ML17279A360
| ML17279A360 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 06/26/1987 |
| From: | Bradfute J Office of Nuclear Reactor Regulation |
| To: | Kirsch D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| TAC-65367, NUDOCS 8707060111 | |
| Download: ML17279A360 (12) | |
Text
36 JUN 1S87 Docket No.:
50-397 87070bOiii 87062b PDR ADOCH, 05000397 6
MEMORANDUM FOR:
Dennis Kirsch, Director Division of Reactor Safety and Projects Region V
DISTRIBUTION NRC $ Local PDRs JLee PD5 Memo THRU:
FROM:
SUBJECT:
George W. Knighton, Director Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects John 0. Bradfute, Project Manager Project Directorate V
Division of Reactor Projects - III, IV, V and Special Projects NRR SALP INPUT FOR WNP-2 AND THE SUPPLY SYSTEM FOR THE REPORT PERIOD FROM FEBRUARY 1, 1986 THROUGH May 31, 1987.
(TACO 65367)
The enclosed report provides NRR's input to the SALP Report for WNP-2, covering licensing activities from February 1, 1986 through July 31, 1987.
The overall performance of the Supply System in the functional area of Licensing Activities is at a Category 2 level with a perceived improving trend.
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Enclosures:
As stated Original Ilgnag by John 0. Bradfute, Project Manager Project Directorate v
Division of Reactor Projects - III, IV, V and Special Projects cc: 'T. E.
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Murley Miraglia Crutchfield Holaha n Knighton Samworth Bradfute CONTACT:
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Docket No. 50-397 UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 LICENSEE:
Washington Public Power Supply System FACILITY:
WPPSS Nuclear Project No.
2
SUBJECT:
NRR CONTRIBUTION TO SALP REPORT EVALUATION PERIOD:
1 February 1986 through 31 May 1987 I.
INTRODUCTION A Systematic Assessment of Licensee Performance (SALP) is conducted periodically by the USNRC.
This report presents the NRR contribution to the overall. SALP review for WNP-2 and it addresses in detail the assessment of the functional area of "Licensing Activities".
The other functional areas are also addressed from the NRR point of view for use in the detailed evaluations by region V which has responsibility for the final SALP report for WNP-2.
The assessment has been prepared generally in accordance with the SALP guidance package provided by memorandum from Region V dated 7 May 1987.
The Region V memorandum incorporates the significant aspects of the NRC Manual Chapter 0516 as attachments.
II.
CRITERIA AND
SUMMARY
NRC Manual Chapter 0516 identifies six performance criteria with characteristic attributes.
SALP performance ratings were provided with the work products prepared by the various NRR reviewers primarily in conjunction with the various licensing actions requested by the licensee.
As specified in the Manual Chapter, each of the identified criteria was evaluated from several points of view and assigned a
performance rating category (Category 1, 2 or 3) based on a subjectively evaluated composite of the characteristic attributes.
These work products (mostly safety evaluations) and associated SALP ratings were formally transmitted to the Project Manager who combined this information with his own assessment of licensee performance
- and, applying judgmental weighting factors, arrived at an overall rating for the licensee.
Based on these ratings as indicated
- above, the overall performance rating for the Washington Public Power Supply System in the functional area of "Licensing Activities" is Category 2.
II.
PERFORMANCE ANALYSIS The evaluations of the licensee's performance were based on considerations of the attributes of the six criteria as given in the Region V Memorandum.
For most of the licensing actions considered in these evaluations, only three of the criteria were of great significance.
Therefore the composite or overall rating was heavily based on the following criteria:
o Management Involvement in Assuring Safety o
Approach to resolution of Technical issues from a safety Standpoint o
Responsiveness to NRC Initiatives Narrative assessments for each of the criteria are as follows:
1.
Mana ament Involvement and Control in ~Assurin
~valet WNP-2 undertook two fuel reloads during this rating period.
The first was accomplished during the spring of 1986 and was managed and executed in an exemplary manner.
The second occurred at the end of the current SALP period and appeared also to be handled in an excellent manner although some schedule delays in restar ting were noted.
