ML17328A779
| ML17328A779 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/15/1990 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML17328A778 | List: |
| References | |
| 50-315-90-01, 50-315-90-1, 50-316-90-01, 50-316-90-1, NUDOCS 9011200209 | |
| Download: ML17328A779 (39) | |
See also: IR 05000315/1990001
Text
9
INITIALSALP
REPORT
U.S.
NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT
OF LICENSEE
PERFORMANCE
Inspection
Report
No. 50-315/90-01;
50-316/90-01
Company
Donald
C.
Cook Nuclear Plant
July 1,
1989,
through August 31,
1990
TABLE OF
CONTENTS
~Pe
e No.
I.
INTRODUCTION ...
II.
SUMMARY OF RESULTS
.
verview ..............
0
III. CRITERIA
.
IV.
PERFORMANCE ANALYSIS ..
A.
Plant Operations ...
B.
Radiological Controls ..
C.
Maintenance/Surveillance '.
D.
Emergency
Preparedness .............
13
E
Security
.
F.
Engineering/Technical
Support .....................
G.
Safety Assessment/guality
Verification
17
19
V.
SUPPORTING
DATA AND SUMMARIES
23
A.
Licensee Activities ...............
23
B.
Inspection Activities ..
C.
Escalated
Enforcement Actions ..................
~ ..
26
D.
Confirmatory Action Letters
(CALs)
26
Review of Licensee
Event Reports .............
26
I ~
INTRODUCTION
The Systematic
Assessment
of Licensee
Performance
(SALP) program is an
integrated
NRC staff effort to collect available observations
and data
on
a periodic basis
and to evaluate
licensee
performance
on the basis
of this information.
The program is, supplemental
to normal regulatory
processes
used to ensure
compliance with NRC rules
and regulations.
It
is intended to be sufficiently diagnostic to provide
a rational basis for
allocating
NRC resources
and to provide meaningful
feedback to the licensee's
management
regarding
the NRC's assessment
of the facility's performance
in each functional area.
An NRC SALP Board,
composed of the staff members listed below,
met on
October
26 and 31,
1990, to review the observations
and data
on performance,
and to assess
licensee
performance
in accordance
with the guidance in
NRC
Manual Chapter
0516., "Systematic
Assessment
of Licensee
Performance."
The
guidance
and evaluation criteria are
summarized
in Section III of this
report.
The Board's findings,and
recommendations
were forwarded to the
NRC Regional Administrator for approval
and issuance.
This report is the
NRC's assessment
of the licensee's
safety performance
at D.
C.
Cook Nuclear Plant for the period July 1,
1989,
through
August 31,
1990.
The
SALP Board for D.
C.
Cook Nuclear Plant was
composed of the following
individuals:
Board Chairman
H. J. Miller, SALP Board Chairman, Director, Division of Reactor
Safety
(DRS)
Board Members
E.
G. Greenman,
Director, Division of Reactor Projects
(DRP)
R.
C. Pierson,
Project Directorate, Office of Nuclear Reactor Regulations/
Project Directorate
(NRR/PD) III-I
W. L. Axelson,
Deputy Director, Division of Radiation Safety
and
Safeguards
B. Clayton, Chief, Reactor Projects
Branch 2,
T.
G. Colburn, Senior Project Manager,
NRR/PD III-I
B. L. Jorgensen,
Senior Resident
Inspector,
Other Attendees
at the
SALP Board Meetin
A. B.
C. J.
M. A.
G.
C.
B..L.
J.
R.
M.
C.
Davis, Regional Administrator,
Region III
Paperiello,
Deputy Regional Administrtor, Region III
Ring, Chief, Engineering
Branch,
Wright, Chief, Operations
Branch,
Burgess,
Chief, Reactor Projects
Section
2A,
Creed,
Chief, Safeguards
Section,
DRSS
Schumacher,
Chief, Radiological Controls
and Chemistry Section,
DRSS
I&
Other Attendees
at the
SALP Board Meetin
con't.
W.
G. Snell, Chief,
Emergency
Planning Section,
DRSS
J.
A. Isom, Senior Resident
Inspector,
D.
G. Passehl,
Resident
Inspector,
E.
R. Schweibinz,
Senior Project Engineer,
P.
S. Koltay,
NRR, SIB
M. L. Dapas,
C. A. Carpenter,
M. L. McCormick-Barger,
Reactor Engineer,
F. A. Maura,
Reactor Inspector,
Z. Falevits,
Reactor Inspector,
J.
M. Ulie, Reactor Inspector,
C.
F. Gill, Senior Reactor
Programs Specialist,
DRSS
J.
A. Gavula,
Reactor Inspector,
II.
SUMMARY OF RESULTS
Overview
The licensee's
was acceptable
effectiveness,
improvement in
overall performance
level during this assessment
period
in all areas.
The degree of management
attention
and
however,
ranged
from commendable
in
some areas
to needing
others'he
licensee
generally
conformed to its
own standards,
which were appropriately
directed to the needed
assurance
of safe performance.
In a couple of
areas,
however,
there
was
a lack of progress
in achieving resolution of
identified weaknesses.
Management
appeared
proactive
and effective in meeting high standards
of
performance
in operations,
emergency
preparedness,
and security,
and
consistently
demonstrated
a conservative
operating philosophy..
Tolerance
of prolonged
weaknesses
in maintenance
and in engineering/technical
support
was noted.
Over the period,
some
improvements
were noted in maintenance
support
systems
and in plant housekeeping
and material condition.
Additional
planned
changes, if well implemented,
should result in an overall
improvement
in the of quality of the management
and implementation of maintenance.
Weaknesses
in engineering/technical
support adversely affected
capabilities in other areas,
especially
maintenance,
and
some were long
standing.
There is reason for concern
about the adequacy
of design
development,
and implementation
and control of modifications.
This is
based
on identified instances
of failure to achieve
compliance for such
issues
as Appendix
R design
requirements,
problems with design
verification, and continued identification of design calculation errors.
Material
and personnel
resources
were generally
adequate
in all areas.
Organizational
changes
and adjustments
in resource
allocations
were
made
in some areas
which appeared
appropriate
to address
some previous problems.
These
had not yet had significant effects at the end of the assessment
period.
The performance
ratings during the previous
assessment
period and
this assessment
period according to functional areas
are given below:
Functional
Area
Rating Last
Period
Rating This
Period
Trend
Plant Operations
Radiological Controls
Maintenance/Surveillance
Emergency
Preparedness
Security
Engineering/Technical
Support
Safety Assessment/equality
Verification
1
2
2
1
2
.2
2
~
1
2~ 3A'
1
3
2
improving"
- Rating changed
from a
2 to a
3 improving by Regional Administrator
III. CRITERIA
Licensee
performance is assessed
in selected
functional areas.
Functional
areas
normally represent
areas
significant, to nuclear safety
and the
environment.
Some functional areas
may not be assessed
because
of little
or no li'censee activities or lack of meaningful observations.
Special
areas
may be added to highlight significant observations.
The following evaluation criteria were
used to assess
each functional
area:
l.
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. events (including response
to, analyses
of, reporting
of, and corrective actions for);
5.
Staffing (including management);
and
6.
Effectiveness
of training and qualification program.
However, the
NRC is not limited to these criteria and others
may have
been
used where appropriate.
On the basis of the
NRC assessment,
each functional
area evaluated is
rated according to four performance
categories.
The definitions of
these
performance
categories
are
as follows:
~Cate or
1:
Licensee
management
attention to and involvement in nuclear
safety or safeguards
activities resulted
in a superior
level of performance.
