ML18038A357
| ML18038A357 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point |
| Issue date: | 06/14/1991 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18038A356 | List: |
| References | |
| CON-IIT07-431-91, CON-IIT07-431A-91, CON-IIT07-431B-91, CON-IIT7-431-91, CON-IIT7-431A-91, CON-IIT7-431B-91 50-220-90-99, 50-410-90-99, NUDOCS 9106200220 | |
| Download: ML18038A357 (58) | |
See also: IR 05000220/1990099
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
REPORT NOS. 50-220/90-99 AND 50-410/90-99
INITIALSALP REPORT
NIAGARAMOHAWKPOWER CORPORATION
NINE MILEPOINT UNITS 1 AND 2
ASSESSMENT PERIOD: MARCH 1, 1990 - MARCH 31, 1991
BOARD MEETING DATE: MAY15, 1991
'9106200220
5'10614
ADOCK 05000220
9
TABLE
F
NTENT
I,
INTRODUCTION
"~Pae
II.
SUMMARYOF RESULTS
II.A
Overview,
II.B
Facility Performance Analysis
Summary'II.
PERFORMANCE ANALYSIS
III.A
Plant Operations
III.B
Radiological Controls
III.C
Maintenance/Surveillance
III.D
III.E
Security and Safeguards
III.F
Engineering and Technical Support
III.G
Safety Assessment/Quality
Verification
IV.
SUPPORTING DATA AND SUMMARY
IV.A Licensee Activities
IV.B
NRC Inspection and Review Activities
IV.C
Significant Meetings
IV.D Reactor Trips and Unplanned Shutdowns
4
4
8
11
14
16
18
20
23
23
23
24
24
Attachment
1 - SALP Criteria
I.
INTR DUCTION
The Systematic Assessment of Licensee Performance (SALP) is an integrated NRC staff effort
to collect observations,
data and to periodically evaluate licensee performance on the basis of this
information. The SALP process is supplemental to normal regulatory processes
used to ensure
compliance with NRC rules and regulations.
SALP is intended to be sufficiently diagnostic to
provide a rational basis for allocating NRC resources and to provide meaningful feedback to the
licensee's
management
to improve the quality and safety of plant operations,
An NRC SALP Board, composed of the staff members listed below, met on May 15, 1991, to
review the collection of performance
observations
and
data,
and to assess
the licensee's
performance
at Nine Mile Point.
This assessment
was conducted
in accordance
with the
guidance in NRC Manual Chapter 0516, "Systematic Assessment of Licensee Performance".
h irman
J. Wiggins, Deputy Director, Division of Reactor Projects (DRP)
Members
D. Brinkman, Project Manager, Nuclear Reactor Regulations (NRR)
R. Capra, Project Directorate, NRR
W. Cook, Senior Resident Inspector, Nine Mile Point, DRP
R. Cooper, Deputy Director, Division of Reactor Safety and Safeguards
W. Lanning, Deputy Director, Division of Reactor Safety
J. Linville, Chief, Branch 1, DRP
II.
UMMARY F RE
T
II.A
Overview
Niagara Mohawk demonstrated
an overall improvement in performance during this assessment
period as the site-wide initiatives begun as part of the Unit 1 Restart Action Plan increased in
effectiveness.
The functional areas of plant operations,
maintenance/surveillance
and safety
assessment/quality verification, in particular, have shown marked improvement. Specific Nuclear
Division actions which have contributed to this improvement were increased corporate and station
management
involvement
in day-to-day
activities,
broad
implementation
and
employee
participation in self-assessment
activities; and greater adherence
to procedures
and attention to
detail.
Contributing to the successful
execution of these
actions
was a Nuclear Division
reorganization which more clearly defined individual responsibilities and accountability.
Performance in the area of plant operations at both units significantly improved.
Operators at
Unit
1 were challenged by a demanding power ascension
testing program and a number of
unplanned plant transients.
Overall, operators performed well and maintained the unit in a safe
configuration.
The Unit 2 operators
exercised
improved control over plant systems
and
significantly reduced the number of plant transients and unplanned safety system actuations.
In the area of maintenance
and surveillance testing, performance generally improved.
The
increased
supervisory and management
involvement in day-to-day activities resulted in fewer
maintenance related plant transients or systems problems.
In addition, a major revision of the
maintenance administrative control procedures
helped to streamline the work control processes
and minimize the potential for personnel error.
In the radiological controls area,
performance
continued
to be generally
good.
performance was considered mixed, in that, Unit 2 outage exposure projections were inaccurate
and ALARA reviews of emergent
work items were considered
cursory.
However,
the
subsequent Unit 1 mid-cycle outage reflected many of the lessons learned from the Unit 2 outage
ALARAconcerns and performance was much improved. Progress was noted in addressing many
of the effluent and process radiation monitor operability concerns.
Emergency
preparedness
performance
remained
strong
with a fully qualified staff and
considerable depth and experience.
training continued at a high level
and was reflected in the Niagara Mohawk staff performance during the observed drilland actual
events throughout the assessment
period.
Particularly noteworthy was the continued excellence in performance in the security area.
A
regulatory evaluation review conducted during the middle of the SALP period identified the
Niagara Mohawk nuclear security program to have been one of the best in the nation.
In summary,
the broad improvement initiatives implemented by the licensee have resulted in
substantially
improved
overall
performance.
In particular,
the
increased
management
involvement
and
oversight
of station
activities
and
increased
emphasis
on
individual
accountability with more clearly defined responsibilities has resulted in overall improved safety
assessment
and quality verification of day-to-day activities.
0
II.B Facilit Performance Anal
. is Summar
F~unctional
Area
Ratin
Trend
Last Period
Ratin
Trend
~Thi Period
Plant Operations - Unit 1
- Unit 2
Radiological Controls
Maintenance/Surveillance
Security and Safeguards
Engineering and Technical Support
Safety Assessment/Quality
Verification
3 Improving
Previous Assessment
Period:
March 1, 1989 to February 28, 1990
Present Assessment
Period:
March 1, 1990 to March 31, 1991
III.
PERF
RMAN E ANALYI
III.APlant 0 erations
@nit
1
The previous SALP report rated Plant Operations at Unit
1 as Category 3.
The SALP report
stated
that station
management
had made substantial
progress
in addressing
and correcting
concerns previously identified. However, other problems were noted relative to the evaluation
of personnel performance,
self-assessment
capability, problem identification, and attainment of
operator performance at the level established by the Nuclear Division Standards of Performance,
Unit
1 operations performance this assessment
period demonstrated
significant improvement.
The operations staff successfully met the challenges of transitioning from a prolonged shutdown,
progressing through an extensive power ascension test program (PATP), and achieving fullpower
operations.
Operations management demonstrated improved oversight and assessment capabilities
as reflected in the PATP self-assessment
and the successful application of the lessons
learned
throughout this assessment
period.
A number of operational events and challenges were encountered
by the operations staff this
assessment
period. With few exceptions, operations staff support of the unit restart effort (i.e.,
system walkdowns, valve lineups, surveillance and inservice testing, and maintenance support)
was good.
During the PATP, in addition to the demanding
test schedule,
a number of
unanticipated events challenged the operators who responded professionally and competently to
these events to maintain the unit in a safe configuration.
These events included:
unidentified
drywell leakage which resulted in a forced shutdown; turbine high vibration which caused two
forced shutdowns; and abnormal neutron monitor response in the intermediate range.
A number
of other events during this assessment
period (i.e., loss of offsite power, turbine control valve
malfunction resulting in automatic reactor scram, and recirculation pump trips) were likewise
appropriately responded,to
by the control room operators.
