ML20035G656
| ML20035G656 | |
| Person / Time | |
|---|---|
| Site: | Perry  |
| Issue date: | 12/19/1991 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Lyster M CENTERIOR ENERGY, CLEVELAND ELECTRIC ILLUMINATING CO. |
| References | |
| NUDOCS 9304290014 | |
| Download: ML20035G656 (19) | |
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UM1ED STATES A
NUCLEAR REGULATORY COMMISSION
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DEC1SBSI Docke; n:. ED-U 6 Docket No. 50-441 C+nterier Servics Company ATTN:
Mr. Michael D. Lyster Vice Presiden:
Nuclear - Perry c/o The Cleveland Electric Illuminating Company 10 Center Road Perry, OH 44081
Dear Mr. Lyster:
Enclosed for your review, prior to our scheduled meeting of January 23, 1992, is the Initial SALP 11 Report for the Perry Nuclear Power Plant, covering the period August 1, 1990, through October 31, 1991.
In accordance with NRC policy, I have reviewed the SALP Board Assessment and concur with their ratings.
It is my view that your conduct of nuclear activities in connection with the Perry facility was good. Overall, your performance has improved as indicated by the improving trend in Engineering / Technical Support and the reversal of the declining trend in Maintenance /Surveillan':e. Security and Emergency Preparedness were rated Category 1; the remaining functional areas were rated Category 2, with the noted changes in trends.
Performance in the Operations area showed improvement, as evicenced by no reactor scrams and the continued excellent response to operational events.
However, problems in the development and implementation of the revised Emergency Operating Procedures (EOPs) were attributable to this area and to the Safety Assessment / Quality Verification area. The Operatiens department failed to follow the governing administrative procedure, and r.anagement failed to adequately assure the quality of the process. Management actions to correct previously identified weaknesses in the surveillance and the licensing areas were effective. An improving trend was noted in the area of Engineering / Technical Support. Staffing levels and personnel qualifications were generally considered to be strengths. However, your increased attention is warranted to assure that personnel errors are kept to a minimun.
You are again commended for your sustained superior performance in the areas of Security and Emergency Preparedness, which have now been recognized for six and seven consecutive SALP periods respectively.
At the SAlp meeting, you should be prepared to discuss our assessments and any plans you have to improve performance. The meeting is intended to be a f3 candid dialogue wherein any coments you may have regarding our report are
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l discussed. Additionally, you may provide written comments within 30 days after the ceeting. You co'=ments, a summary of our meeting, and my cisposition of yc;r cot ents fil be issued as the Final SALP report.
In accc-cante utr. Sec:':n 2.750 of the N;C's ";;1es of Practice." Part 2, T 'le 10, Code of Federa! Regalations, a copy of this letter and the Initial SALP Report will be pla:ed ir. the N;C's Public Document Room.
Should you have ary questions :encerning the Initial SALP Report, we would be pleased to discuss them with you.
I Sincerely, Gs 0
NM A. Bert Davis Regional Administrator
Enclosure:
Initial SAL: 11 Report No. 50-4 0/910:1 cc w/ enclosure:
F. R. Stead, Director, huclear Support Department R. A. Stratman, General Manager, Perry Nuclear Power Plant Kevin P. Donovan, Manager, Licensing and Compliar.ce Section S. F. Kensick.1, Directe, Per y Nuclear Engineering Deat.
H. Ray Caldwell, Genera
- Superintendent Nuclear Operations DCD/DCB (RIDS)
Licensing Fee & Debt Collectic :
Branch Resident Inspector, RII:
Terry J. Lodge, Esq.
James R. Williams, State of Dr'o Robert E. Owen, Ohio Department of Health Distribution (Centinued) 2
__ _ _ __ _ _ _ _______ _ ______ _ a
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- a Centerier Service Co:pany 3
DEC 1 S 2991
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Distribution (Continued)
A. Graticjean, St&te of Ohio, Public Utilities Cc= mission Clir.::n 5RI J. H. Snietek, DEDR T. E. Merley, Direct:r, NRR The Chairman K. C. Rogers, Commissioner J. R. Curtiss, Commissioner F. J. Remick, Commissioner E. G. de Planque, Commissioner J. N. Hannon, NRR Director, Project Directorate III-3 J. Lieberman, Director, Of fice of Enforcement NRR/LPEB RIII PRR State Liaison Officer, State of Ohio INPO L. R. Greger, RIII M. J. Pearson, RIII L. L. Ccx, RIII TSS, RIII RIII Files i
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TABLE OF CONTENTS r
6 Pace I.
INTRODUCTION.........................................
1 ab..-,,,,-.,SUTS......................................
2 22.
nnnni vr nt Overview...............................................
2 III. PERFORMANCE ANALYSIS.................................
3 A.
Plant Operations..................................