NRC will consider
reduced levels of inspection effort.
~Cate
or
2:
Licensee
management
attention to and involvement in nucle'ar
safety'or
safeguards
activities resulted
in a good level of performance.
NRC will consider maintaining
normal levels of inspection effort.
~
Cate<aCor
3:
Licensee
management
attention
to and involvement in nuclear
safety or safeguards
activities resulted in an acceptable
level of
performance;
however,
because
of the NRC's concern that
a decrease.
in
performance
may approach or reach
an unacceptable
level,
NRC will
consider
increased
levels of inspection effort.
~Cate
or
N:
Insufficient information exists to support
an assessment
of licensee
performance.
These
cases
would include instances
in which
a r'ating could not be developed
because
of insufficient licensee
activity or insufficient
NRC inspection.
The
SALP Report
may include
an appraisal
of the performance
trend in a
functional area for use
as
a predictive indicator.
Licensee
performance
during the assessment
period should
be examined to determine whether
a
trend exists.
Normally, this performance
trend should only be used if
a definite trend is discernible.
The trend, if used,
is definedas:
~lm rovin
Licensee
performance
was determined to be improving during
the assessment
period.
~Dec111fnin
Licensee
performance
was determined
to be declining during
the assessment
period,
and the licensee
had not taken meaningful
steps to
address this pattern.
IV.
PERFORMANCE ANALYSIS
A.
Plant 0 erations
1.
A~nal sis
Evaluati'on of this functional
area
was based
on the results of
12 routine inspections
and
1 special
(augmented
team)
inspection
by resident
and regional
inspectors.
Enforcement history in this functional
area
was comparable
to
that of the previous
assessment
period.
One violation involved
an equipment configuration control problem,
one involved
multiple failures to document shift turnover log reviews
as
required
by procedures,
and one involved the failure of a
non-licensed
equipment operator'to
perform and to document
required
rounds.
The licensee
took strong disciplinary action
against
the equipment operator for his misconduct
and applied
a
programmatic
approach to ensure that other equipment operators
clearly understood their assignments
and were performing and
documenting
them completely.
The violations were not repetitive
or otherwise greatly significant from a programmatic
or safety
standpoint.
The number of events that required submittal of licensee
event
reports
(LERs) continued to decline in this functional area.
One
LER corresponded
to the violation involving configuration
control, another
was
a voluntary report of an operator
equipment
manipulation error,
and
a few more involved fire protection
program activities, typically incomplete implementation of
required compensatory
measures.
This last category
appeared
slightly improved in that fewer events
occurred
compared to the
previous
assessment,
but events
were clustered
in the middle of
the current period.
In responding
to these
events,
management
,appeared
properly focused
on the
need to reduce
the administrative
burden
on plant operators,
rather
than
make it more complex,
so
that operators
could concentrate
on monitoring the reactor
and
its associated
safety
systems.
Only two reactor trips occurred in the entire period,
both
on
Unit 2.
This performance
compares
favorably to the four Unit 1
trips and two Uni't 2 trip signals
(no rod motion) that occurred
during the previous
assessment
period.
Both current reactor
trips were caused
by random equipment failures.
Both units operated
almost continuously throughout the
period,
except for a scheduled
Unit 2 refueling outage
in the
last
2 months.
Still, operators
were occasionally challenged
to respond to plant transients.
These
included both Unit 2
one of which was corhplicated
by a significant
loss of control
room instrumentation
from the initiating event.
By following procedures
and taking appropriate actions,
operators
safely recovered
from this event. despite
the complications.
Other transients
included
a substantial
Unit
1 power reduction
to re-isolate
the ice condenser,
a Unit 2 thimble tube leak,
and
a couple of "Unusual
Event" conditions
caused
by electrical
faults.
Operators
also
responded
well (conservatively
and
without any error) to these
events.
Likewise, routine plant
startups
and shutdowns,
though few, were all completed
uneventfully.
On the other hand,
although equipment configuration
control errors were rare
and only once approached
the level that
calls for mandatory
LER reporting,
some lesser errors did occur
late in the period.
These
included making different components
in opposite trains concurrently inoperable,
contrary to the
licensee's
administrative control practices;
mispositioning
a
diesel
control air dryer valve; installing locks
on essential
service water valves in a way that did not prohibit valve
operation;
and starting
a recirculation fan instead of a recombiner.
The licensee
documented
each of these
occurrences
for detailed
corrective action review,
and in several
cases,
applied the
Human Performance
Evaluation
System
(HPES) to ensure
consistency
and thoroughness
in assessing
root cause.
5
Operations
Department
management
was actively involved in the
assurance
of quality of performance
in this functional area.
This was evident in mariagement's
consistent,
safety-conservative
operating philosophy in dealing with issues,
in their swift,
strong action to deal with an auxiliary operator
who was delinquent
in performing his duties,
and in their continued insistence
on
a high standard of formality and decorum in control
room
operations
and communications.
The licensee's
command
and
control during plant manipulations
were uniformly excellent.
The plant manager
continued
a policy of being personally present
in the control
room for significant scheduled
evolutions,
whatever the day or hour.
The time spent
by corporate
management
onsite,
including direct
observation
and assessment'in
the control
room,
was substantially
increased
during this appraisal
period.
The Vice
President-Nuclear
was normally at the plant at least
one day
each
week.
This executive
was present
on both occasions
when
electrical faults caused
"Unusual
Event" condit'ions
and was able
to personally
observe
the response
of his staff to these
events.
Licensee
management
kept abreast of plant operating
parameters
and trends,
both by direct observation
and by monitoring systems
of data collection
and reports.
The licensee's
approach to the resolution of technical
issues
from a safety standpoint related to operations
remained
sound
and conservative.
When questions
arose
concerning
the status of
post-maintenance
testing
on check valves
one day after
the
Unit
1 startup
from refueling (a few days into this assessment
period), operators
immediately returned the unit to Mode
5 while
the situation
was studied
and rectified.
Established
policy to
limit interactions with safety
components
(inspections,
tests,
repairs, etc.) to
a single train served to unburden shift
personnel
from having to make frequent interpretations
of
operability interfaces
and implications.
Likewise, continued
progress
on the computerized
"clearance
permit" system
served
to reduce
the potential for error inherent in developing
clearances
on
an ad hoc basis.
One apparent
counter-example
to
the general
tendency to expeditiously
move to
a conservative
plant mode to resolve questions
occurred.
This involved a
delayed decision to take Unit 2 to Mode
5 in January
1990 when
problems
were encountered
with the performance of the main steam
isolation valves.
During the delay,
however,
the operability
of these
valves
was repeatedly
demonstrated
while. the problem
(condensate
collection in the operating cylinder) was studied.
Throughout the
SALP period,
housekeeping
and the material
condition of the plant improved, but did not achieve
exceptionally
good levels.
Plant lighting was poor early in
the period but improved with an upgrade
program the licensee
started
in late
1989.
Some
examples of poorly lighted areas
remained
through the
end of the period.
The licensee
had an ample operating staff, with licensed
personnel
assigned
to operating shifts well in excess
of the requirements
of Technical Specifications.
The Operations
Department
made
very limited use of overtime.
A five-shift rotation
was used,
with a new schedule
of 12-hour shifts being
implemented in the
middle of the assessment
period (February
1990) after more than
80 percent of the affected staff vote'd to endorse this schedule.