In contrast to the above, a few events involving licensed and non-licensed operations personnel
showed
instances
of poor performance
and
inattention
to detail.
These
events
included
inadequate
control of a blue markup on a feedwater pump, improper testing control for the
turbine torsional test, a several thousand gallon condensate spill in the radwaste building, and an
inadvertent reactor scram from full power during a surveillance test when the wrong fuses were
pulled.
Station and corporate management
response to these events was prompt, thorough and
effective in precluding recurrence.
For example,
in some cases,
station management
took
disciplinary action to reinforce their performance expectations.
In total, the operations staff
demonstrated
that they were capable of achieving expected standards of performance,
and when
they fell short, were capable of being sufficiently self-critical to identify the root cause of the
problem, implement effective corrective action and learn from their mistakes.
The restructuring of the management
organization resulted in better oversight and control of
operations-related
activities.
In particular, the operations management staff was increased
and
some key personnel
changes
were made which contributed to improved direct supervisory
involvement on a day-to-day basis.
This increased oversight and involvement was demonstrated
by increased supervisory presence in the control room, supervisory participation in pre-evolution
and
routine shift briefings,
by more
frequent
plant tours
and
self-assessment
activities.
Operations
management
presence
was also evident in the operator training programs.
Also,
effective management oversight was evidenced by increased emphasis on evaluating performance
and identifying problems that led to a few instances where, licensed operators were removed from
shift work for remediation and operator license candidates
were removed from the training
program prior to administration of the NRC examinations.
Niagara Mohawk continued
to improve the operator
training program
at Unit l.
Initial
examinations were administered to five senior reactor operators (SRO) and three reactor operator
(RO) applicants;
all of which passed
except for one SRO who failed both the written and
operating portions of the examination.
Overall, the applicants were well prepared for NRC
license
examinations.
No programmatic
weaknesses
were identified.
In addition,
two
requalification program evaluations were conducted involving seventeen
license holders. Alloperators passed the examinations indicating their ongoing preparedness
for
the examination and overall proficiency. Niagara Mohawk training and operations management
was effective in these efforts by incorporating the "lessons learned" from the previous NRC
requalification program evaluations at Unit 2 and other related inspections.
The operations group was generally effective in the control of test activities, particularly during
the PATP. Operators were cautious, deliberate, and methodical during each phase of the power
ascension
process.
The test program effectively incorporated hold points and self assessment
activities.
Niagara Mohawk demonstrated
good control of technical issues which developed
during this process
and, in general,
were effective in tracking them to resolution.
The one
exception to this generally effective control of test activities was the turbine torsional testing
mentioned above.
Staffing levels in the operations area were ample this assessment
period.
Operators were in a
five-shift crew rotation plus a permanent
day-shift relief crew.
In addition, there were a
sufficient number of senior reactor operator license holders available who became involved with
rotational assignments
in other station departments for both individual career development and
improved departmental interaction and coordination.
In summary,
the concerns
addressed
in the previous SALP reports with respect
to operator
performance, training programs and management oversight have been appropriately resolved with
signs of continued improvement,
A number of significant challenges to the capabilities of the
operations staff were encountered
this SALP period and, in general,
the operations staff met
these challenges with good success.
Performance Ratin:
Category 2
Board Recommendati n:
None
gni~2
The previous SALP report rated Plant Operations at Unit 2 as Category 3.
Contributing to this
rating was inconsistent operator performance in which poor control of component and system
status resulted in several unnecessary
operational events and, in addition, an unsatisfactory NRC
evaluation of the licensed operator requalification program.
During this SALP period, overall operations staff performance improved substantially.
Control
of component and system
status was noted to be good during maintenance,
surveillance and
outage activities.
The number of automatic reactor scrams and forced shutdowns
decreased
during this assessment
period and operator
response
to those encountered
was good.
The
licensed operator requalification program was restored
to a satisfactory rating.
Particularly
noteworthy was operations management
involvement in day-to-day activities.
Control of system
and equipment
status
was much improved this assessment
period due to
operations staff advance review of work packages
in accordance with the revised maintenance
control processes,
increased operations management oversight and increased emphasis on personal
accountability and professionalism.
Notwithstanding, some isolated operational events did occur
due to personnel error.
These events (e.g., inadvertent safety feature actuations,
a discharge of
new spent fuel pool cleanup resins into the refuel cavity, and minor Technical Specification (TS)
surveillance problems) were all of low safety significance and not indicative of poor operating
practices.
For those isolated events, operations management
took prompt and effective action
to evaluate
the event, determine the root cause(s),
implement corrective action and impose
disciplinary action, when warranted.
These few events represent
a significant reduction from
previous SALP periods.
Automatic and forced unit shutdowns were reduced to a total of four this assessment
period and
the causes
were design problems rather than personnel related.
Operator response
to all four
shutdowns
was excellent.
For the three forced shutdowns,
control room operators quickly
diagnosed the problem, took actions to minimize the plant transient, effectively maintained the
unit in a safe configuration, and avoided the need for automatic protective function initiations.
The electrohydraulic system pipe break was detected by an auxiliary operator making rounds and
quick action by the control room operators avoided the need for any automatic system response.
The reactor coolant pressure boundary leak, which resulted in a forced shutdown near the end
of the SALP period, was detected early by control room operators and closely monitored. Prior
to reaching the TS limit, station management
decided
to reduce reactor power and make a
drywell entry to investigate the source of the unidentified leakage.
As clearly demonstrated
by
these events,
the operations staff has taken timely and conservative action with respect to the
continued safe operation of the unit.
Both the initial operator license training and requalification training programs at Unit 2 were
determined to be good.
Initial examinations
were administered
applicants; with only one failure. Examinations were administered to six SRO applicants limited
to fuel handling (LSRO); one applicant failed the written examination.
Overall, the applicants
were well prepared.
A requalification program evaluation was conducted in May 1990 for six
and
nine ROs.
All operators
passed
the examination.
It was evident that plant
management
took an active role in identifying and correcting inadequate
operator, crew and
training staff performance.
The NRC concluded
that Niagara Mohawk had
adequately
implemented the necessary
corrective actions following the previous SALP period (July 1989)
unsatisfactory requalification program evaluation.
Accordingly, the Unit 2 licensed operator
requalification program was determined to be satisfactory in November 1990.
The NRC evaluation of emergency
operating procedures
(EOPs)
concluded
that they were
technically correct, could be physically carried out in the plant and could be implemented by the
plant staff. The operator understanding of the EOP bases and their ability to use the EOPs were
considered strengths.
Some technical and human factors deficiencies were identified, mostly with
the EOP support procedures.
These deficiencies were attributed to the weak validation'and
verification process for support procedures.
The quality assurance (QA) department involvement
in the EOP area was effective since a number of deficiencies identified by the NRC staff had
already
been identified by the QA staff and were being corrected
by the operations
staff.
Overall, the good results of the EOP team inspection indicated that Niagara Mohawk made a
concerted effort to adapt previous lessons learned from Unit 1 and other industry inspections in
order to improve the Unit 2 EOP program structure and content.
During this assessment
period, operations management
involvement and oversight was evident
in a number of ways.
Progress
was
made in the reduction of nuisance
control room
The prioritization of the modification packages
necessary
to eliminate these
nuisance alarms and the significant commitment of resources
to implement them was evident.
A reorganization
and increased
operations
supervisory
staffing permitted more supervisory
presence
in the control room during both day shift and backshift evolutions.
Shift turnover
briefings were typically attended by operations management.
Special planned evolutions or tests
were observed and frequently briefed by operations management.
Their increased oversight and
day-to-day involvement were considered instrumental in the error free execution of the turbine
torsional testing and the smooth transition from the first refuel outage to unit restart and power
ascension.
