ML17262A798

SALP Rept 50-244/90-99 for 901001-920118.Performance in Emergency Preparedness Area Declined

ML17262A798
Person / Time
Site:	Ginna
Issue date:	04/01/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17262A799	List: IR 05000244/1990099 ML17262A798
References
50-244-90-99, NUDOCS 9204070124
Download: ML17262A798 (48)

See also: IR 05000244/1990099

Text

ENCLOSUIM 1

INITIALSALP REPORT

U. S. NUCLEAR REGULATORY COlVlIVfISSION

=REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE

PERFORMANCE

SALP BOARD REPORT 50-244/90-99

ROCHESTER GAS AI'6) ELECTRIC CORPORATION

R. E. GIIVNANUCLEAR POWER

PLY'SSESSMENT

PERIOD:

OCTOBER 1, 1990-

JANUARY 18, 1992

9204070l24

920401

PDR

ADOCK 05000244

8

PDR

TABLEOF CONTENTS

TABLE OF CONTENTS ............

~ ~.........................

i

NTRODUCTION

o ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

~

~

'

~

~

~

~

~

~

~

~

~

~

~

o

'1

I

II.

SUMMARYOF RESULTS

II.A

Overview

II.B

Facility Performance Analysis Summary

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

2

~

~

2

3

III.

PERFORMANCE'NALYSIS..........

III.A Plant Operations ..............

'III.B

Radiological Controls...........

III.C

Maintenance/Surveillance

III.D Emergency Preparedness.........

III.E

Security

- III.F

Engineering/Technical

Support

III.G

Safety Assessment/Quality

Verification

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

~

4

~

~

~

4

~

~

o

6

8

11

13

15

18

IV.

SALP EVALUATIONCRITERIA ........ ~...................

21

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.

SALP is supplemental to normal

regulatory processes

used to ensure compliance with NRC rules and regulations.

SALP is

intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources

and to provide meaningful guidance to the licensee management

to promote quality and safety

of plant operation.

This report is the NRC's assessment

of the licensee's

safety performance at the R. E. Ginna

Nuclear Power Plant for the period October

1, 1990 through January

18, 1992.

A NRC SALP Board, composed of the staff members listed below, met on March 5, 1992 to

review the collection of performance observations

and data to assess

the licensee performance

in accordance with Chapter NRC-0516, "Systematic Assessment of Licensee Performance".

The guidance and evaluation criteria are summarized in Section IV of this report.

The

Board's findings and recommendations

were forwarded to the NRC Regional Administrator

for approval and issuance.

Chairman:

C. Hehl, Dire'ctor, Division of Reactor Projects (DRP)

Members:

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

R. Cooper, Deputy Director, Division of Radiation Safety and Safeguards

(DRSS)

J, Linville, Chief, Projects Branch No. 3, DRP

T. Moslak, Senior Resident Inspector

W. Butler, Director, Project Directorate I-3 (PD I-3), Office of Nuclear Reactor Regulation

(NRR)

A. Johnson, Project Manager, PD I-3, NRR

II.

SUMIHARYOF RESULTS

II.A

Overview

RG&E management

continued to be substantially involved in monitoring routine activities,

supporting the development of several program initiatives, and promoting increased

engineering support to site activities.

These efforts have been successful in maintaining

performance at the levels noted in the previous SALP with improved performance in certain

- al'eas.

C

The plant continued to be operated in a safety conscious manner with operators appropriately

responding to plant challenges

and aggressive

management

involvement in the resolution of

operational events.

However, procedure inadequacies

and deficiencies in assessing

the

impact of certain maintenance

tasks on plant operations indicate the need for continued

attention-to-detail in the control of plant activities.

While improvements have been made in

this area, management involvement is needed to ensure plans for long term improvement are

effective.

The licensee has strengthened

the overall performance of the facility. Performance in the

areas of Maintenance,

Security and'Emergency

Preparedness

was superior.

Management's

commitment to sustained high quality performance was evident through support given to

program initiatives and hardware upgrades.

Notwithstanding, some concerns worthy of

additional management

attention were identified in emergency

response" training and staffing

depth raising questions regarding the support in that area.

Overall, a strong interface between operations and corporate'engineering

has expedited the

resolution of operational problems and the timely implementation of comprehensive

corrective actions.

Although progress was made in the Engineering and Technical Support

area, engineering assurance

deficiencies identified in addressing

Service Water System design

issues indicate continued management

attention is warranted,

Sound safety controls were established for the refueling outage to ensure availability of

residual heat removal and electrical distribution systems.

Management took a conservative

approach to emergent outage issues to minimize personnel dose and contaminations.

Radiological control and quality assurance

programs were conscientiously implemented with

improvements being made in the areas of monitoring and self assessment.

However,

deficiencies were noted in REMP QA/QC programs and laboratory technician training.

II.B

Facility Performance Analysis Summary

i

l

Rating, Trend*

- Rating, Trend**

1.

Plant Operations

2

2.

Radiological Controls

3.

Maintenance/Surveillance

4.

Emergency Preparedness

5.

Security

6.

Engineering/Technical

Support

2 Improving

2 Improving

1, Declining

7.

Safety Assessment/Quality

Verification

2

• June 1, 1989 to September 30, 1990

• October

1, 1990 to January

18, 1992

III.

PERFORMANCE -ANALYSIS

m.A

Plant Operations

III.A.1

Analysis

Plant operations was rated Category 2 in the previous assessment

period.

Past strengths

identified in this area included experienced professional operators,

excellent emergency

operating procedures,

and strong station management

involvement in dail'y plant activities.