The licensee carefully prepared for the transition to 12-hour
shifts,
and potential
problems (overtime scheduling
and control,
"shiftwise" frequency for activities, etc.) were averted.
Further,
the licensee
conducted
continuing assessments
to
determine whether personnel
exhibited
any loss of alertness
late
in the extended shifts.
The licensee
found no such indications.
The training and qualifications
programs for personnel
performing
in this functional
area
appeared
to be effective and to contribute
to hi'gh-quality performance.
Unit
1 operated this cycle and
utilized
a reduced
primary coolant
system pressure/temperature
with no associated
problems.
Likewise,
as previously noted,
the
licensee
conducted
scheduled
plant evolutions including startups,
shutdowns,
and major power-level
changes without
a single
significant operational
error.
Personnel
made
few errors,
but
as previously noted,
personnel
did make. some errors in equipment
.
configuration control.
One
such error resulted in one of the
violations, which was also
a subject of a management
meeting
between
NRC Region III staff and the licensee early in the
assessment
period.
Through the middle of the period,
configuration control appeared
to be excellent.
Then, late in
the period,
a few more errors of minor significance occurred.
During this assessment
period, the plant control-room simulator
and
a number of operating,
off-normal,
and emergency
procedures
for the plant were exercised
by an
NRC inspection
team.
The
inspectors
found the procedures
generally effective and free of
significant flaws.
The simulator remained
a major, asset
in the
overall training and qualification of the staff.
2.
Performance
Ratin
The licensee's
performance is rated Category 1'n this area.
The licensee'
performance'as
rated Category
1 during the
previous
assessment
period.
3.
Recommendations
None.
B.
Radiolo ical Controls
l.
~Anal sis
Evaluation of this functional area
was based
on the results
of seven
inspections
by regional
inspectors
and observations
by resident inspectors.
Enforcement-related
performance
in this area
was good.
One
Severity Level IV violation was identified.
Although this
violation did not constitute
a programmatic
breakdown
in licensee
radiological controls, it involved a weakness
in pre-job planning
and the licensee's
review of a contracted
safety valve testing
job which caused
a minor injury, hot particle spread,
and
personnel
and area contaminations.
Staffing, training,
and qualifications were generally
good.
The staff turnover rate for RP was very low; thus, the experience
level increased.
However, the turnover rate for chemistry
technicians
was high.
The licensee
continued to reduce its
dependence
on contract
RP technicians.
The assignment
of an
ALARA (as
low as reasonably
achievable)
representative
to the
planning/scheduling
staff was
an improvement.
J Overall,
managem'ent's
involvement in ensuring quality showed
significant improvement in the support of radiological controls
at the plant manager
level during the
second half of the assessment
period.
The licensee
has
improved the
Use of the radiological
awareness
reporting
system to record,
investigate,
and initiate
c'orrective action
on radiological
problems identified by station
personnel
and has initiated an aggressive
program for hot
particle
and contamination
controls
The licensee is continuing
to make progress
on actions to address
weaknesses
identified in
the maintenance
team inspection
as evidenced
by improved
integration of ALARA/RP controls into the maintenance
process.
An exception
appeared
to be the safety valve testing work
previously noted.
Management
weakness
was also noted in the
event involving low-level iodine exposure
to a number of workers
in containment that resulted
from poor communication
between
the
~ operations
and radiation protection groups.
This was
a recurrent
problem,
also
noted in the previous
assessment
period.
This
poor communication
also
appeared. to be
a factor in the
somewhat
fragmented responsibility for oversight of releases
through the
turbine building sump.
Management
has
supported
a good water
chemistry program that conforms to industry guidelines,
and its
monitoring of secondary
water chemistry
and data handling
has
improved.
The licensee
addressed
most of the inspection
concerns identified
during this period,
as evidenced
by the implementation of the
valve recovery
program to reduce
leaking valves,
making
'perational
a second whole-body counter,'pgrading
methods of
counting
and documenting
smear surveys,
improving laboratory
quality assurance/quality
control (gA/gC) and chemistry parameter
trend charts, initiating a training program for long-term
contract radiation protection technicians,
and addressing
concerns
related .to personnel
contamination
events originating
at the upper
and lower containment exit control
points'he
licensee's
approach to the identification and resolution
of technical
issues
was generally
good.
Personnel
contamination
events
(PCEs)
were occurring at
a significantly lower rate in
1990 compared with 1989.
A high percentage
of PCEs appeared
to
involve hot particles,
but this may be
a result of the licensee's
improved hot particle identification program.
The licensee
also
significantly reduced
contaminated
areas.
The total station
dose in 1989 was 534 person-rem,
indicating adequate
performance.
Reported liquid and gaseous
radioactiv'e effluents were well
within Technical Specification limits, and
a downward trend in
the generation
of solid radwaste
was evident,
No transportation
events
were identified.
Inspectors
noted performance
weaknesses
were evident in the events that involved the containment
exposures
and the safety valve test.
The licensee's
performance
in the nonradiological
confirmatory
measurements
program was good, with 27 agreements
in 33
comparisons.
After instrument recalibration, this figure
improved to 32 agreements
in 33 comparisons.
The licensee's
performance
in the radiological confirmatory measurements
program was fair, with only 63 agreements
in 85 comparisons.
.Eighteen of the disagreements
were caused
by the insensitivity
of -the licensee's
counting
systems
which resulted
in failure to
identify the radionuclides.
The licensee
installed
a new,
improved system,
which should
be operational
early in the next
assessment
period.
Split samples of liquid radwaste
analyzed
by
a licensee contractor
agreed
in all five comparisons.
The
Radiological
Environmental Monitoring Program
(REMP) appeared
to
be operating
in accordance
with regulatory requirements.,
and-
equipment
was well- maintained.
However,, the licensee's
uncertain
knowledge regarding the
use of the local groundwater aquifer for
drinking water was
a weakness.
2.
Performance
Ratin
The licensee's
performance is rated Category
2 in this area.
The licensee's
performance
was rated Category
2 in the previous
assessment
period.
3.
Recommendations
None.
C.
Maintenance/Surveillance
l.
A~nal sis
Evaluation of this functional
area
was based
on the results of
12 routine inspections
performed
by resident
inspectors
and
5
routine or special
inspections
by regional
inspectors,
including
a December
1989 maintenance
team inspection.
Two Level
IV violations were issued during the assessment
period
compared to eight during the previous period.
One violation was
for failing to take required
compensatory
action for a
surveillance test failure.
The second
involved multiple examples
of failing to follow procedures;
one of the examples specifically
tl
involved maintenance activities and two examples
involved
surveillance activities.
Mhile the violations were not of
major safety significance,
occasional
examples of procedural
violations were also noted during the previous
SALP period.
Furthermore,
during
a Safety System Functional
Inspection
(SSFI)
conducted
near the
end of the
SALP per'iod, failures to follow
procedures
in 'maintenance
and surveillance
were again observed.
The number of events in this functional area,
requiring submittal
of LERs,-decreased
slightly during the appraisal
period.
During
the current period,
a few of the
LERs were caused
by equipment
problems;
some were caused
by procedure deficiencies,
and the
remainder resulted
from human errors.
As'during the previous
period, essentially all of the reportable
events
involved
surveillance testing.
The current events
were not repetitive
and lacked generic or programmatic implications.
Further,
none
of the events
in this functional area
had major safety
significance.
In the first half of the assessment
period,
management
involvement
in maintenance'as
noted
as weak;
however,
improvements
were noted
in the latter part of the period.
The maintenance
program contained
a number of programmatic
weaknesses
as noted in the following examples.