However, the inadvertent engineered safety feature actuations and minor surveillance
problems which occurred due to inattention to detail indicated the continued need for heightened
supervisory and operations
management
day-to-day oversight.
Good planning and operations
management
involvement in the training programs helped to ensure adequate
staffing and the
return to a six shift rotation, plus a permanent relief day shift. In addition, station management
response to operational events was prompt and thorough.
In summary, operations performance improved and was more consistent this assessment
period.
Fewer
personnel
errors
occurred
due
to increased
operations
management
oversight
and
involvement in day-to-day activities.
Operator response to plant events was good and staffing
levels were ample.
The licensed o'perator requalification program was evaluated as satisfactory
and an EOP review found the procedures
to be good and well understood
by the operators.
Niagara Mohawk demonstrated
good performance in this area for the assessment
period.
Performance Ratin:
Category 2
Board Recommendations:
None
III.B Radiolo ical Controls
The previous SALP report rated Radiological Controls as Category 2. Continuing problems were
noted in the area of operability of the effluent monitoring system, especially at Unit 2.
The
radwaste and environmental monitoring programs were considered strong.
Niagara Mohawk made
significant changes
to improve its management
oversight of the
radiological safety area during the second half of the assessment
period.
Changes were made
in both the organizational structure and the management
personnel in this area.
These changes
resulted in more aggressive
resolution of radiological issues
raised by either its own quality
assurance
programs or the NRC.
Two new radiation protection managers,
one for each unit,
were hired.
New supervisors for radcon operations, ALARAand radcon support were also
assigned for each unit. Internal dosimetry, external dosimetry and shipping staffs were left under
the site support organization.
Radiological controls at both units were determined to be generally good, with occasional lapses
of control in ensuring timeliness and posting of surveys and ensuring the utilization of proper
protective clothing by plant personnel.
Hot particle controls, especially during the Unit 2 first
refueling outage, were generally effective.
Unit 1 maintained an effective ALARAprogram that had considerable
success during the mid-
cycle outage which occurred near the end ofthe assessment
period. This success was attributable
to excellent cooperation and coordination between the ALARAsupervisor and the operations and
maintenance
departments,
together with a strong commitment in support of the ALARAgoals
by both the Unit 1 plant manager and outage manager,
In addition, the Unit 1 staff benefitted
from the lessons learned during the Unit 2 refueling outage with respect to emergent work item
impact on ALARAgoals and planning.
ALARAperformance at Unit 2 was mixed, being generally good while the plant was operating,
but considerably less successful during the first refueling outage.
Problems during the outage
were attributable to inaccurate dose rate projections due to a lack of historical data, incomplete
pre-planning of the full scope of testing and inservice inspection work to be performed during
the outage,
and the subsequent
ineffective ALARA review of emergent work.
The Unit 2
ALARAsupervisor was geherally not included in the early'stages of outage planning activities.
Additionally, radiation work permit amendments
fo? emergent work were often provided to the
Unit 2 ALARAgroup only hours before the work needed to be performed.
Corporate support of ALARA was also determined
to be weak as indicated by inconsistent
performance between the two units, and the lack ofa clearly defined corporate ALARAprogram.
Towards the end of the assessment
period, Niagara Mohawk began developing an action plan to
address
these weaknesses,
and to stress management's
commitment to ALARA.
Niagara Mohawk's external
dosimetry program
continued
to be effectively implemented.
Procedures addressing external dosimetry controls, including the operation of the TLD facility,
were found to be generally well established
and written.
However, although the number"and
magnitude of internal contaminations for 1990 were found to be small, procedures
addressing
internal exposure control were found to be generally incomplete, difficultto use, and sometimes
inconsistent.
Niagara Mohawk continued its aggressive program to reduce the size of contaminated
areas in
Unit 1, with the completion of the first phase of the radwaste building 225 foot elevation
decontamination.
This was a major project involving the extensive utilization of robotics to
perform debris removal and surface decontamination.
In general, the amount of contaminated areas at Unit 2 remained small, in spite of the six month
long refueling outage.
However, significant portions of the Unit 2 refueling floor continued to
be used for the storage of outage equipment awaiting decontamination.
Also noted at both units
were several instances of trash and laundry left in piles on the floor inside contaminated
areas.
In general,
the Niagara Mohawk program for the assurance of quality in radiation protection
remained
a notable strength
throughout the assessment
period.
Audits were found to be
performance based, with excellent scope and technical depth.
Radiation protection and radwaste
management
continued to use these audits as a means for improving performance.
Niagara
Mohawk also continued to use an extensive surveillance program to further enhance its programs
in these areas.
However, this surveillance program was not effective in dealing with the ALARA
problems noted during the refueling outage at Unit 2.
Staffing levels in the radiological safety and radwaste areas were good.
All key supervisory
positions were filled by Niagara Mohawk employees,
Background and training for personnel
were appropriate.
Training of Niagara Mohawk personnel
involved in radwaste
remained
generally strong,
although
a formal retraining program for the training staff had not been
developed.
10
Niagara Mohawk performance in the areas of radwaste processing
and transportation remained
strong.
Allshipments were accepted at the burial sites without incident, with the exception of
a cask shipment of irradiated hardware from the Unit
1 fuel pool made at the end of the
assessment
period. This shipment was identified by the State ofWashington as having excessive
amounts of removable contamination on the outer cask surface.
This was considered an isolated
event and not indicative of overall performance.
The Unit 2 commitment to waste minimization was also a notable strength.
Waste volume
generation at Unit 2 continued to be low.
Confirmato
Mea urements
Chemical and Radi lo ical
Niagara Mohawk's performance with respect to NRC standard chemical measurements
was good.
Allof the measurements
were in agreement or qualified agreement
under the criteria used for
comparing results.
The results of the radiological sample measurements
comparisons also were
very good, with all in agreement under NRC criteria used for comparing results.
An appropriate
laboratory measurements
QC program was implemented in both units.
Radi lo ical Environmental and Effluent Monitorin
Pro ram
Niagara Mohawk continued
to have a strong environmental
monitoring program.
Niagara
Mohawk operated
an
extensive
surveillance
program
for the collection
and
analysis of
environmental samples and for the meteorological monitoring instrumentation.
The programmatic weakness of the operability of effluent monitors, identified during the last
SALP period,
continued
during the current
assessment
period.
The root cause of the
inoperability ofthese monitors was design deficiencies that impaired equipment reliability. These
problems (reported in semiannual effluent reports, LERs, and Special Reports) were generally
corrected near the end of this SALP period as the result of special management
attention and
initiatives to improve their design
and availability. Liquid and gaseous
effluent sampling,
analysis, and reporting were good. Aircleaning systems were maintained and tested as required
by the Technical Specifications.
Quality assurance audits generally covered the stated objectives and were found to be ofexcellent
technical depth to assess
the radiological environmental and effluent monitoring programs.
verall
mm
Niagara Mohawk continued to implement an effective radiological safety program and completed
staffing and organizational changes to support continued success.
Performance in the area of
ALARA was generally good with some ALARA shortcomings identified during the Unit 2
refueling outage.
Radwaste processing
and transportation remained a strength.
Radiological
chemistry controls were good and progress was noted in the area of effluent monitoring.
e
11
Performance Ratin:
Category 2
Board Recommend
ti n:
.
None
III.C Maintenance
urveillance
The previous SALP report rated Maintenance/Surveillance
as Category 3.
Inadequate control
of maintenance activities resulted in a high number of operational events, particularly at Unit 2.
Weaknesses
were also noted in the proper diagnosis of equipment failures and the limited
maintenance backlog reduction.