3 B.
Radiological Controls.............................
4 C.
Maintenance / Surveillance..........................
6 D.
Emergency Preparedness............................
8 E.
Security..........................................
9 F.
Engineering / Technical Support.....................
10 G.
Safety Assessment / Quality Veri fication............
12 l
l IV.
SUPPORTING DATA AND SUMKARIES..........................
14 A.
Maj or Li censee Acti vi tie s.........................
14 B.
Major Inspection Activities.......................
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ItCRDDUCTION 4)
- i The Systematic Assessment of. Licensee Performance (SALP) program is an i
integrated U.S. Nuclear Regulatory Commission (NRC) staff effort to collect available observations and data periodically and to evaluate licensee i
performance cr. the basis of this information. The program is supplemental to 1
normal -agulatory processes'used to ensure compliance with NRC rules and I
regulat ons. It is intended to be sufficiently diagnostic to provide a i
rationa" bas's for alloca:ing NRC resources and to provide meaningful feectack i
to the 'icensee's management regarding the NRC's asssssment cf the facility's
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performance in each functional area.
An NRC SALP B:ard, composed of the staff members listed below, met on
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December 11, 1991, to review the observations and data on performance _ and to assess licensee performance in accordance with the guidance in NRC Manual t
Chapter D516, " Systematic Assessment of Licensee Performance."
This re: ort is the NRC's assessment of the licensee's safety performance at Perry Nucisar Power Plant for the period August 1,1990, through October 31, 1991.
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The SALF Boarc for Perry Nuclear Power Plant was composed of the following individuals-Board Cnairma.
C. E. N:relius, Director, Division of Radiation Safety and Safeguards (DRSS)
Board Merbers W. L. Ferney, Deputy Director, Division of Reactor Projects (DRP)
T. O. Martin, Deputy Director, Division of Reactor Safety (DRS)
J. A. Zwolinski, Assistant Director for Region III Reactors, Dffice of Nuclear Reactor Regulation (NRR)
R. C. K.:p, Cmief, Reactor Projects Branch 3, DRP J. R. Hall, Project Manager, Project Directorate III-3, NRR P. L. Hiland, Senior Resident Inspector Other A::endees at the SALP Board Meeting A. B. Da.is, Regional Administrator, RIII l
L. R.- Greger, Chief, Reactor Programs Branch, DRSS G. C. W-ight, Chief, Operations Branch, DRS R. D. Lanksbury, Chief, Reactor Projects Section 33, DRP F. J. Jamienski, Chief, Maintenance and Outage Section, DRS M. C. Senumacher, Chief, Radiological Protection Section, DRSS J. R. Creed, Chief, Safeguards Section, DRSS W. G. Sr. ell, Chief, Emergency Planning Section, DRSS r
C. F. Gill, Reactor Inspector, DRSS M.. A. Kunowski, Radiation Specialist, DRSS J. E. Fcster, Emergency Preparedness Analyst, DRSS J. W. Mc ormick-Barger, Project Engineer, DRP J. R. Kr.icely, Reactor Inspector, DRS i
a J. A. Hcpkins, Project Engineer, DRP A. E. Vegel, Resident Inspector, DRP 1
W. D. Pegg, Intern, DRS K. Marcus, Intern, DRS C. E. Brown, Reactor Engineer, Technical Support Staff DRP II. SUP.P.ARY OF RESULTS Overview Overall, the licensee's performance was found to be good and has improved from the previous assessment period. Altt ugh the extent of the improvements was not sufficient to merit an increase 11 the numerical rating in any functior.al area, an improving trend was noted 1* the area of Engineering / Technical Support.
In addition, the declining trend previously identified in the functional area of Maintenance / Surveillance was corrected. The functional areas of Security and Emergency Prepa-edness received Category I ratings for the sixth and seventh consecutive SA 2 period respectively. Tr.e remaining functional areas received Category 2 ratings, with the noted changes in trends.
Performance in the Operations area showed improvement, as evidenced by no reactor scrams and the continued excellent respense to operaticnal events.
However, problems in the development and implementation of the revised Emergency Operating Procedures (EOPs-) were attributable to this area and to the Safety Assessment / Quality Verification area. The Operations department failed to follow the governing administrative procedure and management failed to adequately ensure the quality of :ne process. Management actions to correct previously identified weaknesses in the surveillance area and the licensing area were effective. Staffing levels and personnel qu611fications were generally considered to be strergths. However, increased management attention is warranted to ensure tha; personnel errors are kept to a minimum.
The performance ratings during the previous assessment period and this assessment period according to functt:nal areas are given below:
4 Ratfcg Last Rating This Functional Area Period Perio:
Trer.d Plant Operations 2
2 Radiological Controls 2
2 Maintenance / Surveillance 2 Declining 2
1 Security 1
1 i
Engineering / Technical Support 2
2 Impreving Safety Assessment / Quality i
Verification 2
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III. PERFORMANCE ANALYSIS A.
