ML18038A357

From kanterella
Jump to navigation Jump to search
SALP Repts 50-220/90-99 & 50-410/90-99 for March 1990 - March 1991
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

PDR

ADOCK 05000220

9

PDR

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

Emergency Preparedness

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.

ALARA

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.

Emergency preparedness

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

Emergency Preparedness

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

SRO and twelve RO

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

to seven SRO and three RO

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

SROs

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

annunciators.

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

emergency preparedness

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

unidentified leakage.

(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

scram.

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

scram.

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