ML17290B150
| ML17290B150 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 05/04/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML17290B149 | List: |
| References | |
| 50-397-94-09, 50-397-94-9, NUDOCS 9405110151 | |
| Download: ML17290B150 (8) | |
See also: IR 05000397/1994009
Text
SALP Report - Washington Nuclear Project
2
(WNP-2)
NRC Inspection
Report 50-397/94-09
I.'ntroduction
The Systematic
Assessment
of Licensee
Performance
(SALP) process
is used to
develop the NRC's conclusions
regarding
a licensee's
safety performan'ce.
The
SALP report documents
the NRC's observations
and insights
on
a licensee's
performance
and communicates
the results to the licensee
and the public.
This
report is the NRC's assessment
of the nuclear safety performance
at WNP-2 for
the period of Harch
1, 1993,'hrough
Harch 31,
1994.
A board
was convened to
assess
nuclear safety performance
on April 14,
1994,
pursuant to
NRC
Hanagement Directive 8.6,
"Systematic
Assessment
of Licensee
Performance."
Board members
were Stuart Richards
(Chairperson),
Acting Director, Walnut
Creek Field Office, Division of Reactor Projects,
Region IV; A. Bill Beach,
Director, Division'f Reactor Projects,
Region IV; Ross
Scarano,
Deputy
Director, Division of Radiation Safety
and Safeguards,
Region IV; and Ted
quay, Project Director, Project Directorate
IV-3, Office of Nuclear Reactor
Regulation.
The performance
category ratings
and the assessment
functional
areas
used
below are defined
and described
in NRC Hanagement
Directive 8.6.
II.
Performance
Ratin
s
The current
SALP process
assesses
performance
in four functional
areas
instead
of the previous
seven.
The four areas
are Plant Operations,
Haintenance,
Engineering,
and Plant Support.
Safety Assessment/guality
Verification is
considered for each of the four functional areas rather than
as
a separate
functional area.
The Plant Support functional area
assesses
the previous
functional
areas of radiological controls,
emergency
preparedness,
and
security.
Three category ratings continue to be used in the assessment
of
performance
in each functional, area.
Performance 'trends,
improving or
declining,
have
been eliminated
as
a part of the ratings.
Current
Functional'Area
Plant Operations
Haintenance
Engineering
Plant
Support'Ratin
Previous
Functional
Area
Plant Operations
Haintenance/Surveillance'ngineering/Technical
Support
Radiological Controls
Emergency
Preparedness
Security
Safety Assessment/
equality,Verification
~Rat in
2
2 Declining
3
2
2
1
3 Improving
9405i10i5i 940504
ADOCK 05000397
8
"
III.
Performance
Anal sis
A.
Plant
0 erations
This functional
area
addresses
overall
performance
in plant operations.
Plant
and
human performance
during the appraisal
period was
good
as evidenced
by the
longest continuous
power operation period in the plant's history.
Conduct of
operations
during this period generally demonstrated
good operator
response
to
plant events;
however,
response
to some events
was not timely and involved
failures to follow procedures.
Operations
performance
in controlling and
prioritizing plant work has
improved;
however,
the licensee
has not been fully
effective in minimizing human performance deficiencies;
The licensee
has
made progress
in reducing the number of operation's
procedure
adherence
problems.
Continued effort is warranted,
however,
as indicated
by
,
instances
of plant operators failing to perform activities in accordance
with
procedures
in response
to alarms
and off-normal events or conditions during
operations.'xamples
include:
(1) not following procedures
in response
to
high steam tunnel/reactor building differential temperature;
and (2) not
declaring
a channel of reactor
vessel
level indication inoperable
when
procedures
required.
Although plant management
has
been providing additional
emphasis
on this area,
these
problems continue to recur.
NRC management
has
discussed
this concern with licensee
management
several
times during the
assessment
period.
Control
room professionalism,
teamwork,
and communication
have
improved.
However, shift turnovers
have not consistently
communicated
the required
information to support event-free
operation,
and reviews of logs
and completed
procedures
do not consistently identify errors in the performance of plant
activities.
Toward the end of the assessment
pe'riod, licensee
management
required that shift managers
conduct their shift turnovers in the control
room
to correct these
problems.
Hanagement
oversight of plant operations
has
improved but was inconsistent,
as evidenced
by several
errors
by operators
and
supervisors
during the
1993 refueling outage.
