Text

Forwards Summary of 891130 Meeting Re SALP Rept 50-416/89-22 & SALP Slides from Meeting & Util 900104 Response to Rept & Errata Sheet for Final SALP Rept.No Formal Changes to SALP Rept Needed,As Result of Review of Util Comments
	ML20005G582
Person / Time
Site:	Grand Gulf
Issue date:	01/09/1990
From:	Ebneter S; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Cottle W; SYSTEM ENERGY RESOURCES, INC.
Shared Package
ML20005G583	List: IR 05000416/1989022; ML20005G582;
References
	NUDOCS 9001190358
	Download: ML20005G582 (29)
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i Docket.No. 50-416-

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System Ener'gy Resources, Inc.

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( ATTN:) .Mr.1 W.. T. Cottle, Vice President

Nuclear. Operations-

P. O. Box'469~-

,

.PortiGibson,.MS.39150-

e [ Gentlemen

SbBJECT: LSYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE

s.

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"

.(NRCfINSPECTION REPORT NO.~ 50-416/89-22)

-

,

-

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!

'

This/ refers to the' NRC's' Systematic Assessment: of: Licensee Performance-(SALP-

~

.

' Report forEyour. Grand- Gulf facility which -was-;sent to you on November 22,-

-

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'

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.1989;;our meeting of November 30, 1989,' at which we discussed:.this report;-and

~

jyour written comments' dated January '4,(1990, relative to the report.

.

E

_ e have reviewedlyourt written comments and' find that no formal changes to the

W

SALP' report are neededL therefore,'the November 22; 1989 report constitutes.the

s

.,

, FinaloSALP report.- The performance of the Grand Gulf facility: has been

J

excellent and our SALP report identifies ~ that your efforts have been directed

toward the safeloperation of the facility. ' We note in particular initiatives'

%

in areas-where= weaknesses were'noted.

Your continued commitment to improve

.

a

1overall plant'operationsishould lead to continued excellent p.erformance.

'NoL reply: to' this 1.etter. is required; however, should you have any questions

~M

concerning these' matters, I will be pleased to discuss them with you.

.

Sincerely,

originalsoned By: g

James L Milhoan -

Stewart D. Ebneter

"

-

Regional Administrator

1

Enclosures:

1.

November ~30, 1989 Meeting Summary

'

2.1' November 30, 1989 SALP Slides

!

13. -SERI Response to SALP Report

>

s

.

(Letter dated January 4, 1990)

'

-4.

Errata Sheet for Final SALP Report

cc w/encls:

(See page 2)

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Office of the Governor

T. H.1Cloninger, Vice President

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LNuclear Engineering and_ Support

-State of Mississippi

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System-Energy Resources, Inc.

. Jackson, MS 39201

P. O. Box 31995.

.

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Jackson,.MS '39286'

Attorney _ General

Gartin Building

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C. R. Hutchinson, General-Manager

Jackson, MS 39205

.

D

- Grand. Gulf Nuclear Station

4

f

System Energy Resources,-Inc.

Jack McMillan, Director

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P. O. Box 756

Division of Solid Waste Management

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Port Gibson, MS- 39150

Mississippi Department.of

Natural Resources

c

~J. G. Cesare', Director

P. O. Box 10385

LNuclear Licensing

Jackson, MS 39209

~ System Energy Resources,-Inc.

_

'

P. O. Box 469~.

President.

i,

. Port Gibson, MS 39150

Clairborne County Board

.

of Supervisors

Mr. Ral.h T..Lally_

Port Gibson, MS 39150

.

F

. Manager of Quality Assurance

Entergy Services, Inc.

State of Mississippi

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P. 0. Box 31995-'

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Jackson,'.MS -39286-

bec w/encls-

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K. M. Carr, Chairman

!

R.,B. McGehee, Esq.

T. M. Roberts, Commissioner

. Wise, Carter, Child, 'and Caraway

F. J. Remick, Commissioner

-P. 0. Box'651'

K. C. Rogers, Commissioner

- Jackson',' MS 39205

J. R. Curtiss, Commissioner

l

J. M. Taylor, EDO

_

_N. S. Reynolds, Esq.

H. L. Thompson, Jr. , EDO

Bishop, Cook,-Purcell=&-Reynolds

R. W. Borchardt, Regional-

,

1400 L Street, NW - 12th Floor

Coordinator, EDO

1

Washington, D. C.

20005-3502

T. E. Murley, NRR

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S. Varga, NRR

l

C. B. Hogg, Project Manager

E. Adensam,'NRR

,

Bechtel _ Power Corporation

L. Kintner, NRR

1

-

P. O. Box 2166

R. Nease, SALP Coordinator, NRR

. Houston,' TX - 77252-2166

Regional Administrators, RI, RIII

+

RIV, and RV

i

Alton B. Cobb, M.D.