Weaknesses

in procedure adherence

and independent verification of system alignments were

identified early in the assessment

period; however, improvements in these areas were noted

later in the period.

During this period, the licensee continued to demonstrate

a strong commitment to safe and

high quality operations,

Senior corporate and site management

were actively involved in

plant activities and promptly responded

to operational events.

This was demonstrated

by the

detailed investigation conducted 'by senior corporate management

into the causes for the

. temporary disabling of Engineered

Safeguards

instrumentation.

Management

developed,

comprehensive

corrective actions in response

to this event.

Actions included a quarantine of

suspect procedures

followed by a detailed review for any similar procedural inadequacies,

'and

modification of the procedure change process to require operational review by licensed

personnel.

Briefings were also conducted for each operating shift to emphasize

management's

expectations for operators to maintain a questioning attitude and stressing the

importance of attention-to-detail and thorough review before authorizing work.

Operator professionalism,

conduct of control room operations,

and response

to off-normal

plant conditions were excellent.

Immediate operator action following trips was appropriate.

Plant challenges that could have resulted in a reactor trip were met on several occasions by

prompt and decisive operator response,

Operators demonstrated

a sound understanding of integrated plant operations by quickly

identifying deficient conditions, such as feedwater flow disturbances

caused by electrical

interference from the diesel fire pump start circuitry. However, in one event concerning the

disabling of Engineered

Safeguards

instrumentation, the operators performance in identifying

deficient conditions was mixed.

Although the shift supervisor demonstrated

a questioning

attitude and understanding of the plant, the control room foreman who was implementing the

procedure lacked sufficient guidance and understanding

to assess

the'impact of the use of the

procedure on plant operations.

Procedure adherence

and independent verification of system alignments significantly

improved during the period.

New administrative procedures

were developed

and site-wide

training was effective in these areas.

Operators consistently followed procedures.

Plant housekeeping

continued to be excellent throughout this assessment

period.

During the

outage, supervisors consistently ensured that loose material was expeditiously removed from

job sites after work completion and that the formalized housekeeping

program was

implemented.

In addition to personnel conscientiously keeping the shop and plant areas clean

and orderly, management

instituted a vigorous painting program to brighten various plant

areas,

These efforts resulted in significant improvements in plant appearince.

During the outage, site control of plant activities was excellent.

While in reduced coolant

inventory conditions, management briefed personnel on potential challenges to plant safety

and deferred several activities to ensure the reactor coolant system level would not be

perturbed and safety equipment availability would not be impacted.

The operator training program was satisfactory.

During the initial operator licensing

examination, all five senior reactor operator candidates

and three reactor operator candidates

passed the exams.

During the requalification examination, two reactor operators

and three of

five senior reactor operators passed

the exams.

There were no crew failures,

The

Requalification Program was not evaluated due to the limited number of individuals fess than

12) examined.

Examination materials developed by the Training Department were well

developed and maintained.

The various plant departments

and Training Department worked closely together.

Operators

were promptly trained on plant modifications such as the Advanced Digital Feedwater

Control System (ADFCS) and the zebra mussel control measures.

Training materials were

promptly updated

as a result of strong communications between plant departments

and the

training organization.

The curriculum committee was effective in assuring that personnel

were receiving pertinent subject matter with the appropriate level of detail.

Involvement by

the training organization in daily plant planning meetings and the use of a computerized

networking system to respond to inquiries and suggestions

affecting training also enhanced

the timeliness of improving training material.

Inappropriate operator action on two occasions

led to degraded

safety system conditions.

The cause of the first, involving the deenergization of vital bus 18 while performing a

routine monthly emergency diesel generator load test, was not readily apparent.

Management directed corporate engineering to extensively evaluate the event.

The probable

cause was attributed to an operator prematurely closing the generator output breaker before

synchronization.

Issues developed in this evaluation were thoroughly reviewed and

adequately resolved by the Operations and Training Departments.

The second event, which

occurred during the outage, involved temporarily removing the Residual Heat Removal

System from service to stop a Component Cooling Water System valve packing leak which

developed during valve maintenance.

In response,

management initiated a human

performance evaluation to identify the root cause and establish corrective actions.

The cause

was found to be unclear communications between the operations and maintenance

departments

that resulted in the valve being electrically backseated

instead of manually

backseated

prior- to maintenance.

Both events were of short duration.

The licensee

responded

appropriately and quickly restored plant equipment to service.

$gm~m~

Overall, the plant was operated safely as indicated by appropriate operator response

to plant

challenges,

a reduction in the number of reactor trips, and aggressive

management

involvement in the resolution of operational problems.

However, procedure inadequacies

and

deficiencies in assessing

the impact of certain maintenance

tasks on plant operations indicate

the need for continued attention-to-detail in the control of plant activities.

Excellent

housekeeping

was the direct result of conscientious worker practice and management

support.

A strong interface between the Operations Department and corporate engineering expedited

the root cause analysis proqess and the implementation of corrective actions.

Operator

training reflects close interdepartmental

coordination, ensuring that personnel are provided

effective training on plant modifications.

Performance Rating:

Category 2

III.B Radiological Controls

Analysis

The Radiological Controls area was rated Category 2 in the last assessment.

Strengths

included responses

to audit and inspection findings and ALARAreviews of routine and

modification work.

Weaknesses

were noted in staffing, supervisory oversight of field

activities, quality assurance

in the Radiological Environmental Monitoring Program (REMP),

training, posting and updating surveys of the plant, and communications between Radiation

Protection (RP) personnel.

