ML18058A511
| ML18058A511 | |
| Person / Time | |
|---|---|
| Site: | Palisades  |
| Issue date: | 06/08/1992 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML18058A510 | List: |
| References | |
| 50-255-92-01, 50-255-92-1, NUDOCS 9206160085 | |
| Download: ML18058A511 (19) | |
See also: IR 05000255/1992001
Text
INITIAL SALP REPORT
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
Inspection Report No. 50-255/92001
Consumers Power Company
Palisades Nuclear Generating Plant
January. 1, 1991, through March 31, 1992
9206160085 920608
ADOCK 05000255
G
SALP 11
CONTENTS*
I.
INTRODUCTION ****************************** * *************
Page
1
II.
SUMMARY OF RESULTS *************************************
2
JII. PERFORMANCE ANALYSIS *****...****** ~ **.********** ~......
3
A.
Plant Operations ***.**......**....*.**.***.****.**
3
B.
Radiological Controls ******** ~....................
5
C.
Maintenance/Surveillance ************ ~.............
7
D.
Emergency Preparedness *************r*******~******
9
E.
Security .......... *................................
10
F.
Engineering/Technical Support **** ~ ********* ~~.....
11
G.
Safety Assessment/Quality' Verificat.ion * * * * * ** * * * * *
13
IV.
SUPPORT! NG DATA AND SUMMAR I ES * * . * * *.* * * * * * * * * * * * * * * * * * * *
16
A.
Major Licehsee Activities ***.*********************
16
B.
~ajor Inspec~ion Activities ************ ~.*~******~
17
I.
INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated U. S. Nuclear Regulatory Co1m1ission (NRC) staff effort to collect
av*ilable observations and data on a periodic basis and to evaluate licensee
performance on the basis of this information. The program is supplemental to
normal regulatory processes used to ensure compliance with NRC rules and
regulations. It is intended* to be sufficiently diagnostic to provide a
rational basis for allocating NRC resources and to provide meaningful feedback.
to the licensee's management regarding the.NRC's assessment of the facility's
performance in each functional area.
An NRC SALP Board, composed .of the staff members 1 i sted be 1 ow, met on May 13,
1992, to review the observations and data on performance, and to assess
licensee. performance in accordance with the guidance in NRC Manual
Chapter 0516, "Systematic Assessment of Licensee Performance."
This report is the NRC's assessment of the lic~nsee's safety performance at
Palisades for the period January 1, 1991, through March 31, 1992.
The SALP Board for Palis.ades was composed of the following individuals:
Board Chairman *
E. G. Greenman, Director, Division of Reactor Projects (DRP)
Board Members
H. J. Miller, Director, Division of Reactor Safety (DRS)
C. E. Norelius, Director~ Division of Radiatibn Safety and Safeguards (DRSS)
L. B. Marsh, Project Director, Project Directorate (PD) III-1, Office of
Nuclear Reactor Regulation (NRR)
B. L. Jorgensen, Chief, Section 2A, DRP
B. E. Holian, Senior Project Manager, PD IV-2, NRR
J. K. Heller, Senior Resident Inspector, Palisades
- Non-voting member
Other Attendees at the SALP Board Meeting
C. E. Brown, Reactor Engineer, DRP
R. L. Bywater, Reactor Engineer, DRP
J. R~ Creed, Chief, Safeguards Section, DRSS
M. K. Gamberoni, Project Engineer, PD III-1, NRR
G. M. Hausman; Reactor Inspector, DRS
J. E. House, Senior Radiation Specialist, DRSS
F. J. Jab~onski, Chief, Maintenance and Outages Section, DRS
A. w. Markley, Senior Radiation Specialist, DRSS
F. A. Maura, Reactor Inspector, DRS
J. H. Neisler, Reactor Inspector, DRS
M. P. Phillips, Chief, Section 2B, DRP
T. J. Ploski, Senior Emergency Planning Specialist, DRSS
D. L. Schrum, Reactor Inspector, DRS
W. G. Snell, Chief, Radi~logical Controls Section, DRSS
II.
SUMMARY OF RESULTS
Overall performance at the Palisades Nuclear Power Plant was characterized by .
generally st.eady or improving results and showed a conservative and safe
operating philosophy.
The overall degree of management attention and
effectiveness was acceptable in all areas. However; regulatory compliance
problems indicated a need for increased emphasis in several functional areas~
Performance declined slightly in the area of Plant Operations. Several
unrelated shift management judgment errors occurred which were of some
rnnrPrn_
~nwPvPr_ ~trnnn nvPrall nPrfnrmanrP ann anmini~trativP nrnnram~
already in place,' combined with the actions taken to resolve the errors,
resulted in this area maintaining a Category 1 rating.
Radiologic~l Controls was again rated Category 2 *. Efforts to reduce personnel
dose.and personnel contaminations were commendable and. should be continued.
-However, some events and programmatic problems were not effectively handled,
indicating that increased management attention is warranted. The Safety
Assessment/Quality Verification functional area was again rated Category 2.