K. Clark, RII, PA0

,

'

State Health Office

D. Verrelli, DRP, RII

State' Board of Health

F. Cantrell, DRP, RII

i

P. 0. Box 1700 .

P. Balmain, DRP, RII

Jackson, MS 39205

K. Landis, Chief, TSS

NRC

Resident

Inspector

,"

The Honorable William J. Guste, Jr.

DRS and DRSS Branch Chiefs,

~ Attorney General

and Section Chiefs

Department of Justice

INPO

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State of Louisiana

IMPELL

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Baton Rouge, LA 70804

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ENCLOSURE-1-

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Meetino' Summary

A.

A meeting was1 held at 10:00 a.m. , on November 30,1989, at the Grand

Gulf Nuclear Station near Port Gibson,. Mississippi, to discuss the

SALP Board Report for' the Grand Gulf facility.

,

8.

Licensee Attendees

E._Lupberger, Chairman, SERI Board'of Direc...s

W. Cavanaugh, President and Chief Executive 'n 'icer

.f

D. C. Hintz, Executive Vice President

W. T. Cottle, Vice President Nuclear Operations

T. H. Cloninger, Vice President Nuclear Engineering and Support

C. R. Hutchinson, GGNS General Manager

.The list of licensee attendees above does not include the large

number of: SERI employees that were present at the 'SALP

presentation.

The _ personnel were supervisors, . plant operators,

.

maintenance personnel, and various plant staff.

This large turnout

was beneficial to the SALP process and is highly recommended for

future presentations.

Ci

NRC Attendees

1

i

S. D.~Ebneter, Regional Administrator

C. W. Hehl, Deputy Director, Division of Reactor Projects (DRP)

D. M. Verre111, Chief, Reactor Projects Branch 1, DRP

E. G. Adensam, Director, Project Directorate II-1, Office of

Nuclear Reactor Regulation (NRR).

i

L. L. Kintner, Senior Project Manager, NRR

l

H. O. Christensen, Senior Resident Inspector - Grand Gulf, DRP

J. Mathis, Resident Inspector - Grand Gulf, DRP

,

D.

SALP Meeting Slides

!

See Enclosure 2

7

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- . - . - . . . . - . . . . . . . - . . . _ . - - - - - . . . . -

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ENCLOSURE 2

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UITED STATES

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KCLEAR REGLLATORY

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RESOURCES, INC.

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MAY 1,1988 THROUGH SEPTEMBER 30,1989

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GRAND GULF UNIT 1

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NOVEMBER 30,1989

PORT GIBSON, MS

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1. lDENTIFY TRENDS IN LICENSEE PERFORMANCE.

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3. IMPROVE NRC REGULATORY PROGRAM

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1Two New funct"onal Areas

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Eng"neering/Techn" col Support

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Safety Assessment / Quality VerifLcation

Attributes Address"ng Human Performance

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Emphasis on Analysis

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PERFORMANCE ANALYSIS AREAS

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FOR OPERATING REACTORS

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A. PIANT OPERATIONS

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G. SAFETY ASSESSMENT / QUAlflY VERIFICATION

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isitot address the adequacy of technical

and: engineering; support for all plant

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Activities associated with the design

of plantimodifications; engineering and

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(technical sup) ort for operations, outages,

maintenance, testing, surveillance; and

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procurement activities; training; and

configuration manacement 'inc uding

maintaining design bases and margins}.

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The purpose of this' functional area is to address the

technical odequacy and completeness of the' licensee's

approoch toward a variety of activities ossociated with

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requests, relief requests, response to generic letters,

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bulletins,'ond information. notices, and resolution of TWl-

items and other regulatory initiatives.

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licensee activities related to the resolution of safety

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committee and self-assessment activities, ano!ysis of

industry's operational experience, root cause onolyses of

plant events, use of feedback from plant quality assurance /

quality control (QA/QC) reviews, and participation in self-

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substandard or onomalous performance in monitoring the

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BEING ACHElVED.

REDUCED NRC ATTENTION MAY BE

APPROPRIATE.

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LEVEL 0F PERFORMANCE ABOVE THAT NEEDED TO MEET

REGULATORY: REQUIREMENTS. UCENSEE RESOURCES ARE

ADEQUATE AND REASONABLY ALLOCATED S0 THAT GOOD PLANT

AND PERSONNEL PERFORMANCE IS BEING ACHEIVED. NRC

ATTENTION MAY BE MAINTAINED AT NORMAL LEVELS.