Plant Operations I
1.
Analysis Evaluation of this functional area was based on nine routine inspections, cne team inspection, and information from the Region III operator licensing section.
Enforcement history in this area declined.
Four Severity Level IV violaticns were identified.
In addition, one Severity Level III violation, discussed in the Safety Assessment /Ouality Verification functional area, was identified that was, in part, due to problems within the Operations Department. During the previous assessment period, no violations were identified. The Severity Level III violation, which carried a S100,000 civil penalty, concerned a significant breakdown in the manacement oversight and control during the development, review, and approval of plant emergency instructions (PEIs). The four Severity Level IV violations concerned three isolated instances of personnel errors and one long standing problem concerning inadequate system lineups during maintenance l
activities.
Personnel errors on the part of plant operators resulted in several violations and an engineered safety feature (ESF) actuation. In each case, the personnel errors were considered independent occurrences resulting from inattention to detail during routine plant evolutions.
In general, plant operator response to events was considered excellent as exemplified by operator response to a rapid loss of main turbine hydraulics, a reactor recirculation pump trip, a loss of a turbine driven feedsater pump, a dri(ting control rod, and a conductivity excursion.
Some operational events resulted from inadequate preparation or attention to detail by cperators as exemplified by a safety relief valve being open longer than anticipated and several control rod misposition events.
t During the assessment period, no automatic scrams occurred. One reactor protection system (RPS) trip occurred (with no rod movement) and is discussed in the Maintenance / Surveillance functional area. This represents an improvemen:
over the last assessment period when one scram from above 15 percent power and one RPS trip (with no rod movement) occurred. The ability to sustain low automatic scram rates cver the past two assessment periods indicates the licensee's corrective actions for a high incidence of automatic scrams in 1988 have been, and continue to be, effective.
Management effectiveness in ensuring quality was mixed. Good oversight and management were observed in the day-to-day conduct of plant operations.
Control room decorum was generally good with nonbusiness activity kept to a minimum. Management commitment to safe plant operation was evident. This was demonstrated by the decision to promptly shut the plant down on two occasions; when unidentified drywell leakage increased and following slow control rod scram time tests. However, the lack of management control and oversight during the development and implementation of the PEIs resulted in PEls which were incapable of mitigating several accident scenarios which were beyond the design basis. This issue is core fully discussed in the Safety Assessment /0uality Verification functional area.
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The approach to' identifying' and resolving technical issues from a safety standpoint was generally good. The conservative decision to replace all~of the scram solenoid pilot valves from suspect lots to resolve slow control rod scram times demonstrated a strong commitment to safe plant operation. The use of human performance enhancement system (HPES) analysis in event root cause investigations appeared effective in identifying technical and human performance issues. Examples of this were the control rod misposition events, rapid loss of electro hydraulic control event, and a conductivity excursion. However, the lack of a technical justificaticn, or inadequate justificatiens, for several deviations from ownkrs grcup guidelines during the developmer.t of PEIs indicated a lack of understanding of the intent or basis of the guidelines.
The licensee's training and qualification program was good. Operator license
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training continued to be a noted strength. The requalification training program evaluation was deferred due to a small sample size (i.e., less than 32); however, 3 crews, consisting of 8 senior reactor operaters (SR0s) and 2 reactor operators (R0s), successfully passed requalificatien examinations.
Initial licensing examinations were successfully completed by all 10 of the SRO candidates and by 10 of the 11 RO candidates.
Staffing in this functional area was ample. A sufficient complement of operations personnel allowed for continued use of six-shif t rotation during routine plant operations.
Generally, overtime guidelines were maintained within established administrative limits. Deviations from the administrative limits were approved by management. In no case were the technical specification (TS) guidelines exceeded.
The fire protection program was considered to be adequately i=plemented.
Plant housekeeping-has improved to adequate levels in high traffic areas of the plant. However, the more remote areas were, at times, found to be in a less than desirable condition. In the previous assessment period, housekeeping was considered poor. One notable item has been the initial painting and plant preservation effort initiated during this assessment period.
2.
Performance Rating The licensee's performance is rated Category 2' the area of plant operations.
The licensee's performance in this area was rated Category 2 in the previous assessment period.
3.
Recommendations None. However, the board notes that subsequent to this assessment period a followup inspection to assess the operators' ability to implerent the PEI's was performed. No problems were identified.
B.
Radiolooical Controls 1.
Analysis Evaluation of this functional area was based on the results of six inspections.
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i Enforcement history declined somewhat withLthree Severity Level IV violations e
issued for, failure to control access to a Locked High-Radiation Area, for failure to adequately survey a. work area, and for an inadequate. calibration i
procedure. : All were licensee ' identified but were cited because corrective actions for previous similar events had not prevented their recurrence.