The SALP board commented that the- fillingof Radiological

Controls vacancies

and assuring the effectiveness of training programs for health physics and

environmental laboratory technicians were areas for improvement.

A well defined and staffed RP organization was in place at the end of the assessment

period.

Complete staffing of the RP organization resulted in the correction of several weaknesses

including improved posting and updating of surveys, and improved communications within

the Radiation Protection Organization.

During the last assessment

period a decline in the

quality of oversight of field work was caused by the loss of RP management

personnel and a

shortage of permanent RP technicians.

To address

this weakness,

Rochester

Gas and Electric

(RG&E) augmented

the RP Organization with the addition of a Health Physicist position and

eight RP Technician positions.

During this assessment

period the licensee hired qualified

personnel to fillthese newly created positions.

Several programmatic improvements resulted

from the increased

staffing levels, including the appointment of Lead Technicians and a

Quality Improvement Specialist.

The RP Technician training program showed improvement since the last assessment

period

and is now considered to be a strength.

An excellent training program on the radiological

.hazards of specific systems was initiated for new RP Technicians.

'An additional RG&E

initiative involved inco'rporating the systems training lesson plans into the continuing training

for all permanent RP Technicians.

The training program for contractor RP technicians is

also considered to be strong.

Enhanced RP training was given to decontamination

technicians in an effort to improve work

practices.

Preliminary review of the program indicated that the decontamination

technician

training was effective and is considered

a good program initiative.

'G&E's

ALARAprogram continued to effectively reduce annual personnel exposures.

Notwithstanding significant high exposure challenges, RG&E continued to maintain

cumulative annual exposures ALARA. A strength in this area continued to be the effective

use of mock-ups prior to high exposure jobs.

RG&E restructured

the ALARAorganization

with dedicated staffing.

This resulted in an effective organizational structure for

implementation of the ALARAprogram.

The ALARAgroup was actively involved in

testing new equipment,

such as the insulation removal and transfer system used in radiation

areas.

The ALARAarea is considered

to be another program strength.

RG&E's program for assurance of quality is considered to be generally sound with some

areas in need of improvement.

An effective program was in place for tracking and assuring

appropriate followup of RP program weaknesses.

A weakness

was noted which indicated

that improvement was needed in the area of management

review of procedural changes.

For

example, a surveillance requirement specified in the technical specifications was omitted

from a ventilation testing procedure during a procedure. revision.

Subsequent

management

review of the procedure revision did not identify the omission.

Similar examples were noted

in controls of revisions to plant operations procedures.

Another area of weakness

involved

the lack of sufficient technical QA review in environmental laboratory audits which is

discussed

below.

The resolution of technical- issues from a safety standpoint by the station staff is considered

to be generally effective.

Management attention to reducing the number of personnel

contaminations and minimizing.dose was excellent.

RG&E's evaluation and corrective

actions for an operational event involving a leaking secondary

source was also considered

to

very good.

However, RG&E's identification and resolution of some technical issues were

not performed in a timely manner.

These issues included evaluating the adequacy of the

certification of personnel dosimeters

used during power entries, source checking of neutron

survey meters and area radiation monitors,

and in-place testing of HEPA filters.

RG&E's program for processing

and transporting radioactive material is considered very

.

good.

The licensee implemented several initiatives in the radwaste program.

The initiatives

included upgrading the radwaste handling and transportation procedures,

having a consultant

evaluate the program and make recommendations

for improvements,

and completing an

b

8

extensive effort to remove all excessive radioactive material from the site.

RG&E had an

effective program for training individuals involved in the radwaste and transportation

program.

Supervisory oversight of this area was also considered very good.

During the previous assessment

period weaknesses

were identified in the REMP laboratory

QC program and REMP laboratory technician training.

These weaknesses

continued.

As of

the last inspection, the REMP laboratory technician was not qualified to independently run

the REMP laboratory and received little supervisory oversight in this position.

A new

individual was appointed to this position later in the assessment

period.

QA audits of the

REMP focused on administrative rather than technical aspects of the program and, therefore,

did not probe for technical weaknesses.

Technical weaknesses

were identified in REMP

analytical procedures by the NRC but not by the licensee's QA Department.

In contrast, however, the licensee's radioactive liquid and gaseous effluent control program

was effectively implemented.

Well written procedures

combined with an effectively trained

staff resulted in good procedure adherence,

and release permits met the TS requirements for

sampling and analysis.

The licensee's

upgrading of the radiation monitoring system was

noteworthy and excellent;

grimm~

Staffing of the RP organization improved during the assessment

period and is now considered

to be appropriate.

The training program showed improvement and is considered to be strong

,with the exception of training in the environmental monitoring area.

RG&E's ALARA

program continued to effectively reduce annual personnel exposures.

RG&E's program for

assurance of quality is considered

to be generally sound with continued weakness

in the

REMP laboratory QA program.

The resolution of technical issues from a safety standpoint

by the station staff is considered

to be generally effective.. RG&E's program for processing

and transporting radioactive material is considered very good.

The licensee's radioactive

liquid and gaseous effluent program was well implemented.

Performance Rating:

Category 2

III.C Maintenance/Surveillance

Analysis

During the previous SALP, Maintenance/Surveillance

was rated Category 2, Improving. The

assessment

determined that maintenance

and surveillance activities were well planned,

and

capably performed.

Corporate and site management

actively supported

a strong maintenance

program.

Maintenance procedure upgrading and development of a reliability centered

maintenance

approach were positive initiatives.