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2. APPROACH TO RESOLUTION OF TECHNICAL ISSUES

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FROM A SAFE 1Y STANDPOINT

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3. RESPONSNENESS TO NRC INITIATNES

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4. ENFORCEMENT HISTORY-

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5. REPORTING AND ANALYSIS OF REPORTABLE EVENTS

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LERs PER UXIT

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PLANT OPERATIONS - CATEGORY 1

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OVERALL OPERATIONAL PERFORMANCE WAS GOOD

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MANAGEMENT ATTENTION HAS REDUCED THE NUMBER OF EVENTS

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OPERATION $ STAFF HAS VERY PROFESSIONAL AND KNOWLEDGEABLE

APPROACH TO OPERATIONS

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STATION HOUSEKEEPING AND CONTROL ROOM DECORUM ARE STRENGTH $

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PROTECTION PROGRAM REFLECTS

STRONG MANAGEMENT

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OUTAGE MANAGEMENT WAS EFFECTIVE

,

RESPONSIVE TO NRC CONCERN $

!

r

e

3

i

O

- - -

-

- - - - , ,

..----,.....a.

- - , - , - - , ~

-,~a,--,.._v.,,,,----,-

,,--,.-,-ve-,-,

- - - ,a-n,-,,..r,,,,

. - - - - ,-,-

.m

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l

RADIOLOGICAL CONTROL $ - CATEGORY 1

l

-

i

OVERALL HP PERFORMANCE IN $UPPORT OF ROUTINE AND OUTAGE

'

f

ACTIVITIES WAS 0000

KNOWLEDGE AND EXPERIENCE LEVEL OF HP STAFF CONSIDERED A

l

PROGRAM STRENGTH

l

,

HP TRAINING WAS HIGH QUALITY

j

!

EFFECTIVE AUDITS OF HP PROGRAMS

[

-!

IMPROVEMENTS NOTED IN ALARA PROGRAM

i

REDUCTION IN CONTAMINATED AREA

,

NO UNPLANNED RELEASES AND EFFLUENTS WITHIN LINITS

,

f

COUNT ROOM PERFORMED WELL

.

CONTINUED TO TAKE POSITIVE ACTIONS REGARDING PLANT WATER

QUALITY

INCREASE NOTED IN COLLECTIVE DOSE AND CONTAMINATION EVENTS

'

i

s

<>-,-e

+=

c-

. < . ~

,=-es...r.

e.---.

. . - - - - - - -

-

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.. -,--

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- - -. - - --

-.-, , -

.. . , . .. .- - . - - ,

'

.

, .

'* -

,

.

MAINTENANCE /SURVE!LLANCE - CATEGORY I

OVERALL

MAINTENANCE

AND

SURVEILLANCE

ACTIVITIES

EFFECTIVELY SUPPORTED PLANT OPERATIONS

MANAGEMENT CDPMITMENT AND INVOLVEMENT EVIDENT

l

IMPROVED CONTROL OF_ MAINTENANCE ACTIVITIES

-

MAINTENANCE ORGANIZATION STAFFING AND TRAINING WAS A

STRENGTH

PLANNING AND SCHEDULING ACTIVITIES FUNCTION WELL

'

EFFECTIVE PROGRAM TO CONTROL BACKLOG

SIGNIFICANT REDUCTION IN THE NUMBER OF MISSED SURVEILLANCES

'

.

STRONG INSERVICE INSPECTION PROGRAM

.

IMPROVEMENTS NEEDED IN DEFICIENCY TAGGING AND INITIATION

OF MWR'S

!

MAINTENANCE WORK ORDERS LACK DESCRIPTIVE DETAIL

ADDITIONAL ATTENTION NEEDED IN MAINTAINING SOME SYSTEMS

1

--

.- -

_ -_-. - _

'

.

"

-

, , , .

4 . .'

~

l

'

.

1

I

EMERGENCY PREPAREDNES$ - CATEGORY 1

r

l

)

l

PERFORMANCE DURING EXERCISES WAS A STRENGTH

'

.

MANAGEMENT

DEMONSTRATED EFFECTIVE USE OF EMERGENCY

j

ORGANIZATION DURING EXERCISE

.

DEMONSTRATED CAPABILITY TO IMPLEMENT CRITICAL ASPECTS OF

EMERGENCY PREPAREDNE$$

.

DETAILEO AND EFFECTIVE POST EXERCISE CRITIQUES

,

l

i

PROMPT AND EFFECTIVE RESPONSE TO SPURIOUS ACTIVATION OF ANS

!

NRC

CONCERNS

REGARDING

EXERCISE

SCENARIOS

AND

ACCOUNTABILITY DRILL

b

,

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1.

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._._...,,.,_,_,y.

_ , . _ . , , -

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,

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'.4

,

SECURITY - CATEGORY 1

.

1

(

CONTINUED STRONG MANAGENENT SUPPORT OF SECURITY PROGRAM AT

'

BOTH $1TE AND CORPORATE LEVELS

t

!

REQUIREMENTS CONTINUED TO BE IMPLEMENTED IN' AN EFFECTIVE

l

t

!

MANNER

.

,

PROGRAM IS AGGRESSIVELY SUPERVISED AND MANAGED

r

FLEXI8tLITY

DEMONSTRATED REGARDING CHAMES AND NEW

i

REQUIREMENTS

,

l.