The Board noted generally good performance in the support of self-improvement.
initiatives, event assessments, and inter-department communication and
coordination. However, continued emphasis is warranted in management oversight
of quality and corrective action followup.
Improved performance was noted.in the areas of Emergency Preparedness and
Engineering/Techn.ical Support.
Each area was rated Category 2. These areas
were previously rated Category 2 with a declining trend.
In the area of
Emergency Preparedness, improvements in training and staffing were noted by
the Board.
In the area of Engineering/Technical Support, the Board noted t.hat
the system engineering pr.ogram continued to be a strength. However, continued
emphasis is needed to resolve environmental qualifi~ation (EQ) problems and to
properly implement a program for procurement and dedication of commercial-grade
parts for safety-related applications.
Continued superior performance was noted in the areas of Security and
Maintenance/Surveillance, resulting in each area maintaining a Catego~y 1
rating.
The performance ratings during the previous assessment period and this
assessment period according to functional areas are given below:
Functional Area
Plant Operations
Radiological Cont~ols
Maintenance/Surveillance
Security
Engineering/Technical
Support
Safety Assessment/Quality
Verification
Rating Last
Period
1
2
. 1
2 Declining
1
2 Declining
2
2
Rating This
Period
1
2
.1
2
1
2
2
-
III. PERFORMANCE ANALYSIS
A.
Plant Opeiatirins
1.
Analysis
Evaluation of this functional area was based on 11 routine inspections by
the resident inspectof'.s, 2 licensed operator requalification examinations
and 2 inspections (a fire protection inspection and a special inspection) by
regional inspectors.
Enforcement history declined from the previous assessment period. One Severity
Level III violation was issued for an inoperable contain~ent spray pump *.
Corrective actions were prompt, ~ffective, and addressed the underlying
programmatic problem which the licensee identified with the restoration of
certain circuit breakers after an outage. A Severity Level IV violation was
issued for not complying with an applicable Technical Specification (TS).
The.
safety ~ignificance was minor, the violation was not repetitive arid the
corrective actions were prompt and effective.
Several licensee event reports (LERs) were issued that, applied to this
functional area. A couple of these events were attributed to personnel errors
that had a minor effect -0n safety. Others documented the three "at power"
reactor t~ips (discussed below) and the Severity Level III vicilation discussed
above.
The operators properly analyzed and initiated the appropriate response to the
three plant trips.
In addition,.they promptly and completely reported the
events. * Component aging was a root cause for the first reactor trip when t,rip
modules in the reactor protection system malfL!nctioned, actuating thehigh
pres~ure logic for the primary coolant system.
The initiating e~ent for the
second reactor trip was a decrease in turbine generator seJl oil pressure.
During the subsequent rapid power reduction, the operators manually tripped the
reactor upon observing high water level in the steam generators. The third
- reactor trip followed a feedwater pump trip. The root cause analysi~ identified
an original plant design ~roblem that permitted an oil to electrical interfacing
short, circuit. This appeared to be the most likely root cause of the L!nexplained
plant trips' discussed in previous assessment periods.
In general, transient response procedures were appropriate; however, certain
off normal and emergency_ procedures did not clearly indicate the entry and
exit points for the procedures.
When one of these problems was identified
during a training session, the proced~re was not immediately revised.
However, the operators s~bseq~ently acted appropriately during a transient.
The assessment period began_and ended with the plant in startup activities
f~om two planned outages. During these activities, strong administrative
programs were in effect to control activities for heatups, cooldowns, reduced
water inventory operations, shutdown, and startup. A work control program
called "system windows~ was used to optimize scheduling of shutdown~related
activities. Prerequisites for refueling activities were planned and established
during the day shift to minimize the burden to back shift personnel. Although
these activities were planned* in advance, a few shift management judgment
3
I
I
errors occurred. These* included one containment integrity problem, a 5-minute
loss of shutdown cooling, and thebreaker problem that resulted in the Severity
Level III violation. These events were of concern to the NRC.
The operations department developed an effective program to determine the
trends of key plant parameters. In finding many of these trends, *the
operations staff evaluated the *system response and developed an overall
integrated view of performance. These trends were accessible to personnel
throughout the entire plant, which provided an important communication link
to the operating shifts. Examples were trending programs for leakage from
the service water and comoonent coolina water svstems.
ThP Pnd re~ult w~~
improved s~stem integrity~
-
- *
-
.
Management's effectiveness in ensuring quality was demonstrated by a
conservative* and safety-oriented operating philosophy as shown by the examples
above.
In addition, when proposed revisions to the TS. were submitted with more
restrictive out-of-service time and reporting requirements, they were
administratively implemented. Administrative programs were also i~plemented to
balance preventive maintenance, corrective maintenance, and limiting condi~ions
for operations to maximize component reliability and minimize out-of-service
time during "at power" operation.
Corporate management visited the site regularly to a~sess a~tivities in the
control room and plant. Specifically, the Vice President of Nuclear Generation
performed monthly tours and the Chief Executive Officer performed quarterly
tours. Site managers remained cognizant of plant parameters by attending daily
meetings, making direct observations, and reviewing daily plant reports. Upper
and middle level plant managers were frequently observed in the control room*
and in the plant.
