ML20035D933
| ML20035D933 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 01/30/1993 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20035D934 | List: |
| References | |
| 50-285-93-99, NUDOCS 9304140129 | |
| Download: ML20035D933 (22) | |
See also: IR 05000285/1993099
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INITIAL SALP REPORT
U. S. NUCLEAR REGULATORY COMMISSION
REGION IV
SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-285/93-99
Omaha Public Power District
Fort Calhoun Station
August 1,1991, through January 30,1993
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TABLE OF CONTENTS
Page
I.
INTRODUCTION . . . . . . . . . . . . . . . . . . . . . .
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II.
SUMMARY OF RESULTS . . . . . . . . . . . . . . . . . . .
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III. CRITERIA . . . . . . . . . . . . . . . . . . . . . . . .
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IV.
PERFORMANCE ANALYSIS . . . . . . . . . . . . . , . . . .
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A.
Plant Operations . . . . . . . . . . . . . . . . .
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B.
Radiological Controls
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C.
Maintenance / Surveillance . . . . . . . . .
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D.
Emergency Preparedness . . . . . . . . . .
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E.
Security . . . . . . . . . . . . . . . .
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F.
Engineering / Technical Support
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G.
Safety Assessment / Quality Verification . . . . . .
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V.
SUPPORTING DATA AND SUMMARIES
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A.
Major Licensee Activities
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B.
Direct Inspection and Review Activities
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INTRODUCTION
The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
periodic basis and to evaluate licensee performance based upon 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 licensee management regarding
the NRC's assessment of their facility's performance in each functional area.
An NRC SALP Board, composed of the staff members listed below, met on
February 26, 1993, to review the observations and data on performaace and to
assess licensee performance in accordance with NRC Manual Chapter 0516,
" Systematic Assessment of Licensee Performance."
This report is the NRC's assessment of the licensee's safety performance at
the Fort Calhoun Station for the period August 1, 1991, through January 30,
1993.
The SALP Board for Fort Calhoun was composed of:
Chairman
L. J. Callan, Director, Division of Radiation Safety and Safeguards (DRSS),
Region IV
Members
M. Virgilio, Assistant Director for Region IV & V Reactors, NRR
T. Gwynn, Deputy Director, Division of Reactor Projects (DRP), Region IV
A. Howell, Deputy Director, Division of Reactor Safety (DRS), Region IV
P. Harrell, Chief, Technical Support Staff, DRP, Region IV
R. Mullikin, Senior Resident Inspector, Fort Calhoun Station, DRP
S. Bloom, Project Manager, Fort Calhoun Station, NRR
The following personnel also participated in or observed the SALP Board
meeting:
C. Skinner, Intern, Technical Support Staff, DRP, Region IV
G. Hubbard, Acting Director, Project Directorate IV-1, NRR
L. Constable, Chief, Plant Support Section, DRS, Region IV
R. Vickery, Reactor Inspector, DRS, Region IV
D. Powers, Chief, Maintenance / Surveillance Section, DRS, Region IV
I. Barnes, Technical Assistant, DRS, Region IV
P. Baranowsky, Region IV Coordinator, Office of the Executive Director
of Operations
J. Pellet, Chief, Operations Section, DRS, Region IV
R. Azua, Resident Inspector, Fort Calhoun Station
B. Murray, Chief, Facilities Inspection Program Section, DRSS, Region IV
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SUMMARY OF RESULTS
Overview
Overall, licensee performance was good.
It was apparent that management's
priority was the safe operation of the facility. This was apparent both in
the conservative operability determinations made and the heightened awareness
of shutdown risks.
Performance in the Plant Operations functional area was
very good.
Significant improvements were noted in the quality of emergency
and abnormal operating procedures as well as the guidance provided to
operations personnel.
In addition, the number of licensed operators was
increased to an appropriate level. During an actual event that challenged the
operations staff and emergency response organization, the response was
excellent. However, the plant perturbations caused by personnel errors and
the loss of shutdown cooling indicated a need for increased management
attention in these areas.
Performance in the Radiological Controls area declined. Weaknesses in the
radiological protection program were identified due to two uptake events.
Overall, the radiation protection department had a good performance level.
Excellent performances were noted in the ALARA program, radioactive waste
effluents management, radiological environmental monitoring, transportation of
radioactive materials and wastes, training, and audits and surveillances.
Performance in the Maintenance / Surveillance area was good. However, oversight
of surveillance activities during refueling outages and nonsafety-related
maintenance activities that could impact safety-related systems may need
increased management attention.
Performance in the Emergency Preparedness area increased to an excellent level
as indicated by the response to an actual ALERT and during exercises, drills,
and walkthroughs with operating crews.
Performance in the Security functional
area was maintained at an excellent level.
Performance in the Engineering / Technical Support area was superior.
Examples
of the licensee's superior performance were the resolution of engineering
issues and the identification of design issues and the communication of these
issues to the NRC staff.
In addition, the systems engineering program was
notable.
Performance in the Safety Assessment / Quality Verification area was maintained
at a superior level.
Licensee management provided notable oversight of the
safe operation of the facility, except for the incident involving unauthorized
sampling of a liquid waste system.
