained

because

of the assignment

of security force members

to collateral duties.

The security force training and requalification program is well developed

and

effectively administered.

This is apparent

from the excellent job knowledge

demonstrated

by securi .y force members during interviews by

NRC personnel

and

few on-the-job errors.

As part of its efforts to assess

security program im-

plementation,

the licensee

also conducted

numerous

Safeguards

Contingency

Plan

drills.

Such drills further demonstrate

the licensee's

desire to maintain

an

effective security force.

During this assessment

period,'he

licensee

submitted three revisions to the

Security Plan in accordance

with the provisions of 10 CFR 50.54(p).

Two of the

revisions were reviewed by the

NRC and found to be acceptable,

although

a resub-

eitta1

was required in one case to provide more complete information.

The

third revision is currently under review by the

NRC,

The licensee

also sub-

.

mitted revisions to the'.Security

Plan in response

to the

10 CFR 73.55, Mis-

cellaneous

Amendments

and Search

Requirements.

The revisions contained

com-

mitments which meet the objectives of the rule change

and were

found to be ac-

ceptable.

The accuracy of the exit<'ng Security Plan

was also reviewed during on-site

inspections

by

NRC personnel,

and inconsistencies

in the Plan were identified.

From these

reviews,

there are indications that'he

licensee

does

not fully

understand

the importance of maintaining

a clear consistent

Security Plan

and

the

need to submit timely and accurate

revisions.

The licensee

has initiated

a review of their plan to address

this concern,

but the effectiveness

of this

review has not been

assessed.

16

The licensee

has,

in general,

maintained

an effective security program.

There

are

some indications,

however, of a lack of management

oversight

and support to

the continuing

need for security

system

upgrades

and modernization,

and for

maintaining

an effective Security Plan

~

As in the .past,

the strongest

areas

in

the security program are the training program for the security force and the

performance of the security force members.

However, the staffing level of the

contract security force, at times,

could be strained.

Also, the weakness

in

managerial

expertise

in physical security

systems

have contributed to the

decline in overseeing

the proper operation of systems

and equipment

and the

quality of the security plan.

III.E.2

Performance

Ratin

Category

2.

III.E.3

Recommendations:

Licensee:

Evaluate

the adequacy of the management

system to monitor and track

security

system

and equipment

performance.

IIIsF

En ineerin /Technical

Su

ort (311 Hours,

6X)

III.F.I

A~nal sls

In the prior assessment

period,

Engineering/Technical

support

was rated

as

a

Category 2.

The board noted problems

such as:

staffing shortages

causing

en-

gineering to operate

in a reactive

mode, limited routine support to the plant,

ineffective prioritization of projects,

weak interface

between corporate

and

site resulting in delays in resolving issues,

inadequate

assessments

of safety

significant issues

and omissions of safety evaluations,

and weak management

control in Equipment gualification activities.

Several

positive factors noted

by the board were:

the nucleus of competent

corporate

engineering

personnel,

aggressiveness

in the fire protection activity, and

good engineering training.

The board

recommended

a reexamination

in the depth of the engineering staff to

ensure

resources

are available to enhance plant performance

by the conduct of

proactive initiatives.

The following evaluation is based

on assessments

of engineering

support effec-

tiveness

from routine

and special

inspections

performed during this assessment

period.

Assessments

also related to the licensee's

activities in response

to

the prior assessment

comments.

Corporate

and site organizational

changes

have

been

made.to define account-

ability and improve management's

capability to assess

and resolve engineering

issues.

The separation

of the corporate

engineering

nuclear

and non-nuclear

functions was

a noted

improvement.

Creating

two new supervisory positions that

oversee all plant activities and report to the plant manager

was considered

a

positive action.

These

changes

have improved management

involvement in assur-

ing quality.

17

In response

to staffing shortages

identified in the previous

SALP, increases

were evident at both corporate

and site engineering.

In corporate

engineering

there

was

an increase

of 22 engineers

with present

approval for 12 more.

At

the site the technical

group staff was increased

from thirteen to twenty"six.

The staffing increases

at both locations

has aided the effectiveness

in com-

munications

between

corporate

and site.

It was also noted that two

PRA engi-

neers

have recently

been hired and

PRA reliability analyses

are planned.

The

above staffing increases

indicate

management

commitment to improve the quality

of the engineering

support to the plant.

Despite the above

improvements,

the licensee

performance

in this area

has

been

mixed.