Problems were noted in the area of

- procedural adherence;

however, progress was noted later in the SALP period.

Mi

nn

Overall, maintenance activities were effective in supporting the safe and reliable operation of

the plant.

This effectiveness

was evident by a decrease in forced shutdowns and reduced

challenges

to plant safety systems.

Corporate and site management actively monitored

routine maintenance activities and strongly supported programmatic initiatives to assure high

reliability of plant systems.

Development of a reliability centered maintenance program has

steadily progressed

to improve preventive maintenance effectiveness.

State-of-the-art

diagnostic techniques,

such as infrared thermography, were routinely used as predictive

maintenance

tools.

The planning of daily and weekly preventive/corrective

maintenance

activities continues to be thorough.

During the refueling outage, management effectively

controlled contracted activities.

A highly trained, stable work force continued to be a major strength of the maintenance

organization,

Past training program weaknesses

were adequately

addressed.

Th'e licensee

maintained a rigorous maintenance training program that incorporated'a technician annual

refresher program, consolidated health physics team training, and recent plant modifications.

Training was enhanced

through the extensive use of mock-ups, including cut-away electrical

breakers,

full-size steam generator lower shells, motor operated valves, and assorted

valve/piping manifolds.

The licensee continued to shift to a more hands-on approach

to

maintenance training from the traditional classroom descriptions of task performance.

This

training, combined with low technician turnover and adequate

staffing, resulted in an

effective maintenance work force.

Priority maintenance work load was well controlled and remained low. The overall backlog

increased slightly as a result of scheduling more preventive maintenance

tasks to support the

reliability centered

maintenance program.

Appropriate management

attention was given to

the effort through increased staffing.

The rework rate remained low.

The licensee made good progress in the upgrade of maintenance procedures,

Recently issued

upgraded maintenance

procedures

were comprehensive

and consolidated within'the body of

the procedure acceptance

criteria and vendor technical manual data and illustrations.

Tasks were consistently well planned, controlled, and coordinated through a formalized work

control system.

Work packages

were well prepared by the maintenance

planner, with

relevant acceptance

criteria identified in the governing maintenance procedure,

supporting

work instructions, or associated

quality control procedures.

Pre-job and post-job briefings by

maintenance

foremen were well conducted.

Post maintenance

testing was systematically

performed.

However, documentation within the work package of the as-found and as-left

'quipment

condition was generally brief, providing limited feedback information for the

maintenance

analyst during subsequent review.

10

Procedure revisions and subsequent

training proved to be effective in improving procedure

adherence

and independent verification of system configuration.

The implementation of an

inadequate corrective maintenance procedure that led to the temporary disabling of

~

Engineering Safeguards

instrumentation was an isolated event, resulting from an oversight in

the pre-PORC procedural review process.

Although this event was important, it did not

reflect a'programmatic breakdown.

An extensive quarantine of suspect procedures

and

subsequent review identified no similar inadequacies.

The maintenance organization demonstrated

an excellent capability to assess

and resolve

several emergent plant equipment problems.

In addition to completing repairs to aging

service water system components,

the licensee demonstrated

the ability to effectively analyze

and correct emergent problems while maintaining a sound safety perspective by resolving rod

control system malfunctions and promptly identifying undervoltage monitoring system circuit

card design deficiencies.

The overall material condition of equipment and systems was well maintained.

Age-related

wear contributed to a degraded

material condition for certain compo'nents in the service water

system.

The licensee was appropriately addressing

these plant aging concerns.

A Service

Water System Reliability Optimization Program was established

that will systematically

replace aging containment air coolers, fan motor coolers, and assorted

service water system

valves/piping during future outages.

Qurve~ill

ncaa

The overall surveillance program continued to be effective in verifying the operability of

safety related equipment and satisfying Technical Specifications.

Surveillances were

performed on schedule,

were adequately

documented,

and testing deficiencies were properly

dispositioned.

Test results were trended for each component tested to detect degradation.

Surveillance procedures

were clearly written containing precautions,

acceptance

criteria, and

specific responsibilities of test personnel. L'icensee control of surveillance testing was very

good.

Procedures

were adhered to and expeditiously performed to minimize system

unavailability.

Following surveillance testing, independent verification of system realignment

ensured proper equipment restoration.

Sum~mry

In summary, maintenance activities were effective in supporting the safe and reliable

operation of the plant.

Steady progress

was made in the maintenance procedure upgrade

program and reliability centered maintenance program, with new procedures

and diagnostic

methods being implemented.

Management continued to strongly support and closely monitor

maintenance activities.

Plant material condition was well maintained and equipment aging

concerns were adequately being addressed.

Surveillance testing was well planned and

conscientiously carried out.

III.C.2

Performance Rating:

Category

1

11

III.D Emergency Preparedness

III.D.1

Analysis

During the previous SALP, Emergency Preparedness

(EP) was rated Category

1.

There was

noteworthy management involvement, good training, excellent exercise performance,

and a

good relationship with the State and surrounding counties.

In the November 1990 partial-participation exercise,

degrading plant conditions were readily

recognized by licensee personnel.

Positive interactions were noted among members of the

Emergency Response

Organization (ERO).

The NRC identified a weakness in timeliness of

Protective Action Recommendations

(PARs), but overall performance showed the ability to

protect public health and safety.

During the September

1991 full-participation exer'cise,

degrading plant conditions were again readily recognized.

Use of the plant simulator during

'his

exercise was a positive and productive initiative to improve training realism.

Licensee

accide'nt assessment

during the exercise demonstrated

sound technical knowledge of the plant.