Rating Last Period
Rating This Period
Functional Area
(05/01/90 to 07/31/91)
(08/01/91 to 01/30/93)
Plant Operations
21*
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Radiological Controls
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Maintenance / Surveillance
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Rating Last Period
Rating This Period
.Functional Area
(05/01/90 to 07/31/91)
(08/01/91 to 01/30/93)
Security
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Engineering / Technical
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Support
Safety Assessment /
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Quality Verification
- I Improving Trend - Licensee performance was determined to be improving
during this assessment period.
Continuation of the trend may result in a
change in the performance rating.
III. CRITERIA
The evaluation criteria, category definitions, and SALP process methodology
that were used, as applicable, to assess each functional area are described in
detail in NRC Manual Chapter 0516, dated September 28, 1990.
This chapter is
available in the Public Document Room files. Therefore, these criteria are
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not repeated here, but will be presented in detail at the public meeting to be
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held with licensee management.
IV.
PERFORMANCE ANALYSIS
A.
Plant Operations
1.
Analysis
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This functional area consists primarily of the control and execution of
activities directly related to operating the plant.
Evaluation of this functional area was based on routine inspections performed
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by the resident inspectors and six inspections performed by region-based
personnel.
In addition, the results from an Augmented Inspection Team were
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included in this assessment.
The previous SALP report (NRC Inspection Report 50-285/91-99) recommended that
management continue with the efforts that were already in progress for
increasing the number of licensed, on-shift operators and upgrading the
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emergency operating procedures.
In addition, it was recommended that
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operations management become more proactive in providing guidance and
direction to operations personnel.
During this assessment period, the licensee increased the number of licensed,
on-shift operators to an appropriate staffing level. Operations management
was proactive in its approach to providing guidance and direction to
operations personnel and, as a result, a previous concern with onshift
communications was appropriately addressed. The inspectors noted that the
licensee provided shift briefings before nonroutine activities and used the
simulator to provide operators with the expected plant response to potential
plant transients.
For example, a condition occurred in the plant that
resulted in the potential for the loss of a dc bus. The licensee used the
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order to prepare operations personnel in the event that the plant transient
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occurred.
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It was noted, during the conduct of routine, day-to-day plant operations, that
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the operations staff maintained an excellent awareness of plant status and
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limiting conditions for operation in effect.
Excellent coordination and
communication between operations personnel and other groups was observed.
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Plant housekeeping was generally maintained at an excellent level, with some
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exceptions. Management personnel routinely toured all plant operating spaces.
The response by the on-shift operations staff to the July 3-4, 1992, stuck
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open pressurizer code safety valve, loss-of-coolant event demonstrated an
outstanding level of performance by the licensed operators for off-normal
events. The excellent response by the licensed operators ensured that this
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event did not result in a threat to the public.
Another on-shift licensee
crew was challenged by a similar, but less severe event on August 22, 1992,
and also responded very well.
Although overall operations personnel performance was excellent, there were
plant perturbations caused by personnel error.
An operator trainee caused the
generation of a containment isolation actuation signal during a surveillance
test when an override switch was not fully engaged. An operator trainee also
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caused an automatic start of Diesel Generator 2 after failing to synchronize
Emergency Diesel 1 to the bus during surveillance testing.
During the
refueling outage, an operator failed to put a reactor trip channel for low
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flow in bypass before shutting down a reactor coolant pump and, as a
consequence, a reactor trip signal was initiated. An operator inadvertently
started Emergency Diesel Generator 2 during the performance of a . surveillance
test by pushing the local start button instead of the alarm acknowledge button
at the local panel. Overpressurization of the steam generator blowdown system
occurred because of an oversight by licensed operators during the development
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of a equipment tagout. These events indicated a lack of attention to details
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by the operations staff.
The events initiated by operator trainees occurred
relatively early in this assessment period and the licensee has taken
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appropriate actions to address this issue.
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The Fort Calhoun Station experienced three automatic reactor trips during this
assessment period. One trip was due to personnel error when a level sensor
for a main steam reheater was incorrectly returned to service. This was the
first automatic trip since July 1986. The other two trips were due to
equipment malfunctions. The first resulted from the malfunction of a
nonsafety-related inverter and the second resulted from the f ailure of the
power supply for the electrohydraulic control system for the main turbine.
Operator training effectiveness and the relationship between the operations
and training organizations continued to improve during this assessment period.
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Operations management involvement in the operator licensing examination
process was evident.
This cooperative relationship resulted in a beneficial
teamwork approach to resolving training issues. The 100 percent pass rate on
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- two sets of initial license examinations and on the requalification
examination demonstrated the licensee's commitment to improving licensed
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operator training.
The licensee made significant improvements in the content of the emergency and
abnormal operating procedures.
The procedures were well organized, logical,
and provided effective transitions to other procedures and attachments. The
Augmented Inspection Team credited the upgrade of the emergency operating
procedures as a contributing factor to the successful response to the
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July 3-4, 1992, stuck open pressurizer code safety valve, loss-of-coolant
event. The operators' knowledge and skills and the labeling of plant
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equipment were considered strengths. Good measures for configuration control,
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maintenance of the procedures, and training on the procedures were noted.