Inadequate

engineering

support of the

pump and valve inservice test

program led to testing omissions

and inadequate

testing of safety

system

com-

ponents

and resulted

in a level III violation with a civil penalty.

The

licensee

has

made rapid and significant progress

in addressing

this deficiency.

The site technical

group staffing increase

aided in the licensee's

quick cor-

rective action.

During the startup

from the

1989 refueling outage,

operators

were not fully

aware of the status of the SI and

AMSAC modifications.

Failure of the engi-

neering groups to ensure

operators

were formally notified of changes

imple"

mented resulted

in a plant trip and

a forced shutdown.

The licensee

has

been aggressive

in attempting to correct

10 CFR 50.59 problems

by instituting training, placing additional

departmental

overview in the formal

review process,

and discussing daily modification work at the morning meetings

as

an informal review process.

However,

weaknesses

in 10 CFR 50.59 reviews

and

engineering

reviews continued to exist.

Typical examples

included inappropri-

ate evaluation of: condensate

storage

tank capacities

that used incorrect tem-

perature

and did not consider the tap location; the

CST level indication modi-

fication that used

tygon tubing; the spent fuel pool modification and the

PORV

block valve replacement

that did not fully establish

the operability and quali-

fication of the

new valves.

A licensee

program to address

these

weaknesses

was

in place at the

end of the

SALP period, but had not yet been evaluated.

Fire Protection activities, previously identified as

a strength,

have

shown

some problems during this assessment

period.

Weaknesses

were identified in

inadequately installed fire barrier wrap, fire door closure

problems, fai lure

to consider

the

need to wrap cable tray supports,

and as mentioned in the Plarit

Operations Analysis.

Another issue

not fully addressed

involves availability

of compensatory

measures

to be taken

on loss of city water supply

on

a loss of

screen

house

and

AC power supply scenario.

On

'h'e positive side,

the licensee

has exhibited initiative in the innovative

redesign of the large

steam generator

supports

which eliminated the need for 6

of the 8 hydraulic snubbers.

The use of sophisticated

computer

codes to ensure

proper pipe sizing and established

test procedures

to assure

required flows and

~

18

discharge

pressures

demonstrated

good engineering

and planning for the licen-

see's

submittals to

NRR regarding

the modification of recirculation lines for

the

RHR and SI pumps.

Engineering

has provided significant support for the

installation of a second

station transformer.

Modification packages

from corporate

engineering

do not always get to the plant

within sufficient time to properly plan the activities.

The licensee's

ALARA

program, for instance,

has suffered

because

of this.

However, with this excep-

tion, outage planning

was

a coordinated

team effort that was competently

directed.

Major modification efforts included the safety injection and resi-

dual

heat

removal recirculation piping upgrade,

turbine trip system

ATWS modi-

fication, offsite power reconfiguration work, steam generator

snubber replace-

ment,

and

steam generator

blowdown system upgrade.

Considerable

additional

work was also performed concurrent with the major modifications

and included:

steam generator

inspection

and sleeving,

ten year ISI reactor vessel

inspec-

tion, high and low pressure

turbine overhaul,

primary heat exchanger

inspec-

tions,

and

many maintenance activities.

The licensee recently developed

an-

alytical.basis for prioritizing modifications and other activities; the program

is presently being

used to determine priorities for the next refueling outage.

T'>e licensee's

steam generator

inspection

and sleeving activities was especially

noteworthy.

The licensee

performed

an inspection of all active tubes in both

steam generators

to determine

the actual condition of tubes.

The licensee

de-

veloped<a training program for qualification and certification of visual ex-

aminers that exceeds

the

ASME Code requirements,

and includes

hardware

mock-ups

of actual plant equipment,

and implemented effective automation for sleeve in-

sertion

and welding in order to minimize personnel

radiation exposure.

The

reactor pressure

vessel

inspection

was well planned

and it used state of the

art techniques.

The licensee

also

has

an effective erosion-corrosion

control

program.

The effectiveness

of this program was evident in the identification

and replacement of several

components

before problems occurred.

The technical capability and the professional

conduct of the engineering staff

continues to be

a licensee

strength.

Staffing corrective

measures

have

been

instituted.

Management attention

should

be given .to assure effective use of

the staff in performing thorough engineering

evaluations

and reducing the ex-

isting backlog.

A pertinent observation of the

IPAT inspection

was that over-

reliance

on experienced

and qualified personnel

was not adequately

balanced

with programs

and procedures

and that Engigeering is not as proactive

as

needed

to assure

top quality performance.