Management effectiveness in ensuring quality was mixed. On the negative side, the events noted above were indications of less than effective management involvement in ensuring corrective action.. Weaknesses were also noted in radiological controls over work on a recirculation pump shaft that resulted in area and personnel contaminations and in the selection'of access control points during the second cycle refueling outage. On the positive side, effective management involvement was evident in the use of mockups and a video-disc plant tour system for training, in the incorporation of radiological control activities in the outage schedule, and efforts in source term reduction.
Moreover, most of the performance problems were identified by licensee reviews and audits which continue to improve. Good management initiatives were also evident in organizational changes that put the corporate health physicist reporting directly to the Vice President, Nuclear rather than through two i
intermedia ries.
The approach to identifying and resolving technical issues from a safety standpoint was good. The radwaste demineralizers were modified to significantly i
increase their effectiveness in particulate and iodine removal. Efforts were initiated to avoid shutdown dose rate increases seen at some plants with zinc injection. Additionally, ALARA evaluations regarding maintaining clean areas in containment and for the use of robots in high dose and highly contaminated areas were being evaluated.
4 The station dose total for 1990, with contribution from a 4 month refueling outage, was high at 638 person rem, but was down from the previous year.
From January 1991 to the end of the assessment period, station dose total was 123 person-rem, which included 35 person-rem incurred during a forced outage in April. The licensee's ALARA program is well developed and appears to be making i
progress in reducing doses resulting from the high source term. Although l
somewhat high, personnel contaminations declined from the previous assessment period. No significant transportation or burial site problems were identified.
Good efforts were made to reduce the quantity of radioactive waste stored on site and extensive use of a waste processor was made to reduce the cuantity shipped for burial.
The licensee continued to perform well in the NRC radiological confirmatory 4
measurements program, achieving 50 agreements in 52 comparisons, and also 1
performed well in other interlaboratory comparison programs. The Radiological Environmental Monitoring Program was well implemented and equipment was well ~
maintained.
Staffing and qualifications were good. An experienced and knowledgeable individual was hired to be manager of the radiation protection and chemistry groups. The station and corporate ALARA (as low as reasonably achievable) staffs and upper management in the chemistry and radiation protection groups were also experienced and knowledgeable.
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-The quality of the training anc qualificaticn program in radiological controls was mixed. Good initia:!ves ir training included a course on radioactive material shipping and bu-ial site requirements anc an advanced training course for radiation workers. However, poor training contributed to incidents involving the improper decontamination of several workers, unapproved entries into unsurveyed or poorly surveyed a-eas, and the spread of contamination during work on a recirculation : ump stift.
2.
Performance Ratina The licensee's performan:e is -atec Category 2 in the area of radiological controls. The licensee's perf:-mance in this area was rated Category 2 in the previcus assessment :eri--
3.
Recommendations f
None.
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Maintenance / Surveillance 4
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Analysis l
Evaluation of this functiona: a-ea was base: on : e results of 10 routine inspections and 1 maintenance : sam inspectien.
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Enforcament history in tnis arsa improved. Three Severity Level IV violations i
were identified early in the assess =ent per'od.
Curing the previous assessment period, one Severity Level III and seven Severity Level IV violations were identified. The three Severity Level IV viciations identified during this assessment period concerr.ed a failure to folicw procedure, failure to properly segregate nonconforming rate-ia', and inade:uate :ssting of fire pumps.
A large number of reportable e.snts cccurred that were attributable to i
maintenance or surveillance ac:f vities. As was the case during the previous assessment period, about half cf the events were caused by personnel error.
l Personnel errors resultec in cissed TS surveillances or action statements,
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unexpected ESF actuations, less of safety systez trains, and one RPS trip (with no rod movement). Altho;;h -he frequency of perscnnel errors was high, the resulting events did not sigr.ificantly impa:t safe plant operations.
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t Management effectiveness in ers; ring quality in : e area of maintenance was j
mixed. On the positive side, :ne overall mainter,ance program was effective and l
properly implemented with emphasis placed cr. safety-related werk. Management effectively tracked maintenar.ce performance indicators to determine status and to maintain control of mainter.ance work.
E:th the corrective and preventive backlogs were properly c:ntrolied with deferrals technically justified. The reliability centered maintenar.cs program has not ceen in place long enough to evaluate its effectiveness.
C:nversely, accelera:ed work control processes I
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.I were used excessively rather than the normal methods and controls. Examples 4;
included instances of starting maintenance activities before receiving the normal approval and release of the work order package and excessive use of I;
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temporary change notices to procedures, rather than the normal revision process.
Management was extensively involved in the September 1990 main steam isolation valve troubleshooting activities; however, problems encountered in the planning and preparation of testing materials resulted in delays. Also, since the work i
order was not prescriptive enough, the quarantined "as-found" conditions of one of the air packs was not retained.