SEVERAL PHYSICAL SECURITY HARDWARE UPGRADES NOTED

.

e

TRAINING AND REQUALIFICATION CONTINUES TO BE A STRENGTH

'

i

l

,

.

CLOSE LIAISON WITH 0FFSITE RESPONSE AUTHORITIES CONTINUES

'

,

CONTINUE TO ACCURATELY LOG AND REPORT PHYSICAL / SECURITY

.

EVENTS IN A TIMELY MANNER

-

NEED TO RESOLVE FAILURE OF OUTAGE PERSONNEL TO ADHERE TO

ACCESS CONTROL PROCEDURES

.

. .

- .

.

. - .

.-

-

_.

-

._.

-

-.

.. .

-

,

- .

,yc,

.

'

.

-

ENGINEERING / TECHNICAL SUPPORT - CATEGORY 2

OVERALL ENGINEERING AND TECHNICAL SUPPORT WAS G000

INITIATED MAJOR EFFORTS TO ENHANCE QUALITY OF ENGINEERING

f

!

FORMED SYSTEMS ENGINEERING AND CONFIGURATION MANAGEMENT

'

{

GROUPS

!

CONTINUED DESIGN BASE CONSOLIDATION ACTIVITY

,

' INITIATED ENGINEERING EVALUATION REQUEST AND MINOR CHANGE

PROGRAMS

F.NGINEERING RESPONSE TIMELY AND COMPREHENSIVE TO EMERGENT

,

PROBLEMS

-

.

SAFETY EVALUATION GENERALLY THOROUGH AND TECHNICALLY ADEQUATE

!

RESPONSIVE TO NRC CONCERNS

,

OPERATOR TRAINING PROGRN4 EFFECTIVE

-.

_ . .

_ . - - - _

.

- -

. . -

. .

.

. .

.

-

)

'

,

. . ,

..

!AFETY ASSESSMENT / QUALITY VERIFICATION - CATEGORY 2

i

-

OVERALL SAFE *Y ASSESSMENT / QUALITY VERIFICATION ACTIVITIES

-

i

MADE POSITIVI: CONTRIBUTION'TO PLANT SAFETY

l

3

o

SAFETY SYSTEM FUNCTIONAL ASSESSMENT FOUND TO BE INDEPTH

AND DETA! LED

l

QUALITY

PROGRAMS

PERFORMANCE BASED

INSPECTIONS ARE

i

1

IDENTIFYING AND CORRECTING PROBLEMS

,

PLANT AND OFFSITE SAFETY REVIEW Com!TTEES WERE GENERALLY

i

EFFECTIVE

LERS SUBMITTED WERE APPROPRIATE

'

DEMONSTRATED ABILITY TO TAKE PROMPT CORRECTIVE ACTION ON

,

SIGNIFICANT ISSUES

i

WEAKNESSES IDENTIFIED IN 10CFR 50.59 SCREENING PROCESS AND

.

TS POSITION STATEMENTS

IMPROVEMENTS NOTED IN ROOT CAUSE IDENTIFICATION, CONTINUED

.

ATTENTION WARRANTED

'

LICENSING SUBMITTALS GENERALLY 0000 ALTHOUGH SOME PROBLEMS

NOTED

. . . . .

.

. -

.

- . - - - .

.

-

_

.

- _ - .

..

. - ~ . .

..

-_

.. -

.

.e

_

f

.

..

(

i

'

'

!

i

$UMMARY OF RESULTS

-

OVERALL PERFORMANCE WAS VERY G000

l

'

!

t

'

OPERATIONS PERFORMANCE AND PHYSICAL CONDITION OF PLANT

!

CONTINUED TO BE A $TRENGTH

,

i

FIRE PROTECTION PROGRAM MANAGED EFFECTIVELY

I

'

TREND REGARDING PERSONNEL

ERROR $ SHOWS IMPROVEMENT,

CONTINUED ATTENTION NEEDED

,

HEALTH PHYSICS PERFORMANCE WAS G000

L

ADDITIONAL MANAGEMENT ATTENTION WARRANTED IN AREA 0F

,

!

PERSONNEL CONTAMINATION EVENTS

.

l-

-

MAINTENANCE ORGANIZATION EFFECTIVELY SUPPORTED PLANT

-

1

!

OPERATIONS

,

'

.

FURTHER MANAGEMENT ATTENTION !$ NEEDED ON CERTAIN SYSTEMS

l

IMPORTANT TO SAFETY

l

IMPLEMENTATION OF EMERGENCY PREPAREDNESS FUNCTIONAL AREA

WAS GOOD

'

.t.

,

t.

, - .

,

a .

.

.* <

l 0

,

SUPMARY OF RESULTS (CON'T) .