Emergency classifications were timely and conservative.-

The licensee corrected the previous

exercise weakness

concerning timeliness of PAR issuance.

For both exercises,

the licensee's

post-exercise critiques were thorough.

Overall, emergency exercise performance was

proficient.

For the November 1990 exercise,

the as-submitted

scenario lacked detail in areas

such as

anticipated actions of ERO personnel,

trending analysis of key reactor parameters,

and off-

site monitoring data.

Corrections were made before the exercise.

For the September

1991

exercise,

the submitted scenario exhibited improved quality of presentation

and technical

content.

During this period, two plant events required emergency plan activation.

Each was quickly

recognized and properly classified as an Unusual Event.

In response,

site management

demonstrated

a conservative,

safety-conscious

approach.

Effective event response

was also

demonstrated

when a severe ice storm swept through Wayne and Monroe Counties in March

1991.

Because of extensive damage to transmission lines and power distribution equipment,

the counties activated their Emergency Operation Centers (EOCs).

Licensee personnel

manned EOC stations to coordinate power restoration.

The licensee quickly determined that

the siren system was to be considered unreliable because of storm damage.

To compensate,

local fire department and law enforcement personnel were briefed by EP personnel on Route

Alert measures

to be implemented in a nuclear emergency.

This licensee response

showed

proficiency and competence in responding to a non-nuclear off-site event.

Emergency response facilities were well maintained.

Administrative and emergency

response

procedures

were generally well written. The licensee's

10 CFR 50.54(t) audit was

appropriate in scope and content.

Audit results were provided to state and county officials.

12

Corrective actions were generally prompt and effective, but findings were maintained within

two separate

tracking systems.

During the transition to a single tracking system, some minor

items were not carried over into the new system.

NRC review of the Technical Support Center (TSC) ventilation system noted an inability to

tell whether the system had shifted to the accident (recirculation) mode.

The licensee

initiated a review to establish the best method of doing so.

The NRC found that on-shift personnel lacked the capability of performing dose assessment

'or

a postulated

steam generator tube rupture.

Other licensee personnel had that capability,

but they were not always promptly available, and the licensee's ability to properly classify

some events was impacted.

The cause appeared

to involve procedure and training

inadequacies.

The licensee took timely action to implement an appropriate interim procedure

and additional training.

The EP program, on-site and off-site, was administered by the Director, Corporate Radiation

Protection.

Two full-time people with technical backgrounds were assigned

to maintain the

emergency plan and its implementing procedures,

conduct drills and exercises,

ensure

readiness of emergency

response facilities and equipment, and interface with off-site support

groups.

Management participation was evident by maintenance of ERO qualifications and

participation in drills and exercises.

NRC contact with one county identified satisfaction with

the licensee interface,

However, the following weaknesses

were identified:

the emergency

'lan

did not fully reflect the current program; there were several months in which the

equipment inspection and the pager test logs were not documented;

some discrepancy

corrective actions were not reviewed; and drill/exercise records lacked formality and

consistency,

Overall; NRC review found good program performance, but minor weaknesses

in administration and management.

EP training, except dose and core damage

assessment,

was the responsibility of the Training

Department.

However, rather than provide-training in EP throughout the year, and thus

enable continued familiarity with the emergency plan and.its implementing procedures,

essentially all EP training was completed within a two-month window prior to the September

1991 exercise.

After considering the potential contribution of more frequent and regular EP

training, Rochester

Gas and Electric Company initiated action to revise the training cycle.

All ERO positions were filled at least three deep, but some key managers

were assigned

more than one ERO job.

Long-term ERO staffing was therefore potentially strained.

The

licensee stated the intention of qualifying more individuals in ERO positions.

Course requirements

necessary

to satisfy each ERO position were subject to management

review and approval.

Lesson plans for ERO training were excellent.

Reactor operators

received classroom

and simulator training in accident classification, off-site notification and

PAR development.

A noteworthy initiative was the-use of mock-ups for drills and exercises.

13

The training program was well-defined and, except for on-shift dose projections, provided an

excellent contribution to emergency preparedness

effectiveness

as demonstrated

by the overall

proficient performance during exercises,

actual events, and walk-throughs.

In summary, the licensee effectively responded

to actual events and to exercise scenarios.

Procedural and training weaknesses

were found during follow-up of on-shift inability to

assess

potential dose consequences,

but procedures were otherwise very good and training

was otherwise very effective.

Considerable licensee effort was expended on the working

relationshipwith the State and the county authorities, and effective results were indicated.

NRC review identified several weaknesses

in program administration and management,

but

the licensee's ability to protect public health and safety was maintained.

III.D.2

III.D.3

Performance Rating;

Category

1, Declining

Board Comments:

The board was concerned that program support had

degraded

resulting in the identified weaknesses.

III.E

Security

III.E.1

Analysis

During the previous SALP period the licensee's performance was rated as Category 2,

Improving. This was based on the licensee's

implementation of an effective and sound

security program and taking steps to upgrade and enhance the program.

However,

weaknesses

in auditing, deficiency correction, and lesson plans detracted from the

effectiveness of the program.

During this SALP period, the licensee exhibited a,strong commitment to improve the

program further.

This was most notable in the significant ongoing upgrades

and

enhancements

of systems and equipment, in particular, commencing replacement of the

perimeter intrusion detection system.

The licensee also completed modifications of the

security access control facility that included a third new explosives detector, new hand-held

metal detectors,

and a redesigned

search area.

Other upgrades included the perimeter barrier

and the assessment

system, and the purchase of a new security computer system, which was

being assembled

at the end of this assessment

period.