The preventive
"maintenance
program focused principally on equipment
covered
by the technical specifications;
only limited consideration
was given to vendor recommendations
for plant equipment.
Significantly greater
maintenance effort was given to corrective
maintenance
rather than
maintenance
to prevent
or reduce
equipment fai lures.
At the time of the maintenance
team
inspection,
the absence
of an integrated
approach to planning,
scheduling,
and coordination for corrective
and preventive
maintenance
was
a contributor to. unnecessary
equipment
downtime
and
a large backlog of non-outage
corrective maintenance
job
orders.
Adding to this problem,
planners
and schedulers
did not
have formal job descriptions
and were not thoroughly trained in
their tasks.
There were also
examples of work histories
that were poorly recorded
on job orders,
which detracted
from
the ability to accurately trend problems
and develop
good root
cause
analysis of component failures'lso,
post maintenance
test requirements
were not always sufficiently specific
or detailed.
In December
1989, there
were
a significant
number of steam,
water and oil leaks noted in the plant
during the maintenance
team inspection.
For example,
there
were
numerous
packing leaks; oil, fuel
and water leaks were
noted
on the emergency diesel
generators
and
a large
number of
minor fluid leaks were noted in the auxiliary building.
Some of the leaks involved contaminated
water;
however,
plastic containments
were in place to contain the leaks
and
minimize radiological problems.'n
the latter part of
the appraisal
period,
some
improvements
were noted in the plant
material condition as well as maintenance
support
systems
such
as uniform setting of priorities and centralizing
preventive
maintenance activities.
10
Examples of positive management
involvement included incorporating
industry experience
with check valve problems into applicable
maintenance
procedures,
conducting
a broad outage job order
review when
one job was found that lacked
a post maintenance
test,
and performing
a generic
review of implications of "Bellevilie"
washer decompression
in some motor operated
valve applications.
The quality of surveillance
procedures
remained
good,
and
developed
maintenance
procedures
were adequate
in most cases.
The surveillance
program which verified component availability
was performed in a timely manner with good procedural
control.
Findings
showed
a high degree of reliability for safety related
equipment.
However,
maintenance
jobs were frequently performed
without detailed
procedures.
The licensee
continued to rely on
first line supervisors
to provide additional
needed details
for
a given job rather than providing formal procedures
or
instructions to include these details.
The lack of maintenance
procedures
occasional,ly resulted in poor,
incomplete,
or
incorrect work.
A specific example
involved the charging
pump
seal
replacement.
For maintenance activities conducted late in the appraisal
period,
some jobs
showed evidence of improved planning;
however,
there
was also
some evidence of poor planning
and scheduling of
electrical
maintenance activities.
There were cases
when
personnel
failed to adhere to procedures,
or excessive liberties
were taken with procedural
intent as noted in the violations.
Late in the appraisal
period the licensee
placed
an increased
emphasis
on improving compliance to maintenance
and test
procedures;
however,
there were still instances
of weak
maintenance
procedures.
The licensee's
approach to resolution of technical
issues
from a
safety standpoint
was of mixed quality.
When the licensee
recognized
or believed that
an issue
had potential
safety
significance,
a conservative
approach
was generally taken.
Examples include (1) the approach to the incore tube thinning
problem, (2) development of effective preventive maintenance
for
vital instrument electrical
power supplies,
and (3) performance of
special
main
steam isolation valve monitoring processes
to ensure
timely identification of potential degradation.
Conversely,
the licensee
sometimes
did not initially respond
with a broad or conser'vative
approach.
Examples of this include
the failure to recognize
the implications of the main steam
isolation valve test failures of June
1989
and January
1990,
and questionable justification for short-duration
Type
C pressure
drop tests'he
licensee
changed its approach
on each of these
items
upon questioning
by NRC.
Because
the main steam isolation
valve test results
were not given adequate
attention,
the
cause-effect
relationship
between
dump valve leakage
and poor
main
steam isolation valve performance
was not recognized
and
known dump valve leaks
had low priority for repair.. There were
li
S
also
a few instances
of rework because initial repair attempts
were unsuccessful,
and the licensee
did not always thoroughly
investigate
the root cause of equipment failures.
Staffing in this functional
area
was generally adequate.
However, the license relied heavily on contracted
workers to
perform substantial
amounts of less 'complex maintenance
work.
This caused
or contributed to work schedule
coordination
problems
and to
some instances
of job-related
paper work duplication
and
confusion regarding work status.
An example of this problem
involved the work on the breaker for the emergency
incoming feed
for emergency diesel
generator
2AB.
There were occasional
examples of 'poor work practices
by both plant and contractor
personnel.
For example,
undocumented
temporary repairs
were
installed, incorrect torque values
were used,
post-work area
inspections
were omitted and areas
were left dirty, and
some
detailed procedural
controls (including administrative controls)
were not followed.
A licensee
sponsored
staffing study
recommended
converting
some
contract workers to permanent
maintenance
workers.
The degree
to which this recommendation will be implemented,
and the
schedule,
were not immediately established
but remained
in
development at the close of the assessment
period.
Overtime was
'enerally
well controlled
and not excessive.
NRC guidelines for
control of overtime were rarely approached.
Mhen brief instances
of demand for high overtime arose,
they were properly reviewed
and approved.
The licensee's
training and qualification programs resulted
in
a force of knowledgeable
site workers for the performance of
maintenance
and surveillance tasks.
Overall the skill level of
plant craft personnel
was very good.
Expertise of other staff
(e.g.,
schedulers,
supervisors)
.was adequate.
Mhile chronic programmatic
weaknesses
were noted in the
maintenance
area early in the appraisal
period,
the licensee
planned
several
maintenance
improvement initiatives.
However,
implementation of the licensee's
planned
program
improvements,
including the aspects
of the reliability centered
maintenance
effort, have
been
slow, deliberate
and have not yet been fully
effective at improving the maintenance
process.
2.
Performance
Ratin
Licensee
performance is rated Category W3" with an improving
trend in this functional area.
The previous rating was
Category
2.
- Rating changed
by the Regional Administrator from a Category
2 to
a
Category
3 with an improving trend.
.12
n
3.
Recomendations
Accelerated
implemeptation of all maintenance
improvement
programs
and increased
RIII inspection after 9-12 months.
D.
Emer
enc
Pre aredness
1.
~Anal sis
Evaluatiop of this functional
area
was based
on three
inspections
by regional
inspectors
and observations
made
by
resident
inspectors.
Enforcement-related
performance
remained excellent.
No violations
were identified during this assessment
period or the previous
period.
Management's
involvement in assuring quality continued to be
very good.
Corporate staff members
are assioned
to conduct
in-depth quarterly internal audits of selected
program areas.
Management's
support of the emergency
preparedness
program was
excellent,
and program requirements
have
become part
of= the
normal plant survei llances
and operations.
Program
enhancements
by the licensee
during this assessment
period included (1) the
implementation of monthly drills, (2) creation of a permanent
scenario
development
committee,
(3) agreements
with a second
hospital to provide medical
support facilities,
and (4) several
additions
and upgrades
to emergency
response facilities and
equipment.
Staffing of the emergency
response
organization
(ERO) was
excellent throughout this assessment
period.
The licensee
maintained
a roster of qualified personnel
available to fill
all
key positions in the
ERO.
The ability of licensee
personnel
to respond
was well demonstrated
by their timely response
and
activation of emergency
response facilities during the
May 24,
1990, "Alert" declaration.