Management ensured the quality of the fire protection program by implementing
effective administrative controls for transient combustibles, by evaluating
the fire brigade, and by ensuring that the fire protection audits were
complete. Administrative controls for transient ~ombustibles were well written
and provided clear guidance to plant personnel. While performing fire drills,
the brigade demonstrated that it was well trained. Routine audits were
performed to ensure that equipment availability was maintained. Fire
protection problems from the previous assessment period did not reoccur.
Housekeeping and material condition in the auxiliary building were good.
Areas were well lighted; leaks of steam, water, or oil were minimized and
controlled; and the amount of contaminated area was small.
On the other
hand, housekeeping in the turbine building was inconsistent, varying at
times from good to.poor.
The approach to the resolution of technical issues from a safety standpoint
was routinely demonstrated by the conservative operating policy. Although not
required by TS, the plant was removed from service to correct a faulty level
indicator for a safety injection tank. The indicator did not directly affect
operability but indicated that an instrument problem may exist with the safety
injection tanks.
The turbine-driven auxiliary feedwater pump was conservatively
d~clared inoperable because the operators would not have had full response .
capability from the alternate steam supply line. This steam supply was not
4
required by the TS nor discussed in the final safety analysis report. The
operators demonstrated sensitivity to containment integrity when the back shift
operating crew, with su~port from ~ainte~ance and engineering personnel,
corrected a problem with minimum integrity risk.
Experience levels of managers and operations.personnel were excellent.
Staffing size was adequate.
Use of overtime during power operations and
outages was well managed.
The simulator was moved from a remote location to
the site~ Other simulator improvements included expanded computer capacity,
upgraded filming capabilities (used during student critiques), and instructor
control nanel enhan~ement~-
ThP trn;n;nn ftnn n11ftlifir~+inn nrnnr~mc woro
excelleni as evidenced by the 100 perceni pass 'rate f~r i~~ ~~~~~j{ii~;~ion
examination administered by the NRC.
2.
Performance Rating
Performance is rated Category 1 in this area. Performance was fated
Category 1 during the previous assessment period.
3.
Recommendations
None.
8.
Radiological Controls
1.
Analysis
Evaluation of this functional area was based on the results of routine resident
inspections and six inspections by regional inspectors.
Enforcement history declined somewhat during this assessment period. Five
violations (four Severity Level IV and one Severity Level V) were issued.
None
had major safety significance. Aspects of some violations are discussed below.
A single reportable event occurred which was assigned to this functional area,
relating to the circumstances involved in one of the violations.
Management's effectiveness in ensuring quality was mixed.
Management failed
to evaluate the safety significance of a change made in the processing and
storage of radioactive waste.
When discovered, a review led to the
identification of three similar failures* in earlier years.
On occasion,
management failed to ensure that various deficiencies were reported, adequately
evaluated, and corrective measures taken in a timely manner.
For example, a
hot particle exposure event was not reported in the plant's corr~ctive action
system, a comprehensive evaluation was not performed, and the corrective.action
was found to be inadequate. There was one instance of a transportation program
problem when a shipment of radioactive material left the plant with a leaking
package. Although this event had minimal safety significance, it created
public and ~ongressional concern that would have been avoided with proper
control over the activity. Evaluation found a programmatic weakness relating
to paperwork not providing drivers with an emergency point of contact.
5
[xamples of good management performance were the continued progress in
implementing the corrective actions from the health physics self-assessment,
strong support of the water quality program by installing new steam generator
blowdown demineralizers, and the significant upgrades of secondary plant
equipment which yielded much improved plant water qualjty. Managers also
significantly improved their support of ALARA (as-low as reasonably achievable)
philosophy by including ALARA criteria in the performance evaluations for
individuals and managers and broader support for ALARA ColTBTlittee efforts.
Progress was made to better integrate ALARA activities into all the plant
organizations, which was a problem area noted in the previous assessment period.
An effective. diverse source term reduction oroaram was continued. Audits were
generally accurate in assessing perf~rmance.
The approach to identifying and resolvin~ issues from a safety perspective was
good.
Good performance was noted with the effluents programs and radioactive
waste reduction. Improvements were noted in the use of electronic dosimetry,
ALARA planning, and records maintenance.
Health physics, ALARA, and chemistry
.organi~ations actively participated in daily, pre-outag~, and outage planning
meetings. Performance in nonradiological chemistry comparisons between the
licensee and the NRC was improved with all agreements in 26 comparisons.
Radiological confirmatory measurements results were also excellent with all
agreements in 49 comparisons.
The radiological env.ironmental monitoring
program was well implemented and equipment was well maintained.
On the.other
hand, the nonradiological environmental program did not adequately reflect
applicable TS. -There were some examples in which efforts reflecting
performance in the identification and resolution of issues from a safety
perspective were somewhat narrowly focused. These included problems with
radioactive source control and timely.communicati9n of radiological survey
information.