WEAKNESS NOTED REGARDING SCENARIO, NEED TO CONDUCT FULL

ACCOUNTABILITY DRILL IDENTIFIED

ENGINEERING AND TECHNICAL SUPPORT CONTINUE TO BE 0000

'-

-

MANAGEMENT CONTINUED MAJOR EFFORTS TO IMPROVE QUALITY OF

ENGINEERING SUPPORT

SAFETY ASSES $NENT AND QUALITY VERIFICATION PERFORMANCE HAS

BEEN ADEQUATE

WEAKNESS NOTED IN PERFORMANCE OF SAFETY EVALUATIONS AND

ROOT CAUSE ANALYSIS; IMPROVEMENTS NOTED BUT RECOPMEND

FURTHER MANAGEMENT ATTENTION

.

I

-- . . _

_ . . . _ . .

. . _ _ .

.

.. _ _ . . _ ,

_ _ , . _ _ _ . _ _ _ _ _ _ _ _ _ _

_ ___ _ _ _ _ __ j

_

ENCLOSURE 3

p, gjg

dC 5 E

13:53

CORRECTED CDPy to Atat 49/0231: To Chante MCN Number only

3

. ..

-

Jamary 4,1990

i

'

U.S. Naclear Regulatory Comission

Mail Station F1-137

,

Washington, D.C.

20555

Attention: Document Control Desk

{

!

Gentlement

!

SUMECT

Grand Gulf Nuclear Station

Unit 1

'

Docket No. 50-416

License No. NpF-29

Response To SALP Report

i

AECM 90/0004

,

Your letter dated November 22, 1999, transmitted the Systematic

Assessment of Licensee Perforinance (SALP) report for the Grand Gulf

Nuclear station (0GNs) facility for the period May 1, 1988 through

September 30, 1989. On November 30, 1989, members of our staff and the

i

OGNS Safety Review Constittee met with you and members of your staff to

'

l

review the results of the report.

System Energy Resources, Inc. (SERI)

is responding to that report via this letter.

,

SERI endorses the SALP concept and believes that objective

evaluations of licensee performance benefit the licensee, the NRC and

the public by identifying and focusing attention and resources on

!

matters inportant to safety of plant operation. SERI is consnitted to

operating OGNS safely and at a standard well above the minimum

regulatory repairements. Accordingly, we intend to be responsive te the

conclusions and recomendations discussed in your report.

On December 26, 1989, SERI contacted Mr. Floyd Cantrell of NRC

.

Region II to discuss submittal of the SALP response. SERI requested an

oxtension to January 5, 1990 due to holidays and general availability of

management staff. Mr. Cantrell agrood that this extension would be

,

acceptable.

e0V ^ y

r-t

WTClows

Attachment

RESPSALP/5CMPS12x1At l .A:X5A Y5555 ** 30225.M4 l C 4!4 CCC

: &-7

Avone k ~.'"esCu* m

. f'";T.7 *

'

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1

p,9

_-

_ _ . _ _

. _ _

_ __

__

___ - . . _ _ _ . . - _ _ _ _ _ . _ _ . _ .

. _ _ _ _ . . _ _ .

,

. JAN ,5 '90.

13:H

Agen,ad/,,.3;j !

.-

rete 2

.

o

e

!

a

..

,

to: Mr. D. C. Nints (w/a)

l

Mr. f. M. Cloninger (w/a)

.

Mr. R. S. NeGehoe (w/a)

!

Mr. M. 8. Reynolds (w/a)

'

Mr. N. L. Thomas (w/o)

.

Mr. N. O. Christensen (w/a)

.

l

Kr. Stewart D. Ebneter (w/a)

Regional A4ministrator

i

~U.S. Mclear Regulatory conmission

-

Region II

!

101 Marietta St. , N.W. , Suite 2000

!

Atlanta, Georgia 30323

,

Mr. L. L. Kintner, Project Manager (w/a)

Offies of Nuclear Reactor Regulation

'

U.S. Nuclear Regulatory Connission

Mail stop 14320

Washington, D.C.

20555

t

.

.,

i

,

i

!

,

!

,

i

l

RESPtALP/SCNPFLR - 2

1

. - _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ , _

. . _ - . . . . _ _ . . - . . _ . . . _ . _ _ _ . _ . . _ , . _ . - , _ , , , _ . _ . _ - - _ _ _ . . . - . - _ . . . _ _ _ _ - . _ - - - . , ,

fgy.p

y.

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,

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'

SERI C02SNTS ON SALP REPORT

l

I '.

M

The SALP report acknowledged in9rovenants and strengths in the

'

areas of Plant operations, Radiological controle,

Maintenance / Surveillance, Emergency Preparedness and security.

SERI is very pleased with the category I rating received in these

j

areas but recognises the need to continue management attention in

'

.these areas and other areas of concern.

.