Performance in the area of surveillance testing was observed
to have improved. Computerized scheduling and tracking ofTechnical Specification surveillance
tests at both units resulted in a significant reduction in missed tests, particularly at Unit 2.
Maintenance
During this assessment
period, performance in the maintenance area improved.
There were no
direct maintenance-related
forced shutdowns or scrams at Unit 2; however, there were four
forced shutdowns at Unit
1 directly caused
by improper maintenance.
Overall, maintenance
activities observed at both units during routine operation and during outages were conducted well
and in accordance with procedures.
Operational events involvingpreventive or corrective maintenance were significantly reduced this
assessment
period.
At Unit 1, four forced shutdowns occurred during the assessment
period
because of improperly performed maintenance.
Two of the four forced shutdowns were caused
by maintenance
performed during the previous assessment
period (turbine generator lube oil
system overhaul and main steam line isolation valve internals repair).
One forced shutdown was
caused
by improper corrective maintenance
on an electromatic relief valve (ERV).
The root
cause for the ERV forced shutdown was personnel error. The ERV pilot valve post-reassembly
adjustment was improperly determined not to be applicable, although specified by the procedure.
A fourth shutdown,
caused
by turbine generator front standard
malfunctions,
was partially
attributable to insufficient routine preventive maintenance and cleaning.
No direct maintenance-
related shutdowns occurred at Unit 2.
The four forced shutdowns at Unit 2 all resulted from
design deficiencies.
The maintenance staff responded
to these events promptly and properly.
They developed thorough troubleshooting and/or repair plans to address
the problems.
A number of difficult equipment
failures/problems
were
successfully
addressed
by the
maintenance groups at both units this assessment
period. AtUnit 1, a feedwater pump impeller
installation deficiency, turbine generator 'front standard malfunctions, and a transformer fault
which caused a complete loss of offsite power were all carefully investigated and appropriately
addressed.
At Unit 2, an emergency
diesel generator
cracked cylinder head
was properly
diagnosed and replaced.
12
During the assessment
period, there were several
scram signals generated
while Unit 1. was
shutdown.
These scrams were primarily the result of persistent equipment problems in three
areas.
These
areas
were:
spurious spiking on the intermediate range nuclear instruments;
spurious failure/cycling ofcontacts in the low condenser vacuum/main steamline isolation bypass
circuitry; and deenergization of reactor protection system buses
11 or 12 due to problems with
their associated motor generator sets.
These problems were well documented
and considerable
maintenance staff troubleshooting, engineering staff'review and senior management attention was
expended
to identify and correct the source of these problems.
These scram signals were of
minimal safety consequence
and would generally have not challenged
the reactor protection
system during normal power operations.
Niagara Mohawk has identified the underlying causes
for these scram signals and appears
to have initiated appropriate corrective maintenance and/or
engineering design changes to resolve them,
A maintenance
performance
assessment
team (MPAT) inspection
was conducted during this
assessment
period and concluded maintenance performance was acceptable.
The team noted that
maintenance
personnel
were knowledgeable
and
experienced.
The
team
concluded
that
maintenance was being performed in accordance with procedures.
In addition, the team observed
that maintenance issues were properly and conservatively resolved.
The team identified only one
concern involving the improper control and assembly of scaffolding in safety-related
areas.
However, station staff response
to this concern was prompt and thorough.
In addition, the
MPAT identified that the Unit
1 work control center effectively planned,
scheduled
and
controlled work activities.
The maintenance backlog at Unit 1 was significantly reduced prior to restart from the 1988-91
refuel outage.
However, the maintenance backlog at Unit 2 remained high throughout most of
the assessment
period and only began to trend downward towards the end of the period after the
unit was returned to power. Niagara Mohawk attempted to reduce the Unit.2 backlog, but plant
events precluded a net reduction in the total backlog.
Maintenance department staffing levels at
both units was ample.
Prioritization of work items was observed
to be appropriate
and
conducive to continued safe operation.
Maintenance
administrative procedures
were upgraded
to include more precise
procedural
controls over maintenance
activities such as troubleshooting,
temporary modifications, plant
impact reviews,
and
measuring
and
test
equipment
calibration
and
usage.
In addition,
maintenance
management
has emphasized
procedural adherence
and individual accountability.
In spite of these initiatives, there were a few events at Unit 2 which resulted from instances of
poor maintenance performance.
Some examples included: improper selection ofa torque wrench
and failure to follow RWP requirements during preventive maintenance
on control rod drive
hydraulic control units; failure to backfill a reactor pressure transmitter which resulted in an
inadvertent ESF actuation; and improper restoration from a local leak rate test which resulted in
personnel
contaminations.
Although these
events
were of minor safety significance,
they
indicated inattention to detail and poor procedural adherence.
An improving trend in these areas
was noted in the latter part of the assessment
period and an increase in maintenance supervision
presence in the field was observed, particularly at Unit 1.
13
Housekeeping
at both units this assessment
period was good.
A noticeable effort was made at
Unit
1 to clean up and repaint the reactor building corner rooms.
However,
lapses
were
identified at both units with respect to general area cleanliness
and radiological housekeeping
practices.
These
lapses
were generally coincident with unit outages.
In contrast,
inspector
drywell tours
at the conclusion of unit outages
identified good
material
and
cleanliness
conditions.
surveillance
During this assessment
period, surveillance testing continued to improve. Implementation of the
inservice inspection and testing programs was satisfactory,
The execution of the power ascension
testing program (PATP) at Unit 1 was noteworthy.
There were few missed
surveillance
tests this assessment
period.
Those that were missed
occurred at Unit 2 and were the result ofpersonnel inattention to detail and were of minor safety
consequence.
This overall improvement can be attributed to an effective computerized tracking
system at both units and the diligent efforts of the responsible station staff. Surveillance testing
improvements were complemented by the successful completion of some complex special testing
performed at Units 1 and 2 (i.e., integrated leak rate test and turbine torsional test at Unit 2; and
a loss of offsite power test at Unit 1).
In addition, the planning, execution and assessment
of
results from the numerous
and involved PATP tests at Unit
1 were well coordinated
and
controlled.
To support the conduct of the Unit 1 PATP, Niagara Mohawk dedicated significant resources
to carefully prepare test procedures
and to plan and coordinate the three major testing phases.
Indicative of the good planning and preparation was the smooth execution of the program and
the good correlation between anticipated
and actual test results.
The one exception,
to this
otherwise excellent test program, was the performance of the Unit 1 turbine torsional test.
A
poorly written test procedure unnecessarily challenged the operators and operations support staff
and ultimately was the basis for aborting the test.
In addition, problems encountered with the
test initiallywere not addressed
in an effective manner.
Subsequent performance of the turbine
torsional test at Unit 2 was generally enhanced,
due to training on the lessons learned from the
Unit 1 torsional test.
Inservice inspection (ISI) and inservice testing (IST) programs at both units were satisfactorily
implemented during this period.
ISI examinations at Unit 2 identified a weld indication in the
high pressure core spray nozzle safe-end, which required Niagara Mohawk evaluation and NRC
review and approval for continued operation without rework. Detailed internal reviews of Unit
2 IST procedures identified discrepancies in the testing of service water pumps and residual heat
removal motor operated valves.
These self identified problems were reflective of conscientious
and dedicated ISI and IST staffs.
14
verall Summ
Performance in the maintenance
area was improved this period; however, a few instances of
poorly performed
or insufficient maintenance
resulted
in unplanned
Unit
1
shutdowns.
Notwithstanding,
significant maintenance
staff efforts to improve procedural
controls
and
personnel procedural adherence
were evident.
Progress was noted in the work request backlog
reduction at both units.