The emergency
plan training program
was good.
The program
provides extensive initial training and has established
practical
factors demonstrations
required,
which includes completion of
position-specific "qualification cards" for all
ERO members.
Periodic participation of
ERO member s in drills or exerci ses is
also required.
These
requirements
have
been
met for all
members.
Inspectors
found that annual retraining requirements
were less clearly defined
and identified
some ambiguity between
program areas.
The licensee initiated immediate actions to
clarify the ambiguity between initial and annual training
programs
and to clearly define emergency
preparedness
retraining
requirements.
They also
have
an aggressive
schedule
to completely
review all emergency
response
training and to resolve
any
identified concerns.
13
The l.icensee's
resolution of technical
issues
from a safety
stand-point
was excellent
and consistently conservative.
In
response
to emergency
plan activations,
the licensee
conducted
post-activation
reviews for each event to identify areas that
could be improved.
Items identified through these
reviews
of real events,
as well as critiques of drills and exercises,
internal
and external
audits,
and inspections,
were effectively
tracked
and appropriately
resolved
by the licensee
in a timely
manner.
The licensee's
response
to operational
events
was excellent.
A
total of eight events
were classified
and reported pursuant to
10 CFR 50.72 as
emergency
plan "Unusual Events."
One event
involving an explosion
and fire in the plant switchyard
on
May 24,
1990,
was upgraded
to an "Alert" when the licensee
decided to reduce Unit 1 power output to minimize the risk of a
plant transient during necessary
switching.
Each event
was
correctly classified in a timely manner.
Appropriate
notifications to the State.,
counties,
and the
NRC were
made
within the required time limit for each event.
The licensee
effectively utilized the emergency
response facilities,
procedures,
and organization to evaluate
plant conditions
and
anticipated actions to successfully mitigate the consequences
of
the
May 24,
1990,
"Alert".'he
licensee
kept its emergency
plan
and implementing procedures
current by conducting appropriate
periodic reviews.
When
necessary,
the licensee
made revisions in a timely manner
and
appropriately distributed the revisions.
Emergency
response
facilities and equipment
have
been well maintained
and are
inventoried,
inspected,
response
checked,
and tested for
operability, in accordance
with a well-defined surveillance
program.
The licensee
demonstrated
an excellent
emergency
response
capability in both emergency
exercises
evaluated
during
this assessment
period.
Inspectors
identifi'ed no exercise
weaknesses.
The licensee
greatly improved exercise
realism by
including the
use of a plant simulator with the
1989 exercise.
The
1990 exercise
was consider'ed
complex
and particularly
challenging
since it was conducted off hours,
was initiated at
0100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />,
and was not announced
to station
employees
or State
and county participants.
2.
Performance
Ratin
The licensee's
performance is rated
a Category
1 in this area.
The licensee's
performance
was rated
a Category
1 during the
previous
assessment
period.
3.
Recommendations
None.
~Securit
1.
~Anal sis
Evaluation of this functional area
was based
on the results of
four inspections
conducted
by regional'nspectors
and
'bservations
made
by the resident
inspectors.
Enforcement-related
performance
improved during this assessment
period
and is considered
excellent. 'nspectors
identified no
violations during thi s assessment
period while they identified
four violations during the previous period.
Management's
involvement in assuring quality was excellent.
Senior management
aggressively
supported security initiatives as
evidenced
by (1) upgrades
of the security
system,
(2) reduction
in personnel
errors involving security,
(3) ample allocations of
both personnel
and equipment resources,
(4) extensive
management
overviey and thorough planning,
and (5) self-audits
and
surveillances
by quality assurance
and security personnel.
The
high level of security awareness
that exists within the plant
work .force contributed to
a positive attitude towards security
and
a reduction, i'n errors.
1
The licensee's
approach
to th'e identification and resolution of
technical
issues
was excellent.
The licensee
upgraded or
replaced
equipment before it reached
the end of its lifespan.
The licensee's
program included upgrades
such
as (1) the purchase
and installation of new state-of-the-art
closed circuit television
(CCTV) cameras,
including switching units
and replacement
of
existing cabling with fiber optics; (2) implementation of a
new
radio communication
system;
(3) upgrading of perimeter intrusion
detection
system (IDS); and (4) installation of a "video capture"
assessment
system to aid in perimeter
alarm assessment.
In
addition, the licensee
developed
a 5-year security equipment
replacement
plan to assist
in continuous
upgrading of security
equipment,
taking into consideration
maintenance
requirements
and performance capabilities of the current equipment.
This
plan will also
be used
as
a guide for replacement
and budgeting
for new equipment
before the equipment
reaches
the
end of its
lifespan.
These proactive efforts by the licensee
have reduced
the
number of false or nuisance
alarms
and
have greatly increased
the reliability of the detection
system
and assessment
capabilities.
The technical
coordination
and working
cooperation
between
the security
and the maintenance
work units
was excellent.
The overall'effectiveness
of the
security-related
equipment
was attributed to diligent and
competent technical
maintenance
support.
However, inspectors
raised
a concern
about the timely repair of security lighting.
Although lighting requirements
were maintained,
some security
lights were not repaired
in a timely manner
and
no preventive
maintenance
program existed for security lighting.
15
The licensee's
attention to security issues
is excellent.
Security
and site 'management
aggressively
pursue
and evaluate
all issues that can strengthen
the security program.
This is
evidenced
by the involvement
and support of site management
to
significantly reduce
personnel
errors involving badge control
and unsecured
security doors.
The decline in personnel
errors
in security 'procedures
is the result of careful tracking and
trending by management
of not only the
number of incidents,
but
of the individuals involved, their employer,
and the responsible
department
head or contractor representative.
Individuals
responsible
for each event,
as well as their respective
supervisors
and department
heads,
are held personally accountable.
In
addition, .the licensee
analyzes
each
event for root cause
by
taking into consideration
human factors
and equipment.
The licensee's
security staffing and other staff,.resources
dedicated to'he security organization
were ample
and
effectively utilized.
This was demonstrated
by the licensee's
internal security force structure that effectively blends
the
utility and contractor organization into elements that are
each
responsible
for implementing specialized
portions of the
security program,
including portions of the fitness for duty
(FFD) program.
These
elements
operate
independently
but are
monitored by security management
personnel
who coordinate
the
effectiveness
of the overall security program.
The close
and
effective liaison established
between
the security contractor
and the licensee's
security managers
is
a major strength of the
program.
guality assurance
audits of the security program
make
a positive contribution to the security organization's
overall performance.
The audits are aggressive,
detailed,
broad
in scope,
and well documented.
As a result of management/employee
relations
programs,
the security force turnover rate for 1990 is
only about
3 percent,
which is the lowest rate yet achieved.
The licensee's
program for reporting required security events
and keeping the
NRC informed of security-related
issues
was
excellent.
Required reports
were accurate
and timely.
The
licensee's
program for logging security events
uses
appropriate
regulatory guidance,
was implemented
in a conservative
manner,
and ensured
good monitoring of potential
equipment
problems.
Security-related
records
were complete, well maintained,
and
readi ly'vai 1 abl e.
The training and qualification program for the security
organization
was generally
good and is well implemented.
The
licensee
has
completed,
a 2-year project of revising the
program to reflect up-to-date
industry guidelines.
Although
security is not subject to industry accreditation,
the licensee
undertook the revision to make security training methods
and
documentation
as consistent
as possible with other plant
department training methodology
and to provide
a more effective
means of conducting
and do'cumenting qualification of personnel.