Further the plant availability during the intervening period was high indicating an apparent high degree of management involvement in the operation of the plant.
The continuing problems with both recirculating pumps over a two year period, however, is a cause for some concern.
The receipt and installation of the improper gasket suggests a need for management's reexamination of the Supply System's guality Assurance program.
Participation by the WNP-2 management in the licensing process was noticeably improved during this SALP rating period.
During this period twenty-three licensing actions were completed and none was required nor requested on an exigent or emergency basis.
This performance compares with thirteen Technical Specification amendments granted during the previous SALP rating period, seven of which were requested on an expedited basis.
This performance reflects a
substantially improved focus of attention by the WNP-2 management.
Similarly the quality of the submittals has shown marked improvement.
The NRR staff suggests that the Supply System management generally reflects good control, significant involvement and consistent prior planning and assignment of priorities. It appears from ratings on
fire protection issues that the Supply System management does not regard the resolution of the staff's fire protection concerns with the same priority as other concerns.
This area needs further improvement.
In summary,
- however, management involvement and control in assuring quality is rated as Category 1 for this rating period.
The previous rating was Category 2 and an improving trend in performance is apparent.
2.
~Aroach to resolution of Technical Issues from a ~Safet
~Stand oint The Supply System's approach to the resolution of technical issues has generally been sound and viable.
The NRR staff feels that the Supply System demonstrated a very good understanding of the technical aspects and functioning of their plant and a sensitivity to the safety issues which, for the most part, they addressed conscientiously and in compliance with the regulations.
Although we must note that the Supply System has not performed in a like manner with respect to the considerable number of fire protection issues that surfaced during this SALP period.
With that, the overall performance of the Supply System is regarded as satisfactory.
Hased on this evaluation, the licensee's approach to the resolution of technical issues during this evaluation period is rated as Category 2.
The previous rating was Category 1; consequently the trend appears to be decreasing and additional management involvement would seem warranted.
It should be noted that the primary issue associated with the reduced rating relates to fire protection which is an ongoing issue in which the WNP-2 management (as well as the NRC) has
~
demonstrated a significant interest.
The apparent decreasing trend reflects concern that the numerous fire protection issues have not yet been resolved or closed.
- 3. ~i NC The Supply System'esponsiveness to NRC initiatives has been appropri-ate, timely and acceptable.
The fire protection issues are perceived as the primary exceptions.
An additional exception involves the licensee's responses to numerous attempts to resolve a relatively minor organizational detail presently governed by the Technical Specifications.
The licensee's responsiveness to NRC initiatives during this evaluation period is rated Category 2.
This rating during the previous SALP period was also Category 2 and no trend is evident.
4.
Enforcement
~Hister The enforcement history during this evaluation period was evaluated from the total number of enforcement actions and the absence of violations above severity level IV.
These observations suggest good performance in this atribute.
A rating of Category 2 is supportable.
d <<E E
The reactor scram which occurred on March 22,
- 1987, and the subsequent recovery difficulties (LER 87-02) were of interest to NRR management.
During recovery the reactor water level reached the elevation of the main steam line inlet three times over nearly a three hour period following the scram.
This was the second steam line flooding event during the SALP interval (see also LER 86-25).
NRR management was briefed on the event on May 12, and the ACRS was informed of the event on June 5,
1987.
It was subsequently concluded that no NRR licensing action is needed.
The SALP rating should reflect the reporting of the event under 10 CFR 50.72.
The problems experienced during recovery from the initial scram were not reported to the Operations Center and were therefore not known to those screening events for immediate follow up.
The rating for this attribute during this SALP period is Category 2.
6.
~Staffin
~lncludin
~Mana ament)
The Supply System's licensing staff, in its working relationship with the engineering and operations staff has a sound technical understanding of their system and its performance characteristics.
Appropriate personnel are invariably in attendance at meetings and telephone conferences with the NRC staff so that conferences are generally short and productive.
On the other hand, NRR has recently become concerned about the licensee staff's implementation of the procedures for making changes to the licensing basis documents.