In conclusion,

improvements

have

been

made in engineering staffing and the

technical capability of the engineering staff continues to be

a strength.

A

1=.i.k of formal communication

from engineering

groups to the operations

group

was evident throughout the modification process for both SI and

AMSAC modifi-

cations during the

1989 refueling outage.

A number of problems

were encoun-

tered during the first half of this

SALP period and

may be attributed in part

to past staffing inadequacies,

weaknesses

in management

over sight and

ineffective use of gA.

The backlog of work projects

remains

high and needs

to

be addressed.

The licensee

has

been aggressive

in correcting

NRC identified

19

issues.

Management

changes

were

made in the later half of the assessment

period and

a more proactive

management

stance

and commitment to assurance

of

quality engineering

support

has

been evident.

III.F.2

Performance

Ratin

Category 2.

III.F.3

Recommendations:

None.

III.G

Safet

Assessment/ ualit

Verification (202 Hours,

4%)

III.G.I

A~nal sl s

In previous

SALP reports,

Assurance of guality and Licensing Activities were

evaluated

in separate

sections of the report.

This

new section'(Safety

Assess-

ment/guality Verification) has

been created

not only to consolidate

those

two

sections,

but also to encompass

activities

such

as safety reviews,

responses

to

NRC-generated initiatives such

as generic letters, bulletins, information

notices,

and resolution of TMI items.

This section, continues to encompass lic-

ensee

revi,ew activities associated

with licensee

amendment

requests

and Tech-

nical Specification

change.s;

activities related to the resolution of safety

issues;

treatment of unreviewed safety questions;

self-assessment

activities;

analyses

related to industry operational

experience;

root cause

analyses

of

plant events;

and

use of feedback

from plant quality reviews.

This section

provides

a broad

assessment

of the licensee's ability to identify and correct

problems related to nuclear

safety.

This includes

the effectiveness

of the

licensee's

quality verification function in identifying and correcting

sub-

standard

or anomalous

performance

and in monitoring the overall performance

of

the plant.

This constitutes

the first assessment

of this functional area.

For the pre-

vious

SALP report,

Assurance of guality was rated

Category

2 and Licensing Ac-

tivities was -rated Category

1.

During this assessment

period the licensee

made

a

number of changes

to plant

,

programs,

organizational

structure,

and corporate

management

alignments to

better focus

on problem areas identified in previous

SALP periods.

RG&E has

hired

a number of engineering

and professional staff members to augment the

RG&E staff at plant and corporate offices.

In addition goals

and commitment to

safety

have

been

promulgated

by Senior corporate officers.

In response

to identified problems

RG&E strengthened

the, process for making

changes

to the facility in accordance

with the provi sions of 10 CFR 50.59.

RG&E Staff guidance is being rewritten

and major efforts are

underway

on up-

grading "g" Lists and plant drawings.

The

new guidance

has

strengthened

RG&E's

treatment of any unreviewed safety questions with regard to any probability/

consequences

of malfunction of plant equipment

and its respective

margin of

safety.

~

20

In general

the licensee

continued to provide high quality licensing submittals

to the

NRC,

many of which involved complex issues.

The submissions

were. gene-

rally timely, technically sound,

and responses

to requests

for information were

complete.

Examples

include:

responses

to Loss of Decay Heat

Removal Generic

Letter, Inservice Inspection

program,

the Bulletins relating to rapid propagat-

ing fatigue cracks in steam generator

tubes

and potential safety-related

pump

loss.

However,

one notable exception to this performance

was related to the

steam driven Auxiliary Feedwater

(AFW) Pump.

Substantial

NRC involvement was

required to effect appropriate

corrective actions including a change to the

facility Technical Specifications.

Although the licensee

agreed to a conser-

vative operating

philosophy for the

AFW system in December

1988,

a technical

specification

change

supporting this philosophy was not submitted until May

1989.

Midway through the cycle the licensee

made changes

to improve the credibility

and utilization of the quality organizations.

One action

was the creation of a

new position, Director of Quality Assurance/Quality

Control.

The Director of

QA/QC reports to the President

and Chief Operating Officer, and is responsible

for site and corporate quality organizations.

The position was filled by the

former Ginna Outage Coordinator,

an

SRO licensed

engineer with significant

operating experience.