Performance in the surveillance area was good during this assessment
period.
A few missed surveillances
at Unit 2 resulted from inattention to detail, but overall
compliance with the Technical Specification testing was good.
Power Ascension Testing at Unit
1 was generally well planned and executed.
Overall implementation of the ISI and IST programs
was good.
Performance Ratin:
Category 2
Board Recommendations:
None
III.DEmer enc
Pre aredness
The previous SALP rated Emergency Preparedness
as Category
1.
This rating was based on
good performance during an exercise, strong management support ofthe emergency preparedness
program and an effective emergency preparedness
training program.
Corporate and site management
was effectively involved in assuring emergency
preparedness
quality with the exception oftheir response to the Emergency Response Facility Appraisal items.
The Vice President Nuclear Support routinely participated in Emergency Preparedness
Branch
staff meetings.
Managers maintained Emergency Response Organization position qualification,
reviewed and approved the Emergency Plan and procedure changes,
participated in drills and
exercises,
and effectively interfaced with State and County Offices of Emergency Management
personnel.
Emergency. Plan
and procedure
changes
were also appropriately reviewed
and
approved by the Station Operating Review Committee following a review to insure the changes
did not decrease
effectiveness.
Site
management
was
also involved with off-site activities to assure
quality.
Managers
participated in frequent Emergency Plan development and coordination meetings with State and
County officials.
Public information material was developed
and distributed.
Two remote
sensing systems were used to test sirens daily and continuously.
This testing frequency exceeds
that suggested in NRC guidance.
Niagara Mohawk maintained these redundant testing systems
to insure reliability. Siren availability significantly exceeded FEMA specifications during this
assessment
period.
0
15
Niagara Mohawk has been slow to complete action on several enhancement
items identified
during the 1988 Emergency Response Facility Appraisal. At the beginning of 1991, nine items
remained open.
Four items were related to dose projection, four to plant computer systems and
one to habitability.
At the conclusion of the assessment
period, two of the items had been
closed.
The licensee projects completion of the remaining items in late 1991 or early 1992.
The emergency
preparedness
training (EPT) program,
based
on exercise
and actual event
response,
made a positive contribution to emergency
preparedness
effectiveness.
A training
matrix and lesson plans were based on the emergency plan and procedures.
All lesson plans
were rewritten to ensure user friendliness and conformance with revised training department
format.
In addition to classroom training, four station drills and five drills of different types
were held. Additionally, core damage mitigation training was given to the technical staff. Over
1000 site personnel
were qualified for an emergency
response
organization (ERO) position.
There were six staff members qualified for each ERO management and decision making position.
Two weaknesses
were identified during the annual exercise, however they did not indicate an
ineffective EPT program.
One weakness
resulted from failure of an ERO manager to request
core damage
assessment
and the other resulted from failure of the dose assessors
to consider
plume trajectory variability when calculating projected
doses.
Several
strengths
were also
identified including strong engineering
response
by the Technical Support Center staff and
development of protective action recommendations
based on degrading plant conditions.
Licensed operators received classroom and simulator training in both classification and protective
action recommendation development during each training cycle. When simulator scenarios were
used,
the entire control room staff participated to provide an integrated shift response.
The
effectiveness of operator emergency preparedness
training was demonstrated by response to six
operational events each ofwhich involved a different cause.
The events were properly classified
as Unusual Events.
Notifications to the State and County were timely.
As the result ofa reorganization, an emergency preparedness
branch has been established,
headed
by a director who reports directly to the Vice President,
Nuclear Support.
The branch was
staffed by ten persons iricluding three clerical, two senior reactor operators and an experienced
dose assessor.
An ample staff capable of effectively implementing the emergency preparedness
program was available.
In summary,
Niagara Mohawk maintained
an effective emergency
preparedness
program.
Corporate
and station
management
was routinely involved with and committed to quality.
However,
the schedule
set for resolving the Emergency
Response
Facility Appraisal items
indicates
that management
attention
was not uniformly applied,
The emergency
response
organization was qualified and fully staffed.
Training was effective as demonstrated
by the
annual
exercise
response
and the response
to six actual conditions requiring classification.
Niagara Mohawk maintained a good interface with State and County officials,
16
P rf rmanc
Ratin
Category
1
B
rd Recommendation 'one
III.E Security and Safeguards
The previous SALP report rated Security and Safeguards
as Category 1. This rating was based
upon:
maintaining a very effective and-performance-oriented
program; continuing efforts to
upgrade the operation and reliabilityof security systems and equipment; a training program that
was dynamic in scope and well administered; and, management support that was clearly evident
in all areas of the day-to-day security operation and active in planning for the security upgrades
and enhancements.
Plant and corporate management involvement in the security program continued to be a notable
strength as evidenced by the budgeting and planning to support program upgrades throughout the
entire period. Security management personnel also remained actively involved in industry groups
engaged
in nuclear plant security matters.
The security manager
and his staff continued to
demonstrate an excellent understanding ofnuclear plant security objectives.
The background and
nuclear security expertise of this staff was the main strength of this organization.
They were
quick to r'ecognize where improvements could be effected in the program and provided sound
and effective resolutions.
Niagara Mohawk made very good progress
on a comprehensive
upgrade of the assessment
system.
In addition, they have completed the installation of a double security fence around the
entire protected area and completed an upgraded intrusion detection system on the Unit 2 side
of the protected area.
A revision to the surveillance procedures was also recently completed that
now emphasizes performance testing of equipment.
The continued assignment ofapproximately
20 full-time instrumentation
and controls g&C) technicians
to the security organization
to
maintain security systems and equipment is one of the key elements to the continued success of
the security program.
Their dedication to the program was evident in the overall excellent
preventive maintenance program and the rapid response to equipment problems which minimized
the need for compensatory
measures.
A Regulatory Effectiveness Review (RER) was conducted in June 1990 and the team concluded
that, in general, all elements of the Nine MilePoint security program were sound, well-managed
and effective.
The program was considered to be one of the most effective that the RER team
had assessed,
to date.
While some potential weaknesses
with assessment
aids were found, they
had already been identified and compensated for by Niagara Mohawk, and a major upgrade was
in progress.
The RER also noted that it was the first time they had tested an intrusion detection
system without identifying a weakness.
This was further evidence of the effectiveness of the
security staff and program.
In addition, the armed response
capability demonstrated
sound
strategic
planning,
excellent training, effective deployment of response
equipment,
and
a
competent response force,
17
The security training program was also a key element of the program.
The experience
and
background of the security training staff was excellent.
Their competence
and dedication was
evidenced in the demeanor,
professionalism
and knowledge exhibited routinely by the security
officers. Niagara Mohawk continued to maintain well equipped training facilities which include
an on-site firing range and a fully-equipped exercise and fitness center for security officers that
was
also
available
to other
plant
personnel.
Niagara
Mohawk recently
completed
a
comprehensive revision of the training and qualification plan to consolidate numerous revisions
and to make crucial security force tasks more performance-oriented.
Niagara Mohawk continued to use self-assessments
to provide effective oversight of security
program implementation
and personnel
performance.
The self-assessments,
along with the
annual audit, were thorough, comprehensive
and performance-based.
Corrective actions on
findings and recommendations were prompt and effective with adequate follow-up to ensure their
implementation.
Niagara Mohawk made two, one-hour security event reports during the assessment
period.
One
report concerned
an informational picket line against a contractor working at the plant and the
second report involved the accidental discharge of a hand-gun by a security officer. The latter
event was considered
an isolated case in which the individual did not follow written procedures
and practices in which he was trained.
Niagara Mohawk took prompt and appropriate actions
in each case.