Management effectiveness in ensuring quality in the surveillance area was a strength.
During the previous assessment period, management attention to test activities i
was considered a weakness. Previously, initial test data was considered
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invalid, with little or no justification, if a second test performance was acceptable. The licensee demonstrated its com=itment to accept initial test data and take appropriate actions. Examples include testing on check valves during cold shutdown, emergency diesel speed control problems, American Society of Mechanical Engineers (ASME)Section XI pump and valve testing, and, most i
notably, control rod scram-time testing. The in-service inspection (ISI)
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activities were found to be adequately planned with appropriate priorities assigned by the licensee. All ISI actitities were controlled with well stated and defined procedures. Records were complete, well maintained, and retrievable.
The approach to identifying and resolving technical issues from a safety standpoint was good. The licensee had thorough troubleshooting plans for removal, testing, and disassembly of MSIV air pack actuators.
To assist in t
determining the root cause of the air pack failures, parts were sent to an independent laboratory for further analysis.
In addition to immediate corrective actions, long-term measures to prevent recurrence included pursuing potential design modifications with other' utilities and component vendors. Problems with l
scram solenoid pilot valves were dealt with in a conservative manner by increasing test frequency and sample size, and on two separate occasions, replacing entire suspect lots. Thorough investigation into abnormal component behavior identified a programmatic problem in the service life cf i
Agastat relays.
Staffing levels and qualifications in this functional area were gooc. The l
completion of required surveillance tests and the ability to maintain a l
reasonable maintenance backlog were indicators of adequate staffing levels. In general, the maintenance and surveillance activities observed were conducted by i
knowledgeable and experienced personnel. One exception observed was maintenance activities being performed on a " quarantined" MSIV air pack. The use of j
full-scale mock up training for planned maintenance, such as reactor recirculation pumps, was a strength. The ISI personnel had adequate expertise to perform their functions. Contract ISI personnel were utilized and adequate i
management oversight was provided. Personnel performing nondestructive examinations were well qualified, appeared to be knowledgeable, and were conscientious in performing their work.
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Performance Rating The licensee's performance is rated Category 2 in the area of maintenance / surveillance. The licensee's performance in this area was rated Category 2 with a declining trend in the previous assessment period.
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Recornendations y'
None.
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Emercency Freparedness i
1.
Analysis l
Evaluation of this functional area was based on :ne results of two inspections.
Enforcement history remained excellent; no violations were identified.
Management' effectiveness in ensuring quality was excellent. The licensee relocated and upgraded the plant's backup emerger.cy operations facility (EOF) such that it is a replica of their onsite EOF. The offsite radiation monitoring i
team's response capability was also improved thrcugh the acquisition of new four-wheel-drive vehicles and radios. The licensee icproved the emergency j
response organization's (ERO's) call out capabilities by developing and implementing three separate methods of notifying ERO personnel. Perry's emergency response facilities and equipment were maintained at a high level of readiness.
I The licensee's approach to identifying and resolving technical issues from a safety standpoint remained very good. One Unusual Event was declared in a timely manner with appropriate and adequately detailed notifications to NRC, State, end county officials made promptly. A mir.or problem was encountered in notifying the State; however, the licensee too(adequate corrective actions.
An internal evaluation of the emergency plan activation was well done and included appropriate documentation of the identified problem and associated corrective actions. During the 1991 annual exercise, event classification and timely notification of offsite authorities were good.
l The licensee's overall performance during the 1991 exercise was very good with j
no performance weaknesses identified. Although only the utility was involved, i
the licensee challenged the ERO to respond to a full nock NRC site team. The exercise scenario was realistic and included many challenging aspects. Only i
one concern was identified. The concern involved the calibration and maintenance i
of the area radiation monitors in the Technical Support Center and the EOF.
Staffing of the Emergency Planning Unit remained very good with no changes in l
personnel since the previous assessment period. The ERO staffing also remained very good.
Four or five qualified individuals were assigned to fill each key ERO position and numerous qualified personnel were assigned to support positions.
l The licensee increased the frequency of off-hours pager drills from semiannually j
to quarterly to better ensure the capability to augment onshift personnel.
l The training and qualification program in emergency preparedness (EP) remained i
effective in training ERO personnel for all key and support positions. The licensee developed a training manual procedure to formally outline criteria for i
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l the conduct and maintenance of the EP training program.
This procedure resulted in three major enhancements to the training program. These were the creation-3" of an EP overview module for initial training of all ERO personnel, the expansion of the number of training modules to provide more position-and facility-specific training, and the creation of an operational support center (OSC) overview module for OSC staff not required to complete the specific OSC training module. All required drills and exercises were conducted in an excellent fashion and included thorough critiques.