Operations
management
did not
conservatively
evaluate
or thoroughly question leaking pressure
isolation
valves
and deficiencies identified during control rod drive scram solenoid
pilot valve testing.
Although these
issues
are discussed
in detail in the
engineering functional area,
operations
management
did not demonstrate
the
expected
sense of ownership
and safety perspective.
Management
also
has not
fully corrected
problems regarding the timeliness
and completeness
of
corrective actions.
Examples
include:
(1) untimely corrective actions to
limit excessive
overtime
usage during the last refueling outage;
(2) incomplete corrective actions to address
numerous
problems with locked
valves
and tagging;
and (3) continued
performance
problems with equipment
operators.
The'icensee
successfully
corrected
problems with overdue
surveillances
during this appraisal
period,
and does not currently make
routine use of allowed time extensions for Technical Specification required
'urveillances.
The facility performed well during
a requalification program evaluation this
pe}iod, with all crews
and operators
passing.
The performance rating is Category
2 in this area-.
B.
Maintenance
The functional
area of maintenance
addresses
activities relat'ed to equipment
condition, maintenance,
surveillance
performance,
and equipment testing.
During this assessment
period, the declining performance
trend previously
identified during the last
SALP period was arrested
and
some minor overall
improvement
was noted.
Procedural
adherence
and supervisory oversight
continue to be weak.
Planning, control,
and coordination of maintenance
work
require
improvement.
The Maintenance
area is well staffed, with a low personnel
turnover rate,
and,
with a strong maintenance
training group to support the organization.
However, procedural
adherence
has continued to contribute to an excessive
number of errors
in the maintenance
area.
This has
been evident in examples
of surveillances
not being properly completed,
various work rules not being
followed,
and craft errors resulting in half-scram
and ha')f-containment
isolation conditions.
Although senior licensee
management
has taken action to
clarify their expectations
on procedure
adherence
following the receipt of a
$75,000 Civil Penalty in November
1993,
maintenance
supervisors
have not been
fully effective in reenforcing these
expectations
by providing adequate
oversight of field work.
The weak supervisory oversight
may be influenced
by
the administrative
burdens
placed
on the maintenance
supervisors.
In
recognition of this, the licensee
has instituted
a new electronic
system,
named
PASSPORT, that is intended to make the administrative
process
more
efficient.
This system is too new for its impact to be assessed.
The licensee
has
been successful
in improving maintenance
performance
in
several
respects.
Increased
management
involvement has resulted in the
significant reduction of the corrective maintenance
backlog.
The number of
control
room deficiencies
has also
been significantly reduced,
with the
average
number of nonoutage
control
room deficiencies
being maintained
relatively low at about
10.
Overall maintenance
support to operations
has
improved.
The licensee
has eliminated the routine use of the Technical
Specification allowed
25 percent
grace period for conducting surveillances,
and the licensee's
initiative to review and upgrade
maintenance
procedures
continues to progress.
During this assessment
period,
one planned refueling -outage
and
one forced
outage occurred.
Both outages
were generally well managed,
which was
an
improvement over prior outage
performance.
During the forced outage,
the
licensee
was aggressive
in taking the opportunity to repair steam leaks
and to
address
maintenance
items that required
a plant shutdown for repair.
Although overall
management
of outages
improved, the control
and coordination.
of routine work warrants further improvement.
.For example,
the licensee's
h
oversight of efforts to temporarily repair
a steam leak on
system
valve was not well controlled.
In another
case,
a plant modification was
partially completed prior to the Plant Operations
Committee approving the
modification.
Additionally, at the end of the assessment
period,
the licensee
was preparing for the upcoming Refueling Outage
9 and
was behind schedule
in
the preparation of work packages
for the outage.
The overall quality of maintenance
work has
improved somewhat,
as demonstrated
by a reduced
number of recurring
equipment failures related to maintenance
and
by the relatively uneventful
operation of the plant from August
1993 until the
end of the assessment
period.
However, the one plant scram during the
assessment
period was the result of a maintenance
error in assembling
an HSIV
solenoid-operated
pilot valve.
Other examples that illustrate that work
'quality remains
an issue
include the repeat
overhaul of a spent fuel
po'ol
cooling pump,
the incorrect assembly of seismic restraints
associated
with a
station battery,
and the improper setting of limit switches that contributed
to water hammering in the service water system.
