ML17250B046
| ML17250B046 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/01/1989 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17250B045 | List: |
| References | |
| 50-244-87-99-01, 50-244-87-99-1, NUDOCS 8911130290 | |
| Download: ML17250B046 (64) | |
See also: IR 05000244/1987099
Text
ENCLOSURE
1
FINAL SALP
REPORT
U.
S.
NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
FINAL SALP
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 ll, 1989
8911130290
891101
ADQCK 05000244
Pgl I
I,
INTRODUCTION.........
II.
SUMMARY OF RESULTS..
TABLE OF CONTENTS
PAGE
II.A
Overview.
II.B
Facility Performance
Analysis Summary..
III. PERFORMANCE ANALYSIS .'.
2
3
~
~
~
~
~
~
~ I
~
~
~
~
~
~
~
4
III.A
III.B
III . C
III.D
III.E
III.F
III.G
Plant Operations..
Radiological Controls
Maintenance/Surveillance.
Emergency
Preparedness'ecurity
Engineering/Technical
Support.
Safety Assessment/Quality
Verification.
7
9
12
14
16
19
SUPPORTING
DATA AND SUMMARIES
A. 1
Licensee Activities
A.2
Direct Inspection
and Review Activities
B.
Criteria.
C.
Unplanned
Shutdowns,
Plant Trips and Forced
D.
Enforcement Activity
E.
-Inspection
Hour Summary
F.
Licensee
Event Report Casual
Analysis
Outages..
SD/S-1
...........SD/S-2
SD/S-2
SD/S-4
SD/S-6
........SD/S-7
SD/S-8
TABLES
Table
1 - Enforcement/Severity
Level
Table
2
'nspection
Hour Summary
Table
3
Listing of LERs by Functional
Area
P
I
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 i s 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
(DRS)
J. Joyner,
Division Project Manager,
Division of Radiation Safety
and Safe-
guards
(DRSS)
R. Wessman,
Director, Project Directorate I-3,
A. Johnson.
Project Manager,
PO 'I-3,
E. Wenzinger,
Chief, Projects
Branch
No 1,
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,
DRSS
T. Dragoun,
Senior Radiation Specialist,
DRSS
D. Haverkamp,
Chief, Reactor Projects
Section
3B,
J.
Johnson,
Chief, Projects
Branch
No.
3,
R. Keimig, Chief, Safeguards
Section,
DRSS
J. Prell, Senior Operations
Examiner,
E. Sylvester,
Senior
Reactor
Engineer,
ORSS
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 Quality Assurance
and Quality Control organization
as
a management
tool to improve station performance.
9
Operator
performance
and professionalism
continue to be
a strength during nor-
mal plant operations
and in emergency situations.
The operator
degree
program
is
a positive initiative which has
been well received
by the operations staff
and supported
by management.
Constructive
and effective daily staff meetings
have
improved communication
between
departments'here
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'he
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 fai lure 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.
3.
II. B Faci 1 it
Performance
Anal si s
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/Quality
Veri-
fication area.
The Safety Assessment/Quality
Verification section is largely
a
synopsis of observations
in other functional areas.
Additionally, the Fire
Protection,
Licensing, Refueling/Outage,
Training and Assurance of Quality
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"""
D.
Emergency
Preparedness
E.
Security
F.
Engineering/Technical
Support
G.
Safety Assessment/Quality
Verification
H.
Licensing Activities
I.
Training
& Qualification Effectiveness
J.
Assurance
of Quality
2/1
2
June
1,
1986 to November 30,
1987
- "
December
1,
1987 to May 31,
1989
- "* Previously addressed
as
separate
areas.
¹
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
once
III. PERFORMANCE ANALYSIS
III.A
Plant
0 erations
(2517 Hours, 52/)
III.A.I
A~nal sis
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
o'f 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
PE 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 refueling 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
Power"
EOPs.
Candidates
were also unable to properly prioritize the Functional
Restoration
Procedures.
However, inplant use of the
was performed
smoothly
and effectively during
a loss of normal offshift power,
and following the June
',
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
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-
'cribed
in their procedures
and specific tasks
such
as complicated surveillance
tests,
major plant systems tests,
refueling operations,
and abnormal
and emer-
gency operations
were addressed
with the personnel.
Operator training 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 several
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 commitments,
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 proper
system
alignment per
was not properly interpreted
and implemented.
Control'f housekeeping,
identified as
a weakness
in the prior SALP report,
continued to be
a weakness.
Plant management'as
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
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 P&ID 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 were 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.
Poor 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.
None.