A review of the logable security event reports revealed that events were tracked
and analyzed and the deficiencies were effectively corrected by the security staff. The reporting
procedures
were well understood
by security
supervisors
and
were consistent
with NRC
regulations.
During this assessment
period, Niagara Mohawk submitted two revisions to the security plan.
Both were technically sound and exhibited the licensee's thorough knowledge and understanding
of NRC requirements
and security objectives.
In summary, excellent security practices,
a sound, performance-oriented
training program, and
effectively installed and well maintained equipment, coupled with a very competent and effective
management
team assured
the continued implementation of a high quality program during this
assessment
period.
Management attention to and support for the program were clearly evident
in all aspects ofprogram implementation.
The security personnel were competent and dedicated
professionals with the demonstrated
skills and knowledge necessary
to meet the security plan
objectives.
P rf rmance Ratin:
Category
1
8 ard Recommendations:
None
0
18
III.F En ineerin
and Technical Su
ort
The previous SALP report rated Engineering and Technical Support as Category 2.
Niagara
Mohawk had improved the overall quality ofengineering work and support for the station during
the last SALP cycle.
In general, engineering work was good with some areas for improvement
noted.
The following areas were identified as needing improvement: timeliness and quality of
engineering
work and
increased
management
oversight of engineering
work; management
attention to assure the timely implementation of the technical training program for the nuclear
engineering staff; and, the need for a thorough review of technical issues to assure quality work.
In response to the problem areas identified during the last assessment
period, Niagara Mohawk
management demonstrated a determination to improve its performance with the followingactions:
a team of engineering
managers
was established
to monitor technical issues
and the overall
effectiveness of engineering support; senior management
issued criteria for handling technical
issues to clarify when engineering support should be requested
and provided; and management
attention was focused
on the implementation of the new broad-based
engineering
technical
training program.
The establishment of the site systems engineering group has achieved noticeable improvements
in the quality of engineering support.
The system engineers
have become the focal point for
engineering activities at the site.
They were involved and were being held accountable for the
coordination of maintenance, modification and testing activities involving their systems.
Systems
engineers were knowledgeable and had a positive impact on plant performance.
For example,
the system engineers at Unit 2 identified improper calibration of hydrogen analyzers, improper
inservice testing of service water motor-operated
valves, improper installation of containment
monitoring system resistance temperature detectors and improper Type B testing of a traversing
incore probe flanged connection. AtUnit 1, systems engineers helped to resolve motor generator
set performance problems and gaseous effluent monitor operability concerns.
Good working relationships and communications were observed between the various station and
corporate engineering staffs. In addition, Niagara Mohawk reorganized the nuclear engineering
department on a unit basis for design and plant support functions.
This has helped to establish
more clearly defined individual duties and responsibilities for plant changes
and modifications
and has assisted in building the observed stronger ties between the engineering and station staffs.
For example, active participation and coordination of corporate and site engineers resulted in the
successful completion of the Unit 1 power ascension
testing program (PATP).
The engineering staff's project work load was controlled in accordance with the Niagara Mohawk
integrated priority system procedures.
Technical issues were assigned, prioritized, and tracked
on a weekly basis.
The system for assigning priorities to plant modifications appeared
to have
the proper safety perspective.
The engineering department
was adequately
staffed (including
contractors) to support the needs of the station.
0
19
There
was ample evidence of increased
engineering
management
involvement during this
assessment
period. For example:
a concern regarding the potential for diesel generator fuel oil
contamination was immediately resolved; a thorough technical review and good overall control
of the turbine torsional test at Unit 2 was observed; and a site licensing group was newly formed
to expedite the closure of licensing issues and to coordinate resolution of technical issues with
the engineering staff.
The engineering staff training program was previolisly identified as a programmatic weakness
by the NRC and the need for continued
management
attention
was addressed
in the last
assessment
report.
Critical training in thirteen specific areas was completed in May 1990 to
address
the training weaknesses
in the interim. A broad-based
technical training program was
being finalized by engineering management
near the end of this SALP period.
Generally, good performance was observed in design change activities this assessment
period.
Review of modifications identified well organized and technically accurate
design packages.
Field verifications revealed
correct as-built configurations,
properly revised
drawings
and
procedures
and knowledgeable
responsible
design engineers.
Examples of good engineering
work at Unit 1 included:
identification and resolution of potential system operability concerns
for containment spray and reactor building closed loop cooling heat exchangers;
resolution of
core spray sparger pipe whip operability concerns;
resolution of detailed control room design
review issues; and a thorough review of feed water system flow induced vibrations. At Unit 2
an additional example of good engineering effort was the successful completion of the safety
parameter display system modifications prior to restart from the first refueling outage.
However, some isolated design and technical review problems of minor safety significance were
encountered during this assessment
period.
For example,
a Unit 1 modification was installed
without the Station
Operation
Review Committee
(SORC) review required
by procedure.
Subsequent review by Niagara Mohawk identified six modifications for Unit 2 which were also
not SORC reviewed.
The resolution of motor generator (MG) set problems at Unit 1 has been
slow. Problemswith theMGsetdatebacktotheearly80s.
During theextended Unit1outage,
a task force determined
that the MG sets should be replaced with static invertors for increased
system reliability. AtUnit 2, four different design problems were identified, resolved or remain
to be addressed
for long term resolution.
These design problems involved balance of plant
systems which caused forced shutdowns.
Technical support to the station operations and maintenance staff was found to be adequate
and
effective.
Evidence of good
technical
support
was identified during various NRC team
inspections and particularly during reviews of power ascension
testing at Unit 1.
However,
incidents of poor performance in other areas demonstrated
some inconsistency in the quality of
engineering review activities. For example, at Unit 1 the inadequate followup and resolution of
an improper emergency condenser isolation setpoint led to both systems being declared operable
before a proper recalibration was conducted.
In addition, at Unit 1 there was no basis for the
acceptance criteria selected for special tests to determine the adequacy of minimum flow of the
core spray pumps.
Also, pump suppliers were not involved in determining this acceptance
criteria as suggested by Bulletin 88-04.
20
In summary,
Niagara Mohawk showed
evidence of increased
management
involvement in
engineering activities compared to the previous assessment
period.
The addition of the systems
engineers to each of the plant staffs was shown to have been an asset to the overall quality of
engineering
support.
However,
a few examples
during the assessment
period
indicated
performance
inconsistencies
and minor shortcomings
in engineering
management
oversight.
Overall engineering and technical support performance was good and generally improved.
Perf rmance Ratin:
Category 2
Board Recommendation.:
None
III.G
afet
Asse.. ment/
ualit Verification
The previous SALP report rated Safety Assessment/Quality
Verification as Category 3 with an
improving trend.
Niagara Mohawk's performance demonstrated
some inconsistency,
but an
overall improvement was observed.
The previous assessment
noted an apparent turning point
in Niagara Mohawk's approach to assuring quality. Implementation of the Restart Action Plan
was responsible for better problem identification, more critical problem evaluation and self-
assessment,
and the establishment of programs
and standards
to promote and sustain
good
performance.
The approach appeared
to have yielded improved results noted in the engineering
and
surveillance
areas
and
the general
improvement
in most other areas.
However,
the
performance in several areas remained at minimally acceptable levels providing a challenge for
Niagara Mohawk management
to utilize this better approach to produce improved results on a
consistent basis in all aspects of plant operations.
Niagara Mohawk implemented
several
management
changes
during this assessment
period.
These changes included the appointment ofa new Executive Vice President;Nuclear;
a new Vice
President, Nuclear Generation; and a new Plant Manager - Unit 2. A reorganization of the site
staff, which provides unitized control of each plant, was also implemented.