Performance in controlling personnel contaminations was good, even though the
licensee's goal -for the 1992 refueling outage was not met.
The total amounts
of personnel exposure reflected improving performance.
Exposure for the early
part of the period was expectedly higher because of the Steam Generator
Replacement Project (SGRP).
ALARA efforts have matured significantly over
this assessment period with good performance in this area.
-
Staffing levels and qualifications of the radiation protection, radwaste
management, and chemistry programs were good.
Verification of contract
radiation protection technician experience and qualifications improved markedly
during this assessment period. The training programs were effective~ The
staff was appropriately trained and qualified to perform assigned duties.
2.
Performance Rating
Perforinance is rated Category 2 in this_ area. Performance was rated Category
2 during the previous assessment period.
3.
Recommendations
None.
6
C. *Maintenance/Surveillance
1.
Analysis
Evaluation of this functional area was based on the results of 10 routine
inspections by the resident inspectors, a special inspection performed by
headquarters inspectors and 3 inspections performed by regional inspectors.
Enforcement history was excellent. There was one Severity Level IV violation *.
The safety significance was minor and the violation was not programmatic or
r~n~titivi:o_
There were several LERs applicable to this functional area, comparable in
frequency to the previous assessment period.
One pertained to an inadequate
surveillance procedure that caused a reactor trip signal during cold shutdown
conditions. Another discussed an inadequate work instruction that.resulted in
an inadvertent left-chann~l containment isolation. Both events resulted from
the use of plant schematics that did not reflect the correct system configuration~
Plant ~ocument accuracy issues are being actively pursued by th~ Configuration
Control Project. The other events did not indi~ate repetitive, generic, or
programmatic problems.
None of the events had major safety significance.
The survei 11 ance program was successfully managed and implemented, with tests
routinely completed on time.
The extension of surveillance intervals to permit
use of the "grace period" was minimized by appropriate management controls.
Surveillance procedures were controlled, revised, and maintained by the plant
organization most knowledgeable and responsible for the equipment.
Eac~
procedure had a supporting basis document that explained the assumptions,
defined the calculations, and amplified the justification for the acceptance
criteria.
-
Plant personnel consistently used the procedures at the job site, and discussed
unexpected equipment responses with plant management.
Problems were
appropriately resolved in the corrective action program. Several problems
were encountered when infrequently performed test procedures were used during
outage startup activities. This resulted in a number of events reportable
under 10 CFR 50.72. *These problems did not result in safety problems or
inoperable equipment; however, they indicated that the challenge of
infrequently performed tests observed early in the period had not been
resolved. A special review group was formed to evaluate this challenge
and its evaluations were still in progress at the end of the period.
The post-maintenance test program was good with responsibility assigned to the
appropr1ate maintenance superintendent and system *engineer to determine the
appropriate post-maintenance test. Operations personnel ensured that the
tests were properly authorized, performed, reviewed, and documented before
returning the equipment to service. However, a maintenance personnel error
resulted in a loss of shutdown cooling for approximately 5 minutes.
The predictive maintenance program effectively used vibration monitoring,
lube oil analysis and infrared thermography to trend equipment performance.
Examples included the identification of an impending service water pump bearing
.7
failure, a resonant frequency problem on a service water pump, and alignment
problems between.the pump and motor which resulted in improved alignment
techniques.
Management effectiveness in ensuring quality remained a strength. Personnel
were effectively utilized for planning *and scheduling of. work activities,
including arranging for pre-staging of parts, and routine visits t~ the job
site by supervisors. A violation assigned to the Safety Assessment/Quality .
Verification functional area, however, documented a problem with the control
of vendor manuals when planning and performing work *. This did not result
in inoperable equipment but did identify that personnel did not appreciate the
administrative program for control of vendor manuals. A computerized work
order system permitted easy reference to historical information. The value of
, detailed work order summaries was observed as indicated by the presence and use
of previous work order.summaries at the job site.
There were two planned outages performed during this p~riod: Outage
. management maintained the global overview required to ensure the safety of the
plant.and safety of personnel involved in various activities. The outages were
weJl planned and used a 24-hour rotating shift manager position to ensure that
proper attention was directed to the outage work path and that new work was
properly evaluated .and categorized. For example, multi-disciplinary work
groups were established to recover a fuel bundle which became stuck to the
upper.guide structure, and a dropped fuel pin in the spent fuel pool.
The approach to the identification and resolution of technical issues with a
view to safety remained strong. Maintenance activities were closely followed*
by both the system engineer and first line supervjsor. Examples included.
repairs to a feedwater heater d~ain valve, noise within the governor 6f a .
feedwater pump turbine, and turbine generator lube oil problems.
Each day,
upper level managers were informed of current work.
Meetings included
discussion of problems encountered and usually resulted in prompt evaluation
and effective resdlutions as discussed above ..