16
f
The licensee's
fitness for duty program
was upgraded
and
implemented during this assessment
period in accordance
with 10.
CFR Part
26.
The licensee's
program
was
implemented
2 months
ahead of the required January
3,
1990,
implementation date.
2.
Performance
Ratin
H
The licensee's
performance
was rated Category
1 in this area.
The licensee's
performance
was rated Category
2 in the previous
assessment
period.
3.
Recommendations
None.
En ineerin /Technical
Su
ort
1.
~Anal sis
Evaluation of this functional
area
was based
on two routine
inspections,
one special
inspection,,
and
one team inspection
by
regional inspectors,
several
inspections
by resident
inspectors,
one
enforcement
conference,
a safety
system functional inspection
(SSFI)
team inspection,
and interactions
between
the licensee
and the staff of the Office of Nuclear Reactor Regulation
(NRR).
Enforcement history consisted
of five Level IV violations
reflecting the weaknesses
identified by several
inspectors
throughout this assessment
period.
There were few reportable
events
d'uring this assessment
period:
Among events that did not reach the requirement for reporting,
however,
were two cases
which indicated that the licensee
did
not always deal with matters of .lesser
significance
as effectively
as reportable matters.
Management's
involvement in ensuring quality in this functional
area continued to be of a mixed nature.
On the negative
side,
the licensee
had not effectively dealt with certain
problem
areas.
One area
was the lack of proper engineering
involvement
in activities as evidenced
by the interruption of on-going
activities during the replacement of control
room instrumentation
distribution 125-amp inverter breakers
due to breaker
incompatibility and wiring drawing deficiencies,
and the
inadequate
testing of the diesel
generator
relays,
due to inadequate
procedure
guidance
and test equipment.
A
further weakness
was the continuing identification of calculational
and design verification errors.
For example,
a pipe support
where the engineer initially failed to account for bending
in a pin,
and
a pipe support evaluation
where the most critical
load directions
were not considered.
Although subsequent
analysis
demonstrated
the loads to be acceptable,
the failure to
perform
a proper evaluation
demonstrated
a lack of attention to
detail.
Similar findings in the
ar ea of attention to detail
17
were noted by the
team inspection late in the assessment
period.
Numerous deficiencies
existed in the plant's fire protection
safe
shutdown
program.
These deficiencies
(inadequate
emergency
lighting evaluation
and inadequate
design control) continued to
exist even after
a number of years of program development
and
were identified by a licensee
audit conducted in preparation for
the
NRC team inspection of safe
shutdown capabilities.
Additional
items identified by the
NRC ( shortly after the
SALP assessment
period ended)
and not identified by the licensee
included
inadequate shift staffing procedure
regarding
minimum staffing
to perform post fire safe
shutdown procedures,
human factors
problems
in procedures,
and the potential
loss of both
units'ontrol
room
HVAC systems.
Cumulatively, the deficiencies
indicated
an inadequate
assessment
of applicable
Appendix
R
requirements,
and
a lack of attention to details
Positive
management
influences,
in response
to
NRC concerns
in
the last assessment
period,
were evident in the continued
implementation of organizational
changes at the corporate
level to
create
an engineering division dedicated to the
D.
C.
Cook plant,
stationing of several
additional corporate
engineering
personnel
on
site,
and the implementation of an independent
audit of the design
change
and control program.
Nevertheless,
the evidence indicates
that it is too early to determine
the effectiveness
of these
programs.
Other initiatives included taking an industry leadership
role in
designing
and seismically testing "temporary" scaffolding,
installing on-line steel alloy verification equipment,
equipment
environmental qualification, the prioritization and scheduling
of work, and the implementation of the requalification program,
where
a marked
improvement
was noted over the
SALP 7 assessment
period.
In the area of Appendix R, strengths
included the
reorganization
of the
Emergency
Remote
Shutdown
(ERS) procedures,
the
use of the
ERS procedure
status
check sheets,
and the fire
protection engineering
analysis related to fire detection,
suppression,
and fire barriers.
Engineering
and technical
support of licensing actions
was of
mixed quality, with the inaccurate
or incomplete submittals to
the
NRC appearing
to be caused
by a breakdown in communication
between
the licensee's
corporate
engineering
personnel
and the
site staff.
The licensee's
approach
to the identification and resolution of
technical
issues
from a safety standpoint
has
been of mixed
quality.
A conservative
emphasis
on safety
was evident in the
licensee's
approach to such issues
as
a potential
adverse
performance
trend for diaphragm-type
valves in heat-traced
systems,
a repetitive nonessential
(NESW) seal
failure phenomenon,
the potential for inadvertent
moderator
dilution inherent in the chemical
and volume control
system
(CVCS) crosstie modification,
and
a "hydraulic lock" condition
discovered
in manipulation of NESM isolation valves.
18
'nstances
occurred,
however,
in which the licensee failed to
identify the problem or appeared,
at least initially, to misjudge
or underestimate
the 'technical
or safety implications of issues.
Examples
included the susceptibility of the auxiliary feedwater
system to deadheading
one train by a
common miniflow line, the
implications of the main steam isolation valve performance
change,
the discrepancies
between
the size
and setpoints of the
thermal
overload trip devices in safety-related
motor circuits,
and the applicability of Regulatory
Guide 1.97 to power supply
separation
for the wide-range
level instruments.
However, the licensee
generally responded
appropriately
when
issues
such
as these
were presented.
Staffing for engineering
and technic~1
support
was ample,
pnd
personnel
were adequately qualified.
The licensee's ability to
apply these
resources
effectively, however,
remained
somewhat in
question.
During this assessment
period,
the licensee
implemented
initiatives involving corporate
engineering
support reorganization
and onsite implementation of a system engineer
program.
Both
initiatives appear to have long-range
promise,
but short-term
effects were not remarkable
and were partially offset by early
communication
and coordination hurdles inherent in the nature of the
changes
themselves.
Training and qualification program activities were generally
adequate.
The licensee
implements
a defined training program
across multiple disciplines,
including technical staff training.
The licensee's
requalification program was effective in preparing
the operators for the NRC-administered
examinations.
However, for
initial examinations,
the program
showed weaknesses
in the
simulator training of new operators.
This weakness
was reflected
in a low passing
rate
(59 percent) for the first examination
using the plant specific simulator.
Improvements
in the training
program, especially in the exercise of the emergency
operating
procedures,
resulted in an 89 percent passing
rate late in the
assessment
period.
2.
Performance
Ratin
The licensee's
performance
is rated Category
3 in this area.
The
licensee's
performance
was rated Category
2 in the previous
assessment
period.
3.
Recommendations
Design control
needs
improvement
as does support to
maintenance.
Region III needs to increase
inspection.
G.
Safet
Assessment/
ualit
Verification
l.
~Anal sis
This functional area
was evaluated
based
on results of twelve
inspections
by the resident
inspectors
and several
inspections
19
n
by regional
inspectors.
In addition, the
ARC staff's reviews of
licensee
submittals
and requests
for amendments
to the operating
licenses
were considered.
The enforcement history in this functional
area consisted
of one
Severity Level III violation and four 'Severi-ty Level
IV violations.
This is an increase
in enforcement activity compared to the two
Level IV violations noted in the previous
assessment.
The Level
III violation involved the long-term conditional inoperability
of the Unit 2 turbine-driven auxiliary feedwater
pump, for which
a $75,000 civil penalty was
imposed.
The violations all involved
inadequate
or untimely corrective actions for identified problems.