1

)

SERI has implemented, or is in the process of isplementing

initiatives to improve overall plant performance.

These

,.

l~ -

initiatives are discussed further under the appropriate functional

l

SERI will evaluate the' effectiveness of these initiatives

l

areas.

to ensure that results supseted are achieved.

,

!!. Plant QHrations

SERI will continue to strive for a reduction in the number of

]

events caused by personnel errors, i.e., inattention to details,

,

l-

failure to follow procedures. SERI considers this to be an area

that is not at an acceptable level and is continuing and/or

inplementing the following initiatives aimed towards improving

overall personnel perfomance,

SERI has developed a program for evaluating Incident

s.

Reports and other significant human error related events.

'

This program requires in depth reviews and high

management involvement in the process. This program has

been evolutionary in nature.

It has been very effective

>

in addressing the root sausa and ensuring adequate

.

'

corrective actions are taken for human error related

events.

,

b.

A series of briefings will be conducted by Grand Gulf

management to ensure all personnel are aware of the

,

Incident Review Board process, Human Performance

Evaluation System (Hpts) and Management philosophy.

SERI will publish results of significant incidents and

c.

!

hman performance evaluations (HPES) to enphasise

management's interest in reducing personnel related

events.

.

Other initiatives will continue to be evaluated and laplemented as

appropriate, one such initiative currently in trial use is the

Eero Deviation Recognition Program.

.

AsspsALP/SCNPFLR - 4

_ . . . _ , _ . . . _ - _ _ _ . _ _ . . . _ . . _ _ _ _ _ _ _ _ _ _ - _ _ _ _

_

._.

_.

._ .

m .'$

5 't3

13:55

Aten s? 5./.11

)

i

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y,

3' +3

Page 5

,

1;

..

'

III. Radialaminal controle

]

A.

The SALP report comented, "A weakness was noted in

!

controlling contract worker adherence to posting

i

requirements." SERI recognises that ingroved control of

contracted work activities is vital in achieving overall plant

.

radiological goals. To further inprove personnel adherence to

,

these. requirements, SERI will develop and implement an advance

radiation worker training oourse aimed towards inyroving

i

casuunications between Health Physics personnel and contracted

workers.

'

}

This training will consist of shinistrative controle

governing Radiation Work permits, minimisation of personnel

contamination events and adherence to radiological posting

l

requirements. This course will be shinistered to SSRI

,

%

supervisors, contracted craft supervisors and foremen. It

L

will enable craft personnel to better assess work activities

j

as they relate to radiological requirements; thereby, reducing

!

'

the number of contractor personnel errors.

Initial training

'

will be coupleted prior to Refueling Outage Number 4 (RF04).

,

S.

As stated in the SALp report, "An increase was noted in

personnel contamination events (Pcts) when canyared with

events from the previous assessment period." SERI will

continue the following management initiativos in an effort to

reduce the number of personnel contamination events at the

?

Grand Oulf facility:

1.

The painting program which seals porous surfaces making

I

decontamination easier and helping to eliminate the

,

buildup of low-level contamination will be continued.

2.

SERI will continue to assign personnel as refueling floor

t

coordinators to minimise errors made during refueling

,

activities which have resulted in a large percentage of

,

personnel contamination. By having an overall

i

coordinator, more effective contamination control of the

refueling floor area can be accomplished.

]

3.

Efforts to maintain the total amount of contaminated area

as low as reasonably possible will be continued.

'

SERI will also inplement an advanced radiation worker training

course to include guidance on minimisation of personnel

contamination. This training will be given to SSRI

supervisors, contracted craft supervisors an( foremen as

appropriate.

Initial training will be conyleted prior to

,

RF04.

.

RESP 8 ALP /ScNPFLR - 5

.

--

- -

-

--

_

- . - . -

_ . . . _

._

. ._

_ . . _ _ _ _ _ _ _ . _ _ _ _ _ -

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ggg.,g

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.

N , [ $ 'I3:56:

Page 6*'

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f

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"

'

' ' '

- IV . Maintenanca/Surve111anae

The 8&LP report consented, "The NRC staff concluded (during

the Maintenance Inspection conducted in October and November

A.-

1998) that the system for deficiency tagging and initiation of

a

'

Maintenance Work Orders (NW0s) was not working effectively and

o

stRI.has self identified the need for

,

'

needed improvement."

'

improvements in these areas and has taken steps to strengthen

existing controls.

Deficioney taan

The following steps have been taken to enhance the deficiency

identification program:

The Maintenance Work order Deficiency Tagging System

1.

procedure was revised to incorporate the fellowing:

A requirement to include the deficiency tag number

and the location of the tog on the work order,

j

a.

l-

Additionally, work supervisors are required to

sign-off on completed work orders indicating removal

j

of deficiency tage initiated.

b

Assigned responsibility to the maintenance

i

b.

planners for transferring deficiency tag information

l

for consolidated or cancelled work orders.

i

l

The shift superintendent or designee is prohibited

!

from returning to servios work orders that reference

c.

deficiency tags, unless the tags are removed and

!

placed with the work package.