The.work order backlog was routinely evaluated and managed by a program that
considered available person-hours and crew size. Additional, non-site
resources were available to control backlog size, resulting in a well managed
backlog. At the beginning of 1992, only 90 non-outage work requests wereover
12 weeks old, indicating that maintenance was timely and long-standing
equipment problems were mini~ized. Work orders scheduled to be completed
during the outages required senior management approval to be deferred, and the
nu~ber actually deferred was minimal (approximately 2 percent of the 1992
. refueling outage work orders).
The maintenance program had a defined policy for finding, evaluating, and
implementing corrective action for repeat maintenance.
The computerized work
order program and database were useful for evaluating equipment history.
Preventive maintenance programs were effective as evidenced' by the equipment
availability and the material condition of the pl ant. A valve improvement
program implemented during a previous assessment period proved beneficial
as indicated. by the absence of containment boundary valve failures during local
leak rate testing.
.8
Staffing in this functional area continued to be a strength. This was
- attributed to the low turnover rate of both.workers and supervisors. Programs.
remained in place to provide temporary upgrades of maintenance. workers to staff
positions for use as planners.
In *addition, support engineers continued to be
rotated into licensing classes. Rotations wefe controlled arid did not affect
- quality; rather, quality was enhanced by improved communication and
coordinatfon between wotk groups~ *
2.
Performance Rating
during the previous assessment period.
3.
Recommendations
None.
D.
1.
Analysis
Evaluation of this functional area was based on the r~sults of two inspectio~s.
Enforcement history was excellent with. no violations identified.
No
reportable events occufred which were assigned to this functional area.
Management's effectiveness in ensuring qualitj~as good.
Corrective actions
to eliminate training program inadequacies, identified at the end of the
previous assessment period, became effective in mid~l991. The emergency
.
preparedness coordiriato.r (EPC) position became a full-time assignment late iii
the period~ Emergency resp.onse facilities were good and *well maintained, with
. several .equipment upgrades either complete or nearly complete.
Working
relationships with State and county officials were very good.
.
.
The identification and resolution of technical issues with a view to safety
generally remained good.
Actual emergency plan activations were *correct and
timely, including making the conservative unusual event declaration in February
1992 upon experiencing a fuel handling problem.* Response to thi$ problem
included a partial activation of the technical support center (TSC) by management,
- health physics, and communications personnel. State, county, and NRC officials
were notified of actual emergency decl~rations in an accurate and timely
manner.
The licensee thoroughly evaluated its records associated with actual
emergency declJrations.
In contrast, during followup of an NRC~jdentified
issue in 1991', the licensee identified a significant limitation in the
telecomputers used to notify *1ts emergency response organization (ERO) during
off hours.
Efforts remained in progress at the end of the assessment period to
overcome this equipment limitation, so that th~re would be reasonable assurance
that *onshift personnel would be sufficiently augmented in a timely manner
during off hours.
Overall performance during the 1991 exercise was good, with improvements
evident within the emergency operations facility. All emergency clas~ification
decisions and associated offsit~ notifications were correct and timely.
9
Although performance improved during the 1991 exercise, a previously noted
problem relating to the coordination and tracking of inplant teams by supervisors
in the control room and several response facilities had not been corrected.
Corrective actions were incomplete at the end of the assessment period. The
effectiveness of completed or planned ch-anges to the layout, equipment, staffing,
and procedures of response facilities has not been demonstrated during an
exercise.
The EP groups from the plant and the corporate office were adequately staffed
by well qualified persons. Late in the assessment period, the EPC was relieved
ur ~~~ ca11~t~~~~ ~~~~:: :: t~:i~~~; ~==~1i~~t~~. ~~i~h h~rl rnn~um~d about
30 percent of his time. This allowed him to dedicate his efforts full time to
_the EP area.
The EPC was supported by two part-time assistants, a part-time
training instructor, and several corporate personnel. The ERO's staffing
level improved and is now very good to ensure 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing capability for
key and support positions with currently qualified personnel.
The-EP training program improved and became well organized during the
assessment period.
In response to violations identified during the previous
period, administrative controls and practices were established by the EPC a*nd
training department staff to ensure that only currently trained personnel were
on the ERO's call out list. The maintenance and overall quality of EP lesson
plans improved and was very good.
All required drills were conducted and
critiqued *.
2.
Performance Rating
Performance is rated Category 2 in this area. Performance was rated Category 2
with a declining trend during the previous assessment period.
3.
Recommendations
None.
E.
Security
1.
Analysis
Evaluation of this functional area was based on the results of two inspections
and routine resident inspector observations.
Enforcement tiistory improved and was excellent; no violations were identified.
Management's effectiveness in ensuring the qua1ity of the security program
remained excellent. Senior managers supported security initiatives by
encouraging the contract security supervisors to attend licensee-sponsored
management development classes. Management's dedication to improving security
was demonstrated through the continued reduction in personnel errors and
improved implementation by plant personnel of security requirements.
The
managers maintained good oversight of the daily implementation of the program.
The approach to the identification and resolution of technical issues was
excellent.
One initiative-involved appointment of an operations liaison to
10
work with the security department in identifying pertinent information on -
protecting vital equipment to improve tactical response capabilities.
Management also began program planning for replacing the card reader and
computer portion of the access control system.