They were otherwise dissimilar,
and
none appeared
programmatic
in nature.
The Level III violation involved
a program deficiency
which no longer existed during the current assessment
period.
The only LERs in this area
were related to three of the
violations.
, The involvement of the licensee's
management
in assuring quality in
this functional
area
was mixed.
On the positive side,
an
organizational
change
elevated
the plant's Safety
and Assessment
Department
so that it reported directly to the plant manager.
The plant's
senior
managers
stayed well informed about
activities'nd
results
by monitoring performance
information and by active
participation in both the Problem Assessment
Group
(PAG) reviews
and the Plant Nuclear Safety
Review Committee
(PNSRC) activities.
The information derived in these
evaluations
and reviews appeared
to be appropriately applied in nearly all cases.
The occasional
recurrence
of a previously identified problem was
an exception.
Management
coptinued to support various self-improvement
initiatives, several
of which were carried
over from the previous
appraisal
period, including: (I). computerization of long-range
planning processes
and of an integrated
information management
program; (2) broadening of the Quality Maintenance
Team program;
and, (3) retaining of technical consultants
for critical self-
assessments.
One example of the latter initiative was the audit
by CYGNA Energy Services of design practices for the Cook plant.
The lengthy duration of some of these
self-improvement
programs
raised questions
about the amount of resources
and management
commitment applied to bring them to completion.
Management
took
strong steps to "reclaim" the auxiliary building after problems
were identified with material condition and storage of extraneous
materials.
The licensee
continued to operate
a large-volume low-threshold
corrective action program, with a focus
on timely classification
and segregation
of potentially significant items for higher-level
review.
The program retained
a focus
on the potential for
repetitive problems
and was sensitive to identification of
possible
adverse
trends.
In the Appendix
R area,
however,
the deficiencies identified during the most recent
NRC inspection
(conducted shortly after the
SALP assessment
period ended)
were
similar to
some
1982 Appendix
R post-fire safe
shutdown inspection
'20
findings.
For events potentially involving personnel
error, the
licensee
used the
Human Performance
Evaluation
System
(HPES) to
evaluate
selected
items.
However, the reviews were not always
completed in a timely manner
because
the position of HPES
Coordinator
was temporarily vacant
on two occasions.
Further,
management
did not follow HPES reviews closely
and was unaware
that
some reviews
remained
"open" for more than
a year.
One problem which the licensee
apparently did not adequately
address
involved design calculation deficiencies.
Even though
problems
were recognized
by the licensee
as early as
1987,
the
licensee did not initiate prompt corrective actions
nor thoroughly
apply additional
adequate
verifications of design calculations
during the current assessment
period.
As
a consequence,
some
design assumptions,
references,
and calculations
contained
avoidable errors.
It was noted that calculations
performed
later in the assessment
period did not contain errors similar to
those
noted at the beginning of'he period.
However,
implementation
of the verification process
remained
incomplete.
Further,
a
maintenance
self-assessment
from early
1988 contained
about
70
recommendations
for enhancements
or corrective actions.
Followup
on about half of these
was later judged to be incomplete
because
management
had chosen
not to implement them.
However, early in
the current appraisal,
the licensee
reversed this decision
and
undertook the actions
recommended.
The Quality Assurance
audit organization onsite
responded
to the
identified issue of maintenance
programmatic
weaknesses,
but was
not proactive in initially identifying problems.
Management
supported
QA by increasing
the surveillance of main'tenance
activities, in the latter half of the period.
The licensee
provided the quality control group with newly purchased
equipment,
and the training to operate it properly, for screening metal/alloy
components
during receipt inspection to detect potential
counterfeits.
Audit and surveillance activities by both the
QA and
QC groups
were independent
and technically oriented.
Technical expertise
in review of issues
was apparent
in the following activities:
(1) the
QA group identified incomplete "half-loop" training
coverage for maintenance
workers; (2) the Safety
and Assessment
group identified a potential
adverse
trend in fuse control; (3)
the
QA group noted
a lack of independent
substantiation
of
personnel
security background
checks
by one contractor;
and, (4)
the
QC group displayed
a conservative,
inquisitive attitude
,about
any anomalous
results
in alloy parts testing.
Early in
the assessment
period, neither
the
QA group nor the
QC group.
were programatically involved in the assessment
of work in
progress.
Work verification was being accomplished
instead
by a
"peer inspection"
program.
Inspectors
considered
administrative controls for this program
vague,
lacking sufficiently detailed
guidance
and acceptance
criteria to ensure effectiveness.
Additionally, the "peer
inspection" process
doesn't
provide the
same data for evaluation
21
that- would normally be available
from a guality Control Inspection
surveillance.
As a result,
the opportunity. for identification
of declining performance
trends
may not reach
management's
attention for implementation of appropriate
corrective action,
However,
no cases
of ineffective verification were
'noted.
During the assessment
period the overall quality of licensing
submittals
improved.
The sa'fety evaluations
supporting
the
license
amendments
almost always addressed
the criteria of
10 CFR 50.92 in sufficient detail.
The quality of licensing
submittals could be improved further by greater attention to
detai l.
A number of license
amendments
contained
minor editorial
errors.
The licensee
usually approached
resolution of technical
issues
in this functional area
from a conservative
safety standpoint.
At times,
the licensee's
proactive pursuit of issues
led to
prevention of problems or questions
which affected other licensees
as
was the case in their safety review under
10 CFR 50.59 to
address
a
new technique to test main
steam safety valves at
power.
The quality assurance
that the licensee
applied to the
ATMS (anticipated transient without scram) mitigating system
actuation circuitry (AMSAC) modification generally
met or
exceeded
the supplemental
gA guidance
given in Generic Letter 85-06.
On the other hand,
the licensee's
actions for NRC
Bulletin 85-03, involving motor operated
valve problems
appeared
designed
to meet
minimum requirements.
Thus,
most valves
remained
untested
against
the criteria of the Bulletin.
Information on technical
issues
was not always adequately
di sseminated
within the licensee's
organization.
As a result,
the corporate
Nuclear Safety
and Licensing group, which is the
designated
point of contact
on issues
for the
NRC Office of
Nuclear Reactor Regulation,
lacked current information on
some
relatively significant events at the plant.
In one case,
the
corporate licensing staff appeared
to have information (concerning
stop valve stroke timing problems)
which differed
from that at the plant site
~
Staffing remained sufficient and stable
in this functional area.
The onsite review committee
was properly staffed
and functioned
well. It included both strong
management
and strong technical
involvement.
The offsite review committee
was not evaluated.
Training and qualification of personnel
appeared
to be
a positive
factor in the identification and resolution of potential
problems
in this functional area.
Personnel
assigned
to quality
verification responsibilities
including craft personnel,
typically
possessed
technical
expertise
in the activity being examined.
Findings, therefore,
were usually founded
on technical merits.
22
A
2.
Performance
Ratin
The licensee's
performance
is rated Category 2"'in this area.
The licensee's
performance
was rated Category
2 during the
previous
assessment
period.
3.
Recommendations
None.-
V.
SUPPORTING -DATA AND SUMMARIES
A.,Licensee Activities
Unit
1
Throughout most of the assessment
period, Unit
1 of the
D.C.
Cook plant operated routinely at 100-percent
power.
The
assessment
period began at the
end of a refueling outage.
During the rest'f the assessment
period, Unit
1 shut
down only
once for a
3 day ice condenser
surveillance
in March 1990.
Unit
1 did not experience
any reactor trips during this
period.