A 100% walk-down of deficiency tags was performed by

,

2.

plant personnel following start-up from Refueling Outage

Deficiencies noted during this walk-down were

Number 3.

evaluated and subsequently corrected. This program is

i

being closely monitored through continuous

self-assessments and programatic audits.

A more durable deficioney tag is currently being used in

\\

3.

lieu of the carbon copy type.

,

'

Isplewntation of the Station Infomation Management

4.

system (SIMS) provides a mandatory requirement that any

deficiency tog written must be entered into SIMS for

It also requires the work

tracking purposes.

l .

supervisor's signature on completed work orders

j

indicating tags have been appropriately removed.

RESPSALP/SQLPFLR - 6

'

_

,

I:

agen.s?. 7/l1

~

jANj{1

10 %

page ,

..

.

-

,,

Ha4ntenanceWorkordars

The snLp indicated " weaknesses concerning the lack of details

l

i

in the narrative description of work orders, description of

problems and corrective actions en work ordere were very

i

cryptic and the activity log was not being used consistently."

i

stRI has taken the following steps to improve the Maintenance

l

work Order Progreat

!

1.

sut has sospleted implementation of SINS which will

!

allow SERI Management the opportunity to closely monitor

l

planned work activities. This system will provide

!

4dditional space for documenting detailed description of

l

problems and the corrective actions taken.

I

2.

An Engineering Review Group has been fomed within the

'

' Performance and System Engineering Department to perform

a final, independent review of work orders prior to

closeout. This group is tasked with ensuring work orders

reflect adequate details of the identified problem,

i

including the overall work scope, root cause, corrective

actions taken and conponent failures. This will allow

(

for better planning, coordination and ouscution of future

work activities.

3.

Activity logs will be !aciudod in work orders to document

.

work activities performed by plant personnel. This

action will provide consistency within the work order

isplementation process.

3.

The SALp Report also stated that no formal, proceduralised

program on Predictive maintenance existed at cons. Su!

recognises the need and benefit of a formalised system that

will consolidate the programs currently being used to detect

potential degrading equipeent problems prior to failure. ssRI

has begun plans to iglement such a program. This program

-

will be coupleted by the end of the first quarter 1990.

SERI is aggressively pursuing the issue to " properly maintain

c.

systems important to safety" through the use of a task Force

created to ensure those systems important to safety, but not

addressed by Technical specifications are receiving

appropriate management attention. This group will assess the

need to enhance the level of attention being applied to other

.

>

systems, such as, the Post Accident Sampling System and

Instrument Air. SERI will make the necessary changes to plant

procedures and programs, as appropriate, after congletion of

this review.

!

RESPSALP/SCMpFLR = 7

. .

_

- _ _ _

.__

,.

. _ _ ._ .._ _. _ __ . _ _ . _ . _ . _ _ _ _ _ _ _ .__ _ _ _ . _ . _ .. _ _ _ _

.

..

1 N' 5 $

1D 57

P. B/11

'~

. .6

ucN st/0231

-

=

p:ge 4

l

, ,

V.

Easreaner presaredness

A.

The anLp report identified a weakness noted during the

September 1989 full scale euereise. This weakness is based on

the similarities of the scenarie used during the practies

,

i'

drill and the annual esercise senducted three weeks later.

i

In response to.this eencern, stRI plans to implement a-

computerised scenarie tracking system for initiating events

'

used in previous drills and esercises.

This eyeten will be

i

used to compare recently developed initiating events with

previously performed events and will inevitably preclude

!

future scenario similarities. Emergency preparedness

Administrative procedure No. 203 will be o%nged to implement

l

and maintain this system.

2splementation will be cospisted

i

during the first quarter 1990.

!

The thLp report indicated that a " full accountability drill

l

3.

for onsite personnel should be conducted during the nemt

annual energency exercise." Relative to this concern, StRI

,

'

will submit as an euereise objective for the 1990 annual NRC

exercise, performance of a full accountability drill for

i

onsite personnel within the protected area. The 1990 annual

i

exercise is currently scheduled for the week of August 27,

1990.

!

'

V!. M

,

No columents.

'

VII. 'a=la-ha/Taa%iami numt

'

n.

An NRC identified weakness which was not resolved prior to the

end of this assessment period was "the lack of fossal training

for system engineers in root cause analysis to ensure

consistent performance in oesponent trending and deficiency

reporting."

SERI shares the NRC's concerne over this issue

-

and is taking steps to remedy this problem. The following are

specific initiatives currently in progress to assist in this

ondeavor:

1.

The Material Nonconformance Report (NNCR) procedure has'

been revised to require a root cause determination review

(

be performed in the NNCR process for significant

deficiencies.