Although the

new Director of QA/QC left

REISE in April

1989 and the position was not filled at the end of the

SALP period,

he com-

pleted

a self-assessment

of the site quality organization.

He also provided

a

plan to<improve quality effectiveness.

Although this was

a positive initi-

ative, to date,

implementation of the quality plan

has lost momentum,

as poor

corrective actions indicating continued

QA department

ineffectiveness

has

been

evidenced

by the .following examples:

Audits of the radiological protection organization,

performed

by the

QA group,

assisted

by the corporate

HP staff,

as discussed

in the Radiological Controls

section, identified weaknesses

during the early part of the

SALP period, but

evidenced

no improvement with respect

to required corrective actions

by the

second audit in September

1988.

Corrective action,

as

a result of NRC security inspections

which identified

four violations,

was delayed

due to the lack of QA management

attention (refer

to Section III.E.1).

Control

and documentation

of receipt,

storage

and handling of materials

and

components

also displayed

some weaknesses.

The, present

documentation

system

does

not appear

able to assure

shelf life is considered

in selection

and

use

of parts

and materials

stored in the stockroom

system.

Significant IST deficiencies

were identified during the period.

The licensee

vigorously pursued

the issue to correct the deficiencies during the refueling

outage to ensure

implementation of an acceptable

program that would meet

NRC

requirements.

The effort by the

RG&E staff produced

a good. IST program

and

developed

a thorough understanding

by the plant and engineering staff of NRC

requirements with regard to IST.

RG&E was

one of the first licensees

to re-

spond to

NRC Generic Letter 89-04, providing

a comprehensive

program for IST.

p

rr

~

21

Although the licensee's

corrective actions

were aggressive,

previous audits

had

not identified the problems

(as discussed

in Maintenance/Surveillance).

During this

SALP period

RG&E took appropriate

action

by their multi-plant ac-

tion (MPA) management

team to closeout

TMI Action Items III.A.1.2 and III.A.2

with regard to the Ginna emergency

response facilities (ERF).

RG&E proposed,

scheduled,

and completed

an upgrade

program for meteorological

measurements

and

analyses.

RG&E installed

a second

100 percent station service transformer

(second

source

of preferred

power)

as

a conservative

action that will increase offsite power

reliability.

The engineering effort for this modification has

been extensive.

During an event in December

1988,

a plant shutdown

was initiated due to freez"

ing of a two steam generator

pressure

sensing lines.

The anticipated

Safety

Injection (SI) activation

was negated

by use of a simulated signal.

The plant

operator's

actions

were appropriate

to the circumstances

as actions were car-

r'ied out

~ after shift supervisory

and shift technical

advisor judgement con"

sidered the safety implications.

In response

to

NRC concerns,

RG&E has pro-

ceduralized

the supervisory

and operator's

actions to ensure that all safety

implications are considered

when

such actions

by the plant operator are taken.

Although management

was very responsive

to the safety implications of this

event;

they failed to assure

adequate

corrective action

was taken after

a

similar>line freezing event which occurred

several

years earlier.

The 1989, Cycle

19 refueling outage

was

a complex outage,

longer than antici-

pated

in which active senior

RG&E management

involvement was observed.

Major

activities at Ginna during the Cycle

19 refueling outage which exemplified

a

high caliber of management

oversight

and technical capability were: ISI exami-

nation of the reactor vessel utilizing new techniques,

sleeving

steam generator

tubes in the peripheral

sections with newly developed tools and procedures;

modifications to SI

pump recirculation lines;

and implementation of the newly

approved

IST program which required the disassembly

of major valves for inspec-

tion and testing.

However,

some engineering

packages

were not,completed with

sufficient lead time for adequate

ALARA planning.

Inadequate

ALARA planning

resulted

in missed opportunities for total dose

savings during the outage

period.

Also, insufficient post-maintenance

testing of the SI

pump recircu-

lation lines resulted in having to reset

the valve positions after the restart

from the outage.

Also,

a plant trip, caused

by a locked-in; relay from prior

testing,

occurred

as

a result of an inadvertent ASS Mitigation System Actu-

ation Circuitry (AMSAC) initiation.

In response

to

NRC identified weaknesses,

the licensee

developed

several

man-

agement tools to improve plant management

effectiveness.

These include:-a

tracking system for Non-Conformance

Reports

(NCR), the Identified Deficiency

Report (IDR), and

a

new reporting

system for non-safety-related

deficiencies.

A tracking system for IORs similar to the system for NCRs was also developed.