No engineered
safety feature
(ESF) actuations
were
reported during the assessment
period.
There were
no
significant outages,
and only two events
occurred during
the assessment
period
as
summarized
below.
Unit
1 Si nificant Outa
es
and Events
/
On May 8,
1990,
a containment recirculation fan was
inadvertently started
which caused
the lower ice condenser
inlet doors to open,
and ice bed temperatures
increased
above
the technical
specification limit.
The reactor
power was
subsequently
reduced to 8 percent to allow personnel
entry to.
close the doors manually.
On May 24,
1990,
a fire and explosion occurred in the Unit 1,345KV
Power
was reduced to 62 percent to allow a breaker
to be removed
from service, as
a result of insulator
damage
and
an oil leak on
a transformer.
2.
Unit 2
Throughout most of the assessment
period;
D.C.
Cook, Unit 2,
operated routinely at 100-.percent
power and shut
down for
a refueling outage
on June
30,
1990.
The unit was shut
down for'
planned
3 day ice condenser
surveillance
in January
1990,
and remained
shut
down
an additional
16 days for repairs to the
stop valves.
Unit 2 experienced
two reactor trips during the assessment
period.
Both trips resulted
from electronic
equipment
23
1
4'1
failures.
One enginee'red
safety feature
(ESF) actuation
was
reported. during the assessment
period.
Unit 2 Si nificant Outa
es
and Events
a.
The first Unit 2 reactor trip occurred
on August 14,
1989,
following 'a severe
condition
on the 120-volt
Control
Room Instrumentation Distribution Panel
No.
4 (GRID
IV).
The undervoltage condition, which occurred
when the
GRID IV input was transferred
from the non-Class
lE
alternate
supply to the normal Class
1E supply through
a
failed switching circuit, also resulted in a partial loss
of indication and control
used for post-trip recovery
(e.g., all wide-range
level indication and
condenser
steam
dump control).
b.
On January
6,
1990, Unit 2 entered
into a planned
Mode
3
outage for ice condenser
surveillances.
During
stop valve testing
on January
8,
1990,
stop valve closure times
on, three of the four stop valves
exceeded
the Technical Specification limit of 5 seconds.
The licensee
continued to test the valve's in Mode
3 until
January
11,
1990,
when the unit was placed in cold shutdown
in order to repair the valves.
The unit was placed
back in
service
on January
25,
1990.
On June ll, 1990,
a second
reactor trip was caused
by
a negative flux rate signal.
Although the licensee
was
unable to determine
the root cause of this signal,
a single
phase of the power supply to one group of rods
was found
electrically "open."
d.
On July 19,
1990, during
a refueling outage,
a fatal
accident occurred
near
an energized
4KV feeder.
A worker
was electrocuted,
and
a flash fire seriously burned the
three other
workers present.
B.
Ins ection Activities
Thirty-two inspection reports
are discussed
in this
SALP report
(July 1,
1989, through August 31,
1990)
and are listed below under
"Inspection Data."
Table
1 lists the violations by functional area
and severity levels.
Significant inspection activities are listed
below under "Special
Inspection
Summary."
l.
Ins ection Data
a.
Unit
1
Docket No. 50-315
Inspection
Reports
Nos.
89-21 through 89-23,
89-25
through 89-34,
90-02,
90-03,
90-05 through 90-08,
90-10
through 90-17,
90-19 through 90-21,
and 90-201
b.
Unit 2
Docket No. 50-316
Inspection
Reports
Nos.
89-21 through 89-23,
89-25
through 89-34,
90-02 through 90-08,
90-10 through 90-17,
90-19 through 90-21,
and 90-201
Table
1
Number of Violations in Each Severit 'evel
Functional
Areas
Unit
1
III
IV
V
Unit 2
III
IV
V
Common
III
IV
V
A.
Plant Operations
B.
Radiological
Controls
C.
Maintenance/Surveillance
D.
Emergency
Preparedness
Security
F.
Engineering/Technical
Support
G.
Safety Assessment/
guality Verification
TOTALS
2 ~
S ecial
Ins ection
Summar
1
1
1
4
3
10
a.
During August
15 through
18,
1989,
a special
Augmented
Inspection
Tea'm (AIT) conducted
a review of the
ci rcumstances 'surrounding
the Unit 2 reactor trip as
a
result of the undervoltage
condition
on the Control
Room
Instrumentation
Panel
(GRID) (Inspection
Report
Nos.50-315/89-25;50-316/89-25).
During December
4 through 22,
1989,
a special, Maintenance
Team Inspection
(MTI) was conducted
(Inspection
Report
Nos. 50-315/89-31;
50"316/89-31)
.
c.
During April 2.through 6,
1990, the annual
emergency
preparedness
exercise
was conducted
(Inspection
Report
Nos. 50-315/90-03;
50-316/90-04).
d.
e.
During March
13 through August 22,
1990,
a special
maintenance
inspection
was conducted
to assess
improvements
in maintenance
(Inspection
Report
Nos. 50-315/90-07;
50-316/90-07) .
During June
11-22 and July 9-13,
1990,
a Safety
System
Functional
Inspection
was conducted (Inspection
Report
Nos.50-315/90"201;
50"316/90-201).
25
C.
Escalated
Enforcement Actions
2.
On January
4,
1990,
an enforcement
conference
was held regarding
the violation of TS for the failure to ensure operability of the
turbine-driven auxiliary feedwater
pump for Unit 2 (Enforcement
Case
No. EA-89-252, Inspection
Report
No. 50-316/90-03).
A
Severity
Level III violation was issued
and
a $75,000 civil
penalty
was imposed.
On February
27,
1990,
'an enforcement
conference
was held
regarding
Stop Valve operability (Inspection
Report
Nos. 50-315/90-08;
50-316/90-08).
A Severity
Level IV
violation was i ssued with no civil penalty.
D.
Confirmator
Action Letters
None.
E.
Review 'of Licensee
Event
Re orts
Collectively,
26
LERs were issued during this assessment
in
accordance
with NUREG-1022 guidelines.
These
LERs are addressed
in,this
SALP 9 report.
Unit 1-LER Nos.
89009 through 89015
and
90001 through
90004
Unit 2-LER Nos.
89011 through 89019
and 90001'through
90007
~Note
No. 69016
was oot used)
Table
2 shows
LER cause
areas for Unit
1 and Unit 2.
Tabl e
2
Number of LERs b
Cause
Cause
Area
'Unit
1
Unit 2
Personnel
Errors
Design Deficiencies
External
Causes
Procedure
Inadequacies
Equipment/Component
Other/Unknown
7
1
0
3
0
0
TOTALS
15
'26
Table
3 shows
a comparison of LER causes
for SALP 8 and
9.'able
3
Cause
Area
Personnel
Errors
Design Deficiencies
External
Causes
Procedure
Inadequacies
Equipment/Component
Other/Unknown
TOTALS
FREQUENCY (LERs per month)
- Includes three voluntary
LERs
"*Includes one voluntary
LER
SALP 8
(16 Months)
16 (41.0%)
1 (2.6%)
0 (0.0%)
5 (12.8%)
12 (30.8%)
~512. 8%
39" (100%)
2.4
SALP 9
(14 Months)
11 (42.3%)
2 (7.7%)
0 (0.0%)
7 (26.9%)
6 (23.1%)
~00. 0%L
26"" (100%)
1.9
NOTE:
This information is derived from a review of LERs performed
by
the
NRC staff and the cause
may not completely correspond
to the
causes
assigned
by the licensee.
27