2.

A Root cause Analysis training course will be developed

.

and incorporated into the Technical staff and Managers

Training program by June 30, 1990. Appropriate technical

statf personnel, including system engineers, will be

required to attend.

>

usPsALP/SCMPFLR

8

.

.. -

--

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- - . - -

-

- _ _ _ . _ _ _ _ _ _ _

lJ$ $ h

13:63

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Page 9

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3.

Implementation of SIMS will provide information that is

i

essential for trending component degradation and

l

performing root cause determinations. This system

i

L

includes engineering information from the Nuclear Plant

l

1-

Reliability Data System (NpkDS) relative to cesponent

fallures. Su ! has initiated an NPRD8 familiarisation

-

training session for system engineers.

Initial training

.

will be cospleted by December 31, igg 0.

!

l'#

B.

Confipration Management

I

The SALP report noted several activities eenpleted to improve

the confipration Management Program. SMI recognises the

!

,

e

L

need for sentinued inprovement to achieve our overall

objective in this area and is inylementing the following

initiatives:

o

A substantial upgrade of the suisting computer Aided

l

Drafting system

l

o

Verification of Instrument des!gn basis

Revision of Technical Specification setpoint calculations

e

o

Revision of key safety related electrical AC calculations

4

o

on going development of system design eriteria

'

VIt!.

t-

,

A.

License Amendments

The SALP report raised several concerns regarding SERI

'

submittals related to proposed changes to technical

specifications in the area of thoroughness and timeliness of

requests and responses. To address these concerne, SERI is

developing a " cycle lisensing plan" to include major licensing

act{vities. The plan will be maintained as a living-document

for discussion with the NRC. The plan will allow SERI tot

o

Apply sensitivity to proper assessment of priority

o

Rasure safety issues are appropriately addressed

+

o

Support internal planning and discussions with the NRC on

work forecast and resource utilisation

o

Receive internal management review, including the Vice

President, Nuclear Operations approval

RESPSALP/SCNPFLR = 9

-. .

- . - - - - . . - - -

. . -

-

. . -

. .

.

__

_ . _ . . . . _ - -

..__w

_._ _ _ _ _ _

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E N 5 ' E

13:59-

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To strengthen the overall license amendment process, stat will

include a senior Roseter operator (820) in the review and

approval cycle, as appropriate, for proposed changes to the

operating license. Plans are also being made to include

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Nuclear Licensing personnel in future licensed operator

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training programs.-

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8.

10CpA50.59 Safety tvaluations

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The 84Lp report indicated, ".. 10CFR50.59 evaluations and

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events continue to be weak." 8tRI has recognised the need to

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.

improve the 10CFR$0.59 process. A number of enhancements were

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made during the SALP period to address internal SERI

.

management and NRC concerns: Procedures and policies have

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been revised; corporate-wide training has been Laplemented;

and the Safety Review Committee and Plant Safety Review

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Comnittee have been given responsibility for the 10CFR50.99

screening process including review and approval of procedures.

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In addition to these enheacements, Quality Programa (97) has

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scheduled an audit of the screening process and its

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effectiveness. The audit report is tentatively scheduled to

be issued by March 31, 1990.

SERI will evaluate the results

of this audit for any further 10CFR50.59 ohanges..

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Two procedural weaknesses are being studied for the inclusion

of appropriate improvements into the 10CFR50.59 process.

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One issue involves the absense of a question specifically

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addressing " nuclear safety" in the screening process, in

addition to the standard applicability criteria. As

'

diemussed with the NRC staff, stRI recognises the need to

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apply appropriate criteria in the screening process to

.

ensure its effectiveness, i.e., the proper level of

'

safety evaluation of a proposed change. SERI recognises

.

the importance of this question and intends to give it

proper attention. Steps to assess this matter include

surveys of other utility programs for their use of this

,

criteria, the upcoming SERI screening effectiveness

,

audit, additional review and study of the NUMARC

'

guidelines, and consultation with NUMAnc staff on the

subject. SERI plans to arrive at a decision on this

issue and inylement any needed policy changes by

September 30, 1990.

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the sooend issue involves palifications of screeners and

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stR1 recognises that personnel p alifications

reviewers,

are as important in an effective safety evaluation

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program as the criteria used in the screening and

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evaluation process.

Isprovements, principally in the

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form of more definition and procedural eensistency

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between departments, as wo11 as a demanding training

progres, have been put in place to establish proper

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walifications. However, 88R1 is sentinuing to assess

this area for inprovements. Qualification rep irements

are now being reviewed. Any changes to those

p alification rep irements will be made by September 30,

1990.

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SERI is further revising its 10CrR80.59 training eeures to

include r84R and Technical Specification training. This

revised training course will be developed by May 15, 1990.

Retraining will begin June 1, 1990 and be eenpleted by July

31,' 1991.

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