These organization
changes enabled Niagara Mohawk site management to better implement the improved standards
of performance and accountability measures which had been previously introduced.
During this assessment
period, increased
management oversight, a conservative attitude, and a
good safety perspective
in the areas of plant operations
and maintenance/surveillance
were
evident during both routine activities and special evolutions.
For example, preparations for the
Unit 1 power ascension
test program and the Unit 2 startup following the first refueling outage
were comprehensive
and thorough.
Although Niagara Mohawk experienced
some difficulties
during the initial attempt to perform the Unit 1 turbine torsional test, these difficulties were
properly addressed,
particularly after intervention by senior corporate management.
The lessons
learned from this test which included technical and organization performance issues, and lessons
from another licensee were thoroughly reviewed and appropriately considered before conducting
the Unit 2 turbine torsional test.
Good management oversight was observed during the Unit 2
turbine torsional test and during troubleshooting of the Unit 1 main turbine pressure oscillations.
0
21
Generally effective implementation of Niagara Mohawk's
standards
of performance
were
observed; however, some isolated inconsistencies were noted. Implementation ofthese standards
of performance
and their reinforcement by accountability
meetings
were effective tools in
reinforcing individual responsibilities and accountability.
An overall improving trend was seen
in the area ofadherence to these higher performance standards,
especially towards the latter part
of the assessment
period. 'owever,
occasional
lapses
were noted throughout the period in
procedural adherence and proper problem identification and resolution.
Examples ofthese lapses
include control of blue markups at Unit 1, pulling of wrong fuses during surveillance testing at
Unit 1, improper
reassembly
and
adjustment of an electromatic relief valve at Unit 1,
maintenance of hydraulic control units at Unit 2, and a radwaste building condensate
spill at
Unit l.
Improved engineering
and administrative procedures
for the proper control of plant design
changes
and modifications were generated
this assessment
period and have been, in general,
effectively implemented by Niagara Mohawk. More specific measures were provided to ensure
proper technical reviews,
independent
verifications, appropriate
levels of approvals,
proper
installation, and post-modification testing.
The revised review and approval processes
were
effective in ensuring that plant changes
were properly evaluated in accordance
with 10 CFR 50.59 to determine ifan unreviewed safety question was involved.
Analyses
to determine
root causes
of most events
have
been
thoroughly
and effectively
performed.
A noted exception
to this good performance
occurred early in the period and
involved the evaluation of the Unit 1 feedwater pump blue markup problem, which resulted in
operation of the feedwater pump with the suction valve shut.
The analysis for this event was not
thorough in that site management focused only on the personnel performance aspect of the event
and did not consider the programmatic aspects.
During this assessment
period, both units instituted a permanent outage group and assigned
an
outage manager.
These groups gained experience and improved their performance throughout
the assessment
period.
Lessons learned from problems encountered during the Unit 2 refueling
outage, including clearly defining and freezing the scope of work and improved contingency
planning,
enabled
the Unit
1 outage group to be more effective in their overall planning,
coordination, and work control during the Unit 1 mid-cycle outage in February-March
1991.
This outage was completed ahead of schedule and under the projected ALARAgoals.
Niagara Mohawk effectively utilized its self-assessment
programs
as a diagnostic tool.
Self-
assessments
performed
during
the Unit
1
power
ascension
test
program
(PATP)
were
comprehensive
and critical.
Implementation of the self-assessment
process
became
more
effective as the power ascension
test program
progressed
and
as Niagara Mohawk made
appropriate modifications to improve the process.
Self-assessments
have continued to function
as
an effective management
tool since completion of the power ascension
test program.
Comprehensive
and
performance-based
self-assessments
were
also
effective in providing
management oversight in the maintenance of high levels of performance in the functional areas
of Security and Emergency Preparedness.
t
, ~
22
The safety oversight committees (Site Operations Review Committee and Safety Review and
Audit Board) provided a positive performance impact on the station.
These committees focused
on the safety issues
and effectively reviewed station activities to maintain that focus.
The
Independent Safety Engineering Group (ISEG) provided timely and effective reviews ofplant and
industry. events.
ISEG safety
assessments
and recommendations
generally
indicated
good
technical
reviews
and
sound
recommendations.
The ISEG
redefined
and
expanded
its
responsibilities and involvement to include independent
oversight of both Unit
1 and Unit 2
activities. This expansion ofreview functions to include Unit 1 activities was accomplished even
though, the Unit 1 Technical Specifications.do not require. an ISEG function.
The quality assurance
(QA) staff was strengthened
by adding individuals with an operations
background.
A reorganization of the QA group resulted in the Vice President, Quality Assurance
focusing on nuclear responsibilities and moving his office and direct support staff to the station.
The impact and effectiveness of this reorganization
has not yet been assessed.
The QA audits
reviewed this assessment
period were in-depth and performance-based,
Quality control (QC)
surveillances were also performance-based.
In addition to normal duties, QC was responsive to
station management
and provided independent
assessments,
by special request, of suspected
problem areas,
Licensing submittals were generally technically sound and thorough.
The submittals usually
demonstrated
sufficient management
involvement and oversight so that resolution of the issues
was accomplished without requiring additional information, thereby demonstrating
a thorough
understanding of the issues.
License amendment requests have almost always been submitted in
a timely manner.
However, occasional problems have occurred.
For example,
the Unit
1
request for a temporary waiver of compliance for improving instrument channels
was not
adequately reviewed by Niagara Mohawk before proposing it to the NRC, In addition, the initial
response
to Generic Letter 89-13 did not include sufficient detail to enable the NRC staff to
complete its review.
Licensee Event Reports (LERs) were well-written and described the major aspects ofeach event,
the system and components involved, and the significant actions taken or planned to prevent
recurrence.
The LERs also appropriately identified the root cause(s) of the event.
Timely
telephone notifications made pursuant to 10 CFR 50.72 were comprehensive
and permitted the
NRC Operations Officer, to clearly understand the events.
A conservative approach in reporting
was evident in that several events were reported even though NRC notification may not have
been specifically required by regulation.
Category 2
In summary,
Niagara Mohawk demonstrated
an improved approach
to assuring quality and
assessing
the safety
significance of issues
affecting plant operations.'he
self-assessment
programs became more effective during the latter portions of the assessment
period.
The new
standards of performance
and their methods of implementation were effective in articulating
management expectations and requirements and were found to be generally well understood and
followed by the Nuclear Division personnel.
Licensing action submittals
were generally
technically adequate
and timely.
Overall performance in this functional area improved during
this SALP period.
Performance Ratin:
B
rd Rec mmendati n.:
None
23
IV.
P RTIN
DATAAND SUMMARY
IV.A I.icen. ee Activiti
During this assessment
period Unit 1 remained shutdown until July 29, 1990 when the reactor
was taken critical for the first time in approximately two and one-half years.
A number of
forced shutdowns occurred following startup, as highlighted in Section IV.D. A comprehensive
power ascension testing pr'ogram was completed by the middle of November 1990. A mid-cycle
maintenance and surveillance outage was successfully conducted near the end of the assessment
period. The outage was completed ahead of schedule and considerably under ALARAexposure
goals.
At the end of the assessment
period the unit was operating smoothly at full capacity.
Unit 2 operated at full power from the beginning of the assessment
period until May 14, 1990
when a loss of instrument air caused
control room operators
to manually scram the reactor.
Repairs were made to the instrument air system and the unit returned to full power on June 8.
End of cycle coastdown
commenced
on July 14.
The reactor automatically scrammed
from
approximately 65% power on September 7 due to a generator field ground.
The first refueling
outage was commenced following the September 7 scram and completed on January
19, 1991.
