ML17262A877

Final SALP Rept 50-244/90-99 for Oct 1990 - Jan 1992

ML17262A877
Person / Time
Site:	Ginna
Issue date:	01/18/1992
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17262A876	List: ML17262A875 ML17262A877
References
50-244-90-99-01, 50-244-90-99-1, NUDOCS 9206090262
Download: ML17262A877 (48)

See also: IR 05000244/1990099

Text

ENCLOSUIUK1

I

FINALSALP REPORT

U. S. NUCLEAR REGULATORY COIVllVHSSION

REGION I

SYSTEMATIC ASSESSMENT OF LICENSEE

PERFORMANCE

FINALSALP REPORT 50-244/90-99

ROCHESTER GAS AND ELECTRIC CORPORATION

R. E. GIJI'WA NUCLEAR POWER PLANT

r

ASSESSMENT. PERIOD: OCTOBER 1, 1990-

JANUARY 1S, 1992

9206090262

920604,

PDR

ADOCK 05000244

8

PDR

1

TABLEOF COXH~PlTS

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

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INTRODUCTION,...'

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SUMMARYOF RESULTS .'...........

II.A

Overview

II.B

Facility Performance Analysis Summary

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III.

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

III.A Plant Operations

III.B

Radiological Controls

III.C

Maintenance/Surveillance

III.D Emergency Preparedness

III~E

Security

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III.F

Engineering/Technical

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III.G

Safety. Assessment/Quality

Verification .

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IV.

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

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I.

INTRODUCTION

The Systematic Assessment of Licensee Performance-(SALP) is an.integ'rated NRC staff

effort to collect the available, observations and data;on.a periodic basis md.to evaluate

" - '-.~ <"'-'licensee:performance+ased~upon..thirinformation..-SALP

is"supplemental&wormal

., 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, Director, 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

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

(NRR)

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

/;

I

II.

SUMMARYOF 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

areas.

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

responding to plant challenges and aggressive management

involvemen't in the resolution of

operational events. 'owever, 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.

Manage'ment'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 w'ith

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

Fun 'n

Ar

Rating Trend*

- "Rating,"Trend**

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P

1.

Plant Operations

2.

Radiological Controls

3.

Maintenance/Surveillance

4.

Emergency Preparedness

5.

Security

6.

'ngineering/Technical

Support

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2 Improving

1, Declining

2 Improving

'

7.'afety Assessment/Quality

Verification

2

• June 1, 1989 to September 30, 1990

• • October 1, 1990 to January

18, 1992

III.

PERFORMANCE ANALYSIS

III.A'lant 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 statio'n management involvement in daily.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 oi.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.

n

Plant housekeeping

continued to be excellent throughout this yssessment

period.

During the

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

-'.job sites"Kfter work'completion"and'that<the.formalized

housekeepingq)rogram;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 appearance.

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'evel 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,'raining

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

'ynchronization.

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 mrvice:~~

lay'm~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 operationalproblems.

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 betw'een the Operations Department and corporate engineering expedited

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

Operator

training reflects close interdepartmental coordination, ensuring that personnel are provided

effective training on plant modifications.

III.A.2

Performance Rating:

Category 2

III.B Radiological Controls

III.B,I

Analysis

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

Strengths

included responses,to

audit and.inspechon

findings and AI.ARAreviews 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 impi:oved posting and updating ofsurveys, and improved communications within

" -.

the Radiation Protection Organization.

During the I'ast 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,

hazar'ds of'specific"systetnswas"initiated'for.new

RP Technicians";-;~additional RG&E.:..

= initiative involved incorporating the systems training lesson plans into the continuing training

for all permanent RP Technicians.

The training program for co'ntractor 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.

RG&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

" -extensive effort to remove all ex'cessive radioactive material. from the~site.

RG&E had an

.'effective program'or training individuals 'involved in.the radwaste'and.transportation

"program..'Superv'isory

"oversight of"'this"area was also considered very;good;=.

During the previous assessment

period weaknesses

were identified in.theZKMP 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

"staffresulted'.: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.

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.

III.B.2

Performance Rating:

Category 2

III.C Maintenance/Surveillance

m.C. 1

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.

Min nn

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[ '.Overall; tnaintenance activities.were effective in supporting. the-safemd-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 preventivelcorrective 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.