In particular there seems to be a
lack of appreciation of the need for timely filing of amendments to the FSAR in safety areas.
An example is the case of correcting Amendment 37 concerning power being removed from valves RHR-V-8 and RHR-V-9 when we understood it had been decided not to operate in that mode.
Apparently there was no plan to amend this unreyiewed safety area until the annual FSAR update.
- Further, the licensee staff discussed changes to the technical specifications bases without obtaining NRR staff concurrence.
It has been necessary to advise them that since the approved technical specifications'reflect the "bases" such changes require staff concurrence.
The rating for this attribute during this SALP period is Category 2
which is reduced from the rating for the previous SALP period, Category 1, and the examp1 es identi fi ed above, probably s ignal a
decreasing trend.
IV.
RECOMMENDATIONS As the Supply System's performance in the area of Licensing Activities is mixed, recommendations are varied:
o With respect to the management control of license amendment
- requests, the Supply System has shown remarkable improvement by the elimination of emergency technical specification changes during this SALP period.
This improvement was encouraged in the previous SALP report and the licensee appears to have been responsive.
Further encouragement may be in order but recognition and commendation for significant improvement in this area is appropriate.
o With respect to the Supply System's use of the appropriate procedures for accomplishing modifications to their licensing basis documents, it is recommended that the Supply System should take measures to ensure that their licensing staff and operation management achieve a mutual under-standing of the requirements for timely and accurate filing of FSAR amendments and for modifying other licensing basis documents according to the provisions of 10 CFR Part 50.
V.,
ASSESSMENT OF OTHER FUNCTIONAL AREAS While the primary thrust of this evaluation is focused on licensing activities and the rating assignment pertains only to this functional
- area, some NRR observations relating to the other functional areas are included:
o Plant
~0 erations There hae been little NRR contact with the operating staff other than the plant manager and his assistant.
Visits to the site have led to the conclusion that p'lant housekeeping has markedly improved during this SALP period and the observed control room operations seem to run smoothly and with decorum.
Me have no bases to conclude that the plant operations were not performed in an acceptable manner.
Th>>1 y
Monitoring Report indicated that the total collective dose for 1986 was 221.55 man-rems.
This value is below the industry average and is well below the average for BMR plants.
The Supply System should be commended.
o Maintenance
- Severe vibration problems with the two g p p
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gh I
Ily 11 1
this SALP evaluation period.
Although the root cause of this difficulty now appears to be a design deficiency, possibly aggravated by a quality assurance
- weakness, the possibility remains that poor maintenance may be contributing.
It should be noted that the problem is not regarded by NRR as an immediate safety issue;, nevertheless the chronic nature of the problem is cause for concern because it suggests that failure of both pumps could result in a safety issue or that safety related issues could be allowed to become chronic.
o Surveillance - No specific NRR observations have been made.and no h
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I p
h LER's that resulted from personnel errors.
Since defective procedures are themselves distinct causes for surveillance
- errors, perhaps this relatively large number should be cause for a somewhat modified emphasis of the training program.
o Fire Protection - While the overall fire protection issue has aaasoor e
an enormous fraction of attention by Region V, NRR and the Supply System almost from the beginning of this SALP period, we note that the issue has given rise to but one LER.
We recommend a diligent and continuing effort by all three organizations to resolve the remaining issues promptly and effectively.
I
~Pd
-ggg dg <<I df I
fd esponse Center 1n support of Region V's Emergency Preparedness Drill in September 1986.
No fault with the Supply System's participation was found by the Headquarters staff that participated.
o Securit
- During several site visits by the Project Manager and ot er R personnel during this rating period, the Supply System's plant security system appeared to be designed and functioning quite well.
The Security personnel appeared to be well trained and highly motivated.
o Outa es - Outages have been few but appeared by NRR to have been an e
expeditiously and effectively by the Supply System when outage events have required it.
o oalit Pro rams and Administrative Control Affectin Safet 1
b ~ <<d
- above, no observations have been made by NRR and no difficulties have been brought to our attention.
s ii i
i
i
<<h System's training program was conducted by NRR primarily to evaluate the INPO audit of the same area.