The unit operated
at power until March 30,
1991 when the unit was shutdown to repair an
unisolable reactor pressure boundary leak.
IV.B NR
In.
ection and Review Activi ie.
Three NRC resident inspectors
were assigned
to the site throughout the assessment
period.
Region based inspectors performed routine inspections throughout the assessment
period.
NRC
team inspections were conducted in the following areas:
Reinspection of the Unit 2 licensed
operator
requalification training program
was
conducted in April 1990.
Readiness
assessment
team inspection of Unit 1 in May 1990.
Regulatory effectiveness review of site security and safeguards in June 1990.
Augmented inspection coverage ofUnit 1 restart preparations and startup activities in July
1990.
Maintenance performance assessment
team inspection of both units in October 1990.
Augmented inspection coverage ofUnit2 restart from first refuel outage in January 1991.
A team review ofUnit 2 emergency operating procedures was conducted in January 1991.
24
IV.C
i nificant Meetin
.
The followingsignificant meetings were held during this assessment
period between the NRC and
Niagara Mohawk staffs:
March 9, 1990 Enforcement Conference to discuss apparent violations concerning the
Unit 1 reactor building emergency ventilation system.
r
March 29, 1990 NRC Restart Review Panel meeting to discuss Unit 1 restart readiness.
May 14,
1990 NRC Commissioners
briefing to discuss
the NRC staff assessment
of
readiness for restart of Unit 1.
September 7, 1990 meeting with ACRS to discuss restart of Unit 1.
December
18,
1990 public meeting
to discuss
Power Ascension Test Program self-
assessment
results.
IVeD Reactor Tri
and Un tanned
hutdown.
gni~1
Date
~Pwer
~R~t~au e
Functi
n l Ar
l.
7/30/90
1%
Personnel Error
Maintenance
The failure to perform post-maintenance
adjustments
on two of six electromatic relief valves
(ERVs).allowed them to relieve pressure at 15 psig during reactor heatup.
A failed open vacuum
breaker on one of the ERV downcomers resulted in steam escaping and condensing in the drywell
which led to a forced shutdown and declaration of an Unusual Event due to rapid increase in
'rywell
(LER 90-16)
2.
8/6/90
19%
Personnel Error
Maintenance
During rollup of the turbine prior to synchronizing the generator with the grid, high vibration
occurred on the number five main bearing at 1750 rpm. Operators tripped the turbine and broke
vacuum on the condenser
to allow rapid slowdown of the turbine.
The reactor was manually
scrammed in anticipation of an automatic scram on low condenser vacuum.
The cause of the
failure of the bearing was traced to a blank flange inadvertently left installed on the bearing oil
supply line.
(LER 90-17)
I
Date
3.
8/19/90
~Pwer
21.5%
25
~Root
ause
Procedural Deficiency
F ncti
n l Ar
Engineering and
Technical Support
During performance of the turbine torsional test, turbine vibration problems were experienced.
Operators tripped the turbine and broke vacuum on the condenser.
A manual scram was inserted
to preclude an automatic scram on low condenser vacuum.
The most likely cause of the low
pressure turbine rotor vibration was the slow acceleration rate through a critical speed range and
insufficient turbine warming.
(LER 90-20)
4.
11/17/90
96%
Personnel Error
Operations
During the performance of surveillance testing on the main steam line radiation monitors, an
operator pulled an incorrect set of fuses which generated
a full main steam isolation valve
(MSIV) logic signal and resulted in a reactor scram.
(LER 90-26)
5.
12/29/90
98%
Personnel error
Maintenance
During performance ofa surveillance test on the MSIVs, an inboard MSIV(01-02) became stuck
in the partially closed position.
Unable to open the valve due to grounds on all three phases of
the valve motor operator, and with a one-half scram condition caused by the partially shut MSIV,
plant operators
were forced to shutdown
the plant.
The root cause
was determined
to be
improper alignment of the valve internals during reassembly.
(LER-90-19)
6.
12/29/90
10%
Random Failure
N/A
During the 12/29 forced shutdown, while at 10% power,
a spike on an intermediate range
monitor (IRM) occurred causing a trip signal to be generated
on RPS channel
11.
This, in
coincidence with a trip signal on RPS channel
12 caused by the stuck MSIV, generated
a full
The cause of the IRM spiking was not determined.
(LER 90-19)
7.
2/12/91
83.%
Equipment malfunction
Maintenance
A problem in the turbine mechanical hydraulic control system caused
a turbine control valve to
rapidly go to the 50% closed position and then back to full open.
This induced a pressure
transient on the reactor which caused reactor power to increase and the reactor to scram as a
result of the high flux condition.
Inspection of the turbine front standard during the outage did
not identify any specific mechanical problem which could have caused the turbine control valve
to act erratically, however,
general cleanliness
and some worn bearings
and linkages were
considered potential causes for the malfunction.
(LER 91-02)
26
@nit 2
Date
~Pwer
Root Cause
Functional Area
l.
5/14/90
100%
Design Deficiency
Engineering/
Technical Support
A turbine building instrument air line rupture resulted in the offgas condenser level control valves
to fail shut and a subsequent
loss of main condenser vacuum.
A manual reactor scram was
appropriately initiated at 45% reactor power.
2.
9/5/90
64%
Design Deficiency
Engineering/
Technical Support
A generator field ground resulted in a turbine generator trip which caused
an automatic reactor
3.
1/18/91
12%
Design Deficiency
Engineering/
Technical Support
Failure of a weld on an electro-hydraulic control (EHC) oil line resulted in a loss of EHC
pressure
and forced shutdown for repairs.
The root cause
was determined
to be vibration
induced fatigue failure.
4.
3/29/91
100%
Design Deficiency
Engineering/
Technical Support
The sample line connection on the A recirculation loop riser developed
a leak resulting in a
forced shutdown for repairs.
The root cause of the piping leak was still under investigation at
the close of the SALP period.
ATTACHMENT1
SALP EVALUATIONCRITERIA, PERFORMANCE CATEGORIES AND TRENDS
E
The following evaluation criterion were used,
as applicable, to assess
each functional area:
2.
3.
Assurance of quality, including management
involvement and control.
Approach to the identification and resolution of technical issues from a safety standpoint.
Enforcement history'.
4.
Operational and construction events (including response to, analysis of, reporting of, and
corrective actions for).
5.
Staffing (including management).
6.
Effectiveness of training and qualifications program.
The performance categories
used when rating licensee performance are defined as follows:
Category 1. Licensee management attention to and involvement in nuclear safety or safeguards
activities in a superior level of performance.
NRC will consider reduced levels of inspection
effort.
~ate ory 2. Licensee management attention to and involvement in nuclear safety or safeguards
activities resulted in a good level of performance.
NRC willconsider maintaining normal levels
of inspection effort.
Categ~3.
Licensee management
attention to or involvement in nuclear safety or safeguards
activities resulted in an acceptable level ofperformance; however, because of the NRC's concern
that a decrease in performance may approach or reach an unacceptable level, NRC willconsider
increased levels of inspection efforts.
~ate oi~N. Insufficient information exists to support an assessment
of licensee performance.
These
cases
would include instances
in which a rating could not be developed
because of
insufficient licensee activity or insufficient NRC inspection.
The SALP Board may assess
a performance trend, ifappropriate.
The trends are:
~tm rovin: Licensee performance was determined to be improving during the assessment
period.
~Declintn: Licensee performance was determined to be declining during the assessment
period
and the licensee had not taken meaningful steps to address this pattern.
Trends are normally assigned when one is definitely discernable and a continuation of the trend
may result in a change in performance during the next assessment
period.
I
h
"C