The operations staff's performance during the refueling outage was good. The
licensee implemented measures to reduce shutdown risk, which included the
installation of a temporary diesel generator, the policy to always have three
electrical sources available at all times, and to restrict midloop operations
to less than 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Despite these measures, a 7-minute loss of shutdown
cooling occurred because of the shutdown of the cooling pump. The electrical
system was in an abnormal lineup during the performance of a surveillance test
and an overloaded breaker caused the bus that powered the shutdown cooling
flow control valve controller and flow indication to be lost. Operators
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secured the running low pressure safety injection pump to prevent a possible
runout condition due to the flow control valve failing open.
The cause of the
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electrical system being in an abnormal lineup during surveillance testing was
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a lack of oversight by the licensee.
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At the beginning of the refueling outage, the licensee failed to implement
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adequate controls designed to preclude foreign materials from entering the
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refueling and spent fuel pool exclusion areas. After this concern was
identified by the NRC, it was immediately resolved by the licensee in a
satisfactory manner.
Fuel movement was performed efficiently and without an
incident. However, a weakness was noted in the use of visual and audio aids
to assist the refueling crew inside containment.
It was also noted that the
refueling crew did not always check the path of the refueling machine trolley
and bridge and formal guidance was needed concerning the control of suspended
irradiated fuel assemblies.
Licensee management generally made conservative equipment and component
operability decisions. When it became apparent in September 1991 that a
potential common-mode failure existed with the emergency station batteries
because of case cracking, the licensee shut down the plant and replaced the
batteries.
However, the licensee had prior indication in July 1991 that a
battery common-mode failure potential was present and failed to take actions
to address battery operability.
To reduce shutdown risk during the
replacement of the batteries, the licensee used the initial group of removed
batteries as a backup while new batteries were being installed.
The backup
batteries could have been manually connected to a dc bus if needed. An
example of conservative decisionmaking occurred when the licensee suspended
plant heatup from the refueling outage after cracked cam followers were
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The critical switches were replaced
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before heatup continued.
In summary, overall performance in the area of plant operations was good.
The
licensee appropriately addressed all of the weaknesses that were identified in
the previous SALP report. The operating staff's performance was excellent,
both in day-to-day operations and response to events. The personnel errors
that resulted in plant perturbations demonstrated a lack of attention to
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details. Management involvement in plant operations was also excellent.
Management generally made conservative decisions in regard to safe plant
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operation, with the exception of battery operability. Operator training
effectiveness was apparent by the 100 percent pass rate on both initial and
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requalification examinations. The emergency and abnormal operating procedures
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showed significant improvement. The performance of the operations staff
during the refueling outage was good. However, a lack of oversight by the
licensee resulted in a loss of shutdown cooling.
2.
Performance Rating
The licensee is considered to be in Performance Category 2 in this functional
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area.
3.
Recommendations
a.
NRC Actions
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Review the licensee's outage management controls program during the next
scheduled refueling outage.
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b.
Licensee Actions
Improve controls over outage management and address the occasional lack of
attention by operations personnel.
B.
Radiological Controls
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Analysis
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This functional area consists primarily of activities related to radiation
protection, radioactive waste management, radiological effluent control and
monitoring, radiological environmental monitoring, and transportation of
radioactive materials.
This area was inspected four times by region-based radiation specialist
inspectors and on a continuing basis by the resident inspectors.
Excellent
performance was noted in this functional area during the previous assessment
period and no specific concerns or recommendations were identified.
During this assessment period, several violations were identified relating to
two uptake incidents that occurred during February and April 1992. The
violations involved improper implementation of the radiation protection
program, which included the failure to follow radiation protection procedures,
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. poor communications among radiation protection department personnel, and the
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lack of supervisory oversight. The violations were related to the specific
events and did not indicate a significant breakdown in the overall radiation
protection program.
The licensee's investigation and assessment of the uptake incidents were
excellent. The root cause analysis of each uptake incident was very good.
The investigation identified some minor weaknesses in the radiation protection
program that contributed to the violations. The corrective actions for the
uptake incidents and other events involving radiation protection were prompt,
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comprehensive, and conservative. The licensee's performance was excellent
regarding the difficult evaluation of transuranic radioactive radionuclides
involved in one of the uptake incidents.
Management provided excellent support for the radiation protection program.
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In general, radiation protection supervisory oversight of the day-to-day
activities was very good.
Radiological protection personnel were found to be
knowledgeable of their responsibilities and performed their duties in a
professional manner. Their efforts in support of plant activities during the
1992 refueling outage, following the loss-of-coolant event on July 3-4, 1992,
and activities related to the testing and removal of the pressurizer code
safety valves were excellent. A very good radiological occurrence report
program was implemented.
An excellent planning and preparation program was established for the 1992
refueling outage. An excellent inventory of radiation protection supplies and
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equipment was maintained for refueling outage activities.
Excellent
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coordination existed between the radiation protection department and other
departments.
External and internal radiation exposure controls were
implemented effectively.
High radiation and very high radiation areas were
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properly posted and controlled.
An excellent as-low-as-reasonably-achievable (ALARA) program was implemented.
The radiological protection department was proactive in the area of ALARA
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briefings, which were conducted prior to the performance of complex
maintenance and operational activities and/or when the potential for high
radiation exposure was present. The ALARA prejob briefings were thorough and
emphasized good radiological protection practices.