-
Security staffing was good.
The experience level of the guard force was high-
as a result of low turnover. - A close and effective liaison existed between
local law enforcement agencies and licensee security managers. During this
assessment period, the security managers continued to routinely keep both
resident inspectors and regional personnel fully informed of site security
issues. Security operational events were orooerlv identified~ analvzed. and
documented. Security-related records and logs were complete, well maintained,
and readily retrievable.- A timely program was implemented to heighten security
awareness during the Persian Gulf conflict.
The training and qualification program for the_ security force was good.
In the
middle ~art of the assessment period, an outside contractor with tactical training
expertise was hired. This action helped correct the weakness identified in the
previous period regarding the need for additional and more effective tactical
response training. Security personnel were competent in executing their
duties.
2.
Pe~formarice Rating
Performance is rated Category 1 in this area~ Performance w~s rated
Category- 1 during the previous assessment period.
3.
Recommendations -
None.
F.
Engineering/Technical Support
1.
Analysis
Evaluation of this functional area was based on the results of 14 routine
inspections, an electrical distribution system functional inspection (EDSFI),
a modified operational safety team inspection (OSTI-) ,_ 3 operator 1 icensing
examinations, and interactio-ns among the licensee and NRR staffs.
Enforcement history was weak.
One Severity Level III violation was issued for
a programmatic breakdown in the area of piping and pipe support design.
However, much of the inspection jnformation which resulted in this violation
was discussed in the previous SALP.
This violation was similar in nature to
the Level III violation issued in the previous assessment period. Subsequent
corrective actions and root cause evaluations were adequate and appeared to
be comprehensive.
Two Severity Level IV violations were also issued.
One
of these was in electrical design control, for which a design change in 1986
was not implemented *. The other violation was in the area of corrective action.
This was the second time within the last three SALP periods that the licensee
had failed to take the corrective action .stated in its response to a previously
'issued Notice of Violation.
11
.
-
Several LERs were attributed to this functional area. Approximately half of
the LERs discussed failure to meet EQ commitments associated with Regulatory
Guide (RG) 1.97. Many of these resulted from the licensee's review of the .*.
contractor report discussed below.
The remaining. LERs were issued for
inadequate design controls. Most of the LERs were th~ result of activities in
previous assessment periods.
Management effectiveness in ensuring quality remained mixed.
On the positive
side, the system engineering program, established in the mid-1980s, was well
implemented *. System engineers were involved in the daily operation and
performance of assiQned systems and supported olant maintenance in identifyino
trends in system performance, identifying equipment problems, and planning
maintenance activities. The configuration control project continued to make
good progress. For example, several original plant electric design
deficiencies were identified. Relocation of corporate engineering resources
to the site significantly improved engineering support o~ the plant.
The EDSFI found design develop~ent and implementation for the electric~l
distribution* system were satisfactory. For the most part, design attributes
were retrievable and verifiable, although some modification documentation, such
as for the unbolted diesel silencers, was not retrievable. Engineering
calculations were technically sound, although some nonconservative assumptions
were identified in cable sizing and design calculations. Most of these
problems were associated with initial design.
Improvement in design control
was noted for recent design activities. This had been an area of concern
during the previou~ assessment.
Management's effectiveness in the area of operator requalification and initial
operator examinations improved from the previous assessment period partly a.s a
result of the additional personnel assigned to the training staff. The
- relocation of the training simulator to the plant training building had a
positive impact due to increased accessibility.
On the negative side, management's effectiveness in controlling the EQ program
was poor. Although the licensee hired a contractor to study the EQ program,
it did not provide sufficient staff and attention to review the problems
- identified in a report by the contractor and to take corrective action. A
detailed review of the report was not completed until a year after it was
received. Similarly, management involvement and control of the RG 1.97 program
was not effective. Program requirements were not completed and commitments
made in response t6 a Notice of Violation were not performed. Managers ~lso
failed to apply the necessary attention and resources in the program for
procuring and dedicating commercial grade components for safety-related
applications. Finally, weaknesses were identified by the EDSFI team in
post-modification testing.
The approach to the identification and resolution of technical issues from a
safety standpoint was mixed.
On the positive side, system engineers prepared
-quarterly system performance monitoring reports on all systems in which
selected system performance indicators were trended.
The reports identified
adverse component trends and were an effective predictive maintenance tool.
The system engineers also routinely demonstrated a conservative approach in
12
r~solving problems.
Examples included the handling of a problem with the
alternate steam supply valve for the turbine-driven auxiliary feedwater pump,
the response to reactor trips initiat~d by a loss of feedwater due to a short
circuit caused by oil leaking in a control cabinet for the main feedwater
. pumps, and the use of vibration analysis beyond normal- inservice testing
requirements to diagnose serv,ice water pump problems. Root cause analyses were
routinely performed by engineers following acceptable guidelines. Corrective
actions to resolve.significant problems identified in the configuration control
and design bases review programs continued to be well prioritized.