2.
Parfcrmar.cc hting l
The ifcensee's performance is rated Category 1 in the area of emergency preparedness. The licensee's performance in this area was rated Category 1 in i
the previous assessment period.
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Recommendations None.
E.
Security 1.
Analysis I
Evaluation of this functional area was based on the results of two security i
inspections, one fitness-for-duty (FFD) inspection, and one-regulatory effectiveness review (RER).
i Enforcement history was excellent; no violations were identified.
i Management effectiveness in ensuring the quality of the security program i
remained excellent. The licensee completed the Unit 2 expansion project which had been started in the previous assessment period. This project included i
installing a state-of-the-art perimeter intrusion detection system, a new i
security fence, and new closed circuit television cameras.
l The approach to identifying and resolving technical issues from a safety I
standpoint was good. The licensee's installation of a state-of-the-art intrusion detection system for Unit I addressed maintenance and false alarm rates. The installation of a " video capture" system provided an upgrade in the performance capabilities of perimeter alarm assessment.
Security operational events were properly identified, analyzed, and documented during the assessment period. The licensee implemented a timely and comprehensive program to heighten security awareness during the Persian Gulf conflict.
Security staffing was ample. The experience level of the guard force was high as a result of a low turnover rate. The security resources were effectively utilized and a high level of security awareness was evident. A close and effective liaison continued among local law enforcement agencies and licensee I
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L securityTsanagement.. Also, excellent communication was maintained between e,
senior sta' tion management and the licensee security staff. The RER team noted the well-established and productive working relationship between control room operators and.the security staff.
The training and qualification program for the security force was excellent.
During the RER, it was observed that there was a thorough, well thought-out l
effort in the area of armed response capabilities. The licensee continued to l
implement ar.d improve'its tactical contingency training program. Security f
personnel wara competent in the execution of their auties. The amount of
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supplemental security training taught by outside agencies was increased.
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The FFD program satisfied the general performance objectives of 10 CFR 26.10.
Program strengths included strong management support for the program, thorough-quality assurance (QA) auditing of the program, ample personnel resources devoted to implementing the FFD program, and a canine procram to locate controlled substances.
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Performance Rating The licensee's performance is rated Category 1 in the area of security. The licensee's performance in this area was rated Category I during the previous assessment period.
3.
Recommendations None t
F.
Engineering / Technical Support r
1.
Analysis Evaluation of this functional area was based on the results of Il routine inspections. 2 operator licensing examinations., 2 team inspections, and interactions between the licensee and the NRR staff.
Enforcement history was excellent; no violations were identified.
I Two significant events were attributed to this functional _ area. The more significant of these was the failure of two main steam isolation valves 3
(MSIVs) to close on demand due to design problems with the dual Automatic l
Switch Company (ASCO) solenoid valves. The second-event involved an original design configuration deficiency that resulted in the failure of the emergency control room ventilat' ion system to maintain independent " operable" trains
'during maintenance. Other events attributable to this area involved individual system challenges or failures due to original design. None of the above events were indicative of any current programmatic weaknesses.
Management effectiveness in ensuring quality was adequate. There was consistent evidence of planning and prior assessment of priorities. Procedures and policies for control of activities were well stated, controlled, and explicit.
Decision making was consistently at a level that ensured adequate management 10 3
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r review. Engineering evaltations were :echr.ically adequate, and records and plant performance ' data were cc::lete, well c.afntained, and available. Thorough investigations'into scram solen:id pilot valve failures, reactor. core isolation cooling check valve failure, anc Agastat relay failures vere performed with appropriate engineering management oversight. In some 1e: stances, the ongoing investigations resulted in maintaining the rea: tor shutdown or placing the reactor in a shutdown condition. Mana;emen: effectiveness in operator licensing i
examinations was good. This was decer.strated ay the quality of the pre exam review, the imposition of more -igorcus passir.g criteria by facility evaluators in the dynamic simulator portic of :ne examir.ation, and the minimal post-examination comments. The techni:al cuality of licensee submittals regarding station blackou:, em gency ciesei cenerator (EDG) fuel oil TS I
requirements, and the addition cf a centrol ream pull-to-lock feature for the Division 3 EDG were geod. kith respect tc the two feedvater nozzle weld crack indications identified du-ing the last refueling outage, the licensee's evaluation of crack growth was adequate to su:: ort plant operation for the duration of the o;erati g cycle.
Weaknesses were present in some engineerinc st: port activities. These events indicate a need for better engireerine assess ents in test planning.
In one l
case, the licensee attempted to cycle :ne reactor core isolation' cooling l
(RCIC) head-injection check valve duri g a plant startup which resulted in the valve failing to open because the hydraulic actuating system was not designed to open the valve at pressure. In an :her case, during local leak rate testing of the main steamlines, peor planning :revented the determination of the relative contributions of each flow path. The :icensee also failed to ensure that the -
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fire pump surveillance tests reflected current code requirements. Regarding modifications, there were many ntnor examples of inattention to design details and lack of followup to determi e if a:::ropriate procedural requirements had been evaluated.