The ALARA suggestion
program was very good. The ALARA program looked for ways to reduce person-rem
exposures and personnel contamination events. The person-rem exposures for
1992 were about at the established goal, whereas the personnel contamination
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events exceeded the goal.
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An excellent liquid and gaseous radioactive waste effluent program was
maintained. Quantities of radionuclides released in liquid and gaseous waste
effluents, and radiation doses to the environment calculated from the effluent
releases, were within the Technical Specification and Offsite Dose Calculation
Manual limits. Semiannual radioactive effluent release reports were submitted
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in a timely manner and contained all of the required information presented in
the required format. One abnormal radiological gaseous release occurred
during this assessment period.
Changes to the Offsite Dose Calculation Manual
and process control program were documented properly. A good program was
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. established for testing the air cleaning systems.
It was noted that several
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of the effluent radiation monitors were out of service for extended periods of
time and, in some cases, the licensee's efforts to return the monitors to
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service have not been fully successful.
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An excellent radiological environmental monitoring program was maintained.
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The program was well managed and included very good implementing procedures.
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The environmental sampling stations and equipment were well maintained and
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calibrated. The environmental thermoluminescent dosimeter program was well
maintained and the thermoluminescent dosimeter results compared very well with
the NRC's thermoluminescent dosimeter results at collocated sites. Annual
radiological environmental operating reports were timely and contained the
required information.
Excellent solid radwaste and radioactive materials transportation programs
were maintained.
Excellent procedures for the preparation and shipment of
radioactive waste and other radioactive materials were in.glemented.
The
licensee properly characterized, classified, and prepared radioactive waste
for shipment and burial.
Radioactive materials and waste shipments were made
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without incident or problems.
Staffing was maintained at appropriate levels in the chemistry, radwaste, and
radiological services departments. Two supervisor positions had been open in
the radiation protection departments since mid-1992.
The various departments
experienced a very low turnover of technical personnel. The radiation
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protection staff was sufficient and appropriately supplemented with contract
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radiation protection technicians during outages.
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Excellent training and qualification programs were established and
implemented for personnel in this functional area. The radiological controls
area personnel were well trained and qualified.
Training instructors were
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well qualified.
Excellent coordination existed between the training
department and the various contributing departments that received training in
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this functional area. An excellent radiological training program was
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established for radiation workers.
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Excellent audits and surveillances were performed in the radiological controls
area.
The audits and surveillance identified several findings that were
reflective of an aggressive audit program. Corrective actions for the
findings were timely and technically sound.
The audit teams included
technical experts to review the specific program areas.
In summary, several violations were identified that involved the two uptake
events which occurred in early 1992. A thorough investigation was performed
by the licensee regarding the events and some weaknesses in the radiation
protection program were identified.
In general, the radiation protection
department maintained a good performance level. An excellent ALARA program
was maintained.
Excellent performances were noted in the areas of radioactive
waste effluents management, radiological environmental monitoring,
transportation of radioactive materials and wastes, training, and audits and
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Effluent monitors have been out of service for extended
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periods. Management provided strong support for the radiological controls
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2.
Performance Rating
The licensee is considered to be in Performance Category 2 in this functional
area.
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Recommendations
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a.
NRC Actions
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Review in-plant implementation of the licensee's radiological protection
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program.
b.
Licensee Actions
Address filling of the vacant positions in the radiological protection
department, resolve the rerformance of effluent monitors, and resolve the
causes for the high numbers of contaminations.
C.
Maintenance / Surveillance
1.
Analysis
This functional area consists of activities associated with the preventive and
corrective maintenance of plant structures, systems, and components. This
area also includes the conduct of surveillance testing, and inservice testing
and inspection activities.
NRC inspection efforts consisted of routine inspections by the resident
inspectors and six inspections performed by region-based inspectors.
In the
last SALP report, no recommendations were made for overall program
improvement.
The maintenance program has undergone a number of improvements, which resulted
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in overall good physical appearance of the plant and in the good performance
of maintenance activities. The licensee continuously upgraded the preventive
maintenance program and optimized the program's approach. The maintenance
training program included a notable range of courses designed to familiarize
the maintenance staff with vital plant systems. As a result, the licensee
maintained a stable and well-qualified maintenance work force.
In addition, a
strong calibration program was developed and calibration scheduling was
effectively controlled to ensure compliance with program frequencies.
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Calibration procedures were exceptionally well written, detailed, and
comprehensive.
The inservice inspection program and implementing procedures were well written
and consistent with requirements of Section XI in the ASME Code. The repair
and replacement program provided appropriate instructions for controlling
repair and replacement activities and performing any required preservice and
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- inservice inspection program examinations.
Observation of inservice
inspection program examinations and review of personnel certification records
indic<.ted that the nondestructive examinations were properly performed by
qualified personnel using qualified procedures.
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The f ort Calhoun Station experienced a reactor trip during this assessment
period that was directly related to the performance of a nonsafety-related
maintenance activity.
Reviews of the nonsafety-related activity did not
address the potential deleterious effects these activities could have on
safety-related activities. As a result, actions needed to eliminate the
potential were overlooked. Other maintenance errors identified during this
assessment period were found to have minor safety significance with no
programmatic concerns identified. The licensee took prompt actions to correct
identified maintenance deficiencies.