III.B
Radiolo ical Controls (229 Hours,
5%)
III.B.I
A~nal sis
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.
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'nspection.
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,
h'owever, 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 i
to
support the
1988 outage,
exhibited weakness
in technical
knowledge
and perform-
ance.
While the licensee's
training programs partially addressed
the technical
knowledge area, it could not make
up for weaknesses
in technician
experience.
These
weaknesses
contributed 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-
strumentation
control charts
had previously been identified in repeated lic-
ensee
audits,
but not corrected.
Also, NRC-identified weaknesses
with job-
related
survey procedures
remained. unresolved
since the previous
SALP.
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.
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 al.l 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 majority 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
c rrective
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
inspec-
tion, goa'l setting
and planning for one-time-jobs,
such
as plant modifications,
were routinely found to be weak.
One 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 radwaste
workers.
These
were areas identified during the previous
assessment
period as
being minor weaknesses.
During 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
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's
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 workers, 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'ecommendations:
Licensee:
Nones
NRC:
Conduct
a special
inspection of the licensee's
corrective action programs.
III.C
Maintenance/Surveillance
(802 Hour s, 17/)
III.C.I
A~nal sin
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
attention
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,'ave
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 addre>>
component
aging,
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
knowle'dge
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
I
current,
and did not provide useful information to managers.
The (}-list was
inadequate,
as identified by the
NRC; licensee
long'erm 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 coordinated 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 maint'enance
backlog are
under development;
an in-
terim instruction
was written to suppleii,ant the g-list until
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-
'ulted
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,
was 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
survei llances.
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, 2')
III.D.I
~Anal sis
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
prepa 'edness
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 samples
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
and 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
(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
arear'n
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
operators
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'his
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
managements
As
a short term response
to
NRC concern re-
gardi'ng 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
~
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 failure to provide local governments
copies of audit reports.
III.0.2
Performance
Ratin
- Category
1.
III.D.3
Recommendations:
None.
14
III.E
~Securit
(187 Hours,
4%)
III.E.I
A~nal sis
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
assessment
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 supervising
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
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,
and
implemented
by personnel
knowledgeable of the reporting requirements.
Three reports
were
made during the assessment
period.
One involved
a loss of security
system
power supply,
and the other
two were related to inattentive security force
mem-
berss
while on post.
The licensee'
and contractor supervisor's
actions in each
case
were prompt and appropriate,
and reflected
prope~
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
(Sro'), 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
r equalification program is well developed
and
effectively administered.
This is apparent
from the excellent job knowledge
demonstrated
by security 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,
the 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-
mittal was required in one case
to provide more complete information.
The
third'evision 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-
mi,tments which meet the objectives of the rule change
and were found to be ac-
ceptable.
The accuracy of the existing 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 the 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'o
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.ED 2
Performance
Ratin
Category
2.
III'.3
Recommendations:
Licensee:
Evaluate
the adequacy
of the management
system to monitor
and track
security
system
and equipment
performance.
III.F
En ineerin /Technical
Su
ort (311 Hours,
6%)
III.F.I
A~nal sis
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'esulting
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
ANSAC 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
block valve replacement
that did not fully establish
the operability
and
quali-'ication
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, failure
to consider
the
need to wrap cable tray supports,
and
as mentioned
in the Plant
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 the positive side,
the licensee
has exhibited initiative in the innovative
redesign of the large
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 engi'neering
and planning for the licen-
see's
submittals to
NRR regarding
the modification of recirculation lines for
the
Engineering
has provided significant support for the
installation of a second
stati'on transformer.
Modification packages
from corporate
engineering
do not always get to the plant
within sufficient time to properly plan the activities.
The licensee's
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
blowdown system
upgrade.
Considerable
additional
work was also performed concurrent with the major modifications
and included:
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.
The licensee's
inspection
and sleeving activities was especially
noteworthy.
The licensee
performed
an inspection of all active tubes'n
both
to determine
the actual condition of tubes.
The licensee
de-
veloped
a training program for qualification'nd 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
exposures
The
reactor pressure
vessel
inspection
was well planned
and it used state of the
art techniques.
The licensee
also
has
an effective erosion-cor'rosion
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 Engineering 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
lack 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
oversight
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
'ssues.
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 sis
In previous
SALP reports,
Assurance
of Quality and Licensing Activities were
evaluated
in separate
sections
of the report.
This
new section (Safety Assess-
ment/Quality 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
review activities associated
with licensee
amendment
requests
and Tech-
nical Specification
changes;
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 Quality 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.