The report of the NRR audit team indicated that the Supply System's training program was excellent and in some aspects could be considered a model for the industry.
VI.
SIGNIFICANT OCCURRENCES NRR/Licensee
~Meetin s - Two significant meetings were convened in which both NRR and the Supply System personnel participated.
Region V
representatives participated in both.
o Project Directorate 3 of the Division of BWR Licensing (previous organization) held a one day meeting in Bethesda with representatives of all utilities and all Project Managers associated with the Directorate.
The meeting was held on 9 September 1986 and its purpose was to provide an opportunity for the utilities and the NRC to share concerns and discuss difficulties so as to improve the licensing climate within the Directorate.
The meeting was marginally successful.
o Fire Protection -
On 14 January 1987 a meeting was held at the Supply System Headquarters in Richland as a preliminary information exchange prior to a combined inspection of the WNP-2 facility by Region V and NRR.
The meeting was attended by many of the responsible managers from Region V, NRR and the Supply System.
The subsequent inspections were intended to clarify the many fire protection issues that had been identified by Region V
inspectors and NRR reviewers on numerous inspections and visits during the proceeding months.
The meeting and subsequent inspections accomplished much of their intended purpose but left several fire protection issues open.
Commission ~Meetin s - There was none NRR Site Visits - Seven visits to the WNP-2 facility were made by NRR personnel during this SALP period.
The dates of the visit are as follows:
6 -
7 Mar 1986" 20 - 21 Mar 1986 16 - 24 Jul 1986 12 - 13 Aug 1986*
12 - 16 Jan 1987*
17 - 20 Mar 1987 19 - 22 May 1987 Many of these visits were group visits and the three marked (*) were oriented toward the significant licensing issue of fire protection.
Schedular Extensions Granted - Two schedular exemptions were granted by license amendment during this SALP period.
Amendment 23, dated 5 May 1986, extended the required schedule for,implementing the upgrading of neutron flux measurement instrumentation to comply with Regulatory Guide 1.97 requirements.
The schedular exemption extended the requ'ired implementation from restart following 'the first refueling outage to restart following the second refueling outage.,
Amendment 25, dated 23 May 1986, extended the schedule for upgrading the Suppression Pool Level instrumentation in a similar manner.
Reliefs Granted - The following table shows the status of relief requests that were received or disposed
'of during the current SALP period:
Date of TAC
~Re uest Number 28 Feb 85 57728 29 May 85 58034 Relief Re<euest PSI Program Plan IST Program Plan 7 requests Dis osition granted 31 Jul 86 1 withdrawn 22 Jul 86 5 granted 27 Mar 87 1 denied 27 Mar 87 14 Jun 85 59295 ASME Section XI not granted 6 Nov 86
" il during this SALP period; both were exemptions from requirements of Appendix J.
~Emer enc Actions Granted - None was requested and none was grated.
License Amendments Issued - See Attachment 1.
Orders Issued - There was none.
Issues
~Pendin
- At the end of this SALP period there were thirty-three Licensing Actions under review and in progress.
This number included five Multiplant Actions.
YII. CONCLUSIONS Individual ratings for the six evaluation criteria for the functional area of Licensing Activities are tabulated below.
The tabulation includes the previous SALP ratings and an indication of the perceived trend.
Criterion Previous Current SALP SALP
~Rat i n
~Rat i n Trend 1.
Management Involvement and Control in Assuring equality improving 2.
Approach to Resolution of Technical Issues 3.
Responsiveness to NRC Initiatives 4.
Enforcement History 5.
Operational and Construction Events 6.
Staffing (Including Management) down The overall SALP performance rating for the Supply System in the functional area of "Licensing Activities" is Category 2.