The implementation of the maintenance program by the licensee was very good.
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Maintenance activities were performed in accordance with approved procedures
and were well coordinated.
Preplanning of maintenance activities and
attention to detail by maintenance personnel were notable strengths, with very
good communication between maintenance personnel in the field and other
organizations. Management oversight of maintenance activities was excellent
throughout this assessment period, with supervisory personnel presence noted
during complex activities and periodically during the performance of more
routine efforts.
The systems engineering organization was actively involved in maintenance and
surveillance activities.
The oversight provided by the engineers helped to
ensure that the maintenance and surveillance programs were implemented in a
very good manner.
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The licensee's implementation of the surveillance program was noteworthy, with
one exception.
Because of a lack of oversight by the outage control center
during the performance of surveillance activities during the refueling outage,
shutdown cooling was lost due to an overloaded electrical bus.
Surveillance
tests were scheduled and performed as required by the Technical
Specifications.
Personnel adherence to surveillance procedures was excellent.
The Type B and C local leak rate test results were good.
Coordination among
surveillance, systems engineering, and operations personnel during testing
activities was very good.
In summarc performance in this functional area was good. The licensee has
been proa.tive and has taken actions to continually improve the maintenance
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program.
Procedural compliance was very good. Management oversight of this
functional area was notable. A loss of shutdown cooling resulted from the
lack of oversight during the performance of surveillance testing.
Plant
perturbations resulted from nonsafety-related maintenance activities.
2.
Performance Ratina
The licensee is considered to be in Performance Category 2 in this functional
area.
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Recommendations
a.
NRC Actions
None
b.
Licensee Actions
Perform an assessment of the effect that nonsafety-related maintenance
activities could have on safety-related systems and provide an appropriate
level of oversight of surveillance testing during refueling outages.
D.
1.
Analysis
This functional area includes activities related to the establishment and
implementation of the emergency plan and implementing procedures, onsite and
offsite plan development and coordination, support and training of emergency
response organizations, licensee performance during exercises and actual
events that test the emergency plans, and interactions with onsite and offsite
emergency response organizations during planned exarcises and actual events.
Evaluation of this functional area was based on the results of two inspections
conducted by regional emergency preparedness analysts and observations by the
resident inspectors.
The previous SALP report noted that management attention and aggressive
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actions should be taken to improve overall performance.
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During this assessment period, there were five actual emergency declarations.
Four of the declarations were classified as Notification of Unusual Events,
resulting from entering a Technical Specification shutdown action statement.
In all four of the cases, the licensee made timely classifications and offsite
notifications. On July 3,1992, an Alert was declared because of a
loss-of-coolant event. During this event, emergency response facilities were
activated and response personnel successfully implemented major portions of
the emergency plan and implementing procedures.
The Augmented Inspection Team
noted that the licensee's overall response during this event was excellent.
In addition to the effective response to actual classified events, the
licensee's emergency response organization demonstrated improved performance
during emergency drills and the 1992 emergency exercise. During the exercise
and drills, NRC evaluators and observers noted efficient and effective
implementation of the emergency plan and implementing procedures.
Implementation of abnormal and emergency operating procedures by the
operations staff was very good.
Emergency command and control was excellent
and technical assessment and mitigation efforts were strong.
During the
exercise, operational support personnel performed well as d improvements were
noted in the exercise of radiological controls during emergencies. The
exercise scenario was run using the control room simulator in the dynamic mode
to enhance challenge and realism. One minor exercise weakness was identified
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classification of conditions corresponding to a Site Area Emergency.
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Emergency training drills exceeded requirements in both number and scope.
For
example, a casualty control drill, not required by the NRC, was held to
provide enhanced training for maintenance personnel assigned to the Operations
Support Center staff.
The licensee's exercise and drill critiques were
effective in identifying areas in need of corrective action.
The operational status inspection found that changes to the emergency plan
were generally reviewed and submitted to NRC in an appropriate manner.
Emergency facilities, equipment, and supplies had been maintained in a state
of operational readiness. An appropriate level of staffing had been
maintained for the emergency response organization and an excellent program
had been implemented to train and maintain the proficiency of these response
personnel. Comprehensive and effective audits of the emergency preparedness
program had been performed.
The licensee maintained a cooperative and supportive working relationship with
offsite response organizations. The Federal Emergency Management Agency did
not evaluate the 1992 exercise; however, they did evaluate an unannounced /off-
hours drill and a medical drill involving offsite agencies. No deficiencies
were identified during the drills.
In walkthroughs conducted with shift crews during the operational status
inspection, the three teams evaluated demonstrated excellent proficiency in
implementing the emergency plan and implementing procedures in response to a
rapidly escalating scenario. All simulated events were properly classified.
Timely and accurate notifications were made to offsite authorities.
Dose
assessments and protective action recommendations were based on plant
conditions and were appropriate.
In summary, licensee management and staff continued to improve the emergency
preparedness program.
Efforts produced excellent results in key emergency
preparedness areas. The excellent training provided to emergency response
organization personnel was evident during exercises, drills, and walkthroughs
with operating crews. The performance of the emergency response personnel
during the Alert was excellent. The emergency preparedness program has been
effectively managed.
2.
performance Rating
The licensee is considered to be in Performance Category 1 in this functional
area.