In addition, plant and corporate

security management

personnel remained active in organizations involved in nuclear plant

security matters.

These significant commitments of capital improvements and involvement

are indicative of management's

interest in and support of an effective security program.-

During the period, the security force was responsive to potential challenges.

For example,

following a lightning strike that disabled a number of high mast lights, corrective measures

were rapidly initiated to ensure that site security could not be compromised.

The licensee

also implemented appropriate increased

security measures

during the Persian Gulf conflict.

k

tI

14

Licensee oversight of the contract security force continued to be effective.

Members of the

security force exhibited a professional demeanor,

high morale, and were knowledgeable of

their duties,

Staffing of the security force was consistent with program needs,

as indicated

by maintaining an effective security program with the minimal use of overtime. The"

turnover rate was significantly below national average.

The licensee's training and requalification program was well developed and effectively

administered,

as evidenced by a minimum of personnel errors.

Security training personnel

completed several instructor courses and provided feedback into the Security Officer Training

Program for the enhancement of all officers.

Additionally, the weaknesses

in the lesson

plans identified during the last SALP period were effectively corrected.

The lessons learned

during day-to-day program implementation were being incorporated into the formal lesson

plans.

During the annual emergency preparedness

exercise several scenarios

that challenged the

security force were incorporated, including responding to an uncontrolled discharge of a

flammable material and the seizure of a nonvital area by a disgruntled employee.

The drill

scenarios

were realistic, well developed and were conducted in a professional manner.

The

post-drill critiques also provided meaningful training for the security force.

The exemplary

performance of the security force during the drill reflected an effective training and

qualification program.

The licensee improved its annual security program audit by engaging independent security

consultants to evaluate overall program performance.

The audit was comprehensive

in scope

and depth; management's

corrective actions in response

to the audit findings were prompt

and effective.

The licensee also developed and implemented a formal surveillance program

during this period- to monitor the day-to-day operation of the security program and force.

In

addition, improvements were made in the tracking of equipment deficiencies to effect more

timely repairs.

The licensee's Fitness-for-Duty (FFD) program was reviewed during the assessment

period.

Although some minor problems were encountered

during the initial implementation of the

program, these were rectified promptly and the licensee was found to be responsive to the

spirit and intent of the rule.

The licensee's security event reporting system and procedures

were found to be well

understood and consistent with the NRC regulations.

No event occurred that required a one-

hour report, indicating a strong and effective program.

Loggable events were appropriately

tracked and corrective actions were timely and effective.

Under the provisions of 10 CFR 50.54(p), the licensee submitted one revision to the Training

and Qualification Plan, and one complete revision and two minor revisions to the Physical

Security Plan.

The revisions were technically sound and demonstrated

a thorough knowledge

and understanding of NRC requirements

and security objectives.

15

$ymrpgry

The licensee continued to implement improvements in an effective and performance-oriented

security program.

Management attention to and support of the program were clearly evident

by the significant commitment of capital improvements for upgrades and enhancements

in

systems, equipment and the training of personnel.

The efforts expended to improve an

effective program during this period are commendable and demonstrated

the licensee's

commitment to a high quality security program.

III.E.2

Performance Rating:

Category

1

III.F

Engineering/Technical Support

III.F.1

Analysis

In the last SALP, performance was rated Category 2 in this functional area.

Improvements

were noted in the corporate and site engineering interface on major modifications, timeliness

of work packages,

decreased

major modification backlog, and safety analyses

content.

Competency of the engineering staff and the commitment to a large configuration

management

program were also noted.

The last SALP also noted weaknesses

in overall

engineering assurance

practices.

During the current assessment

period, site and corporate engineering support was evident for

day-to-day plant operation.

Participation of corporate engineers at plant daily meetings and

the effective and widespread

use of a computerized network enabled corporate engineering to

quickly respond to safety concerns and support the site in identifying root causes

and

resolving safety-related component failures.

Examples of good engineering support included

the evaluation and technical justification for the acceptability of an elongated

steam generator

manway stud,

resolving the cause of a vital bus deenergization during a surveillance test,

and the well prepared root cause analyses of the recent "A" service water pump motor

failure.

Other good examples were the comprehensive

root cause analysis of a failed pipe

hanger supporting moisture separator reheater drain lines, the identification of a circuit card

design deficiency in the Anticipated Transient Without Scram (ATWS) Mitigating System

Actuation Circuit, and resolution of the cause of electrical interference in the feedwater

control system.

Reviews of recently completed modification packages

showed they were well planned and

exhibited good safety perspectives

and responsiveness

to site needs.

The advanced digital

feedwater control system effort displayed excellent engineering planning, effective

communications throughout the organization, strong engineering and continuous management

oversight.

In performing extensive instrument upgrading for the feedwater system,

engineering initiative was evident in the development of predesigned

tubing and instrument

supports and the development of the generic spacing of varied tubing sizes.

Other significant

16

modifications that were thoroughly prepared and effectively performed were the seismic

upgrading of the diesel generator air start system, replacement of pressurizer insulation,

installation of chlorination equipment in the service water system, and upgrading of the

radiation monitoring system.

Coordination of the steam generator tube sample removal to

study fouling also showed good engineering.

The engineering evaluation, which led to expansion of the erosion/corrosion (E/C) program

and the inclusion of small bore piping into the program, following the rupture of a turbine

casing drain line reflected a commitment to personnel

safety.

Effectiveness of the E/C

program continued to be demonstrated

as shown in the replacement of two and the repair of

five components during the 1991 outage.