A positive initiative of the licensee
has
been the Technical Specification
Surveillance
Improvement
Program.
This effort has
been very thorough
and
has
identified numerous deficiencies
in surveillance
procedures.
Host licensee
event reports in the maintenance
area this assessment,
period were related to
deficiencies
in the scheduling
and performance of surveillances.
Although Quality Assurance
(QA) reviewed
some aspects
of maintenance
during
the assessment
period, there
was only one focused audit of the maintenance
area.
QA did not appear to significantly contribute to changes
being
made in
the maintenance
area.
Overall, the actions
taken
by Supply System senior managers
during this
assessment
period halted
a declining performance
trend
and resulted
in some
improvement.
Continuing licensee attention is needed
to firmly establish
a
higher performance
level for procedural
adherence
and supervisory oversight.
Improved coordination
and control of work are also warranted.
The performance rating is Category
2 in this area.
C.
This functional
area
addresses
the adequacy of technical
and engineering
support for all plant activities.
Engineering
performance
was acceptable.
The licensee
took actions during thi's assessment
period to address
a number of
the issues identified during the previous period.
In particular,
improved
communications
were generally noted
between
Operations
and Engineering.
The
reduction in engineering
backlogs indicates that the licensee is managing
emergent
work and prioritizing work more effectively.
Temporary
modifications
and control
room deficiencies
have
been significantly reduced.
In addition, plant staff visits to other sites
appear effective in improving
engineering
knowledge of industry issues,
and using the experience of other
utilities.
There were also
a number of positive examples of engineering
"i
personnel
identifying issues
and effectively addressing
those
issues.
However, additional effort is warranted to improve engineering timeliness,
quality of work, thoroughness,
and safety perspective.
Engineering
has
been
slow in correcting
a number of long-standing
deficiencies.
An example early in the assessment
period was the slow
resolution of the diesel'enerator
starting air capacity problems.
Recently,
the licensee's
examination of the recurrence
of waterhammer
in the standby
service water system
was not as thorough
as would be expected for a repetitive
problem.
In addition, identified deficiencies with the control
room
habitability system
remained
uncorrected for over
a year.
Other deficiencies
in the
same
system were identified by
NRC inspections
rather than Engineering.
Late in the assessment
period,
an
NRC team inspection of the engineering
area
concluded that
a number of the Washington Public Power Supply System's
- initiatives were having
a positive effect and that the design
change
process
was general.ly
sound.
However, several
events late in the period illustrated
engineering
weaknesses
in addressing
emerging
issues.
Specifically,
when
faced with leaking shutdown cooling isolation valves,
the licensee
delayed
obtaining
a leakrate for the inboard valve for 2 weeks, while initially
maintaining that testing could not be performed.
The subsequent
satisfactory
test results
demonstrated
the integrity of the valve.
In another instance,
an
employee raised
concerns
to both his supervision
and to senior Washington
Public
Power
Supply System
management
that fire barrier penetration
seals did
not conform to standards.
These
concerns
were not adequately
addressed
until
the
NRC became
involved.
Licensee
considerations
of the effects that
an
increased
capacity factor and anticipated
hardware modifications would have
on
fuel loading for the upcoming cycle were not well supported
by Engineering.
Finally, during
a surveillance test of control rods,
one rod failed to insert,
apparently
due to degraded
scram solenoid pilot valve Buna-N components
(diaphragms).
Prior to this event,
other degraded
had
been
recently observed;
however,
the engineering
response
was not aggressive
until
the rod failed to move.
Subsequent
to the failure, the licensee
determined
that continued plant operation
was justified based
on engineering
conclusions
that were later found to be not so conclusive
as originally thought.
Many license
amendment
submittals
were of relatively low quality in that they
did not provide sufficient justification to support requested
Technical
Specification
changes
and did not always address all the safety issues.
Those
amendment
submittals
also contained Sholly dis ussions that were consistently
weak.
The licensee
was late in submitting licensing- issues for the upcoming
refueling outage,
with 8 of ll licensing action requests
received
by the
NRC
less
than
6 months before the start of the outage.
Of those eight, the
licensee
submitted four actions less
than
3 months before the outage.