3.
Recommendations
None
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Security
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1.
Analysis
This functional area includes activities that ensure security of the plant,
including all aspects of access control, security background checks, and
protection of safeguards information.
Evaluation of this functional area was based on the results of two inspections
performed by region-based physical security specialist inspectors and routine
observations by the resident inspectors.
In addition to the normal regional
inspections, a special Operational Safeguards Response Evaluation was also
performed during this assessment period.
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The previous SALP report noted a strong and effective security program. No
specific recommendations were included in the previous report.
During this assessment period, one repeat Severity Level III violation was
identified involving the protection of safeguards information.
The licensee
took effective corrective actions, with substantial programmatic changes made
with respect to the handling of safeguards information. Overall, the
enforcement history was good during this assessment period.
Management continued to provide strong support to ensure that an effective
security program was maintained. Management was actively involved in
day-to-day activities and provided excellent oversight of the implementation
of the security program.
Quality assurance audits of the security program were thorough, performance
oriented, and comprehensive. The audits of the self-screening contractors
were very comprehensive and identified several problems with contractor
programs. The security organization provided timely, effective, and
technically correct responses to the audit findings and recommendations.
<
The testing and maintenance program was effective in ensuring that security
systems were maintained operational. Testing personnel were well trained and
allowed to use their initiative when testing the security systems.
The licensee submitted four Physical Security Plan revisions pursuant to
10 CFR Part 50.54(p) that involved significant changes to their program.
The
changes were in compliance with the requirements of Part 50.54(p).
The licensee had an appropriate number of security force personnel assigned to
normal shifts. During the 1992 refueling outage, prior planning by the
security management staff resulted in a significant reduction in overtime
hours, when compared to previous outages.
The security training program was very effectively administered and
implemented. Training records were well maintained.
Excellent training
facilities and training aids were maintained and used. A new weapons training
range was constructed and effectively used.
In preparation for the
Operational Safeguards Response Evaluation inspection, tactical training was
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training. During this evaluation, the security force demonstrated the ability
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to bring sufficient response assets to bear quickly and effectively against
simulated armed intruders. The Operational Safeguards Response Evaluation
pointed out that there exists a strong security management team that was
involved in and supportive of the security program. The security forces
demonstrated an effective contingency response capability and a strong
defensive strategy. Another positive element of the response capability was
the command, control, and communications.
The overall results of the
Operational Safeguards Response Evaluation inspection was evidence of a well-
motivated and well-trained security force.
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In summary, the licensee had maintained an excellent security program. The
security organization was appropriately staffed with well trained officers.
The security management staff was proactive, professional, and received
excellent management support from plant and corporate management. The results
of the Operational Safeguards Response Evaluation were indicative of a strong
security program.
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2.
P_ftrformance Ratinq
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The licensee is considered to be in Performance Category 1 in this functional
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area.
3.
Recommendations
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None
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F.
Engineering / Technical Support
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1.
Anal ysis
This functional area consists of technical and engineering support for all
plant activities.
It includes all licensee activities associated with the
design of plant modifications; engineering and technical support for
operations, outages, maintenance, testing, surveillance, and procurement
activities; training; and configuration management.
NRC inspection efforts consisted of routine inspections by the resident
inspectors and seven region-based inspections.
The inspection effort included
team inspections to assess the motor-operated valve progrcm, as specified in
Generic Letter 89-10, " Safety-Related, Motor-0perated Valve Testing and
Surveillance," and engineering and technical support functions.
The previous SALP report did not address any recommendations.
Enforcement
history during this assessment period was excellent.
The licensee's engineering organization continued to be proactive in the
identification and resolution of engineering issues.
For example, the
licensee reviewed information supplied by the NRC concerning a potential
safety issue at another facility. This resulted in the discovery that
backleakage could occur through the safety injection and refueling water tank
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- discharge check valves during the recirculation phase. This could have
allowed radioactive water to enter the tank, which is vented to atmosphere.
The licensee's prompt evaluation of this concern allowed the valves to be
replaced during the 1992 refueling outage.
The systems engineering program generally continued to function well. One
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example was the discovery that a personnel access lock equalizing valve had
never been leak rate tested.
Systems engineering was also involved in the
discovery that cam followers on certain safety-related switches were
susceptible to cracking.
The system engineer's performance in day-to-day
activities was excellent.
They were observed to be actively involved in all
activities associated with their system. The system engineers' performance
with regard to surveillances and maintenance was excellent.
However, the
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systems engineering organization was responsible for inappropriately taking
reactor coolant drain tank samples, resulting in the loss of containment
integrity. This sampling was performed without the use of an approved
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procedure.
In addition, in response to a problem that involved battery case
cracking, a root cause analysis indicated that a potential common-mode failure
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existed. This root cause analysis did not receive timely attention and action
by plant management.
The licensee's design basis reconstitution program continued tc identify items
that were outside the plant's design basis.
The identification of design
issues and the communication of these issues to the NRC staff was considered
superior.
The engineering organization's response to plant events and other complex
activities was superior.
The engineering organization performed well during
the refueling outage with support for the reactor vessel thermal shield
inspection and repair, reactor vessel inservice inspection, steam generator
eddy current testing, ultrason4 testing of de off-loaded fuel, emergency
battery replacements, and the u.;tallation of a temporary diesel generator.