On the
. negative side, deficiencies associated with design work performed for the SGRP
were not resolved in a timel.Y manner because manaaement failed to rPr.noni7i:o
their significance. Resolution of these deficiencies was only underta~en
after lengthy discussions with the NRC and a second inspection of the area
during this assessment period confirmed the previous findings.
The licensee
identified significant problems when it performed a re-analysis to address
these deficiencies.
One finding resulted in having to.re-modify the main -
steam system.
Engineering and technical support staffing was sufficient in siie to adequately
address most technical issues. The system engineers were experienced and well
motivated.
In response to concerns identified in the previous assessment
period, a design ehgineering reorganization took place which elevated the
position of Manager of Nuclear Engineering to report directly to the Vice
Presiderit of Nuclear GeneratiOn.
The design change program was strengthened*
considerably by relocating corporate engineers to the site, resulting in a
sense of "own~rship" for the design of specific projects. The engineers who
performed design ba~is*documentation (DBD) developm~nt and safety system design
configuration (SSDC) activities were knowledgeable in system design and
operations. The staffing problems in the training department, identified
during the last assessment period, were corrected. The EQ program was
understaffed and due to the high turnover experienced over the years, the
engineers wer~ wotking mainly on their backlog rather than dealing ~ith
emerging issues.
The effectiveness of the initial operator and requalification program was
excellent as evidenced by the 100 percent passing rate during the assessment
period. A formal training program existed for system engineers and included
root cauie analysis.
2.
Performance Rating
Performance is rated Category 2 in this area. Performance was rated
Category 2 with a declining trend during the previous assessment period.
3.
Recommendations
None.
G.
Safety Assessment/Quality Verification
1.
Analysis
Evaluation of this functional area was based on the results of routine
inspections by resident, regional, and NRR inspectors and special team
13
inspections.
In addition, requests for amendments, exemptions or relief,
responses to NRC generic communications, and other interactions with the NRC
staff were considered.
During this assessment period four Severity Level IV v.iolations were issued.
The violations covered a variety of areas, and were neither*programnatic nor
repet~tive. In addition, enforce~ent action was pending at the conclusion of
the assessment period for a significant failure of the corrective action
program, relating to EQ problems recently identified, but which occurred in
previous periods.
une LER was attributed to this functional area. A TS change was approved and
implemented without a .full understanding of the programmatic changes caused by
the revised TS.
Although this was an isolated event, it indicated a weakn~ss in
the process for reviewing TS changes. Additionally, two LERs (assigned
to other functional areas) indicated that proper onsit~ revie~s of
documentation provided by offsite organizations were not conduC:ted.
The LERs
submitted during this assessment period were,* in general~ clearly written a.nd.
comprehensive.
Management involvement and control to ensure quality were generally good.
Site-wide
11teamwork
11 and good interdepartment convnunications were generally
evident.
Manager~ continued to support various self-improvement initiatives,
several 'of which began during the previous assessment period and are scheduled
to continue into the next period. These initiatives included the configuration
control project and critical self assessments, such as the independent EQ
evaluation, to help corporate and plant management improve work activities.
When items were entered into the formal corrective action program, the program
provided a timelj classification and proper segregation of items for review by
the appropriate plant and corporate managers.
The staff and managers
discussed, clearly defined, and documented courses of action.
The initial
screening process, however, did not always prompt a retrospective operability
review~ This was the case in the containment spray pump inoperability issue
which prompted the NRC to take escalated enforcement action.
However,
adequate operability reviews have been performed in recent situations arising
from the corrective action program.
Responsibility for re.solution of corrective action documents was assigned to
specific indi~iduals. This established accountability and ownership. Most
corrective actions demonstrated sufficient evaluations of the problem and
associated system, and usually addressed the root causes. The plant licensing
dep~rtment tracked corrective action documents.which ensured timeliness and
minimized overdue actions~
Management follow-up of corrective actions in several areas, however, was
considered poor.
As indicated in the Engineering/Technical Support section,
corrective actions were not always adequate or timely for EQ, design work for
the SGRP, and DBD discrepancies related to cable routing problems.
The hiring
of a contractor to perform twQ EQ assessments was considered a very positive
action. Although one assessment report was adequately evaluated upon receipt,
the initial review for the second report was not sufficiently comprehensive to
14
ensure that items having potential impact on operability were promptly
addressed.
Upon a more comprehensive review of the second report, the licensee
determined (among other things) that the main steam isolation valves could be
rendered inoperable by a steam line break outside containment. The cause of
the delayed review appears to be either a 'lack of deta-iled knowledge about EQ
requirements on the part of the reviewer, or excessive workloads associated
with the steam generator replacement project. Additionally, no formal tracking
of the contractor report was performed to ensure management's awareness of the
report and timely completion of the detailed review.
Management strenQthened its support and overview of the confiQuratioh control
project. The categorization and closing of findings from DBD development and
SSDC activities were timely and effective. The DBD Writer's Guide, although
modified to adequately cover technical areas and.provide sufficient
instruction, was not used to update relevant design, operation, maintenance,
and regulatory documents.