Effectiveness

of these

new tools

has not yet been

assessed.

22

In summary,

changes

were

made in corporate

and plant programs,

management,

and

staffing during this assessment

period which resulted in a significant change

in corporate

philosophy.

However, the heavy reliance

on technically competent

individuals,

has resulted in weak administrative controls,

and continued lack

of effectiveness

of quality organizations

as

a management

tool.

During this

SALP period, senior

management

was actively involved in licensing activities

and technical

issues

which ensure

a high quality of licensee

support perfor-

mance.

III.G.2

Performance

Ratin

Category 2.

III.G.3

Recommendation:

Licensee:

Meet with the

NRC staff to describe overall approach

to assure

that

quality organizations will be effectively used

as

a management

tool

to assure

safe station operation.

NRC:

None.

~ I)Pi

SUPPORTING

DATA AND SUMMARIES

A.l. Licensee Activities

At the beginning of the assessment

period, the plant was operating at full

power.

On February

5,

1988, while the plant was being

shutdown for the annual

refueling outage,

a reactor trip occurred

due to high counts,

when the source

range detectors

energized.

Faulty connectors

were determined to be the root

cause of the high counts.

Outage activities included refueling, plugging 74

steam generator

tubes,

repairing

B main

steam isolation valve,

a reactor cool-

ant

pump seal

inspection,

boric acid system piping upgrade,

and emergency

diesel generator

fuel oil system piping modifications.

The plant was started

up on March 9,

1988, but tripped

on March 10,

1988 from 25 percent

power due to

low steam generator

level with a

steam flow-feed flow mismatch.

During the

start-up, operators

experienced

reactor coolant

system temperature

control

problems

due to the slightly positive moderator

temperature coefficient.

The plant was returned to power on March 12,

1988,

but

a steam generator

tube

leak forced

a shutdown

on March 14,

1988 from 89 percent

power.

Nine tubes

were plugged during this forced outage.

The plant was returned to power

on

March 24, 1988.

On June

1, 1988, the reactor tripped from full power due to a low steam

gene-

rator level caused

by the

random failure of a feedwater flow transmitter fuse.

A safety injection signal

was generated

due to low pressurizer

pressure.

The

plant was returned to power on June

5,

1988.

A substation

breaker

bushing

failure and fire forced

a shutdown

from full power

on July 16,

1988.

The plant

was returned to power

on July 17,

1988.

A turbine runback occurred

on August

25,

1988 when

a power range detector

dropped

rod rod stop bistable failed.

The

plant was stabilized at approximately

70 percent

power and was returned to full

power after the bistable

was replaced.

Two steam generator

pressure

sensing

lines froze

on December

11,

1988 causing

plant personnel

to initiate

a technical

specification required plant shutdown.

Power was reduced to sixty-three percent

before the sensing lines were returned

to operable.

The plant was returned to full power later the

same

day.

Operators

manually tripped the turbine from 48 percent

power

on January

21,

1989 when turbine load was lost during intercept

and reheat

stop valve testing.

Plant power was reduced to repair main condenser

tube leaks.

A short circuit

during the test caused all valves to close

when only one should

have closed

momentarily.

The plant was returned to power the following day.

On February

6,

1989,

a spike in the vital

DC system

caused

a turbine runback.

The plant was stabilized at approximately

72 percent

power and was returned to

full power later the

same day.

The plant was

shutdown for the annual refueling

and maintenance

outage

on March 17,

1989.

SD/D-1

Outage activities included refueling, ten year inservice inspection,

safety

injection system

and residual .heat

removal

system recirculation modifications,

and

steam generator

tube recovery, consisting partly of peripheral

tube sleev-

ing.

The reactor

was taken critical on May 29,

1989 and operators

attempted to syn-

chronize the generator

to the grid on May 30,

1989.

The generator

breaker

im-

mediately

opened

when closed

and the turbine tripped due to open slide links

at the main transformer."

The generator

was successfully

synchronized

to the

grid on

May 30,

1989, after the links were closed.

A reactor trip occurred

on June

1,

1989 from 53 percent

power due to

a turbine

trip.

The turbine tripped due to an unanticipated

actuation of the

ATWS Miti-

gation System Actuation Circuitry (AMSAC).

A.2. Direct Ins ection

and Review Activities

Two

NRC resident

inspectors

were assigned

to the site throughout the assessment

period.