It was noted tr.at mocifica icas were spread throughout many i
departments without any centralized gr:up beinc in control.
The approach to identifyir.g acc resolving technical issues from a safety standpoint was generally good. Of note were ne efforts to identify the root causes for surveillance test ancmalies. On two occasions, slow control rod i
scram time tests led the licensee to replace entire " lots" of scram solenoid
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pilot valves.
Investigation of the failed PCIC head injection check valve was in-depth, with all reasontale ca;ses being evaivated. When containment isolation valves failed to close as expec ed, the licensee's root-cause analysis was
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comprehensive and identified tha: Agastat relays used throughout the plant were not being maintained and had reacred the end of their service life.
Technical issues for safety-rela:ed systems we e thoroughly evaluated, with conservatism generally exhibitec.
Technical support to plan: opera ions Las geot. Examples included evaluation of safety relief valve ancmalies; evaluation of emergency diesel generator test i
failures; and evaluation cf system enhancements on the control room heating, ventilation, and air-conditionir.; system. Engineering support to the inservice testing program was consicered a strength based on the alternative examination methods discussed with NRR, some of which have been implemented by the licensee.
Although the Nuclear Engireerine Department generally provided accurate and timely responses to plant problens, a weakness was identified wherein lifted leads and jumpers were used to a:complish design changes instead of the formal i
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i engineering design _cnange request process. The overall results of the Electrical Distribution System Functional Inspection were positive. The only weakness not 1l attributable to initial design was the lack of a ' comprehensive Rectrical load I,
growth program.
Staffing was stable ta girovided prompt resolution of most technical issues.
Engineering positions and responsibilities were well defined. Generally, the plant has an experienced engineering staff. The system engineer concept was well irrplemented and generally effective.
System assignments considered both the complexity of the system and the level of experience of the individual.
System engineers had good technical knowledge and were accountable for monitoring system performance and specifying post-maintenance testing.
The training and qualification program was good. The licensed operator training programs were very effective as evidenced by the rate of individuals passing i
the NRC requalification and initial license exams. Operators were well prepared i
for the examinations. The licensee had developed a good training program for j
engineering personnel.
It was noted that only about half of the electrical engineers had completed their training.
i 2.
Performance Rating i
The licensee's performance is rated Category 2 with an improving trend in the
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area of engineering / technical support. The licensee's performance in this area was rated Category 2 in the previous assessment period.
l 3.
Recommendations None.
i G.
Safety Assessment /Ouality verification I.
Analysi s f
Evaluation of this functional area was based on the results of 14 routine inspections and 3 team inspections.
In addition, licensee requests for i
amendments, exemptions, or relief; responses to NRC generic communications; i
and other interactions with the NRC staff were considered.
i Enforcement history in this functional area declined. Two Severity Level IV violations were identified and problems in this functional area contributed to the Level III violation discussed in the' plant operations functional area. The first Level IV violation concerned a repeat example of a failure to report an f
event within required time limits. The second Level IV violation concerned
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inadequate corrective actions taken for repeated MSIV lo:al leak rate test failures.
l Management effectiveness in ensuring quality was mixed. On the positive side, the licensee routinely verified that adequate and effective actions were taken i
to address audit findings prior to closure. Of note were the performance-based 12 jj
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g audits that resulted in improved health physics controls, maintenance, and j
testing activities, during the second refueling outage. Audits in the areas of 3
security and emergency preparedness were thorough and generated good 2
recommendations for program improvements. Quality control (QC) activities were acceptable, and a' good working relationship between the QC and Maintenance Departments was observed. The licensee's quarterly self-assessment process for identifying areas needing management attention continued to be an effective tool. The trending of performance in the maintenance area was considered a strength, in addition ~ to the trend analysis of event reports and condition reports. Management supported extensive design changes to the control room ventilation and emergency recirculation systems to resolve a high number of system failures. On the negative side, management was not effective in preventing the significant programmatic weaknesses identified by the NRC E0P inspection. team. The deficiencies in the plant emergency instructions (PEIs) -
were not identified prior to issuance, due to inadequate confirmation of PEI development procedural adherence, inadequate actions in response to NUREG-1358, inappropriate resources dedicated to the program, and the failure to conduct an independent, comprehensive QA audit. These problems are indicative of a breakdown in management control and oversight of the E0P program, due in part to poor internal communications through the line organization and between departments.
The licensee's Nuclear Safety Review Committee (NSRC), the offsite review committee, continued to perform satisfactorily, providing a detailed level of review in areas of perceived plant weakness.