The 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

equipment 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.>>= Theimplementation,of an

.'"';"inadequate'corrective"maintenanceyrocedure

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 co'ndition for certain components in the service water

system.

The licenseemas

appropriately addressing

these plant aging concerns.

A Service

Water System Reliability Optimization Program was established that willsystematically

replace aging containment air coolers, fan motor coolers, and assorted service water system

valves/piping during future outages.

~rveill nce

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.

Licensee, 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.

$gmmary

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 exercise,

degrading plant conditions were again readily recognized.

Use of the plant simulator during

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

Licensee,

";; --.accident assessment

durin~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.

'II

12

.

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

'.,; two separate. tracking systems:

During.the transition to a,single;trackingaystem,.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

'ell

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

The licensee

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

'he NRC found that on-shift personnel lacked the-capability of performing. dose assessment "

for 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.

'he'EP:program-,mn

site md'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"

plan 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.'n

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

'.."-" .'rofici'ent'.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

relationship with'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

Performance Rating:

Category

1, Declining

Board Comments;

- The board was concerned that program support had

.idegraded'resulting

in'the identified weaknesses.

III.E Security

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'nd

the assessment

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

.

'being assembled

at the end ofrthis 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'ecurity 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.

14

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

"'-":security: force exhibited.-a professional: demeanor,.high,morale;iand~were

knowledgeable of .,,-

- *"'<their duties".'Staffing'of'thersecurity~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 requalifiication 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

" ..'-;".'~ "flammablematerial.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

.$gmmarr.

"," '

-" "The licensee con6nued" to implement<improvements in an'effecfive~dqerformance-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.

m.E.2

Performance Rating:

Category

1

III.F

Engineering/Technical Support

m.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

'ngineering 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

modifications that were thoroughly prepared and effectively performed were the seismic

16

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

installation of chlorination equipment:in the. service water, system,-.and~pgrading.of

the

" raliatio'n 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&e,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 Iirogram. '-The program'as

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&ndexing'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 original 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.

. In summary,'ngineering

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

'lectrical distribution system and weaknesses

in the engineering support of the service water

system.

Continued drawing upgrades reflected good engineering; and, DBD efforts were

underway.

Performance Rating:

Category 2

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 mere 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.

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 conscious attitude and resulted in timely issuance.

Examples included the extension to'he'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.

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

. 'he, 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=~louring,this. SALP=

period, NSARB effectiveness:has

been enhanced. by. including m..independent consultant.and.a

representative from another utility as 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 inadequ'ate 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~a untimely manner., All.LERs.issued, gave appropriate attention to discussion

of root causes,

safety significance of events, and corrective actions.

, 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 wairanted.

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

gym'~'

".. -':Senior management~as'i'ctively: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 generaHy 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.

III.G.2

Performance Rating:

Category 2

21

IV.

SALP EVALUATIONCRmt&IA

"'"" '

":"."."License'eaperforman'ce"is msessedeinrselecte'd

functional areas,<<dependinggon~whether

the

.facility is in a construction or operational phase.

Functional areas normally represent areas

significant to nuclear safety and the environment.

Some functional areas may not be assessed

because of little or no licensee activities or lack of meaningful observations 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:

1.

Assurance of quality, including management involvement and control.

2.

Approach 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:

Q~te

ry l

Licensee management attention to and involvement in nuclear safety or

safeguards activities resulted in a superior level of performance.

NRC willconsider reduced

levels of inspection effort.

~ate ~ory 2.

Licensee management

attention to and involvement in nuclear safety or

safeguards activities resulted in a good level of performance.

NRC willconsider maintaining

normal levels of inspection effort.

~Cate o

3

Licensee management, attention to and.invoivement in nuclear safety or

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

NRC's concern that a decrease

in performance may approach or reach an unacceptable level,

NRC will consider increased levels of inspection effort.

N. i iii ii '<<

ii

iii

performance.

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

because of insufficient licensee activity or insufficient NRC inspection.

22

R

~ The SALP Board may assess

a performance trend,. ifappropriate.

-The trends are:

'" ~Im r~n"-'icensee performance

as )determined.to.be improVingAuring'the,assessment '-

period.

~Dectinin

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 next assessment

period.