However, in response to the loss of shutdown cooling, engineering provided
incorrect procedural guidance to limit the 480-volt bus loading. The result
was a subsequent loss of three 480-volt busses.
This was considered an
isolated occurrence.
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The licensee's initial efforts in developing a program in accordance with its
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commitments to Generic letter 89-10 was generally good. Some weaknesses were
identified in the licensee's program, but these weaknesses were typical of
those found throughout industry, and no operability concerns were identified.
The licensee maintained a competent nuclear engineering staff with notable
in-house computing and reload safety analysis capabilities.
The licensee's
nuclear engineering staff was assertive in maintaining cognizance of fuel
performance and potential adverse impacts, as evidenced by the requirement
that all proposed changes to fuel assembly design be reviewed and approved by
the licensee prior to implementation in the reload batch. The licensee's fuel
examination activities and first-time application of a fuel assembly
reconstitution process were successful and performed without encountering any
significant problems.
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3he licensee developed and implemented an effective program to control design
changes, modifications, and temporary modifications in accordance with the
Technical Specifications, Updated Safety Analysis Report, and regulatory
requirements.
The licensee's process for the performance of safety
evaluations was considered to be exceptional.
For example, the number of
active temporary modifications was relatively few and those that were in
effect were properly implemented.
The implementation of plant modifications was considered good. The
modifications to the electrical power system for the electrohydraulic control
system were implemented in a timely manner and should improve the reliability
of the facility. The licensee's analysis for the revision to the high
pressurizer pressure reactor trip and pressurizer power-operated relief valve
setpoints following the loss-of-coolant event provided an appropriate basis.
The prompt implementation of the modification to readjust these setpoints was
found to be commendable.
The licensee's calculations and evaluations related
to the electrical distribution system were noteworthy.
The replacement of two
safety injection and refueling water tank valves was properly implemented.
Engineering management's oversight of the engineering organization's
involvement with safety issues continued to be superior. Design Engineering
interfaced well with their site contacts and system engineering.
Communication between the engineering departments and the rest of the plant
organization was very good.
The staffing levels were considered to be
consistent with the workload. The design basis documents and user friendly
procedures were found to be a positive influence on design engineering job
performance. The licensee had identified several strategic engineering
initiatives.
For example, the licensee initiated actions to enhance steam
generator reliability, plant reliability,- and outage planning and control.
These initiatives were commendable.
The system engineer training program was a strength in the development of an
effective system engineering program. The system engineer's coordination of
activities related to their assigned systems was viewed as superior.
The
system engineers had developed very good credibility and working relationships
throughout the licensee's organization.
There was a strong sense of ownership
of systems by the system engineers.
The training department's performance in operator training was very good.
This was evident in the 100 percent pass rate on two sets of initial licensee
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examinations and the requalification examination.
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In summary, the licensee's overall performance in this functional area was
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superior. The licensee's engineering organization continued to be proactive
in the resolution of engineering issues.
The systems engineering program was
notable.
Some engineering problems were considered isolated cases and not
indicative of a programmatic problem. The identification of design issues and
the communication of these issues to the NRC staff was considered superior.
Engineering made significant efforts to resolve ongoing issues.
Engineering
management's oversight of the engineering organization's involvement with
safety issues continued to be excellent. The licensee maintained a competent
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- nuclear engineering staff with notable capabilities.
The licensee developed
and implemented excellent programs for design changes, modifications, and
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2.
Performance Rating
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The licensee is considered to be in Performance Category 1 in this functional
area.
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3.
Recommendations
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None
G.
Safety Assessment /0uality verification
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1.
Analysis
This functional area includes licensee activities associated with the
implementation of licensee safety policies; licensee activities related to
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amendment, exemption, and relief requests; responses to generic letters and
bulletins; the resolution of safety issues and performance of safety
evaluations; safety committee and self-assessment activities; licensee
activities related to the identification and resolution of equipment and
programmatic problems; and licensee activities associated with quality
verification functions.
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NRC inspection efforts in this area consisted of the core inspection program,
regional initiative inspections, and NRR program reviews. The previous SALP
report did not identify any recommendations in this functional area.
The licensee's commitment to safety was evident during the refueling outage.
]
A control center was formed as the central coordinating body for the outage,
which had the overall, day-to-day responsibility for outage activities.
Two
assistant plant managers were appointed as outage managers. The outage
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control center assumed responsibility for as much of the routine control room
outage activities as possible.
However, equipment taken out of service
continued to require control room approval.
A definite focus on reducing
shutdown risks was prevalent, as exemplified by the installation of a
temporary diesel generator as an additional power supply.
The outage control
center performed excellently throughout the outage, except for one instance
where a surveillance test of the safety injection pumps was performed a day
earlier than scheduled.
As a result, shutdown cooling was lost for
approximately 7 minutes. This event was considered an indication of a
programmatic weakness with outage planning and control.
Overall, the
performance of the licensee during the refueling outage was very good.
The Nuclear Safety Review Group was effective in carrying out its charter, as
evidenced by the group's involvement in major events and issues. A notable
characteristic of the Nuclear Safety Review Group was its timeliness in
addressing issues and issuing findings or recommendations. The Quality
Assurance organization initiated a functional area trending program, which
identified weaknesses or concerns. The issues identified by this process were
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Nuclear Safety Review Group and Quality Assurance.