The total inspection time for the assessment

period was 4859 hours0.0562 days <br />1.35 hours <br />0.00803 weeks <br />0.00185 months <br />

(resident

and region based) with a distribution in the appraisal

functional

area

as

shown with each functional area.

This equates

to 3241 hours0.0375 days <br />0.9 hours <br />0.00536 weeks <br />0.00123 months <br />

on

an an-

nual basis.

Special!inspections

included the following:

Refueling outage

team inspection to assess

readiness

for restart

(February

22-26.

19889).

Special

team inspection to assess

the adequacy

and verify adherence

to

regulatory requirements

and license

commitments for the implementation of

the IST program

(May 16-20,

1988).

Special

inspection of June

1,

1988 reactor trip with complications

(June

1-4, 1988).

Integrated

Performance

Assessment

Team Inspection

(September

8-22,

1988).

The annual

emergency

preparedness

exercise

was held

on October

19,

1988.

Special

inspection to assess

the safety significance of the December ll,

1988

B steam generator

frozen pressure

sensing

lines

(December

11-21,

1988).

B.

Criteria

Licensee

performance

is assessed

in selected

functional areas,

depending

on

whether the facil.ity is in a construction,

preoperational,

or operating

phase.

Each functional area

normally represents

areas significant to nuclea~ safety

and the environment,

and are

normal

programmatic

areas.

Special

areas

may be

added to highlight significant observations.

SD/D-2

The following evaluation criteria,

where appropriate,

were used to assess

each

functional area:

l.

Assurance of quality, including management

involvement and control;

2.

Approach to resolution of technical

issues

from a safety standpoint;

3.

Responsiveness

to

NRC initiatives;

4.

Enforcement history;

5.

Operational

events (including response

to, analyses

of, reporting of and

corrective actions for)

6.

Staffing (including management),

and

7.

Effectiveness of training and qualification program.

On the basis of the

NRC assessment,

each functional area evaluated is rated

according to three

performance

categories.

The definitions of these

perform-

ance categories

are

as follows:

~Cate or

1.

Licensee

management

attention

and involvement are readily evident

and place

emphasis

on superior performance

of nuclear safety or safeguards

ac-

tivities, with the resulting performance substantially

exceeding

regulatory

requirements.

Licensee

resources

are

ample

and effectively used

so that

a high

level of plant and personnel

performance

is being achieved.

Reduced

NRC at-

tention

may be appropriate.

~Cate or

2.

Licensee

management

attention to and involvement in the perform-

ance of nuclear safety or safeguards

is good.

The licensee

has attained

a

level of performance

above that needed

to meet regulatory requirements.

Lic-

ensee

resources

are

adequate

and reasonably

allocated

so that good plant and

personnel

performance

is being achieved.

NRC attention

may be maintained at

normal

levels'atecaCorr

3

Licens.ee

management

attention to and involvement in the perform-

ance of nuclear safety or safeguards

activities are not sufficient.

The lic-

ensee's

performance

does

not significantly exceed that needed to meet minimal

regulatory requirements.

Licensee

resources

appear to be strained or not ef-

fectively used.

NRC attention

should

be increased

above

normal levels.

The

SALP Board may assess

a functional area to compare

the licensee's

perform-

ance during the last quarter of the assessment

period to that during the entire

period in order to determine the recent', trend.

The

SALP trend categories

are

as follows:

The trend, if used,

is defined as:

~Im rovin

Licensee

performance

was determined

to

be improving near the close

.

of the assessment

period.

~geclinin

Licensee

performance

was determined to be declining near the close

of the assessment

period and. the licensee

had not taken mean'ingful

steps

to

address

this pattern.

A trend is assigned

only when, in the opinion of the

SALP Board,

the trend is

significant enough to be considered

indicative of a likely change

in the per-

formance'category

in the near. future.

For example,

a classification of "Cate-

gory 2, Improving" indicates

the clear potential for "Category I" performance

in the next

SALP period.

It should

be noted that Category

3 performance,

the lowest category,

represent

acceptable,

although minimally adequate,

safety performance.

If at any time

the

NRC concluded that

a licensee

was not achieving

an adequate

level of safety

performance, it would then

be incumbent

upon

NRC to take prompt appropriate

action in the interest of public health

and safety.

Such matters

would be

dealt with independently

from, and

on

a more urgent

schedule

than,

the

SALP

process.

It should also

be noted that the industry continues

to be subject to rising

performance

expectations.