The
licensee
has
made recent
changes
in personnel
associated
with licensing
actions.
In addition,
the licensee recently demonstrated
its commitment to
improve in this area
by sending
14 staff members to
NRC Headquarters
to
discuss
regulatory requirements
in the licensing area.
Engineering continues
to have difficulty ensuring that fire protection design
features
are properly'installed
and maintained.
In addition to the fire
barrier penetration
seal
concerns
discussed
above,
NRC inspectors
identified
that Engineering
had not correctly determined all the locations within the
plant with Thermolag installed.
The licensee
also noted problems with control
of cable tray covers.
The performance rating is Category
3 in this area.
0.
~P1
S
This functional
area
addresses
all activities related to radiological
controls,
emergency
preparedness,
secui ity, chemistry
and fire protection.
Generally,
improved performance
was demonstrated
in the plant support, area,
with the exception of fire protection.
The most significant program area
improvement
was in radiological controls,
with advancements
in the areas of ALARA planning,
volume of radioactive waste
stored onsite,
and plant staff awareness
of radiation control issues.
Significant quantities of radioactive
waste which had
been stored
on site,
some since the first outage,
were shipped for disposal.
A'ew organization,
including replacement
of the majority of the supervisors
in the Health Physics
Department,
appeared
to have
a positive influence
on the program.
Early in
the
SALP period,
problems
were noted with the timeliness
and effectiveness
of
corrective actions in response
to
NRC violations.
These
problems
were not
evident during the last portion of this
SALP assessment
period.
The
licensee's
lack of= depth at the professional
technical staff level in
radiation protection is
a continuing concern.
Hanagement
oversight of
radiation control activities was generally good, with the exception of a spill
of glycol solution that resulted
in an Unusual
Event being declared.
In emergency
preparedness',
the licensee
continued to build on existing good
performance.
Substantial
resources
have
been
expended
on the remodeling of
the technical
support center
(TSC)
and the emergency
operations
facility (EOF).
A state-of-the-art
pager call-out system
was installed in
conjunction with the computer
system previously in place.
A program to
establish staffing teams, five deep,
was instituted to ensure
appropriate
resources
are available to staff the emergency facilities.
Although
a full
scale exercise
was not conducted during this
SALP period,
the licensee
successfully
conducted
several drills in'pecific emergency
preparedness
areas
(e.g.,
health physics,
medical, etc.).
Problems with the maintenance
of
inventory records
and scheduling of emergency
preparedness
surveillances
dealing with emergency
equipment
were noted..
The security area continued to be
a strength,
with a well-qualified staff and
strong
management
support.
A strong
management
team was recognized
as having
a significant role in the success
of the security department..
The licensee
maintains
a good relationship with local law enforcement
agencies
(LLEA), as
evidenced
by joint special drills and exercises.
To compensate
for
degradation of the closed circuit television
(CCTV) image caused
by the
cooling tower mist, the licensee
designed
and installed environmental
enclosures
on the cameras
that successfully mitigated the effect of the mist.
However, there continues to be
a concern with the licensee's
ab)lity to detect
slow, long-term deterioration of the
CCTV image.
Following the security event
at Three Nile Island, the licensee
was proactive in establishing
measures
to
prevent similar occurrences
at its facility.
During the
SALP period, it was
identified that .certain security surveillance
procedures
did not have
provisions to assure that acceptable
random failures did not have
a
common
cause.
The licensee
has generally
been aggressive
in efforts to maintain good plant
chemistry.
the
lan
su
ort area
was
enerall
ood.
Self assessment
in
p
t
pp
g
y g
Strengths
were
noted in the audits of emergency
preparedness
and security
and in the use of
outside expertise to enhance
the audits.
guality involvement in fire
protection
was not evident until after issues
were developed
by the
NRC.
The performance rating is Category
2 in this area.
Although the area of fire protection
was adequate,
there were weaknesses
identified in the response
to technical
issues,
and in personnel
knowledge
and
understanding of fire protection procedures.
Instances
of" a lack of control
of combustible material
were noted.
For example, fire doors were propped
open
without the necessary
compensatory
measures
in place,
and combustible materia)
was left in the plant without proper controls.
In addition,
degraded fire
were identified by the licensee
and fire impairments
were not issued
for compensatory
actions.
Housekeeping
was generally noted to have
shown
substantial
improvement.