Outage planning and the control of modifications during outages continued to be a licensee

strength.

Engineering played a major role in this success

by thorough advance planning and

continual attentiveness

throughout the project completion.

Engineering support was notable

in the unplanned replacement of the service water discharge valves and piping elbows for

both component cooling water heat exchangers.

The engineering department actively responded

to the prior SALP concern regarding overall

engineering assurance

by developing a comprehensive

engineering process upgrade program

dedicated to improving engineering performance.

An objective engineering self assessment

pointing to many areas in need of, improvement followed by an independent contracted study

formed the basis of the program.

The program has management

approval, but its

implementation began late in the assessment

period and its effectiveness

could not yet be

evaluated.

Improvements in the design modification process and quality of root cause, corrective

actions, and calculations were noted during NRC review of the electrical distribution system.

However, the NRC review of the service water system performed late in the assessment

period identified a number of concerns related to engineering support.

These concerns

.

included instances of inappropriate engineering review and use of non-controlled calculations,

instances where prior testing was not compared to current system configuration, incomplete

testing verification of current system configuration, and discrepancies

in the Updated Final

Safety Analysis system description.

Because the service water issues were identified late in

the assessment

period, their evaluation is presently in process.

These findings point to

weaknesses

in engineering support of service water issues.

The piping and instrument drawing upgrade, completed the past assessment

period, was

further enhanced by a new drawing change request methodology and tracking system that has

made the drawing change process

more effective.

An extensive in-house structural

arrangement drawing upgrade and reformatting was just completed and provided accurate

portrayals of existing plant equipment.

The relatively unchanged

engineering work request

backlog is appropriately reviewed and prioritized.

Paperwork closeout delays are being

addressed.

17

The engineering approach to design bases document (DBD) reconstitution was underway.

Preliminary work on three pilot DBDs led to a massive electronic indexing of all Ginna

licensing documents, attachments,

and calculations.

The electronic indexing of all prior

Ginna licensing data, combined with the capability to recall information was a creditable

engineering accomplishment.

There is active participation with the Westinghouse owners

group effort that has three systems nearing completion.

The configuration management

program commitment is to complete system and topical DBDs by the end of 1994.

Engineering participation in licensing matters continued to be strong and engineering keeps

abreast of current and anticipated actions and resolution of issues from a safety perspective.

High quality submittals with good engineering bases enabled recapture of construction= time

and extended the operating license.

High quality finite element analyses

and seismic

modeling facilitated the containment structure verification that the existing pre-stress

continues to meet origi'nal design requirements.

Submittals of post accident response

instrumentation safety evaluation issues and responses

to the probabilistic risk assessment

generic letter were timely and demonstrated

competent engineering.

Overall, engineering

support of licensing has been excellent.

Recent additions of qualified and experienced

engineering personnel were beneficial as

evidenced by the work done in-house on probability risk assessment,

the comprehensive

equipment Q-list, and the widespread availability and use of electronic databases.

The

technical competence of engineering personnel noted in prior SALPs continues to be a

licensee strength, and effective support of day to day plant problems has-contributed

to

continued high plant availability.

j

In summary, engineering during this assessment

period was effective in support of plant

operations, evaluation of problems, and determination of root causes.

Modifications were

well planned and implemented and exhibited good initiatives and safety perspectives.

Engineering support was also strong when unplanned equipment replacement

was needed.

Support of licensing has been excellent..Management

dedicated considerable

resources

to

improve engineering performance and recent staff additions benefitted the organization.

The

results of major inspections were mixed with strengths observed in the engineering support of

electrical distribution system and weaknesses

in the engineering support of the service water

system.

Continued drawing upgrades reflected good engineering;

and, DBD efforts were

underway.

III.F.2

Performance Rating:

Category 2

il

18

III.G Safety Assessment/Quality

Verification

III.G.1

Analysis

During the previous SALP, Safety Assessment/Quality

Verification was rated Category 2.

Programmatic improvements in administrative controls and engineering depth were made

within the Quality Performance organization.

Quality assurance

was more effectively used as

a management

tool.

Self-assessment

concerns

needed to be tracked to completion.

H

During the current SALP period, management

support and participation in licensing matters

continued to be strong and the licensee continued to keep abreast of all current and

anticipated actions that could impact plant operations.

The licensee continued to make

changes

to plant programs, adjust corporate and plant organizational structure, and align

corporate management

to better focus on problem areas identified in previous SALP periods.

New engineering and professional staff were added to augment the corporate and plant

organization.

The goals and commitment to safety were promulgated by senior corporate"

officers,

Management and plant personnel demonstrated

the ability to be constructively self-

critical of their programs.

Several proposed amendments

to the facility operating license were of high quality.

These

proposed amendments

indicated a safety'onscious

attitude and resulted in timely issuance.

Examples included the extension to the Ginna operating license to recapture the construction

period, a reformat of technical specifications,

and an addition to technical specification

requirements.

The licensee's

resolution of generic issues was good.

Recent revisions to the Ginna Inservice

Inspection gSI) and Inservice Pump and Valve Testing /ST) Programs demonstrated

a

thorough understanding of codes and regulations,

The licensee's

resolution of issues

contained in NRC Generic Letters, Bulletins and Information Notices were timely and

reflected effective prioritization of work.

Several voluntary, safety-related improvements demonstrated

a safety conscious attitude.

Two

sources of preferred power through two independent

station transformers from the offsite

transmission network were completed.

Human factor improvements in the control room-

were implemented during the refueling outage.