These groups provided good
support to the Safety Audit and Review Committee. The Quality Assurance and
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Nuclear Safety Review Groups' overview of engineering activities were
considered a strength.
The onsite and offsite committees were effective in the identification of
issues. The onsite Plant Review Committee was proactive in assessing the
adequacy of proposed corrective actions.
The nuclear planning organization
was engaged in a process of identifying strategic issues, such as steam
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cenerator reliability, or issues with long-term or future implications, such
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as the installation of a third permanent offsite power source. The majority
of these strategic issues are safety-related.
Quality control personnel were
noted in the plant on numerous occasions.
Excellent communication and
coordination was apparent between the quality control inspectors and plant
personnel.
The licensee has expended significant resources in the upgrade of all plant
safety-related and nonsafety-related procedures. As a result of these
efforts, the procedures provide concise and effective instructions for the
performance of tasks.
The quality of plant procedures was generally excellent
based on the licensee execution of the procedures. On occasion, minor
inconsistencies were noted in the procedures, but personnel involved backed
out of the procedures and obtained clarification before recommencing the
ongoing evolution.
The licensee has been proactive in the identification and correction of
problem areas. The licensee continued to exert a strong effort toward the
identification of problems related to safety and conditions adverse to
quality. An assessment of the licensee's corrective actions in response to
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inspection findings and licensee event reports revealed that the actions were
thorough, proper, and timely,
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A review of recent changes revealed innovative enhancements to the programs
for root cause analysis and the investigation of human performance related to
specific events. Human performance evaluation had evolved to the point where
investigations were performed by a team staffed by members from nonrelated
disciplines. All root cause analyses were performed by the system engineering
group.
The actions resulting in the violation of containment integrity was an example
where licensee management failed to exercise control over certain plant
activities. The incident, where a liquid sample was taken from a drain valve
(WD-1060) that was located between two containment isolation valves, was
significant due to the number of occurrences and the nonquestioning attitude
of those plant personnel that were aware of the activity. The sampling was
allowed to be done without the use of an approved procedure, nor was the
evolution approved for performance by the operations staff.
During this assessment period, the NRR staff reviewed a large number of
license amendments and safety analyses performed by and for the licensee.
Generally, the licensee's submittals demonstrated a clear and concise
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management that was extremely involved in the licensing process.
The
submittals were generally technically competent, unambiguous, and complete.
However, in some cases, additional information was required to complete the
review. Occasionally, technical staff's responses to questions were
inconsistent with prior submittals or the NRC staff had to explain the
question. On several submittals, the licensee's review process failed to
detect mistakes involving either the technical information or the writeup
explaining the information. The licensing department initiated an additional
level of review, but a subsequent submittal showed that the review process
still needed improvement.
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During a 10 CFR Part 50.59 package review, the NRC staff found that the
licensee's evaluations were well prepared and well documented.
Multidiscipline issues were addressed and included a review by engineers from
various discipline groups. The affected sections of the Updated Safety
Analysis Report were clearly identified and the safety evaluations addressed
the potential safety concerns, including the Part 50.59 issues related to
unreviewed safety questions.
The review also found that a screening criteria
and Part 50.59 reportability analysis existed if needed to process temporary
modifications.
There have been four waivers of compliance issued to the licensee during this
assessment period.
The waivers dealt with the opening of the outer personnel
air lock door, to perform repairs, and the performance of a steam generator
inservice inspection following a loss-of-coolant event. The waivers requested
by the licensee were thorough and complete.
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Licensee management has provided an excellent level of oversight for the safe
operation of the facility. Management and the licensee's staff demonstrated
their capabilities when challenged by abnormal and emergency situations.
Through management's and the staff's participation in industry working groups,
they have effected changes in the facility operation based on their awareness
of problem areas that are being identified at other facilities. Management's
strong oversight of plant operations is due, in part, to their familiarity
with the operation of the facility since all personnel in the line management
function, up to and including the Senior Vice President, are former plant
managers.
Overall, licensee management provided notable oversight of the safe operation
of the facility, except for the incident involving unauthorized sampling of a
liquid waste system. The licensee's independent oversight organizations were
actively involved in ensuring that facility operations were performed in a
safe manner.
Licensee submittals made by the licensee were technically
competent, unambiguous, and complete; however, some submittals required NRC
staff assistance or were not consistent. The licensee's root cause analysis,
Part 50.59 program, human performance evaluation system, and corrective action
programs were excellent.
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Performance Rating
The licensee is considered to be in Performance Category 1 in this functional
area.
3.
Recommendations
None
V.
SUPPORTING DATA AND SUMMARIES
A.
Major Licensee Activities
1.
Major Outages
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September 1991 - Replacement of station batteries
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February 1992 - Refueling outage
July 1992
- Loss-of-coolant event
August 1992
- Premature lifting of a pressurizer code safety valve
2.
License Amendments
Eleven license amendments were issued during this assessment period.
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B.
Direct inspection and Review Activities
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NRC inspection activity during the assessment period included 40 inspections.
Approximately 4500 direct inspection hours were expended, which did not
include operator licensing examinations or contractor hours.
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