Activities in this functional area reflected, in general, a proper emphasis
on safety in resolving technical issues. Initiatives were proactive in .
identifying deficiencies in design control and operations. The audit program,
independent design reviews, and configuration control project identified
problems and specified appropriate corrective actions for many deficiencies in
the plant electrical system.
On the negative side, although the plant had a
history of EQ problems, only one quality assurance audit had been performed in
this area since 1985. This audit, conducted in March 1991, was very limited in
scope.
During this assessment period, three plant events.highlighted the licens~e*s
strengths and weaknesses in clearly and concisely _communicating with the NR~ *.
The first pertained to a temporary waiver of compliance (TWOC) for unqualified
main steam isolation valve control citcuits. The second pertained to a fuel
bundle that stuck to the bottom of the upper guide structure when it was lifted
for defueling. For these two events, the oral communications demonstrated a
thorough understanding of the problem and accurately conveyed that the licensee
was properly managing the situations. Also, the written documentation
demonstrated a*comprehensive working knowledge of the NRC TWOC administrative
procedure.
The third event pertained to a configuration control project finding relating
to inconsistencies in cable routing drawings and data.
In contrast to the
other two events, information presented to the NRC during various conference
calls was not always consistent. These communication difficulties contributed
to the impression that cable routi11g inconsistencies were *not aggressively
pursued.
A new director of safety an~ licensing was assigned during this assessment
period. The new director brought a valuable knowledge of probabilistic risk
assessment, which was incorporated when evaluating items to determine
appropriate corrective actions and to determine the schedule for implementation.
For example, it was determined that a fast transfer circuit problem existed for
the emergency diesel generators. The licensee properly evaluated the problem
and initiated discussion with the NRC to effect a resolution.
In addition,
relocafion of the licensing staff to the site improved communications, both
internally and externally.
15
I I
The onsite Plant Review Committee (PRC)' was properly staffed and functioned*
well. A subcommittee was established to manage the workload of the PRC and
determine which issues require formal co11111ittee review.
The 10 CFR 50.59 *
- evaluations were generally well documented and comprehensive.
Most licensing submittals were of good quality and showed improvement over
the previous assessment period.* The licensee routinely demonstrated that it
properly understood technical issues and that ma~agement effectiveness was
good.
However, a number of submittals did not provide sufficient information,
or required revision prior to final acceptance by the NRC staff. This was
discussed with the licensee midway through the assessment period, and
Noteworthy responses were made on two significant licensing issues.
The first
issue involved an unreviewed safety question relating to the potential for
radioactive water inleakage into the safety injection and refueling water tank
following a loss of. cool ant accident *. Pl ant management ident_ified this concern
and initiated discussion with the *NRC staff.
An Information Notice was
subsequently issued by the NRC staff to all pressurized water reactor licensees.
The second issue related to the generic issue of reactor vessel pressurized*
thermal shock. Although initially slow in aggressively pursuing this issue,
the licensee formed an effective plant task force, with excellent management
guidance and oversight~ later in the assessment period.
The task force
compiled and evaluated a large data base of information on the reactor vessel *.
Ma,nagers expertly responded to NRC staff technical questions during several
meetings and in follow-up correspondence.
2.
Performance Rating *
Performance is rated Category 2 in this area. Performance was rated Catego*ry 2
during the previous assessment period.
3~
Recommen.dations
- None.
IV.
SUPPORTING DATA AND SUMMARIES
A.
- Major Licensee Activities
Significant outages and events are described below~
The unit began the period in a refueling and steam generator replacement
outage that ended on March 10, 1991~
On March 24, 1991, the unit was shut down to repair a failed level float
switch for a safety injection tank.
The unit was returned to service on
March 25, 1991.
On July 3, 1991, the unit tripped because of a failure of two relays in the
reactor prot~ction system *. The uriit was returned to service on July 8, 1991.
16
On July 12, 1991, the unit tripped because of a loss of a main feedwater
pump.
The unit was returned to service on July 13, 1991.
On December 9, 1991, the unit tripped during an emergency power reduction
necessitated by a turbine-generator seal oil system failure.
The unit was
returned to service on December 15, 1991.
On. February 6, 1992, the unit was removed from service for a refueling and
maintenance outage.
B.
Major Insp~ction Activities
1.
Inspection Data
The inspection reports discussed in the SALP are listed below:
Docket No. 50-255
Inspection Reports: 90025, 90039, 91002 through 91024, 91026, 91201, 91202,
and 92002 through 92011.
2.
Special Inspection Summary
a.
From September 19, 1990, through April 18, 1991, the NRC conducted an
engineering team inspection (IR 90025).
b.
From June 10 through 21, 1991, the NRC conducted an engineering and
design control inspection (IR 91202).
c.
From September 10 through 20, 1991, the NRC conducted a special safety
inspection (IR 91017).
d.
From November 4 through December 13, 1991, the NRC conducted an
electrical distribution system functional inspection (IR 91019).
e.
From January 6 through 10, 1992, the NRC conducted a modified operational
safety team inspection (IR 92003).
17
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I