Except for the failure to ensure the PEI development process had been properly implemented, the Plant Onsite Review Committee (PORC) functioned effectively, maintaining a proper focus on safety as the primary concern. The effectiveness of the Independent Safety Engineering Group (ISEG) improved with the development of controls to ensure that ISEG recommendstions received adequate and timely responses.
Management has promoted improved communications with the NRC staff,_resulting in better quality and more timely licensing submittals. This is a significant improvement from the previous assessment period. The licensing staff met frequently with the NRC Project Manager to explain the technical issues related to potential TS changes well before their formal submittal. Proposed TS changes have focused on plant safety by clarifying confusing or ambiguous language and by proposing alternative actions to avoid unnecessary challenges to plant safety systems.
Responses to NRC bulletins and generic letters continued to be timely and thorough, particularly the detailed followup submittals concerning nonconforming materials.
The licensee's approach to resolving technical issues from a safety standpoint was mixed. On the positive side, safety assessments, and subsequent 10 CFR Part 21 notifications, regarding problems identified with the scram solenoid pilot valves and "E-system" snubbers demonstrated a sound approach to resolving technical issues. On the negative side, the absence of a program for periodic replacement of Agastat relays was considered a weakness.
Management oversight of the corrective action program was generally adequate.
Daily discussions of condition reports and radiological occurrence reports enabled. management to prioritize significant plant issues. The licensee's 13 j
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root-cause investigations _ were generally thorcugh and the evaluations of check i
valve failures,'MSIV stroke time failures, anc scram pilot valve failures received good management support. However, ccrrective actions to address i
repetitive ' leak rate test' failures of the MSIVs and the centrol rod drive hydraulic check valve were' inef fective.
Some improvement in the quality of 10 CFR 50.59 evaluations was noted, the evaluations were generally well documented anc demonstrated a scand technical rationale. However, previously identified preolems in the pericrmar.ce of 10 CTR 50.59 applicability checks persisted, cespite the implementatien of revised procedures and training to clarify the policy.
In ' general, the written quality of licensee event reports (LERs) was good and the level of detail was appropriate. However, the large numoer attributable to personnel errors, procedural, or programmatic problems is an indication that i
management communication did not achieve the p oper attitude toward quality at the working level.
Staffing levels in the area of QA were adequate to perform required audits, i
special audits, surveillance audits, and quali:y control functions. When necessary, quality functions were augmented with outside contractors or specialists. The training and qualifications of audit and inspection persennel were considered adequate for the assigned tasks.
In addition, tne ISEG, NSRC, and PORC were adequately staffed and the qualifications of membe s cf all three groups met or exceeded TS requirements.
2.
Performance Ratino The licensee's performance is rated Category 2 in the area of safety assessment / quality verification. The licensee's performance in this area was rated Category 2 in the previous assessment period.
3.
Recommendations None.
IV. SUPp0RTING DATA AND SUMMARIES 1
A.
Major Licensee Activities j
1.
On September 7, 1990, the unit was shut d:wn to comme ce its second
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refueling outage.
2'.
On January 4,1991, the unit completed its second ref eling cutage and the main generator was synchronized to the grid.
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3.
On April 1, 1991, the unit entered a forced outage due to a failed weld on a reactor recirculation vent and drain line. Repair of a RCIC
" testable" check valve required removal of the drywell head and extended the forced outage to 2 weeks.
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4.
On July 14, 1991, _..
1 the main. generator was removed from service due to a j'
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rapid. loss of main turbine electric-hydraulic centrol fluid.
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5.
On October 6,-1991, the unit was shut down for approximately 3 days to replace slow-acting co,ntrol rod scram solenoid pilot valves, i
B.
Major Insoection Activities The inspection reports discussed in th's SALP are listed below:
Unit 1, Docket No. 50-440 Inspection Reports No. 90012, 90018 through 90022, 91002 through 91008, and 91010 through 91022.
Unit 2, Docket No. 50-441 Inspection Report No. 91003.
1.
From September 17 to October 5,1990, a special maintenance team inspection was conducted to review the licensee's maintenance, engineering, support of maintenance, and related management activities.
(Inspection Report No. 440/90012) 2.
From April 29 to May 24, 1991, a special electrical distribution system functional inspection was conducted tc review the design and implementation of the plant electrical distribution system.
The Unit 2 extended construction delay program was inspec:ed concurrently.
(Inspection Reports No. 440/91005; c41/91003) 3.
From July 9 to 12,1991, a special safety inspection of the fitness-for-duty program was conducted. (Inspection Report No. 440/91011) 4.
From August 19 to 30, 1991, a special safety inspection was conducted to verify that the emergency operating procedures (EOPs) were i
technically correct and useable, and to determine that tha quality of the E0Ps could be controlled and maintained. (Inspection Report No. 440/91013) t 15 i
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