RGKE has
hired
a number of engineering
and professional
staff members
to augment
the
RGEE 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
RGEE strengthened
the process for making
changes
to the facility in accordance
with the provisions of 10 CFR 50.59.
RGEE Staff guidance is being rewritten
and major efforts are
underway
on up-
grading
"Q" Lists and plant drawings.
The
new guidance
has
strengthened
RGEE'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 operati ng philosophy for the
AFW system in December
1988,
a technical
specification
change
supporting this philosophy
was not submitted until Nay
1989.
Hidway 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 RG&E 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.
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
'ith 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-
ried out after shift supervisory
and shift technical
adv'.sor
judgement
con-
side'red 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 pla,
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
tubes in the peripheral
sections with newly developed tools and procedures;
modifications to SI
pump recirculation lines;
and implementation of the newly
approved
IST prog'ram 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 afte'r 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
ATWS 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 IDRs 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.
SUPPORTING
DATA AND SUMMARIES
A. 1. 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
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
system temperature
control
problems
due to the slightly positive moderator
temperature
coefficient.
The plant was returned to power on March 12,
1988, but
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
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 cir cuit
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
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.'he 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
io 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
r eadiness
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
11,
1988
frozen pressure
sensing
lines (December
11-21,
1988).
B.
Criteria
Licensee
performance
is assessed
in .selected
functional areas,
depending
on
whether the facility is in a construction,
preoperational,
or operating
phase.
Each functional
area
normally represents
areas
significant to nuclear 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:
6.
7.
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)
Staffing (including management),
and
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
',s being achieved.
Reduced
NRC at-
'tention
may be
appropriately
~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.
~Cate or
3.
Licensee
management
attention to and involvement in the perform-
ance of nuclear safety or safeguards
activities are not sufficient.
The lic-
ensee's
performance
does riot significantly exceed that
needed
to meet minimal
regulatory requirements.
Licensee
resources
appear to be strained or not ef-
fectively used'RC
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.
~Declinin
Licensee
performance
was determined
to be declining near the close
of the assessment
period
and the licensee
had not taken meaningful
steps to
address this pattern.
SD/D-3
II
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 neat
future.
For example,
a classification of "Cate-
gory 2, Improving" indicates
the clear potential for "Category
1" 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 matter s would be
dealt with independently
from,
and
on
a more urgent
schedule
than,
the
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
Pl nt Tri
s and Forced
Outa
es
Date
2/5/88
Power
Level
0%
Root
Cause
Personnel
Error
Functional
Area
Maintenance/
Surveillance
Descri tion
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
25%
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
system temperature
and
level
control problems.
SD/D-4
Date
Power
Level
Root.
Cause
Functional
Area
Descri tion
3/14/88
89
6/1/88
1 00/o
7/16/88
100/o
Personnel
Error
Component Failure
Component Failure
Maintenance/
Surveillance
Mainten'ance/
Surveillance
Maintenance/
Surveillance
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.
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
causing reactor coolant sys-
tem pressure
to drop.
A breaker
bushing failure
in the plant'
main sub-
station
caused
a loss of
normal offsite power.
The
bushing's oil level
was broken
and oil lev'el
decreased
causing internal
arcing
and subsequent
bushing failure.
- The plant
was
shutdown to effect re-
pairs to the substation.
1/21/89
48/o-'omponent
Failure
N/A
SD/D-5.
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 reactor
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 Each Severity Level
V
IV
III
II
I
Total
A.
Plant Operations
B.
Radiological Controls
C.
Maintenance/Surveillance
1
4
2
4
1
1
1
0.
Emergency
Preparedness
E.
Security
F.
Engineering/Technical
Support
1
1
G.
Safety Assessment/(}uality
Verification
5
H.
Other
Total
6
20
1
27
SD/D-6
E.
Ins ection Hour Summar
Functional
Area
Actual
Annualized
Hours
Percent
Plant Operations
~'adiological
Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/equality
Verification
Other
2517
229
802
103
187
311
202
508
1678
153
535
69
125
207
135
339
52
17
10
TOTAL
4859
3241
100
SD/D-7
F.
Licensee
Event
Re ort Casual
Anal sis
Functional
Area
Number
By Cause
Code
A
B
C
D
E
X
Total
Plant Operations
Radiological
Controls
1
4
Maintenance/Surveillance
Emergency
Preparedness
1
1
Securi ty
Engineering/Technical
Support
Safety Assessment/equality
Verification
Other
Totals
4
2
--
1
6
--
13
Cause
Codes
A Personnel
Error
B Design, Manufacturing, Construction
or Installation Error
C - External
Cause
D - Defective Procedures
E - Component Failure
X Other
SD/0-8