NRC expects

licensees

to use industry-wide and

plant-specific operating

experience

actively in order to effect performance

improvement.

Thus,

a licensee's

safety performance

would be expected

to show

improvement over the years

in order to maintain consistent

SALP ratings.

C.

Un lanned

Shutdowns

Plant Tri

s and Forced Outa

es

Power

Root

Functional

Date

,

Leve1

Cause

Area

Descri tion

2/5/88

OX

Personnel

Error

Maintenance/

Surveillance

A reactor trip occurred

on Source

Range

Hi Flux

during

a planned shut-

down for the annual

re-

fueling outage.

The

source

range instruments

reenergized

prematurely

as

a result of connec-

tors apparently

damaged

during previous mainten-

ance activities.

3/10/88

25K

Personnel

Error

Operations

A reactor trip occurred,

during plant start-up,

on low steam generator

level coincident with

steam flow-feed flow

mismatch.

A lack of

operator training 'with

positive moderator

tem-

perature coefficient

caused

reactor coolant

system temperature

and

steam generator

level

control problems.

SD/D-4

Date

Power

Level

Root

Cause

Functional

Area

Descri tion

3/14/88

89

Personnel

Error

Maintenance/

Surveillance

A steam generator

tube leak

).1

gpm forced plant shut-

down.

The licensee failed

to correctly identify a de-

fect in the leaking tube

during

Eddy Current data

analysis

performed during

the refueling outage.

6/1/88

100K

7/16/88

100%

1/21/89

48K

Component Failure

Maintenance/

Surveillance

Component Failure

Maintenance/

Survei'.lance

Component Failure

N/A

A reactor trip occurred

on

low steam generator

level

coincident with steam flow-

feed flow mismatch.

A fuse

in the controlling feed flow

channel

power supply blew

causing

feed flow and

steam

generator

level swings.

A

safety injection signal

was

caused

by operators

over-

feeding the

steam generators

causing reactor coolant sys-

tem pressure

to drop.

A breaker

bushing failure

in the plant's

main sub-

station

caused

a loss of

normal offsite power.

The

bushing's oil level

gauge

was broken

and oil level

decreased

causing internal

arcing

and subsequent

bushing failure.

The plant

was

shutdown to effect re-

pairs to the substation.

While repairing main con-

denser

tube leaks,

opera-

tors manually tripped the

turbine when load was lost

during testing of the inter-

cept

and reheat

stop .valves.

A short circuit caused all

valves to close

when only

one should

have closed

momentarily.

The rector

was taken subcritical to

effect repairs to the

turbine control

system.

Date

Power

Level

Root

Cause

Functional

Area

Descri tion

6/I/89

53%

Personnel

Error

Engineering/

Tech Support

A reactor trip occurred

on

a turbine trip due to

actuation of AMSAC.

Operators

unblocked

AMSAC without first

totally resetting

the

system.

A procedural

inadequacy

resulted

from

a deficiency in the

training material

sup-

plied by engineering for

the modification.

D.

Enforcement Activit

Functional

No. of Violations in Ea"h Severity Level

V

IV

III

II

I

Total

A.

Plant Operations

1

4

B.

Radiological Controls

2

4

C.

Maintenance/Survei

1 1 ance

1

P

D.

Emergency

Prepar edness

E.

Security

1

1

F.

Engineering/Technical

Support

1

1

G.

Safety Assessment/guality

1

Verification

H.

Other

Total

6

20

1

27

SD/D-6

E.

Ins ection

Hour

Summar

Functional

Area

Plant Operations

Radiological Controls

Maintenance/Surveillance

Emergency

Preparedness

Security

Engineering/Technical

Support

Safety Assessment/equality

Yerification

Other

Actual

2517

229

802

103

187

311

202

508

Annualized

Hours

1678

153

535

69

125

207

135

339

Percent

52

17

10

TOTAL

4859

3241

100

SD/0-7

F.

Licensee

Event

Re ort Casual

Anal sis

Functional

Area

Number By Cause

Code

A

8

C

0

E

X

Total

Plant Operations

Radiological Controls

Maintenance/Surveillance

Emergency

Preparedness,

1

1

Security

Engineering/Technical

Support

Safety Assessment/guality

Verification

Other

4

4

Totals

4

2

1

6

13

Cause

Codes

A - Personnel

Error

8 - Design, Manufacturing,

Construction or Installation Error

C External

Cause

0 - Defective Procedures

E - Component Failure

X - Other

SD/0-8