License Amendments Issued During SALP Period February 1,
1987 and May 31, 1987 Attachment 1
Amendment Number 21 22 23 24 25 26 27 28 29 30 31 32 33 TAC Number 60546 57546 60415 60548 61114 60953 60952 60804 61482 59793 60050 59500 59673 Title Drywell Head "0" Surveillance Primary Containment Integrity Flux Monitoring Manual to Automatic FPC-U-149 Metwell Level Measurement Table 3.6.3-1 Table 3.8.4
~ 3-1 Cycle 2 Reload Physical Security Plan Vacuum Breakers Inoperable Primary 8 Secondary Containment Integrity Radioactive Effluent Monitoring Composition of CNSRB Date of Issuance March 18, 1986 May 2, 1986 May 5, 1986 May 13, 1986 May 23, 1986 May 23, 1986 May 23, 1986 May 23, 1986 Oct.
16, 1986 Oct.
31, 1986 Nov. 6, 1986 Nov. 6, 1986 Dec.
2, 1986 34 62181 Turbine Overspeed Protection System Dec.
11, 1986 35 36 37 38 39 60765 61222 61116 62045 61641 Pressure Temperature Limits Chlorine Detection System Removal Hz-Oz analyzers Safety/Relief Valve Setpoints Iodine Spiking Dec.
17, 1986 Jan.
21, 1987 March 27, 1987 March 27, 1987 March 31, 1987 40 64217 Snubber Removal while in Modes 485 April 21, 1987 41 43 60740 63052 64358 Appendix J, Type B8C Leak Testing Containment Penetration Fuss SLCS Boron Concentration and Flow Rate April 29, 1987 May 21, 1987 May 29, 1987
~
p WNP-2 1987 SALP RATINGS Attachment 2
TAC Nr Title Date Reviewer 1-Manaq Ratings 2-Tech 3-Resp 4-Staff 6-Train Overal I 56181
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57546 57728 57805 58034 59031 59295 59500 59673 59793 59798 59904 60050 60345 60415 60545 60546 60548 60737 60739 bo7no 60765 boBon 60915 60952 60953 61014 61114 61116 61222 61482 61641 61850
- 2045 62181 62784 63052 63935 64106 64217 64320 64595 64987 Control Room Ventilation DCRDR Isolation Valve Surveillance Isolation Valve Exclusion PSI Program Plan Relief MPA Item 2. 1 ISI Program Plan Zc Relief Diesel 4utostart Use of Later ASME Code Offgass Treatment
- Monitors, CNSRB Composition Vacuum Breakers Training Coordinators LPRM Calibration Primary Containment Integrity Purge Time Limit Flux Monitoring Upgrade MOV Thermal Overload Protection Drywell Head "0" Ring Surviellan Manual to Autamatic FPC-V-149 "Spray On" Coatings High Burn Up Fission Gas Release Type B 4 C Leak Testing Pressure/Temperature Limits Cycle 2 Reload Fire Protection Tabl e 3. 8. 4. 3-1 Table 3. 6. 3-2 Ultimate Heat Sink Wetwell Level Measurements H2 02 Analyzers Chlorine Detectors Removal Physical Security Plan Iodine Spiking Neutron Flux Monitoring Setpoint Tolerances Turbine Overspeed Protection Fire Protection Concerns Primary Containment Overcurrent TIP Nitrogen Line Turbine Missiles (LC 7)
Snubbers 0
Cable Spreading Room Cade Case Nnli Cycle 3 Reload 29 6
9 2
27 19 6
17 16 21 16 1
13 1
10 17 6
23 ce18 20 17 15 16 27 15 6
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7 15 5
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13 7
9 13 10 24 27 13 22 Apr 86 Nov 86 Jul 85 May 86 Mar 86 Dec 86 Feb 87 Dec 86 Dec 86 Feb 86 Jan 86 Nov 85 Nov 86 May 86 Apr 86 Mar 86 May 86 May 86 Feb 86 Feb 86 Oct 86 May 86 Mar 87 Mar 86 May 86 Nov 86 May 86 May 86 4pr 86 May 86 Nov 86 Dec 85 May 86 Sep 86 Dec 86 Nov 86 Oct 86 Mar 87 Feb 87 4pr 87 feb 87 May 87 Feb 87 May 87 May 87 Hayes Serig El tawi 1 a>>
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- 1. 602 1 ~ 688