4

10 CFR 50.59 safety reviews were technically sound, thorough and well documented.

The

annual

10 CFR 50.59 reports were timely and complete.

A major modification, which was

indicative of the licensee's

thorough safety reviews, was the installation of an Advanced

Digital Feedwater Control System (ADFCS). The licensee's safety evaluation supporting this

modification was particularly detailed and addressed

the potential challenges to the Reactor

Protection System by component failures in the original analog feedwater control system.

19

The Nuclear Safety Audit and Review Board (NSARB) effectively provided an oversight role

by periodically reviewing the activities of the Plant Operations Review Committee (PORC),

reviewing plant events and evaluating the adequacy of the QA program.

During this SALP

period, NSARB effectiveness,has

been enhanced by including an independent consultant and

a representative

from another utilityas board members.

In general, the PORC provided strong decisive control for assuring that quality procedures

and safety reviews were developed.

During meetings, priorities were established,

discussions

were candid and thorough, and final committee approval was consistently based on

satisfactory resolution of pertinent safety issues.

One significant event, however, occurred

as

a result of an inadequate review of a maintenance procedure.

This inadequate review

resulted in the inadvertent disabling of the safeguard logic instrumentation.

Subsequently,

stronger controls revising plant procedures

were implemented.

The Licensee Event Reports (LERs), which were submitted by the licensee, were well

written and submitted in a timely manner.

AllLERs issued gave appropriate attention to

discussion of root causes,

safety significance of events,

and corrective actions.

f

The licensee has initiated several enhancements

to the corrective action process.

These

changes included improved guidance in the corrective action procedures,

development of a

formalized root cause analysis process and implementation of a computerized corrective

action tracking system.

In general, the licensee's identification of deficiencies, corrective actions and root cause

determinations were effective.

Notable examples included the circuit card design deficiencies

for the Undervoltage Monitoring/Protection System and the ATWS Mitigation System

Actuation Circuitry. In contrast, quality assurance

deficiencies were identified in the control

of engineering processes

with regard to the Service Water System design and operation.

Additionally, the identified weaknesses

in the REMP QA/QC programs during the last SALP

period continued into this period.

These deficiencies indicate that continued management

attention in quality assurance

is warranted.

Management's

use of the Quality Performance Department enhanced plant performance.

During quarterly QA/QC subcommittee meetings, which were attended by senior corporate

and site management,

the results of audits, the findings of the quality assurance

surveillances,

and details surrounding recent plant experiences

were critically discussed.

A general

indication of plant performance was provided to management

based on the number of

initiated audit finding corrective action reports, field change requests,

maintenance work

requests,

nonconformance

reports, and corrective action reports.

20

/yamry

Senior management

was actively involved in technical issues which ensured

a high quality of

licensee support performance.

Management at all levels was closely, involved in the

operation and maintenance of the plant.

Operational decisions were made on the basis of

safety implications.

10 CFR 50.59 safety reviews were detailed and thoroughly documented,

The Nuclear Safety Audit and Review Board provided an effective oversight role of the plant

activities and the PORC.

Although PORC was generally effective in their reviews,

procedure revisions and safety evaluations,

an inadequate procedure review resulted in the

disabling of safeguards

logic instrumentation.

The Quality Performance Department refined

its assessment

method which resulted in an improvement in effectiveness.

Quality assurance

weaknesses

in controlling engineering processes

and in the REMP indicate the need for

continued management

attention.

1

III.G.2

Performance. Rating:

Category 2

t

IV.

SALP EVALUATIONCRITH(IA

21

I

t

Licensee performance is a'ssessed

in selected functional areas,

depending on whether the

facility is in a construction or operatio'nal phase.

Functional areas normally represent

areas

significant to nuclear safety and the environment.

Some functional areas may not be assessed

because of little or no licensee activities or lack of meaningful observations in that area.

Special areas may be added to highlight significant observations.

The following evaluation criteria were used, as applicable, to assess

each functional area:

Assurance of quality, including management

involvement and control.

2. 'pproach

to the identification and resolution of technical'issues

from a safety

standpoint.

3.

Enforcement history.

4.

Operational and construction, events (including response

to, analysis of, reporting of,

and corrective actions for)..

5.

Staffing (including management).

6.

Effectiveness of training and qualification programs,

The performance categories

used when rating licensee performance are defined as follows:

Qataggr ~1

Licensee manag'ement

attention to and involvement in nuclear safety or

safeguards

activities resulted in a superior level of performance.

NRC will consider reduced

levels of inspection effort.

Q~g~ry 2

Licensee management

attention to and involvement in nuclear safety or

safeguards

activities resulted in a good level of performance.

NRC will consider maintaining

normal levels of inspection effort.-

C~tggg~

Licensee management

attention to and involvement in nuclear safety or

safeguards

activities resulted in an acceptable level of performance; however, because of the

NRC's concern that a decrease

in performance may approach or reach an unacceptable

level,

NRC willconsider increased

levels of inspection effort.

Insufficient information exists to support an assessment of licensee

performance.

These cases would include instances-in which a rating could not be developed

because of insufficient licensee activity or insufficient NRC inspection.

22

The SALP Board may assess

a performance trend, ifappropriate.

The trends are:

Lmmr,itin'icensee

performance was determined to be improving during the assessment

period.

~Dli~in

Licensee performance was determined to be declining during the assessment

period and the licensee had not taken meaningful steps to address

this pattern.

Trends are normally assigned

when one is definitely discernable and a continuation of the

trend may result in a change in performance during the'ext assessment

period.